Attachment_22_Air_Monitoring_Plan.pdf

Training Operations and Support

Services – COBRATF

Attachment 22

COBRATF Air Monitoring Plan

FOR OFFICIAL USE ONLY

PLAN

Organization: Center for Domestic Preparedness Date: April 1, 2013

Title: COBRATF Air Monitoring Plan

Foreword Statement

The purpose of the CDP COBRATF Air Monitoring Plan is to provide guidance for air monitoring activities at the facility. This plan is designed to ensure the safety of all visitors, employees and the surrounding environment of the facility by providing a consistent framework for the generation of analytical data sufficient to support realistic and challenging training in a chemical environment.

Approved By:

James E. Smith Date

Superintendent

Center for Domestic Preparedness

COBRATF Air Monitoring Plan Revision 8

Effective Date: April 1, 2013

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Table of Contents

Section Subject Page

Foreword Statement

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 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 XXX 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 and the chemical agent laboratory staff.

2.0 References

Department of the Army Pamphlet 385-61

Chemical Agent Standard Analytical Reference Material Quality Assurance Plan for

Chemical Agent Air Monitoring at Training Facilities

3.0 Acronyms, Abbreviations, and Definitions

Definitions:

AgF Silver fluoride

Alarm MINICAMS sound an alarm when the concentration of GB or VX exceeds the alarm set point, which is 75 percent of the airborne exposure limit 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/m 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.

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

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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

XXX 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

Acronyms:

AD Assistant Director

AELs Airborne Exposure Limits; allowable concentrations in the air for workplace and general population exposure; include short term exposure limits

(STELs), COBRATF maximum concentration limits (CMCLs) and immediately dangerous to life or health values (IDLHs).

APR Air Purifying Respirator

ASC Allowable stack concentration or stack emission limit, which is 0.0003 mg/m for GB and for VX; this is the concentration at which the incinerator stack is monitored.

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.

CDP Center for Domestic Preparedness

COBRATF Chemical, Ordnance, Biological, Radiological Training Facility

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CMCL COBRATF Maximum Concentration Limit; the CMCL method levels are as follows: VX: 0.02 mg/m

GB: 0.2 mg/m

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.

DA PAM Department of the Army Pamphlet

ECBC Edgewood Chemical Biological Center, Aberdeen Proving Ground, Maryland

GC Gas Chromatograph; an analytical instrument for measuring chemical components

IDLH Immediately Dangerous to Life and Health; an atmosphere that poses an immediate threat to life, would cause irreversible health effects, or would impair an individual’s ability to escape from a dangerous atmosphere, regardless of protective clothing and equipment use. For planning purposes, the respirator wearer will be unaffected by the environment for up to 30 minutes without any respirator being worn. IDLH also includes atmospheres where oxygen content by volume is less than 19.5 percent (DA

PAM 385-61).

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, CMCL, and ASC/SEL concentrations.

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, analysis of data procedure, and the Quality Manual for the COBRATF Air Monitoring Program.

RDECOM Research, Development and Engineering Command

RDT&E Research, Development, Testing and Evaluation

SEL Source Emission Limit or ASC; the concentration at which the incinerator stack is monitored and is the maximum allowable emission.

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STEL Short Term Exposure Limit concentration; the maximum concentration to which unprotected chemical workers may be exposed to for up to 15 minutes continuously. The STEL method levels are as follows:

a. VX: 0.00001 mg/m

b. GB: 0.0001 mg/m

XXX A process by which a toxic agent contaminated item is treated to ensure the

Decontamination item does not off-gas toxic agent at concentrations greater than the STEL.

XXX Verification The use of a monitoring method or instrument to verify that a decontaminate item no longer poses a vapor hazard. Items are XXX verified by monitoring the air inside a closed container with the item to demonstrate that agent vapor concentrations inside the container are less than the STEL alarm level used (that is, less than 75 percent STEL).

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:

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:

Medical room

Male and female dressing (locker) rooms

Cold laundry

Cold corridor

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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 XXX decontamination prior to any item being removed from areas under engineering controls. All XXX waste and other XXX decontaminated items to be discarded are incinerated on-site (or disposed of using other methods 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.

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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:

AEL for the Worker Population – Allowable concentrations in the air for workplace and general population exposures. AELs include WPLs, STELs, CMCLs and IDLHs.

WPL – The maximum allowable eight hour time weighted average concentration that an unmasked worker could be exposed to for an eight hour workday and a 40 hour work week for

30 years without adverse health effects.

STEL – The maximum concentration to which unprotected chemical workers may be exposed to for up to 15 minutes continuously.

Guidance for the maximum concentration of agents allowed in the toxic agent training areas is provided by the definition of CMCL concentration, which is given below.

CMCL – This is the concentration above which personnel must wear SCBA (Level A) PPE or evacuate the area. The CMCL concentrations are 0.200 mg/m or 200 ng/L for GB and 0.020 mg/m or 20 ng/L for VX. Toxic agent training areas are monitored for GB and VX at CMCL concentrations near the pour locations.

SEL/ASC – This concentration is the maximum concentration of agent that may be present in the effluent or exhaust stack of incinerator stacks. ASC is used because MINICAMS displays ASC in place of SEL. ASC is an airborne exposure limit that serves as a SEL and not as a health standard. It is used for monitoring the incinerator stack. The exhaust stack of the incinerator is monitored at the SEL concentration for GB and VX.

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. The STEL concentration for GB is three times lower than its SEL concentration. The STEL concentration for VX is 30 times lower than its SEL concentration.

7.0 Purpose of Air Monitoring

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

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 or in the exhaust stack of the incinerator.

Verify XXX 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 STEL method levels.

The chemical agent laboratory must be monitored at the STEL and CMCL 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 CMCL 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 PPE worn 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.

The exhausts from the incinerator stack must be monitored at concentrations not greater than

ASC/SEL 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 (ASC/SEL concentrations). Thus, even greater environmental protection than required is demonstrated routinely for the charcoal filter exhaust stack.

The MINICAMS used to monitor ASC/SEL concentrations for the incinerator stack displays the

GB and VX concentrations reported in units of ASC, which are exactly the same as the SEL concentrations given above. The MINICAMS does not allow the abbreviation “SEL” to be displayed.

MINICAMS are calibrated at appropriate levels for routine monitoring to protect personnel or the environment are set to alarm at 75 percent of the airborne exposure limits defined previously.

STEL MINICAMS used to monitor the concentrations of agents in hot laundry bins are set to alarm at 9999 percent (99.99 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 are less than 75 percent STEL.

NOTE: Levels of protection are defined in the COBRATF Chemical Hygiene Plan and related SOPs.

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

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8.0 Air Monitoring Program

The Air Monitoring Program at the COBRATF utilizes a network of MINICAMS to perform near real time air monitoring. These automated instruments are designated Type 1 monitoring systems that are configured to monitor the various AELs. DAAMS are designated Type 2 monitoring systems used to confirm or deny the presence of toxic agent vapors following

MINICAMS alarms. 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

XXX decontaminated items.

8.2 Air Monitoring Section and Equipment

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

CMCL 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, (for example, the incinerator exhaust stack) 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 and ASC/SEL 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.

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

CMCL 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.

STEL, ASC/SEL MINICAMS and CMCL MINICAMS are connected to remote annunciator panels in safety control to display the status of this equipment at all times. Thus, the safety

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control staff are aware of any malfunction, alarm or communications failure for a given

MINICAMS. STEL and ASC/SEL MINICAMS operated to monitor cold areas of the training building, the charcoal filtration system and the incinerator stack 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.

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. An air monitoring technician initiates a deselect action request form. The form is reviewed by the Chemical Hygiene Officer and approved by the AD, COBRATF.

The completed form is maintained in the air monitoring section files.

NOTE 2: Due to the sensitive nature of MINICAMS systems, known documented interferent chemicals shall not be used 24 hours prior to agent operations. Following agent operations, known documented interferent chemicals may not be used prior to

MINICAMS monitoring the training building at the STEL level for 4 consecutive hours with no readings greater than 75 percent for the chemical agents GB and VX.

8.3 Chemical Laboratory and Equipment

The chemical agent laboratory supports the air monitoring operation as follows:

Confirming or denying possible agent detection by Type 1 method

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

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:

The chemical fume hood where the agent storage vaults are located

The chemical fume hood where working standard solutions are prepared

Emergency exit doors from the toxic agent training areas to the cold corridor

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.

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9.2 MINICAMS Sampling Locations

The MINICAMS sampling locations are listed in Table 1 and include locations that are sampled only during toxic agent operations, as needed for XXX decon verification, 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, the appropriate area must be monitored and demonstrated to be free of toxic agent vapors at a level less than 75 percent of the STEL 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, 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 specific purpose for each sample location listed in Table 1 and shown in Figures 1 and 2 is as follows:

Protecting the environment (locations 10 and 32); for example, by monitoring the exhaust stack of the charcoal filtration system and the exhaust stack of the incinerator.

Monitoring the charcoal-filter midbed (locations 1-9). Providing, for each charcoal filter bank, a warning of the breakthrough of toxic agent past the first set of filters.

Clearing PPE items, that is, verification of XXX decontamination prior to the processing of these items by cold laundry staff (locations 24-29 hot laundry bins).

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Detecting toxic agent off-gassing from PPE if it occurs from hot laundry bins (location 30 in the hot laundry room).

Verifying XXX decontamination of trash and other items (locations 35-39).

Monitoring AEL concentrations during toxic agent training operations in the toxic agent training areas (locations 41-46, 49) 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 are not conducted in training areas where no chemical agent is in use.

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

33, 34, 40, 47).

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 48).

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:

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 CMCL method levels.

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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 CMCL method level. If the MINICAMS fails during toxic agent training operations, such that the toxic agent training bay can no longer be monitored at least once per four minutes at each toxic agent pour location, 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). Concentration must first be verified to be below allowable STEL concentrations of toxic agent inside the toxic agent training area where the door is to be opened, and it must be ensured that no toxic agent operations are in progress in any of the toxic agent training areas.

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.

If a STEL MINICAMS monitoring any cold area outside of engineering controls (for example, in the lobby of the training building) alarms before the start of toxic agent operations, the toxic agent operations cannot begin until DAAMS samples are collected, analyzed, and no agent is detected in the DAAMS samples. If toxic agent operations are already in progress when the alarm occurs, toxic agent operations may continue at the direction of the AD, COBRATF except in the unlikely event that the DAAMS sample shows that toxic agent is present in the area.

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.

Although not considered a toxic agent operation, incineration of XXX decontaminated items and non-contaminated waste cannot begin unless the incinerator stack (exhaust) is being monitored using an ASC/SEL level MINICAMS. If the ASC/SEL MINICAMS fails, no new items or waste can be fed into the incinerator until the MINICAMS is repaired or replaced, calibrated and passed QP challenges, as required. DAAMS sampling and analysis cannot be used as a substitute for MINICAMS to allow feeding additional contaminated items into the incinerator.

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. For example, if the

MINICAMS that monitors the lobby of the training building fails, the AD, COBRATF may decide to start or continue toxic agent operations while air monitoring staff repair or replace the

MINICAMS. In general, however, non-critical toxic agent operations, such as conducting an

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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.

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, (for example, in the lobby of the training building) 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 or ASC/SEL 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 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

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samples may, of course, be collected at any time, if deemed necessary by the air monitoring staff or by the AD, COBRATF.

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 1-5, 7-9), 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. 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 dons the appropriate level of PPE prior to entering an area after evaluating the

MINICAMS alarm. The minimum PPE required to enter an area is the appropriate shorts, shirt, socks, PPE over garments, glove liners, butyl rubber gloves, butyl rubber boots and a negative pressure APR where a STEL MINICAMS alarm level is 75 percent or greater of the

STEL method concentration reported by a MINICAMS for GB and/or VX, and the alarm level is less than 75 percent of the CMCL method reported by a MINICAMS for GB and/or

VX.

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 an area in alarm, or an area that has been in alarm, when it is safe to do so and while wearing the appropriate PPE. DAAMS samples may also be collected 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 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.

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For an alarm in the charcoal filter exhaust stack (location 10), the incinerator exhaust stack

(location 32), or the chemical agent laboratory (locations 11-13): the chemical agent laboratory staff analyze the DAAMS samples immediately (when safe to do so).

For an alarm in a midbed of the charcoal filter system (locations 1-9) 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.

For an alarm in a midbed of the charcoal filter system (locations 1-9) 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.

For alarms in cold areas of the training building (that is, locations 14-23, 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).

For alarms in cold areas of the training building (that is, locations 14-23, 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. 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, Chemical Hygiene Officer, 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, incinerator stack, for emergency response, and in support of toxic agent training operations in the chemical agent laboratory. In summary, alarm reports are required for locations 1-23, 32, 40, and 47.

Alarm reports are not required for STEL MINICAMS used for XXX 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 CMCL MINICAMS monitoring

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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 24-31, 33-39, 41-46 and 49.

Alarm reports are prepared and submitted to the AD, COBRATF, Chemical Hygiene Officer, Laboratory Manager, Operations Officer, Contractor Project Manager, COBRATF Quality

Manager and Contractor Quality Support Supervisor.

12.0 Verification of XXX Decontamination

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

XXX 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 XXX report for hot laundry bins (and, if necessary, a DAAMS XXX 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 XXX 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 XXX report form and cleared by the air monitoring section prior to their removal.

All bags or wrapped items that require XXX 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 XXX verification may be passed from the hot laundry to the cold laundry only if:

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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 XXX 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.

A MINICAMS XXX report (and, if necessary, a DAAMS XXX 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 XXX 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 and CMCL MINICAMS sample pumps.

All XXX decontaminated items are handled IAW applicable SOPs.

13.0 Quality Control System for Air Monitoring

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

Monitoring at Training Facilities, 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 and a quality manual. 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.

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14.0 Backup Power

Each MINICAMS used for near…