Attachment 25 Air Monitoring Plan.pdf

CDP COBRATF Training Operations and Support Services

Attachment 25

Air Monitoring Plan

FOR OFFICIAL USE ONLY

May 20, 2019

UNCONTROLLED

COBRATF Air Monitoring Plan UNCONTROLLED

Revision 11

Effective Date: May 20, 2019

FOR OFFICIAL USE ONLY 2

Table of Contents

Section Subject Page

1.0 Introduction

2.0 References

3.0 Acronyms, Abbreviations, and Definitions

4.0 Description of the COBRA Training Facility

5.0 Activities Involving the Use of GB and VX

6.0 Airborne Exposure Limits for GB and VX

7.0 Purpose of Air Monitoring

8.0 Air Monitoring Program

8.1 Responsibilities

8.2 MINICAMS Air Monitoring Section and Equipment

8.3 Chemical Laboratory and Equipment

9.0 Sampling Locations for Automated Air Sampling

9.1 Potential Chemical Agent Migration Points

9.2 MINICAMS Sampling Locations

9.3 Purpose of Sampling Locations

10.0 Minimum Monitoring Requirements

11.0 Response to Alarms

11.1 Response to Alarms During Normal Working Hours

11.2 Response to Alarms After Hours, Weekends and Holidays

11.3 Alarm Reports

12.0 Verification of 3X Decontamination

13.0 Quality Control System for Air Monitoring

14.0 Backup Power

15.0 Response to Equipment Failures after Hours, Weekends, and Holidays

Figure 1 Training Building Floor Plan

Figure 2 Sample Points in the Charcoal Filtration System

Table 1 Sampling Points During Toxic Agent Training Operations

Table 2 Alarm Response Summation

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1.0 Introduction

The U.S. Department of Homeland Security’s CDP operates the COBRATF in Anniston, Alabama. The CDP’s aim is to provide realistic and challenging training in a chemical environment, enhancing the proficiency and confidence of first responders. Training is conducted using the nerve agents GB and VX.

Air monitoring is conducted by the air monitoring section (MINICAMS) and the chemical agent laboratory (DAAMS & confirmation testing) staff.

2.0 References

COBRATF Toxic Agent Exposure Control Plan

Chemical Agent Standard Analytical Reference Material Quality Assurance Plan for

Chemical Agent Air Monitoring

3.0 Acronyms, Abbreviations, and Definitions

Definitions:

3X A process by which a toxic agent contaminated item is monitored and treated to ensure the decontamination item does not off gas toxic agent at conenctrations greater then the STEL.

AgF Silver fluoride

Alarm MINICAMS sound an alarm when the concentration of GB or VX exceeds the alarm set point established for the area.

Calibration A process through which the MINICAMS response is determined for a known amount of analyte.

Cold Area Refers to an area of the facility where chemical agents are not normally expected to be present in the air; for example, the lobby of the training building is a “cold area”.

Concentration The quantities of toxic agent present in a measured volume of air or solution; for example, 0.0001 mg/m3 or 0.1 ng/L equal to 1.00 STEL of GB in air.

Engineering Systems used to contain or trap agent vapors; for example, the charcoal

Controls filtration system and the negative-pressure system within the training building are engineering controls.

G-analog The detectable component that airborne VX is converted into by passing the air stream through a AgF conversion filter.

Inside Areas in the training building from which all of the air exhausts to the

Engineering environment through the charcoal filtration system; for example, all of the

Controls training bays are “inside engineering controls.”

mg/m3 Milligrams per cubic meter; a unit of concentration of a substance in air.

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Midbed Refers to a sampling location between the two charcoal filters arranged in series in each charcoal filter bank. Each bank is sampled by MINICAMS at its midbed to detect agent breakthrough from the first bed long before agent breakthrough of the downstream bed can occur. This provides an early warning of the possible failure of a given filter bank before the release of chemical agent into the environment can occur.

Neat Toxic Agent Liquid chemical agents not mixed or diluted with other substances.

ng Nanogram; a unit of mass equal to one billionth of a gram.

Outside Areas in the training building that do not exhaust to the environment

Engineering through the charcoal filtration system; for example, the cold corridor is

Controls outside engineering.

QP Challenges A measured volume of dilute chemical agent used to test the operation of

MINICAMS or to test the effectiveness of DAAMS sampling and analytical methods. These challenges are made by injecting a measured volume of a dilute agent solution containing GB and VX into the MINICAMS inlet or onto a DAAMS tube.

Sorbent Tubes Glass or metal tubes containing a sorbent bed (usually a porous polymer) capable of trapping agent from an air stream pulled through the tube.

Toxic Agent Refers to an area in which liquid agent GB or VX, or vapors of these agents, Training Area may be present as a result of toxic agent training operations. For example, training bay 2 is a toxic agent training area. Such areas may be declared 3X decontaminated only after being monitored to demonstrate that GB and VX vapor concentrations are less than 75 percent STEL method levels.

Toxic Agent Refers to activities that involve the use or handling of neat agent GB or VX.

Operations

Type 1 Method A fully quantitative analytical method that yields a numerical estimate of the analyte concentration within a working range.

Type 2 Method A method that is used to indicate whether an analyte is present at or above a specific concentration.

Acronyms:

AD Assistant Director

AELs Airborne Exposure Limits; Center for Disease Control and Prevention

(CDC) allowable concentrations in the air for workplace and general population exposure.

APF Assigned Protection Factor. The APF is the workplace level of respiratory protection that a respirator or class of respirators is expected to provide to employees when the employer implements a continuing, effective respiratory protection program as specified by this section. For a FFAPR

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the OSHA APF is fifty (50). APFs for other types of respirators are listed in

29 CFR 1910.134.

APR Air Purifying Respirator

CAM Chemical Agent Manager

CASARM Chemical Agent Standard Analytical Reference Materials; standards with a known concentration of chemical agent that has been accurately determined and given a certificate of analysis.

CASARM QAT CASARM Quality Assurance Team, Aberdeen Proving Ground, Maryland;

certifies the Air Monitoring Program.

CDC Centers for Disease Control

CDP Center for Domestic Preparedness

COBRATF Chemical, Ordnance, Biological, Radiological Training Facility

DAAMS Depot Area Air Monitoring System; a manual sampling and analytical technique in which toxic agents are collected in a sorbent-packed tube for later analysis for the presence or absence of toxic agent using a chemical agent laboratory gas chromatograph.

ECBC Edgewood Chemical Biological Center, Aberdeen Proving Ground, Maryland

FFAPR Full Face Air Purifying Respirator

GC Gas Chromatograph; an analytical instrument for measuring chemical components

L Liter; a unit of volume

MINICAMS Miniature Continuous Air Monitoring System; a field-portable gas chromatograph capable of detecting or monitoring for chemical agents at

STEL, 2MUC, and IDLH concentrations.

MUC Maximum Use Concentration. The MUC means the maximum atmospheric concentration of a hazardous substance from which an employee can be expected to be protected when wearing a respirator, and is determined by the assigned protection factor of the respirator or class of respirators and the exposure limit of the hazardous substance. The MUC can be determined mathematically by multiplying the assigned protection factor (APF) specified for a respirator by the required OSHA permissible exposure limit, short-term exposure limit, or ceiling limit. When no OSHA exposure limit is available for a hazardous substance, an employer must determine a MUC on the basis of relevant available information and informed professional judgment. At COBRATF the permissible exposure limit is either the CDC

STEL or the CDC WPL depending on the duration of exposure.

MUCST – is the APF (50 for a FFAPR) times the CDC STEL

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MUCWP – is the APF (50 for a FFAPR) times the CDC WPL

2MUCST or 2MUCWP – twice the base MUC value.

N/A Not applicable

O&M Operations and Maintenance

PPE Personal protective equipment; used to protect individuals from exposure to hazardous materials like chemical agents.

QLFT Qualitative Fit Test

QMP Quality management procedures; a group of documents that direct activities involving document control, records management, management review, training procedures, purchasing, internal quality system audits, quality improvement actions, and analysis of data procedure for the COBRATF Air

Monitoring Program.

RDECOM Research, Development and Engineering Command

RDT&E Research, Development, Testing and Evaluation

4.0 Description of the COBRA Training Facility

The COBRATF is a fenced complex that includes the following:

Guard Post 1 (entry control point)

Administration/classroom building

Operations and maintenance building

Incinerator building

Wastewater holding tanks

Outdoor training area

Charcoal filtration system

Training building

The training building includes areas that are inside engineering controls. These areas are maintained at a constant negative pressure with respect to surrounding environment/facilities during work involving neat toxic agent. This ensures that no toxic agent escapes into the cold areas of the building. Instead, the air at negative pressure exits to the atmosphere through a charcoal filtration system located outside the building. The areas inside the training building within engineering controls include the following:

Agent and Chemical laboratories

Hot laundry

Doff area

Service gallery

Medical anteroom

Training bays

Chemical agent storage vault area

In addition, cold areas located outside engineering controls within the training building include the following:

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Medical room

Male and female dressing (locker) rooms

Cold laundry

Cold corridor

Safety control room

Mezzanine

Air monitoring section

Lab lobby

Training building lobby

The northwest stairwell leading to the observation deck

Biological laboratory

5.0 Activities Involving the Use of GB and VX

Operations involving the use of the neat toxic agents GB and VX, or highly concentrated solutions of these toxic agents, are conducted only in designated areas within the training building. These operations include the following:

Removing ampoules of neat toxic agent, shipped from ECBC, from their shipping containers and placing these ampoules inside toxic agent storage vaults in the chemical agent laboratory.

Periodically opening and inventorying containers of neat toxic agent. This activity takes place inside the glove box in the chemical agent laboratory.

Decontaminating (destroying) low quality, or congealed, neat toxic agent unsuitable for use.

This takes place inside the glove box in the chemical agent laboratory.

Loading syringes with neat toxic agent for use inside the toxic agent training areas. This takes place inside the glove box in the chemical agent laboratory.

Passing agent-loaded syringes (in a latched container) from the glove box through the chute to Agent Custodians located in the service gallery. Agent Custodians open the container and verify the volume of agent in each syringe.

Dispensing drops of neat toxic agent onto surfaces within the toxic agent training areas.

Decontaminating surfaces contaminated with agent and destroying any excess agent remaining in syringes in the toxic agent training areas.

Diluting RDT&E standard solutions of GB and VX received from ECBC to yield the required working standard solutions. This takes place inside the lab hood in the chemical agent laboratory.

All agent solutions, neat toxic agent (as required), agent chemical waste, and liquid-agent-contaminated items are decontaminated using chemical decontaminants (such as bleach). These decontaminated items are then monitored using MINICAMS. DAAMS are used following any

MINICAMS response greater that 75 percent STEL for the agents GB or VX. This procedure is required to verify 3X decontamination prior to any item being removed from areas under engineering controls. All 3X waste and other 3X decontaminated items to be discarded are incinerated at a RCRA permitted off-site facility(or decontaminated and disposed of using other

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methods IAW the decontamination and disposal requirements in the COBRATF Toxic Agent

Exposure Control Plan and as approved by the AD, COBRATF on a case-by-case basis).

Air potentially contaminated with agent vapor in the training bays, the fume hoods, and the chemical agent laboratory glove box is exhausted to the environment through the charcoal filtration system attached to the outside of the training building.

6.0 Airborne Exposure Limits for GB and VX

The maximum concentrations of toxic agents allowed in cold areas, and in the exhaust from the filter banks and the incinerator are specified by the CASARM Quality Assurance Plan for

Chemical Agent Air Monitoring At Training Facilities. The definitions and allowed concentrations are as follows:

Airborne Exposure Limits (AEL) – Allowable concentrations in the air for workplace and general population exposures.

General Population Limit (GPL) – This is the level at which the unprotected general public can be exposed for 24 hours a day, seven days a week for a long period of time without experiencing any adverse health effects.

Worker Population Limit (WPL) – This is the level at which an unprotected worker can operate safely eight hours a day, five days a week for a working lifetime without adverse health effects.

Short-term Exposure Limit (STEL) – The STEL defines a level at which an unprotected worker may operate safely for one or more 15-minute periods (depending on the agent) during an eight hour workday.

Immediately dangerous to life or health (IDLH) – The IDLH is the level at which an unprotected worker could escape within 30 minutes without becoming impaired or experiencing irreversible health effects.

To provide additional protection to the surrounding community, both GB and VX are monitored at their STEL concentrations at the exhaust of the charcoal filter stack.

7.0 Purpose of Air Monitoring

In general, the purpose of the air monitoring program is to provide data sufficient to:

Verify that personnel are not exposed above acceptable limits based on the protective ensemble worn to include the type of respirator and duration of wear.

Warn on-site personnel in the event agent is detected in the cold areas of the training building.

Protect the environment by warning of the presence of GB or VX in the exhaust stack of the charcoal filtration system.

Verify decontamination of equipment, trash, and specific areas of the training building (as necessary).

Indicate the possible need for action if toxic agent concentrations exceed any of the airborne exposure limits defined in Section 6.0.

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The neat toxic agents GB and VX are used in the toxic agent training areas, chemical agent laboratory fume hoods and glove box. Thus, it is necessary to monitor for GB and VX in the air as follows:

The cold areas of the building, where workers and students may be present and where PPE is not worn except in the event of the detection of toxic agent; must be monitored at WPL method levels.

The chemical agent laboratory must be monitored at the STEL and IDLH method levels during all neat toxic agent operations to ensure that the concentrations of GB and VX do not exceed allowable limits.

The toxic agent training areas must be monitored at the appropriate IDLH and MUC

(MUCST or MUC WP) method levels when toxic agent training is being performed in those areas to ensure that the concentrations of GB and VX do not exceed allowable limits for the type of respirator worn and the duration of wear in training.

The exhausts from the charcoal filter banks and charcoal filter stack must be monitored at concentrations not greater than STEL method levels to ensure that GB and VX are not released into the environment.

As previously noted, the charcoal filter exhaust stack is monitored at the STEL concentrations for GB and VX, which are much lower limits for these toxic agents than required for a point source Thus, even greater environmental protection than required is demonstrated routinely for the charcoal filter exhaust stack.

MINICAMS are calibrated at appropriate levels for routine monitoring to protect personnel or the environment are generally set to alarm at 75 percent of the applicable airborne exposure limits defined previously (See Table 2).

STEL MINICAMS used to monitor the concentrations of agents in hot laundry bins are set to alarm at 9999 percent (99.99% of STEL) to disable the MINICAMS alarm feature. The detection of agent in laundry bins filled with PPE items that have been in an agent environment is expected. Thus, an audible or visual alarm in this situation is meaningless; it does not serve to protect the environment or personnel. Even though the alarm feature of the MINICAMS is disabled, no items are pulled from a given hot laundry bin unless the vapor concentrations of both GB and VX in the bin or 3X Enclosure are less than 75 percent STEL.

NOTE: Levels of protection are defined in the COBRATF Toxic Agent Exposure Control

Plan and the hazard assessment for each SOP.

Reported agent concentrations may be read on the MINICAMS liquid crystal display or on the host computer used to collect MINICAMS data.

8.0 Air Monitoring Program

The Air Monitoring Program at the COBRATF utilizes both a network of near-real time

MINICAMS and discrete DAAMS tube air sampling to perform air monitoring. The automated

MINICAMS instruments are designated Type 1 monitoring systems that are configured to monitor at the IDLH, MUC and STEL levels. Type 2 DAAMS methods are available to confirm or deny the presence of toxic agent vapors following MINICAMS alarms in areas where agent is

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not anticipated to be found. Type 1 and Type 2 laboratory methods are available. Certified air monitoring technicians work in conjunction with certified chemical agent laboratory personnel to perform air monitoring at the COBRATF.

8.1 Responsibilities

The AD, COBRATF is responsible for the air monitoring program and all decisions relating to toxic agent training operations, responses to air monitoring systems alarms, and the disposal of decontaminated items.

The industrial hygienist is responsible for providing technical support to the air monitoring program to include identifying the appropriate monitoring levels for each area, alarm levels, and clearance levels for items to be removed from the toxic agent area.

8.2 MINICAMS Air Monitoring Section and Equipment

The air monitoring section includes air monitoring technicians trained and certified to operate and maintain MINICAMS and associated accessories. MINICAMS are located in the

MINICAMS Laboratory and other locations. (See Table l). Either heated or unheated Teflon® sample lines lead from various areas throughout the training building to the MINICAMS in the air monitoring section. The pumps for STEL MINICAMS are exhausted through the charcoal-filtered exhaust system. The STEL MINICAMS connected to various sampling locations within the charcoal filtration system and the filter exhaust stack are collected through heated Teflon tubing.

IDLH MINICAMS are also located in the air monitoring section. Teflon sample lines lead from the training bays to these MINICAMS. Sample pumps for the MINICAMS are located in the sample pump room and are exhausted back to the inlet of the filter bank system. This ensures that toxic agent pulled from the toxic agent training areas and through the sample lines to the

MINICAMS is not accidentally exhausted into any cold area of the building.

Teflon lines that sample high-moisture areas of the training building, or that pass through areas exposed to low temperatures during the winter, are heated to prevent the condensation of water in the lines.

The MINICAMS detection equipment used by the air monitoring section is an automated, gas-chromatographic system that includes a sorbent tube and a phosphorus-specific flame-photometric detector. STEL MINICAMS report agent concentrations not less often than once per 10 minutes of operation. Most of the STEL MINICAMS are connected to a multi-port stream selection system, which allows the MINICAMS to sample air from several different locations on a sequential basis or can be locked in on a specific monitoring point. IDLH

MINICAMS report toxic agent concentrations no less often than once per four minutes of operation. IDLH MINICAMS may also be connected to a stream selection system so that more than one IDLH location can be sampled by a single MINICAMS.

Except as noted below, all near real time STEL sampling locations outside engineering controls are sampled no less often than once every two hours during toxic agent training operations. All

IDLH sampling locations where GB and VX are poured are sampled no less often than once every four minutes when toxic agent training operations are in progress.

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STEL, 2MUC MINICAMS and IDLH MINICAMS are connected to remote annunciator panels in safety control to display the status of this equipment at all times. Thus, the safety control staff is aware of any malfunction, alarm or communications failure for a given MINICAMS. STEL

MINICAMS operated to monitor the agent laboratory/vault and the charcoal filtration system are also connected to a remote annunciator panel located in the Guard House Post 1. Thus, security personnel are aware of the status of these MINICAMS 24 hours per day, seven days per week.

MUC MINICAMS report agent concentrations not less often than once per 7 minutes of operationare operated in a dual-line offset sampling mode. This combination minimizes or eliminates any gaps that would normally occur when the MINICAMS is purging the PCT for analysis. MUC MINICAMS can provide data from a static sampling point or the dual sample lines can be attached to an individual to provide personal breathing zone sampling. This personal breathing zone sampling provides OSHA MUC compliance data, while static samples are used on an ongoing basis to identify variances in area concentrations that may be indicative of the need for personal breathing zone sampling.

NOTE 1: The air monitoring section must be notified if a known, previously documented chemical interferent will be used in an area that is normally monitored 24 hours per day.

After obtaining the approval of the AD, COBRATF, an air monitoring technician may deselect any sampling point(s) that would be responsible for picking up the known interferent as specified on the interferent evaluation form.

NOTE 2: Due to the sensitive nature of MINICAMS systems, known documented interferent chemicals shall only be used as documented on the interferent evaluation form in terms of use before or after agent operations.

8.3 Chemical Laboratory and Equipment

The chemical laboratory both supports the MINICAMS air monitoring operation as outlined below and conducts independent air monitoring using DAAMS tubes as follows:

Preparing working standard solutions of GB and VX used to calibrate and challenge appropriate instrumentation

Preparing and issuing AgF pads required for air monitoring

Preparing and issuing DAAMS tubes used to collect manual air samples

DAAMS sampling and analysis o Collecting DAAMS samples at various locations not monitored by MINICAMS

(supported by qualified DAAMS tubes collectors) o Analysis of DAAMS samples using Type 1 and 2 methods.

9.0 Sampling Locations for Automated Air Sampling

9.1 Potential Chemical Agent Migration Points

One of the factors considered in the selection of sampling locations is the identification of areas where toxic agent leakage is considered possible. The potential chemical agent migration locations are:

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The chemical fume hood where the agent storage vaults are located

The chemical fume hood where working standard solutions are prepared

The glovebox where agent is prepared for use in the Training Bay.

Emergency exit doors from the toxic agent training areas to the cold corridor, medical room, and showers/locker rooms

The door from the service gallery to the QLFT chamber area next to the lobby

The door from the hot laundry to the cold laundry

The chemical agent storage vault

MINICAMS sampling is conducted at locations near these areas and in other areas, as needed, to detect agent leakage and ensure the protection of personnel and the environment.

9.2 Sampling Locations

The sampling locations are listed in Table 1 and include locations that are sampled only during toxic agent operations; as needed for decon verification; during non-training periods; or during an emergency. Table 1 also lists the typical monitoring frequency for each location.

Sampling locations have been approved on the basis of toxic agent characteristics, air sampling procedures, airflow patterns, and the type of monitoring equipment used.

The location of all sample points within the training building (as indicated by the same numbers in Table 1) is shown in the floor plan in Figure 1.

NOTE: Doors leading into the cold corridor from the toxic agent training areas should never be opened during toxic agent training.

If the doors to the cold corridor from the toxic agent training areas need to be opened for any reason (other than an emergency exit), the appropriate area must be monitored and demonstrated to be free of toxic agent vapors at a level less than 75 percent of the WPL monitoring method for the chemical agents GB and VX before opening.

The door from the doff equipment drop area into the hot laundry and the doors from the hot laundry into the cold laundry are generally not used during toxic agent operations. If these doors are used during toxic agent training operations, only one door at a time should be opened.

One of the doors between the hot laundry and the cold laundry is allowed to be opened only if the STEL MINICAMS monitoring at sample point 30 in the hot laundry area yields concentration readings below 75 percent of STEL for three consecutive MINICAMS monitoring cycles.

Air supplies for the heating and ventilation system for the cold areas of the training building are not shown in the floor plan because these areas are never exposed to agent vapors. A schematic representation of the charcoal filtration system for the training building, including sampling locations, is shown in Figure 2. Each filter bank includes two sets of charcoal filters in series. In general, the midbed in each filter bank is monitored to detect toxic agent that may break through the first set of charcoal filters. Thus, agent breakthrough in a given filter bank would be detected long before there is an opportunity for toxic agent to break through the second set of filters. Also, Effective Date: May 20, 2019

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the charcoal filter exhaust stack is monitored to detect any toxic agent that may break through the second filter in any filter bank.

9.3 Purpose of Sampling Locations

The general purpose for each sample location listed in Table 1 and shown in Figures 1 and 2 is outlined below. A detailed discussion of the rationale for each sample location is contained in the current version of the COBRATF Air Monitoring Rationale white paper.

Protecting the environment locations; for example, by monitoring the exhaust stack of the charcoal filtration system (See Table 1)

Monitoring the charcoal-filter midbed locations. Providing, for each charcoal filter bank, a warning of the breakthrough of toxic agent past the first set of filters. (See Table 1)

Clearing PPE items, that is, verification of 3X decontamination prior to the processing of these items by cold laundry staff locations hot laundry bins. (See Table 1)

Detecting toxic agent off-gassing from PPE if it occurs from hot laundry bins or 3X

Enclosure (location 30 or 38/39 in the hot laundry room).

Verifying 3X decontamination of trash and other items locations.

Monitoring AEL concentrations during toxic agent training operations in the toxic agent training areas locations providing a warning in the event that toxic agent concentrations exceeds the AEL alarm level in the environments in which students and instructors train.

Monitoring at AEL method levels in training areas where no chemical agent is in use but the potential for migration exists. (See Table1)

Providing air monitoring data at other sampling locations on an as-needed basis locations.

(See Table 1)

Enabling samples to be taken to confirm a MINICAMS alarm in the lab without having to enter a potentially contaminated area in PPE, or have additional personnel and support enter the agent storage vault location. (See Table 1)

Providing information to help guide cleanup operations in the event of a toxic agent release outside of engineering controls (all locations outside of engineering controls and in the chemical agent laboratory).

Any STEL sample line may be used to collect confirmation samples as needed.

10.0 Minimum Monitoring Requirements

As stated in Section 1.0, the overall air monitoring program is outlined in this document.

Although it is the intent of the air monitoring staff to operate as described in this plan, there will be times when equipment may fail. Such failures may occur during toxic agent training operations. It is the responsibility of the AD, COBRATF to determine whether toxic agent training operations can continue in the event air monitoring problems occur. The purpose of this section of the plan is to provide guidance to management staff for such situations.

At a minimum, the following air monitoring requirements must be met to conduct toxic agent training operations:

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No toxic agent training operations can begin in the chemical agent laboratory or in training bays unless the charcoal filtration system’s exhaust stack is being monitored at least once every 40 minutes using a MINICAMS monitoring at the STEL method level.

If the MINICAMS monitoring the exhaust stack fails during toxic agent training operations, the MINICAMS must be restored to proper operation and pass quality control tests

(calibration and/or QP challenges) or the sample line is connected to another MINICAMS for monitoring within 60 minutes of the last reliable concentration report from the MINICAMS.

If the MINICAMS monitoring the exhaust stack cannot be replaced or restored to proper operation within this time limit, toxic agent training operations must be suspended until automated monitoring is restored.

No toxic agent training operations can begin in the chemical agent laboratory unless the chemical agent laboratory is being monitored at the STEL and IDLH method levels.

If the STEL MINICAMS monitoring the chemical agent laboratory fails after the start of toxic agent training operations, then the neat toxic agent in the chemical agent laboratory must be resealed and remain in the glove box. No further toxic agent training operations can take place until the MINICAMS is repaired or replaced and has passed required quality control tests (calibration and/or a QP challenges).

Toxic agent training operations may begin in a given toxic agent training bay only if that bay is being monitored at the IDLH method level (and at the 2MUC level for agent bays). If the

MINICAMS fails during toxic agent training operations, such that the toxic agent training bay can no longer be monitored for a) IDLH at least once per four minutes at each toxic agent pour location or b) for 2MUCST at least every seven minutes, safety control is notified and toxic agent training operations is suspended in that toxic agent training bay until full operation of the MINICAMS is restored.

Only in an emergency may doors in the toxic agent training areas be opened to areas outside of engineering controls (for example, to the cold corridor).

Except in an emergency, agent concentrations must be monitored at the STEL monitoring level verifying that toxic agent vapor concentrations are below 75 percent of STEL for three consecutive MINICAMS monitoring cycles prior to opening toxic agent training area doors.

NOTE: Toxic agent operations may begin or continue if the alarm is caused by an operator error.

DAAMS sampling and analysis may not be used as a substitute for MINICAMS monitoring during toxic agent operations.

If all engineering controls that contain agent are fully functional, the AD, COBRATF may approve the start or continuation of toxic agent operations for situations involving air monitoring that are not expected to impact the safety of personnel within the training building, or personnel and the local community (general population) outside the training building. In general, however, non-critical toxic agent operations, such as conducting an annual toxic agent inventory in the chemical agent laboratory, should not begin unless all air monitoring equipment needed to support the operation is fully functional.

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11.0 Response to Alarms

Whenever the GB or VX concentration determined by a MINICAMS indicate an alarm level, the

MINICAMS turns on a horn and flashes a red lamp on the top cover of the MINICAMS. A horn on the status panels turns on and a specific light-emitting diode (LED) on the panel that corresponds to the MINICAMS station in alarm turns on.

11.1 Response to Alarms During Normal Working Hours

In general, on days when toxic agent training operations are planned, being conducted, or have been conducted:

If a known, previously documented chemical interference causes a MINICAMS false alarm in any cold area outside of engineering controls, before the start of toxic agent training operations, such operations may begin only after DAAMS samples are collected, analyzed, and no agent is detected in the samples. If toxic agent training operations are already in progress when the false alarm occurs, toxic agent training operations may continue except in the unlikely event that the DAAMS sample shows that agent is present in the area.

An alarm for sample locations outside engineering controls that occurs during toxic agent training operations is first assumed to be caused by agent (even if there has been a spill of a known, previously documented chemical interferent in the area being sampled), and appropriate safety precautions must be taken (as directed by safety control and the AD, COBRATF).

A MINICAMS alarm for areas outside engineering controls that occurs during toxic agent training operations must be confirmed or proven false by collecting DAAMS samples at the sample location. The DAAMS samples are then analyzed by chemical agent laboratory personnel, even if it is suspected that the alarm was caused by a known, previously documented chemical interference in the area being sampled or caused by an equipment malfunction.

In general, during the normal workday, when toxic agent training operations are not planned, not in progress, or have not been conducted:

If a STEL MINICAMS alarms and the reason for the alarm is unknown or is suspected to be caused by agent vapor, DAAMS samples must be collected and analyzed as soon as possible to confirm or deny the presence of agent.

If a MINICAMS alarm is caused by a known, previously documented chemical interference, equipment failure, or operator error, DAAMS samples do not have to be collected.

NOTE: DAAMS samples are not required for areas in which liquid toxic agent is present or toxic agent vapors are normally expected to be present. DAAMS samples are not required for alarms that indicate the presence of agent in the training bays, service gallery, doff, or hot laundry room. DAAMS samples are not required for any situation in which staff would be endangered by collecting the samples. In addition, DAAMS samples are not required for alarms caused by operator errors or a known, documented chemical interference. DAAMS samples may, of course, be collected at any time, if deemed necessary by the air monitoring staff or by the AD, COBRATF.

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11.2 Response to Alarms After Hours, Weekends and Holidays

In the event of a MINICAMS alarm after hours, on a weekend or during a holiday, a certified air monitoring technician (that is, a certified MINICAMS operator) reports to the COBRATF as soon as possible, when required.

The technician assesses the sampling location where the MINICAMS reported a GB or VX concentration of 75 percent of the STEL method or greater (that is, the location “in alarm”).

The technician checks with O&M staff on-site to be certain that all engineering controls

(negative pressure systems, door seals, charcoal filtration system, etc.) are fully operational.

If the alarm is for a midbed in one of the charcoal filter banks locations, the technician asks the O&M staff on-site to close the valve between the filter bank in alarm and the exhaust stack to stop the flow of air from the midbed to the exhaust stack. The fan motor will also be shut down and receive the requisite lock out/tag out procedure. (See Table 1) The midbed will remain closed off until MINICAMS (and if confirmation is needed, DAAMS) show that

GB and VX concentrations in the midbed are both less than 75 percent of the STEL method.

The technician assesses the probable cause of the alarm (toxic agent alarm, unknown, instrument malfunction or chemical interference).

The technician reporting in response to an alarm consults with the Lead Air Monitoring

Technician, as necessary, and notifies the Contractor Project Manager of the progress and facts surrounding the alarm. The AD, COBRATF and the Laboratory Manager are notified of the progress and facts surrounding an alarm.

The technician collects DAAMS samples from the sample line located in the air monitoring room from the area where the alarm originated, when possible.

NOTE: DAAMS samples are not required for areas in which liquid agent or agent vapors are normally expected to be present. Thus, DAAMS samples are not required for alarms that indicate the presence of agent in the training bays, service gallery, doff, or hot laundry room. DAAMS samples are not required for any situation in which staff would be endangered by collecting the samples. In addition, DAAMS samples are not required for alarms caused by operator errors or a known, documented chemical interference. Of course, DAAMS samples may be collected at any time, if deemed necessary by the air monitoring staff or by the AD, COBRATF.

For an alarm in the charcoal filter exhaust stack location or the chemical agent laboratory locations: the chemical agent laboratory staff analyze the DAAMS samples immediately

(when safe to do so). (See Table 1)

For an alarm in a midbed of the charcoal filter system locations when toxic agent training operations are scheduled for the next normal workday: chemical agent laboratory staff analyze the DAAMS samples before toxic agent training operations begin to allow the charcoal filter to be returned to proper operation, if possible. (See Table 1)

For an alarm in a midbed of the charcoal filter system locations when toxic agent training operations are not scheduled for the next normal workday: chemical agent laboratory staff analyze the DAAMS samples on the next normal workday. (See Table 1)

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For alarms in cold areas of the training building that is locations, which are outside engineering controls) that occur within one complete monitoring cycle for each monitoring location after the end of toxic agent training operations: chemical agent laboratory staff analyze the DAAMS samples immediately (when safe to do so). (See Table 1)

For alarms in cold areas of the training building locations, which are outside engineering controls) that occur more than one complete monitoring cycle for each monitoring location after the end of toxic agent training operations: chemical agent laboratory staff analyze the

DAAMS samples the next normal workday. (See Table 1) Personnel are not allowed in an area in alarm unless at least one of the following is met; (1) DAAMS are collected, analyzed and the results indicate that there is no agent present; (2) the area is no longer in alarm

(below alarm level, i.e. less than 75 percent concentration reported by MINICAMS); (3) have appropriate PPE for the environment.

Before the certified air monitoring technician leaves the COBRATF, a draft alarm report should be prepared and submitted to the AD, COBRATF, CDP Industrial Hygienist, Laboratory Manager, Operations Officer, Contractor Project Manager, COBRATF Quality

Manager and Contractor Quality Support Supervisor.

After completing the draft alarm report, the technician may leave the site when all equipment is working properly and the situation is under control.

The AD, COBRATF assumes responsibility for necessary additional support to be called out.

The AD, COBRATF may direct air monitoring or chemical agent laboratory staff to take actions different from those listed above.

11.3 Alarm Reports

Reports must be completed for all MINICAMS alarms for areas in which agent is not normally expected to be present. Reports are required for alarms for MINICAMS used for routine near real time monitoring in cold areas of the training building, charcoal filter system, for emergency response, and in support of toxic agent training operations in the chemical agent laboratory. In summary, alarm reports are required for locations. (See Table 1)

Alarm reports are not required for STEL MINICAMS used for 3X decontamination verification of PPE items, toxic agent trash, etc.; for alarms occurring in STEL monitoring areas; or for alarms occurring when MINICAMS are operating in service (SER), calibrate (CAL), or check

(CHK) modes. Alarm reports are also not required for IDLH or 2MUC MINICAMS monitoring the toxic agent training areas; this concentration data is included in toxic agent training reports prepared after the conclusion of each day of toxic agent training operations. In summary, alarm reports are not required for locations. (See Table 1)

Alarm reports are prepared and submitted to the AD, COBRATF, CDP Industrial Hygienist, Laboratory Manager, Operations Officer, Contractor Project Manager, COBRATF Quality

Manager and Contractor Quality Support Supervisor.

12.0 Verification of 3X Decontamination

No agent waste (items previously containing or contaminated with chemical agent and subsequently decontaminated) can leave engineering controls without first undergoing 3X

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verification monitoring. All items leaving engineering controls must pass into the hot laundry room either through the hot laundry bins or through the door between the outer garment doff area and the hot laundry room.

PPE items placed in a hot laundry bin or 3X Enclosure may be pulled from the bin by cold laundry staff if all of the following conditions are met:

More than 12 hours have elapsed since the end of toxic agent training operations in the training bays.

3X decontamination of the PPE items has been verified successfully by air monitoring staff

(using MINICAMS and, if necessary, DAAMS), demonstrating that the vapor concentrations of GB and VX reported for all of the items in the hot laundry bins are less than 75 percent of

STEL.

The vapor concentrations of GB and VX reported for the center of the hot laundry room

(location 30) are less than 75 percent of STEL.

A MINICAMS 3X report for hot laundry bins (and, if necessary, a DAAMS 3X report) showing that the GB and VX vapor concentration in the bins is less than 75 percent of STEL for three consecutive monitoring cycles has been received by safety control.

Non-PPE items (or specially designated PPE items) must be passed through the door between the outer garment doff area and the hot laundry room. Items previously contaminated with liquid toxic agent or dilute solutions of agent, items located in training bays while liquid agent was being “poured”, items stored continuously in the training bays, and items suspected of being contaminated with liquid agent or dilute solutions of agent require 3X decon verification. Such items must be decontaminated prior to moving them into the hot laundry room.

Once passed through the door from the outer garment doff area into the hot laundry room and contained, bags of items and large wrapped items must be assigned a unique number by a certified air monitoring technician. All bags or individual items placed in the hot laundry room must be listed on the air monitoring 3X report form and cleared by the air monitoring section prior to their removal.

All bags or wrapped items that require 3X verification must be monitored using a STEL

MINICAMS to determine agent vapor concentrations inside the bag or inside the wrapping for large items. Items that require 3X verification may be passed from the hot laundry to the cold laundry only if:

More than 12 hours have elapsed since the end of toxic agent training operations in training bays.

The item(s) have been contained at least four hours before 3X monitoring begins.

The reported GB and VX vapor concentrations are less than 75 percent of STEL for at least three MINICAMS monitoring cycles.

The vapor concentrations of GB and VX reported for the center of the hot laundry room

(location 30) are less than 75 percent of STEL.

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A MINICAMS 3X report (and, if necessary, a DAAMS 3X report) recording that neither GB nor VX have been detected at a concentration greater than 75 percent of STEL inside the bag or inside the wrapping around large items has been received by safety control.

Examples of items that must be bagged or wrapped and verified as 3X decontaminated:

All PPE items specially designated to be contained and passed through the door from the outer garment doff area into the hot laundry room. For example, butyl rubber gloves and a negative pressure APR worn by an individual who was cut out and passed through to the medical room will be thus contained.

Items present in any of the toxic agent training areas at the time liquid agent was poured in the training area or stored continuously in the toxic agent training area (that is, items that may have been exposed directly to liquid agent or to high concentrations of agent vapors in the toxic agent training areas.

Potentially contaminated items and waste passed through the chute from the glove box in the chemical agent laboratory into the service gallery.

Items known or suspected to be contaminated with liquid agent or dilute solutions of toxic agent.

MINICAMS sample pumps.

Sample lines (Teflon tubing) leading from the toxic agent training area to the air monitoring section.

Vacuum lines (Teflon or Nylon tubing) leading from MINICAMS in the air monitoring section to the STEL,IDLH and 2MUC MINICAMS sample pumps.

All 3X decontaminated items are handled IAW applicable SOPs. For any 3X item to be transported off-site a written evaluation and clearance must be completed IAW the Toxic Agent

Exposure Control Plan.

13.0 Quality Control System for Air Monitoring

The air monitoring program is certified under the CASARM QA Plan for Chemical Agent Air

Monitoring, which is administered by the CASARM QAT. This program includes approved QC plans for the air monitoring section and for the chemical agent laboratory, as well as locally approved standard operating procedures, quality management procedures, data forms, a training plan for air monitoring technicians, a continuous improvement plan. The air monitoring program is subjected to monthly quality control inspections, quarterly contract performance reviews, annual management reviews, internal audits, CASARM external audits, and audits by other external agencies (as scheduled). Deficiencies are identified and corrected using a formal corrective action request system.

14.0 Backup Power

Each MINICAMS used for near real time monitoring during toxic agent training operations is plugged into an uninterruptible power supply (UPS) backed by automatic emergency power that switches on in the event of a power outage at the site. Each UPS unit is capable of supporting

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the operation of a MINICAMS for several minutes to allow time for the automatic emergency power system to come on-line.

15.0 Response to Equipment Failures after Hours, Weekends, and Holidays

The status of each critical STEL MINICAMS is displayed at all times on the status panel in the guard house Post 1. Any time a MINICAMS malfunctions, security staff are alerted by the illumination of a yellow error lamp (LED) or a green power lamp turning off on the annunciator panel. If this occurs, the certified air monitoring technician on-call is notified and reports to the site within 2 hours of being notified or as soon as possible to take corrective action.

The cause of the equipment failure and the corrective actions taken is documented using a

MINICAMS malfunction (error) report. A copy of this draft report is provided to the AD, COBRATF, the Operations Officer, the Contractor Project Manager, the CDP Industrial

Hygienist, the COBRATF Quality Manager and the Contractor Quality Support Supervisor. A final version of the report is issued as soon as a second certified air monitoring technician has reviewed the report and any changes needed are made.

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NW

Stairwell

Cold Corridor

Mezzanine

Figure 1 Training Building Floor Plan

Cold Laundry Area

Air Monitoring Section

Med Room r

Bay 1

Chiller Room

Service Gallery

Male Doff

Hot Laundry Area

Anteroom Room

Outer Garment

Doff…