&EPA
United States
Environmental Protection
Agency
EPA-600/R-05/123b
 September 2005
      GUIDANCE FOR EVALUATING
      LANDFILL GAS EMISSIONS
      FROM CLOSED OR
      ABANDONED FACILITIES:
      Appendix C

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                                     EPA-600/R-05/123b
                                       September 2005
   GUIDANCE FOR  EVALUATING
LANDFILL GAS EMISSIONS FROM
     CLOSED OR ABANDONED
       FACILITIES: Appendix C
                       by
             Thomas Robertson and Josh Dunbar
           Environmental Quality Management, Inc.
             Cedar Terrace Office Park, Suite 250
             3325 Durham-Chapel Hill Boulevard
             Durham, North Carolina 27707-2646
          EPA Contract No. 68-C-00-186, Task Order 3
            EPA Project Officer: Susan A. Thorneloe
            U.S. Environmental Protection Agency
            Office of Research and Development
          Air Pollution Prevention and Control Division
         National Risk Management Research Laboratory
          Research Triangle Park, North Carolina 27711
            U.S. Environmental Protection Agency
            Office of Research and Development
                Washington, DC 20460

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                                  Abstract
This document provides guidance  to  superfund remedial project  managers, on-scene
coordinators, facility owners, and potentially responsible parties for conducting an air pathway
analysis for landfill  gas emissions  under the  Comprehensive Environmental Response,
Compensation, and Liability Act, Superfund Amendments and Reauthorization Act,  and the
Resource Conservation and Recovery Act. The document provides procedures and a set of tools
for evaluating LFG emissions to ambient air, subsurface vapor migration due to landfill gas
pressure gradients, and subsurface vapor intrusion into buildings. The air pathway analysis is
used to evaluate the inhalation risks to offsite receptors as well as the hazards of both onsite and
offsite methane explosions and landfill fires.
                                        11

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                                 Foreword
   The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting
the Nation's land, air, and water resources. Under a mandate of national environmental laws,
the Agency strives to formulate and implement actions  leading to  a compatible balance
between human activities and the ability of natural systems to support and nurture life. To meet
this mandate, EPA's research program is providing data and technical support for solving
environmental problems today and building a science knowledge base necessary to manage
our ecological resources wisely, understand how pollutants affect our health, and prevent or
reduce environmental risks in the future.

   The National Risk Management Research  Laboratory (NRMRL) is the Agency's center for
investigation of technological and management approaches for preventing and reducing risks
from  pollution that threaten human health and  the environment. The focus of the Laboratory's
research  program is on methods and their cost-effectiveness for prevention and control of
pollution to air, land, water, and subsurface resources; protection of water  quality in public
water systems; remediation of contaminated sites, sediments and ground water; prevention
and control of indoor air pollution; and restoration of ecosystems.  NRMRL collaborates with
both  public and  private sector partners  to  foster technologies that  reduce the  cost of
compliance and to anticipate emerging problems. NRMRL's research provides solutions to
environmental problems by: developing and promoting technologies that protect and improve
the environment;  advancing scientific and engineering information to support regulatory and
policy decisions;  and providing the technical support  and information transfer to ensure
implementation of environmental regulations and  strategies at the national,  state,  and
community levels.

   This publication has been produced as part  of the Laboratory's strategic long-term research
plan. It is published and made available by EPA's  Office  of Research and  Development to
assist the user community and to link researchers with their clients.
                                       Sally Gutierrez, Director
                                       National Risk Management Research Laboratory
                                       in

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                            EPA Review Notice
This report has been peer and administratively reviewed by the U. S. Environmental Protection
Agency and approved for publication. Mention of trade names or commercial products does not
constitute endorsement or recommendation for use.

This document is available to the public through the National Technical Information Service,
Springfield, Virginia 22161.
                                 Disclaimer
   This guidance is intended solely for informational purposes. It cannot be relied upon to
create any rights enforceable by any party in litigation with the United States. This guidance
is directed to EPA personnel; it is not a final action, and it does not constitute rule making. EPA
officials may decide to follow the guidance provided herein, or they may act at variance with
the guidance, based on  site-specific circumstances. The guidance may be reviewed and/or
changed at any time without public notice.
                                        IV

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            Appendix C

             Example
Generic Quality Assurance Project Plan

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              EXAMPLE GENERIC
      QUALITY ASSURANCE PROJECT PLAN
                     for the
 APPLICATION OF GUIDANCE FOR EVALUATING
         LANDFILL GAS EMISSIONS AT
         CLOSED or ABANDONED SITES
           EPA Contract No. 68-C-00-186
               Task Order Number 3
            EQ Project No.  030177.0003
                  Prepared for

              Mrs. Susan Thorneloe
        U.S. Environmental Protection Agency
         Office of Research and Development
     Air Pollution Prevention and Control Division
   National Risk Management Research Laboratory
    Research Triangle Park, North Carolina 27711
                  Submitted by

ENVIRONMENTAL QUALITY MANAGEMENT, INC.
        Cedar Terrace Office Park, Suite 250
        3325 Durham-Chapel Hill Boulevard
        Durham, North Carolina 27707-2646
         (919) 489-5299 FAX (919) 489-5552
            Revision 0 - August 31, 2005

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      QUALITY ASSURANCE PROJECT PLAN:
   EVALUATING LANDFILL GAS EMISSIONS AT
           CLOSED or ABANDONED SITES
                 EPA Contract No.	
                 Work Assignment No:
EPA Remedial Project Manager: 	
                     Name                        Date
EPA WA Manager:         	
                     Name                        Date
EPA QA Officer:          	
                     Name                        Date
Contractor Proj ect Manager:   	
                     Name                        Date
Contractor QA Officer:       	
                     Name                        Date

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                              Table of Contents
   List of Appendices	2
   List of Figures 	3
   List of Tables	3
   List of Acronyms	4
   Distribution List	5

A. Project Management  	7
   A-l  Project Definition and Background	7
   A-2  Project Organization	8
   A-3  Project Task Descriptions	11
   A-4  Quality Objectives and Criteria	22
   A-5  Special Training/Certification	36
   A-6  Documents and Records	37

B. Data Generation and Acquisition Elements	39
   B-l  Sampling Process Design 	39
   B-2  Sampling Methods  	42
   B-3  Sample Handling and Custody  	43
   B-4  Analytical Methods	49
   B-5  Quality Control	55
   B-6  Instrument/Equipment Testing, Inspection and Maintenance Requirements	59
   B-7  Instrument Calibration and Frequency 	62
   B-8  Inspection/Acceptance Requirements for Supplies and Consumables	70
   B-9  Indirect Measurements 	70
   B-10  Data Management	72

C. Assessment/Oversight	73
   C-l Assessments and Response Actions	73
   C-2 QA Reports to Management	80

D. Data Validation and Use  	80
   D-l  Validation and Verification Methods	80
   D-2  Reconciliation with User Requirements	85

Appendix
   A.    Site Specific QAPP - TBD                                                  A-l

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                                List of Figures

A-l Project Organization Chart 	  9
A-2 Flow Chart for Assessing Air Impact by Modeling  	  12
A-3 Flow Chart for Assessing Vapor Diffusion from Groundwater 	  13
A-4 Idealized Project Schedule 	  23
B-l Chain-of-Custody Form	  45
B-2 Chain-of-Custody Report for Canister Samples  	  47
B-3 Example Nonconformance Report  	  61
C-l Field QA/QC Audit Outline	  74
C-2 Laboratory QA/QC Audit General Considerations	  75
C-3 Sample Corrective Action Report	  77
C-4 Sample Field Change Request	  79
D-l Data Package List 	  82
D-2 Data Package Document Inventory List	  83
                                 List of Tables

A-l Preliminary Target Analyte List  	  16
A-2 Summary of Data Collection Efforts	  20
A-3 Air Pathway Action Levels	  21
A-4 Field Sampling Summary for Each Site  	  29
A-5 Summary of Precision, Accuracy, and Detection Limits for VOC Analysis of Air
   Samples, Low-Level Sample Technique  	  32
A-6 Summary of Precision, Accuracy, and Detection Limits for VOC Analysis of Air
   Canister Samples, High-Level Sample Technique	  33
A-7 Summary of Precision, Accuracy and Completeness Goals for Physical Properties 	  34
B-l Summary of Sampling and Analytical Approach 	  40
B-2 Targeted Instrument Conditions for Analysis of VOCs  	  51
B-3 Guidelines for Minimum QA/QC Samples for Field Sampling Programs  	  57
B-4 Routine Preventative Maintenance Procedures and Schedules for Field
   Monitoring Equipment	  62
B-5 Target Calibration Concentrations and Quantitation Ions for COPC  	  66
C-l QA Reports to Management 	  80

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                               List of Acronyms
Acronym                           Definition
ARARs         applicable or relevant and appropriate requirements
ASTM          American Society of Testing and Materials
CCV            continuing calibration verifications
CERCLA        Comprehensive Environmental Response, Compensation and Liability Act
CFR            Code of Federal Regulations
CLU-IN         Hazardous Waste Cleanup Information
COC            chain of custody
COPCs         contaminants of potential  concern
DQA            data quality assessment
DQOs           data quality objectives
ELCT           electrolytic conductivity detector
ERTC           Environmental Response Team Center
FID             flame ionization detector
FRM            Federal reference method
GC/MS         gas chromograph/mass spectrometer
IS              internal Standard
LEL            lower explosive limit
LFG            landfill gas
LOI             limit of identification
MDL            method detection limit
MQL            method quantitation limit
MRL            method reporting limit
MS/MSD        matrix spike/matrix spike  duplicate
NIOSH         National Institute for Occupational Safety and Health
NIST            National Institute of Standards and Technology
NMOCs         nonmethane organic compounds
NSCEP         National Service Center for Environmental Publications
OSHA          Occupational Safety and health Administration
OVA            organic vapor analyzer
PE             performance evaluation
PID             photoionization detector
QAPP           Quality Assurance Project Plan
QA/QC         quality assurance/quality control
RDL            reliable detection limit
RPD            relative percent difference

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List of Acronyms (concluded)
Acronym                         Definition
RPM     remediation project managers
RRT     relative retention time
SARA    Superfund Amendments and Reauthorization Act
SCS     Soil Conservation Service
SOP     standard operating procedure
TAL     target analyte list
TCD     thermal conductivity detector
THC     total hydrocarbon concentration
TNR     toluene-normalized response
TOM     task order manager
UHP     ultra high purity
VOCs    volatile organic compounds

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                              Distribution List
   EPA Remediation Project Manager
   EPA Laboratory Manager
   EPA WA Manager
   EPA QA Manager
   Contractor Project Manager
   Contractor QA Officer
   Contact task order manager to determine the date of the most recent version of this QAPP.

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ELEMENT A - PROJECT MANAGEMENT
A.I Project Definition and Background
   EPA recently  developed a draft guidance document to assist remediation project managers
(RPMs), risk assessors, and others in assessing human health and safety concerns associated with
landfill gas (LFG) emissions at closed or abandoned landfill sites. The Comprehensive Environmental
Response, Compensation,  and Liability  Act (CERCLA) and the Superfund  Amendments  and
Reauthorization Act (SARA) mandate the characterization of all  contaminant migration pathways
from contaminated sites. At CERCLA landfills, characterization of the air pathway is often delayed
until the  cover systems are designed. Recently  there has  been  increased interest  in the use of
alternative (i.e., permeable) cover systems that may not adequately control LFG. In these cases, it is
necessary  to characterize the nature of the LFG emissions and  the risks that would result from
exposure. To address these concerns, a guidance document entitled Guidance for Evaluating Landfill
Gas Emissions at Closed or Abandoned Sites has  been developed. A fact sheet and the guidance is
available for viewing or downloading from EPA's Hazardous Waste Cleanup Information (CLU-IN)
Web site at http://cluin.org  (accessed August 2005). Hard copies are available free of charge from:
   U.S. EPA National Service Center for Environmental Publications (NSCEP)
   P.O. Box 42419
   Cincinnati, OH 45242-2419
   Telephone: (513) 489-8190 or (800) 490-9198
   Fax:(513)489-8695

   The task order manager (TOM) and RPM will  determine which sites are to be  selected. It is
anticipated that existing information will indicate if LFG is being  emitted from the landfill in an
uncontrolled manner, if there is a groundwater plume migrating offsite, if there are nearby offsite
structures, and if access to the site and nearly structures is assured.

   The primary purpose of the project is to provide the RPMs with information that will allow them
to determine if LFG controls are needed and if compliance with applicable or relevant and appropriate
requirements (ARARs) have been achieved. Field  work is a means to collect the information needed
to implement the procedures included in the guidance. Comparability of concentration data from site-
to-site is not anticipated. Still there needs to be a unifying level of acceptable uncertainty in order to
define measurement quality objectives. Data quality objectives are a starting point of an interactive
process, and they do not necessarily constitute definitive rules for accepting or rejecting results. The
measurement quality objectives have been defined in terms of standard methods with accuracy,
precision,  and completeness. These objectives are believed to be achievable based on method
specifications, instrument capabilities, historic data, and experience.

   The density of sample locations will be determined on a  site-specific basis. It is anticipated that
the number of samples will be statistically robust, and the  completeness goals  recognize that the
guidance techniques can be evaluated without collecting a massive number of samples. The study
design is such that the impacts of the LFG emissions on the residence closest to the  portion of the
landfill with the highest contaminant of potential concern (COPC) and methane (CH4) concentrations
are evaluated. Whether or not there are other offsite receptors that may be adversely affected by the
LFG emissions is not determined.

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   This generic Quality Assurance Project Plan (QAPP) will be used as a guidance document for
preparing site-specific QAPPs. This QAPP will be applied to all activities involving environmental
measurements. This document includes sections that detail the procedures that will be used to sample
and analyze LFG. Preparation of this QAPP follow EPA requirements as stated in the document EPA
QA/R-5 Requirements for quality assurance project plans (March 2001).
A.2 Project Organization
    The project organization chart is shown in Figure A-l.	is the TOM. She/he is
responsible for coordinating activities and for obtaining the staff and resources needed to complete
this project.	is the contractor project manager with primary responsibility for both
administrative and technical matters. This project is a collaborative effort between (organizations).
Close coordination  between the project participants will be  needed to  ensure that the QAPP
requirements  are understood and that all of the project objectives are met.

    The TOM has overall responsibility for ensuring that the proj ect meets EPA obj ectives and quality
standards. The TOM is also responsible for defining the scope of work and deliverables required for
the delivery order. She/he will ensure that the performance of assigned tasks addresses the quality
assurance (QA), quality control (QC), and chain-of-custody (COC) procedures specified in this
QAPP. She/he is responsible for selecting the landfill sites and for coordinating activities at them. The
TOM must review and approve the QAPP.

    The EPA  QA manager will be responsible for reviewing and approving the  generic and site-
specific QAPPs. The EPA QA manager may schedule audits at her/his discretion.

    The site laboratory manager is  responsible for directing all of the onsite activities including
obtaining equipment,  supplies,  and qualified personnel.  He/she will  assign duties  to  the site
monitoring and sampling team as required to complete the study effort in a cost-effective and timely
manner. The  site laboratory manager is responsible for organizing and deploying competent field
crews. He/she will communicate regularly with the TOM and proj ect manager to ensure that progress
is achieved and that expenditures are controlled. The sampling and monitoring team will include
persons that have the training and experience needed to carry out the activities described in the
generic and site-specific QAPPs. The sampling and monitoring field team leader is responsible for
documenting  compliance with the QAPP and standard operating procedures (SOPs). The field team
leader shall implement corrective  actions as needed and he/she shall report any sampling  or
monitoring issues that may affect data  quality to the quality assurance officer. The site laboratory
manager must review and approve the QAPPs.

    The contractor proj ect manager is responsible for preparing proj ect deliverables and for managing
the proj ect. She/he will ensure that the agreed project milestones budgets and schedules are achieved.
He/she will communicate regularly with the TOM, the Environmental Response Team Center (ERTC)
project manager, and the site-specific remedial project coordinators to ensure that the project and
QAPP is completed as planned. The project manager must approve the QAPPs.

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                                                  EPA Task Order Manager
  EPA Environmental
Response Team Center
   Project Manager
       Site Sampling and
        Monitoring Team
        Volatile Organic
           Analysis
      Organic Laboratory
           Manager
      Physical Parameter
           Analysis
        Site Laboratory
           Manager
EPA QA Manager
 EPA Remeadiation
Project Site Manager
                                   Health and
                                 Safety Officer
  Contractor
Project Manager
                                  QA Officer
                                                                 Chemist
                                                               Sampling and
                                                                Analytical
                                                                Specialist
                                                              Hydrogeologist
                                                             Data Reduction &
                                                             Info. Management
                                                                Specialist
                                                                                                 Document/Record
                                                                                                    Management
                                        Figure A-1.  Project Organization Chart
                                                                                                                                      o  -
                                                                                                                                      l-*5 K<
                                                                                                                                      oo o
                                                                                                                                      o> o
                                                                                                                                         (Jl

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   The RPM is responsible for providing background and historical information, site access, site
security, utilities, and health and safety training. The background information will include site plans,
topographic maps, historical sampling data, and so forth. The RPM is also responsible for defining
ARARs and acceptable risk ranges on a site-by-site basis. The RPM must approve the generic QAPP
and the site-specific QAPP applicable to his/her site.

   The QA officer will remain independent of the day-to-day activities and will have direct access
to the corporate executive staff as needed to resolve any QA disputes. In these roles she/he will:
   •  Maintain QA/QC oversight;
   •  Prepare and review QAPPs and amendments;
   •  Review and provide audit reports;
   •  Initiate, review, and follow-up on corrective actions;
   •  Approve QAPPs and amendments; and
   •  Participate in project meetings as directed.

   The QA officer shall be responsible for reviewing and approving the generic and site-specific
QAPP. The QA officer shall review the laboratory reports to determine if the methods and procedures
have been properly followed and documented. Discrepancies will, if feasible, be corrected, and
appropriate annotations will be recorded. Any variances that cannot be corrected will be flagged, and
the usefulness and limitation of the laboratory data will be ascertained.  The QA officer will conduct
field audits in order to verify that QAPP and  SOP requirements are being followed. The field audit
will be completed during the first two days  of each site investigation. Corrective actions will be
initiated from the field in order to minimize adverse impacts. Audit items will include:
   •  Verification of field instrument calibration,
   •  Duplicate reading of direct read instruments at 5 percent of locations,
   •  Predefined precision, accuracy, and completeness objectives,
   •  Review of Log Books,  and
   •  Verification of training.

   The sampling and analytical specialist is an expert that can be accessed by the field team.

   The document and record  manager is responsible for preparation of all reports and for filing all
material in the appropriate project file.

   The hydrogeologist is a subject area expert that will provide assistance  in evaluating the soil
properties and the nature and extent of any groundwater contamination.

   The data reduction and information  management specialist will be responsible for entering the
field and laboratory results into a data management system. The system will allow the concentration
gradients to be calculated and graphed accordingly.  The system will allow for statistical evaluation
and it will include flags and audit tails that will allow one to find the original information source.

   The technical staff for this project are  experienced employees  who possess the degree of
specialization and technical competence required to effectively  and efficiently perform the work
described herein. Each manager as shown on the organization chart is responsible for the qualification
and capabilities of the staff being selected and assigned to this project.

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A.3 Project Task Descriptions
    The air pathway evaluation procedures contained in the draft guidance document encompass
estimates of emissions to the ambient air and subsequent air dispersion and inhalation exposures.
Figure A-2 is a flow chart for assessing air impacts by modeling. Emission estimation procedures use
the LandGEM model1 along with LFG sampling to estimate the uncontrolled release of toxic and
nontoxic LFG constituents to the ambient  air. Ambient air dispersion is simulated using both
screening-level and refined models to estimate exposure point concentrations for both risk evaluation
purposes and for comparison with air pathway ARARs.2 In addition to an ambient  air exposure
evaluation, subsurface vapor transport  and intrusion into  aboveground structures must also  be
evaluated. Subsurface vapor intrusion into buildings can be caused by convective vapor transport (i.e.,
due to pressure gradients) and diffusive vapor transport from contaminated groundwater below the
structure. These exposure pathways are evaluated using a combination of modeling and sampling.
Figure A-3 is a flow chart for assessing the impacts from contaminated groundwater. The following
tasks will be completed during this project.

Task 1 - Preparation of QAPP
    In cooperation with the TOM and the EPA site laboratory manager, the contractor will prepare
a QAPP that specifies the type of data to be collected at each of the sites being  evaluated. Sites may
vary significantly in age, size, content, design, meteorology, topography, and so forth. Comparability
of concentration data from site-to-site is not anticipated.  The TOM and the RPM will determine
which site is being evaluated. The QAPP will  indicate (1) the specific data and information to be
collected at each site by EPA Regional personnel, (2) the field testing and sampling to be conducted
by the sampling and analysis team, and (3) the data and information to be collected and analyzed by
the contractor. A  site-specific QAPP will specify the sampling and analytical procedures to  be
employed as well  as the QA and QC procedures to be used  to ensure that the data obtained are of
sufficient quality and quantity for risk evaluation purposes. Each site-specific QAPP will act as a road
map for conducting site-specific data acquisition and site information retrieval.

Task 2 - Estimation of LFG Emissions
    For each site, historical data will be collected on the size of the landfill, the amount and type of
waste deposited, and the waste deposition  dates and frequencies. For sites that lack these data, the
volume of each landfill will be estimated based on the landfill dimensions; the total amount of waste
will be estimated based on a default value of the in situ waste density. Waste deposition frequencies
and distributions will also be approximated if historical data are lacking. From these data and the
distribution of wastes in the landfill or landfill cells, the LandGEM model will be  employed to
estimate the time-dependent LFG emissions over a residential exposure duration of 30 years for risk
evaluation purposes and over the appropriate averaging time(s) for the purposes of comparison with
any air pathway ARARs. The emissions of individual toxic components of the LFG will also be
          landfill Gas Emission Model, Version 3.01. U.S. EPA Control Technology Center,
   EPA-600/R-05/047. Available at http://www.epa.gov/ttn/catc/dirl/landgem-v302-guide.pdf
   (accessed August 2005).

          2Guidance for Evaluating Landfill Gas Emission at Closed or Abandoned Facilities,
   EPA-600/R-05/123a.

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c
Start
fc


^
w
Grid Sample
PIDandFID

Sample All
with PID and FID





                         End Ambient Air
                            Analysis
YES—
            Use LandGem Model
             and 90th Percentile
             Cones, to Estimate
            Emissions by Stratum
                and/or Vent
                                       Determine COPC
                                     90th Percentile Cones.
                                       for Each Stratum
                                         and/or Vent
  Construct
Detailed LFG
Sampling Plan
                                                                              Perform Max.
                                                                                 Cone.
                                                                             Screening-Level
                                                                                Analysis
                                                                                         Option 1
                                                                                                                                                   >
                                                                                                                                                   e 5d
                                                                                                                                                  1?
                                                                                                                                                K<  ^J 0

                                                                                                                                                O •'  3
                                                                                                                                             o
                                                                                                                                             (Jl
                                                                       Subdivide Site into
                                                                        Strata of Similar
                                                                         COPC Cone.
                                                                           Variability
                             Option2

                            N	
                                                                                                                   Use Options
                                                                                                                   in Appendix
    Cind Ambient Air
      Analysis
            Use ISC3 Dispersion
             Model to Estimate
            Normalized Air Cones.
             by Stratum and/or
             Vent at Receptor(s)
                                    Use Normalized Air
                                    Cones, and Actual
                                   Emissions to Estimate
                                     Actual Air Cones.
                                Figure A-2. Flow Chart for Assessing Air Impacts by Modeling.

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                Contaminate
            Groundwater Below
            Building(s) or Future
               and-use Sites?

Collect/Estimate
Groundwater
Cones. Below
Receptor Site(s)




                                                                   Use Existing Data
                                                                   to Determine Soil
                                                                   Stratigraphy and
                                                                     Properties at
                                                                    Receptor Site(s)
                                       End Vapor Intrusion
                                       from Groundwater
                                            Analysis
                                                                   Use Soil Borings to
                                                                     Determine Soil
                                                                    Stratigraphy and
                                                                      Properties at
                                                                     Receptor Site(s)
                                                                           Estimate Indoor
                                                                           Air Cones. Using
                                                                          EPA Groundwater
                                                                           Vapor Intrusion
                                                                                Model
                                              - SCS soil classes
                                              - Soil dry bulk densities
                                              - Soil water-filled porosities
                                              - Soil organic carbon contents
Perform Risk
Calculations
 Estimate Indoor
Air Cones. Using
 EPA Soil Vapor
 Intrusion Model
 Perform Soil
     Gas
  Sampling at
Receptor Site(s)
 Option 1
	—YES
                                                          Option 2
              -YES-
                                  YESH
                                                                STOP
                                                       End Groundwater
                                                        Vapor Intrusion
                                                           Analysis
        Figure A-3.  Flow Chart for Assessing Vapor Intrusion from Contaminated Groundwater.
                                                                                                                                         O O
                                                                                                                                         O
                                                                                                                                         (Jl

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estimated using the LandGEM model. This requires an average LFG concentration of each con-
stituent. These concentrations will be measured using LFG sampling techniques.

   If the landfill employs uncontrolled vents, each vent will be sampled separately. If vents are not
employed or if the area of influence for the vents is not adequate, site LFG concentrations will be
delineated using a superimposed grid system. The number of sampling points will be determined as
a function of the landfill size, homogeneity of its contents, and the amount of resources available for
sampling and analysis activities. Soil gas sampling will be conducted approximately one meter below
any landfill cover using either a slam-bar sampling device or a Geoprobe sampling rig depending on
equipment  availability  and soil properties.  It is assumed that ERTC will  provide all  sampling
equipment required. Screening level sampling will  be performed using portable instruments that
respond to either methane and non-methane organic compounds (NMOCs). EPA Method 25A will
be used to  determine total hydrocarbon concentration (THC). The NMOC  concentration will be
determined by placing a charcoal trap between the sample location and the instrument.  From these
data, the relative NMOC concentrations will be determined by the difference between the total organic
concentrations with and without methane. Once the NMOC concentrations have been determined, the
areal extent of the site will be partitioned  statistically into contiguous areas  of near homogeneous
NMOC concentration.

   The number of samples that must be obtained to estimate the mean concentration of an area is
strongly dependent on the heterogeneity of the chemical distribution. Thus, for an area with uniform
distribution, few samples are needed to provide good characterization.  Conversely, an area with
widely variable distribution would require a great number of samples. For areas with nonuniform
distribution such as a landfill, the total number of samples can be reduced by subdividing the area into
zones with similar levels of contamination and variability. The objective of screening is to identify
the areas with near homogeneous NMOC concentration; the Wilcoxon rank sum test (also known as
Mann-Whitney test) will be used to determine if there is an area with a higher mean concentration
when compared to the entire  landfill.

   The Wilcoxon rank sum test may be used to test for a shift in location between two independent
populations (i.e., the measurements from one population tend to be consistently larger than those from
the other population). This statistical procedure does not require normal distribution. The method is
not adversely affected by no detect values, and an equal number of samples is not required.

   The Wilcoxon rank sum test procedure is as follows.
   H0: Populations from which the two data sets have been drawn have the same mean.
   HA: The population have different means.

   For this project, a significance level (a) has been set to 5 percent.
   1. Consider all m = nl+ n2 data  as one set. Rank the m data from 1 to m; that is, assign the rank
       1 to the smallest datum, the rank 2 to the next largest datum,..., and the rank m to the largest
      datum. If several data have the same value, assign them the mi drank, that is, the average of the
      ranks that would otherwise be assigned to those data.
   2. Sum the ranks assigned to the n^ measurements from population one; denote this sum by Wrs.
   3. If «j <  10 and n2 < 10, the test ofH0 may be made by referring Wrs to the appropriate critical

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      value in Table X in Christensen (1977)3 page A-14.
   4. If «j > 10 and n2 > 10 and no ties are present, compute the large sample statistic
                                      Wrs -
   5. If «j > 10 and n2 > 10 and ties are present, compute
                                  12
                                       m+ 1-

\m-
                                                mm
                                                             1/2
      where7 is the number of tied groups and tj is the number of tied data in theyth group.
   6. For a one-tailed a level test of H0 versus the HA that the measurements from population one
      tend to exceed those from population two, reject H0 and accept HA if Zrs > Zj.a.
   7. For a one-tailed a level test ofH0 versus the HA that the measurements from population two
      tend to exceed those from population one, reject H0 and accept HA if Zrs < - Z^.

This procedure will  be  repeated until the landfill  has been divided in zones or areas of near
homogeneity. This partitioning will be subsequently used to determine sampling patterns for the
second round of sampling.

   Each area with a near homogenous NMOC concentration as determined by the screening level
results will be sampled, using a slam-bar or Geoprobe for subsurface sampling and stack sampling
equipment for vents. LFG samples will be collected in Summa or equivalent canisters. An on-site gas
chromatography/mass spectrometer (GC/MS) will be provided by the ERTC for sample analysis. EPA
Method TO-15, "Determination of Volatile Organic Compounds" will be used for analyzing the
cannister contents. The target analytes for all sites are listed in Table A-l. This list may be expanded
on a site-specific basis if other chemicals of potential concern are identified by the RPM. In addition,
duplicate samples in canisters will be sent to the ERTC offsite laboratory for analyses. The duplicate
sample concentrations will be compared with the on site GC/MS results to estimate any potential
sample bias. This is important because on-site GC/MS analysis is not anticipated to be a commonly
available analytical option for future users of the guidance, and it provides a QC check of the methods
being used. Sample concentrations will be subsequently corrected for air infiltration according to the
procedures specified on page 2-8 in the draft guidance document.
         3Christensen, Howard, 1977. Statistics - Step by Step, Houghton Mifflin Company,
   Boston.

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                         Table A-1.  Preliminary Target Analyte List
Classification
Very Volatile Organic
Speciated Volatile Organic Compounds
Analyte
Methane
Nonmethane Organic Compounds (NMOCs)
1,1,1-Trichloroethane (Methyl Chloroform)
1,1-Dichloroethene (Vinylidene Chloride)
1,2-Dichloroethane (Ethylene Bichloride)
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
Chloroethane (Ethyl Chloride)
Chlorofluorocarbons (as
Dichlorodifluoromethane)
Chloroform
Dichlorobenzene (Meta- and Para-isomers)
Ethylene Dibromide
Dichloromethane (Methylene Chloride)
Perchloroethylene (Tertrachloroethylene)
Toluene
Trichloroethylene (Trichloroethene)
Vinyl Chloride
Xylenes (all isomers)
Estimated LFG
Concentration
(ppmv)
500,000
4,000
4
15
32
28
93
0.25
10
7
56
2
0.33
0.001
46
15
380
8
20
80
   With the area-dependent mean concentrations of LFG constituents, the mass emissions of each
constituent for each near homogeneous area will be estimated using the LandGEM model based
on steady-state constituent concentrations. The LandGEM model will be run for a period of 30
years (and for ARAR-specific averaging times) for each area. The time-dependent emissions of
each LFG constituent will then be determined as the product of the yearly LFG emissions
predicted by the LandGEM model and the constituent mass fraction. The time-averaged emissions
of each constituent from each area will then be calculated using a trapezoidal approximation of the
integral  over the exposure duration as specified on Page 2-13 of the draft guidance document.

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Task 3 - Estimation of Ambient Air Concentrations
   Time-averaged ambient air concentrations of each constituent will be approximated using the
SCREENS dispersion model4 as specified in the draft guidance document. A risk evaluation will
then be performed for each constituent based on default residential inhalation exposure
assumptions at the point of maximum plume impact. Residential exposure assumptions are defined
for the inhalation/pathway by the following equations and assumptions:
                                CRmh(l) =  ADI x CSFmh(l)
                              C x IR x ET x EF x ED x O.OOlmg / jug
                       ADI =  —	——
                                     BW X AT X 365days I yr
where
   ADI    = Average daily intake of chemical /',
   CSFinh(i) = Chemical specific inhalation cancer slope factor,
   URFj   = Chemical specific inhalation unit risk factor,
   Ca      = Total air concentration of COPC /',
   IR      = Inhalation rate of 0.63 m3/h adults; 0.3 m3/h children,
   ET     = Exposure time, 24 h/day,
   EF     = Exposure frequency = 350 days/yr,
   ED     = Exposure duration;  30 yr-adult, 6 year child,
   BW    = Body weight 70 kg  adult, 15 kb/ child, and
   AT     = Averaging time 70 yr.

   As  required, a comparison of estimated ambient air concentrations with the appropriate air
pathway ARARs will also be made. Estimated average exposure point concentrations and resulting
inhalation risks will  be compared with the acceptable  risk range and also compared with any
regulatory standards as specified in the site-specific air pathway ARARs. The RPM is responsible for
establishing the acceptable risk range, regulatory standards, and ARARs on a site-specific basis.
Determination of ARARs and risk ranges are site-specific determinations that are beyond the scope
of this  example generic QAPP. The  guidance presents procedures and techniques for estimating
ambient air and indoor air concentrations that can be compared to the applicable regulatory and health
standard. If the results of the SCREENS dispersion modeling indicate that the exposure point air
concentrations are clearly not a  problem, the ambient  air risk  and ARAR  evaluations can be
         4SCREEN3 Screening Procedure for Estimating Air Quality Impacts of Stationary
   Sources Revised EPA 450/R-92-019.

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considered accomplished. If the screening level comparison indicates there is a potential problem,
dispersion modeling will be continued using the refined ISC3 model. The refined model uses site-
specific information (location, geometry, meteorological, etc.) to estimate the ambient air concen-
tration at the selected receptor locations. If refined dispersion modeling indicates that the exposure
point concentrations still represent a potential  health risk or that air pathway ARARs may  be
exceeded, ambient air sampling may be considered at the discretion of the TOM. Such ambient  air
sampling would consist of a series of stationary Summa canisters.

Task 4 - Estimation of Indoor Air Concentrations Due to LFG Transport
   At each selected site, pre-existing LFG monitoring data (e.g., pressure, COPC concentration, CH4
concentration, NMOC concentration, flowrate, etc.) will be obtained. This information will be used
to estimate the  subsurface methane and LFG COPC concentrations at selected landfill boundary
points. If these data are lacking and if approved by the TOM, cluster wells will be drilled to determine
subsurface methane and COPC  concentrations. If required, drilling, equipment, and personnel to
install the cluster wells will be supplied by the RPM. LFG constituent concentrations (e.g., methane,
NMOCs, COPCs) will be determined for each soil stratum between the ground surface and the depth
of the landfill in proximity to the landfill boundary closest to an offsite structure. If any subsurface
methane  concentration  is greater  than the lower explosive  limit (LEL) at the site boundary,
preliminary vapor transport and intrusion modeling will be performed for methane and COPCs using
the Little et al. (1992)5 steady-state model as specified in the guidance. This involves estimates of the
subsurface pressure at the landfill boundary and the soil vapor permeability. If data are available for
in situ soil saturated hydraulic conductivity, the soil vapor permeability will be estimated based on
this value. If saturated hydraulic conductivity data are lacking, the  soil vapor permeability will be
estimated based on the Soil Conservation Service (SCS) soil textural classifications.  This involves
taking subsurface soil samples and  analyses of soil particle size distributions through an American
Society for Testing and Materials (ASTM) standard method (ASTM methods D2216, D1587, D854,
and D422). Subsurface pressure at the landfill boundary must be empirically determined for the most
permeable soil  strata between the landfill boundary and the offsite structure(s) of interest. If sub-
surface monitoring wells are available, pressure will be measured using the procedures specified in
40 CFR 60, Appendix A, Method 2E. In addition to vapor transport and intrusion modeling, portable
photoionization detection (PID) instruments will be used to  detect any methane in  preferential
subsurface convection pathways or conduits (e.g., water meters, utility lines, etc.) as well as within
and under any potentially affected offsite structure(s).

   If preliminary modeling or sampling indicates potential indoor air methane concentrations greater
than 25 percent of the LEL, or COPC concentrations that represent unacceptable risks, soil gas
sampling below or adj acent to potentially affected buildings or indoor air sampling will be considered
at the direction of the TOM. If soil gas sampling is used, further modeling6 will be employed to  better
estimate indoor air concentrations based on soil gas sampling results. If indoor air sampling is used,
          5Little, J.C., J.M. Daisey, and W.W. Nazaroff 1992. "Transport of subsurface
   contaminants into buildings" Environ. Sci. TechnoL, 26(11):2058-2066.

          6Users Guide for Johnson and Ettinger Model for Subsurface Vapor Intrusion into
   Buildings, EPA-OERR, June 2003.

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other sources of the COPCs must also be accounted for including outdoor air and anthropo- genie
sources inside the structure of interest such as off-gassing of household chemicals and building
products.

Task 5 - Estimation of Indoor Air Concentrations Due to Vapor Intrusion from Contaminated
Groundwater
   Existing site data will be reviewed to determine if groundwater contaminated by landfill waste has
migrated off site under houses or other structures. If so, COPC concentrations within the contam-
inated groundwater will be estimated from existing site data as a function of downgradient location
and distance. These data will be provided by the RPM. These data will then be used by the contractor
to estimate, through modeling,  the potential indoor air concentrations of COPCs due to vapor
transport and intrusion into offsite structures. The screening-level models described in the draft
guidance document will be used to predict indoor air concentrations. Use of these models requires
data on subsurface soils directly below potentially affected structures. These data include soil dry bulk
density, moisture content, and  vapor permeability (top soil stratum  only). If  data are lacking,
continuous soil cores would be taken from the soil surface to the top of the water table at locations
adjacent to the structure(s). Enough cores must be obtained to allow for a reasonably accurate
estimate of average values below the structures. It is assumed that all equipment required to obtain
these soil samples will be provided by the RPM. If the subsequent risk evaluation indicates possible
adverse health effects, soil gas or indoor air sampling would be performed at the direction of the TOM
to verify predicted indoor air concentrations.

Task 6 - Preparation of Work Assignment Report
   At the conclusion of the field investigation part of the work assignment, the contractor will
prepare a written report summarizing the results of the field investigations, present a series of lessons
learned, and provide recommendations to be used in revising the draft guidance document and draft
fact sheet previously prepared under a separate EPA contract and work assignment. Revisions will
be suggested  based on the results  of applying the draft guidance document procedures at the test
landfill  sites.  Upon approval of the written report by the TOM, the contractor will revise the draft
guidance document and fact sheet and prepare three case studies for use in the draft guidance
document based on the three test sites. These documents will then be submitted to the TOM for
review. Upon receipt of all final comments from the TOM on the revised guidance document and fact
sheet, the contractor will prepare and submit to the TOM final versions of both documents.

   This QAPP describes a sampling, analysis,  and monitoring program designed to estimate the
emissions of hazardous and toxic compounds that exist in the LFGs at each site. A general overview
of the data collection effort is provided in Table A-2.

   Determination of conformance with the National Contingency Plan (NCP), 40 CFRPart 300, or
compliance with any non air pathway ARARs, permit conditions, or Federal, state, or local regula-
tions and statutes is beyond the scope and intent of this example generic QAPP. The sampling and
analytical procedures described herein are designed to evaluate the significance of the emissions from
the landfill. Action levels for the air pathway are site specific. The site-specific QAPP will include
the information needed to complete Table A-3.

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                        Table A-2. Summary of Data Collection Efforts.
     Site Background Information
     1.  Administrative contact, address, and telephone number
     2.  Maps (topographic, site plan, proximity, soil, groundwater, basement, wetland, etc.)
     3.  Landfill cross section and areal dimensions
     4.  Cover design basis (engineering specifications and design parameters)
     5.  LFG collection and treatment system design basis
     6.  Description and quantification of landfill contents and COPCs
     7.  Operational history (annual acceptance rates, years of operation, fill plan, etc.)
     8.  Extent and nature of groundwater contamination

     Sampling, Monitoring, and Analytical Componentsa
     -  Methane and NMOC via portable flame ionization detectors (FID) on a 30-meter grid and at all
        vents and on-site structures
     -  CO2, CH4, N2, and O2 via Method 3 C at 20 locations with highest NMOC concentration
     -  Site-specific COPC Tedlar bags or Summa canisters and mobile GC/MS (Laboratory-SOP 2102
        or 1819) at locations with highest NMOC concentrations for each near homogeneous area (not to
        exceed 20)
     -  If needed, LFG gas flow  rate via five equal volume wells spread over the landfill using Federal
        Reference Method 2E
     -  Soil properties (% moisture, bulk density, particle density, particle size) at locations with the
        highest NMOC soil gas concentration using Laboratory-SOP 2012 and ASTM methods D2216,
        D1587, D854, and D422  standard for each near homogeneous area
     -  In situ LFG pressure at up to 10 locations with 30-meter spacing along the landfill boundary
        closest to any off-site structures
     -  Site-specific volatile organic target analyte list via Tedlar bags or Summa cannister and mobile
        GC/MS (Laboratory-SOP 2102 or 1819) at up to 10 landfill boundary locations having the
        highest NMOC soil gas concentration
     -  If needed, in situ hydraulic conductivity of permeable soil horizons via standard constant head
        (D2434) methods at up to 10 boundary locations
     -  If needed, site-specific COPCs via Tedlar bag or Summa canisters and mobile GC/MS
        (Laboratory-SOP 2102 or 1819) at up to three locations between the landfill boundary having the
        highest NMOC soil gas concentration and the nearest off-site structure
     -  If needed, indoor air for site-specific COPCs  via Tedlar Bag or Summa Cannister and mobile
        GC/MS (Laboratory-SOP 1819) at the off-site structure closest to the boundary location having
        the highest NMOC soil gas concentration
     -  If needed, up to three ambient outdoor air samples for site specific COPCs via Summa cannister
        and mobile GC/MS (Laboratory-SOP 1819) at the off-site laboratory
     -  If needed, soil properties  (% moisture, bulk density, particle density, and particle size) at up to
        three potentially affected off-site structures using standard laboratory methods (ASTM Methods -
        D2216, D1587, D854, and D422)
     -  If needed, up to three groundwater samples for the site-specific COPCs via 40-ml volatile organic
        analysis (VGA) vials and GC/MS (SW846-8260) at potentially affected off-site structures located
        over the top of the groundwater plume	
  Site-specific QAPP will identify when the "if needed" samples are to be collected.

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                              Table A-3.  Air Pathway Action Levels.
Chemical of Potential
Concern
1,1,1 -Trichloroethane
1 , 1 -Dichloroethene
1 ,2-Dichloroethane
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chlorofluorocarbons (as
Dichlorodiflur-methane)
Chloroform
(Trichloromethane)
1 ,2-Dichlorobenzene
Ethylene Dibromide
Hydrogen Sulfide
Methylene Chloride
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Xylene (P)
Xylene (M)
Xylene (O)
Methane
Mercury
Limits of
Explosivity,"
%
1.8-14
6.5-15.5
6.2- 16
3-17
1.2-7.8
NA
1.3-9.6
3.0-15.4
NA
NA
2.2-9.2
NA
4-44
13-23
NA
1.1-7.1
8-10.5
3.6-33
1.1-7.0
1.1-7.0
0.9-6.7
5.4-15
NA
Non-carcinogenic
Reference
Concentration,15
Jlg/m3
1 x 103
3.2 x 101
1 x 1Q1
2.0 x 10°
6 x 101
2.5 x 10°
2.0 x 101
1 x IQ4
2x 102
3.5 x 1Q1
2.0 x 102
2 x 1Q-1
ND
3 x IQ3
3.5 x 1Q1
4.0 x 102
2.1 x 1Q1
1.0 x 102
7x 103
7 x 103
7 x 103
ND
3 x 1Q-1
Carcinogenic
Inhalation Unit
Risk Factor,b
(^g/m3)1
NAC
5 x IQ-5
2.6 x IQ-5
6.8 x IQ-5
7.8 x IQ-6
1.5 x IQ-5
NDd
ND
ND
2.3 x IQ-5
ND
2.2 x IQ-4
ND
4.7 x IQ-7
5.8 x IQ-7
ND
1.7 x IQ-6
4.4 x IQ-6
ND
ND
ND
ND
ND
State/local
Ambient Air
Toxics
Standard,
Jlg/m3























a Pocket Guide to Chemical Hazards USDHHS-CDC-1998
b Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities, July 1998.
c NA - Not applicable
dND-Nodata

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    Site-specific QAPPs will include a listing of the methods, procedures, and protocols. The O&M
manuals, field related SOPs for sampling and analysis, Health and Safety Plan, and QAPP will be
available for the field team to use and reference during onsite activities. The site laboratory manager
is responsible for assuring that the appropriate documents are available. The site-specific QAPP
components will be  submitted to the TOM at least 30 days  prior to the beginning of any data
generating activity at the site. The QA requirements are described in EPA QAR-5, "Requirement for
Quality Assurance Proj ect Plans." The contractor anticipates that the TOM and EPA Q/A officer will
review and approve any substantive changes in the QAPP.

    Figure A-4 presents an example of an idealized project schedule. Site-specific schedules will be
developed at least 30 days prior to initiating any field activities on a site-by-site basis.

    Project and quality record requirements may include:
    •  Site-specific QAPP,
    •  Audit reports,
    •  Status reports,
    •  Corrective action reports,
    •  Data review and data validation reports, and
    •  Project data records .
A.4 Quality Objectives and Criteria
    Data quality obj ectives (DQOs) are qualitative and quantitative statements developed using EPA's
DQO process (QA/G-4 Guidance for DQO Process). The statements clarify the project's objectives,
define the appropriate types of data, and specify tolerable levels of potential decision errors. These
end use requirements form the basis for establishing the quality and quantity requirements of the data
being generated. DQOs define the performance criteria  that must be met in order to limit the
probability of making unacceptable decision errors.

    DQOs are quantitative and qualitative statements that are designed to:
    •  Clarify study objectives,
    •  Define type of data,
    •  Establish most appropriate conditions from which to collect data, and
    •  Specify acceptable levels of decision error that will be used as the basis for establishing the
      quantity and quality of the data needed to support the outcome decisions.

    For this proj ect the qualitative obj ectives are to evaluate the kinds and amounts of emissions from
selected landfill and to determine whether the draft guidance allows the users to determine if LFG
controls are needed. This generic  QAPP and the site-specific QAPP result from the systematic
planning process and contain information needed to carry out the data gathering and meet the DQOs.
No  criteria are currently in place to decide which types or how many data gaps or procedural problems
will trigger a revision or even  abandonment of the draft guidance. Combined with the likely
variability of emissions and the proximity to off site structures,  the threshold of what will qualify as
significant will probably be when it is determined that the procedures are to costly or that the guidance
user is unable to reach an acceptable end point for one of the three sites being evaluated. Based on

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ID
1
2
3
4
5
S
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Task Name
Tasfcl
Draft OAPP
EPA Review of Draft QAPP
Final QAPP
Site Selection and Coordination
Site-Specific QAPP
Task 2
Sit* 1 Field Work
Site I Data Analysis
Site 1 Case Study
Site 2 Field Work
Site 3 Field Work
Site 2 Data Analysis
Site 3 Data Analysis
Site 2 Case Study
Site 3 Case Study
EPA Review of Case Studies
TaskS
Revise Draft Guidance
Revise Draft Fact Sheet
EPA Review Drafts
Final Guidance
Final Fact Sheet
Duration
1S4 days
22 days
68 days
30 days
20 days
15 days
93 Days
1 0 days
25 days
13 days
10 days
1 0 days
25 days
25 days
8 days
8 days
20 days
30 Days
1 0 days
1 0 days
1 0 days
1 0 days
1 0 days
Start
Won 7/23/01
Won 7/23/01
Wed 8/22/01
Fri 11/30/01
Wed 1/23/02
Wed 2/13/02
Won 4/8/02
Mon 4/8/02
Mon 4/22/02
Tue 5/28/02
Mon 4/2S/02
Mon 5/20/02
Mon 5/13/02
Tue 6/4/02
Tue 671 8/02
Wed 7/1 0/02
Mon 7/22/02
Mon 8/19/02
Mon 8/19/02
Mon 8/19/02
Tue 9/3/02
Tue 9/17/02
Tue 9/17/02
Finish
Wed 3/6/02
Tue 8/21/01
Thu 1 1/29/01
Tue 1/29/02
Wed 2/20/02
Wed 3/6/02
Fri 8/1 6/02
Fri 4/19/02
Fri 5C4/02
Thu 6/13/02
Fri 5/10/02
Mon 6/3/02
Mon 6/17/02
Tue 7/9/02
Thu 6/27/02
Fri 7/1 9/02
Fri 8/16/02
Mon 9/30/02
Fri 8/30/02
Fri 8/30/02
Mon 9/1 6/02
Mon 9/30/02
Mon 9/30/02
August
7/16 ] 7/22 7/29 3/6 8/12 8/19 8/28

[ 	
September
9/2 9/7 9/16 9/23


October
9/30 10/7



Project; Application* of Guidance
For Evaluating Landfill Gas Emissions at Supertund Site:

Task
Split
Progress
Mitestora

i 	 "... . Summary •^•^•••^•^•B External Milestone
*
t^.^
4-
	 rroject summary gp— — spj ui
•^•^•B ExUir ml Tasks I 1
External Milestone ^
sadline ^

Page 1
  >  ^ 2.

o -~ §
*+>  K» H
00  O ,—.
ON  O °
    (Ji

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ID
1
2
3
4
5
S
7
8
9
to
11
12
13
14
15
16
17
18
19
20
21
22
23
Task Name
Tasfcl
Draft OAPP
EPA Review of Draft QAPP
Final QAPP
Site Selection and Coordination
Site-Specific QAPP
Task 2
Site 1 Field Work
Sltel Data Analysis
Site 1 Case Study
Site 2 Field Work
Site 3 Field Work
Site 2 Data Analysis
Site 3 Data Analysis
Site 2 Case Study
Site 3 Case Study
EPA Review of Case Studies
TaskS
Revise Draft Guidance
Revise Draft Fact Sheet
EPA Review Drafts
Final Guidance
Final Fact Sheet
Duration
154 days
22 days
68 days
30 days
20 days
15 days
93 Days
1 0 days
25 days
13 days
10 days
1 0 days
25 days
25 days
8 days
8 days
20 days
30 Days
10 days
10days
todays
todays
todays
Start
Mon 7/23/01
(Won 7/23/01
Wed 8/22/01
Fri 11/30/01
Wed 1/23/02
Wed 2/13/02
Mon 4/8/02
Won 4/8/02
Mon 4/22/02
Tue 5/28/02
Mon 4/29/02
Mon 5/20/02
Mon 5/13/02
Tue 6/4/02
Tue 6/18/02
Wed 7/1 0/02
Mon 7/22/02
Mon 8/19/02
Mon 8/19/02
Mon 8/19/02
Tue 9/3/02
Tue 9/17/02
Tue 9/17/02
Finish
Wed 3/6/02
TueB/21/01
Thu 11/29/01
Tue 1/29/02
Wed 2/20/02
Wed 3/6/02
Fri 8/1 6/02
Fri 4/19/02
Ffl 5/24/02
Thu 6/13/02
Fri 5/10/02
Mon 6/3/02
Mon 6/17/02
Tue 7/9/02
Thu 6/27/02
Fri 7/1 9/02
Fri 8/16/02
Mon 9/30/02
Fri 8/30rt)2
Fri 8/30/02
Mon 9/1 6/02
Mon 9/30/02
Mon 9/30/02
November
10/14 10/21 10/28 11/4 n/11 11/18 11/26
December January
12/2 12& 12/18 12/23 12/30 "MS

!* . .


Project; Application! of Guictanc*
For Evaluating Landfill Gas Emissions at Supertund Sttes

Task
Split
Progress
Mltestorn

> 	 ' 	 ; Summary ^^^H^^^B External Milestone A

^^M
+

•••••I External Tasks | !
External Milestone -^
^adltne ^y
Page 2
        H
oo  o
ON  O
    (Ji

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ID
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Task Name
Tasfcl
Draft OAPP
EPA Review of Draft QAPP
Final QAPP
Site Selection and Coordination
Site-Specific QAPP
Task 2
Sit* 1 Field Work
Site I Data Analysis
Site 1 Case Study
Site 2 Field Work
Site 3 Field Work
Site 2 Data Analysis
Site 3 Data Analysis
Site 2 Case Study
Site 3 Case Study
EPA Review of Case Studies
TaskS
Revise Draft Guidance
Revise Draft Fact Sheet
EPA Review Drafts
Final Guidance
Final Fact Sheet
Duration
1S4 days
22 days
68 days
30 days
20 days
15 days
93 Days
1 0 days
25 days
13 days
10 days
1 0 days
25 days
25 days
8 days
8 days
20 days
30 Days
1 0 days
1 0 days
1 0 days
1 0 days
1 0 days
Start
Won 7/23/01
Won 7/23/01
Wed 8/22/01
Fri 11/30/01
Wed 1/23/02
Wed 2/13/02
Won 4/8/02
Mon 4/8/02
Mon 4/22/02
Tue 5/28/02
Mon 4/2S/02
Mon 5/20/02
Mon 5/13/02
Tue 6/4/02
Tue 671 8/02
Wed 7/1 0/02
Mon 7/22/02
Mon 8/19/02
Mon 8/19/02
Mon 8/19/02
Tue 9/3/02
Tue 9/17/02
Tue 9/17/02

Project; Application* of Guidance
For Evaluating Landfill Gas Emissions at Supertund Site:
Finish
Wed 3/6/02
Tue 8/21/01
Thu 1 1/29/01
Tue 1/29/02
Wed 2/20/02
Wed 3/6/02
Fri 8/1 6/02
Fri 4/19/02
Fri 5C4/02
Thu 6/13/02
Fri 5/10/02
Mon 6/3/02
Mon 6/17/02
Tue 7/9/02
Thu 6/27/02
Fri 7/1 9/02
Fri 8/16/02
Mon 9/30/02
Fri 8/30/02
Fri 8/30/02
Mon 9/1 6/02
Mon 9/30/02
Mon 9/30/02
February March
1/13 ] 1/20 1/27 213 2flO 2/17 2124 3/3 3/10 3/17 3/24



	 ,..!
y. ..".


April
3fll V7



Task
Split
Progress
Mitestora
-

4-
Summary ^^•^••^•^•^ External Milestone
Project Summary Deadline ^
External Tasks [ |
External Milestone ^


Page 3
00  °
ON  O
    (Ji

-------

ID
1
2
3
4
5
6
7
8
9
to
11
12
13
14
15
16
17
18
19
20
21
22
23
Task Name
Taskl
Draft QAPP
EPA Review of Draft QAPP
Final QAPP
Site Selection and Coordination
Site-Specific QAPP
Task 2
Site 1 Field Work
Sltel Data Analysis
Site 1 Case Study
Site 2 Field Work
Site 2 Data Analysis
Site 3 Data Analysis
Site 2 Case Study
Site 3 Case Study
EPA Review of Case Studies
TaskS
Revise Draft Guidance
Revise Draft Fact Sheet
EPA Review Drafts
Final Guidance
Final Fact Sheet
Duration
154 days
22 days
68 days
30 days
20 days
15 days
93 Days
1 0 days
25 days
13 days
todays
25 days
25 days
8 days
8 days
20 days
30 Days
todays
todays
todays
todays,
todays
Start
Mon 7/23/01
Mon 7/23/01
Wed 8/22/01
Fri 11/30/01
Wed 1/23/02
Wed 2/13/02
Mon 4/8/02
Won 4/8/02
Mon 4/22/02
Tue 5/28/02
Mon 4/29/02
Mon 5/20/02
Mon 5/13/02
Tue 6/4/02
Tue 6718/02
Wed 7/1 0/02
Mon 7/22/02
Mon 8/19/02
Mon 8/19/02
Mon 8/19/02
Tue 9/3/02
Tue 9/17/02
Tue 9/17/02

Project; Application! of Guidance
For Evaluating Landfill Gas Emissions at Supertund Sttes

Finish
Wed 3/6/02
TueB/21/01
Thu 11/29/01
Tue 1/29/02
Wed 2/20/02
Wed 3/6/02
Fri 8/1 6/02
Fri 4/19/02
Fri 5/24/02
Thu 6/13/02
Fri 5/10/02
Mon 6/3/02
Mon 6/17/02
Tue 7/9/02
Thu 6/27/02
Fri 7/1 9/02
Fri 8/16/02
Mon 9/30/02
Fri 8/30/02
Fri 8/30/02
Mon 9/1 6/02
Mon 9/30/02
Mon 9/30/02
May
4/14 4/21
4/28 6/5 6/12 6/19 6/26

—^

t 	
'| { 	 	
1 ' 	

June
6/2 6/9
6/16 6/23


A

July
8/30 7/7


- t

Task
Split
Progress
Mitestorw
>. 	 f 	 ; SUIT

i • Ext.
mary ^^•^••^•^•^ En

rnal Tasks | i
"rnal Milestone ^

ternal Milestone •''.-
adline ^
Page 4
oo  o
ON  O
    (Ji

-------

ID
1
2
3
4
5
S
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Task Name
Tasfcl
Draft OAPP
EPA Review of Draft QAPP
Final QAPP
Site Selection and Coordination
Site-Specific QAPP
Task 2
Sit* 1 Field Work
Site I Data Analysis
Site 1 Case Study
Site 2 Field Work
Site 3 Field Work
Site 2 Data Analysis
Site 3 Data Analysis
Site 2 Case Study
Site 3 Case Study
EPA Review of Case Studies
TaskS
Revise Draft Guidance
Revise Draft Fact Sheet
EPA Review Drafts
Final Guidance
Final Fact Sheet
Duration
1S4 days
22 days
68 days
30 days
20 days
15 days
93 Days
1 0 days
25 days
13 days
10 days
1 0 days
25 days
25 days
8 days
8 days
20 days
30 Days
1 0 days
1 0 days
1 0 days
1 0 days
1 0 days
Start
Won 7/23/01
Won 7/23/01
Wed 8/22/01
Fri 11/30/01
Wed 1/23/02
Wed 2/13/02
Won 4/8/02
Mon 4/8/02
Mon 4/22/02
Tue 5/28/02
Mon 4/2S/02
Mon 5/20/02
Mon 5/13/02
Tue 6/4/02
Tue 671 8/02
Wed 7/1 0/02
Mon 7/22/02
Mon 8/19/02
Mon 8/19/02
Mon 8/19/02
Tue 9/3/02
Tue 9/17/02
Tue 9/17/02

Project; Application* of Guidance
For Evaluating Landfill Gas Emissions at Supertund Site:
Finish
Wed 3/6/02
Tue 8/21/01
Thu 1 1/29/01
Tue 1/29/02
Wed 2/20/02
Wed 3/6/02
Fri 8/1 6/02
Fri 4/19/02
Fri 5C4/02
Thu 6/13/02
Fri 5/10/02
Mon 6/3/02
Mon 6/17/02
Tue 7/9/02
Thu 6/27/02
Fri 7/1 9/02
Fri 8/16/02
Mon 9/30/02
Fri 8/30/02
Fri 8/30/02
Mon 9/1 6/02
Mon 9/30/02
Mon 9/30/02
August
7/14 ]
7/21 7/28 8/4 8/11 8/18 8/26




I



	 IB

. . .. .. .. .. ..


S«pt«mb«r October
9/1 9/8 9/16 9/22 9/29 10/8

4^
t
	 ' 	 J;
i» ' ' ' , '

Task
Split
Progress
Mitestora
-

4-
Summary ^—^ E,
Project Summary Ds
External Tasks [ |
External Milestone ^

ternal Milestone
adline ^
Page 5
    » 3.
    L*J En'
       5'
00  °
ON  O
    (Ji

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August 31,2005
 Page 28 of 86

these premises, quantitative objectives are established for critical measurements in terms of data
quality indicators goals for accuracy, precision, and completeness.

   The overall QA objective is to determine if the LFG emissions to the ambient air and subsurface
vapor intrusion into buildings create acceptable or unacceptable inhalation risks or hazards of fire or
explosion and whether potential ambient air ARARs may be exceeded.

   The objectives are achieved if as a result of conducting the field investigation and implementing
the guidance one can:
   •  Determine compliance with air pathway specific ARARs,
   •  Determine if the methane concentration at receptors is greater than 25 percent of the LEL, and
   •  Determine if the health risks due to LFG migration and vapor migration from groundwater to
      off-site receptors are acceptable.

   The guidance document assumes that the user will gather available information and that said
information has been generated in a manner consistent with good management practices. The conduct
of basic research or resolution of disputes concerning the following is beyond the scope of work for
this project:
   •  Age of landfill,
   •  Dimensions and cross sections of landfill,
   •  Content of landfill and identification of COPCs on a section-by-section basis,
   •  Annual waste acceptance rate,
   •  Design basis of the landfill cover, and
   •  Design basis of the LFG collection  and vent system .

It should be noted,  however,  that the adequacy  and correctness of the existing information may
materially affect the outcome and decisions that are made concerning health risk and explosion
hazards.

   For QA purposes the existing site data and information will be accepted and used if:
   •  It has been publicly acknowledged and accepted by EPA and
   •  It has been included in the publicly available site-specific records and documents and there has
      been no dispute concerning the validity or acceptability of the records and documents.

If there are data gaps in the existing data and information, the site-specific case study will note  the
critical data gap(s).

   For QA purposes physical and chemical data will be accepted if it is from standard and commonly
accepted references  (e.g., CRC Handbook of Chemistry).

   QA objectives and protocols  for the  field sampling and analysis portion of the project  are
summarized in Table A-4. The number of samples to be collected for this project/event  are site
specific and will be  included in an appendix at least 30 days prior to conducting the field activities
presented in Table A-4. This table identifies analytical parameters desired; type, volume, and number
of containers needed; preservation requirements; number of samples to be collected; and associated

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                                                                            August 31,2005
                                                                             Page 29 of 86
number and type of QA/QC samples based on QA level III. All project deliverables will receive an
internal peer review prior to release. The following QA protocols are applicable to the sample
matrices:
    1. Sample  documentation in the form of field logbooks, the appropriate field data sheets, and
      COC forms will be provided. COC sheets are optional for field screening locations.
    2. All instrument calibrations and performance check procedures or methods will be summarized
      and documented in the field/personnel or instrument log notebook.
    3. Detection limit(s) will be determined and recorded, along with the data, where appropriate.
    4. Sample  holding times will be documented; this includes documentation of sample collection
      and analysis dates.
    5. Initial and continuing instrument calibration data will be provided.
      a.  For air samples, lot blanks, field blanks, collocated samples, trip blanks, and breakthrough
         samples will be included.
      b.  For  soil gas samples, duplicate samples, zero air samples, field standards,  ambient air
         samples, and matrix spikes will be included.

                     Table A-4. Field Sampling Summary for Each Site
Source
Landfill
cover,
passive
vents,
extractive
vents
Parameter
A. CH4
screen
B. CH4 QC
duplicate
C. NMOC
screen
D. NMOC
QC duplicate
E. Organic
COPCs
F. Organic
COPC QC
collocate/
split
G. Fixed gas
H. Fixed gas
QC collocate/
split
I. Trip/plot
blank
Media
in situ
in situ
in situ
in situ
Tedlar bag
or Summa
cannister
Summa
cannister
in situ
Summa
cannister
Summa
cannister
Holding
Time3
Direct read
instrument
Direct read
instrument
Direct read
instrument
Direct read
instrument
7 day
7 day
Direct read
instrument
7 day
7 day
Flow Rate,
L/min
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1

Volume,
L
1.0
1.0
1.0
1.0
1.0 to 6.0
6.0
1.0
6.0
6.0
No. of
Samples
TBD
5% A
TBD
5%C
3 per
homogeneous
area
5%E
E
5%G
10% For
I/day
                                                                               continued

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August 31,2005
 Page 30 of 86
Source
Native
Offsite Soil
Air
(ambient or
indoor)
Parameter
A. CH4
B. CH4 QC
Duplicate
C. Organic
COPCs
D. Organic
COPC - QC
duplicate
E. Organic
COPC QC
collocate/
split
F. Soil
properties
G. Soil
properties
QC Duplicate
H.Gas
pressure
I. Gas
pressure QC
Duplicate
J. Trip/lot
blank
A. Organic
COPC
B. Organic
COPC QC
Duplicate
C. Trip/lot
blank
Media
Tedlar bag
or Summa
cannister
Summa
cannister
Tedlar bag
or Summa
cannister
Summa
cannister
Summa
cannister
Split barrel
Split barrel
in situ
in situ
Summa
cannister
Summa
cannister
Summa
cannister
Summa
cannister
Holding
Time3
7 day
7 day
7 day
7 day
7 day
24 h
24 h
Direct read
instrument
Direct read
instrument
7 day
7 day
7 day
7 day
Flow Rate,
L/min
0.01
0.01
0.01
0.01
0.01
NAb
NA
NA
NA
0.01
0.01
0.01
0.01
Volume,
L
1.0 to 6.0
6.0
1.0 to 6.0
6.0
6.0
0.5
0.5
NA
NA
6.0
6.0
6.0
6.0
No. of
Samples
TBD
5% A
TBD
5%C
5%D
TBD
5%F
TBD
5%H
10%Eor
I/day
TBD
5% A
10%Bor
I/day
 a All samples are unpreserved, stored at temperatures between 65 and 75 °F and away from sunlight.
 b NA = not applicable.

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                                                                             August 31,2005
                                                                              Page 31 of 86

    6. Performance evaluation (PE) samples are not anticipated but may be included at the discretion
      of the TOM.
    7. The following three options are applicable:
      a.  Definitive Identification - analyte identification on 10 percent of the screened (field or lab)
          or 100 percent of the unscreened samples will be confirmed using a U.S. EPA-approved
          method; documentation such as chromatograms, mass spectra, etc., will be provided.
      b.  Quantitation - documentation for  quantitative results from  screening and U.S. EPA-
          approved verification methods (for screened samples) or quantitative results (in the case
          of unscreened samples) will be provided.
      c.  Analytical Error - the analytical error will  be determined by calculating the precision,
          accuracy, and coefficient of variation on a subset of the screened samples or on  all of the
          unscreened samples using an EPA-approved method.

    The quality components of precision, accuracy, representativeness, completeness, and compar-
ability for this project are discussed below.  This QAPP applies to any project site that requires
sampling  or monitoring. Site-specific information, however, will be addressed in  a site-specific
QAPP.

A. 4.1 Precision and Accuracy
    Uncertainty associated with the measurement data is expressed in terms of accuracy and precision.
The accuracy of a single value contains the component of random error  in a measurement and also
the systematic error, or bias. Accuracy thus reflects the total error for a given measurement. Precision
values represent a measure of only the random variability for replicate measurements. In general, the
purpose of calibration is to eliminate bias, although inefficient analyte recovery or matrix inter-
ferences can contribute to sample bias, which is typically assessed by analyzing matrix spike samples.
At very low levels, blank effects (contamination or other artifacts) can also contribute to low-level
bias. Bias  can also be introduced by laboratory contamination. The potential for bias is evaluated by
method blanks. Instrument bias is evaluated by control samples.

    Calibration standards, QC check samples,  and performance evaluation samples will be  prepared
from vendor-certified standards  or generated from stock materials of known purity. Records of the
preparation and validation of all QA/QC-related samples will be maintained by the laboratories
responsible for the analyses. Laboratories will be identified in the site-specific QAPPs.

    Experience in conducting volatile organic compound (VOC) measurement programs has shown
that the typical analytical precision values that can be  attained, measured as the percent coefficient
of variation (%CV), are <50 percent for electrolytic conductivity detector (ELCD) compounds and
<30 percent for flame ionization detector (FID) compounds and fixed  gases. Accuracy values of
between 50 and 150 percent recovery can typically be achieved for the  ELCD  compounds, and
recoveries between 70 and 130 percent can typically be achieved for the FID compounds and fixed
gases. The instrument detection  limit for many of the VOC compounds  are typically below  1 ppbv
for low-lev el samples. In high-level samples, however, compounds present in low concentrations will
be masked by the largest peaks or will be below detectable quantities because of dilution or injection
volume considerations. This is particularly a problem when one or two compounds are orders of
magnitude higher in concentration than the remaining compounds in the sample. These matrix effects
can adversely affect the precision and accuracy of the method.

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   The soil gas and air samples being collected as part of this project are expected to be relatively
low in concentration, resembling unaffected ambient air samples, while the extractive/passive vent
samples are expected to contain ppm-level concentrations (e.g., 5-250 ppm) of hydrocarbons. Both
sample sets will be quantitated for the same list of target analytes (Table A-l). The main differences
in the two analyses will be the method the samples are injected into the chromatograph and the
number and concentration of the calibration standards. Tables A-5, A-6, and A-7 list the accuracy,
precision, and targeted/estimated detection  limits for a subset of the target analytes. Analytical
detection limits are matrix, laboratory, instrument specific. Each laboratory will be required to
explain  and justify only differences that are discovered during the project. Table A-5 shows
anticipated limits for the low-level analysis (i.e., soil gas samples) for compounds where these limits
have been experimentally and empirically determined. This same information for the high-level
samples (i.e., vent and gas collection system samples) is shown in Table A-6. For compounds not on
these  lists,  the accuracy, precision, and detection limits may or may not have been empirically
determined. The collection of duplicate samples during this program will help assess the precision
of the other compounds; however, for  cost control purposes and because the information is not
needed to meet the project objectives, no attempt will be made to derive empirical detection limits
or accuracy estimates for compounds not included in the site-specific target analytes list (TAL).

   Table A-5. Summary of Precision, Accuracy, and Detection Limits for VOC Analysis of Air
                           Samples, Low-level Sample Technique.
Analyte (VOC Compound Number)
Analytical
Precision3
Analytical
Accuracy*
Target Detection
Limits0 (ppbv)
PRIMARY COMPOUND LIST (Includes TO-14 Compounds): These compounds are monitored daily for
precision and accuracy.
Benzene46'58 (#79)
Benzyl chloridef & m-dichlorobenzenef (#230)
Chlorobenzenef (#128)
Ethylbenzene4e'f(#129)
n-Decanee & p-dichlorobenzenef (#23 1)
o-Dichlorobenzenef'h (#163)
o-Xylene4*'1 (#137)
p-Xylene & m-xylene46' (#131)
Methane
Arcylonitrile
Ethylene Dibromide
Toluene46'^*!!!)
1, 1, l-Trichloroethanef (methyl chloroform - #76)
l,2-Dichloroethanef'g (#74)
l,l-Dichloroethylenef (vinylidene chloride - #42)
Caibon tetrachloridef (#80)
Chloroethanef (ethyl chloride - #21)
Chloroformf(#67)
Dichlorodifluoromethanef (freon 12 - #7)
30%
50%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
50%
50%
50%
50%
50%
50%
50%
70-130%
50-150%
50-150%
50-150%
50-150%
50-150%
50-150%
70-130%
70-130%
70-130%
70-130%
70-130%
50-150%
50-150%
50-150%
50-150%
50-150%
50-150%
50-150%
0.4
0.6
0.5
0.7
0.7
0.7
0.5
1.0
0.2
0.2
0.7
0.5
0.2
0.2
0.2
0.5
0.2
0.1
0.2
                                                                                  continued

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                                                                                               August 31,2005
                                                                                                Page 3 3 of 86
Analyte (VOC Compound Number)
Methylene chloridef>B (dichloromethane - #44)
Tetrachloroethylenef (#125)
Trichloroethylenef & Bromodichloromethane (#235)
Vinvlchloridef(#10)
Analytical
Precision3
50%
50%
50%
50%
Analytical
Accuracy1"
50-150%
50-150%
50-150%
50-150%
Target Detection
Limits0 (ppbv)
0.2
0.1
0.1
0.3
a Analytical precision is measured from duplicate analysis of the daily calibration standard (DCS) or continuing calibration
 checks (CCCs) at a concentration of 2-8 ppbv for primary compounds.
b Analytical accuracy is measured using two sigma control charts using DCS recoveries or from laboratory control sample
 recoveries when available (see footnote e). No more than two compounds from FID and three compounds from ELCD (or the
 appropriate 95% Poison probability value) should exceed these tolerances in any valid standard analysis for the system to be in
 statistical control. NOTE: This measurement reflects analytical accuracy and does not include sampler recovery, storage
 stability, or matrix effects.
c Instrument detection limits (IDLs) for core compounds represent the most conservative measured value (rounded up) based on
 seven replicate detection limit determination studies. These IDLs may change with actual IDL determination and sample
 matrix. The IDLs listed for TAL represent a one-time seven replicate detection limit study. NOTE: These detection limits
 assume a dilution factor of 1. This procedure is based on guidance contained in 40 CFR Part 136 Appendix B.
d Compounds in standard used to measure database (qualitative) accuracy.
e Compounds used to determine carbon response factor accuracy with a second source standard.
fTO-15analyte.
g Analytical individual response factor  (IRF) accuracy will be determined by comparing compounds common in both the
 individual response factor laboratory  control standard (IRF-LCS) and the DCS.
h Compound may coelute with other compounds in typical VOC sample patterns. Polar compounds may coelute with several
 compounds, especially when present at high concentration.
1 Carbon response factor, not an IRF, will be used for quantitation because of chromatographic coelution in the DCS.
   Table A-6.  Summary of Precision, Accuracy, and Detection Limits for VOC Analysis of Air
                           Canister Samples,  High-Level Sample Technique
Analyte (VOC Compound Number)
Analytical
Precision3
Analytical
Accuracy6
Target Detection
Limits0 (ppbv)
CALIBRATED COMPOUND LIST: These compounds are monitored on daily basis. This is a high level
standard.
Benzene46'58 (#79)
Benzyl chloridef & m-dichlorobenzenef (#230)
Chlorobenzenef(#128)
Ethylbenzened-e'f(#129)
n-Decanee & p-dichlorobenzenef (#23 1)
o-Dichlorobenzenef'h (#163)
o-Xylene4*'1 (#137)
p-Xylene & m-xylene46' (#131)
Toluene4e'f'g(#lll)
1, 1, l-Trichloroethanef (methyl chloroform - #76)
l,2-Dichloroethanef'g (#74)
l,l-Dichloroethylenef (vinylidene chloride - #42)
Carbon tetrachloridef (#80)
Chloroethanef (ethyl chloride - #21)
Chloroformf (#67)
Chloromethanef (methyl chloride - #5)
30%
50%
30%
30%
30%
30%
30%
30%
30%
50%
50%
50%
50%
50%
50%
50%
70-130%
50-150%
50-150%
50-150%
50-150%
50-150%
50-150%
70-130%
70-130%
50-150%
50-150%
50-150%
50-150%
50-150%
50-150%
50-150%
100
150
125
175
175
175
125
250
125
50
50
50
125
50
25
250
                                                                                                   continued

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 Page 34 of 86
Analyte (VOC Compound Number)
Dichlorodifluoromethanef (freon 12 - #7)
Methylene chloridef>B (dichloromethane - #44)
Tetrachloroethylenef (#125)
Trichloroethylenef
c- 1 , 3 -Dichloroethylene
t- 1 ,3 -Dichloroethylene
Vinvlchloridef(#10)
Analytical
Precision3
50%
50%
50%
50%
50%
50%
50%
Analytical
Accuracy1"
50-150%
50-150%
50-150%
50-150%
50-%50
50-150%
50-150%
Target Detection
Limits0 (ppbv)
50
50
25
25
50
50
75
 1 Analytical precision is measured from duplicate analysis of the daily calibration standard (DCS) or continuing
  calibration checks (CCCs) at a concentration of 2-8 ppbv for primary compounds.
 3 Analytical accuracy is measured using two sigma control charts using DCS recoveries or from laboratory control
  sample recoveries when available (see footnote e). No more than two compounds from FID and three compounds
  from ELCD (or the appropriate 95% Poison probability value) should exceed these tolerances in any valid
  standard analysis for the system to be in statistical control. NOTE: This measurement reflects analytical accuracy
  and does not include sampler recovery, storage stability, or matrix effects.
 : Instrument detection limits (IDLs) based on a load volume of 0.5 mL for core compounds represent the most
  conservative measured value (rounded up) based on seven replicate detection limit determination studies. These
  IDLs may change with actual IDL determination and sample matrix. NOTE: These detection limits assume a
  dilution factor of 1.  This procedure is based on guidance contained din 40 CFR Part 136 Appendix B.
 1 Compounds in standard used to measure database (qualitative) accuracy.
 : Compounds used to determine carbon response factor accuracy with a second source standard.
 fTO-15analyte.
 1 Analytical individual response factor (IRF) accuracy will be determined by comparing compounds common in
  both the Individual response factor laboratory control standard (IRF-LCS) and the DCS.
 1 Compound may coelute with other compounds in typical VOC sample patterns. Polar compounds may coelute
  with several compounds, especially when present at high concentration.
  Carbon response factor, not an IRF, will be used for quantitation because of chromatographic coelution in the
  DCS.
 Table A-7.  Summary of Precision, Accuracy and Completeness Goals for Physical Parameters.
Parameter
Precision
Accuracy (%)
Fix Gas (CO2, CH4, N2, O2)
Gas Standard
Calibration Error
Sampling Bias
Zero and Drift
5% RSD
NAa
NA
NA
20% Bias
2% Bias
5% Bias
3% Bias
Soil Properties
Percent Moisture
Bulk Density
Particle Density
Particle Size
Balance Calibration Check
5% RSD
5% RSD
5% RSD
5% RSD
0.5 K
5
5
5
5
5
Completeness
80




80





 JNA = not applicable.

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    The Guidance for Evaluating Landfill Gas Emissions at Closed or Abandoned Sites (EPA-600/R-
05/123a) notes that modern  analytical  techniques are not capable of achieving a detection or
quantitation limit that would demonstrate there is no significant risk (e.g., 1 x 10"6) for at least seven
of the COPCs. The guidance assumes that if the COPC is measurable and quantifiable, then one can
determine if LFG controls are necessary and if the risks are acceptable. The guidance recommends
that if the laboratory does not detect a specific COPC in any sample then the chemical be excluded
from the risk and remediation analysis.  If the laboratory reports a COPC concentration for some
samples but no COPC concentration for other samples, then a value equal to 50 percent of the
quantitation limit will  be assigned to the non-detects (NDs)  and the average  concentration be
calculated accordingly.

    Analytical precision estimates for this program will be based on the collection and analysis of
duplicate  samples collected  from different locations across  the landfill.  A discussion of the
experimental design, including duplicate sample collection,  is presented in Section B.I. Duplicate
samples will be collected at a minimum frequency of 5 percent of the total number of samples. In
order to assess both sampling and analytical precision, a nested  design will be used with each
duplicate also being analyzed in duplicate.

    Accuracy estimates for the TAL list will be obtained by analyzing known  standards or spiked
samples—i.e., lab control standard (LCS) and LCS duplicate (LCSD) samples.  Accuracy estimates
for the on-site analyzers will be obtained by analyzing certified  standards.

A. 4.2 Representativeness
    A key consideration is collecting enough samples to adequately incorporate the large spatial
variability inherent in a population of gaseous emissions. Soil vapor sites generally depict seasonal
patterns that fluctuate in response to soil surface-sealing events such as precipitation and frost, in
contrast to dry warm periods. Precipitation and frost tended to alter the physical structure of the soil
pore spaces, rendering the soil less permeable. During soil surface-sealing events, the preferential
escape route for soil gas flow is through the unrestricted soil vapor wells due to their penetration
through the surface seal. (Similar responses have been noted  in protected crawl spaces beneath
homes.) The literature indicates that annual cycles depict highest methane concentrations around
spring thaws, secondarily  high concentrations around early fall, and the  rest of  the year showing
considerably  lower concentrations. From  an environmental perspective, the  most disconcerting
changes are those noted at monitoring locations that initially had low-to-insignificant combus-tible
gas concentrations, but later exhibited escalating LEL values. Long-term temporal variability is not
represented in this study. Short-term variability will be incorporated and assessed.

    Emission samples will be  collected at approximately 20  sample points following a preliminary
screen for areas of higher emissions (described in Section A-6 under Task 2). Section B. 1 discusses
the rationale for the sampling design. Thus, a biased sampling approach is intended to ensure that the
areas of higher emissions are included in the sample design.  The soil gas emissions are expected to
be relatively small compared with the passive vent emissions. All  of the passive vents will be screened
for flow rates and LFG to ensure the most accurate representation of this parameter.

    Samples from the gas extraction system will be collected from each vent. The combined header
is the best location to obtain a representative sample of LFG because this source is a spatial composite

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of all the extraction wells. Although it will be necessary to collect grab (rather than time-integrated)
samples, samples will be collected at different times over the course of the study to incorporate short-
term sample variation in the design and obtain the best representation of the extracted LFG.

   Nongaseous samples are also scheduled to be analyzed for the TAL and other physical chemical
properties. These include native soils, landfill cover soils, and potentially,  groundwater.  These
samples will all be collected in a way to ensure that the samples are representative of the time and
space they inhabit, but the sample design is not intended to incorporate the large component of spatial
or temporal variability. These samples will, therefore, not purport to represent the landfill site as a
whole or the surrounding areas.

A. 4.3 Completeness
   Data completeness, or the rate of data capture, is defined as the percentage of the total number of
observations of a given parameter that is considered valid. For these sample types, data completeness
will equal the number of valid sampling and analysis events divided by the total number of sampling
and analytical episodes attempted. The data capture objective for this program is 80 percent.

A.4.4 Data Usability
   The analytical data will be reviewed and  checked against the defined quality specifications for
each method. The effect of failing to meet any objective depends on the particular situation. In any
case, when the quality criteria are not met, the effect will be evaluated and discussed in the final data
report. Corrective action will be initiated, as appropriate. Any qualifications in the usability of the data
will be delineated.
A.5 Special Training/Certification
    Quality work can only be expected from staff who are qualified to perform project assignments.
As a minimum, project personnel shall receive training, as applicable, on (1) QAPPs, (2) site health
and safety plans, and (3) instrument calibration procedures. The sites are undergoing a hazardous
substance response that  is covered under  CERCLA;  as such,  employees (including contractor
employees) engaged in field activities are subj ect to the Occupational Safety and Health Act (OSHA)
standards specified in 40 CFR 1910.120. All field workers must demonstrate that they have received
a minimum of 40 hours of training prior to arriving on site.

    Additionally, on-site management and supervisors must demonstrate that they have received at
least eight additional hours of specialized training on  managing hazardous substance operations.
Project staff conducting site work shall be under the direct supervision of a trained and experienced
supervisor for at least three days before routine operations may begin. The contractor anticipates that
site-specific health  and safety training will be conducted by the site safety and health officer as
designated by the RPM.

    At least one field team member, prior to arrival onsite, will be trained on the Department of
Transportation standards that are applicable when shipping hazardous materials.

    The sampling, monitoring, analytical, and data reduction techniques and procedures are believed

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to be routine and  standardized. Each person assigned a duty or task shall  have demonstrated
proficiency and experience prior to arriving at the site or conducting an assigned task. Records of
personnel qualification and  training are to  be maintained by each  participating organization.
Affirmative statements from each person participating in the field project will be obtained to indicate
that the person has been appropriately trained on the QAPP, calibration procedures, health and safety
plan, and OSHA requirements prior to their being allowed to work on the sites. This information shall
be recorded in a log book by the field team manager.

A.6 Documents and Records
   Document control is the process of ensuring that documents are reviewed for adequacy, approved
for release or distribution, and used where a prescribed activity is to be performed. Record control is
the process of providing ready and reliable storage, protection and disposition of records. The records
manager will prepare an index of the records  used to complete this project.

   The TOM will be responsible for ensuring that the most up-to-date and approved version of the
QAPP has been distributed to those persons identified on the distribution list.
   The following types  of records will be compiled. The RPM will provide an index and cross
reference to  all  site-specific documents and files that are being used to provide the historical  data
concerning the site. This index will be included in the project files and stored until the project records
are disposed.
   •  Field Logbooks - The field  team manager is responsible for ensuring that logbooks include
      sufficient information to document the  events so that reliance on memory is minimized. The
      title page of each logbook will include:
      - Person to whom the logbook is assigned,
      - Logbook number,
      - Project name,
      - Start  date,
      - End date, and
      - Number of completed pages.

      Entries into the logbook will include but not be limited to:
      - Names of persons conducting field  activities;
      - Level of personal protection equipment;
      - Signature of person making entry;
      - Sample number and description of sample event;
      - Equipment and methods used;
      - Climatic conditions;
      - Sample location (coordinates and description);
      - Instrument readings and reference to raw data sheets used;
      - Changes and variance from SOPs (nonconformance document);
      - Corrective actions taken  to correct and minimize  impact  of  nonconforming  actions
         (corrective action report);
      - Field data, observation notes, and calibration results;  and
      - Description of packaging, shipping, and custody records.

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   •  COC Records - COC forms will be used to ensure that sample custody is  documented.
      Standardized COC forms and procedures will be followed. A copy of the COC form used for
      each group of samples will be placed in the project files.
   •  QC Sample Records - Information needed to document the generation of QC samples (such as
      field, trip, equipment, duplicate, and matrix spike) shall be compiled and placed in the project
      files.  The information will include  documentation on sample  integrity and  preservation,
      calibration, and standards traceability.
   •  Corrective Action Reports - These reports will be compiled whenever there is a variance from
      the QAPP. The report will describe the reasons for the variance and document the effects on
      the data usability.
   •  Manifest Records - If applicable and necessary to show regulatory compliance, copies of
      manifest records will be  prepared and placed in the project records.
   •  Laboratory Records - Each laboratory  will  compile  and maintain  sufficient  records to
      document that samples were managed in accordance with  the site-specific  QAPP and the
      laboratory-specific QAPP. Each laboratory shall include the following information as part of
      its deliverable:
      -  Sample data (e.g., run date and time, batch number,  quantity, results),
      -  Sample management records (COC, handling and storage, preservation),
      -  Test method (sample preparation, extraction, instrument calibration results, detection and
         reporting limits, test-specific QC criteria), and
      -  QA/QC reports demonstrating proper control and compliance with the analytical methods
         or applicable SOPs.

   The format of the data packages will be consistent with the site-specific QAPP requirements.
Records and project files will be retained for at least three years from the date that the revised draft
guidance document is submitted for EPA review and approval.  The index of records will be retained
for at least 5 years. The record will be retained at the contractors project office.

   The evidence files for analytical data will be maintained at the contractor's Project Management
Office. The content of the evidence file will include all relevant records, reports, correspondence,
logs, field logbooks, laboratory sample preparation and analysis logbooks, data package, pictures,
subcontractor's reports, COC records/forms, data review reports, etc. The evidence file will be under
custody of	, in a secured area.

   Raw data from the VOC chromatograms will be stored on magnetic tape or disks. Other analytical
data (i.e., records of injections, volumes, dilutions, and absorbency values) will be recorded in bound
paginated instrument logbooks. All logbook entries will be dated and initialed  by the author. In
addition to the analytical results, the preparation of analytical standards and QC samples will also be
documented.  Typical information  will  include  the dates of preparation  for stock  standards,
manufacturers' lot numbers, preparation procedures, and so forth. Chromatograms, standard curves,
and other laboratory documentation will be maintained in a central file for future inspection. Copies
of instrument logbooks and maintenance records will also be available for review.

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ELEMENT  B. DATA GENERATION AND ACQUISITION
B.I   Sampling Process Design
   Although this QAPP applies to all sites being monitored and sampled, specific sampling process
design can only by addressed on a site-specific basis.

   The information needed to determine the practicality  and usefulness  of the guidance will be
captured by observing the field activities, documenting issues and questions that arise, determining
if the required data was obtained, and seeking input from the proj ect participants concerning the level
of effort required versus  the level of effort anticipated. The project team  led by the  TOM will
collaboratively determine if the guidance was practical and useful.

   This document describes a monitoring program designed to estimate the  emission rates and the
concentrations of methane and other chemicals of potential concern. The experimental design is to
study the composition and emission rates of the landfill gas being emitted to ambient air. Each of the
three selected landfill sites will be sampled to:
   •  Provide the landfill gas composition that is representative of each section of the landfill as a
      whole,
   •  Provide the landfill gas composition at the landfill boundary in the subsurface strata,
   •  Provide the landfill gas composition in the subsurface strata immediately above a groundwater
      plume and adjacent to potentially affected off-site structures,

   A general overview of the sampling and monitoring approach is provided in Table B-l.

   The limitations inherent in this study include logistical constraints on the number of samples that
can be evaluated. Spatial and temporal variability are considered to be important variables relative
to sampling. Landfills are known to exhibit large variations in gas production from one  area to the
next.  The  focus  of the sample design is to maximize the spatial coverage by collecting LFG
information from all vents and on-site structures and from locations that are  established by using a
systematic 30 m by 30 m sampling grid that is defined by the landfill cover and extends to 30 m
beyond the landfill boundary. This systematic screening technique is designed to identify hot spot
locations for both methane and NMOCs. The screening results will be used to  identify up to 20
locations that will be sampled for the COPC-TAL. Depending on the landfill cover material, it is
assumed that the landfill vents will have higher LFG concentrations, and their impact on the ambient
air will be greater than the impacts derived from the surface emissions. The sample design assumes
that the emissions from the 20 locations with the highest NMOC concentration will adequately
characterize  the total landfill emissions.

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                  Table B-1. Summary of Sampling and Analytical Approach.
Emission Source
^andfill grid size 30 x
30m plus vents and
msite structures
.andfill NMOC hot
spots (not to exceed 20
ocations)
'ermeable native
subsurface soil gas at
)oundary locations (not
to exceed 20 samples)
'ermeable native
subsurface soil gas at
)ff-site structure(s) (not
to exceed 3 samples)
ndoor air (not to
;xceed 3 samples)
Outdoor air (not to
;xceed 3 samples)
Parameter
CH4 and NMOC
hot spots
COPCs
COPCs
Fixed LFG (CH4,
CO2, N2, and O2)
CH4
COPC
Soil properties (%
moisture, bulk
density, particle
size,
classification)
Gas pressure
Soil properties (%
moisture, bulk
density, particle
size,
classification)
COPCs
COPCs
Sampling
Technique
Direct reading
instrument
Summa canister SOP
1704
Summa canister SOP
1704
Summa cannister
Direct reading
Summa canister SOP
1704
Summa canister SOP
1704
Split barrel SOP
2012
Direct reading
instrument
Split barrel sampling
SOP 2012
Low-level Summa
cannister SOP 1704
Low-level Summa
canister SOP 1704
Analytical Technique
On- site
Modified FRMa 21
Section 4.3.1
TAGA-SOP 1712
Mobile GC/MS
SOP 1819

Multigas analyzer
Multigas manager
Mobile GC/MS
SOP 1819

FRM2-E

Mobile GC/MS
SOP 1819
Mobile GC/MS
SOP 1819
Off-site


TO15
FRM3C
Multigas monitor
with appropriate
detectors

TO15
ASTMD2216,
D1587, D854,
D422, D2487

ASTMD2216,
D1587, D054,
D422, D2487


 1FRM = Federal reference method.

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   The sample design assumes that the proximity of off-site structures to the landfill boundary is the
dominant risk driver for subsurface vapor intrusion into off-site buildings via pressure gradients. This
assumption may be invalid if there are interceptors, diversion structures, barriers, geologic faults, and
preferential vapor pathways between the landfill and the building.

   The sample design assumes that up to 10 clustered LFG monitoring wells, spaced 30m apart and
situated along the landfill boundary closest to the nearest off-site building, is sufficient to delineate
the presence of a methane vapor plume. This assumption may be invalid if the LFG concentration and
pressures outside of the established study area are higher than those inside the study area. Site-specific
data concerning native soil variability, LFG concentration variability, and distances between the
nearest structure and the landfill all affect the risks posed by the landfill. The number of wells and the
spacing may be adjusted up and down at the discretion of the TOM.

   The sample design assumes that the nearest off-site building may be affected by the subsurface
migration of LFG. Off-site subsurface soil gas sampling for up to three locations in the vicinity of the
nearest building is anticipated. These samples will be collected within each soil strata and as close to
the building foundations as practicable. Three indoor air and three ambient air samples may be col-
lected if screening level modeling shows potentially unacceptable risks. The ambient air samples
would be collected just outside of the building's roof drip line.

   The sample design assumes that at least one building may be affected by vapor volatilizing from
contaminated groundwater. The sample design assumes that the groundwater concentration of each
COPC is already known and that soil gas sampling will be conducted in the vicinity of a building
located within the areal extent of the groundwater plume. The sample design assumes that soil gas
samples may be collected within each permeable soil strata and as close to the potentially affected
building foundation as possible.

   The sample design also assumes that three indoor air samples may be collected from the basement
or an interior room of the potentially affected building located above the groundwater plume. Up to
three ambient air samples will be collected just outside of the building's roof drip line. The following
technical criteria will be used to identify the building:
   •  Accessibility and
   •  Proximity to most contaminated groundwater.

   Soil gas emissions are controlled by many physical and chemical properties and processes. Soil
gas monitoring does not provide repeatable quantitative information over time because of the dynamic
nature of phase equilibria, geologic variability, temperature variability, biodegradation, abiogenic
degradation, and so forth. The study design is not intended to address temporal variability. Field
activities will be halted and rescheduled if the ground has been saturated by rain, snow, or flood
waters within 48 hours of the scheduled sampling date. The field team leaders will record in a logbook
local temperature, humidity, barometric pressure, and elapsed time since a significant (0.1 inch) rain,
snow melt, or flood.

   The sample design proposes that hand-held global positioning system devices will be used to
guide the field technician in establishing the X, Y, Z coordinates for each  sample or measurement
taken. The project-specific QAPP will include a local coordinate system, and it will establish a bench

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mark that will allow the locations to be plotted on a scale map of the study area. Field technicians will
use professional judgment in determining whether or not they can reasonably collect the samples or
instrument readings at the predefined location. Log notes will be used to document the rational and
decision process whenever a sample location is modified. The field technician will collect duplicate
samples at the next location if a sample cannot be collected within 15m of the predefined location.
These replicate samples will be used to evaluate reproducibility and variability of the sampling and
analysis procedures.

    The maximum tolerable uncertainty associated with determining the LFG-COPC concentrations
and the pressure measurements has not been established. The  concentration data will be used in
equations and models that  use other  parameters and  constants that have a substantial degree of
uncertainty already associated with them. Expending additional resources to improve the measurement
data quality by a factor of two to five would require the use of ultra trace techniques that are much
more costly and time consuming.  The sampling  and analytical methods proposed herein are well
defined and commonly used.

    The sample design assumes that the RPM will select the off-site building and obtain access
agreements.

    The sample design assumes that the RPM will have already completed the utility checks and that
they are accurately plotted on scale drawings.

B.2 Sampling Methods
    This section describes the sampling and analytical methods that  will be used to complete this
project. The monitoring will consist  of measuring the concentration of LFG components (CH4,
NMOCs, CO2, N2, O2, and COPCs), determinating soil properties, and determinating in situ LFG
pressure.

    The soil gas samples will be collected at site-specific locations. The soil gas sampling will be
performed in accordance with U.S. EPA - ERT standard operating procedures (Laboratory-SOP 2042
- Soil Gas Sampling). The soil gas samples will be obtained by the slam-bar method to create a small-
diameter hole that is approximately 5 to 6 feet below ground surface. A narrow diameter tube will be
inserted into the hole to a point just above the bottom of the hole. The top of the hole will be sealed.
The soil gas sampling tube  will be purged by use of a sampling pump before a soil gas  sample is
collected.

    If Summa canisters are  used to collect LFG samples, all  canisters will be cleaned prior to the
sampling event, by placing them in areas maintained at 150 °C; the canisters will be evacuated to at
least 10"3 torr and then pressurized with humidified nitrogen to 30 psig. This process will be repeated
three times. This process is described in Laboratory-SOP-1703 - Summa Canister Cleaning.

    The extractive vents (individual gas collection wells) will be sampled for gas temperature, gas
flow rate, and gas composition, including methane, carbon dioxide, total NMOCs and the COPCs
included on the target analyte list. The moisture content will be determined on the basis of adiabatic
saturation. The extractive vents will be operating under a relatively high vacuum (e.g., 10 to 12 in.

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of Hg); hence, the cannister samples will be filled until the canister and duct pressures are equal.
Subatmospheric sampling will require a regulator, pressure gauge, and temperature gauge to be part
of the sampling equipment. The volume of gas is to be collected is fixed by the volume of the Summa
canister (6 L).

   Passive vents will be sampled to determine LFG flow rates. The passive vent flow rates will be
determined using a vane anemometer or a turbine meter (EPA reference Method 2D). These methods
are intrinsically safe and simple to operate, and measurements can be conducted without modifying
the vents. The gas will be collected into Summa canisters and Tedlar bags as specified in the sampling
strategy. The sample line will be inserted several feet inside the vent. Canisters will be kept at a slight
vacuum (e.g., 1 to 4 in. Hg) following sample collection.

   Ambient air sampling (indoor and outdoor) must be performed by following SOP 2105 - Air
Assessment Sampling and Monitoring Guidelines. Any ambient air samples will be collected over an
8- to 10-hr period.

   The gas samples will be collected in a Summa canister(s) as specified in the sampling strategy.
Samples will be drawn into the Summa canisters in accordance with Laboratory SOP 1704 - Summa
Canister Sampling. All  samples will be documented following Laboratory SOP  4001 - Log Book
Documentation, Laboratory  SOP 2002 - Sample documentation, Laboratory SOP 2004 -  Sample
packaging and shipment, and the COC procedures described in Section B.3.

   The gas samples will be  analyzed for the organic COPC target analyte list by using the mobile
GC/MS and following SOP 1819 - Analysis of Volatile Organic Compounds in air samples by Viking
Spectratrack 620 Gas Chromatography/Mass Spectrometry. All Summa canisters destined for off-site
analysis will be shipped to the laboratory that will be named in the site-specific QAPP.

B.3 Sample Handling and Custody
   The following text and COC procedures will be followed.

   A sample or evidence file is under one's custody if either:
   •  Are in your possession,
   •  Are in your view, after being in your possession,
   •  Are in your possession and you place them in a secured location, and
   •  Are in a designated secure area.

   The sample packaging and shipment procedures summarized below will ensure that the samples
will arrive at the laboratory with  the COC intact. Standard procedures for sample  handling and
custody include:
   •  The field sampler is personally responsible for the care and custody of the samples until they
      are transferred or properly dispatched. As few people as possible will handle the samples;
   •  All canister and bag containers will be tagged with sample numbers and locations;
   •  Sample tags will be completed for each sample using waterproof ink unless prohibited by
      weather conditions. For example, a logbook notation would explain that a pencil was used to
      fill out the sample tag because the ballpoint pen would not function in freezing weather;

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   •  The field team leader will review all field activities to determine whether proper custody
      procedures were followed during the field work and decide if additional samples are required.

   Field logbooks will provide the means of recording data collection activities performed. As such,
entries will be described in as much detail as possible so that a particular situation could be recon-
structed without reliance on memory. Field logbooks will be bound field survey books or notebooks.
Logbooks will be assigned to field personnel, but will be stored in the document control center when
not in use. Each logbook will be identified by the project-specific document number.

   The title page of each logbook will contain the following:
   •  Person to whom the logbook is  assigned,
   •  Logbook number,
   •  Project name,
   •  Project start date, and
   •  End date.

   Entries into the logbook will contain a variety of information. At the beginning of each entry, the
date, start time, weather, names of all sampling team members present, level of personal protection
being used, and the signature of the person making the entry will be  entered. The names of visitors
to the site, field sampling or investigation team personnel, and the purpose of their visit will also be
recorded in the field logbook.

   Measurements made and samples collected will be recorded. All entries will be made in ink and
no erasures will be made. If an incorrect entry is made, the information will be crossed out with a
single strike mark. Whenever a sample is collected, or a measurement is made, a detailed description
of the location of the station, which includes compass and distance measurements, will be recorded.
The number of the photographs taken of the station, if any, will also be noted. All equipment used to
make measurements will be identified, along with the date of calibration.

   Samples will be collected following the sampling procedures documented in the site-specific
QAPP. The equipment used to collect samples will be noted, along with the time of sampling, sample
description, depth at which the sample was collected, volume, and number of containers. A sample
identification number will be assigned prior to sample collection. Field duplicate samples, which will
receive an entirely separate sample identification number, will be noted under sample description.

   The COC form is used to track and document unbroken custody of samples as identified by the
unique sample number. The contractor's standard form is  shown on Figures B-l  and B-2. Blank
forms can be obtained by contacting The contractor's QA/QC staff personnel. The original COC form
will be kept by the receiving laboratory and will accompany the analytical report. A copy of the COC
form from each group of samples will  be supplied to the contractor's's QA/QC chemist, and a copy
will be placed in the project files.

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             Stainless Steel Canister Chain-of-Custody
            	To be Completed by Field Sampler	
 Sample Control Number              	
 Canister Number                    	
 Date Sampled                       	
 Well/Station Number                 	
 OVA Reading (Peak)                 	
 Address/Refinery Location            	
 Sampler's Initials                    	
 Type (Circle One)  Ambient or Point Source (specify):
                          Time:
 Comments:
                          To be Completed by Lab (Part One)
       Operation
1. Canister Cleaned
2. Canister Blanked
3. Filter Cleaned
4. Canister Evacuated
5. Canister Shipped
6. Canister Received
7. Analysis Completed
8. Sample Discarded
      Date
     Initials
         Comments
                                    Pressure:
                                   APL =
                                   APF =
                                   APL-APF=
                          To be Completed by Lab (Part Two)
      Parameter
Dilution 1
Dilution 2
Dilution 3
Dilution 4
Initial Pressure
Final Pressure
Add UHPAir
Dilution Factor
FINAL Dilution Factor
Dilution Date
Dilution Time
Initials
                Figure B-2. Chain-of-Custody Report for Canister Samples.

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    Samples will be accompanied by a properly completed COC form, and the sample numbers and
locations will be listed on the COC form. When transferring the possession of samples, the individuals
relinquishing and receiving will sign, date, and note the time on the record. This record documents
transfer of custody of samples from the sampler to another person, to a mobile laboratory, to the
permanent laboratory, or to/from a secure storage area.

    Samples will be properly packaged for shipment and dispatched to the appropriate laboratory for
analysis, with a separate signed  custody record  enclosed in each sample container.  Shipping
containers will be locked and secured with strapping tape and EPA custody seals for shipment to the
laboratory. The preferred procedure includes use of a custody seal attached to the front right and back
left of the container. The custody seals are covered with clear plastic tape. The container is strapped
shut with strapping tape in at least two locations.

    All shipments will be accompanied by the COC record identifying the  contents. The original
record will accompany the shipment, and the pink and yellow copies will be retained by the sampler
for returning to the sampling office.

    If the samples are sent by common carrier, a bill of lading should be used. Receipts of bills of
lading will be retained as part of the permanent documentation. If sent by mail, the package will be
registered with return receipt requested. Commercial carriers are not required to sign off on the
custody form as long as the custody forms are sealed inside the sample cooler and the custody  seals
remain intact.

    The contractor's chemist must be notified prior to any sample collection activity. This person will
be the primary line of communication between the project site and the laboratory.

The designated laboratory sample receipt clerk is authorized to accept samples and is charged with
the responsibility for proper completion of the required sample receipt documentation. As required,
analysts are assigned to assist the sample receipt clerk in sample log-in procedures. In all cases, COC
and analytical request documents become part of the permanent file relative to the samples collected.
Those files are retained indefinitely in the laboratory's facility.

    All samples in storage at the laboratory are retained in the custody of the designated sample
custodian until released as required for analytical work. A record of the custody change is made by
the analyst and checked by the sample custodian at the time the sample is taken from the cold storage.
Internal custody files are retained indefinitely in laboratory  files.

    After analysis is complete on a sample set, the samples or sample processing products will be held
for 30 days. The laboratory is responsible for disposing the samples, and it must be accomplished in
complete accordance with all regulations governing such  activities.

    All samples,  including those collected with direct reading  instruments, will be given a unique
sample identification number that identifies the type of sampling medium, the date collected, and the
sample type (regular, blank, collocated). This information will facilitate manipulation of the  data.
Each sample number will have five distinct parts. An example is shown below.

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                                 LFSG-01-101501-R-001

   The first part of the sample number designates the sample type:
   •  LFSG indicates landfill soil gas;
   •  NSG indicates native soil gas;
   •  PVG indicates passive vent gas;
   •  EVG indicates extractive vent gas;
   •  AA1 indicates ambient air indoor;
   •  AAO indicates ambient air outdoor;
   •  OC indicates other condensate sample type;
   •  OL indicates other liquid sample type, groundwater, leachate, etc.; and
   •  OS indicates other soil type, split barrel.

   The second part designates the sample media:
   •  00 indicates Tedlar bag sample,
   •  01 indicates Summa canister sample,
   •  02 indicates direct-read gas analysis,
   •  04 indicates fixed gas (CH4, O2, N2, CO2) analysis, and
   •  05 indicates soil sample to be analyzed for physical properties.

   The next six numbers represent the date the sample was collected (MMDDYY). The next letter
indicates the sample type:  R for Regular, D for duplicate, C for Collocated or B for Blank. The last
three digits are a sequential number unique for each site, starting at 001  and continuing until the
sampling is complete.

B.4   Analytical Methods
   The analytical methods for this project are divided into on-site analysis—organic vapor, fixed
gases  (oxygen,  nitrogen, methane,  carbon dioxide), and flow rate measurements—and  off-site
analyses (VOC canisters and physical properties).  The analytical methods  to be used in this project
include:

   Compound                       Method
Gaseous Organic COPC        TO-15 per EPA/600/R-96/033, March 1996
Methane                     TO-15 per EPA/600/R-96/033, March 1996
Gaseous NMOC              GC/FID per EPA/600-R-98/16
Fixed Gases (CO2, CH4, N2, O2) FRM 3C
Soil Moisture                 ASTM D2216
Bulk Density                  ASTM D1587
Particle Density               ASTM D854
Particle Size                  ASTM D422
Aqueous Liquids              SW846 Method 8260
                             SW846 Method 8270
LFG Pressure                 FRM 2E

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   Acceptance criteria is established by data generated from a specific method and instrument, and
will be laboratory specific. Procedures (laboratory SOPs or published methods) will include specific
information on tuning criteria, calibration procedures, and acceptance criteria for QC check standards.
The specific information on laboratory analysis will be included in the site-specific QAPPs.

B.4.1  On-site Analyses
   The Agilent 6890 gas chromatograph and 5973N mass  spectrometer (GC/MS) will be used to
perform on-site analysis of gas samples. The target compounds are site specific but inclusive of the
COPCs identified in Table A-3.

   Organic vapor samples will be analyzed by trapping and subsequent thermal desorption of aliquots
via an OI analytical 4560 sample concentrator followed by GC/MS analysis. The ChemStation data
system will be used to evaluate and process the data. Table B-2 lists the targeted Agilent GC/MS and
the OI Analytical 4560 Sample Concentrator operating conditions. Once the trap is cooled, an aliquot
of sample (250 to 1000 mL) will be drawn onto the sorbent trap along with 25 nL of the internal
standard. The  internal standard is a mixture of bromochloromethane, chlorobenzene-d5 and 1,4-
diflorobenzene at 10 ppbv in accordance with Method TO-15. The sample will be inj ected by thermal
desorption onto the  column head of the GC/MS  for subsequent analysis. The GC is temperature
programmed to separate the VOCs that will be detected by the MS detector.  VOCs in the sample will
be identified by comparing their retention times and mass spectra to those of an analytical standard
and a reference mass spectral database, the National Institute of Standards and Technology (NIST)
library.

   The fixed gases  of methane, oxygen,  nitrogen, and carbon dioxide will be analyzed using the
micro gas chromatograph (Model M200H MGC). The M200H MGC will be set up on site. The site-
specific QAPP will  define the setup procedures that will  be used by EPA-Laboratory. Soil gas
samples will be collected and brought to the M200H MGC location for analysis. The M200H MGC
will be operated in accordance with the manufacturer's operating manual.

   The M200H MGC is a dual capillary column (A and B) and micro-chip thermal conductivity
detector (jiTCDs) analytical instrument. An internal sampling pump pulls a vapor-phase  sample
through a fixed sampling loop for a programmed period of time. Injection valves are activated, and
a sample aliquot is simultaneously injected onto both capillary columns.

   Once injected into the  MGC  system, the sample components are separated by the capillary
columns into discrete peaks. The peaks are detected by the (iTCDs, and the  results are electronically
stored by the EZChrom 200 data system. The dual column and dual jiTCD system allows independent
detection and identification of compounds. The results from  column A are reported for nitrogen and
oxygen. The results from column B are reported for carbon dioxide and methane.

   The EZChrom 200 data system controls all operations for the M200H MGC. The identification
and quantitation  of compound peaks are conducted by comparing the sample peak responses and
retention times with those of standards stored in the EZChrom 200 method calibrations. Both single-
point and multipoint calibrations can be used. The gas samples will be analyzed using a multipoint
calibration for CH4, O2, andN2 (the primary target compounds), and a single-point calibration for CO2
(the secondary target compound) with an additional check standard to verify results.

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               Table B-2.  Targeted Instrument Conditions for Analysis of VOCs.
Agilent GC/MS
Column
lead Pressure
?low rate
Split Ratio
GC Temperature
njector Temperature
Vlass Spectrometer
Source Temperature
Rtx-Volatiles, 0.18 mm ID x 20 m, 2.0 |im df
16.82psi
helium at 0.8 mL/min
40:1
35°C(holdl.Omin)
15°Cperminto 190 °C
10 °C per min to 200 °C (hold 5.0 min)
180 °C
Electron impact ionization at a nominal electron energy
of 70 electron volts, scanning from 36 to 260 amu at
one scan/s
230 °C
JI Analytical 4560 Sample Concentrator
'urge Gas
?low Rate
'urge3
Sample Vacuum Flow
Valve Temperature
Transfer Line Temperature
Adsorption Temperature
)esorb Temperature
3ake
Water Management Heat
During Purge
During Desorb
During Bake
helium
40 mL/(min)
±12minat20°C
50 mL/min
150 °C
150 °C
Ambient (27 °C)
4minatl90°C
8 min at 200 °C
ON
100 °C
o°c
240 °C
1 Total purge time varies depending on the total sample volume.

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   Two landfill systems will be monitored for flow rate: the extractive system vents and passive
landfill gas vents. The flow rate from the extractive system will be measured using a standard pitot
tube placed at the centroid of the header pipe or from an in-line orifice plate. The duct temperature
will also be measured. The delta pressure inside the pipe, static pressure of the pipe, gas temperature,
gas molecular weight, and moisture content, and pipe cross-sectional area will be used to calculate
a volumetric flow rate. The equations used to calculate the volumetric flow rate are shown below.
To help minimize any effect caused by disturbance of the pitot tube itself, a Vs-inch-diameter standard
pitot will be used.

   Pd = Pa + Ps                                                                        (1)
    V,  =   Td(kP)/(MW)Pd                                                        (2)

    a  = (^)G4)(3600)                                                                  (3)

    Q, = (a)(528°R)/ Wy29.92)                                                       (4)
Where:  Pd = absolute duct pressure (inches Hg),
        Pa = ambient pressure (inches Hg),
        Ps = duct static pressure (inches Hg),
        Vs = vapor recovery well velocity (feet per second),
        Td = duct temperature (degrees Rankine),
        AP = differential pressure across the pipe (inches H2O),
        MW= average gas molecular weight (pounds per pound-mole),
        Qa = actual flow rate (cubic feet per hour),
        A = cross-sectional area of duct (square feet),
        Q, = standard flow rate (SCFH),
        528°R = standard temperature in degrees Rankine (68 °F), and
        29.92 in. Hg = standard pressure.

The LFG molecular weight will be determined from results of canister analysis using EPA Method
3 procedures. The moisture content will either be estimated on the basis of duct temperature and
adiabatic saturation tables, measured directly using EPA Method 4, or taken from plant measurements.

   Flow rate measurements from the LFG passive vents will be performed using a vane anemometer
or portable turbine meter (EPA Method 2D). These devices provide a measure of linear velocity and
are very adapted to measuring ducts and vents. The velocity can then be converted to volumetric flow
using the vent cross-sectional area. Gas temperature and barometric pressure will be measured and
used to calculate a standard volumetric flow.

   Organic  vapor analyzers (OVA) will be used on site to  "sniff out areas of high methane and
NMOC  concentrations. These instruments use FIDs or PIDs to measure methane and non-methane
hydrocarbon concentrations. These instruments will be used to identify locations where the LFG
escaping from the landfill has the highest NMOC concentration. The instruments will be calibrated
daily during the project using methane or ethane (10,000 ppmv) in air standards traceable to NIST

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standards. The OVA's will also be checked using a zero point—ultra high purity-air (UHP-air)—and
low range (100 ppmv) calibration gas.

B. 4.2 Off-site Analyses
   Bulk density is the ratio of the mass of the dry solids to the bulk volume of the sample. The bulk
volume includes the volume of the solids, pores, and any liquid that may be present. For lithified
geologic materials (rocks, stones, gravel), the bulk density for a given sample is a fixed value. For
unconsolidated sediments, the bulk density will vary as a function of grain packing. If expandable
clays are present, the bulk density will vary as a function of moisture content. For this project, bulk
density will be determined using ASTM method D854. The mass of the samples is calculated  by
difference using a top-loading balance.  The dimensions of the specimen (cube or cylinder) are
measured using a ruler having a precision of ±1 mm. The bulk density is calculated by dividing the
mass by the volume (grams per cubic meter).

   For particles less than 4.75 mm in diameter, particle density is determined by measuring the mass
of liquid required to fill a closed container of known volume containing a known mass of solids. The
volume of the liquid is calculated from the mass of the liquid and the known density of the liquid at
the temperature at which the measurements are made. The  volume of the solids is the difference
between the volume of the container and the volume of the liquid. Particle density is the mass of the
solids divided by the volume of the solids. In ASTM Method D 854, specific gravity is defined as "the
ratio of the weight in air of a given volume of a material at a stated temperature to the weight in  air
of an equal volume of distilled water at a stated temperature." If specific gravity rather than density
is desired, then the density of the solids at the stated temperature is divided by the density of water
at a stated temperature.

   The water content or moisture content of the soil samples will be determined using ATSM Method
D 2216. In this method, a measured mass of soil is dried in  an oven at 110 ±5 °C until the sample
reaches a constant mass. If performed on site, a microwave oven may be used to dry the soil samples.
The water content, expressed  as a percentage,  is then calculated as the ratio of the mass of water
present to the mass of soil, multiplied by 100.

   The particle size distribution of the soil samples will be determined using ASTM D422-63, which
is performed in two steps. The first step, for particulates above 75 |im, (retained on a Number 200
sieve) uses a number of sieves  of various sizes to achieve fractionation down to 75 |im (Number 200
sieve). In the second step, the size distribution of the material that passes the Number 200 sieve (i.e.,
less than 75 |im) will be determined by using a sedimentation process and a hydrometer.

   As specified in the sampling strategy, some organic vapor samples will be sent to  an off-site
laboratory. The VOCs collected will be analyzed using a  GC equipped with dual columns and
multiple detectors. The detectors include a FID, a PID, and an ELCD. Samples will also be analyzed
using GC/MS to confirm compound identity and help identify compounds not identified by other
methods. Fixed gas (i.e., N2, O2, CO2, and CH4) analyses will also be performed off site using a
thermal conductivity detector (TCD). Calibration information is presented in  Section B.7.

   The canisters will be shipped to the site-specific laboratory for analysis. On arrival, the canister

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COC forms will be reviewed for completeness, and the final field pressures will be checked to verify
that the canisters did not leak during transit. Canisters determined to have leaked will be voided and
not analyzed. Following pressure checks, the canisters will be pressurized with UHP-grade helium
to both dilute the sample and facilitate its removal from the canister. Helium will be used because
UHP-grade nitrogen or air would normally interfere with the fixed-gas analysis.

   The speciated VOC analysis samples will use Method TO-15. EPA method TO-15 provides
techniques for the analysis of airborne VOCs collected as whole air or LFG samples in stainless steel
canisters. Up to 0.5 L of gas is withdrawn from the canister through a mass flow controller and is
either cryofocused via liquid argon or concentrated using a multi-sorbent bed. The focused sample
is then flash heated through a hydrophobic drying system which removes water from the sample
stream prior to analysis by full scan GC/MS. For low level analysis, a cryogenic valve is employed
to cold trap the gases onto the GC column.

   Compounds are qualitatively identified based on retention time and by comparing background-
subtracted sample spectra to the reference library spectra. An analyte is qualitatively identified when
the following two criteria are met:
   •  The relative retention time (RRT) for the analyte must be within ±0.06 RRT units of the RRT
      of the analyte in the daily continuing calibration check. When high moisture in a sample causes
      a retention time shift, an exception is taken, providing the shift is consistent based on the
      internal standards;
   •  Ions present in the standard spectrum greater that 10 percent of the most abundant ion must be
      present. Also, the relative intensity of the ions greater than  10 percent, must be ± 20 percent
      of the intensity in the standard spectrum.

   The ion intensity  test is performed by the GC/MS software. Ions that do not meet the intensity
criteria are flagged in the raw data. Failure to meet the intensity criteria my be indicative of matrix
interference or low signal to noise (i.e., low concentration).

   Quantitation is based on the integrated abundance of the primary ion for each analyte. If the
response for any quantitation ion exceeds the initial calibration range of the GC/MS system, the
sample is diluted and reanalyzed.

   When interference with the primary quantitation ion occurs, quantitation on the secondary ion is
carried out after a new response factor (using the secondary ion) is generated from the calibration.
Therefore, the same ion used to establish the response factor is used to quantify target analytes in the
sample. This is noted in the laboratory narrative included in the report. The criterion for using the
secondary ion for quantitation is a difference in the reported result of 50 percent or more.

   Canisters are connected to the inlet of the focusing unit with  1A in. stainless steel fittings, and
connections are leak checked by monitoring the flow on the controller. As vacuum is achieved, the
flow will drop to less than 5 ml/min. After leak checking is complete, the valve on the canister is
opened and flow allowed to equilibrate. The equilibration period also allows for sweeping of the line
and trap. During this time, a 1-cc gas sample valve injection of internal standard/surrogate standards
is made.

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    Sampling is initiated by rotating the port valve into the sample position. Air from the canister flow
into the focusing trap. Sampling continues until the desire volume of air has been withdrawn.

    Following the sampling period, the port valve is rotated into the back flush position, and the trap
heater is turned ON. Contents of the trap are then swept by carrier gas into the drier. Following this,
the drier is flash heated and the contents back flushed into the GC/MS. For low level analysis, the
gases are cold-trapped on to the GC column using a cryogenic valve. A 4 to 5 min bake cycle is then
used to clean the system for the next sample. The bake cycle eliminates sample carryover by sweeping
both the heated trap and heated drier to vent.

    VOC samples collected in Summa polished stainless steel canisters are subject to a 7-day hold
time. The 7-day analytical hold time is not meant to be a statement of compound stability or sample
integrity. All compounds on the target analyte list have been studied for compound stability in Summa
canisters and found to be stable up to 30 days (there have been very limited studies of stability beyond
30 days).

    The identification of peaks will be based on normalized retention times, detector responses, and
individual compound response from the daily calibration standard in accordance with Method TO-15.
The retention time of each peak on the FID will be calculated relative to the retention time (RRT) of
toluene. The PID data will then be scanned for any peaks that matched the FID retention times. The
corresponding PID/FID response ratio will then be compared with the sample's PID/FID response for
toluene to generate a toluene-normalized response (TNR) factor. Different  compound classes and
individual compounds produce characteristic TNRs. The RRT and TNR data will be compared with
the compound database parameters as well as the daily analysis of calibration standard for potential
matches. The potential matches will be reviewed and validated by experienced personnel (both at the
performing laboratory and by the contractor's chemist) to ensure  data quality. During this program,
the chromatograms will be validated for the major compounds  (i.e., those contained in the calibration
standard) found in the chromatogram followed by evaluation  of the chromatograms for compounds
not calibrated. The quantitation of the major compounds will be based on individual response factors,
which will be calculated daily by analyzing either a low-level standard (cryogenic trapping technique)
or a higher-level  standard (fixed loop method). The remaining compounds will be quantitated on the
basis of a hexane response. The identification will be based on a library search. The lessons learned
project summary will note whenever compounds not on the target list are identified, but there will be
no attempt to quantify the concentrated by rerunning the samples with a different set of calibration
curves.

B.5 Quality  Control
    The overall QA objective is to provide defensible data of known quality meeting QA objectives.
To that end, procedures are developed and implemented for field sampling, COC, laboratory analysis,
and reporting that  will provide results which are legally defensible in  a  court of law.  Specific
procedures for sampling, COC, instrument calibration, laboratory analysis, data reporting, audits,
preventive maintenance of field equipment, and corrective action are described in Section B6 of this
QAPP.

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   Each laboratory participating in this project will have established a QA program with the
objective of providing sound analytical chemical or physical measurements. This laboratory-specific
program will incorporate the QC procedures, any necessary corrective actions, and all documentation
required during data collection, as well as the QA measures performed by the laboratory's manage-
ment to ensure acceptable data production. The contractor's Q A officer will verify that the laboratory
has a written QA plan and that the laboratory has an organizational structure committed to
   •  Maintaining data integrity, validity, and usability;
   •  Ensuring that analytical measurement systems are maintained;
   •  Detecting problems through data assessment and established corrective action procedures that
      keep the analytical process reliable; and
   •  Documenting all aspects of the measurement process to provide data that are technically sound
      and defensible.

   The EPA laboratory team manager will select the laboratories using their existing contractor
selection processes. The purpose of this section is to address the specific objectives for accuracy,
precision, completeness, representativeness, and comparability.

   Field blank, trip blank, duplicate and matrix spike, and split/collocated samples will be analyzed
to assess the quality of the data derived from the field sampling program. Field blank samples consist
of distilled water and are analyzed to check for procedural contamination at the site that may cause
sample contamination. Trip blanks consist of distilled water and or reagents. These trip blanks will
be used to assess  the potential for sample contamination during sample shipment  and storage.
Duplicate samples will be analyzed to  check for sampling and  analytical reproducibility. Matrix
spikes provide information about the effect of the sample matrix on the digestion and measurement
methodology. The  matrix spike will include the COPC-TALs identified in Table A-l. Laboratory
spiking levels will be  at the same  concentration as the field sample. All matrix spikes will  be
performed in duplicate and will hereinafter be referred to as matrix spike/matrix spike duplicate
(MS/MSD) samples. MS/MSDs will be collected for every 20 or fewer investigative samples. Soil
and gas MS/MSD samples require no extra volume for VOAs or extractable organics. Split/collocated
samples will be collected for five percent of the gaseous  samples. These collected samples will be
analyzed offsite as  a check on the on-site laboratory efforts.

   The number of duplicate, field blank, equipment blank, trip blank, and split samples to  be
collected are listed in Table B-3.

   The level of QC effort for testing on the organics target analyte list (volatiles and semi-volatiles)
will be equivalent to the protocols of "Laboratory Data Validation Functional Guidelines for Eval-
uating Organic/Pesticides and PCBs Analyses" EPA-540/R/94/090-092.  The level of QC effort for
testing of methane and NMOC in air samples will conform to the protocols from the National Institute
for Occupational Safety and Health (NIOSH) "Manual of Analytical Methods," Third Edition, U.S.
Department of Health and Human Services, August 1994.

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       Table B-3. Guidelines for Minimum QA/QC Samples for Field Sampling Programs.
Media
Soil,
Sediment,
Solids
Gases
Calibration/
vfeat Source
Material
Duplicates/
Replicates
5%
5%
One per 20
samples
Field
Blanks
None
One per reagent per
sampling event, per
media lot
One per reagent per
sampling event
Equipment
Blanks
None
One per
sampling event
One per
sampling event
Trip
Blanks
None
5%
None
Split
Samples
None
5%
None
MS/MSDs
None
5%
None
Note:   Laboratory blanks are method-specific and are not included in this table.
    The QC level  of effort for the field measurement of methane and NMOCs consists  of pre-
measurement calibration and a post-measurement verification using standard reference materials.
This procedure will be performed twice a day for each day of screening level analyses. The QC effort
for field measurements will include twice daily calibration of the instrument using mixtures of gas
in cylinders. The calibration gases will include UHP-air, methane, and ethane in air. Dilution probes
will be used to verify that calibration between 0 and 500 ppm is maintained. Scott Speciality Gases
or similar commercial suppliers will provide the calibration gases and a certificate of analysis will be
obtained for each lot used.

    The fundamental QA objective with respect to accuracy, precision, and sensitivity of laboratory
analytical data is to achieve the QC acceptance criteria of the analytical methods being used  and the
targets presented in Tables A-5, A-6, and A-7.

    Laboratory results  will be assessed for compliance with required precision, accuracy, and
sensitivity as described below.

Precision
    Precision of laboratory analysis will be assessed by comparing the analytical results between
MS/MSD for organic analysis. The relative percent difference (RPD) will be calculated for each pair
of duplicate analysis using the equation
                                RPD =
                                           S-D
                                             D)I2)
x 100
Where:   S = First sample value (original or MS value) and
          D = Second sample value (duplicate or MSD value).

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   Field precision is assessed through the collection and measurement of field duplicates at a rate of
1 duplicate per 20 analytical samples.

Accuracy
   Accuracy of laboratory results will be assessed for compliance with the established QC criteria
using the analytical results of method blanks, reagent/preparation blank, MS/MSD samples and field
blanks. Blank contamination is an indicator of systemic contamination, and it may alter the detection
limits that can be achieved by the analytical methods. The analytical results of the various blanks will
not be used to alter the quantitative results. The percent recovery (%R) of matrix spike samples will
be calculated using the equation

                                  %R = —~— X 100


Where:    A = The analyte concentration determined experimentally from the spiked sample,
          B = The background level determined by a separate analysis of the unspiked sample, and
          C = The amount of the spike added.

   Accuracy in the field is assessed through the use of field and trip blanks and through the adherence
to all sample  handling, preservation, and  holding times. Onsite analyses will be validated via
collocated/split samples being sent to an offsite analytical laboratory at a rate of one collocated sample
per 20 samples analyzed onsite.

Sensitivity
   Achieving method detection limits depends  on instrumental sensitivity  and matrix  effects.
Therefore, it  is important to monitor the instrumental sensitivity to ensure data quality through
constant instrument performance. The instrumental sensitivity will be monitored through the analysis
of method blank, calibration check sample, and laboratory control samples, and so forth.

   The usefulness of sampling and  analysis data also depends on whether they meet the criteria for
completeness, representativeness, and comparability. The QA objectives are that all measurements
be representative of the medium or operation being tested and that all data resulting from sampling
and analysis be comparable. Wherever possible, sampling and analysis by reference methods and
standard  reporting units specified by the analytical method will be used to aid  in ensuring that QA
objectives are met.

   COMPLETENESS is a measure of the amount of valid data obtained from a measurement system
compared to the amount that was expected to be obtained under normal conditions. It is expected that
the analytical laboratory will provide data meeting QC  acceptance criteria of 80 percent or more for
all samples tested. Following completion of the analytical testing, the percent completeness will be
calculated by the equation
                                  (number of valid data)
      Completeness (%): =    7	-jr-  X 100
                             f number of samples collected j
                             V for each parameter analyzed;

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   Field completeness is a measure of the amount of valid measurements obtained from all the
measurements taken in the proj ect. Field completeness for this proj ect will be greater than 80 percent.

   REPRESENTATIVENESS expresses the degree to which data accurately and precisely represent
a characteristic of a population, parameter variations at a sampling point, a process condition, or an
environmental condition. Representativeness is a qualitative parameter that depends on the proper
design of the sampling program and proper laboratory protocol.  The sampling network will  be
designed to provide data representative of site conditions. During development of the sampling
network, consideration will be given to past waste disposal practices, existing analytical data,  physical
setting and processes, and  constraints inherent to the Superfund program. The rationale of the
sampling network is discussed in detail in Section B.I.  Representativeness will be satisfied  by
ensuring that proper sampling technique are used, proper analytical procedure are followed, and
holding times of the samples are not exceeded in the laboratory. Representativeness depends on the
proper design of the sampling program and will be satisfied by ensuring that the site-specific QAPP
is followed and that proper sampling techniques are used. Representativeness is determined through
completion of the DQO Process presented in Section A7. Representativeness will be assessed by the
analysis of duplicated samples, and Table A-4 indicates how many duplicate samples are to  be
evaluated. The duplicate sample locations will be identified in the site-specific QAPPS.

   COMPARABILITY expresses the confidence with which one data set can be compared with
another. The extent to which existing and planned analytical data will be comparable depends on the
similarity of sampling and analytical methods. The procedures used to obtain the planned analytical
data  are expected to provide comparable  data.  These new analytical data, however, may not  be
directly comparable to existing data  because of a difference  in procedures and QA objectives.
Comparability depends on the proper design of the sampling program and will be satisfied by ensuring
that the site-specific QAPP is followed and that proper sampling techniques are used.

   Field data will be assessed by the QC  officer. The QC officer will review the field results for
compliance with the established QC criteria. Accuracy of the field measurements will be assessed
using daily instrument calibration, calibration  check, and analysis  of blanks. Precision will  be
assessed on the basis of reproducibility by  obtaining multiple readings of a single sample.

B.6  Instrument/Equipment Testing, Inspection and Maintenance Requirements
   The nature of the project activities requires periodic inspections to ensure that they are being
completed in accordance with applicable regulations and project/contract requirements. Inspections
are typically completed by the QA officer and other designated project personnel. The nature and
frequency of inspections is a function of project activities; preparation, initial, follow-up, and final
inspections are typically conducted. Results of inspections will be summarized, and inspection reports
will  be provided to the TOM  on a regular basis. Recommendations  for correcting deficiencies
identified during inspections are developed by the Project Manager and discussed with the TOM.

   Equipment used in the field is calibrated by the manufacturer or calibration is checked in-house
prior to use. Calibration of the equipment is verified in accordance with the manufacturer recom-
mendations and whenever repairs are made after a malfunction has been noted. The Field Team
leader maintains a list of certificates for each piece of equipment being used. Maintenance records

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of equipment adjustments and repairs are kept in equipment maintenance logs. These records include
the date and description of the maintenance performed.

   A preparatory inspection will be performed, at the request of the TOM, prior to initiation of field
activities. The preparatory inspections will include:
   •  Review of task order requirements,
   •  Review and approval of plans and other submittals,
   •  Verification of control testing procedures and schedules,
   •  Examination of all materials and equipment to ensure that approved submittals conform to
      design specifications and are promptly stored,
   •  Review of activity hazard assessments to ensure appropriate levels of health and safety,
   •  Verification of construction tolerances and workmanship standards,
   •  Verification of adequacy of any required preliminary activities including an inspection of the
      work area,
   •  Discussion of QC procedures that required levels of workmanship and inspection criteria on
      site with project  staff concentrating on the work plan and impending activities,
   •  Review of preparatory inspection notes and verification of the status of preparatory activities,
   •  Verification of procedures and schedules for control testing,
   •  Evaluation of the results of any control testing,
   •  Examination of the quality of the workmanship of construction (where appropriate),
   •  Review of the safety procedures in accordance with the site Safety and Health Plan including
      equipment required and upgrade/downgrade criteria, and
   •  Review of project submittals and proposed activities for omissions or dimensional errors.

Follow-up/Final Inspections
   Follow-up inspections will  be performed at the request of the  TOM to  ensure continued
compliance with the project contract requirements. These inspections encompass:
   •  Verifying control test results,
   •  Examining the quality of workmanship of construction (where appropriate),
   •  Reviewing project submittals relating to project closeout.

   Any nonconforming items will be documented in a nonconformance report. Figure B-3 presents
an example nonconformance report. Corrective actions to  noted deficiencies will be required unless
a variance from the specifications is approved by the  TOM.

   Field equipment  for a site will be identified in  the  site-specific  QAPP.  Specific preventive
maintenance  procedures  to be followed for field  equipment  are those  recommended by  the
manufacturer.

   Field instruments will be checked and calibrated in the warehouse before they are shipped or
carried to the field. These instruments will be checked and calibrated daily before use. Additionally,
calibration checks will  be performed after every 20 samples and will be documented on the Field
Meter/Calibration Log Sheets.

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 ' s •* J '
                     Nonconformance Report
Date 	  Project
Project     	
Description of Nonconformance:
Inspector 	  Date
Corrective Action Required:


Prepared by:
Name:
To be verified by:
Name:
Date
Date

Corrective Action Executed:


Executed by:
Name:
Inspected by:
Name:
Approved by:
Name:
Follow up
Name:
Date
Date
Date

Date

                  Figure B-3. Example Nonconformance Report.

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   Critical spare parts such as tape, papers, diaphragms, and batteries will be kept on the site to
minimize instrument downtime. Backup instruments and equipment will be available on site or within
one-day shipment to avoid delays  in the field schedule. Table B-4  presents routine preventive
maintenance schedules for common field monitoring equipment.

               Table B-4. Routine Preventative Maintenance Procedures and
                         Schedules for Field Monitoring Equipment.
Instrument
Combustible Gas and O2
Alarm
Photoionization Detector
Flame lonization
Detector
Water Level Indicator
Activity
Charge battery pack
Clean sample inlet filter
Clean probe
Clean lamp
Check for proper operation and response
Recharge battery pack
Recharge hydrogen tank with zero hydrogen
to 1500 - 2000 psi
Check for proper operation and response
Replace batteries
Keep tape and probe free from contamination
Frequency
As needed
Each time recharged
Each use
As needed
Daily
After each use
As needed
Daily
As needed
Before and after each use
   A routine preventive maintenance program is conducted by the analytical laboratory as part of a
QA/QC program to minimize the occurrence of instrument failure and other system malfunctions.
The analytical laboratory is expected to have an internal group or equipment manufacturer's service
contract to perform routine scheduled maintenance and to repair or to coordinate with the vendor for
the repair of all instruments. All laboratory instruments will be maintained in accordance  with
manufacturer's  specifications  and the requirements of the  specific  method employed.  This
maintenance must be carried out on a regular scheduled basis and be documented in the laboratory
instrument  service logbook for each instrument. Emergency  repair or scheduled manufacturer's
maintenance will be provided under a repair and maintenance contract with qualified representatives.
Project-specific equipment lists will be included in the site-specific QAPP.

B.7 Instrument Calibration and Frequency
   This  section describes procedures for  maintaining the accuracy of all the instruments and
measuring equipment that will be used for conducting  field tests and laboratory analyses. These
instruments and equipment should be calibrated prior to each use or on a scheduled periodic basis.
The Field Team Leader is responsible for assuring that calibrations are current and documented.

   Whenever possible, widely accepted calibration methods, such as those published by ASTM or
U. S. EPA or those provided by manufacturers, will be adopted for both field and laboratory analytical
instrumentation. At a minimum, calibration methods will take into consideration the type of equip-
ment to be calibrated, reference equipment, and standards to be used. Equipment will be calibrated

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using reference  equipment  and standards  having known relationship to nationally recognized
standards (e.g., NIST) or accepted values of natural physical constants. If national standards do not
exist, the basis for the reference standard or calibration will be documented.

   Reference equipment will be used only for calibration and will be stored separately from
functioning, measuring, and testing equipment to  prevent inadvertent use. In general, reference
equipment will be at least 4 to 10 times as accurate as the equipment being calibrated.

   All continuing calibrations are performed in the field prior to instrument use. Every calibration
is recorded in the maintenance logbook for each instrument. QC check standards from separate
sources will be used to check initial calibration and acceptance and rejection criteria. When the
difference between the continuing calibrations and the QC check standards exceeds plus or minus 20
percent, use of the  instrument will be suspended until corrective actions  are taken or until  it is
determined that a greater variance will be allowed. The acceptance/rejection criteria can only be
revised by approval of the laboratory manger and the TOM. Vapor meters will be calibrated daily with
one span gas. All  analytical instrumentation will utilize continuing calibration standards in addition
to the initial calibration curve. These will be run at varying concentrations including low, mid, and
high range to ensure continuation of the curve.

   Calibration procedures and frequency specified by the method will be used by the field analytical
laboratory. When the field laboratory is used only for screening purposes, however,  a less-stringent
approach to calibration can be used—for example, using three concentration levels  instead of five.
The option will be specified and documented in the project-specific QAPP.

   All certified gas standards will be provided by Scott Specialty Gases, Inc., or a similar supplier.
The VOC standard will contain at least 20 COPC-TAL compounds each at approximately 1 ppmv in
helium. Helium is used to avoid problems associated with conducting the fixed gas (CO2, N2, O2)
analyses. The initial calibration will be performed by varying the volume of the standard; volumes
of 1, 5, 25, 50, and 100 mL of the 1 ppmv standard result in a calibration curve of 1, 5, 25, 50, and
100 nL, respectively.  Daily  calibration check standards will be obtained by analyzing the 25-nL
standard. The initial calibration response factor report and the continuing calibration reports will be
provided with the laboratory report.

   Stock standards should be purchased in a high pressure cylinder blend  that  is  designed to
minimize vapor phase interactions and maximize long-term stability. The standards would be blended
into the working range by taking known aliquots using density-based calculations. Density-based
calculations are used to determine the prescribed amounts  and final concentrations.

   To prepare internal standards (IS) the prescribed amounts of neat material and 50  |iL of water are
spiked into a Tedlar bag containing 10.0 L of nitrogen. The contents of the Tedlar bag are transferred
into an evacuated 6  L Summa canister, pressurized, and diluted. A 1.0 mL of the internal standard
blend is injected into the canister interface as each standard, blank, and sample is being loaded. The
final concentration is 25 ppbv for each of the following:
      bromochloromethane
      chlorobenzene-dj
      1,4 -difluorobenzene

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   The internal standards' retention times for the blanks and samples must be within ±0.5 min (30 s)
of the retention times in the continuing calibration check. In addition, the IS area must be within ±40
percent of the continuous calibration verification's (CCV's) IS area for the blanks and samples.  A
warning limit of ±30 percent is used to investigate possible mis-injection of the IS. If the ISs for the
blank do not pass the acceptance criteria, the system is inspected and the blank reanalyzed. Analyses
are discontinued until the blank meets the IS criteria.

   If the ISs in a sample do not pass the acceptance criteria, the sample must be reanalyzed unless
obvious matrix interference is documented. If the ISs are within limits in the re-analysis, the second
analysis will be reported. If the ISs are out-of-limits a second time, then the data is reported from the
first analysis and the matrix effect narrated in the laboratory narrative included with the report.

   A humidified blank (less than 20% relative humidity at 25 °C) is analyzed after each CCV sample
run: (1) At the beginning of the analytical shift or sequence (when an initial calibration is not being
performed); (2) every 12 hr of analyses or every 20 samples, whichever comes first; and (3) at the end
of the analytical sequence. A blank is also analyzed in the event  saturation-level concentrations are
incurred to  demonstrate that contamination does not exist in the chromatographic system.

   The acceptance criteria for the concentration of each target analyte in each blank must be less than
the greater of (1) the reliable detection limit (RDL) for the target analyte; (2) the method reporting
limit (MRL) when the MRL is not greater than 5% of the project and analyte specific action level, (3)
5 % of the analyte concentration detected in each associated field samples; and (4) 10% of the action
level. Environmental sample detections greater than the MRL but less than 10 times the corresponding
blank detections should be qualified. The following definitions and procedures are used to quantify
the acceptance criteria.

   The RDL is the upper 95% upper confidence limit of the method detection limit (MDL). The
MDL is the minimum concentration of a substance that is significantly greater than zero (an analytical
blank) at the 99% limit of confidence and is determined using the procedure described in 40 CFR, Part
136, Appendix B.

   The MRL  is the threshold or censoring limit below which target analyte concentrations are
reported as  " < MRL" where "MRL" is the numerical value of the method  reporting limit. The MRL
is usually established by contract and is based on the laboratory's limits of identification (LOIs),
method quantitation limits  (MQLs), or project-specific action levels. The MRL for undetected
analytes should not be less than the LOI or RDL and must not be greater than the action level.

   The LOI is the lowest concentration of analyte that can be detected with 99% confidence; that is,
the LOI is the concentration at which the probability of a false negative is 1%. The LOI is adjusted
for method  specific factors (e.g., sample size) and may be approximated as twice the detection limit.
The LOI may  be set equal to about two times the MDL (e.g.,  if it is assumed that the standard
deviation is not strongly dependent upon concentration).

   The MQL is the concentration of an analyte in a sample that is equivalent to the concentration  of
the lowest initial calibration standard adjusted for method specified sample weights and volumes (e.g.,

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extraction volumes and dilutions). Typically, MQLs are equal to or greater than the lowest initial
calibration standard and are at least five times greater than the MDL. MQLs must also be less than
project-specific action levels. It is usually desirable for the MQL to be equal to some fraction of the
project's action levels (e.g., one half or one third of the action levels).
   A duplicate sample analysis will be performed on 10 percent of the samples at the laboratory. The
relative percent difference between the two analyses must be less than or equal to 25 percent for all
compounds detected at greater that 5 times the detection limit. If this limit is exceeded, the sample
will be re-analyzed a third time. If the limit is exceeded again, the cause is investigated and the
system brought back to working order. If no problem is found in the system, the data will be flagged
to note the non-conforming event.

   A mid-level spike (laboratory control sample using a subset of the independent source standard)
is analyzed daily prior to sample analysis. If the site specific criteria are not meet, the system is
checked and the standard re-analyzed. In the event that the criteria cannot be met, the instrument is
recalibrated.

   The calibration for meta and para-xylenes will be performed using only the meta-xylene isomer
because the two isomers co-elute on the GC column and have identical ion spectra and response
factors. The IS mix will consist of bromochloromethane, 1,4-difluorobenzene and chlorobenzene-d5,
each at approximately  1 ppmv. Twenty-five mL of the internal standard mix, equivalent to a 25-nL
standard, will  be added to all samples and standards.  The targeted standard concentrations and
quantitation ions that will be used are listed in Table B- 5.

   Mass spectrometer tuning will  be  performed and  checked daily.  Seven mL of p-bromo-
fluorobenzene (BFB) at 1 ppmv, equivalent to about 50 ng of BFB, will be analyzed to validate the
mass spectrometer tuning. The specific mass number that the instrument will be tuned to is laboratory
specific. This number will be provided in the site-specific QAPP.

   VOCs in the samples will be identified and quantitated using ChemStation software. This soft-
ware uses reconstructed and extracted ion chromatograms matched with retention time windows to
identify and quantify  target  compounds.  The report prints the identified  compound, calculated
concentration, mass spectra (both raw and background  subtracted), quantitation, and qualifier ion
chromatograms. The spectra of all  non-target compounds with a peak area of at least 20 percent of
the nearest internal standard in the total ion chromatogram will be compared to the NIST Mass
Spectral Database. The summaries will  contain the best match provided by the computer search
algorithm and an  estimated  amount for each  tentatively identified compound.  The tentatively
identified compounds produced by this automated search will be found in the library search compound
(LSC) report.

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        Table B-5. Target Calibration Concentrations and Quantitation Ions for COPCs.
Compound
Working Calibration Standard
, 1 -Dichloroethane
,2-Dichloroethane
,1,1-Trichloroethane (methyl chloroform)
, 1 ,2-Trichloroethane
,1-Dichloroethene (vinylidene chloride)
cis- 1 ,2-Dichloroethene
trans- 1,2-Dichloroethene (ethylene Bichloride)
Acylonitrite
Benzene
Carbon Terrachloride
Chlorobenzene
Chloroethane (ethyl chloride)
Chloroform
Chloromethane (methyl chloride)
Dichlorobenzene
Dichlorodifluoroethane
Ethylbenzene
Ethyl chloride
Ethylene Dibromide
Methylene Chloride
Tetrachloroethene (Perchloroethylene)
Toluene
Trichloroethene (Trichloroethylene)
Vinyl chloride
M - Xylene
o-Xylene
P-xylene
Internal Standard
Bromochloromethane
1 ,4-Difluorobenzene
Chlorobenzene -d5
Tuning Standard
4-Bromofluorobenzene
Quant. Ion

63
62
97
97
61
96
96
53
78
117
112
64
83
50
146
85
91
64
107
49
166
92
130
62
91
91
91

128
114
117

N/A
Concentration

1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv
1.00 ppmv

1.00 ppmv
1.00 ppmv
1.00 ppmv

1.00 ppmv

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   Detection limits are determined by analyzing a low level standard (1 to 5 |lg/ml). The limit of
quantitation (LOQ) for each sample analyzed via TO-15 is calculated using

                                      LOQ= (OC)(DF)
Where:   LOQ  = Results (parts per billion by volume in sample),
         OC= parts per billion by volume on-column from the MDL
         DF= Dilution factor
   The target compound results will be calculated using
Where  Rc   = Results concentration (parts per billion by volume on-column),
        Ac   = Area of compound in sample,
        AIS   = Area of internal standard in sample,
        CIS   = Concentration of the internal standard (ppbv), and
        ICAL-RRF = Initial calibration relative response factor.

Then
                                     R= (

Where R  = Results (parts per billion by volume in sample)
      DF= Dilution factor.

   Dilution factor includes canister pressurization dilution and any subsequent dilution required to
ensure all results are within the instrument calibration range.

   An OVA will be used to screen the landfill for methane and non-methane organic carbon vapors.
This instrument will be calibrated using methane and ethane in air standards. An initial calibration
using zero air and two upscale standards (500 to 100,000 ppmv) will be completed twice each field
day. Following this calibration, the OVA will be single-point checked daily with a mid-level (100 to
500 ppmv) methane or ethane standard as appropriate.

   The following QA/QC procedures will be performed for this project.
   •  The Agilent  GC/MS  will  be tuned daily for perfluorotributylamine (PFTBA) to meet
      abundance criteria for p-bromofluorobenzene as listed in EPA Method 624. Tuning results will
      be included in the calibration data section. The tune will be adjusted when necessary.
   •  Initial calibrations  will be performed. All compounds must meet the acceptance criteria of
      having a correlation coefficient greater than 0.95.
   •  Continuing calibrations will be performed. All compounds must meet the acceptance criteria

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      of having a percent difference (%D) of less than or equal to ±25 percent.
   •  Five instrument blanks will be analyzed after the calibration standard(s) and before samples
      will be analyzed. Blank analyses will be performed after samples with high VOC concen-
      trations to check for carryover and to ensure that the GC/MS system was clean.
   •  Sample container blanks will be collected daily and analyzed for the COPC-TAL.
   •  Known concentrations of the gas standards will be used to generate a 2-point calibration for
      nitrogen and oxygen, and a single-point calibration for carbon dioxide. A Scott Specialty Gas
      standard, containing 15 percent methane, 5.01 percent oxygen,  4.99 percent nitrogen, and
      49,600 ppm carbon dioxide will be used for the level  1 calibration.  Ambient air, with a
      concentration of 20.950 percent oxygen and 78.080 percent nitrogen (Reference: Handbook
      of Chemistry and Physics) will be used for the Level 2 calibration for oxygen and nitrogen.
      A Scott Specialty Gas standard containing 10,100 ppm carbon dioxide will be used as a check
      standard to validate the carbon dioxide calibration. The procedure may be changed to a single-
      point calibration for oxygen and nitrogen using ambient air as the standard and the 10,100 ppm
      carbon dioxide standard if the oxygen and nitrogen content of all of the initial samples are very
      close to the amounts found in ambient air and samples containing the most carbon dioxide had
      levels relatively close to the 10,100 ppm carbon dioxide standard.
   •  Approximately 5  percent duplicate samples will be collected and analyzed.
   •  Approximately 5  percent split replicate analyses will be performed.
   •  Periodically throughout each  sampling day (once  every 20 samples  at least), calibration
      standards will be injected and the performance of the instrument noted. The instrument will be
      recalibrated as required.
   •  To ensure the system is clean prior to analysis, the columns will be baked over night prior to
      each day of analysis. Ambient air samples will be analyzed after each initial calibration.

   Target compound results will be reported in tabular form. Analytical results will be reported in
parts per billion by volume.

   The calibration package for each day of analysis will be included in an appendix to the laboratory
report. This package will include copies of the injection logbook, BFB tune, and the initial and the
continuing calibration  quantitation  report. The quantitation  report will list the retention  time,
quantitation ion, peak area, and amount in  nano liter. Amounts listed on these quantitation reports
will be generated by using the linear regression plot of the initial calibration.  The calibration plots
will  also be included in an appendix. Quantitation reports for the blanks and  samples will also be
found  in  an  appendix.  Quantitation will  only be  interpolated between calibration standards.
Extrapolation below or above the calibration standard will not be done. The lower calibration standard
will  be at the MDL  as  established  by the individual laboratory.  The COC  forms  will be in an
appendix.

   The following is a list of the QA/QC flags that may be used in qualifying the results:
      A  - Assumed volume for the method blank,
      B   - Concentration less than three times the reported blank result,
      C   - Compound  calibration relative standard deviation (RSD)  greater than 30 percent
          (concentrations calculated by average response factor only),
      D   - Compound calibration check relative percent deviation greater than 25 percent,

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      E   - Concentration exceeded highest calibration level,
      J   - Below quantitation limit,
      U  - Not detected at or below the LOQ,
      I   - Concentrations are estimated due to interference, and
      R  - Data unusable, narrative provided in summary report.

   A formal calibration program is essential for verifying that the instruments and equipment are
working properly and are capable of producing quality data.

   The two basic types of calibrations are periodic and operational. Periodic calibration is usually
applied to apparatus such as thermometers, balances, ovens, and pipettes that do not directly produce
an analytical result. Periodic calibrations are performed on a specific time schedule regardless of the
frequency of use of the apparatus. Operational calibration  applies to analytical instruments and
manual analyses. Operational calibrations precede each use of the instrument and are performed
during use at frequencies defined in the test method. Each participating laboratory is expected to have
a QA plan that addresses operational and periodic calibrations, maintenance,  and documentation
procedures and requirements.

   Bench analysts are responsible for ensuring  that their analyses are performed  under valid
calibrations.
   •  Balances
      A qualified and experienced technician will examine  and calibrate if needed, analytical and
      top-loader balances annually. Calibration will be verified daily or before each use.
   •  Refrigerators and Freezers
      The temperature of refrigerators  and freezers used for storing  samples and extracts must be
      monitored daily. Nongaseous  samples must be  stored at  4±2 °C. Organic standards are
      maintained at -10 to -20 °C. Summa cannister will be  stored at ambient temperatures.
   •  Ovens
      The temperatures of ovens used for sample analysis must be monitored daily.
   •  Thermometers
      Thermometers must be checked upon receipt and annually thereafter against a NIST-traceable
      thermometer over the range at which they are to be used. Those differing more than 2°C from
      true are returned (if new) or discarded.
   •  Micro pipettes
      Micro pipettes are used for preparing dilutions of calibration solutions and samples and for
      adding reagents and spiking solutions during analysis. Micro pipettes must be calibrated upon
      receipt, monthly thereafter, and after maintenance. The pipette is repaired or discarded if its
      delivery volume is greater than ±5 percent of the true value.

   Equipment that fails calibration or becomes inoperable during use will be removed from service,
segregated to prevent inadvertent use, and tagged to indicate it is out of calibration. Such equipment
will be repaired and recalibrated to the satisfaction of the field team supervisor,  as  appropriate.
Equipment that cannot be repaired must be replaced. Results of activities performed using equipment
that has failed recalibration will be evaluated by the involved QA personnel or site supervisor, as
appropriate. The results of the evaluation will be documented and appropriate personnel will be
notified. Scheduled calibration of measuring and test equipment does not relieve any personnel of the

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responsibility of using properly functioning equipment. If an equipment malfunction is suspected,
the device will be tagged and removed from service or recalibrated as needed.

   Records will be prepared and maintained by the individual laboratory in accordance with its QA
plan, for each  piece of calibrated measuring and test equipment and each piece of reference
equipment, to indicate that established calibration procedures have been followed. Records  for
equipment used only for a specific project will be maintained in the project files.

B.8 Inspection and Acceptance Requirements for Supplies and Consumables
   It is the responsibility of the equipment and supply manager to secure all the equipment, supplies,
and consumables necessary to conduct the monitoring, sampling, and analytical methods described
in  Sections B. 1 through B.4. Each of the participants in this study will have a document system that
is designed to assure that equipment and supply specifications are developed in accordance with the
methods and procedures needed to meet the project objectives.  The system should:
   •  Determine technical and quality requirements for all supplies and consumables by evaluating
      task order requirements, applicable or relevant and appropriate technical requirements, contract
      requirements, and other issues or documents identified.
   •  Determine if acceptance testing should be performed based on findings of the technical review.
   •  Determine acceptability of leased, rented, or purchased items based on findings of the quality
      review.
   •  Arrange and documenting acceptance testing, if required.
   •  Handle any nonconforming items.
   •  Procure equipment,  supplies, and consumables that meet established technical and quality
      requirements.
   •  Track and verify the quality of the required equipment, supplies, and consumables.
   •  Maintain required documentation to ensure the quality and adequate technical performance of
      all equipment, supplies, and consumables.

   Prior to mobilizing, a packing list of the equipment  and consumables being used at the site for
field sampling, monitoring, or on-site analysis will be sent to the QC officer for review and approval.
The list will include as appropriate:
   •  Size, type, and number of sample containers,
   •  Model number(s) of instruments being used for screening the landfill for methane and NMOC
      contaminants,
   •  Quantities and characteristics of calibration and span gases  or solutions,
   •  Quantities and characteristics of spiking material, and
   •  Log book assignments by person and serial number.
   The QC officer will compare the list of equipment  and consumables to those required by  the
methods and the QAPP.

B.9 Indirect Measurements
   Sources of previously collected data and other information must be clearly identified to establish
acceptance criteria for use of such data as well as limitations resulting from uncertainty in its quality.
Information that is nonrepresentative  and possibly biased and is used uncritically may  lead to
decision errors. Acquired data may include but are not limited to

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   •  Data from handbooks,
   •  Historical information,
   •  Computerized databases,
   •  Site-specific parameters, and
   •  Maps, drawings, photographs.

   Indirect measurement data must be developed to support data QA objectives. Acceptance criteria
for each collection of data for use has been determined with respect to
   •  Representativeness. To be assessed qualitatively by verifying that the site-specific informa-
      tion was developed in a systematic and documented manner. Comparability is being ensured
      by the use of the same reporting units and normalization of the information. Comparison of
      the laboratory and monitoring data generated by this project with historical data is not a
      significant factor.
   •  Bias. To be assessed by checking the available records for statements concerning bias. For
      example, if the percent recovery for matrix spike samples has been used to indicate that the
      historically reported  concentrations for chemicals of potential concern  are biased low, the
      decision to exclude a chemical from the site-specific COPC-TAL would be erroneous, and the
      risk would be underestimated. Similarly, if the reported concentration data is biased high, the
      decision to include a  specific COPC on the TAL would be erroneous and resources spent on
      unnecessary sampling and analysis would be wasted. Site-specific COPC-TAL will be estab-
      lished prior to mobility for field work. Time and budget constraints will be a dominant factor
      in selecting the COPC-TAL.
   •  Precision. To be assessed by checking the available records for  statements concerning
      precision. If the relative standard deviation or coefficient of variance for the historical  data
      used to characterize the COPC concentrations is high, the number of samples or the density of
      the sample grid could be erroneous, and an inadequate number of samples would be collected.
      Similarly, if the precision is low, the number of samples and the density of the sample  grid
      would need to be increased, and the costs for sampling and analysis would be increased
      unnecessarily. The sample density will be established prior to mobility for field work. Time
      and budget constraints will be the dominant factor in selecting the number of samples to be
      collected and analyzed.
   •  Qualifiers. To be assessed by checking the available records  for statements concerning the
      usability and limitations of the results. Clearly, any data that has been previously rejected will
      not be used. Absent clear indications that the data quality is questionable or must be restricted,
      the data will be used as if it is correct and the best available.
   •  Summarization. The data will be summarized and normalized to the extent reasonable and
      possible. Normalization will be achieved by using common units of measure. The data quality
      obj ective achieved would be compared to the obj ectives for accuracy, precision, completeness,
      and detection limits specified herein.

   Use of indirect data will be limited when found to not meet acceptance criteria. The impact of
results on DQOs with  respect to the environmental decision will be reviewed to determine re-
quirements for qualification or replacement of results.

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B.10 Data Management
    This section describes the procedures and criteria for recording, validating, and reporting data.
Several types of data will be generated and reported during this program. As part of the QC effort,
the field team leader and the QC officer will verify that persons responsible for data entry (electronic
and manual) are being careful. Periodic  observations will be made to assure that accurate data re-
cording is achieved. The electronic data will be in the form of digital data files created by the data
acquisition system. Backup copies of the electronic files will be created daily. The integrity of the
raw data files is to be maintained, so all  data manipulation will be performed on a copy of the raw
data file.

    Much of the data will be generated  on site; therefore, these parameters will be recorded and
validated on a semi-continuous basis during the monitoring program. This activity will consist of
ensuring that data calibrations are kept current, that data are continuously recorded in the proper
format, and that any problems are properly and expeditiously recorded. An on-site computer will be
used to help process and archive the data produced during the field sampling effort. The site-specific
QAPP will identify the type of computer and software needed to interface with the instrumentation
being used in the field. Data loggers will be used to the extent possible in order to  minimize data
entry errors. This will help ensure that  all the samples scheduled are collected and that the data
collected during this program is properly handled.

    Following field collection of data, all electronic data collected will be stored in a central project
file server for security and retrieval in  its original form  (as collected) and in its modified form
(following data validation and reevaluation). Those items not in electronic form will be  filed in a
central project filing system at the contractor's project office and in accordance with the contract
agreement between the EPA and contractor that authorizes the work.

Analytical Data Handling
    Specific data  recording and validation resulting from analytical procedures as described in
Sections B.2 through B.4 will be recorded by the generating laboratory and will be included with the
laboratory report and records being stored by the contractor.  These records will  be available upon
request of the TOM for a period of 3 years.

On-Site Data Handling
    The data generated while on site will all be real-time or semi real-time; care must be exercised to
ensure that all the data are being properly recorded and that accurate records are kept of all on-site
activities. All on-site data will be kept  on formatted data sheets  and in bound logbooks. Where
possible, instrument data loggers will be used that can then be downloaded through an RS-232 port
directly into  the  on-site computer system. Logbook entries will be  made in  ink, and separate
notebooks or notebook  sections will be set aside for the  various parameters. All supporting data
generated will be well documented regarding where the data were collected, the landfill  section, grid
number or vent identification number  or identifier, time and date the data were collected, and any
other supporting documentation. Microsoft Office software is the platform of choice for recording and
archiving electronic field data.  The field team leader and the QC officer will verify that persons
responsible for data entry are being careful. Periodic observations will be made to assure that accurate
data recording is being achieved. The field team leader or the QC officer will determine twice a day

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if corrective actions are required.
   The on-site data validation procedures focus mainly on ensuring good accurate data collection
and identification. In addition, instrument calibration will be regularly checked and compared with
previous calibration data to determine if there is any change or drift in these data. Duplicate sample
measurements will be evaluated to ensure that the instruments are operating properly and repro-
ducibly. If discrepancies in instrument operation are noted, the data will be flagged accordingly.
ELEMENT  C. ASSESSMENT AND OVERSIGHT

   The purpose of assessment is to ensure that the QAPP is implemented as prescribed. This section
addresses tools and procedures for assessing the effectiveness of implementation of the project and
associated QA/QC.

C.I Assessments and Response Actions
   Performance and system audits of both field and laboratory activities may be conducted to verify
that sampling and analysis are performed in accordance with the procedures established in the QAPP.
The audits of field and laboratory activities include two separate independent parts: internal and
external audits.

   Internal audits of field  activities  (sampling and  measurements) will be conducted by the
contractor's  QA officer.  The audits will include examination of field sampling records,  field
instrument operating records, sample collection, handling and packaging in compliance with the
established procedures, maintenance of QA procedures, COC, and so forth. These audits will occur
during the first two days  of the field work being completed on a site-by-site basis of the project to
verify that all established procedures are followed. Upon detection of a deficiency, the auditor has
the authority to stop work being conducted with the notification of the project manager and TOM in
order to determine and implement corrective action. Follow-up audits will be conducted to correct
deficiencies and to verify that QA procedures are maintained throughout the project. The audits will
involve review of field measurement records, instrumentation calibration records, and sample docu-
mentation. A summary of general considerations for field audits is presented in Figure C-l.

   External field audits may be conducted by the U.S. EPA Office of Research and Development
National Risk Management Research Laboratory's Air Pollution Prevention and Control Division.
These audits may be conducted anytime during the field operations. These audits may or may not be
announced and are at the discretion of the U. S. EPA. External field audits will be conducted according
to the field activity  information presented in the QAPP.

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                       I.  Sample Collection
                           Work Plan Adherence
                           Proper Documentation
                            • Sample matrix
                            • Location
                            • Volume
                            • Analysis requested
                            • coc

                       II.  Sample Storage and Shipment
                           Proper Containers and Preservative
                           Samples Refrigerated/Iced

                       III. Decontamination
                           Equipment
                            • Protective
                            • Sampling
                            • Large (backhoes, drill rigs, etc.)
                           Proper Solutions Used
                           Disposal Procedure

                       IV. Safety
                           Proper Level of Protective Clothing
                           Site Health and Safety Plan Present
                           Monitoring Equipment
                           First Aid Accessibility

                       V.  Quality Control
                           DQOs
                           SOPs for Sampling
                           Work Plan Availability
                           Weather Conditions Affecting Sample Quality
                           Figure C-1.  Field QA/QC Audit Outline.
   The internal performance and system audits of an analytical laboratory may be conducted by
the contractor's QA officer or authorized QA chemist. Internal performance and system audits are
not currently anticipated.  The system audits may be conducted on an as-requested basis if QC
problems  are suspected and will include examination  of laboratory documentation  on sample
receiving, sample log-in, sample storage, COC procedure, sample preparation and analysis, instrument
operating  records, and so forth. Blind replicate QC samples may be collected and submitted to the
laboratory concurrently with the project samples. The QA officer  will evaluate the analytical results
of these blind performance samples to ensure the laboratories maintain acceptable performance. A
summary of general considerations for laboratory audits is presented in Figure C-2. Upon detection
of a deficiency, the auditor has the authority to stop work being conducted with the notification of the
project manager and TOM in order to determine and implement corrective action.

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                       I.  Sample Receipt
                            coc
                            Adequate Facilities

                       II.  Sample Storage
                            Controlled Access
                            Proximity to Chemical Storage
                            Physical Conditions
                            Holding Times

                       III. Sample Work and Analysis
                             SOPs
                             Adequate Facilities
                              •  Organized work space
                              •  Proper ventilation
                              •  Minimized contamination
                             Notebooks
                             Logbooks
                              •  Sample and standard preparation
                              •  Instruments - sample analysis
                              •  Calibration - tune
                              •  Check samples
                              •  Balance
                              •  Temperature

                       IV. QC Samples
                             Blanks
                             Spikes
                             Duplicates
                             Surrogates
                             Control charts

                       V.  Lab Organization
                             Internal QA Program
                              •  Written QA Plan
                              •  Internal Audit
                             Data Handling  and Review
                             Data File Storage
                              •  Hard Copies
                              •  Other Media
                             Lab Capacity
                 Figure C-2. Laboratory QA/QC Audit General Considerations.
   Corrective actions may be required for two classes of problems: analytical and equipment problems
and noncompliance problems. Analytical and equipment problems may occur during sampling and
sample  handling, sample preparation, laboratory instrumental analysis, and data review.

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   For noncompliance problems, a formal corrective action program  will be  determined and
implemented at the time the problem  is identified. The person who identifies the problem is
responsible for completing  a Nonconformance Report and notifying the project manager. If the
problem is analytical in nature, information on these problems will be promptly communicated to the
QA officer.  Implementation of corrective action will be confirmed in writing through the same
channels and by completing a Corrective Action Report. Figure C-3 presents a sample corrective
action report.

   Any nonconformance with  the established QC procedures in the site-specific QAPP  will be
identified and corrected. The project manager, TOM, laboratory manager or RPM or their designee
will issue a Nonconformance Report for each nonconforming condition.

   Corrective actions will be implemented and documented in the field record book. No staff member
will initiate corrective action without prior communication of findings to the field team manager. If
corrective actions are insufficient, work may be stopped by stop-work order by the project manager,
laboratory manager or the TOM.

   Technical staff and project personnel will be responsible for reporting  all suspected technical or
QA nonconformances or suspected deficiencies of any activity or issued document by reporting the
situation to the project manager or designee. This manager will be responsible for assessing the
suspected problems in consultation with the project QA officer on making a decision based on the
potential for the situation to impact the quality of the data. If it is  determined that the situation
warrants a reportable nonconformance requiring corrective action, then a nonconformance report will
be initiated by the manager.

   The project manager will be responsible for ensuring that corrective action for nonconformances
are initiated by:
   •  Evaluating all reported nonconformances,
   •  Controlling additional work on nonconforming items,
   •  Determining disposition or action to be taken,
   •  Maintaining a log of nonconformances,
   •  Reviewing nonconformance reports and corrective actions taken, and
   •  Ensuring nonconformance reports are included in the final site documentation in project files.

   If appropriate, the project  manager will  ensure that no  additional  work  dependent  on the
nonconforming activity is performed until the corrective actions are completed.

   Corrective action for field measurements may include:
   •  Repeating the measurement to check the error,
   •  Checking for all proper adjustments for ambient conditions such as temperature,

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                             Corrective Action Report
   Date:                               Job Name:
   Name:                              Title:
Description of Problem:




Reported to:
Name:
Title:

Corrective Action:




Reviewed and Implemented by:
Name:
Title:

   Six-Week Follow-up Performed by:
   Name:                               Title:
cc:     project manager
       QA officer
       Project Activity Log
                       Figure C-3. Sample Corrective Action Report.
     Checking the batteries,
     Recalibrating,
     Checking the calibration,
     Replacing the instrument or measuring devices, or
     Stopping work (if necessary).

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   The laboratory manager or his designee is responsible for all on-site activities of the project team.
In this role, the laboratory manager is required to adjust the activities and schedule to accommodate
site-specific needs. When it becomes necessary to modify a QAPP, the responsible person notifies
the TOM  of the  anticipated change and implements  the  necessary changes  after obtaining the
approval of the TOM. The change in the program will be documented on a field change request (FCR)
signed by  the initiators and the project manager. The FCR for each document will be numbered
serially. The FCR shall be referenced in the field team manager's log book, and they will be
transported to the project record office for filing and storage. Figure C-4 presents a sample FCR. The
TOM must approve the change in writing, if feasible, or verbally prior to field implementation. If
unacceptable, the action taken during the period of deviation will be evaluated in order to determine
the significance of any departure from established program  practices and action taken.

   The project manager is responsible for controlling, tracking, and implementing the identified
changes. Reports on all changes will be distributed to all affected parties, which includes the TOM,
laboratory manager, contractor project manager, and the contractor QA officer.

   Corrective actions are required whenever an out-of-control event or potential out-of-control event
is noted. The investigative action taken is dependent  on the analysis and the event.  Laboratory
personnel are alerted that corrective actions may be  necessary if:
   • QC data are outside the warning or acceptable windows for precision and accuracy;
   • Blanks contain target analytes above acceptable levels;
   • Undesirable trends are detected in spike recoveries or RPD between duplicates;
   • There are unusual changes in detection limits;
   • Deficiencies are detected by the QA Department during internal or external audits or from the
     results of performance evaluation samples; or
   • Inquiries concerning data quality are received.

   Corrective action procedures are often handled at the bench level by the analyst, who reviews the
preparation or extraction procedure for possible errors and checks the instrument calibration, spike
and calibration mixes, instrument sensitivity, and so on. If the problem persists or cannotbe identified,
the matter is referred to the laboratory supervisor, manager, or QA department for further investi-
gation. Once resolved, full documentation of the corrective action procedure is filed with the QA
department.

   The contractor QA officer also may request corrective action for any contractual nonconformance
identified by audits or data validation. The TOM may request corrective action by the laboratories
for any nonconformances identified in the data validation process through the ERTC manager.
Corrective action may include:
   • Re-analyzing the samples, if holding time criteria permits,
   • Resampling and analyzing,
   • Evaluating  and amending sampling procedures or evaluating and amending analytical
     procedures,  or
   • Accepting data and acknowledging the level of uncertainty.

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Date:
 Project Name:_
 Description of Change:
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                       Field Change Request

                       	  Project No.	
 Initiator:
                                  Date:
 Reason for Change:
 Approvals:

 Field Team Leader:

 QA officer:	
 Project manager:
 Owner Representative:
                                      . Date:.

                                      Date: _

                                      . Date:

                                      Date:
                      Figure C-4. Sample Field Change Request.

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   If resampling is deemed necessary due to laboratory problems, the project manager must identify
the necessary approach including cost recovery for the additional sampling effort.

C.2 QA Reports to Management
   Periodic reports will be submitted by the Q A officer. Table C-1 lists all Q A reports to management.
                         Table C-1. QA Reports to Management.
Report
Progress
Quarterly QA
Performance
Self-Evaluation
Lab Audit
Data Validation
Frequency
Monthly
Quarterly
As needed
As needed
As needed
Distribution
TOM, Laboratory
Manager, RPM, EPA
QC Manager
TOM, Laboratory
Manager, EPA QC
Manager
TOM, Laboratory
Manager, EPA QC
Manager
TOM, Laboratory
Manager, EPA QC
Manager
Laboratory Manager,
TOM, RPM, EPA-QC
Manager
Comments
Contains QA section where monthly activities
are listed and includes any audits performed
during the month and proposed corrective
actions.
Summarizes status report of corrective actions
initiated during the quarter.
Contains QA section outlining performance on
all sites.
Audit findings report including list of audit
exceptions and rating of the laboratory
following an on-site systems audit.
Report summarizes the findings from the
validation of a data package submitted by the
subcontracted laboratory.
ELEMENT D. DATA VALIDATION AND USE
   Data are reviewed and validated by the contractor's QA officer using the laboratory data validation
guidelines established by the U. S. EPA in the reference titled "Laboratory Data Validation Functional
Guidelines for Evaluating Organic/Pesticides andPCB' s analyses" EPA/540/R94/090-092. Additional
criteria may be deemed necessary by the EPA on a site-specific basis. These additional requirements
will be listed in a site-specific QAPP, if needed.

D.I  Validation and Verification Methods
   All samples collected at a project site will be analyzed on site or sent to the analytical laboratory
that has been selected by ERTC in accordance with existing contract procedures.

   The analytical laboratory will perform in-house analytical  data reduction and verification under
the direction of the laboratory manager. The laboratory QA officer is responsible for assessing data
quality and advising of any data that were rated "preliminary" or "unacceptable" or other notations

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that would caution the data user of possible unreliability. Data reduction, validation, and reporting
by the laboratory(ies) will be conducted as follows:
   •  Raw data produced by the analyst is turned over to the respective area supervisor;
   •  The area supervisor reviews the data for attainment of QC criteria as outlined in established
     EPA methods and for overall reasonableness;
   •  Upon acceptance of the raw data by the area supervisor, a computerized report is generated and
     sent to the laboratory  QA officer;
   •  The laboratory QA officer completes a thorough audit of reports at a frequency of one in ten,
     and an audit of every report for consistency;
   •  The QA officer and subject area supervisors decide whether any sample reanalysis is required;
     and
   •  Upon acceptance of the preliminary reports by the QA officer, final reports will be generated
     and signed by the laboratory project manager. The laboratory package shall be presented in the
     same order in which the samples were analyzed.

   Data packages will  be organized in accordance with the data package checklist and the data
package  inventory list (Figures D-l and D-2).  Then,  data will be sent  to the contractor project
management office for data validation.

   The contractor QA chemist will conduct a systematic review of the data to verify compliance with
established QC criteria based on the spike, duplicate, and blank results provided by the laboratory.
An evaluation of data accuracy, precision, sensitivity, and completeness based on criteria in Section
B will be performed and presented in the site report.

   The data review will identify any out-of-control data points and data omissions and interacts with
the laboratory to correct data deficiencies. Decisions to repeat sample collection and analyses may
be made by the TOM based on the extent of the deficiencies and their importance in the overall
context of the project.

   Validation will  be accomplished by comparing the contents of the data packages  and QA/QC
results to the requirements contained in Office of Solid Waste and Emergency Response Directive
9360.4-01. Raw data such as GC/MS ion abundance chromatograms, GC chromatograms, and mass
spectra, data reports, and data station printouts will be examined to ensure that reported results are
accurate. The contractor QA officer will be responsible for this.

   The quality of analytical data used throughout a project is determined by assessing the data
usability and evaluating the compliance of the data with the analytical protocol. This is determined
by assessing quantitative and qualitative quality control measures. Analytical data validation is a
rigorous  qualitative and  quantitative assessment of the reported analytical data and  provides an
indication of the overall data  quality for use in the decision  making process. The  data quality
assessment is based on both an evaluation of the compliance to the method performance, reporting,
and quality control criteria as well as on evaluation and interpretation of the QC measured and their
impact on the usability of the results.

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EQ
    ^                   DATA PACKAGE CHECKLIST
C.O.C.#	    Laboratory:.
      GENERAL
       1.     All enclosed pages are legible, sequentially numbered, and easily identifiable.
       2.     There are no yellow sticky notes, tablet sheets, or other undocumented forms in
             the data package.
       3.     All required documents, including a completed chain of custody form are enclosed.
       4.     The data package is divided into sections that are clearly labeled for each analyte
             or method.

      NOTEBOOK PAGES
       5.     All copies of notebook pages are identified by notebook number (if applicable) and
             page number.
       6.     All units are clearly defined.
       7.     Each page has been signed and dated by the analyst and reviewer.
       8.     All written explanations have all of the necessary information included and may
             stand alone as written.

      CERTIFICATE OF ANALYSIS
       9.     The report sheet has been signed and dated by both the reviewer and the analyst.
IV.    RAW DATA
	 10.    All raw data (chromatograms, quant lists, other instrument output, etc.) has been
             labeled properly, signed, and dated by the analyst.

V.    CORRECTIONS
	11.     No white-out or correction tape has been used on any raw data.
	12.     All cross-outs consist of only a single line, and have been initialed and dated.
	13.     All cross-outs have a legitimate, sufficient, documented explanation.

I have checked this report and data package to make certain that the above conditions are in
compliance with the assigned data quality objective.
Name                     Title                                   Date

Data were obtained while the analytical process was in-control and met the agreed upon data
quality objectives.

                          Project Manager                        Date


                            Figure D-1.  Data Package List.

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             DATA PACKAGE DOCUMENT INVENTORY LIST
c.o.c.#
                     Laboratory:,
If the listed document is in the data package, initial and indicate the page of the associated item:
Document
Narrative
Review sign-off sheet
Chain-of-custody sheet
Methods used
Sample results report form
QA/QC results report form
Copy of extraction and logbook pages
Extraction / sample preparation bench sheets
DFTPP 12 hour tuning and mass calibration report(s)
BFB 12 hour tuning and mass calibration report(s)
Initial calibration raw data
Continuing calibration raw data
Raw data for field, QC, and blank samples
Check-standard results
Chromatogram with peak indicated, dated and initialed
Expanded scale blow-up of manually integrated peak
Unknown report, library search, best-fit spectra
Raw data for quantitated analytes
Serial Dilutions
Standard Methods
Interference Check Standard
Example calculations
Page#






















Initial






















For Items that are not applicable note as N/A

I have checked this report and certify that the above items are present in the data package and
are found on the associated page number.
Name
                                  Title
Date
                   Figure D-2. Data Package Document Inventory List

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   QA Level IA is a term to describe a data package standard that has neither definitive identification
of pollutants nor definitive quantitation of their concentration level. It is used to determine a quick
preliminary assessment of site contamination.

   QA Level IB is a term to describe a data package standard that requires additional deliverables and
further review of the data than a QA Level IA package. Laboratory precision and accuracy data are
evaluated (through the use  of  summary forms)  in this level  to  provide results that can be
semiquantitative. It is used for analyte-specific site assessments.

   The QC chemist is responsible for
   •  Reviewing  faxed preliminary laboratory data to verify  that requested methods were used,
     appropriate detection limits were achieved, sample identifications are correct, and the data was
     reported on time;
   •  Verifying completeness of package and reviewing calibration data, QC sample results, raw data
     (if applicable), and any problems identified by the laboratory;
   •  Contacting laboratory to recover items not found in the preliminary data check and maintaining
     communication with the laboratory as the need arises throughout the data validation procedure;
   •  Performing the data validation as outlined in Section 6.0 of this document and completing the
     Data Validation Checklist; and
   •  Completing the Validation Report that details  and summarizes the findings  of the  data
     validation.

D.1.1 QA Level IA Data Validation
   Once a final data package is received by the contractor, the QC chemist separates the package into
sections and notes if any items are missing.

   If items are missing from the data package, the laboratory is notified, and the missing items are
requested to be sent the next business day.

   Once the package is complete, the following items are reviewed:
   •  Chain-of-custody information,
   •  Sample results summary,
   •  Method references,
   •  Dates of extraction and  analysis,
   •  Calibration summaries,  and
   •  Surrogate recoveries.

   The sample result certificates are copied and the originals are forwarded to the project manager
along with a cover letter identifying the results of the QA IA validation.

D.1.2 QA Level IB Data Validation
   All criteria in the Q A Level IA Data Validation are reviewed; however, the following items in the
data package are also evaluated:
   •  Matrix spike and matrix spike duplicate results,
   •  Sample duplicate results,

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   •  Laboratory control sample results,
   •  Tuning criteria (if applicable),
   •  Internal standards results (if applicable),
   •  Method blank summaries, and
   •  Interference check sample results (if applicable).

   The sample result certificates are copied and the originals are forwarded to the project manager
along with a cover letter identifying the results of the QA IB validation.

   Included in data validation of a sample set is an assessment of COC and associated field QC
samples. COC must be maintained from point of sampling through laboratory analysis. Both field and
laboratory COCs are reviewed and certified by the validator. Field QC samples are also reviewed,
verified, and reported in the validation report. Field QC sample acceptance criteria are presented in
Section B.

   All  data generated  for the sites will be in a format organized to facilitate  data  review and
evaluation. The computerized data set will include the data flags determined by data validation. The
data flags will include such items as: (1) concentration below required detection limit, (2) estimated
concentration due to poor spike recovery, and (3) concentration of chemicals also found in laboratory
bank. The data reviewer comments will indicate that the data are: (1) usable as a quantitative con-
centration, (2) usable with caution as an estimated concentration, or (3) unusable due to out-of-control
QC results.

   The data set will be presented to the TOM and available for controlled access by the project
manager and authorized personnel using a site-specific project number. The complete data set will
be incorporated into the final site report.

D.2 Reconciliation with User Requirements
   The purpose of data reconciliation is to determine if the data qualitative and quantitative are of
the right type, quantity, and quality to support their intended use. To that end, evaluations will be
performed by the contractor's data reduction and information specialist to reconcile data with the
requirements defined by project specifications.

   The data quality assessment (DQA) process is used to reconcile results with DQOs. By using the
DQA process, decisions or estimates can be made with the desired confidence, and sampling design
performance over a wide range of performance outcomes can be determined.

   The DQA process involves five steps that begins with a review of the planning documentation and
ends with an answer to the question posed during the planning phase of the study. These  steps
roughly parallel the actions of an environmental statistician when analyzing a set of data. The five
steps are briefly summarized as follows:
   1. Review the DQOs and Sampling Design Review the DQO outputs to ensure that they are still
     applicable. If DQOs have not been developed, specify DQOs before evaluating the data (e.g.,
     for environmental decisions,  define the statistical hypothesis and specify tolerable limits on
     decision errors; for estimation problems, define an acceptable confidence or probability interval

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     width). Review the sampling design and data collection documentation for consistency with the
     DQOs.
   2. Conduct a Preliminary Data Review Review QA reports, calculate basic statistics, and generate
     graphs of the data. Use this  information to learn about the structure of the data and identify
     patterns, relationships, or potential anomalies.
   3. Select the Statistical Test Select the most appropriate procedure for summarizing and analyzing
     the data, based on the review of the DQOs, the sampling design, and the preliminary data
     review. Identify the key underlying assumptions that must hold for the statistical procedures to
     be valid.
   4. Verify the Assumptions Verify the assumptions of the statistical test and evaluate whether the
     underlying assumptions hold or whether departures are acceptable, given the actual data and
     other information about the study.
   5. Draw Conclusions from the Data. Perform the calculations required for the statistical test and
     document the influences drawn  as a result of these calculations. If the design is to be used
     again,  evaluate the performance of the sampling design.

   These five steps are presented  in a linear sequence, but the DQA process is by its very nature
iterative. For example, if the preliminary data review reveals patterns or anomalies in the data set that
are inconsistent with the DQOs, then some aspects of the study planning may have to be reconciled
in Step 1. Likewise, if the underlying assumptions of the statistical test are not supported by the data,
then previous steps of the DQA process may have to be revisited. The strength of the DQA process
is that it is designed to promote an understanding of how well the data satisfy their intended use by
processing it in a logical and efficient manner.

   Nevertheless, it should be emphasized that the DQA process cannot absolutely prove that one has
or has not achieved the DQOs set  forth during the planning phase of a study. This situation  occurs
because a decision maker can never know the true value of the item of interest. Data collection only
provides the investigators with  an estimate of this, not its true value. Further, because analytical
methods are not perfect, they too can only provide an estimate of the true value of an environmental
sample. Because investigators make a decision based on estimated and not true values, they run the
risk of making a wrong decision (decision error) about the item of interest.

   For this project, the qualitative objectives are to determine if LFG controls are needed. This
generic QAPP and the site-specific QAPPs result from the systematic planning process and contain
information  needed to carry  out the data gathering and meet the DQOs. Combined with the likely
variability of emissions and the proximity to off site structures, the threshold of what will qualify as
significant will be determined by the  RPM. Based on these premises, quantitative objectives are
established for critical measurements in terms of data quality indicators goals for accuracy, precision,
and completeness. The target acceptance criteria for these indicators are included in Tables A-5, A-6,
and A-7.

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         APPENDIX A




     SITE I SPECIFIC QAPP




(TO BE DEVELOPED BY THE RPM)
             A-l

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                                    TECHNICAL REPORT DATA
                          (Please read Instructions on the reverse before completing)
1. REPORT NO.
     EPA-600/R-05/123b
                              2.
                                                             3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Guidance for Evaluating Landfill Gas Emissions from Closed
or Abandoned Facilities: Appendix C
             5. REPORT DATE
              September 2005
             6. PERFORMING ORGANIZATION CODE
7. AUTHORS
Thomas Robertson and Josh Dunbar
                                                             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Quality Management, Inc.
3325 Durham-Chapel Hill Boulevard
Durham, North Carolina  27707-2646
                                                             10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

             68-C-OO-186, Task Order 3
12. SPONSORING AGENCY NAME AND ADDRESS
U. S. EPA, Office of Research and Development
Air Pollution Prevention and Control Division
Research Triangle Park, North Carolina 27711
                                                             13. TYPE OF REPORT AND PERIOD COVERED
             Final:
             14. SPONSORING AGENCY CODE

             EPA/600/13
15. SUPPLEMENTARY NOTES
The EPA Project is Susan A. Thorneloe, Mail Drop E 305-02, Phone (919) 541-2709, e-mail
16. ABSTRACT
The report provides guidance to superfund remedial project managers, on-scene coordinators,
facility owners, and potentially responsible parties for conducting an air pathway analysis for landfill
gas emissions under the Comprehensive Environmental Response, Compensation, and Liability
Act, Superfund Amendments and Reauthorization Act, and the Resource Conservation and
Recovery Act. The document provides procedures and a set of tools for evaluating LFG emissions
to ambient air, subsurface vapor migration due to landfill gas pressure gradients, and subsurface
vapor intrusion into buildings. The air pathway analysis is used to evaluate the inhalation risks to
offsite receptors as well as the hazards of both onsite and offsite methane explosions and landfill
fires Summary examples of the application of these procedures and tools to three Superfund sites
are included.
17.
                                    KEY WORDS AND DOCUMENT ANALYSIS
             DESCRIPTORS
                                                b. IDENTIFIERS/OPEN ENDED TERMS
                                                                           c. COSATI Field/Group
Air Pollution
Landfills
Emissions
Methane
Organic Compounds
Toxic Chemicals
Pollution Control
Stationary Sources
13B
13C
14G
07C

07 D
18. DISTRIBUTION STATEMENT
                                                19. SECURITY CLASS (This Report)
                                                 Unclassified
                           21. NO. OF PAGES
                                   94
       Release to Public
20. SECURITY CLASS (This Page)
 Unclassified
                                                                            22. PRICE
EPA Form 2220-1 (Rev. 4-77 ) PREVIOUS EDITION IS OBSOLETE
                        forms/admin/techrpt.frm  7/8/99 pad

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