Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
Revision 0 - August 2012
Contract No. EP-S8-11-02
Task Order No. 00005
Prepared for:
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region 8
Prepared by:
^K!th
CDM Federal Programs Corporation
555 17th Street, Suite 1100
Denver, Colorado 80202
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A% Title and Appeal Page
Sampling and Analysis plan/Quality Assurance Project Plan?
2012 Post-Constmction Activity-Based Sampling
Lib by Asbestos Operable Unit 2
Revision 0 ~ Auga$i2012
Approved
M&tfe&B Smith
ApprotfecLQy;
riy Ctowell
CDMSmpi, Quality MtenAger
Date;.
Bate:.
Approved by:.
Approved by:
jSkppSBgved >y
Retfecca Thomas
EPA, Region ¥111, Remedial fecf^tManager
• Ajfcj&jQ L* $&£££&*
David Berry
EPA*
jtofee Reviewer
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Approved by;
Date: ^(
'4, gegton VW, Iib% Asfetefittss Project Team
»» c/wh7~
fh *ry
USA
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Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
REVISION LOG:
Revision No.
Date
Description
0
8/17/12
—
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A2. Table of Contents
Al. Title and Approval Page 3
A2. Table of Contents 5
A3. Distribution List 11
A4. Proj ect Task Organization 12
A4.1 Project Management 12
A4.2 Technical Support 13
A4.2.1 SAP/QAPP Development 13
A4.2.2 Field Sampling Activities 13
A4.2.3 Asbestos Analysis 13
A4.2.4 Data Management 14
A4.3 Quality Assurance 14
A5. Problem Definition/Background 15
A5.1 Site Background 15
A5.2 Reasons for this Project 16
A5.3 Applicable Criteria and Action Limits 16
A6. Projecf/Task Description 17
A6.1 Task Summary 17
A6.2 Work Schedule 17
A6.3 Locations to be Evaluated 17
A6.4 Resources and Time Constraints 17
A7. Quality Objectives and Criteria 17
A7.1 Data Quality Objectives 17
A7.2 Performance Criteria 18
A7.3 Precision 18
A7.4 Bias/Accuracy and Representativeness 18
A7.5 Completeness 18
A7.6 Comparability 18
A7.7 Method Sensitivity 19
A8. Special Trainin^Certifications 19
A8.1 Field 19
A8.2 Laboratory 20
A8.2.1 Certifications 20
A8.2.2 Laboratory Team Training^Mentoring Program 20
A8.2.3 Analyst Training 22
A9. Documentation and Records 22
A9.1 Field 22
A9.3 Logbooks and Records of ModificatioiVDeviations 23
Bl. Study Design 24
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Bl.l ABS Locations 24
B1.2 Sampling Design 24
B1.3 Study Variables 25
B1.4 Critical Measurements 25
B1.5 Data Reduction and Interpretation 26
B2. Sampling Methods 26
B2.1 Sample Collection 26
B2.1.1 ABS Air 27
B2.1.2 Soil Moisture 27
B2.1.3 Vegetative Cover 28
B2.1.4 Visible Vermiculite 29
B2.1.5 Meteorological Data 29
B2.2 Global Positioning System Coordinate Collection 29
B2.3 Equipment Decontamination 30
B2.4 Handling Investigation-derived Waste 30
B3. Sample Handling and Custody 30
B3.1 Sample Identification and Documentation 30
B3.1.1 Sample Labels 30
B3.1.2 Held Sample Data Sheets 31
B3.1.3 Field Logbooks 32
B3.1.4 Photographs 32
B3.2 Field Sample Custody 33
B3.3 Chain-of-Custody Requirements 33
B3.4 Sample Packaging and Shipping 34
B3.5 Holding Times 34
B3.6 Archival and Final Disposition 34
B4. Analytical Methods 35
B4.1 Analytical Methods and Requirements 35
B4.1.1 Health and Safety Monitoring Samples 35
B4.1.2 ABS Air Samples 35
B4.2 Analytical Data Reports 37
B4.3 Laboratory Data Reporting Tools 37
B4.4 Analytical Turn-around Time 38
B4.5 Custody Procedures 38
B5. Quality Assurance/Quality Control 38
B5.1 Field 38
B5.1.1 Training. 38
B5.1.2 Modification Documentation 39
B5.1.3 Field Surveillances 39
B5.1.4 Field Audits 39
B5.1.5 Field QC Samples 39
B5.2 Analytical Laboratory 40
B5.2.1 Training^Certifications 41
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B5.2.2 Modification Documentation 41
B5.2.3 Laboratory Audits 41
B5.2.4 Laboratory QC Analyses 42
B6/B7. Instrument Maintenance and Calibration 43
B6/B7.1 Field Equipment 43
B(/B7.1.1 General Maintenance 43
B(/B7.1.2 Air Pump Calibration 43
B6/B7.2 Laboratory Instruments 44
B8. Inspection/Acceptance of Supplies and Consumables 44
B8.1 Field 44
B8.2 Laboratory 46
B9. Non-direct Measurements 46
BIO. Data Management 46
B10.1 Field Data Management 46
B10.2 Analytical Laboratory Data Management 47
B10.3 Libby Pro j ect Database 47
B10.4 Data Reporting 48
CI. Assessment and Response Actions 49
Cl.l Assessments 49
C1.2 Response Actions 49
C2. Reports to Management 50
Dl. Data Review, Verification and Validation 51
Dl.l Data Review 51
D1.2 Criteria for LA Measurement Acceptability 51
D2. Verification and Validation Methods 51
D2.1 Data Verification 51
D2.2 Data Validation 52
D3. Reconciliation with User Requirements 54
References 56
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List of Figures
Figure A-l
Figure A-2
Figure A-3
Organization Chart
Operable Units
OU2 Site Layout
List of Tables
Table B-l Number of Samples by Scenario
Table B-2 Interpretation of Field Test for Moisture Content
Table D-l General Evaluation Methods for Assessing Asbestos Data Usability
List of Appendices
Appendix A Detailed Data Quality Objectives
Appendix B Standard Operating Procedures
Appendix C ABS Scripts
Appendix D Analytical Requirements Summary Sheet (POSTOU2-0812)
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List of Acronyms and Abbreviations
% percent
ABS activity-based sampling
Ago grid opening area
APP Accident Prevention Plan
cc cubic centimeter
CDM Smith CDM Federal Programs Corporation
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CHISQ chi-squared
CI confidence interval
cnr2 per square centimeter
COC chain-of-custody record
DQO data quality objective
ED exposure duration
EDD electronic data deliverable
EDS energy dispersive spectroscopy
EDXA energy dispersive x-ray analysis
EF exposure frequency
EFA effective filter area
EPA U.S. Environmental Protection Agency
ERT Environmental Response Team
ET exposure time
f indirect preparation dilution factor
f/cc fibers per cubic centimeter
FBAS fluidized bed asbestos segregator
FSDS field sample data sheet
ft2 square foot
FTL field team leader
g1 per gram
GOx number of grid openings
GPS global positioning system
ID identification
IUR inhalation unit risk
IDW investigation-derived waste
IRIS Integrated Risk Information System
ISO International Organization for Standardization
L liters
L/cc liters per cubic centimeter
L/min liters per minute
LA Libby amphibole
LC laboratory coordinator
MDEQ Montana Department of Environmental Quality
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MDT
Montana Department of Transportation
mm
millimeter
mm2
square millimeters
N
number
NIST
National Institute of Standards and Technology
NVLAP
National Voluntary Laboratory Accreditation Program
OSHA
Occupational Safety and Health Administration
PCM
phase contrast microscopy
PCME
phase contrast microscopy-equivalent
PLM
polarized light microscopy
QA
quality assurance
QAPP
quality assurance project plan
QA/QC
quality assurance/quality control
QATS
Quality Assurance Technical Support
QC
quality control
RBC
risk-based concentration
ROM
Record of Modification
s/cm2
structures per square centimeter
s/g
structures per gram
SAP
sampling and analysis plan
SAED
selective area electron diffraction
Site
Libby Asbestos Superfund Site
SOP
standard operating procedure
STEL
short-term exposure limit
TAS
target analytical sensitivity
TEM
transmission electron microscopy
TWA
time-weighted average
TWF
time-weighting factor
V
air sample volume
VWC
volumetric water content
wt%
mass percent
(im
micrometers
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A Project Management
A3. Distribution List
Copies of this completed and signed sampling and analysis plan/quality assurance project plan
(SAP/QAPP) should be distributed to:
U.S. Environmental Protection Agency, Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
Victor Ketellapper, Ketellaper.Victor@epa.gov (1 hard copy, electronic copy)
Rebecca Thomas, Fagen.EHzabeth@epa.gov (electronic copy)
Don Goodrich, Goodrich.Donald@epa.gov (electronic copy)
Jeff Mosal, Mosal.leffrev@epa.gov (electronic copy)
Dania Zinner, Ziriner.Dariia@epa.gov (electronic copy)
David Berry, Berry.David@epa.gov (electronic copy)
EPA Information Center - Libby
108 East 9th Street
Libby, Montana 59923
Mike Cirian, Cirian.Mike@epa. gov (2 hard copies, electronic copy)
U.S. Army Corps of Engineers
Rapid Response Program Office
Offutt AFB, Nebraska 68113
Mark Herse, Mark.R.Herse@iisace.army.mil (1 electronic copy)
Mary Darling, Mary.N.Darling@usace.amiy.mil (1 electronic copy)
Larry Woscyna, Lawrence. IW oscyna@usace. amiy .mil (1 electronic copy)
Mark Buss, Mark.E.Bttss@msace.amiy.mil (1 electronic copy)
Jeff Hubbard, Ieffrev.W.Hubbard@usace.army.mil (1 electronic copy)
Jeremy Ayala, Jeremy.A.Ayala@usace.army.mil (1 electronic copy)
Montana Department of Environmental Quality
1100 North Last Chance Gulch
Helena, Montana 59601
Carolyn Rutland, CRutland@mt.gov (electronic copy)
TechLaw, Inc.
ESAT, Region 8
16194 West 45th Drive
Golden, Colorado 80403
Doug Kent, Kent.Doug@epa.gov (electronic copy)
CDM Smith - Libby Field Office
60 Port Boulevard, Suite 201
Libby, Montana 59923
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Thomas Cook, cookTE@cdmsmith.com (2 hard copies, electronic copy)
Terry Crowell, crowellTL@cdmsmith.com (electronic copy)
Damon Repine, repineDL@cdmsmith.com (electronic copy)
CDM Smith - Denver Office
555 17th Street, Suite 1100
Denver, Colorado 80202
Nathan Smith, smithNT@cdmsmith.com (electronic copy)
Copies of the SAP/ QAPP will be distributed to the individuals above by CDM Federal
Programs Corporation (CDM Smith), either in hard copy or in electronic format (as indicated
above). The CDM Smith Project Manager (or their designee) will distribute updated copies each
time a SAP/QAPP revision occurs. An electronic copy of the final, signed SAP/QAPP (and any
subsequent revisions) will also be posted to the Libby Field eRoom1.
A4. Project Task Organization
Figure A-l presents an organizational chart that shows lines of authority and reporting
responsibilities for this project. The following sections summarize the entities and individuals
that will be responsible for providing project management, technical support, and quality
assurance for this project.
A4.1 Project Management
The U.S. Environmental Protection Agency (EPA) is the lead regulatory agency for Superfund
activities within the Libby Asbestos Superfund Site (Site). The EPA Region 8 Libby Asbestos
Project Team Leader is Victor Ketellapper. The EPA Regional Project Manager (RPM) for this
sampling effort is Rebecca Thomas. The EPA Region 8 Onsite Field Team Leader for this
sampling effort is Michael Cirian.
The U.S. Army Corps of Engineers (USACE), Omaha District, provides project management,
environmental engineering, and remediation support to EPA at the Site. The USACE Program
Managers are Mark Herse and Mary Darling. The USACE Construction Control Representatives
are Jeremy Ayala, Jeff Hubbard, and Mark Buss.
The Montana Department of Environmental Quality (MDEQ) is the support regulatory agency
for Superfund activities at the Site. The MDEQ Project Manager for this sampling effort is
Carolyn Rutland. The EPA will consult with MDEQ as provided for by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), the National
Contingency Plan, and applicable guidance in conducting Superfund activities.
1 https://team.cdm.com/eRoom/R8-RAC/Libby
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A4.2 Technical Support
A4.2.1 SAP/QAPP Development
This SAP/ QAPP was developed by CDM Smith at the direction of, and with oversight by, the
EPA. This SAP/ QAPP contains all the elements required for both a SAP and a QAPP and has
been developed in general accordance with the EPA Requirements for Quality Assurance Project
Plans, EPA QA/R-5 (EPA 2001) and the Guidance on Systematic Planning Using the Data Quality
Objectives Process, EPA QA/G4 (EPA 2006). This SAP/QAPP was finalized under a contract
agreement with EPA (Contract No. EP-S8-11-02, Task Order No. 00005).
Copies of the SAP/ QAPP will be distributed by the CDM Smith Project Manager (or their
designee), either in hard copy or in electronic format, as indicated in Section A3. The CDM
Smith Project Manager (or their designee) will distribute updated copies each time a
SAP/QAPP revision occurs. An electronic copy of the final, signed SAP/QAPP (and any
subsequent revisions) will also be posted to the Libby Field eRoom.
A4.2.2 Field Sampling Activities
CDM Smith will also be responsible for conducting all field sampling activities in support of the
sampling program described in this SAP/QAPP. Field support will be provided under a
contract agreement with USACE (Contract No. W9128F-11-D-0023). Key CDM Smith personnel
that will be involved in this field sampling program include:
¦ Thomas Cook, Project Manager
¦ Asami Tanimoto, Field Team Leader
¦ Tracy Dodge, Sample Coordinator
¦ Scott Miller, Field Data Manager
¦ Terry Crowell, Quality Assurance Manager
¦ Damon Repine, Health and Safety Manager
A4.2.3 Asbestos Analysis
All samples collected as part of this project will be sent for preparation and analysis for asbestos
at laboratories selected and approved by the EPA to support the Site. The EPA Environmental
Services Assistance Team (ESAT) is responsible for procuring all analytical and preparation
laboratory services and providing direction to the laboratories. Don Goodrich (EPA Region 8) is
responsible for managing the ESAT laboratory support contract for asbestos. The ESAT Region
8 Team Manager at TechLaw, Inc. is Mark McDaniel. He is also the designated laboratory
coordinator (LC) for the Libby project that is responsible for directing the analytical
laboratories, prioritizing analysis needs, and managing laboratory capacity.
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A4.2.4 Data Management
All data generated as part of this sampling effort will be managed and maintained in Scribe.
The EPA Environmental Response Team (ERT) is responsible for the administration of all Scribe
data management aspects of this project. Joseph Schafer is responsible for overseeing the ERT
data management support contract. ERT is responsible for the development and management of
Scribe and the project-specific data reporting requirements for the Libby project.
The CDM Smith field data manager (Scott Miller) is responsible for uploading sample
information to the field Scribe project database. ESAT is responsible for uploading new
analytical results to the analytical Scribe project database. The ESAT project data manager for
the Libby project is Janelle Lohman (TechLaw, Inc.).
Because of the quantity and complexity of the data collected at the Site, the EPA has also
designated a Libby Data Manager to manage and oversee the various data support contractors.
The EPA Region 8 Data Manager for the Libby project is Jeff Mosal.
A4.3 Quality Assurance
There is no individual designated as the EPA Quality Assurance Manager (QAM) for the Libby
project. Rather, the EPA Region 8 QA program has delegated authority to the EPA RPMs. This
means that the EPA RPMs have the ability to review and approve governing investigation
documents developed by Site contractors. Thus, it is the responsibility of the EPA RPM for this
sampling effort (Rebecca Thomas), who is independent of the entities planning and obtaining
the data, to ensure that this SAP/ QAPP has been prepared in accordance with the EPA QA
guidelines and requirements. The EPA RPM is also responsible for managing and overseeing all
aspects of the quality assurance/quality control (QA/QC) program for this sampling effort. In
this regard, the RPM is supported by the EPA Quality Assurance Technical Support (QATS)
contractor, Shaw Environmental, Inc. (Shaw). The QATS contractor will evaluate and monitor
QA/QC sampling and is responsible for performing annual audits of each analytical laboratory.
Terry Crowell (CDM Smith) is the field QAM for this project. Ms. Crowell is responsible for
evaluating and monitoring field QA/ QC, for providing oversight of field sampling and data
collection activities, and for designating a qualified individual to conduct the field surveillance
(see Section B5.1).
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A5. Problem Definition/Background
A5.1 Site Background
Libby is a community in northwestern Montana located 7 miles southwest of a vermiculite mine
that operated from the 1920s until 1990. The mine began limited operations in the 1920s and
was operated on a larger scale by the W.R. Grace Company from approximately 1963 to 1990.
Studies revealed that the vermiculite from the mine contains amphibole-type asbestos, referred
to as Libby amphibole (LA).
Epidemiological studies revealed that workers at the mine had an increased risk of developing
asbestos-related lung disease (McDonald et al. 1986, Amandus and Wheeler 1987, Amandus et
al. 1987, Sullivan 2007). Additionally, radiographic abnormalities were observed in 17.8 percent
of the general population of Libby including former workers, family members of workers, and
individuals with no specific pathway of exposure (Peipins et al. 2003). Although the mine has
ceased operations, historic or continuing releases of LA from mine-related materials could be
serving as a source of on-going exposure and risk to current and future residents and workers
in the area. The Site was listed on the National Priorities List in October 2002.
For long-term management purposes, the Site has been divided into eight operable units (OUs).
This document describes a sampling effort to be conducted in OU2 (see Figure A-2). OU2
includes areas impacted by contamination released from the former W.R. Grace (Grace)
Screening Plant. OU2 includes the former Screening Plant (Subarea 1), the Flyway (Subarea 2),
the Rainy Creek Road frontages (Subarea 3), and a privately-owned property (Subarea 4) (see
Figure A-3). The Kootenai Development Corporation (KDC) Bluffs, located across the Kootenai
River from the former Screening Plant, has been removed from OU2 and is now part of OU4.
Because Subarea 1 (former Screening Plant), Subarea 3 (Rainy Creek Road frontages), and
Subarea 4 are all privately-owned, the focus of this sampling program is on Subarea 2 (the
Flyway). The Flyway is comprised of approximately 19 acres located northeast of Libby,
immediately south of the former Screening Plant. The Flyway is bounded by Highway 37 to the
northeast, a residential subdivision to the south, the Kootenai River to the southwest, and the
former Screening Plant and private property to the north (see Figure A-3). The Flyway is
accessed through a gated entrance to the adjacent private property off Highway 37. The Flyway
area includes the Highway 37 right-of-way (ROW), which is adjacent to the west side of
Highway 37. The ROW is used and maintained by Montana Department of Transportation
(MDT).
When owned by Grace, the Flyway housed a pump that was used during vermiculite mining
operations to convey water from the Kootenai River to the mine site. The pumphouse, located
close to the Kootenai River, has since been abandoned and the pump is no longer functional.
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The interior insulation of this metal structure was removed and all parts of the building were
washed. The empty structure was left on-site for possible future use.
In 1999, when the EPA first visited the property, the Flyway was found to contain several
vermiculite piles. One portion of the property had been covered with imported fill material and
it was suspected that vermiculite-containing material had been moved from the former
Screening Plant and used as fill material to level parts of the Flyway where drainages existed.
Following investigation work performed as a part of the Libby emergency response, a portion
of the Flyway was remediated in 2001 by Grace at the direction of the EPA. Additional remedial
activities were performed by the EPA in 2003 and by Grace at the direction of EPA in 2004. In
2005, the Highway 37 ROW was remediated by EPA. Details of investigation and remediation
activities conducted at the Flyway are provided in the Final OU2 Remedial Investigation Report
(EPA 2009), the OU2 Record of Decision (EPA 2010) and the Final Remedial Action Report, Former
Screening Plan and Surrounding Properties, Operable Unit 2 (CDM Smith 2012).
The Flyway is currently vacant, undeveloped land. At this time, there are no plans to develop
this property.
A5.2 Reasons for this Project
Because the construction of the remedial action at OU2 is complete, the purpose of this
sampling program is to collect data to support a post-construction risk assessment to confirm
the effectiveness of the remedy. In particular, data are needed to evaluate potential exposures to
MDT workers that mow the ROW in the Flyway and individuals that may recreate or trespass
(either intentionally or inadvertently) along the Kootenai River bank in the Flyway. Individuals
may be exposed to LA that is released to air during activities in these areas. These inhalation
exposures may pose a risk of cancer and/ or non-cancer effects.
A5.3 Applicable Criteria and Action Limits
As noted above, remedial actions are already complete at OU2. Thus, there are no LA-specific
criteria or action limits that apply to this sampling program.
Personal air monitoring of sampling personnel will be performed in accordance with
Occupational Safety and Health Administration (OSHA) requirements. In accordance with
these requirements, samples will be analyzed for asbestos by phase contrast microscopy (PCM)
and compared to the OSHA limits for workplace exposures. The short-term (15-minute)
exposure limit (STEL) is 1.0 fiber per cubic centimeter of air (f/cc), and the long-term time-
weighted average (TWA) exposure limit is 0.1 f/cc.
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A6. Project/Task Description
A6.1 Task Summary
Basic tasks that are required to implement this SAP/QAPP include collecting personal air
samples under conditions simulated to mimic the types of activities and exposures that may
occur in OU2. This type of sampling is referred to as "activity-based sampling", or ABS. These
ABS air samples will be analyzed for asbestos and the resulting concentrations will be used to
estimate potential exposures in a post-construction human health risk assessment for OU2.
These basic tasks are described in greater detail in subsequent sections of this SAP/QAPP.
A6.2 Work Schedule
It is anticipated that this ABS program will be completed in late August 2012. Sample analysis
and data evaluation and interpretation of the results will be performed over the late fall and
winter of 2012.
A6.3 Locations to be Evaluated
Location selection for the collection of ABS air is described in Section Bl.l.
A6.4 Resources and Time Constraints
As noted above, sampling is scheduled to occur in late August 2012. The intent is to collect ABS
air samples during the most arid time of the year. This will help ensure that the air samples are
representative of the worst-case exposure conditions for asbestos release from potential source
materials in OU2.
A7. Quality Objectives and Criteria
A7.1 Data Quality Objectives
Data quality objectives (DQOs) are statements that define the type, quality, quantity, purpose,
and use of data to be collected. The design of a study is closely tied to the DQOs, which serve as
the basis for important decisions regarding key design features such as the number and location
of samples to be collected and types of analyses to be performed. The EPA has developed a
seven-step process for establishing DQOs to help ensure that data collected during a field
sampling program will be adequate to support reliable site-specific decision-making (EPA 2001,
2006).
Appendix A provides the detailed implementation of the seven-step DQO process associated
with this SAP/ QAPP.
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A7.2 Performance Criteria
The range of LA concentrations that will occur in ABS air during disturbance activities in OU2
is not known. However, it is possible to estimate the concentration levels that correspond to a
level of human health concern. These calculations are provided in the DQOs (see Appendix A).
The analytical requirements for LA measurements in ABS air as established in Section B4 ensure
concentrations will be reliably detected and quantified if present at levels of concern.
A7.3 Precision
The precision of asbestos measurements is determined mainly by the number (N) of asbestos
structures counted in each sample. The coefficient of variation resulting from random Poisson
counting error is equal to 1/N05. In general, when good precision is needed, it is desirable to
count a minimum of 3-10 structures per sample, with counts of 20-25 structures per sample
being optimal to limit uncertainty due to analytic counting error.
A7.4 Bias/Accuracy and Representativeness
It is expected that LA levels in ABS air may vary widely as a function of location, activities
performed, and meteorological conditions. The ABS locations selected for evaluation in this
study are located in OU2 in areas where actual activities may occur. The ABS air sample
collection will be performed under simulated activities intended to be representative of the
types of activities and exposures that may occur in OU2. The mowing equipment used to
perform the ABS activity (i.e., a walk-behind mower) will be different from the commercial
mowers used by MDT workers, thus there is the potential for results to be biased, but this is not
known with certainty. ABS activities will be performed during the dry, summer months when
the potential for LA release is likely to be highest, thus measured LA concentrations in ABS air
may be biased high.
A7.5 Completeness
Target completeness for this project is 100 percent (%). If any samples are not collected, or if LA
analysis is not completed successfully, this could result in that portion of the study providing
no useful information. In this event, additional sampling may be needed to support EPA
decision-making.
A7.6 Comparability
Although the ABS scripts for this sampling program are unique to this effort, the data generated
during this study will be obtained using sample collection, preparation, and analysis methods
for measuring LA in air used previously at OU2 and other OUs at the Site. The use of consistent
methods will yield data that are comparable to previous ABS studies at the Site.
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A7.7 Method Sensitivity
The method sensitivity (analytical sensitivity) needed for LA analysis of ABS air is discussed in
Section B4.
A8. Special Trainin^Certifications
A8.1 Field
Asbestos is a hazardous substance that can increase the risk of cancer and serious non-cancer
effects in people who are exposed by inhalation. Therefore, all individuals involved in the
collection of samples must have appropriate training. Prior to starting any field work, any new
field team member must complete the following, at a minimum:
Training Requirement
Location of Documentation Specifying
Training Requirement Completion
Read and understand the governing Accident
Prevention Plan (APP)
APP signature sheet
Attend an orientation session with the field
health and safety (H&S) manager
Orientation session attendance sheet
Occupational Safety and Health Administration
(OSHA) 40-Hour Hazardous Waste Operations
and Emergency Response (HAZWOPER) and
relevant 8-hour refreshers
OSHA training certificates
Current 40-hour HAZWOPER medical clearance
Physician letter in the field personnel files
Respiratory protection training,
as required by 29 CFR 1910.134
Training certificate
Asbestos awareness training,
as required by 29 CFR 1910.1001
Training certificate
Sample collection techniques
Orientation session attendance sheet
All training documentation will be stored in the CDM Smith field office. It is the responsibility
of the field H&S manager to ensure that all training documentation is up-to-date and on-file for
each field team member.
Prior to beginning field sampling activities, a field planning meeting will be conducted to
discuss and clarify the following:
¦ Objectives and scope of the fieldwork
¦ Equipment and training needs
¦ Field operating procedures, schedules of events, and individual assignments
¦ Required quality control (QC) measures
¦ Health and safety requirements
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It is the responsibility of each field team member to review and understand all applicable
governing documents associated with this sampling program, including this SAP/QAPP, all
associated standard operating procedures (SOPs) (see Appendix B), and the APP (CDM Smith
2011a).
A8.2 Laboratory
A8.2.1 Certifications
All analytical laboratories participating in the analysis of samples for the Libby project are
subject to national, local, and project-specific certifications and requirements. Each laboratory is
accredited by the National Institute of Standards and Technology (NIST)/National Voluntary
Laboratory Accreditation Program (NVLAP) for the analysis of airborne asbestos by
transmission electron microscopy (TEM). This includes the analysis of NIST /NVLAP standard
reference materials (SRMs), or other verified quantitative standards, and successful
participation in two proficiency rounds per year of airborne asbestos by TEM performed by
NIST/NVLAP.
Copies of recent proficiency examinations from NVLAP or an equivalent program are
maintained by each participating analytical laboratory. Many of the laboratories also maintain
certifications from other state and local agencies. Copies of all proficiency examinations and
certifications are also maintained by the LC.
Each laboratory working on the Libby project is also required to pass an on-site EPA laboratory
audit. The details of this EPA audit are discussed in Section B5.3.3. The LC also reserves the
right to conduct any additional investigations deemed necessary to determine the ability of each
laboratory to perform the work. Each laboratory also maintains appropriate certifications from
the state and possibly other certifying bodies for methods and parameters that may also be of
interest to the Libby project. These certifications require that each laboratory has all applicable
state licenses and employs only qualified personnel. Laboratory personnel working on the
Libby project are reviewed for requisite experience and technical competence to perform
asbestos analyses. Copies of personnel resumes are maintained for each participating laboratory
by the LC in the Libby project file.
A8.2.2 Laboratory Team Training/Mentoring Program
Initial Mentorine
The orientation program to help new laboratories gain the skills needed to perform reliable
analyses at the Site involves successful completion of a training/ mentoring program that was
developed for new laboratories prior to their analysis of Libby field samples. All new
laboratories are required to participate in this program. The training program includes a
rigorous 2-3 day period of on-site training provided by senior personnel from those laboratories
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already under contract on the Libby project, with oversight by the QATS contractor. The tutorial
process includes a review of morphological, optical, chemical, and electron diffraction
characteristics of LA, as well as training on project-specific analytical methodology,
documentation, and administrative procedures used on the Libby site. The mentor will also
review the analysis of at least one sample by each type of analytical method with the trainee
laboratory.
Site-Specific Reference Materials
Because LA is not a common form of asbestos, U.S. Geological Survey (USGS) prepared Site-
specific reference materials using LA collected at the Libby mine site (EPA 2008a). Upon entry
into the Libby program, each laboratory is provided samples of these LA reference materials.
Each laboratory is required to analyze multiple LA structures present in these samples by TEM
in order to become familiar with the physical and chemical appearance of LA and to establish a
reference library of LA energy dispersive spectroscopy (EDS) spectra. These laboratory-specific
and instrument-specific LA reference spectra (EPA 2008b) serve to guide the classification of
asbestos structures observed in Libby field samples during TEM analysis.
Regular Technical Discussions
On-going training and communication is an essential component of QA for the Libby project.
To ensure that all laboratories are aware of any technical or procedural issues that may arise, a
regular teleconference is held between the EPA, their contractors, and each of the participating
laboratories. Other experts (e.g., USGS) are invited to participate when needed. These calls
cover all aspects of the analytical process, including sample flow, information processing,
technical issues, analytical method procedures and development, documentation issues, project-
specific laboratory modifications, and pertinent asbestos publications.
Professional/Technical Meetings
Another important aspect of laboratory team training has been the participation in technical
conferences. The first of these technical conferences was hosted by USGS in Denver, Colorado,
in February 2001, and was followed by another held in December 2002. The Libby laboratory
team has also convened on multiple occasions at the ASTM Johnston Conference in Burlington,
Vermont, including in July 2002, July 2005, July 2008, and July 2011, and at the Michael E. Beard
Asbestos Conference in San Antonio, Texas in January 2010. In addition, members of the Libby
laboratory team attended an EPA workshop to develop a method to determine whether LA is
present in a sample of vermiculite attic insulation held in February 2004 in Alexandria, Virginia.
These conferences enable the Libby laboratory and technical team members to have an on-going
exchange of information regarding all analytical and technical aspects of the project, including
the benefits of learning about developments by others.
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A8.2.3 Analyst Training
All TEM analysts for the Libby project undergo extensive training to understand TEM theory
and the application of standard laboratory procedures and methodologies. The training is
typically performed by a combination of personnel, including the laboratory manager, the
laboratory QAM, and senior TEM analysts.
In addition to the standard TEM training requirements, trainees involved with the Libby project
must familiarize themselves with Site-specific method deviations, project-specific documents,
and visual references. Standard samples that are often used during TEM training include
known pure (traceable) samples of chrysotile, amosite, crocidolite, tremolite, actinolite and
anthophyllite, as well as fibrous non-asbestos minerals such as vermiculite, gypsum, antigorite,
kaolinite, and sepiolite. New TEM analysts on the Libby project are also required to perform an
EDS spectra characterization evaluation (similar to EPA 2008b) on the LA-specific reference
materials provided during the initial training program to aide in LA mineralogy recognition
and definition. Satisfactory completion of each of these tasks must be approved by a senior TEM
analyst.
All TEM analysts are also trained in the Site-specific laboratory QA/QC program requirements
for TEM (see Section B5.3.4). The entire program is discussed to ensure understanding of
requirements and responsibilities. In addition, analysts are trained in the project-specific
reporting requirements and data reporting tools utilized in transmitting results. Upon
completion of training, the TEM analyst is enrolled as an active participant in the Libby
laboratory program.
A training checklist or logbook is used to assure that the analyst has satisfactorily completed
each specific training requirement. It is the responsibility of the laboratory QAM to ensure that
all TEM analysts have completed the required training requirements.
A9. Documentation and Records
A9.1 Field
Field teams will record sample information on the most current version of the Site-specific field
sample data sheets (FSDSs) developed for personal air samples2. Section B3.1.2 provides
detailed information on the documentation requirements for FSDS forms. In brief, the FSDS
forms document the unique sample identifier assigned to every sample collected as part of this
program. In addition, the FSDSs provide information on whether the sample is representative of
a field sample or a field-based QC sample (e.g., field blank, field duplicate).
2 The most recent version of the FSDS forms are provided in the Libby Field eRoom.
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A9.2 Laboratory
All preparation and analytical data for asbestos generated in the laboratory will be documented
on Site-specific laboratory bench sheets and entered into an electronic data deliverable (EDD)
for submittal to the data managers. Section B4.2 provides detailed information on the
requirements for laboratory documentation and records.
A9.3 Logbooks and Records of Modification/Deviations
It is the also responsibility of the field team, preparation laboratory, and analytical laboratory
staff to maintain logbooks and other internal records throughout the sample lifespan as a record
of sample handling procedures. Significant deviations (i.e., those that impact or have the
potential to impact investigation objectives) from this SAP/QAPP, or any procedures
referenced herein governing sample handling, will be discussed with the EPA Project Manager
(or their designee) and the CDM Smith Project Manager prior to implementation. Such
deviations will be recorded on a Record of Modification (ROM) form. Sections B5.1.2 and B5.2.2
provide detailed information on the procedures for preparing and submitting ROMs by field,
preparation laboratory, and analytical laboratory personnel, respectively.
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B Data Generation and Acquisition
Bl. Study Design
Bl.l ABS Locations
Two different ABS scenarios will be evaluated as part of this sampling program. For Scenario 1,
the ROW on the west side of Highway 37, in the northeastern portion of the Flyway (see Figure
A-3), will be evaluated to determine possible exposures to MDT workers that mow the ROW.
The ROW has approximately 1,500 feet of road frontage. For Scenario 2, areas in the Flyway
adjacent to the Kootenai River (see Figure A-3) will be evaluated to determine possible
exposure levels to individuals that recreate or trespass along approximately 2,100 feet of river
frontage.
Prior to the start of field activities, appropriate access agreements will be obtained by EPA, as
necessary.
Should any portion of these ABS areas become inaccessible during or prior to the ABS event,
this should be documented on a field ROM form, as described in Section B5.1. In addition,
global positioning system (GPS) coordinates should be collected to reflect the boundaries of the
actual ABS area (see Section B2.2).
B1.2 Sampling Design
The following provides an overview of the sampling effort that will be conducted. Detailed
information on sampling procedures and methods are presented in Section B2.
For the mowing ABS scenario (Scenario 1), an actor wearing a personal air monitor will mow
the ROW using a walk-behind mower or brush-hogger. [Note: It is recognized that this type of
equipment differs from the commercial mowers used by MDT workers, but because MDT has
already completed mowing activities for the ROW this season and due to safety concerns of
CDM Smith workers using MDT equipment, this alternate mowing scenario will be used.]
Appendix C provides a detailed description of the ABS script for the mowing scenario. During
the ABS event, two replicate ABS air samples will be collected - one with a high volume pump
and one with a low volume pump. However, only one of the two air filters for each ABS
sample, either the high volume or the low volume, will be analyzed by TEM (see Section B4). A
total of three mowing ABS events will be performed, separated in time by at least one week.
Thus, a total of six air filters will be generated, three of which will be analyzed.
For the recreational/ trespasser hiking ABS scenario (Scenario 2), two actors, each wearing a
personal air monitor, will hike along the river frontage on any footpaths that may be found,
stopping at obvious areas of river access when encountered. Appendix C provides a detailed
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description of the ABS script for the hiking scenario. During the ABS event, two replicate ABS
air samples will be collected for each actor - one with a high volume pump and one with a low
volume pump. However, only one of the two air filters for each ABS sample, either the high
volume or the low volume, will be analyzed by TEM (see Section B4). A total of three hiking
ABS events will be performed sequentially, with each ABS event taking place along different
paths/routes, traversing both above and below the high water mark along the river frontage.
Thus, a total of 12 air filters will be generated, six of which will be analyzed.
The requirements for field QC sample collection are discussed in Section B5.1.
Table B-l: Number of Samples by Scenario
Scenario
Number of
samples collected
per ABS event
Number of ABS
events
Total number of
samples collected
Number of
samples analyzed*
1 - mowing in
ROW
2 (1 HV, 1 LV)
3
6
3
2 - hiking along
river
4 (2 HV, 2 LV)
3
12
6
* Either the HV or LV for each ABS sample will be selected for analysis, depending upon filter loading.
HV = high volume filter
LV= low volume filter
B1.3 Study Variables
The level of asbestos in outdoor ABS air under source disturbance activities can depend on
factors that vary seasonally (e.g., soil moisture, wind speed, humidity, etc.). ABS should be
performed under conditions that have a high probability of resulting in measureable ABS air
concentrations of LA, if it is present.
It is preferable to conduct ABS sampling when the conditions for release of LA fibers are
generally favorable, so outdoor ABS will be restricted to summer months (August-September)
when rainfall and soil moisture levels are at their lowest. The exact dates have not yet been set.
ABS sampling will not occur if rainfall in the past 36 hours has exceeded V4 inch, if there is
standing water present, or if the soil moisture is greater than the maximum threshold (see
Section B2.1.2) to ensure conditions are optimal for asbestos release from any source materials.
Additionally, ABS sampling will not occur if there are excessive windy conditions. Although
there are no real-time quantitative measurements of wind for this event, the ABS field team
leader (FTL) will use field judgment in determining if too much wind is present.
B1.4 Critical Measurements
The critical measurement associated with this project is the measurement of the concentration of
LA in ABS air under scenarios that are representative of potential exposure conditions for
humans that may work or trespass in OU2. The analysis of LA may be achieved using several
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different types of microscope, but the EPA generally recommends using TEM because this
technique has the ability to clearly distinguish asbestos from non-asbestos structures, and to
classify different types of asbestos (i.e., LA, chrysotile). In addition, analysis by TEM provides
structure-specific dimensions that allow for the estimation of PCM-equivalent3 (or PCME) air
concentration, which is required for the purposes of assessing exposure and risk.
B1.5 Data Reduction and Interpretation
ABS air samples collected in the field will be used to prepare grids for TEM examination (see
Section B4). From this examination, the total number of PCME LA structures observed will be
recorded and the PCME LA ABS air concentration is calculated as follows:
Cair = (N • EFA) / (GOx • Ago • V • 1000 • f)
where:
Cair = Air concentration (structures per cubic centimeter [s/cc])
N = Number of PCME LA structures observed (structures)
EFA = Effective filter area (mm2)
GOx = Number of grid openings examined
Ago = Area of a grid opening (mm2)
V = Sample air volume (L)
1000 = L/cc (conversion factor in liters per cubic centimeter)
f = Indirect preparation dilution factor (assumed to be 1 for direct preparation)
Data for PCME LA concentrations in ABS air will be used to compute an exposure point
concentration (EPC) as part of a post-construction human health risk assessment for OU2.
The EPC will be calculated as the average measured ABS air concentration (EPA 2008c). The
EPC will be combined with assumptions about exposure frequency and duration and toxicity
factors for LA in the risk assessment that is expected to provide a basis for the EPA to
determine, in consultation with MDEQ, whether response actions have been effective in
protecting human health in OU2. Appendix A (DQO Step 5) provides detailed information on
how risks will be calculated and results interpreted.
B2. Sampling Methods
B2.1 Sample Collection
The following subsections provide investigation-specific requirements for sample collection. A
list of general field equipment that will be used to perform this sampling is provided in each of
3 PCME structures are defined as structures longer than 5 micrometers (|im), with a width greater than or
equal to 0.25 um, and an aspect ratio (length:width) of 3:1 or greater.
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the field sampling SOPs. A medium- and investigation-specific equipment list is provided in
Section B8.1 of this SAP/QAPP.
As part of this investigation, personal air samples will also be collected for ongoing health and
safety monitoring. The health and safety samples will be collected using an additional low
volume sampling pump and are not intended for use as ABS air samples. To differentiate these
samples from the other personal air samples collected as part of this sampling effort, 'PA-EXC'
or TA-TWA' will be selected in the Sample Air Type field of the FSDS to designate the health
and safety personal air excursion and TWA samples, respectively. These samples will be
collected and analyzed in accordance with the Response Action SAP (CDM Smith 2011b) and will
represent both the TWA and STEL sampling periods.
B2.1.1 ABS Air
ABS air samples will be collected, handled, and documented in general accordance with Site-
specific standard operating procedure (SOP) EPA-LIBBY-2012-10, Sampling of Asbestos Fibers in
Air (see Appendix B). In addition, the following investigation-specific requirements apply for
ABS air samples collected under this SAP/QAPP. ABS should not be conducted if soil moisture
conditions do not meet the requirements specified in Section B2.1.2, if rainfall in the past 36
hours has exceeded V4 inch, or if site conditions are windy.
During every event, each actor will wear two different sampling pumps - a high volume pump
and a low volume pump - to allow for the collection of two "replicate" filters (i.e., each filter
represents the same sample collection duration, but different total sample air volumes). The
high volume pump will be an F&J L-15P, or equivalent, and the low volume pump will be an
SKC 224-PCXR4, or equivalent. The appropriate flow rate for each sampling pump will be
optimized to achieve the highest sample air volume possible without causing the filter to
become overloaded. Initially, the high volume pump flow rate will be 5.5 liters per minute
(L/min) and the low volume pump flow rate will be 2.0 L/min. Only one of the two resulting
air samples from each actor will be selected for analysis (see Section B4).
Pump flow rates will be verified at the beginning and end of the ABS scenario. See Section
B6/B7.1 for details regarding pump calibration.
B2.1.2 Soil Moisture
Prior to conducting ABS, soil moisture will be measured from a minimum of 10 locations (0-3
inches below ground surface) within the ABS area using the soil moisture meter. ABS activities
will not be performed if the average VWC is greater than 50%, or if the VWC for any of the
measurement points is greater than 75%. The 10 soil moisture readings for each area will be
recorded in the field logbook and the average VWC will be recorded on the ABS Property
Background and Sampling Form. In addition, soil moisture should also be estimated by the
hand squeeze appearance method and the results will be recorded on the ABS Property
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Background and Sampling Form. This is performed by firmly squeezing a handful of soil and
comparing the results to the table below. ABS activities will not be performed if the soil
moisture deficiency is less than 50%.
Table B-2: Interpretation of Field Test for Moisture Content
% Soil Moisture
Moderately coarse
Medium texture
Fine and very fine
Deficiency
texture
texture
0 (field capacity)
Upon squeezing, no free water appears on soil, but wet outline of ball is left on
hand.
0 to 25
Forms weak ball, breaks
Forms ball, very pliable,
Easily ribbons out
easily when bounced in
slicks readily*
between thumb and
hand*
forefinger*
25 to 50
Will form ball, but falls
Forms ball, slicks under
Forms ball, will ribbon
apart when bounced in
pressure .*
out between thumb and
hand.*
forefinger*
50 to 75
Appears dry, will not
Crumbly, holds together
Somewhat pliable, will
form ball with
from pressure .*
ball under pressure .*
pressure*
75 to 100
Dry, loose, flows
Powdery, crumbles
Hard, difficult to break
through fingers.
easily.
into powder.
* Squeeze a handful of soil firmly to make ball test.
% = percent
B2.1.3 Vegetative Cover
For Scenario 1 (mowing ABS), a qualitative estimate of the extent of vegetative cover and
vegetation condition of the ROW will be determined at the start of each sampling event and will
be recorded on the FSDS. The extent of vegetative cover in the ABS area will be assigned a score
as follows:
Score
Vegetative Cover Extent
1
less than 5 percent cover
2
5 to 25 percent cover
3
25 to 50 percent cover
4
50 to 75 percent cover
5
more than 75 percent cover
Prior to the start of ABS activities, vegetative condition of the ABS area will be qualitatively
ranked as either poor, good, or lush. To the extent that the vegetative condition differs across
the ABS area, this should be documented on the FSDS. Any changes in vegetation condition, as
a consequence of ABS, should also be recorded on the FSDS after the ABS activities have been
completed. To the extent that vegetative conditions differ along the ROW (e.g., vegetative cover
extent scores differ between areas), this should be recorded on the FSDS.
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Photographic documentation will be collected to document the various types of cover and
conditions at the ABS area. Procedures for collecting photographic documentation are discussed
in Section B3.1.4.
Estimates of vegetative cover are not necessary for Scenario 2 (hiking ABS).
B2.1.4 Visible Vermiculite
During ABS efforts, sampling team members should continually inspect the ground surface for
visible vermiculite within the ABS area. All visible vermiculite observations should be
documented in the comments section of the FSDS, as well as within the field logbook. If
vermiculite is observed within an ABS area, the team member should immediately notify the
FTL.
B2.1.5 Meteorological Data
During days when ABS activities are occurring, the FTL or appropriate data manager will
download meteorological data from the local National Oceanic Atmospheric Administration
station, LBBM8. For comparison and additional data, meteorological data will also be
downloaded from two other nearby stations located at the mine (ZONM8) and Troy (TROM8).
The following parameters are recorded hourly at this station:
• Temperature (degrees Fahrenheit [°F])
• Dew point (°F)
• Relative humidity (percent)
• Wind speed (miles per hour [mph])
• Wind gusts (mph)
• Wind direction
• Solar radiation (watts per square meter per hour)
• Precipitation (inches)
B2.2 Global Positioning System Coordinate Collection
For Scenario 1 (mowing ABS), GPS location coordinates do not need to be recorded unless the
spatial extent of the ABS area is altered from the original area selected for evaluation (see Figure
A-3). If the ABS area requires adjustment, GPS coordinates will be recorded in basic accordance
with Site-specific SOP CDM-LIBBY-09, GPS Coordinate Collection and Handling (see Appendix B),
to document where ABS activities were performed.
For Scenario 2 (hiking ABS), GPS location coordinates should be recorded at regular intervals,
such that it is possible to document the specific hiking route associated with each ABS event.
GPS coordinates will be recorded in basic accordance with Site-specific SOP CDM-LIBBY-09.
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GPS coordinates will be collected as Sample Points, requiring the input of sample ID (also
referred to as index ID) and location ID. Since multiple samples may be attributed to one area,
for this sampling program the index ID will be input as 'N/ A'.
Field-collected GPS data are converted to a usable geographic information system (GIS) format
using the general processes described in SOP CDM-LIBBY-09. After the conversion from GPS
points to GIS files, 100% of the data is checked visually to identify any potential data entry
errors.
B2.3 Equipment Decontamination
Equipment used to collect, handle, or measure environmental samples will be decontaminated
in basic accordance with Site-specific SOP EPA-LIBBY-2012-04, Field Equipment Decontamination
at Nonradioactive Sites (see Appendix B). Materials used in the decontamination process will be
disposed of as investigation-derived waste (IDW) as described below. This SOP specifies the
minimum procedural requirements for equipment decontamination. Additional equipment
decontamination procedures are also specified in the medium-specific collection SOPs.
B2.4 Handling Investigation-derived Waste
Any disposable equipment or other IDW will be handled in general conformance with Site-
specific SOP EPA-LIBBY-2012-05, Guide to Handling of Investigation-Derived Waste (see Appendix
B). In brief, IDW will be double bagged in clear 6-mil poly bags with 'IDW' written, in letters at
least 3-inches high, in indelible ink on at least two sides of the outer bag. All IDW generated
during this sampling program will remain in the custody of the sampling team until the team
returns to Libby where the IDW will enter the waste stream at the local class IV asbestos
landfill.
B3. Sample Handling and Custody
B3.1 Sample Identification and Documentation
B3.1.1 Sample Labels
Samples will be labeled with sample identification (ID) numbers supplied by field
administrative staff and will be signed out by the sampling teams. For air samples, the labels
will be affixed to the sample cassette and the inside of the sample bag. Sample ID numbers will
identify the samples collected during this sampling effort using the following format:
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FA-#####
where:
FA = Prefix that designates samples collected under this SAP/QAPP (Flyway ABS)
##### = A sequential five-digit number
B3.1.2 Field Sample Data Sheets
As noted previously in Section A9, field teams will record sample information on the most
current version of the Site-specific FSDS. Use of standardized forms ensures consistent
documentation across samplers. Hard copy FSDSs are location-specific and allow for the entry
of up to three individual samples from the same location on the same FSDS form. If columns are
left incomplete due to fewer than three samples being recorded on a sheet, the blank columns
will be crossed out, dated, and signed by the field team member completing the FSDS.
Erroneous information recorded on a hard copy FSDS will be corrected with a single line
strikeout initial, and date. The correct information will be entered in close proximity to the
erroneous entry.
FSDS information will be completed in the field before field personnel leave the sampling
location. To ensure that all applicable data is accurately entered and all fields are complete, a
different field team member will check each FSDS. The team member completing the hard copy
form and the team member checking the form will initial the FSDS in the proper fields. In
addition, the FTL will also complete periodic checks of FSDSs prior to relinquishment of the
samples to the field sample coordinator. Once FSDSs and samples are relinquished to the field
sample coordination staff, the FSDSs are again checked for accuracy and completeness when
data are input into the local Scribe field database.
If a revision is required to the hard copy FSDS during any of these checks, it will be returned to
the field team member initially responsible for its completion. The error will be explained to the
team member and the FSDS corrected. If the team member is no longer on site, revisions will be
made by sample coordination staff or the FTL. It is the responsibility of the field data manager
to make the appropriate change in the local Scribe field database.
Each hard copy FSDS is assigned a unique sequential number. This number will be referenced
in the field logbook entries related to samples recorded on individual sheets. Field
administrative staff will manage the hard copy FSDSs in their respective field office. Original
FSDSs will be filed by medium and FSDS number. Hard copies of all FSDS forms will also be
sent to the CDM Smith office in Denver, Colorado for archive.
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B3.1.3 Field Logbooks
The field logbook is an accounting of activities at the Site and will duly note problems or
deviations from the governing documents. Field logbooks will be maintained in general
conformance with Site-specific SOP EPA-LIBBY-2012-01, Field Logbook Content and Control (see
Appendix B). In addition to general logbook content requirements outlines in the SOP, the
following items will be recorded for each logbook entry:
¦ Soil moisture deficiency
¦ Pump calibration and flow rate verification
Separate field logbooks will be kept for each investigation and the cover of each field logbook
will clearly indicate the name of the investigation and its sequence number. Field logbooks will
be completed for each investigation activity prior to leaving a sampling location. Field logbooks
will be checked for completeness and adherence to SOP requirements on a daily basis by the
FTL or their designee for the first week of each investigation. When incorrect field logbook
completion procedures are discovered during these checks, the errors will be discussed with the
author of the entry and corrected. Erroneous information recorded in a field logbook will be
corrected with a single line strikeout, initial, and date. The correct information will be entered in
close proximity to the erroneous entry.
The field administrative staff will manage the field logbooks by assigning unique identification
numbers to each field logbook, tracking to whom and the date each field logbook was assigned,
the general investigation activities recorded in each field logbook (e.g., ambient air monitoring),
and the date when the field logbook was returned. As field logbooks are completed, originals
will be catalogued and maintained by the field administrative staff in their respective field
office. Scanned copies of field logbooks will be maintained on the local servers for the CDM
Smith offices in Libby and Denver.
B3.1A Photographs
Photographic documentation will be collected with a digital camera in general conformance to
SOP EPA-LIBBY-2012-02, Photographic Documentation of Field Activities (see Appendix B).
Photographs should be taken to document representative examples of ABS scenarios
performed, sampling locations, site conditions during ABS activities, pre-sampling conditions,
and at any other special conditions or circumstances that arise during the activity.
Electronic captions will be used to describe the photographs instead of maintaining
photographic logs in daily logbook entries.
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Photograph file names will be in the format:
OU2_FA_date
where:
OU2_FA indicates the OU2 Flyway ABS program
The date is formatted as MM-DD-YY
B3.2 Field Sample Custody
All teams will ensure that samples, while in their possession, are maintained in a secure manner
to prevent tampering, damage, or loss. At the conclusion of the sampling program, the team
will relinquish all samples and FSDSs to the sample coordinator or designated secure sample
storage area. The field team will be responsible for documenting this transfer of sample custody
in the logbook.
B3.3 Chain-of-Custody Requirements
The chain-of-custody (COC) is used as physical evidence of sample custody and control. This
record system provides the means to identify, track, and monitor each individual sample from
the point of collection through final data reporting. A complete COC record is required to
accompany each shipment of samples. COC procedures will follow the requirements as stated
in Site-specific SOP EPA-LIBBY-2012-06, Sample Custody (see Appendix B).
At the end of each day, all samples will be relinquished to the field sample coordinator by the
sampling team following COC procedures, and an entry will be made into the field logbook
indicating the time samples were relinquished and the sample coordinator who received the
samples. The field sample coordinator will follow COC procedures to ensure proper sample
custody between acceptance of the sample from the field teams to delivery or shipment to the
laboratory.
A member of the sample coordination staff will manually enter sample information from the
hard copy FSDS into the local Scribe field project database using a series of standardized data
entry forms developed in Microsoft Access by ESAT, referred to as the sample Data Entry Tool,
or the "DE Tool". The DE Tool has a variety of built-in QC functions that improve accuracy of
data entry and help maintain data integrity. After the data entry is checked against the hard
copy FSDSs (by a different sample coordination staff member than completed the original data
entry), the DE Tool is used to prepare an electronic COC. A three-page carbon copy COC will be
generated from the electronic COC. The field sample coordinator will retain one hard copy of
the COC for the project file; the other two hard copies of the COC will accompany the sample
shipment.
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The field sample coordinator will note the analytical priority level for the samples (based on
consultation with the LC) at the top of the COC. A copy of the investigation-specific Analytical
Requirements Summary Sheet (see Appendix D) will also accompany each COC.
If any errors are found on a COC after shipment, the hard copy of the COC retained by the field
sample coordinator will be corrected with a single strikeout, initial, and date. A copy of the
corrected COC will be provided to the LC for distribution to the appropriate laboratory. It is the
responsibility of the field data manager to make any corrections to the local Scribe field project
database. Sample and COC information will be published to Scribe.NET regularly from the
local Scribe field project database by the field data manager (see Section B10.1 for additional
details).
B3.4 Sample Packaging and Shipping
Samples will be packaged and shipped in general accordance with SOP EPA-LIBBY-2012-07,
Packaging and Shipping of Environmental Samples (see Appendix B). In brief, a custody seal will be
placed over at least two sides of the shipping cooler and then secured by tape. Prior to sealing
the shipping container, the sample coordinator will perform a final check of the contents of the
shipment with the COC, sign and date the designated spaces at the bottom of the COC. The
field sample coordinator will then place the custody seals on the shipping container.
The field sample coordinator will be responsible for sending samples to the appropriate
location, as specified by the LC. With the exception of samples that are hand-delivered to the
EMSL Mobile Laboratory in Libby, all samples will be sent to the Troy Sample Preparation
Facility (SPF) for subsequent shipment to the appropriate analytical laboratory, or archive.
Samples will be hand-delivered, picked up by a courier service, or shipped by a delivery service
to the designated location, as applicable. For hand-deliveries and courier pickups, samples will
be packaged for transit such that they are contained and secure (i.e., will not be excessively
jostled). Clean plastic totes with the lids secured or sample coolers may be used for this
purpose. For samples requiring shipment, an established overnight delivery service provider
(e.g., Federal Express) will be used.
B3.5 Holding Times
There are no holding time requirements for air samples collected for asbestos analysis.
B3.6 Archival and Final Disposition
All samples and grids will be maintained in storage at the Troy SPF or analytical laboratory
unless otherwise directed by the EPA. When authorized by the EPA, the laboratory will be
responsible for proper disposal of any remaining samples, sample containers, shipping
containers, and packing materials in accordance with sound environmental practice, based on
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the sample analytical results. The laboratory will maintain proper records of waste disposal
methods, and will have disposal company contracts on file for inspection.
B4. Analytical Methods
B4.1 Analytical Methods and Requirements
This section discusses the analytical methods and requirements for samples collected in support
of the OU2 post-construction sampling program. This section includes detailed information on
the analysis of ABS air, as well as the data reporting requirements, sample holding times, and
custody procedures.
An analytical requirements summary sheet (POSTOU2-0812), which details the specific
preparation and analytical requirements associated with this sampling program, is provided in
Appendix D. The analytical requirements summary sheet will be reviewed and approved by all
participating laboratories in this sampling program prior to any sample handling. A copy of this
analytical requirements summary sheet will be submitted with each chain-of-custody record
(COC).
B4.1.1 Health and Safety Monitoring Samples
The personal air samples collected for the ongoing health and safety monitoring will be
analyzed in accordance with the Response Action SAP (CDM Smith 2011b). In brief, air samples
will be prepared and analyzed by PCM in accordance with NIOSH Method 7400, Issue 2.
B4.1.2 ABS Air Samples
The DQOs for the OU2 post-construction sampling program (see Appendix A) provide detailed
information on the sample preparation, analysis method, counting rules, and stopping rules for
ABS air samples. Each of these analysis requirements is summarized below.
Sample Preparation
Two filters are collected for each ABS actor during each sampling event - a high volume filter
and a low volume filter. The high volume filter will be analyzed in preference to the low
volume filter. If the high volume filter is deemed to be overloaded (i.e., >25% particulate
loading on the filter), the low volume filter should be analyzed in preference to performing an
indirect preparation on the high volume filter. If the low volume filter is also deemed to be
overloaded, an indirect preparation (with ashing) may be performed of the high volume filter in
accordance with the procedures in Libby-specific SOP EPA-LIBBY-08, Indirect Preparation of Air
and Dust Samples for Analysis by TEM (see Appendix B). The filter will be used to prepare a
minimum of three grids using the grid preparation techniques described in Section 9.3 of
International Organization for Standardization (ISO) 10312:1995(E) (ISO 1995).
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Analysis Method
Grids will be examined by TEM in basic accordance with the recording procedures described in
ISO 10312, as modified by the most recent versions of Libby Laboratory Modifications4
LB-000016, LB-000029, LB-000066, LB-000067, and LB-000085.
Counting Rules
All ABS air samples will be examined using counting protocols for recording PCME structures
only (per ISO 10312 Annex E). That is, filters will be examined at a magnification of about
5,000x, and all amphibole structures (including not only LA but all other amphibole asbestos
types as well) that have appropriate selective area electron diffraction (SAED) patterns and
energy dispersive x-ray analysis (EDXA) spectra, and having length > 5 micrometers (Mm),
width > 0.25 (im, and aspect ratio > 3:1 will be recorded on the Libby-specific TEM laboratory
bench sheets and EDDs for the recording of air samples. If observed, chrysotile structures
should be recorded in accordance with ISO 10312 recording procedures, but chrysotile
recording can stop after 25 chrysotile structures have been recorded.
Stopping Rules
Appendix A provides detailed information on the derivation of the stopping rules for ABS air
field samples analyzed by TEM. The stopping rules are as follows:
1. Count a minimum of two grid openings from each of two grids.
2. Continue counting until one of the following is achieved:
a. The target analytical sensitivity (see below) is achieved.
b. 25 PCME LA structures have been observed.
c. A total filter area of 2.0 square millimeters (mm2) has been examined (this is
approximately 200 grid openings).
When one of these criteria has been satisfied, complete the examination of the final grid opening
and stop. The target analytical sensitivity differs between the two types of ABS scenarios. For
the mowing ABS scenario (Scenario 1), the target analytical sensitivity is 0.047 per cubic
centimeter (cc)1. For the hiking ABS scenario (Scenario 2), the target analytical sensitivity is
0.0058 cc1. The COC will identify the applicable ABS scenario for all ABS air samples.
For lot blanks and field blanks, the TEM analyst should examine an area of 1.0 mm2
(approximately 100 grid openings).
4 Copies of all Libby Laboratory Modifications are available in the Libby Lab eRoom.
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B4.2 Analytical Data Reports
An analytical data report will be prepared by the laboratory and submitted to the LC after the
completion of all required analyses within a specific laboratory job (or sample delivery group).
This analytical data report may vary by laboratory and analytical method but generally includes
a case narrative that briefly describes the number of samples, the analyses, and any analytical
difficulties or QA/QC issues associated with the submitted samples. The data report will also
include copies of the signed COC forms, analytical data summaries, a QC package, and raw
data. Raw data is to consist of instrument preparation logs, instrument printouts, and QC
sample results including, instrument maintenance records, COC check in and tracking, raw data
instrument print outs of sample results, analysis run logs, and sample preparation logs. The
laboratory will provide an electronic scanned copy of the analytical data report to the LC and
others, as directed by the LC.
B4.3 Laboratory Data Reporting Tools
Standardized data reporting tools (i.e., EDDs) have been developed specifically for the Libby
project to ensure consistency between different laboratories in the presentation and submittal of
analytical data. In general, unique Libby-specific EDDs have been developed for each analytical
method and each medium. Since the beginning of the Libby project, each EDD has undergone
continued development and refinement to better accommodate current and anticipated future
data needs and requirements. EDD refinement continues based on laboratory and data user
input. Electronic copies of all current EDD templates are provided in the Libby Lab eRoom.
For TEM analyses, detailed raw structure data will be recorded and results will be transmitted
using the Libby-specific EDDs for TEM. Standard project data reporting requirements will be
met for TEM analyses. EDDs will be transmitted electronically (via email) to the following:
¦ Doug Kent, Kent.Doug@epa.gov
¦ Janelle Lohman, Lohman.Ianelle@epa.gov
¦ Tracy Dodge, DodeeTA@cdmsmith.com
¦ Phyllis Haugen, HaugenPT@cdmsmith.com
¦ Libby project email address for CDM Smith, libby@cdmsmith.com
Note: ESAT is in the process of developing a new Site-specific analytical results reporting tool,
referred to as the Libby Asbestos Data Tool (LADT). This tool is a relational Microsoft® Access
database with a series of standard data entry forms specific to each analytical method. The
LADT creates a Microsoft® Excel export file that can be directly uploaded into an analytical
Scribe project database (see Section B10.4). Laboratories have the option of using LADT as a
data reporting method instead of the Libby-specific EDDs.
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B4.4 Analytical Turn-around Time
Analytical turn-around time will be negotiated between the EPA laboratory coordinator (LC)
and the laboratory. It is anticipated that turn-around times of 2-4 weeks are acceptable, but this
may be revised as determined necessary by the EPA.
B4.5 Custody Procedures
Specific laboratory custody procedures are provided in each laboratory's Quality Assurance
Management Plan, which have been independently reviewed at the time of laboratory
procurement. While specific laboratory sample custody procedures may differ between
laboratories, the basic laboratory sample custody process is described briefly below.
Upon receipt at the facility, each sample shipment will be inspected to assess the condition of
the shipment and the individual samples. This inspection will include verifying sample
integrity. The accompanying COC will be cross-referenced with all of the samples in the
shipment. The laboratory sample coordinator will sign the COC and maintain a copy for their
project files.
Depending upon the laboratory-specific tracking procedures, the laboratory sample coordinator
may assign a unique laboratory identification number to each sample on the COC. This number,
if assigned, will identify the sample through all further handling at the laboratory. It is the
responsibility of the laboratory manager to ensure that internal logbooks and records are
maintained throughout sample preparation, analysis, and data reporting.
B5. Quality Assurance/Quality Control
B5.1 Field
Field quality assurance/quality control (QA/QC) activities include all processes and
procedures that have been designed to ensure that field samples are collected and documented
properly, and that any issues/deficiencies associated with field data collection or sample
processing are quickly identified and rectified. The following sections describe each of the
components of the field QA/ QC program implemented at the Site.
B5.1.1 Training
Before performing field work in Libby, field personnel are required to read all governing field
guidance documents relevant to the work being performed and attend a field planning meeting
specific to the OU2 post-construction ABS effort. Additional information on field training
requirements is provided in Section A8.1.
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B5.1.2 Modification Documentation
All field deviations from and modifications to this SAP/QAPP will be recorded on the Libby
field ROM form5. The field ROM forms will be used to document all permanent and temporary
changes to procedures contained in guidance documents governing investigation work that
have the potential to impact data quality or usability. Any minor deviations (i.e., those that will
not impact data quality or usability) will be documented in the field logbooks. ROMs are
completed by the FTL overseeing the investigation/ activity, or by assigned field or technical
staff. As modifications to governing documents are implemented, the FTL will communicate the
changes to the field teams conducting activities associated with the modification.
Each completed field ROM is assigned a unique sequential number (e.g., LFO-000026) by the
CDM Smith field QAM. A ROM tracking log for all field modifications is maintained by the
field QAM. This tracking log briefly describes the ROM being documented, as well as ROM
author, the reviewers, and date of approval. Once a form is prepared, it is submitted to the
appropriate EPA RPM for review and approval. Copies of approved ROMs are maintained on
the CDM Smith server in Libby.
B5.1.3 Field Surveillances
Field surveillances consist of periodic observations made to evaluate continued adherence to
investigation-specific governing documents. One field surveillance will be conducted during
the early stages of this investigation to identify any deficiencies so that any impact on project
data quality is mitigated or limited. Additional field surveillances may be conducted if field
processes are revised or other QA/QC procedures indicate potential deficiencies.
B5.1A Field Audits
Field audits are broader in scope than field surveillances. Audits are evaluations conducted by
qualified technical or QA staff that are independent of the activities audited. Field audits can be
conducted by field contractors, internal EPA staff, or EPA contracted auditors. It is the
responsibility of the field QAM (in consultation with the EPA RPM) to ensure that field auditing
requirements are met for each investigation. It is not anticipated that a field audit will be
performed for this investigation.
B5.1.5 Field QC Samples
Field QC samples are collected to help ensure that field samples are not contaminated from
exogenous sources during sample collection, and to help evaluate the precision of field sample
analytical results. Field QC samples are assigned unique field identifiers and are submitted to
the analytical laboratory along with the associated field samples.
5 The most recent version of the field ROM form is available on the Libby Field eRoom.
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Two types of field QC samples will be collected as part of this ABS program - lot blanks and
field blanks.
Lot Blank
Lot blanks are collected to ensure air samples for asbestos analysis are collected on asbestos-free
filters. A lot blank is a randomly selected filter cassette from a manufactured lot. One lot blank
is required for every 500 cassettes. It is the responsibility of the FTL to submit the appropriate
number of lot blanks prior to cassette use in the field. The lot blanks are analyzed for asbestos
by TEM analysis as described above (see Section 5.1.3). Lot blank results will be reviewed by the
FTL before any cassette in the lot is used for sample collection. The entire batch of cassettes will
be rejected if any asbestos is detected on either lot blank. Only filter lots with acceptable lot
blank results are placed into use for the ABS effort.
Field Blank
Field blanks are collected to evaluate potential contamination introduced during sample
collection, shipping and handling, or analysis. For this sampling effort, field blanks for ABS air
will be collected at a rate of 1 per ABS team per day. It is the responsibility of each field team to
collect the appropriate number of field blanks. Field blanks are collected by removing the end
cap of the sample cassette to expose the filter in the same area where sample collection occurs
for about 30 seconds before re-capping the sample cassette. One field blank per ABS scenario,
chosen at random by the sample coordinator, will be analyzed. The field blanks are analyzed for
asbestos by TEM analysis as described above (see Section 5.1.3).
If any asbestos is observed on a field blank, all other field blanks collected for the ABS scenario
will be submitted for analysis to determine the potential impact on the related sample results.
The FTL and/or laboratory manager will be notified and will take appropriate measures (e.g.,
re-training on sample collection and analysis procedures) to ensure staff are employing proper
sample handling techniques. In addition, a qualifier of "FES" will be added to the related field
sample results in the project database to denote that the associated field blank had asbestos
structures detected.
B5.2 Analytical Laboratory
Laboratory QA/QC activities include all processes and procedures that have been designed to
ensure that data generated by an analytical laboratory are of high quality and that any problems
in sample preparation or analysis that may occur are quickly identified and rectified. The
following sections describe each of the components of the analytical laboratory QA/QC
program implemented at the Site.
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B5.2.1 Training/Certifications
All analytical laboratories participating in the analysis of samples for the Libby project are
subject to national, local, and project-specific certifications and requirements. Additional
information on laboratory training and certification requirements is provided in Section A8.2.
Laboratories handling samples collected as part of this sampling program will be provided a
copy of and will adhere to the requirements of this SAP/QAPP. Samples collected under this
SAP/ QAPP will be analyzed in accordance with standard EPA and/or nationally-recognized
analytical procedures (i.e., Good Laboratory Practices) in order to provide analytical data of
known quality and consistency.
B5.2.2 Modification Documentation
All deviations from project-specific and method guidance documents will be recorded on the
laboratory ROM form6. The ROM will be used to document all permanent and temporary
changes to analytical procedures. ROMs will be completed by the appropriate laboratory or
technical staff. As ROMs are completed, it is the responsibility of the LC to communicate any
changes to the project laboratories. When the project management team determines the need,
this SAP/QAPP will be revised to incorporate necessary modifications.
Copies of approved ROMs for this SAP/ QAPP will be made available in the Libby Lab eRoom.
B5.2.3 Laboratory Audits
Each laboratory working on the Libby project is required to participate in an annual on-site
laboratory audit carried out by the EPA through the QATS contract. These audits are performed
by EPA personnel (and their contractors), that are external to and independent of, the Libby
laboratory team members. These audits ensure that each analytical laboratory meets the basic
capability and quality standards associated with analytical methods for asbestos used at the
Libby site. They also provide information on the availability of sufficient laboratory capacity to
meet potential testing needs associated with the Site.
External Audits
Audits consist of several days of technical and evidentiary review of each laboratory. The
technical portion of the audit involves an evaluation of laboratory practices and procedures
associated with the preparation and analysis of samples for the identification of asbestos. The
evidentiary portion of the audit involves an evaluation of data packages, record keeping, SOPs,
and the laboratory QA Management Plan. A checklist of method-specific requirements for the
6 The most recent version of the laboratory ROM form is available on the Libby Lab eRoom.
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commonly used methods for asbestos analysis is prepared by the auditor prior to the audit, and
used during the on-site laboratory evaluation.
Evaluation of the capability for a laboratory to analyze a sample by a specific method is made
by observing analysts performing actual sample analyses and interviewing each analyst
responsible for the analyses. Observations and responses to questions concerning items on each
method-specific checklist are noted. The determination as to whether the laboratory has the
capability to analyze a sample by a specific method depends on how well the analysts follow
the protocols detailed in the formal method, how well the analysts follow the laboratory-
specific method SOPs, and how the analysts respond to method-specific questions.
Evaluation of the laboratory to be sufficient in the evidentiary aspect of the audit is made by
reviewing laboratory documentation and interviewing laboratory personnel responsible for
maintaining laboratory documentation. This includes personnel responsible for sample check-
in, data review, QA procedures, document control, and record archiving. Certain analysts
responsible for method quality control, instrument calibration, and document control are also
interviewed in this aspect of the audit. Determination as to the capability to be sufficient in this
aspect is made based on staff responses to questions and a review of archived data packages
and QC documents.
It is the responsibility of the QATS contractor to prepare an On-site Audit Report for each
analytical laboratory participating in the Libby program. These reports are handled as business
confidential items. The On-site Audit Report includes both a summary of the audit results and
completed checklist(s), as well as recommendations for corrective actions, as appropriate.
Responses from each laboratory to any deficiencies noted in the On-site Audit Report are also
maintained with the respective reports.
It is the responsibility of the QATS contractor to prepare an On-Site Audit Trend Analysis
Report on an annual basis. This report shall include a compilation and trend analysis of the on-
site audit findings and recommendations. The purpose of this reported is to identify common
asbestos laboratory performance problems and isolate the potential causes.
Internal Audits
Each laboratory will also conduct periodic internal audits of their specific operations. Details on
these internal audits are provided in the laboratory QA Management Plan. The laboratory QAM
should immediately contact the LC and the QATS contractor if any issues are identified during
internal audits that may impact data quality.
B5.2.4 Laboratory QC Analyses
The Libby-specific QC requirements for TEM analyses of asbestos are patterned after the
requirements set forth by NVLAP. In brief, there are three types of laboratory-based QC
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analyses for TEM - laboratory blanks, recounts, and repreparations. Detailed information on the
Libby-specific requirements for each type of TEM QC analysis, including the minimum
frequency rates, selection procedures, acceptance criteria, and corrective actions are provided in
the most recent version of Libby Laboratory Modification LB-000029.
With the exception of inter-laboratory analyses, it is the responsibility of the laboratory manager
to ensure that the proper number of TEM QC analyses is completed. Inter-laboratory analyses
for TEM will be selected post hoc by the QATS contractor or their designee in accordance with
the selection procedures presented in LB-000029. The LC will provide the list of selected inter-
laboratory analyses to the laboratory manager and will facilitate the exchange of samples
between the analytical laboratories.
B6/B7. Instrument Maintenance and Calibration
B6/B7.1 Field Equipment
B6/B7.1.1 General Maintenance
All field equipment (e.g., soil moisture meters, GPS units) should be maintained in basic
accordance with manufacturer specifications. When a piece of equipment is found to be
operating incorrectly, the piece of equipment will be labeled "out of order" and placed in a
separate area from the rest of the sampling equipment. The person who identified the
equipment as "out of order" will notify the FTL overseeing the investigation activities. It is the
responsibility of the FTL to facilitate repair of the out-of-order equipment. This may include
having appropriately trained field team members complete the repair or shipping the
malfunctioning equipment to the manufacturer. Field team members will have access to basic
tools required to make field acceptable repairs. This will ensure timely repair of any "out of
order" equipment.
B 6/B 7.1.2 Air Pump Calibration
Air sampling pumps will be calibrated at the start of each day's sampling period using a
rotameter that has been calibrated to a primary calibration source. The primary calibration
standard used at the Site is a Bios DryCal® DC-Lite. For pre-sampling purposes, calibration will
be considered complete when ±5% of the desired flow rate is attained, as determined by three
measurements with the calibrator using a cassette reserved for calibration (from the same lot as
the sample cassettes to be used in the field). Additional calibration may be performed during
sample collection as described below.
If at any time the observed flow rates are ±10% of the target rate, the sampling pump should be
re-calibrated, if possible. If at any time an air sampling pump is found to have faulted or the
observed flow rates are 25% below (due to heavy particulate loading or a pump malfunction) or
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50% above the target rate, the pump will be replaced or the activity will be terminated.
Collection of air samples will continue, regardless of the amount of particulate loading on the
filters, unless the flow rate is affected. At the beginning of the sampling program, flow rates and
particulate loading may be checked more frequently as conditions require, establishing
expected conditions.
To calculate the percentage of an observed flow to the target flow, the following formula is
used:
_ Observed Flow Rate (L / min)
yC /q —— 100
Target Flow Rate (L / min)
For post-sampling calibration, three separate constant flow calibration readings will be obtained
with the sampling cassette inline and those flow readings will be averaged. If the flow rate
changes by more than 5% during the sampling period, the average of the pre- and post-
sampling rates will be used to calculate the total sample volume.
Samples for which there is more than a 30% difference from initial calibration to end calibration
will be invalidated. The sample collector will record the pump serial number, sample number,
initial flow rate, sample start/end times, sample locations, and final flow rate, as well as mark
the sample "void," in the field logbook and FSDS. These samples will not be submitted for
analysis.
To prevent potential cross-contamination, each rotameter used for field calibration will be
transported to and from each sampling location in a sealed zip-top plastic bag. The cap and
calibration cassette used at the end of the rotameter tubing will be replaced each day after it is
used.
B6/B7.2 Laboratory Instruments
All laboratory instruments used for this project will be maintained and calibrated in accordance
with the manufacturer's instructions. If any deficiencies in instrument function are identified,
all analyses shall be halted until the deficiency is corrected. The laboratory shall maintain a log
that documents all routine maintenance and calibration activities, as well as any significant
repair events, including documentation that the deficiency has been corrected.
B8. Inspection/Acceptance of Supplies and Consumables
B8.1 Field
In advance of field activities, the FTL will check the field equipment/ supply inventory and
procure any additional equipment and supplies that are needed. The FTL will also ensure any
in-house measurement and test equipment used to collect data/samples as part of this
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SAP/ QAPP is in good, working order, and any procured equipment is acceptance tested prior
to use. Any items that the FTL determines unacceptable will be removed from inventory and
repaired or replaced as necessary.
The following list summarizes the general equipment and supplies required for most
investigations:
¦ Field logbook - Used to document field sampling activities and any problems in sample
collection or deviations from the investigation-specific SAP/QAPP. See Section B3.1.3
for standard procedures for field logbooks.
¦ Field sample data sheets (FSDSs) - FSDSs are medium-specific forms that are used to
document sample details (i.e., sampling location, sample number, medium, field QC
type, etc.). See Section B3.1.2 for standard procedures for the completion of FSDSs.
¦ Sample number labels - Sample numbers are sequential numbers with investigation-
specific prefixes. Sample number labels are pre-printed and checked out to the field
teams by the FTL or their designee. To avoid potential transcription errors in the field,
multiple labels of the same sample number are prepared - one label is affixed to the
collected sample, one label is affixed to the hard copy FSDS form. Labels may also be
affixed to the field logbook.
¦ Indelible ink pen, permanent marker - Indelible ink pens are used to complete required
manual data entry of information on the FSDS and in the field logbook (pencil may not
be used). Permanent markers may also be used to write sample numbers on the sample
containers.
¦ PPE - As required by the APP.
¦ Land survey map or aerial photo - Used to identify appropriate sampling locations. In
some cases, sketches may be added to the map/photo to designate sampling and visual
inspection locations and other site features.
¦ Digital camera - Used to document sampling locations and conditions. See Section
B3.1.4 for standard procedures in photographic documentation.
¦ GPS unit, measuring wheel, stakes - Used to identify and mark sampling locations. See
B2.2 for standard procedures in GPS documentation.
¦ Soil moisture meter - Used to measure soil moisture content in the ABS areas.
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¦ Zip-top bags - Zip-top bags are used as sample containers for most types of
environmental samples. Sample number labels will be affixed to the bags or the sample
number will be hand-written in permanent marker on the bags.
¦ Decontamination equipment - Used to remove any residual asbestos contamination on
reusable sampling equipment between the collection of samples. See Section B2.3 for
standard decontamination procedures.
In addition to the generic equipment list, the following equipment will be required for sampling
activities as part of this program:
¦ ABS air sampling equipment: 25-mm diameter mixed cellulose ester filter cassette (0.8
(im pore), high and low flow rate battery-powered air sampling pumps, rotameter,
tygon tubing, rotameter, tygon tubing, belt or backpack to attach pumps to sampler.
B8.2 Laboratory
The laboratory manager is responsible for ensuring that all reagents and disposable equipment
used in this project is free of asbestos contamination. This is demonstrated by the collection of
blank samples, as described in Section B5.
B9. Non-direct Measurements
There are no non-direct measurements that are anticipated for use in this project.
BIO. Data Management
The following subsections describe the field and analytical laboratory data management
procedures and requirements for this investigation. These subsections also describe the project
databases utilized to manage and report data from this investigation. Detailed information
regarding data management procedures and requirements can be found in the EPA Data
Management Plan for the Libby Asbestos Superfund Site (EPA 2012).
B10.1 Field Data Management
Scribe is a software tool developed by ERT to assist in the process of managing environmental
data. A Scribe project is a Microsoft Access database. Data for the Site are captured in various
Scribe projects. Additional information regarding Scribe and the Libby Scribe project databases
is discussed in Section B10.3.
The field data manager utilizes a "local" field Scribe project database (i.e.,
LibbyCDM_Field.mdb) to maintain field sample information. The term "local" denotes that the
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database resides on the server or personal computer of the entity that is responsible for the
creating/ managing the database. It is the responsibility of the field data manager to ensure that
all local field Scribe project databases are backed-up nightly to a local server.
Field sample information from the FSDS is manually entered by a member of the field sample
coordination staff using a series of standardized data entry forms (i.e., DE Tool). This tool is a
Microsoft Access database that was originally developed by ESAT. The DE Tool is currently
maintained by CDM Smith and resides on the local server in the Libby field office. This tool is
used to prepare an electronic COC. Data in the DE Tool are imported into the local field Scribe
project database by the field data manager.
It is the responsibility of the field data manager to "publish" sample and COC information from
the local field Scribe database to Scribe.NET on a daily basis. It is not until a database has been
published via Scribe.NET that it becomes available to external users.
B10.2 Analytical Laboratory Data Management
The analytical laboratories utilize several standardized data reporting tools developed
specifically for the Libby project to ensure consistency between laboratories in the presentation
and submittal of analytical data. In general, a unique Libby-specific EDD has been developed
for each analytical method and each sampling medium. Electronic copies of all current EDD
templates are provided in the Libby Lab eRoom.
Once the analytical laboratory has populated the EDD with results, the spreadsheet(s) are
transmitted via email (see Section B4.3 for the email distribution list). Other email recipients
may also be specified by the ESAT LC.
The ESAT project database manager utilizes a local analytical Scribe project database (i.e.,
LibbyLab2012.mdb) to maintain analytical results information. The EDDs are uploaded directly
into the analytical Scribe project database. It is the responsibility of the ESAT project data
manager to publish analytical results information from the local analytical Scribe database to
Scribe.NET.
B10.3 Libby Project Database
As noted above, Scribe is a software tool developed by ERT to assist in the process of managing
environmental data. A Scribe project is a Microsoft Access database. Multiple Scribe projects can
be stored and shared through Scribe.NET, which is a web-based portal that allows multiple data
users controlled access to Scribe projects. Local Scribe projects are "published" to Scribe.NET by
the entity responsible for managing the local Scribe project. External data users may "subscribe"
to the published Scribe projects via Scribe.NET to access data. Subscription requests are
managed by ERT.
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All data collected for this investigation will be maintained in Scribe. As discussed above, data
will be are captured in various Scribe project databases, including a field Scribe project (i.e.,
LibbyCDM_Field.mdb) and an analytical results Scribe project (i.e., LibbyLab2012.mdb).
B10.4 Data Reporting
Data users can access data for the Libby project through Scribe.NET. To access data, a data user
must first download the Scribe application from the EPA ERT website7. The data user must then
subscribe to each of the published Scribe projects for the Site using login and password
information that are specific to each individual Scribe project. Scribe subscriptions for the Libby
project are managed by ERT. Using the Scribe application, a data user may download a copy of
any published Scribe project database to their local hard drive. It is the responsibility of the data
user to regularly update their local copies of the Libby Scribe projects via Scribe.NET.
The Scribe application provides several standard queries that can be used to summarize and
view results within an individual Scribe project. However, these standard Scribe queries cannot
be used to summarize results across multiple Scribe projects (e.g., it is not possible to query both
the "LibbyCDM_Field" project and the "LibbyLab2012" project using these standard Scribe
queries).
If data users wish to summarize results across multiple published Scribe projects, there are two
potential options. Data users may request the development of a "combined" project from ERT.
This combined project compiles tables from multiple published Scribe projects into a single
Scribe project. This allows data users to utilize the standard Scribe queries to summarize and
view results.
Alternatively, data users may download copies of multiple published Scribe project databases
for the Site and utilize Microsoft Access to create user-defined queries to extract the desired
data across Scribe projects. This requires that the data user is proficient in Microsoft Access and
has an intimate knowledge of proper querying methods for asbestos data for the Site.
It is the responsibility of the data users to perform a review of results generated by any data
queries and standard reports to ensure that they are accurate, complete, and representative. If
issues are identified by the data user, they should be reported via email to the EPA Region 8
Data Manager (Mosal.Ieffrev@epa.gov). It is the responsibility of the EPA Region 8 Data
Manager to notify the appropriate entity (e.g., field, Troy SPF, analytical laboratory) in order to
rectify the issue. A follow-up email will be sent to the party reporting the issue to serve as
confirmation that a resolution has been reached and any necessary changes have been made.
" http:// www.ertsiipport.org/scfibe home .htm
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C Assessment and Oversight
Assessments and oversight reports to management are necessary to ensure that procedures are
followed as required and that deviations from procedures are documented. These reports also
serve to keep management current on field activities.
CI. Assessment and Response Actions
Cl.l Assessments
System assessments are qualitative reviews of different aspects of project work to check the use
of appropriate QC measures and the general function of the QA system. Field and office system
assessments will be performed under the direction of CDM Smith's QA Director, with support
from the CDM Smith QA Manager. As noted previously, it is anticipated that a field
surveillance will be performed during this sampling program. The EPA RPM and QATS
contractor will be notified of any significant deficiencies. Additional field surveillances may be
conducted if field processes are revised or other QA/QC procedures indicate potential
deficiencies.
Laboratory system assessments/ audits will be coordinated by the EPA. Performance
assessments for the laboratories may be accomplished by submitting blind reference material
(i.e., performance evaluation samples). These assessment samples are samples with known
concentrations that are submitted to the laboratories without identifying them as such to the
laboratories. Performance assessments will be coordinated by the EPA.
C1.2 Response Actions
Corrective response actions will be implemented on a case-by-case basis to address quality
problems. Minor actions taken to immediately correct a quality problem will be documented in
the applicable field or laboratory logbooks and a verbal report will be provided to the
appropriate manager (e.g., the FTL or EPA LC). Major corrective actions will be approved by
the EPA RPM and the appropriate manager prior to implementation of the change. Major
response actions are those that may affect the quality or objective of the investigation. EPA
project management will be notified when quality problems arise that cannot be corrected
quickly through routine procedures.
In addition, when modifications to this SAP/ QAPP are required, either for field or laboratory
activities, a ROM must be completed by field staff and approved by the EPA prior to
implementation.
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C2. Reports to Management
No regularly-scheduled written reports to management are planned as part of this project.
However, QA reports will be provided to management for routine audits and whenever quality
problems are encountered. Field staff will note any quality problems on FSDSs or in field
logbooks. Further, the CDM Smith project manager will inform EPA project management upon
encountering quality issues that cannot be immediately corrected. Weekly reports and change
request forms are not required for work performed under this SAP/ QAPP.
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D Data Validation and Usability
Dl. Data Review, Verification and Validation
Dl.l Data Review
Data review of Scribe project data typically occurs at the time of data reporting by the data
users and includes cross-checking that sample IDs and sample dates have been reported
correctly and that calculated analytical sensitivities or reported values are as expected. If
discrepancies are found, the data user will contact the EPA database administrator, who will
then notify the appropriate entity (field, preparation facility, or laboratory) in order to correct
the issue.
D1.2 Criteria for LA Measurement Acceptability
Several factors are considered in determining the acceptability of LA measurements in samples
analyzed by TEM. This includes the following:
1. Evenness of filter loading. This is evaluated using a chi-squared (CHISQ) test, as described
in ISO 10312 Annex F2. If a filter fails the CHISQ test for evenness, the result may not be
representative of the true concentration in the sample, and the result should be given
low confidence.
2. Results of QC samples. This includes and evaluation of results for both field and
laboratory QC samples, such as field and laboratory blank samples, as well as various
types of recount and re-preparation analyses. If significant LA contamination is detected
in field or laboratory blanks, all samples prepared on that day should be considered to
be potentially biased high. If agreement between original analyses and field or
laboratory duplicates (i.e., repreparation or recount analyses) is poor, results for those
samples should be given low confidence.
D2. Verification and Validation Methods
D2.1 Data Verification
Data verification includes checking that results have been transferred correctly from the original
hand-written, hard copy field and analytical laboratory documentation to the project databases.
The goal of data verification is to identify and correct data reporting errors.
For analytical laboratories that utilize the Libby-specific EDD spreadsheets, data checking of
reported analytical results begins with automatic QC checks that have been built into the
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spreadsheets. In addition to these automated checks, a detailed manual data verification effort
will be performed for 10% of all samples and TEM analytical results collected as part of this
sampling effort. This data verification process utilizes Site-specific SOPs (see Appendix B)
developed to ensure TEM results and field sample information in the project databases is
accurate and reliable:
¦ EPA-LIBBY-09 - SOP for TEM Data Review and Data Entry Verification - This Site-
specific SOP describes the steps for the verification of TEM analyses, based on a review
of the laboratory benchsheets, and verification of the transfer of results from the
benchsheets into the project database.
¦ EPA-LIBBY-11 - SOP for FSDS Data Review and Data Entry Verification - This Site-
specific SOP describes the steps for the verification of field sample information, based on
a review of the FSDS form, and verification of the transfer of results from the FSDS
forms into the project database. An FSDS review is performed on all samples selected for
TEM or PLM data verification.
The data verification review ensure that any data reporting issues are identified and rectified to
limit any impact on overall data quality. If issues are identified during the data verification, the
frequency of these checks may be increased as appropriate.
Data verification will be performed by appropriate technical staff that are familiar with project-
specific data reporting, analytical methods, and investigation requirements. The data verifier
will prepare a data verification report (template reports are included in the SOPs) to summarize
any issues identified and necessary corrections. A copy of this report will be provided to the
appropriate project data manager, LC, and the EPA RPM. The data verifier will also transmit
the results of the data verification, including any electronic files summarizing identified
discrepancies, via email to the EPA Region 8 Data Manager (Mosal.Ieffrev@epa.gov) for
resolution. A follow-up email will be sent to the data verifier the issue to serve as confirmation
that a resolution has been reached on any issues identified.
It is the responsibility of the EPA Region 8 Data Manager to coordinate with the FTL and/or LC
to resolve any project database corrections and address any recommended field or laboratory
procedural changes from the data verifier. The EPA Region 8 Data Manager is also responsible
for ensuring that verification status is electronically tracked in the project database, including
who performed the verification and when.
D2.2 Data Validation
Unlike data verification, where the goal is to identify and correct data reporting errors, the goal
of data validation is to evaluate overall data quality and to assign data qualifiers, as
appropriate, to alert data users to any potential data quality issues. Data validation will be
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performed by the QATS contractor (or their designee), with support from technical support staff
that are familiar with project-specific data reporting, analytical methods, and investigation
requirements.
Data validation for asbestos should be performed in basic accordance with the draft National
Functional Guidelines (NFG) for Asbestos Data Review (EPA 2011), and should include an
assessment of the following:
¦ Internal and external field audit/surveillance reports
¦ Field ROMs
¦ Field QC sample results
¦ Internal and external laboratory audit reports
¦ Laboratory contamination monitoring results
¦ Laboratory ROMs
¦ Internal laboratory QC analysis results
¦ Inter-laboratory analysis results
¦ Performance evaluation results
¦ Instrument checks and calibration results
¦ Data verification results (i.e., in the event that the verification effort identifies a larger
data quality issue)
A comprehensive data validation effort should be completed quarterly and results should be
reported as a technical memorandum. This technical memorandum shall detail the validation
procedures performed and provide a narrative on the quality assessment for each type of
asbestos analysis, including the data qualifiers assigned, and the reason(s) for these qualifiers.
The technical memorandum shall detail any deficiencies and required corrective actions.
The QATS contractor will also prepare an annual addendum to the Quality Assurance and
Quality Control Summary Report for the Libby Asbestos Superfund Site (CDM Smith 2011c) to
summarize results of the quarterly data validation efforts. This addendum should include a
summary of any data qualifiers that are to be added to the project database to denote when
results do not meet NFG guidelines and/ or project-specific acceptance criteria. This addendum
should also include recommendations for Site QA/QC program changes to address any data
quality issues.
The data validator will transmit the results for each data validation effort via email to the EPA
Region 8 Data Manager (Mosal.IeffreY@epa.gov). This email should include a summary of the
records that have been validated, the date they were validated, any recommended data
qualifiers, and their associated reason codes. It is the responsibility of the EPA Region 8 Data
Manager to ensure that the appropriate data qualifiers and reason codes recommended by the
data validator are added to the project database, and to electronically track in the project
database which data have been validated, who performed the validation, and when.
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In addition to performing quarterly data validation efforts, it is the responsibility of the QATS
contractor (or their designee) to perform regular evaluations of all field blanks and SPF
preparation blanks, to ensure that any potential contamination issues are quickly identified and
resolved. If any blank contamination is noted, the QATS contractor should immediately contact
the appropriate field QAM or SPF QAM to ensure that corrective actions are made.
D3. Reconciliation with User Requirements
It is the responsibility of data users to perform a data usability assessment to ensure that DQOs
have been met, and reported investigation results are adequate and appropriate for their
intended use. This data usability assessment should utilize results of the data verification and
data validation efforts to provide information on overall data quality specific to each
investigation.
The data usability assessment should evaluate results with regard to several data usability
indicators. Table D-l summarizes several indicators of data usability and presents general
evaluation methods for each indicator. Depending upon the nature of the investigation, other
evaluation methods may also be appropriate. The data usability assessment results and
conclusions should be included in any investigation-specific data summary reports.
Non-attainment of project requirements may result in additional sample collection or field
observations in order to achieve project needs.
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Table D-l: General Evaluation Methods for Assessing Asbestos Data Usability
Data Usability
Indicator
General Evaluation Method
Precision
Sampling - Review results for co-located samples and field duplicates to provide
information on variability arising from medium spatial heterogeneity and sampling
and analysis methods.
Analysis - Review results for TEM recounts and repreparations to provide
information on variability arising from analysis methods. Review results for inter-
laboratory analyses to provide information on variability and potential bias between
laboratories.
Accuracy/Bias
Calculate the background filter loading rate and use results to assign detect/non-
detect in basic accordance with ASTM 6620-00. For air samples, determine the
frequency of indirect preparation.
Representativeness
Review relevant field audit report findings and any field/laboratory ROMs for
potential data quality issues.
Comparability
Compare the sample collection SOPs, preparation techniques, and analysis methods to
previous investigations.
Completeness
Determine the percent of samples that were able to be successfully collected and
analyzed (e.g., 99 of 100 samples, 99%).
Sensitivity
Determine the fraction of all analyses that stopped based on the area examined
stopping rule (i.e., did not achieve the target sensitivity).
ASTM = American Society of Testing and Materials
LA = Libby amphibole
QATS = Quality Assurance Technical Support
ROM = record of modification
SOP = standard operating procedure
TEM = transmission electron microscopy
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References
Amandus, H.E., and Wheeler, R. 1987. The Morbidity and Mortality of Vermiculite Miners and
Millers Exposed to Tremolite-Actinolite: Part II Mortality. American Journal of Industrial Medicine
11:15-26.
Amandus, H.E., Wheeler, P.E., Jankovic, J., and Tucker, J. 1987. The Morbidity and Mortality of
Vermiculite Miners and Millers Exposed to Tremolite-Actinolite: Part I Exposure Estimates.
American Journal of Industrial Medicine 11:1-14.
CDM Smith (formerly CDM). 2011a. Accident Prevention Plan, Remedial Activities. May.
. 2011b. Response Action Sampling and Analysis Plan, Revision 2. June.
. 2011c. Quality Assurance and Quality Control Summary Report for the Libby Asbestos
Superfund Site. Prepared for U.S. Environmental Protection Agency by CDM Smith. Draft -
May.
. 2012. Final Remedial Action Report, Former Screening Plant and Surrounding Properties,
Operable Unit 2, Libby Asbestos Superfund Site. Prepared for U.S. Environmental Protection
Agency by USACE and CDM Smith. April.
EPA (U.S. Environmental Protection Agency). 2001. EPA Requirements for Quality Assurance
Project Plans - EPA QA/R-5. U.S. Environmental Protection Agency, Office of Environmental
Information. EPA/240/B-01/003. March, http://www.epa.gov/quality/qs-docs /r5-final.pdf
. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process - EPA
QA/G4. U.S. Environmental Protection Agency, Office of Environmental Information.
EPA/240/ B-06/001. February. http:/ / www.epa.gov/quality/qs-docs/g4-final.pdf
. 2008a. Performance Evaluation of Laboratory Methods for the Analysis of Asbestos in
Soil at the Libby, Montana Superfund Site. Produced by Syracuse Research Corporation for
EPA, Region 8. Draft - October 7, 2008.
. 2008b. Characteristic EDS Spectra for Libby-Type Amphiboles. Produced by Syracuse
Research Corporation for EPA, Region 8. Final - March 18, 2008.
. 2008c. Framework for Investigating Asbestos-Contaminated Sites. Report prepared by the
Asbestos Committee of the Technical Review Workgroup of the Office of Solid Waste and
Emergency Response, U.S. Environmental Protection Agency. OSWER Directive #9200.0-68.
http://www.epa.gov/superfurtd/health/coiitamirtaiits/asbestos/pdfs/fram.ework asbestos g
uidance.pdf
. 2009. Remedial Investigation Report, Operable Unit 2 - Former Screening Plant and
Surrounding Properties, Libby Asbestos Site, Libby, Montana. Prepared for U.S. Environmental
Protection Agency, Region 8 by CDM Smith and SRC, Inc. Final - August.
ftp://ftp.epa.gov/r8/libby/OUl And OU2/CombinedOU2 RLpdf
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. 2010. Record of Decision for Libby Asbestos Superfund Site, Former Screening Plant and
Surrounding Properties, Operable Unit 2, Lincoln County, Montana. Final - May.
ftp://ftp.epa.gov/r8/libbY/OUl And QU2/LibbvQU2 ROD Mav2010.pdf
. 2011. National Functional Guidelines for Asbestos Data Review. U.S. Environmental
Protection Agency, Office of Superfund Remediation and Technology Innovation. Draft -
August 2011.
. 2012. EPA Data Management Plan for the Libby Asbestos Superfund Site. Draft - 2012.
ISO (International Organization for Standardization). 1995. Ambient Air - Determination of
asbestos fibers - Direct-transfer transmission electron microscopy method. ISO 10312:1995(E).
McDonald, J.C., McDonald, A.D., Armstrong, B., and Sebastien, P. 1986. Cohort Study of
Mortality of Vermiculite Miners Exposed to Tremolite. British Journal of Industrial Medicine
43:436-444.
Peipins, L.A., Lewin, M., Campolucci, S., Lybarger, J.A., Kapil, V., Middleton, D., Miller, A.,
Weis, C., Spence, M., and Black, B., 2003. Radiographic Abnormalities and Exposure to
Asbestos-Contaminated Vermiculite in the Community of Libby, Montana, USA. Environmental
Health Perspectives 111:1753-1759.
Sullivan, P.A. 2007. Vermiculite, Respiratory Disease and Asbestos Exposure in Libby, Montana:
Update of a Cohort Mortality Study. Environmental Health Perspectives 115(4):579-585.
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Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
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FIGURES
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_L
Janelle Lohman
ESAT Scribe Data Manager
TechLaw, Inc.
Talena Oliver
ESAT PLM Laboratory Manager
TechLaw, Inc.
Technical Specialists
Toxicologists, Geologists, Air Modelers
EPA, Region 8
Douglas Kent
ESAT TEM Laboratory Manager
TechLaw, Inc.
Michael Lenkauskas
Quality Assurance Manager
Shaw Environmental, Inc.
Rebecca Thomas
Quality Assurance Managers
EPA, Region 8
Rebecca Thomas, Mike Cirian
Remedial Project Managers
EPA, Region 8
Jeff Mosal
Libby Data Manager
EPA, Region 8
Joseph Schaefer
ERT Data Mgmt Contract Manager
EPA, Region 8
Don Goodrich
ESAT Laboratory Contract Manager
EPA, Region 8
Dania Zinner
QATS Libby Task Manager
EPA, Region 8
Steve Wharton
Remedial Unit Chief
EPA, Region 8
Nikki MacDonald
ESAT QA Manager
TechLaw, Inc.
Terry Crowell
Quality Assurance Manager
CDM Smith
Victor Ketellapper
Project Team Leader
EPA, Region 8
Deborah McKean
Technical Assistance Unit Chief
EPA, Region 8
Dania Zinner
QATS Libby Task Manager
EPA, Region 8
Brad Morgan
Response Manager Administrator
Weston Solutions, Inc.
Mary Darling
Program Manager
USACE
Jeremy Ayala, Jeff Hubbard, Mark Buss
Construction Control Representatives
USACE
Carolyn Rutland
Project Manager
MDEQ
Andrea Wandler
Project Sample Coordinator
TechLaw, Inc.
CDM Smith GSA Contract Manager:
Nathan Smith, Project Manager
CDM Smith USACE Contract Manager:
Thomas Cook, Project Manager
Mark McDaniel
ESAT Region 8 Team Manager/
Laboratory Coordinator
TechLaw, Inc.
Lynn Woodbury, Document Author
CDM Smith SAP/QAPP Staff:
Laboratory Manager
Quality Assurance Manager
Sample Coordinator
Troy Soil Preparation Facility
Management Staff:
Laboratory Manager
Quality Assurance Manager
Sample Coordinator
Senior Analyst(s)
Analytical Laboratory Management Staff:
Asami Tanimoto, Field Team Leader
Tracy Dodge, Field Sample Coordinator
Scott Miller, Field Data Manager
Damon Repine, H&S Manager
CDM Smith Field Staff:
EPA Region 8 Staff
USACE Staff
MDEQ Staff
Figure A-l. General Organizational Chart for the OU2 Post-Construction ABS Study
CDM Smith Staff
TechLaw Staff
TechLaw Subcontractors
Shaw Staff
Lines of authority
Lines of communication
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0U7 - Troy
OU4 - Libby
OU2 - Former
Screening Plant
OU8 - State
Highway Corridors
OU1 - Former
Export Plant
OU5 - Former
Stimson Lumber
OU6-BNSF
Rail Corridor
/
/
W V- {
OU3-Mine and j
Kootenai River
|
7^
OU2
Former Screening Plant
OU4
v Libby
Legend
N
12,500 25,000
50,000
-+-
-t-
-+-
Feet
1 inch = 25,000 feet
H
OU1 - Former Export Plant
OU2 - Former Screening Plant
OU3 - (Study Area) Mine and Kootenai River
OU4 - Libby
OU5 - Former Stimson Lumber
OU6- BNSF Rail Corridor
OU7 - Troy
OU8 - State Highway Corridors
Figure A-2
Operable Units
Libby Asbestos Superfund Site
Lincoln County, Montana
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200
N
400
800
I ^ + 1 1- S t * i
Feet
1 inch = 400 feet
Legend
OU2 Boundary
Subarea 1 - Former Screening Plant
Subarea 2 - Flyway
Subarea 3 - Private Property
Subarea 4 - Rainy Creek Road Frontages
Figure A-3
OU2 Site Layout
Libby Asbestos Superfund Site
Lincoln County Montana
Smith
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Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
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Appendix A
Data Quality Objectives (DQOs)
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APPENDIX A
Data Quality Objectives: OU2 Post-Construction ABS
Data Quality Objectives are statements that define the type, quality, quantity, purpose, and use
of data to be collected. The design of a study is closely tied to the DQOs, which serve as the
basis for important decisions regarding key design features such as the number and location of
samples to be collected and types of analyses to be performed. EPA has developed a seven-step
process for establishing DQOs to help ensure that data collected during a field sampling
program will be adequate to support reliable site-specific risk management decision-making
(EPA 2001, 2006).
The following sections implement the seven-step DQO process associated with this SAP.
A.l Step 1: State the Problem
Construction of the remedial action to address Libby amphibole (LA) contamination in
Operable Unit 2 (OU2) of the Libby Asbestos Superfund Site is complete. However, there is no
measured data to support a post-construction risk assessment to confirm the effectiveness of the
remedy. In particular, data are needed to evaluate potential exposures to Montana Department
of Transportation workers that mow the right-of-way (ROW) in the Fly way (Subarea 2) and
individuals that may recreate or trespass (either intentionally or inadvertently) along the
Kootenai River bank in the Flyway. Individuals may be exposed to LA that is released to air
during activities in these areas. These inhalation exposures may pose a risk of cancer and/ or
non-cancer effects.
A.2 Step 2: Identify the Goal of the Study
The goal of this study is to collect outdoor air data to be used in a post-construction risk
assessment for the OU2 Flyway. These data will be used to estimate exposure and risk from LA
to individuals from exposures in the Flyway under post-construction conditions. Results will be
used by risk managers to decide whether or not additional response actions are needed to
protect individuals from unacceptable risks from LA in the Flyway.
A.3 Step 3: Identify Information Inputs
The following sections describe the types of information needed to meet the study goals.
A.3.1 ABS Air Concentrations of LA
The information needed to characterize human exposures in OU2 consists of reliable
measurements of LA concentrations in air under realistic and representative exposure scenarios
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-l
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that are characteristic of soil-disturbing activities engaged in by individuals in the Flyway. The
collection of air samples under conditions simulated to mimic disturbance activities is referred
to as "activity-based sampling", or ABS. These ABS air samples will be analyzed for asbestos
and the resulting concentrations will be used to estimate potential exposures and risks in a post-
construction human health risk assessment.
Disturbance Activities
People may disturb soil or other LA-containing source materials in the Flyway by a variety of
different activities. It is not feasible to evaluate every possible type of disturbance, so ABS
should be performed using selected scenarios that are considered to be realistic and
representative examples of disturbances that could be performed in the Flyway. Two different
disturbance scenarios are considered to be realistic examples of disturbances that might occur in
the Flyway:
• Scenario 1: Mowing the ROW with a gasoline-powered rotary lawn mower or brush-
hogger
• Scenario 2: Hiking along the frontage of the Kootenai River
Type of Air Sample
Experience at Libby and at other sites has demonstrated that personal air samples (i.e., samples
that collect air in the breathing zone of a person) tend to have higher concentrations of LA than
air samples collected by a stationary monitor (EPA 2007), especially if the person is engaged in
an activity that disturbs an asbestos source such as contaminated soil. Because personal air
samples are more representative of breathing zone exposures, this study should focus on the
collection of personal air samples during ABS. ABS measurements should be obtained by
drawing a known volume of air through a filter that is located in the breathing zone of the
individual performing the disturbance activity and measuring the number of LA structures that
become deposited on the filter surface.
Target Analyte List
ABS air samples should be analyzed for LA using transmission electron microscopy (TEM).
Because asbestos toxicity depends on the particle size and mineral type, results should include
the size attributes (length, width) of each asbestos structure observed, along with the mineral
classification (LA, other amphibole, chrysotile). In addition, because it is possible that there
could be various sources of LA present in soils, information on the sodium and potassium
content of each LA structure observed, as determined by energy dispersive spectroscopy (EDS),
should also be recorded. This requirement is based on the observation of Meeker et al. (2003)
that most particles from the Libby ore body contain detectable levels of both sodium and
potassium, whereas other potential sources of amphibole fibers may not.
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-2
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A.3.2 Other Data
Release of LA from soil into air is expected to depend on several environmental factors that may
tend to vary over time. These factors may include meteorological conditions (temperature,
wind), soil moisture content, and amount and type of ground cover. It may be helpful to
evaluate ABS air concentrations as a function of these environmental factors. Therefore,
measurements of soil moisture in the study areas and estimates of the spatial coverage of
various types of ground cover should be estimated at the time ABS is conducted. In addition,
meteorological weather station data should be downloaded from the National Oceanic
Atmospheric Administration (NOAA) station in Libby for days when ABS activities are
scheduled.
A.4 Step 4: Define the Bounds of the Study
The following sections specify the geographic (spatial) and temporal boundaries of this study.
A.4.1 Spatial Bounds
The Libby Asbestos Superfund Site is located in northwestern Montana. OU2 of the Site
includes areas impacted by contamination released from the former W.R. Grace Screening Plant.
Subarea 2 of OU2 is referred to as the "Flyway". The Flyway is comprised of approximately 19
acres located northeast of Libby, immediately south of the former Screening Plant. The Flyway
is bounded by Highway 37 to the northeast, a residential subdivision to the south, the Kootenai
River to the southwest, and the former Screening Plant and private property to the north.
For ABS Scenario 1 (mowing), the ROW on the west side of Highway 37, in the northeastern
portion of the Flyway, should be evaluated to determine possible exposures to Montana
Department of Transportation workers that mow the ROW. The ROW has approximately 1,500
feet of road frontage.
For Scenario 2 (hiking), areas in the Flyway adjacent to the Kootenai River should be evaluated
to determine possible exposure levels to individuals that recreate or trespass along the
approximately 2,100 feet of river frontage.
A.4.2 Temporal Bounds
In general, it is expected that human exposures to LA in outdoor air are more likely to occur
when snow cover is limited or absent, and that releases will tend to be higher during dry
months in the summer or fall than wet months in the winter or spring. Based on this, ABS
should be performed in the late summer or early fall. In addition, in order to help ensure that
data are not biased low, ABS sampling should not occur if rainfall in the past 36 hours has
exceeded Vi inch, if measured soil moisture conditions indicate the average volumetric water
content (VWC) is greater than 50 percent, or if site conditions are windy.
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-3
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A.5 Step 5: Define the Analytic Approach
ABS data collected as part of this study can be used to estimate exposure and risk from LA that
will support risk management decision-making for the Flyway. The EPA has recently proposed
LA-specific toxicity values for use in estimating cancer risks and non-cancer hazard quotients
(HQs) from exposures to LA in air. The following sections describe how cancer risks and non-
cancer HQs will be calculated.
A.5.1 Estimation of Cancer Risk
The basic equation for estimating cancer risk from LA using EPA's LA-specific IUR value is as
follows:
Risk = EPC * TWFC * IURla
where:
Risk = Lifetime excess risk of developing cancer (lung cancer or mesothelioma) as a
consequence of site-related LA exposure.
EPC = Exposure point concentration of LA in air (PCM or PCM-equivalent [PCME]
s/cc). The EPC is an estimate of the long-term average concentration of LA in inhaled air
for the specific activity being assessed.
TWFC = Time-weighting factor for cancer. The value of the TWF term ranges from zero
to one, and describes the average fraction of a lifetime during which exposure occurs
from the specific activity being assessed.
TWFC = ET/24 * EF/365 * ED/70
where:
ET = Average exposure time (hrs/ day)
EF = Average exposure frequency (days/year)
ED = Exposure duration (years)
IURla= LA-specific lifetime inhalation unit risk (LA PCM s/cc)1
A.5.2 Estimation of Non-Cancer Hazard Quotient
The basic equation for characterizing non-cancer risk from LA using EPA's LA-specific RfC
value is as follows:
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-4
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HQ = EPC * TWF / RfCLA
where:
HQ = Hazard quotient for non-cancer effects from site-related LA exposure
EPC = Exposure point concentration of LA in air (PCM or PCME s/cc)
TWFnc = Time-weighting factor for non-cancer. Note that the interval over which
exposure duration is calculated is from age 0 to age 60. This is because the non-cancer
toxicity factor is based on cumulative lifetime exposure lagged by 10 years.
TWFnc = ET/24 * EF/365 * ED/60
where:
ET = Average exposure time (hrs/ day)
EF = Average exposure frequency (days/year)
ED = Exposure duration (years)
RFCla = LA-specific lifetime reference concentration (LA PCM s/ cc)
A.5.3 Decision Rule
EPA guidance provided in Office of Solid Waste and Emergency Response (OSWER) Directive
#9355.0-30, "Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions" (EPA
1991) indicates that if the cumulative cancer risk to an individual based on reasonable
maximum exposure (RME) is less than 1E-04 and the non-cancer HQ is less than 1, then
remedial action is generally not warranted unless there are adverse environmental impacts. The
guidance also states that a risk manager may decide that a risk level lower than 1E-04 is
unacceptable and that remedial action is warranted where there are uncertainties in the risk
assessment results.
A.6 Step 6: Specify Acceptance Criteria
As noted above, ABS data collected as part of this study will be used to support risk
characterization to support risk management decision-making. In making decisions about
human health risks in OU2, two types of decision errors are possible - false negative and false
positive.
¦ A false negative decision error occurs when a risk manager decides an area is safe when it is
actually not safe.
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-5
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¦ A false positive decision error occurs when a risk manager decides an area is unsafe when it
really is safe.
EPA is most concerned about guarding against the occurrence of false negative decision errors,
since an error of this type may leave humans exposed to unacceptable levels of LA. To minimize
chances of underestimating the true amount of exposure and risk, EPA generally recommends
that risk calculations be based on the 95 percent upper confidence limit (95UCL) of the sample
mean (EPA 1992). Use of the 95UCL in risk calculations limits the probability of a false negative
decision error to no more than 5 percent. To support this approach, EPA has developed a
software application (ProUCL) to assist with the calculation of 95UCL values (EPA 2010a).
However, equations and functions in ProUCL are not designed for asbestos datasets and
application of ProUCL to asbestos datasets is not recommended (EPA 2008). EPA is presently
working to develop a new software application that will be appropriate for use with asbestos
datasets, but the application is not yet available for use. Because the 95UCL cannot presently be
calculated with confidence, risk calculations will be based on the sample mean only, as
recommended by EPA (2008). This means that risk estimates may be either higher or lower than
true values, and this will be identified as a source of uncertainty in the risk assessment.
EPA is also concerned with the probability of making false positive decision errors. Although
this type of decision error does not result in unacceptable human exposure, it may result in
unnecessary expenditure of resources. The risk of false positive decision errors can be
minimized by increasing the number of samples. The number of samples needed depends on
the magnitude of between-sample variability and the proximity of EPC to the decision rule. If
between-sample variability is low, or if the EPC is not near a decision rule, then the number of
samples needed is usually relatively low. However, if between-sample variability is high and
the EPC is relatively near a decision rule, then the number of samples needed is usually higher.
Based on measured data from previous outdoor ABS sampling efforts (EPA 2010b), there is
often substantial variability in measured ABS concentrations of LA in air and measured
concentrations may be near risk management decision thresholds. Therefore, there is a need to
collect multiple samples at each exposure area to limit the level of uncertainty. Because it is not
possible at present to quantify the uncertainty in the mean of an asbestos dataset as a function
of the number of samples, it is not possible to calculate a minimum number of samples required
to minimize the risk of false positive decision errors.
A.7 Step 7: Develop the Plan for Obtaining Data
The following sections present key aspects of the ABS study design that will yield data that will
address the DQOs specified in Steps 1-6 above.
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-6
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3.7.1 Study Design Considerations
Sampling Events
As noted above, because it is not possible at present to quantify the uncertainty in the mean of
an asbestos dataset as a function of the number of samples, it is not possible to calculate a
minimum number of samples required to minimize decision errors. The uncertainty around the
mean depends on sample size and on the underlying variability. There is no information on the
level of variability in measured air concentrations under ABS scenario conditions in OU2.
In the absence of information, to ensure that reliable estimates of long-term average
concentrations may be computed from individual short-term measurements of air
concentrations during soil disturbance activities, this ABS effort will seek to perform three
sampling events for each ABS area for each scenario. If the collected data show there is high
variability across measured ABS air concentrations, additional sampling may be necessary to
provide a reliable basis for calculating the long-term average exposure concentration in the risk
assessment. However, the need for additional data will depend upon the degree of variability
across samples and the proximity of the mean concentration to a decision threshold.
ABS Air Sampling Approach
The two key variables that may be adjusted during collection of air samples are sampling
duration and pump flow rate. The product of these two variables determines the amount of air
drawn through the filter, which in turn is an important factor in the analytical cost and
feasibility of achieving the target analytical sensitivity (see below). In general, longer sampling
times are preferred over shorter sampling times because: a) longer time intervals are more likely
to yield representative measures of the average concentration (as opposed to short-term
fluctuations); and b) longer collection times are associated with higher volumes, which reduces
the number of grid openings that need to be examined to achieve the target analytical
sensitivity. Likewise, higher flow rates are generally preferred over lower flow rates because
high flow results in high volumes drawn through the filter over shorter sampling times.
When feasible, ABS personnel should wear two different sampling pumps - a high volume
(HV) pump and a low volume (LV) pump. This will allow for the collection of two "replicate"
filters (i.e., each filter represents the same sample collection duration, but different total sample
air volumes). The appropriate flow rate for each sampling pump should be optimized to
achieve the highest sample air volume possible without causing the filter to become overloaded.
The high volume filter will be analyzed in preference to the low volume filter. If the high
volume filter is deemed to be overloaded, the low volume filter should be analyzed in
preference to performing an indirect preparation on the high volume filter to avoid potential
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-7
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bias associated with indirect preparation1. If the low volume filter is deemed to be overloaded,
an indirect preparation (with ashing) may be performed.
TEM Stopping Rules for ABS Air Samples
In general, three alternative stopping rules are specified for TEM analyses to ensure resulting
data are adequate:
1. The target analytical sensitivity (TAS) to be achieved
2. A maximum number of structures to be counted
3. A maximum area of filter to be examined
The basis for each of these values for this study is presented below.
Target Analytical Sensitivity
The level of analytical sensitivity needed to ensure that analysis of ABS air samples will be
adequate is derived by finding the concentration of LA in ABS air that might be of potential
concern, and then ensuring that if an ABS sample were encountered that had a true
concentration equal to that level of concern, it would be quantified with reasonable accuracy.
This process is implemented below:
Step 1. Calculation of Risk-Based Concentrations
Cancer. The basic equation for calculating the risk-based concentration (RBC) for cancer is:
RBC(cancer) = Maximum Acceptable Cancer Risk / (TWFC * IURla)
For cancer, the maximum acceptable cancer risk is a risk management decision. For the
purposes of establishing an adequate target sensitivity, a value of 1E-05 is assumed. The
proposed LA-specific IUR is 0.17 (PCM s/cc)-1.
Non-Cancer. The basic equation for calculating the RBC for non-cancer effects is:
RBC(non-cancer) = (Maximum Acceptable HQ * RfCLA) / TWF
For non-cancer, the maximum acceptable HQ is 1. The proposed LA-specific RfC is 0.00002 LA
PCM s/cc.
Exposure Parameters. The exposure parameters needed to calculate TWF are not known with
certainty, so the following RME exposure parameters were selected based on professional
1 Indirect preparation has the potential to increase the number of LA structures recorded during TEM analysis, which
may bias resulting air concentrations high (Berry et al. 2011).
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-8
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judgment:
Scenario
ET
(hrs/day)
EF
(days/yr)
ED (yrs)
1-mowing
1
5 M
15
2-hiking
2
10W
30
M Assumes ROW is mowed once a month during the summer (May through September)
M Assumes hiking occurs twice a month during the summer (May through September)
Based on these parameters the calculated TWFs and RBCs for cancer and non-cancer as follows:
Scenario
TWF
RBC (PCME s/cc)
Cancer
Non-
cancer
Cancer
Non-
cancer
1-mowing
0.00012
0.00014
0.48
0.14
2-hiking
0.0010
0.0011
0.060
0.018
Because the non-cancer RBC is lower than the cancer RBC, the non-cancer RBC is used to derive
the TAS, as follows.
Step 2: Determining the Target Analytical Sensitivity
The TAS is determined by dividing the RBC by the target number of structures to be observed
during the analysis of a sample with a true concentration equal to the RBC:
TAS = RBC / Target Count
The target count is determined by specifying a minimum detection frequency required during
the analysis of samples at the RBC. This probability of detection is given by:
Probability of detection = 1 - Poisson(0/Target Count)
Assuming a minimum detection frequency of 95 percent, the target count is 3 structures. Based
on this, the target analytical sensitivity is 0.047 cc1 for Scenario 1 (mowing) and 0.0058 cc1 for
Scenario 2 (hiking).
Maximum Number of LA Structures
Ideally, all samples would be examined by TEM until the target analytical sensitivity is
achieved. However, for filters that have high asbestos loading, reliable estimates of
concentration may be achieved before achieving the target analytical sensitivity. This is because
the uncertainty around a TEM estimate of asbestos concentration in a sample is a function of the
number of structures observed during the analysis. The 95% confidence interval (CI) around a
count of N structures is computed as follows:
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-9
-------
Lower bound (2.5%) = % • CHIINV(0.975, 2 • Nobserved + 1)
Upper bound (97.5%) = Vi • CHIINV(0.025, 2 • Nobserved + 1)
As Nobserved increases, the absolute width of the CI range increases, but the relative uncertainty
(expressed as the CI range divided by Nobserved) decreases. This concept is illustrated in the
figure below.
Relationship Between Number of Structures Observed and Relative Uncertainty
500%
_Q
O
450%
z
0 400%
cxo
c
A3
C£L
^ 300%
0s-
in
2- 250%
350%
¦| 200%
S 150%
3
g 100%
50%
0%
0
10
20
30
40
50
60
70
80
Number of structures observed (Nobs)
The goal is to specify a target N such that the resulting Poisson variability is not a substantial
factor in the evaluation of method precision. As shown in the figure, above about 25 structures,
there is little change in the relative uncertainty. Therefore, the count-based stopping rule for
TEM should utilize a maximum structure count of 25 LA structures. Note: This stopping rule is
based on the number of PCME LA structures observed (i.e., not total LA structures).
Maximum Area to be Examined
The number of grid openings that must be examined (GOx) to achieve the TAS is calculated as:
GOx = EFA / (TAS • Ago • V • 1000 • f)
where:
EFA = Effective filter area (assumed to be 385 square millimeters [mm2])
TAS = Target analytical sensitivity (cc)1
Ago = Grid opening area (assumed to be 0.01 mm2)
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-10
-------
V = Sample air volume (liters [L])
1000 = L/cc (conversion factor in liters per cubic centimeter)
f = Indirect preparation dilution factor (assumed to be 1 for direct preparation)
Because TAS varies for each scenario, the number of grid openings needed to achieve the target
analytical sensitivity will vary depending upon the type of ABS sample collected. The following
table presents the GOx for each ABS scenario to achieve the TAS based on an estimate of the
sample air volume and assuming that the filter is able to be prepared directly (i.e., f = 1). If an
indirect preparation is necessary, the GOx is inversely proportional to the dilution needed (i.e.,
an f of 0.1 will increase the number of grid openings by a factor of 10).
Scenario
Estimated
Sample
Duration
(minutes)
Pump
type
Flow
Rate
(L/min)
Sample Air
Volume
(L)
GOx
1-mowing
30
HV
5.5
165
5
LV
2
60
14
2-hiking
30
HV
5.5
165
40
LV
2
60
110
In the event that analysis of the low volume sample is needed (due to particulate overloading
on the high volume filter) or if an indirect preparation of the low volume sample is necessary, it
is possible that the GOx to achieve the TAS may be cost or time prohibitive. In order to limit the
maximum effort expended on any one sample, a maximum area examined of 2.0 mm2 is
identified for this project. Assuming that each grid opening has an area of about 0.01 mm2, this
would correspond to about 200 grid openings.
Summary ofTEM Stopping Rules
The TEM stopping rules for this study should be as follows:
1. Count a minimum of two grid openings from each of two grids.
2. Continue counting until one of the following is achieved:
a. The TAS is achieved.
b. 25 LA structures have been observed.
c. A total filter area of 2.0 mm2 has been examined (this is approximately
200 grid openings).
When one of these criteria has been satisfied, complete the examination of the final grid opening
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-ll
-------
and stop.
A.7.2 Refining the Study Design
In accordance with the EPA DQO process, it is expected that the ABS program described in this
document may be modified as deemed necessary to ensure that the data are representative. For
example, the sampling durations and pump flow rates may be modified if a high frequency of
filter overloading is reported. Any changes from the SAP/QAPP should be documented and
approved by EPA prior to implementation.
REFERENCES
EPA (U.S. Environmental Protection Agency). 1991. Role of the Baseline Risk Assessment in
Superfund Remedy Selection Decisions. Washington, DC. OSWER Directive 9355.0-30.
http:// www.epa.gov/oswer/riskassessment/pdf/baseline.pdf
. 1992. Supplemental Guidance to RAGS: Calculating the Concentration Term. United
States Environmental Protection Agency, Office of Solid Waste and Emergency Response.
Publication 9285.7-081.
. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process - EPA
QA/G4. U.S. Environmental Protection Agency, Office of Environmental Information.
EPA/240/B-06/001. February 2006. http:/ / www.epa.gov/quality/qs-docs/g4-fmai £df
. 2007. Summary Report for Data Collected under the Supplemental Remedial
Investigation Quality Assurance Project Plan Libby, Montana Superfund Site. Prepared for U.S.
Environmental Protection Agency, Region 8. Final - October.
. 2008. Framework for Investigating Asbestos-Contaminated Sites. Report prepared by the
Asbestos Committee of the Technical Review Workgroup of the Office of Solid Waste and
Emergency Response, U.S. Environmental protection Agency. OSWER Directive #9200.0-68.
epa.gov/superfund/health/contaminants/asbesto; mework asbestos guidan
ce.pdf
. 2010a. ProUCL Version 4.00.05 Technical Guide (Draft). U.S. Environmental Protection
Agency, Office of Research and Development. EPA/600/R-07/041. May 2010.
http://www.epa.gov/esd/tsc/ProUCL v4.00.05/ProUCL v4.00.05 tech guide(draft).pdf
. 2010b. Activity-Based Sampling Summary Report, Operable Unit 4, Libby, Montana,
Superfund Site. U.S. Environmental Protection Agency, Region 8. June 2.
Meeker GP, Bern AM, Brownfield IK, Lowers HA, Sutley SJ, Hoeffen TM, Vance JS. 2003. The
Composition and Morphology of Amphiboles from the Rainy Creek Complex, Near Libby,
Montana. American Mineralogist 88:1955-1969.
Appendix A: Data Quality Objectives
OU2 Post-Construction ABS
Page A-12
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Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
Revision 0 - August 2012
Appendix B
Standard Operating Procedures (SOPs)
SOP ID
SOP Description
1 iVIil l'rococl lire's
E P A-LIBB Y-2012-01
Field Logbook Content and Control
EPA-LIBBY-2012-02
Photographic Documentation of Field Activities
EP A-LIBB Y-2012-04
Field Equipment Decontamination
EP A-LIBB Y-2012-05
Handling Investigation-Derived Waste
EPA-LIBBY-2012-06
Sample Custody
EPA-LIBBY-2012-07
Packaging and Shipping of Environmental Samples
EP A-LIBB Y-2012-10
Sampling of Asbestos Fibers in Air
CDM-LIBBY-09
GPS Coordinate Collection and Handling
1 «i bor.ilorv I'm*, oil n res
n\\-i.ir.r.V()N
Indirei I Piv|\ii\ilinn nf Air and 1 Hisl S,im|-i|es I'nr Aiidlvsis In 1 I'M
\ I'lifii tilion l'rocoduros
EPA-LIBBY-09
TEM Data Review and Data Entry Verification
EPA-LIBBY-11
FSDS Data Review and Data Entry Verification
The most recent versions of all field SOPs are provided electronically in the Libby Field eRoom
(https://team, cdm.com/eRoom/R8-RAC/Libby).
The most recent version of all laboratory and data verification SOPs are provided electronically in the Libby Lab eRoom
(https://team.cdm.com/eRoom/mt/LibbyLab).
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Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
Revision 0 - August 2012
Appendix C
ABS Scripts
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APPENDIX C
OU2 Post-Construction ABS Scripts
Two types of activity-based sampling (ABS) efforts will be conducted at Operable Unit 2 (OU2)
in the Flyway:
¦ Scenario 1: Mowing the Highway 37 right-of-way (ROW)
¦ Scenario 2: Hiking along the Kootenai River frontage
The following sections describe the specific activities that will be performed by the actors
completing these ABS scenarios.
Scenario 1: Mowing the Highway 37 Right-of-Way
During the mowing activity, one actor will operate a gas-powered walk-behind lawn mower
(bag-less, side discharge, 3- to 5-horsepower mower) or brush-hogger. The actor will adjust the
height of the blade to be approximately 2 to 2.5 inches above the ground surface. The actor will
mow in a straight line, covering the entire length of the ROW. Two passes (side-by-side) of the
ROW should be performed, such that the mowed area extends approximately five feet in from
the roadway. There is no specified sampling duration requirement for this ABS scenario.
Rather, the actor should continue mowing until the entire area has been mowed (regardless of
how long this activity takes). Once the entire area has been mowed, the sampling pumps may
be turned off and the air cassettes can be removed. Sampling pump flows should be checked at
the beginning and end of the ABS scenario.
A total of three mowing events will be performed, separated in time by at least one week.
Scenario 2: Hiking Along the Kootenai River Frontage Paths
During the hiking activity, two actors will walk along the river frontage, one behind the other,
along any footpaths that may be found, stopping at obvious areas of river access. Every five
minutes, the two actors should switch positions (i.e., leader/follower). The hiking activity
should be performed for a total 30 minutes. At the end of 30 minutes, the sampling pumps may
be turned off and the air cassettes can be removed. Sampling pump flows should be checked at
the beginning and end of the ABS scenario.
A total of three hiking events will be performed sequentially within the same day, with each
event taking place along different paths/routes within the ABS area.
Appendix C: ABS Scripts
OU2 Post-Construction ABS
Page C-l
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Sampling and Analysis Plan/Quality Assurance Project Plan:
2012 Post-Construction Activity-Based Sampling
Libby Asbestos Site, Operable Unit 2
Revision 0 - August 2012
Appendix D
Analytical Requirements Summary Sheet
[POSTOU2-0812]
The most recent version of the Analytical Requirements Summary Sheet is provided electronically in the Libby Lab eRoom
(https://team.cdm.com/eRoom/mt/LibbyLab).
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Requirements Summary: #POSTOU2-O812
Requirements Revision #: 0
Effective Date: August 17, 2012
SAP/QAPP REQUIREMENTS SUMMARY #POSTOU2-O812
SUMMARY OF PREPARATION AND ANALYTICAL REQUIREMENTS FOR ASBESTOS
Title: Sampling and Analysis Plan/Quality Assurance Project Plan. 2012 Post-Construction Activity-Based Sampling. Operable Unit 2
SAP Date (Revision): August 2012 (Revision 0)
EPA Technical Advisor: Rebecca Thomas (303-312-6552. Thomas.Rebecca@epa.gov')
(contact to advise on DQOs of SAP related to preparation/analytical requirements)
Sampling Program Overview: This program will conduct activity-based sampling in the Flvwav of OU2. As part of this program. ABS air samples will be
collected and analyzed for asbestos by TEM for two different ABS scenarios (mowing, hiking). Personal air samples will also be collected for H&S monitoring
and analyzed by PCM.
Sample ID Prefix: FA-
Estimated number and timing of field samnles:
All samples will be collected in August-September 2012 timeframe (exact dates have not yet been determined).
» ABS Air, mowing = 3 samples + field QC samples
» ABS Air, hiking = 6 samples + field QC samples
TEM/PCM Preparation
and Analytical Requirements for Air Field Samples:
Medium
Code
Medium,
Sample Type
Preparation Details
Analysis Details
Applicable Laboratory
Modifications
(current version of)
Investi-
gative?
Indirect Prep? (b)
Filter
Archive?
Method
Recording
Rules (c)
Analytical Sensitivity/Prioritized
Stopping Rules (d)
With
Ashing
Without
Ashing
A
Air, ABS
Mowing
Yes
Yes, if
material is
overloaded
(>25%) or
unevenly
loaded on
filter
No
Yes
TEM-
Modified
ISO
10312,
Annex E
(Low
Mag,
5,000X)
All PCME
asbestos;
L: > 5 nm
W: >0.25 nm
AR: >3:1
Count a minimum of 2 grid
openings in 2 grids, then
continue counting until one is
achieved:
i) the target sensitivity is
achieved
ii) 25 PCME LA structures are
recorded
iii) 2.0 mm2 of filter has been
examined
LB-000016, LB-000029,
LB-000066, LB-000067,
LB-000085
B
Air, ABS
Hiking
Page 1 of 3
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Requirements Summary: #POSTOU2-O812
Requirements Revision #: 0
Effective Date: August 17, 2012
Medium
Code
Medium,
Sample Type
Preparation Details
Analysis Details
Applicable Laboratory
Modifications
(current version of)
Investi-
gative?
Indirect Prep? (b)
Filter
Archive?
Method
Recording
Rules (c)
Analytical Sensitivity/Prioritized
Stopping Rules (d)
With
Ashing
Without
Ashing
C
Air, Health &
No
No
Yes, if
Yes
PCM -
For PCM:
For PCM: Count a minimum of
For PCM: LB-000015
Safety
material is
NIOSH
NIOSH 7400,
20 FOVs, then continue counting
overloaded
7400,
"A" rules
until one is achieved:
For AHERA:
(>25%) or
Issue 2
i) 100 fibers are recorded
LB-000029, LB-000031,
unevenly
If AHERAis
ii) 100 FOVs are examined
LB-000067, LB-000085
loaded on
TEM-
reauested:
(regardless of count)
filter
AHERA
All asbestos;
(upon
L >0.5 (im
For AHERA: Examine 0.1 mm2
request)
AR >5:1
of filter
(a) The high volume filter will be analyzed in preference to the low volume filter if direct preparation is possible. If the high volume filter is overloaded, use the low volume filter.
If the low volume filter is overloaded, prepare indirectly (with ashing), calculate number of grid openings to analyze to reach target analytical sensitivity, and contact EPA project
managers or their designate before proceeding with analysis.
(b) See most current version of SOP EPA-LIBBY-08 for preparation details.
(c) If observed, chrysotile and other amphibole asbestos should be recorded. Recording of chrysotile can stop after 25 chrysotile structures have been recorded (finish GO where
25th chrysotile found).
(d) Target analytical sensitivity for mowing scenario is 0.047 cc-1 and for hiking scenario is 0.0058 cc-1.
TEM/PCM Preparation and Analytical Requirements for Air Field Quality Control Samples:
Medium,
Sample
Type
Preparation Details
Analysis Details
Applicable Laboratory
Modifications
(current version of)
Medium
Indirect Prep?
Recording
Rules
Code
With
Ashing
Without
Ashing
Archive?
Method
Stopping Rules
D
Air,
lot blank
and field
blank
No
No
Yes
TEM - Modified
ISO 10312,
Annex E
(Low Mag,
5,000X)
All PCME
asbestos;
L: > 5 jim
W: >0.25 nm
AR: >3:1
Examine 1.0 mm2 of filter.
LB-000016, LB-000029,
LB-000066, LB-000067,
LB-000085
E
Air, Health
& Safety
field blank
No
No
Yes
PCM - NIOSH
7400, Issue 2
TEM-AHERA
(upon request)
For PCM:
NIOSH 7400,
"A" rules
If AHERAis
reauested:
All asbestos;
L >0.5 (im
AR >5:1
For PCM: Count a minimum of 20
FOVs, then continue counting until
one is achieved:
i) 100 fibers are recorded
ii) 100 FOVs are examined
(regardless of count)
For AHERA: Examine 0.1 mm2 of
filter
For PCM: LB-000015
For AHERA:
LB-000029, LB-000031,
LB-000067, LB-000085
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Requirements Summary: #POSTOU2-O812
Requirements Revision #: 0
Effective Date: August 17, 2012
Analytical Laboratory Quality Control Sample Frequencies:
TEM (k): Lab Blank - 4% PCM (11: Blind Recounts - 10%
Recount Same - 1%
Recount Different - 2.5%
Verified Analysis - 1%
Interlab - 0.5%
Repreparation - 1%
(k) See LB-000029 for selection procedure and QC acceptance criteria
(1) See NIOSH 7400 for QC acceptance criteria
Requirements Revision:
Revision #:
Effective Date:
Revision Description
0
8/17/2012
N/A
Analytical Laboratory Review Sian-off:
L ! " ':' - Libby [sign & dale: | iX] dale: Douglas_Kcnl_10_July_2012_
L "" ¦ - Cinnaininson [sign & dale: | ,, , dale: ]
L "" ¦ - Bcltsville [sign & dale: | • , L Jale: |
L "¦-Denver [sign & dale: I
/( initialing above Indicates that the laboratory has reviewed and acknowledged the preparation and analytical requirements associated
w I
Page 3 of 3
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