Arsenic Soils Removal Work Plan _ Arsenic Soils Removal Work Plan
For
Proposed City of Tigard Library Site
Located At
SW Hall and SW Omara
Tigard, Oregon
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Prepared by
Apex Environmental Consulting Services, Inc.
PO BOX 1445
Wilsonville, OR 97070
503-682-9737
July 2003
SITE WORK PLAN TIGARD LIBRARY
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Arsenic Soils Removal Work Plan
SEC 1ON
Work Plan 1
Site Plan
2
1910.1018 Inorganic Arsenic Standard Appendix A Appen,lix A
Analytical Methods Air& Soil Sampling Apper fix B
Tech Memorandum Draft Hahn and Associates Apper. fix C
Previous Soil Sampling Results Spreadsheet
This Arsenic Soils Removal Work Plan survey report is for the exclusive use of the client and/or building
owner and is not to be photographed, photocopied, or similarly reproduced in total or in part without the
expressed written consent of the client and/or property owner.
City of Tigard
-. 05/13/03
1
SITE WORK PLAN TIGARD LIBRARY
1.1 EXECUTIVE SUMMARY
New construction is being undertaken at the proposed Tigard Library Site. The
site is known to have arsenic contamination due to past activities. Hahn and
Associates conducted an Environmental Evaluation on the proposed Tigard
Library site for arsenic contaminated soils. The site had reportedly been
agricultural in usage with an orchard established at the site sometime in the past.
.�, Based upon information provided to Apex Environmental this is the only known
usage of the site. Soil borne arsenic levels were noted to be above the background
levels set by the EPA of 7 ppm in several areas of the site occupying
-- approximately 1/3 of the site.
Arsenic levels at the site have been well documented in the top 1' of surface soil
1i- and are generally low or near background levels. Additional testing indicates that
arsenic levels drop considerably and in most cases to undetectable levels in most
areas of the site with the exception of a few hot spot areas (site diagram, section
-� 2). Excavation at the site will be conducted to remove soil areas where arsenic
contaminated soils above 7 ppm down to 1' below ground surface (bgs). Areas
that contain above 100 ppm arsenic (hot spots)will be excavated to 2' bgs. Areas
within the wetlands that are not to be developed in any way will not be excavated.
The area will not change from its current usage. Most of the areas within the
flood plain are close to 7 ppm or below. Two Leachate samples from the site
returned results below the detection limit. The soil at the site is considered non-
hazardous contaminated soil.
Industrial hygiene sampling will be conducted throughout the excavation to ensure
that no airborne levels exceeding the OSHA Permissible Exposure Limit for arsenic.
All personal sampling was conducted using a low-volume air collection device in
accordance with NIOSH and OSHA procedures. Any airborne levels exceeding the
Action Level (AL) of 5ug/m3 will be reported to the general contractor, excavation
contractor and site owner. In addition, Engineering controls and/or Personal
Protective Equipment (PPE) may be increased or additional requirements
implemented if the Action Level (AL) is exceeded at any time during the excavation
procedures.
1.2 SITE DESCRIPTION
Prior to any excavation at the Tigard Library Site, the exclusion zone or "hot
zone" will be clearly identified using surveyors and marking out the areas known
to contain arsenic above background levels. Contaminated areas will be
restricted to general contractor, excavation subcontractor, waste hauling
subcontractor and industrial hygiene personnel. The area will be delineated using
-e barrier tape during excavations. This "hot zone" area will be identified by using
sampling information provided by Hahn and Associates and the site maps
developed by Kurahashi. The "hot zone" will establish areas where added
-p protection and safety procedures for exposure to arsenic.
City of Tigard Page 1 of 7
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Outside this area in a defined egress from the exclusion zone will be established a
decontamination area or contamination reduction zone. Hand wash and boot
wash stations will be established.
1.2.1 Terminology
dft Hot Zones—Area of highest contamination where excavation work is to
be performed. The highest level of personal protective equipment must be
worn in these areas.
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Decontamination—the removal of hazardous substances from employees
and their equipment to the extent necessary to preclude the occurrence of
y foreseeable adverse health effects.
Engineering Controls— methods used to control hazardous environments
and associated potential exposures. Examples of engineering controls are:
ventilation, wet methods, employee rotation etc.
Personal Protective Equipment—equipment worn by individuals designed
to protect employees from hazards in contaminated areas. Some examples
of PPE are respirators, clothing, boots, gloves, glasses, and hard hats.
1.2.2 Employee Responsibility
All employees have a responsibility to themselves and others to use good
judgement when working in areas that may be contaminated. Proper
implementation of personal protective equipment, decontamination procedures,
and engineering controls will provide a safe and efficient work environment.
The on-site Industrial Hygienist is Dave Keck of Apex Environmental. Dave has
.w the authority to establish barriers, remove individuals from areas in which they
are not adequately protected and carry out the project safety plan.
The following is a brief description of supervisory staff associated with this
project and their responsibilities. Subcontractors shall provide specific
descriptions of their supervisory staff in their on-site work plan.
Dan VanBrabant, Hoffman Construction: On-site Supervisor
Tony Howard, Hoffman Construction: Site Safety Manager
Eric Hoffman, Hoffman Construction: Operations Manager,
Brian Clarke, Hoffman Construction: Safety Specialist
Dave Keck, Apex Environmental: HAZWOPER Supervisor on-site. Responsible
�. for all exposure monitoring and recommendations on appropriate PPE for
protection of airborne contaminants.
Brad Kelsay, Apex Environmental: Environmental Project Manager
City of Tigard Page 2 of 7
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SITE WORK PLAN TIGARD LIBRARY
1.3 EMERGENCY RESPONSE/CONTACTS
The local fire department has been contacted and briefed concerning the hazards
associated with work on this project. The fire department will be contacted via 911
should any worker become ill or unconscious due to exposure of airborne
contaminants. Employees of Hoffman and/or associated subcontractors are not
authorized to perform emergency rescue of individuals inside the excavation in
response to airborne contaminant exposures.
1.3.1 On-Site and Off-Site Emergency Contacts
On Site: Dan VanBrabant— (503) 806-2904
On Site: Dirk Koopman—(503) 680-1511
Offsite: Tony Howard— (503) 799-3916
Offsite:Brian Clarke— (503) 221-8978
Offsite:Eric Hoffman— (503) 221-8818
Offsite:Brad Kelsay— (503) 705-0514
Nearest Medical Facility:
Legacy Meridian Park Hospital
19250 SW 65a'Ave
�• Tualitan, Oregon
(503) 692-7416
1.4 HAZARD EVALUATION
1.4.1 Arsenic
Arsenic was detected in the soil at between 7-107 ppm. Arsenic can be a skin
irritant as well as an airborne concern. The arsenic contaminant has been
determined to be located in the top 1-2' feet of soil at the site.
,.� 1.4.4 Site Evaluation
Prior to excavation a HAZWOPER Supervisor in conjunction with a Hoffman
.� representative will perform an evaluation of the site. The evaluation will include
a visual inspection of the soils in the area to be excavated, installation of barriers
designating areas that PPE will be required and air monitoring to determine initial
airborne concentrations of suspected contaminants. Personal protective
equipment to be utilized by the employees will be determined based upon the
initial evaluation and on-going monitoring. Personal protective equipment
selected will exceed that required from initial airborne concentrations until air
monitoring during excavation can be performed. Once air monitoring is
performed during excavation additional determinations will be applied. Apex
Environmental's HAZWOPER Supervisor will perform all exposure monitoring.
City of Tigard Page 3 of 7
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1.5 TRAINING
The training requirements for arsenic are located in the arsenic standard
1920.1018 included in the appendices of this document. Training is required for
any one who may be exposed to the action level regardless of PPE and for anyone
,r whom there is the possibility of skin or eye irritation. Training for personnel
should include the following information:
A) The information contained in Appendix A of 1910.1018 including
a. Substance identification
b. Health hazard information
c. Personal Protective Equipment
d. Hygiene facilities and Practices
e. Signage and Labeling
-• f. Medical Examination
B) The quantity, location, manner of use, storage, sources of exposure,
and specific nature of operations where exposure may occur and
associated protective steps.
C) The purpose, proper use and limitations of respirators.
-i D) Purpose and a description of the medical surveillance program as
required by the standard.
E) Engineering controls and work practices as outlined by this document.
F) A review of 1910.1018 standard.
In addition to training, employees shall have access to a copy of the standard to
review.
-� 1.6 MEDICAL SURVEILLANCE
The medical surveillance program will be established for all employees exposed
to hazardous-substances or health hazards at or above action level (AL) of 5ug/m3
for more than 30 days per year; and for all employees who are injured become ill
or develop symptoms due to possible overexposure to work site contaminants.
Subcontractors working on the site may elect to develop their own medical
surveillance program at their expense.
During the project respirators will be required at the beginning of the project until
sufficient exposure assessment data has been collected to ensure that a downgrade
in person protective equipment is warranted. Based upon this information
respirator fit-testing and associated medical respirator fitness exams will be
required as is identified in the standard 1910.1018 and 1926.1200.
City of Tigard Page 4 of 7
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1.7 ENGINEERING CONTROLS
During the excavation of"dry" soils wetting will occur to minimize dust. Over
wetting will not occur as this could cause runoff. Additional engineering controls
will be utilized as deemed necessary by the on-site supervisor.
... Soils contaminated with arsenic above background levels of 7 ppm to be removed
from the site should hauled by covered load trucks and soils should be sufficiently
wetted on the top layer to prevent dust migration during transport.
1.8 AIR MONITORING
Air monitoring will be conducted by the on-site HAZWOPER Supervisor to
identify and quantify airborne levels of hazardous substances and to document
exposures. This information will be utilized to determine the effectiveness of
engineering controls and work practices, and the appropriate level of employee
protection. Those employees most likely to experience the highest potential
�► exposure to hazardous substances and health hazards will be monitored.
Arsenic air monitoring at the site will be using low volume or high volume air
.. samplers with a 0.8um cellulose ester filter and analyzed by a NVLAP laboratory
using NIOSH method 7900.
Personal exposure monitoring will be performed for suspected contaminants using
a low-volume air collection device in accordance with OSHA and NIOSH
procedures. Perimeter monitoring will be performed using the high volume pump
placed downwind from excavations at the site and in various locations around the
perimeter of the work area and the overall site. If at any time air monitoring
results are at or above action level (AL) of 5ug/m3 or above permissible exposure
limits level (PEL) of I Oug/m3 an assessment of engineering control methods and
PPE will be examined and may be upgraded.
' If at any time during the excavation of contaminated soils the owner, general
contractor and subcontractors will be informed in writing with potential upgrades
in PPE or alteration of onsite engineering controls.
An air monitoring and field observation report will be completed for each day
work is performed in the "hot zones". The report will contain collection times,
locations of testing, contaminant concentrations and PPE determinations. All air
monitoring equipment will be calibrated in accordance with the manufacturer's
guidelines.
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.. 1.9 PPE
Personal protective equipment will be worn in accordance with 29CFR 1910.132
and 1910.1018. All employees working in accordance with this plan will wear
PPE designated by the HAZWOPER Supervisor. Employees are to adhere to
good personal hygiene practices and wash after working in contaminated areas.
�+ Employees experiencing any ill effects shall immediately report to their
supervisor and/or a Hoffman representative. PPE may be downgraded or
upgraded once air-monitoring results have been received. The on-site
HAZWOPER Supervisor will make all recommendations of PPE to be utilized,
based upon air monitoring results.
.. Personal Protective Equipment Protocols during initial excavation will be:
1. Half-mask negative pressure respirator with P-100 filters
2. Cloth tyvek with hood or impervious tyvek
-; 3. Safety glasses
4. Boots and impervious gloves
1.10 WASH STATIONS/DECONTAMINATION
Wash stations will be provided on site and will consist of a hand washing station
'°` at a minimum with cold running water. Use of wash stations is required for
employees working in all areas of the jobs site, prior to breaks, end of the shift,
prior to use of chewing gum or tobacco products, prior to use of rest facilities and
inadvertent skin contact with contaminants.
In addition, an emergency shower unit for emergency cleaning (skin contact) will
be provided at the site.
1.11 SOIL REMOVAL
Soils that contain greater than 7 ppm arsenic will be disposed of at the Hillsboro
Landfill or other approved landfill at the discretion of the site work contractor.
Prior testing at the site and testing throughout the soils project will be used for
profiling soils for disposal and to expand excavation as needed to have all soils at
the site where possible below the 7 ppm background levels as determined by EPA
and DEQ as default background levels. Apex Environmental will collect soil
samples from the site at a rate sufficient to prove that soil removal of 6", 1' and 2'
in various areas is sufficient to remove soils above background levels. Additional
soils will be removed as needed to meet background levels.
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SITE WORK PLAN TIGARD LIBRARY
Soils contaminated with arsenic above background levels should be removed from
the site by covered load trucks and soils should be sufficiently wetted on the top
layer to prevent dust migration during transport.
It is the understanding of Apex Environmental that areas of the site are wetlands
that are not to be disturbed. Soils to remain will be identified in close out
documents.
1.12 SITE RE-EVALUATION
This work plan will be re-evaluated during the course of the project. Training,
PPE and monitoring requirements may changed based upon air monitoring results
and site conditions. The site conditions will be re-evaluated once soils have been
removed from areas and all soil and air testing has been completed.
This safety plan will remain on going during the course of the site work at the
project and until such a time as testing has shown there are no more areas
requiring soil removal and/or the areas with arsenic levels above 7 ppm are
capped and no longer a threat to human health. Changes to the plan may be
made during the project. The plan will be reviewed weekly or when conditions at
the site merit modification of the plan.
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Legend
SOIL BORNE
CONCENTRATION General Notes
ABOVE 7 PPM.
REMOVE SOILS TO
Soil's should be adequately
1 FOOT BELOW
wetted such that no visibleGROUND SURFACE
IT01 emissions occur, based upon
ARSENIC AREA the NESHAPs rules
EXTENDS INTO THE
concerning hazardous air
100 YR FLOOD
PLAIN
pollutants.
OT
SOILS N TESTED
2. Site coordination of soil
FOR ARS&C A
0
h
CONTAMINATION hauling and soil removal
rl
'All
A with general contractor.
..........
rT7
SOIL BORNE
CONCENTRATIONS
TRY 3. Decontamination procedures
BETWEEN
�WW MAW
should be conducted prior
7-20 PPM.
e.
REMOVE SOILS
TO 1 FOOT
IO leaving the exC-
lusion 1P Tj
BELOW GROUND
SURFACE &I SAW zone.
e
I__TrET
SOIL BORNE j j
® i3 .i ;➢EE lte+l ltd. .T.i.+
CONCENTRATIONS
..............
ABOVE 50 PPM.
REMOVE SOILS TO
2 FEET BELOW AREA 1N BN-"FER
GROUND SURFACE.Nt
5:'; GRADING'JN BUF _
FF�
ESTIMATED EXTENT
OF ARSENIC G
JREES REEovEc ,
13
CONCENTRATIONS i I
47#
11", t —J
qI
IN SOIL OVER 4!
100 PARTS PER
MILLION (PPM)
r y I_1 ,111�
X
EXCLUSION ZONE
ONLY AUTHORIZED
TRAINED PERSONNEL
WITHIN THIS AREA
T1 G A R D LISR A R Y
13125 S.W.HALL BLVD.
r..-GARD,OREGON 9722.3
S CALE
GRAP11b",
16C 40 2�0
Apex Environmental Consulting Services, Inc.
P.O. Box 1445
Wilsonville, OR 97070
(503) 682-9737
SHEET
DATE 1,S �2 4,�' 64
N FEET
TIGARD I
5/20/03z rl
LIBRARY
NORTH
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Oregon Administrative Rules ADOPTION BY Z
Oregon Occupational Safety REFERENCE
and Health Division
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OAR 437, DIVISION 2
GENERAL OCCUPATIONAL SAFETY AND HEALTH RULES
SUBDIVISION Z - TOXIC AND HAZARDOUS SUBSTANCES
437-002-0360 Adoption by Reference. In addition to, and not in lieu of, any other safety and
health codes contained in OAR Chapter 437, the Department adopts by reference the following
-'� federal rules as printed in the Code of Federal Regulations, 29 CFR 1910, revised as of 711198,
and anysubsequent amendments published in the Federal Register as listed below:
(19)29 CFR 1910.1018 Inorganic arsenic, published 5/25/78, Federal Register, vol.
43, p. 19624; amended by the following FR publications: 6/30/78, FR vol. 43, p. 28472;
5/23/80, FR vol. 45, p. 35282; 6/7/89, FR vol. 54, p. 24334; 6/30/93, FR vol. 58, no. 124,
p. 35310; 3/7/96, FR vol. 61, no. 46, P. 9245; 1/8/98, FR vol. 63, no. 5, p. 1286; 6/18/98,
FR vol. 63, no. 117, p. 33468.
These standards are available at the Oregon Occupational Safety and Health Division, Oregon
Department of Consumer and Business Services, and the United States Government Printing
Office.
Stat.Auth.: ORS 654.025(2)and 656.726(3).
'i Stats.Implemented: ORS 654.001 through 654295.
Hist: APD Admin.Order 13-1988,f.8/2/88,ef.82/88(Benzene).
APD Admin.Order 14-1988,f.9/12188,ef.9/12/88(Formaldehyde).
APD Admin.Order 18-1988,f.11/17/88,ef.11/17/88(Ethylene O)ide).
APD Admin.Order 4-1989,f.3131/89,ef.5/1/89(Asbestos-Temp).
"a APD Amin.Order 6-1989,f.420/89,ef.5/1/89(Non-Asbestiforms-Temp).
APD Admin.Order 9-1989,f.717/89,ef.717/89(Asbestos&Non-Asbestfforms-Perm).
APD Admin.Order 11-1989,f.7/1489,ef.8/14/89(Lead).
APD Admin.Order 13-1989,f.7/1789,ef.7/17/89(Air Contaminants).
OR-OSHA Admin.Order 1-1990,f.1/11/90,ef.1/11190(Formaldehyde-Temp).
,.. OR-OSHA Admin.Order 3-1990,f.1/19/90,ef.1/19/90(Asbestos&Non-Asbestfforms-Temp).
OR-OSHA Admin.Order 6-1990,f.32/90,ef.32/90(Formaldehyde-Perm).
OR-OSHA Admin.Order 7-1990,f.32190,ef.32/90(Asbestos&Non-Asbestiforms-Perm).
OR-OSHA Admin.Order 9-1990,f.58/90,ef.8/8/90(Labs).
OR-OSHA Admin.Order 11-1990,f.6!7/90,ef.7/1/90(Air Contaminants).
OR-OSHA Admin.Order 13-1990,f.6/28190,ef.8/1/90(Asbestos-Temp).
OR-OSHA Admin.Order 14-1990,f.628/90,ef.8/1/90(Lead).
OR-OSHA Admin.Order 19-1990,f.8/31/90,ef.8/31/90(Asbestos-Perm).
OR-OSHA Admin.Order 20.1990,f.9/18/90,ef.9118/90(Lead).
OR-OSHA Admin.Order 21-1990,f.9/18190,ef.9/18/90(Air Contaminants).
OR-OSHA Admin.Order 7-1991,f.425!91,ef.425/91(Air Contaminants,Asbestos,Formaldehyde).
OR-OSHA Admin.Order 13-1991,f.10/10/91,ef.10/10/91(Lead,Formaldehyde).
OR-OSHA Admin.Order 15-1991,f.12/13/91,ef.12113/91(Asbestos).
OR-OSHA Admin.Order 1-1992,f.122/92,ef.122/92(Formaldehyde).
OR-OSHA Admin.Order 4-1992,f.4/16/92,ef.4/16/92(Formaldehyde).
OR-OSHA Admin.Order 5-1992,f.424/92,ef.7/1192(Bloodborne Pathogens).
OR-OSHA Admin.Order 6-1992,f.5/18/92,ef.5/18/92(Asbestos).
OR-OSHA Admin.Order 10-1992,f.9/24/92,ef.924/92(Lead-temp).
OR-OSHA Admin.Order 11-1992,f.1019/92,ef.10/9/92(Asbestos).
OR-OSHA Admin.Order 12-1992j.10/13/92,ef.10/13/92(Formaldehyde).
OR-OSHA Admin.Order 15-1992,f.12/30/92,ef.12/30/92(Air Contaminants,BBP,Labs).
�,. OR-OSHA Admin.Order 1-1993,f.122193,ef.122/93(Cadmium,MDA).
OR-OSHA Admin.Order 6-1993,f.5/17/93,ef.5/17/93(Air Contaminants-Temp).
OR-OSHA Admin.Order 12-1993,f.8/20/93,ef.11/1/93(remainder of 2/Z).
OR-OSHA Admin.Order 17-1993,f.11/15/93,ef.11/15193(Air Contaminants-Penn).
OR-OSHA Admin.Order 4-1995,f.329/95,ef.329/95(Asbestos).
OR-OSHA Admin.Order 8-1995,f.825195,ef.825/95(Asbestos).
..� OR-OSHA Admin.Order 4-1996,f.9/13/96,ef.9/13/96(Lead).
(19) Z- 1 437-002-0360
-� ADOPTION BY Oregon Administrative Rules
ZOregon Occupational Safety
REFERENCE and Health Division
w
OR-OSHA Admin.Order 6-1996,f.1129/96,ef.1129196(Asbestos).
OR-OSHA Admin.Order 4-1997,f.42/97,ef.4/2/97.
OR-OSHA Admin.Order 6-1997,f.52/97,ef.5/2/97.
..r OR-OSHA Admin.Order 8-1997,f.11/14/97,ef.11/14/97(Methylene Chloride).
OR-OSHA Admin.Order 1-1998,f.2/13/98,ef.2/13/98(Methylene Chloride).
OR-OSHA Admin.Order 3-1998,f.7!1/98,ef.7/7/98.
OR-OSHA Admin.Order 1-1999,f.322/99,ef.322/99.
OR-OSHA Admin.Order 4-1999,f.4/30/99,ef.4/30/99.
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rcr
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437-002-0360 Z-2
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Oregon Administrative Rules INORGANIC
Oregon Occupational Safety Z
and Health Division ARSENIC AO 4-1999
SUBDIVISION Z
TOXIC AND HAZARDOUS SUBSTANCES
§1910.1018 INORGANIC ARSENIC.
(a) Scope and application. This section applies to all occupational exposures to
inorganic arsenic except that this section does not apply to employee exposures in
agriculture or resulting from pesticide application,the treatment of wood with
preservatives or the utilization of arsenically preserved wood.
(b) Definitions.
"Action level" means a concentration of inorganic arsenic of 5 micrograms per cubic
meter of air(5 pg/m ) averaged over any eight(8)hour period.
"Assistant Secretary" means the Assistant Secretary of Labor for Occupational Safety
and Health, U.S. Department of Labor, or designee.
"Authorized person" means any person specifically authorized by the employer whose
duties require the person to enter a regulated area, or any person entering such an area
as a designated representative of employees for the purpose of exercising the right to
observe monitoring and measuring procedures under paragraph (e)of this section,
"Director" means the Director, National Institute for Occupational Safety and Health,
U.S. Department of Health and Human Services, or designee.
"Inorganic arsenic" means copper acetoarsenite and all inorganic compounds
containing arsenic except arsine, measured as arsenic(As).
(c) Permissible exposure limit. The employer shall assure that no employee is
exposed to inorganic arsenic at concentrations greater than 10 micrograms per cubic
meter of air(10 pg/m3), averaged over any 8-hour period.
(d) Notification of use.
(1) By October 1, 1978 or Within 60 days after the introduction of inorganic arsenic
into the workplace, every employer who is required to establish a regulated area in
his workplaces shall report in writing to the OSHA area office for each such
workplace:
(I) The address of each such workplace;
(!I) The approximate number of employees who will be working in regulated
areas; and
(a)- (d)(11)(ii) Z-3 1910.1018
INORGANIC Oregon Administrative Rules
Z ARSENIC Oregon Occupational Safety
and Health Division
(iii) A brief summary of the operations creating the exposure and the actions
which the employer intends to take to reduce exposures.
(2) Whenever there has been a significant change in the information required by
paragraph (d)(1)of this section the employer shall report the changes in writing
within 60 days to the OSHA area office.
(e) Exposure monitoring.
(1) General.
(1) Determinations of airborne exposure levels shall be made from air samples
that are representative of each employee's exposure to inorganic arsenic over
an eight (8) hour period.
(ii) For the purposes of this section, employee exposure is that exposure which
would occur if the employee were not using a respirator.
(iii) The employer shall collect full shift (for at least 7 continuous hours)
personal samples including at least one sample for each shift for each job
classification in each work area.
(2) Initial monitoring. Each employer who has a workplace or work operation
covered by this standard shall monitor each such workplace and work operation to
accurately determine the airborne concentration of inorganic arsenic to which
employees may be exposed.
(3) Frequency.
(I) If the initial monitoring reveals employee exposure to be below the action
level the measurements need not be repeated except as otherwise provided in
paragraph (e)(4)of this section.
(1111) If the initial monitoring, required by this section, or subsequent monitoring
reveals employee exposure to be above the permissible exposure limit, the
employer shall repeat monitoring at least quarterly.
(111i) If the initial monitoring, required by this section, or subsequent monitoring
reveals employee exposure to be above the action level and below the
permissible exposure limit the employer shall repeat monitoring at least every
six months.
(iv) The employer shall continue monitoring at the required frequency until at
least two consecutive measurements, taken at least seven (7) days apart, are
below the action level at which time the employer may discontinue monitoring
for that employee until such time as any of the events in paragraph (e)(4) of
this section occur.
1910.1018 Z-4 (d)(1)(1111)-(e)(3)(iv)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
(4) Additional monitoring. Whenever there has been a production, process,
control or personal change which may result in new or additional exposure to
inorganic arsenic, or whenever the employer has any other reason to suspect a
change which may result in new or additional exposures to inorganic arsenic,
additional monitoring which complies with paragraph (e) of this section shall be
conducted.
(5) Employee notification.
(i) Within five (5)working days after the receipt of monitoring results, the
employer shall notify each employee in writing of the results which represent
that employee's exposures.
(ii) Whenever the results indicate that the representative employee exposure
exceeds the permissible exposure limit, the employer shall include in the written
notice a statement that the permissible exposure limit was exceeded and a
description of the corrective action taken to reduce exposure to or below the
permissible exposure limit.
(6) Accuracy of measurement.
(i) The employer shall use a method of monitoring and measurement which
has an accuracy(with a confidence level of 95 percent)of not less than plus or
minus 25 percent for concentrations of inorganic arsenic greater than or equal
to 10 pg/m3.
(ii) The employer shall use a method of monitoring and measurement which
has an accuracy (with confidence level of 95 percent) of not less than plus or
minus 35 percent for concentrations of inorganic arsenic greater than 5 pg/M3
but less than 10 pg/m3.
(f) Regulated area.
(1) Establishment. The employer shall establish regulated areas where worker
exposures to inorganic arsenic,without regard to the use of respirators, are in
excess of the permissible limit.
(2) Demarcation. Regulated areas shall be demarcated and segregated from the
rest of the workplace in any manner that minimizes the number of persons who will
be exposed to inorganic arsenic.
(3) Access. Access to regulated areas shall be limited to authorized persons or to
persons otherwise authorized by the Act or regulations issued pursuant thereto to
enter such areas.
(e)(4)-(f)(3) Z-5 1910.1018
INORGANIC Oregon Administrative Rules
Oregon Occupational Safety
ARSENIC and Health Division
(4) Provision of respirators. All persons entering a regulated area shall be
_ supplied with a respirator, selected in accordance with paragraph (h)(2) of this
section.
(5) Prohibited activities. The employer shall assure that in regulated areas,food
or beverages are not consumed, smoking products, chewing tobacco and gum are
not used and cosmetics are not applied, except that these activities may be con-
ducted in the lunchrooms, change rooms and showers required under paragraph
... (m) of this section. Drinking water may be consumed in the regulated area.
(g) Methods of compliance.
(1) Controls.
(i) The employer shall institute at the earliest possible time but not later than
December 31, 1979, engineering and work practice controls to reduce
exposures to or below the permissible exposure limit, except to the extent that
the employer can establish that such controls are not feasible.
(ii) Where engineering and work practice controls are not sufficient to reduce
exposures to or below the permissible exposure limit, they shall nonetheless be
used to reduce exposures to the lowest levels achievable by these controls and
shall be supplemented by the use of respirators in accordance with paragraph
(h)of this section and other necessary personal protective equipment.
Employee rotation is not required as a control strategy before respiratory
protection is instituted.
(2) Compliance Program.
(i) The employer shall establish and implement a written program to reduce
exposures to or below the permissible exposure limit by means of engineering
and work practice controls.
(ii) Written plans for these compliance programs shall include at least the
following:
(A) A description of each operation in which inorganic arsenic is emitted;
e.g. machinery used, material processed, controls in place, crew size,
operating procedures and maintenance practices;
(B) Engineering plans and studies used to determine methods selected for
controlling exposure to inorganic arsenic;
(C) A report of the technology considered in meeting the permissible
exposure limit;
1910.1018 Z-6 (f)(4) - (g)(2)(ii)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
(D) Monitoring data;
(E) A detailed schedule for implementation of the engineering controls and
work practices that cannot be implemented immediately and for the adap-
tion and implementation of any additional engineering and work practices
necessary to meet the permissible exposure limit;
(F) Whenever the employer will not achieve the permissible exposure limit
with engineering controls and work practices by December 31, 1979, the
employer shall include in the compliance plan an analysis of the effective-
ness of the various controls, shall install engineering controls and institute
work practices on the quickest schedule feasible, and shall include in the
compliance plan and implement a program to minimize the discomfort and
maximize the effectiveness of respirator use; and
(G) Other relevant information.
(iii) Written plans for such a program shall be submitted upon request to the
Assistant Secretary and the Director, and shall be available at the worksite for
examination and copying by the Assistant Secretary, Director, any affected
employee or authorized employee representatives.
(iv) The plans required by this paragraph shall be revised and updated at least
every 6 months to reflect the current status of the program.
(h) Respiratory protection.,
(1) General. For employees who use respirators required by this section, the
employer must provide respirators that comply with the requirements of this
paragraph. Respirators must be used during:
(i) Periods necessary to install or implement feasible engineering or work-
practice controls.
(ii) Work operations, such as maintenance and repair activities,for which the
employer establishes that engineering and work-practice controls are not
feasible.
(011) Work operations for which engineering and work-practice controls are not
yet sufficient to reduce employee exposures to or below the permissible
exposure limit.
(iv) Emergencies.
(g)(2)(111)-(h)(1)(11v) Z-7 1910.1018
INORGANIC Oregon Administrative Rules
zOregon Occupational Safety
ARSENIC and Health Division
(2) Respirator program.
(i) The employer must implement a respiratory protection program in
accordance with 29 CFR 1910.134(b)through (d) (except(d)(1)(iii)), and (f)
through (m).
(ii) If an employee exhibits breathing difficulty during fit testing or respirator
use, they must be examined by a physician trained in pulmonary medicine to
determine whether they can use a respirator while performing the required
duty.
(3) Respirator selection.
(1) The employer must use Table I of this section to select the appropriate
respirator or combination of respirators for inorganic arsenic compounds
without
ithout significant vapor pressure, and Table 11 of this section to select the
appropriate respirator or combination of respirators for inorganic arsenic
compounds that have significant vapor pressure.
(I!) When employee exposures exceed the permissible exposure limit for
inorganic arsenic and also exceed the relevant limit for other gases (for
example, sulfur dioxide), an air-purifying respirator provided to the employee as
specified by this section must have a combination high-efficiency filter with an
appropriate gas sorbent. (See footnote in Table 1 of this section.)
(III) Employees required to use respirators may choose, and the employer
must provide, a powered air-purifying respirator if it will provide proper
protection. In addition, the employer must provide a combination dust and acid-
gas respirator to employees who are exposed to gases over the relevant
exposure limits.
1910.1018 Z-8 (h)(2)(i)-(h)(3)(iii)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
Table I — Respiratory Protection for Inorganic Arsenic Particulate
.� Except for Those With Significant Vapor Pressure
Concentration of inorganic arsenic(as As)
or condition of use Required respirator
(i) Unknown or greater or lesser than 20,000 pg/m3 (A) Any full facepiece self-contained breathing apparatus
(20 mg/m)or firefighting operated in positive pressure mode.
(ii) Not greater than 20,000 pg/m3(20 mg/m3) (A) Supplied air respirator with full facepiece,hood,or
—� helmet or suit and operated in positive pressure
mode.
(iii) Not greater than 10,000 pg/m3(10 mg/m) (A) Powered air-purifying respirators in all inlet face
coverings with high efficiency filters.'
(B) Half-mask supplied air respirators operated in positive
pressure mode.
(iv) Not greater than 500 ug/m3 (A) Full facepiece air-purifying respirator equipped with
- high-efficiency fitter.'
(B) Any full facepiece supplied air respirator.
(C) Any full facepiece self-contained breathing apparatus.
(v) Not greater than 100 pg/m3 (A) Half-mask air-purifying respirator equipped with high-
efficiency filter.'
(B) Any half-mask supplied air respirator.
' High-efficiency filter—99.97 pct efficiency against 0.3 micrometer monodisperse diethyl-hexyl phthalate(DOP)particles.
Table II — Respiratory Protection for Inorganic Arsenicals (Such as Arsenic Trichloride
and Arsenic Phosphide) With Significant Vapor Pressure
Concentration of inorganic arsenic(as As)
or condition of use Required respirator
.— (i) Unknown or greater or lesser than 20,000 pg/m3 (A) Any full facepiece self-contained breathing apparatus
(20 mg/m)or firefighting operated in positive pressure mode.
(ii) Not greater than 20,000 pg/m3(20 mg/m3) (A) Supplied air respirator with full facepiece,hood,or
helmet or suit and operated in positive pressure
mode.
(iii) Not greater than 10,000 pg/0(10 mg/m3) (A) Half-mask'supplied air respirator operated in positive
pressure mode.
(iv) Not greater than 500 pg/m3 (A) Front or back mounted gas mask equipped with high-
efficiency filter'and acid gas canister.
(B) Any full facepiece supplied air respirator.
(C) Any full facepiece self-contained breathing apparatus.
(v) Not greater than 100 pg/m3 (A) Half-mask'air-purifying respirator equipped with high-
efficiency filter'and acid gas cartridge.
(B) Any half-mask supplied air respirator.
High efficiency filter—99.97 pct efficiency against 0.3 micrometer monodisperse diethyl-hexyl phthalate(DOP)particles.
2 Half-mask respirators shall not be used for protection against arsenic trichloride,as it Is rapidly absorbed through the skin.
i
(h)(3)(111ii) Table I -
(h)(3)(iii) Table 11 Z-9 1910.1018
INORGANIC Oregon Administrative Rules
zOregon Occupational Safety
ARSENIC and Health Division
(I) [Reserved]
Protective work clothing and equipment.
(1) Provision and use. Where the possibility of skin or eye irritation from
inorganic arsenic exists, and for all workers working in regulated areas, the
employer shall provide at no cost to the employee and assure that employees use
appropriate and clean protective work clothing and equipment such as, but not
limited to:
(1) Coveralls or similar full-body work clothing;
(ii) Gloves, and shoes or coverlets;
(iii) Face shields or vented goggles when necessary to prevent eye irritation,
which comply with the requirements of§1910.133(a)(2)through (6); and
(iv) Impervious clothing for employees subject to exposure to arsenic
trichloride.
(2) Cleaning and replacement.
(i) The employer shall provide the protective clothing required in paragraph
(j)(1)of this section in a freshly laundered and dry condition at least weekly,
and daily if the employee works in areas where exposures are over 100 pg/m'
of inorganic arsenic or in areas where more frequent washing is needed to
prevent skin irritation.
(I!) The employer shall clean, launder, or dispose of protective clothing
required by paragraph 0)(1)of this section.
(111) The employer shall repair or replace the protective clothing and equipment
as needed to maintain their effectiveness.
(iv) The employer shall assure that all protective clothing is removed at the
completion of a work shift only in change rooms prescribed in paragraph (m)(1)
of this section.
(v) The employer shall assure that contaminated protective clothing which is to
be cleaned, laundered, or disposed of, is placed in a closed container in the
change room which prevents dispersion of inorganic arsenic outside the
container.
(vi) The employer shall inform in writing any person who cleans or launders
clothing required by this section, of the potentially harmful effects including the
carcinogenic effects of exposure to inorganic arsenic.
1910.1018 Z-10 (1)-(j)(2)(vi)
Oregon Administrative Rules INORGANIC Z
Oregon Occupational Safety ARSENIC
and Health Division
(vii) The employer shall assure that the containers of contaminated protective
clothing and equipment in the workplace or which are to be removed from the
workplace are labelled as follows:
Caution: Clothing contaminated with inorganic arsenic; do not remove dust by
blowing or shaking. Dispose of inorganic arsenic contaminated wash water in
accordance with applicable local, State or Federal regulations.
(viii) The employer shall prohibit the removal of inorganic arsenic from
protective clothing or equipment by blowing or shaking.
(k) Housekeeping.
(1) Surfaces. All surfaces shall be maintained as free as practicable of
accumulations of inorganic arsenic.
(2) Cleaning floors. Floors and other accessible surfaces contaminated with
inorganic arsenic may not be cleaned by the use of compressed air, and shoveling
and brushing may be used only where vacuuming or other relevant methods have
been tried and found not to be effective.
(3) Vacuuming. Where vacuuming methods are selected, the vacuums shall be
used and emptied in a manner to minimize the reentry of inorganic arsenic into the
workplace.
(4) Housekeeping plan. A written housekeeping and maintenance plan shall be
kept which shall list appropriate frequencies for carrying out housekeeping
operations, and for cleaning and maintaining dust collection equipment. The plan
shall be available for inspection by the Assistant Secretary.
(5) Maintenance of equipment. Periodic cleaning of dust collection and ventila-
tion equipment and checks of their effectiveness shall be carried out to maintain the
effectiveness of the system and a notation kept of the last check of effectiveness
and cleaning or maintenance.
-- (1) [Reserved]
(m) Hygiene facilities and practices.
(1) Change rooms. The employer shall provide for employees working in regu-
lated areas or subject to the possibility of skin or eye irritation from inorganic
arsenic, clean change rooms equipped with storage facilities for street clothes and
separate storage facilities for protective clothing and equipment in accordance with
29 CFR 1910.141(e).
—
0)(2)(vii) -(m)(1) Z- 11 1910.1018
INORGANIC Oregon Administrative Rules
Oregon Occupational Safety
ARSENIC and Health Division
r
(2) Showers.
(i) The employer shall assure that employees working in regulated areas or
subject to the possibility of skin or eye irritation from inorganic arsenic shower
at the end of the work shift.
(ii) The employer shall provide shower facilities in accordance with
§1910.141(d)(3).
(3) Lunchrooms.
(i) The employer shall provide for employees working in regulated areas,
lunchroom facilities which have a temperature controlled, positive pressure,
filtered air supply, and which are readily accessible to employees working in
regulated areas.
(ii) The employer shall assure that employees working in the regulated area or
subject to the possibility of skin or eye irritation from exposure to inorganic
arsenic wash their hands and face prior to eating.
(4) Lavatories. The employer shall provide lavatory facilities which comply with
§1910.141(d)(1) and (2).
(5) Vacuuming clothes. The employer shall provide facilities for employees
working in areas where exposure, without regard to the use of respirators, exceeds
100 pg/m3 to vacuum their protective clothing and clean or change shoes worn in
such areas before entering change rooms, lunchrooms or shower rooms required
by paragraph Q) of this section and shall assure that such employees use such
facilities.
(6) Avoidance of skin irritation. The employer shall assure that no employee is
exposed to skin or eye contact with arsenic trichloride, or to skin or eye contact with
liquid or particulate inorganic arsenic which is likely to cause skin or eye irritation.
(n) Medical surveillance.
(1) General.
-- (i) Employees covered. The employer shall institute a medical surveillance
program for the following employees:
(A) All employees who are or will be exposed above the action level,
without regard to the use of respirators, at least 30 days per year; and
1910.1018 Z- 12 (m)(2)(i)- (n)(1)(1)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
(B) All employees who have been exposed above the action level, with-
out regard to respirator use,for 30 days or more per year for a total of
10 years or more of combined employment with the employer or prede-
cessor employers prior to or after the effective date of this standard. The
determination of exposures prior to the effective date of this standard shall
be based upon prior exposure records, comparison with the first measure-
ments taken after the effective date of this standard, or comparison with
records of exposures in areas with similar processes, extent of engineering
controls utilized and materials used by that employer.
(ii) Examination by physician. The employer shall assure that all medical
examinations and procedures are performed by or under the supervision of a
licensed physician, and shall be provided without cost to the employee, without
loss of pay and at a reasonable time and place.
(2) Initial examinations. By December 1, 1978, for employees initially covered by
the medical provisions of this section, or thereafter at the time of initial assignment
to an area where the employee is likely to be exposed over the action level at least
30 days per year,the employer shall provide each affected employee an opportunity
for a medical examination, including at least the following elements:
(I) A work history and a medical history which shall include a smoking history
and the presence and degree of respiratory symptoms such as breathlessness,
cough, sputum production and wheezing.
(ii) A medical examination which shall include at least the following:
(A) A 14"by 17"posterior-anterior chest X-ray and International Labor
Office UICC/Cincinnati (11-0 U/C) rating;
(13) A nasal and skin examination; and
(C) Other examinations which the physician believes appropriate because
of the employees exposure to inorganic arsenic or because of required
respirator use.
(3) Periodic examinations.
(1) The employer shall provide the examinations specified in paragraphs
(n)(2)(i) and (n)(2)(ii)at least annually for covered employees who are under
45 years of age with fewer than 10 years of exposure over the action level
without regard to respirator use.
(ii) The employer shall provide the examinations specified in paragraphs
(n)(2)(i) and (n)(2)(ii)(B) and (C)of this section at least semiannually, and the
x-ray requirement specified in paragraph (n)(2)(ii)(A) of this section at least
annually, for other covered employees.
(n)(1)(i)-(n)(3)(Ii) 2-13 1910.1018
ZINORGANIC Oregon Administrative Rules
ARSENIC Oregon Occupational Safety
and Health Division
(iii) Whenever a covered employee has not taken the examinations specified
in paragraphs (n)(2)(i) and (n)(2)(ii) of this section within six(6) months pre-
ceding the termination of employment, the employer shall provide such exami-
nations to the employee upon termination of employment.
(4) ,Additional examinations. If the employee for any reason develops signs or
symptoms commonly associated with exposure to inorganic arsenic the employer
shall provide an appropriate examination and emergency medical treatment.
(5) Information provided to the physician. The employer shall provide the
following information to the examining physician:
(i) A copy of this standard and its appendices;
(ii) A description of the affected employee's duties as they relate to the
employee's exposure;
(iii) The employee's representative exposure level or anticipated exposure
level;
(iv) A description of any personal protective equipment used or to be used;
and
(v) Information from previous medical examinations of the affected employee
which is not readily available to the examining physician.
(6) Physician's written opinion.
(i) The employer shall obtain a written opinion from the examining physician
which shall include:
(A) The results of the medical examination and tests performed;
(B) The physician's opinion as to whether the employee has any detected
medical conditions which would place the employee at increased risk of
material impairment of the employee's health from exposure to inorganic
arsenic;
-- (C) Any recommended limitations upon the employee's exposure to
inorganic arsenic or upon the use of protective clothing or equipment such
as respirators; and
(D) A statement that the employee has been informed by the physician of
the results of the medical examination and any medical conditions which
require further explanation or treatment.
1910.1018 Z- 14 (n)(3)(iii) - (n)(6)(i)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
(ii) The employer shall instruct the physician not to reveal in the written opinion
specific findings or diagnoses unrelated to occupational exposure.
(iii) The employer shall provide a copy of the written opinion to the affected
employee.
(o) Employee information and training.
(1) Training program.
(i) The employer shall institute a training program for all employees who are
subject to exposure to inorganic arsenic above the action level without regard
to respirator use, or for whom there is the possibility of skin or eye irritation
from inorganic arsenic. The employer shall assure that those employees
participate in the training program.
(ii) The training program shall be provided by October 1, 1978, for employees
covered by this provision, at the time of initial assignment for those subse-
quently covered by this provision, and at least annually for other covered
employees thereafter; and the employer shall assure that each employee is
informed of the following:
(A) The information contained in Appendix A;
(B) The quantity, location, manner of use, storage, sources of exposure,
and the specific nature of operations which could result in exposure to
inorganic arsenic as well as any necessary protective steps;
(C) The purpose, proper use, and limitation of respirators;
(D) The purpose and a description of the medical surveillance program as
_ required by paragraph (n) of this section;
(E) The engineering controls and work practices associated with the
employee's job assignment; and
(F) A review of this standard.
(2) Access to training materials.
(i) The employer shall make readily available to all affected employees a copy
of this standard and its appendices.
(ii) The employer shall provide; upon request, all materials relating to the
employee information and training program to the Assistant Secretary and the
Director.
(n)(6)(ii) -(o)(2)(ii) Z-15 1910.1018
INORGANIC Oregon Administrative Rules
Z
Oregon Occupational Safety
ARSENIC and Health Division
(p) Signs and labels.
(1) General.
(i) The employer may use labels or signs required by other statutes,
regulations, or ordinances in addition to, or in combination with, signs and
labels required by this paragraph.
(ii) The employer shall assure that no statement appears on or near any sign
or label required by this paragraph which contradicts or detracts from the
meaning of the required sign or label.
(2) Signs.
(i) The employer shall post signs demarcating regulated areas bearing the
legend;
DANGER
INORGANIC ARSENIC
CANCER HAZARD
AUTHORIZED PERSONNEL ONLY
NO SMOKING OR EATING
RESPIRATOR REQUIRED
(ii) The employer shall assure that signs required by this paragraph are
illuminated and cleaned as necessary so that the legend is readily visible.
(3) Labels. The employer shall apply precautionary labels to all shipping and
storage containers of inorganic arsenic, and to all products containing inorganic
arsenic except when the inorganic arsenic in the product is bound in such a manner
so as to make unlikely the possibility of airborne exposure to inorganic arsenic.
(Possible examples of products not requiring labels are semiconductors, light
emitting diodes and glass).The label shall bear the following legend:
DANGER
CONTAINS INORGANIC ARSENIC
CANCER HAZARD
HARMFUL IF INHALED OR SWALLOWED
USE ONLY WITH ADEQUATE VENTILATION OR RESPIRATORY PROTECTION
1910.1018 Z-16 (p)(1)(i)-(p)(3)
Oregon Administrative Rules INORGANIC Z
Oregon Occupational Safety
and Health Division ARSENIC
(q) Recordkeeping.
(1) Exposure monitoring.
(i) The employer shall establish and maintain an accurate record of all
monitoring required by paragraph (e) of this section.
(ii) This record shall include:
(A) The date(s), number, duration location, and results of each of the
samples taken, including a description of the sampling procedure used to
determine representative employee exposure where applicable;
(B) A description of the sampling and analytical methods used and
evidence of their accuracy;
(C) The type of respiratory protective devices worn, if any;
(D) Name, social security number, and job classification of the employees
monitored and of all other employees whose exposure the measurement is
intended to represent; and
y
(E) The environmental variables that could affect the measurement of the
employee's exposure.
(iii) The employer shall maintain these monitoring records for at least 40 years
or for the duration of employment plus 20 years, whichever, is longer.
-" (2) Medical surveillance.
(i) The employer shall establish and maintain an accurate record for each
employee subject to medical surveillance as required by paragraph (n) of this
section.
(ii) This record shall include:
(A) The name, social security number, and description of duties of the
employee;
(B) A copy of the physician's written opinions;
(C) Results of any exposure monitoring done for that employee and the
representative exposure levels supplied to the physician; and
(D) Any employee medical complaints related to exposure to inorganic
arsenic.
(q)(1)(11)- (q)(2)(ii) Z-17 1910.1018
Z INORGANIC Oregon Administrative Rules
Oregon Occupational Safety
ARSENIC and Health Division
(iii) The employer shall in addition keep, or assure that the examining
physician keeps, the following medical records;
(A) A copy of the medical examination results including medical and work
history required under paragraph (n) of this section;
(B) A description of the laboratory procedures and a copy of any
standards or guidelines used to interpret the test results or references to
that information;
(C) The initial X-ray;
(D) The X-rays for the most recent 5 years; and
(E) Any X-rays with a demonstrated abnormality and all subsequent
-- X-rays.
(iv) The employer shall maintain or assure that the physician maintains those
-- medical records for at least 40 years, or for the duration of employment plus
20 years whichever is longer.
(3) Availability.
(i) The employer shall make available upon request all records required to be
maintained by paragraph (q) of this section to the Assistant Secretary and the
Director for examination and copying.
(ii) Records required by this paragraph shall be provided upon request to
employees, designated representatives, and the Assistant Secretary in
accordance with 29 CFR 1910.1020(a) through (e) and (g) through (i).
—
.(4) Transfer of records.
(i) Whenever the employer ceases to do business, the successor employer
shall receive and retain all records required to be maintained by this section.
(ii) Whenever the employer ceases to do business and there is no successor
employer to receive and retain the records required to be maintained by this
section-for the prescribed period, these records shall be transmitted to the
Director.
(iii) At the expiration of the retention period for the records required to be
maintained by this section, the employer shall notify the Director at least
3 months prior to the disposal of such records and shall transmit those records
to the Director if he requests them within that period.
1910.1018 Z- 18 (q)(2)(iii) - (q)(4)(iii)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
(iv) The employer shall also comply with any additional requirements involving
the transfer of records set in 29 CFR 1910.1020(h).
(r) Observation of monitoring.
'~ (1) Employee observation. The employer shall provide affected employees or
their designated representatives an opportunity to observe any monitoring of
employee exposure to inorganic arsenic conducted pursuant to paragraph (e) of this
section.
(2) Observation procedures.
(i) Whenever observation of the monitoring of employee exposure to inorganic
arsenic requires entry into an area where the use of respirators, protective
clothing, or equipment is required, the employer shall provide the observer with
and assure the use of such respirators, clothing, and such equipment, and shall
require the observer to comply with all other applicable safety and health
procedures.
(ii) Without interfering with the monitoring, observers shall be entitled to;
(A) Receive an explanation of the measurement procedures;
(B) Observe all steps related to the monitoring of inorganic arsenic
performed at the place of exposure; and
(C) Record the results obtained or receive copies of the results when
returned by the laboratory.
-a
(s) Effective date. This standard shall become effective August 1, 1978.
-„ (t) Appendices. The information contained in the appendices to this section is not
intended by itself, to create any additional obligations not otherwise imposed by this
standard nor detract from any existing obligation.
(u) Startup dates.
(1) General. The startup dates of requirements of this standard shall be the
-- effective date of this standard unless another startup date is provided for either in
other paragraphs of this section or in this paragraph.
(2) Monitoring. Initial monitoring shall be commenced on August 1, 1978, and
shall be completed by September 15, 1978.
(3) Regulated areas. Regulated areas required to be established as a result of
initial monitoring shall be set up as soon as possible after the results of that
monitoring is known and no later than October 1, 1978.
(q)(4)(iv) - (u)(3) Z- 19 1910.1018
INORGANIC Oregon Administrative Rules
ZOregon Occupational Safety
ARSENIC and Health Division
(4) Compliance program. The written program required by paragraph (g)(2) as a
result of initial monitoring shall be made available for inspection and copying as
soon as possible and no later than December 1, 1978.
(5) Hygiene and lunchroom facilities. Construction plans for change rooms,
showers, lavatories, and lunchroom facilities shall be completed no later than
December 1, 1978, and these facilities shall be constructed and in use no later than
July 1, 1979. However, if as part of the compliance plan it.is predicted by an
independent engineering firm that engineering controls and work practices will
reduce exposures below the permissible exposure limit by December 31, 1979, for
affected employees, then such facilities need not be completed until 1 year after the
engineering controls are completed or December 31, 1980,whichever is earlier, if
such controls have not in fact succeeded in reducing exposure to below the
permissible exposure limit.
(6) Summary of startup dates set forth elsewhere in this standard.
Startup Dates
August 1, 1978—Respirator use over 500 pg/m3.
.� as soon as possible but no later than
September 15, 1978—Completion of initial monitoring.
October 1, 1978—Complete establishment of regulated areas. Respirator use for
employees exposed above 50 pg/m3. Completion of initial training. Notification of
use.
December 1, 1978—Respirator use over 10 pg/m3. Completion of initial medical.
Completion of compliance plan. Optional use of powered air-purifying respirators.
July 1, 1979—Completion of lunch rooms and hygiene facilities.
December 31, 1979—Completion of engineering controls.
All other requirements of the standard have as their startup date August 1, 1978.
(Approved by the Office of Management and Budget under control number 1218-0104)
Stat.Auth: ORS 654.025(2)and 656.726(3)
Stats.Implemented: ORS 654.001 through 654.295.
Hist: OR-OSHA Admin.Order 12-1993,f.8120/93,ef.11/1/93.
OR-OSHA Admin.Order 4-1997,f.4/2197,ef.4/2/97.
OR-OSHA Admin.Order 3-1998,f.717/98,ef.7/7198.
OR-OSHA Admin.Order 4-1999,f.4/30/99,ef.4/30/99.
1910.1018 Z-20 (u)(4) -(u)(6)
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
APPENDIX A — INORGANIC ARSENIC SUBSTANCE INFORMATION SHEET
1. SUBSTANCE IDENTIFICATION
A., Substance. Inorganic Arsenic.
B. Definition. Copper acetoarsenite, arsenic and all inorganic compounds con-
taining arsenic except arsine, measured as arsenic(As).
C. Permissible Exposure Limit. 10 micrograms per cubic meter of air as deter-
mined as anaverageover an 8-hour period. No employee may be exposed to any
skin or eye contact with arsenic trichloride or to skin or eye contact likely to cause
skin or eye irritation.
D. Regulated Areas. Only employees authorized by your employer should enter a
regulated area.
11. HEALTH HAZARD DATA
A. Comments. The health hazard of inorganic arsenic is high.
B. Ways in which the chemical affects your body. Exposure to airborne con-
centrations of inorganic arsenic may cause lung cancer, and can be a skin irritant.
Inorganic arsenic may also affect your body if swallowed. One compound in
particular, arsenic trichloride, is especially dangerous because it can be absorbed
readily through the skin. Because inorganic arsenic is a poison, you should wash
dft your hands thoroughly prior to eating or smoking.
111111. PROTECTIVE CLOTHING AND EQUIPMENT
A. Respirators. Respirators will be provided by your employer at no cost to you
for routine use K your employer is in the process of implementing engineering and
work practice controls or where engineering and work practice controls are not
feasible or insufficient.You must wear respirators for non-routine activities or in
emergency situations where you are likely to be exposed to levels of inorganic
arsenic in excess of the permissible exposure limit. Since how well your respirator
fits your face is very important, your employer is required to conduct fit tests to
make sure the respirator seals properly when you wear it. These tests are simple
and rapid and will be explained to you during training sessions.
Appendix A Z-21 1910.1018
INORGANIC Oregon Administrative Rules
ZOregon Occupational Safety
ARSENIC and Health Division
B. Protective clothing. If you work in a regulated area, your employer is required
to provide at no cost to you, and you must wear, appropriate, clean, protective
r. clothing and equipment. The purpose of this equipment is to prevent you from
bringing to your home arsenic-contaminated dust and to protect your body from
repeated skin contact with inorganic arsenic likely to cause skin irritation. This
clothing should include such items as coveralls or similar full-body clothing, gloves,
shoes or coverlets, and aprons. Protective equipment should include face shields or
vented goggles, where eye irritation may occur.
IV. HYGIENE FACILITIES AND PRACTICES
You must not eat, drink, smoke, chew gum or tobacco, or apply cosmetics in the
regulated area, except that drinking water is permitted. If you work in a regulated area
your employer is required to provide lunchrooms and other areas for these purposes.
If you work in a regulated area,your employer is required to provide showers, washing
_Ask facilities, and change rooms. You must wash your face, and hands before eating and
must shower at the end of the work shift. Do not take used protective clothing out of
change rooms without you r employer's permission.Your employer is required to provide
for laundering or cleaning of your protective clothing.
V. SIGNS AND LABELS
Your employer is required to post warning signs and labels for your protection. Signs
must be posted in regulated areas. The signs must warn that a cancer hazard is
present, that only authorized employees may enter the area, and that no smoking or
eating is allowed, and that respirators must be wom.
VI. MEDICAL EXAMINATIONS
If your exposure to arsenic is over the Action Level (5 pg/m3)—(including all persons
working in regulated areas) at least 30 days per year, or you have been exposed to
arsenic for more than 10 years over the Action Level, your employer is required to
provide you with a medical examination.The examination shall be every 6 months for
employees over 45 years old or with more than 10 years exposure over the Action Level
and annually for other covered employees. The medical examination must include a
medical history; a chest x-ray; skin examination and a nasal examination. The exami-
ning physician will provide a written opinion to your employer containing the results of
the medical exams.You should also receive a copy of this opinion. The physician must
not tell your employer any conditions he detects unrelated to occupational exposure to
arsenic but must tell you those conditions.
1910.1018 Z-22 Appendix A
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
VII. OBSERVATION OF MONITORING
Your employer is required to monitor your exposure to arsenic and you or your repre-
sentatives are entitled to observe the monitoring procedure.You are entitled to receive
an explanation of the measurement procedure, and to record the results obtained.
When the monitoring procedure is taking place in an area where respirators or personal
protective clothing and equipment are required to be worn,you must also be provided
with and must wear the protective clothing and equipment.
VIII. ACCESS TO RECORDS
You or your representative are entitled to records of your exposure to inorganic arsenic
and your medical examination records if you request your employer to provide them.
IX. TRAINING AND NOTIFICATION
Additional information on all of these items plus training as to hazards of exposure to
inorganic arsenic and the engineering and work practice controls associated with your
job will also be provided by your employer. If you are exposed over the permissible
exposure limit, your employer must inform you of that fact and the actions he is taking to
reduce your exposures.
Stat.Auth: ORS 654.025(2)and 656126(3)
State.Implemented: ORS 654.001 through 654.295.
Hist: OR-OSHA Admin.Order 12-1993A 8120/93,ef.11/1193.
OR-OSHA Admin.Order 4-1999,f.4130/99,ef.4/30/99.
rr
Appendix A Z-23 1910.1018
Oregon Administrative Rules
Oregon Occupational Safety
and Health Division
A*
AM
Z•24
Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
APPENDIX B — SUBSTANCE TECHNICAL GUIDELINES
ARSENIC, ARSENIC TRIOXIDE, ARSENIC TRICHLORIDE (THREE EXAMPLES)
I. PHYSICAL AND CHEMICAL PROPERTIES
A. Arsenic(metal).
1. Formula: As.
2. Appearance: Gray metal.
3. Melting point: Sublimes without melting at 613° C.
4. Specific Gravity: (H2O = 1):5.73.
5. Solubility in water: Insoluble.
B. Arsenic Trioxide.
1. Formula: As203, (As406).
2. Appearance: White powder.
3. Melting point: 315° C.
4. Specific Gravity (H2O = 1):3.74.
5. Solubility in water: 3.7 grams in 100cc of water at 20° C.
C. Arsenic Trichloride(liquid).
1. Formula: AsC 13.
2.Appearance: Colorless or pale yellow liquid.
3. Melting point: -8.5° C.
4. Boiling point: 130.2° C.
5. Specific Gravity (H2O = 1):2.16 at 20° C.
6. Vapor Pressure: 10mm Hg at 23.5° C.
7. Solubility in Water: Decomposes in water.
Appendix B Z-25 1910.1018
INORGANIC Oregon Administrative Rules
ARSENIC Oregon Occupational Safety
and Health Division
II. FIRE, EXPLOSION AND REACTIVITY DATA
A. Fire: Arsenic, arsenic Trioxide and Arsenic Trichloride are nonflammable.
B. Reactivity:
1. Conditions Contributing to instability: Heat.
�► 2. Incompatibility: Hydrogen gas can react with inorganic arsenic to form the
highly toxic gas arsine.
III. MONITORING AND MEASUREMENT PROCEDURES
Samples collected should be full shift (at least 7-hour)samples. Sampling should be
done using a personal sampling pump at a flow rate of 2 liters per minute. Samples
should be collected on 0.8 micrometer pore size membrane filter(37 mm diameter).
-� Volatile arsenicals such as arsenic trichloride can be most easily collected in a midget
bubbler filled with 15 mL of 0.1 N NaOH.
The method of sampling and analysis should have an accuracy of not less than +25 per-
cent(with a confidence limit of 95 percent)for 10 micrograms per cubic meter of air
(10 pg/m3) and ±35 percent (with a confidence limit of 95 percent)for concentrations of
inorganic arsenic between 5 and 10 pg/m3.
Stat.Auth: ORS 654.025(2)and 656.726(3)
Hist: OR-OSHA Admin.Order 12-1993,f.11120/93,ef.11/1/93.
r
v
1910.1018 Z-26
Appendix B
—• Oregon Administrative Rules INORGANIC
Oregon Occupational Safety
and Health Division ARSENIC
r
APPENDIX C — MEDICAL SURVEILLANCE GUIDELINES
I. GENERAL
Medical examinations are to be provided for all employees exposed to levels of
inorganic arsenic above the action level (5 pg/m3)for at least 30 days per year(which
would include among others, all employees,who work in regulated areas). Examinations
are also to be provided to all employees who have had 10 years or more exposure
-• above the action level for more than 30 days per year while working for the present or
predecessor employer though they may no longer be exposed above the level.
An initial medical examination is to be provided to all such employees by December 1,
1978. In addition, an initial medical examination is to be provided to all employees who
are first assigned to areas in which worker exposure will probably exceed 5 pg/m3 (after
the effective date of this standard) at the time of initial assignment. In addition to its
-`� immediate diagnostic usefulness, the initial examination will provide a baseline for
comparing future test results. The initial examination must include as a minimum the
following elements:
(1) A work and medical history, including a smoking history, and presence and
degree of respiratory symptoms such as breathlessness, cough, sputum
production, and wheezing;
(2) A 14" by 17" posterior-anterior chest X-ray and an International Labor Office
UICC/Cincinnati (ILO U/C) rating;
(3) A nasal and skin examination; and
.� (4) Other examinations which the physician believes appropriate because of the
employee's exposure to inorganic arsenic or because of required respirator use.
Periodic examinations are also to be provided to the employees listed above. The
periodic examinations shall be given annually for those covered employees 45 years of
age or less with fewer than 10 years employment in areas where employee exposure
exceeds the action level (5 pg/m3). Periodic examinations need not include sputum
-� cytology and only an updated medical history is required.
Periodic examinations for other covered employees, shall be provided every six (6)
months. These examinations shall include all tests required in the initial examination,
except that the medical history need only be updated.
The examination contents are minimum requirements. Additional tests such as lateral
and oblique X-rays or pulmonary function tests may be useful. For workers exposed to
three arsenicals which are associated with lymphatic cancer, copper acetoarsenite,
potassium arsenite, or sodium arsenite the examination should also include palpation of
•-• superficial lymph nodes and complete blood count.
Appendix C Z-27 1910.1018
INORGANIC Oregon Administrative Rules
ZOregon Occupational Safety
ARSENIC and Health Division
11. NON-CARCINOGENIC EFFECTS
The OSHA standard is based on minimizing risk of exposed workers dying of lung
cancer from exposure to inorganic arsenic. It will also minimize skin cancer from such
exposures.
The following three sections quoted from "Occupational Diseases:A Guide to Their
Recognition", Revised Edition, June 1977, National Institute for Occupational Safety and
Health is included to provide information on the non-neoplastic effects of exposure to
inorganic arsenic. Such effects should not occur if the OSHA standards are followed.
A. Local. Trivalent arsenic compounds are corrosive to the skin. Brief contact has
no effect but prolonged contact results in a local hyperemia and later vesicular or
pustular eruption. The moist mucous membranes are most sensitive to the irritant
action. Conjunctiva, moist and macerated areas of skin, the eyelids, the angles of
the ears, nose, mouth, and respiratory mucosa are also vulnerable to the irritant
effects.The wrists are common sites of dermatitis, as are the genitalia if personal
hygiene is poor. Perforations of the nasal septum may occur. Arsenic trioxide and
pentoxide are capable of producing skin sensitization and contact dermatitis.
Arsenic is also capable of producing keratoses, especially of the palms and soles.
B. Systemic. The acute toxic effects of arsenic are generally seen following
ingestion of inorganic arsenical compounds.This rarely occurs in an industrial
setting. Symptoms develop within 1/2 to 4 hours following ingestion and are usually
characterized by constriction of the throat followed by dysphagia, epigastric pain,
vomiting, and watery diarrhea. Blood may appear in vomitus and stools. If the
amount ingested is sufficiently high, shock may develop due to severe fluid loss,
and death may ensue in 24 hours. If the acute effects are survived, exfoliative
dermatitis and peripheral neuritis may develop.
Cases of acute arsenical poisoning due to inhalation are exceedingly rare in industry.
When it does occur, respiratory tract symptoms-cough, chest pain, dyspnea -giddi-
ness, headache, and extreme general weakness precede gastrointestinal symptoms.
The acute toxic symptoms of trivalent arsenical poisoning are due to severe inflamma-
tion of the mucous membranes and greatly increased permeability of the blood
capillaries.
Chronic arsenical poisoning due to ingestion is rare and generally confined to patients
taking prescribed medications. However, it can be a concomitant of inhaled inorganic
arsenic from swallowed sputum and improper eating habits. Symptoms are weight loss,
nausea and diarrhea alternating with constipation, pigmentation and eruption of the skin,
loss of hair, and peripheral neuritis. Chronic hepatitis and cirrhosis have been described.
Polyneuritis may be the salient feature, but more frequently there are numbness and
parasthenias of"glove and stocking"distribution.The skin lesions are usually melanotic
1910.1018 Z-28 Appendix C
-~
~� Oregon Administrative Rules INORGANIC ou���mm��m-�o�w��
Oregon Occupational Safety ^�
�������U�0��
m� Hee�D�im\on ��m����n�o��
=^
and keratotic and may occasionally take the form of an intradermal cancer of the
squamous ogi|b/pe, butwkhomt infikrat' ' properties. Horizontal white lines (striations)
~~
on the fingernails and toenails are commonly seen in chronic arsenical poisoning and
are considered to be diagnostic accompaniment mfarsenical polyneuritis.
==
Inhalation ofinorganic arsenic compounds isthe most common cause ofchronic
poisoning in the industrial situation. This condition is divided into three phases based on
signs and symptoms.
=
First Phase: The worker complains ofweakness, loss ofappetite, some nausea,
occasional vomiting, a sense of heaviness in the stomach, and some diarrhea.
�~
Second Phase: The worker complains ofconjunctivitis, m catarrhal atobo of the mucous
membranes of the nose, larynx, and respiratory passage. Coryza, hoarseness, and mild
tracheobronchitis may occur. Perforation ofthe nasal septum kacommon,
' ndia
probably the most typical lesion ofthe upper reopi�dorytract inmucupotkJnm| exposure
toarsenical dust. Skin |ooions, eczematoid and allergic intype, are common.
oft Third Phase: The worker complains of symptoms ofperipheral neuritis, initially mf
hands and feet,which isessentially sensory. Inmore severe cases, motor paralyses
occur; the first muscles affected are usually the toe extensors and the pen0nmi |nonly
the most severe cases will paralysis of flexor muscles of the feet or of the extensor
~�
muscles ofhands ocour.
Liver damage from chronic arsenical poisoning is still debated, and as yet the question
�= isunanswered. |ncases mfchronic and acute arsenical poisoning, toxic effects to the
myocardiurn have been reported based on EKG changes.These findings, however, are
now largely discounted and the EKG changes are ascribed tmelectrolyte disturbances
concomitant with arsenicalism. |nhm|mM0m of arsenic trioxide and other inorganic
arsenical dusts does not give rise horadiological evidence orpneumoconiosis. Arsenic
does have adepressant effect upon the bone marrow,with disturbances ofboth
erythropoiesis and myelopoiesis.
=
Bibliography
~= Dinrnan, B. k]. 190D. Arsenic; chronic human intoxication. J. Occup. Med. 2:137.
Elkins, H. B. 1959. The Chemistry of Industrial Toxicology, 2nd ed. John Wiley and
Sone. New York.
Holmquist, L. 1951. Occupational arsenical dermatitis; astudy among employees mta
copper-ore smelting vvodka including investigations of skin reactions to contact with
="
arsenic compounds. Acta. Demn. Vgnenao|. (Supp. 2O) 31:1.
~^
Appendix C Z~29 1910.1018
��
INORGANIC Oregon Administrative Rules
Z ARSENIC Oregon Occupational Safety
and Health Division
Pinto, S. S., and C. M. McGill. 1953. Arsenic trioxide exposure in industry. Ind. Med.
r
Surg. 22:281.
Pinto, S. S., and K. W..Nelson. 1976. Arsenic toxicology and industrial exposure. Annu.
Rev. Pharmacol. Toxicol. 16:95.
Vallee, B. L., D. D. Ulmer, and W. E. C. Wacker. 1960. Arsenic toxicology and
biochemistry. AMA Arch. Indust. Health 21:132.
[39 FR 23502,June 27,1974,as amended at 43 FR 19624,May 5,1978;43 FR 28472,June 30,1978;45 FR 35282,May 23,1980;54
FR 24334,June 7,1989;58 FR 35310,June 30,1993;61 FR 5508,Feb.13,1996;61 FR 9245,Mar.7,1996;63 FR 1286,Jan.8,1998;
63 FR 33468,June 18,1998]
Stat.Auth: ORS 654.025(2)and 656.726(3)
Stats.Implemented: ORS 654.001 through 654.295.
Hist: OR-OSHA Admin.Order 12-1993,f.8/20193,ef.11/1/93.
OR-OSHA Admin.Order 4-1999,f.4/30/99,elf.4/30/99.
wi
at
1910.1018 Z-30 Appendix C
4
TECHNICAL MEMORANDUM
DRAFT
DATE: April 25, 2003 HAI Project No. 5927
TO: Mr. Dominic Colletta
—` Ramis Crew Corrigan &Bachrach, LLP
Portland, Oregon
FROM: Mr. Robert Ede, R.G.
Hahn and Associates, Inc.
Portland, Oregon
SUBJECT: Soil Management Protocols and Summary of Site Investigations for Persistent
Agricultural Chemicals, Proposed Tigard Library Site, 13360-13560 SW Hall
Boulevard,Tigard, Oregon
Herein, Hahn and Associates, Inc. (HAI) summarizes the results of investigation activities
conducted to assess for persistent agricultural chemicals in the near surface soils of the
above-referenced site. In addition, HAI presents comments on potential site development
issues relating to the presence of elevated arsenic levels in the soils at the site, and provides
recommendations and options for management of soils containing elevated arsenic as part of
future site re-development activities.
Investigations Summary
In July 2002, a Phase I Environmental Site Assessment(ESA)' of the subject property
revealed that the central portion of the subject property was formerly used as an orchard
from at least 1940 until 1953. In September 2002, Phase II ESA2 activities were conducted
to determine if persistent agricultural chemicals may be present in the near-surface soils of
the property. This testing did not identify the presence of chlorinated pesticides or
herbicides in orchard area soils. However, arsenic was detected in soil at concentrations
above risk screening levels [U.S. Environmental Protection Agency (EPA) Region 9
Preliminary Remedial Goals (DRGs)for residential and industrial soils]. Arsenic, although
a naturally-occurring element, was identified at concentrations exceeding typical natural
background levels in area soils [typically below 7 parts per million (ppm)].
The 7 ppm regional background concentration for arsenic in soil is supported by a study
conducted by the Department of Ecology (DOE)for soils in Washington State3, as well as a
' Hahn and Associates, Inc. (2002a). A Phase 1 Environmental Site Assessment, 14.70-Acre
Residential Property, 13360-13560 SW Hall Boulevard, Tigard, Oregon(HAI Project 5861). July 26,
2002.
2 Hahn and Associates, Inc. (2002b). A Phase II Environmental Site Assessment, 14.70-Acre
Residential Property, 13360-13560 SW Hall Boulevard, Tigard, Oregon(HAI Project 5927). December
2, 2002.
3 San Juan, C. (1994). Natural Background Soil Metals Concentrations in Washington.State
(Washington Department of Ecology Publication No.94-115). October 1994.
r
Technical Memorandum Page 2 of 5
Recommended Soil Management Protocols Project No.5927
Proposed Tigard Library Site DRAFT April 25,2003
Tigard, Oregon
r
study conducted by the United States Geological Survey (USGS)for soils nationwide4.
Further, in an October 28, 2002 Memorandum from the Oregon Department of
Environmental Quality (DEQ)Toxicology Workgroup, 7 ppm was identified as appropriate
for use as a default background arsenic concentration for soils in Oregon.
In January, February, and April 2003, additional testing of near-surface soils for arsenic
was conducted in areas of the site that may be disturbed as part of the proposed library
development. This testing included detailed vertical profiling to determine depths of
elevated arsenic presence within the soil profile, as well as collection of samples at
additional locations to determine the lateral extent of elevated arsenic levels in the area of
proposed development. Vertical profiling revealed arsenic is typically found at the highest
concentrations in the upper one foot of soil at portions of the site, while lesser
concentrations are typically present in the second foot of soil, but still exceeding the default
background level. In most instances, arsenic levels were found to drop to below levels of
detection at depths greater than 2 feet bgs, although slightly elevated levels were identified
at one location beneath this depth (10.2 ppm from 2 to 3 feet bgs at sample location SS-44).
In total, arsenic was detected at concentrations above typical background levels in 39 of 105
..� soil samples that were tested at the site, at concentrations up to 107 ppm. Table 1
(attached) is a summary of all soil testing conducted to date for arsenic and other persistent
agricultural chemicals at the property. Laboratory analytical reports and chain-of-custody
documentation for all testing activities conducted subsequent to the referenced Phase 1I
ESA activities,have also been attached herein.
An interpretation of arsenic extent in soil is shown on Figure 1 (attached). Of note, arsenic
-� was not found throughout the former orchard area at elevated levels. In addition, elevated
arsenic was found in areas that were not thought to be historical orchards. Instead, the
elevated arsenic in near surface soil appears to better correlate with swales and low-lying
areas of the site. Within the developable portion of the property, elevated arsenic appears to
be limited to a south to north sloping Swale at the central portion of the site and a connected
east to west sloping swale near the southern property boundary. Both swales are joined
upslope near the southwestern property boundary, with the overall Swale extending off-site
to the southwest.
Erosion and overland transport of arsenic within soil, with deposition in low-lying areas,
-r may explain the observed pattern of arsenic at the site. Although the specific source of the
elevated arsenic is not known, the greatest concentrations on the property (91.3 to 107 ppm)
were found in the vicinity of a former structure (barn?) located on the southernmost parcel
near the confluence of the swales, as observed on historical aerial photographs and as
depicted on Figure 1. It is possible that pesticide storage, mixing, and/or equipment rinsing
may have occurred at the location of the former structure, which may explain the presence
of arsenic in the non-orchard swale. Alternatively, or in addition, because the swale extends
up-slope and off site to the southwest, it is possible that run-off from orchards formerly
4 Schaklette, H.T., and Boernegen,J.G. (1984). Element Concentrations in Soils and Other
Surficial Materials of the Conterminous United States (U.S. Geological Survey Professional Paper
1270).
HAHN AND ASSOCIATES,INC.
Technical Memorandum Page 3 of 5
Recommended Soil Management Protocols Project No. 5927
Proposed Tigard Library Site DRAFT April 25, 2003
Tigard, Oregon
located to the southwest of the property may have contributed to the identified arsenic
impacts.
In summary, testing results indicate the vertical extent of elevated arsenic is predominantly
r
limited to the upper two to three feet of soil at the site, and the lateral extent of elevated
arsenic (i.e., greater than 7 ppm)is present predominantly in swales and low-lying areas of
the site, as delineated on Figure 1. It is of note that the full lateral extent of elevated
arsenic has not been determined in those portions of the site that are within the flood plain
and are not proposed for development. Testing of select soil samples by Synthetic
Precipitation Leaching Procedure (SPLP) and Toxicity Characteristic Leaching Procedure
(TCLP) indicates concentrations of leachable arsenic were not detected, indicating that
-- arsenic leaching to groundwater is not a migration pathway of concern, and that excavated
soils would not meet criteria for defining a characteristic hazardous waste through the
Resource Conservation and Recovery Act (R.CRA).
Regulatory Issues
As long as the property remains in agricultural use, no actions are necessary with respect to
the arsenic in soil. However,because of the proposed change in-land use at the site,
Oregon's Hazardous Substance Remedial Action rules (OAR Division 122) will likely require
actions to address the elevated arsenic in soil. For a metal such as arsenic in near surface
soil, the typical remedial actions are access restrictions, removal, and/or capping. There is
no requirement to report the site to the Oregon Department of Environmental Quality
(DEQ), and all remedial actions can be conducted as an Independent Cleanup without DEQ
oversight, as long as they meet the cleanup rule requirements. However, to obtain official
"No Further Action" designation for the site, DEQ involvement would be necessary.
Remedial Action Approach and Development Issues
A conceptual remedial action approach that seems to best fit the development plans for the
property is composed of the following elements:
1) Removal—For those areas with elevated arsenic (greater than 7 ppm on Figure 1),
every effort should be made to minimize the volume of soil that needs to be removed
as part of site development for surface preparation. We understand that at least the
upper 6 inches of soil.will need to be removed. This soil should be sent to an
appropriate landfill for disposal, or used on-site as fill. If used on-site, the areas of
...: filling will need to be carefully documented, and covered with an impermeable cap
(pavement or building foundation) or cap of clean fill. Specific soil management
protocol recommendations are provided in the following Section.
HAHN AND ASSOCIATES,INC.
Technical Memorandum Page 4 of 5
Recommended Soil Management Protocols Project No. 5927
Proposed Tigard Library Site DRAFT April 25, 2003
Tigard,'Oregon
,.• 2) Capping—For those areas of elevated arsenic located within the developed portion of
the site following site grading (greater than 7 ppm on Figure 1), a cap of clean soil,
pavement, or a structure should be installed and maintained. Controls should be in
place to ensure future excavation workers (e.g., utility line construction or repair)
who may penetrate the cap are aware of special precautions and soil management
procedures that may be necessary.
3) Access Restrictions—For those areas of elevated arsenic located outside the
developed portion of the site, some sort of access restriction may be the most
appropriate approach. Because the extent of elevated arsenic outside the portion of
the site to be developed(within the wetland boundary)has not been delineated at
this time, it is recommended that access to surficial soils should be restricted
throughout this area.
Recommended Protocols for Management of Contaminated Media
1) Those personnel conducting activities on-site for which potential exposure to
contaminants exists should be in compliance with all federal and state rules and
regulations, including rules promulgated by the Occupational Safety and Health
Administration, Code of Federal Regulations (CFR), Title 29, Part 1910.120, and the
substance-specific Construction standards (inorganic arsenic) contained in 437
Division 2, 1910.1018.
2) The Oregon Occupational Safety and Health Agency (OR-OSHA)permissible
exposure limit(PEL)for arsenic is 10 micrograms per cubic meter(µg/m3) of air,
averaged over an eight-hour period. OR-OSHA also defines a regulatory action level
for an eight-hour time-weighted average (TWA). The action level for arsenic is 5
µg/m3. The need for, and design of, air quality monitoring to ensure adherence with
the arsenic PEL and action level should be determined by the earthwork contractor.
• However, air monitoring during grading or excavation activities in the area of
elevated arsenic concentrations (Figure 1) to document a lack of worker inhalation
hazard and the adequacy of engineering controls (dust suppression)is
recommended.
3) Dust controls should be implemented during earthwork or other construction
activities, as necessary, such that dust generation is minimized and to prevent off-
site migration of dust. Dust controls could include use of water trucks to moisten
roads and other areas that could generate dust. Further, construction vehicle speed
limits and/or placement of gravel in heavily traveled areas could be used.
Additionally, during dry weather, the use of compressed air for dust removal or
equipment cleaning could be prohibited. Finally, earthwork equipment and trucks
should be inspected and rinsed via wheel wash stations, as necessary, prior to
leaving the site to prevent spreading of site soil to nearby public streets.
W
�. HAHN AND ASSOCIATES,INC.
Technical Memorandum Page 5 of 5
Recommended Soil Management Protocols Project No. 5927
Proposed Tigard Library Site DRAFT April 25, 2003
Tigard, Oregon
4) If excavated soils from an area documented as containing greater than 7 ppm
arsenic (Figure 1) are to be temporarily stockpiled on site, then the stockpile(s)
should either remain within the area depicted on Figure 1 as containing elevated
arsenic levels (i.e., greater than 7 ppm), or else the stockpiles should be placed on a
-- minimum of 6 mil geomembrane to prevent mixing with the underlying soil. Dust
suppression measures, such as covering, should be implemented for the stockpiles to
prevent generation of windblown dust.
r
5) Soil excavated from areas delineated on Figure 1 as containing arsenic at
concentrations greater than 7 ppm will require either on-site restricted subgrade
use, or off-site disposal in a lined landfill permitted by the DEQ to accept non-
hazardous contaminated soil wastes. Permitting and pre-approval from the disposal
facility will be necessary prior to implementing the landfill disposal option. On-site
reuse should be restricted to placement below pavement, buildings, or below a
-- minimum of 3 feet of clean fill in those areas that will not be covered with pavement
or structures (or other impermeable cover). A preference should be given to reuse as
subgrade backfill within the presently delineated area identified as having arsenic
concentrations greater than 7 ppm.
6) A distinct geotextile marker should be used to delineate the boundary between soils
containing greater than 7 ppm arsenic and the overlying material [either non-
impacted soil or and impermeable barrier (e.g., structure or pavement)]. The
geotextile marker will act as a physical indicator to future excavation workers as to
the location arsenic-impacted soil.
7) The location and extent of all geotextile markers should be documented during
construction and permanently recorded. This documentation, in addition to the
physical presence of the geotextile marker, can be used as a planning tool and
control with regard to future excavation activities that could encounter soils
containing arsenic at concentrations greater than 7 ppm.
If you have any questions regarding the above information,please call at (503) 796-0717 or
email at rede@hahnasoc.com.
HAHN AND ASSOCIATES,INC.
5
TABLE I-Summary of Analytical Results for Soil Samples
Site Investigation
14.7-Acre Property
13360.13560 SW Hall Boulevard
71gard,Oregon HAI Project No.5927
ace: .,x
... Analytical-
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....L6acl
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ablei
PAM:..
003 020905.003 5-Sep-02 0.25'-1.51 18.7
004 020905.004 5-Sep-02 0.25'-1.5' 26.1
009 020905-009 5-Sep-02 0.25-1.5 ND>2.00 10.6 7.32 ND>0.016
010 020905-010 5•Sep-02 0.25-1.5 2.64 11.2 7.49 ND>0.016_-
011 20905-001,-002 5-Sep•02 0.25'-1.5' 2.83 9.96 7.59 ND>0.015 ND ND
012 20905-003,-004 5-Sep-02 0.25'-1.5' 21.5 6.47 6.39 ND>0.016 ND ND
013 20905-005,-006 5-Sep-02 0.25'-1.5' 9.07 6.74 3.7 ND>0.016 ND ND
014 20905-007,-008 5-Sep-02 0.25'-1.5' ND-2.00 9.27 6.21 ND>0.015 ND ND
SS-1 030108-015 8-Jan-03 0.0'-0.25' 10.7
030108-016 8-Jan-03 0.25'-0.5' 4.41
030108-017 8-Jan-03 0.5'-0.75' 64.6
030108-018 8-Jan-03 0.75'-1.0' 3.37
030108-019 8-Jan-03 1.0'-1.5' 4.94
030108.020 8-Jan-03 1.5'-2.0' 17.4
030108-021 8-Jan-03 2.0'-2.5' 1,M>1.85
030108-022 8-Jan-03 2.5'-3.0' ND>2.00
SS-2 030108-023 8-Jan-03 0.0'-0.25' 2.41
030108-024 8-Jan-03 0.25'-0.5' 4.42
030108-025 8-Jan-03 0.5'-0.75' ND>2.00
030108-026 8-Jan-03 0.75'-1.0' 5.41
030108-027 8-Jan-03 1.01-1.51 5.16
030108-028 842n-03 1.5'-2.0' 10.2
030108-029 8-Jan-03 2.0'-2.5' ND>1.85
030108-030 8-Jan-03 2.5'-3.0' ND>2.00
SS-3 030206-031 6-Feb-03 0.0'-1.0' ND>2.08
SS-4 030206-033 6-Feb•03 0.0'-1.0' 33.3
030206-034 6-Feb-03 1.0'-2.0' 15.7
SS-5 030206-035 6-Feb-03 0.0'-1.0' ND>2.00
SS•6 030206-037 6-Feb-03 0.0'-1.0' ND>1.85
SS-7 030206-039 6-Feb-03 0.0'-1.0' 11.
030206.040 6-Feb-03 1.0'-2.0' 11.2
SS-8 030207-041 7-Feb-03 0.0'-1.0' 2.12
SS-9 030207-043 7-Feb-03 0.0'-1.0' 12.2
030207-044 7-Feb-03 1.0'-2.0' 2.76
-
SS•10 030207-045 7-Feb-03 0.0'.1.0' ND>1.85
SS-11 030207-047 7-Feb•03 0.0'-1.0' ND>1.72
SS-12 030207-049 7-Feb-03 0.0'-1.0' ND>1.85
SS-13 030207-051 7-Feb•03 0.0'-1.0' 2.94
SS-14 030207-053 7-Feb-03 0.0'-1.0' ----6.84
Updated:5/2212003 MSM Page I of 5
File Name:5927-Table-l-.R.1-Soil.Rs1ts.xls HAHN AND ASSOCIATES,INC.
TABLE I-Summary of Analytical Results for Soil Samples
Site Investigation
14.7-Acre Property
13360-13560 SW Hall Boulevard
Tigard,Oregon HAI Project No.5927
Sample-Surface . Sample:. Simple R Wts.::
T.
.. DumberDate Depth le-
'amp
ppw
'Total:
.anon _I»terval Metals byEPA.6QIOPw .
P
. ek mMn 13p HEF11iC1deS:
.6
V 2-PA Lea' abt�.
Arftnk < Lead
:' Leaclialle;
A AML
7= 177 77-
7
Updated:5/22/2003 MSM Page 2 of 5
File Name:5927-Table-13.1-Soil_Rsltsals HAHN AND ASSOCIATES,INC.
TABLE 1-Summary of Analytical Results for Soil Samples
Site Investigation
14.7-Acre Property
13360-13560 SW Hall Boulevard
'regard,Oregon HAI Project No.5927
Sam
pl -WAP e::
es
...... .....
b Date
-Y
Sarnpl:e. Nxn.er *VPP:::M.
I.
terv**1
..........
El
?A'6010/7000 OrAn tod
'6011D en":: , : ^:>.::>< : .
Tutiff Metab-by A bo S.'*4" . .
es H
es
. .............
. Y,
EPA
feet b
Arsenic e � pLP . .. e hab)
<Aseritc
SS-15 030207-055 7-Feb-03 0.01-1.01 36.6 ND>0.02
030207-056 7-F 1.0'-2.0' 15.4 ND>0.02
SS-16 030207-057 7-Feb-03 0.0'-1.0' 4.24
SS-17 030207.059 7-Feb-03 0.0'-1.01 2.16
SS-18 030207-061 7-Feb-03 0.0'-1.0' ND>1.85
SS-19 030207-063 7-Feb-03 0.0'-1.0' ND>1.92
SS-20 030207-065 7-Feb-03 0.0'-1.0' 2.26
SS-21 030207-067 7-Feb-03 0.0'-1.0' ND>1.85
SS-22 030207-069 7-Feb-03 0.0'-1.0' ND>1.92
SS-23 030207-071 7-Feb-03 0.0'-1.0' ND>1.85
030207-072 7-Feb-03 1.0'-2.0' ND>1.92--
SS-24 030207-073 7-Feb-03 0.01-1.01 4.46
SS-25 030207-075 7-Feb-03 0.01-1.0 23.4
030207-076 7-Feb-03 1.0'-2.0' 8.89
SS-26 030207.077 7-Feb-03 0.0'-1.01 8.74
030207-078 7-Feb-03 1.0'-2.0' 4.59
SS-27 030207-079 7-Feb-03 0.0'-1.0' ND>1.85--
SS-28 030209-081 9-Feb-03 0.0'-1.0' 2.23
SS-29 030209-083 9-Feb-03 0.01-1.01 4.85
SS-30 030209-085 9-Feb-03 0.01-1.01 1.98
SS-31 030209-087 9-Feb-03 0.0'-1.0' ND>1.85
SS-32 030209-089 9-Feb-03 0.0'-1.01 ND>2.00
030209.090 9-Feb-03 1.0'-2.0' ND>2.00
SS-33 030209-091 9-Feb-03 0.0'-1.0' ND-1.85
030209-092 9-Feb-03 1.0'-2.0' ND>1.92
SS-34 030209-093 9-Feb-03 0.0'.1.01 2.06
030209-094 9-Feb-03 1.0'-2.0' ND-2.08
SS-35 030209-095 9-Feb-03 0.0'-1.0' ND>2.00
SS-36 030209-097 9-Feb-03 0.0'-1.0' ND>2.00
SS-37 030408.139 8-Apr-03 0.0'-1.0' 17.8
SS-38 030408-140 8-Apr-03 0.0'-1.0' 11.
SS-39 030408-141 8-Apr-03 0.01-1.0' ND-1.85
SS-40 030408-142 8-Apr-03 0.0'-1.0' ND>1.92
SS-41 030408.143 8-Apr-03 0.0'-1.0' ND>2.08
SS-42 030408-138 8-Apr-03 0.01-1.01 29.6
SS-43 030408-136 8-Apr-03 0.0'-1.0' 10.7
SS-44 030408-133 8-Apr-03 0.0'-1.0' 14.5
030408-134 8-Apr-03 1.0'-2.0' 6.47
030408.135 8-Apr-03 2.0'-3.0' 10.2
Updated:512212003 MSM Page 3 of 5
File Name:5927-Table-1-R.1-Sofl.Rslts.xls IIAHN AND ASSOCIATES,INC.
TABLE I-Summary of Analytical Results for Soil Samples
Site Investigation
14.7-Acre Property
13360-13560 SW Hall Boulevard
'hgard,Oregon HAI Project No.5927
atno e
N,iu-bef',
bate ::De�th -k Xp ow"
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e erence,
Updated:5/22/2003 MSM Page 4 of 5
File Name:6927-Table-1-R.1-Soil-Rslts-xls HAHN AND ASSOCIATES,INC.
TABLE I-Summary of Analytical Results for Soil Samples
Site Investigation
14.7-Acre Property
13360.13560 SW Hall Boulevard
Tigard,Oregon HAI Project No.5927
W
de. Sample._ a
Sam pli�.: Number 4,
Date D th;
mi-
Th
Location. : . Interval
Z
Mina
Tow:meta 106
U by:EP-A GO, 000 Serres
LP
']SP �i:
TCLP
EPA Method
A::
4':
. Mere 8jD8.
Leeach
Leec}tableL
SS-45 030408-131 8-Apr-03 0.0'-1.0' 7.74
SS-46 030408.129 8-Apr-03 0.0'-1.0' 10.2
SS-47 030408-121 8-Apr-03 0.01-1.01 9.36
SS-48 030408-122 8-Apr-03 0.01-1.01 107. ND>0.100
030408.123 8.Apr-03 1.0--2.0' 48.2
SS-49 030408-124 8-Apr-03 0.01-1.01 4.15
SS-50 030408-126 8-Apr-03 0.01-1.01 4.72
SS-51 030408.128 8-Apr-03 0.01-1.01 3.89
SS-52 030407-120 7-Apr-03 0.0'-1.0' 7.62
SS-53 030407.110 7-Apr-03 0.0'-1.0' 7.83
SS-54 030407-111 7-Apr-03 0.0'-1.0' 27.3
030407-112 7-Apr-03 1.0'.2.0' 31.4
SS-55 030407-113 7-Apr-03 Off-1.01 22.
030407-114 7-Apr-03 1.0'-2.0' 8.2
030407-115 7-Apr-03 2.0'-3.0' 5.68
SS-56 030407-116 7-Apr-03 0.0'-1.0' 4.57
SS-57 030407-118 7-Apr-03 0.01-1.01 3.23
SS-58 030407-119 7-Apr-03 0.01-1.01 2.26
SS-59 030407.108 7-Apr-03 0.0'-1.0' 91.3
030407-109 7-Apr-03 1.0'-2.0' 18.4
SS-60 030407-106 7-Apr-03 0.0'-1.0' 8.02
SS-61 030407-104 7-Apr-03 0.01-1.01 7.38
SS-62 030407-103 7-Apr-03 0.01-1.01 3.
SS-63 030407.102 7-Apr-03 0.01-1.01 6.75
SS-64 030407.099 7-Apr-03 0.0'-1.0' 4.17
SS-65 030407-100 7-Apr-03 0.01-1.01 6.71
-
SS-66 030407-101 7-Apr-03 0.0'-1.0' ND>1.92
.. ......... .... Level.. .......
er-Once,
.7
Note; =not analyzed EPA=US Environmental Protection Agency ND=not detected above detection limit indicated
b gs=below ground surface mg/kg=milligram per kilogram ppm=part per million
DEQ=Oregon Department of Environmental mg/L=milligram per liter SPLP=Synthetic Precipitation Leaching Procedure
TCLP=Toxicity Characteristic Leaching Procedure
I=Sample number prefix:5927-
2=Composite Sample
3=Reference Levels based on DEQ Suggested Default Background Concentrations for Soil(October 2002),unless otherwise indicated
4=TCLP Regulatory Level(40 CFR 261.24)
Bold=Detected concentration exceeds Reference Level
Updated:5/22/2003 MSM Page 5 of 6
File Name:5927-Table-1--R.1-Soil-Rslts.xls HAHN AND ASSOCIATES,INC.