Libby, Montana
FINAL Remedial
Investigation Report
Operable Unit 8
Libby Asbestos National
Priorities List Site
OA United States
Nri Environmental Protection Agency
To protect human health and to safeguard the natural environment
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FINAL
Remedial Investigation Report
Operable Unit 8
Local and State Highways in Libby and Troy
Libby Asbestos National Priorities List Site
Libby, Montana
June 2013
Prepared for
US Environmental Protection Agency
by
HDR Engineering, Inc.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
1.0 INTRODUCTION 1-1
1.1 OVERVIEW AND REPORT ORGANIZATION 1-1
1.2 NPL SITE LOCATION & TOPOGRAPHY 1-2
1.3 NPL SITE HISTORY 1-3
1.4 REGULATORY HISTORY 1-4
1.5 PREVIOUS INVESTIGATIONS & REPORTS 1-4
2.0 SITE CHARACTERISTICS 2-1
2.1 CLIMATE 2-1
2.2 GEOLOGY 2-1
2.3 HYDROLOGY AND HYDROGEOLOGY 2-2
3.0 SAMPLING AND ANALYSIS 3-1
3.1 SAMPLE TYPES AND COLLECTION PROCEDURES 3-1
3.1.1 Soil Samples 3-2
3.1.2 Air Samples 3-3
3.1.3 Quality Control Samples 3-1
3.2 SAMPLE PREPARATION AND ANALYSIS 3-2
3.2.1 Soil 3-2
3.2.2 Air 3-4
4.0 DATA RECORDING, DATA QUALITY ASSESSMENT, AND DATA
SELECTION 4-1
4.1 DATA RECORDING 4-1
4.2 DATA QUALITY ASSESSMENT 4-2
4.3 DATA SELECTION 4-3
5.0 NATURE AND EXTENT OF LA 5-1
5.1 CONTAMINANTS OF CONCERN 5-1
5.2 LA IN SOIL 5-2
5.3 LA IN AIR 5-3
6.0 CONTAMINANT FATE AND TRANSPORT 6-1
7.0 HUMAN HEALTH RISK ASSESSMENT 7-1
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8.0
9.0
CONCLUSIONS
REFERENCES...
8-1
9-1
LIST OF TABLES
3-1 Sampling Events Relevant to OU8
LIST OF FIGURES
1-1 OU Boundaries
1-2 Limits of OU8
3-1 OU8 Sampling Locations
3-2 Inner and Outer Perimeter Air Sampling Locations
5-1 LA in Surface Soil - PLM Results
5-2 Visible Vermiculite in Surface Soils
5-3 ABS Air Results for ATV Riding, Brush Hogging and Grass Cutting
5-4 ABS Air Results for Rotomilling
5-5 Inner Perimeter (ABS) Rotomilling Air Results
5-8 Outer Perimeter (Ambient Air) Results
APPENDICES
Appendix A - Data Quality Assessment
Appendix B - EPA Scribe Database
Appendix C - Asbestos Analysis Methods and Data Reduction Techniques
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LIST OF ACRONYMS
ABS
Activity-Based Sampling
AM
Amosite
AT SDR
Agency for Toxic Substances and Disease Registry
ATV
All Terrain Vehicle
bgs
below ground surface
CSF
Close Support Facility
COC
Chain of Custody
DQA
Data Quality Assessment
DQOs
Data Quality Objectives
EDD's
Electronic Data Deliverables
EPA
U.S. Environmental Protection Agency
ERT
Emergency Response Team
ESAT
Environmental Services Assistance Team
FSDS
Field sample data sheet
Ft
Feet
Ft/day
Feet per day
ISO
International Organization for Standardization
LA
Libby Amphibole
MCE
Mixed Cellulose Ester
MDOT
Montana Department of Transportation
ND
Non-Detect
NPL
National Priority List
OUs
Operable Units
PCM
Phase Contrast Microscopy
PCME
Phase Contrast Microscopy Equivalent
PLM
Polarized light microscopy
PLM-VE
Polarized Light Microscopy - Visual Estimation
QAPP
Quality Assurance Project Plan
RI
Remedial Investigation
ROW
Right-Of-Way
s/cc
structures per cubic centimeter
SAP
Sampling and Analysis Plan
SERAS
Scientific, Engineering, Response and Analytical Services Program
SH2
State Highway 2
SH37
State Highway 37
SOPs
Standard Operating Procedures
TEM
Transmission Electron Microscopy
[j,m
micrometer
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EXECUTIVE SUMMARY
Overview
This Remedial Investigation (RI) Report describes the nature and extent of Libby amphibole
(LA) asbestos at Operable Unit 8 (OU8) of the Libby Asbestos National Priority List (NPL) Site
located in Libby, Lincoln County, Montana (the Site). An evaluation of potential exposures to
and risks from LA will be included in the site-wide risk assessments for the Libby Asbestos
Superfund Site.
Operable Unit 8 is also referred to as state and local highways and includes segments of roadway
right-of-way (ROW) in and within 30 miles of Libby (Figure ES-1).
Gold miners discovered vermiculite in Libby in 1881; in the 1920s the Zonolite Company
formed and began mining the vermiculite. In 1963, W.R. Grace bought the Zonolite mining
operations which closed in 1990. While in operation, the Libby mine may have produced 80
percent of the world's supply of vermiculite. Vermiculite has been used in building insulation
and as a soil conditioner.
Vermiculite often contained asbestos and therefore, vermiculite mining, processing, and shipping
acted as a carrier to spread asbestos throughout Libby. Raw vermiculite ore was estimated to
contain up to 26% LA.
Asbestos found at the Libby Site contains a variety of different amphibole types. Amphibole is
the name of an important group of generally dark-colored minerals, forming prism or needlelike
crystals. Because there are presently insufficient toxicological data to distinguish between the
different forms of amphibole asbestos, the Environmental Protection Agency (EPA) evaluates all
of the mine-related amphibole asbestos types together (referred to as LA). Asbestos exposure in
humans may cause both cancer and non-cancer effects. Among them are:
Non-Cancer Effects:
Asbestosis
Pleural Abnormalities
Cancer Effects:
Lung cancer
Mesothelioma
People who visit or work at OU8 may be exposed to LA by incidental ingestion of contaminated
soil or dust and by inhalation of air that contains LA fibers. Of these two pathways, inhalation
exposure is considered to be of greater concern as it is most often associated with disease of the
respiratory system.
Asbestos fibers can be released into the air due to disturbance of asbestos containing
environmental media such as soil. The amount of LA fibers released into the air at the site will
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vary depending upon the level of LA in the source material and the intensity and duration of the
disturbance activity. Because of this, predicting LA levels in air associated with disturbance
activities based only on measured LA levels in source material is extremely difficult. Therefore,
the most direct way to determine potential exposures from inhalation is to measure, through
sampling and analysis, the concentration of LA in air during a specific activity that disturbs a
source material. For convenience, this is referred to as activity-based sampling (ABS).
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DATE: MAY. 2011
County Highway 567
Kootenai River
Road
Rainy Creek Road
County Highway 482
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LS HWY
Slate ri'A'Y
Secondary Roads
Limits of OU8
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Operable Unit S - R0.11tw.1y Right ot W.iy
Figure ES-1
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Site Investigations
Once OU8 was established in 2009, EPA conducted extensive sampling of soil and air during
2010 and 2011 as part of the remedial investigation including the following media-specific
sampling:
Soils
> Surface - composite samples collected from as much as 6-inches bgs.
Air
> Personal air samples - collected using a sampling pump and filter located in the
breathing zone of an individual (or mounted on equipment) while performing
various outdoor activities.
> Stationary air samples - collected using a stationary sampling pump and filter
placed in a location that acts as a surrogate for a personal air sample.
Soil samples were collected and analyzed for LA in order to determine the distribution of LA
(and visible vermiculite) along roadway ROWs. This information was used to, among other
things; determine whether ABS sampling was performed over a range of LA levels and visible
vermiculite conditions. Visible vermiculite is often used as an indicator for the presence of LA.
In most cases, one composite soil sample was created from ten aliquots collected for every 1,000
ft of ROW. A total of 485 field (non-QC) composite soil samples were collected from July 7 to
September 10, 2010. Of these, 397 contained no detectable LA and the remaining 88 samples
contained trace levels of LA.
Visible vermiculite was not observed in composite soil samples with the exception of those
collected along the far eastern end of State Highway 37 (Figure ES-1). In this area, more than ten
samples contained visible vermiculite. However, polarized light microscopy results for these
samples were non-detect to trace for LA, which is typical of the rest of the OU. It is not clear
why vermiculite was noted by visual inspection but LA was not detected by laboratory analyses.
ABS air samples were collected in association with the following activities:
Recreational Activities
Riding all terrain vehicles (ATV) with a lead and following ATV.
Montana Department of Transportation (MDOT) Maintenance Activities
Rotomilling of asphalt pavement (removing the top layer by grinding)
Grass cutting and brush hogging (cutting to remove shrubs and saplings) in ROWs.
All ATV, brush hogging and grass cutting ABS sampling during the 2010-2011 OU8 Field
Program was conducted along Hwy 37 between Libby and Rainy Creek Road (Figure ES-1).
This portion of roadway was selected for ABS based on the presence of LA and visible
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vermiculite in surface soils as determined during investigations in 2003 and 2005. Samplers were
mounted on the front and back of the grass cutting and brush hogging equipment as well as on
the "following" ATV.
Rotomilling ABS sampling was performed along Hwy 37 in downtown Libby as part of
regularly scheduled maintenance work conducted by the MDOT. The general area of interest
(California Ave.) was selected because one of several asphalt core samples collected in
California Ave. in March 2010 contained a trace (0.1%) of LA.
Rotomilling ABS consisted of samplers mounted on the moving rotomill as well as on a small
front-end loader. In addition, stationary samplers were positioned on the sidewalk adjacent to the
street where rotomilling operations were conducted. These samplers comprised the "inner
perimeter" sampling stations.
In addition to the ABS sampling, several stationary air samplers were placed at various locations
within downtown Libby but remote from the rotomilling operations. Samples collected from
these locations are representative of ambient conditions and are referred to as "outer perimeter"
samples.
Sample results are summarized below:
Of the 34 ABS air samples associated with ATV riding, brush hogging and grass cutting,
LA was detected in 8 samples. Of those, 7 were associated with brush hogging and one
was found in association with ATV riding.
Of the 10 ABS air samples collected from rotomilling equipment, no LA was detected.
Of the 51 air samples collected from the inner perimeter, only one contained detectable
LA.
Of the 25 ambient air samples collected around downtown Libby, none contained
detectable LA.
In addition to the data discussed above, EPA conducted certain limited investigations of LA in
surface soil between 2003 and 2005. This work focused on the segment of Montana State
Highway 37 between Libby and Rainy Creek Road (See Figure ES-1). These data revealed the
presence of LA in some soil samples.
Risk Assessment
An evaluation of potential exposures to and risks from LA will be included in the site-wide risk
assessments for the Libby Asbestos Superfund Site. Site-wide risk assessments are stand-alone
documents which support the feasibility study and record of decision.
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1.0 INTRODUCTION
1.1 OVERVIEW AND REPORT ORGANIZATION
This Remedial Investigation (RI) Report describes the nature and extent of Libby amphibole
(LA) asbestos and associated human health risks at Operable Unit 8 (OU8) of the Libby
Asbestos National Priority List (NPL) Site (the Site). LA occurrence throughout the Site resulted
from long time mining, processing, and shipping activities and the use and handling of materials
which contained LA.
U.S. Environmental Protection Agency (EPA) has had a presence in Libby since 1999 and has
completed a number of sampling activities and clean up efforts. The EPA determined there was
an imminent and substantial endangerment to public health from asbestos contamination in
various types of source materials in and around Libby.
In light of evidence of human asbestos exposure and associated increase in health risks, it was
recommended that EPA take appropriate steps to reduce or eliminate exposure pathways to these
materials to protect area residents and workers. In 2002, the Libby Asbestos Superfund Site was
included on the NPL, which due to its large size, has been divided into eight Operable Units
(OUs):
OU1 - Former Export Plant
OU2 - Former Screening Plant
OU3 - Mine Site
OU4 - Residential and commercial properties in and around Libby
OU5 - Former Stimson Lumber Mill
OU6 - Rail Line
OU7 - Residential and commercial properties in and around Troy
OU8 - US and Montana State highways and secondary highways in the vicinity of Libby
and Troy, Montana.
Figure 1-1 presents a map showing the entire NPL area and boundaries of all OUs. This RI
addresses OU8, which includes various State and local highways in the vicinity of Libby and
Troy, Montana.
As determined by previous investigations conducted at the Site, LA is present in multiple
environmental media. During 2003 and 2005 soil samples were collected along portions of State
Highway 37 (SH37) and were found to contain LA and visible vermiculite (CDM, 2005). During
2006 and 2007, soil and air samples were collected during routine maintenance activities
performed by the MDOT. LA was detected in some of those samples. In March 2010, five
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asphalt core samples were taken from California Street and US Highway 2 (in downtown Libby)
and analyzed for asbestos. In one of the core samples, a trace (0.1%) of LA was detected
indicating LA may be embedded in the roads in and around Libby (Lockheed Martin, 2010a).
Based on this evidence, EPA established OU8 and began planning for the RI described in this
report.
The RI Report is organized into the following major sections:
Section 1 - Introduction - This section describes the purpose of the RI and summarizes prior
work and NPL Site history.
Section 2 - Site Characteristics - This section provides a brief description of Site setting,
climate, geology, hydrogeology, and surface water hydrology.
Section 3 - Sampling and Analyses - This section discusses sample types and collection methods
and analytical techniques.
Section 4 - Data Recording, Data Quality Assessment, and Data Selection - This section
discusses the Libby database, quality control measures and how data were selected to produce
the final OU8 data set used to describe the nature and extent of contamination.
Section 5 - Nature and Extent of LA - This section provides a description of the current type and
extent of LA in surface soils and outdoor air.
Section 6 Contaminant Fate and Transport - This section provides a qualitative discussion of
LA contaminant migration routes and persistence in the environment.
Section 7 - Human Health Risk Assessment - This section discusses the human health and
ecological risk assessment
Section 8 - Conclusions - This section presents general conclusions.
Section 9 - References - This section provides full references for all citations in the body of the
report.
1.2 NPL SITE LOCATION & TOPOGRAPHY
The City of Libby, Montana is located in the northwest corner of the state, 35 miles east of Idaho
and 65 miles south of the Canadian border (Figure 1-1). It is at an elevation of approximately
2,580 feet (ft) above mean sea level (msl). The source of LA, Vermiculite Mountain, is located
approximately 7 miles northwest of Libby. The city has a total area of 1.3 square miles and lies
in a valley carved by the Kootenai River and bounded by the Cabinet Mountains to the south.
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Operable Unit No. OU8 consists of the ROW of the following State and local highway segments
(See Figure 1-2):
Montana State Highway 37 (SH37)
Montana State Highway 2 (SH2)
Kootenai River Road
County Highway 482 (Farm to Market Road)
County Highway 567 (Pipe Creek Road)
1.3 NPL SITE HISTORY
Libby is located near a large open-pit vermiculite mine located on Vermiculite Mountain.
Vermiculite is a mica-like mineral that can be processed for use as an insulating material or soil
amendment and was mined in Libby between 1919 and 1990. It is estimated that the Libby mine
was the source of over 70 percent of all vermiculite sold in the U.S. from 1919 to 1990. Over its
lifetime, it employed more than 1,900 people. W. R. Grace bought the mine and processing
facility in 1963 and operated it until 1990 (EPA, 2010).
Vermiculite from this mine contains varying levels of amphibole asbestos, consisting primarily
of winchite and richterite, with lower levels of tremolite, magnesioriebeckite, and possibly
actinolite. Because existing toxicological data are not sufficient to distinguish differences in
toxicity among these different forms, the EPA does not believe that it is important to attempt to
distinguish among these various amphibole types. Therefore, the EPA simply refers to the
mixture as LA asbestos. Historic mining, milling, and processing operations, as well as bulk
transfer of mining-related materials, tailings, and waste to locations throughout the Libby Valley
resulted in releases of vermiculite and LA to the environment. This has caused a range of adverse
health effects in exposed people, including individuals who did not work at the mine or
processing facilities.
The EPA has been working in Libby since 1999 when an Emergency Response Team was sent to
investigate local concerns and news articles about asbestos-contaminated vermiculite. Since that
time, the EPA has been working closely with the community to clean up contamination and
reduce risks to human health.
Based on health risks associated with asbestos, which include asbestosis, lung cancer and
mesothelioma, EPA placed the Libby Asbestos Site on the NPL in October 2002.
Libby, Montana, which is the Lincoln County seat, has a population of less than 3,000, and
12,000 people live within a ten-mile radius. While Libby's economy is still largely supported by
natural resources such as logging and mining, there are also many tourist and recreational
opportunities in the area.
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1.4 REGULATORY HISTORY
The following is a brief chronological summary of major regulatory actions taken at the Site.
1999 - Local concern alerts EPA to investigate asbestos in and around Libby, Montana
2002 - Libby Asbestos Site proposed for the NPL
2002 - Libby Asbestos Site formally added to the NPL
2009 - Operable Unit No. 8 added to the Site.
EPA has not entered into any enforcement agreements or issued any orders for investigation,
removal, or remedial work at any part OU8. However, EPA has addressed some parts of OU8
along with the remedial actions for other OUs. EPA addressed the portion of Highway 37
adjacent to OUs 1 and 2 as part of their respective removal and remedial actions. These actions
were not pursuant to any enforcement agreement or order. They were funded with special
account money under the settlement EPA entered into with W. R. Grace, in 2008. That
agreement provided for a cash settlement of past and future response costs owed by W.R. Grace
for the entire Libby NPL Site except OU3, the mine site.
1.5 PREVIOUS INVESTIGATIONS & REPORTS
Prior to the designation of OU8 as a Site Operable Unit, several investigations generated data
from areas that lie within current OU8 boundaries. In addition, OU8-specific investigations were
conducted in 2010 and 2011. Planning documents for these investigations and associated reports
are listed below:
Sampling and Analysis Plans
Sampling and Analysis Plan/Quality Assurance Project Plan for Activity-Based
Outdoor/Air Exposures, Operable Unit 8, Libby Asbestos Site, Libby, Montana, 2010
Sampling Events. Prepared by TechLaw. Revision Date July 15, 2010.
Reports on Investigation Results (pre-OU8 designation) Containing Data Relevant to OU8
Contaminant Screening Study, Libby Asbestos Site, Operable Unit 4, Libby, Montana.
Final Summary Report for the J. Neils Park and Montana State Highway 37
Investigations, Revision 1. Prepared By CDM. December 2005.
Report of Findings, Potentially Asbestos-Containing Soil in MTD Rights-of- Way,
Traction Sand and Road Aggregate Sources, Collected Road Sweepings, and Sampled
Worker Air Space During Routine Maintenance Activities, Libby, Montana. Prepared By
Tetra Tech, Inc., February 21, 2007.
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Report of Findings, Sampled Worker Air Space during Routine Maintenance Activities,
Libby, Montana. Prepared By Tetra Tech, Inc., July 19, 2007.
Sampling Investigation Results Reports Specific to 0U8 (post-OU8 designation)
Verification Summary Report for Operable Unit 8, Libby Asbestos Superfund Site (Based
on Scribe database provided on 1/27/11), Prepared by SRC. February 1, 2011.
Trip Report (on ABS activities), Libby Asbestos Site, Libby, Montana. Prepared by
Lockheed Martin Scientific, Engineering, Response and Analytical Services. November 1,
2010.
Trip Report (on Rotomilling ABS Activities and Ambient Air Sampling), Libby Asbestos
Site, Libby, Montana. Prepared by Lockheed Martin Scientific, Engineering, Response
and Analytical Services. June 24, 2011.
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2.0 SITE CHARACTERISTICS
Operable Unit 8 encompasses a large geographic area but is constrained to roadway rights-of-
way (ROW). Therefore, an OU-specific detailed discussion of many site characteristics, such as
geology, is impractical for linear features such as a roadway. In addition, the investigation of LA
in OU8 is restricted to surface soil and air. Therefore, subsurface conditions are not relevant to
the RI. As a result, the following discussion of Site characteristics is based on conditions in and
around Libby where such information has been developed as a part of work in other OUs.
2.1 CLIMATE
Annual average precipitation in Libby is 24.7 inches, with an annual average of 105 inches of
snowfall (WRCC, 2010). Precipitation and humidity in Libby are greatest during the winter
months due to the presence of temperature-regulating Pacific air masses. In December and
January, average temperatures range between 25-30 °F. Occasionally, dry continental air masses
occupy the Libby area for short periods of time during the winter, creating cold and less-humid
conditions (CDM, 2009).
Fog is common in Libby during winter months and in early morning throughout the year.
Summer months are drier than winter and are warm with occasional rainfall. The average July
temperature ranges between 56-70 °F, with an average high of 80 °F (CDM, 2009).
Prevailing winds are from the west north-west and average approximately 6-7 miles per hour.
Wind direction and velocities fluctuate depending on temperature variances caused by vertical
relief in the area. Inversions often trap stagnant air in the Libby valley (CDM, 2009).
2.2 GEOLOGY
Regional geology in the Libby valley is comprised of lacustrine deposits underlain by
Precambrian rocks. Surrounding mountains are formed by Precambrian rocks. Cliffs along the
lower portion of the valley are formed by glacial lake bed deposits. The Kootenai River and
Libby Creek cut through lacustrine and alluvial deposits and form a discontinuous sequence of
gravel, sand, silt, and clay (EPA, 2010b).
Alluvial deposits extend from the surface to 190 ft bgs and are comprised of sand, gravel, silt,
clay and cobbles. Glacial till, which consists primarily of silt and clay with varying amounts of
sand and gravel, underlies alluvial deposits. Deposits of glacial till are believed to be quite deep,
occurring at depths exceeding 500 ft bgs (EPA, 2010b).
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Soils in the Libby area typically are loamy soil composed of sand and silt with minor amounts of
clay. Soil was formed by erosion of Precambrian rocks, downstream transport of clays by rivers
and creeks, and organic matter from historically forested areas (CDM, 2009).
Site soils are a combination of historical soil modified in areas by human activities. These
activities may include addition of vermiculite as a soil amendment, soil reworking for building
construction, road and railroad operation, vermiculite processing and transport, and general site
work.
2.3 HYDROLOGY AND HYDROGEOLOGY
Within OU8, portions of SH 2 and SH 37 follow the Kootenai River and runoff from these
roadways discharges to the river. In addition, the portion of SH 2 south of Libby parallels Libby
Creek. The Kootenai River originates in British Columbia, Canada, and flows through Montana
and Idaho before returning to Canada and flowing into the Columbia River. Flows in the
Kootenai River and Libby Creek are tied to runoff from the mountains surrounding Libby.
Runoff peaks in spring when high-elevation snow begins to melt. Stream flow decreases in
summer due to low precipitation and snowmelt flow moderation by high elevation lakes (CDM,
2009).
Based on investigations at the Libby Groundwater Site (a separate NPL Site within the Libby
Asbestos NPL Site), the hydrogeology in the southeast portion of Libby consists of saturated
alluvial deposits extending from the surface to approximately 190 ft bgs. These deposits have
been sorted into three classifications: upper aquifer, intermediate zone, and lower aquifer. The
upper aquifer contains high hydraulic conductivity material including silty gravel and sand with
occasional interbedded clayey, silty deposits. It is unconfined and extends from the water table (5
to 30 ft bgs) to approximately 70 ft bgs. Hydraulic conductivity ranges from 100 to 1,000 feet
per day (ft/day). The inferred groundwater flow direction is north-northwest towards the Kooteni
River (EPA, 2010b).
The intermediate zone is comprised of low permeability deposits similar to the upper aquifer, but
with a higher percentage of fine-grained material. Acting as a confining layer, the intermediate
zone is 40 to 60 ft thick, extending from approximately 60-70 ft bgs to 110 ft bgs. The hydraulic
conductivity of this layer is much lower than the upper aquifer at approximately 1 ft/day.
The lower aquifer extends from approximately 100 ft bgs to 190 ft bgs, and contains more low-
permeability silt and clay layers than the upper aquifer. It is confined and under pressure, so
water in wells screened in this aquifer rises to 14-26 ft bgs. Hydraulic conductivity of the lower
aquifer ranges from 50 to 200 ft/day. The inferred groundwater flow direction is north-northwest
towards the Kooteni River (EPA, 2010b).
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3.0 SAMPLING AND ANALYSIS
Most analytical and other data relevant to OU8 were collected during 2010 and 2011, after OU8
was established. However, some data relevant to OU8 were collected prior to 2010 as part of the
investigation of other OUs or Site-wide investigations. Table 3-1 summarizes all sampling events
that generated data relevant to OU8.
The following sections describe sample types, sample collection and analytical methods. All
sample media and associated analytical results are discussed in this section. However, certain
data are excluded from the discussion of nature and extent of LA occurrence (Section 5)
including:
Data that were deemed irrelevant to the assessment of risk to human health. These
include certain indoor dust and outdoor ambient air samples and street sweepings.
Occupational Safety and Health Administration compliance monitoring data for EPA
contractors working on the remedial investigation.
This was done to simplify and focus the description of nature and extent of LA occurrence to
those measurements most relevant to the estimation of human health risks.
3.1 SAMPLE TYPES AND COLLECTION PROCEDURES
As shown in Table 3-1, the following media-specific sampling was conducted:
Soils
> Surface - composite samples collected from as much as 6-inches bgs.
Air
> Personal air samples - collected using a sampling pump and filter located in the
breathing zone of an individual (or mounted on equipment) while performing
various outdoor activities.
> Stationary air samples - collected using stationary sampling pump and filter
placed in a location that acts as a surrogate for a personal air sample.
Samples were collected, documented, and handled in accord with standard operating procedures
(SOPs) as specified in the respective Sampling and Analysis Plans (SAPs) prepared for the
various investigations summarized on Table 3-1. Additional details on the 2010 and 2011 RI
Field Programs including the study design and data quality objectives (DQOs) is provided in the
Quality Assurance Project Plan (QAPP; Lockheed Martin, 2010a).
Data documenting sample type, location, collection method, and collection date were recorded
both in a field log book maintained by the field sampling team and on a field sample data sheet
(FSDS) designed to facilitate data entry into the Libby site database, as described in Section 4.1.
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All samples collected in the field were maintained under chain of custody (COC) during sample
handling, preparation, shipment, and analysis.
3.1.1 Soil Samples
Composite soil samples were collected along both sides of the ROW from the following
roadways in OU8 (See Figure 3-1):
Montana SH37
Montana SH2
Kootenai River Road
County Highway 482 (Farm to Market Road)
County Highway 567 (Pipe Creek Road)
The soil samples were collected and analyzed for LA in order to determine the distribution of LA
(and visible vermiculite) along roadway ROWs. This information was used to, among other
things, determine whether air sampling (activity-based sampling (ABS); See section 3.1.2) was
performed over a range of surface soil LA levels and visible vermiculite conditions.
In general, one soil aliquot was collected for every 100 ft of ROW. The aliquots were originally
to be collected in locations of visible vermiculite. However, this biased sampling was not
performed in most areas due to the absence of visible vermiculite in all locations except for
SH37 from Rainy Creek Road to the dam.
In most cases, one composite soil sample was created from the ten aliquots collected for every
1,000 ft of ROW. However, composite samples were created from as many as 30 to as few as 3
aliquots in sections of ROW where hard surfaces comprise much of the ROW. A total of 485
field (non-QC) composite soil samples were collected from July 7 to September 10, 2010.
Soil sample locations were recorded at the midpoint of each 1,000 foot segment of ROW from
which each composite sample was collected. The locations of all composite samples are shown
on Figure 3-1.
In addition to soil samples collected during 2010, composite samples consisting of three aliquots
were collected in 2003 and 2005 (CDM, 2005) and referred to as "Legacy Data" throughout the
remainder of this report. The Legacy Data were collected only between Libby and Rainy Creek
Road along SH 37 and are not shown on Figure 3-1. However, the analytical results from these
samples are presented and discussed in Section 5.0.
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3.1.2 Air Samples
All air samples were collected by drawing a sample through a filter that traps asbestos and other
particulate material on the face of the filter. Two main categories of air samples were collected:
1. Personal Air Samples - Sampling equipment worn by a person or affixed to operating
equipment/vehicle.
2. Stationary Air Samples - Sampling equipment placed on a motionless surface.
Personal air sampling involved a variety of activities performed by the sampler generally
involving operation of recreational or roadway maintenance equipment/vehicles. Such sampling
is referred to in the remainder of this report as Activity-Based Sampling (ABS).
Air sampling for asbestos was conducted using Emergency Response Team (ERT) SOP #2015,
Asbestos Sampling. The sampling train consisting of 0.8-micron (~m), 25-millimeter (mm)
mixed cellulose ester (MCE) filter cassette connected to a sampling pump (Lockheed Martin,
2010b). For personal ABS sampling, participants were fitted with the appropriate sampling pump
with the cassettes secured near the operator's breathing zone.
ABS Sampling:
For the 2010 and 2011 OU8 RI field program, these activities included:
Recreational Activities
Riding ATVs with a lead and following ATV.
MDOT Maintenance Activities
Rotomilling of asphalt pavement
Grass cutting and brush hogging in rights-of-way
All ABS sampling during the 2010-2011 OU8 Field Program was conducted along SH37
between Libby and Rainy Creek Road (See Figure 3-1). This portion of roadway was selected for
ABS (excluding rotomilling) based on the presence of LA and visible vermiculite in surface soils
as determined during investigations conducted in 2003 and 2005 (CDM, 2005).
Rotomilling ABS sampling was performed along Hwy 37 as part of regularly scheduled
maintenance work conducted by MDOT. The general area of interest (California Ave.) was
selected because one of several core samples collected in California Ave. in March 2010
contained a trace (0.1%) of LA (Lockheed Martin, 2010a).
All ABS sampling other than rotomilling was performed in September or October in order to
make measurements during the time of year where conditions are drier than most other months.
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The effects of seasonal soil moisture has no effect on the results of asphalt rotomilling ABS
sampling.
A summary of the ABS sampling procedures implemented during the 2010-2011 OU8 field
program is provided below. Further details are provided in a QAPP (Lockheed Martin, 2010a)
and ABS Trip Reports (Lockheed Martin, 2010b and 2011).
Brush Hogging
Brush hogging activities took place over three days in September 2010. This activity involved
powered equipment using rotary blades similar to a large lawn-mower (tractor and implement) to
cut shrubs and small tress along the roadway embankment. A total of seven activities (scenarios)
took place at seven locations at a rate of two to three per day. Each scenario was between
approximately 60 and 200 minutes. During each scenario four air samples were collected at
varying air flow rates. Two samples were collected at the front of the unit (tractor and
implement) and two samples were collected on the back of the unit. In addition, a 30-point
composite soil sample was collected to represent the seven locations where the brush hogging
ABS was performed.
Grass Cutting
One grass cutting activity (scenario) was conducted at two locations over the course of two days
in September 2010. Each scenario was approximately 150 minutes and involved the collection of
four air samples. Two samples were collected at the front of the unit (tractor and implement) and
two samples were collected on the back of the unit (at varying air flow rates). In addition, a 30-
point composite soil sample was collected to represent the two locations where the grass cutting
ABS was performed.
ATY Riding
Eight ATV riding activities (scenarios) took place at four locations over the course of four days
in September 2010. Each scenario involved a lead and following ATV and was performed twice
at each location during approximately 120 minutes. The ATVs maintained their relative positions
at a distance of approximately 50 to 75 ft throughout each scenario. Two sampling pumps were
placed on the lead ATV and two sampling pumps were placed on the following ATV resulting in
the collection of four samples per scenario (32 samples total). In addition, a 30-point composite
soil sample was collected to represent the three locations where the off-road ATV ABS was
performed. One of the ATV scenarios involved riding on a paved surface and no soil sample was
collected for that event.
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Rotomilling
Rotomilling activities took place over three days in April 2011. Personal air samples were
limited to those collected from the moving rotomill and skid steer (a small front end loader).
A total of 10 field personal air samples were collected. Eight were collected from the rotomilling
machine and two were collected from the skid steer.
Additional samples associated with rotomilling were stationary and are discussed below.
Stationary Air Samples:
Stationary sampling included ambient air proximal to a person or piece of equipment conducting
ABS activities. Such stationary air samples were collected to represent conditions in the
breathing zone as a surrogate for a personal air sample. These are referred to as perimeter
samples and typically monitor the perimeter of an ABS activity involving equipment operation
that mobilizes dust into the air.
For the 2011 OU8 Field Program the following types of stationary air sampling were conducted:
At fixed locations on both sides of the street where rotomilling operations were
conducted. The samplers formed an inner perimeter around the rotomill spaced about a
block (approximately 300 ft) apart.
At selected locations up to 1,000 ft from California Ave., comprising an outer perimeter
(also referred too as ambient air samples in the QAPP; Lockheed Martin, 2010a). These
outer perimeter samples were initiated at the beginning of the day and completed at the
end of each work day.
Overall, 76 stationary field air samples were collected at 38 locations (See Figure 3-2).
3.1.3 Quality Control Samples
Quality control samples type and collection frequency included:
Soil Samples
Field duplicate soil samples were collected at a rate of one duplicate sample per 20 soil
samples collected.
Soil sample field blanks (blank sand) were collected at a rate of one field blank sample
per 20 soil samples.
Air Samples
One lot blank was analyzed for each new lot of MCE filter cassettes.
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One field blank was collected and submitted for analysis for each day of sampling for the
duration of the ABS and rotomilling activities.
Four perimeter field duplicates were collected and analyzed for each day of sampling
(two collected at the high flow rate and two at the low flow rate).
One ambient air field duplicate was collected over an 8-hour period at the high flow rate
and analyzed each day for the duration of the rotomilling project.
An assessment of data quality is summarized in Section 4 and the full Data Quality Assessment
(DQA) Report is provided as Appendix A.
3.2 SAMPLE PREPARATION AND ANALYSIS
3.2.1 Soil
Polarized Light Microscopy (PLM)
Soil samples collected as part of the OU8 sampling programs were prepared for analysis in
accord with SOP ISSI-LIBBY-01 as specified in the CDM Close Support Facility (CSF) Soil
Preparation Plan (CDM, 2004). In brief, each soil sample is dried and sieved through a Vi inch
screen. Particles retained on the screen (if any) are referred to as "coarse" fraction. Particles
passing through the screen are referred to as fine fraction, and this fraction is ground by passing
it through a plate grinder. Resulting material is referred to as "fine ground" fraction. The fine
ground fraction is split into four equal aliquots; one aliquot is submitted for analysis and the
remaining aliquots are archived at the CSF.
Soil samples are analyzed using PLM by visual estimation (PLM-VE) whereby the analyst
visually estimates the amount of asbestos in the sample (expressed as percent by weight) based
on comparison to reference materials.
The coarse fractions were examined using stereomicroscopy, and any particles of asbestos
(confirmed by PLM) were removed and weighed in accord with SRC-LIBBY-01 (referred to as
"PLM-Grav"). Fine ground aliquots were analyzed using a Libby-specific PLM method using
visual area estimation, as detailed in SOP SRC-LIBBY-03. For convenience, this method is
referred to as "PLM-VE."
PLM-VE is a semi-quantitative method that utilizes site-specific LA reference materials to allow
assignment of fine ground samples into one of four "bins," as follows:
Bin A (ND): non-detect
Bin B1 (Trace): detected at levels lower than the 0.2% LA reference material
Bin B2 (<1%): detected at levels lower than the 1% LA reference material but higher
than the 0.2% LA reference material
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Bin C: LA detected at levels greater than or equal to the 1% LA reference material
Visual Inspection
For soil samples, field teams also provide a semi-quantitative estimate of visible vermiculite
present at soil sampling point(s). Visual inspection data can be used to characterize the level of
vermiculite (and presumptive LA contamination) in an area and considers both frequency and
level of vermiculite. This is achieved by assigning a weighting factor to each level, where
weighting factors are intended to represent relative levels of vermiculite in each category.
As presented in SOP CDM-LIBBY-06, guidelines for assigning levels are as follows:
None - No flakes of vermiculite observed within the soil sample.
Low - A maximum of a few flakes of vermiculite observed within the soil sample.
Moderate - Vermiculite easily observed throughout the soil sample, including the surface
and contains <50% vermiculite.
High - Vermiculite easily observed throughout the soil sample, including the surface and
contains 50% or more vermiculite.
Based on these descriptions, weighting factors used to characterize magnitude of LA occurrence
in soil are as follows:
Visible Vemiieulile l.e\el (l.i)
Weighting factor (\\ j)
None
0
Low
1
Moderate
3
High
10
The composite score is then the weighted sum of the observations for the area:
r>,"v,
Score = ¦
30
This value can range from zero (all 30 points are "none") to a maximum of 10 (all 30 points are
"high"). For example, an ABS area with 1 "low" point and 29 "none" points would receive a
value of 1/30 = 0.033, while an ABS area with 24 "intermediate" points and 5 "high" would
receive a score of (24-3 + 5 10) / 30 = 4.13.
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In addition to the visual estimation method described above, field crews used a less sophisticated
technique prior to implementation of SOP CDM-LIBBY-06 in 2006. This involved noting in the
field the simple presence or absence of visible vermiculite in soil samples.
3.2.2 Air
In the past, the most common technique for measuring asbestos in air was phase contrast
microscopy (PCM). In this technique, air is drawn through a filter and airborne particles become
deposited on the face of the filter. All structures that have a length greater than 5 micrometers
([j,m) and have an aspect ratio (the ratio of length to width) of 3:1 or more are counted as PCM
fibers. The limit of resolution of PCM is about 0.25 um, so particles thinner than this are
generally not observable.
A key limitation of PCM is that particle discrimination is based only on size and shape. Because
of this, it is not possible to classify asbestos particles by mineral type, or even to distinguish
between asbestos and non-asbestos particles. For this reason, nearly all samples of air collected
in Libby are analyzed by transmission electron microscopy (TEM).
This method operates at higher magnification (typically about 20,000x) and hence is able to
detect structures much smaller than can been seen by PCM. In addition, TEM instruments are
fitted with accessories that allow each particle to be classified according to mineral type.
Air samples filters were directly prepared for analysis by TEM in accord with preparation
methods provided in International Organization for Standardization (ISO) 10312 (ISO, 1995). In
the case where filter cassettes were found to be overloaded, the filters were prepared for analysis
in accordance with SOP EPA-Libby-08 (indirect prep). This indirect preparation method was
employed for three samples associated with brush hogging and two samples associated with
rotomilling.
Sample analysis was by TEM in basic accord with counting and recording rules specified in ISO
10312, and certain project-specific counting rule modifications including changing the recording
rule to include structures with an aspect ratio >3:1.
For each countable structure particle identified, the analyst records structure-specific information
(e.g., length, width, asbestos mineral type) which is then used to calculate air concentration in
LA structures per cubic centimeter (s/cc).
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4.0 DATA RECORDING, DATA QUALITY ASSESSMENT, AND DATA
SELECTION
4.1 DATA RECORDING
All analytical results are stored and maintained in the OU8 Scribe Database. A copy of the
database is available through EPA Region 8 records center (See Appendix B).
Standardized data entry spreadsheets (electronic data deliverables or EDDs) have been
developed specifically for the Libby project to ensure consistency between laboratories in the
presentation and submittal of analytical data. In general, a unique EDD has been developed for
each type of analytical method. Each EDD provides the analyst with a standardized laboratory
bench sheet and accompanying data entry form for recording analytical data. Data entry forms
contain a variety of built-in quality control functions that improve accuracy of data entry and
help maintain data integrity. These spreadsheets also perform automatic computations of
analytical input parameters (e.g., sensitivity, dilution factors, and concentration), thus reducing
the likelihood of analyst calculation errors.
Asbestos analytical data (soil and air) was reported by the analytical laboratory in the form of an
EDD and a pdf of the Data Report via email. All asbestos analytical data was then uploaded into
the OU8 Scribe Database by the Environmental Services Assistance Team (ESAT - EPA's
contractor) Data Manager.
Hard copies of all analytical reports are stored in the Scientific, Engineering, Response and
Analytical Services (SERAS - EPAs contractor) Program Central Files and electronic copies are
stored on SERAS Local Area Network.
All sampling location identification numbers were given to EPA's Environmental Response
Team (ERT - EPA technical experts) by ESAT prior to the sampling event. Field sampling data
were recorded for each sample collected by ERT personnel on a sample log sheet and loaded into
the OU8 Scribe Database. All samples and copies of sample log sheets were delivered to the
EMSL/Libby laboratory. ERT/SERAS prepared all COC forms prior to delivery of the samples
to the laboratory.
Hard copies of all FSDSs, field log books, and COC forms generated during the OU8 sampling
program were transferred to the Sample Receiving Coordinator at CDMs Libby Montana Project
Office.
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4.2 DATA QUALITY ASSESSMENT
DQA is the process of reviewing existing data to establish the quality of the data and to
determine how any data quality limitations may influence data interpretation (EPA, 2006). The
full DQA is provided as Appendix A and a summary is provided below.
A verification of a minimum of 10% of the TEM results was performed based on the OU8 Scribe
Database provided by ESAT on 1/27/11 in accord with SOP EPA-LIBBY-09 (rev 1). No
discrepancies were discovered upon review of the original hand-written laboratory bench sheets
to determine if the raw structure data were recorded in accord with ISO 10312 counting rules and
SAP stopping rules. In addition, no errors were discovered when checks were performed to
ensure that the data from the bench sheet were transferred into the OU8 Scribe Database without
error or omission.
A verification of a minimum of 10% of the PLM-VE results was performed based on the OU8
Scribe Database provided by ESAT on 1/27/11 in accord with draft SOPs for PLM verification.
A review of the original laboratory PLM bench sheets and verification of the transfer of results
from the bench sheets into the OU8 Scribe Database was performed. Because the issues
identified are not likely to impact data interpretation, no future verification of PLM-VE results
was recommended.
A verification of FSDS information for all 62 analyses selected for PLM-VE and TEM
verification was performed based on the OU8 Scribe Database provided by ESAT on 1/27/11.
Several issues were discovered, some with the potential to impact data interpretation. The main
issues involve discrepancies in the visible vermiculite information (number of aliquots vs.
number of visible vermiculite observations) and sample date as well as omission of detailed
pump information.
Discrepancies in the number of aliquots associated with visible vermiculite observations were
limited to 4 samples out of 508. These visible vermiculite results (associated with sample HW-
00129, HW-00130, HW-00133 and HW-0082) have been omitted from the remainder of the RI
report.
In addition, the DQA explains that detailed pump information was examined on the original
FSDS and that the issue was limited to the lack pump information in the OU8 Scribe Database.
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4.3 DATA SELECTION
Raw data for samples utilized in describing the occurrence of LA in OU8 soils and air (Section
5) were obtained via a subscription to the OU8 Scribe Database through Scribe.net. A copy of
this database was obtained by HDR, Inc. on December 16, 2012. A copy of the database is
available through EPA Region 8 records center (See Appendix B).
Scribe queries were written to sort data by media, analytical method and to exclude quality
control samples. The data set resulting from execution of the queries (excepting the four visible
vermiculite results discussed in Section 4.2) was used to describe the nature and extent of LA
occurrence.
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5.0 NATURE AND EXTENT OF LA
5.1 CONTAMINANTS OF CONCERN
The contaminant of concern at the Libby Site is asbestos. Asbestos is the generic name for the
fibrous form of a broad family of naturally occurring poly-silicate minerals. Based on crystal
structure, asbestos minerals are usually divided into two groups - serpentine and amphibole.
Serpentine - The only asbestos mineral in the serpentine group is chrysotile. Chrysotile is
the most widely used form of asbestos, accounting for about 90% of the asbestos used in
commercial products (IARC, 1977). There is no evidence that chrysotile occurs in the
Libby vermiculite deposit, although it may be present in some types of building materials
in Libby.
Amphibole - Five minerals in the amphibole group that occur in the asbestiform
morphology have found limited use in commercial products (IARC, 1977), including
actinolite, amosite, anthophyllite, crocidolite, and tremolite.
At the Libby Site, the form of asbestos that is present in the vermiculite deposit is amphibole
asbestos that for many years was classified as tremolite/actinolite (McDonald et al., 1986a,
Amandus and Wheeler, 1987). More recently, the U.S. Geological Service performed electron
probe micro-analysis and X-ray diffraction analysis of 30 samples obtained from asbestos veins
at the mine (Meeker et al., 2003). Using mineralogical naming rules recommended by Leake et
al. (1997), the results indicate that asbestos at Libby includes a number of related amphibole
types. The most common forms are winchite and richterite, with lower levels of tremolite,
magnesioriebeckite and possibly actinolite.
Because mineralogical name changes that have occurred over the years do not alter the asbestos
material that is present in Libby, and because EPA does not find that there are toxicological data
to distinguish differences in toxicity among these different forms, the EPA does not believe that
it is important to attempt to distinguish among these various amphibole types. Therefore, EPA
simply refers to the mixture as LA.
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5.2 LA IN SOIL
Surface Soil
Figure 5-1 illustrates LA occurrence in OU8 surface soils based on PLM results. A 4-color
scheme is used to indicate the amount of LA present in a sample (additional detail on analytical
reporting is provided in Appendix C):
green = Bin A (non-detect)
yellow = Bin B1 (trace)
orange = Bin B2 (< 1%)
red = Bin C (> 1%)
In this figure, composite samples collected during the 2010 field program are plotted as circles.
Composite samples collected in 2003 and 2005 and referred to as "Legacy Data" are plotted as
triangles (CDM, 2005). Lhe Legacy Data was collected only between Libby and Rainy Creek
Road along SH 37.
Of the 485 non-QC field composite samples, one (HW-00376) has no geographic information
associated with it. Lherefore, it is excluded from Figure 5-1. Lhis sample contained no detectable
LA.
Figure 5-2 illustrates vermiculite occurrence in surface soils based on visible vermiculite
observations which utilized a semi-quantitative approach. Results are shown as squares and are
color-coded based on the visible score (see Section 3.2.1):
green = score of 0 (no visible vermiculite detected)
yellow = score <0.1
orange = score 0.1 to < 0.3
red = score > 0.3
One potential limitation to the approach for presenting visible score data is that the choice of cut-
offs for use in color-coding is arbitrary. If other cut-offs were chosen, the appearance of the
figures would be different. For example, the cutoff for red is 0.3 out of a possible score of 10.
Nevertheless, the figures do provide a useful indication of the degree to which there is variation
across OU8 and locations where higher than average levels have been observed.
Soil PLM results are generally ND to trace except between Libby and Rainy Creek Road where
results are trace to <1% with a few NDs. Relatively higher levels of LA in surface soils between
Libby and the Rainy Creek Road is expected as ore trucks traveled this route during operation of
the mine.
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Visible vermiculite is limited to soil samples collected from the section of SH 37 east of Rainy
Creek Road. This result is unexpected given that soil samples from this area (analyzed by PLM)
contained detectable LA at a frequency that is not elevated relative to the rest of OU8 (Figure 5-
1).
The lack of visible vermiculite in soil samples collected between Libby and Rainy Creek Road is
also unexpected given that soil samples from this area (analyzed by PLM) contained detectable
LA at a frequency that is elevated relative to the rest of OU8 (Figure 5-1). Contrary to these
findings (from the 2010 data set), vermiculite was observed in surface soils along this portion
SH 37 in 2003 and 2005 (CDM, 2005).
Spatial variability may account for some of the differences in the level of visible vermiculite
across sample events. Other differences likely arise from the inherently subjective nature of
vermiculite level category assignments, as well as variations in site conditions between rounds
(e.g., cloud cover vs. sunshine, amount of ground cover, soil moisture, etc.).
5.3 LA IN AIR
ABS Air
The amount of LA fibers released to air will vary depending upon the level of LA in the source
material (e.g., outdoor soil) and the intensity and duration of the disturbance activity. Because of
this, predicting the LA levels in air associated with disturbance activities based only on measured
LA levels in the source material is extremely difficult. Therefore, ABS is considered to be the
most direct way to estimate potential exposures from inhalation of asbestos. ABS results for
ATV riding, brush hogging and grass cutting are presented on Figure 5-3. ABS results for
rotomilling are presented on Figure 5-4.
As seen on Figure 5-3, LA was not detected in air during grass cutting activities. However, LA
was detected during ATV riding and brush hogging. Concentrations associated with these
activities ranged between <0.0020 LA s/cc to 0.0180 s/cc. As discussed in Section 3.1.1, the area
over which these ABS activities were performed was selected based on the presence of LA and
visible vermiculite in surface soils during the 2003 and 2005 sample event (CDM, 2005).
As seen on Figure 5-4, LA was not detected in air samples collected from the rotomilling
machine and skid steer (small front-end loader). Detection limits ranged from 0.0216 s/cc to
0.0025 s/cc.
Based on the surface soil PLM results (Section 5.2), the ABS air sampling was performed in that
portion of OU8 with the highest levels of LA in soil. This suggests that the ABS air samples
discussed in this section represents the worst case condition in the entire OU.
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Stationary Air
As discussed in Section 3.1.2, stationary sampling included ambient air proximal to a person or
piece of equipment conducting ABS activities. Such stationary air samples were collected to
represent conditions in the breathing zone as a surrogate for a personal air sample (e.g., a person
walking on the sidewalk during rotomilling operations on the adjacent street).
For the 2011 OU8 Field Program the following types of stationary air sampling were conducted:
At fixed locations on both sides of the street where rotomilling operations were
conducted. The samplers formed an inner perimeter around the rotomill spaced about a
block (approximately 300 ft) apart.
At selected locations up to 1,000 ft from California Ave., comprising an outer perimeter
(also referred too as ambient air samples in the QAPP; Lockheed Martin, 2010a).
As seen on Figure 5-5, LA was detected in 1 of 52 inner perimeter field samples at a
concentration of 0.0030 s/cc. Detection limits ranged from 0.0017 s/cc to 0.0247 s/cc.
As seen on Figure 5-6, LA was not detected in any outer perimeter (ambient) sample. Detection
limits ranged from 0.0007 S/cc to 0.0.0010 s/cc.
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6.0 CONTAMINANT FATE AND TRANSPORT
The source for LA detected in surface soils and an air sample associated with rotomilling may
include:
Vermiculite ore released from ore trucks by wind or other means during transport along
state and local highways.
Imported fill containing vermiculite mine wastes used during earthwork for roadway
construction or maintenance.
Naturally occurring LA (at background levels) in native soils in roadway ROW.
Aggregate containing vermiculite mine wastes used to manufacture asphalt.
Naturally occurring LA (at background levels) in aggregate used to manufacture asphalt.
Natural background levels of LA at the Site have not been established, although a study is
underway that attempts to do this. Nevertheless, the relatively low levels and uniform
distribution of LA in soils in roadway ROWs (excepting the portion of SH 37 between Libby and
Rainy Creek Road), precludes elimination of natural background conditions as responsible for
some of the LA detected in OU8.
The fate and transport of asbestos containing fibers is dependent on the type of host media (soil,
water, air, etc.), land use, and site characteristics. Asbestos fibers (both serpentine and
amphibole) are indefinitely persistent in the environment. According to the Agency for Toxic
Substances and Disease Registry (ATSDR):
"Asbestos fibers are nonvolatile and insoluble, so their natural tendency is to settle out of
air and water, and deposit in soil or sediment (EPA 1977, 1979c). However, some fibers
are sufficiently small that they can remain in suspension in both air and water and be
transported long distances. For example, fibers with aerodynamic diameters of 0.1 1 /im
can be carried thousands of kilometers in air (Jaenicke 1980), and transport offibers
over 75 miles has been reported in the water of Lake Superior (EPA 1979c). " In
addition, "they are resistant to heat, fire, and chemical and biological degradation "
(ATSDR, 2001).
The primary transport mechanisms for asbestos and asbestos containing material include:
Suspension in air and transport via dispersion
Suspension in water and transport downstream
Asbestos can become suspended in air when asbestos or asbestos containing material is
disturbed. Wind, recreational activities, construction, and site work can disturb material
outdoors.
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Asbestos residence time in the air is determined primarily by particulate thickness; however it is
influenced by other factors such as length and static charge. The average thickness of LA
particles is 0.4 |im and ranges from approximately 0.1 to 1.0 |im. The suspension of LA in air is
measured in "half times" which is the amount of time it will take 50% of LA particles to settle
out of the air column. A particle with a thickness of 0.5 |im has a half time of approximately two
hours, assuming the source of disturbance has been removed (CDM, 2009).
Larger particles will settle faster; a particle of 1 |im has a half time of about 30 minutes. Smaller
LA particles may stay suspended for significantly longer. The typical half time for a 0.15 particle
is close to 40 hours (CDM, 2009)
Activity-specific testing found that the half-time of LA suspended by dropping vermiculite on
the ground was about 30 minutes. LA suspended from disturbing vermiculite insulation settled
within approximately 24 hours (CDM, 2009).
Once suspended, LA moves by dispersion through air. LA concentration will be highest near the
source and will decrease with increasing distance. In outdoor air, wind speed will determine
direction and velocity of LA particle transport. Wind can cause the rapid dispersal of LA from
the source of release.
In water, LA particles can be transported downstream with the current. As in air, larger particles
tend to settle to the bottom more rapidly than smaller particles. Settled particles may be
transported downstream with sediment (CDM, 2009).
LA is insoluble and therefore transport in solution will not occur in surface water, groundwater
or from soils to water. Further, as a particle, LA is not expected to be mobilized from surface or
near surface soils vertically through the soil column to the water table.
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7.0 HUMAN HEALTH RISK ASSESSMENT
An evaluation of potential exposures to and risks from LA will be included in the site-wide risk
assessments for the Libby Asbestos Superfund Site. Site-wide risk assessments are stand-alone
documents which support the FS and ROD. As such, OU-specific risk assessment reports have
not been developed.
The Site-Wide Human Health Risk Assessment will evaluate potential risks to humans from
exposures to LA under a variety of different exposure scenarios, including both indoor and
outdoor exposure scenarios that may occur at the Site. Potential risks will be evaluated both
alone and across multiple exposure scenarios as part of a cumulative exposure assessment.
The Site-Wide Ecological Risk Assessment will evaluate potential risks to aquatic and terrestrial
ecological receptors from exposures to LA that may be present in the environment at the Site.
Refer to the respective site-wide risk assessment reports to provide information on potential
exposures and risks from LA to human and ecological receptors.
Final Remedial Investigation Report
Operable Unit 8, Libby Asbestos NPL Site
7-1
-------
8.0 CONCLUSIONS
The RI reached the following general conclusions:
1. Approximately 80% of PLM results for surface soil samples collected as part of the OU8
RI field program are non-detect (ND) with the remainder containing trace amounts of
LA. Some soil samples collected prior to the establishment of OU8 (legacy data) between
the Libby Mine (Rainy Creek Road) and the town of Libby contained LA at levels
between trace and 1%. Relatively higher levels of LA in surface soils between Libby and
the Rainy Creek Road are expected as ore trucks traveled this route during operation of
the mine.
2. Visible vermiculite is limited to the section of SH 37 east of Rainy Creek Road. This
result is somewhat unexpected given that frequency of LA detections in soil samples in
this area is not elevated relative to the rest of OU8.
3. Predicting LA levels in air associated with disturbance activities based only on measured
LA levels in soil is extremely difficult. Therefore, ABS is considered to be the most
direct way to estimate potential exposures from inhalation of asbestos.
4. Exposure pathways that are thought to be most likely of potential concern in OU8 include
exposure of ATV riders along roadway ROW and exposure of outdoor roadway
maintenance workers performing grass cutting, brush hogging and rotomilling.
5. ABS air sampling was conducted to assess exposure to roadway maintenance workers
and ATV riders. Air sampling pumps were affixed to ATVs and maintenance equipment
during ABS sample events.
6. Air sampling associated with rotomilling also involved fixed sampling stations on both
sides of the street where rotomilling operations were conducted (forming an inner
perimeter). In addition, stationary air samples were collected at various locations up to
1,000 ft from the rotomill, comprising an outer perimeter.
7. An evaluation of potential exposures to and risks from LA will be included in the site-
wide risk assessments for the Libby Asbestos Superfund Site. Site-wide risk assessments
are stand-alone documents which support the FS and ROD
Final Remedial Investigation Report 8-1
Operable Unit 8, Libby Asbestos NPL Site
-------
9.0 REFERENCES
CDM, 2004. Close Support Facility, Soil Preparation Plan, Libby Montana Asbestos Project
Sample Processing. March 2004.
CDM, 2005. Contaminant Screening Study, Libby Asbestos Site, Operable Unit 4, Libby,
Montana, Final Summary Report for the J. Neils Park and Montana State Highway 37
Investigations, Revision 1. December 2005
CDM, 2009. Former Export Plant Site Final Remedial Investigation Report, Operable Unit 1,
Libby Asbestos Site, Libby, MT;-. August 3, 2009.
EPA, 2005. Supplemental Remedial Investigation Quality Assurance Project Plan for Libby,
Montana. Revision 1. U.S. Environmental Protection Agency, Region 8. August 5.
EPA, 2006. Data Quality Assessment: A Reviewer's Guide. EPA QA/G-9R. US EPA, Office of
Environmental Information. EPA/240/B-06/002. February.
EPA, 2010. Libby Asbestos, Region 8, US EPA. Website. Retrieved April 2010 from the World
Wide Web: www.epa.gov/libb vA January 2010.
ISO, 1995. International Organization for Standardization Ambient Air. Determination of
asbestos fibres - Direct-transfer transmission electron microscopy method. ISO 10312:1995(E).
Leake, B.E., Woolley, A.R., Arps, C.E.S., Birch, W.D., Gilbert, M.C., Grice, J.D., Hawthorne,
F.C., Kato, A., Kisch, H.J., Krivovichev, V.G., Linthout, K., Laird, J., Mandarino, J.A., Maresch,
W.V., Nickel, E.H., Rock, N.M.S., Schumacher, J.C., Smith, D.C., Stephenson, N.C.N.,
Ungaretti, L., Whittaker, E.J.W., and Youshi, G., 1997. Nomenclature of amphiboles: Report of
the subcommittee on amphiboles of the International Mineralogical Association, Commission on
new minerals and mineral names: American Mineralogist, v. 82, p. 1019-1037.Lockheed Martin,
2010a, Quality Assurance Project Plan Libby Asbestos Site, Libby, MT, Work Assignment No.:
SERAS-084 - Lockheed Martin Scientific, Engineering, Response and Analytical Services.
August 23, 2010.
Lockheed Martin, 2010b. Trip Report Libby Asbestos Site, Libby, MT, Work Assignment No.:
SERAS-084 - Lockheed Martin Scientific, Engineering, Response and Analytical Services.
November 1, 2010.
Lockheed Martin, 2011. Trip Report Libby Asbestos Site, Libby, MT, Work Assignment No.:
SERAS-084 - Lockheed Martin Scientific, Engineering, Response and Analytical Services. June
24, 2011.
Final Remedial Investigation Report
Operable Unit 8, Libby Asbestos NPL Site
9-1
-------
Meeker, G.P., Bern, A.M., Brown, IK., Lowers, H.A., Sutley, S.J., Hoefen, T.M., and Vance,
J.S., 2003. The composition and morphology of amphibole from the Rainy Creek Complex, near
Libby, Montana. American Mineralogist, 88, 1955.1969.
Tetra Tech, 2007a. Report of Findings, Potentially Asbestos-Containing Soil in MDT Rights of
Way, Traction Sand and Road Aggregate Sources, Collected Road Sweepings, and Sampled
Worker Air Space During Routine Maintenance Activities, Libby Montana. February 21, 2007.
Tetra Tech, 2007b. Report of Findings, Sampled Worker Air Space During Routine Maintenance
Activities, Libby Montana. July 19, 2007.
Western Regional Climate Center (WRCC). Accessed April 23, 2010.
http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl7mt5000
Final Remedial Investigation Report
Operable Unit 8, Libby Asbestos NPL Site
9-2
-------
Tables
-------
TABLE 3-1
Sampling Events Relevant to OU8
Location
Date
Investigation Description
Media Collected and
Analyzed
Reason for Selecting Sample Location
Reference
Montana State Highway 37
2001
Exposures to cleanup workers
and highway users during
remediation activities
Air associated with vehicle and
foot traffic
Opportunistic air sampling (sampler affixed
to personnel and vehicles)
CDM, 2005
Montana State Highway 37
2003
Contaminant Screening Study,
Libby Asbestos Site, Operable
Unit 4
Surface soil (0-6") composite
samples
Systematic surface soil sampling
CDM, 2005
Montana State Highway 37
2005
To resample the 2003
locations in the 0-1" interval
Surface soil (0-1") composite
samples
Co-locate with 2003 locations.
CDM, 2005
Montana State Highway 37
2005
Assess exposure to individuals
working on or near Hwy 37
Stationary air samples
Systematic air sampling along the same
portion of Hwy 37 that was subjected to
soil sampling in 2003
CDM, 2005
MDT Rights-of-Way within 5-
miles of Libby
2006
Assessment to support MDT
Industrial Hygene Policy
Activity-Based Air Samples
(ABS) associated with MDT
maintenance activities
Traction sand and road
aggregate
Road sweepings
Surface soil grab samples
Opportunistic air sampling (sampler affixed
to personnel and equipment);opportunistic
traction sand and aggregate sampling ;
random road sweeping sampling;
systematic soil sampling
Tetra Tech, Inc, 2007 a
Montana State Highway 37
2007
Assessment to support MDT
Industrial Hygene Policy
ABS air samples associated
with MDT maintenance
activities
Opportunistic air sampling (sampler affixed
to personnel and equipment)
Tetra Tech, Inc., 2007 b
OU8 State and Local Highway
embankement
2010
Remedial Investigation Field
Program
ABS Air samples asscoiated
with recreational and MDT
embankement maintenance
activities; surface soil
composite samples
ABS air samples collected between Libby
and Rainy Creek Road (location along Hwy
37 where LA was detected during 2005 soil
sample event); systematic soil sampling
throughout OU8
EPA Scribe Database
OU8 State and Local Highway
pavement
2011
Remedial Investigation Field
Program
ABS Air samples associated
with pavement rotomilling
activities
Oppotunistic air sampling
EPA Scribe Database
-------
Figures
-------
Canada
Montana
tyoming
'?//////.
OU5: Former Stimson Lumber
OU6: Rail Line
OU1: Former Export Plant
OU2: Former Screening Plant
OU3: Mine Site OU7: The Town of Troy
OU4: Libby Homes and Businesses OU8: Roadway
KR HDR Engineering, Inc.
OU Boundaries
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: MARCH, 2011
Figure 1-1
I Miles
-------
Kootenai River
Road
lliSlfewcfflsdWsa.
County Highway 567
Rainy Creek Road
County Highway 482
HDR Engineering, Inc
US HWY
Limits of OU8
State HWY
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
Secondary Roads
Figure 1-2
DATE: MAY, 2011
The limits of OU8 are marked by
thick, gray lines running perpendicular
to the roadway
-------
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O Soil Sample Location
~ ABS Air Sample Location
US HWY
State HWY
Secondary Roads
ABS Area
HDR Engineering, Inc.
OU8 Sampling Locations
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: MAY, 2011
Figure 3-1
-------
Air Sample Locations
| Inner-Perimeter
( ) Outer-Perimeter
HDR Engineering, Inc
vmwermimimrt
Inner and Outer-Perimeter
Air Sample Locations
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: DECEMBER, 2011
ABS measurement unit: LA structures
per cubic centimeter (S/cc)
Miles
-------
River
Highway 37
MM
County Highway 567
Rainy Creek Road
County Highway 482
LA in Surface Soil
Results
# Non-Detect
O Trace
HDR Engineering, Inc
US HWY
LA in Surface Soil
PLM Results
State HWY
Secondary Roads
ABS Area
Detect; >=1%
Legacy Data - 2003 & 2005
A Non-Detect
A Trace
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
NOTE:
Legacy data
locations are
approximated
from CDM report
(see section 3.1.1)
DATE: DECEMBER, 2011
Figure 5-1
Detect; >= 1%
-------
County Highway 567
.
Rainy Creek Road
Highway 37
Kootenai River
Road
Rainy Creek Road
County Highway 482
Visible Vermiculite
Composite Score
a o.oo
¦ 0.01-0.10
~ 0.11-0.29
HDR Engineering, Inc
Visible Vermiculite in
Surface Soils
US HWY
State HWY
Secondary Roads
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
Figure 5-2
DATE: DECEMBER, 2011
See Section 3.2.1 for
discussion of visible
vermiculite scoring
-------
Sample # Result (S/cc)
HW-00598 < 0.0055
HW-00596 < 0.0053
Sample #
HW-00622
HW-00659
HW-00624
HW-00657
Result (S/cc)
<0.0029
<0.0027
<0.0027
<0.0027
Sample # Result (S/cc)
HW-00650 < 0.0029
HW-00652 < 0.0030
Sample # Result (S/cc)
HW-00594 0.0178
HW-00592 0.0120
Sample # Result (S/cc)
HW-00583 < 0.0020
HW-00585 < 0.0021
Sample # Result (S/cc)
HW-00654 < 0.0030
HW-00655 < 0.0078
Sample #
HW-00647
HW-00588
HW-00590
HW-00645
Result (S/cc)
<0.0028
<0.0029
<0.0030
<0.0028
Sample #
HW-00600
HW-00635
HW-00638
HW-00602
Result (S/cc)
0.0028
< 0.0029
< 0.0030
< 0.0030
Sample #
HW-00604
HW-00606
HW-00618
HW-00620
Result (S/cc)
< 0.0029
< 0.0030
< 0.0030
< 0.0028
Sample # Result (S/cc)
HW-00626 0.0180
HW-00628 < 0.0030
Sample # Result (S/cc)
HW-00613 0.0154
HW-00615 0.0087
Sample # Result (S/cc)
HW-00608 < 0.0028
HW-00610 <0.0029
Sample # Result (S/cc)
HW-00630 0.0028
HW-00632 0.0116
ABS Sample Locations
Personnel Task
A ATV Riding
O Brush Hogging
Q Grass Cutting
HDR Engineering, Inc
ABS Air Results
for Bush Hogging, ATV
Riding, and Grass Cutting
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: DECEMBER, 2011
ABS measurement unit: LA structures
per cubic centimeter (S/cc)
-------
Rotomill Samples
Sample #
HW-00752
HW-00767
HW-00785
HW-00795
HW-00824
HW-00852
HW-00868
HW-00891
Result (S/cc)
<0.0030
<0.0028
<0.0031
< 0.0049
< 0.0025
<0.0088
< 0.0029
<0.0216
Skid steer Rotomill Samples
Sample #
HW-00866
HW-00889
Result (S/cc)
<0.0028
<0.0030
Rotomill Track
HDR Engineering, Inc
ABS Air Results
For Rotomilling
WoQtewaiiR'imiu
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: DECEMBER, 2011
Measurement unit: LA structures
per cubic centimeter (S/cc)
Miles
-------
Sample # Result (S/cc)
HW-00850 < 0.0029
HW-00888 < 0.0028
Sample # Result (S/cc)
HW-00783 < 0.0027
HW-00815 <0.0029
Sample # Result (S/cc)
HW-00779 < 0.0025
HW-00811 <0.0025
Sample # Result (S/cc)
HW-00781 < 0.0053
HW-00813 <0.0034
Sample # Result (S/cc)
HW-00846 < 0.0025
HW-00884 < 0.0028
/ Sample# Result (S/cc)
II HW-00777 < 0.0026
^ HW-00809 < 0.0026
Sample # Result (S/cc)
HW-00775 < 0.0027
HW-00807 < 0.0025
; Sample # Result (S/cc)
HW-00844 < 0.0247
HW-00882 < 0.0029
Sample # Result (S/cc)
HW-00842 < 0.0027
HW-00880 < 0.0028
Sample# Result (S/cc)
HW-00848 < 0.0029
HW-00886 < 0.0028
Sample # Result (S/cc)
HW-00771 < 0.0029
HW-00803 < 0.0027
Sample # Result (S/cc)
HW-00773 < 0.0028
HW-00805 < 0.0027
Sample # Result (S/cc)
HW-00838 < 0.0026
HW-00864 < 0.0029
Sample # Result (S/cc)
HW-00840 < 0.0028
HW-00877 < 0.0030
Sample # Result (S/cc)
HW-00765 < 0.0023
HW-00799 < 0.0027
Sample # Result (S/cc)
HW-00801 < 0.0028
Sample # Result (S/cc)
HW-00836 < 0.0027
HW-00862 < 0.0030
Sample # Result (S/cc)
HW-00834 <0.0017
HW-00860 0.0030
Sample # Result (S/cc)
HW-00763 < 0.0028
HW-00797 < 0.0030
Sample # Result (S/cc)
HW-00761 < 0.0030
HW-00793 < 0.0025
Sample # Result (S/cc)
HW-00832 < 0.0028
HW-00858 < 0.0030
Sample # Result (S/cc)
HW-00830 < 0.0024
HW-00856 < 0.0029
Sample # Result (S/cc)
HW-00759 < 0.0028
HW-00791 < 0.0029
Sample # Result (S/cc)
HW-00757 < 0.0027
HW-00789 < 0.0029
Sample# Result (S/cc)
HW-00828 < 0.0025
HW-00854 < 0.0030
Sample # Result (S/cc)
HW-00755 < 0.0030
HW-00787 < 0.0030
Stationary Air Sample
Location
HDR Engineering, Inc
Inner-Perimeter (ABS)
Rotomilling Air Results
WoQtewaiiR'imiu
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: DECEMBER, 2011
Measurement unit: LA structures
per cubic centimeter (S/cc)
Miles
-------
. I'll-ilk-1
Sample # Result (S/cc)
HW-00744 <0.0010
Sample #
HW-00746
HW-00820
HW-00873
Result (S/cc)
<0.0009
<0.0008
<0.0008
Sample #
HW-00745
HW-00819
HW-00872
Result (S/cc)
< 0.0010
< 0.0008
< 0.0008
Sample #
HW-00743
HW-00818
HW-00871
Result (S/cc)
<0.0009
<0.0008
<0.0008
Sample #
HW-00747
HW-00821
HW-00874
Result (S/cc)
<0.0009
<0.0008
<0.0007
Sample # Result (S/cc)
HW-00742 < 0.0009
HW-00870 < 0.0008
Sample # Result (S/cc)
HW-00749 <0.0010
Sample #
HW-00748
HW-00822
HW-00875
Result (S/cc)
<0.0009
<0.0008
<0.0008
Sample #
HW-00741
HW-00816
HW-00869
Result (S/cc)
<0.0009
<0.0008
<0.0008
Sample #
HW-00750
HW-00823
HW-00876
Result (S/cc)
<0.0009
<0.0008
<0.0008
Stationary Air Sample
Location
HDR Engineering, Inc,
vmwermimimrt
Outer-Perimeter
(Ambient Air) Results
Remedial Investigation
Operable Unit 8 - Roadway Right of Way
DATE: DECEMBER, 2011
Measurement unit: LA structures
per cubic centimeter (S/cc)
Miles
-------
Appendices
-------
Appendix A
Data Quality Assessment
-------
VERIFICATION SUMMARY REPORT
FOR OPERABLE UNIT 8
LIBBY ASBESTOS SUPERFUND SITE
(Based on Scribe database provided on 1/27/11)
Prepared for:
U.S. Environmental Protection Agency Region 8
1595 Wynkoop Street
Denver, Colorado 80202
^a8r^
PFtort^
Prepared by:
SRC, Inc.
Denver, CO
February 1,2011
-------
CONTENTS
TEM Consistency Review and Data Transfer Verification Report
PLM Consistency Review and Data Transfer Verification Report
FSDS Data Transfer Verification Report
Attachment la
Attachment lb
Attachment 2
Attachment 3a
ATTACHMENTS
TEM Verification (Analytical and Results Information)
TEM Verification (Raw Structure Information)
PLM-VE Verification
Air FSDS Verification
Attachment 3b
Attachment 3c
Air FSDS Verification (Pump Information)
Soil FSDS Verification
-------
TEM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
Date: 2/1/11 Prepared by: Erin Kelly (SRC)
OU8 TEM Data Verification
SUMMARY OF FINDINGS AND DATA QUALITY IMPLICATIONS
A verification of a minimum of 10% of the TEM results was performed based on the OU8 Scribe Database
provided by ESAT on 1/27/11 in accord with Standard Operating Procedure EPA-LIBBY-09 (rev IV No
discrepancies were discovered upon review of the original hand-written laboratory bench sheets to determine if the
raw structure data were recorded in accord with ISO 10312 counting rules and SAP stopping rules. In addition, no
errors were discovered when checks were performed to ensure that the data from the bench sheet were transferred
into the Scribe Database without error or omission.
Recommendations for future review and verification: No future verification is recommended.
-------
TEM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
TEM-ISO 10312 SELECTION AND CONSISTENCY REVIEW RESULTS
Summary of available analyses:
Analyst, Lab
Number of TEM-ISO 10312 Analyses
Number of Analyses Selected for Review
Detect Nc
n-Detect
Total
Detect
Non-Detect
Total
E. Wyatt-Pescador, EMSL 27
8
26
34
2
2
4
Goal
Actual
Selected Total
4
4_
Selected Detects
2
2_
Selected Non-Detects
2
2_
Detailed summary of bench sheet consistency review -
Number of analyses reviewed: 4 (100% of total analyses selected)
If not all analyses could be reviewed, provide a brief explanation for why: N/A
Number of analyses with recording issues identified: 0 (0% of total analyses reviewed)
Types of recording issues identified (indicate the number of analyses):
Reported structure types are inconsistent with ISO guidance
Primary and/or total columns are not populated correctly
NAM structures are recorded and not identified as non-countable
Fibers recorded as countable do not meet aspect ratio criteria (LB-000016)
Mineral class designation is missing or inconsistent
Structure comments are inconsistent with LB-000066
Structure comments are inconsistent with recorded data
Structure attributes in the database do not match the bench sheet
Do the recording issues identified appear to be associated with a particular analyst or laboratory? Yes (No
If yes, identify the analyst and/or laboratory:
-------
TEM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
DATA TRANSFER VERIFICATION RESULTS
Number of analyses verified1: 4 (100% of total analyses selected)
Number of analyses with data transfer issues identified: 0 (0% of total analyses reviewed)
Types of data transfer issues identified:
Incorrect/missing information on analysis details (e.g., lab job number, analysis date, filter status)
F-factor calculation is incorrect or inputs are missing
Air volume or dust area reported by laboratory is inconsistent with field value
Number of grid openings counted is incorrect
Sensitivity calculation is incorrect or inputs are missing
Total number of countable LA structures is incorrect
Do the data transfer issues identified appear to be associated with a particular analyst or laboratory? Yes (No)
If yes, identify the analyst and/or laboratory:
Comments: No errors were discovered in the verification process.
ISSUE RESOLUTION AND STATUS
No resolutions are required. Attachments la and lb contain the analyses that were verified and the information that
was verified. Attachment la contains the analytical and results information and Attachment lb contains the raw
structure information.
1 Only those analyses that have passed the bench sheet consistency review are included in the data transfer verification.
-------
PLM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
Date: 2/1/11 Prepared by: Erin Kelly (SRC)
OU8 PLM- VE Data Verification
SUMMARY OF FINDINGS AND DATA QUALITY IMPLICATIONS
A verification of a minimum of 10% of the PLM-VE results was performed based on the OU8 Scribe Database
provided by ESAT on 1/27/11 in accord with draft Standard Operating Procedure for PLM verification. A review
of the original laboratory PLM bench sheets and verification of the transfer of results from the bench sheets into the
Scribe Database was performed.
Recommendations for future review and verification: Because the issues identified are not likely to impact data
interpretation, no future verification is recommended.
-------
PLM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
PLM-VE SELECTION AND CONSISTENCY REVIEW RESULTS
Summary of available analyses:
Analyst, Lab
Number of PLM-VE Analyses
Number of Analyses Selected for Review
Detect
Non-Detect
(Bin A)
Total Dei
ect
Non-Detect
(Bin A)
Total
A. Goncalves, ESATR8
11
102
113
2
11
13
N. Fischer, ESATR8
18
96
114
2
10
12
N. MacDonald, ESATR8
14
105
119
2
11
13
T. Oliver, ESATR8
44
144
188
5
15
20
Total
87
447
534
11 47
58
Selected Total
Selected Detects
Selected Non-Detects
Detailed summary of bench sheet consistency review -
Number of analyses reviewed: 58 (100% of total analyses selected)
If not all analyses could be reviewed, provide a brief explanation for why:
Number of analyses with recording issues identified: 0 (0% of total analyses reviewed)
Goal Actual
58 _ 58
11 _ _11_
47 47
Do the recording issues identified appear to be associated with a particular analyst or laboratory? Yes (No
If yes, identify the analyst and/or laboratory:
-------
PLM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
DATA TRANSFER VERIFICATION RESULTS
Number of analyses verified1: 58 (100% of total analyses selected)
Number of analyses with data transfer issues identified: 5 (8.6% of total analyses verified)
Types of data transfer issues identified:
6 analyses had incorrect/missing information on analysis details (e.g.. lab job number, analysis date)
Do the data transfer issues identified appear to be associated with a particular analyst or laboratory? (^esT) No
If yes, identify the analyst and/or laboratory: N. Fisher (ESATR8)
Comments: The lab sample IDs in Lab Job Number A101383 require revision throughout the lab job. In addition,
the initials for the analyst in Lab Job Number A101373. Lab Sample IDs A101373-6 through -10 are unclear. Thev
appear to be "ND". not "NF". Clarification on the benchsheets is required.
ISSUE RESOLUTION AND STATUS
The issues discovered in the verification process are summarized in the comments above and in Table 1 provided
below. In addition. Attachment 2 contains a list of all analyses that were verified and the information that was
verified.
Table 1. Summary of Issues
SampleNo
Lab Job Number
Verification Notes
HW-00087
A101373
Analyst's initials require clarification.
HW-00121
A101383
Lab Sample IDs are incorrect on benchsheets.
1 Only those analyses that have passed the bench sheet consistency review are included in the data transfer verification.
-------
FSDS DATA TRANSFER VERIFICATION REPORT
Date: 2/1/11 Prepared by: Erin Kelly (SRC)
OU8 FSDS Data Verification
SUMMARY OF FINDINGS A NI) DATA QUALITY IMPLICATIONS
A verification of the sample information for analyses selected for PLM-VE and TEM verification was performed
based on the OU8 Scribe Database provided by ESAT on 1/27/11. Several issues were discovered, some with the
potential to impact data interpretation. The main issues discovered involve discrepancies in the visible vermiculite
information and sample date as well as omission of detailed pump information.
Recommendations for future review and verification: Because some issues identified could potentially impact data
interpretation, additional verification is at the discretion of the data managers.
-------
FSDS DATA TRANSFER VERIFICATION REPORT
FSDS SELECTION
A verification of all FSDS information for all 62 analyses selected for PLM-VE and TEM verification was
performed.
DATA TRANSFER VERIFICATION RESULTS
Number of samples verified: 64 (100% of total analyses selected)
Number of samples with data transfer issues identified: 10 (15.6% of total samples verified)
Types of data transfer issues identified:
1 Sam pie Date
3 Location Type
1 LocationID
3 Location Description
1 Visible Vermiculite Information
1 Sam pie CompositeYN
1 Sam pie Aliquots
Comments: There were several data transfer issues that require clarification on the benchsheets and/or revision to
the database. An inconsistency between the visible vermiculite information and the number of aliquots of the soil
sample was one of the more important issues discovered. As a result, a review of this information as presented in
the database was performed for all samples. There were 3 more samples that contained this inconsistency in the
database. A review of the logbook notes is recommended in order to confirm the appropriate values for these
fields. In addition, it was discovered in the verification process that the raw data for computing volume are not
available in the database. Because only 4 air samples were verified during this effort, it was not inconvenient to
verify this information manually based on the information contained in the FSDS forms. However, it is
recommended that this information be collected electronically in future data collection efforts so that the raw data
may be verified and also be available to data users that do not have the FSDS forms available to them.
ISSUE RESOLUTION AND STATUS
The issues discovered in the verification process are summarized in the comments above and in Table 1 provided
below. In addition. Attachments 3a - 3c contain all samples that were verified and what information was verified.
Attachment 3a contains the air FSDS verification. Attachment 3b contains the air pump information verification,
and Attachment 3c contains the soil FSDS verification.
-------
FSDS DATA TRANSFER VERIFICATION REPORT
Table 1. Summary of Issues
Samp No
Verification Notes
HW-00229
Sampling date is 7/28/10 on FSDS form.
HW-00129
Sample aliquots differ from number of vis verm observations.
HW-00130
Sample aliquots differ from number of vis verm observations.
HW-00133
Sample aliquots differ from number of vis verm observations.
HW-00082
Sample aliquots differ from number of vis verm observations.
HW-00087
FSDS has the location type as sampling location, not sampling point.
HW-00095
FSDS has the location type as sampling location, not sampling point.
HW-00639
Location description is null on FSDS form.
HW-00642
Location description is null on FSDS form.
HW-00644
Location description is null on FSDS form.
HW-00091
Sample composite in "N" on FSDS and "Y in database.
HW-00173
Location© is "AD-OU8NA" in database and "NA" on FSDS form.
HW-00404
Sample Venue is not circled on FSDS form.
-------
ATTACHMENT 1a. TEM VERIFICATION (Analytical and Results Information)
PersonnelTa
SampleQuan
Analysis
Quantity
Analysis
AnalysisL
AnalysisAnalystNa
AnalysisMet
AnalysisLab
AnalysisLabSam
AnalysisPrep
Analysis Filte
AnalysisGO
AnalysisGO
AnalysisGO
AnalysisFFa
ResultMiner
SENSITIVIT
STRUCTCN
STRUCTCO
Verifier's
Verification
Samp_No
sk
tity
Analyzed
Date
abID
me
hod
JobNumber
plelD
Method
rStatus
Comments
AnalysisEFA
Counted
Chrys
Size
ctor
alClass
Y
T
NC
Initials
Notes
HW-00583
Brush hoggin
192
192
10/8/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001351
271001351-0001
Direct
Analyzed
385
77
77
0.013
1
CH
0.00200321
0
0 EK
HW-00583
Brush hoggin
192
192
10/8/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001351
271001351-0001 Direct
Analyzed
385
77
77
0.013 1
LA
0.00200321
0
0 EK
HW-00583
Brush hoggin
192
192
10/8/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001351
271001351-0001
Direct
Analyzed
385
77
77
0.013
1
OA
0.00200321
0
0 EK
HW-00594
Brush hoggin
384
384
9/27/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001129
271001129-0004
Direct
Analyzed
385
26
26
0.013
1
CH
0.00296628
0
0 EK
HW-00594
Brush hoggin
384
384
9/27/10
EMSL27
E. Wyatt-Pescador TEM-ISO
271001129
271001129-0004 Direct
Analyzed
385
26
26
0.013
1 LA
0.00296628
6 0.01779771 EK
HW-00594
Brush hoggin
384
384
9/27/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001129
271001129-0004
Direct
Analyzed
385
26
26
0.013
1
OA
0.00296628
0
0 EK
HW-00606
ATV riding
400
400
10/14/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001354
271001354-0004
Direct
Analyzed
385
25
25
0.013
1
CH
0.00296154
0
0 EK
HW-00606
ATV riding
400
400
10/14/10
EMSL27
E. Wyatt-Pescador TEM-ISO
271001354
271001354-0004 Direct
Analyzed
385
25
25
0.013 1
LA
0.00296154
o
0 EK
HW-00606
ATV riding
400
400
10/14/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001354
271001354-0004
Direct
Analyzed
385
25
25
0.013
1
OA
0.00296154
0
0 EK
HW-00626
Brush hoggin
366
366
10/25/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001352
271001352-0004
Direct
Analyzed
385
27
27
0.013
1
CH
0.0029969
0
0 EK
HW-00626
Brush hoggin
366
366
10/25/10
EMSL27
E. Wyatt-Pescador TEM-ISO
271001352
271001352-0004 Direct
Analyzed
385
27
27
0.013 1
LA
0.0029969
6 0.01798141 EK
HW-00626
Brush hoggin
366
366
10/25/10 EMSL27
E. Wyatt-Pescador TEM-ISO
271001352
271001352-0004
Direct
Analyzed
385
27
27
0.013
1
OA
0.0029969
0
0 EK
-------
ATTACHMENT 1b. TEM VERIFICATION (Raw Structure Information)
Structure! D
Samp_No
AnalysisID
Grid
GridOpening
Structure
Type
Mineral
Class
Primary
Total
Length
Width
AR
Structure Co
mment
Verifier's
Initials
Verification
Notes
271001351-0001 ISO D-1
HW-00583
271001351-0001 ISO D
A1
E2
ND
EK
271001351-0001 JSO_D-2
HW-00583
271001351-0001J SO_D
A1
E4
ND
EK
271001351-0001 ISO D-3
HW-00583
271001351-0001 ISO D
A1
E6
ND
EK
271001351-0001 ISO D-4
HW-00583
271001351-0001 ISO D
A1
E8
ND
EK
271001351-0001 ISO D-5
HW-00583
271001351-0001 ISO D
A1
E10
ND
EK
271001351-0001 JSO_D-6
HW-00583
271001351-0001J SO_D
A1
F1
ND
EK
271001351-0001 ISO D-7
HW-00583
271001351-0001 ISO D
A1
F3
ND
EK
271001351-0001 ISO D-8
HW-00583
271001351-0001 ISO D
A1
F5
ND
EK
271001351-0001 JSO_D-9
HW-00583
271001351-0001J SO_D
A1
F7
ND
EK
271001351-0001 ISO D-10
HW-00583
271001351-0001 ISO D
A1
F9
ND
EK
271001351-0001 ISO D-11
HW-00583
271001351-0001 ISO D
A1
G2
ND
EK
271001351-0001 ISO D-12
HW-00583
271001351-0001 ISO D
A1
G4
ND
EK
271001351-0001 JSO_D-13
HW-00583
271001351-0001J SO_D
A1
G6
ND
EK
271001351-0001 ISO D-14
HW-00583
271001351-0001 ISO D
A1
G8
ND
EK
271001351-0001 ISO D-15
HW-00583
271001351-0001 ISO D
A1
G10
ND
EK
271001351-0001 ISO D-16
HW-00583
271001351-0001 ISO D
A1
H1
ND
EK
271001351-0001 JSO_D-17
HW-00583
271001351-0001_ISO_D
A1
H3
ND
EK
271001351-0001 ISO D-18
HW-00583
271001351-0001 ISO D
A1
H5
ND
EK
271001351-0001 ISO D-19
HW-00583
271001351-0001 ISO D
A1
H7
ND
EK
271001351-0001 ISO D-20
HW-00583
271001351-0001 ISO D
A1
H9
ND
EK
271001351-0001 JSO_D-21
HW-00583
271001351-0001J SO_D
A1
12
ND
EK
271001351-0001 ISO D-22
HW-00583
271001351-0001 ISO D
A1
14
ND
EK
271001351-0001 ISO D-23
HW-00583
271001351-0001 ISO D
A1
16
ND
EK
271001351-0001 ISO D-24
HW-00583
271001351-0001 ISO D
A1
18
ND
EK
271001351-0001 JSO_D-25
HW-00583
271001351-0001 _ISO_D
A1
110
ND
EK
271001351-0001 ISO D-26
HW-00583
271001351-0001 ISO D
A2
B2
ND
EK
271001351-0001 ISO D-27
HW-00583
271001351-0001 ISO D
A2
B4
ND
EK
271001351-0001 ISO D-28
HW-00583
271001351-0001 ISO D
A2
B6
ND
EK
271001351-0001 JSO_D-29
HW-00583
271001351-0001J SO_D
A2
B8
ND
EK
271001351-0001 ISO D-30
HW-00583
271001351-0001 ISO D
A2
B10
ND
EK
271001351-0001 ISO D-31
HW-00583
271001351-0001 ISO D
A2
C1
ND
EK
271001351-0001 ISO D-32
HW-00583
271001351-0001 ISO D
A2
C3
ND
EK
271001351-0001 JSO_D-33
HW-00583
271001351-0001_ISO_D
A2
C5
ND
EK
271001351-0001 ISO D-34
HW-00583
271001351-0001 ISO D
A2
C7
ND
EK
271001351-0001 ISO D-35
HW-00583
271001351-0001 ISO D
A2
C9
ND
EK
271001351-0001 ISO D-36
HW-00583
271001351-0001 ISO D
A2
D2
ND
EK
271001351-0001 JSO_D-37
HW-00583
271001351-0001_ISO_D
A2
D4
ND
EK
271001351-0001 ISO D-38
HW-00583
271001351-0001 ISO D
A2
D6
ND
EK
271001351-0001 ISO D-39
HW-00583
271001351-0001 ISO D
A2
D8
ND
EK
271001351-0001 ISO D-40
HW-00583
271001351-0001 ISO D
A2
D10
ND
EK
271001351-0001 JSO_D-41
HW-00583
271001351-0001J SO_D
A2
E1
ND
EK
271001351-0001 ISO D-42
HW-00583
271001351-0001 ISO D
A2
E3
ND
EK
271001351-0001 ISO D-43
HW-00583
271001351-0001 ISO D
A2
E5
ND
EK
271001351-0001 ISO D-44
HW-00583
271001351-0001 ISO D
A2
E7
ND
EK
271001351-0001 JSO_D-45
HW-00583
271001351-0001J SO_D
A2
E9
ND
EK
271001351-0001 ISO D-46
HW-00583
271001351-0001 ISO D
A2
F2
ND
EK
271001351-0001 ISO D-47
HW-00583
271001351-0001 ISO D
A2
F4
ND
EK
271001351-0001 ISO D-48
HW-00583
271001351-0001 ISO D
A2
F6
ND
EK
271001351-0001 JSO_D-49
HW-00583
271001351-0001J SO_D
A2
F8
ND
EK
271001351-0001 ISO D-50
HW-00583
271001351-0001 ISO D
A2
F10
ND
EK
271001351-0001 ISO D-51
HW-00583
271001351-0001 ISO D
A2
G1
ND
EK
271001351-0001 ISO D-52
HW-00583
271001351-0001 ISO D
A2
G3
ND
EK
271001351-0001 JSO_D-53
HW-00583
271001351-0001J SO_D
A2
G5
ND
EK
271001351-0001 ISO D-54
HW-00583
271001351-0001 ISO D
A2
G7
ND
EK
271001351-0001 ISO D-55
HW-00583
271001351-0001 ISO D
A2
G9
ND
EK
271001351-0001 ISO D-56
HW-00583
271001351-0001 ISO D
A3
F9
ND
EK
271001351-0001 JSO_D-57
HW-00583
271001351-0001J SO_D
A3
F7
ND
EK
271001351-0001 ISO D-58
HW-00583
271001351-0001 ISO D
A3
F5
ND
EK
271001351-0001 ISO D-59
HW-00583
271001351-0001 ISO D
A3
F3
ND
EK
271001351-0001 ISO D-60
HW-00583
271001351-0001 ISO D
A3
F1
ND
EK
271001351-0001 JSO_D-61
HW-00583
271001351-0001 _ISO_D
A3
E10
ND
EK
271001351-0001 ISO D-62
HW-00583
271001351-0001 ISO D
A3
E8
ND
EK
271001351-0001 ISO D-63
HW-00583
271001351-0001 ISO D
A3
E6
ND
EK
271001351-0001 ISO D-64
HW-00583
271001351-0001 ISO D
A3
E4
ND
EK
271001351-0001 JSO_D-65
HW-00583
271001351-0001 _ISO_D
A3
E2
ND
EK
271001351-0001 ISO D-66
HW-00583
271001351-0001 ISO D
A3
D9
ND
EK
271001351-0001 ISO D-67
HW-00583
271001351-0001 ISO D
A3
D7
ND
EK
271001351-0001 ISO D-68
HW-00583
271001351-0001 ISO D
A3
D5
ND
EK
271001351-0001 JSO_D-69
HW-00583
271001351-0001_ISO_D
A3
D3
ND
EK
271001351-0001 ISO D-70
HW-00583
271001351-0001 ISO D
A3
D1
ND
EK
271001351-0001 ISO D-71
HW-00583
271001351-0001 ISO D
A3
C10
ND
EK
271001351-0001 ISO D-72
HW-00583
271001351-0001 ISO D
A3
C8
ND
EK
271001351-0001 JSO_D-73
HW-00583
271001351-0001_ISO_D
A3
C6
ND
EK
271001351-0001 ISO D-74
HW-00583
271001351-0001 ISO D
A3
C4
ND
EK
271001351-0001 ISO D-75
HW-00583
271001351-0001 ISO D
A3
C2
ND
EK
271001351-0001 ISO D-76
HW-00583
271001351-0001 ISO D
A3
B9
ND
EK
271001351-0001 JSO_D-77
HW-00583
271001351-0001J SO_D
A3
B7
ND
EK
271001129-0004 ISO D-1
HW-00594
271001129-0004 ISO D
B5
H9
ND
EK
271001129-0004 ISO D-2
HW-00594
271001129-0004 ISO D
B5
H7
ND
EK
271001129-0004 ISO D-3
HW-00594
271001129-0004 ISO D
B5
H5
F
LA
1
1
40.1
3.25
12.3384615
NaK; WRTA
EK
271001129-0004J SO_D-4
HW-00594
271001129-0004_ISO_D
B5
H3
ND
EK
271001129-0004 ISO D-5
HW-00594
271001129-0004 ISO D
B5
H1
ND
EK
271001129-0004 ISO D-6
HW-00594
271001129-0004 ISO D
B5
D9
F
LA
2
2
84.5
1
84.5
NaK; WRTA
EK
271001129-0004J SO_D-7
HW-00594
271001129-0004_ISO_D
B5
D7
ND
EK
-------
ATTACHMENT 1b. TEM VERIFICATION (Raw Structure Information)
Structure! D
Samp_No
AnalysisID
Grid
GridOpening
Structure
Type
Mineral
Class
Primary
Total
Length
Width
AR
Structure Co
mment
Verifier's
Initials
Verification
Notes
271001129-0004J SO_D-8
HW-00594
271001129-0004_ISO_D
B5
D5
ND
EK
271001129-0004 ISO D-9
HW-00594
271001129-0004 ISO D
B5
D3
ND
EK
271001129-0004 ISO D-10
HW-00594
271001129-0004 ISO D
B5
D1
ND
EK
271001129-0004 ISO D-11
HW-00594
271001129-0004 ISO D
B5
C8
ND
EK
271001129-0004J SO_D-12
HW-00594
271001129-0004_l SO_D
B5
C6
ND
EK
271001129-0004 ISO D-13
HW-00594
271001129-0004 ISO D
B5
C4
F
LA
3
3
12.4
0.4
31
NaK; WRTA
EK
271001129-0004 ISO D-14
HW-00594
271001129-0004 ISO D
B6
G5
ND
EK
271001129-0004 ISO D-15
HW-00594
271001129-0004 ISO D
B6
G3
ND
EK
271001129-0004J SO_D-16
HW-00594
271001129-0004J SO_D
B6
G1
ND
EK
271001129-0004 ISO D-17
HW-00594
271001129-0004 ISO D
B6
E9
ND
EK
271001129-0004 ISO D-18
HW-00594
271001129-0004 ISO D
B6
E7
ND
EK
271001129-0004 ISO D-19
HW-00594
271001129-0004 ISO D
B6
E5
F
LA
4
4
13.5
1
13.5
NaK; WRTA
EK
271001129-0004J SO_D-2 0
HW-00594
271001129-0004J SO_D
B6
E3
ND
EK
271001129-0004 ISO D-21
HW-00594
271001129-0004 ISO D
B6
E1
ND
EK
271001129-0004 ISO D-22
HW-00594
271001129-0004 ISO D
B6
C9
ND
EK
271001129-0004 ISO D-23
HW-00594
271001129-0004 ISO D
B6
C7
ND
EK
271001129-0004J SO_D-24
HW-00594
271001129-0004_l SO_D
B6
C5
ND
EK
271001129-0004 ISO D-25
HW-00594
271001129-0004 ISO D
B6
C3
F
LA
5
5
23.75
0.7
33.9285714
NaK; WRTA
EK
271001129-0004 ISO D-26
HW-00594
271001129-0004 ISO D
B6
C1
MD11
6
EK
271001129-0004 ISO D-27
HW-00594
271001129-0004 ISO D
B6
C1
MF
LA
6
7
1.1
6.36363636
NaK; WRTA
EK
271001354-0004J SO_D-1
HW-00606
271001354-0004J SO_D
L4
F2
ND
EK
271001354-0004 ISO D-2
HW-00606
271001354-0004 ISO D
L4
F4
ND
EK
271001354-0004 ISO D-3
HW-00606
271001354-0004 ISO D
L4
F6
ND
EK
271001354-0004 ISO D-4
HW-00606
271001354-0004 ISO D
L4
F8
ND
EK
271001354-0004_ISO_D-5
HW-00606
271001354-0004J SO_D
L4
F10
ND
EK
271001354-0004 ISO D-6
HW-00606
271001354-0004 ISO D
L4
G1
ND
EK
271001354-0004 ISO D-7
HW-00606
271001354-0004 ISO D
L4
G3
ND
EK
271001354-0004 ISO D-8
HW-00606
271001354-0004 ISO D
L4
G5
ND
EK
271001354-0004_ISO_D-9
HW-00606
271001354-0004J SO_D
L4
G7
ND
EK
271001354-0004 ISO D-10
HW-00606
271001354-0004 ISO D
L4
G9
ND
EK
271001354-0004 ISO D-11
HW-00606
271001354-0004 ISO D
L4
H6
ND
EK
271001354-0004 ISO D-12
HW-00606
271001354-0004 ISO D
L4
H8
ND
EK
271001354-0004J SO_D-13
HW-00606
271001354-0004J SO_D
L4
H10
ND
EK
271001354-0004 ISO D-14
HW-00606
271001354-0004 ISO D
L5
E9
ND
EK
271001354-0004 ISO D-15
HW-00606
271001354-0004 ISO D
L5
E7
ND
EK
271001354-0004 ISO D-16
HW-00606
271001354-0004 ISO D
L5
E5
ND
EK
271001354-0004J SO_D-17
HW-00606
271001354-0004J SO_D
L5
E3
ND
EK
271001354-0004 ISO D-18
HW-00606
271001354-0004 ISO D
L5
E1
ND
EK
271001354-0004 ISO D-19
HW-00606
271001354-0004 ISO D
L5
D10
ND
EK
271001354-0004 ISO D-20
HW-00606
271001354-0004 ISO D
L5
D8
ND
EK
271001354-0004JSO_D-21
HW-00606
271001354-0004J SO_D
L5
D6
ND
EK
271001354-0004 ISO D-22
HW-00606
271001354-0004 ISO D
L5
D4
ND
EK
271001354-0004 ISO D-23
HW-00606
271001354-0004 ISO D
L5
D2
ND
EK
271001354-0004 ISO D-24
HW-00606
271001354-0004 ISO D
L5
C3
ND
EK
271001354-0004_ISO_D-25
HW-00606
271001354-0004J SO_D
L5
C1
ND
EK
271001352-0004 ISO D-1
HW-00626
271001352-0004 ISO D
J4
D9
ND
EK
271001352-0004 ISO D-2
HW-00626
271001352-0004 ISO D
J4
D7
ND
EK
271001352-0004 ISO D-3
HW-00626
271001352-0004 ISO D
J4
D5
F
LA
1
1
11.5
0.7
16.4285714
WRTA/NaK; I
EK
271001352-0004J SO_D-4
HW-00626
271001352-0004J SO_D
J4
D3
MD10
2
EK
271001352-0004 ISO D-5
HW-00626
271001352-0004 ISO D
J4
D3
MF
LA
2
4.75
0.25
19
WRTA/NaK; I
EK
271001352-0004 ISO D-6
HW-00626
271001352-0004 ISO D
J4
D1
ND
EK
271001352-0004 ISO D-7
HW-00626
271001352-0004 ISO D
J4
C10
ND
EK
271001352-0004J SO_D-8
HW-00626
271001352-0004_ISO_D
J4
C8
ND
EK
271001352-0004 ISO D-9
HW-00626
271001352-0004 ISO D
J4
C6
ND
EK
271001352-0004 ISO D-10
HW-00626
271001352-0004 ISO D
J4
C4
ND
EK
271001352-0004 ISO D-11
HW-00626
271001352-0004 ISO D
J4
C2
ND
EK
271001352-0004J SO_D-12
HW-00626
271001352-0004_l SO_D
J4
B9
ND
EK
271001352-0004 ISO D-13
HW-00626
271001352-0004 ISO D
J4
B7
ND
EK
271001352-0004 ISO D-14
HW-00626
271001352-0004 ISO D
J4
B5
ND
EK
271001352-0004 ISO D-15
HW-00626
271001352-0004 ISO D
J4
B3
F
LA
3
3
10
1.7
5.88235294
WRTA/NaK; I
EK
271001352-0004J SO_D-16
HW-00626
271001352-0004_l SO_D
J4
B1
ND
EK
271001352-0004 ISO D-17
HW-00626
271001352-0004 ISO D
J5
E10
F
LA
4
4
7
0.25
28
WRTA/Nak; 1
EK
271001352-0004 ISO D-18
HW-00626
271001352-0004 ISO D
J5
E8
ND
EK
271001352-0004 ISO D-19
HW-00626
271001352-0004 ISO D
J5
E6
ND
EK
271001352-0004J SO_D-2 0
HW-00626
271001352-0004J SO_D
J5
E4
ND
EK
271001352-0004 ISO D-21
HW-00626
271001352-0004 ISO D
J5
E2
ND
EK
271001352-0004 ISO D-22
HW-00626
271001352-0004 ISO D
J5
D9
F
LA
5
5
6
0.2
30
WRTA/NaK; 1
EK
271001352-0004 ISO D-23
HW-00626
271001352-0004 ISO D
J5
D7
F
LA
6
6
7.75
0.4
19.375
WRTA/NaK
EK
271001352-0004J SO_D-24
HW-00626
271001352-0004_ISO_D
J5
D5
ND
EK
271001352-0004 ISO D-25
HW-00626
271001352-0004 ISO D
J5
D3
ND
EK
271001352-0004 ISO D-26
HW-00626
271001352-0004 ISO D
J5
D1
ND
EK
271001352-0004 ISO D-27
HW-00626
271001352-0004 ISO D
J5
C4
ND
EK
271001352-0004J SO_D-2 8
HW-00626
271001352-0004_ISO_D
J5
C2
ND
EK
-------
ATTACHMENT 2. PLM-VE VERIFICATION
SampleNo
Taa
Lab Job
Number
AnalysisLabS
amplelD
Date
Analyzed
AnalysisLabSa
mplelD
AnalysisAppeara
nee
LA
OA
C
Opitcal Property Data for Detected Samples
Verifier's
Initials
Verification Notes
FBRCOLOR
ELONG
PLEOCH
EXTINCT
RIALPHA
RIGAMMA
BIREF
HABIT
HW-00009
FG1
A101371
A101371-9
12/9/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00021
FG1
A101381
A101381-1
12/13/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00023
FG1
A101381
A101381-3
12/13/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00026
FG1
A101381
A101381-6
12/13/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00029
FG1
A101381
A101381-9
12/13/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00039
FG1
A101381
A101381-19
12/14/10
T. Oliver
Brown soil, fine
Tr
ND
ND
Colorless
Positive
No
Inclined
1.618
1.64
Medium
Prismatic
EK
HW-00046
FG1
A101379
A101379-6
12/13/10
A. Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00055
FG1
A101379
A101379-15
12/14/10
A. Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00057
FG1
A101379
A101379-17
12/15/10
A. Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00070
FG1
A101372
A101372-10
12/9/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00075
FG1
A101372
A101372-15
12/9/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00076
FG1
A101372
A101372-16
12/10/10
A Goncalves
Brown soil, fine
Tr
ND
ND
Colorless
Positive
No
Inclined
1.619
1.627
Low
Prismatic
EK
HW-00080
FG1
A101372
A101372-20
12/10/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00083
FG1
A101373
A101373-3
12/9/10
N. Fischer
Brown soil, fine
Tr
ND
ND
Tan
Positive
No
Inclined
1.619
1.636
Medium
FIBER BUNDLE
EK
HW-00087
FG1
A101373
A101373-7
12/9/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
analyst's initials unclear
HW-00091
FG1
A101373
A101373-11
12/9/10
N. MacDonald
Tan soil, fine
ND
ND
ND
EK
HW-00094
FG1
A101373
A101373-14
12/9/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00095
FG1
A101373
A101373-15
12/9/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00104
FG1
A101382
A101382-4
12/13/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00121
FG1
A101383
A101383-1
12/14/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
lab sample id is incorrect on benchsheet.
HW-00129
FG1
A101383
A101383-9
12/15/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
lab sample id is incorrect on benchsheet.
HW-00132
FG1
A101383
A101383-12
12/15/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
lab sample id is incorrect on benchsheet.
HW-00137
FG1
A101383
A101383-17
12/15/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
lab sample id is incorrect on benchsheet.
HW-00150
FG1
A101384
A101384-10
12/15/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00151
FG1
A101384
A101384-11
12/15/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00161
FG1
A101385
A101385-1
12/18/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00168
FG1
A101385
A101385-8
12/18/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00173
FG1
A101385
A101385-13
12/20/10
T. Oliver
Tan soil, fine
ND
ND
ND
EK
HW-00179
FG1
A101385
A101385-19
12/20/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00184
FG1
A101386
A101386-4
12/21/10
N. MacDonald
Brown soil, fine
Tr
ND
ND
Blue
Positive
No
Inclined
1.625
1.641
Medium
FIBER BUNDLE
EK
HW-00195
FG1
A101386
A101386-15
12/21/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00200
FG1
A101386
A101386-20
12/21/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00206
FG1
A101387
A101387-6
12/17/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00208
FG1
A101387
A101387-8
12/17/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00216
FG1
A101387
A101387-16
12/20/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00218
FG1
A101387
A101387-18
12/20/10
A Goncalves
Brown soil, fine
Tr
ND
ND
Colorless
Positive
No
Inclined
1.635
1.641
Low
FIBER BUNDLE
EK
HW-00229
FG1
A101388
A101388-9
12/17/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
HW-00231
FG1
A101388
A101388-11
12/17/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
HW-00240
FG1
A101388
A101388-20
12/20/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
HW-00243
FG1
A101389
A101389-3
12/21/10
T. Oliver
Brown soil, fine
Tr
ND
ND
GRAY
Positive
No
Inclined
1.617
1.638
Medium
FIBER BUNDLE
EK
HW-00249
FG1
A101389
A101389-9
12/21/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00260
FG1
A101389
A101389-20
12/22/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00266
FG1
A101390
A101390-6
12/21/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00271
FG1
A101390
A101390-11
12/21/10
A Goncalves
Brown soil, fine
ND
ND
ND
EK
HW-00272
FG1
A101390
A101390-12
12/22/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00273
FG1
A101390
A101390-13
12/22/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00294
FG1
A101391
A101391-14
12/23/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
HW-00304
FG1
A101392
A101392-4
12/29/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00312
FG1
A101392
A101392-12
12/29/10
N. MacDonald
Brown soil, fine
ND
ND
ND
EK
HW-00315
FG1
A101392
A101392-15
12/29/10
N. MacDonald
Brown soil, fine
Tr
ND
ND
Blue
Positive
No
Inclined
1.619
1.638
Medium
FIBER BUNDLE
EK
HW-00347
FG1
A101394
A101394-7
12/29/10
N. Fischer
Brown soil, fine
ND
ND
ND
EK
HW-00358
FG1
A101394
A101394-18
12/30/10
N. Fischer
Brown soil, fine
Tr
ND
ND
Colorless
Positive
No
Inclined
1.619
1.635
Medium
Prismatic
EK
HW-00382
FG1
A101396
A101396-2
12/30/10
T. Oliver
Brown soil, fine
Tr
ND
ND
Colorless
Positive
No
Inclined
1.617
1.637
Medium
Prismatic
EK
HW-00393
FG1
A101396
A101396-13
1/3/11
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00404
FG1
A101397
A101397-4
1/4/11
N. MacDonald
Tan soil, fine
ND
ND
ND
EK
HW-00639
FG1
A101254
A101254-3
10/25/10
T. Oliver
Brown soil, fine
ND
ND
ND
EK
HW-00642
FG1
A101254
A101254-6
10/25/10
T. Oliver
Brown soil, fine
Tr
ND
ND
Blue
Positive
No
Inclined
1.638
1.643
Low
FIBER BUNDLE
EK
HW-00644
FG1
A101254
A101254-8
10/25/10
T. Oliver
Brown soil, fine
Tr
ND
ND
GRAY
Positive
No
Inclined
1.642
1.65
Low
FIBER BUNDLE
EK
-------
ATTACHMENT 3a. AIR FSDS VERIFICATION
Samp_No
Sample
Venue
Sample
Air Type
Personnel Task
SampleDate
Location
Sub_Location
Location Description
Sample Type
Sample
Quantity
Sample
Quantity
Units
Sample Field
Comments
Verifier's
Initials
Verification Notes
HW-00583
Outdoor
PA-ABS
Brush hogging
07-Sep-10
XX-002392
Tractor Back; Hi; MM2 to First driveway; Hwy 37 N
Right of Way-only
Field Sample
192
L
EK
Verifier manually checked
volume; info not available
in DB.
HW-00594
Outdoor
PA-ABS
Brush hogging
07-Sep-10
XX-002394
Tractor Back; Hi; Driveway across from Amerigas; Hwy 37 N
Right of Way-only
Field Sample
384
L
EK
Verifier manually checked
volume; info not available
in DB.
HW-00606
Outdoor
PA-ABS
ATV riding
08-Sep-10
XX-002397
Hwy 37 mm 4.4 to 5.5 West Side Only Off Road Follow Hi
Right of Way-only
Field Sample
400
L
Pump 10 for 28
minsthen pump
2 for 12 mins
EK
Verifier manually checked
volume; info not available
in DB.
HW-00626
Outdoor
PA-ABS
Brush hogging
09-Sep-10
XX-002401
MM 4.5 to 4.0 Hwy 37 W Tractor Front Hi
Right of Way-only
Field Sample
366
L
EK
Verifier manually checked
volume; info not available
in DB.
-------
ATTACHMENT 3b. AIR FSDS VERIFICATION (PUMP INFORMATION)
Panel A: Pump Information Data Entry
Samp_No
Start Flow
End Flow
Start_DateTime
Stop_DateTime
Vol Interval
HW-00583
3
3
9/7/10 9:40
9/7/10 10:44
192
HW-00594
3
3
9/7/10 10:53
9/7/10 12:00
201
HW-00594
3
3
9/7/10 12:23
9/7/10 13:24
183
HW-00606
10
10
9/8/10 8:59
9/8/10 9:27
280
HW-00606
10
10
9/8/10 10:37
9/8/10 10:49
120
HW-00626
3
3
9/9/10 9:00
9/9/10 11:02
366
Panel B: Volume Calculation
Samp_No
Volume
Verifier's
Initials
Verification Notes
HW-00583
192
EK
HW-00594
384
EK
HW-00606
400
EK
HW-00626
366
EK
-------
ATTACHMENT 3c. SOIL FSDS VERIFICATION
Samp_No
SampleD
ate
Sample
Venue
LocationType
Location
Sub Location
LocationDescription
Visible Vermiculite
SampleType
Sample
Compos
iteYN
SampleAl
iquots
Samp_De
pth
Samp_De
pth_To
SampleField
Comments
Verifier's
Initials
Verification Notes
None
Low
Medium
High
Comments
HW-00168
7/26/10
Outdoor
Sampling Point
XX-002072
South Shoulder East of Easy St
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00179
7/26/10
Outdoor
Sampling Point
XX-002081
South Shoulder at Quartz Creek Rd
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00184
7/26/10
Outdoor
Sampling Point
XX-002086
South Shoulder near 2455 K. River Rd
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00195
7/27/10
Outdoor
Sampling Point
XX-002095
North Shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00200
7/27/10
Outdoor
Sampling Point
XX-002100
North shoulder West of mile 1 marker
Riqht of Way-only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00206
7/27/10
Outdoor
Sampling Point
XX-002106
North shoulder West of mile 2 marker
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00208
7/27/10
Outdoor
Sampling Point
XX-002108
North shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00216
7/27/10
Outdoor
Sampling Point
XX-002114
North Shoulder 3803 Kootenai River Rd
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00218
7/27/10
Outdoor
Sampling Point
XX-002116
North Shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00229
7/29/10
Outdoor
Sampling Point
XX-002127
North Shoulder by Cliffside Drive
Riqht of Way-only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
Sampling date is 7/28/10 on FSDS form
HW-00231
7/28/10
Outdoor
Sampling Point
XX-002129
North Shoulder approaching end
Right of Way - only
8
0
0
0
F
eld Sample
Yes
8
0
3
EK
HW-00104
7/23/10
Outdoor
Sampling Point
XX-002014
Pipe Creek Rd (West Shoulder)
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00121
7/24/10
Outdoor
Sampling Point
XX-002029
Pipe Creek Rd (West Shoulder) South of Sanitary Lan
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00129
7/24/10
Outdoor
Sampling Point
XX-002036
Pipe Creek Rd (West Shoulder)
Right of Way - only
10
0
0
0
F
eld Sample
Yes
6
0
3
No Grass
EK
Sample aliquots differ from number of vis verm observations.
HW-00130
7/24/10
Outdoor
Sampling Point
XX-002037
Pipe Creek Rd (West Shoulder)
Right of Way - only
10
0
0
F
eld Sample
Yes
7| 0
3
no grass
Sample aliquots differ from number of vis verm observations.
HW-00132
7/24/10
Outdoor
Sampling Point
XX-002038
Pipe Creek Rd (West Shoulder) South of Power Statio
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00133
7/24/10
Outdoor
Sampling Point
XX-002039
Pipe Creek Rd (West Shoulder) North of 37
Right of Way - only
10
0
0
cut of grass
F
eld Sample
Yes
6
0
3
Out of Grass
Sample aliquots differ from number of vis verm observations.
HW-00137
7/24/10
Outdoor
Sampling Point
XX-002043
Pipe Creek Rd (East Shoulder)
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00150
7/25/10
Outdoor
Sampling Point
XX-002056
Pipe Creek Rd (East Shoulder)
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00151
7/25/10
Outdoor
Sampling Point
XX-002056
Pipe Creek Rd (East Shoulder)
Right of Way - only
10
0
0
0
F
eld Duplicai
Yes
10
0
3
EK
HW-00161
7/25/10
Outdoor
Sampling Point
XX-002065
Pipe Creek Rd East Shoulder (Mile Marker 5) North oi
Riqht of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00312
7/30/10
Outdoor
Sampling Point
XX-002202
Begin N of Concrete Barriers
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00315
7/30/10
Outdoor
Sampling Point
XX-002205
N Bound 2 near Cedar Creek
Right of Way - only
7
0
0
0
F
eld Sample
Yes
7
0
3
Guard Rail
EK
HW-00347
7/31/10
Outdoor
Sampling Point
XX-002233
South bound side
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00358
8/1/10
Outdoor
Sampling Point
XX-002244
Kootenai River Outfitters
Riqht of Way-only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00382
8/2/10
Outdoor
Sampling Point
XX-002265
Coles Rd
Right of Way - only
10
0
0
0
F
eld Duplicai
Yes
10
0
3
EK
HW-00393
8/3/10
Outdoor
Sampling Point
XX-002275
Begin N end of rail
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00240
7/28/10
Outdoor
Sampling Point
XX-002136
SE Bound Farm to Market near McKays St
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00243
7/28/10
Outdoor
Sampling Point
XX-002139
NW Bound Granny's Garden Rd
Riqht of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00249
7/28/10
Outdoor
Sampling Point
XX-002145
NW bound 1657 Farm to Market
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00260
7/29/10
Outdoor
Sampling Point
XX-002154
SE Bound Begin NW of Evans Rd
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00266
7/29/10
Outdoor
Sampling Point
XX-002160
SE Bound by Mine by Mile 3
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00271
7/29/10
Outdoor
Sampling Point
XX-002165
NW Bound Across from Mine
Riqht of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00272
7/29/10
Outdoor
Sampling Point
XX-002166
SE Bound
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00273
7/29/10
Outdoor
Sampling Point
XX-002167
SE Bound
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00294
7/29/10
Outdoor
Sampling Point
XX-002186
SE Bound NW Corner of Meadowlark
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00304
7/30/10
Outdoor
Sampling Point
XX-002194
NW Bound
Riqht of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00009
7/20/10
Outdoor
Sampling Point
XX-001929
Hwy 37 East of (south Shoulder) mile marker 7
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00021
7/21/10
Outdoor
Sampling Point
XX-001939
Hwy 37 (south Shoulder) West of mile marker 11
Right of Way - only
6
4
0
0
Small amo
F
eld Sample
Yes
10
0
3
EK
HW-00023
7/21/10
Outdoor
Sampling Point
XX-001941
Hwy 37 (South Shoulder) West of 11501 Hwy 37
Right of Way - only
8
2
0
0
Small amo
F
eld Sample
Yes
10
0
3
EK
HW-00026
7/21/10
Outdoor
Sampling Point
XX-001944
Hwy 37 (South shoulder) West of Mile marker 12
Riqht of Way - only
5
5
0
0
Small amo
F
eld Sample
Yes
10
0
3
EK
HW-00029
7/21/10
Outdoor
Sampling Point
XX-001947
Hwy 37 (South Shoulder)J[Mile Marker 13)
Right of Way - only
7
3
0
0
small amoi
F
eld Sample
Yes
10
0
3
EK
HW-00039
7/21/10
Outdoor
Sampling Point
XX-001956
Hwy 37 (South Shoulder)
Right of Way - only
5
5
0
0
Small amo
F
eld Sample
Yes
10
0
3
EK
HW-00046
7/21/10
Outdoor
Sampling Point
XX-001962
Hwy 37 (South shoulder) West of mile post 17
Right of Way - only
9
1
0
0
Small amo
F
eld Sample
Yes
10
0
3
EK
HW-00055
7/22/10
Outdoor
Sampling Point
XX-001969
Highway 37 North shoulder
Riqht of Way-only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00057
7/22/10
Outdoor
Sampling Point
XX-001971
Highway 37 North shoulder East of River Bend
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00070
7/22/10
Outdoor
Sampling Point
XX-001983
Highway 37 north shoulder west of mile post 11
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00075
7/22/10
Outdoor
Sampling Point
XX-001987
Highway 37 North shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00076
7/23/10
Outdoor
Sampling Point
XX-001988
Highway 37 North shoulder West of 10000 Highway 3
Riqht of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00080
7/23/10
Outdoor
Sampling Point
XX-001991
Highway 37 North shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00082
7/23/10
Outdoor
Sampling Point
XX-001993
Highway 37 North shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
7| 0
3
Sample aliquots differ from number of vis verm observations.
HW-00083
7/23/10
Outdoor
Sampling Point
XX-001994
Highway 37 North shoulder East of National Forest Bo
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00087
7/23/10
Outdoor
^^^^¦XX-001998
Highway 37 North shoulder mile marker 8
Riqht of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
FSDS has the location type as sampling location, not sampling point.
HW-00094
7/23/10
Outdoor
Sampling Point |xX-002004
Highway 37 North shoulder
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
HW-00095
7/23/10
Outdoor
Sampling Point
XX-002005
Highway 37 North shoulder; 6884-6814 Highway 37
Right of Way - only
10
0
0
0
F
eld Sample
Yes
10
0
3
EK
FSDS has the location type as sampling location, not sampling point.
HW-00639
9/9/10
Outdoor
Sampling Point
XX-002392
HWY 37 E SHOULDER MM 2 TO DRIVEWAY WITH I
Right of Way - only
30
0
0
0
F
eld Sample
Yes
30
0
3
NO FIELD Bl
EK
Location description is null on FSDS form
HW-00642
9/9/10
Outdoor
Sampling Point
XX-002395
HWY 37 E SHOULDER MM 3.0 TO -MM 3.5
Riqht of Way - only
30
0
0
0
F
eld Sample
Yes
30
0
3
NO FIELD Bl
EK
Location description is null on FSDS form
HW-00644
9/9/10
Outdoor
Sampling Point
XX-002397
HWY 37 W SHOULDER MM 4.4 TO RAINEY CREEK
Right of Way - only
30
0
0
0
F
eld Sample
Yes
30
0
3
EK
Location description is null on FSDS form
HW-00091
7/23/10
NA
NA
AD-OU8NA
Field Blank (Sand)
NA
F
eld Blank
Yes
0
0
0
EK
Sample composite in "N" on FSDS and "Y in database.
HW-00173
7/26/10
NA
NA
AD-OU8NA
Field Blank
NA
F
eld Blank
No
0
0
0
EK
LocationID is "AD-OU8NA" in database and "NA" on FSDS form.
HW-00404
8/3/10
NA BNA
AD-OU8NA
Field Blank-Sand
NA
F
eld Blank
No
0
0
0
EK
Sample Venue is not circled on FSDS form.
-------
Appendix B
EPA Scribe Database
(A copy of the Database may be requested by contacting
the Region 8 EPA Records Center)
-------
Appendix C
Asbestos Analysis Methods and Data Reduction
Techniques
-------
ASBESTOS ANALYSIS METHODS AND DATA REDUCTION TECHNIQUES
1 Asbestos Mineralogy
Asbestos is the generic name for the fibrous habit of a broad family of naturally occurring poly-
silicate m inerals. B ased o n cr ystal s tructure, asbestos m inerals ar e u sually divided i nto t wo
groups: serpentine and amphibole.
Serpentine'. The only asbestos mineral in the serpentine group is chrysotile. Chrysotile is the
most w idely us ed f orm of a sbestos, a ccounting for a bout 90% of t he a sbestos us ed i n
commercial products (IARC 1977). There is no evidence that chrysotile occurs in the Libby
vermiculite deposit, although it may be present in some types of building materials in Libby.
Amphiboles: F ive minerals in the amphibole group that occur in the asbestiform habit have
found limited use in commercial products (IARC 1977), including:
- actinolite
- amosite
- anthophyllite
- crocidolite
- tremolite
At the Libby site, the form of asbestos that is present in the vermiculite deposit is an amphibole
asbestos that for many years was classified as tremolite/actinolite (e.g., McDonald et al 1986a,
Amandus and Wheeler 1987). M ore recently, the U.S. Geological Service (USGS) performed
electron p robe m icro-analysis an d X-ray di ffraction a nalysis of 30 s amples obt ained f rom
asbestos ve ins a tt he mine ( Meeker e t al. 2003). U singm ineralogical na mingr ules
recommended by Leake et al. (1997), the results indicate that the asbestos at Libby includes a
number of related amphibole types. T he most common forms are winchite and richterite, with
lower levels of tremolite, actinolite, and magnesioriebeckite. B ecause the mineralogical name
changes t hat h ave o ccurred o ver t he years d o n ot al ter t he as bestos m aterial t hat i s p resent i n
Libby, and because EPA does not find that there are toxicological data to distinguish differences
in toxicity among these different forms, the EPA does not believe that it i s important to attempt
to di stinguish a mong t hese va rious a mphibole t ypes. T herefore, E PA s imply r efers t o t he
mixture as Libby Amphibole (LA) asbestos.
2 Measurement Techniques for Asbestos in Air
In t he pa st, t he m ost c ommon t echnique f or measuring a sbestos i n a ir w as ph ase contrast
microscopy (PCM). In this technique, air is drawn through a filter and airborne particles become
deposited on the face of the filter. All structures that have a length greater than 5 um and have
an aspect ratio (the ratio of length to width) of 3:1 or more are counted as PCM fibers. The limit
-------
of r esolution of P CM i s a bout 0.25 um , s o pa rticles t hinner t han t his ar e generally n ot
observable.
A key limitation of PCM is that particle discrimination is based only on size and shape. Because
of this, it i s not pos sible to classify asbestos particles by mineral type, or even to di stinguish
between asbestos and non-asbestos particles. For this reason, nearly all samples of air collected
in L ibby a re a nalyzed by transmission electron m icroscopy (TEM). This method operates at
higher m agnification (typically a bout 20,000x ) a nd he nee i s a ble t o d etect s tructures m uch
smaller than can b een s een b y P CM. In ad dition, TEM i nstruments are fitted with acces sories
that allow each particle to be classified according to mineral type.
3 Transmission Electron Microscopy (TEM)
3.1 Sample Preparation
If air samples were not deemed to be overloaded by particulates1, filters are directly prepared for
analysis b y t ransmission e lectron m icroscopy ( TEM) i n a ccord w ith t he pr eparation m ethods
provided in ISO 10312 (ISO 1995).
If ai r s amples ar e d eemed t o b e o verloaded, s amples ar e p repared i ndirectly (either w ith o r
without ashing as determined by the analyst) in accord with the procedures in SOP EPA-LIBBY-
08. In brief, rinsate or ashed residue from the original filter is suspended in water and sonicated.
An aliquot of this water is applied to a second filter which is then used to prepare a set of TEM
grids. Reported air concentrations for indirectly prepared samples incorporate a dilution factor,
or F-factor (see Section 3.4 below).
3.2 Sample A nalysis
Air samples collected as partofthe OU8 sampling programs were analyzed by TEM in basic
accord with the counting and recording rules specified in ISO 10312 ( ISO 1995), and certain
project-specific c ountingr ule m odifications. T hese m odifications i ncluded c hanging t he
recording rule to include structures with an aspect ratio >3:1.
When a sample is analyzed by TEM, the analyst records the size (length, width) and mineral type
of each individual asbestos structure that i s observed. M ineral type i s determined by Selected
Area E lectron D iffraction ( SAED) a nd E nergy Dispersive S pectroscopy ( EDS), a nd each
structure is assigned to one of the following four categories:
LA Libby-class amphibole. Structures having an amphibole S AED pattern and an
elemental composition similar to the range of fiber types observed in ores from
1 Overloaded i s de fined a s >25% obs curation on the majority of t he grid ope nings ( see Libby Laboratory
Modification #LB-000016 and SOP EPA-LIBBY-08).
-------
the Libby mine (Meeker et al. 2 003). This is a sodic tremolitic solid solution
series o f min erals in eluding a ctinolite, tr emolite, w inchite, a nd r ichterite, w ith
lower amounts of magnesio-arfedsonite and edenite/ferro-edenite.
OA Other amphibole-type asbestos fibers. Structures ha ving a n amphibole S AED
pattern and an elemental composition that is not similar to fiber types from the
Libby mine. Examples include crocidolite, amosite, and anthophyllite. There is
presently no evidence that these fibers are associated with the Libby mine.
C Chrysotile fibers. Structures having a serpentine SAED pattern and an elemental
composition characteristic of chrysotile. There is presently no evidence that these
fibers are associated with the Libby mine.
NAM Non-asbestos material. These m ay i nclude non -asbestos m ineral fibers s uch as
gypsum, glass, or clay, a nd m ay also i nclude va rious t ypes of or ganic a nd
synthetic fibers derived from carpets, hair, etc.
For the purposes of this report, air concentrations are based on countable LA structures only (i.e.,
results for other amphibole-type asbestos and chrysotile are not discussed).
3.3 Estimation of PCME
For the purposes of computing risk estimates, it is necessary to utilize the results from a TEM
analysis to estimate what would have been detected had the sample been analyzed by PCM. This
is because available toxicity information is usually based on workplace studies that utilized PCM
as the primary method for analysis. For convenience, structures detected under TEM that meet
the recording rules for PCM (i.e., length > 5 um, width > 0.25 um, aspect ratio > 3:1) are referred
to as PCM-equivalent (PCME) structures.
There are two alternative approaches available for expressing units of PCME s/cc. The first (and
most di rect) a pproach is to ex press t he co ncentration o f each s ample i n t erms o f t he P CME
structures observed in that sample. The second approach is to express the concentration of LA in
each sample in terms of the total LA in that sample, and then multiply the total LA concentration
by a v alue that represents the average fraction of total LA structures that meet PCME counting
rules. For this evaluation, the first approach was followed.
In this document, all air concentrations will be reported in units of PCME LA s/cc.
-------
3.4 Calculation of Air Concentrations
The concentration of LA in air is given by:
Air Concentration (s/cc) = N S
where:
N = Number of structures observed
S = Sensitivity (cc"1)
For air, the sensitivity is calculated as:
§ EFA
GO Ago V 1000 F
where:
S = Sensitivity for air (cc"1)
EFA = Effective area of the filter (mm )
GO = Number of grid openings examined
Ago = Area of a grid opening (mm )
V = Volume of air passed through the filter (L)
1000 = Conversion factor (cc/L)
F = Fraction of primary filter deposited on secondary filter (indirect preparation only)
3.5 Estimating Confidence Bounds
For an Individual Sample
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 around a count of N structures is given by:
LB = /4 CHIINV[0.025, 2N+1]
UB = /4 CHIINV[0.975, 2N+1]
where:
LB = Lower bound on the 95% confidence interval on N
UB = Upper bound on the 95% confidence interval on N
CHIINV = Inverse chi-squared cumulative distribution function
N = Number of structures observed
As N i ncreases, t he a bsolute w idth of t he c onfidence i nterval i ncreases, but t he r elative
uncertainty [ expressed as t he co nfidence i nterval ( CI) di vided b y t he obs erved va lue (N)]
decreases. This is illustrated in the table below.
Relationship Between Number of Structures
Observed and Relative Uncertainty
Number of
Structures
Observed
(N)
2.5%
Lower
Bound N
(LB)
97.5%
Upper
Bound N
(UB)
95%
Confidence
Interval
Range (CI)
[UB-LB]
Relative
Uncertainty
[CI/N]
0
0.00
2.51
2.51
+Infinity
1
0.11
4.67
4.57
457%
2
0.42
6.42
6.00
300%
3
0.84
8.01
7.16
239%
5
1.91
10.96
9.05
181%
10
5.14
17.74
12.60
126%
20
12.61
30.28
17.67
88%
50
37.54
65.35
27.81
56%
75
59.44
93.46
34.02
45%
100
81.82
121.08
39.26
39%
2.5% LB = 0.5 CHIINV[0.975, (2 I\
f+1)]
97.5% UB = 0.5 CHIINV[0.025, (2 N+l)]
-------
Using t his approach, t he e quation f or c alculation of t he uppe r a nd 1 ower bounds on the a ir
concentration of asbestos structures is:
Air Concentration (s/cc) = (LB or UB) S
where:
LB or UB = Number of structures based on lower bound (LB) or upper bound (UB)
S = Sensitivity (cc"1 for air)
Across Multiple Samples
Calculation of the unc ertainty bounds a round t he average of a group of a sbestos s amples i s
complicated by the fact that the between-sample variability in the measured concentration values
includes t he b etween-sample v ariability th at a rises f rom b oth a nalytical me asurement error i n
individual samples and from between-sample temporal or spatial variability. E PA has not yet
developed a method for calculating uncertainty bounds around the mean of asbestos data sets, so
no uncertainty bounds are provided in this report for mean values (EPA, 2008 ). However, it is
important to recognize that the values are uncertain, and that actual values might be either higher
or lower than reported.
4 Polarized Light Microscopy Analysis (PLM)
4.1 Sample Preparation
Soil s amples co llected as part of t he O U8 sampling pr ograms w ere pr epared for a nalysis i n
accord with SOP ISSI-LIBBY-01 as specified in the CDM Close Support Facility (CSF) Soil
Preparation Plan (SPP) (CDM, 2004). In brief, each soil sample is dried and sieved through a Vi
inch s creen. P articles retained o n t he s creen (if an y) are r eferred t o as the "co arse" f raction.
Particles passing through the screen are referred to as the fine fraction, and this fraction is ground
by passing it th rough a plate grinder. T he resulting material is referred to as the "fine ground"
fraction. T he fine ground fraction i s split into four equal aliquots; one aliquot is submitted for
analysis and the remaining aliquots are archived at the CSF.
4.2 Sample A nalysis
Soil samples collected at the Libby Site are analyzed using polarized light microscopy (PLM).
The co arse f ractions w ere examined u sing s tereomicroscopy, an d any p articles o f asbestos
(confirmed by PLM) were removed and weighed in accord with SRC-LIBBY-01 (referred to as
2 EPA. 2008. F ramework for I nvestigating Asbestos-Contaminated S ites. R eport pr epared by t he Asbestos
Committee oftheTechnical Review Workgroupofthe Office of Solid Waste andEmergency Response, U.S.
Environmental protection Agency. OSWER Directive #9200.0-68.
-------
"PLM-Grav"). Of the 508 soil field samples collected during these OU8 sampling program, only
4 samples had a coarse fraction.
The fine ground aliquots were analyzed using a Libby-specific PLM method using visual area
estimation, as detailed in SOP SRC-LIBBY-03. For convenience, this method is referred to as
"PLM-VE".
PLM-VE is a semi-quantitative method that utilizes site-specific LA reference materials to allow
assignment of fine ground samples into one of four "bins", as follows:
Bin A (ND): non-detect
Bin B1 (Trace): detected at levels lower than the 0.2% LA reference material
Bin B2 (<1%): detected at 1 evels 1 ower than the 1 % LA reference m aterial but higher
than the 0.2% LA reference material
Bin C: LA detected at levels greater than or equal to the 1% LA reference material
5 Soil Visual Inspection
At the time of soil sample collection for PLM analysis, the sampling team performed a visual
inspection of the displaced soil at each sampling point to determine if visible vermiculite was
present i n a ccord w ith S OP C DM-LIBBY-06. A s emi-quantitative e stimate ( none, 1 ow,
medium , high) of the amount of visible vermiculite present was noted for each sampling point.
For c omposite s amples, a count of t he num ber of s ampling poi nts a ssigned t o each vi sible
vermiculite r anking w as r ecorded o n t he Field S ample D ata S heet (FSDS) i n t he s ample
comments (e.g., 18 none [X], 6 low [L], 4 medium [M], 2 high [Ft]).
There are several alternative ways that this visual inspection data can be used to characterize the
level of vermiculite contamination (and presumptive LA contamination) in an area.
Option 1: Present/Absent
The simplest strategy classifies an area either as "Vis if all sampling points in the composite
were assigned a va lue of" none", or as " Vis + " i f one or m ore of t he sampling poi nts w ere
assigned a value of "low", "medium", or "high".
A potential limitation to this ranking strategy is that it d oes not account for differences in the
amount or frequency of visible vermiculite detections. For example, an area with 1 "low" point
3 The visual inspection SOP C DM-LIBBY-06 u ses t he t erminology "intermediate" t o r efer t o t he "medium"
classification. F or t he p urposes o f th is d ocument, the te rm "medium" i s r etained t o co rrespond with t he
accompanying field documentation.
-------
and 29 " none" points and an area with 24 " medium" points and 5 " high" points would both be
ranked as "Vis +".
Option 2: Detection Frequency
In t his a pproach, an ar ea i s as signed a v alue eq ual t o t he d etection f requency b y visible
inspection. For example, an area with 1 "low" point and 29 "none" points would receive a value
of 1/30 (3.3%), while an area with 24 "medium" points and 5 "high" points would receive a
score of 29/30 ( 97%).
While this approach does account for the frequency of visible vermiculite, it does not consider
the amount vermiculite obs erved. In other words, an ABS area with 5 " low" poi nts and 25
"none" points would have the same detection frequency of 5/30 (17%) as an ABS area with 5
"high" points and 25 "none" points.
Option 3: Amount-Weighted Score
In this approach, both the frequency and the level of vermiculite are considered. This is achieved
by a ssigning a w eighting f actor t o each 1 evel, w here t he w eighting f actors ar e i ntended t o
represent the relative levels of vermiculite in each category. As presented in SOP CDM-LIBBY-
06, the guidelines for assigning levels are as follows:
None = No flakes of vermiculite detected observed within the inspection point.
Low = A maximum of a few flakes of vermiculite observed within the inspection
point.
Medium/High = Vermiculite easily observed throughout the inspection point, including the
surface. A ranking of High is reserved for samples that are 50% or more
vermiculite. Others (<50%) are assigned a ranking of Medium.
Based o n t hese d escriptions, t he w eighting factors t hat w ere u sed t o calculate s cores a re as
follows:
Visible
Vermiculite Level
(LD
Weighting
factor (W;)
None
0
Low
1
Medium
3
High
10
-------
The score is then the weighted sum of the observations for the area:
Score =
x
This va lue c an r ange f rom z ero ( all poi nts a re "none") t o a m aximum of 10 ( all poi nts a re
"high"). For example, an area with 1 "low" point and 29 "none" points would receive a value of
1/30 = 0.033, w hile an area with 24 " medium" points and 5 " high" would receive a score of
(24 3 + 510)/ 30 = 4.13.
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Denver, CO 80202
p. (303) 764-1520
f. (303) 860-7139
2060 Briargate Parkway
Suite 1 20
Colorado Springs, CO 80920
p. (719) 272-8800
f. (719) 272-8801
41 9 Canyon Blvd.
Suite 316
Fort Collins, CO 80524
p. (970) 419 - 4388
f. (970) 419 - 4389
FINAL Remedial Investigation Report
Operable Unit 8
Libby Asbestos National Priorities List
June 201 3
5*CQA United States
Environmental Protection Agency
"...to protect human health and to safeguard the natural environment..'
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