Document yk3jeQ4GY2pjVeqD0yGrVD4Vr

A09 887 Pebruary 13, 1987 HCTA 88-241 Hr. Milieu D. Stautavllle Envlroaaenttl SclMtltt Compliance Officer Xao<al Enforcement Section (3HH14) U.S. Environmental frotaction Agency - Region III 841 Chestnut Street Philadelphia, Pennsylvania 19107 Deer Hr. Steutevllle: Thl* letter will report on tlie Metlonel Institute for Occepetlonel Sefety eM Heelth (NIOSH) enrlreneental levestlgetlen of the Southeastern Pennsylvania Transit Authority (SEPTA) feclllty In Peoll. fennsylvenle, for eveleetlon of . airborne end surfece polycblorlnoted biphenyls (fC8) contaelnotion within the SEfTA cor shop nelntenence end repolr building. Htfr9d On Herch 14, 1988, M10SH received e Joint reddest from the Environmental frotectine Agency (ERA) end the Agency for Toxic Substances end D1 sense Registry (ATSOR) to provide tachnfcel esslstance In on levestlgetlen of the SEPTA roll yerd end surrounding comaunlty. Speclflcelly, the reouest to RIOSH wes for on eveluetlen of occupetlonel PC8 exposure enong SEPTA enployees et the Peoll yerd, end to provide raco--ndotlons for exposure reduction. The Peoll Roll Yerd Is e 23 ecra site owned by AMTRAK end previously operated by Coerell. Since January 1983. the site hes been loosed to end operated by SEfTA. The roll yerd Includes e switching eras, office end storage feci 11 ties, eeployed locker end lunchrooM, end e building where etectrlcol powered cnessitsr trains ire repelred end nlntslned. PCS contselnotion of the repelr building hes been known since et leost 1978. The contentnetlon Is essuned to be the resalt of the use of PCB-contalnlnc oils In the trensforsers of the letter rail cers. Owing the susaer of 1988, under on EPA stlpuletlen, e pertleT cloen up of the nelntenence end repelr building wes undertaken by SEfTA.(1) On Herch 28 end 27, 1988, e raglonel Industrlel hygienist end e nodical officer from RIOSH and an EPA representative node a pro11 winery visit to the Peoll Roll Yard. Although access to the feclllty wes denied on Herch 28 by SEPTA officials, a United 'silent* tow of the facility was granted on Herch 27. Based upon the observations of the Invest!goting officials, several prellnlnary recoanendatlons were aede Including the necessity of an envlronaental evaluation for determination of enployee PCS exposure.(2,3) HONS 019190 Pip 2 * Hr. Wllllaa 0. Steutevllle As i followup to too March 1956 visit, tliroo NIOSH Industrial hygienists vlsltod tko facility on Hoveuber 6 and 7, 19M. Entry to tP facility uos permitted by SEPTA with tlw following constraints: tbn NIOSH Investigators ware not pnrittod to colloct personal (breathing sons) air saaplos for POs. speak with SEPTA eaployees (for any reason), or colloct PCP*1p sanplas fro* prsonal Itnns of employees or within tlw rail cars (to datarnliw tlw potential for spread of PCP contentnation to off-slto locations). TP focus of tlw onvlrooswntal ovaluatlon was tlw nalntonanca and repair building and adjoining lunch, lockor, storap. and office areas. Tlw oalntonanco and repair building contains four service rail tracks tnwSiiinl Z-i) running Its entire length, accessed by bay doors at either end. Pits of apprenlnately throe feet In depth are located between the rails of the tracks which allow eeployee access to the anderslda of the self-powered electrical rail cars. Catwalks are located between the tracks to allow access to the taps of the rail cars. Tracks 2 and 3 are generally used for routine nalntenance activities, consisting of 45 and 90 day audited Inspections. Tracks 4 and 5 are reserved for 'Parlor* work Involving repair and/or reaoval and replacenent of undp canrlap Item. Two overpad crams are located above 4 and 5 tracks which are used to raise the cars for placemot u stenIs, tens allowing romval of Item Iron tP underside of the cars. Apprexlmtely 50 rail cars/week are serviced In tP car shop.(4) On either sIP and directly adjacut to tP repair and nalntenance operations area are facilities for welding, aachlalng of parts. Inspection of electrical cenpeaents. pttery cPrglag, locker storap areas, parts sterop and distribution, and maagemat offices. Within clou proxlnfty of tP sPp are teo lockor room (one large, two story locker roo* with shower and break areas, ud one snail lockor roon) and a lunch roo*. TP fact lily operates on three shifts, with approalaately 55 esployees m 1st shift (roughly 7a* to 3p*>, 35 eaployees on the 2nd shift, and 15 en the 3rd. TP prlaary Job categories were Ascribed aS mcPnlcs and electricians. Although som yard (outside) work Is necessary, tP aajorlty of tP mlntenmce and repair operations occur within the Plldlng. Oetolls cmearnlag job descriptions and day to day activities were unattainable during the evaluation. Methods TP NIOSH onvirtue*eta1 evaluation protocol ooployad at the SEPTA facility Included standard mthods normlly used by tP Nasard Evaluations and TecPIcal Assistance granch for dotenrlnation of Pth alrborm and surface Kl contanlnation. Environmental air saaplos were collected fro* 29 stationary positions within tP car shop and related offices, lunch roo*, and lockor room during tP Spa - Up* shift on Novenpr 5, and during tP Taa - 3p* HONS 019191 Page 3 Nr. Will 1 0. Steutavllle shift M Moveaber 7. The air luslii wars col lactad over the duration af tha shift using standard ISO atlllgraa dual-section florlsll tahas ceaaactad ta battery-operatad air sailing poops callbratad at 0.S - 1.0 llttrArtaatt. Surfaca saaplleg ai also conducted at various locations ulthln tha car shop, offices, lockar and lunch rooas. .Thasa <4 saoples uara collactad using 3*0* soxhlat axtractad pauze pads pre-wetted with 0 alllllltnrs of hasana and ulplng surfaces of 100 ea2 to 0.25 a2 both horizontally and vertically. Tha air toaples uara prepared for analysis by separating tha Initial and bach-up sections of tha florlsll tubas and desorbing each section in ana millllter (all of hoxano with soalcatlon for 0.5 hr. (as rlrawtnpiphH analysis was perfOraad on a Hewlett-Packard Modal 5730* gas chreaategraph equipped with an electron capture detector and accessories for capillary colean capabilities. A 30 aatar x 0.31 millaater fused silica WCOT capillary cel tan coated Internally with OS-5 was used with tasperature prograanleg froa 210 *C (held for mo alnates) to 310 *C at a rate of 0 C/n1nata. rive percent aethane In aryon was used as the carrier gas. Tha Injector was operated In tha splltless aade. The presence of an Areclor was dataralnad by cooperIson with standard saaples of Aroclors 1015, 1221. 1232, 1242, 1240. 1254, and 12M obtained froa the CPA. Quantitation was perforaed by sanrtng tha peak heights of tha flue aajor peeks of tha standards and congering those sum to tha sum of tha sane peaks In the saapla. The calculated Halt of detection (LOO) was 0.05 McrograM lug) fCS/sasole, while tha calcelated limt of quantitation (LOQ) was 0.17 ug PCO/sasple. The gauze surface saaples ware prepared for analysis by extraction in 40 nl of banana with shaking far 30 mantas. Tha hexane was transferred to a concentrator tuba and blown dawn with dry nitrogen. The gaaza was rinsed hilea with 10 al of hexane which was than added to tha original extract and brought to a final voluae of two al. Extreaely dirty saaples were brought ta a voIum of five nl with one al put Into a concentrator tube and used for the coapletloa ef preparation. Two drops of concentrated sulfuric acid were added to tha saapla nixed an a evapo-mx and allowed to settle for 30 nlnates. The solvent was then drawn off and rinsed through a nlcro-florlsil colwa with 9 al of hexane. Tha elwate was brought to a final voluae of 3al. A 1:10 dilution of each saapla was put In a ono-al crlap top SC-vlal with tha rust stored In a refrigerator la a 5-al aabor vial. Tha gas ckronetograpMc analysis was the seas as previously described for the air saaples. The calculated LOO was O.U ug PCO/saaple, while the calculated LOQ was 0.51 ug PCS/saaple. Evaluatlan Criteria As a guide to tha evaluation of tha hazards posed by work place exposures. MOON field staff eapley onvlroaaaatal evaluation criteria for asaessaaot of a nwaber ef clerical and physical agents. Thasa criteria are Intended to HONS 019191 Pag* * * Hr. Wllllaa 0. Steutevllle suggest levels of exposure to which aoit workers My bo exposed up to 10 hour* por ooy. 40 hows per wook for work1 up Hfetlw wlthoot experiencing oMtrso ho*1th effects. It Is. however, laportsnt to noto thst not all warkors will bo protoetoo froa adverse hoalth affacts If tholr exposures aro Mlotalood bolow- those levels. A wall percentage My experience adverse health effects becauM of Individual susceptibility, a pre-existing wdlcal condition, end/or a hypersensitivity (allergy). In addition, sow haxardeus substances My act In conblMtlon with other work place exposures, the general envlroewnt, or with asdicstlons or personal habits of the worker to product health effects ovm If the occupational exposures are controlled at the level wt by the evaluation criterion. These coafelnad effects are often not considered In the evaluation criteria. Also, sow substances are absorbed by direct contact with the skin and aucous aeabranes, and thus potentially IncreaM the overall exposure. Finally, evaluation criteria nay change owr the years as new InforMtlon w the toxic effects of an agent becow available. TM prlaary sources of envlronwntal evaluation criteria for the work place are: 1) MOSH Criteria Oocusents and roceuMndatlons. 2) the Aaerlwn Conferenw of Sovemaantal Industrial Hygienists' (ACCIN) Threshold Liasft Talws (TlT's). and 3) the tl.S. Departnant of labor (OSMA) occupational health standards. Oftan, the 111OSH recoawnda tlons and ACSM Tiv's are lower than tM corresponding OSHA stanwrds. loth NIOSH recowandatlons tad ACSIH Til's usually are baaed on aore recent InforMtlon than are the OSHA staaMrds. The OSHA standards also any be rewired to taka Into account the feasibility of controlling exposures In various Industries where the agents are used: the NIMH raiowanMd exposure Halts, by contrast, are based prlMrlly on concerns relating to the prevention of occupational disease. A tlM-welghtod average (TNA) exposure refers to the average airborne concentration of a substance during a norwl *- to 10-how workday. Sons substances have recoaaenMd short-tsra exposure Halts or celling values which are Intended to suppleaant the TVA where there are recognised toxic effects froa high short-tans exposures. HIOSH rsmassnili that airborne exposure to Kli in the wwk place be Halted to, or below, thd atnlaua reliable Mtectable concentration of 1 aferograa of KP per cubic Mter of air (ug/a*) (using the rocoanandsd sanpllng mfeeds) Mtonalnod as a TNA fer up to a 10-hr workday, 40-hr workweek. The HIOSH nil newnisi exposure Halt (RCL) was based upon the findings of adverse reproductive effects In oxperlaental anlMls, on the conclusion that KIs are carcinogenic In rats and alee and, therefore, potential hwan carcinogens in fee wwk place, and an the conclusion thst tauan and anlMl studies hove not denonstrated a level of exposure to KIs feat will not subject workers to possible liver injury.(I) TM Occupational Safety and Health Adalnl stration (OSHA) proaulgsted Its peraisslble exposure Halt (PEL) of 1 og/o3 for airborne chlorodlphenyl HONS 019193 Pag* $ * Mr. W1111**1 b. Steutevlll* products (PCbs) containing 42* chlorine and O.S ug/*3 for chlorodlphenyl products cootalolog 54* cMorlno dotorulnod as B-hr tine-weighted average CNA) concontratlons based on tlw IMS Threshold Limit Values (TLVs) of the African Conforonc* of Governmental Industrial Hygienists (ACCIH).(6.7) The TLVs. which have renal nod unchanged at 1 mg/m3 and 0.5 mg/in through IPS*, aro basea on tho prevention of liver Injury In exposed workers. The ACGIM Short Ter* Exposure Unit* (STEU for airborne chlorodlphenyls are 2 wf/o3 and 1 eg/n3 for 42* and 54* chlorine products, respectively. The OSH* PEL and tho ACGIH TLV and STEL valuos Include a `Skin* notation which refers to the potential contribution to overall exposure by the cutaneous route. Including tha uucous eosferanes and eyes, by either airborne or direct skin contact with PCS*. Thor* are no standard evaluation criteria (REls. PELs, or TLVs) for Industrial surfaces contaminated with PCBs. In July of 19*5, an advisory penal was convened to provide puldel In* reenuuendatlons for air and surface clean 19 for PCBs. dioxins, and furans for the State Highway Department Building In Santa Fo, How Mexico. Both HIOSH and the Environmental Protection Agency war* roproaoutod on this panel. These guidelines Included specifications for PC* concontratlons not to exceed SO ug/m2 on *vork1ng* surfaces.(B) Exnuples of working surfaces Included `high contact* Items such as desk tups and chairs. Although application' of these guidelines to the Industrial environment is difficult, recent recoumendatlons by BIOSH for surface clean up of PCBs In an aircraft aetatanance facility proposed 250 ua/m2 for low contact surfaces, and 100 ug/m2 for actual aircraft parts, or `high contact* ltsne.19) In * January 1M7, tho EPA proposed a standard of 100 ug/sK for high us* arose, which was defined as `an area In which people can oak* frequent and regular skin contact with surfaces present In the area.*(10) hesuits Table I presents results of the NIOSH environmental air saspies by location and duration In eg PCB/OH of air. The Initial entry for a specific location presents results of samples collected during the iftemoon/evening shift on Hovoeher 5, with the second entry presenting results of saeples collected during the uornlng/aftomoon shift on Hoveuber 7. 19*4. tesults appearing in parentheses represent 'trace* concontratlons which wore detected upon analysis, yet of an Insufficient amount to uaet prescribed limits for accurate quantitation (l.e. tho results were between 0.05 ug/sanpl* LOO and 0.17 eg/saeple LOO). Airborne PCBs wore detected at all sanplod locations on at loast one of the too days of sailing. Twenty-seven of 45 saeples collected within tha car shop area wore reported below the LOO (less than 0.17 ug/taeplo), with one reported as non-d*tectable (less than 0.05 ug/sauple). Airborne PCB concentrations of IB saeples reported above the LOQ within the car shep ranged HONS 019194 Pag* a * Nr. Hi 11 Ian 0. Stoutevllle Iron 0.3a to 0.72 ug/n3, averaging 0.S0 ug/n3. Airborne concentrations above the 10Q wort alto raportad within tha general forenan's office (0.41 aad u.4< ug/n*), tlw supply roan (0.44 and 0.43 ug/o2), end tlw uppar Itvtl af tiw larga leckar rooa 10.45 ug/n*). Airborne PCS concantratlons within tha lunch rooa. saall lockor rooa. and tha lowar level of tha larga lockar rooa woro uelow tlw analytical loval of quantitation (Table I). Forty-one turfaca wlpa saaplas wara collected within tha car shop araa. Eight of thasa saaplas wara obtained froa tlw bottoas of tha four nalntenance pits, with PCS surfaca concentrations ranging froa 17.000 to 330,000 nlcrogroan par squaro aatar (ug/n2), avaraglng 90,000. Eight saaplas wara also collactad froa tho pit walla, with PCI concantratlons ranging froa 392 to 2,400 wg/n2, avaraglng 1,204. PCI surfaca cantool nation raportad froa eight saaplas of floors and alsla ways within tho shop ranged froa 2,410 eg/n2 (on a racantly painted surface), to 490,000 ug/a2 on tha alsla way at tha aast and of tha Klleaga Hao* work araa. The realising 17 saaplas collected within the shop araa also Indicate excessive and widespread PCI surface contasrlnation, with concentrations ranging froa 21 to 31,000 ug/n2, averaging S.500. Six surfaca saaplas collacted froa the floors or stair steps In tha larga and sail lockar rooas. lunch rooa. supply rooa, and forenan's offlea, ranged froa 1,200 to <0,000 ug/a2, averaging 20,000 (Table 11). - Discussion . As pressntod In Table 1. at the tine of stapling tha airborne PCI concantratlons within tho repair facility ware below the N10SN kEL of 1 ug/n3. la general, duo to the low vapor pressure/hlgh aolecwlar weight of tha PCI aolacules, vaporization at artiest tauperaturns Is quite low. However, PCS nolecoles will bind with particulates which nay aerosolito and thus present an alroorno exposure situation. During tha two days of nsnltorlng at tha SEPTA facility by HIOSH, surfaces outside tha aalntenence building wara wet froa recant rains, which nay have nods a significant contribution to tho relatively lew airborne PCI concantratlons within tha building. Tho potential for significant airborne PCI ladan particulates was ansostrated by haaples collected near tha parking area by an EPA consultant where PCI soil cantaolnation ranges froa 142 to 3000 ppu.(11) Hear the entrance gats to tho perking area, an airborne concentration of 1 ng/n* was recorded.(12) Surfaca PCI saaplas collactad within the nalntenance facility Indicate excessive and widespread contaalnation, latad upon previous onulroanantal nsnltorlng, questionnaire data and subsequent recoonendatloas by a SEPTA consultant, a pragma of Otcoatanlnation of tha Interior surfaces of tha access pits was undertahon during tha tuaaer of 19M.(13) Tha questloaoelre data froa the enployees Indicated that nest workers spend tha tajorlty of their tine at locations described as Inside tha pits or alongside tha aisles, and therefore the clean up effort was directed at these locations. HONS 019195 Page 7 - Mr. Million 0. SteutevUle Prior to the clean up offort, surfict concontratlons reported by tut SEPTA consulttnt within tbt pits ranged froa 1SS.OOO to l.OOd.OOO ug PCI/a2. Surface concentrations aeasured by NIOSH following the dacontaalnatlon effort ranged froa 17,000 to 330,000 ug PCb/a2. Although lowered, these concentrations still present an unnecessary exposure situation and grossly In excess of the 100 ug/n2 proposed standard for working surfaces. The present contaalnatlen of the pit surfaces nay either be due to recontaalnation froa non-cleaned areas, or seepage of PCB-ladened oils through the resurfacing aeterlals. Surface uaples collected froa floors throughout the facility consistently showed high levels of contasrlnation. A probable contributing factor is the high concentrations of PChs In soils surrounding tlw aalntanance building which are constantly tracked Into and throughout the structure. High levels of PCS contaalnatlen on floors was not Halted to the repair and aelnteaance area. Seaales collected froa the floors In the lunch rooo, large locker rooa and snail locker rooa wore reported at 32000, 60000, and 1200 og PC*fa*, respectively. This sane pattern was deaonstrated froa floor saaalet obtained In the foreoan's office and supply rooa, reported at 20400 and 5200 ug PCI/u2. respectively (unfortunately, the NIOSH Investigators were unable to oeasarc PCB contaalnatlen on eapleyoe's shoes). This situation causes concern not only for occupational exposure to the wortaen, but also for Migration of PIS contaalnatlen-to off-site locations. Including autonomies and hones Of workers, and to the rail cars. decent nonltorlng by EPA has oanenstratad surface contaalnatlen on the floors of rail cars Mrvlced at the Paoll site as high as 1400 ug/n2.(14) This finding Is not surprising In light of the aagnltude of PCI contaadnatlou within the facility. During the NIOSH site visit we observed anlntenance eaployeos using rail cars as thoroughfares within the shop when the car's position blocked side to side access. This practice undoubtedly caused PCI-laden aaterlals to be tracked onto the floors of the cars. In addition, the nelntBMnce custodians responsible for routine cleaning of the rail cars are also responsible for cloanlng the pits (current pit cleaning schedule H each p1t/nonth).(3) If any tools or apparel of the nalntenance custodians tre cannon to both sites, contasrlnation of the rail cars probably results. Also, any activities ta the yard area requiring entrance Into the cars would also result In contaalnatlen of their floors, based upon the level of contaelnation of the yard soil.(10) This contanlnation of the rail cars presents an unnecessary exposure situation to the operators of the cars and off-site nalntsntnco custodians responsible for dally cleanings. In addition to the general public. A nunhor of high contact Itens were uapled for surface coeumnation within the ealntonaaca and repair areas. Including such Itens as air hoses, hendles to various tools, and crane controls, to represent surfaces which would nornally be handled for long periods of tine, usually with bare hands. HONS 019196 Pagd 8 - Nr. William 0. Stoutavin* Results ranged from 21 to 9800 ug PCI/n2. The car shop amploycos ire required to own their nail tools.(4) Although we were not permitted to sample the surfaces of personal Items, the consistent level of high contamination found on SEPTA-owned tools Indicates that the employee's tools are likewise contaminated. No Information could be obtained regarding storage ot personal tools or frequency of transport of these Items to the residence. Although results of high contact surface samples obtained In the lunch and locker rooms were substantially lower than those from the maintenance and repair area, a number of surfaces did show significant contamination. For example, PCI surface contamination on a window ledge directly above a utensil storage area was measured at CM uo/n2. Contamination on benches In the locker rooms ranged from 2M to 760 ug/m2. As previously described, floor contamination In these areas was extremely high (1,200 - 60,000 ug/a2). It should be noted that there is an inherent variation Involved with the collection procedures for surface samples. Differences In collection techniques between Investigators and types of sampled surfaces Introduce this variation, however, the variation Is negative In nature (1e. not all of the surface PCI contamination Is collected on the wipe sample!. As can be teen from the data presented In Table 2. results of most stapled Items, particularly floors. Indicate extremely high levels of contamination. - Conclusions and Huconmondatlons . The data contained In Table 1 Indicate airborne concentrations of PCIs within the aalntenaece facility at levels below the NIOSH UL during the tine of the evaluation. However, these date do not reprosont employee expesures, but rather airborne concentrations at stationary locations (samples from the breathing zone of amployeos were unattainable). Although a contribution to airborne PCI concentrations within the facility would be expected from airborne PCI-laden particulates, the extant of such an Increase Is only speculative without appropriate monitoring (1e. personal sampling during dry weather conditions). The environmental surface sampling data collected during the IIOSH survey Indicate extensive PCI contamination within the car shop. This finding Is In general agreanaot with the Nay 1-9. 19M evaluation conducted by a SEPTA consultant. (12) These levels of contamination are the highest encountered by MUSH during a health hazard evaluation. In addition to hand hold, high contact Items with surface contamination as high as 31,000 ug/m*. all areas- tasted showed high levels of contamination on the floors. This aspect Is important net only with regard to an occupational exposure, but has Implications for potential tracking of PCI contamination to off-site locations. Data obtained by EPA consultants also Indicate a high level of contamination In the soils surrounding the maintenance building. This HONS 019197 i'age V Hr. Will 1m D. Steutevllle situation Dos probably made a significant contribution to PCS contamination within tho building. Contanlnation of tho pit floors remains as high as 330,000 ug/m*. It Is uneortaln whothor tho currant contaarination within tno pits Is a rosult of ineffective dacon tanl nation and resurfacing techniques or a result of recontanl nation. The following recoeamndatlous are based upon the environmental data collected during the NlOSM evaluation, environmental data obtained by EPA and SEPTA consultants. Information Attained from a deposition of a SEPTA nanagenent enployee. and our visual observations of the facility and work practices of the SEPTA enployeos. 1. The only acceptable long-tern solution for reduction of PCS exposures experienced by SEPTA enployeos Is decontamination of the facility, including the aalntananca and repair building and associated structures, plus the surrounding soil accessible by the workers. a. Previous dacontaarination efforts within the pits were shown to be Ineffective. To snot the proposed EPA standard for PCS surface contamination of 100 ug/m2, It nay be necessary to conduct 'pilot* studies of the various surfaces-and Items within- the facility ts demonstrate effective clean up/decoetaarlnation techniques, including a post-decontamination sampling protocol to ensure effectiveness. b. Stringent controls should bo laplononted to protact against recontaarlnation of cleaned areas during the clean up effort, particularly through tracking of PCI contaminated materials and migration of PCI-laden particulates. 2. As an interim measure, employees should be made aware of and strictly adhere to the recommendations contained In the NlOSM interim letter/reports of April I and Nay S, ISM. (1.2) 3. To pravant off-site contamlnatlea of worker's automobiles and homes, disposable Tyvek shoe covers should bo used and discarded when traversing the area beMoan the parking lot and the locker room. Me emphasise that separata work sheet and street sheas be used. Also, tools or other items used ea-slte should remain on-site. a. hall cars thornId be cleaned with a non-ionic detergent, and a representative number of cars should be sampled to demonstrate surface contamination below the proposed EPA criteria. HONS 019198 Page 10 * Nr. HI 11laa 0. Steutevllle a. Only necessary personnel should b allowed Instdo tho cars while In tha yard or ropalr facility. b. Disposable shoo covers should bo used upon entering the cars. c. Tools uaod for routine cleaning of the cars (1e. DrooM and oops) should not be used on any other surfaces within the facility, and oust be stored In a non-contentnsted area. Conflicting Intonation was obtained on the extent of tho transforner oil retrofit! progran. (3,10) If the retroflll prograai has bean coexisted and tha levels of PCI contaarination of tha transforner oils neat prescribed criteria, the fallowing rocoaaendatlon nay not ba appropriate. A. Since any euployae any becone Involved In tha initial clean up of a PCI spill (3), all sheold undergo approprlata training for proper uae of personal protective equlpuent and clean up techniques. If yon have any questions concerning tho Infornatlon contained In this loner, or If yaw would Ilka additional Infornatlon, foal free to contact no at FT3 M4-4374. Sincerely yours. Enclosure t cc: Hr. Walters. ETA Mr. Norteuses. ATSM bee: 0. Tharr R. Hartle H. Ruch HETA id-141 Richard H. Hartle, C.I.N. Supervisory Industrial Hygienist Industrial Hygiene Section Hazard Evaluations and Technical Assistance Hranch Division of Surveillance, Hazard Evaluations and Field Studies HONS 019199 REFERENCES 1. Letter (end attachaent) fro* Ralph H. Siskind, Esquire. to The Honorable Frank M. Venderheyden. Office of Administrative lew Judges, U.S. Environmental Protection Agency (Region til). Decesber 23, igg$ 2. Intarln letter/report fron P.R. Kerndt end F. Lewis, NIOSH, METAI, to t.K. Mortensan, ATSOR. April 9, 1906. 3. Letter fro* P.R. Kerndt and F. Lewis. NIOSH, HETAI, to B.K. Hortensen. ATSOR. Hey S, 1986. 4. u$A v. SEPTA; deposition of Richard J. Hanratty. Jr., Decaaber 9. 19M. i. National Institute for Occupational Safely and Health. Criteria for a rern--nded standard: occupational exposure to polychlorinated biphenyls. Cincinnati, Ohio: National Institute for Occupational Safety and Health. 1977. (INCH publication no. (NIOSH) 77-22S). 6. Occupational Safely and Health A<tela1itrat1on. OSHA safety and health standards. 29 CFR 1910.1000. Occupational Safety and Health Administration, revised 1900. 7. Anarlcan Conference of Covenaental Industrial Hygienists. Threshold Unit values far chaarical substances and physical agents In the wertroen environment and biological exposure Indices with Intended changes for . 1909-00. Cincinnati, Ohio: AC6IN, 1909. b. Kealnsky, J.R. and Hellas, J.H. Final certification report: New Nested Stott Highway Departnent's fienoral Office lulldlng and Annex, 1120 tom lies Rood. Santa Fe, How Hexlco. HETA Report no. 16-414. Rational Institute for Occupational Safely and Health, Cincinnati, OMo, Septender 1900. 9. Depertaent of the Navy. "Hlnutes of expert advisory panel neetlne regarding content nation caused by the PCS transformer fire In building V-90, Naval Air Rework Facility, Norfolk,* Hens fro* J.H. Aldrich, Contending Officer, Naval Air Rework Facility, Norfolk, VA, dated July 7, 1909. 10. Heanrandu* to Vickie Province, Deputy OSC, U.S. EPA, Region III fro* Peter Harnett. TAT, Region III. January 5, 1907. 11. Letter to J. Oalabrldgo fro* S. Hasserswg, and attectannts. Including Nsusrondun to Robert Caron and Vickie Province, OSC's CPA, Region III fro* Andre P. Zewnlr, Eartroaaental Engineer, Environmental Response trench, U.S. EPA Raglan III., Decanter 10, 1909. 12. Sanple Hemoraadum at Pa*11 Rallyard fro* Sella H. turchetta, EERU to Philip R. Caapegna, CRT Task HoeItor. HONS 019200 13. Oraft Project (Uport SEP-88-1. "Evaluation of PCS conctntratlons in aurfaca. air and uatnr tanplti at SEPTA Paoll Rallyard, Paoll. PA.* Fro* 8.8. Jurlnikl and P. 8aaly. NuClmCo, Ine., to R. Faay. SEPTA and C.S. Uynkoop. Blank. Rom. Coariskay i NcCaulay, SdptoMor 1. 1M8. H. Lattor to J. BainOrldga. HETA8, OSHCFS, NIOSH, froa B. Sarltfi, HNC8, U.S. EPA Radon III. January 8. 1987. HONS 019201 TA4L2 I aii sanpu sssuus ro> rcs SEPTA FAOLI, PtaSIXLVAlflA HRA 24-241 Oevaafesr 4-7, INI annua tim(aiit/an*)tln 1.3. #3 pit. 1/4 Alstsass frsa 4. cod 34. #3 pit, 1/4 Alstsass frsa sad 1420-2224 0714-1313 3. #3 pit. aldaap 37. #3 pit. aldaap 1423-2223 0714-1313 4. #3 sisla, midway 44. #3 sisla. aldaap 1423-2224 0713-1311 . 43 pit. 1/A dlstsaca frsa V. aad 73. #3 pit. 1/4 dlstsaca frsa N. sad 1427-2223 0721-1340 4. lasklas skap, aaar alsla far 43 pit 33. Baskias akop, aaar alsla far 43 pit 1424-2224 0721-1312 4. #4 pit. 1/4 dlataasa frsa W. aad 74. #4 pit. 1/4 dlataasa frsa V. sat 1430-2213 0722-1304 2. katassa 44-3 trasks. 1/3 dlataasa to H. aad 1432-2220 44. >4>WW 44-3 trasks. 1/3 dlataasa to V. aad 0723-1307 1. 44 pit. aldaap 74. 44 pit. aldaap ' 1433-2217 0724-1303 7. kltWtSB 44-3 trasks. 1/3 dlataasa to 4. aad 1434-2213 32. kilnssa 44-3 trasks. 1/3 dlataasa to 4. aad 0720-1300 to 1.14. 44 pit. 1/4 Alstsass to 4. aad 42. 44 pit. 1/4 dirtmss aad 1433-2217 0720-1300 14. kataasa 43-4 tracks. 1/3 dlataasa to 4. aad 1430-2210 74. kataasa 43-4 trasks. 1/3 dlataasa to B. aad 0727-1430 1*. #3pit, 1/3 Uatam to I. aad 73. #3 fit, 1/3 Alataais to I. aad 1440-2214 0723-1431 24. tttww #3-4 tracks, 1/4 dlstansa ts H. aad 1441-2221 74. Wtwn #3-4 tracks, 1/4 Alstsass to U. sa4 0730-1431 U. #3|tt, 1/4 ilatanss ts H. sad S3. #3#lt. 1/4 Alstsass ts U. sad (esat.) 1443-2214 0731-1432 (0.30)* (0.40) (0.23) 40a* (0.24) (0.31) . (0.23) (0.23) ; (0.27) (0.27) (0.34) (0.13) (0.22) (0.22) (0.23) (0.47) (0.37) (0.30) 0.30 (0.40) 0.42 0.47 (0.30) 0.72 0.44 0.31 0.44 0.44 HONS 019202 TABU I (eont.) lo. Location BanUWI Concentration (ug/e3) II. #2 pit, 1/4 dlatanco to W. 44. #2 pit, 1/4 dlatanco to W. 17. #2 pit, 1/4 dlatanco to I t>. #2 pit, 1/4 dlatanco to I Id. manta area at lockara 17. moat* area at lockara 1443-1743 0711-1454 1447-2214 0734-1435 1440--2214 0731-1433 (O.SS) 0.41 <0.17) 0.40 <0.27) 0.41 14. Illaage area. 1/4 dlatanco to W. and 71. Rlloage araa. 1/4 dlatanco to M. and 1430-2214 0731-1434 (0.23) 0.33 U. kllaage (ant foranan'a office IS. Ulaata gae foranan'a offlco 11. 1. eatwelk, 1/3 dlatanco to W. 0. B. catwalk, 1/3 dlatanco to W. 27. t. catwalk, 1/3 dlatanco to I 70. 0. oatwelk, 1/3 dlatanco to I 1435-2203 0730-1431 1431-2207 0740-1300 1431-2200 0741-1450 (0.13) (0.23) (0.30) 0.41 - 0.33 (0.57) 20. catwalk Between #2-3 tracka, 1/3 to H. and 1302-2200 77. catwalk kotwoan #2-3 tracka, 1/3 to U. and 0741-U02 0.30 0.47 20. cctcnlk kotwoan #2-3 tracka, 1/3 to I. and 1303-2200 SB. catwalk botwaan #2-3 trocka, 1/3 to I. end 0743-1303 0.47 o.4t 21. aupply roan wataido dark'a offlco 11. ewpplp roan outeldc dark*a office 1300-2231 0751-1314 0.40 0.43 21. ganerel foranan'a offlco 00. general foranan'a offlaa .22 31. 1300-2231 0732-1313 1330-2230 0733-1303 0.43 0.41 (0.30) (0.21) 23 Ll lector 73 1 looker 1331-2230 0733-1331 (0.22 (0.13) 30. ltwc level of largo lacker roan 31. lower lord of largo looker roan 1332-2030 0731-1337 (0.43) (O.M) 23. wooer level of largo lacker roan S3, wopor load of largo locker roan 1337-2223 0737-1511 (0.20) 0.43 Taiwan In porontkaooa repraaent 'trace- ceneantratlena wklck era of on laawffldont enaent to neat proocrlbod llnlta for accurate fuantltatleo (l.a. a*orniii: pla 100). HONS 019203 TABU IX lUVACf SAMPU USULTS FOR PCSa mu PAOLI, PRRnXLVASIA KCTA 14-241 lOTMtar 4-7, 1HI lb. Laotian (surface type) H M tokl* fra* Sautk eeB (foniea) B-2 tshla at South aaB (foniea) W-3 M tabls froa South aui (foniea) B-4 4th tabU froa South auA (foniea) *4 floor aaor Boor (polatod eouaut) W-4 Boor; both oiBoo plus haufloo (poiatod aotal) W-7 pop tolophoao; ootlro outor ourfaco (plaatie) V4 vinBow ledfe above utoooii rtonso (painted ei it) 40 40 34 32 32.000 4 IS** 434 W-U haoia of circular slab (aoawlowsrato eaaaat) mil floor holou tUo cot lean) char (poroua painted eaaoat) W-12 Boors hath oiBao iaelaOiac hantlao (paiatad wood) 740 10S 1200 44 W-13 floor la aocth-eeatral aroa (poroua paiatad eaaaat) 1520 W-14 iaahara - Boors aa t'a 233 A 233 (oaooth pslataB oatal) 23 W-13 haaB rail of stairs ta upper laool (auooth paintaB aotal) 314 W-14 atair stop to uppar local (aorrusatoB aatal) 40.000 (Coat.) HONS 019204 TABU II (eoat.) iBj. Lacstlae (surface type) Lettr *-17 lunch table In upper lav*; (formica) W-ll bench hatunen lackara (porous wood) CBBtiQtriUw (u*/*) 2M W-19 Porauan's Beak tap (fecalea) ii] W-20 aar to office; hath sidas 1naiadlap handles (painted used) <32 *-11 flsar between deer and dash (tile; slightly parous) M.400 W-U (lsar near antrsaia dear (smooth painted eawant) *-23 elark'a dank (plastic blatter) 9.300 100 W-2S ps pit a. sail; 30* fraa east end (painted eaaant) W-29 PS pit floor; 30* fraa oast and (porous eaaent) W-M PS pit S. sail; midway (painted eaaent) W-31 PS pit near; midway (parous eaaent) V-32 PC pit I. unlit <9* fraa east and (painted eaaent) W-33 P* pit flsar; 39* frea oast sad (parous eaaent) *34 P4 pit I. wall; 100* fraa west and (pointed eaaent) W-33 pa pit floor; 90* (tea oust and (parous eaaaat) W-M #3 pit floor; 79* fraa waet aad (parous eaaaut) W-37 93 pit 9. sell; M* fraa want aad (painted eaaaat) W-M PS pit S. well; *0* fraa oast and (painted cannot) (Cant.) 39<oo 07.000 720 20.000 1.000 df.OOO too 17.000 3M.000 1.S40 2,400 HONS 019205 TAILS IX (eont.) Ikt lacatlm (write* tpp*> -J* 13 fit fleer; 40' free eaet an4 (?eroua canent) 21,000 (MO 82 pit I. mil; 23* from eaet tod (painted tenant) 1,120 (Ml #1 pit fleer; 30' Iran eaet and (permit eaanat) ft.000 (M2 #2 pit I. mil; OS' fren mat and (painted eaaent) 1,200 (M3 *2 pit fleer; 100' fren mat end (pormi* tenant) 70,000 (MO 8. aitle at #5 track, exit to lunch ra (recently paiatad) 4,000 (4-50 8. aitla at #5 track, enit t* lunch ta (peraua tenant) 240,000 (4-51 Tread kraak arm mrk haneh (palntad natal) to 14-32 ra-wlpa f (4-31 134 (4-33 Cab eional roan met beach (unflatched mad) 340 M-34 Machine chef fleer (paiatad concrete) 4,880 (MS eiaa handle in aaahina alaep (mtal) 21* (1-34 8. aitla at track *3 aaar mid atop (reeantlp painted) 2,400 (M7 8. aiale at trank #3 aaar mid atop (permit tenant) 74,000 (4-30 letter 8. dale, 84 track, 30' to v. and (pacern tenant) 70,000 (4-30 tram entrl hatmm #4 and 3 track* (paiatad natal) 287 (4-40 fleer hatmm trethe 83-4 (need tamr ta aceeea pit) 110,000 (Ml jack handle (natal) hatmm 83-4 tracka 1,473 (M2 min dear to atop, both aide* plea handle* (painted mod) 24 (M3 mrk heath at 8. and of MHaapa 11m (paiatad natal) 1.240 044 fleer at 8. and ef Ulema line (parent tentreto) 4*0,00* (1-43 eaapraaead air tom at Ulem* U> (rubber) (Cent.) 0,040 HONS 0l926 tMU II (east.) m * (MrfM* tn) *-* MlBiMr lrf|< at (Mitral Ulaaaa 11m (yalatad mmU) M.OM U-af^ahalf af tattary Mama araa (vaa4) u.OOO W-M alaatria Uw-fark ><! la BUaaca araa (aatal) A. ol IMI 4aak U llaata araa (|1m tlattar) iif H-70 HmV la Ntlaaga araa (aaaaaita) ;\o X7 aa U-71 hiljft atalra U aataalfc is I.H. aaraar (yalata* Mtal) W V-71 flaar at latsalli la M. aaaaar (yaraua km4> ll.oot IMS MW.wt feaaa taUUas aataalt la a.H. aaraar (maty aatal) ma?t .SFarafcitia>n aaataaaatt aMlillwl aartaaa at aaaslaS If. witilaala an myrarlaatr 72t HONS 019207