Batreiie
The Business of Innovation
Environmental Technology
Verification Program
Advanced Monitoring
Systems Center
Test/QA Plan for Verification of
Releasable Asbestos Field Sampler
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Verification of Releasable Asbestos Field Sampler
August 2, 2010
Prepared by
Battelle
505 King Avenue
Columbus, OH 43201-2693
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SECTION A
PROJECT MANAGEMENT
Al VENDOR APPROVAL PAGE
ETV Advanced Monitoring Systems Center
Test/Quality Assurance Plan for Verification of
Releasable Asbestos Field Sampler
Version 1.0
August 2, 2010
APPROVAL:
Name
Environmental Quality Management, Inc.
Date
Notice
The U.S. Environmental Protection Agency, through its Office of Research and Development, funded and managed,
or partially funded and collaborated in, the research described herein. It has been subjected to the Agency's peer
and administrative review. Any opinions expressed in this report are those of the author(s) and do not necessarily
reflect the views of the Agency, therefore, no official endorsement should be inferred. Any mention of trade names
or commercial products does not constitute endorsement or recommendation for use.
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A2 CONTENTS
Section
SECTION A: PROJECT MANAGEMENT 2
Al VENDOR APPROVAL PAGE 2
A2 CONTENTS 3
A3 ACRONYMS AND ABBREVIATIONS 6
A4 DISTRIBUTION LIST 8
A5 VERIFICATION TEST ORGANIZATION 9
A5.1 Battelle 10
A5.2 Technology Vendor 13
A5.3 EPA 14
A5.4 Verification Test Stakeholders 15
A5.5 Reference Laboratory 15
A6 BACKGROUND 17
A6.1 Technology Need 17
A6.2 Technology Description 17
A7 VERIFICATION TEST DESCRIPTION AND SCHEDULE 20
A7.1 Verification Test Description 20
A7.2 Verification Test Schedule 22
A7.3 Verification Location 22
A7.3.1 Environmental Laboratory 22
A7.3.2 Field Test Sites 22
A8 QUALITY OBJECTIVES 24
A9 SPECIAL TRAINING/CERTIFICATION 27
A10 DOCUMENTATION AND RECORDS 28
SECTION B: MEASUREMENT AND DATA ACQUISITION 29
Bl EXPERIMENTAL DESIGN 29
Bl.l Test Procedures 29
Bl.1.1 Field Testing 29
Bl.1.2 Reproducibility 33
Bl.l.3 Comparability 34
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Bl.1.4 Operational Factors 35
B1.2 Laboratory Test 35
B 1.2.1 Accuracy 35
Bl.2.2 Variability/Consistency 36
B1.3 Statistical Analysis 36
Bl.3.1 Reproducibility 37
Bl.3.2 Comparability 37
Bl.3.3 Accuracy 38
Bl.3.4 Variability and Consistency 38
B2 SAMPLING METHOD REQUIREMENTS 39
B3 SAMPLE HANDLING AND CUSTODY REQUIREMENTS 39
B3.1 Field Chain-of-Custody 40
B3.2 Sample Shipment 40
B3.3 Sample Receipt 40
B4 ANALYTICAL METHOD REQUIREMENTS 41
B5 Quality Control Requirements 41
B5.1 RAFS Lot Blank 41
B5.2 RAFS Field Blank 41
B5.2.1 Open Field Blank 41
B5.2.2 Closed Field Blank 42
B5.3 RAFS Equipment Blank 42
B5.4 Laboratory Blank 42
B5.5 Performance Evaluation Samples 43
B5.6 Duplicates 43
B6 INSTRUMENT/ EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE 43
B7 INSTRUMENT CALIBRATION AND FREQUENCY 43
B8 INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES 43
B9 NON-DIRECT MEASUREMENTS 44
BIO DATA MANAGEMENT 44
SECTION C: ASSESSMENT AND OVERSIGHT 46
Cl ASSESSMENT AND RESPONSE ACTIONS 46
Cl.l Performance Evaluation Audit 46
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C1.2 Technical Systems Audits 46
C1.3 Data Quality Audits 47
C1.4 QA/QC Reporting 48
C2 Reports to Management 48
SECTION D: DATA VALIDATION AND USABILITY 50
D1 DATA REVIEW, VERIFICATION, AND VALIDATION REQUIREMENTS 50
D2 VERIFICATION AND VALIDATION METHODS 50
D3 RECONCILIATION WITH USER REQUIREMENTS 51
APPENDIX A:
APPENDIX B:
APPENDIX C:
APPENDIX D:
APPENDIX E:
APPENDIX F:
APPENDIX G:
APPENDICES
STANDARD OPERATING PROCEDURE FOR SOIL SAMPLE COLLECTION
DURING THE RELEASABLE ASBESTOS FIELD STUDY (RAFS)
FIELD DATA SHEETS
STANDARD OPERATING PROCEDURES FOR ACTIVITY BASED SAMPLING
MANUAL FOR SOIL MOISTURE METER
MANUAL FOR OPTICAL PARTICLE COUNTER
CHAIN OF CUSTODY FORM
RAFS MANUAL
FIGURES
Figure 1. Organizational Chart 11
Figure 2. Schematic of RAFS with Rake Mechanism Detail 19
TABLES
Table 1. Planned Verification Test Activities and Approximate Schedule 21
Table 2. Sample Collection Quality Control Assessments During RAFS Verification 25
Table 3. Sample Analysis Quality Control Assessments 26
Table 4. Summary of Tests and Testing Frequency 30
Table 5. Guidance to Determine Target Sampling Time Based on Generated Particulate Number
Generation Rate or Concentration 32
Table 6. Vendor-Specified Operating Parameters 34
Table 7. Summary of Data Recording Process 45
Table 8. Summary of Assessment Reports 49
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A3 ACRONYMS AND ABBREVIATIONS
ABS Activity Based Sampling
ADQ audit of data quality
AMS Advanced Monitoring Systems
ATSDR Agency for Toxic Substances and Disease Registry
cc cubic centimeter
COC chain-of-custody
DQI data quality indicators
EPA U.S. Environmental Protection Agency
EQ Environmental Quality Management, Inc.
ETV Environmental Technology Verification
HAZWOPER Hazardous Waste Operations and Emergency Response
ISO International Organization for Standardization
LA Libby amphibole asbestos
1pm liters per minute
LRB laboratory record book
MCE mixed cellulose ester
NIST National Institute of Standards and Technology
NVLAP National Voluntary Laboratory Accreditation Program
NYDOH New York Department of Health
OU Operable Unit
PE performance evaluation
PLM Polarized Light Microscopy
QA quality assurance
QC quality control
QAO quality assurance officer
QMP Quality Management Plan
RAFS Releasable Asbestos Field Sampler
RMO Records Management Office
RPD relative percent difference
RSD relative percent standard deviation
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SOP
TEM
TQAP
TSA
VTC
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Standard Operating Procedure.
Transmission electron microscopy
test/quality assurance plan
technical systems audit
verification test coordinator
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A4 DISTRIBUTION LIST
Vendor
John R. Kominsky
Environmental Quality Management, Inc.
1800 Carillon Boulevard
Cincinnati, Ohio 45240
EPA
John McKernan, Sc.D., CIH
Michelle Henderson
U.S. Environmental Protection Agency (EPA)
National Risk Management Research Laboratory
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
Verification Organization, Battelle
Ramona Darlington, Ph.D.
Betsy Cutie
Rosanna Buhl
Amy Dindal
Battelle
505 King Ave.
Columbus, OH 43201
Reference Laboratory
Jim Flores
Forensic Analytical
377 Depot Road, Suite 409
Hayward, CA 94545-2761
Field Sites
Nicole Bein, EPA Region 8,
Libby Asbestos Site
Christina Leung, EPA Region 2,
Weedsport Site
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AS VERIFICATION TEST ORGANIZATION
The verification test will be conducted under the U.S. Environmental Protection Agency (EPA)
Environmental Technology Verification (ETV) Program. It will be performed by Battelle, which is
managing the ETV Advanced Monitoring Systems (AMS) Center through a cooperative agreement with
EPA. The scope of the AMS Center covers verification of monitoring technologies for contaminants and
natural species in air, water, and soil. This verification test will evaluate a field sampler that provides air
samples for quantitative measurement of the releasability of asbestos from soil in situ.
The objective of the verification is to test the ability of the Releasable Asbestos Field Sampler (RAFS) to
measure the emission rate from soil (asbestos structures/sec), and the asbestos concentration released
from soil (asbestos structures per cubic centimeter [cc] of air). This will be accomplished by generating
data for performance parameters that will assess the ability of the asbestos sampler through laboratory
testing with asbestos-fortified soil samples and field testing for direct comparison with activity-based
sampling (ABS). The performance parameters for this test are accuracy, reproducibility, comparability,
variability/consistency, and a number of operational factors defined in Section B.
The performance of the RAFS will be based on comparison with measurements made through ABS, an
EPA-designated reference sampling method for asbestos. For this test ABS will be conducted by the site
representative, and results from the ABS will be compared to those from the RAFS technology. The ABS
samples will be collected on the same day as the RAFS samples (or within 24 hours). ABS samples will
be collected by the site representative. Filter samples from both the RAFS and ABS will be analyzed
using International Organization for Standardization (ISO) Method 10312:1995 (ISO 10312), but
conducted at different laboratories. Quality control (QC) samples will be submitted, and a performance
evaluation (PE) audit will be conducted by Battelle at each laboratory as a QC check of the inter-
laboratory variability, and to assess their QC procedures. Standard operating procedures (SOPs) will be
obtained and reviewed from each laboratory.
The day to day operations of this verification test will be coordinated and supervised by Battelle, with the
participation of the RAFS technology vendor. Laboratory testing of the RAFS technology will be
conducted at Battelle in Columbus, Ohio. Field tests will be conducted at a site in Libby, Montana,
(Asbestos Site Operable Unit 4 [Libby OU4]) and at a site in Weedsport, New York. The vendor will
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provide Battelle with two replicate copies of the technology, and will train Battelle staff on its use.
Battelle staff and the vendor will operate the technology during verification testing.
The organization chart in Figure 1 identifies the responsibilities of the organizations and individuals
associated with the verification test. Roles and responsibilities are defined further below. Quality
assurance (QA) oversight will be provided by the Battelle Quality Manager, the designated Battelle
Quality Assurance Officer (QAO), and also by the EPA AMS Center Quality Manager, at her discretion.
A5.1 Battelle
Dr. Ramona Darlington is the AMS Center's Verification Test Coordinator (VTC) for this test. In this
role, Dr. Darlington will have overall responsibility for ensuring that the technical, scheduling, and cost
goals established for the verification test are met. Specifically, Dr. Darlington will:
Prepare the draft test/QA plan (TQAP), verification report(s), and verification statement(s);
Revise the draft TQAP, verification report(s), and verification statement(s) in response to
reviewers' comments;
Assemble a team of qualified technical staff to conduct the verification test;
Establish a budget for the verification test and manage staff to ensure the budget is not
exceeded;
Coordinate with the vendor for provision of its technology for testing;
Direct Battelle technical staff in the laboratory testing and coordinate with vendor personnel
for performance of the field testing;
Direct the team in performing the verification test in accordance with this TQAP;
Hold a kick-off meeting approximately one week prior to the start of the verification test to
review the critical logistical, technical, and administrative aspects of the verification test.
Responsibility for each aspect of the verification test will be confirmed by the VTC;
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Battelle
Management
Battelle AMS Center
Quality Manager
Rosanna Buhl
Quality Assurance
Officer
Betsy Cutie
AMS Center
Stakeholders
Battelle AMS
Center Manager
Amy Dindal
Verification Test
Coordinator
Ramona Darlington
Battelle Testing
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EPA AMS Center
Project Officer
John McKernan
EPA AMS Center Quality
Manager
Michelle Henderson
Vendor
Representatives
Figure 1. Organizational Chart
Ensure that all quality procedures specified in this EPA Quality Level III test/QA plan1 and in
the AMS Center Quality Management Plan2 (QMP) are followed;
Serve as the primary point of contact with the vendor representative;
Ensure that confidentiality of sensitive vendor information is maintained;
Assist vendor as needed during verification testing;
Become familiar with the operation of the technology through instruction by the vendor, if
needed;
Prepare a deviation report for any departure from the TQAP during the verification, obtain
the requisite EPA approvals, and distribute the approved report as specified in the AMS
Center QMP;
Respond to any issues raised in assessment reports, audits, or from test staff observations, and
institute corrective action as necessary; and
Coordinate distribution of the final TQAP, verification reports, and verification statements.
U.S. EPA, Environmental Technology Verification Program Quality Management Plan, EPA Report No: 600/R-08/009
EPA/600/R-03/021, U.S. Environmental Protection Agency, Cincinnati, Ohio, January 2008.
2 Battelle, Quality Management Plan for the ETV Advanced Monitoring Systems Center, Version 7.0, U.S. EPA Environmental
Technology Verification Program, prepared by Battelle, Columbus, Ohio, November 2008.
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Ms. Amy Dindal is Battelle's Manager for the AMS Center. As such, Ms. Dindal will oversee the various
stages of verification testing. Ms. Dindal will:
Review the draft and final TQAP;
Attend the verification test kick-off meeting;
Review the draft and final verification report(s) and verification statement(s);
Ensure that necessary Battelle resources, including staff and facilities, are committed to the
verification test;
Maintain communication with EPA's technical and quality managers; and
Issue a stop work order if Battelle or EPA QA staff discovers adverse findings that will
compromise test results.
Technical staff from Battelle will support Dr. Darlington in planning and conducting the verification test.
The responsibilities of the technical staff will be to:
Assist in planning for the test, and making arrangements for the receipt of and training on the
technology;
Attend the verification test kick-off meeting if participating in testing (e.g., operating the
vendor technology);
Perform statistical calculations specified in this TQAP on the verification data as needed;
Provide results of statistical calculations and associated discussion for the verification
report(s) as needed; and
Support Dr. Darlington in responding to any issues raised in assessment reports and audits
related to statistics and data reduction as needed.
Ms. Rosanna Buhl is Battelle's QA Manager for the AMS Center. Ms. Buhl will:
Review the draft and final TQAP;
Assign a QAO for each verification test;
Delegate to other Battelle quality staff any QAO responsibilities assigned below as needed to
meet project schedules;
Review any audit checklists prepared by the QAO for completeness and detail;
Review draft audit reports prior to release to the VTC and/or EPA for clarity and appropriate
assessment of findings;
Review audit responses for appropriateness;
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Review and approve TQAPs, TQAP amendments, deviations and audit reports;
Maintain real-time communication with the QAO on QA activities, audit results, and
concerns;
Work with the QAO, VTC, and Battelle's AMS Center Manager to resolve data quality
concerns and disputes; and
Recommend a stop work order if audits indicate that data quality or safety is being
compromised.
Ms. Betsy Cutie is Battelle's QAO for this test. Ms. Cutie will:
Attend the verification test kick-off meeting and lead the discussion of the QA elements of
the kick-off meeting checklist;
Prior to the start of verification testing, verify the presence of applicable training records,
including any vendor training on test equipment;
Conduct a technical systems audit at least once during the verification test;
Conduct audits to verify data quality;
Prepare and distribute an audit report for each audit;
Verify that audit responses for each audit finding and observation are appropriate and that
corrective action has been implemented effectively;
Communicate to the VTC and/or technical staff the need for immediate corrective action if an
audit identifies TQAP deviations or practices that threaten data quality;
Provide a summary of the QA/QC activities and results for the verification reports;
Review the draft and final verification report(s) and verification statement(s);
Maintain real-time communication with the Battelle Quality Manager on QA activities, audit
results, and concerns, including potential schedule and budget problems;
Communicate data quality concerns to the VTC and/or Battelle's AMS Center QA Manager;
and
Recommend the need for a stop work order if audits indicate that data quality or safety is
being compromised.
A5.2 Technology Vendor
The technology vendor is Environmental Quality Management, Inc. (EQ). Mr. John Kominsky is EQ's
representative and point of contact. The responsibilities of the technology vendor are:
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Review and provide comments on the draft TQAP;
Accept (by signature of a company representative) the final TQAP prior to test initiation;
Participate in the kick-off meeting for the verification test;
Initially provide two replicates of the technology to carry out comparative analysis during the
verification test;
Supply instructions on the use of the technology, and written consent for test staff to carry out
verification testing; and
Review and provide comments on the draft verification report and verification statement for
their respective technology.
A5.3 EPA
EPA's responsibilities in the AMS Center are based on the requirements stated in the "Environmental
Technology Verification Program Quality Management Plan" (EPA QMP). The roles of specific EPA
staff are as follows:
Ms. Michelle Henderson is EPA's AMS Center Quality Manager. For the verification test,
Ms. Henderson will:
Review the draft TQAP;
Perform one external technical systems audit during the verification test;
Notify the EPA AMS Center Project Officer of the need for a stop work order if the external
audit indicates that data quality is being compromised;
Prepare and distribute an assessment report summarizing results of the external audit; and
Review draft verification report(s) and verification statement(s).
Dr. John McKernan is EPA's Project Officer for the AMS Center. Dr. McKernan will:
Review the draft TQAP;
Approve the final TQAP;
Review and approve deviations to the approved final TQAP;
Appoint a delegate to review and approve deviations to the approved final TQAP in his
absence, so that testing progress will not be delayed. Review the first day of data from the
verification test and provide immediate comments if concerns are identified;
Review the draft verification report(s) and verification statement(s);
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Oversee the EPA review process for the TQAP, verification reports, and verification
statements; and
Coordinate the submission of verification reports and verification statements for final EPA
approval.
A5.4 Verification Test Stakeholders
This TQAP and the verification report(s) and verification statement(s) based on testing described in this
document will be reviewed by experts in the fields related to asbestos sampling. The following experts
have been providing input to this TQAP and have agreed to provide a peer review.
Mark Follansbee, SRC, Inc.
Patricia Billig, SRC, Inc.
Jonathan Thornburg, Ph.D., Research Triangle Institute
Dave Ferguson, EPA
Bill Barrett, Ph.D., EPA
Jim Konz, EPA
The responsibilities of verification test stakeholders and/or peer reviewers include:
Participate in technical panel discussions (when available) to provide input to the test design;
Review and provide input to the draft TQAP; and
Review and provide input to the verification report(s)/verification statement(s).
In addition, this technology category was reviewed with the broader AMS Center Stakeholder
Committees during the regular stakeholder teleconferences, including the June 2010 meetings, and input
from the committees was solicited.
A5.5 Reference Laboratory
The reference laboratory, Forensic Analytical, is required to receive and analyze filters for asbestos from
the vendor technology as well as soil samples. (Note that samples collected using the ABS reference
method will be analyzed at a laboratory selected by the specific site. In such a case, both analytical
laboratories will follow ISO Method 10312:1995, as well as the counting and stopping rules. Battelle will
send a performance evaluation reference filter and soil samples to both laboratories for analysis to
determine inter-laboratory variability). Secondly, 5% of the samples will be designated as PE samples
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and distributed to both analytical laboratories. Five percent of the soil and filter samples analyzed by
Forensic Analytical will be identified by the VTC as additional PE audit samples. These will be
forwarded to the site laboratory for replicate analysis and verified counting. Mr. Jim Flores will be the
contact person for Forensic Analytical. The responsibilities of the reference laboratory for this
verification test include:
Maintaining accreditation by the National Institute of Standards & Technology (NIST)
National Voluntary Laboratory Accreditation Program (NVLAP) for the performance of
airborne asbestos analysis by transmission electron microscopy (TEM);
Acknowledging receipt of filter samples and maintaining the chain-of-custody forms for the
samples;
Analyzing air filter and soil samples by TEM direct-transfer technique using ISO Method
10312:1995. The target analytical sensitivity is 0.005 (cc)"1. The aspect ratio for analysis is
3:1. All structures 0.50 micrometer (micron or (im) or longer in length are to be quantified
with the following breakdown according to ranges by length: >0.50 to 5.0 (im; > 5.0 (im to
10 (im; and larger than 10 (im;
Providing analysis results within 30 days of receipt of samples;
Providing documentation as requested (such as SOP) for an independent technical systems
audit (TSA) of laboratory procedures; and
Participating in a PE audit (see Section Cl. 1). Since this is an accredited laboratory, an on-
site audit of the laboratory is not anticipated, provided the laboratory meets the acceptable
criteria of the performance evaluation audit.
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A6 BACKGROUND
A6.1 Technology Need
The ETV Program's AMS Center conducts third-party performance testing of commercially available
technologies that detect or monitor natural species or contaminants in air, water, and soil. The purpose of
ETV is to provide objective and quality assured performance data on environmental technologies so that
users, developers, regulators, and consultants can make informed decisions about purchasing and
applying these technologies. Stakeholder committees of buyers and users of such technologies
recommend technology categories, and technologies within those categories, as priorities for testing.
Among the technology categories recommended for testing are asbestos field samplers. In particular, the
use of sampling technologies for the measurement of releasable asbestos fibers from soil in situ was
identified as an area of interest for technology verification.
Asbestos becomes aerosolized or released when material and surfaces on which asbestos fibers are
contained are disturbed by human activity or natural forces. The resultant health risk is due to inhalation
of airborne asbestos fibers. Currently, EPA has established ABS as the preferred approach for measuring
a person's inhalation exposure during surrogate activities such as lawn mowing, raking, jogging, or riding
motorcycles/ATVs that can release asbestos from the soil. It is, however, an expensive and labor-
intensive procedure and EPA has acknowledged that the surrogate activities may not adequately capture
all personal exposures. ABS provides information on a single area under one set of environmental
conditions with a choice of multiple exposure scenarios. Other methods available for determining
asbestos aerosolization from soil are not suitable for field use. The methods require removal and
transport of the soil, thereby potentially altering the physical characteristics of the matrix and subsequent
aerosolization.
An alternative technology appropriate for field use is therefore needed that provides repeatable and
representative asbestos aerosolization data from soil in situ with less labor and at a lower cost than ABS at
comparative exposure scenarios.
A6.2 Technology Description
The following technology description was provided by the vendor. The RAFS, which is owned by EQ
(U.S. Patent No. 7,758,813), is a field-portable system for determining the potential for exposure to
asbestos fibers released from soils. The RAFS was designed to measure the emission rate (asbestos
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structures/sec) and concentration (asbestos structures per cc of air) from soil. The RAFS operates in situ
under actual soil conditions with representative moisture content and grain size. Thus, the possibility that
soil conditions may change during handling, transport, and storage is eliminated.
The RAFS is a field instrument that provides an in situ measurement of asbestos releasability using
mechanical agitation of the source material soil (Figure 2). The RAFS consists of a variable-speed, high
efficiency particulate arrester-filtered fan attached to a tunnel (6-inches by 6-inches by 24-inches) with an
open bottom for exposure to the test matrix soil. The fan discharges the air at the tunnel inlet through
diffusers to evenly distribute the airflow. A variable-speed motorized rake mechanism inside the tunnel
provides consistent and reproducible agitation of the top 1A inch of soil. The rake mechanism has 10 tines
that oscillate slightly as it traverses the tunnel back and forth to agitate the soil to aerosolize the asbestos
fibers. An attachment at the tunnel exit can support up to three 25-mm diameter mixed-cellulose ester
membrane filter cassettes with 50-mm extension cowls for asbestos collection and analysis using direct-
transfer TEM. This aspect of the RAFS design permits collection of concurrent samples for different
sampling periods with resultant varied air volumes to obtain an acceptable particulate loading for analysis
using direct-transfer TEM. A typical sampling period ranges from 10 to 60 minutes, depending on the
filter particulate loading. These filters are then tested for asbestos. Based on the amount of asbestos
present on the filters, the likely exposure of individuals performing activities on the asbestos
contaminated soil can be estimated. The person collecting the sample typically does not need to wear
protective equipment such as a respirator.
Each filter assembly is attached with flexible tubing to an electric-powered (110-volt alternating current)
1/10-horsepower vacuum pump operating at an airflow rate of approximately 13.5 liters per minute (1pm).
Each pump is equipped with a flow-control regulator and individually calibrated rotameter that maintains
the initial flow rate of approximately 13.5 1pm.
The RAFS collects anisokinetic samples where the free stream velocity is greater than the sample
velocity. Under these conditions, smaller-sized particles are not collected in a representative manner.
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Figure 2. Schematic of RAFS with Rake Mechanism Detail
(U.S. Patent Number 7,758,813)
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A7 VERIFICATION TEST DESCRIPTION AND SCHEDULE
The purpose of the test is to generate performance data on a field technology for collecting air samples to
determine the concentration of asbestos released from soil in situ during soil raking activities. The data
generated from this verification test are intended to provide organizations and users interested in
operating this sampling technology with information on the accuracy of measurements and comparability
of the sampling technology to ABS utilizing activities that are most similar to the RAFS operations (e.g.,
soil raking).
A7.1 Verification Test Description
The purpose of this TQAP is to specify procedures for a verification test applicable to sampling and
measuring asbestos releasability from soil. The primary evaluation is to compare releasability measured
by the asbestos field sampler (RAFS) to those made by the EPA-preferred ABS method. In performing
the verification test, Battelle will follow the technical and QA procedures specified in this TQAP, and will
comply with the data quality requirements in the AMS Center QMP.2
Testing will be conducted in three phases over a two-month period (Table 1) by Battelle staff and the
vendor. Each phase will involve approximately one week of testing. Field testing will be conducted in
two phases, and laboratory testing will be conducted in one phase.
The RAFS samplers will be evaluated on the following performance parameters, described in detail in
Section B:
> Comparability;
> Accuracy;
> Reproducibility;
> Variability/Consistency; and
> Operational factors (qualitative assessment).
The field testing will be done in two phases (Phases 1 and 3) with each phase involving a different site.
Three of the performance parameters, comparability, reproducibility and operational factors will be tested
in the field. The same tests will be performed at both sites. At least three areas (10 by 10 ft) at each site
will be tested. Specific tests using the RAFS will be conducted at three sampling points within each area.
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The sampling parameters such as fan speed, rake power (characterized by rake traverse cycles/minute)
and sample volumetric flow rate will be approximately the same. The reproducibility of the sampler will
be tested by comparing the asbestos concentration measured by the filters within the RAFS. RAFS and
ABS sampling will be conducted within site areas known to contain concentrations of asbestos greater
than 0.25% to assess the comparability of the sampler to ABS. Soil samples will be taken at each of the
sampling points.
Table 1. Planned Verification Test Activities and Approximate Schedule
Tests
Field
Laboratory
Phase
1
3
2
Expected
Month of
Completion
August
2010
September
2010
September
2010
Location
Libby, Montana
Weedsport, NY
Battelle
Laboratories
Columbus, OH
Testing Activities
EPA approved ABS method by raking
Reproducibility of the RAFS
Operational parameters
Technical systems audit
Audit of data quality
EPA approved ABS method by raking
Reproducibility of the RAFS
Operational parameters
Audit of data quality
Accuracy of sampler in soil known to
contain asbestos
Variability and consistency between two
replicate RAFS samplers
Technical systems audit
Audit of data quality
Operational parameters including ease of use, training and sustainability (sampling time, waste produced,
and the amount of protective equipment required by the individual operating the instrument) will be
evaluated by Battelle staff. More details on the test design are provided in Section B.I.3.
The laboratory testing will be done in one phase. Two of the performance parameters, accuracy and
variability/consistency will be verified in the laboratory. The laboratory tests allow an evaluation of the
accuracy of measurement by testing the instrument in soils spiked with asbestos fibers. A loose soil
containing fine and coarse grained sand and organic matter will be used. Soil moisture content is critical
when utilizing the RAFS that tests the releasability of asbestos from soil. By varying the soil moisture
content, the ability of the RAFS sampler to determine asbestos concentration within its acceptable range
of soil moisture contents (< 35% soil moisture content) will be tested.
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Subsequent to verification testing, Battelle will prepare one verification report for the field and laboratory
evaluations. The report will describe the RAFS performance on the verification parameters tested within
each phase of the verification (as described in Section B. 1.3). The report will be reviewed by the
technology vendor and by peer reviewers, and revised and submitted to EPA for final approval. In
performing the verification test, Battelle will follow the technical and QA procedures specified in this
TQAP and will comply with the data quality requirements in the AMS Center QMP.
Quality procedures include a TSA and audit of data quality (ADQ). The Battelle QAO or her designee
will perform the TSA. The first batch of data will be delivered within 30 days of test initiation.
Unaudited data will include the disclaimer "has not been reviewed by Battelle QA Manager." The first
ADQ will review the first batch of data delivered. Subsequent ADQs will be performed for each phase of
testing. Additional quality procedure details are provided in Section C.
A7.2 Verification Test Schedule
Table 1 shows the planned schedule of activities for the verification testing and data analysis and
reporting. Both laboratory and field testing of the RAFS samplers will be initiated upon final EPA and
vendor approval of this TQAP, and are planned to begin on or about August 1, 2010. Testing at the
second field site is planned for September 2010. Laboratory and field testing will occur over
approximately a two-month period.
A7.3 Verification Location
Laboratory testing will be conducted in the Environmental Laboratory at Battelle in Columbus, Ohio.
Field testing will be conducted at two sites (Libby OU4, MT and Weedsport, NY).
A7.3.1 Environmental Laboratory. Battelle staff will conduct testing in laboratories that are fully
equipped to handle asbestos-related activities and soils in a controlled environment. The Environmental
Laboratory is located at the Battelle Columbus campus.
A7.3.2 Field Test Sites. Phase 1 of the verification test will be field testing at the Libby OU4
Montana Site. Libby is a community in northwestern Montana, located 7 miles southwest of an open pit
vermiculite mine that operated from 1920 until 1990. Studies at the site revealed that the vermiculite
from the mine contains amphibole-type asbestos (LA). EPA collected initial data beginning in 2005 to
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evaluate human exposure to LA, and the efficacy of cleanup activities. Although the data varied widely, a
discernable correlation between elevated LA levels in soil (by the polarized light microscopy [PLM]
visual area estimation method) and elevated levels of asbestos in air were determined. At Libby, testing
will be conducted in the yards of four Libby residents.
Phase 3 of the verification test will be field testing at the Weedsport, New York site. The former Zonolite
CompanyAV.R. Grace facility located on Dunn Road in Brutus, New York, operated from 1963 until
1989. The facility was known as the "Weedsport facility" because of its close proximity to the Village of
Weedsport. The Agency for Toxic Substances and Disease Registry (ATSDR3) and the New York State
Department of Health (NYSDOH) are evaluating the plant because it processed vermiculite mined in
Libby. The facility exfoliated ("popped" or expanded) vermiculite ore to manufacture insulation, building
products, agricultural products, and fireproofing material (under the brand name Monokoteฎ). This
process released asbestos fibers from the ore into the air, where they could be inhaled. It also produced
unpopped, waste vermiculite often known as stoner rock. The facility processed an estimated 148,485
tons of vermiculite from Libby. Before leaving the site in 1989, W.R. Grace cleaned the former
exfoliating building and had a contractor collect air samples inside the structure. The results showed no
asbestos. Recent EPA soil sampling at this site showed some asbestos in soil. Currently, the site is
unoccupied.
3 Perkins, R.L and B.W. Harvey. 1993. Method for Determination of Asbestos in Bulk Building Materials. ISO Method
10312:1995 EPA/600/R-93/116.
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A8 QUALITY OBJECTIVES
This verification test is designed to evaluate the performance of RAFS samplers in determining the
releasability of asbestos from soil in situ. This verification will vary soil conditions in the laboratory and
instrument parameters throughout the verification to include instrument challenges under controlled and
repeatable test conditions. ABS samples will be analyzed for asbestos using the same analytical method
(i.e., ISO 10312:1995). The quality indicators for this verification test lie in the performance parameters
and the QC samples. Acceptance criteria for the QC samples are detailed in Tables 2 and 3.
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Table 2. Sample Collection Quality Control Assessments During RAFS Verification
Type of Sample or
Data
RAFS
Air Sample
PvAFS
Rake Speed
RAFS
Air Speed
Soil
Soil Moisture
Parameter
Asbestos
Met 1 Optical Particle
Counter
Speed
Speed
Asbestos
%H2O
QC Check
Field Blank
Equipment
Blank
Triplicate
Zero Check
Replicate
Measurements
Replicate
Measurements
Replicate
Samples
Replicate
Measurements
Frequency
1 per area
1 per area
See Table 7
1 per day per OPC
2 per experiment
2 per experiment
2 per location
5 per location
Acceptance
Criteria
< 0.005 str/mm2
< 0.005 str/mm2
20% RPD
< 10 particles per
L of air
5% RPD
5% RPD
n/a
5%RSD
Corrective Action
Blank correct sample data
Blank correct sample data
Flag sample as potentially
invalid. Investigate cause
Repeat until criteria achieved
Repeat until criteria achieved
Repeat until criteria achieved
n/a
Recalibrate and retest
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Table 3. Sample Analysis Quality Control Assessments
Type of
Analysis
TEM
ISO Method
10312:1995
PLM
Analytes
Asbestos
(str)
Asbestos
(points)
QC Check
Lot Blank
Lab Blank
Clean Area Blank
Replicate Analysis
Verified Counting
(intra-lab, inter-lab)
Duplicate Analysis
Inter-laboratory
Duplicate Analysis
Replicate Analysis
Duplicate Analysis
Frequency
2 per Lot
1 per batch of filters prepared
When a Lab Blank does not
meet acceptance criteria
Not to exceed 5% of total
number of samples
Not to exceed 5% of total
number of samples
Not to exceed 5% of total
number of samples
Not to exceed 5% of total
number of samples
Not to exceed 5% of total
number of samples
Not to exceed 5% of total
number of samples
Acceptance Criteria
< 10 str/mm2
< 10 str/mm2
< 10 str/mm2
Replicate(a)=1.96
Duplicate(a) = 2.24
Replicate(a)=1.96
Duplicate(a) = 2.24
Replicate(a) =1.96
Duplicate(a) = 2.24
Replicate(a)=1.96
Duplicate(a) = 2.24
Replicate(a) = 2.24
Duplicate(a) = 2.50
Replicate(a) = 2.24
Duplicate(a) = 2.50
Corrective Action
Reject filter lot
Collect and analyze Clean Area Blank,
re-prep sample.
Identify and eliminate source of
contamination
Re-examine grids to determine cause of
variation
Re-examine grids to determine cause of
variation
Re-examine grids to determine cause of
variation; re-prep sample
Re-examine grids to determine cause of
variation; re-prep filter samples
Re-examine sample to determine cause of
variation; re-prep sample
Re-examine sample to determine cause of
variation; re-prep sample
(a)
Analytical Precision: This variability is the absolute value of the difference of the two analyses, divided by the square root of the sum, which is an
estimate of the standard deviation of the difference based on a Poisson counting model. For replicate air samples, for which the simple Poisson model is
most directly applicable, the value 1.96 is chosen so the criterion will flag approximately 1 replicate pair out of 20 for which the difference is due only
to analytical variability, i.e., it has a "false positive" rate of 5%. For the other types of analyses, where greater natural variability is expected than
indicated by a pure Poisson model, the criterion value has been increased from 1.96 in order to avoid flagging excess cases where the difference between
the values is due only to normal variation, and not to issues with either analysis. The values 2.24 and 2.50 were selected as targeting false positive rates
of 2.50% (1/40) and 1.13% (1/80) forthe Poisson model.
Analytical Vrecision =
(AnalysisA) - (AnalysisB)
^AnalysisA + AnalysisB
Example: For replicate air samples where A = 0 fiber and B = 3 fibers, the variation is considered acceptable, while A = 0 and B = 4 would be flagged for further
investigation. Likewise A = 1 and B = 6 is acceptable, while A = 1 and B = 7 is flagged. At higher levels, A = 20 and B = 34 is acceptable, but A = 10 and B = 24
is flagged.
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A9 SPECIAL TRAINING/CERTIFICATION
Documentation of training related to technology testing, field testing, data analysis, and reporting is
maintained for all Battelle technical staff in training files at their respective locations. The Battelle
Quality Manager will verify the presence of appropriate training records prior to the start of testing.
Battelle and EPA staff involved in this verification at the field sites will be specifically trained on the
operation of the participating technology. Training in the use of the PvAFS sampler will be based on the
instructions provided in the vendor's user manual (Appendix G) and through hands-on training. Battelle
will document this training with a consent form, signed and dated by the vendor, which states which
Battelle technical staff have been trained to use the technology and can train other staff to do so as well.
In the event that other staff members are required to use the technology, they will be trained by the
operators that were trained by the vendors.
FfAZWOPER training and respirator fit testing are required in order to work at the field sites, and at
Battelle Columbus when using the asbestos-spiked soils. Health and safety plans at both the Battelle
laboratory and field sites will be followed.
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A10 DOCUMENTATION AND RECORDS
The documents for this verification test will include the TQAP, vendor instructions, reference methods,
verification reports, verification statements, and audit reports. The project records will include laboratory
record books (LRBs) and data collection forms, supporting laboratory records, training records, electronic
files (both raw data and spreadsheets), and QA audit files. Section BIO summarizes data management for
the test and the types of data to be recorded. Documentation of Battelle staff training by vendors and
copies of other project specific training will also be included in the project files. All of these records will
be maintained by the VTC during the test, and will be transferred to permanent storage at Battelle's
Records Management Office (RMO) at the conclusion of the verification test. All Battelle LRBs are
stored indefinitely with the project files by Battelle's RMO. Section BIO further details the data
management practices and responsibilities.
All data generated during this project will be recorded directly, promptly, and legibly in ink. All data
entries will be dated on the date of entry, and signed or initialed by the person entering the data. Any
changes in entries will be made so as not to obscure the original entry, will be dated and signed or
initialed at the time of the change and will indicate the reason for the change. Project-specific data forms
will be developed prior to testing to ensure that all critical information is documented in real time. The
draft forms will be provided to the Battelle QA Manager for review.
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SECTION B
MEASUREMENT AND DATA ACQUISITION
Bl EXPERIMENTAL DESIGN
This TQAP addresses the verification of RAFS samplers through laboratory and field testing.
Specifically, the RAFS sampler will be evaluated for the following performance parameters:
Comparability;
Accuracy;
Reproducibility;
Variability/Consistency; and
Operational factors (including sustainability).
The verification test will be conducted over a period of two months. The field testing will be completed
in two phases, with each phase being at a different site; laboratory testing will be completed at Battelle's
laboratories in Columbus.
Bl.l Test Procedures
The following sections describe the test procedures that will be used to evaluate each of the performance
parameters listed above. Accuracy and variability/consistency will be evaluated in the laboratory.
Reproducibility, comparability and operational factors will be tested in the field. Cost information will be
provided by the technology vendor (i.e., price of instrument, operation and maintenance cost). The
performance parameters are defined in detail in Table 4.
Bl.1.1 Field Testing. Field testing will be performed in a similar manner at each of the two field
test sites. The site will be prepared by cordoning off at least three distinct areas. The areas could be 10 ft
by 10 ft squares at an industrial site (Weedsport, NY) or the yard of a private residence (Libby, MT). To
be consistent, similar sampling points around each home will be selected for sampling. Within each area,
a minimum of three sampling points will be selected for RAFS operation. Ideally, each soil type, soil
cover, and asbestos contamination level for the test areas will be as similar as possible, but the asbestos
contamination level in the soil may be significantly different. A relatively flat testing area, approximately
1 ft wide and 4 ft long, will be selected for the RAFS. This will allow the RAFS to maintain solid contact
with the soil. The sampler tunnel has a footprint of 6-inches wide by 24-inches long. An uneven surface
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Table 4. Summary of Tests and Testing Frequency
Location
Field
Laboratory
Laboratory
(Continued)
Phase
1&3
1&3
2
2
Performance
Parameter
Reproducibility
Comparability
Accuracy
Variability and
Consistency
Objective
Determine the
reproducibility
within the RAFS
during application
at a sampling point
Determine the
ability of the PvAFS
to measure the
releasability of
asbestos from soil
at the same
accuracy as the
EPA accepted
method, ABS
Determine the
ability of the PvAFS
to measure the
releasability of
asbestos from soil
that is known to
contain asbestos
fibers
Determine the
consistency in data
obtained between
two different
instruments
Variable
Asbestos
concentration on
three filters within
the PvAFS
Asbestos
concentration
obtained by the
average of the
concentration on
three filters within
the PvAFS.
ABS filter asbestos
concentration
Average asbestos
concentration
obtained from the
three filters within
the RAFS at
different soil
moisture contents
Average
concentration of
asbestos from three
filters within the
RAFS of two
RAFS instruments
Comparison Based On
Asbestos concentration
on the three filters
produced at each
sampling point
Soil samples, ABS and
the RAFS will be
applied at the same
sampling point and the
asbestos concentration
obtained from each will
be compared
Whether or not asbestos
is detected by the RAFS
in soil known t contain
asbestos. Asbestos
concentration
determined in soil know
to contain asbestos at
different soil moisture
contents
Average asbestos
concentration detected
on the three filters
produced at each
sampling point from
two independent
samplers at the same
location
Testing Frequency
Triplicate filters from
at least 8 sites, equally
divided between
Libby, MT and
Weedsport, NY
The RAFS will be
applied at three
locations within one
ABS sampling area
The RAFS will be
applied at three
locations within the
4ft by 4ft wooden
frame with soil
The RAFS will be
applied at three
different sampling
locations in soil
known to contain
asbestos. A second
independent sampler
will also be applied in
the soil known to
contain asbestos
Minimum
number of
data points
from asbestos
filters
8
24
21
18
Number of
data points
from soil
sampling
8
24
7
6
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beneath the tunnel walls will be evened to prevent the release of air beneath the walls. Small gaps
between the sampler and the soil will be filled with extra soil.
The surface beneath the sampler tunnel walls will be leveled to ensure that the rake tines reach a depth of
between % to 3/4-inch into the soil. The rake tines will maintain consistent contact with the soil along the
entire length of traverse during sample collection.
The sampling point soil will be kept free of rocks, twigs, roots, and other detritus larger than
approximately !/2-inch in any dimension to prevent the rake mechanism from stalling. As a general rule,
the sampling point is acceptable if the bare soil to vegetation ratio is 1:1 with even coverage. Heavy
vegetation, such as a lawn, will require removal of vegetation to achieve the 1:1 ratio. Extremely
compacted soil may be gently loosened with a hand-held pickax if the rake tines are unable to penetrate
the soil. These conditions will be applied to test areas for RAFS and ABS.
The rake will be mounted to a shaft, which is attached to a motorized screw-drive. The mounting
connection allows for a moderate degree of lateral motion as the rake traverses the tunnel. The lateral
motion of the rake increases the surface area of the soil that is mechanically disturbed. As the rake
traverses the tunnel, grooves are created in the soil and the rake mechanism is lowered by its weight to
accommodate the soil plane. Typically, the rake reaches a depth of approximately 1/8-inch in compacted
soil, %-inch in firm soil, and greater than !/2-inch in sandy soil.
If precipitation is forecasted, the sampling points will be covered with approximately a six by six ft plastic
tarp, held in place with tent stakes to maintain the soil moisture content. The soil moisture content will be
measured at five locations around the sampler's footprint to obtain a representative value of the soil
moisture content (i.e., measured at the four ordinal points and at the center of RAFS tunnel). Before the
RAFS is used, the soil moisture content will be measured using a soil moisture meter. A MetOne (or
equivalent) particle counter will be utilized to measure the releasability of particles from the soil surface
to determine the period of time required for collecting each sample. Soil samples will be taken from each
one by four ft area at the center of the RAFS and at the four cardinal points of the sampler, and
composited into one soil sample to determine the asbestos concentration in the soil. Therefore, there will
be one composite soil sample per RAFS sampling point. The SOP for soil sampling is provided in
Appendix A. The asbestos content in these soil samples will be measured by 1,000 point count (0.1%) by
PLM using EPA 600/R-93/116.
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Determining sampling time- Sample collection is dependent on the generated aerosol concentration and
sample volume (sampling flow rate x sampling time) of the RAFS sampler. Sample periods will be
sufficiently long to collect an adequate amount of aerosol to achieve the specified direct-transfer TEM
analytical detection limit (e.g., 0.005 [cc]"1). The following methods will be used to determine the
sampling time.
a) A hand-held optical particle counter (e.g., MetOne GT-521) will be used to determine the
3
particulate air concentration (i.e., number particles/cm ) or generation rate (number particles
per second) from the RAFS. The MetOne particle counter manual is provided in Appendix E.
Typically, the highest particle concentration and generation rate occur within the first five
minutes of sample collection. Hence, the sample collection time for the first sample will be
determined based on the air concentration or generation rate after the first five minutes.
Table 5 provides guidance on determining sampling time for the first sample to obtain an
acceptable filter loading for asbestos analysis using direct transfer specimen preparation for
TEM analysis.
Table 5. Guidance to Determine Target Sampling Time Based on Generated
Particulate Number, Generation Rate, or Concentration
Aerosol Concentration
(number of
particles/cm3 )
>25
-10
~5
~ 7
~ 1
<1
Sampling
Time (mins)
5 or less
5 to 10
10 to 20
15 to 40
30 to 75
45 to 110
Sample Volume
(liters3)
<68
68 to 135
135 to 270
203 to 540
400 to 1000
600 to 1500
b) After initiating the test sample, once the target sampling period is reached, all three sampling
pumps (pumps within the RAFS that pull air over the soil and through the filters) will be
paused and the filter cassette removed from location # 1 for observation by visual examination
by an unaided eye. Based on the visual examination of the filter particulate loading, sampling
will either be terminated and the remaining two filter cassettes removed, or sampling will
continue with the sampling on filter cassettes #2 and #3. If loading is insufficient on location
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#1, the cassette will be reinserted for additional sample collection. Otherwise filter cassette
#1 will be properly stored for potential subsequent TEM analysis in the laboratory.
Typically, the sampling period for the second filter cassette will extend five, 10, or 15
minutes (or even longer), depending on the visible particulate loading on the filter and the
aerosol concentration being observed. After achieving the target sampling period, the two
sampling pumps will be paused, and the filter cassette removed from location #2. Based on
the visual examination of the filter particulate loading, either the sampling will be terminated
and the third filter cassette removed, or sampling on filter cassette #3 will be continued. If
loading is insufficient on location #2, the cassette will be reinserted for additional sample
collection. Otherwise filter cassette #2 will be properly stored for potential subsequent TEM
analysis in the laboratory.
c) The sampling period for the third filter cassette will extend five, 10, or 15 minutes (or even
longer) depending on the visible particulate loading on the filter and the aerosol concentration
being observed. After achieving the target sampling period, the sampling pump will be
paused, and the filter cassette removed from location #3. If loading is insufficient on location
#3, the cassette will be reinserted for additional sample collection. The filter cassette will be
properly stored for potential subsequent TEM analysis in the laboratory.
d) The sample time for the sample with the largest air volume and acceptable particulate loading
for TEM analysis using direct transfer specimen preparation will be selected and the
corresponding sampling time will be used to collect all samples.
Determining soil moisture content - The vendor indicated that soil moisture content should be below
35% for proper release and aerosolization of asbestos from the soil. Soil moisture content will be
measured by a soil moisture meter (e.g., FieldScout TDR 100 Soil Moisture Meter). The manual for the
soil moisture meter is provided in Appendix D. Data quality indicators (DQIs) or quality parameters are
presented in Table 2.
Bl.1.2 Reproducibility. Reproducibility assessment will determine the precision of the asbestos
concentrations measured by the RAFS. With each application of the RAFS, up to three independent
filters are obtained. If the fan speed, rake power, volumetric flow rate, and sample time (Table 6) are kept
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reasonably constant, the concentration of asbestos detected on the three filters contained each time the
RAFS is applied should be similar. Similar concentrations indicate that the RAFS measurements are
reproducible. To obtain sufficient data to conduct a statistical evaluation, asbestos concentration on the
three filters will be compared for each sampling point. At the RAFS reproducibility, triplicate samples
will be collected at a minimum of eight locations (four at Libby and four at Weedsport). Asbestos
concentration on the three filters for each sampling point will be compared as described in Section B 1.3.
Table 6. Vendor-Specified Operating Parameters
Item
Fan
(air velocity)
Rake
(traverse speed)
Sampling pump
(flow rate)
Target Setting
280 - 380 fpm
1 cyc/20 - 30 s
13 - 14 1pm
Adjustment Location
RAFS control panel
RAFS control panel
Rotameter flow valve
Bl.1.3 Comparability. Comparability refers to the ability of the RAFS sampler to monitor
releasability of asbestos at the same or similar level to the EPA ABS method (considered the reference
measurement). Use of the RAFS will follow the manual provided with the equipment, and ABS activities
will be conducted as outlined in the SOP for Activity Based Sampling, SOP 2084 (Appendix C). At least
eight 10 by 10 ft areas, or residences, will be selected for ABS/RAFS comparability measurements. Four
areas will be located at the Weedsport, NY site and four residences will be sampled in Libby, MT. Within
each area, at least three sampling points will be selected. At each sampling point, the RAFS will first be
applied. ABS by raking will then be conducted in the same selected area. The asbestos concentrations
obtained from a RAFS sample taken from within a given 10 by 10 ft area will be averaged for comparison
with the ABS result from the same area. ABS samples will be taken by the EPA representative as
outlined in the Libby OU4 Sampling and Analysis Plan. A composite sample of soil from the four
cardinal points of the RAFS and at the center of the RAFS will be collected at each sampling point.
Asbestos concentrations will be measured using the ISO 10312:1995 method for both the ABS and RAFS
filters. A minimum of 24 soil samples (eight areas, three sampling points, five samples per point,
combined into one composite sample) and 24 filters from the RAFS (eight areas, three sampling points,
one filter per point) will be analyzed. Battelle will divide the sample quantities equally between Libby,
MT and Weedsport, NY. Note that ISO Method 10312:1995 analysis of ABS samples will be performed
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at the analytical laboratory specified by the EPA Regional Office. Table 4 outlines the number of
samples to be taken.
Bl.1.4 Operational Factors. The operational factors to be measured in the field include the training
required to operate the RAFS sampler. The vendor will train one Battelle staff member on the use of the
RAFS sampler. The Battelle staff member, as well as the vendor, will individually use the sampler during
the field and laboratory tests. The Battelle staff member will then report on the ease of training and use of
the RAFS. The RAFS will also be compared to the EPA approved ABS method in terms of its
sustainability (i.e., the sampling time, waste produced, and the amount of protective equipment required)
by the Battelle staff member. Examples of information to be recorded include vendor effort during
training, ease of technology use, cost associated with maintenance of technology, overall convenience of
the technology, safety issues of technology, number of samples that can be taken per day, and clarity of
the vendor instructions and manual. Battelle will summarize these observations to aid in describing the
operational factors for the technology in the verification report.
B1.2 Laboratory Test
The objectives of the laboratory tests are to assess the RAFS ability to release asbestos from soil as a
function of environmental conditions, specifically asbestos concentration in soil and soil moisture
content. The laboratory tests will be performed on topsoil in a temperature and humidity controlled
laboratory. The soil used will be a mixture of fine and coarse sands with organic materials to control soil
moisture. All laboratory tests will be performed in a four by four ft wooden frame holding approximately
three inches of soil. Several four by four ft wooden frames will be used for the laboratory tests. The
results of the laboratory tests are independent and will not be compared to the results of the field tests.
Bl.2.1 Accuracy. The accuracy of the sampler will be verified by measuring the asbestos
releasability from soil that is known to contain asbestos. Chrysotile "A" Rhodesian Asbestos 0.10 g will
be mixed with soil and packed into a four by four ft wooden frame. Before addition of the asbestos to the
soil, the moisture content of the soil in the wooden frame will be determined to ensure that soil moisture
content is less than 35%. Soil samples taken at the four ordinal points around the RAFS and at the center
of the RAFS will be combined into one composite soil sample. The RAFS will then be applied to the soil
to determine the optimum sampling time using the procedure outlined in Section B. 1.1.1. That sampling
time will then be utilized to test the RAFS's ability to release and detect asbestos from the soil. The
RAFS only needs to be applied at one sampling point since asbestos is known to be present. This yields
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three filters and one composite soil sample. The fan speed, rake power, and sample volume will be
recorded and held constant during this test (Table 6).
The aerosolization of asbestos by the RAFS will also be tested at varying soil moisture content within the
acceptable range. Soil moisture content of 5% and 15% will be tested on the soil amended with asbestos
starting with soil at 5% and increased by 10% by adding water before the test. The soil moisture content
will be confirmed at the soil surface at least to a depth of one inch using the soil moisture meter. At each
soil moisture content, the sampler will take three separate measurements. A total of 18 filters will be
analyzed (two soil moisture conditions, three sampling points per moisture condition, three filters per
RAFS application) and six soil samples (two soil moisture conditions, three sampling points per moisture
condition, five samples per sampling point composited into one sample each).
Bl.2.2 Variability/Consistency. In the laboratory, two RAFS will be used to measure the
releasability of asbestos from soil known to contain asbestos. The ability of both samplers to measure the
releasability of asbestos identically will be monitored by operating each sampler three times within the
four by four ft wooden frame containing soil known to contain asbestos. The fan speed, rake power and
sample volume collected will be recorded and remain constant for both samplers (Table 6). The length of
time the samples are taken will be previously determined using the procedure described in Section B 1.1.1.
An average of the asbestos concentration obtained from the three filters within the RAFS will be
calculated and compared to the same value for the second RAFS. A total of 18 filters will be analyzed
(three per sampling event, three sampling events, for two RAFS), and six soil samples (two RAFS, three
sampling events each, one composite soil sample per sampling event).
B1.3 Statistical Analysis
The analytical data obtained from the RAFS will be used to calculate the emission rate of the RAFS and
the asbestos concentration released from the soil.
AsbestosStructuresperfilter
EmissionRate =
SamplingTime
AsbestosStructuresperFilter
AsbestosConcentration =
SampleVolume
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The statistical methods and calculations used for evaluation of the quantitative performance parameters
are described in the following sections.
Bl.3.1 Reproducibility. The reproducibility of the data obtained from the three filters within the
RAFS will be determined. The RAFS will be applied at three sampling points. At each sampling point,
three filters, and therefore three data points, will be obtained and compared. This will be done at three
sampling points yielding triplicate measurements. The relative percent standard deviation (RSD) between
the measurements will be calculated.
%RSDฃ = 4 x 100
*i
Y-
Where l is the average sampler response /', and s the standard deviation of the sampler
responses.
Bl.3.2 Comparability. Comparability is the agreement between the measurements collected by two
identical devices or measures (in this case, asbestos concentration obtained from the RAFS and by ABS).
Comparability is reported as the relative percent difference (RPD) between multiple samples,
measurements, or sample analyses. At each sample point, three filters and three asbestos concentrations
will be obtained. An average of the asbestos concentration at each sampling point will be determined. At
each area where ABS is applied, the RAFS is applied at four sampling points so there will be four data
points to compare to each ABS result. An RPD (difference over mean) will be determined for each of the
four RAFS sampling points to the ABS result.
(RAFS + ABS)/2
In addition, a one way ANOVA or t-test of the data will be conducted to compare the average asbestos
concentration obtained from the RAFS and ABS methods.
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nA
where u represents the average asbestos concentration for one sampling area, R represents the RAFS data,
and A represents the ABS data. The variance of the data is var, and n is the number of samples.
Bl.3.3 Accuracy. The accuracy of the sampler will be verified by measuring the asbestos
releasability from soil that is known to contain asbestos. The details of the test are presented in Section
Bl.2.1.
When soil moisture concentration is found to be variable, a sampling point at each moisture concentration
will be collected. From each sampling point, three asbestos concentrations will be obtained from the
three filters within the RAFS. An average RAFS concentration will be obtained from the three filters.
Soil moisture contents of 5% and 15% will be targeted for soils with known asbestos concentrations. The
percent difference in releasability of asbestos at the different moisture conditions will be measured.
%RPD = ^
where u\ represents the average asbestos concentration obtained from the three filters at each RAFS
sampling point, and / represents the concentration of asbestos obtained from the ABS measurement in that
sampling area.
Bl.3.4 Variability and Consistency. Variability and consistency is determined in a laboratory
analysis by measuring the releasability of asbestos from two RAFS in soil known to contain asbestos.
Each RAFS will be applied at three sampling points. From each sampling point, three asbestos
concentrations are obtained from the three filters within the RAFS. An average RAFS concentration will
be obtained from the three filters. This will be done three times for both RAFS. To compare the
variability and consistency of the results, the RPD of the data will be determined.
%RPD= ~
(M! +1/2) / 2
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where u\ represents the average asbestos concentration obtained from one sampling point from the first
RAFS, and u2u2 represents the average asbestos concentration obtained from one sampling point for the
second RAFS.
B2 SAMPLING METHOD REQUIREMENTS
Sampling will be performed according to the vendor provided instructions and training. ABS sampling
will be performed by field staff at the site as part of each site's on-going characterization activities.
RAFS sampling will be conducted according to the RAFS manual provided by the vendor (Appendix G).
Manuals and SOPs for all instruments are provided in the appendices.
B3 SAMPLE HANDLING AND CUSTODY REQUIREMENTS
Sample custody will be documented for the filter, soil, and ABS samples. A chain-of-custody (COC)
form will include details about the sample, such as the time, date, location, and person collecting the
sample. The COC form will track sample release from the sampling location to the testing laboratory.
The COC form will be signed by the person relinquishing samples once that person has verified that the
COC form is accurate. Upon arrival at the testing laboratory, COC forms will be signed by the person
receiving the sample once that person has verified that all samples identified on the COC forms are
present. Copies of all COC forms will be delivered to the VTC and maintained with the test records.
Section B3.2 describes the proper handling of the filter cassettes for subsequent TEM analysis. All
samples will be transferred to the analytical laboratory using COC documentation.
The COC procedures emphasize careful documentation of constant secure custody of samples during the
field, transport, and analytical stages of project. The sample custodian (and alternate) responsible for the
proper COC during this project is:
Person's/Name;
Company Name/Address; and
Phone number.
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B3.1 Field Chain-of-Custody
Each sample will have a unique project identification number. This identification number will be
recorded on a Sampling Data Form along with the other information specified on the form. After the
labeled sample cassettes and containers are inspected, the sample custodian will complete an analysis
request and COC record. This form will accompany the samples, and each person having custody of the
samples will note receipt of the same and complete an appropriate section of the form. Samples will be
sent to the appropriate laboratory via one or two day courier service.
B3.2 Sample Shipment
RAFS filter and soil samples will be securely packaged and shipped directly to the appropriate analytical
laboratory. RAFS air filter samples will be packaged facing upwards and secured to minimize jostling,
rattling, or other movement that may dislodge particles from the filter. Using the recommended
procedure, the cassettes will be placed, wrapped in a paper towel, in the original egg-crate shipment box.
The box will then be sealed and placed in a secondary container, such as a cooler, with appropriate
packing material to minimize movement. Soil sample jars will be shipped in a separate cooler with
sufficient packing material to prevent movement.
A COC sheet will accompany each shipment. At a minimum, the COC sheet will contain the site location
name, sample identification number, sample type, approximate sample volume, shipper's initials,
shipment date, receiver's initials, and receipt date.
B3.3 Sample Receipt
The laboratory's sample clerk will examine the shipping container and each sample cassette or sample
container to verify sample numbers and check for any evidence of damage or tampering. The COC form
is checked for completeness and signed and dated to document receipt. Any changes will be recorded on
the original COC form and then the form will be forwarded to the VTC. The sample clerk will log in all
samples and assign a unique laboratory sample identification number to each sample and sample set.
COC procedures will be maintained in the analytical laboratory.
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B4 ANALYTICAL METHOD REQUIREMENTS
All filters generated in the field and in the laboratory will be analyzed for asbestos by TEM direct-transfer
technique using ISO Method 10312:1995. The target analytical sensitivity is 0.005 (cc)"1, which is
obtained by varying the number of grid openings and grid area during analysis of the filters. For example,
39 grid openings, a 0.01 mm2 grid area, a filter area of 385 mm2, and an air volume of 200 liters would
achieve an analytical sensitivity of 0.005 structures (str)/cm3 (i.e., the AS specified in the TQAP). The
aspect ratio for analysis is 3:1. All structures 0.5 (im or longer in length are to be quantified with the
following breakdown according to ranges by length: >0.5 to 5.0 (im; >5 (im to <10.0 (im; and > 10 (im.
Asbestos concentration in soil samples will be measured by 1000 point PLM method (EPA 600/R-
93/116).
B5 QUALITY CONTROL REQUIREMENTS
QC measures are included to ensure quality data is provided by the verification test. This includes lot
blanks, field blanks, equipment blanks, laboratory blanks, PE samples and duplicates/replicates. The QC
procedures and acceptance criteria are presented in Table 2 and described in Appendix G.
B5.1 RAFS Lot Blank
Before air samples are collected, a minimum of 2% of unused filters from each filter lot of 100 filters will
be analyzed to determine the mean asbestos structure count. The lot blanks will be analyzed for asbestos
structures by using ISO 10312:1995. If the mean count for all types of asbestos structures is found to be
more than 10 str/mm2, the filter lot will be rejected.
B5.2 RAFS Field Blank
B5.2.1 Open Field Blank. A field blank (25-mm dia., 0.8-um pore size mixed cellulose ester
[MCE] membrane filter with 50-mm extension cowl) is collected to check for accidental contamination of
samples by the operator. An open field blank is taken by removing the filter cap and waving the filter in
the ambient air for 30 seconds. One "open field blank" is collected for each sample set from each area.
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B5.2.2 Closed Field Blank. A closed field blank is a QC sample (25-mm dia., 0.8-um pore size
MCE membrane filter with 50-mm extension cowl) which is not opened. That is, it is transported to the
field and sent to the laboratory without removing the plugs or caps. The closed field blank will be taken
before the RAFS samples are taken. One closed field blank is collected per area.
B5.3 RAFS Equipment Blank
An equipment blank is a QC sample used to detect asbestos fibers introduced to samples during the
measurement process (i.e., it determines the cleanliness and decontamination effectiveness of the RAFS).
Immediately prior to collection of field samples, a vendor equipment blank sample will be collected to
demonstrate the cleanliness of the vendor equipment. The RAFS unit is placed on a clean aluminum
sheet, or equivalent non-porous surface. The equipment blank (open-face, 25-mm dia., 0.8-um pore size
MCE filter with 50-mm extension cowl) is then collected using exactly the same procedure as used to
collect a test sample. During the sampling period, the emission of any particles is determined using the
optical particle counter. If the concentration on the optical particle counter exceeds 100 str/cm , the unit
is cleaned again, the filters replaced, and the test started again. One equipment blank is taken
immediately prior to collection of samples on each area.
To collect an equipment blank, the clean RAFS will be placed on a clean non-porous surface. A 'blank'
sample (open-face, 25-mm dia., 0.8-um pore size MCE membrane filter with 50-mm extension cowl) will
be collected from the RAFS using the same procedures to collect a test sample, with the exception that the
RAFS is positioned on a clean surface. The fan will be operated at the same speed as that utilized during
testing. During the blank sampling period, the emission of any particles will be determined using an
3
optical particle counter. If the concentration on the optical particle counter exceeds 100 str/cm , the unit
will be cleaned again, and testing restarted.
B5.4 Laboratory Blank
Laboratory blanks are unused filters that are prepared and analyzed in the same manner as the field
samples to verify that reagents, tools, and equipment are free of the subject analyte and that contamination
has not occurred during the analysis process. The laboratory will analyze one blank per prep series.
Blanks are prepared and analyzed along with the other samples. If the blank control criteria are not met,
the results for the samples prepared with the contaminated blank are suspect and will not be reported, or
are reported and flagged accordingly. The preparation and analyses of samples will be stopped until the
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source of contamination is found and eliminated. Before sample analysis is resumed, contamination-free
conditions will be demonstrated by preparing and analyzing laboratory clean area blanks that meet the
blank control criteria. Laboratory blank count sheets will be maintained in the project folder along with
the sample results. A PE audit will be conducted on each laboratory that will analyze filter and soil
samples for this project. Forensic Analytical will analyze the filters and soil; then the site laboratory will
perform a replicate analysis and verified counting on 5% of the samples. The PE audit will be prepared
by RTI International (RT). RTI is accredited to prepare PE audit samples.
B5.5 Performance Evaluation Samples
PE samples will be analyzed by each laboratory that will analyze soil and filter samples for this project as
is described in Section Cl.l.
B5.6 Duplicates
Replicate soil samples will be taken at each sampling area at the frequency outlined in Table 2. Replicate
measurements of rake speed, airspeed and soil moisture will also be taken.
B6 INSTRUMENT/ EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE
When Battelle staff operate and maintain the RAFS undergoing testing, those activities will be performed
as directed by the vendor. Otherwise, operation and maintenance of the samplers will be the
responsibility of the vendor. The manual for each piece of equipment used is provided in the appendices.
B7 INSTRUMENT CALIBRATION AND FREQUENCY
The RAFS does not require any calibration, but does require a performance check of its primary operating
settings: fan speed and rake speed. The particle counter and moisture meter are calibrated once per year;
see manuals in appendices.
B8 INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES
All materials, supplies, and consumables will be ordered by the vendor.
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B9 NON-DIRECT MEASUREMENTS
Data published previously in the scientific literature will not be used to evaluate the vendor's technology
during this verification test.
BIO DATA MANAGEMENT
Various types of data will be acquired and recorded electronically or manually by Battelle and vendor
staff during this verification test. Table 7 summarizes the types of data to be recorded. All maintenance
activities, repairs, calibrations, and operator observations relevant to the operation of the sampling
systems being tested will be documented by Battelle or vendor staff in the project-specific LRB or
dedicated data collection forms. Report formats will include all necessary data to allow traceability from
the raw data to final results. A dedicated shared folder within the ETV AMS Center SharePoint site will
be established for all project records.
Records received by or generated by any Battelle or subcontractor staff during the verification test will be
reviewed by a Battelle staff member within five days of receipt or generation, respectively, before the
records are used to calculate, evaluate, or report verification results. If a Battelle staff member generated
the record, this review will be performed by a Battelle technical staff member involved in the verification
test, but not the staff member who originally received or generated the record. The review will be
documented by the person performing the review by adding his/her initials and date to the hard copy of
the record being reviewed. In addition, any calculations performed by Battelle will be spot-checked by
Battelle technical staff to ensure that calculations are performed correctly. Some of the checks that will
be performed include:
QC samples and calibration standards were analyzed according to the TQAP and the
acceptance criteria were met. Corrective action for exceedances was taken;
100% hand-entered and/or manually calculated data were checked for accuracy;
Calculations performed by software were verified at a frequency sufficient to ensure that
the formulas were correct, appropriate, and consistent;
For each cut and paste function, the first and last data value was verified versus the
source data;
Data were reported in the units specified in the test/QA plan;
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Results of QC samples were reported; and
All statistical calculations described in this TQAP were conducted.
Battelle will provide technology test data and associated reference data (including records; data sheets;
notebook records) from the first day of testing within one day of receipt to EPA and the vendor for
simultaneous review. The goal of this data delivery schedule is prompt identification and resolution of
any data collection or recording issues. These data will be labeled as preliminary and will not have had a
QA review before their release.
Table 7. Summary of Data Recording Process
Data to Be Recorded
Dates, times, and details of
test events
Asbestos Sampler operating
conditions, maintenance,
down time, etc.
Asbestos sampler settings
Asbestos concentration in soil
Soil moisture content
Asbestos concentrations on
filter
Where Recorded
ETVLRBs, field
sampling records
ETVLRBs, or
electronically
Recorded
electronically by
each monitor and
then downloaded to
computer daily
Obtained from
laboratory
Read electronically
from instrument and
recorded in
laboratory note book
Obtained from
laboratory
How Often
Recorded
Start/end of test
event
When performed
Recorded
continuously by
each monitoring
system
After each
sampling event
Recorded from
after each
measurement
After each
sampling event
By Whom
Battelle staff
Vendor and
Battelle staff
Vendor staff for
transfer to
Battelle
Battelle Staff
Vendor and
Battelle staff
Battelle staff
Disposition of Data
Used to organize/check
test results; manually
incorporated in data
spreadsheets as
necessary
Incorporated in
verification report as
necessary
Converted to
spreadsheet for
statistical analysis and
comparisons
Converted to
spreadsheet for
statistical analysis and
comparisons
Converted to
spreadsheet for
statistical analysis and
comparisons
Converted to
spreadsheets for
statistical analysis and
comparisons
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SECTION C
ASSESSMENT AND OVERSIGHT
Cl ASSESSMENT AND RESPONSE ACTIONS
Every effort will be made in this verification test to anticipate and resolve potential problems before the
quality of performance is compromised. One of the major objectives of this TQAP is to establish
mechanisms necessary to ensure this. The procedures described in this TQAP, which is peer reviewed by
a panel of outside experts, implemented by the technical staff and monitored by the VTC, will provide
information on data quality on a day-to-day basis. The responsibility for interpreting the results of these
checks and resolving any potential problems resides with the VTC. Technical staff has the responsibility
to identify problems that could affect data quality or the ability to use the data. Any problems that are
identified will be reported to the VTC, who will work with the Battelle Quality Manager to resolve any
issues. Action will be taken to control the problem, identify a solution to the problem, minimize losses,
and correct data, where possible. Independent of any EPA QA activities, Battelle will be responsible for
ensuring that the audits described below are conducted as part of this verification test.
Cl.l Performance Evaluation Audit
Two types of PE audits will be conducted during this test. First, two PE audit samples, soil and filter, of
known concentrations will be prepared by RTI and submitted to both laboratories. Results must fall
within the PE sample acceptance range. Second, 5% of the samples will be designated as PE samples and
distributed to both analytical laboratories. Five percent of the soil and filter samples analyzed by Forensic
Analytical will be identified by the VTC as PE audit samples. These will be forwarded to the site
laboratory for replicate analysis and verified counting. The results will assess comparability of multiple
laboratories analyzing the same samples using the same methods (confirming that both laboratories can
accurately perform the required analytical methods).
C1.2 Technical Systems Audits
The Battelle QAO or delegate will perform a TSA during performance of Battelle laboratory testing and
one of the field-testing sites. The purpose of these audits is to ensure that the verification test is being
performed in accordance with the AMS Center QMP and this TQAP. The reference laboratory is not
expected to be assessed during a separate TSA, provided acceptable performance on the PE audit. The
field TSA may be designated to an independent person by providing a checklist to be completed on site.
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During the TSAs, the Battelle QAO or designee will compare actual test procedures to those specified or
referenced in this plan and review data acquisition and handling procedures. The Battelle QAO will
prepare a project-specific checklist based on the TQAP requirements to guide the TSA, which will
include a review of the test location and general testing conditions; observe the testing activities; and
review LRBs. The Battelle QAO will also check data acquisition procedures, and may confer with the
vendor staff. The Battelle QAO will prepare an initial TSA report and submit the report to the EPA
Quality Manager (with no corrective actions documented) and VTC within 10 business days after
completion of the audit. A copy of each final TSA report (with corrective actions documented) will be
provided to the EPA AMS Center Project Officer and Quality Manager within 20 business days after
completion of the audit. At EPA's discretion, EPA QA staff may also conduct an independent on-site
TSA during the verification test. The TSA findings will be communicated to technical staff at the time of
the audit and will be documented in a TSA report.
C1.3 Data Quality Audits
The Battelle QAO, or designee, will audit at least 10% of the sample results data acquired in the
verification test and 100% of the calibration and QC data versus the TQAP requirements. Four ADQs
will be conducted for this project: the first batch of data will be audited within 10 business days of receipt
and assessed using a project-specific checklist. Additional ADQs will be audited within 10 business days
of receipt of all Phase 1, 2, and 3 data. During these audits, the Battelle QAO, or designee, will trace the
data from initial acquisition through reduction and statistical comparisons, to final reporting. All
calculations performed on the data undergoing the ADQ will be checked. Data must undergo a 100%
validation and verification by technical staff (i.e., VTC, or designee) before it will be assessed as part of
the data quality audit. All QC data and all calculations performed on the data undergoing the audit will be
checked by the Battelle QAO. Results of each ADQ will be documented using the checklist and reported
to the VTC and EPA within 10 business days after completion of the audit. These reports will not include
documented corrective actions. The completed ADQs with corrective actions documented will be
provided to EPA within 10 business days of receipt from the VTC. A final ADQ that assesses overall
data quality, including accuracy and completeness of the technical report, will be prepared as a narrative
and distributed to the VTC and EPA within 10 business days of completion of the audit.
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C1.4 QA/QC Reporting
Each assessment and audit will be documented in accordance with Section 3.3.4 of the AMS Center
QMP. The results of all audits will be submitted to EPA within 10 business days as noted above.
Assessment reports will include the following:
Identification of any adverse findings or potential problems;
Recommendations for resolving problems. (If the QA audit identifies a technical issue, the
VTC or Battelle AMS Center Manager will be consulted to determine the appropriate
corrective action);
Response to adverse findings or potential problems;
Confirmation that solutions have been implemented and are effective; and
Citation of any noteworthy practices that may be of use to others.
C2 REPORTS TO MANAGEMENT
During the field and laboratory evaluation, any TQAP deviations will be reported immediately to EPA.
The Battelle Quality Manager and/or VTC, during the course of any assessment or audit, will identify to
the technical staff performing experimental activities any immediate corrective action that should be
taken. A summary of the required assessments and audits, including a listing of responsibilities and
reporting timeframes, is included in Table 8. If serious quality problems exist, the Battelle Quality
Manager will notify the AMS Center Manager, who is authorized to stop work. Once the assessment
reports have been prepared, the VTC will ensure that a response is provided for each adverse finding or
potential problem and will implement any necessary follow-up corrective action. The Battelle Quality
Manager will ensure that follow-up corrective action has been taken. The TQAP and final report are
reviewed by the EPA AMS Center Quality Manager and the EPA AMS Center Project Officer. Upon
final review and approval, both documents will then be posted on the ETV Web site (www.epa.gov/etv).
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Table 8. Summary of Assessment Reports(:
Assessment
Phase 1
(Field)TSA
Phase 2
(Laboratory) TSA
ADQ (Initial batch
and Phases 1,2,
and 3)
Prepared By
Battelle or
delegate
Battelle
Battelle
Report Submission Timeframe
TSA response is due to QAO
within 10 business days of receipt
from QAO
TSA responses will be verified by
the QAO and provided within 20
business days
10 business days after TSA is
complete
ADQ will be completed within 10
business days after receipt of the
initial data batch and then after all
data for a phase is submitted
Submitted To
EPA ETV AMS Center
EPA ETV AMS Center
EPA ETV AMS Center
(a) Any QA checklists prepared to guide audits will be provided with the audit report.
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SECTION D
DATA VALIDATION AND USABILITY
Dl DATA REVIEW, VERIFICATION, AND VALIDATION REQUIREMENTS
The key data review and data verification requirements for this test are stated in Section BIO of this
TQAP. In general, the data review requirements specify that data generated during this test will be
reviewed by a Battelle technical staff member within five days of generation of the data. The reviewer
will be familiar with the technical aspects of the verification test but will not be the person who generated
the data. This process will serve both as the data review and the data verification, and will ensure that the
data have been recorded, transmitted and processed properly. Furthermore, this process will ensure that
the monitoring systems data were collected under appropriate testing.
The data validation requirements for this test involve an assessment of the quality of the data relative to
the DQI for this test referenced in Tables 2 and 3. Any deficiencies in these data will be flagged and
excluded from any statistical comparisons to the RAFS being tested, unless these deviations are
accompanied by descriptions of their potential impacts on the data quality.
D2 VERIFICATION AND VALIDATION METHODS
Data verification is conducted as part of the data review as described in Section BIO of this TQAP. A
visual inspection of handwritten data will be conducted to ensure that all entries were properly recorded
or transcribed, and that any erroneous entries were properly noted (i.e., single line through the entry, with
an error code, such as "wn" for wrong number, and the initials of the recorder and date of entry).
Instrument parameters and laboratory data collected during the test will be inspected to ensure proper
transfer from the datalogging system. All calculations used to transform the data will be reviewed to
ensure the accuracy and the appropriateness of the calculations. Calculations performed manually will be
reviewed and repeated using a handheld calculator or commercial software (e.g., Excel). Calculations
performed using standard commercial office software (e.g., Excel) will be reviewed by inspection of the
equations used for the calculations and verification of selected calculations by handheld calculator.
Calculations performed using specialized commercial software (i.e., for analytical instrumentation) will
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be reviewed by inspection and, when feasible, verified by handheld calculator, or standard commercial
office software.
To ensure that the data generated from this test meet the goals of the test, a number of data validation
procedures will be performed. Sections B and C of this TQAP provided a description of the validation
safeguards employed for this verification test. Data validation efforts include the completion of QC
activities and the performance of a TSA as described in Section C. The data from this test will be
evaluated relative to the measurement DQIs described in Section A8 of this TQAP. Data failing to meet
these criteria will be flagged in the dataset and not used for evaluation of the RAFS, unless these
deviations are accompanied by descriptions of their potential impacts on the data quality.
An ADQ will be conducted by the Battelle Quality Manager to ensure that data review, verification, and
validation procedures were completed, and to ensure the overall quality of the data.
D3 RECONCILIATION WITH USER REQUIREMENTS
The purpose of this verification test is to evaluate the performance field samplers for asbestos detection.
This evaluation will include a comparison to ABS. To meet the requirements of the user community,
input on the tests described in this TQAP has been provided by external experts. Additional performance
data regarding operational characteristics of the field RAFSs will be collected by verification test
personnel. To meet the requirements of the user community, these data will include thorough
documentation of the performance of the samplers during the verification test. The data review,
verification, and validation procedures described above will ensure that data meeting these requirements
are accurately presented in the verification reports generated from this test, and will ensure that data not
meeting these requirements will be appropriately flagged and discussed in the verification reports.
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APPENDIX A
STANDARD OPERATING PROCEDURE FOR SOIL SAMPLE
COLLECTION DURING THE RELEASABLE ASBESTOS FIELD STUDY
(RAFS)
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CAT 600: Soil Sample Collection
Rev. #00
5/14/2010
Page 53 of 68
Standard Operating Procedure
for
Soil Sample Collection
during the Releasable Asbestos Field Study (RAFS)
Prepared by: Cortina Johnson
Reviewed by: _Andrew Dart_
Approved by:
Date: 5/10/2010
Date: 5/10/2010
Date:
RTI International
3040 Cornwall! s Road
Research Triangle Park, NC 27709
USA
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Table of Contents
1. Background 56
2. Sampling Procedure 56
2.1. Equipment 56
2.2. Cleaning 56
2.3. Soil Sample Collect on Procedure for Outdoor RAF S 57
3. Shipment Preparation 58
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List of Revisions
CAT Revision ซ. n .
Number Number Changes Date
600
0
Original, based on RAFS QAPP
05/2010
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1. Background
This procedure provides a systematic approach for the collection of asbestos contaminated soil at
multiple locations at a site. The collected soil samples are analyzed to determine asbestos soil
loading. Trained field technicians use this method. Soil samples are collected in a manner that
meets the requirements of this method and the needs of the investigator for whom the soil is
being analyzed. The technician collects a composite soil sample at each location. A
representative portion of the soil sample material is collected in a rigid, sealable, non-breakable
container. The soil is shipped to a laboratory for PLM or TEM analysis.
2. Sampling Procedure
2.1. Equipment
2.1.1. Template - Cleanable plastic or metal template with a square central hold of
size 15cm x 15cm x 1cm.
2.1.2. Scoop - A rigid metal or plastic scoop or trowel with a sharp edge.
2.1.3. Sample Compositing Container - Large area rigid, container of sufficient size to
hold 1.5 L dry soil.
2.1.4. Sample Containers - Rigid, sealable, non-breakable containers of sufficient size
to hold 1000 cm3 dry soil (1 container per composite).
2.1.5. Tape - To seal sample containers.
2.1.6. Adhesive labels - To label samples.
2.1.7. Spray Bottle - A plastic bottle filled with soapy water or other cleaning
solution.
2.1.8. Lint-free cloths - Moistened with de-ionized water for cleaning sampling
equipment before and after use.
2.1.9. Paper Towels - To dry equipment and for general use around sampling site.
2.1.10. Shipping Container - A rigid container of sufficient volume and structural
integrity to hold sample containers for shipping.
2.1.11. GPS Unit - GPS unit to mark coordinates of the soil sample location.
2.1.12. Marker Flags - (Optional). Construction marker flags to physically indicate
where soil samples were collected. These flags are useful if different personnel
will return to the site for additional sample collection.
2.2. Cleaning
2.2.1. The materials listed above must be cleaned thoroughly before and after use to
avoid cross contamination. Remove all extraneous material and debris by hand
and wipe the equipment using the lint-free DI wipes. Allow sufficient time for
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the equipment to dry before use (if necessary, manually dry the equipment with
a clean un-used paper towel).
2.2.2. Disposal of waste in doubled garbage bag, taped closed, disposed in hazardous
waste landfill or municipal trash, as specified in site protocols.
2.3. Soil Sample Collection Procedure for Outdoor RAFS
This section describes soil sample collection from a relatively flat horizontal surface.
2.3.1. Sample Location Characteristics - Try to select locations within minimal
vegetation. If a location with minimal vegetation cannot be identified, the
technician should use their judgment to select another location or remove excess
vegetation by hand.
2.3.2. Sample Point Selection -
2.3.2.1. Preliminary Site Evaluation Sample Collection: Collect soil using the
template from five cardinal locations of a 3 m by 3 m square (or as
close as possible). Cardinal locations correspond to the North, East,
South, West, and Center points of the 3 m by 3 m square. Technician
should use their best judgment when selecting sample locations.
Record GPS coordinates of the "center" point on the COC sheet.
2.3.3. Sample Collection - If necessary, loosen the soil with a garden trowel or garden
pick. Using the template to mask the area where soil will be collected, scoop
soil from the masked area down to a depth of 1 cm and place it into the
compositing container. Repeat for all 5 locations.
2.3.4. Mixing - After all 5 samples are collected; thoroughly mix the soil in the
compositing container.
2.3.5. Sample Distribution - Distribute an aliquot of soil into the sample container.
2.3.6. Labeling - Label the sample containers and corresponding datasheet (See Table
1) using the code shown below. Note: COC sheet already completed with
desired sample IDs.
Site-"SOIL"-Area#-Location#-Jar#.
Examples for Silver Strand Navy Site, San Diego, California:
SDCA-SOIL-A1-L1-1
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Figure 1. Five points to collect soil samples surrounding oRAFS footprint.
3. Shipment Preparation
3.1. Sealing- Once samples are collected and sealed, the jars shall be taped around the rim
and loaded into the shipping container. All available space in cooler should be filled
using foam or plastic wrap to prevent damage during transport.
3.2. COC sheet - See Forensic Analytical COC sheet. Complete the following COC cells as
instructed below.
3.2.1. Date (next to Sample ID)
3.2.2. Sample Location/Description: Navy Area ID (A, B, G, etc) and GPS coordinates
3.2.3. Sampled By/Date/Time
3.2.4. Shipped Via
3.2.5. Relinqui shed By
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APPENDIX B
FIELD DATA SHEETS
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ETV Test of Asbestos Sampling Tools
AIR SAMPLING AND INSTRUMENT DATA COLLECTION FORM
RELEASABLE ASBESTOS FIELD SAMPLER (RAFS)
Site
Sampling Condition Parameters
Area:
Weather Phenomena
Location Description
Location: RH:
(e.g. rain, wnd gusts):
(e.g. vegetation, soil consistency):
Sample
ID
MetOne GT 521 Filename
RAFS
Unit Nซ
Start
Date:
Tech:
GPS:
Altitude:
N
W
feet
% Temp: ฐF WindVel: mles/hr Bar Press: inches of Hg
Direction: DewPt: ฐF
Test Qualifier:
Rotometer,
Pump Nฐ
Rotometer Reading
Start
(L/m)
Stop
Flow
Rate (L/m)
Stop
(L/m)
Agitator Data
Start
Count
Stop
Count
Cycle
Time (s)
Depth
(inches)
Time
Start
Stop
Comments
Soil Moisture Readings
Reading 1
Reading 2
Reading 3
Reading 4
Reading 5
Additional Sample Period Comments
Soil Sample Tracking
Split*
j
3
4
5
Sample ID
Filter
Comments ._
Vane Anemometer
feet/minute
Comments
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APPENDIX C
STANDARD OPERATING PROCEDURES FOR ACTIVITY BASED SAMPLING
(Click on the title for a link to this appendix)
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APPENDIX D
MANUAL FOR SOIL MOISTURE METER
(Click on the title for a link to this appendix)
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APPENDIX E
MANUAL FOR OPTICAL PARTICLE COUNTER
(Click on the title for a link to this appendix)
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APPENDIX F
CHAIN OF CUSTODY FORM
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Soil Sampling COC
RELEASABLE ASBESTOS FIELD SAMPLER (RAFS)
Site:
Date
Sample ID
Sample Type
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
soil
Shipper Initials
Ship Date
Receipt Init
Receipt Date
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AIR SAMPLING AND INSTRUMENT SAMPLE CUSTODY FORM
RELEASABLE ASBESTOS FIELD SAMPLER (RAFS)
Site:
Date
Sample ID
Sample Type
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
AirTEM
Vol. (L)
Priority
Shipper ID
Ship Date
Receipt ID
Receipt
Date
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APPENDIX G
RAFS MANUAL
(Click on the title for a link to this appendix)
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