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SFCTIOM 4
ANALYSIS _OF LARGE PARTICLE DEPOSITION
4.1 PROCEDURE
This section describes the procedures followed and the
results obtained from the analysis of dry-deposition due to
gravitational'settling alone. As discussed in section 2, the
results of this analysis should provide a lower limit prediction
to the total mass of heavy metals which have been deposited
in the flat terrain areas within the Palmerton Valley.
The calculations of deposition were performed through the
use of the lonq term version of the Industrial Source Complex
model {ISCLT). This model is described completely in the ISC
Model User's Guide8. The ISC model is a gaussian dispersion
model designed to make predictions of either air concentrations
or total deposition resulting from multiple and varied emission
sources. Because of computational difficulties related to a
varying depositing surface this model is incapable of predicting
deposition in complex terrain: thus the analysis was performed
in the flat areas at the bottom of the valley.
The ISCLT model requires both a meteorological and source
emissions data base for input. Each of the data sets used in
this analysis were described in detail in section 3. Since
the goal of this analysis was to predict the total dry-
deposition due to gravitational settling over the entire 80
yr. life of the plant, the data sets need to represent what
had occurred during this time frame.
In general, the source data was divided into 3 separate
time periods: (1) the 1st 50 yrs. of operation, (2) the next
20 yrs. of operation, & (3) the last 10 years of operation.
Each of these periods represents a distinct configuration of
sources during which emissions could be considered relatively
uniform. In constructing the emissions inventory used in
the model, the emissions from a given source were considered
separately for each of the 3 time periods. Thus a single
physical source would appear 3 separate times, in the inventory,
if it had existed during the entire 80 years of the plant's
operation. The emissions for each source in the inventory
represents the total mass of material emitted by the source
during the particular time period. Thus, summing the emissions
from each of the sources listed in the inventory would equal
the total mass of a given pollutant emitted by N.J. Zinc
during its operational life.
-43-
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In addition to the amount of mass that has been emitted
by a source, data regarding the size distribution of the
particles is needed. Information such as percentage of the
total mass residing in a particular size fraction, settling
velocities specific to size fractions, and reflection
coefficients are necessary inputs to calculate the total mass
of material deposited. The emission rate as well as particle
size distributions for the various sources were supplied by
the Company. Settling velocities and reflection coefficients
were derived from the data supplied.
As described in section 3 the meteorological data represents
a two year (1978 & 1979) mixed data set. Hourly average wind
speed and direction were taken from a meteorological tower in
the Palmerton Valley located between the East and West plants.
Since neither cloud cover/ceiling height nor lateral turbulent
intensity was measured at this location atmospheric stability
was derived using cloud cover and ceiling height data measured
at the Allentown NWS site and wind speeds from the Palmerton
Valley Tower. Although cloud cover & ceiling height data are
generally regional in nature, & thus usually representative
over a distance on the order of the distance between the
plant and the Allentown airport, the fact that the Blue
Mountain Ridge is located between the two monitoring sites
makes the mixture of the data sets less than ideal. It is
not possible to determine, with available data, the amount of
error introduced into the determination of stability class by
mixing these data sets.
The ISCLT model reguires, as input, a joint frequency
distribution of wind speed, wind direction and stability
class. This distribution was constructed from the two year
meteorological data base. As such, when processed through
the model the results are representative of the average
meteorological conditions which occurred over the two year
period. Since the analysis being performed is to be
representative of an 80 yr. period the use of a 2 yr. data
set would seem inadequate. However, since the scales of motion
important to the transport & dispersion process are of a
period much shorter than 2 yrs., a two year period of record
should represent, fairly well, the important features of the RO
yr. period. Certainly, there will be some error introduced
but it shouldn't be very significant.
-44-
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Deposition calculations were performed on eight rectangular
grids located aloncj. the floor of the Palmerton Valley. Each
of the eight grids has a resolution of 200 m. Running from
the southwest to the northeast the 8 grids, when placed
adjacent to one another, form a continuous grid which extends
approximately 2.5 km southwest of the West plant and 4 km
northeast of the east plant. Thus, the grids extend a
total of approximately 12 kms aloncj the valley floor. The
two grids at the southwest end and the two grids at the
northeast end of the valley have a width of approximately 1
km. The four grids which cover the area including and between
the two plants have a width of approximately 2 kms. The
total area covered by the deposition grids is approximately
16.5 km2.
4.2 RESULTS OF LARGE PARTICLE DEPOSITION ANALYSIS
The results of the analysis, for each of the four metals,
are summarized in figures 4-1 thru 4-4. Each of these figures
presents deposition isopleths, for a given metal, over the
total area examined with the model. In certain areas,
particularly in the vacinity of the sources, the gradients of
deposition are so great that the change in deposition values
between adjacent isopleths is much greater than in other
areas. It was not possible to keep the isopleth intervals
constant over the entire grided area for a particular pollutant
or from pollutant to pollutant. Therefore care should be
exercised in interpreting these figures.
The following Table (4-1) summarizes the range of deposition
values predicted to have resulted from the operation of the
plant. Appendix A presents the numerical output for all
receptor locations modeled for each of the four metals.
TABLE 4-1
RANGE OF PREDICTED LARGE PARTICLE DEPOSITION
METAL
CADMIUM
LEAD
ZINC
COPPER
RANGE OP
DEPOSITION
(gms/m2)
0.2 - 448.0
0.5 - 576.0
11.0 - 18,984.0
0.017 - 119.0
LOCATION OP
MAXIMUM DEPOSITION
UTM - (KM)
„ 4517. 6N x 450. 5E
4516. 2N x 446. 5E
4515. 7N x 445. 8E
4517. 6N x 450. 5E
-45-
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As one would expect, for near ground level sources, the
location of each of these maxima were predicted to be within
the boundaries of the plant. It is interested to note that
th» Cd and Cu maxima are associated with the East plant,
while the Zn and Pb maxima are associated with the West plant.
The minimum values, for three of the metals were predicted to
occur at the western extreme of the grid while the minimum
value for Pb occurred at the eastern edqe.
In order to provide a quantitative measure of the total
area, within the calculation grid, which has experienced a
certain degree of deposition, a cumulative area distribution,
for each pollutant, of deposited material was determined and
is presented in the following table.
TABLE 4-2
CUMULATIVE AREA DISTRIBUTION (large Particle Deposition)
POLLUTANT
CADMIUM
LEAD
ZINC
COPPER
1 DEPOSITION
GREATER THAN
(gm/m2)
ino
50
25
10
5
1
0.2
100
50
20
10
5
1
0.5
5000
2500
1000
500
100
50
11
50
25
5
1
.5
.1
.017
% OF
MAXIMUM
DEPOSITION
22
11
5.5
2.2
1.1
0.?
0.04
17
3.6
3.5
1.7
0.8
0.17
0.08
26
13
5.3
2.6
0.5
0.3
0.06
43
21
4.2
.9
.4
0.09
0.01
TOTAL
AREA
(Km2)
0.75
1.3
2.4
4.5
7.0
13.8
16.5
1.2
1.5
4.1
5.8
10.8
15
16.5
0.75
1.5
3
4.5
11.8
15.3
16.5
.4
.6
2
5.3
10.5
13.8
16.5
% OF TOTAL
GRIDED AREA
4.5
7.9
14.5
27.0
42
83
100
7.2
9.0
25
35
65
91
100
5
9
18
27
72
93
100
2.4
3.6
12
32
64
84
100
-46-
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Graphical representations of the data presented in this
table are given in figures 4.5 - 4.9. These figures provide
information related to how large an area is affected by a
particular range of deposition values. For example, if it
were determined that all areas having experienced a deposition
of greater than "x" gm/m2 of Cd would need treatment, Figure
4-7 should prpvide a lower bound on the total area needing
treatment. Additionally, figure 4-5 provided a comparison
among the 4 metals. To provide a comparison as to how those
deposition patterns varied among pollutants deposition values
for each pollutant were normalized to that pollutants
predicted maximum. Examining figure 4.5 shows that the
functional relationships are guite similar for each of the
pollutants. The only metal which presents a slightly different
response is Copper. It can be seen from figure 4.5 that the
amount of Copper deposition occurring over a given area falls
off more quickly with total area than for other pollutants.
This is easily understood by examining the isopleth diagrams
for each of the metals (figures 4-1 thru 4-4). It can be
seen from these figures that copper is the only pollutant
which is emitted from lust the west plant: the other three
pollutants are emitted from hoth plants: thus causing a more
widespread problem.
In general, the isopleths in the areas to the west of the
West plant and to the east of the Bast plant are oriented
perpendicular to the valley axis.* *For Copper that is true
in all directions out from the east plant. Thus, it can be
expected that deposition values in these areas should continue
to decrease with distance from the two plants in a fairly
predictable fashion.
For all pollutants except Copper, it can be seen that
for the area between the two plants the isopleths exhibit a
tendency to run parallel with the valley axis. This is not
an unexpected result considering the manner in which the two
plants interact. That is, total deposition from each plant
is simply additive in the long-term. Consider, as one moves
from the East plant west towards the West plant one can
expect deposition values to initially fall with distance
until the effects from the West plant become comparable to
the East plants effects. At this point one should expect a
very small change in deposition values for some distance.
Then as one approaches the Bast plant one should expect
deposition values to start increasing.
-47-
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DT AHc.A GKLAinH
-48-
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IUIML
-49-
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TOTAL AREA (km2)
o
m
O
z
3
N,
3
10
-50-
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TOTAL AREA (km2)
O
m
O
z
«o
3
-51-
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TOTAL AREA (km2)
-52-
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The manner in which the magnitude of deposited material
changes with distance (deposition gradient) varies widely
across the valley floor. With the exception of Copper the
general nattern of. deposition gradients throughout the valley
is quite similar for each of the metals. In general, the
gradients appear to he greatest as one travels along the
valley axis and guite small cross-valley. This tendency is
also seen in the Copper isopleth diagram. For both zinc,
copper and lead the largest deposition gradient was found to
occur in the area northwest of the east plant. The longest
cadmium deposition gradient was predicted to occur northwest
of the west plant. However, in the areas to the Northwest of
the east plant a secondary maximum was found.
In the area of Palmerton which extends from the western
edge of the residential area to 8th street and from Columbia
Ave. to the base of the Blue Mt. very little variation in Zn,
Cd and Pb deposition should be found. This will not be true
for copper since there has never been any copper emissions
from the west plant. Rather, as one travels west from the
east plant a fairly regular decrease in copper deposition has
been predicted. The magnitude of this decrease is guite
similar to that found as one travels upvalley toward Walkton.
With the exception of the fairly uniform residential
area, described above, the most gradual change in deposition
occurs in the area to the east of the east plant for zinc,
cadmium and lead. In the areas to the west of the west plant
substantially higher gradients are expected for these metals.
-53-
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SECTION 5
ANALYSIS OF SMALL PARTICLE DEPOSITION
5.1 PROCFDURE
This section describes the procedures followed and the
results obtained from the analysis of long term ground level
concentrations of the four heavy metals. As discussed in
Section 2, it is beyond the scope of this study to perform a
direct prediction of small particle dry-deposition. Rather,
calculations of atmospheric concentrations were made and
used as a surrogate measure of both the expected hot spots
and the spatial variability of soil concentrations resulting
from small particle deposition.
The calculations of ground level air concentrations
(GLC) were performed through the use of the LONGZ model.
This model is described completely in the LONGZ Model User's
Manual9. The LONGZ model is a gaussian dispersion model
designed to make predictions of long-term GLC for multiple
and varied emission sources in areas where the terrain is
mountainous. Although the model is capable of making
predictions on the windward side of terrain, it is incapable
of predicting GLC on the lee side of a terrain feature.
Therefore, the analysis performed with the LONGZ model was
restricted to the areas north of the Blue Mountain ridge.
Since windward side calculations are possible with LONGZ the
study area was not restricted to the valley floor, as was
the large particle deposition analysis, but covered a
substantial area within the Palmerton Valley. The area
covered extends approximately 10 kms from the Blue Mountain
Ridge line north and approximately 31 kms from the town of
"anoning east.
The LONGZ model requires the input of both meteorological
and source emissions data. Bach of the data sets used in
this analysis were discussed in detail in Section 3.
The input source data set used in the LONGZ analysis is,
in general, the same as that used in the ISCLT modeling. The
major difference relates to the form of the emissions parameter.
-54-
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In Che TSCLT analysis emissions were entered as the total
mass of material emitted by a qiven source during one of the
3 time periods. In the LONG?, analysis our interest is not
in predicting total deposition, but in predicting the average
GLC from a given source, during a given time period, weighted
to account for the different lengths of the 3 time periods.
Therefore, the emissions parameter appropriate to each source
is egual to the mass per unit time emitted times the ratio of
the number of years within the particular time period (either
50 vrs, 20 yr's. or 10 yrs) to the total years of operation
(i.e., 80 yrs.). In addition, since it is not the purpose of
this analysis to predict total deposition, it was not essential
to input any data related to the particle size distributions
of the emissions. Although/ use of this data in the LONGZ
model would have provided a means by which to account for the
loss of mass due to large particle settling, it's use would
have required that the analysis be restricted to the flat
areas within the valleys. As discussed in previous sections,
present day operational models are not capable of accounting
for deposition due to settlina in areas of varying terrain
elevation. It is important to realize that the error introduced
by ignoring settling would tend to produce overpredictions.
Given this error, it was felt that the prediction of
concentrations over the large complex terrain area, would be
more useful than producing more accurate predictions in the
much restricted flat terrain areas of the valley floor.
Therefore, for the purposes of this analysis, the total mass
of emissions was assumed to remain suspended.
The meteorological data set used in this analysis is
identical to the data used in the ISCLT modeling. A discussion
of the merits of this data set was presented in section 4.
The points made in that discussion also apply to the prediciton
of GLC by the LONGZ model.
GLC calculations were performed on a single rectangular
grid havina a resolution of 1.0 km. This grid was designed to
provide coverage over a substantial portion of the Palmerton
Valley. The southwest corner of the grid is located
approximately 2 kms. southwest of the town of Ashville at UTM
coordinate 437000mE X 4514000mN. The grid extends 10 km north
into an area approximately 0.5 km south of Jim Thorpe. To the
east the qrid extends 31 kms into an area approximately 3 km
northwest of Chaoraan. The northeast corner of the grid is
located in an area approximately 2 km east of Rossland.
Since it is not possible to make calculations on the lee side
of terrain the above described qrid was reduced to exclude
all grid points located south of the ridge line of the Blue
-55-
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Mounta in.
310 km2 minus
Mountain; i.e..
The total area covered by
60 km2 of area located
250 km2.
the prediction grid
south of the Blue
is
5.2 RESULTS OP SMALL PARTICLE DEPOSITION ANALYSIS
Results of the GLC analysis, for each of the four metals,
are summarized in Figures 5-1 thru 5-4. These figures present
the BO yr. average concentration isopleths, covering the
entire prediction grid for each of the oollantants. The
units of the numbers which label each isopleth are pico-gms/m^
or 10~6ug/m3. In certain areas, particularly in the vicinity
of the sources, the gradient of: GLC is so great that the
change in GLC between adjacent isopleths is much greater
than in other areas. Therefore, care should be exercised in
interpreting these figures. Also, examining the figures will
show isooleths extending onto the leeside of the Blue Mountain,
That portion of an isopleth which covers leeside terrain
should be considered an anomaly of the isoplething process:
having no physical meaning.
The following table (5-1) summarizes the maximum and
minimum GLC's predicted to have resulted from the operation
of the plant. Appendix A presents the numerical output for
all receptor locations modeled for each of the four metals.
As can be seen from Table 5-1. The range of predicted GLC,
for each of the metals, spans 3 orders of magnitude.
TABLE 5-1
RANGE OF PREDICTED GROtJND LEVEL CONCENTRATIONS
METAL
Zinc
Cadmium
Lead
Copper
RANGE OF
CONCENTRATIONS
(ug/m3)
0.17 - 439
0.002 - 2.9
0.004 - 7.5
0.0004 - 0.9
LOCATION OF
MAXIMUM CONCENTRATION
DTM - (Km)
4516N x 446E
4518N x 451E
4516N x 447E
4518N x 451E
-56-
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As was the case with the larqe particle deposition
analysis, Cd and Ca maxima arv associated with operations of
the East plant, while 7,n and Pb maxima are associated with
the West Plant.
In order to provide a auantitat i
-------
Graphical representations of the data presented in this
table are aiven in fiaures (5.5 - 5.9). These figures provide
information related to how large an area is effected by a
particular range of GLC's.
Figure 5.5 orovides a comparison of the distributions of
effected areas among the various pollutants. To provide for
the comparison, the GLC's of each distribution are normalized
to the pollutants predicted maximum. This figure shows the
distributions for the four pollutants to be very similar. It
can be seen that as area increases the minimum GLC effecting
that area drons-off very rapidly.
It can be seen from figures 5.1 thru 5.4 that the general
pattern of GLC is quite similar for all metals. However, due
to the lack of Cu emissions from the West plant, certain
patterns which are consistently found with the other metals
are not found with Cu. General results found from the small
particle deposition analysis are discussed below.
-58-
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% OF AREA GREATER THAN
-59-
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TOTAL AREA (km2)
NO
O
A
O
o>
O
00 O N3 A Ot 00
o o o o o o
N)
o
o
NO
ro
o
ND
A
O
K>
O
O
-60-
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TOTAL AREA (km2)
O O
0
-61-
-------
TOTAL AREA Ckm2)
-62-
-------
TOTAL AREA (km2)
-63-
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Examining figure 5-1 thru 5-4, one can see a substantial
bulge in the isooleths for each of the four metals, along a
northeast azimuth from the center of the East plant. This
indicates that the highest GLC, at any given radial distance,
in the area to the east of the East plant, will be found on
this northeast radial. This result should not be unexpected
since the greatest frequency of occurrence of a given wind
direction has been shown in figure 2-1 to be out of the
southwest quadrant. Obviously, this particular area is
prime for taking soil samples.
In the area to the north of the two plants one can again
see a bulge in the isopleths, although not guite as pronounced
as that previously discussed. Considering the fact that a
number of the sources are elevated, one would expect GLC's
to be higher in an area of elevated terrain; that is, assuming
one holds all other variables constant. Looking at the area
where the bulge is occurring it can be seen that the terrain
in that area is somewhat higher than the terrain to either
side. One would expect this terrain ridge to be responsible
for the bulge in the isopleths.
Comparing the isonleths in the areas to the west, north
and east of the two plants it seems clear that more of the
pollutant mass is transported to the east than to either of
the other two directions. For example for cadmium, looking
at the area to the east, one must travel 15 km, from the
center of Palmerton, to encounter the .017 ug/ra3 isopleth
Traveling west and north this isopleth is encountered at a
distance of only 4.5 km and 5.0 km respectively.
Considering the height of the terrain on the northern
slope of the Blue Mountain one would expect relatively high
GLC to be predicted. Examining the figures it can be seen
that, in general* the GLC's are significantly higher on this
terrain than at other areas within the valley at similar
distances from the plants. The only exception to this is the
area within the plant boundary where the highest predicted
GLC's occur. These very localized high GLC's are due to
close in impacts from near ground level sources.
-64-
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As was the case with the large particle deposition
analysis, isonleths in the area to the west of the West
plant and to the east of the East plant are oriented
pernendicular to the valley axis. Of course, in the case of
Copper, this is true in all directions out from the East
plant. Thus, it can be expected that deposition values in
these areas should continue to decrease with distance from
the two plants in a fairly predictable fashion.
Also, as was the case for the larae particle analysis,
for all nollutants except Copper it was found that for the
area between the two plants the isopleths exhibit a tendency
to run parallel with the valley axis.
The manner in which the magnitude of GLC changes with
distance in different areas of the study grid is quite similar
to what was found for the large particle deposition. In
qeneral, the gradients are greatest along the Valley axis,
and guite small cross-valley. The largest concentration
gradients are found to be northwest of the West plant for Pb
and Zn and northwest of the East plant for Cd and Cu.
Very little variation in GLC was found between the two
plants for all metals except Cu. Also on the high terrain
directly across from the plants a mild variation in GLC has
been predicted. This appears to be due to the steepness of
the terrain causing plume impaction to occur at approximately
the same distance from the plant at various elevations.
-65-
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SECTIOM 6
SUMMARY AND CONCLUSIONS
followina presentation is a summary of the major
conclusions reached resulting from a consideration of all
analyses performed both qualitative and auantitative-
. Conside'rina the wind analyses as well as the quantitative
larqe and small particle deposition analysis it can be
concluded that the majority of mass deposition has occurred on
the valley floor not the valley side walls.
. Due to the expected trajectory during stable drainage
conditions one would expect large deposition to have occurred
of the "gap".
. As has been seen in other studies high ground level
concentrations, and therefore expected high deposition, can
he found on the leeside of a mountain ridge. Transport over
a mountain ridge is accomplished most easily during neutral
and unstable conditions of atmospheric stability. Since
these conditions are most frequent under a northwest flow the
areas due southeast of both plants on the southern slope of
the mountain should have experienced the largest leeside effect,
. Considering both the wet and dry deposition analyses
one would expect those areas to the northeast and southwest
of each plant to have experienced the greatest average
deposition of any of the areas within the valley.
. For those areas outside of the Valley, with the exception
of the area within the gap, enhanced dispersion due to
transport up and over the mountain will have dramatically
diffused the plumes causing an expected low gradient of
deposition in those areas.
-66-
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. Malor Cadmium and Conner deposition is related to
operations tbac ha>'« occurred at the East plant: while West
plant operations were responsible for more 2inc and lead
deposition then were East plant operations.
. Relative to a Pollutants predicted large particle maxima
the most widespread metal, is lead followed in order by zinc,
cadmium and Conner.
. Relative to a pollutants predicted small particle maxima
the most wide'spread metal is cadmium followed in order by
lead, copper and zinc.
. With the exception of Copper, soil concentrations between
the two plants are expected to be hiqh and fairly uniform
(i.e.. small gradients of deposition).
. Small deposition gradients should be expected as one
travels cross-valley: while high deposition gradients should
be found alonq the valley's axis.
. The largest gradients of deposition should be expected
to occur in the vicinity of a specific pollutants maximum.
. In general, greater heavy metal soil concentrations can
be expected in the area east of the East plant than in the
area west of the West plant. However, in this area a higher
gradient of concentration should be found than in the area
east of the Sast plant.
-------
RRFEPENCRS
1. r.iu H-T, and Lin J-T Laboratory Simulation of Plume
nisnersion from Lf»ad Smelter in G)over, Missouri, in
Neutral and Stable Atmosphere - EPA-A50/3-75-006-
Anril 197 s.
2. Lavevy P.. Bass A., Strimritis D., Ventiatran A..
Greene B.R., nrivas P.J., Roan B.A. EPA Complex
Terrain Modelinq Program First Milestone Report - 1981.
3. Simpson, C.L. Sone Measurements of the Deposition of
Matter and Its Relation to Diffusion from a Continuous
Point Source in a Stable Atmosphere. HW-69292 Rev.
Pichland, Washinqrton. 1961 26 pp.
A. Islitzer, M.F., and DumbawId, R.K. Atmospheric Diffusion-
Deposition Studies Over Flat Terrain. Presented at the
National Meeting of the American Meteorological Society.
Jan 22-2* New York, New York. 1962.
5. Chamberlain, A.C. Aspects of Travel and Deposition of
Aerosol and Vapor Clouds. A.R.R.E., HP/R 1261 H.M.S.O 1953.
6. Silvestris, M. Untitled Letter to Shoener, E. Sept. 13, 1984
7. Silvestris, M. - Cimorelli, A. Personal Communication
Sent. 17, .1984.
8. lowers, J.F., Biorklund. J.R.. Cheney, C.S., Industrial
Source Complex (ISC) Dispersion Model User's Guide (Volume
I) EPA-450/4-79-030 December 1979.
9. Bjorklund, J.R., Bowers, J.F., User's Instructions For
the Short2 and Lonqz Computer Programs (Volume I) EPA-903/
9-004a March 19«?2.
-68-
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Appendix A- Modeling Results
Tables A.I thru A.8 present the result of the modelinq
runs that were made to accomolish both the larqe and small
particle deposition analyses. The maximum deposition or
concentration found in each of the tables has been underlined
-69-
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-------
SUBJECT: Quality Assurance Onsite Sampling Evaluation of the Palmerton
Zinc NPL Site Investigation
FROM: Kenneth W. Brown
Botanist
Exposure Assessment Research Division
TO: Ed Shoener
Remedial On-Scene Coordinator
Superfund Program, Region 3
Evaluation Team; Kenneth W. Brown, Team Leader, EAD, EMSL-LV?
Betty C. Malone, Staff Associate, Techlaw Inc.; Jeffrey Lapp,
Associate Consultant, Techlaw Inc.; Kathy Lauchner, Quality Assurance
Specialist, University of Nevada - Las Vegas.
Persons Contacted; Ed Shoener, Remedial On-Scene Coordinator, Region 3;
Eric J. Slavin, Project Manager, R.E. Wright Associates; Tom Nobile,
R.E. Wright Associates; Fred Rider, R.E. Wright Associates; Ian Milner,
R.E. Wright Associates.
Purpose; The purpose of this onsite inspection was to evaluate
the sampling effort at Palmerton and the sample bank at the R.E. Wright
Associates facility in Middletown, Pennsylvania. It was conducted to
document the extent to which procedures identified in the sampling
protocol are being followed with respect to implementing specified
field tests, chain-of-custody, record keeping, quality assurance,
sampling procedures and techniques, and sample handling methods.
The sampling effort at Palmerton was evaluated for 1) personnel;
2) general facilities; 3) sampling equipment; 4) sampling methods and
procedures; 5) security; 6) record keeping and documentation; and
7) chain-of-custody.
The sample bank at Middletown was evaluated for 1) personnel;
2) general facilities; 3) sample preparation and mixing equipment;
4) security; 5) record keeping and documentation; and 7) chain-of-custody.
Concurrently with the audit of the sampling procedures and
techniques, an inspection was made by representatives of Techlaw Inc.
for evidentiary and chain-of-custody procedures. The results of this
audit will be reported to you by Techlaw Inc. In addition, comments
concerning chain-of-custody are identified in Attachment 1, page 20,
part VII.
EAD:BROWN:x2214:sk 12/3/85
EAD:MEIER
-------
The onsite evaluation consisted of interviewing sampling and
sample bank personnel, observing sample collection and documentation
methods and techniques, observing field instrumentation, touring and
observing the sample preparation procedures at the sample bank
facility, inspecting field and sample bank logs, completing the
attached checklist (Attachment 1), and conducting a debriefing with
sampling and regional personnel to identify and review the team's
findings.
Observations; It is EPA's policy that before any environmental
measurements are collected that an approved quality assurance (QA)
plan be in effect. A QA plan was not available for the team's review
and comment. Prior to the initiation of the definitive study,
the team recommends that a QA plan be officially approved by the
appropriate Region 3 personnel.
As shown in Attachment 1, there were no serious deficiencies
noted. The onsite team was impressed with the caliber of personnel,
equipment, sample bank facility, and the dedication and commitment
of the sampling team personnel to meet the goals and objectives of this
study* The general consensus was that the problems identified below
were minor in nature.
. Sample bank personnel should wear disposable gloves when
preparing and handling soils.
. A number of procedural changes were identified. The changes
which are noted below should be documented by writing an
addendum to the sampling protocol:
1. Document that the orientation of the sampling site photo-
graph is always to the North.
2. Describe the site information (i.e., site I.D. code and
date), that is placed on the photograph prior to its
attachment to the site description fora.
3. Describe the type of information (i.e., profile descrip-
tion, sand, silt, clay, depth of each component) being
obtained from the soil core descriptions.
4* Document that the vegetation sample refrigeration
storage procedures do not meet chain-of-custody require-
ment*. Describe procedures that are being used.
5. Describe the computer data base procedures (i.e., data
storage, security of disks and hard copy outputs) that
are being used for the sample bank logbook.
6. Document that five gram (5g) soil aliquots are now being
prepared for analysis instead of the two gram (2g)
aliquots identified in the soil sampling protocol.
-------
The evaluation team hopes this information and the comments in
Attachment 1 will be useful to Region 3 and R.E. Wright Associates.
The team would like to thank the Palmerton sampling team and the sample
bank personnel for their cooperative and positive attitude and for their
dedication to the success of this project.
cc: w/attachment
Kathy Lauchner, ERC, UNLV
David McNelis, ERC, UNLV
Betty C. Malone, Techlaw Inc., Denver
Jeffrey Lapp, Techlaw inc., Region 3
Robert Laidlaw, NEIC
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TABLE OF CONTENTS
Page
I. General Information i
Facility/Site Information 1
Sampling Team Information 2
Audit Team Information 2
II. Organization and Personnel Management Structure 4
III. General Facilities 6
IV. Quality Assurance/Quality Control (QA/QC) Plan -
Sampling Protocols 9
V. Soil Sampling 12
Grid Soils 12
VI. Sample Duplicates, Splits and Decontamination Blanks 18
VII. Sample Bank and Chain-of-Custody 20
VIII. On-site Work Performance 26
Appendices
I Palmerton Zinc NPL Site Investigation Soil Sampling Protocol . 1-1
II Palmerton Zinc NPL Soil Sampling Location (Site) 1-2
iii
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SAMPLING AUDIT
I. GENERAL INFORMATION
Purpose: The purpose of this sampling evaluation is to document the extent to
which procedures identified in the sampling protocol and/or quality assurance
plan are being followed with respect to implementing specified field tests,
chain-o&custody, record keeping, quality assurance, and sampling procedures and
techniques, and sample handling methods.
Audit Dates: 11 / 04 / 85 to 11 / 06 / 85 /
Facility/Site Information
Facility/Site Name: Palmerton NPL Site
Facility/Site Address or Location: (The New Jersey Zinc Co., Inc., Palmerton, PA
18071 - Field Site), (R. E. Wright Associates, 3240 Schoolhouse Road,
Middletown PA 17057 - Sample Bank
Facility/Site Telephone No.: (215) 826 - 8945 Palmerton, PA
(717) 944 - 5501 Middletown, PA
Facility Contact (Name/Title): Eric J. Slayin_- R* E. Wright Associates
Project Officer
Function/Description of Facility/Site: New Jersey Zinc Co* Office is location
of pre-audit meeting. Sampling crews operate out of a large van. R. E. Wright
Associates facility is location of sample preparation area (Sample Bank).
Media Being Sampled:
|7| Soil
Q Water
III Air
|~| Other (describe)
-------
Sampling Team Information
Team Contact (Name/Title/Affiliation): Eric J. Slavin, Project Manager,
R. E. Wright Associates. 3240 Schoolhouse Road, Middletown, PA 17057
(717) 944-5501.
Team Members (Name/Title/Affiliation):
1. Bruce Williman, Soil Scientist. R. E. Wright Associates
2. Dan Hoffman, Crew member, R. E. Wright Associates
3. Tom Mobile, Soil Scientist. R. E. Wright Associates
4. Fred Rider, Crew member, R. E. Wright Associates
5.
6.
7.
8.
9.
10.
Team Contact Telephone No.: (717) 944 - 5501 FTS -
Team Contact Address: R. E. Wright Associates, Inc.
3240 Schoolhouse Road
Middletown, PA 17057
Audit Team Information
Team Leader (Nane/Title/Affiliation): Kenneth W. Brown. Botanist,
U.S. Environmental Protection Agency. Las Vegas, Nevada
-------
Team Members (Name/Title/Affiliation);
1. Betty C. Malone, Staff Associate, Techlaw Inc.
2. Jeffrey Lapp, Associate Consultant, Techlaw Inc.
3. Kathy Lauchner, Quality Assurance Specialist, University of Nevada—Las Vegas
4. .
5.
6.
7.
8. _____
9.
10.
Team contract telephone No.: (702) 798 - 2214 FTS 545 - 2214
Team contract address: U.S. Environmental Protection Agency, Environmental
Monitoring Systems Laboratory, P.O. Box 15027, Las Vegas. Nevada 89114
Techlaw Inc., 12600 West Coifax Avenue, Suite C-310
Lakewood, Colorado 80215
(303 233-1248
University of Nevada
Environmental Research Center
Las Vegas, Nevada 89154
(702) 739-3382
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II. ORGANIZATION AND PERSONNEL - MANAGEMENT STRUCTURE
Project Director: (EPA, Ed Shoener) (R. E. Wright Associates, Eric J. Slavin)
Project Coordinator: Eric J. Slavin
Laboratory Analysis and QA Officer: unknown
Statistical Analysis and Data Management: unknown
Sample Bank Officer: Eric J. Slavin
Project Director: (Individual responsible for overall technical effort):'
Eric J. Slavin
1. Sample Preparation: (Individual(s) responsible for preparing samples for
analysis). Name, Media, and Experience.
Responsible Individual, Eric J. Slavin
Chemist, Ian Milnes
Laboratory Technician, Annette Prins
2. Do personnel assigned to this project have the appropriate educational/exposjd
to successfully accomplish the objectives of this program?
|xj Yes |_| No Comments: Each field team supervised by a. soil scientist,
sample preparation supervised by a laboratory chemist.
3. Are curriculum vitae available for all sampling personnel?
C! Ye9 © No Comments: These were not made available for review.
-------
4. Is the sampling organization adequately staffed to meet project commitments
in a timely manner?
Yes No Comments:
5. The Projects Quality Assurance Officer: unknown
Comments: Mr. Slavin oversees performance in sampling, chain-of-custody
and sample preparation.
6. Was the Quality Assurance Officer available during the evaluation?
|~~| Yes |xj No Comments:
7. Was the Project Director available during the evaluation?
Ixl Yes I I Mo Comments: Both Ed Shoener and Eric Slavin
8. Are the same personnel performing on-site sampling procedures as those
described in the Sampling Plan?
Q Yes \—\ No Comments: Sampling team members were not identified
in sampling plan. Eric J. Slavin was identified in a variety of corres-
pondence* Dealing with the Palmer ton NPL site study.
If not, have replacement personnel been trained for the position they have
assumed?
l__l ^ea lil No Comments: This was not evident.
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III. GENERAL FACILITIES
The field work is headquartered in Palmerton, PA at a facility where equipment A
and samples are stored. Sample team personnel, work out of this facility. \
1. Do the sampling facilities have adequate workspace?
|xj Yes |__] No Comments: The sampling team uses a large van
2. Is the sampling facility maintained in a clean and organized manner?
|xj Yes |_| No Comments: _____________________________________
3. Are hoods provided to allow efficient work with dusty or volatile materials?
l_l Yes I*J No Comments: Van was not equipped with a hood. Hoods
were noted to be at the sample bank facility. ___
4. Are adequate facilities provided for separate storage of samples, i.e.,
prepared sample blanks and standards, including cold storage?
|xj Yes |_| No Comments: Ice chests are provided for storage, however
a specific temperature is not maintained.
5. Are the temperatures of the cold storage units recorded daily in logbooks?
Q Yea jjcj No Comments: Ice cheats are utilized. Inside temperature
was not recorded. . _
-------
6. Are contamination-free work areas provided for the handling of samples?
|xj Yes |_ No Comments: As much as possible, the transfer of samples
from sampling tool to containers is being completed onsite. However, steri-
lized containers are utilized. Samplers wear gloves and decontamination
blanks are collected.
7. Are swipes collected from working areas, i.e., workbench tops, to determine
decontamination efficiency?
|_| Yes |xj No Comments: This was not being done. We recommend that
Eric Slavin initiate the use of swipes at the sample bank.
8. Are swipe results noted in logbooks?
I I Yes |x| No Comments: See number seven above.
9. Is the sampling facility utilizing distilled and/or demineralized water?
|x| Yes I"! No
If yes, is: the conductivity of distilled and/or demineralized water
routinely checked and recorded?
|x| Yes PI No
Can the sampling supervisor document that trace-free water is available for
preparation of standards and blanks?
Ixl Yes |""| No
What is the source of the distilled and/or demineralized water?
Comments: Water is purchased. The quality is checked at the sample bank.
-------
10. Are waste disposal policies/procedures adequate?
|x| Yes I I No Comments:
11. Are balances used at the sampling facility?
Ixl Yes |~! No
If yes, are they located away from draft and areas subject to rapid
temperature changes?
|xl Yes |~| No
Calibrated on a routine basis?
lie I Yes I I No Comments:
Is calibration information recorded in logbooks?
Ix:! Yes l"~| No Comments:
12. Is the sampling facility secure? |xj Yes |_| No
Are sample containers, tags, sampling equipment, forms (i.e. chain-of-
custody, site description, shipping) and logbooks properly secured?
Ijtl Yes PI Ho Comments:
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IV. QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) PLAN-SAMPLING PROTOCOLS
1. Is a QA/QC Plan available for review?
|_| Yes 211 No Comments: A QA/QC plan will be perpared for second
phase or definitive study.
2. Does the QA/QC Plan discuss the objectives of the sampling program to be
performed and how the sampling approach(es) will satisfy program require-
ments?
|| Yes |xj No Comments: Only in sampling plan or protocol.
3. Are levels of precision and confidence levels identified in the QA/QC Plan?
I I Yes 1x1 No Comments:
4. Does the QA/QC Plan and/or sampling protocol describe the system to be used
for identifying, logging and tracking all samples obtained?
|x| Yes I | No Comments:
-------
5. Are sampling methods, including sampling equipment and procedures discussed
in the QA/QC Plan and/or sampling protocol?
Yes No Comments:
4
6. Does the QA/QC Plan and/or sampling plan identify criteria used for select-
ing the media (e.g., soil, etc.) to the sampled?
Yes No Comments:
7. Does the Sampling Plan identify criteria used for selecting sampling points
for each media?
Yes No Comments:
8. Does the QA/QC Plan and/or sampling protocol provide detailed information
identifying the size, number, locations, and types of samples to be
collected?
x Yes | No Comments:__
10
-------
9. Does the QA/QC Plan and/or the sampling protocol describe procedures, for
and the extent of compositing or other sample reduction methods?
Yes No Comments:
10. Are the types of sample containers and methods and materials used to clean
these containers identified in the sampling plan?
~1 Yes 1 I No Comments:
11. Are field decontamination procedures and materials for sampling equipment
discussed in the Plan?
lie) Yes PI No Comments: In the sampling protocol.
11
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V. SOIL SAMPLING
Grid Soils
NOTE: All soils will be collected at predetermined sites (Soil Sampling Proto-
col, Appendix I). The sites selected for this sampling effort are identified
in Appendix II. In addition, soil samples will not be composited at some sites
while at other sites soils will be collected at depth increments ranging from
2.5 cm to 15.0 cm in depth.
1. Does the sample bank logbook show that samples collected from identified
grid intersections were submitted for analysis?
|xj Yes |_J No Comments: The sample bank log is computerized.
Data is recorded on two disks and a hard copy is available.
Are soil samples placed in Whirl-Pakm polyethylene containers?
Ixl Yes I I No Comments:
3. Is a noncontaminating (Cd, Pb, Zn, Cu) corer (0.75 inch diameter) being
used to collect the soil?
|_| Yes |xj No Comments: The corer contains copper. A coter
that didn't contain any of the above metals could not be obtained. This
was approved by Mr. Ed Shoener. ^____________________________
4. Are the samplers wearing polyethylene gloves when collecting soil samples?
|x~l Yes |~| No Comments: ___
12
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5. After collection is the corer being washed with tap water and rinsed with
DDI water?
Yes I I No Comments:
6. Are sample containers properly labeled?
jjcl Yes | ] No Comments:
7. Do site description forms and/or field log books show exact sampling locations?
lil Yes l_l No Comments: The site description form is used in
conjunction with a photograph of the actual site samples. (Photo
orientation is always to the northO.
Are date and time of collection recorded?
lie! Yes |H No Comments:
Are all notations on the site description form addressed?
\~x\ Yes |~| No Comments: One description form (audited) was missing^
an address. Correlation between the site I.D. code and the aerial photo-
graph produced the address.
13
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8. Are four 15 cm deep soil cores collected from a 6 meter diameter circle at
each designated sampling location (see Appendix II, page 1)?
|xj Yes |_| No Comments: The collection procedures were being done
accurately.
9. If obstructions prevented the collection of samples at a specific site and/or
a circular sampling configuration was not used, does the site description
form and/or field logbook identify the obstruction, the reason for moving
the sampling location and/or the configuration used?
|xj Yes |__| No Comments: A site description form and photograph
identifies and shows the area sampled.
10. Are sampling teams using aerial photographs to identify sampling sites?
Ixl Yes I I No Comments:
11. If the sampling site was moved, is the site properly identified on the aerial
photographs?
|j[| Yes |_J No Comments: A soil scientist is properly identifying
the actual sampling location on the aerial photographs. .
12. Were four soil cores composited (see Appendix II for locations)?
Ixl Yes PI No Comments:
14
-------
13. At the following locations have 2.5 cm depth increments down to 30 cm been
collected?
Yes No Comments:
BH34 BW32 Comments: Site BZ34 has been sampled correctly. The
BN34 BW36 remaining sites are still to be sampled.
BQ32 I BZ34
BQ36 CA27
BT34 CF34
14. Are the 2.5 cm Depth Increment Location noted on the site description forms/
field logbooks, and/or sample bank logbooks?
|jc| Yes |_) No Comments: The 2.5 cm depth increment location
(samples) is logged in the sample bank logbook,
15. Are 15 cm depth increments (0-15 cm and 15-30 cm) being collected at the
following locations?
\~x\ Yes |~"| No Comments:
AH23 BT52 Comments: Both depth increments are logged in the sample
AS34 CN54 bank logbook as PABF48 and PABF48-13.
BF48 CX34
BJ24 CZ66
BT19 DJ34
15
-------
16. Are the 15.0 cm depth increments location noted on the site description
forms/field logbooks and/or sample bank logbooks?
Yes No Comments:
17. At the following locations have four individual samples been collected?
NOTE: Not to be composited.
lil Yes I—i No Comments:
B029 BV38 Comments: The CF46 site is indicated in the sample bank.
BR33 BX30 logbook as PACF46W, PACF46E, PACGA6N and PACF46S.
BR38 CF46
BS33 CI34
BU33 CJ50
13. Are the individual sample locations noted on the site description forms/
field logbooks, and/or sample bank logbooks?
Ix"! Yes HI No Comments:
19. Are sod layers being encountered?
|jcj Yes |~j No Comments: Vegetation samples are being collected
and archived. The storage of these samples do not meet chain-of-custody
requirements* Mr, Ed Shoener (EPA) has been informed.
16
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If yes, are the sod layers being removed from Che soil sample, packaged in
a polyethylene container, properly labeled and stored for possible analysis?
Yes No Comments:
20. Were performance and container contamination checks completed? (See Soil
Sampling Protocol Attachment 3, Appendix 1).
|xj Yes |_| No Comments: Performance procedures were adequate to
avoid contamination.
21. Were any changes made in the sampling procedures:
|x[| Yes |__| No Comments: Vegetation samples were not being stored
under approved chain-of-castody procedures.
If yes, were these procedures properly identified and recorded?
IZ1 Yes l_l No Comments: An addendum to the protocol showing the
following is recommended.
1. Computer data base used for the sample bank logbook.
2. Five gram (5 g) soil aliquots are being prepared for analysis instead
of 2 g aliquots.
3. Polaroid photographs are taken of the sampling site. Photograph is
always oriented to the north.
4. Vegetation samples are not being stored as described.
17
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VI. SAMPLE DUPLICATES, SPLITS AND DECONTAMINATION BLANKS
1. Are duplicate samples being collected at the following locations?
Ixl Yes IH No Comments:
AK26 BT32 Comments: Duplicates logged in sample bank logbook as
A030 I BT46 | PABY29A and PABY29; and PABT46 and PABT46A.
BP30 I BY29
BQ33 DL78
BQ34 DP34
2. Are duplicate samples recorded on the site description forms/field logbooks,
and/or sample bank logbooks?
|aH Yes f"l No Comments:
3. Are splits from the following identified sampling sites, being prepared?
Ixl Yes in No Comments:
AY34 CB34 Comments:
BR34 CB42
BT35 CD24
BT70 DD70
BV35 DP82
18
-------
Are the split samples correctly identified in the sample bank logbook.?
lit I Yes I I No Comments:
5. Are samples that will not be submitted for analysis (see Appendix 2) properly
identified in the sample bank logbook?
Yes No Comments:
5. Are decontamination blanks (one for every 20 soil samples) being collected?
Ixl Yes I I No Comments:
7. Are field and sample logbooks kept current, complete and up-to-date?
IZI Yes U No Comments: The field logbooks are the site description
forms.
3. Were any changes made in the procedures and/or methods for collecting and
preparing duplicates, splits, and blanks?
Yes Ixl No Comments:
If yes, were these changes properly recorded?
tea No Comments:
19
-------
9. Are "standard soil" samples being prepared at the sample bank?
LI Yes LI No Comments: A "standard" soil was sent to R. E. Wright
Associates. This soil may not be used because of low metal levels. Use of
QC material "soils" should be fully documented in the sample bank logbook.
20
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VII. SAMPLE BANK AND CHAIN-OF-CUSTODY
NOTE: All tags for this sampling program are accountable documents, as
such they must be properly filled out and maintained in a secured environ-
ment.
1. Has a sample custodian been assigned to receive all samples?
|7| Yes |~| No Comments: Mr. Slavin
2. Does the custodian carefully inspect the condition of sample containers
and/or packages upon receipt?
|7j Yes |_] No Comments: Good practices were observed during sample
inspections. _____
3. If damaged or leaking containers and/or packages with broken seals are
received, is this fact documented?
171 Yes |""| No Comments:
4. a. Are sample containers and/or packages inspected to see if the sample
tag is intact?
Ill Yes Q No
b. If the tag is missing, is the Information recorded in the logbook
or on a data sheet?
|7j Y«« |~j No Comments: Information concerning all samples
are recorded on the site description forms*
21
-------
5. a. Does the sample custodian check to ensure that the information (i.e.,
sample number, date, sampling location, on the sample label match that
on the chain-of-custody form?
|:c| Yes |~| No
b. If discrepancies are found between the label and the chain-of-custody
record, what actions are taken to resolve the problem?
Comments: During this audit the sample custodian had to ask the
sampling team for missing information. The sampler had to refer to
the aerial map to recollect site description information. If problems
such as this is not detected initially, resampling may have to be
initiated.
c. Are discrepancies noted in the sample and logbook?
|~| Yes |i| No
6. Is a separate sample bank number assigned to each sample received?
IZI Yea Q No
Is this number recorded in the log book along with the other information
describing the sample?
I El Yes U No Comments:
7. Is a sample label or tag attached to each sample container?
lil Yes Cl No Comments:
22
-------
8. At a minimum, has the following information been completed on each sample
label or tag?
|jcj Collector's name
|]c| Date and time of collection
|3c| Place of collection (site code)
Comments: Sample collector was identified on the site description form.
9. Are all samples stored in a clean and secure area?
Ixl Yes P! No Comments:
10. Are samples properly prepared?
lie I Yes H No Comments:
11. Are sample holding times being recorded?
| is | Ye» Qj No Comments: The time of collection and the time the
samples are sent to the analytical laboratory are recorded in the sample
bank log.
23
-------
12. Do sample bank records show the transfer and receipt of samples? (i.e.
current custodian).
Yes I No Comments:
13. Is the following information being recorded in field logbooks, sample
bank logbooks and/or on site discription forms and questionnaires?
Yes Nto
lil Q Project Name and Project Number
1211 Q Purpose of sampling (i.e., quarterly sampling, resample to
confirm previous analysis, initial site visit, etc.)
jx] |~1 Date and time each sample was collected
J£J Q Blank, duplicate and split sample identification numbers
J£J |~] Sample description including type (i.e., soil, etc.)
P| |x[| Preservation method for each sample
Cl Cl Weather conditions at time of sampling (Did not observe this)
lil Cl Photographic log identifying subject, reason for photograph, date,
time, direction in which photograph was taken, number of the picture
on the roll
Rl Cl Sample destination (To Analytical Laboratory)
|x| P| Analyses to be performed on each sample
[x| P] Reference number from all forms on which the sample is listed
~" ~" or labels attached to the sample (i.e., chain-of-custody, bill
of lading or manifest forms etc.)
|}[j Q £«•*(•) of sampling personnel
lil Cl Signature of person(s) making entries on each page
|it| Q Archived samples, including nonsieved materials (i.e. soils)
24
-------
Comments: Photographs are attached to the back of the site description
form.
14. Is a chain-of-custody record completed for all samples collected?
|x"| Yes I I No Comments:
15. Is the following information completed on each chain-of-custody record?
Yes No
|x"| |_J Sample identification number
|£| |~| Sample collector's signature
li! Cl Date and time of collection
lil Cl place and address of collection
lil l_l Shipper's name and address
lil U Name and address of organization(s) receiving sample
|xj |__| Signatures and titles of persons involved in chain-of-possession
Commentfl:
16. Does a sample analysis request sheet accompany all samples on delivery to
the laboratory sample custodian (sample bank)?
l""| Yes l""| Mo (See Comments)
25
-------
If yes, has the following information been completed on each sample analysis
request sheet?
|__| Name of person receiving sample I
|_| Laboratory sample number
|__| Analyses to be performed
|~1 Collector's name, affiliation name, address and phone number
Q Date and time of sampling
|~| Location of sampling
Q Special handling and/or storage requirements
Comments: Did not observe this.
17. Are custody seals being used on sample transport containers (commercial)?
PI Yes PI No Comments: Did not observe this.
26
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VIII. ON SITE WORK PERFORMANCE
1. Indicate sampling team performance in the following areas observed during
the on-site audit. (NOTE: Identify poor work practices and violations of
protocol under comments.)
Work Practice Good Fair Poor
Sampling technique |jc| |~| |~|
Safety procedures |~| |]c| |~|
Forbidden personal practices (e.g., _ __ _
smoking, eating in forbidden areas) |xj |_| |_|
Equipment use/maintenance/calibration/ |lc| |~| |~|
storage?
Comments: Vegetation samples were not stored in a secured freezer. It
was felt that sample bank personnel should wear gloves during sample
preparation.
In addition to the observations given, one individual suggested that
the data base being used to log in the samples be set up in a manner by
which the samples could be catagorized by depth increaents (i.e., logged
in order in which the samples were collected).
Verification of samplea may be much easier if saaple logging was
accomplished in a catagorized fashion.
27
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SUBJECT:
FROM:
TO:
Special On-Site Laboratory Evaluation of Soil and Environmental
Chemistry Laboratory, Pennsylvania State University, State College,
Pennsylvania, for Inorganic Analysis on December 4, 1985.
John W. Fowler
Chemist
Toxics and Hazardous Waste Operations Branch
Quality Assurance Division
Edward Shoener
U.S. EPA Region 3
841 Chestnut Building
Philadelphia, PA 19107
An on-site at the Pennsylvania State University was conducted on
December 4, 1985. Procedures to be used in the analysis of Palmerton Zinc
samples were reviewed by the on-site team.
The laboratory personnel and equipment are adequate to meet the requirements
of the Palmerton project. Comments and suggested additional quality control
procedures can be found within the body of the following report. These comments
and suggestions were discussed with Mary Kay Amistadi of the Pennsylvania State
laboratory.
An evidentiary audit was conducted simultaneously by the Contract Evidence
Audit Team (CEAT) TechLaw. Their findings will be provided in a separate
report.
Attachment
cc: (w/attachment)
Patricia Krantz, Deputy Project Officer, Region 3
QAO:FOWLER:2115:CS-124-85:12-24-85
QAO:Pearson
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL MONITORING SYSTEMS LABORATORY-LAS VEGAS
P.O. BOX 15027. LAS VEGAS, NEVADA 89114-5027 • 702/798-2100 (FTS 545-2100)
DEC 2 7 1995
SUBJECT:
FROM:
TO:
Special On-Site Laboratory Evaluation of Soil and Environmental
Chemistry Laboratory, Pennsylvania State University, State College,
Pennsylvania, for Inorganic Analysis on December 4, 1985.
John W. Fowler
Chemist
Toxics and Hazardous Waste Operations Branch
Quality Assurance Division
Edward Shoener
U.S. EPA Region 3
841 Chestnut Building
Philadelphia, PA 19107
An on-site at the Pennsylvania State University was conducted on
December 4, 1985. Procedures to be used in the analysis of Palmerton Zinc
samples were reviewed by the on-site team.
The laboratory personnel and equipment are adequate to meet the requirements
of the Palmerton project. Comments and suggested additional quality control
procedures can be found within the body of the following report. These comments
and suggestions were discussed with Mary Kay Amistadl of the Pennsylvania State
laboratory.
An evidentiary audit was conducted simultaneously by the Contract Evidence
Audit Team (CEAT) TechLaw. Their findings will be provided in a separate
report.
Attachment
cc: (w/attachment)
Patricia Krantz, Deputy Project Officer, Region 3
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Laboratory: Pennsylvania State University. State College, Pennsylvania
Date: December 4, 1985 _
Type of Evaluation: Special Inorganic
Contract Number: N/A
Contract Title: Palrcerton Zinc NPL Site Investigation
Personnel Contacted:
Name
Title
Mary Kay Amistadi
Mary Long
Laboratory Evaluation Team:
Chemist
Manager of Merkle Laboratory
Name
John W. Fowler
Steve Markham
Keith Aleckson
Bill Ryhne
Ellen Holder
Title
Team Leader. EMSL-LV
Region 3 Representative
Technical Expert, LEMSCO
Evidence Auditor, TechLaw
Evidence Auditor, TechLaw
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Summary of Laboratory Evaluation
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A. Procedural Changes the Laboratory Agreed to Implement
The following comments refer to deficiencies noted In the Laboratory
Evaluation Checklist (Attachment 1).
1. A recommendation was made to keep a logbook for sample digestions,
telephone conversations, and other Information dealing with this project.
2. EPA QC standards should be analyzed after the calibration curve is
established to verify the accuracy of the standards.
3. A control chart for Cd, Pb, Zn, and Cr results on the Hagerstown soil
should be established to monitor trends in the data.
4. A standard and blank should be analyzed after the last sample in an
analysis run. This la to ensure the validity of the calibration throughout the
run.
5. The balance should be checked with a Class S weight with each batch
of samples weighed.
6. All Instrument printouts should be dated and initialed.
7. A SOP for the sample digestion procedure should be prepared. A copy
of the SOP should be placed in the project file. Also, a list of references
for the analytical method should be placed in the project file.
8. The first set of reference standard digestates should be reanalyzed
using the new IL Vldio 22 with Smith-Hieftje background correction.
9. Someone besides the analyst should also review the data before it is
sent out.
B. Issues to be_Resolved by the Project Officer/Deputy Project Officer (PO/DPO)
1. The data user should request that copies of the raw data be included
with the analytical results. This will aid data review at the Region.
2. Standard reference materials should be digested and analyzed by the
procedures to be used on the Palnerton samples. This will establish the
effectiveness of the laboratory procedures. Standard Reference Material 1645,
River Sediment, from NBS is one possible material.
C. Review of Quarterly Blind Performance Evaluation Samples (QB)
Approximately 30 grams of a well characterized performance evaluation
sample have been sent to R» E. Wright, Associates for shipment to the labora-
tory as a blind check. The material was collected at a smelter site at Ruston,
Washington. Analytical results have not yet been reported by the Pennsylvania
State laboratory*
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D. Other Issues
Analysis for K, Ca, Mg, and Na on the Palmerton samples will be conducted
at the Merkle laboratory. The Merkle laboratory analyzes soil samples for
agricultural purposes. Procedures are adequate to reach the level of accuracy
and precision required for this use. Results from the Merkle laboratory should
be considered semi-quantitative by the data users.
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Attachment 1
Laboratory Evaluation Checklist
I. Organization and Personnel (Page 1 of 2)
ITEM
Laboratory or Project Manager (Individual
responsible for overall technical effort)
Name: Dr. Baker
Exhibit B, page 1, Section C-3
Inductively Coupled Plasma Emission
Spectroscopist
Name: N/A
Experience: 1 year minimum requirement
Exhibit A, page 4, Section 7 a
Flameless Atomic Absorption Spectroscopist
Name: N/A
Experience: 1 year minimum requirement
Exhibit A, page 4, Section 7b
Inorganic Sample Preparation Expert
Name : Mary^ Kay Ami s t adi /Mary Long^
Experience: 3 months minimum requirement
Exhibit A, page 4, Section 7d
Plane and Cold Vapor AA Spectroscopist
Name: N/A
Experience: 9 months minimum requirement
Exhibit A, page 4, Section 7c
Cyanide Analyst
Name: N/A
Experience: 6 months minimum requirement
Exhibit A, page 4, Section 7e
Do personnel assigned to this project have the
appropriate background to successfully
accomplish the objectives of the program?
YES
X
X
X
NO
COMMENT
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I. Organization and Personnel (Page 2 of 2)
ITEM
Quality Assurance Supervisor
Name: Dr. Baker
Glassware Preparation Technician
Name: N/A
Is the organization adequately staffed to
meet project commitments in a timely manner?
Were all personnel involved with the CLP
analysis available during the evaluation?
(List those not present.)
YES
X
NO
X
X
COMMENT
See Comment 1.
Dr. Baker
Additional Comments
1. A recommendation was made to establish data review procedures by someone
other than the analyst.
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II. Sample Receipt and Storage Area
ITEM
Are written Standard Operating Procedures
(SOPs) developed for receipt and storage
of samples?
Exhibit G, page 2, Section 2
Is the appropriate portion of the SOP available
to the sample custodian at the sample receipt/
storage area?
Are the sample shipping containers opened in a
manner which prevents possible laboratory
contamination?
Are soil and cyanide samples that require
refrigeration at 4°C stored in such a way
as to maintain their preservation?
Exhibit 0, page 5, Section 5.1 and Exhibit F,
page 1
Are adequate facilities provided for storage of
samples, Including cold storage?
Is the temperature of the cold storage recorded
daily In a permanent record?
Are temperature excursions (+4*C) noted and
are appropriate actions taken* when required?
Are the sample receipt /storage and temperature
records maintained in a manner consistent with
GLP?
Are standards stored separately from sample
digestates?
YES
X
X
NO
X
X
COMMENT
See comment 1 .
N/A
N/A
See Comment 2.
N/A
N/A
N/A
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II. Sample Receipt and Storage Area (Continued)
ITEM
Has the supervisor of the individual maintaining
the notebook/bench sheet/logbook personally
examined and reviewed the notebook/bench sheet/
logbook periodically, and signed his/her name
therein, together with the date and appropriate
comments as to whether or not the document
is being maintained in an appropriate manner?
Do the digested cases examined contain LCS's,
duplicates, and matrix spikes?
Cases , ,
Exhibit E, Sections 6, 7 and 9
YES
NO
X
COMMENT
N/A
Additional Comments
1. A sample receipt SOP should be written* The SOP should include processing
of chain-of-custody information, assignment of laboratory ID numbers,
sample storage until analysis, etc.
2. A recommendation was made to separate documents from sample digestates.
This was primarily to preventcontamination of the documents or their
distraction by acid fumes.
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III. Sample Preparation Area
When touring the facilities, give special attention to: (a) the
overall appearance of organization and neatness, (b) the proper maintenance of
facilities and instrumentation, (c) the general adequacy of the facilities to
accomplish the required work.
ITEM
Is the laboratory maintained in a clean and
organized manner?
Does the laboratory appear to have adequate
workspace (120 sq. feet, 6 linear feet of
unencumbered bench space per analyst)?
Are contamination-free areas provided for trace
level analytical work?
Are the hoods in good condition and functional?
Are chemical waste disposal policies/procedures
well defined and followed by the laboratory?
Does the laboratory have a source of distilled/
demlneralized water?
Is the conductivity of distilled/demlneralized
water routinely checked and recorded?
Is the analytical balance located away from draft
and areas subject to rapid temperature changes?
Has the balance been calibrated within one year
by a certified technician?
YES
X
X
X
X
X
X
X
X
X
NO
COMMENT
Checked monthly
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III. Sample Preparation Area (Continued)
ITEM
YES
NO
COMMENT
Is Che balance routinely checked with the
appropriate range of class S weights daily
before use and are the results recorded in
a logbook?
See comment 1
Is the sample preparation portion of the SOP
available to the analyst at the sample
preparation area?
Are unexplred standards used to prepare
instrument calibration standards?
Are fresh analytical standards prepared at a
frequency consistent with good QA?
Exhibit E. page 3, Section 1
Are chemicals and standards dated upon receipt?
Are reagent Inventories maintained on a
flrst-in, first-out basis?
Are reference materials properly labeled with
concentrations, date of preparation, and the
identity of the person preparing the sample?
Standards not
dated or initialed
Is a spiking/calibration standards preparation
and tracking logbook(s) maintained?
Exhibit G, page 2, Section 4
Are the primary standards traceable to EPA
standards where possible?
Exhibit G. page 2, Section 4
See comment 2.
Do the analysts record bench data In a neat and
accurate manner?
Exhibit G, page 5
10
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Ill, Sample Preparation Area (Continued)
ITEM
Is Che SOP for glassware washing posted at the
cleaning station?
Is a UV-Visible spectrophotometer operational
and properly maintained?
Is the mercury analyzer operational and well
maintained (i.e., properly vented)?
Are sufficient cyanide distillation apparatus
available to routinely analyze all samples
within the required holding period?
Is the pH of the samples recorded and available
for data review?
Exhibit D, page 2
Are digestion logbooks/bench sheets maintained
in a neat and organized manner?
Exhibit G, page 5
Is an adequate drying oven available with a
temperature measurement device?
Has the supervisor of the individual maintaining
the notebook/bench sheet personnally examined and
reviewed the notebook/bench sheet periodically,
and signed his/her name therein, together with
the date and appropriate comments as to whether
or not the notebook/bench sheet is being
maintained in an appropriate manner?
YES
X
X
NO
X
X
COMMENT
N/A
N/A
N/A
See comment 3
N/A
11
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III. Sample Preparation Area (Continued)
Additional Comments
I. The balance should be checked with a Class S weight along with each batch
of samples weighed out. The measured weight of the Class S weight and certi-
fied weight should be recorded along with the sample weights.
2. A recommendation was made to check the accuracy of instrument calibration
solutions against an EPA QC ampule before sample analysis. A control window
of 90 to 110 percent is used in the contract laboratory program.
3. A digestion log should be kept. This log should include samples and QC
materials digested, reference to procedure, weights, final volumes, and person
performing the digestion.
IV. Sample Analysis Instrumentation
A. ICP/DS Instrumentation
Not Applicable
12
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B. Atomic Absorption (AA) Spectrometer
Manufacturer Model Installation Date
AA
ID t
Data System
AA
ID #
Data System
AA
ID 9
Data System
AA
ID 1
Data System
Instrument
Laboratories
Internal
system
Vidio
22
September 1985
ITEM
Is there a methods manual available to the
operator?
Are element specific SOP's listing instrument
conditions, background correction, instrument
conditions, and required instrument sensitivity
available to the analyst?
Are calibration results (i.e., sensitivity)
kept in a permanent record so that instrument
performance can be measured over time?
YES
X
X
NO
X
COMMENT
Sensitivity
checked but not
recorded.
13
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B. Atomic Absorption (AA) Spectrometer (Continued)
ITEM
Is a permanent service record maintained in a
logbook?
Has the instrument been modified in any way?
Is the Instrument properly vented?
Is the unit equipped with flaneless accessory?
Are Lvov platforms used?
Is an auto-sampler used?
Are EPA or instrument manufacturer matrix
modifiers used?
Is the unit equipped with electrodeless
discharge lamps?
Is service maintenance by contract?
Is preventatlve maintenance applied?
YES
X
X
X
X
X
X
NO
X
X
X
X
COMMENT
Maintenance log
should be
established.
Not used on flame
IL matrix
modifiers used.
Not required for
elements analyzed.
Additional Comments
14
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V. Data Handling and Review
ITEM
YES NO
COMMENT
Are manual data calculations spot-checked by a
second person?
Do records Indicate that appropriate corrective
action has been taken when analytical results
fail to meet QC criteria?
Is a Laboratory Information Management System
(LIMS) used?
Manufacturer/Model: IBM/PC
Is the operation of the LIMS validated with a
test set of data and is the data maintained
for on-site inspection?
Calculations
performed by
computer are
trivial.
Additional Comments
15
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VI. Quality Control Manual and SOP'a
ITEM
Does the laboratory maintain a Quality Control
Manual?
Exhibit G, page 2
Does the manual address the important elements
of a QC program, including the following:
a* Personnel?
b. Facilities and equipment?
c. Operation of instruments?
d. Documentation of procedures?
e. Preventative maintenance?
f. Reliability of data?
g. Data validation?
h. Feedback and corrective action?
Are files of outdated SOP's stored for reference?
YES
X
X
NO
X
X
X
X
X
X
X
COMMENT
N/A
Additional Comments
A quality control plan for the laboratory analysis should be established for
this orolect.
16
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VII. Summary
A. Summary Cbecksheet (Page 1 of 1)
ITEM
YES NO
COMMENT
Do responses to the evaluation indicate that
project and supervisory personnel are aware of
QA/QC and its application to the project?
Have responses with respect to QA/QC aspects of
the project been open and direct?
Has a cooperative attitude been displayed by all
project and supervisory personnel?
Have any QA/QC deficiencies been discussed
before leaving?
Is the overall quality assurance adequate to
accomplish the objectives of the project?
Have corrective actions recommended during
previous evaluations been implemented? If
not, provide details in Section VII.B.
N/A
17
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