FINAL Remedial
Investigation Report
Operable Unit 5
Libby Asbestos National Priorities List Site
Libby, Montana
QA United States
|M Environmental Protection Agency
.(o protect human health and to safeguard the natural environment.
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FINAL
Remedial Investigation Report
Operable Unit 5
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
1.4 015 HISTORY AM) DESCRIPTION 1-3
1.5 REGULATORY HISTORY 1-5
1.6 PREVIOUS RESPONSE ACTIONS AT OU5 1-5
1.7 PREVIOUS INVESTIGATIONS & REPORTS 1-7
1.8 I.IBBY GROUNDWATER SITE 1-7
2.0 SITE CHARACTERISTICS 2-1
2.1 CLIMATE 2-1
2.2 GEOLOGY 2-1
2.3 HYDROLOGY AM) HYDROGEOLOGY 2-2
3.0 SAMPLING AND ANALYSIS 3-1
3.1 SAMPLE TYPES AND COLLECTION PROCEDURES 3-1
3.1.1 Air Samples 3-2
3.1.2 Dust Samples 3-3
3.1.3 Soil Samples 3-4
3.1.4 Waste Bark 3-6
3.2 SAMPLE PREPARATION AM) ANALYSIS 3-6
3.2.1 Air and Dust 3-6
3.2.2 Soil and Bulk Material 3-7
3.2.3 Waste Bark 3-9
4.0 DATA RECORDING, DATA QUALITY ASSESSMENT, AND DATA
SELECTION 4-1
4.1 DATA RECORDING 4-1
4.2 DATA QUALITY ASSESSMENT 4-1
4.3 DATA SELECTION 4-2
5.0 NATURE AND EXTENT OF LA 5-1
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5.1 CONTAMINANTS OF CONCERN 5-1
5.2 LA IN AIR 5-1
5.3 LA IN DUST 5-2
5.4 LA IN SOIL 5-3
5.5 LA IN WASTE BARK 5-4
5.6 Supplemental Studies 5-5
6.0 CONTAMINANT FATE AND TRANSPORT 6-1
7.0 HUMAN HI AI TH RISK ASSESSMENT 7-1
8.0 CONCLUSIONS 8-1
9.0 REFERENCES 9-1
LIST OF TABLES
1-1 Response Actions Taken at OU5
3-1 Sampling Events at OU5
3-2 Visible Vermiculite Inspection Scores and Selected Locations for Outdoor Worker ABS
LIST OF FIGURES
1-1 OU Boundaries
1-2 Libby Groundwater Superfund Site
1-3 OU5 Land Uses and Building Locations
1-4 Building and Soil Abatement Response Actions
3-1 Surface Soil Sampling Locations
5-1 ABS Indoor Air Results
5-2 ABS Outdoor Air Results
5-3 LA in Indoor Dust
5-4 LA in Surface Soil - PLM Results
5-5 Visible Vermiculite in Surface Soils
5-6 LA and Visible Vermiculite in Sub-Surface Soil
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APPENDICES
A - Response Action Reports
A1 - OU5 Redevelopment Area Investigation Summary
A2 - Response Actions at Central Maintenance Building
A3 - Libby and Troy Creek Investigation Summary Memo
A4 - Completion Form for a Quick Response at the Plywood Plant.
A5 - Completion Form for a Quick Response at the Valve House at Stimson Finger-Joiner
Building
A6 - Completion Form for a Quick Response at the Former Popping Plant on OU5.
A7 - Completion Form for a Quick Response at the Lincoln County Port Authority
Property (CDM Offices).
A8 - Documentation of Soil Removal Activities at the Former Tree Nursery
B - Sample Phase List
C - Asbestos Analysis Methods and Data Reduction Techniques
D - Analytical and Other Data
D1 - Scribe Database
D2 - Scribe Queries
E - Data Quality Assessment
F - Supplemental Investigation Reports
F1 - Wood Chip ABS
F2 - Proposed Fishing Pond Pre-design Investigation (at Former Tree Nursery)
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LIST OF ACRONYMS
ABS
Activity-Based Sampling
AT SDR
Agency for Toxic Substances and Disease Registry
bgs
Below ground surface
DQA
Data Quality Assessment
DQOs
Data quality objectives
EDDs
Electronic data deliverables
EPA
U.S. Environmental Protection Agency
ERT
Emergency Response Team
FS
Feasibility Study
FSDS
Field sample data sheet
ft
Foot
GPS
Global Positioning System
ISO
International Organization for Standardization
KBPID
Kootenai Business Park Industrial District
LA
Libby Amphibole
LG Site
Libby Groundwater Superfund Site
Libby2DB
Libby 2 Database
mg/m3
milligrams per cubic meter
msl
mean sea level
NPL
National Priority List
OSHA
Occupational Safety and Health Administration
OUs
Operable Units
PAH
Polycyclic aromatic hydrocarbons
PCM
Phase Contrast Microscopy
PC ME
Phase Contrast Microscopy Equivalent
PCP
Pentachlorophenol
PLM
Polarized light microscopy
PLM-VE
Polarized Light Microscopy - Visual Estimation
PRP
Potentially responsible parties
RI
Remedial Investigation
ROD
Record of Decision
s/cc
Structures per cubic centimeter
s/cm2
Structures per square centimeter
SAP
Sampling and Analysis Plan
SOPs
Standard operating procedures
SQL
Structured query language
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 5 (OU5) of the Libby Asbestos National Priority List (NPL) Site
(the Site) located in Lincoln County, Montana. LA occurrence throughout the Site resulted from
long time mining activities.
Operable Unit 5 is also referred to as the former Stimson Lumber Mill site, as many lumber
processing facilities were located throughout OU5. The majority of lumber production activities
ceased in 2003 when Stimson Lumber Company sold the property to the Lincoln County Port
Authority and ownership was subsequently transferred to the current owner, Kootenai Business
Park Industrial District (KBPID). The OU5 site is currently being redeveloped for a variety of
uses, both recreational and industrial. Major site features and land uses are illustrated on 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 OU5 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.
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Operable Unit 5, Libby Asbestos NPL Site ES-1
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trovedlinB010lRin
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Scale House
(Occupied)
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Bike Path (Unpaved or Partiatly Paved) ~ Buildings - Occupied
Bike Path (Paved. as of Sept '10) I I Buildings Vacant 'ma
] Storm Water Containment and Waste Water Lagoon Area ~ Buildings - Open Ait (less than four walls)
C=J \Nbste Bark Piles Debris RaHroad Spur
~ Approved Waste Bark Disposal Area Former Popping Plant
~ MotoX Track Lumber Yard
CD Libby Groundwater Superfund Site Former Champion Int. Tree Nursery
OU5 Boundary
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HDR Engineering, Inc
OU5 Land Uses and
Building Locations
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby. Montana
Figure ES-1
Southwest Area
Mtซs
Surface V\fater
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Operable Unit 5, Libby Asbestos NPL Site
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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 to air will 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 sample 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).
Site Investigations
Investigations at OU5 began in May of 2002 and continued through 2012. EPA performed
several ABS studies at in 2007 and 2008 to investigate levels of LA in air associated with a
variety of activities under current conditions. In addition to the ABS studies, the following
additional media-specific sampling was conducted:
Dust - standing dust samples collected from horizontal surfaces inside buildings.
Soils
> Surface - composite and grab samples collected from 0 to 6 inches below ground
surface (bgs).
> Sub-surface - composite and grab samples collected 6 or more inches bgs.
Waste Bark - material samples from an existing waste pile.
ABS from most occupied buildings contained detectable levels of LA. For buildings where LA
was detected, the mean concentration varied by a factor of 1,000. LA was detected in seven of
the eight outdoor worker ABS areas. The mean LA concentration varied by a factor of 10 across
the seven areas where LA was detected. Sampling at the MotoX area included stationary
samplers proximal to the location of spectators as well as samplers fixed to the handlebars of dirt
bikes. No LA fibers were detected in any air sample.
ABS was conducted separately for paved and unpaved portions of the bike path. On the paved
path, a stationary air monitor was also mounted in a trailer attachment to one of the bicycles to
characterize potential exposures to a young child being pulled by a parent. Mean LA
concentrations for the adult and child are similar.
Of the 87 indoor dust field samples collected, 28 samples had detectable levels of LA. Only four
samples had levels of LA above the current EPA removal action level for indoor dust (> 5,000
total LA structures per square centimeter).
Soil samples were examined both visually for vermiculite and by polarized light microscopy
(PLM). PLM results are generally non-detect or trace across OU5. The one location where PLM
results have consistently been higher (with observed LA levels up to 1%) is the north-central
portion of the former Tree Nursery area (Figure ES-1). This location also has elevated visible
vermiculite scores.
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Of the 19 waste bark samples analyzed, LA was detected in 1 sample analyzed by PLM and 13
samples analyzed by transmission electron microscopy. These results indicate that LA is present
but it is not possible to quantify how much LA may be present based on this qualitative method.
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 (ROD).
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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 5 (OU5) 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
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 National Priorities List 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 OU5, which is located south of the incorporated limits of Libby and contains the
former Stimson Lumber Mill and all properties owned by Kootenai Business Park Industrial
District (KBPID). The OU5 boundary also encompasses the unrelated Libby Groundwater
Superfund Site (LG Site), which has been on the NPL since September 1983 due to groundwater
contamination resulting from wood preservative processing (Figure 1-2). While the LG Site is
separate from LA investigations described in this RI, the land surface within the LG Site was
sampled as part of the OU5 investigation. In addition, air samples were taken at buildings within
the LG Site.
Libby Creek (which is part of OU4) traverses the western portion of OU5, but is not part of OU5.
Therefore, it will not be discussed in this report.
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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 OU5 data set used to describe the nature and extent of contamination and for calculation
of health risk estimates.
Section 5 - Nature and Extent of Contamination - This section provides a description of the
current type and extent of LA in surface and subsurface soils, indoor and outdoor air and bulk
materials. In addition, a brief discussion of groundwater conditions is provided associated with
the LG Site underlying portions of OU5.
Section 6 Contaminant Fate and Transport - This section provides a qualitative discussion of
LA contaminant migration routes and persistence in the environment.
Section 7 - Baseline 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.
The OU5 site is relatively flat and slopes slightly towards the north north-east. It encompasses
approximately 400 acres and includes a number of commercial and industrial buildings as well as
areas used for recreation.
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1.3 NPL SITE HISTORY
Libby is located near a large open-pit vermiculite mine which is located on Vermiculite
Mountain. Vermiculite is mica-like mineral that can be processed for use as an insulating
material or soil amendment and has been mined in Libby from 1919 to 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, 2010a)
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 Libby amphibole (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, are known to have 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 (ERT) was
sent to investigate local concern 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, the 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.
1.4 OU5 HISTORY AND DESCRIPTION
Operable Unit 5 is also referred to as the former Stimson Lumber Mill site, as many lumber
processing facilities were located throughout. The J. Neils Lumber Company began wood
treating operations at OU5 in approximately 1946. The lumber company and wood treating
operation was purchased by St. Regis Corporation in 1957. Champion International Corporation
purchased the facility in 1985 who then sold it to Stimson Lumber Company in 1993.
The majority of lumber production activities ceased in 2003 when Stimson Lumber Company
sold the property to the Lincoln County Port Authority and ownership was subsequently
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transferred to the current owner, KBPID. The Site is currently being redeveloped for a variety of
uses, both recreational and industrial.
Figure 1-3 shows former and current land uses and buildings throughout the Site that existed in
June 2010. One of the largest structures at OU5, the Plywood Plant, was entirely destroyed by
fire in early 2010.
During Site interviews conducted in 2001, three specific outdoor subareas of interest were
identified (CDM, 2007a) due to potential vermiculite (and associated LA) contamination
concerns (Figure 1-3):
The former Popping Plant was once used as an aboveground storage area for uncontained
vermiculite ore. Ore was stockpiled directly on the native soil surface in this area.
The Railroad Spur was used for shipping raw and unprocessed vermiculite material to
and from OU5.
The former Tree Nursery may have introduced raw vermiculite product into this area as a
growth medium and fill material.
Additionally, waste bark piles remain from historical lumber processing activities at OU5.
Under current conditions, OU5 is used mainly for commercial/industrial purposes. Portions of
the Site are used for recreational purposes. This includes an area that has been developed as a
Moto-Cross (MotoX) Park for dirt biking riding, and a trail along Libby Creek that is popular for
hiking and bicycle riding. Most of these features are illustrated on Figure 1-3.
Currently, there is no residential land use on OU5. However, a residential area (part of OU4) lies
within the OU5 boundaries as shown on Figure 1-3. In addition, residential neighborhoods
surround OU5 to the west and northwest.
Redevelopment plans are currently being formulated for OU5. The Kootenai River Development
Counsel was awarded a grant to upgrade the rail lines and electrical system throughout the Site.
Plans have also been developed for a walking path and fishing pond.
Limited tree and grass plant species are located within OU5, primarily along the northern
boundary and surrounding Libby Creek. The majority of OU5 is un-vegetated and suitable for
industrial/commercial development.
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1.5 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
1999 through 2013 - Response actions taken to remove asbestos and vermiculite
containing material throughout OU5 (Table 1-1)
EPA has not entered into any enforcement agreements or issued any orders for investigation,
removal, or remedial work at any part of OU5. The Stimson Lumber Company removed some
loose and accessible vermiculite insulation in 2002 and 2003. EPA contractors have taken
samples at OU5 many times beginning in 2002. EPA removed vermiculite insulation from a
portion of the roof and walls at the Central Maintenance Building in 2005 and contamination
from surface soils several times since 2009. None of these actions was pursuant to any
enforcement agreement or order. EPA entered into a site wide settlement with the only
Potentially Responsible Party (PRP) for OU5, W. R. Grace, in 2008. That agreement provided
for a cash settlement of past and future response costs for the entire Libby NPL Site except OU3,
the mine site.
1.6 PREVIOUS RESPONSE ACTIONS AT OU5
EPA established a program to inspect all properties in Libby. The emergency response work in
Libby has focused on removing as many LA source areas as possible from all OUs.
Contaminated soils are transported to the former Libby Mine site and contaminated construction
debris is placed in a specially designed landfill cell. These disposal sites are secured and will
remain off-limits to human contact. Recent response efforts have focused on residences and
businesses. Currently, the EPA is transitioning from emergency removal activity to the Remedial
Process (EPA, 2010a).
In an effort to determine the extent of LA occurrence at OU5, there have been multiple sampling
investigations conducted since 2002. These investigations are discussed in detail in Sections 3
and 5 of this report. A number of response actions have been completed to date and are
summarized in Table 1-1. Those buildings and land areas subjected to prior response actions that
remain at OU5 are illustrated on Figure 1-4.
The only known source of residual indoor vermiculite is at the Central Maintenance Building,
where remnants of vermiculite insulation remain in wall cavities (CDM, 2007a). However, the
possibility exists for residual vermiculite to be present in other OU5 buildings.
Beginning in October 2006, EPA implemented the Environmental Resource Specialist (ERS)
program for the entire Libby Superfund Site, including OU5. This program was set up to assist
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with unplanned and urgent exposures to vermiculite attic insulation due to its association with
LA. The ERS program provides a full-time service where property owners, firemen, and other
affected personnel or citizens can obtain access to LA expertise outside the normal course of
scheduled clean-up actions. The ERS program currently responds to reports of residual
vermiculite in OU5 buildings.
In addition to addressing vermiculite (and associated LA) in buildings, EPA performed other
response actions involving OU5 soils (Figure 1-4):
OU5 Redevelopment Area - Soil characterization and limited soil removal in an area
west of the Pipe Shop. A summary of investigative and soil removal work is provided as
Appendix Al.
Central Maintenance Building - Multiple actions to remove vermiculite-containing
building and other materials by vacuum methods, from the edge of the walls and outward
approximately 45 ft. A summary of investigative and soil removal work as well as
asbestos containing building materials mitigation is provided as Appendix A2.
Libby Creek Remediation Area - Removal and replacement of rip-rap on the east bank of
Libby Creek. Libby Creek is a part of OU4 as it traverses OU5. However, a portion of the
response action may have encroached onto OU5 on the east bank of the creek. A
summary of investigative and soil removal work is provided as Appendix A3.
Former Plywood Plant - Soil removal north of the former veneer dryer and removal of
vermiculite-containing bricks. A Completion Form is provided as Appendix A4.
Valve House at Finger Joiner Building - Soil removal from the area surrounding the
Valve House and from the floor of the Valve House. A Completion Form is provided as
Appendix A5
Former Popping Plant location - Soil removal as part of an OU4 action that extended
onto OU5. A Completion Form is provided as Appendix A6.
Port Authority Building (CDM Offices) - Soil removal as part of a re-vegetation pilot
study. Documentation is provided in Appendix A7.
Former Tree Nursery Area - Soil removal in preparation for construction of a proposed
fishing pond in the area. A Completion Form is provided as Appendix A8.
In addition, EPA installed a chain-link fence to isolate the former Tree Nursery area (CDM,
2007a).
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1.7 PREVIOUS INVESTIGATIONS & REPORTS
Numerous reports have been published dating back to 2007 that describe Site characteristics, as
well as conditions on the entire NPL site. Many reports are considered relevant to the OU5 RI
and are listed by primary subject as follows:
Sampling and Analysis Plans
Sampling and Analysis Plan, Building Data Gap Sample Collection, CDM, Final -
11/2/07
Sampling and Analysis Plan, Initial Soils Data Gap Sample Collection, CDM, Final -
9/10/07
Sampling and Analysis Plan Addendum - Initial Soils Data Gap Sample Collection,
Visual Vermiculite Inspection, CDM, Final - 6/13/08
Sampling and Analysis Plan for the MotoX, U.S. Department of Transportation, Final -
8/19/08
Sampling and Analysis Plan for Outdoor Worker Exposures, Syracuse Research Corp.,
Final - 9/8/08
Sampling and Analysis Plan for Recreational User Exposures, Syracuse Research Corp.,
Final - 9/8/08
OU5 Activity Based Sampling, Soil Pilot Study (Modification to MotoXABS SAP &
Outdoor Worker ABS SAP), CDM, Rev 1 - 11/28/09
Reports on Investigation Results
Data Summary Report, CDM, Final - 9/10/07
Sampling Summary Report - 2007 Investigations, CDM, Final - 7/25/08
OU5 Wood Chip ABS Sampling Summary Technical Memorandum, CDM Smith - 1/9/12
1.8 LIBBY GROUNDWATER SITE
The LG Site lies within the OU5 boundary but is otherwise, unrelated to OU5 (Figure 1-2). A
brief chronology and description of the LG Site history is provided below:
In 1979, contamination was discovered in a nearby residential drinking water well.
Contaminants include creosote, PCP (pentachlorophenol), and PAH's (polycyclic
aromatic hydrocarbons).
LG Site added to the NPL on September 8, 1983. It has two designated OUs:
> LG-OU1 consists of the alternative drinking water supply initiative sponsored by
Champion (a PRP) for the affected and potentially-affected residents of Libby.
> LG-OU2 consists of affected environmental media including contaminated soils,
and groundwater in the upper and lower aquifer.
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LG-0U1 Record of Decision (ROD) was finalized on September 26, 1986. The remedy
included:
> Champion's Buy Water Plan in which Libby residents were provided monetary
compensation for using municipal water supply for irrigation and drinking water
instead of contaminated private water wells.
> An ordinance preventing installation of new water wells for human consumption
or irrigation in the upper and lower aquifer within the "corporate limits" for the
City of Libby.
LG-OU2 ROD was finalized on December 30, 1988. The remedy included but is not
limited to:
> Excavation of contaminated soils from identified source areas and placement
within a waste pit to undergo a two-step enhanced biodegradation process. The
solids were transferred to a land treatment unit, which ultimately will be capped
with low permeability materials.
> Insertion of language into the current registered deed identifying locations of
hazardous substances disposal and treatment areas, and land use restriction of
these areas.
> Oil recovery wells to collect highly-contaminated ground water, which is treated
in a fixed film bioreactor prior to reinjection.
> In-situ enhanced biorestoration of upper aquifer ground water.
> Monitoring activities to assess performance of remedy components throughout
the life of remedial activities.
Four 5-year reviews have been performed at the LG Site, with the most recent signed on March
5, 2010. The review found the current remedies for LG-OU1 and LG-OU2 to not be protective.
The remedy for LG-OU2 does not include institutional controls on a portion of the contaminated
groundwater plume. The remedy for LG-OU2 does not currently meet risk-based cleanup levels.
Environmental clean-up activities at the LG Site will continue into the future.
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2.0 SITE CHARACTERISTICS
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 ฐF. Occasionally, dry continental air masses
occupy the Libby area for short periods of time during the winter, creating cold and less-humid
conditions (CDM, 2009a).
Fog is common in Libby during winter months and in early morning throughout the year.
Summer months are dryer and warm with occasional rainfall. The average July temperature
ranges between 56-70 ฐF, with an average high of 80 ฐF (CDM, 2009a).
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, 2009a).
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 consist 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).
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 pre-Cambrian rocks, downstream transport of clays with
rivers and creeks, and organic matter from historically forested areas (CDM, 2009a).
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.
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2.3 HYDROLOGY AND HYDROGEOLOGY
Libby Creek (which is part of OU4) runs through the western portion of OU5 and terminates in
the Kootenai River, which flows just outside the northern OU5 border. 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, 2009a).
Beneath OU5, saturated alluvial deposits extending from the surface to approximately 190 ft bgs
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 1000
foot 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 rise 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
Investigations at OU5 began in May of 2002 and continued through 2012. Table 3-1 summarizes
sampling events that occurred at OU5 over the ten-year sampling period.
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 4)
including:
Air, bulk material or other samples associated with a building/structure that has since
been demolished or otherwise destroyed or has been cleaned under a removal action.
Certain other data that was deemed irrelevant to the assessment of risk to human health.
These include certain indoor dust and outdoor ambient air samples.
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.
In addition, investigations performed after 2009 were in support of lumber product safety
assessment or pre-design investigations related to site development. Data from these studies were
also excluded from the body of the report. However, a summary of each investigation is provided
in Section 5.
3.1 SAMPLE TYPES AND COLLECTION PROCEDURES
As shown in Table 3-1, the following media-specific sampling was conducted:
Air
> Personal air samples - collected using a sampling pump and filter located in the
breathing zone of an individual while performing various activities indoors or
outdoors.
> Stationary air samples - collected using a stationary sampling pump and filter
placed either indoors or outdoors.
Dust - standing dust samples collected from horizontal surfaces inside buildings.
Soils
> Surface - composite and grab samples collected from 0 to 6 inches bgs.
> Sub-surface - composite and grab samples collected 6 or more inches bgs.
Waste Bark - material samples from existing waste pile shown on Figure 1-3.
Samples were collected, documented, and handled in accord with standard operating procedures
(SOPs) as specified in the respective Sampling and Analysis Plans (SAPs). The Data Summary
Report and Sampling Summary Report (CDM, 2007a and CDM, 2008) provide additional details
on sampling events as well as deviations from the SAPs.
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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.
All samples collected in the field were maintained under chain of custody during sample
handling, preparation, shipment, and analysis.
3.1.1 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 a piece of
operating equipment/vehicle. Samples collected both indoors and outdoors.
2. Stationary Air Samples - Sampling equipment placed on motionless surface. Samples
collected both indoors and outdoors.
Personal air sampling involved a variety of activities performed by the sampler with and without
operating equipment/vehicle. These activities may have been scripted or unscripted. Scripted
activities required the sampler and/or equipment to perform a written script. Unscripted activities
are those for which a formal written script was not used. For example; a scripted activity might
involve a sampler performing specific office work routine while wearing a sampling pump and
filter cassette in a building with current use as an office. An unscripted activity might involve the
sample equipment worn by a site worker going about his/her self-determined routine.
Unscripted personal air data was most frequently collected in association with Occupational
Safety and Health Administration (OSHA) exposure monitoring for workers on OU5. These data
were not intended for use in site characterization or for estimation of residual risks to current or
future populations at OU5.
Stationary sampling included sampling of ambient air at OU5 but also included sampling
proximal to a person or piece of equipment conducting scripted activities. Scripted stationary air
samples were collected to represent conditions in the breathing zone as a surrogate for a personal
air sample.
Such sampling was conducted at a variety of locations including but not limited to:
Unoccupied buildings while disturbing the dust with a leaf-blower or equivalent.
Proximal to stadium seating at the MotoX Park during a race.
Inhalation of air is considered to be the most direct route of exposure to LA and is therefore the
primary medium of concern. Scripted air sampling activities were determined to provide the
most meaningful measure of human exposure to LA at OU5 (EPA, 2008a). Such scripted
sampling is referred to in the remainder of this report as Activity-Based Sampling (ABS).
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All ABS events were conducted in accord with EPA's Emergency Response Team (ERT) SOP
#2084 (Activity-Based Air Sampling for Asbestos), with project-specific modifications.
Activity-Based Sampling was conducted to evaluate possible exposure of a variety of
populations at OU5 including commercial/industrial workers, maintenance workers and
recreational visitors. Activity-Based Sampling was conducted at locations shown on Figure 3-1
to target the following populations at OU5:
Visitors participating in and viewing MotoX activities at the MotoX Park (EPA, 2008b)
Visitors riding a bicycle on the bike path along Libby Creek (EPA, 2008c)
Workers engaging in outdoor activities at various locations on OU5 (EPA, 2008d; CDM,
2007)
Workers engaging in indoor activities in various buildings on OU5 (EPA, 2007a)
Activities include raking, operating machinery, riding a bike or motorcycle, moving waste bark
and active and passive indoor worker activities. The intent was to disturb LA containing
materials (ie. soil or dust) by performing an activity typical for a given building or outdoor
location allowing measurement of actual LA exposure for that activity.
A detailed description of the study design and data quality objectives (DQOs) for each ABS
study is provided in the respective SAPs, cited above.
As part of the OU5 outdoor worker ABS investigation, sampling was conducted at eight ABS
areas (Figure 3-1) (EPA 2008d). Each ABS area was approximately 1-1.5 acres in size. These
eight ABS areas were selected based on previous visible vermiculite sampling results to
represent the range of expected soil contamination conditions at the OU5 site.
All outdoor ABS air sampling was performed in September or October in order to make
measurements during the time of year where conditions are drier than most other months.
3.1.2 Dust Samples
Indoor dust samples were collected as part of four different sampling programs; Phase 1
investigation in May 2002, Contaminant Screening Study in September 2002, Pre-Design
Inspection for the Central Maintenance Building in April 2004 (CDM, 2007a), and Building
Data Gap Sample Collection (EPA, 2007a).
Dust samples were collected from horizontal surfaces such as a shelf or floor inside buildings.
Samples were collected using a microvacuum dust filter that was operated for between two and
five minutes. Each sample was a composite consisting of up to ten, 100-square centimeter (cm )
areas.
These data were primarily used to assess whether an occupied building should be considered for
emergency cleanup. As discussed in Section 5.3, several buildings contained dust above the
2 2
action threshold of 5,000 LA structures per cm (s/cm ).
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As discussed in Section 3.1.1 and 5.2, ABS was conducted in occupied and vacant buildings,
including buildings previously subjected to cleaning of interior surfaces and/or removal of LA-
containing building materials (e.g. vermiculite insulation). Results of indoor ABS are discussed
in Sections 5.2 and 5.3.
3.1.3 Soil Samples
Surface Soil
Most soil sampling at OU5 involved surface soils. Soil sampling at OU5 began in 2002 with an
initial phase that included systematic sampling across most of OU5 as well as a focused
investigation of four specific areas of interest including:
Soils near the Central Maintenance Building
MotoX Park
A proposed demolition derby track
Former Tree Nursery area.
At least multiple additional sampling events occurred after the initial 2002 event in order to gain
a more complete understanding of the occurrence of LA and/or vermiculite in soil (Table 3-1).
Reasons for additional sampling included areas not originally sampled, areas known to have
vermiculite containing materials and areas of high use. A discussion of soil sample strategies is
provided in:
Data Summary Report, Operable Unit 5 - Former Stimson Lumber Company, Libby
Asbestos Site, Libby, MT (CDM. 2007a).
Sampling Summary Report, 2007 Investigations, Operable Unit 5 - Former Stimson
Lumber Company, Libby Asbestos Site, Libby, MT (CDM. 2008).
Soil samples included grab and composite samples. Grab samples were collected as a shallow
core approximately 2 inches in diameter and no more than 6 inches bgs. Composites were
comprised of between two and thirty grab samples. In some cases, the individual grab samples
were analyzed along with the composite.
Figure 3-1 shows locations of all surface soil samples (grab or composite) that were collected
and analyzed (or otherwise examined). The variability in sample density apparent on this figure
relates to the various strategies employed to characterize surface soils at OU5 during period of
field investigations (2002-2009).
An initial, roughly systematic sampling event was intended to provide general coverage of OU5.
Sample spacing of this initial event is apparent in the west-central portion of OU5 (Figure 3-1).
This initial investigation omitted the LG Site, which was later subject to additional, relatively
dense systematic sampling as shown on the figure.
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Subsequent localized investigations of surface soil focused on specific areas where vermiculite
(and therefore, associated LA) was either observed or otherwise suspected to be present based on
historical land use (e.g., former vermiculite popping plant).
In addition, locations with current or proposed high-use recreational lands were also the target of
stand-alone investigations. These included the MotoX Park (Figure 3-1) and a proposed
demolition derby (proximal to the MotoX Park).
Prior to selecting the locations for Outdoor Worker ABS events, all existing OU5 surface soil
data were examined to discern trends in spatial variability of LA or vermiculite occurrence. The
purpose of this exercise was to allow selection of Outdoor Worker ABS locations that
represented a range of surface soil contamination.
Ultimately, outdoor worker ABS areas were selected based on visual vermiculite inspection
results. Previous sampling activities characterized vermiculite levels throughout most of OU5
based on visual inspection, and this information was used to categorize the level of vermiculite in
the soil as None, Low, Moderate or High based on relative scoring (See Section 3.2.2). Outdoor
Worker ABS areas were selected to include two areas from each category. Table 3-2 shows the
visible inspection scores at the selected locations for the Outdoor Worker Exposure ABS.
Outdoor Worker ABS locations are shown on Figure 3-1.
Once outdoor ABS locations were selected (for worker and recreational land uses), those areas
were subject to additional surface soil sampling (as shown on Figure 3-1). All ABS areas were
characterized by collecting and analyzing at least 30 individual grab samples and then also
analyzing a 30-point composite sample comprised of the grabs. Most samples were analyzed to
determine presence of LA. Analytical methods are discussed in Section 3.2.2.
The purpose of this additional sampling was three-fold:
Verify that outdoor worker ABS areas did represent a range of LA levels and visible
vermiculite conditions.
Produce data that could be used to develop a mathematical relationship between LA
occurrence in soil and in air.
Evaluate whether composite sampling of OU5 soils is masking variability of LA
occurrence in grab samples.
Subsurface Soil
Subsurface samples were collected in limited areas. Generally, these areas were selected based
on the location of suspected buried LA containing materials including the former Popping Plant
and a buried railroad spur (Figure 1-3). Sampling at these locations as well as a few scattered
locations across OU5 included composites consisting of five grab samples collected from depths
of 40 to 60 inches bgs. Additional subsurface grab samples were collected as part of the LG Site
investigation in 2007. These samples were collected from depths of 12-15 inches bgs.
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3.1.4 Waste Bark
Waste bark is stored on OU5 in stockpiles (see Figure 1-3). On October 15, 2007, bulk waste
bark debris samples were collected to test for a presence of LA and to evaluate removal options
and potential future uses.
Waste bark piles were split into 100 ft by 100 ft grids. Sampling was conducted using a test pit
method in each grid. A total of 27 bulk material samples and one field duplicate were collected
from the top, middle and bottom section of each waste bark test pit. Of these 27 samples, 19 field
samples and one field duplicate were analyzed. The remaining samples may be analyzed at a
later date, as directed by the EPA (CDM, 2008).
3.2 SAMPLE PREPARATION AND ANALYSIS
A detailed description of the number of samples analyzed from each sampling event, sampling
and analytical methods used and detection results is provided in Appendix B. A thorough
description of sample preparation and analytical methodology is also provided in Appendix C
and summarized below.
3.2.1 Air and Dust
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
(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 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.
If air samples were not deemed to be overloaded by particulates1, filters are directly prepared for
analysis by TEM in accord with preparation methods provided in International Organization for
Standardization (ISO) 10312 (ISO, 1995).
1 Overloaded is defined as >25% obscuration on the majority of the grid openings (see Libby Laboratory
Modification #LB-000016 and SOP EPA-LIBBY-08).
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If air samples are deemed to be overloaded, samples are prepared indirectly in accord with
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.
Air and dust samples collected as part of the OU5 sampling programs were analyzed by TEM in
basic accord with counting and recording rules specified in ISO 10312, and project-specific
counting rule modifications specified in the respective SAPs. These modifications included
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) or dust loading in s/cm .
3.2.2 Soil and Bulk Material
Polarized Light Microscopy (PLM)
Soil samples collected as part of the OU5 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
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Bin B2 (<1%): detected at levels lower than the 1% LA reference material 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
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 Venniailile l.e\d (l.i)
Weighting factor (Wj)
None
0
Low
1
Moderate
3
High
10
The composite score is then the weighted sum of the observations for the area:
r oLt*wt
tti=1 ; ;
Score = ฆ
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.
3.2.3 Waste Bark
Waste bark samples were analyzed by adding a sample of test material to water, shaking, and
allowing the sample to separate into "sinks" (mineral particles that settle to the bottom), "floats"
(particles of wood that rise to the top), or "suspended" (particles that remain in the water). The
"sinks" are collected, dried, and analyzed using EPA-Libby-10, Analysis of Waste Bark and
Wood Chip Samples for Fibrous Amphibole, a qualitative analysis method utilizing PLM and
TEM. If no fibrous amphibole is detected in the "sinks", then a sample of the water is analyzed
by TEM for suspended amphibole. If fibrous amphibole is detected in either fraction, the sample
is reported as "detect". If fibrous amphibole is detected in neither fraction, the sample is
reported as "non-detect".
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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 Libby 2 Database (Libby2DB) and more
recently the Libby Data Warehouse. Appendix D1 provides an electronic copy of the database.
Detailed summaries of sample results for environmental media collected in OU5 through 2007
are provided in CDM (2007a) and CDM (2008). 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. The EDDs
generated by the laboratories are uploaded directly into the Libby site database.
Hard copies of all FSDSs, field log books, and chain of custody forms generated during the
various OU5 sampling program are stored in the CDM field office in Libby, Montana.
Hard copies of all analytical bench sheets are included in analytical laboratory reports. These
analytical reports are submitted to the Libby Laboratory Coordinator and stored at CDM offices
in Denver, CO.
Historically, sample and analytical electronic data were stored and maintained in the Libby2DB
which was housed on a structured query language (SQL) server at EPA Region 8 in Denver,
Colorado. At the time of this report, EPA was in the process of transitioning to a new data
management system, referred to as Scribe.net. In the future, sample and analytical electronic data
will be stored and maintained in the Libby Data Warehouse which is populated by Scribe.net and
housed on the EPA network.
4.2 DATA QUALITY ASSESSMENT
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 E.
For the purposes of the risk assessment (Section 7), the principle datasets utilized to quantify
potential exposures are the air samples collected during the various ABS programs at OU5.
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In addition, soil data (both visible vermiculite inspection results and PLM-VE results) are
utilized in the interpretation of Outdoor Worker ABS results. Therefore, the DQA focuses on
ABS air samples and Site-wide soil samples used to support the risk assessment.
The DQA process considered the following:
Field and laboratory audit results.
Field and laboratory quality control sample results.
Data entry verification.
Comparison of data collected with specified DQOs stated in the respective ABS SAPs.
Results of the DQA indicate that air and soil data collected at OU5 and utilized in the risk
assessment generally are of acceptable quality, adequate and representative, and considered to be
reliable and appropriate for use in the RI including the risk assessment.
4.3 DATA SELECTION
Raw data for samples utilized in describing the occurrence of LA in OU5 soils and air (Section
5) were obtained via a subscription to the Libby OU5 project database through Scribe.net. A
copy of this database was obtained by SRC, Inc. on March 12, 2010, and is provided
electronically in Appendix D1 of this report.
Because all data had not yet been migrated from Libby2DB to Scribe.net at the time of this
report (e.g., quality control samples and analyses, air pump information, etc.), data were
supplemented by results from the Libby2DB. The Libby2DB was downloaded into a Microsoft
Accessฎ database by SRC, Inc. on December 8, 2009. Note that any changes made to these
databases since they were obtained/download will not be reflected in Appendix Dl.
In addition, supplemental GPS coordinate data for historical soil samples were provided by CDM
on March 25, 2010. An Microsoft Excelฎ spreadsheet summarizing these coordinate data is
provided in Appendix Dl.
Scribe queries were written to sort data by media, analytical method and to exclude quality
control samples. The Scribe queries for soil and air samples are provided in Appendix D2. The
data set resulting from execution of the queries 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 (e.g., McDonald et al., 1986a,
Amandus and Wheeler, 1987). More recently, the U.S. Geological Service (USGS) 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).
5.2 LA IN 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, indoor dust) 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 indoor and outdoor air are summarized on Figures 5-1 and 5-2,
respectively.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site 5-1
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Indoor Air
Figure 5-1 summarizes ABS results for existing buildings except those that have fewer than four
walls or have a dirt floor. In addition, no ABS air data is available for the Finger Jointer Process
Plant.
Samples from most vacant buildings contained no detectable LA. Samples from most occupied
buildings contained detectable LA. For buildings where LA was detected, the mean
concentration varied by a factor of 1,000.
Outdoor Air
Figure 5-2 summarizes results for the eight Outdoor Worker ABS locations and ABS conducted
along the bicycle path and at the MotoX Park. LA was detected in seven of the eight Outdoor
Worker ABS areas. The mean LA concentration varied by a factor of 10 across the seven areas
where LA was detected.
Sampling at the MotoX Park included stationary samplers proximal to the location of spectators
as well as samplers fixed to handlebars of dirtbikes. No LA fibers were detected in any sample.
Sampling was conducted separately for paved and unpaved portions of the bike path. On the
paved path, a stationary air monitor was also mounted in a trailer attachment to one of the
bicycles to characterize potential exposures to a young child being pulled by a parent. Samples
from the trailer were not collected from the unpaved portion of the path because the unpaved
portion of the path is steep and narrow in sections, and is not safe for pulling a trailer. The mean
LA concentrations for the adult and child were similar.
5.3 LA IN DUST
Figure 5-3 illustrates buildings that have been sampled for indoor dust and presents the total LA
dust loading results relative to the current EPA removal action level for indoor dust (> 5,000
total LA s/cm2; EPA, 2003).
Of the 87 indoor dust field samples collected, 28 samples had detectable levels of LA, with
detectable levels ranging from 35 to 44,116 total LA s/cm . Only four samples had detectable
levels of LA above the current EPA removal action level:
Former Tree Nursery area shed - Total LA dust loading was 7,026 s/cm for one
composite sample collected in May 2002 from sampling locations atop wood piles and
from a ground level beam in this shed. This building was no longer present during the
2007 site visit (CDM, 2007a).
Central Maintenance Building - Total LA dust loading was 8,823 s/cm for one of 29
composite samples collected from this building in September 2002. This sample was
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site 5-2
-------
collected from two engine rooms and the main work area. The source of dust
contamination in this building was likely vermiculite insulation and vermiculite-
containing building materials which were subsequently removed in 2005 (CDM, 2007a).
Diesel Fire Pump House - Total LA dust loading was 8,823 s/cm for one composite
sample collected from three areas within this building in September 2002.
Guard Station at Libbv Creek Bridge - Total LA dust loading was 44,116 s/cm for one
composite sample collected from this building in September 2002. The guard station did
not contain vermiculite insulation at the time of sampling (CDM, 2007a). This building
was no longer present during the 2007 site visit (CDM, 2007a).
5.4 LA IN SOIL
Surface Soil
Figure 5-4 illustrates LA occurrence in OU5 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, individual grab samples (primarily collected within the Outdoor Worker ABS
areas) are shown as triangles, and composite samples are shown as circles plotted at the mid-
point of the area. Composite samples are representative of a larger area than the plotting point
presented in this figure.
Figure 5-5 illustrates vermiculite occurrence in OU5 soils based on visual vermiculite inspection
results. In this figure, historical observations of visible vermiculite which utilized a qualitative
present/absent approach are shown as triangles.
More recent visible vermiculite observations which utilized a semi-quantitative approach are
shown as squares and are color-coded based on the visible score (see Section 3.2.2). A 4-color
scheme is used to indicate visible score data:
green = score of 0 (no visible detected)
yellow = score <0.1
orange = score 0.1 to < 0.3
red = score > 0.3
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
5-3
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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 OU5 and locations where higher than average levels have been observed.
As shown in Figure 5-4, PLM results are generally non-detect or trace across OU5. The one
location where PLM results have consistently been higher (with observed LA levels up to 1%) is
the north-central portion of the former Tree Nursery area. This location also has elevated visible
scores (see Figure 5-5).
Differences in the more recent visual vermiculite results compared to the original results likely
arises from the inherently subjective nature of the category assignments, as well as variations in
site conditions between rounds (e.g., cloud cover vs. sunshine, amount of ground cover, soil
moisture, etc.).
Subsurface Soil
PLM and visual inspection results for subsurface soils are presented on Figure 5-6. LA was not
detected in any composite sample collected near the former Popping Plant or in other samples
scattered across the remainder of OU5. LA was reported as <1% in a single composite sample
collected along the railroad spur.
LA was not detected in any of the grab samples collected in the LG Site. Visible vermiculite was
noted as "moderate" in a single sample. Unlike the visible vermiculite score used to describe the
relative level of vermiculite in composite samples, the result for individual grab samples is
expressed as none, low, moderate or high, as discussed Section 3.2.2.
These results suggest that, in the areas examined, the occurrence of LA or vermiculite does not
increase with depth.
5.5 LA IN WASTE BARK
Of the 19 waste bark samples analyzed, LA was detected in 1 sample analyzed by PLM, and LA
was detected in 13 samples by TEM. These results show that LA is present in these piles, but it is
not possible to quantify how much LA may be present based on the qualitative method used for
waste bark (See Section 3.2.3).
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
5-4
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5.6 Supplemental Studies
As discussed in Section 3.0, several targeted investigations were performed after 2009. These
included:
1. ABS air sampling during the handling of wood chips produced during historical lumber
processing operations. The purpose of the investigation was to evaluate whether
disturbance of the wood chips (by workers or residents) resulted in health risks above a
level of concern. All of the ABS air sample results were non-detect for LA. Without
fibers being detected, risks were not estimated as there was no exposure. A Memorandum
summarizing the investigation and findings was prepared by CDM Smith is provided as
Appendix F1.
2. Soil sampling to assess LA occurrence at the Former Tree Nursery to identify areas
requiring excavation prior to design/construction of a proposed recreational fishing pond.
Unpublished results indicated the presence of trace levels of LA in some of the areas
sampled. Portions of the sampled areas were subsequently excavated (See Table 1-1 and
Figure 1-4). A map illustrating the extent of LA in sampled areas is provided as
Appendix F2.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
5-5
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6.0 CONTAMINANT FATE AND TRANSPORT
As discussed in Section 1.4, asbestos containing material was potentially transported to OU5 via
the following activities:
The former Popping Plant was once used as an aboveground storage area for uncontained
vermiculite ore. Ore was stockpiled directly on the native soil surface in this area.
The Railroad Spur was used for shipping raw and unprocessed vermiculite material to
and from the site.
The former Tree Nursery may have introduced raw vermiculite product into this area as a
growth medium and fill material.
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 fim
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. Indoors, asbestos can be suspended when contaminated material (usually insulation) is
disturbed by cleaning, renovation or other general disruption.
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.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
6-1
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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, 2007a)
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.
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 indoor air, mixing usually takes from 5 to 30 minutes, but is dependent
on airflow within the building.
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.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
6-2
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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 feasibility study 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 5, Libby Asbestos NPL Site
7-1
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8.0 CONCLUSIONS
The RI reached the following general conclusions:
1. PLM results for surface soil samples are generally non-detect or trace across OU5. The
one location where PLM results have consistently been higher (with observed LA levels
up to 1%) is the former Tree Nursery area. This location also has elevated visible
vermiculite scores.
2. PLM and visible vermiculite results for subsurface soil samples are generally non-detect.
These results suggest that no increasing vertical gradient in LA or vermiculite occurrence
exists in the areas examined. However, subsurface soil sampling across OU5 is limited.
3. 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.
4. 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 field study (FS) and ROD.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
8-1
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9.0 REFERENCES
ATSDR, 2001. Toxicological Profile for Asbestos. Atlanta, GA: Agency for Toxic Substances
and Disease Registry, U.S. Department of Health and Human Services, Public Health Service.
September 2001. http://www.atsdr.cdc.gov/toxprofiles/tp61.html
CDM, 2004. Close Support Facility, Soil Preparation Plan, Libby Montana Asbestos Project
Sample Processing. March 2004.
CDM, 2007a. Final Data Summary Report, Operable Unit 5 - Former Stimson Lumber
Company, Libby Asbestos Site, Libby, MT, October 16, 2007.
CDM, 2007b. Technical Memo: Woodchip Stockpile Sampling, Operable Unit 5, Libby
Asbestos Site. U.S. Environmental Protection Agency, Region 8. June 1, 2007.
CDM, 2008. Final Sampling Summary Report 2007 Investigations, Operable Unit 5 - Former
Stimson Lumber Company, Libby Asbestos Site, July 25, 2008.
CDM, 2009. Former Export Plant Site Final Remedial Investigation Report, Operable Unit 1,
Libby Asbestos Site, Libby, MT;-. August 3, 2009.
CDM, 2011. Operable Unit 5 Central Maintenance Building Summary Report Memorandum.
February 27, 2012.
CDM Smith, 2012. OU5 Wood Chip Activity-based Sampling Summary Memorandum, January
9, 2012.
EPA, 2003. Libby Asbestos Site, Residential/Commercial Cleanup Action Level and Clearance
Criteria Technical Memorandum. Draft Final. U.S. Environmental Protection Agency, Region
8. December 15, 2003.
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, 2007. Investigation Quality Assurance Project Plan (SQAPP). U.S. Environmental
Protection Agency, Region 8. October 23, 2007.
EPA, 2008a. Framework for Investigating Asbestos-Contaminated Sites. Report prepared by the
Asbestos Committee of the Technical Review Workgroup of the Office of Solid Waste and
Emergency Response, U.S. Environmental protection Agency. OSWER Directive #9200.0-68.
http://epa.gov/superfund/health/contaminants/asbestos/pdfs/framework asbestos guidance.pdf
EPA, 2008b. Sampling and Analysis Plan for the MotoX, Operable Unit 5, Libby Asbestos
Site. Final. U.S. Environmental Protection Agency, Region 8. August 19, 2008.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
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EPA, 2008c. Sampling and Analysis Plan for Recreational User Exposures, Operable Unit 5,
Libby Asbestos Site. Final. U.S. Environmental Protection Agency, Region 8. September 8,
2008.
EPA, 2008d. Sampling and Analysis Plan for Outdoor Worker Exposures, Operable Unit 5,
Libby Asbestos Site. Final. U.S. Environmental Protection Agency, Region 8. September 8,
2008.
EPA, 2009. Summary of Outdoor Ambient Air Monitoring for Asbestos at the Libby Asbestos
Site, Libby, Montana (October 2006 to June 2008). Prepared by U.S. Environmental Protection
Agency, Region 8, with technical support from SRC, Inc. February 9, 2009.
EPA, 2010a. Libby Asbestos, Region 8, US EPA. Website. Retrieved April 2010 from the World
Wide Web: www.epa.gov/libb vA January 2010.
EPA, 2010b. Region 8, Fourth Five Year Review Report for Libby Groundwater Contamination
Superfund Site; City of Libby, Lincoln County, Montana. March 2010.
EPA, 2010c. Removal and Restoration Completion Form for a Quick Response at the Plywood
Plant.
EPA, 2010d. Removal and Restoration Completion Form for a Quick Response at the Valave
House at Stimson Finger-Joiner Building
EPA, 2010e. Removal and Restoration Completion Form for a Quick Response at the Central
Maintenance Building.
EPA, 2012a. Removal and Restoration Completion Form for a Quick Response at the Lincoln
County Port Authority Building (CDM Offices).
EPA, 2012b. Removal and Restoration Completion Form for a Quick Response at the Lincoln
County Port Authority Property (former Nursery).
EPA, 2012c. Removal and Restoration Completion Form for a Quick Response at the Central
Maintenance Building.
EPA, 2013a. Removal and Restoration Completion Form for a Quick Response at the Lincoln
County Port Authority Building (former Popping Plant location)
EPA, 2013b. Unpublished field documentation of a soil excavation response action at the former
OU5 nursery, provided by EPA via email on May 15, 2013.
EPA, 2013b. Unpublished maps and field notes documenting soil removal at the Former Tree
Nursery.
Final Remedial Investigation Report
Operable Unit 5, Libby Asbestos NPL Site
9-2
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ISO, 1995. International Organization for Standardization Ambient Air. Determination of
asbestos fibers - Direct-transfer transmission electron microscopy method. ISO 10312:1995(E).
Midwest Research Institute, 1982. Collection, analysis, and characterization of vermiculite
samples for fiber content and asbestos contamination. Report prepared for the US Environmental
Protection Agency Office of Pesticides and Toxic Substances. Kansas City, MO: September
1982.
Syracuse Research Corporation/CDM, 2008. Final Sampling and Analysis Plan for Outdoor
Worker Exposures at Operable Unit 5, Libby Asbestos Superfund Site, Libby, MT. September 8,
2008.
Syracuse Research Corporation/CDM, 2008. Final Sampling and Analysis Plan for Recreational
User Exposures at Operable Unit 5, Libby Asbestos Superfund Site, Libby, MT. September 8,
2008.
U.S.D.O.T/CDM/Syracuse Research Corporation 2008. Final Sampling and Analysis Plan for
the MotoX Track at Operable Unit 5, Libby Asbestos Superfund Site, Libby, MT. August 19,
2008.
U.S. Geological Survey, 2002. Bulletin 2192. Reconnaissance study of the geology of US
vermiculite deposits - Are asbestos minerals common constituents? Denver, CO: US Department
of the Interior. May 7, 2002. URL: http://geology.cr.usgs.gOv/pub/bulletins/b2192/g . Accessed
on July 31, 2002.
Western Regional Climate Center. Accessed April 23, 2010. http://www.wrcc.dri.edu/cgi-
bin/cliMAIN.pl?mt5000.
Final Remedial Investigation Report
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9-3
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T ables
-------
TABLE 1-1
Response Actions Taken at OU5
Location (rel'cre 11 ce)
Dale
Lead Aปenc\/('ompanv
Description
Plywood Plant and
Truck Shop (CDM
2007)
November
1999
MCS Environmental through
Stimson Lumber Company
Asbestos abatement
Finger Jointer (CDM
2007)
May 2000
MCS Environmental through
Stimson Lumber Company
Removal of vermiculite
insulation from lunch room
and bathroom
Dry Kiln Tunnel
(CDM 2007)
December 2002
IRS Environmental through
Stimson Lumber Company
Removal of pipe insulation
and asbestos containing
debris
Central Maintenance
Building (CDM 2007)
May/June 2003
IRS Environmental through
Stimson Lumber Company
Removal of vermiculite
insulation and asbestos
containing materials on
ground surface
Plywood Dryers
(CDM 2007)
August 2003
IRS Environmental through
Stimson Lumber Company
Removal of vermiculite
insulation from walls, floors,
and ceilings
Plywood Plant (CDM
2007)
August 2003
IRS Environmental through
Stimson Lumber Company
Removal of pipe insulation of
northwest corner
Screening Building
(CDM 2007)
August 2003
IRS Environmental through
Stimson Lumber Company
Removal of cement asbestos
siding and roofing
Central Maintenance
Building (CDM 2007)
December 2003
IRS Environmental through
Stimson Lumber Company
Removal and repair of
asbestos containing roofing
material and asbestos
containing materials on
ground surface
Former Nursery (CDM
2007)
Fall 2004
EPA
Installation of fence to isolate
area
Finger Jointer Lunch
Room (CDM 2007)
February 2005
IRS Environmental through
Stimson Lumber Company
Removal of vermiculite
insulation
Central Maintenance
Building (CDM 2007)
Summer 2005
EPA
Removal of vermiculite
insulation
Soils northwest of Pipe
Shop to support
redevelopment (CDM
2007)
Spring and
Summer 2009
EPA
Removal of LA-impacted
soils to depths of 6"-18" to
support Site redevelopment.
Libby Creek (OU4
action w/possible
encroachment on
OU5) (CDM 2007)
August 2009
EPA
Removal and replacement of
rip-rap on east bank of Libby
Creek
Former Plywood Plant
(EPA, 2010c)
Summer 2010
EPA
Soil removal north of former
veneer dryer and removal of
vermiculite-containing bricks.
Valve House at Finger
Joiner Building (EPA,
2010d)
Summer 2010
EPA
Removal of soil and
vermiculite-containing
building materials.
Central Maintenance
Building (EPA, 2010e)
January 2010
EPA
Removal of vermiculite-
containing insulation and
interior cleaning.
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TABLE 1-1 (Continued)
Response Actions Taken at OU5
Location (rolerelice)
Dale
Lead Aปcncy/('ompan\
Description
Former Popping Plant
(EPA, 2013a)
Summer 2011
EPA
Soil removal
Central Maintenance
Building (CDM Smith,
2011)
Fall 2011
EPA
Interior cleaning of areas
impacted by land owner
removal of asbestos-
containing roof materials
Port Authority
Soil removal associated with
Building (CDM
Offices; EPA 2012a)
Spring 2012
EPA
revegetation demonstration
plot/
Former Nursery Area
(EPA, 2012b)
Summer 2012
EPA
Soil removal
Central Maintenance
Building (EPA, 2012c)
Removal of vermiculite-
Fall 2012
EPA
containing insulation and
interior cleaning.
Former Tree Nursery
(EPA, 2013b)
Spring 2013
EPA
Soil Removal
\J 1. VJ J | | I
Source: CDM (2007) OU5, Final Data Summary Report - October 16, 200; CDM (2012) Summary
Report Memorandum and various Removal and Restoration Completion Forms (EPA or CDM, 2010-
2013).
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TABLE 3-1
Sampling Events at 0U5
Location
Date
1 n\ esligal ion Descriplion
Media ( olleclcd and
Anal\/ed
Reason lor Selecting Sample
Location
Former Nursery
May 2002
Phase I Investigation
Dust
Investigative
OU5 Site-wide
September/
October 2002
Contaminant Screening
Study (including building
inspections)
Air, personal
Air, stationary
Dust
Soil
Non-discriminatory grid based
sampling
MotoX Track
May 2004
Soil sampling
Soil
High use area
Central
Maintenance
Building
April/May,
August 2004
Pre-design inspection; soil,
dust, and bulk insulation
sampling
Soil
Dust
Bulk
Building contains vermiculite based
materials
Proposed
Demolition
Derby Area
July 2004
Soil sampling
Soil
High use area
Former Nursery
June 2005
Soil and air sampling to
correlate soil contamination
with airborn fibers.
Air, personal
Air, stationary
Soil
Location was suspected to have
vermiculite in soils and was therefore a
suitable location.
OU5 Monitoring
Station
October 2006 to
September 2007
Libby ambient air
monitoring
Air, stationary
Aimed to determine general
background asbestos concentration
levels at site
OU5 Site-wide
October 2007
Soil data gap sampling
Soil
Collect samples from areas not
previously investigated.
Wood
Chip/Waste Bark
Piles
October 2007
Wood chip/waste bark pile
sampling; outdoor worker
activity-based sampling
Air, personal
Soil
Waste bark
Wood chips
Waste bark stored on site may contain
asbestos and traveled to site
Note: Excludes worker air samples collected as part of OSHA requirements that were analyzed by AHERA
Source: Based on a download of the Libby2DB performed 12/9/09
-------
TABLE 3-1 (continued)
Sampling Events at OU5
Location
Date
1 n\ esligal ion Descriplion
Media ( ollcclcd and
Anal\/cd
Reason lor Selecting Sample
Location
Various OU5
Buildings
November 2007
to January 2008
Indoor worker activity-
based sampling
Air, personal
Air, stationary
Dust
Estimate LA exposure to workers
OU5 Site-wide
June/July 2008
Soil data gap addendum
sampling
Air, personal
Soil
Collect samples from areas not
previously investigated.
MotoX Track
September 2008
Outdoor recreational
activity-based sampling
Air, personal
Air, stationary
Soil
Estimate LA exposure to recreational
users
Bicycle &
Hiking Trail near
Libby Creek
September 2008
Outdoor recreational
activity-based sampling
Air, personal
Estimate LA exposure to recreational
users
OU5 Site-wide
September/
October 2008
Outdoor worker activity-
based sampling
Air, personal
Soil
Vegetation
Estimate LA exposure to workers
Landfarm
October 2008
Landfarm soil sampling
Soil
Area of Groundwater Superfund Site
not previously sampled
OU5 Re-
development
Zones
April 2009
Re-development soil
sampling
Soil
EPA requested to do re-development
plans
Libby Creek
Driveway
April 2009
Pre-design inspection; soil
Soil
EPA requested to do re-development
plans
Wood Chip Piles
August 2011
Outdoor activity-based
sampling
Air, personal
Estimate LA exposure to individuals
who distrurb wood chips.
Proposed fishing
pond location
June 2012
Pre-design soil sampling
Soil
Assessment prior to
design/construction of proposed
fishing pond.
Note: Excludes worker air samples collected as part of OSHA requirements that were analyzed by AHERA
Source: Based on a download of the Libby2DB performed 12/9/09; CDM Smith 2012 and EPA 2013b
-------
TABLE 3-2
Visible Vermiculite Inspection Scores and Selected Locations for Outdoor Worker ABS
Area
Visible Inspection Results
Score
Category
None
Low
Med
High
1
30
0.00
None
2
30
0.00
None
3
28
2
0.07
Low
4
28
2
0.07
Low
5
26
4
0.13
Medium
6
26
4
0.13
Medium
7
21
8
1
0.37
High
8
6
20
3
1
1.30
High
See figure 3.2 for ABS Area Locations
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Figures
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kootenai.River
iTfowiO-UM
Canada
\
Legend
HDR Engineering, Inc
OU Boundaries
OU5; Former Stimson Lumber Mill
| OU6: Rail Line
^///; OU7: The Town of Troy
| OU8: Roadway
Map Layout A dapieti from COM
OU1: Former Export Plant
OU2: Former Screening Plant
OU3: Mine Site
OU4: Libby Homes and Businesses
Idaho
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby, Montana
Wyoming
Figure t-1
DATE; SEPTEMBER, 2010
-------
Groundwater Superfund
Site
HDR Engineering, Inc.
Uhby Groundwater Superfund Site
Remedial investigation
Ofxwafife LtnR $ - Ubby Asbestos Site
Ltttoy, Montana
DATS: SEPTEMBER, 2010
-------
[FfcsSteg)
Koo tenailRiverg
p>lvwo od'^lan tJj
(D e strove d{m^0?Q|Rire)]
igower^House]andl
iKowerj H ouselutt i ce!
P Finger JointerjJ
PmcessingJRIantj
MStoragelandB'
[OocomotivelSh'ea
Log Yard
Scale House
{Occupied)
Truck Barn
Central Maintenance
Wagner Shed
Electric Pump House
Steel Storage
Main Office Electnc,Motor-Shed
Office/Lab ratory
Chemical Storage Building
Intermediate Injection Building
BBi ore actor Building
Diesel Pump House
Tank Farm Building
LTU Leach ate I
(Building #2) I
(Vacant) L
bTMQeachate
f(Btiilclihq'#1)
ฆ(ftacaht)
Legend
HDR Engineering, Inc
- Bike Path (Unpaved or Partially Paved) | | Buildings - Occupied
Bike Path (Paved, as of Sept. '10) | | Buildings - Vacant
[_^J Storm Water Containment and Waste Water Lagoon Area | | Buildings - Open Air (less than four walls)
~ Waste Bark Piles Debris Railroad Spur
_ I Approved Waste Bark Disposal Area Former Popping Plant
iMotoX Track Lumber Yard
(Existing Buildings
as of May 2013)
OU5 Land Uses and
Building Locations
Focused Feasibility Study
Operable Unit 5 ฆ Libby Asbestos Site
Libby, Montana
Libby Groundwater Superfund Site
OU5 Boundary
Former Champion Int. Tree Nursery
DATE: MAY, 2013
Log Storage Area
Southwest Area
OU4 (limits are approximately in vicinity of Libby Creek)
Surface Water
Note: Some map objects adapted from CDM
-------
Libby Creek rip-rap removal
(OU4 action with possible
encroachment on OU5)
Tibbv'Crjeek'
y V \ :
'Koo tenailRi vert
Log Yard|
^ScalelHriuse"]
Removal of vermiculii
containing soil (2012)
Removal of vermiculite
containing materials
in lunch room and bathroom
EormerSNurservi
[4 ropose d|Ri s h i nql Ro n d|
Removal of vermiculite containing
soils surrounding valve house and
valve house floor (2010)
Removal of vermiculite
containing soil (2013)
|RoweriiTous'e and J
Power House Office
i
Removal of vermiculite containing
insulation and building materials
from attic space, walls, and
ceiling of valve house (2010)
Stora"geIan"dB3
J-oc om'otivelsnedl
,RIy.w.oodlRlant^q ,
D es trovedi m
-------
Plywood11 Plant
Destroyed
o
-ft ? wretroflome
1
PowenHouse fand
RowerJH o u s elO ft ice
Finger Jointer
StoraqeTand
R ro c es si n q IRIant
otive Shed
Log Yard/ c
Sea eHouse
Truck
F re Ha
Centra Maintenance
Si
Shed
&A
Electric P.
n/ o
oฐฐฐ 6
ouse
k
Steel Storage
Main Office Electric Motor Shed , r
h \o%oTtrr
ซ rfฃb o O O ]|
ฐ \ Chemical Storage Building
jww-JHfflBwwo q o o iซi f,
Office/LTa oratory
Intermediate lnjectionaBuildinc} q q
O O o 0* N
Diesel PumpJHouse
Bioreactor Building ^ ~
tto ฆ hi sakpk o o o a, 0
: Q o o o\ฐ
KiKfe
& /r9 n O
jKHj/ljo-Jank FarnrBuilding
: !o o
o \ O
LTU Leach ate
(Building #2)
L-TiUJLeach ate
VMiBuilding #1)
HDR Engineering, Inc
Surface Water
| Buildings - Occupied
~
~
~
Lji
Legend
Surface Soil Sampling Locations
Bike Path (Unpaved or Partially Paved)
Bike Path (Paved, as of Sept. '10)
Storm Water Containment and Waste Water Lagoon Area
Waste Bark Piles Debris
Approved Waste Bark Disposal Area
MotoX Track
Libby Groundwater Superfund Site
Worker ABS Areas
OU5 Boundary
OU4 (limits grs approximately in vicinity of Lioby Creek)
] Buildings -Vacant
] Buildings - Open Air (less than four walls)
Railroad Spur
] Former Popping Plant
Lumber Yard
Former Champion Int. Tree Nursery
Log Storage Area
Southwest Area
Surface Soil Sampling Locations
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby, Montana
DATE: MAY, 2013
Figure 3-1
0.075
0.15
0.225
0.3
I Miles
-------
Building
Sample Size (N)
Mean
Bioreactor Building
0.00047
O.OOD16
Main Office
0.00224
Central Maint. Building
0.01021
0.00117
Log Yard Truck Scale House
0.01386
Electric Motor Shed
Off ice/Lab oratory
0.00049
0.000163
Chemical Storage Building
Wbby Creek
aI
Diesel Pump House
0.OD02S
0.00091
Electric Pump House
0.00084
Intermediate Injection Building
Log Yard /
Scale House
LTU Leachate Building #1
0.00049
0.00009S
LTU Leachate Building #2
Power House / Office
Tank Farm Building
Power Housejand 1
Power House dffice
Finger Jointer Processing Plant
No ABS Air Data Available
Usto raq eya n d m
LWc o mot iwlS fied
I fPiese11Ru mp]House.
I Rly^odjPlant
(De s'tr.oyed(inf2dlCljFi re)
Elect riclPumpiHouse;
M LbTUJ LTeac hatea
jgLprBu| fj i*ng^2)E
WHHVacant)5fl|
If ifciM
jr LTUjLeachatc
B uildtn gl#i)]
jit feacaniW
[Off ice/Lfabrato r.yj
Astrodome,
ft >
-^Firiger^o inter
c Proccs^ing^l ant
r.
.Jm i
Wagner Shed
Chemical Storage;
^^ฆBuiltiinge
.Tank,liarm.Building
ElectriciMotorShed
B i orea ctorJBuilding
Truck Bam
j7 f Interm'ed iatejinjection^Building
.Central Maintenance
Steel Storage
Legend
~ Buildings - Occupied
I I Buildings - Vacant *%ฃฃ$
~ Buildings - Not Sampled: Buildings have less than four walls
OU5 Boundary
O U 4 (limits are approximately in vicinity of Libby Creek)
.Main Office,
HDR Engineering, Inc
ABS Indoor Air Results
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby, Montana
DATE: MAY, 2013
1 - Includes B & C packaging area
ABS measurement unit is LA structures per cubic centimeter (s/cc)
-------
tSmmmm
Mm,
Mean
Arealb
Max.
0.007207
Ply.wopd P,lant
(Pest ro ved, mg OilOl R ire)
Mean
0.002511
mm&j
1
UibbvICrjeek
Area~5 ' *
Max
0.059399
Mean
0.011912
V
a
.-ฅ^B
0.011941
Min.
Mean
0.00199
005674
0.011181
Mean
0.001275
Min.
Mean
0.003076
Bike Path Area
3
Adult1
N=39
Child2
N=7 1
Max.
0.001778
Max.
0.000924 |
Min.
0
Min.
0 1
Mean
0.00009485
Mean
0.0001319 |
Max.
0.011413
Min.
0
Mean
0.002287
Max.
0.011363
Min.
0
Mean
0.006334
MotoX Area
Personal
3
II
z
Stationary
N=10
| Max.
0
Max.
0
| Min.
0
Min.
0
| Mean
0
Mean
0
ABS Outdoor Air Testing Sites*
Bike Path (Uripaved or Partially Paved)
Bike Path (Paved, as of Sept. '10)
ฃ
-------
KootenaifRiver,
Log Yard
Sea lei House
Libby Creek'
g Power! HoiisejJanaL :
RowerHousefOff ice _
Storage? and LacomotiveJShed
Diesel RurnffiHouse
"Plywood,Plants I .
[gjagShoB.
Wagner,Shed
Astrodome
/ Shed 12
Finger Jointer
Processing Plant
Electric]Rump House!
Lumber
-------
;L<: 7 /
N
'-nTr* !>
a 5 *
Kootenai River,
ฆฆฆ SI:
AreaT6
UibbylCrjeek
UPlywoocTRIant
,(Dest rov^d1 i n>2Q?l*o]
I
ฃ
aatei
J rJk.<
ri-V-vSi
ฃฆ
O
o v^H
Area?3
*
D O O O
O 0 OC-\
--T/JT o O O Ox= 1%
ฉ < 1%
O Trace
Non-Detect
Bike Path (Unpaved or Partially Paved)
Bike Path (Paved, as of Sept. '10)
Storm Water Containment arid Waste Water Lagoon Area
Waste Bark Piles Debris
Approved Waste Bark Disposal Area
| | MotoX Track
J Libby Groundwater Superfund Site
Worker ABS Areas
OU5 Boundary
OU4
(limits are approximately
in vicinity of Ubby Creek)
UZh
Abatement Reponse Action Areas'
] Buildings - Vacant
Buildings - Open Air (less than four walls)
Surface Water
Railroad Spur
Former Popping Plant
Lumber Yard
Former Champion Int. Tree Nursery
Log Storage Area
Southwest Area
Results shown on Figure reflect testing done before
abatement actions. See Figure 1-4 & Table 1-1
for details on response actions taken at OU5.
HDR Engineering, Inc.
LA in Surface Soil - PLM Results
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby, Montana
DATE: MAY, 2013
Figure 5-4
0.08
0.16
0.24
0.32
I Miles
-------
Af
WKoo tenailRiver,
^ฆEyentfl
Area 6
I Events
UtboylCrfiek
Event
Event
Event
ฆPI vwoodlRI a nt
Area.2
{D estrovedIin>2 0101 hire)
epmpKGrab
Events
Eventx2
EverirS
t
mjm
Event
mrv.
Area ,3
a
Event\1
AreaX1' - ..ฃฆ #J1
ฆ y^.\nuA
~7 ~ ~ ~ Q
Event
i/i
Jih Q <
'~^.P
RompMGrabl
Events
Event*!'
Eventr2
Events
mmm
Area-TI
'
Area 8
jagJP PXQfgJ>
\TEvenU1
.ompMGfab
Event*!
Events
!
Events
Event 3
~ Buildings - Occupied
Visible Verrniculite Results
Composite Score
ฆ > 0.3 - 0.5
~ > 0.1 - 0.3
~ <= 0.1
ฆ 0 (Non-Detect)
Qualitative Status (Grab & Comp.)
A VIS +
A VIS-
ฆ Bike Path (Unpaved or Partially Paved)
Bike Path (Paved, as of Sept. *10)
| Storm Wafer Containment and Waste Water Lagoon
) Waste Bark Piles Debris
] Approved Waste Bark Disposal Area
| MotoX Track
I Worker ABS Areas
OU5 Boundary
Abatement Reponse Action Areas1
ฆ ฆ (Existing Buildings
| j Buildings - Vacant as of May 2013)
Area ~ Buildings - Open Air (less than tour walls k
Surface Water
L J Libby Groundwater Superfund Site
Railroad Spur
ง Former Popping Plant
Lumber Yard
Former Champion Int. Tree Nursery
Log Storage Area
I Southwest Area
ABS Score
Note: The ABS results matrix presents
the visible verrniculite scores for the three
30-point composite samples and the three
sets of 30 grab samples (see Section
3.2.2 for discussion of visible verrniculite scoring).
Results shown on Figure reflect
testing done before abatement
actions. See Figure 1-4 & Table
1-1 for details on response actions
taken at OU5.
HDR Engineering, Inc.
Visible Verrniculite
in Surface Soils
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby, Montana
DATE: MAY, 2013
Figure 5-5
0.08
0.16
0.24
0.32
f Miles
-------
UibbyZOreek*
jmvwoocl'RIantM
/^/(De:Iroyed in 2010 Fire)
festrodome,
il^owefl H ouseTandl
HoweriH "useiortiee!
ป Finger Jointera
Processing Plant
^Storage ;and?
[DocorriotivelSh'ea
[ShetlEtgi
Log Yard
'Scale House
Truck Barri
Central Maintenance
Wagner Shed
Electric Pump'House
Steel Storage
Main Office Electric.MotorShed
'Office/LTabratory
Chemical Storage Building
Intermediate Injection-Building
^jBforeactor Building
Diesel PumjTHouse'
\ r
Tank Farm Building
[PTLUJIfeachate
[(Builcjinq^Jf,1
jLTU Leach ate (
(Building #ZmM
Sub-Surface Soil Results
LA in Sub-surface (Grab)
A <1%
A Trace
A Non-Detect
LA in Sub-surface (Composite)
~ Buildings - Occupied
i 1 (Existing Buildings
| | Buildings - Vacant asotMay2013}
~ Buildings - Open Air (less than four walls)
|__J Surface Water
Railroad Spur
Former Popping Plant
1 Lumber Yard
Bike Path (Unpaved or Partially Paved)
Bike Path (Paved, as of Sept. '10)
Worker ABS Areas
HDR Engineering, Inc
LA and Visible Vermiculite in
Sub-Surface Soil
Storm Water Containment and Waste Water Lagoon Area
Waste Bark Piles Debris
@ <1%
O Trace
O Non-Detect
Visible Vermiculite Level (Grab)
Approved Waste Bark Disposal Area
MotoX Track
Remedial Investigation
Operable Unit 5 - Libby Asbestos Site
Libby, Montana
Libby Groundwater Superfund Site
GU5 Boundary
Former Champion Int. Tree Nursery
Log Storage Area
Southwest Area
DATE: MAY, 2013
O U 4 (limits are approxima te/y in vicinity of Libby Creek)
Moderate
Abatement Reponse Action Areas'
Results shown on Figure reflect testing done before
abatement actions See Figure 1-4 & Table 1-1 for
details on response actions taken at OU5.
None
-------
Appendices
-------
Appendix A
Response Action Reports
-------
Appendix A1
OU5 Redevelopment Area
Investigation Summary
-------
CDM
Memorandum
To: Amishi Castelli, Volpe Center Task Order Manager
From: Thomas Cook, CHMM, CDM Field Investigation Manager
Date: May 12, 2009
Subject: Investigation Summary - OU5 Re-development Area
Background
CDM Federal Programs Corporation (CDM) was tasked with performing investigation
activities within a designated area on the former Stimson Lumber Company site, OU5, to
support future re-development activities. The investigation consisted of collecting soil
samples for Libby amphibole (LA) asbestos analysis, performing inspections for vermiculite,
and delineating areas with LA contamination and/ or vermiculite for subsequent removal
activities.
Investigation Summary
All work was completed in accordance with the technical memorandum dated April 17, 2009
from Thomas Cook to Amishi Castelli, Subject: Soil Sampling and Visual Inspection - OU5
Re-development Area (CDM 2009). The investigation activities were performed April 20
through April 22, 2009. Prior to field activities, a field planning meeting was held with key
members of the field sampling team to review the sampling plan and procedures. There were
no deviations in sampling or inspections from the technical memorandum or associated
documents.
Eight sampling zones were established, sampled, and inspected in accordance with the
technical memorandum (Figure 1). Only soil/ gravel areas within the identified zones were
sampled and inspected. Areas covered with concrete or pavement were not included as part
of this inspection. Figure 2 illustrates the detail of each sampling zone and location of
vermiculite observed. Copies of logbook entries, field sample data sheets, and visual
vermiculite estimation forms are included in Attachment A.
A total of nine soil samples (eight field samples and one field duplicate) were collected. In
addition, vermiculite inspections were performed in each sampling zone. All soil samples
were analyzed for LA by the polarized light microscopy-visual estimation method (SRC
2008). Analytical results for all samples were non-detect for LA (Attachment B). Low amounts
of vermiculite were observed in zones six and seven. In zone six, vermiculite was observed
DCN: DC2616.015.202.DVOU5-2945.00
-------
Amishi Castelli
May 12, 2009
Page 2
concentrated within a specific area between the north road and concrete slab (Figure 2).
Within zone seven, vermiculite was observed widespread throughout the entire zone. The
following table summarizes the analytical and vermiculite inspection results for each
sampling zone:
Zone
Sample
Index ID
Analytical Result
(Percent Libby
Amphibole)
Number of Vermiculite Inspection Points by Zone
None
Low
Medium
High
1
SL-01760
Non-detect
30
0
0
0
2
SL-01761
Non-detect
30
0
0
0
2
SL-017681
Non-detect
30
0
0
0
3
SL-01762
Non-detect
30
0
0
0
4
SL-01763
Non-detect
30
0
0
0
5
SL-01764
Non-detect
30
0
0
0
6
SL-01765
Non-detect
30
62
0
0
7
SL-01766
Non-detect
30
103
0
0
8
SL-01767
Non-detect
30
0
0
0
1sample SL-01768 is a field duplicate of SL-01761
Concentrated in specific area
3widespread throughout sample zone
Removal Activities
Areas requiring removal activities were identified based on results of this inspection and
information gathered during previous investigations. In general, areas were identified for
removal if vermiculite was observed and/ or analytical results had detectable levels of LA.
Figure 3 illustrates the areas requiring removal activities.
Prior to removal activities, a government representative will meet with the property owner to
review the removal plan. During removal activities, only government-authorized personnel
are allowed to access the areas being remediated.
All work at the property will be conducted in accordance with the Comprehensive Site Health
and Safety Plan (CDM 2006) and the Response Action Work Plan, Revision 2 (CDM 2008a).
DCN: DC2616.015.202.DVOU5-2945.00
-------
Amishi Castelli
May 12, 2009
Page 3
The following table summarizes the areas identified for removal and planned restoration
activities.
Area
Rationale
Approximate
Area (ft2)
Excavation
Approximate
Volume (yd3)
Restoration
A
Vermiculite1
10,845
6 inches below
surrounding
grade
822
3/4-inch minus
crushed rock to grade
B
Vermiculite2
25,300
12 inches below
grade
937
3/4-inch minus
crushed rock to grade
C
Vermiculite2
5,315
12 inches below
grade
197
3/4-inch minus
crushed rock to grade
Observed during vermiculite inspection June 2008
2observed during vermiculite inspection April 2009
ft2 - square feet
yd3 - cubic yards
The total volume of material to remove is approximately 1,956 cubic cards. Area A, including
mounded areas, will be excavated to 6 inches below surrounding grade. Areas B and C will be
excavated to 12 inches below grade. Confirmation soil samples will be collected in accordance
with the Response Action Sampling and Analysis Plan, Revision 1 (CDM 2008b). All areas
will be restored with 3/4-inch minus crushed rock (structural fill) to grade.
References
CDM. 2006. Comprehensive Site Health and Safety Plan, Revision 5. Libby Asbestos Project,
Libby, Montana. December.
. 2008a. Response Action Work Plan, Revision 2, Libby Asbestos Project, Libby, Montana.
February.
. 2008b. Response Action Sampling and Analysis Plan, Revision 1, Libby Asbestos Project,
Libby, Montana. April.
. 2009. Technical Memorandum from Thomas Cook to Amishi Castelli, Subject: Soil
Sampling and Visual Inspection - OU5 Re-development Area. April.
SRC. 2008. Analysis of Asbestos Fibers in Soil by Polarized Light Microscopy, SOP No. SRC-
LIBBY-03, Revision 2. October.
DCN: DC2616.015.202.DVOU5-2945.00
-------
Amishi Castelli
May 12, 2009
Page 4
cc: Julie Borgesi - Volpe Center, Cambridge
Courtney Zamora - Volpe Center, Libby
Dee Warren - CDM, Denver
Terry Crowell - CDM, Libby
Libby Project File - Denver
DCN: DC2616.015.202.DVOU5-2945.00
-------
Figure 1
_&icu~age-and
Locoi lotive Shed
Finqer Joinl
I
Processing P
^Investigation Boundary |%j
* Area to be removed 1*3
J n^eclioiv Sample Zones |
Shed 12
Lumb >r Kiins
FirejHall
P
Truck-,Bain
DCN: DC2616.015.202.DVOU5-2945.00
-------
Figure 2
CLIENT VOLPt
PROJECT I J&fiM ASBzSTof
DETAIL K1S 3 ' ST7/VS fW
of AftfcfiS j4ฃoUW!>
__ JOB NO.
__ DATE CHECKED
_ CHECKED BY
O&s MODES.. SU-H^. iLrJ+S.SL-S:.!., OL-.^Z,
CP tn
ft
\s*j
CDM 11/17
-------
|1|
PROJECT 1-'fefiปM ASfecaTDS
JOB NO.
DATE.
- ,'- Oc:
COMPUTED BY S-
<%1S US HvWM 2
CHECKED BY
CLIENT MOUPZ
DATE CHECKED
PAGE NO. ! ฐP !
Figure 3
is.
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-------
Attachment A
Field logbooks, field sample data sheets, and visual vermiculite
estimation form
DCN: DC2616.015.202.DVOU5-2945.00
-------
19
i
Volpe/Libby Asbestos Project Logbook:
Owner:grtง46014 L44MB&2? Date: 4' Z^-Zoo0!
Address: 2S
Author: j\ .M ซ _ Weather: SaAg\ซn>y ^ฃ>6
Personnel: A.M. Crifre^ T S. Wit*"
Activities:jsAMKyJZr K Vts*Ac msfCno*^
ja.
PPE: \pM b
All activities completed in accordance w/governing doc.
PDIWP, SOP CDM-Libby-06, Rev.l, and SOP CDM-
Libby-05, Rev. 2.
Trimble 6: ProXRS Asset Surveyor 5.27
Datalogger: 0220169420
Antenna: 0220173334
Receiver 0220270969
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-------
50883.670(7. 2(o\b- 0(5 -Z02. p\/ou,5
Sheet No.: S- 005457
LIBBY FIELD SAMPLE DATA SHEET (FSDS) FOR SOIL
Field Logbook No: 10 1 09^ Page No: Sampling Date: *4-21 -ZQC^
\ddress: SIS Hi a- -S"
FDof
EB
LB
fED
v . 1-*^*^
FDof
EB
LB
Matrix Type <
(Surface soil unless other
wise noted)
..Surface So0
Other
Other
(Surface SolP
Other
Type (circle)
Grab
^cJrm^subsamDles "3^ t
Grab
'tSmjx^subsamDles 5O
Grab
(Comp^f subsamples BO
GPS Status (circle)
^6oilecte3>
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
^ <
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
'"ColieSeS
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
GPS File (fill in or circle)
Filename: i (c A 04ZiQ NA
Filename: T(o AOM-Zl^ NA
Filename: Xk AhU 7\ c. NA
Sample Time
1030
[OSS
Top Depth (inches
below ground surface)
O
a
O
Bottom Depth (inches
below ground surface)
G
Q>
fc
Field Comments
Note ifvermiculite is
visible in sampled area
BD- AD-000 6*6
kiO
BD- AK-OOOfdte*
BD- ArT>--OO0(hฃ)6-,
Entered (LFO)
Volpe:
Entered Validated
Volpe:
Entered Validated
Volpe:
Entered Validated
For Field Team Completion (Provide Initials)
Completed by: A*1 C.
QC by:
-------
67017. 2klfe- 015- 2-0%. 0*0 US
Sheet No.: S- 005458
LIBBY FIELD SAMPLE DATA SHEET (FSDS) FOR SOIL
Field Logbook No: In I Page No: \ฐ\ ^2-\ Sampling Date: *4 2 i 20Q<^
\ddress: SIS 2S (fdwo^r/Tenant: Sri M.soKi m kREi^
Business Name: snUAfbriKl LUKfefce.
Land Use: Residential School ^cstnm^a^ Mining Roadway Other ( )
Sampling Team: Other Names: M* ("Itrt + es
Data item
Sample 1 ฉ
Sample 2 ฉ
Sample 3 ฎ
Index ID
SI- 01763 /
0-
SL- 01764
TflP
1
SL- 01765 4
\AC
Location ID
SP- 136652 ^
4
. SP- 136653
SP- 136654^'
Sample Group
P^-o fee-TV
*
""
Location Description
(circle)
Back yard
Front yard
Side yard a
Driveway
COtheXy
Back yard
Front yard
Side yard /l/Zefc ST
Dqyei/vay
Hither J)
Back yard
Front yard
Side yard q
Driveway
Category (circle)
3>
FD of
EB
LB
(EP
FDof
EB
LB
FDof
EB
LB
Matrix Type (
(Surface soil unless other
wise noted)
^Surfece^il
Other
jurfice SoiD>
Other
Cงurface~Soir>
Other
Type (circle)
Grab
(Comp'^ubsamDles 3o (
Grab
"^omp.^^ubsamples 30
Grab
Cc3mDjฃkubsamples 3ฃ>
GPS Status (circle)
<
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
'Collected
** i i *^**^
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
(Coiected)
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
GPS File (fill in or circle)
Filename: Tt?An'-tZlc\ NA
Filename: Tfc-ACiM-Zt'n NA
Filename: Tie A OU 2 I "n NA
Sample Time
13 ฃ5
-(GCC
Top Depth (inches
below ground surface)
O
o
0
Bottom Depth (inches
below ground surface)
Co
ฃ>
b
Field Comments
Note if vermiculite is
visible in sampled area
BD- /4b- 0O0<&86
NO -
BD- A0-000(o9i^
BD- AD-OOOfc&k
Entered (LFO)
Volpe:
Entered Validated
Volpe:
Entered Validated
Volpe:
Entered Validated
For Field Team Completion (Provide Initials)
Completed by:
c_
QC by:
ej
vs 10507
-------
5068R. blon . 2k 0l5- 2C2- PvouS
Sheet No.: S-
Field Logbook No:
IY FIELD SAMPLE DATA SHEET (FSDS) FOR
i r> (P Page No: \ฐr ^ Sampling Date:
\ddress: &7S High wavj 2 6
Business Name: STlMSoM L-U M.B St2_
(<5wngl"/Tenant: ST" i M. So M l^i * Mftie iฃ.
= M\A-C
M - 21 -
H-'Z-t '<^1,
Land Use: Residential School
Sampling Team: (^Dp> Other
;ommerci^i> Mining Roadway Other (
Names: S-VVUsolO . 4 . M - Cir fTe
Back yard
Front yard
Side yard ^
Doyejway
th
Back yard
Front yard
Side yard
Driveway
"Others
Location Descnption
(circle)
&$SAi2ฃAl
FS sl-6/76 1
(PWof S
Other
^Surface Soil)
Matnx Type
(Surface soil unless other
wise noted)
Other
Other
Grab
Qorrip.^subsamples 3O
Type (circle)
Grab
-^CompT^Iubsamples 30
Comp-jtbubsamples Bo
llectegl^
Previously Collected
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
Collected
[Previously CoNectecK
GPS Status (circle)
Collect
PreviousMCoIlected
Not Collefted-no signal (3 attempts)
Not Collacted-not required for sample
Not Collected-no signal (3 attempts)
Not Collected-not required for sample
Filename:
Filename: T(oAQ<-1-Z\ฐi NA
Filename: TC U/LI
GPS File (fill in or circle)
Sample Time
Top Depth (inches
below ground surface)
Bottom Depth (inches
below ground surface)
BD-AD-POO
BP- AD-DOO
-------
LIBBY SUPERFUND SITE
Visual Vermiculite Estimation Form (WEF)
Field Logbook No.:
Address:
Occupant:
101093
875 Hwy 2 S
Stimson
Owner (If different than occupant):
Investigation Team:
Field Form Check Completed by (100% of Forms):
Page No.:
19
Site Visit Date:
4/21/2009
BD Number:
AD-000686
S.Wilson, A.M Crites
Phone No.:
Phone No.:
Investigation Name:
Structure Description: Property
OU5 Redevelopment
Visual Verification by Field Team Leader (10% of forms):
Zone 1
Zone 2
Zone 3
Zone 4
Zone 5
Zone 6
Zone 7
Zone 8
Type
(SUA/CUA/LUA/ISA)
LUA
LUA
LUA
LUA
LUA
LUA
LUA
LUA
Description
PROPERTY
PROPERTY
PROPERTY
PROPERTY
PROPERTY
PROPERTY
PROPERTY
PROPERTY
Area Size
(square feet)
18119
30600
28500
29700
31350
28900 (not including
concrete)
24035
49600
General Comment
(Cover, etc.)
GRASS
GRASS
GRASS
GRASS
GRASS
GRASS
STRUCTURAL FILL
GRASS
Pis
(X=None, L=Low, M=lntermediate, H=High)
X
30
60
30
30
30
30
30
30
L
5
10
M
H
Total
30
60
30
30
30
35
40
30
Areas previously identified for removal not inspected for visible vermiculite? Yes Location(s): Area along north boundary of GPS node SL-45 and SL-43
Page 1 of: 1
-------
Attachment B
Analytical Results
DCN: DC2616.015.202.DVOU5-2945.00
-------
FILENAME: RESI 171988 PLM VE.xls
Version : 7c
PLM VISUAL ESTIMATION DATA RECORDING SHEET
Laboratory
Name
RESI
Data Entry by:
K. Carlaccini
Job Number
171988
Data Entry Date:
4/29/2009
Date
Received
4/28/2009
SOP
Name.'Revisi
SRC-LIBBY-03 (Rev 2)
QC Check by:
G. Vettraino
Spreadsheet
version
7c
QC Check Date:
4/29/2009
EPA Index ID
Index
Suffix
Char.
Index
Suffix
No.
QA Type
(NOT QA,
LDS.
LDC)
Lab
Sample
ID
Date
Analyzed
Analyst
Name
Stereomicroscopy Examination
Libby Amphibole (LA)
Other Amphibole (OA)
Chrysotile (Ch)
Deviation?
Comments
OPTICAL PROPERTIES FOR LA (see key for data entry inputs)
Sample
Appearance
Qual
LA-MF
(%)
Qual
OA'C-
AF
(%)
Ref
Material
(B orT)
Qual
LA-MF
(%)
Bin
Qual
OA-AF
(%)
OA Type
(AMOS,
ANTH,
CROC,
UNK)
Qual
Ch-AF
(%)
Morph.
Fiber
Color
Sign
Elong.
<+/-)
Pleoch.
(Y/N)
Extinct.
Angle
Ref.
Index
a
Ref.
Index
Y
Biref.
Optical
Comments
SL-01760
FG
1
Not QA
413365
4/29/2009
RSW
Brown soil, fine
ND
A
ND
ND
SL-01761
FG
1
Not QA
413366
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
SL-01762
FG
1
Not QA
413367
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
SL-01763
FG
1
Not QA
413368
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
SL-01764
FG
1
Not QA
413369
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
SL-01765
FG
1
Not QA
413370
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
SL-01766
FG
I
Not QA
413371
4/29/2009
RSW
Brown soil, fine
ND
A
ND
ND
SL-01767
FG
1
Not QA
413372
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
SL-01768
FG
1
Not QA
413373
4/29/2009
RSW
Tan soil, fine
ND
A
ND
ND
-------
COM
pkubt _S=!39rf_ฑi4S2I
06 0109
*1* US Hปm2
amn unL.'V
Figurr Posป Removal Sitr Condrftons
and Oearance Sampling
Area A1
Excavated 6" BGS
Clearance Sample 2R-05227
Rc-sulr NO
A.~.i tl '
Excavated 12" BGS
Clearance Sample 2R-05225
Result ND
Area A4
Excarvated
Area tl-1
Excavated \T BGS
ฆ".leafante Sample 2R <ซ.*>
Result NO
Aifa Bb
12--14'BGS
aranti; Sample 2R-CVS374
NO
Clem
^Result
Area A*.
Excavated 6" BGS
Clearance Sample 2R-QS2M
Result NO
FxcavatM 1T BOS
Cieaianre Sample 2R-0623S
Result ND
12'BGS
lewance Sarป*te 2R-0622A
Hesull NO
AteaB/
Excavated 12* BGS
Clearance San-*>* 2RQS229
Result NO
AreaCi
Excavated 18' BGS
Clearance Sample 2R-05371
Result ND
Area bb
Excavated 12" BGS
Clearance Sample 2IWS230
Result NO
vt
SeaTi 10
Excavated 12" BGS
Clearance Sample 2R 05232
Result ND
Area A>
Excavated 6* BGS
~ Clearance Sample 2R-05229
Result ND
Excavated V &
encountered ennarte slab
No clearance sample collected
' Excavated 10" BGS
''Clearance Sample 2R-OS372
Result ND
Excavated 12" BGS
Clearance Samp* 2R-05224
Result ND
Area 8Eซ
Excavated 12" BGS
AreaBS
Clearance Sample 2R-05231
Excavated 12* BGS
Result ND
Clearance Sample 2R-05237
Result NO
Area A3
Excavaited 12"-14" BGS
Clearance Sample 2R-05373
Result NO
-------
Appendix A2
Response Actions at Central Maintenance Building
-------
Addendum to the
Response Action Work Plan
Former Stimson Central Maintenance Building
Removal Plan
875 Highway 2 South
1.0 Introduction
This removal work plan is an addendum to the Response Action Work Plan (RAWP) (CDM 2003)
and details specific information regarding removal activities that will take place at the Former
Stimson Lumber Central Maintenance building, 875 Highway 2 South.
This plan includes building characterization data for the identification of vermiculite containing
insulation (VCI), vermiculite containing building materials (VCBM), vermiculite containing soil
(VCS), and evidence of Libby Amphibole (LA) asbestos in dust. Specific work to be performed on
this property is also detailed on the following Contract Drawings:
Former Stimson Central Maintenance Building Overall Site Layout - Figure 1
Former Stimson Central Maintenance Building Interior Removal Plan - Figure 2
Former Stimson Central Maintenance Building Exterior Removal Plan - Figure 3
Former Mobile Shop Wall Details - Figure 4
All work on this property will be performed in consultation with the U.S. Environmental Protection
Agency (EPA) On-Scene Coordinator (OSC) and in accordance with the RAWP and all other
Contract Documents. All project quality assurance and quality control requirements for
measurement reports will be addressed in a future data summary report.
2.0 Property Background
The following information was obtained from sampling activities and inspections performed by
CDM at this property.
INTERIOR:
Overall Building Layout
The Central Maintenance building is a rectangular, flat-roofed building, approximately 420
feet long and 142 feet wide.
The entire building is constructed of timber main supports and wood framing. The ceiling
and walls are finished with tongue and groove boards. The floor of the building is concrete
slab on grade, containing several concrete vaults and pits. The roof has a 4-inch layer of
aerated concrete on the tongue and groove ceiling covered by felt paper and tar.
1
-------
Walls throughout the building are constructed with 2-inch by 6-inch framing on 16-inch
centers, and finished with 1-inch by 6-inch tongue and groove boards.
The walls have equipment penetrating the wall cavities, and utilities running outside of the
wall cavities.
The building contains areas with varying wall heights. The building is separated into four
areas for identification purposes relevant to this work plan (refer to Figure 1 for area
locations):
o Former Mobile Shop - a 45-foot tall structure, approximately 260 feet long and 54 feet
wide, located on the north side of the building.
o Former Engineering and Warehouse (E&W) Areas A and B - Two 15-foot tall
structures, consisting of multiple spaces. A midline wall divides the two buildings
along the east-west axis. The western portion of this area is currently occupied by a
manufacturer of wood boilers called Seton Manufacturing. The location is shown on
Figure 1.
Area A refers to the space north of the midline wall
Area B refers to the space south of the midline wall
o Former Lift Truck Barn Area - the western portion of the building, separated from
the other two areas by walls. This area is currently occupied by the business MAL
Resources.
A total of 29 dust samples were collected from all areas within the Central Maintenance
Building to determine levels of LA asbestos. Analytical results for all but one dust
sample are non-detect or below the level requiring cleaning for LA as directed by EPA.
One dust sample collected from the Former Mobile Shop showed elevated levels of LA,
necessitating cleaning of that room. Many additional rooms require spot cleaning of
visible VCI, as defined and set forth in Section 4.2.
The designated areas are described in more detail below:
Former Mobile Shop
The interior of the Former Mobile Shop is open space.
All four walls of the shop contain VCI. However, the west wall is open from the ground up
to approximately 20 feet. The area west of this opening is a bare storage area, with a lower
roof, and is not considered to be part of the wall structure of the Former Mobile Shop.
Walls in the Former Mobile Shop are vertically separated by 8-inch by 8-inch main supports
into thirty-two, 20-foot wide bays. The bays are split into horizontal sections with 6-inch by
6-inch firebreaks. The wall studs divide a section into fourteen cavities. Each of these
cavities contain VCI. See Figure 4 of the Contract Drawings.
2
-------
o On the north wall, five of thirteen bays have 16-foot high (solid) doors; there are
three wall sections above the doors which contain VCI. The remaining eight bays
have four sections of wall containing VCI.
o On the south wall, the bottom section is a 19-foot high solid wall, constructed with
back-to-back layers of vertical 1-inch by 6-inch tongue and groove boards. These
sections do not contain VCI. The remaining two sections along the entire wall above
the solid wall sections contain VCI.
o The south side exterior wall of the Former Mobile Shop has a layer of metal siding
covering the tongue and groove boards. No VCI was observed within the space
between the siding and the boards.
o There are two doors on the lower section of the east wall. The bay between the two
doors is covered with plywood and contains fiberglass insulation in the wall cavity.
The plywood is in poor condition, and the fiberglass insulation is not well contained.
VCI remnants may also be present in this area of the wall.
o The upper two sections of the east wall contain VCI. The sections, combined, are
about 20 feet high, and are accessible from a catwalk. A 35-ton crane and a 15-ton
crane are near this wall. Two steel (2-inch diameter) cross braces across the ceiling
also exists on the east wall. The braces may obstruct access to the highest wall
section of north and south bay 1. The cleanup/construction contractor shall leave
the braces in place, at all extent possible. If the braces require removal in order to
access all VCI, they will require replacement upon completion of remediation
activities.
o The west side of the room has no wall up to a height of approximately 20 feet. There
are three wall sections with VCI, one below and two above the catwalk. All areas are
accessible; although, there are two steel (2-inch diameter) cross braces across the
ceiling that obstruct access to the highest wall section of north and south bay 13. The
cleanup/construction contractor shall leave the braces in place, to the extent
possible. If the braces require removal in order to access all VCI, they will require
replacement upon completion of remediation activities.
o VCI is located on interior surfaces throughout the Former Mobile Shop. VCI has
leaked out of the walls and collected on the crane track and supports in the Former
Mobile Shop, as well as onto shelves and other horizontal surfaces.
Subsurface vaults are located throughout the Former Mobile Shop floor. A number of them
contain VCI remnants within the vaults.
A small cinder block building is attached to the exterior of the north wall, accessible from
inside the Former Mobile Shop. No VCI was observed in this area.
3
-------
Former Engineering and Warehouse Area
The Former E&W Areas A and B are divided by a midline wall. The wall is not continuous
across the entire length of the building; there are doorways and openings that divide the
wall into sections.
Portions of the midline walls are finished with plywood instead of tongue and groove
boards. The walls contain VCI or remnants of VCI. The walls are separated into horizontal
sections with 6-inch by 6-inch beams as firebreaks.
Penetrations and remodeling at the midline wall has caused VCI to be released on either
side of the wall.
VCI is located on interior surfaces throughout the Former E&W Area A, including shelf
units and other horizontal surfaces.
VCI in the Former E&W Area B is limited to small quantities against the wall that have
leaked from penetrations and remodeling.
Seton Manufacturing currently occupies rooms 13-1, 16-1, 18-1, 10-3, 11-3, 12-1, and 12-5.
They also use room 8-3, which is a bathroom. They have access to rooms 17-2 and 17-3 but
do not use these spaces.
According to information gathered during the pre-design inspection, the interior area
currently occupied by Seton Manufacturing (formerly Rohar Industries) was cleaned by the
following methods. The floors were reportedly swept, power washed, and the lower few
feet of the walls were power washed. In addition, Murphy's soap was reportedly used on
the walls of the offices and bathroom (rooms 8-3,10-3,11-3, and 12-5). During inspections
conducted by EPA for this Work Plan, no VCI was observed in the Seton Manufacturing
area. An interior cleaning will not be required in this area; however, spot cleaning, as
defined in Section 4.2, may be required in areas adjacent to the wall where VCI has since
leaked from the midline wall.
VCI was not observed on the second floor balcony in this area.
Former Lift Truck Barn
This area includes room 19-1.
VCI was not observed in this area of the building.
The Former Lift Truck Barn, room 19-1, is occupied by MAL Resources, for the purpose of
washing and stacking decorative stone. One wall of room 17-2 is adjacent to the Former Lift
Truck Barn. This room contains equipment that may make VCI removal from the walls
difficult in this space. Access to the VCI in the shared wall between rooms 17-2 and 19-1,
will be made from room 19-1. Removal methods and coordination with MAL Resources are
discussed further in Sections 3.1, 3.2, and 4.0.
4
-------
One dust sample was collected from the Former Lift Truck Barn area. Analytical results for
the sample were non-detect for LA asbestos.
EXTERIOR:
Roof
Building roofing material on the Former Mobile Shop is composed of an approximate 4-inch
layer of aerated concrete atop the tongue and groove ceiling of the building. On top of the
concrete is a layer of tar, followed by a layer of tar paper.
The roof of the Former Mobile Shop has significant damage; the tar paper has been removed
or damaged on about 30% of the roof, confined mostly to the south and east areas of the
roof. This area has been covered with a tarp (see Figure 3). Inspection of the roof under the
tarp revealed that most of the aerated concrete is intact, with the exception of about one-
third of the material which is severely degraded and wet. The damaged material is
concentrated in the south side of the repaired area.
The eastern quarter of the Former Mobile Shop roof is covered with corrugated metal
siding. There is no indication of the condition of the aerated concrete under the siding.
Friable concrete debris is scattered around this area of the roof and on the tar paper torn
from the roof.
Three bulk samples were collected of the aerated concrete roofing material of the Former
Mobile Shop. Analytical results for all three samples reveal less than 1 percent LA asbestos.
The roof of the Former E&W Area A is also made of the same VCBM, however subsequent
sampling indicates that these areas are non-detect for Libby Amphibole.
Pallets along the wall of the Former Mobile Shop and adjacent to the Former E&W Area A
roof have been contaminated with VCBM debris.
The roof of the Former E&W Area B and the raised E&W area roof do not contain aerated
concrete VCBM.
The entire roof of the Former E&W Area (lower roof) is undamaged and in good condition.
VCI and VCBM debris is present on all roof areas, with the exception of the Former Lift
Truck Barn roof.
All areas of the roof can be accessed by ladders. Locations are shown on Figure 3.
Vaults
There are two subsurface features along the exterior east side of the building: a vault under
a surface-level hatch located on the south east corner, and a vault under a wooden shack on
the far eastern corner of the north side.
5
-------
The shack is constructed of a single wall of 1-inch by 6-inch tongue and groove boards, and
is in very poor condition. The shack is a 5-foot by 4-foot structure with an open bottom,
resting on a concrete vault approximately 8 feet deep. Piping in the vault is covered in part
with damaged suspect asbestos containing material (ACM) pipe insulation. VCI is scattered
throughout the vault, which has leaked from the Former Mobile Shop walls.
o The vault located at the south end of the east side of the building is constructed
with a soil floor and creosote-treated railroad tie walls. Vermiculite was
observed in the soil floor of this vault.
o One soil sample was collected from the floor of the southeast vault. Analytical
results for this sample were non-detect for LA asbestos.
Perimeter Soil
VCBM debris is scattered on the surface soils along the north and east sides of the building.
The source is the damaged roof of the Former Mobile Shop. The debris is scattered on the
ground along a 30-foot perimeter of the east and north sides of the building.
VCI has also leaked from the Former Mobile Shop north wall and was observed in piles
against the exterior north wall of the building.
The soils located around the footprint of the building do not contain visible vermiculite,
except in the southeast vault as previously discussed.
Three soil samples were collected from the north and east perimeter of the building.
Analytical results for the samples were non-detect for LA asbestos.
3.0 Health and Safety
All removal activities at the Former Stimson Lumber Central Maintenance Building must be
performed in accordance with the Libby Comprehensive Health and Safety Plan (CHASP),
regulations set forth by the U.S. Occupational Safety and Health Administration's (OSHA)
Title 29 Code of Federal Regulations (CFR) Parts 1926.
All removal activities will be performed in Level C PPE as defined in the CHASP.
Respiratory protection for removal activities will require use of Powered Air Purifying
Respirators (PAPR's) equipped with P-100 HEPA cartridges. Personal breathing zone air
samples will be collected characterizing task related personal exposures during all phases of
the removal work.
Perimeter air samples will be collected around the exclusion zone (EZ) boundary during the
removal of the Former Mobile Shop roof. The southern boundary of the EZ will require the
perimeter air sample to be collected on top of the lower roof south of the Former Mobile
Shop roof. The north, east and west boundary of the EZ will be monitored at the ground
level. Perimeter air monitoring will be completed as outlined in the RAWP.
The cleanup/construction contractor shall submit a detailed, site-specific Health and Safety
Plan for approval by the On-Scene Coordinator and the oversight contractor, prior to the
6
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start of work. Included in this Health and Safety Plan shall be written procedures for the
following specific items:
o Electrical Safety and Lock Out/Tag Out (LOTO) procedures that must be
implemented by a certified electrician
o Power Industrial Lift Truck Operations
o OSHA 29 CFR 1926 Fall Protection
The Former Mobile Shop roof is a low slope roof. A low sloped roof is defined as a roof
having a slope less than or equal to 4 in 12 (vertical to horizontal).
The cleanup/construction contractor shall comply with all confined space entry regulations
and procedures if entry into any of sub-surface features, vaults or any other confined spaces
on the site is required to perform the work set forth in this Work Plan.
Containment areas will be constructed to segregate removal areas from the existing
businesses that will be operating during removal activities. Containments must be designed
according to OSHA's Class I containment specifications as listed in CFR 1926.1101, and must
be constructed achieve the following requirements:
o Negative air must be sufficient to change out the containment air volume at least 4 to
5 times per hour.
o Negative air must be great enough to achieve a -0.02" H2O pressure differential
between containment and outside air.
o Contamination must be pulled away from worker's breathing zone.
Once the containment is constructed, a hazard analysis form will be completed by the
Government representative to ensure compliance with all applicable Contract Documents.
The Government Representative or oversight contractor will perform a smoke test in all
areas of containment prior to start of work to ensure that the negative air system is sufficient
to assure that asbestos fibers do not migrate to adjacent areas.
The containment must be inspected by the cleanup/construction contractor's competent
person at the beginning of each work shift to ensure the negative air system is operational
and that the containment has not been breached or damaged in any manner. Any damage
or breaches identified during the inspection must be repaired prior to start of work.
Stationary air samples will be collected in both business work areas during removal
operations to ensure that asbestos fiber migration is controlled. One air sample will be
collected in the MAL Resources business area (19-1) during the VCI removal from the walls
in room 17-2. Up to three stationary air samples will be collected in the Seton
Manufacturing business area (13-1, 16-1, 18-1, 10-3, 11-3, 12-1, and 12-5) during VCI
removal from the midline wall. All stationary air samples will be collected in accordance
with the Contract Documents.
7
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3.1 Coordination with Businesses
Two businesses are currently located inside the Former Stimson Building, MAL Resources
and Seton Manufacturing. See Figure 1 for locations.
The businesses will remain operational during the removal activities, to the extent possible.
The cleanup/construction contractor will coordinate with the Government representative,
the oversight contractor, and the business owners to minimize the disturbance to the
businesses during normal working hours.
Electricity that is supplying the business owners will remain on during business hours
during the remediation activities to the extent practical, so as to minimize disturbance to the
business operation. If power must be shut down an alternative power source shall be
provided to the affected businesses by the cleanup/construction contractor. There is no
evidence of electrical wiring inside of the midline walls; however, the cleanup/construction
contractor will take care when penetrating walls to ensure that no electrical conduits are
encountered.
The business owners will be briefed by the Site Health and Safety Officer (SHSO) on the
removal activities, controlled areas, and health and safety requirements to be followed by all
government employees and contractors. The business owners will be responsible for
informing their employees of any requirements and restricted areas
Additional air samples will be collected by CDM to ensure that asbestos fiber migration is
prevented into the workers' areas, as discussed above.
MAL Resources
MAL Resources currently occupies room 19-1, as shown on the Contract Drawings.
The employees will be able to access their southwest single access door as well as their north
large bay door during the duration of the remediation, except during VCI surficial vacuum
of the soils along the perimeter of the building. This disturbance is minimal, and the
cleanup/construction contractor shall coordinate with MAL Resources during the exterior
activities to ensure that they will be able to transport their trucks in and out of the building,
as necessary.
The cleanup/construction contractor will also coordinate with MAL Resources when setting
up containment around the western wall of room 17-2. This set-up will be done after
business hours or on weekends to minimize disturbance to the employees.
Seton Manufacturine
Seton Manufacturing currently occupies rooms 13-1,16-1,18-1,10-3,11-3,12-1, and 12-5.
They also use room 8-3 which is a bathroom. They have access to rooms 17-2 and 17-3, but
do not use these spaces.
The cleanup/construction contractor will coordinate with Seton Manufacturing when
setting up containment around the southern side of the midline wall. The owner has agreed
to move any equipment located next to the walls that are in the way of containment.
8
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The containment set-up will be done after business hours or on weekends to minimize
disturbance to the employees, if necessary.
The employees will have access to all their exterior doors during the duration of the
remediation.
Room 8-3 is the restroom used by Seton Manufacturing employees. The VCI in the midline
wall associated with this room will be cleaned and the room cleared for use in coordination
with Seton Manufacturing. The closure of this room will be minimized in order to allow
Seton Manufacturing use of room 8-3 during their operating hours to the extent practicable.
The cleanup construction contractor shall provide portable toilets and hand washing
stations for use by Seton Manufacturing's employees for the period when the restroom is
not available to them.
3.2 Containment
Containment systems must be constructed prior to the start of interior cleanup work. The building
walls and ceiling require cleaning and will not be covered with 6-mil polyethylene sheeting. The
building walls and ceiling will act as part of the negative pressure enclosure (NPE) and will not
require coverage. The systems shall be set up as follows:
The Former Mobile Shop will be delineated into multiple separate NPEs.
o All doors and openings within each NPE in the Former Mobile Shop will be covered
with 6-mil polyethylene sheeting. During the construction of the west NPE within
the Former Mobile Shop the open west end will be covered with 6-mil polyethylene
sheeting to prevent migration of asbestos fibers from the work area.
Containment in Rooms 7-1, 8-1, 8-2, 8-3, 9-1,10-1 will be constructed in the same manner as
in 1-1 and 4-1, and, at a minimum, be ten feet north of the wall. In rooms 11-2 and 12-1
south of the Former Mobile Shop will be isolated to form a separate NPE the containment
will be constructed, at a minimum, ten feet south of the wall. This will be coordinated with
Seton Manufacturing as necessary.
o The south side of the midline wall will be contained as the southern boundary of the
NPE. A 6-mil polyethylene sheeting containment wall will be constructed
approximately 10 feet south of the midline walls, which will be coordinated with
Seton Manufacturing.
The walls containing VCI in Room 17-2 will be isolated to form a NPE. Removal of VCI
from this wall will be completed from the west side, in room 19-1. This containment will be
constructed of 6-mil polyethylene sheeting extending approximately 10 feet west of the wall
containing the VCI. The use of this area (within room 19-1) will be coordinated with MAL
Resources, as to prevent disruption to their business.
Room 1-1 will be isolated forming a NPE. Removal of remnant VCI will be conducted from
the inside of room 1-1. A separate NPE will be constructed encompassing the midline wall
extending into room 4-1.
9
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Room 8-3 is a restroom used by Seton Manufacturing employees. The room will be checked
and any conduits, cracks, or penetrations into the north, east, and west walls will be sealed
with a combination of poly sheeting and caulk in order to seal the room off from adjoining
spaces. Once work activity on the midline wall in contact with room 8-3 is complete, that
area will be cleared and the containment modified to allow access to room 8-3 by Seton
Manufacturing employees.
HEPA filter equipped air handling units will be placed in locations and quantity that creates
a NPE in accordance with the requirements included in the RAWP.
Clearance Criteria for all areas on the site (interior containments, interior spot cleanings,
roofs, vaults, floors, exterior soils, etc.) shall be determined in consultation with the On-
Scene Coordinator. Clearance methods and protocols shall also be determined in
consultation with the On-Scene Coordinator.
4.0 Remediation Activities
Remediation activities must be carried out in a manner that ensures cleaned areas are not re-
contaminated during work activities. To accomplish that goal, work will be performed in the
following order:
Exterior Roof Remediation
Soil Excavation/Surface Vacuum
VCI Bulk Removal/Spot Cleaning (to be performed simultaneously)
Interior Cleaning/Interior Vault Remediation (to be performed simultaneously)
Encapsulant Application (to be performed simultaneously)
Exterior Vault Remediation
4.1 Exterior Roof Remediation
The following activities will take place on the roof of the building:
The entire Former Mobile Shop roof will be removed and replaced with a comparable
roofing material.
The Former E&W Area A is made of the same material as the Former Mobile Shop;
however, it is undamaged and does not pose a risk of an imminent release. Therefore, it will
not be removed. The Former E&W Roof area B, the Former Lift Truck Barn Roof, and the
Former E&W area higher roof (refer to Figure 3) do not contain VCBM aerated concrete
roofing material.
All work performed by the cleanup/construction contractor on the roofs shall be done in
consultation with the EPA On-Scene Coordinator, the site Health and Safety Officer, the
oversight contractor, and in accordance with this Work Plan.
No enclosures will be constructed during the removal of the vermiculite containing aerated
concrete roofing material. An exclusion zone (EZ) will be delineated at the ground level on
10
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the north, east and west boundaries of the Former Mobile Shop. The lower roof south of the
Former Mobile Shop will be the southern boundary for the EZ.
The corrugated metal sheeting covering the eastern quarter of the Former Mobile Shop will
be removed, washed and disposed of as construction debris. A layer of tar paper may be
located between the aerated concrete and the corrugated metal sheeting. Any tar paper
removed prior to the removal of the aerated concrete will be disposed of as ACBM.
Either a wet cut-off saw or a circular saw equipped with HEPA equipped local exhaust
ventilation will be used to score the layer of aerated concrete. The scoring should reach a
depth of up to 4 inches into the layer of aerated concrete prior to removal. Great care
should be taken when placing these scoring lines to ensure the bottom wooden roof deck
remains undamaged. This method allows for the concurrent removal of the aerated
concrete and the tar paper that is also part of the roof structure (as this tar paper contains
remnants of the aerated concrete stuck on its' surface).
Either manual scraping bars or a power assisted scraping machine will be used to lift the
layer of roofing material off the wooden roof deck. During this scraping operation, wet
methods will be used to limit generation of airborne dust.
A debris chute will be constructed leading from the roof into a hazardous waste container.
The shoot will be placed under negative pressure by attaching a negative air filtration unit
inline on the bottom of the shoot to ensure dust is pulled into the shoot during disposal of
the roofing material.
Former Mobile Shop roof, facing east.
Damaged area repaired with tarps and
nailed down 2" by 4" wood.
Former Mobile shop roof, facing west,
showing extent of heavily damaged
areas.
Cross-section of roof as seen at the ladder
up to Former Mobile Shop roof - tarp on
top of damaged VCBM, overtongue-
groove ceiling
The following roof areas will be surface vacuumed after the completion of the upper roof:
entire lower (Former E&W Area) roof including the roof area west of the upper roof and the
raised roof area that is approximately 10 feet higher than the lower roof area. See Figure 3
for locations. Mechanical means may be used in these areas as well. The only roof area not
requiring vacuuming is the Former Lift Truck Barn roof.
11
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The pallets that line the edge of the Former Mobile Shop on the lower roof will be washed to
remove all surficial material and returned to their original location.
Lower roofs, facing west - these roofs are
not damaged - the northern half has
VCBM, southern half does not.
VCBM is seen as both debris and pulverized
into powder, collecting at low points
including around pipe penetrations (vents).
A row of pallets lines the edge of the
lower roof adjacent to the Former
Mobile Shop. These are to be washed
and returned to their original location.
4.2 Interior Remediation
Once the roof has been cleaned arid replaced, removal of bulk VCI will take place inside the
building, followed by interior cleaning and encapsulant application.
VCI Bulk Removal
Prior to VCI removal, all large equipment items, including the two large cranes in the
Former Mobile Shop, will be cleaned to remove all surficial VCI and left in place. All
equipment will be covered with polysheeting during the remainder of interior remediation
to protect it from being re-contaminated.
VCI will be removed from all walls containing the material. Specifically, VCI will be
removed from the following walls (see Figure 2 for locations):
o All Former Mobile Shop walls
o All midline walls
o Eastern wall of room 1-1
o Western wall of rooms 17-2 and 17-3
VCI will be removed using vacuum methods. Vacuum methods consist of using a HEPA
equipped vacuum truck with a storage container in line.
The fiberglass insulation in the east wall of the Former Mobile Shop (located in between the
two bay doors) will also be removed, as it is not well contained behind the plywood wall
and may contain VCI remnants. The plywood wall will be removed and disposed of as
contaminated material. The plywood will be replaced with a similar comparable material.
12
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Former Mobile Shop
In the Former Mobile Shop, A 6-inch diameter hole will be drilled into the tongue and
groove boards in between each framing cavity to access the VCI (14 cavities per section per
bay; 3 to 4 sections per bay). Adapters will be placed on the end of the vacuum hose to
remove VCI from corners of the framing cavity.
The majority of the Former Mobile Shop walls will be accessed using a man-lift with a
retractable boom.
o All bays on the north and south walls are accessible using the man-lift; this method
was used successfully to access the bays during inspection.
o Upper bays on the east and west wall can not be reached by the man-lift due to
obstacles such as large cranes. These bays can be accessed from a catwalk on either
side of the building.
o The cleanup/construction contractor shall leave the 2-inch diameter steel bracing at
the east and west ceiling in place, to the extent possible. Extra time may be required
in order to access the wall sections that are located near the bracing. If removal of the
bracing is required to access all VCI, the bracing will require replacement upon
completion of remediation activities.
4/30/04
North side bay 13, note obstacles to work area. The North side bays 11, 10, 9 from left to right. A door and
stairway accesses the catwalk on the west side of the solid wall are at lower section of bay 10, Wall cavities with
Former Mobile Shop. VCI are in all of bays 9 and 11. Trusses for crane track in
front of all wall bays.
13
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Typical upper section of bays. Note steel beam and
trasses along north and south side, this feature is for
the 35 ton crane stationed on the east side of shop.
VCI has settled onto many of the horizontal surfaces.
Typical south bays, photo shows bays 8 and 9. The
lower 19 ft. wall sections are solid in all south bays.
West wall of the Former Mobile Shop. The catwalk is
located where the color changes from green to brown.
Steel bracing is at the ceiling in northeast and southeast
corners, but is not visible in this photo.
4/30/04
South side bay 12, showing some of the typical obstacles,
penetrations, and utilities in the work areas.
14
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Former E&W Areas
VCI within the midline wall cavities, as well as rooms 1-1,17-2 and 17-3, will be accessed
using stepladders or platforms.
The west wall of room 17-3 will be accessed and remediated through the west side of the
wall.
Holes will be drilled in these walls to access the VCI in the same manner as the walls of the
Former Mobile Shop.
Room 1-1 (Fig 1). Midline wall. Walls in this room are
accessible from a stepladder. These walls may contain
full or remnant VCI.
Room 17-2. These walls have full or remnant VCI, and are
in a small room with a fixed furnace.
Spot Cleaning
Spot cleaning will consist of HEPA vacuuming, mopping floors, and wiping down
horizontal surfaces, etc. in areas containing visible VCI but not requiring a full interior
cleaning of the entire room/ area.
Spot cleaning of VCI will be completed along the south side of the midline wall and other
areas within the building as necessary.
15
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Spot cleaning will be done in conjunction with bulk cleaning, in a manner that does not
cause cross contamination between cleaned and contaminated surfaces.
Interior Cleaning
Following bulk VCI removal, the entire Former Mobile Shop will require interior cleaning,
including the lower roof Former Mobile Shop area, due to the large quantity of visible VCI
located throughout the interior surfaces of the shop.
All interior cleaning shall be performed in consultation with the On-Scene Coordinator and
the oversight contractor and in accordance with this Work Plan. Strategies for the interior
cleaning shall include the combined use of the HEPA vacuum, wet-wiping, and power
washing of all interior surfaces within the Former Mobile Shop. The cleanup/construction
contractor shall use Best Management Practices for managing and disposing of wash water
and waste water generated during cleanup activities.
Since all dust samples collected within the building were below the levels requiring cleaning
as directed by EPA, no additional rooms besides the Former Mobile Shop will require
interior cleaning.
During interior cleaning of the Former Mobile Shop, all interior vaults and pits will be
opened and inspected. Vaults or pits containing water and/or sludge will not be cleaned.
Any dry vaults or pits will be cleaned of debris, and vacuumed to remove VCI.
Locations of a few vaults are included in Figure 2. The cleanup/construction contractor will
also inspect additional vaults and pits that are discovered during work activities and are
not included on the figure.
The cleanup/ construction contractor shall comply with all confined space entry regulations
and procedures if entry into any of sub-surface features, vaults or any other confined spaces
on the site is required to perform the work set forth in this Work Plan.
Clearance Criteria for all areas on the site (interior containments, interior spot cleanings,
roofs, vaults, floors, exterior soils, etc.) shall be determined in consultation with the On-
Scene Coordinator. Clearance methods and protocols shall also be determined in
consultation with the On-Scene Coordinator.
16
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05/05/2004% <
. It:- .ฆ - ฆ
Some vaults have water/sludge and do not require cleaning.
Tliis pit is dry and has some debris, requires cleaning by
disposing of debris and vacuuming pit. This is at the
middle of east wall.
Encapsulant Application
After the VCI has been removed and the work area inspected by an onsite Government
representative for completeness of dust removal, encapsulant will be applied to all wall cavities
that had contained VCI. Encapsulant will also be applied to exterior surfaces to ensure any
remaining asbestos fibers are sealed in place. Encapsulant will not be directly applied to the
floor of the Former Mobile Shop.
Clear encapsulant material will be required in all areas requiring application of encapsulant.
4.3 Exterior Vault Cleaning and Soil Excavation
Once remediation activities are completed on the roof and inside the building, the remediation
activities along the exterior perimeter of the building will commence. This will ensure cross-
contamination does not occur. The following areas require remediation:
Shack and Northeast Vault
The shack will be dismantled prior to entry to ensure the safety of workers.
The shack materials will be properly disposed of as ACM.
Piping inside the shack will be protected and supported, as necessary.
All suspect ACM insulation from the pipes will be removed and properly disposed.
The vault located in the floor of the shack will then be remediated. Confined space entry
procedures may be applicable for entry into this vault. Any debris inside the vault will be
discarded as ACM.
VCI within the vault will be removed with vacuum methods.
Encapsulant will then be applied to the walls, floor, and piping within the vault.
17
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The shack is located on the east end of the
north side of the Former Mobile Shop (refer
to Fig 2), and has VCI inside and on the
ground outside. The shack will be
dismantled and discarded.
Inside the shack - piping with remains
of suspect ACM insulation. The
insulation will be discarded as ACM.
Looking into the vault - VCI is scattered
throughout this area - discard all debris
within this vault - wash down and surface
vacuum interior, apply encapsulant.
Southeast Vault
The vault 011 the southeast corner of building has vermiculite in the soil floor. However, soil
samples reveal that LA asbestos is non-detect. Therefore, no remediation will be required to
the soil floor of the vault.
Any remnant VCI located on the surface of the soil floor will be vacuumed.
Confined space entry procedures may be applicable for entry into this vault.
Entrance to vault on the south east corner of the building. The
Vault has creosote timber walls and a soil floor.
Floor of the vault as viewed from the entrance.
18
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Exterior Soil
Excavation along the perimeter of the building will not be required, as analytical results of
soil samples taken in the perimeter areas reveal that LA asbestos is non-detect.
However, surficial VCBM and VCI located on the top of the soil along the north and east
sides of the building will be removed by vacuum methods, from the edge of the walls and
outward approximately 45 feet.
Items located within the work area, such as the racks and shelving will be left in place and
protected during surficial removal.
North side of Former Mobile Shop
facing west, from the east end.
North side of Former Mobile Shop
facing east, from the west end.
East side of Building, note the shed/shelves and
pipe rack against the wall - the shed lias no floor.
5.0 Restoration Activities
Restoration activities at this property will consist of performing the following work:
Roof
o Previously discussed in Section 4.1.
Former Mobile Shop
o Blown-in fiberglass will be installed in all exterior walls of the Former Mobile Shop,
which includes the entire north and east walls, and the upper portion of the south
and west walls.
o All holes that were made in the walls to access the VCI will be repaired and sealed.
05/05/2004
19
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Former E&W Areas A and B
o Blown-in fiberglass will be installed in the eastern wall of room 1-1. The interior
walls, including the midline wall and walls of rooms 17-2 and 17-3, will not be
insulated.
o All holes that were made in the walls to access the VCI will be repaired and sealed.
Shack and northeast vault
o The shack will not be re-built.
o A cover will be constructed over the vault for safety purposes, constructed of
plywood and a 2-inch by 4-inch frame to fix the plywood into place, and cement or
steel anti-collision posts will be placed to protect the vault from vehicular traffic.
6.0 References
CDM. 2003. Response Action Work Plan (RAWP), EPA Libby Asbestos Project, Libby, Montana.
November.
CHASP. Libby Comprehensive Health and Safety Plan, EPA Libby Asbestos Project, Libby,
Montana. May 2003.
20
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FIGURE 3
EXTERIOR REMOVAL PLAN
FORMER S TIM SON CENTRAL
MAINTENANCE BUILDING
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-------
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-------
Removal ana Mestor ation Completion Form
'For Quick .Response Action at
Oitcolil Cotmlj Port Amthckity Properly
Central Maintenance Building
Stikgei WeMingr Inc.
M): Port Boalevatfi
tibfey, Montana
Between January 12, 2mmd jlikary 13, ^mqmck response removal and restoration
activities took place at 60 Port Bollfe^rd (lixicobi Comity Port Authority, CoittalMalntettance
Bufldiag/Sttnger Welding, Jnc% Activities were conducted to accordance with the Response
Action Wffli Plan (RAWF) (CEM federal Programs Coloration [CDM] 2008a), and the
Response Action Sampling and Analysis Plan (CDM 2008b), forthwith referred to as the
Contract Documents. This Removal ind RestotationCompleticairoim summaries deanup
activities that tciok place at the properly.
1.0 Removal and Re&taiiion Activities
1.1 Interior (
Vennicalite^onlaming lisiilation Removal ^
Vermiailte<:cmtairang mailatibn wli removed from the east end of the Central Maintenance
Building where a door access was extended. Wall covering was removed and properly
disposed. Following the removisl; cricks, gaps,, and wall cavities axoirnd the access .area were
sealed in. accordance with Conttafct ddttrmefiM The area wks inspected to- confirm it was.
cleaned to standards established % the B.& Environmental Protection Agency (EPA),
interior Oebning
Based on visual Inspection, ah interior' deaning was condufcted in U*s area of the east doer
access. Following the interior cleaning; the interior space was inspected' to confirm the area was
cleaned to standards established by the EPA.
Verw*^1 ite-containing Wall Insulation
Vettmollite-cofitalHing insulation /remains in the interior walls and exterior walls of the ^
building. Existing openings in. tHese-areas were sealed. The EPA strongly recommends that the
material be left alone and. not S^Sp^d. Should it be neceskaxy to access these areas in the
future (such as during rmovatibAj, the property owner is encouraged to refer to the. guidance
included in the post-cleanup a&Mpletfott packet These publications are also available at the
EPA .Information Center (108 Ehst Street) and online at ,
http: / / www.epa.-gov / reponS/stiperfund/.Kbby/rohoine.hiฃol.
-------
2.0 References
CDM. 2008a.. Response Action. Work Han, EPA Iibby Asbestos Project, Ubby, Montana..
February.
. 2008b. Response Action Sampling and Analysis Plan. EPA libby Asbestos Project, Libby,
Montana. April.
I acknowledge feat I have received a copy of the Quick Response Statement of Work for the
property and 'that the removal and restoration, activities, were performed as discussed and
agreed upon, prior to the cleanup.
Owoer Date
-------
Removal and Restoration Completion Form
for Response Action at
Lincoln County Port Authority Property
875 U.S. Highway 2 CMB
Libby, Montana
EE: EPA Property ID: AD-000686
Between October 10, 2012 and October 16, 2012, removal and restoration activities took place at
875 U.S. Highway 2 (Lincoln County Port Authority property). Activities were conducted in
accordance with the Contract Documents. This Removal and Restoration Completion Form
summarizes removal activities that took place at the property.
1.0 Removal and Restoration Activities
1.1 Interior
VermicuIite-Containing Insulation Removal
Vermiculite-containing insulation was removed from the wall space. Following the removal,
existing gaps and openings on the interior wall were sealed using expansive foam and silicone
caulking to minimize the potential for material sifting. Encapsulant was installed in area to
minimize the potential for vermiculite-containing insulation fibers to be released. The space was
inspected and air clearance samples were collected to confirm the area was cleaned to removal
standards established by the U.S. Environmental Protection Agency (EPA). The removed
insulation was replaced unless otherwise stated in the Contract Documents.
Interior Cleaning
Based on visual inspection, an interior cleaning was conducted in the area.
Restoration of the disturbed areas was not performed as part of the scope of work for this
response action.
I acknowledge that I have received a copy of the Final As-Built Drawings for the property.
Removal and restoration activities were discussed and agreed to prior to initiation of removal
activities and that the landscape was replaced according to agreed upon terms.
f 13
Name
Date
OU4 Removal and Restoration Completion Form 11/7/12
-------
CDM
M B _
smiin
Memorandum
To: Rebecca Thomas, EPA RPM
From: Dominic Pisciotta
Date: February 27, 2012
Subject: Operable Unit 5 Central Maintenance Building Summary Report
Memorandum
This memorandum was produced to summarize specific events which took place to facilitate
the cleaning of areas identified as needing response actions, following roof removal activities
on the central maintenance building at Operable Unit 5 by U.S. Army Corps of Engineers
(UASCE) contractors.
1.0 Roof Removal
The property owner's contractor began work to remove Class II asbestos containing material
(ACM) from the roof of the central maintenance building on October 10, 2010. Removal of
Class II ACM on the roof was completed on September 12, 2011. On September 30, 2011 the
Libby area environmental resource specialist (ERS) under the direction of the EPA submitted
a statement of work (SOW) detailing the cleaning of four interior areas. These areas were
identified as having been impacted by debris from activities associated with the roof removal
work.
2.0 Interior Cleaning and Sampling Activities
On November 8, 2011 USACE contractors performed a preparatory inspection and tailgate
meeting to discuss and review the ERS SOW. Rooms identified as needing a response action
by USACE contractors were Area A (17-2), Area B (11-1), Area C (10-1,11-2), and Area D (4-1)
(see attached map).
Set up activities began November 9, 2011 on the rooms identified as needing a response
action. In addition, during set up it was recognized that room 11-2 shared airspace with 10-1
and would require cleaning as well. It was decided between third-party quality assurance
(TQA) personnel and the removal contractor (RC) interior foreman that room 11-2 would be
combined within the same negative pressure enclosure (NPE) as 10-2. Detail cleaning work
began by the RC on the afternoon of November 9, 2011. Cleaning continued on November 10
and 11, 2011.
-------
Operable Unit 5 Central Maintenance Building Summary Report Memorandum
2/27/12
Page 2
TQA performed air clearance activities in Area C on November 11, 2011. On November 14,
2011 air clearance results on Area C were reported back by the analytical laboratory as being
unable to be read due to overloading of sample media. Work activities of the tenants in an
adjoining portion of the building were believed to have caused the overloading due to diesel
particulate emissions and welding activities in the vicinity. In an attempt to avoid the
impacts of the adjoining tenants, NPE's were then re-configured in a manner so that make up
air was drawn from the outside of the building so as to assist in allowing cleaner make up air
to enter the NPE. Cleaning continued in Areas A, B, C, and D.
On November 15, 2011 air clearance samples were collected in Areas B and C. Air clearance
results on Areas B and C were reported back by the analytical laboratory that the air samples
were unable to be read due to overloading.
On November 16, inspections were again performed by TQA and QC personnel to determine
the cause of clearance sample failures. The cause of the failures was determined to be exhaust
fumes located inside the building, at which time USACE representatives were notified. An
agreement was made between the tenants (Thompson Construction Inc.), the property owner,
and the government that the tenant would vacate the building on November 18, 2011. This
was done so that the building would not be exposed to exhaust fumes and enable the RC to
perform an interior cleaning of each room and allow air clearance sampling to follow.
On November 18, 2011 the RC performed the additional cleaning in Areas A, B, C, and D.
However, contrary to the agreement noted above, Thompson Construction Inc. began using
kerosene heaters and moved a machine into the shop area, again filling the area with exhaust
fumes. The issue was reported to USACE and direction was made to not run air clearance due
to the exhaust and additional shop activities by Thompson Construction Inc. TQA was
directed by the EPA and USACE to perform a visual inspection following additional
cleanings of all the NPE's. Upon inspection, TQA requested that the RC perform additional
cleaning in Area A. Area A was not sampled to this date due to the decision by EPA and
USACE to clear rooms by visual inspection. Following the final visual inspection as directed
by the EPA and USACE of all areas, TQA determined that all areas were sufficiently cleaned.
NPE's were disassembled and the RC began demobilization. All work was completed at the
site on November 18, 2011.
On January 26, 2012 government representatives Dominic Pisciotta (CDM Smith) and Eric
Romero (PRI-ER) met with the property manager in order to review and sign final completion
documents. The activities associated with the response actions performed were discussed and
the property manager stated he had reservations regarding not having air clearance sample
results as outlined in the original work plan.
-------
Operable Unit 5 Central Maintenance Building Summary Report Memorandum
2/27/12
Page 3
Based on the property managers concerns, CDM Smith made recommendations to the EPA
and USACE to have the overloaded samples for Areas B and C analyzed by indirect
preparation and base future decisions of removal activities on the results of those samples.
On January 31, 2012 the samples for Areas B and C were re-analyzed by indirect preparation.
The results of those samples were as follows:
Area B - 1 Libby amphibole asbestos (LA) structure detected
Area C - Non-detect (ND) for LA
Decisions were made by the EPA and USACE to remobilize to the site, set up NPE in Areas A
and B, perform cleaning in both areas, and perform air clearance samples according to project
protocol. In addition, both clearance sets would be analyzed under normal project standards.
If either or both samples were overloaded, they would then be analyzed by indirect
preparation. No further action would be taken in Area C due to the results of analysis by
indirect preparation were ND for LA
On February 13, 2012 a meeting was held with the property manager, tenant, PRI-ER, CDM
Smith, USACE, and EPA to discuss the work needed to be performed as part of further
response actions. All parties agreed on dates when work could be performed and that the
areas adjacent to the impacted areas would not have any operations involving the use of
diesel engines, salamander heaters, or any actions which would compromise the ability for
EPA/USACE contractors to perform cleaning and sampling in the impacted areas.
On February 17, 2012 USACE contractors mobilized to the site, set up NPE's in Areas A and
B, and performed cleanings in both areas. The cleaning was completed in Areas A and B the
afternoon of February 17. Air clearance samples were collected in Areas A and B on February
18, 2012. On February 21, 2012 the analytical results from the air clearance samples for both
Areas A and B were reported back by the analytical laboratory as being ND for LA. NPE's
were then dissembled and PRI-ER communicated the results of the air clearance samples to
the property manager.
-------
875 US Highway 2
AD-000686
Central Maintenance Building
ERS - 9/28/11
C Peltier
B
AREAD
Debris disposal In
room 4-1, Area
should be accessed
through Stinger
shop
AREA C
Intenor Cleaning in
room 10-1, Area
should be
accessed through
11-2
PLAN VIEW
AJiWCWAT* SC I
SECOND LCVCL - GfTKXS AMD
9-fl
UL
o-
AREA B
Interior cleaning in
room 11-1, Area
should be accessed
through 12-2
BD 002098
AREA A
Interior Cleaning in
room 17-2
k
10 ซt 1* IJ 14 Id
B
y-
-------
Appendix A3
Libby and Troy Creek Investigation
Summary Memo
-------
CDM
Memorandum
To: Mark Raney
From: C. Tyler Irwin, Nick Raines
Date: November 1, 2008
Subject: Summary of Creek Investigations Completed for Libby Asbestos
Superfund Site Operable Units 4 and 1, October 2008
1.0 Overview of Investigation
EPA tasked the US Department of Transportation, John A. Volpe National Transportation Systems
Center (Volpe) with the investigation of several area creeks within Operable Unit 4 (OU4) in Libby,
Montana and Operable Unit 7 (OU7) in Troy, Montana. The purpose of this investigation was to
evaluate the presence or absence of suspect Libby Amphibole (LA) in material used for the
construction of riprap in the creeks. The purpose and plan for the investigation are discussed in further
detail within Libby and Troy Creek Investigation Memo, October 2008.
Granite Creek and Flower Creek in Libby and Callahan Creek in Troy were previously investigated in
May 2008.The October 2008 investigations included Libby Creek (Cr), Parmenter Cr, Pipe Cr, Doak Cr,
Bobtail Cr, Cedar Cr, and Quartz Cr in Libby (Figure 1), and Lake Cr, Iron Cr, and Brien Cr in Troy
(Figure 2). All creeks are perennial streams and experience significant flow fluctuations during the
spring and following heavy precipitation events. As a result, the creeks have had riprap placed at
various sections by the US Army Corps of Engineers (USACE), Lincoln County, the City of Libby,
and/or private land owners to control erosion. Each listed creek was investigated near overpasses,
bridges, and along roadways, in residential backyards, and other populated areas. The estimated
lengths of each investigated creek are listed below.
Troy
Lake Cr (Kootenai River Section)
Lake Cr (Mid Section)
Lake Cr (Overpass Section)
Iron Cr
Obrien Cr
1.1 miles
0.12 mile
0.12 mile
0.95 mile
0.2 mile
Libbv
Libby Cr
Libby Cr (Hammer Rd Section)
Parmenter Cr
6.7 miles
0.19 mile
1.9 miles
-------
T. Irwin, N. Raines
November 7, 2008
Page 2
Pipe Cr (Lower Section) 1 mile
Pipe Cr (Upper Section) 2 miles
DoakCr 0.19 mile
Bobtail Cr 0.57 mile
Cedar Cr 0.6 mile
Quartz Cr 1.1 miles
Material used for the construction of riprap sections in the creeks included: 1) quarried argillite and
siltstone (metasediments) from the Wallace Formation (Fm) of the Precambrian Belt Group, 2) quarried
syenite from the Rainy Creek ultramafic complex, 3) basalt, and 4) concrete debris, tree stumps, wood
lagging. The syenite is exposed at the Vermiculite Mountain Mine, and riprap constructed with this
material is thought to have originated at the mine. LA material in the form of biotite pyroxenite,
magnetite pyroxenite, and LA are often found in the presence of the syenite.
Results of the investigations are summarized in the sections below. Estimated volumes of individual
sections that contain syenite and LA material are presented in Table 1.
2.0 Results of Creek Investigation Program
2.1 Introduction
Syenite and LA material were not identified in any of the Troy area creeks, and only in two Libby area
creeks during the October 2008 investigation. A description of the occurrence of syenite and LA
material in the Libby area creeks follows.
2.2 Pipe Creek (Lower Section)
A 1-mile section of Pipe Cr, beginning at the Kootenai River, was investigated on October 13, 2008
(Figure 1). Riprap material in this section of Pipe Cr is composed of metasediments and basalt except
for riprap located at two residential properties on the northern bank of Pipe Cr, between Kootenai
River Rd and Botham Drive (Figure 3).
Riprap located on both of these properties is composed of quarried syenite and a smaller volume of
metasediments ranging in size from cobbles to boulders. The largest pieces of syenite are
approximately 3 feet (ft) in length, averaging approximately 18 inches (in). The syenite locally contains
LA material as fracture coatings on syenite. The fracture coatings are the most prevalent form and
appear as small radiating, fibrous aggregates, light blue-gray to dull silver in color, similar to LA
material observed in Libby Cr.
The riprap at 3623 Kootenai River Rd (PC-01 to PC-02) was placed in a curved, linear exposure (10 ft in
total lateral extent) and is approximately 200 ft in length. The riprap at 3737 Kootenai River Rd (PC-03
to PC-04) has similar placement and is approximately 300 ft in length. The riprap at both locations is
weathered and often discontinuous with indications of downstream mobilization of components due to
erosion.
DCN: DC2616. 015.201.CREEK-2770.00
-------
T. Irwin, N. Raines
November 7, 2008
Page 3
The locations of these two sections were surveyed with a Trimble GPS unit.
Field sketches of cross-sections of these two locations were not created due to the inconsistent and
discontinuous distribution of the material. Further survey activities may be required to fully detail the
physical layout of these sections of rip-rap.
2.3 Libby Creek
A 6.7-mile section of Libby Cr, extending from the Kootenai River to near Farm to Market Road (F-M
Rd) on the south end of the section was investigated on October 9, October 10, and October 20, 2008
(Figure 1). All riprap material in this section of Libby Cr is composed of metasediments, basalt, and
concrete debris, except for a small exposure of riprap located on the eastern bank of the creek,
approximately 700 ft south of the Champion Haul Rd bridge (Figure 4).
This riprap section (LC-01 to LC-02) is composed of quarried syenite. The largest pieces are
approximately 3 ft in length, averaging approximately 18 in. The syenite locally contains weathered
xenoliths of magnetite pyroxenite and biotite pyroxenite. LA material is present in this riprap, and
occurs most commonly as fracture coatings on syenite. The fracture coatings appear as small radiating,
fibrous aggregates that are light blue-gray to dull silver in color. The LA is soft and has been
weathered.
The riprap at this section was placed in a linear exposure (15 ft in lateral extent) and is approximately
300 ft in length. This riprap was deposited in layers. The bottom of the syenite layer (approximately 5 ft
height) occurs near the water line and is covered by a 5-ft layer of basalt. The riprap is consolidated
with no obvious indication of downstream mobilization of large components due to erosion.
The location of this section was surveyed with a Trimble global positioning system (GPS) unit.
A field sketch of the cross-section at this location was created in the field log notes and is available
upon request. Further survey activities may be required to fully detail the physical layout of these
sections of rip-rap.
3.0 Summary
Several creeks in the Libby and Troy areas were investigated to evaluate the presence and extent of LA
material used for the construction of riprap. Riprap material at one section of Libby Cr and two
sections of Pipe Cr includes quarried syenite, which is thought to have originated at the Vermiculate
Mountain Mine. The syenite contains LA in the form of weathered fracture coatings. The three
occurrences of syenite and LA material are listed below with location designations and estimated
volumes.
DCN: DC2616. 015.201.CREEK-2770.00
-------
T. Irwin, N. Raines
November 7, 2008
Page 4
Table 1 - Summary of Estimated Volumes of Riprap containing LA
CREEK
STATION
VOLUME (bank cubic yards)
Libby Creek
LC-01 to LC-02
1,000*
Pipe Creek
PC-01 to PC-02
200
PC-03 to PC-04
200
*Not including overlying basalt
DCN: DC2616. 015.201.CREEK-2770.00
-------
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-------
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IronlCreek
Approximate Lengtn or
Investigated Portion
Name
(miles)
Callahan Creek
1.23
Iron Creek
0.76
Lake Creek
1.05
Lake Creek Mid Section
0.12
Lake Creek Road Overpass
0.12
O'brien Creek
0.17
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Creeks/Rivers
Portion of Creek Investigated
Portion of Creek
Investigated Previously
Lake
Populated Areas
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DRAFT - For Official Use Only
Figure 2
Troy Area Creek I nvestigations
Libby Asbestos Site
Libby, Montana
CDM
-------
>Areas Requiring Remedial Action
Portion of Creek Investigated
Feet
50 100 200 300
1 inch equals 125 feet
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DRAFT - For Official Use Only
Figure 3
Pipe Creek (Lower Section)
Remediation Areas
Libby Asbestos Site
Libby, Montana
CDM
Montana
Idaho
Wyoming
Canada
-------
Canada
> Montana
Idaho
Wyoming
Area Requiring Remedial Action
Portion of Creek Investigated
fiibby Creek
1 inch equals 125 feet
DRAFT - For Official Use Only
Aerial Photo Data Sources
Libby Creek
Remediation Areas
Libby Asbestos Site
Libby, Montana
uttiy Odor mage Souce:
COM 2302
Flgnt Cotes: 1M4C2tD 1liriSftl2
.trials flown by\<1ajal IrtellQence Systems, Inc.
1SDS Hqhwav6 SQLth
Houaon.TX 77077
Tray Oder mags Sauce:
hHlonS .Agriculture iTB^eiyProgran (N>*IP)2II1S
Sales Section
USDA Farm Serdce >>gency
.Serial Prป:toqrapIti,'' Field Oflce
2222 VOfea 23DD SOLih
Salt LAe CtyUT 54119-232]
Td: FD1-97S-3SD3
F3C 8D1-97S-3S32
Bra I: apTO.^esiJ^lc ustfi.gov
Vifebate: ffltpjjjjwwgpfc uaJa .gov
-------
Form Numb- Aft-oos
LIBBY ASBESTOS PROJECT
Property Closeoyt Checklist (PCC)
Revision 3
Form Date: o 0*7
Field Logbook No.: lO lle( f Page No.'s: /^7 / 15 , ^j
loilnl %' ~
Address: 1 bhy Cre& IC Citv: Likhy
Occupant: ^ N .
Owner: Sto W. cf- TTVv) ฆ]-&f)0-
Oversight Personnel: lj. 4//^/
Removal Contractor: hฃ& '
Restoration Contractor: _ฃt
Associated BD Numbers: AJ&
PCC Check Completed by (100% of forms"): //6c- 1 C /Z..<2 Date: idjz-i itO^
Data Item
Value
Comments
Type of removal activity
circle all that apply
VCI removal
Interior cleaning
"Exterior remov3j>
Building materials
QSBr:
Circle all that apply:
Quick Response | Partial Removal
Start
Finish
Interior setup date(s)
/J k
i& A-
NA implies interior work not needed
Interior removal date(s)
i^J-
NA implies interior work not needed
Interior restoration date(s)
A_
NA implies interior work not needed
Exterior setup date(s)
00\
NA implies exterior work not needed
Exterior removal date(s)
NA implies exterior work not needed
Exterior restoration
date(s)
NA implies exterior work not needed
/<=>/?/& 9
Total days at property
[include weekends]
/ > / '
Contaminated material
removed
circle all that apply
VCI
Other insulation
Household items
Rubbish/Debris
cOtheB> A#//?*/?
C:\Documents and Settings\beaudoinkr\Desktop\PCC.doc
Page 1 of
-------
Form Numbt p O 0 J H i
Data Item
Value
Comments
Cubic yards (Yd3) of contaminated material removed:
Soil
H0!0! Yd3
NA
VCI
Yd3
Other insulation
Yd3
Type of insulation removed:
Household items
Description:
Rubbish/Debris
IS
Truckloads
NA
Description:
Any contaminated material
remaining after removal is
complete? <
; [responses must be consistent .ฆ
ฆ within the shaded sections] %
No - circle if next two items are circled NA below
-RrTit> - circle if Contaminated soil remaining is circled below
VCI - circle if VCI remaining is circled below
[responses must be consistent <-
'ฆ within: the shaded, sections]
Co ntarninated-so i 1
H-dmai n i n
NA
[When revising this section also ,
revise corresponding item in
shaded section above]
Location description:
AX, ^{<- w V* &
[responses must be consistent
within the shaded sections] :
VCI remaining
[When revising this section also..
revise corresponding item, in ./ฆ:
shaded section above] ฆ
Location description: [include RAWP Addendum background
information]
C:\Documents and Settings\beaudoinkr\Desktop\PCC.doc ,
Page 2 of U)
-------
Form Numbei -r>oฃ
Other material (i.e.,
gravel)
fixswJhVm) Yd3
Njt) !OoO
Type: (<=0 ฅ1"***ฆ
(b) c-^u^e^ ^oc-fr.
(t)
HEPA vacuum given to
resident?
Date:
Reason:
Items damaged during
construction
~ See removal and
restoration checklist
|/ None
ADDITIONAL INFORMATION
ClrOP-, Aw\f Tl^O
C:\Documents and Settings\beaudoiaki\Deslctop\PCC.doc
Page 3 of Lo
-------
CM
CLIENT
PROJECT
DETAIL
SP- 141276
JOB NO. _ 2 COMPUTED'BY _
DATE CHECKED ฐATE _
CHECKED BY PAGE NO. _
SP- 141277
Umi Qfi&K
2R- 07083 APฎ C 65 Nib [^QNWJA
S i A-14-"
Nd viSi Uฃ
2R- 07084 s \j\s t y Lsl. c i 'icji-O'3
2R- 07087 ,
SP- 141278
ฃ 1_. Lcn~^)
2R- 07126 \A^C4D1 Nb
/ '?H4H 'CtscLwp o-c* 4-c^-o-
SP- 141293 (
A(ฉ\ aql z\%
2R- 07133 ^
V \ V? Lt. qIo's^voj-cc^-
SP- 141300 Q_ lo%^)
19.-14-"
x AocA /VS
2R- 07134 ^ |ai4
SP- 141301 VolC^L H Jr W
-------
cms
CLIENT
PROJECT
DETAIL
2ft- 07509
SP- 141305
JOB NO. .
DATE CHECKED .
CHECKED BY .
HV"
Z. \ ฐ/c
AO'Oo&H/tf
COMPUTED BY
DATE
PAGE NO.
IVtomAfJA
$1 I oV'ซ5>rbCe_
2R- 07510
SP- 141306
2R- 07273
SP- 140813
A A '17ป&
f\om A-t x> d
/^K no
face*
" ILovO^^VLU.
to
CDM5
-------
TSSB ฃUJS
1
RIPRAP TO BE REMOVED
(DEPTH VARIES)
_w\\\n
6-FOOT
BY 2-FOOT BY 2-FOOT
CONCRETE BLOCKS
REMOVE CONCRETE BLOCKS
WITH NO REPLACEMENT
'/" f w\ J // f X x \ \% \ \
J, \ W /20V ll^l\\W\ \
SECTION
nzzDvm
5337.5?
12ฐ
032DUQUS
mzr
RIPRAP TO BE REMOVED
(DEPTH VARIES)
ฆT2SLC5
6-FOOT
BY 2-FOOT BY 2-FOOT
CONCRETE BLOCKS
REMOVE CONCRETE BLOCKS
WITH NO REPLACEMENT
SECTION
RIPRAP TO BE REMOVED
(DEPTH VARIES)
032 UTIL&&3
KOOTENAI
BUSINESS PARK *ฆ
INDUSTRY
6-FOOT
BY 2-FOOT BY 2-FOOT
CONCRETE BLOCKS
REMOVE CONCRETE BLOCKS
WITH NO REPLACEMENT
SECT ON
CB tES
SOUTHERN PORTION OF RIPRAP
LOOKING UPSTREAM
CENTER OF RIPRAP AREA LOOKING
SOUTHERN EXTENT OF RIPRAP
SITE ACCESS AND EXCAVATION
DOWNSTREAM
LOOKING DOWNSTREAM
AREA C
SCALE IN FEET
20 0
40
Soil Samples:
B1
B2
B3, C
D1
A1
A2
A3
A4
A5 48-74"
bgs
D2 48-74"
bgs
All other
samples
are12-14"
bgs
NORTHERN PORTION OF RIPRAP
LOOKING UPSTREAM
A*~ Oft Bum
. __
FXTFRIOR REMEDIATION NOTES:
(REFER TO CONTRACT DOCUMENTS FOR ADDITIONAL INFORMATION)
1. THIS PROPERTY HAS BEEN INSPECTED USING STANDARD OPERATING PROCEDURE COM
UBBY-06.
Z THE REMOVAL CONTRACTOR SHAU. PERFORM THE WORK WHILE MINIMIZING
ENVIRONMENTAL POLLUTION AND DAMAGE AS THE RESULT OF CONSTRUCTION
OPERATIONS. THE ENVIRONMENTAL RESOURCES WITHIN THE PROJECT BOUNDARIES AND
THOSE AFFEC1H3 OUTSIDE THE CONSTRUCTION LIMITS SHAU BE PROTECTED DURING THE
ENTIRE DURATION OF THIS PROJECT.
3 THE REMOVAL CONTRACTOR SHALL PUCE SAND BAGS WITHIN THE CREEK BED
UPSTREAM OF EXCAVATION AREAS ADJACENT TO aOWING WATER TO MINIMIZE FLOW AND
LOCALIZE SEDIMENT TRANSPORTATION.
4 THE REMOVAL CONTRACTOR SHALL PROVIDE THE WATER SOURCE FOR PERSONNEL
AND EQUIPMENT DECONTAMINATION. DECONTAMINATION WATER WILL BE CAPTURED AND
DISPOSED OF PROPERLY.
5 REMOVE ALL RIPRAP FROM THE CREEK BANK (AREA A) IN ADDITION TO 12 INCHES
BELOW GROUND SURFACE.
RFST MANAGEMENT PRACTICE NOTES:
1. APPROPRIATE EROSION AND SEDIMENT CONTROLS (SILT FENCES, TEMPORARY WATER
RETENTION BERMS, ETC.)SHAll BE INSTALLED PRIOR TO TOE COMMENCEMENT OF WORK
AND SHALL BE MAINTAINED FOR THE DURATTON OF REMOVAL ACTIVITIES.
2. EQUIPMENT SHALL BE PRESSURE WASHED PRIOR TO SITE ENTRY TO PREVENT THE
SPREAD OF NOXIOUS WEEDS TO THE REMOVAL AREA.
3. EQUIPMENT USED NEAR THE WATER SHALL BE CLEANED PRIOR TO CONSTRUCTION.
4. WORK SHALL BE CONDUCTED DURING A PERIOD OF LOW FLOW.
5. BIODEGRADABLE HYDRAULIC FLUIDS SHALL BE USED IN MACHINERY WHERE
APPROPRIATE
6. REFUELING SHALL OCCUR ON THE BACKSIDE OF THE LEVEE OR ON ESTABLISHED
STAGING AREAS.
7. CONSTRUCTION EQUIPMENT SHALL BE REGULARLY CHECKED FOR DRIPS OR LEAKS.
8. AT LEAST ONE FUEL SPILL KIT WITH ABSORBENT PADS SHALL BE ONSITE AT ALL
TIMES.
9. DRIVE TRAINS OF EQUIPMENT SHALL NOT OPERATE IN THE WATER.
12" BGS EXCAVATION DEPTH
EXCAVATION QUANTITIES
AREA
DESIGNATION
AREA
m
DEPTH
On.)
IN-PUCE
VOLUME Cyd^>
A
7379
12
273
B
5405
12
200
C
400
12
15
RIPRAP
-
-
1000s
TOTAL
1488*
RIPRAP VOLUME IS ESTIMATED
BASED ON FIELD MEASUREMENTS
AND VISUAL OBSERVATIONS.
NOTE: REFER TO SHEET C-1 FOR GENERAL NOTES,
LEGENDS, MAPS AND OTHER INFORMATION. REFER TO
SHEET C2 FOR DETAILS.
D
gjppiiil
mm
Revisions
Symbol
Descriptions
CDM Federal Programs Corporation
Date Approved
U.S. DEPARTMENT OF TRANSPORTATION
*) JOHN A. VOLPE NATIONAL
?/ TRANSPORTATION SYSTEMS CENTER
Designed by.
N.L SMITH
UBBY ASBESTOS PROJECT
SB LiBBY. MONTANA
US EPA
Region Vtlt
Denver. Colorado
UBBY CREEK
REMEDIATION PLAN
Drawn by:
M. KUZMIAK
Checked by.
G. McKENZIE
Scale: AS NOTED
Sheet
number
Plฐ' ,
Scale: '
Submitted by:
T. WALL
Dale: JUNE 5, 2009
Ug;9" UBBY_CREEK,DWG
Dwg.
No.:
File
iv fs
B
A
-------
Appendix A4
Completion Form for a Quick Response
at the Plywood Plant
-------
1111253-R8SDMS
Removal and Restoration Completion Form
For Quick Response Action at
Kootenai River Development Property
875 US Highway 2 (Former Plywood Plant)
Lib by, Montana
RE: EPA Property ID: AD-000686
Between August 30,2010 and September 1,2010, quick response removal and restoration
activities took place at 875 US Highway 2 (Kootenai River Development property). This
Removal and Restoration Completion Form summarizes cleanup activities that took place at the
property.
1.0 Removal and Restoration Activities
1.1 Exterior
Soil was removed along the trenched area north of the former veneer dryer in accordance with
the Contract Documents. Confirmation soil samples were collected from this area to verify the
contamination was removed to the depth required to meet current U.S. Environmental
Protection Agency (EPA) cleanup goals. However, visible vermiculite was observed in the floor
of the excavation in the area indicated on the attached map. EPA strongly recommends that it
be left alone and not disturbed. If the material is disturbed, the property owner is encouraged
to refer to the guidance included in the post-cleanup completion packet. Information about
Libby amphibole and vermiculite is also available at the EPA Information Center (108 E. 9th
Street) and online at http://www.epa.gov/region8/superfund/libbv/inhome.html.
Vermiculite-containing Building Material
Vermiculite was identified in the mortar and bricks along the perimeter of the former veneer
dryers. The vermiculite-containing building materials were removed and disposed of in
accordance with the Contract Documents.
I acknowledge that I have received a copy of the Quick Response Statement of Work for the
property and that the removal and restoration activities were performed as discussed and
agreed upon prior to the cleanup.
Owner
Date
-------
Appendix A5
Completion Form for a Quick Response
at the Valve House at Stimson Finger-Joiner Building
-------
mini ii ii 111 in:
1111250- R8 SDMS
Removal and Restoration Completion Form
For Quick Response Action at
Kootenai River Development Property
875 US Highway 2 (Valve House at Stimson Finger-Jointer Building)
Lib by, Montana
RE; EPA Property ID: AD-000686
Between August 18, 2010 and September 7, 2010, quick response removal and restoration
activities took place at 875 US Highway 2 (Valve House at Stimson Finger-Jointer Building)
(Kootenai River Development property). This Removal and Restoration Completion Form
summarizes cleanup activities that took place at the property.
1.0 Removal and Restoration Activities
1.1 Exterior
Soil was removed from the ground area surrounding the valve house and the floor of the valve
house, and restored in accordance with the Contract Documents. Confirmation soil samples
were collected from these areas to verify the contamination was removed to the depth required
to meet current U.S. Environmental Protection Agency (EPA) removal criteria. However,
contaminated soil remains at depth in the areas indicated on the attached map. These areas
were covered with materials in order to minimize the potential for human exposure. EPA
strongly recommends that it be left alone and not disturbed. If the at-depth material is exposed
or disturbed, the property owner is encouraged to refer to the guidance included in the post-
cleanup completion packet. Information about Libby vermiculite is also available at the EPA
Information Center (108 E. 9th Street) and online at
http: / / www.epa.gov/ regionS / superftmd /libby / inhome.html.
1.2 Interior
Vermiculite-containing Insulation Removal
Vermiculite-containing insulation was removed from the attic space, walls and ceiling of the
valve house. Following the removal, the space was inspected and air clearance samples were
collected to confirm the area was cleaned to standards established by the EPA. The removed
insulation was replaced unless otherwise stated in the Contract Documents.
Interior Cleaning
Based on visual inspection, an interior cleaning was conducted in the valve house. Following
the interior cleaning, the interior space was inspected and air clearance samples were collected
to confirm the area was cleaned to standards established by the EPA.
-------
Vermiculite-containing Building Material
Vermiculite was identified in the tongue and groove from the walls, door and ceiling of the
valve house. The vermiculite-containing building material was removed and disposed of in
accordance with the Contract Documents.
I acknowledge that I have received a copy of the Quick Response Statement of Work for the
property and that the removal and restoration activities were performed as discussed and
agreed upon prior to the cleanup.
Owner
Date
-------
Appendix A6
Completion Form for a Quick Response
at the Former Popping Plant on OU5
-------
Removal and Restoration Completion Form
For Quick Response Action at
Lincoln County Port Authority Property
875 U.S. Highway 2
Libby, Montana
RE: EPA Property ID: AD-000686
Between August 3,2011 and November 7, 2011, quick response removal and restoration
activities took place at 875 U S Highway 2 (Lincoln County Port Authority property). This
Removal and Restoration Completion Form summarizes cleanup activities that took place at the
property.
1.0 Removal and Restoration Activities
1.1 Exterior
Soil was removed from the area used for parking and was restored in accordance with the
Contract Documents. Confirmation soil samples were collected from this area to verify the
Libby amphibole was removed to the depth required to meet current U.S. Environmental
Protection Agency (EPA) removal goals. However, soils impacted with vcrmiculite or Libby
amphibole remain at depth in the areas indicated on the attached map. This area was covered
with materials in order to minimize the potential for human exposure. EPA strongly recommends
that it be left alone and not disturbed. If the at-depth material is exposed or disturbed, the
property owner is encouraged to refer to the guidance included in the post-cleanup completion
packet. Information about Libby amphibole and vermiculite is also available at the EPA
Information Center (108 E. 9th Street) and online at
http://www.epa. gov/region8/superfund/1 ihhv/inhome.html
I acknowledge that I have received a copy of the Removal and Restoration Statement of Work
for the property and that the removal and restoration activities were performed as discussed and
agreed upon prior to the cleanup.
Owner
Date
-------
Appendix A7
Completion Form for a Quick Response
at the Lincoln County Port Authority Property
(CDM Offices)
-------
Removal and Restoration Completion Form
For Quick Response Action at
Lincoln County Port Authority Property
875 U.S. Highway 2
Lib by, Montana
RE: EPA Property ID: AD-000686
Between April 16, 2012 and May 24, 2012, quick response removal and restoration activities
took place at 875 U S Highway 2 (Lincoln County Port Authority property). This Removal and
Restoration Completion Form summarizes cleanup activities that took place at the property.
1.0 Removal and Restoration Activities
1.1 Exterior
Soil was removed from a portion of the yard NW of the Lincoln County Port Authority building
and restored in accordance with the Contract Documents. Confirmation soil samples were
collected from this area to verify the contamination was removed to the depth required to meet
current U.S. Environmental Protection Agency (EPA) removal criteria.
I acknowledge that I have received a copy of the Removal and Restoration Statement of Work
for the property and that the removal and restoration activities were performed as discussed and
agreed upon prior to the cleanup.
-yf- t-ofj
Owner
Date
-------
Appendix A8
Documentation of Soil Removal Activities
of the Former Tree Nursery
-------
Removal and Restoration Completion Form
For Quick Response Action at
Lincoln County Port Authority Property
875 U.S. Highway 2
Libby, Montana
RE: EPA Property ID: AD-000686
Between June 25, 2012 and My 31, 2012, quick response removal and restoration activities took
place at 875 U S Highway 2 (Lincoln County Port Authority property). This Removal and
Restoration Completion Form summarizes cleanup activities that took place at the property.
1.0 Removal and Restoration Activities
1.1 Exterior
Soil was removed from the area previously known as the nursery and was restored in accordance
with the Contract Documents. Confirmation soil samples were collected from this area to verify
the Libby amphibole was removed to the depth required to meet current U.S. Environmental
Protection Agency (EPA) removal goals; however, soils impacted with vermiculite or Libby
amphibole remain at depth in the areas indicated on the attached map. This area was covered
with materials in order to minimize the potential for human exposure.
1 acknowledge that I have received a copy of the Removal and Restoration Statement of Work
for the property and that the removal and restoration activities were performed as discussed and
agreed upon prior to the cleanup.
Owner Date
-------
EXCAVATION QTYS
EXC
ZONE
TOTAL: 16098
V* t
THIS AREA HAD A
r. -v.-.
SHEET:
LIBBY ASBESTOS PROJECT
LINCOLN COUNTY, MONTANA
OF 2
US EPA
Region VIII
Denver, Colorado
US AfiUY CORPS OF CNONCERS
ouaha oistrbcr
RAftO RESPONSE PROGRAM
AO#- 000686 GEOUNIT#: 5730 GRZ#: 00
DRAWING BYfDATE
T. ROBERTSON 03/28/13
OC REVIEW BY/DATE
K. MCKENZIE 04/03/13
REVISION ป:
REVISION DATE:
DESCRIPTION:
LINCOLN COUNTY PORT AUTHORITY
875 US HIGHWAY 2
EXCAVATION DESIGN
0
04/12/13
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
DRAWING FINALIZED BYIDATE
T. ROBERTSON 04/12/13
N/A
N/A
N/A
..\0U4\STREET BY NAME\US HIGHWAY 2\875 US HIGHWAY 2\FISHINC PONO\Cซ\-FINAL DESICN-REV O.DWG
If APPLICABLE, THE ELECTRICITY TO THE HOUSE WILL BE TURNED OFF AS REQUIRED FOR CONSTRUCTION
ACTIVITIES. THE CONTRACTOR IS TO SUPPLY, AS NEEDED, A GENERATOR TO SUPPLY ELECTRICITY TO
APPLIANCES. PLEASE REFER TO PRI-ER RESTORATION AGREEMENT FOR LOCATIONS OF APPLICABLE
ELECTRICAL COMPONENTS.
2. UNDERGROUND UTILITIES AND SEPTIC'SYSTEMS MAY BE PRESENT ON THE PROPERTY. IF KNOWN, THEY
ARE MARKED IN APPROXIMATE LOCATIONS ONLY. PROCEED WITH CAUTION IN ALL EXCAVATION AREAS,
NOT INSPECTED/SAMPLED -
SEE INVESTIGA TION DA TA
NO EXCA VA TION REQUIRED
PER CURRENT REMOVAL CRITERIA
3. WHEN SHOWN, LOCATION OF DECONTAMINATION STATIONS AND BREAK AREAS ARE SUBJECT TO CHANGE
WITH EXCAVATION CONDITIONS. THESE A^EAS WILL NOT CHANGE IN RELATION TO EACH OTHER AND WILL BE
PRESENT AT ALL TIMES DURING REMOVAL ACTIVITIES.
4. IF APPLICABLE, REMOVE AND DISPOSE OF THE FIRST LAYER OF FIREWOOD IN CONTACT WITH
CONTAMINATED SOIL.
Digitally signed by
AYALA JEREMY A. \ 40366269 7
ON: c=US, o-U.S Government, ou=DoD,
OU-PKI, ou-USA,
cn=AYALA.JEREMY.A. 1403662697
Date: 2013.04.15 09,32:58 -OS'OO"
5. MISCELLANEOUS ITEMS NOT REFERRED TO IN THE RESTORATION AGREEMENT ARE TO BE CLEANED AND
STAGED FOR REINSTALLATION.
GOVERNMENT REPRESENTATIVE
6. SEE ADDITIONAL NOTES ON ATTACHED RRA SYNOPSIS AND PRE FORM(S).
NOTES:
LOCA TIONS ARE APPROXIMA TE.
AREAS REQUIRING REMOVAL HAVE BEEN INDICATED IN THE FIELD USING GREEN
FLAGGING.
. EXC ZONE 'B' DOES NOT REQUIRE RESTORATION.
EXCA VA TION IN ZONE 'B' siHALL CONTINUE UNTIL NO VERMICULITE IS OBSERVED
IN THE FLOOR OF EXCAVATION AND CLEARANCE SOIL SAMPLE RESULT IS ND.
EXTERIOR REMOVAL NOTES:
LEGEND
(REFER TO REMOVAL AND RESTORATION1 DOCUMENTS FOR ADDITIONAL INFORMATION)
12" BGS EXCAVATION DEPTH
DE-CON AREA
BREAK AREA
EXCAVATION ACCESS
DEPTH
(in.)
15998
-------
Appendix 6
Sample Phase List
-------
Analysis of Air Samples at OU5
Phase 1
202 field samples (analyzed by TEM-AHERA)
196 stationary indoor, 4 stationary outdoor, 2 personal outdoor
Index ID range 1-08051 to 1-09014
Sample Date range 6/23/2004 to 8/13/2009
Only 1/202 samples were detect for LA
1-08592: total LA cone = 0.0046 s/cc
Phase 1R
232 field samples (analyzed by TEM-AHERA)
160 stationary indoor, 53 stationary outdoor, 19 personal indoor
Index ID range 1R-24496 to 1R-36895
Sample Date range 1/23/2004 to 6/29/2006
10/232 samples were detect for LA (20 samples w/o TEM results)
Total LA cone detects range: 0.0048 s/cc to 1.4 s/cc
Highest detects were personal air samples during bulk removal
All detects measured in May-June 2005
Phase 2R
21 field samples (analyzed by TEM-AHERA)
16 stationary indoor, 5 stationary outdoor
Index ID range 2R-01028 to 2R-05369
Sample Date range 5/22/2008 to 5/21/2009
5/21 samples were detect for LA (5 samples w/o TEM results)
Total LA cone detects range: 0.0048 s/cc to 0.42 s/cc
All detects measured April 28, 2009 from soil split connex
Ambient Air Program (AA)
40 field samples (analyzed by TEM-ISO)
all stationary outdoor [from one OU5 monitor]
Index ID range AA-00081 to AA-01721
Sample Date range 10/4/2006 to 9/21/2007
8/40 samples were detect for LA (1 sample w/o TEM results)
Total LA cone detects range: 3.6E-05 s/cc to 1.6E-04 s/cc
B-l
-------
Analysis of Air Samples at OU5 (Continued)
20 field samples (analyzed by TIEIIV1 -ISO)
12 stationary outdoor, 8 personal outdoor [3 activities * 2 ABS areas]
Index ID range SQ-00041 to SQ-00134
Sample Dates 6/21/2005 (ND ABS area),, 6/25/2005 (Tir ABS area)
6/20 samples were detect for LA
Total LA cone detects range: 9.6E-04 s/cc to 0.0010 s/cc
Stimson Lumber Programs (SL)
456 field samples (analyzed by TEM-ISO, +AHERA for some)
103 stationary indoor, 150 personal indoor, 20 stationary outdoor, 183 personal outdoor
Index ID range SL-00001 to SL-70815
Sample Date range 9/10/2002 to 9/18/02 and 10/10/07 to 10/2/2008
111/456 samples were detect for LA (1 sample w/o TEM results)
Total LA cone detects range: 3.8E-04 s/cc to 0.16 s/cc
Index ID Summary:
SL-00001 to SL-00245 (not sequential):
monitoring of Stimson Lumber site workers (9/10/02 to 9/18/02)
N = 124 personal samples analyzed by ISO and AHERA
N = 38 stationary samples analyzed by ISO and AHERA
SL-00300 to SL-00339. SL-00420 to SL-Q0422: MotoX ABS
IN = 24 personal samples analyzed by ISO (9/10/08 and 9/17/08)
IN = 10 stationary samples analyzed by ISO (9/10/08 and 9/17/08)
SL-00 iL-00407: RecVis Biking ABS
IN = 46 samples analyzed by ISO (9/16/08 to 9/19/08)
SL-00408 to SL-00418. SL-00424 to SL-00601: Outdoor Worker ABS
IN = 48 samples analyzed by ISO (9/23/08 to 10/2/08)
SL-70120 to SL-70258 (not sequential): Wood Chip/Waste Bark ABS
IN = 16 personal samples analyzed by ISO (10/10/07 to 10/15/07)
Sb-70366 to Sb-70393, Sb-70540 to Sb-70664 (not sequential): Indoor Worker ABS, Stationary
IN = 75 samples analyzed by ISO (12/10/07 to 1/14/08)
Sb-70404 to Sb-70489, SL-70681 to SL-70687 (not sequential): Indoor Worker ABS, Personal
IN = 38 samples analyzed by ISO (11/13/07 to 12/16/07)
SL-70672 to SL-70677. SL-70702 to SL-70815 (not sequential):
general worker monitoring during soil sample collection (6/25/08 to 7/14/08)
N = 37 samples analyzed by ISO
***ABS programs are shown in blue
B-2
-------
Analysis of Soil Samples at OU5
Oct 2002 Contaminant Screening Study (CS-)
131 field samples (analyzed by PLM-VE)
105 surface, 26 subsurface (mostly 5-pt composites)
Index ID range: CS-08295 to CS-09672
Sample Date range: 10/14/2002 to 10/18/2002
Only 3/131 samples were detect for LA:
CS-09294 Tr Southeast Area (0-6")
CS-09595 Tr Nursery (0-6")
CS-09658 <1 Former Popping Plant (48-60")
All samples were Vis - (Note: visible status not in Database)
Mav 2004 Bike Track Sampling (CS-)
21 field samples (analyzed by PLM-VE)
8 (0-1"), 11 (2-6"), 2 (6-12") (mostly 5-pt composites)
Index ID range: CS-18433 to CS-18498
Sample Date: 5/15/2004
All samples were non-detect for LA
4/21 samples were Vis +
Mav 2004 Pre-Design. Central Maintenance Bldg (1D-)
4 field samples (analyzed by PLM-VE)
4 (0-1" 5-pt composites)
Index ID range: 1D-01823 to 1D-01826
Sample Date: 5/12/2004
All samples were non-detect for LA
2/4 samples were Vis +
July 2004 Demolition Derby Sampling (CS-)
19 field samples (analyzed by PLM-VE)
9 (0-1"), 9 (2-6"), 1 (6-12") (5-pt composites)
Index ID range: CS-18581 to CS-18599
Sample Date: 7/1/2004
Only 1/19 samples were detect for LA:
CS-18583 Tr Grid 2 (0-1")
All samples were Vis - (Note: visible status not in DB)
June 2005 SQAPP ABS (SQ-)
4 field samples (analyzed by PLM-VE)
4 (0-2") (3-pt to 19-pt composites)
Index ID range: SQ-00061, SQ-00062, SQ-00066, SQ-00067
Sample Dates: 6/21/2005 and 6/25/2005
Only 2/4 samples were detect for LA:
SQ-00066 Tr Lawn mowing scenario location
SQ-00067 Tr Raking & child play scenario location
Both Trace samples were Vis +
B-3
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Analysis of Soil Samples at OU5 (Continued)
Oct 2007 Soil Data Gap Study (SL-)
182 field samples (analyzed by PLM-VE)
180 (0-3" 30-pt composites), 2 (0-12" grabs from beneath piles)
Libby GW Superfund Site, N = 90
Former Nursery Area, N = 11
Waste Bark Piles, N = 2
Libby Creek Banks, N = 21
Stormwater Containment/Waste Water Lagoon, N = 52
Former North Guard Station, N = 1
Diesel Pump House, N = 1
Soil Sample Location CS-09294, N = 4
Index ID range: SL-70001 to SL-70343
Sample Date range: 10/2/2007 to 10/26/2007
7/182 samples were detect for LA:
SL-70038 Tr SCWWL
SL-70053 Tr SCWWL
SL-70072 1 Former nursery area
SL-70073 Tr Former nursery area
SL-70074 Tr Former nursery area
SL-70077 Tr Former nursery area
SL-70110 Tr Libby Groundwater Superfund Site
Visible status reported as n-X, n-L, n-M, n-H in DB
and summarized in CDM report figures
June/Julv 2008 Soil Data Gap Addendum (SL-)
73 field samples (analyzed by PLM-VE)
73 (0-6" 30-pt composites)
MotoX Track, N = 18
Lumber Yard, N = 16
Southwest Area, N = 16
Railroad Spur, N = 1
Log Storage Area, N = 20
Former Popping Plant, N = 0
Index ID range: SL-70700 to SL-70819
Sample Date range: 6/25/2008 to 7/11/2008
30/73 samples were detect for LA:
Tr: N=29 samples
<1%: N=1 sample (Former Nursery)
Visible status reported as n-X, n-L, n-M, n-H in DB
B-4
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Analysis of Soil Samples at OU5 (Continued)
Oct 2008 Outdoor ABS (SL-)
MotoX ABS
62 field samples
1 (0-3" 30-pt composites), 30 (0-3" grabs)
1 (0-6" 30-pt composites), 30 (0-6" grabs)
Index ID range: SL-01054 to SL-01387
Sample Date range: 10/16/2008 and 10/21/2008
2/62 analyzed by PLM-VE (composites only)
Both samples were non-detect for LA
Visible status reported as n-X, n-L, n-M, n-H in DB
Worker ABS
744 field samples [8 areas * 3 sampling rounds]
24 (0-3" 30-pt composites), 720 (0-3" grabs)
Index ID range: SL-00439 to SL-01633
Sample Date range:10/7/2008 to 10/24/2008
463/744 analyzed by PLM-VE
10/463 samples were detect for LA:
8 samples: Tr (Former Nursery)
1 sample: <1% (Former Nursery)
1 sample: Tr (SW Area)
Visible status reported as n-X, n-L, n-M, n-H in DB
Oct 2008 Landfarm (SL-)
51 field samples (analyzed by PLM-VE)
51 subsurface (12-15" grabs)
Index ID range: SL-00900 to SL-00953
Sample Date: 10/14/2008
All samples were non-detect for LA
Visible status reported as n-X, n-L, n-M, n-H in DB
April 2009 Re-Development Sampling (SL-)
8 field samples (analyzed by PLM-VE)
8 (0-6" 30-pt composites)
Collected from 8 zones
Index ID range: SL-01760 to SL-01767
Sample Date: 4/21/09
All samples were non-detect for LA
All samples were Vis -
April 2009 Pre-Design Libbv Creek Driveway (1D-)
7 field samples (analyzed by PLM-VE)
7 (0-3" to 0-6" 30-pt composites)
Index ID range: 1D-12501 to 1D-12507
Sample Date: 4/27/2009
All samples were non-detect for LA
All samples were Vis -
B-5
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Analysis of Dust Samples at OU5
May 2002. Phase 1
2 field samples (analyzed by TEM-ISO)
collected from former nursery shed
Index IDs: 1-06850 and 1-06857
Sample Date 5/2/2002
1-06850: total LA cone = ND
1-06857: total LA cone = 7,026 s/cm2
Sept 2002 Contaminant Screening Study (SL-)
37 field samples (analyzed by TEM-ISO)
collected from all site bldgs
Index ID range SL-00059 to SL-00242
Sample Date range 9/12/2002 to 9/18/2002
18/37 samples were detect for LA
Total LA cone detects range: 131 s/cm2 to 44,116 s/cm2
Exceedances of 5,000 s/cm2:
SL-00061 8,823 Center of central main, bldg
SL-00175 8,823 Diesel fire pump house
SL-00178 44,116 Guard station at Libby Creek bridge
April 2004 Pre-Design. Central Maintenance Bldg (1D-)
24 field samples (analyzed by TEM-AHERA)
collected from central maintenance bldg
Index ID range 1D-01715 to 1D-01791
Sample Date range 4/19/2004 to 4/30/2004
5/24 samples were detect for LA
Total LA cone detects range: 483 s/cm2 to 1,449 s/cm2
EmimLWMlMimEMMksimMm
24 field samples (analyzed by TEM-ISO)
collected from all ABS blldgs
Index ID range SL-70400 to SL-70497
Sample Date range 11/13/2007 to 12/16/2007
4/24 samples were detect for LA
Total LA cone detects range: 35 s/cm2 to 185 s/cm2
***ABS programs are shown in blue
B-6
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Analysis of Bulk Material at OU5
April 2004 Central Maintenance Bide PDI (1D-)
3 field samples (analyzed by PLM NIOSH 9002)
concrete roofing material
Index IDs: 1D-01784, 1D-01787, 1D-01788
Sample Date 4/30/2004
All samples were <1% for TREM-ACT
Aug 2004 Central Maintenance Bide PDI (1D-)
2 field samples (analyzed by PLM NIOSH 9002)
bulk insulation
Index IDs: 1D-01978, 1D-01979
Sample Date 8/12/2004
All samples were non-detect for TREM-ACT
B-7
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Appendix C
Asbestos Analysis Methods and
Data Reduction Techniques
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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 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.
Amphiboles: Five 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). More recently, the U.S. Geological Service (USGS) 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 the asbestos at Libby includes a
number of related amphibole types. The most common forms are winchite and richterite, with
lower levels of tremolite, actinolite, and magnesioriebeckite. Because the 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 Libby Amphibole (LA) asbestos.
2 Measurement Techniques for Asbestos in 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 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 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.
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 by transmission electron microscopy (TEM) in accord with the preparation methods
provided in ISO 10312 (ISO 1995).
If air samples are deemed to be overloaded, samples are prepared indirectly (either with or
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 1.3.4 below).
3.2 Sample Analysis
Air and dust samples collected as part of the OU5 sampling programs were analyzed by TEM in
basic accord with the counting and recording rules specified in ISO 10312 (ISO 1995), and the
project-specific counting rule modifications specified in the respective SAPs. These
modifications included changing the 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 is observed. Mineral type is determined by
Selected Area Electron Diffraction (SAED) and Energy Dispersive Spectroscopy (EDS), and
each structure is assigned to one of the following four categories:
LA Libby-class amphibole. Structures having an amphibole SAED pattern and an
elemental composition similar to the range of fiber types observed in ores from
the Libby mine (Meeker et al. 2003). This is a sodic tremolitic solid solution
series of minerals including actinolite, tremolite, winchite, and richterite, with
lower amounts of magnesio-arfedsonite and edenite/ferro-edenite.
1 Overloaded is defined as >25% obscuration on the majority of the grid openings (see Libby Laboratory
Modification #LB-000016 and SOP EPA-LIBBY-08).
-------
OA Other amphibole-type asbestos fibers. Structures having an amphibole SAED
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 may include non-asbestos mineral fibers such as
gypsum, glass, or clay, and may also include various types of organic and
synthetic fibers derived from carpets, hair, etc.
For the purposes of this report, air concentrations and dust loading values 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 direct) approach is to express the concentration of each sample in terms of the
PCME 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 value 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 and all dust
loading values will be reported in units of total LA s/cc.
3.4 Calculation of Air Concentrations
The concentration of LA in air is given by:
Air Concentration (s/cc) = N ฆ S
where:
N = Number of structures observed
S = Sensitivity (cc"1)
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For air, the sensitivity is calculated as:
S =
GO-Ago-V-1000-F
where:
S = Sensitivity for air (cc"1)
EFA = Effective area of the filter (mm2)
GO = Number of grid openings examined
Ago = Area of a grid opening (mm2)
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 Combining Results from Multiple Samples
When the exposure metric of concern is the average concentration across a set of multiple
samples, the best estimate of the mean concentration is calculated simply by averaging the
individual concentration values. Note that samples with a count of zero (and hence a air
concentration or dust loading of zero) are evaluated as zero when computing the best estimate
of the mean (EPA 2008). This approach yields an unbiased estimate of the true mean that does
not depend on the analytical sensitivity of the samples included in the data set.
3.6 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 = 1/4 CHIINV[0.025, 2N+1]
UB = 1/4 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
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As N increases, the absolute width of the confidence interval increases, but the relative
uncertainty [expressed as the confidence interval (CI) divided by the observed value (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 ฆ CHIINV[0.975, (2 ฆ N+1)]
97.5% UB = 0.5 ฆ CHIINV[0.025, (2 ฆ N+1)]
Using this approach, the equation for calculation of the upper and lower bounds on the air
concentration of asbestos structures is:
Air Concentration (s/cc) = (LB or UB) ฆ 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 uncertainty bounds around the average of a group of asbestos samples is
complicated by the fact that the between-sample variability in the measured concentration
values includes the between-sample variability that arises from both analytical measurement
error in individual samples and from between-sample temporal or spatial variability. EPA 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 samples collected as part of the OU5 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 (SPP) (CDM 2004). In brief, each soil sample is dried and sieved through a %
inch screen. Particles retained on the screen (if any) are referred to as the "coarse" fraction.
Particles passing through the screen are referred to as the fine fraction, and this fraction is
ground by passing it through a plate grinder. The resulting material is referred to as the "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.
4.2 Sample Analysis
Soil samples collected at the Libby Site are analyzed using polarized light microscopy (PLM).
The coarse fractions were examined using stereomicroscopy, and any particles of asbestos
(confirmed by PLM) were removed and weighed in accord with SRC-LI BBY-01 (referred to as
"PLM-Grav"). The fine ground aliquots were analyzed using a Libby-specific PLM method using
visual area estimation, as detailed in SOP SRC-LI BBY-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
Bin C: LA detected at levels greater than or equal to the 1% LA reference material
Of the 985 soil field samples collected during these OU5 sampling programs, 739 samples had
a coarse fraction, and all but one2 of these samples was reported as non-detect for LA when
analyzed by PLM-Grav. In this case, the PLM-VE result was "<1". Because of this, this report
focuses on the PLM-VE results for the fine ground fraction only.
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
2 PLM-Grav result for this sample was reported as "Tr"
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present in accord with SOP CDM-LIBBY-06. A semi-quantitative estimate (none, low,
moderate3, high) of the amount of visible vermiculite present was noted for each sampling point.
For composite samples, a count of the number of sampling points assigned to each visible
vermiculite ranking was recorded on the Field Sample Data Sheet (FSDS) in the sample
comments (e.g., 18 none [X], 6 low [L], 4 moderate [M], 2 high [H]).
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 value of "none", or as "Vis +" if one or more of the sampling points were
assigned a value of "low", "moderate", or "high".
A potential limitation to this ranking strategy is that it does not account for differences in the
amount or frequency of visible vermiculite detections. For example, an area with 1 "low" point
and 29 "none" points and an area with 24 "moderate" points and 5 "high" points would both be
ranked as "Vis +".
Option 2: Detection Frequency
In this approach, an area is assigned a value equal to the detection frequency by 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 "moderate" 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 observed. In other words, an ABS area with 5 "low" points 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 assigning a weighting factor to each level, where the weighting factors are intended
to 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.
3 The visual inspection SOP CDM-LIBBY-06 uses the terminology "intermediate" to refer to the
"moderate" classification. For the purposes of this document, the term "moderate" is retained to
correspond with the accompanying field documentation.
-------
Moderate/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 Moderate.
Based on these descriptions, the weighting factors that were used to calculate scores are as
follows:
Visible Vermiculite
Weighting factor
Level (Lj)
m
None
0
Low
1
Moderate
3
High
10
The score is then the weighted sum of the observations for the area:
ฑLt-Wt
Score =
x
This value can range from zero (all points are "none") to a maximum of 10 (all points are "high").
For example, an area with 1 "low" point and 29 "none" points would receive a value of 1/30 =
0.033, while an area with 24 "moderate" points and 5 "high" would receive a score of (24-3 +
5-10) / 30 = 4.13.
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Appendix D
Analytical and Other Data
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Appendix D1
Scribe Database
Scribe database is available on CD by request.
Contact the EPA Records Center to request a copy: 303-312-6473.
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Appendix D2
Scribe Queries
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SRC Air Results Queries for OU5 Scribe
SRC_Air Total LA Concentration Data
Purpose:
The purpose is to select binned air analytical results for field samples that have been analyzed by TEM.
Results for LA particles from analyses that are not lab QC are selected.
SQL Code:
SELECT Samples.Samp_No, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.Sub_Matrix, Samples.SampleType, Samples.Remarks,
Analysis AnalysisMethod, Analysis AnalysisDate, Analysis AnalysisLabID, Analysis AnalysisPrepMethod,
Analysis AnalysisLabSamplelD, Analysis AnalysisLabJobNumber, Analysis AnalysisFilterStatus,
Analysis AnalysisGOSize, Analysis AnalysisGOCounted, Analysis AnalysisEFA,
Analysis AnalysisFFactor, Analysis AnalysisQuantityAnalyzed, Analysis AnalysisQuantityAnalyzedUnits,
Analysis AnalysisLabQCType, LabResults Result, LabResults Result_Qualifier,
LabResults Lab_Result_Qualifier, LabResults Result_Units, LabResults Comments,
LabResults.CharacteristicID, LabResults ResultMineralClass
FROM (LabResults INNER JOIN Analysis ON LabResults AnalysisID = Analysis AnalysisID) INNER JOIN
Samples ON Analysis Samp_No = Samples Samp_No
WHERE (((Samples Matrix)="air") AND ((Samples SampleType)="field sample") AND
((Analysis AnalysisFilterStatus)="analyzed") AND ((Analysis AnalysisLabQCType)="not qa") AND
((LabResults ResultMineralClass)="la")):
SRC_Soil Results_PLM9002_Part1
SRC_Air Concentration Data_Raw Struc_Part1
Purpose:
The purpose is to select raw structure data for air samples that have been analyzed by TEM.
SQL Code:
SELECT Samples Samp_No, Samples SampleDate, Samples Location, Samples Sub_Location,
Samples Matrix, Samples Sub_Matrix, Samples SampleType, Samples Remarks,
Analysis AnalysisMethod, Analysis AnalysisDate, Analysis AnalysisLabID, Analysis AnalysisPrepMethod,
Analysis AnalysisLabSamplelD, Analysis AnalysisLabJobNumber, Analysis AnalysisFilterStatus,
Analysis AnalysisGOSize, Analysis AnalysisGOCounted, Analysis AnalysisEFA,
Analysis AnalysisFFactor, Analysis AnalysisQuantityAnalyzed, Analysis AnalysisQuantityAnalyzedUnits,
Analysis AnalysisLabQCT ype, Structures Grid, Structures GridOpening, Structures StructureType,
Structures Primary, Structures Total, Structures Length, Structures Width, Structures MineralClass,
[Length)/[Width] AS AR, Structures StructureIdentification
FROM (Analysis INNER JOIN Samples ON Analysis Samp_No = Samples Samp_No) INNER JOIN
Structures ON Analysis AnalysisID = Structures AnalysisID
WHERE (((Samples Matrix)="air") AND ((Analysis AnalysisFilterStatus)="analyzed"));
SRC_Air Concentration Data_Raw Struc_Part2
Purpose:
This query is a continuation of "SRC_Air Concentration Data_Raw Struc_Part1".
The purpose is to select LA raw structure data for field samples that are not lab QC analyses.
SQL Code:
SELECT [SRC_Air Concentration Data_Raw Struc_Part1 ].Samp_No, [S Concentration Data_Raw
Struc_Part1].SampleDate, [S Concentration Data_Raw Struc_Part1].Location, [SRC_Air
Concentration Data.Raw Struc_Part1 ].Sub_Location, [S Concentration Data_Raw
Struc_Part1].Matrix, [SRC_Air Concentration Data_Raw Struc_Part1 ].Sub_Matrix, [SRC_Air
Concentration Data.Raw Struc_Part1].SampleType, [SRC_Air Concentration Data_Raw
Struc_Part1].Remarks, [SRC_Air Concentration Data_Raw Struc_Part1].AnalysisMethod, [SRC_Air
Concentration Data.Raw Struo_Part1].AnaIysisDate, [SRC_Air Concentration Data_Raw
Struc_Part1].AnalysisLablD, [SRC_Air Concentration Data_Raw Struc_Part1].AnalysisPrepMethod,
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[SRC_Air Concentration Data_Raw Struc_Part1].AnalysisLabSamplelD, [SRC_Air Concentration
Data_Raw Struc_Part1].AnalysisLabJobNumber, [SRC_Air Concentration Data_Raw
Struc_Part1]AnalysisFilterStatus, [SRC_Air Concentration Data_Raw Struc_Part1]AnalysisGOSize,
[SRC_Air Concentration Data_Raw Struc_Part1 ].AnalysisGOCounted, [SRC_Air Concentration
Data_Raw Struc_Part1].AnalysisEFA, [SRC_Air Concentration Data_Raw Struc_Part1].AnalysisFFactor,
[SRC_Air Concentration Data_Raw Struc_Part1].AnalysisQuantityAnalyzed, [SRC_Air Concentration
Data_Raw Struc_Part1].AnalysisQuantityAnalyzedUnits, [SRC_Air Concentration Data_Raw
Struc_Part1].AnalysisLabQCType, [SRC_Air Concentration Data_Raw Struc_Part1].GrW, [SRC_Air
Concentration Data_Raw Struo_Part1].GridOpening, [SRC_Air Concentration D. v
Struc_Part1].StructureType, [SRC_Air Concentration Data_Raw Struc_Part1],Primary, [SRC_Air
Concentration Data.Raw Struc_Part1].'Total, [SRC_Air Concentration D. v Struc_Part1].Length,
[SRC_Air Concentration Data_Raw Struc_Part1].Width, [SRC_Air Concentration Data_Raw
Struc_Part1].AR, [SRC_Air Concentration Data.Raw Struc_Part1],MineraIClass, [SRC_Air Concentration
Data_Raw Struc_Part1].Structureldentification, llf([Length]>5 And [WidthJ>=0.25 And [AR]>=3 And
[MineraiCiass] Like "LA" And [Total]>0,1,0) AS PCMEIa. iif([Length]>10 And [AR]>=3 And [MineraiCiass]
Like "LA" And [Total]>0,1,0) AS BCIa
FROM [S Concentration Data_Raw Struc_Part1]
WHEI Concentration Data.Raw Struc_Part1].Matrix)="air") AND ((|SRC_Air Concentration
Data_Raw Struc_Part1].SampleType)="field sample") AND (([SRC_Air Concentration Data_Raw
Struc_Part1].AnalysisFilterStatus)="analyzed") AND (([SRC_Air Concentration Data_Raw
Struc_Part1].AnalysisLabQCType)="not qa"));
-------
SRC Soil Results Queries for OU5 Scribe
SRC_Soil PLMVE Min Analysis Date
Purpose:
Select the first analysis performed for a sample. This is the true "NOT QA". For PLM-VE subsequent
analyses have been performed on samples and the database does not correctly identify these. The main
reason for this is that the laboratories do not know that they are performing a QC analysis and therefor do
not identify them as such. This has been recognized as a problem, but the only solution to it is to change
the database after the fact and this has not happened yet and it is uncertain if this ever will happen.
SQL Code:
SELECT Analysis, Samp_No, Analysis.AnalysisMethod, Min (An a lysis .Ana lys is Date) AS
MinOfAnalysisDate
FROM Analysis
GROUP BY Analysis.Samp_Noซ Analysis.AnalysisMethod
HAVII nalysis.AnalysisMethod)=,,PLM-VEM));
SRC_Soil Results_PLM9002_Part1
Purpose:
List all soil samples analyzed by PLM-9002.
SQL Code:
SELECT Samples.Samp_No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.Sub_Matrix, Min(Analysis.AnalysisDate) AS MinOfAnalysisDate,
Analysis.AnalysisLabQCType, LabResults.CharacteristicID, LabResults.Result,
LabResults.Result_Qualifier, LabResults.ResultJJnits,
Hf([LabResults]![Resu lt_Qualifier]=="ND","ND",llf([LabResu lts]![Resu lt_Qualifier]="T r","TR", llf([LabResu Its]!
[Result_Qualifier]="<","<1",[LabResults]i[Result]))) AS [9002 Result (%)], LabResults.ResultlVIineralClass
FROM Location INNER JOIN ((LabResults INNER JOIN Analysis ON LabResults.AnalysisID =
Analysis.AnalysisID) INNER JOIN Samples ON Analysis.Samp_No = Samples.Samp_No) ON
Location. Location = Samples.Location
GROUP BY Samples.Samp_No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.Sub_Matrix, Analysis.AnalysisLabQCType, LabResults.CharacteristicID,
LabResults.Result, LabResults.Result_Qualifier, LabResults.Result_Units,
llf([LabResults3![Result_Qualifier]=,,ND",,,ND,,,llf([LabResults]![Result_Qualifier]="Tr",'TR,,,llf([LabResults]!
[Result_Qualifier]="<","<1",[LabResults]![Result]))), LabResults.ResultlVIineralClass,
LabResults.Analytical_Method
HAVIi amples.SampleType)="field sample") AND ((Samples.Matrix)="soil") AND
((Samples.Sub_Matrix) Like "*soil*") AND ((Analysis.AnalysisLabQCType)="not qa") AND
((LabResults.Analytical_Method)="PLM-9002"));
SRC_Soil Results_PLM9002_Part2
Purpose:
Transpose soil data_PLM-9002_part1.
SQL Code:
JSFORM Max([SRC_Soil Results_PLM9002_Part1].[9002 Result (%)]) AS [MaxOf9002 Result (%)]
SELECT [SRC_Soil Results_PLM9002_Part1].Samp_No, [S I Results_PLM9002_Part1].Latitude,
[SRC_Soil Results_PLM9002_Part1].Longitude, [SRC_Soil ResuIts_PLM90Q2_Part1],Datum, [SRC_SoiI
Results_PLM9002_Part1].SampleType, [SRC_Soil Results_PLM9002_Part1],SampleDate, [SRC_Soil
Results_PLM9002_Part1].Location, [SRC_SoiI Results_PLM9002_Part1].Sub_Location, [SRC_Soil
Results_PLM9002_Part1].Matrix, [SRC_Soil Results_PLM9C t1].Sub_Matrix, [SRC_Soil
Results_PLM9002_Part1].MinOfAnalysisDate, [SRC_Soil Results_PLM9002_Part1].AnalysisLabQCType
FROM [S I Results_PLM9Q02_Part1 ]
-------
GROUP BY [SRC_Soil Results J3LM9002_Part1].Samp_No, [SRC_Soil
Results_.PLM9002__Part1].Latitude, [SRC_Soil Results__PLM90Q2_Part1].Longitude, [SRC_Soil
Results_.PLM9002__Part1].Datum, [SI Results_PLM9002__Part1].SampleType, [SRC_Soil
Results_PLM9002_Part1].SampleDate, [SRC_Soil Results_PLM9002_Part1].Location, [SRC_Soil
Results_PLM9002_Part1].SubJ_ocation, [SRC_Soil Results_PLM9C i/latrix, [SRC_SoiI
Results_PLM9002_Part1].Sub_Matrix, [SRC_Soil Results_PLM9002_Part1].MinOfAnalysisDate,
[SRC_Soil Results_PLM9002_Part1].AnalysisLabQCType
PIVOT [S I Results_PLM9002_Part1].CharacteristiclD;
SRC_Soil Results_PLMGrav
Purpose:
List results for soil samples analyzed by PLM-Grav. The result is the ResultsQualifier; this is populated
in a new column titled "GRAV RESULT (%)".
SQL Code:
SELECT Samples.Samp_.No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.Sub_Matrix, Min(Analysis.AnalysisDate) AS MinOfAnalysisDate,
Analysis .AnalysisLabQCType,
llf([LabResults]![Result_Qualifier]="ND","ND",llf([LabResults]![Result_Qualifier]="Tr","TR",llf([LabResults]!
[Result_Qualifier]="<","<1 ".[LabResults]![Result]ป) AS [GRAV Result (%)]
FROM Location INNER JOIN ({LabResults INNER JOIN Analysis ON LabResults.AnalysisID =
Analysis.AnalysisID) INNER JOIN Samples ON Analysis.Samp_.No = Samples.Samp_No) ON
Location. Location = Samples.Location
GROUP BY Samples.Samp_No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.SubJVIatrix, Analysis.AnalysisLabQCType,
llf([LabResults]![Result_Qualifier]="ND","ND",llf([LabResults]![Result_Qualifier]="Tr","TR",llf([LabResults]!
[Result_Qualifier]="<","<1",[LabResults]i[Resuit]))), LabResults.ResultMineralClass,
LabResults.AnalyticaLMethod
HAVIi amples.SampleType)="field sample") AND ((Samples.Matrix)="soil") AND
((Samples.Sub_Matrix) Like "*soil*") AND ((Analysis.AnalysisLabQCType)="not qa") AND
((LabResults.ResultMineralClass)="la") AND ((LabResults.AnalyticaLMethod) Like "*grav*"));
SRC_Soil Results_PLMVE
Purpose:
List results for soil samples analyzed by PLM-VE. The result is the ResultsQualifier; this is populated in
a new column titled "VE MF RESULT (%)".
SQL Code:
SELECT Samples.Samp__No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.Sub_Matrix, Min(Analysis.AnalysisDate) AS MinOfAnalysisDate,
Analysis .AnalysisLabQCType,
Hf([LabResults]![Result_Qualifier]="ND","ND",llf([LabResults]![Result_Qualifier]="Tr","TR",llf([LabResults]!
[Result_Qualifier]=,,<",,,<1",[LabResults]([Result]))) AS [VE MF Result (%)]
FROM [S I PLMVE Min Analysis Date] INNER JOIN (Location INNER JOIN ((LabResults INNER
JOIN Analysis ON LabResults.AnalysislD=Analysis.AnalysislD) INNER JOIN Samples ON
Analysis.Samp_No=Samples.Samp_No) ON Location.Location=Samples.Location) ON ([SRC_Soil
PLMVE Min Analysis Date].Samp_No=Analysis.Samp_No) AND ([SI I PLMVE Min Analysis
Date].MinOfAnalysisDate=Analysis.AnalysisDate)
GROUP BY Samples.Samp_No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples.SampleDate, Samples.Location, Samples.Sub_Location,
Samples.Matrix, Samples.SubJVIatrix, Analysis.AnalysisLabQCType,
llf([LabResults]![Result_Qualifier]="ND","ND",llf([LabResults]![Result_Qualifier]="Tr","TR",llf([LabResults]!
-------
[ResuIt_QuaIifier]="<","<1",[LabResuIts]![Result]))), LabResults.ResultMineralClass,
LabResults.CharacteristicID, LabResults.Analytical_Method
HAVIi amples.SampleType)="field sample") AND ((Samples,Matrix)="soil") AND
((Samples.Sub_Matrix) Like "*soil*") AND ((Analysis.AnalysisLabQCType)="not qa") AND
((LabResults.ResultMineralClass)="la") AND ((LabResults.CharacteristiclD)="mfla") AND
((LabResults.AnalyticalJWetfiod) Like "*ve*"));
SRC_Soil Results_ALL
Purpose:
Combine results for all methods available for each sample.
SQL Code:
SELECT Samples,Samp_.No, Location,Latitude, Location,Longitude, Location,Datum,
Samples,SampleType, Samples,SampleDate, Samples,Location, Samples,Sub_Location,
Samples,Matrix, Samples,Sub_Matrix, Min(Analysis.AnalysisDate) AS MinOfAnalysisDatel,
Analysis.AnalysisLabQCType, [S I Results J5LM9002_Part2].[TREM-ACTN] AS [9002 TREM-
ACTN (%)], [SRC_Soil Results_PLMGrav].[GRAV Result (%)], [SRC_Soil Results_PLMVE],[VE 1VIF
Result (%)], Samples,Remarks
FROM ([SRC_Soil ResultsJ^LMGravJ RIGHT JOIN ((Location INNER JOIN (Analysis INNER JOIN
Samples ON Analysis.Sarrtp_No = Samples,Samp__No) ON Location,Location = Samples.Location) LEFT
JOIN [SRC_Soil Results_PLMVE] ON Analysis,Samp__No = [SRC_Soil Results_.PLMVE].Samp_No) ON
[SRC_Soil Results__PLMGrav].Samp__No = Analysis,SampJ T JOIN [SRC_Soil
Results__PLM9002_.Part2] ON Analysis,Samp_.No = [SRC_Soil Results__PLM9002_.Part2].Samp_No
GROI Samples.Samp__No, Location.Latitude, Location.Longitude, Location.Datum,
Samples.SampleType, Samples,SampleDate, Samples,Location, Samples,Sub_Location,
Samples.Matrix, Samples.Sub_Matrix, Analysis.AnalysisLabQCType, [S 1
Results__PLM9002_.Part2].[TREM-ACTN], [SI I Results_PLMGrav].[GRAV Result (%)], [SI , , 1
Resuits_PLMVE].[ฅE MF Result (%)], Samples,Remarks
HAVIi arnpIes,SampIeType)="fieId sample") AND ((Samples.Matrix)="soil") AND
((Samples,Sub_Matrix) Like "*soil*") AND ((Analysis.AnalysisLabQCType)="not qa"));
-------
Appendix E
Data Quality Assessment
-------
Appendix E
Data Quality Assessment
1 Audits
1.1 Field Audits
1.2 Laboratory Audits
. 1
. 1
. 2
. 2
. 2
. 3
. 4
. 6
. 9
. 9
. 9
10
11
13
16
2 Modifications
3 Data Verification
4 Quality Control Sample Summary
4.1 Field QC Samples
4.2 Soil Preparation Laboratory QC Samples
4.3 QC Conclusions
5 Data Adequacy Evaluation
5.1 Moto-X Park ABS Samples
5.2 Recreational Visitor ABS Samples
5.3 Indoor Worker ABS Samples
5.4 Outdoor Worker ABS Samples
6 DQA Conclusions
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).
For the purposes of the risk assessment, the principle datasets utilized to quantify potential
exposures are the air samples collected during the various activity-based sampling (ABS)
programs at the OU5 Site. In addition, soil data (both visible vermiculite inspection results and
polarized light microscopy visual area estimation [PLM-VE] results) are utilized in the
interpretation of the outdoor worker ABS results. Therefore, this DQA focuses on the ABS air
samples and the site-wide soil samples used to support the OU5 risk assessment.
1 Audits
1.1 Field Audits
Field audits are conducted to evaluate field personnel in their day-to-day activities and ensure
all processes and procedures are performed in accord with the applicable field guidance
documents (or approved Libby Field Office [LFO] modification forms) to make certain that
samples collected are correct and consistent. All aspects of data documentation and sample
collection, as well as sample handling, custody, and shipping are evaluated. If any issues are
identified, field personnel are notified and retrained as appropriate.
A field audit was performed on September 17, 2008, to evaluate field procedures for air samples
collected as part of the MotoX Park and Recreational Visitor ABS programs. The auditor
concluded that the field personnel were very effective and efficient at implementing sampling
and reporting ABS program requirements and commended the field personnel and staff for their
1
Appendix E Data Quality Assessment
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efforts in maintaining an effective field program and their persistent focus on detail and quality
(Updike 2009).
1.2 Laboratory Audits
Laboratory audits are conducted to evaluate laboratory personnel to ensure that samples are
handled and analyzed in accord with the program-specific documents and analytical method
requirements (or approved Libby laboratory modification forms) to make certain that analytical
results reported are correct and consistent. All aspects of sample handling, preparation, and
analysis are evaluated. If any issues are identified, laboratory personnel are notified and
retrained as appropriate.
A series of laboratory audits was performed in the Summer/Fall of 2008 to evaluate all of the
Libby laboratories. No critical deficiencies were noted during the laboratory audits that would be
expected to impact data quality.
2 Modifications
During any large-scale sampling program, such as the OU5 ABS programs, deviations from the
original Sampling and Analysis Plan (SAP) may occur and/or it may be necessary to modify
procedures identified in the original SAP to optimize sample collection and analysis. At the
Libby Site, all field and laboratory modifications are recorded in site-specific modification forms.
These forms provide a standardized format for tracking procedural changes in sample collection
and analysis and allow project managers to assess potential impacts on the quality of the data
being collected.
During the OU5 programs, a number of field and laboratory modifications were created that
document changes in sample collection and analysis methodology specified in the original
SAPs. Table E-1 summarizes the modifications that are applicable to the various programs at
the OU5 Site, and notes the impact of each on the quality and usability of the data. As
indicated, most of the modifications are not expected to have an impact on data quality or
usability. Modifications which may have influenced the achieved analytical sensitivities could
have potential impacts on data quality and interpretation. These potential impacts are
discussed in more detail in Section 1.5, the data adequacy evaluation.
3 Data Verification
The Libby Site project database has a number of built-in quality control checks to identify
unexpected or unallowable data values during the upload of any new data into the database.
Any issues identified by these automatic upload checks were resolved by consultation with the
field teams and/or analytical laboratories before entry of the data into the database. After entry
of the data into the database, several additional data verification steps were taken to ensure the
data were recorded and entered correctly.
In order to ensure that the database accurately reflects the original hard copy documentation, all
data downloaded from the database were examined to identify data omissions, unexpected
2
Appendix E Data Quality Assessment
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values, or apparent inconsistencies. In addition, 10% of all samples and analytical results
underwent a detailed verification. In brief, verification involves comparing the data for a sample
in the database to information on the original hard copy field sample data sheet (FSDS) form
and on the original hard copy analytical bench sheets for that sample. Any omissions or
apparent errors identified during the verification were submitted to the field teams and/or
analytical laboratories for resolution and rectification in the project database and in the hard
copy documentation.
FSDS Review. Hard copy FSDS forms were reviewed for a total of 42 ABS air samples as part
of the data verification effort. While a few minor typographical errors were noted, no critical
errors (i.e., errors that would influence the quantitative analytical results reported for the sample)
were identified during this verification effort.
TEM Review. A total of 42 transmission electron microscopy (TEM) analyses were reviewed as
part of the data verification effort. Attachment 1 presents a summary of the findings of the TEM
data verification for the OU5 Site. In general, the majority of issues identified were due to the
incorrect transfer of data from the hard copy report to the EDD (e.g., structure lengths were
rounded, photo reference numbers were incorrect). However, it is important to note that none of
the errors identified were critical in nature (i.e., critical errors are those that would influence the
quantitative results).
PLM Review. A total of 108 PLM analyses were reviewed as part of the data verification effort.
Attachment 2 presents a summary of the findings of the PLM data verification for the OU5 Site.
The data verification identified critical errors in the reported PLM-VE bin for two soil samples
(error rate of -2%). Results for these samples have been corrected. There were also several
findings that involve the incorrect transfer of data from the hard copy report to the EDD;
however, none of these errors were critical in nature. While the critical error rate was low, future
data verification of additional PLM results may be warranted.
All issues identified during the data verification effort were submitted to the field teams and/or
analytical laboratories for resolution and rectification. All tables, figures, and appendices
generated for this report reflect corrected data.
4 Quality Control Sample Summary
A number of Quality Control (QC) samples were collected as part of the ABS programs to help
characterize the accuracy and precision of the data obtained. QC samples included both field-
based samples (which are submitted blind to the laboratories) and laboratory-based samples.
Appendix E Data Quality Assessment
3
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4.1 Field QC Samples
4.1.1 Air and Dust
Lot Blanks
A lot blank is a filter cassette which has been taken from a new box of filter cassettes. Lot
blanks are collected to ensure that sample filter cassettes do not have any asbestos
contamination prior to their use in the field. If any asbestos structures are observed on the lot
blank during the TEM analysis, the entire box of filter cassettes associated with that lot is
discarded.
In accord with the OU5 ABS SAPs, one lot blank was submitted for every 500 air filter cassettes
and every 300 dust filter cassettes. A total of 14 lot blanks were analyzed during the time of the
OU5 ABS programs (i.e., October 2007 to October 2008). No asbestos structures were
observed in any lot blank sample. Based on these results, it is concluded that air and dust filter
cassettes utilized during the various OU5 ABS programs did not have asbestos contamination.
Field Blanks
A field blank is a filter cassette that is taken to the field and opened, but through which no air is
drawn. Field blank samples for air are prepared for TEM analysis using a direct preparation,
while field blank samples for dust are prepared using an indirect preparation.
In accord with the OU5 ABS SAPs, field blanks for air and dust were collected at a rate of one
per property per day. Approximately 10% of the total field blanks collected per week were
analyzed by TEM. The field blanks selected for analysis ranged across the duration of the OU5
ABS programs.
A total of 22 air field blanks and 8 dust field blanks were collected during the time of the OU5
ABS programs (i.e., October 2007 to October 2008) and analyzed by TEM. No asbestos
structures were observed in any of the analyzed field blank samples. This demonstrates that
filter contamination due from either field or laboratory sources is not expected to influence
asbestos results for samples collected as part of the OU5 ABS programs.
Field Duplicates/Replicates
A field duplicate or replicate is a second sample of air or dust which is collected at the same
time and location as the original field sample. These samples are collected independent of the
original field sample with separate sampling equipment. Field duplicates or replicates help to
evaluate the inherent variability of sample results due to small-scale variability in concentration
as well as variability in sample analysis.
A total of 3 air field replicates and 2 dust field duplicates were collected as part of the OU5 ABS
programs. Table E-2 summarizes the detailed TEM results for all field duplicate/replicate
samples collected. The total Libby amphibole (LA) asbestos concentration estimates derived
4
Appendix E Data Quality Assessment
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from the original and duplicate/replicate samples are compared using the method for
comparison of two Poisson rates described by Nelson (1982). As seen, in most cases, both the
original and the duplicate/replicate results were non-detect (i.e., not statistically different from
each other). For the one dust sample where LA structures were observed, the difference
between the original and the dust duplicate results were not statistically different. Based on this,
it is concluded that air and dust sample results are reproducible, at least within the target
analytical sensitivity.
4.1.2 Soil
Field Duplicates
A field duplicate for soil is an independent sample of soil collected at the same place and at the
same time as the primary sample. Field duplicates for soil were collected at a rate of about 1
field duplicate per 20 field samples in accordance with the frequencies specified in the Outdoor
Worker ABS SAP (EPA 2008b), resulting in 37 field duplicates (out of 744 field samples).
Field duplicate results analyzed by PLM are ranked as concordant if both the original sample
result and the field duplicate result report the same semi-quantitative bin classification. Results
are ranked as weakly discordant if the original sample result and the field duplicate result
differed by one semi-quantitative bin classification (e.g., Bin A vs. Bin B1). Results are ranked
as strongly discordant if the original sample result and the field duplicate result differed by more
than one semi-quantitative bin classification (e.g., Bin A vs. Bin B2). Results are evaluated
based on the frequency of strongly discordant results, using the criteria contained in the table
below.
Metric
Good
Acceptable
Poor
% of pairs ranked as
strongly discordant
<5%
5-10%
>10%
Table E-3 summarizes the results of the original and field duplicate samples for soil. As seen,
most samples (35 out of 37) were ranked as non-detect in both the original sample result and
the field duplicate result. For the two sample pairs that were ranked as discordant, the results
were only weakly discordant. This discordance may be due to analytical variability, but might
also arise from authentic heterogeneity between the soil samples. No sample pairs were
ranked as strongly discordant.
These results support the conclusion that estimates of soil concentration by PLM are generally
reproducible, and are not greatly influenced by potential differences in field collection methods,
small-scale spatial variability, or laboratory preparation and analysis techniques.
Appendix E Data Quality Assessment
5
-------
4.2 Soil Preparation Laboratory QC Samples
4.2.1 Preparation Blanks
A preparation blank consists of asbestos-free quartz sand which is processed with each batch
of soil samples. A batch of samples is defined as a group of samples that have been prepared
together for analysis at the same time. Preparation blanks determine if cross-contamination is
occurring during sample preparation processing (i.e., drying, sieving, grinding, and splitting).
A total of 119 preparation blanks were analyzed by PLM-VE during the time of the OU5 ABS
programs. No asbestos was detected in any blank sample. Based on these results, it is
concluded that preparation methods at the soil preparation laboratory were unlikely to introduce
l_A contamination that would result in a quantifiable impact on soil results analyzed by PLM-VE.
4.2.2 Preparation Splits
Preparation splits are splits of field samples submitted for soil sample preparation. After drying
but prior to sieving, the original field sample is split into two equal aliquots using the Jones
splitter. One preparation split is included for every 20 field samples prepared. Comparison of
the results for preparation split with the paired original field samples helps to evaluate the
variability that arises during the preparation and analysis steps. Concordance between the
preparation split analysis and the original analysis is evaluated using a methodology similar to
that described above for field duplicates.
Table E-4 summarizes the PLM-VE results of the original and preparation split samples for soil.
As seen, all samples (42 out of 42) were ranked as non-detect (Bin A) in both the original
sample result and the preparation split result. These results support the conclusion that the soil
sample results are generally reproducible and reliable and are not greatly influenced by
differences in laboratory preparation and analysis techniques.
4.2.3 Performance Evaluation Samples
A performance evaluation (PE) sample is a soil sample with a known level of LA that is provided
blind to the laboratories for the purposes of evaluating analytical accuracy. PE samples of LA
were created as part of the PE Study (EPA 2000; 2003a,b) by spiking uncontaminated soil from
Libby with a known amount of asbestos material derived from the mine in Libby. PE samples
are inserted into the soil sample train by the soil preparation laboratory at the time of sample
preparation.
To date, a total of 34 PE samples have been submitted to the PLM-VE analytical laboratories for
analysis. In order to avoid "unblinding" the nominal levels in the PE samples to the analytical
laboratories, detailed results tables are not presented in this report. In general, the PLM-VE
results provided by the analytical laboratory for all PE samples were fairly consistent with the
expected result based on the nominal level. When results were discordant, the laboratories
tended to overestimate LA levels in soil compared to nominal levels. These results support the
conclusion that the PLM-VE results generally tend to be accurate and reliable.
6
Appendix E Data Quality Assessment
-------
4.3 Analytical Laboratory QC Samples
4.3.1 TEM Analytical Laboratory QC
Laboratory Blanks
A laboratory blank for TEM is a grid that is prepared from a new, un-used filter by the laboratory
and is analyzed using the same procedure as used for field samples. The purpose of the
laboratory blank is to determine if there are any significant sources of contamination arising
during sample preparation or analysis in the laboratory. As specified in Libby Laboratory
Modification #LB-000029B, laboratory blanks are to be analyzed at a frequency of 4%.
A total of 97 TEM laboratory blanks were analyzed by TEM during the time of the OU5 ABS
programs (i.e., October 2007 to October 2008). No asbestos structures were observed in any
laboratory blank sample. Based on these results, it is concluded that sample preparation and
analysis procedures utilized within the analytical laboratories did not introduce asbestos
contamination.
Recounts
A recount analysis is a re-examination of the original TEM grid openings to verify observed
structure counts and characteristics. The following types of recount analyses were performed
by each of the participating analytical laboratories during TEM analysis of ABS samples:
Recount Same (RS) - This is a TEM grid that is re-examined (same grid openings) by
the same microscopist who performed the initial examination.
Recount Different (RD) - This is a TEM grid that is re-examined (same grid openings) by
a different microscopist than who performed the initial examination.
Verified Analysis (VA) - This is a recount of a TEM grid (same grid openings) performed
in accord with the protocol for verified analysis as provided in NIST (1994).
Recount analyses were compared with the original analysis on a grid opening-by-grid opening
and structure-by-structure basis. Only those grid openings that were able to be re-examined
during the recount analysis were included in this evaluation. The degree of agreement
(concordance) between the original analysis and the recount analysis was evaluated based on
the total number of countable l_A structures observed for each grid opening that was re-
examined. Specific concordance criteria are detailed in Libby Laboratory Modification #LB-
000029B.
A total of 11 Recount Same, 11 Recount Different, and 12 Verified Analysis have been
performed as part of the OU5 ABS programs. For these analyses, a total of 342 grid openings
have been re-examined as part of a recount analysis. Table E-5 summarizes concordance
results for each grid opening that was re-examined. In this table, results that are concordant
(i.e., the LA structure count reported for the grid opening in the original analysis matches the
7
Appendix E Data Quality Assessment
-------
count reported in the recount analysis) are shaded in grey. As seen, concordance rates were
good (100% agreement in total LA counts). These results show that l_A structure counts by
TEM are generally reproducible and that differences between TEM analysts are generally small
and are not expected to influence the usability and interpretation of the ABS results.
Repreparations
A repreparation by TEM is a grid that is prepared from a new portion of the same field sample
filter as was used to prepare the original grid. Repreparation analyses are compared to the
original analysis based on the Poisson rate ratio method recommended by Nelson (1982).
Repreparations were prepared for 5 air samples as part of the OU5 ABS programs. Table E-6
summarizes the results of both the original analysis and the repreparation analysis. As seen,
the total l_A levels reported in the repreparation analysis were not statistically different from the
original analysis for all samples. These results show that l_A results are reproducible and that
TEM analytical precision is not likely to be impacted by preparation methods.
4.3.2 PLM A nalytical Laboratory Q C
Laboratory Duplicates
For PLM-VE, a laboratory duplicate is a re-preparation of a soil sample slide by a different
analyst (but within the same laboratory) than who performed the original analysis. Concordance
between the laboratory duplicate analysis and the original analysis is evaluated using a
methodology similar to that described above for field duplicates.
Table E-7 summarizes the original and laboratory duplicate results for PLM-VE. As seen, in all
instances, both the original sample result and the laboratory duplicate result were ranked as
concordant. These results support the conclusion that the soil sample results for PLM-VE are
reproducible and reliable and are not greatly influenced by differences in laboratory analysis
techniques between analysts.
Interlab Samples
For PLM-VE, an interlab analysis is performed by re-analysis of an independent aliquot of the
original soil sample by an analyst from a different laboratory than who performed the initial
analysis. The interlab analysis is blind to the interlab (i.e., the interlab cannot distinguish the
interlab sample from other field samples on the field chain of custody form). Concordance
between the interlab analysis and the original analysis is evaluated using a methodology similar
to that described above for field duplicates.
Table E-8 summarizes the original and interlab results for samples collected as part of the OU5
ABS program. As seen, 23 out of 27 samples were concordant and 2 of 27 were weakly
discordant, no samples were ranked as strongly discordant. These weak discordances may be
due to analytical variability, or might arise from authentic small scale heterogeneity between soil
aliquots drawn from the same sample bottle. These results support the conclusion that the soil
8
Appendix E Data Quality Assessment
-------
sample results for PLM-VE are reproducible and reliable and are not greatly influenced by
differences in analysis techniques across laboratories.
4.4 QC Conclusions
Based on the results of the QC evaluation, it is concluded that:
ฆ Inadvertent contamination of air, dust, and soil field samples with LA is not of significant
concern, either in the field or the laboratory.
ฆ TEM precision is generally good, as indicated by high agreement rates between field
samples and field replicates/duplicates, between original and re-pre pa rati on analyses,
and between original and recount analyses (i.e., samples where the same grid openings
are evaluated twice).
ฆ PLM-VE precision is generally good, as indicated by high concordance rates between
field samples and matched field duplicates, preparation splits, laboratory duplicates, and
interlab samples.
ฆ PLM-VE accuracy is also generally good, as indicated by the concordance rates when
analyzing PE samples. When results were discordant, the laboratories tended to
overestimate LA levels in soil compared to nominal levels (i.e., results were biased high).
5 Data Adequacy Evaluation
The following sections present a data adequacy evaluation to determine if available ABS air and
soil data for OU5 are sufficient to allow risk managers to make informed decisions about
potential risks to human health. This evaluation includes a comparison of the data collected
with the specified data quality objectives (DQOs) stated in the respective ABS SAPs.
5.1 Moto-X Park ABS Samples
5.1.1 Sample Representativeness
The goal of the Moto-X Park ABS program (EPA 2008a) was to collect data which provide a
reasonable representation of activities at the Moto-X Park that may result in exposures to LA in
air. All ABS samples were collected from the Moto-X track during activities consistent with site
use (e.g., during motorcycle use). Samples were collected in mid-September, during the part of
the year when riding activities are expected to occur and when soil conditions are driest. Based
on this, the Moto-X ABS data collected are deemed to be representative.
5.1.2 Sample Completeness
Completeness is defined as the fraction of samples that were planned that were successfully
collected and analyzed. The Moto-X ABS SAP (EPA 2008a) recommended the collection of 24-
32 personal air samples (6-8 individuals, 2 rides per person, on 2 different days) to characterize
9
Appendix E Data Quality Assessment
-------
rider exposures and 10 stationary air samples to characterize spectator exposures. The Moto-X
ABS program collected and analyzed 24 personal air samples and 10 stationary air samples.
The Moto-X ABS SAP also recommended the collection of a 30-point composite soil sample
from the Moto-X track for analysis by PLM-VE. A single 30-point composite soil sample was
collected from the Moto-X track at the time of the ABS sampling. At the time of collection, the
field teams recorded estimated visual vermiculite levels at each sampling point. This sample
was also analyzed by PLM-VE.
Thus, all air and soil samples specified in the SAP were successfully collected and analyzed
(i.e., 100% completeness).
5.1.3 A nalytical Sensitivity
As specified in the Moto-X ABS SAP (EPA 2008a), the target analytical sensitivity was 0.01 cc"1
for personal air monitors and 0.001 cc"1 for stationary air monitors. All personal air samples and
most stationary air samples achieved the target analytical sensitivity. Three of the 10 stationary
air samples achieved sensitivities slightly higher than the target, with values ranging from
0.0013 to 0.0015 cc"1. The consequence of this is that the concentration estimates for these
samples have somewhat higher uncertainty than would have been achieved if the samples had
been analyzed until the analytical sensitivity was achieved. However, it is not expected that this
leads to any bias in the data, so the overall impact on data quality is not expected to be
significant.
5.2 Recreational Visitor ABS Samples
5.2.1 Sample Representativeness
The goal of the Recreational Visitor ABS program (EPA 2008c) was to collect data which
provide a reasonable representation of recreational activities at the OU5 Site that may result in
exposures to LA in air. All ABS air samples were collected from the recreational path along
Libby Creek during activities consistent with site use (e.g., bicycle use). Sampling was
conducted across the entirety of the recreational path, including both paved and unpaved
sections. Samples were collected in mid-September, during the part of the year when
recreational activities are expected to occur and when soil conditions are driest. Based on this,
the Recreational Visitor ABS data collected are deemed to be representative.
5.2.2 Sample Completeness
The Recreational Visitor ABS SAP (EPA 2008c) recommended a minimum of 24 ABS air
samples from each portion of the path (paved and unpaved) to represent adult exposures (3
individuals, 2 rides per day, 4 separate days). In addition, the SAP recommended the collection
of 8 trailer ABS air samples from the paved path to represent child exposures (1 sample per
ride, 2 rides per day, 4 separate days).
Appendix E Data Quality Assessment
10
-------
The Recreational Visitor ABS program collected and analyzed 21 personal air samples from
each portion of the path (paved and unpaved) and 7 trailer air. Although the number of samples
was slightly lower than the specified targets, because the underlying variability in these ABS air
samples was generally small and concentrations were well below decision thresholds (see
Section 7, Human Health Risk Assessment, of the OU5 Remedial Investigation Report), the
number of ABS air samples collected is deemed adequate to support decision making.
5.2.3 A nalytical Sensitivity
As specified in the Recreational Visitor ABS SAP (EPA 2008c), the target analytical sensitivity
for all personal air samples was 0.006 cc"1. All ABS air samples achieved the target analytical
sensitivity (most samples achieved a lower sensitivity of 0.001 cc"1).
5.3 Indoor Worker ABS Samples
5.3.1 Sample Representativeness
The goal of the Indoor Worker ABS program (EPA 2007) was to collect data which provide
information on worker exposures inside buildings at the OU5 Site to determine if cleanup
actions taken to date have reduced LA contamination to a level that is health-protective. For
occupied OU5 buildings, ABS air samples were collected under disturbance scenarios that were
representative of worker activities (both active and passive behavior conditions). For vacant
OU5 buildings, ABS air samples were representative of a high-end disturbance scenario
(following disturbance with a leaf-blower). Although it is likely that indoor air concentrations may
vary over time, the focus of the ABS program was to estimate conservative (high-end) levels, so
repeated sampling over time was not deemed necessary (EPA 2007).
5.3.2 Sample Completeness
The Indoor Worker ABS SAP (EPA 2007) recommended the collection of 5 stationary air
samples from vacant buildings and a single 2-hour personal air sample for each disturbance
scenario (active and passive behaviors) from occupied buildings. All buildings that were
deemed "habitable" (i.e., having four exterior walls, a roof, and a floor that was not soil) were to
be sampled.
A total of 20 buildings (13 vacant buildings and 7 occupied) were deemed "habitable" at the time
of the ABS investigation (November/December 2007). Since this time, 2 vacant buildings
originally sampled have either burned (plywood plant) or been demolished (log yard pump
house). In addition, one vacant building (boundary injection building) that was originally within
the OU5 boundary is outside the current boundary of OU5. For the remaining vacant buildings,
a total of 50 stationary air samples (5 samples from each of 10 buildings1). For the occupied
buildings, a total of 29 ABS samples were collected during active behaviors and 9 ABS samples
were collected during passive behaviors. The number of active behavior samples collected is
higher than expected because the 2-hour time interval was split across multiple samples (e.g.,
1 One vacant building - the finger jointer processing plant - was not sampled.
11
Appendix E Data Quality Assessment
-------
collected at 30-minute or 60-minute intervals) to reduce the potential for particulate overloading
on the filters. The number of passive behavior samples collected is higher than expected
because activities conducted in the CDM office were separated into upstairs and downstairs.
Thus, with the exception of the finger jointer processing plant, all ABS air samples specified in
the SAP were successfully collected and analyzed. Depending upon the future use of the finger
jointer processing plant, measured ABS data may be needed for this building to inform risk
management decisions.
5.3.3 A nalytical Sensitivity
As specified in the Indoor Worker ABS SAP (EPA 2007), the target analytical sensitivity for all
Indoor ABS air samples was 0.0005 cc"1. All passive personal ABS air samples from occupied
buildings achieved the target analytical sensitivity. For active personal ABS air samples,
because multiple samples were collected across the 2-hour activity duration from each building,
the adequacy of the achieved analytical sensitivity for these samples was evaluated based on
the "pooled" sensitivity across samples, which was calculated as:
Pooled Sensitivity (cc"1) = 1/3 TAEj (cc)
where:
TAEi = Total amount of volume evaluated in sample analysis 'i' (cc). The TAEi is equal
to 1/sensitivity in analysis 'i'.
The pooled sensitivity across active ABS samples did not achieve the target sensitivity for 4 of
the 8 occupied buildings. In addition, one or more stationary ABS air samples collected from 4
of the 10 vacant buildings also did not achieve the target sensitivity. When the target analytical
sensitivity was not achieved, it was due to high particulate overloading on the filter which
required indirect preparation, and high dilutions were typically necessary to achieve optimal grid
loading (i.e., f-factors tended to be small). Thus, in most cases, the analysis was stopped
because the maximum grid opening stopping rule was reached (i.e., 100 grid openings were
evaluated).
As noted previously, the consequence of not achieving the target analytical sensitivity is that the
air concentration estimates for these samples have somewhat higher uncertainty than if the
samples had achieved the target analytical sensitivity. However, it is not expected that this
leads to any bias in the data. Estimated risks to indoor workers were within EPA's acceptable
risk range despite the elevated analytical sensitivities (see Section 7, Human Health Risk
Assessment, of the OU5 Remedial Investigation Report). Thus, the available ABS air samples
are deemed to be adequate to support decision making.
Appendix E Data Quality Assessment
12
-------
5.4 Outdoor Worker ABS Samples
5.4.1 Sample Representativeness
The goal of the Outdoor Worker ABS program (EPA 2008b) was to collect data which provide a
reasonable representation of outdoor worker exposures during soil disturbance activities.
Because it is not feasible to conduct outdoor ABS sampling on every acre of the OU5 Site, ABS
was performed at eight 1-1.5 acre areas. These eight ABS areas were selected based on
previous visible vermiculite sampling results to represent the range of expected soil
contamination conditions at the OU5 Site, with Area 1 representing the low end of the soil range
and Area 8 representing the high end of the range. At each ABS area, personal air samples
were collected to represent two activities - raking and operating heavy machinery - which are
considered to be general examples of relatively vigorous soil disturbances that may occur at the
OU5 Site. Although it is likely that outdoor air concentrations may vary over time, the focus of
the ABS program was to estimate conservative (high-end) levels during a time period when LA-
releasability from soil was likely to be highest (i.e., during summer/fall) (EPA 2008b).
5.4.2 Sample Completeness
The Outdoor Worker ABS SAP (EPA 2008b) recommended the collection of a minimum of 4
personal air samples per ABS area (4 samples x 8 areas = 32 samples). As part of the
Outdoor Worker ABS program, two workers wore personal air monitors while performing
scripted raking and bobcat operation activities at each ABS area during 3 separate sampling
events (2 workers x 8 areas x 3 events = 48 samples). A total of 6 ABS air samples per ABS
area were collected and successfully analyzed (i.e., >100% completeness).
The Outdoor Worker ABS SAP also recommended the collection of a 30-point composite soil
sample and 30 individual grab samples from each ABS area during each event for analysis by
PLM-VE. All soil samples were successfully collected and visual vermiculite estimates were
recorded for three 30-point composite samples (1 composite per event) and three sets of 30
grab samples (1 set of 30 grabs per event). Based on the preliminary PLM-VE results from
Round 1, nearly all samples at all ABS areas were non-detect. Therefore, EPA decided to
suspend the PLM-VE analysis of soil samples collected in Round 2 and 3 (see LFO-000141 for
documentation of the suspension of analysis). A total of 16/24 composite samples (67%) and
445/720 grab samples (62%) were analyzed by PLM-VE. Visible vermiculite estimates were
recorded for all soil sampling points during each event (100% completeness). Although only
about % of the samples were analyzed by PLM-VE, comparisons of PLM-VE results to visible
vermiculite estimates from other ABS programs suggest that visible vermiculite inspection
results may be a somewhat more sensitive method for detecting contamination in soil than PLM-
VE analysis of 30-point composite sample (EPA 2010). Therefore, the fact that not all soil
samples were analyzed by PLM-VE is not deemed to be an important data limitation.
5.4.3 A nalytical Sensitivity
As specified in the Outdoor Worker ABS SAP (EPA 2008b), the target analytical sensitivity for
all outdoor worker ABS air samples was 0.001 cc"1. The target analytical sensitivity was not
13
Appendix E Data Quality Assessment
-------
achieved in 30 of 48 ABS air samples. As noted previously, the consequence of not achieving
the target analytical sensitivity is that the air concentration estimates for these samples will have
a higher degree of uncertainty. However, despite the fact that the target analytical sensitivity
was not achieved for all individual samples, it is still possible for risk managers to make
informed decisions for outdoor worker exposures. This is because the exposure point
concentrations for outdoor workers used in the risk assessment are based on the average
across ABS samples evaluating non-detects at zero. This approach yields an unbiased
estimate of the true mean that does not depend on the analytical sensitivity of the samples
included in the data set. Estimated risks to outdoor workers were within EPA's acceptable risk
range despite the elevated analytical sensitivities (see Section 7, Human Health Risk
Assessment, of the OU5 Remedial Investigation Report). Thus, the available ABS air samples
are deemed to be adequate to support decision making.
5.5 Site-wide Surface Soil Samples
As described in the risk assessment (Section 7 of the OU5 Remedial Investigation Report),
because it is not feasible to evaluate risks by conducting outdoor worker ABS sampling on every
acre of the OU5 Site, it is necessary to draw risk conclusions about areas that have not been
studied by ABS by assessing whether soil results from these areas are similar to the soil
contamination levels in the Outdoor Worker ABS areas. Therefore, available soil samples must
be representative of the entire OU5 Site and must have been sampled and analyzed using
appropriate methods.
Outside of the ABS efforts, there have been three major site-wide surface soil sampling
programs conducted at the OU5 Site. Each of these programs is described briefly below:
Contaminant Screening Study (October 2002): As part of the Contaminant Screening
Study (CSS), the OU5 Site was divided into seven sample collection areas based on
land use - Former Popping Plant, Railroad Spur, Lumber Yard, Log Storage Area,
Southwest Area, Former Champion Tree Nursery, and the Libby Groundwater
Superfund Site. A total of 103 surface soil samples (generally 5-point composites) were
collected from these areas in October 2002. All soil samples were analyzed by PLM-VE.
At the time of sample collection, the field teams recorded qualitative information on the
presence/absence of visible vermiculite for the soil sample in the field logbooks. Visible
vermiculite was not reported in any soil sample collected (CDM 2007a). Only 2 surface
soil samples had detectable levels of LA reported by PLM-VE - one sample from the
former tree nursery and one sample from the southwest area near the Luck E G Post &
Rail Company operations reported Bin B1 (trace) levels in soil.
OU5 Soil Data Gap Study, Part I (October 2007): In October 2007, a second site-wide
soil sampling program was conducted to address soil data gaps and further characterize
areas with LA soil contamination at the OU5 Site (CDM 2007b). Sampling efforts
focused on soil collection from the Libby Groundwater Superfund Site, the Former
Champion Tree Nursery, the banks of Libby Creek, the Stormwater Containment/Waste
Water Lagoon Area (an area which was not sampled during the CSS), and the
Southwest Area (where trace levels were noted in the CSS). A total of 180 surface soil
14
Appendix E Data Quality Assessment
-------
samples (30-point composites) were collected from these areas and analyzed by PLM-
VE. At the time of sample collection, the field teams recorded semi-quantitative visible
vermiculite estimates at each soil sampling point in accord with SOP CDM-LIBBY-06.
Detailed PLM-VE and visual vermiculite inspection results from this soil sampling
program are summarized in CDM (2008a) Sampling Summary Report - 2007
Investigations.
OU5 Soil Data Gap Study, Part II (June/July 2008): During the analysis of the 2007
soil data gap samples, an additional data gap was identified for areas that were only
sampled during the CSS in 2002 (CDM 2008b). Although CSS soil samples were
available from these areas, the samples were not representative of more current
collection protocols (i.e., samples were 5-point composite samples as opposed to 30-
point composites and visual vermiculite information was only qualitative as opposed to
semi-quantitative). Therefore, additional sampling was performed in June/July 2008 at
the Moto-X Park, the Lumber Yard, the Southwest Area, the Railroad Spur, and the Log
Storage Area. A total of 73 surface soil samples (30-point composites) were collected
from these areas and analyzed by PLM-VE. At the time of sample collection, the field
teams recorded semi-quantitative visible vermiculite estimates at each soil sampling
point in accord with SOP CDM-LIBBY-06.
Figures 5.4 and 5.5 in the Remedial Investigation Report illustrate the site-wide soil
contamination conditions at the OU5 Site based on PLM results and visual vermiculite
inspection results, respectively. In interpreting these figures, it is important to remember that
composite samples are representative of a larger area than the plotting point presented in the
map. As seen, PLM-VE results and/or visible vermiculite information for soil is available for
most of the OU5 Site. There are two general areas where soil data is not available:
Within the Stormwater Containment and Waste Water Lagoon Area, large portions of
this area were not sampled since they were forested areas and not expected to be used
commercially (CDM 2008a). Measured soil data may be needed from these forested
areas to characterize potential soil contamination depending upon the intended future
land use.
Within the Libby Superfund Groundwater Site, the Land Treatment Unit (LTU) cells were
not sampled in October 2007 due to ongoing remedial activities (CDM 2008a). The
Landfarm area was also not sampled in October 2007 because there was a concern that
the clean top layer of soil could be contaminated by impacted subsurface soils during
sampling (CDM 2008a). Subsurface soils from the Landfarm area were subsequently
sampled in October 2008. A total of 51 grab samples (12-15 inches) were collected and
analyzed by PLM-VE. All samples were reported as non-detect by PLM and visible
vermiculite was only observed in one sample. The LTUs and Landfarm area are being
remediated separately, as part of the Libby Superfund Groundwater Site.
Appendix E Data Quality Assessment
15
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6 DQA Conclusions
Taken together, these results indicate that air and soil data collected at the OU5 Site and
utilized in this risk assessment generally are of acceptable quality, adequate and representative,
and considered to be reliable and appropriate for use in the risk assessment.
REFERENCES
CDM. 2007a. Data Summary Report, Operable Unit 5 - Former Stimson Lumber Company,
Libby Asbestos Site, Libby, Montana. Prepared by CDM for U.S. Environmental Protection
Agency, Region 8. Final - October 16, 2007.
CDM. 2007b. Sampling and Analysis Plan Initial Soils Data Gap Sample Collection, Operable
Unit 5 - Former Stimson Lumber Mill Site, Libby Asbestos Site, Libby, Montana. Prepared by
CDM for U.S. Environmental Protection Agency, Region 8. Final - September 10, 2007.
CDM. 2008a. Sampling Summary Report - 2007 Investigations, Operable Unit 5 - Former
Stimson Lumber Mill Site, Libby Asbestos Site, Libby, Montana. Prepared by CDM for U.S.
Environmental Protection Agency, Region 8. Final - July 25, 2008.
CDM. 2008b. Sampling and Analysis Plan Addendum - Initial Soils Data Gap Sample Collection
and Visual Vermiculite Inspection, Operable Unit 5 - Former Stimson Lumber Mill Site, Libby
Asbestos Site, Libby, Montana. Prepared by CDM for U.S. Environmental Protection Agency,
Region 8. Final - June 13, 2008.
EPA. 2000. Project Plan for the Asbestos in Soil Performance Evaluation Study, Libby
Asbestos Site, Libby, Montana. Part A. Collection of Soil and Asbestos Materials. Prepared by
ISSI Consulting Group, Inc. for U.S. Environmental Protection Agency, Region 8. June 2, 2000.
EPA. 2003a. Quality Assurance Project Plan for the Asbestos in Soil Performance Evaluation
Study, Libby Asbestos Site, Libby, Montana. Part B (Revision 1). Prepared by Syracuse
Research Corporation for U.S. Environmental Protection Agency, Region 8. January 24, 2003.
EPA. 2003b. Quality Assurance Project Plan for the Asbestos in Soil Performance Evaluation
Study, Libby Asbestos Site, Libby, Montana. Part C (Revision 1). Round-Robin Analysis of
Performance Evaluation Samples. Prepared by Syracuse Research Corporation for U.S.
Environmental Protection Agency, Region 8. April, 2003.
EPA. 2006. Data Quality Assessment: A Reviewer's Guide. EPA QA/G-9R. U.S.
Environmental Protection Agency, Office of Environmental Information. EPA/240/B-06/002.
February, http://www.epa.qov/qualitv/qs-docs/q9r-final.pdf
EPA. 2007. Sampling and Analysis Plan, Building Data Gap Sample Collection, Operable Unit
5, Libby Asbestos Site. U.S. Environmental Protection Agency, Region 8. November 2, 2007.
16
Appendix E Data Quality Assessment
-------
EPA. 2008a. Sampling and Analysis Plan for the MotoX, Operable Unit 5, Libby Asbestos Site.
Final. U.S. Environmental Protection Agency, Region 8. August 19, 2008.
EPA. 2008b. Sampling and Analysis Plan for Outdoor Worker Exposures, Operable Unit 5,
Libby Asbestos Site. Final. U.S. Environmental Protection Agency, Region 8. September 8,
2008.
EPA. 2008c. Sampling and Analysis Plan for Recreational User Exposures, Operable Unit 5,
Libby Asbestos Site. Final. U.S. Environmental Protection Agency, Region 8. September 8,
2008.
EPA. 2010. Activity-Based Sampling Summary Report, Operable Unit 4, Libby, Montana,
Superfund Site. U.S. Environmental Protection Agency, Region 8. Final - June 2, 2010.
Nelson, W. 1982. Applied Life Data Analysis. John Wiley & Sons, New York, pp 438-446.
NIST. 1994. Airborne Asbestos Method: Standard Test method for Verified Analysis of
Asbestos by Transmission Electron Microscopy - Version 2.0. National Institute of Standards
and Technology, Washington DC. NISTIR 5351. March 1994.
Updike, Douglas. 2009. CDM Memorandum: Quality Assurance Field Audit Report - 2008
Activity-Based Sampling, Libby, Montana. April 10, 2009.
Appendix E Data Quality Assessment
17
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Table E-l. Impact Assessment for Field and Laboratory Modifications
Tvpe
Number
Effective Date
Description
Impact on Data Evaluation
LFO-000134
9/8/2008
Specifies TEM analysis stopping rules in the Moto-X ABS SAP in
terms of area examined rather than grid openings evaluated.
Modification will standardize stopping rules across laboratories that
may use grid openings of varying sizes.
None.
Field
Mods
LFO-000141
1/13/2009
Modifies the Moto-X ABS SAP and Outdoor Worker ABS SAP to
incorporate a phased approach for the PLM and fluidized bed
analysis of collected soil samples.
Although this modification reduces
the number of soil samples analyzed,
corresponding visual soil inspection
and ABS air data indicate that soil
contamination is fairly uniform and
may not support a quantiative
regression analysis.
LFO-000145
5/11/2009
Modifies the number and types of soil samples that will be analyzed
by the fluidized bed approach.
None.
LB-000076
11/12/2007
Analysis of the ABS air samples in lab job EMSL 270701088
(L13120) was terminated at 100 grid openings rather than terminating
at the target analytical sensitivity specified in the ABS SAP.
If 50 LA structures are recorded, then
there is no impact on data quality. If
counting is stopped at 100 GOs and
structure count is low (e.g., <10), then
Lab
Mods
LB-000081
11/26/2008
Analysis of the ABS air samples in lab job EMSL 040729249
(L13283) was terminated at 100 grid openings rather than terminating
at the target analytical sensitivity specified in the ABS SAP.
there will be increased uncertainty in
the estimates of concentration.
However, there is no introduction of
bias.
LB-000077
10/30/2007
ABS Field Blanks - 30 grid opening stopping rule for all air and dust
field blanks.
None.
LB-000086
4/22/2008
All samples analyzed by SRC-Libby-03 (PLM-VE) shall be referenced
by the use of a concatenation of the Index ID, Suffix ID, and the Suffix
# (e.g. 1D-00827-FG2).
None.
DQA tables frozen
Page 1 of 1
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Table E-2. Results of Air Field Replicates and Dust Field Duplicates Analyzed by TEM
Original Sample
Field
duplicate Sample
Media
Index ID
Analysis
Date
Lab Name
Analysis
Method
Prep
Method
EFA
Gox
GO
Size
F
Factor
Sens
NLA
Struc
LA Cone (s/cc) or
Loading (s/cm2)
Index ID
Analysis
Date
Lab Name
Analysis
Method
Prep
Method
EFA
Gox
GO
Size
F
Factor
Sens
N LA
Struc
LA Cone (s/cc) or
Loading (s/cm2)
Poisson Rate Comparison (95%CI)
Air
SL-00024
9/16/02
RESI
AHERA
DIRECT
385
4
0.011
0.0018
0
SL-00023
9/16/02
RESI
AHERA
DIRECT
385
4
0.011
0.0018
0
0
Both counts are 0; the rates are not different
SL-00024
9/16/02
RESI
ISO
DIRECT
385
10
0.011
0.0007
0
SL-00023
9/16/02
RESI
ISO
DIRECT
385
10
0.011
0.0007
0
0
Both counts are 0; the rates are not different
SL-00214
9/19/02
Mobile Lab
AHERA
DIRECT
385
4
0.0129
0.0034
0
SL-00213
9/19/02
Mobile Lab
AHERA
DIRECT
385
4
0.0129
0.0034
0
0
Both counts are 0; the rates are not different
SL-00214
10/2/02
Westmont
ISO
DIRECT
385
10
0.0064
0.0028
0
SL-00213
10/2/02
Westmont
ISO
DIRECT
385
10
0.0064
0.0028
0
0
Both counts are 0; the rates are not different
SL-00223
9/19/02
Mobile Lab
AHERA
DIRECT
385
4
0.0129
0.0025
0
SL-00222
9/19/02
Mobile Lab
AHERA
DIRECT
385
4
0.0129
0.0025
0
0
Both counts are 0; the rates are not different
SL-00223
10/2/02
Westmont
ISO
DIRECT
385
10
0.0064
0.0021
0
SL-00222
10/2/02
Westmont
ISO
DIRECT
385
10
0.0064
0.0020
Both counts are 0; the rates are not different
Dust
SL-70653
1/23/08
Hygeia
ISO
INDIRECT
346
5
0.01
0.15
46.1
0
SL-70655
1/23/08
Hygeia
ISO
INDIRECT
346
5
0.01
0.15
46.1
Both counts are 0; the rates are not different
SL-70497
12/28/07
RESI
ISO
INDIRECT
346
10
0.011
0.25
12.6
0
SL-70498
12/28/07
RESI
ISO
INDIRECT
346
10
0.011
0.5
6.3
1 6.3
[0-78] The rates are not different
-------
Table E-3. Evaluation of Field Duplicates Analyzed by PLM-VE
Field Duplicate Results
Bin A (ND)
BinBl (Tr)
BinB2 (<1%)
BinC(>l%)
Bin A (ND)
1
0
0
Original
Sample
Results
BinBl (Tr)
i
()
()
BinB2 (<1%)
0
o
()
Bin C (>1%)
0
0
0
0
Total Pairs
('iuia>rdaiil
Weakl\ 1 )isaiidaiil
SimiiuK 1 )isaii'danl
incl. ND
37
^ l')4h"n)
: (^4".,)
0 (()",,)
excl. ND
2
0 (()")
: i loo",,)
0 (U")
-------
Table E-4. Evaluation of Preparation Split Analyzed by PLM-VE
Preparation Split Results
Bin A (ND)
BinBl (Tr)
BinB2 (<1%)
BinC(>l%)
Original
Sample
Results
Bin A (ND)
0
0
0
BinBl (Tr)
0
()
()
BinB2 (<1%)
0
o
()
Bin C (>1%)
0
0
o
0
:
Total Pairs 42
Ciuia>Rlaiii 42 (1 ()()"
Weakl\ l)isan'daiil <>
SiiiinuK I)isciiidaiil ii (""ฆฆI
-------
Table E-5. Comparison of Number of
Countable LA Structures Recorded in the
Original Analysis and Recount Analysis
# of LA Structures
Recount Analysis Results
in Unique GO
0
1
2
3
0
326
0
0
0
Original
Analysis
Results
1
0
15
0
0
2
0
0
0
0
3
0
0
0
1
Total Pairs 342
Match 342 (100%)
Off by 1 Structure 0 (0%)
Off by >1 Structure 0 (0%)
-------
Table E-6. TEM Repreparation Results for Air
Analysis Details
Original Analysis Results
Repreparation Analysis Results
Index ID
Analysis
Method
Prep
Method
Analysisl
DSeqN
Lab Name
Analysis
Date
N LA
Struc
Sensitivity
Total LA
Cone/
Loadinq
Analysisl
DSeqN
Lab Name
Analysis
Date
N LA
Struc
Sensitivity
Total LA
Cone/
Loadinq
Poisson Rate Comparison (95% CI)
SL-00038
TEM-ISO10312
DIRECT
33027
RESI
9/16/2002
0
-
0.0E+00
33018
RESI
9/17/2002
0
-
0.0E+00
Both counts are 0; the rates are not different
SL-00159
TEM-ISO10312
DIRECT
33974
Hygeia
10/2/2002
0
1.4E-02
0.0E+00
34862
Hygeia
10/12/2002
0
1.4E-02
0.0E+00
Both counts are 0; the rates are not different
SL-00300
TEM-ISO10312
DIRECT
185204
Mobile Lab
11/3/2008
0
9.6E-04
0.0E+00
187175
Mobile Lab
12/1/2008
0
1.7E-03
0.0E+00
Both counts are 0; the rates are not different
SL-00399
TEM-ISO10312
DIRECT
182724
RESI
10/6/2008
0
9.1E-04
0.0E+00
182725
RESI
10/7/2008
1
8.8E-04
8.8E-04
[0-40.42] The rates are not different
SL-70787
TEM-ISO10312
DIRECT
179270
MAS
7/31/2008
0
5.0E-03
0.0E+00
179271
MAS
7/31/2008
0
4.9E-03
0.0E+00
Both counts are 0; the rates are not different
-------
Table E-7. Evaluation of Laboratory Duplicates Analyzed by PLM-VE
Cross-Check
Laboratory Duplicate Results
Bin A (ND)
BinBl (Tr)
BinB2 (<1%)
BinC(>l%)
Original
Sample
Results
Bin A (ND)
0
()
0
BinBl (Tr)
0
()
()
BinB2 (<1%)
0
()
()
Bin C (>1%)
0
I)
()
0
:
Total Pairs
(oncoi'daiil
Weakl\ 1 )isaiidaiil
SiiomuK 1 )isciiidaiil
Self-Check
incl. ND excl. ND
68 4
t.X (|()<>") 4 (]()()"..)
0 (U") 0 <<>")
Laboratory Duplicate Results
Bin A (ND)
BinBl (Tr)
BinB2 (<1%)
BinC(>l%)
Original
Sample
Results
Bin A (ND)
0
()
()
BinBl (Tr)
0
()
()
BinB2 (<1%)
0
o
()
Bin C (>1%)
0
0
()
0
.
incl. ND
Total Pairs 58
( oncoidaiil ^X 11()()")
Wcakl\ l)isan'daiil <> d)",,)
Strongly Discordant 0 (0%)
-------
Table E-8.
Comparison of Interlabs Analyzed by PLM-VE
Interlab Results
Bin A (ND)
BinBl (Tr)
BinB2 (<1%)
BinC(>l%)
Bin A (ND)
1
0
0
Original
Sample
Results
BinBl (Tr)
()
()
BinB2 (<1%)
i)
0
()
Bin C (>1%)
0
I)
o
0
:
Total Pairs
Ciuia>Rlaiii
Weakl\ 1 )isaiidaiil
SiiiinuK 1 )isciiidaiil
incl. ND
27
4 ( 14 X",,)
0 (U")
excl. ND
5
i (:o")
4 (S()"i
0 (U")
-------
TEM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
Date: April 20. 2010 Prepared by: Natalie Ross
Validation of OU5 ABS Samples
SUMMARY OF FINDINGS A NI) DATA QUALITY IMPLICATIONS
There were two findings that involve the incorrect transfer of data from the hardcopy report to the EDD. These
issues include one instance of a structure length incorrectly entered in the EDD and one instance where the photo
reference number was incorrect. There were two analyses that have duplicate entries in the database: a corrected
EDD was uploaded to the database but the original EDD was not removed. In one analysis, the structure lengths
were rounded up in the database and do not match the bench sheet. For example, the structure length written on the
bench sheet is 0.05 but is rounded up to 0.1 in the database. In each instance, the mineral class for the structures
was chrvsotile so it does not impact calculations based on LA structures.
There were two analyses where the analyst was inconsistent in recording complex structures on the bench sheet and
recorded dimensions of the entire matrix on the primary structure line. The primary structures were recorded on the
bench sheet but not transferred to the EDD: the secondary structures were correctly recorded on the bench sheet and
transferred to the EDD. In these cases, the laboratory should cross out the primary structure information (including
length, width, identification and mineral class) on the bench sheet and initial. These issues were previously
identified hv Anni Autio on 4/4/2010.
One analysis was not originally selected for validation, however, after a general review for consistency in the
database, there were two grid opening names that appeared to be incorrect so the analysis was selected for
validation. In addition to the grid opening name errors for this analysis, there was one instance where the mineral
class was unclear. It looks like a "1" is entered in the chrvsotile box on the bench sheet, but the EDD has this
structure identified as LA. The laboratory should verify the correct mineral class.
Recommendations for future review and verification:
The error rates in the validation were low and the issues found were not critical and did not impact the calculations
for LA structures. Therefore, future validation is not needed.
-------
TEM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
TEM-ISO 10312 SELECTION AND CONSISTENCY REVIEW RESULTS
Summary of available analyses for samples specified -
Analyst, Laboratory
Number of TEM-ISO 10312 Analyses
Number of Analyses Selected for Review
Detect
Non-Detect
Total
Detect
Non-Detect
Total
J. XU, Batta
7
7
14
2
1
3
K. Corbin, Hygeia
2
0
2
1
0
1
Q. Trieu, Hygeia
9
1
10
2
1
3
A. Keeton, MAS
3
6
9
1
1
2
K. Simpson, MAS
3
1
4
1
1
2
M. Motamedi, MAS
3
11
14
1
1
2
R. Mahoney, EMSL
7
46
53
2
4
6
R. Pescador, EMSL
13
59
72
3
5
8
A. Heitger, Resi
6
3
9
1
1
2
N. DelHierro, Resi
3
1
4
1
1
2
N. Zimbelman, Resi
26
36
62
6
3
9
G. Agnello, Westmont
2
1
3
1
1
2
Total
84
172
256
22
20
42
Goal Actual
Selected Total 26 42*
Selected Detects 13 22
Selected Non-Detects 13 20
*Note: Analysis SL-00397 was not included in the original selection but added after errors were found in the database
Detailed summary of bench sheet consistency review -
Number of analyses reviewed: 42 (10 % of total analyses selected)
Number of analyses with recording and data transfer issues identified: 8 (19% of total analyses reviewed)
Types of recording and data transfer 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)
1 Mineral class designation is missing or inconsistent
Structure comments are inconsistent with LB-000066
1 Structure comments are inconsistent with recorded data
4 Structure attributes in the database do not match the bench sheet
2 Duplicate entries in database
2 Incorrect grid opening name
-------
TEM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
Do the recording issues identified appear to be associated with a particular analyst or laboratory? Yes
If yes, identify the analyst and/or laboratory:
ISSUE RESOLUTION AND STATUS
Requested revisions for recording and data transfer issues were sent to Amy Christensen at ESAT on 4/20/2010. A
summary of the requested revisions can be found in Table 1 below.
Table 1. Requested Revisions for OU5 ABS Samples
Sample
ID
Unique
Grid
Opening
Laboratory
Name
Laboratory
Job
Number
SRC Comments
Database
Revision
EDD/Benchsheet
Revision
SL-00430
1 A2,
1 G7
Batta
CDM-152
Length, width, identification and
mineral class for GOs 1_A2 (MD11)
and 1_G7 (MD10) should be crossed
out and initialed for the primary
structures on benchsheet.
X
SL-00431
1 CIO
Batta
CDM-152
Length, width and identification for
GO 1_C10 (MD10) should be
crossed out and initialed for the
primary structures on benchsheet.
X
SL-70433
Multiple
MAS
M45425
In 11 GOs, the length has been
rounded in the database. For
example, GO CI Gl, the length
written on the benchsheet is 0.05 but
is rounded to 0.1 in the database.
The EDD needs to be reloaded into
the database.
X
X
SL-70361
2 E9
Mobile Lab
270701205
Photo should be #04440 not #0440 in
the EDD.
X
SL-70376
Multiple
Mobile Lab
270800036
Result information in the database is
duplicated; both the original
submitted EDD and the corrected
EDD from 4/1/09 are in the database.
X
SL-70561
Multiple
Mobile Lab
270800036
Result information in the database is
duplicated; both the original
submitted EDD and the corrected
EDD from 4/1/09 are in the database.
X
SL-00397
A A5-4
A A5-1
B B2-6
RESI
161814
GO name in database should be
A_A5-4 not A_39577
GO name in database should be
AA5-1 not A 39574
Mineral class for GO B B2-6 is
unclear, need laboratory to clarify. It
looks like a " 1" is entered in the
Chyrsotile box, but the EDD has this
structure identified as LA.
X
SL-70683
A F2-3
RESI
148479
Length should be 9 not 7 in the EDD.
X
-------
PLM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
Date: July 28.2010 Prepared by: Natalie Ross
SUMMARY OF FINDINGS A NI) DATA QUALITY IMPLICATIONS
The data verification identified errors in the reported PLM-YE bin for two soil samples. One analysis was not
originally selected for validation, however, after a review of an analysis from the same laboratory job it became
apparent that the results for the two samples were incorrectly entered in the EDD.
There were also several findings that involve the incorrect transfer of data from the hard copy report to the EDD.
These issues include transfer errors of the analyst name, analysis date and laboratory job number. In several
analyses, the laboratory inconsistently reported the Lab OA type on the bench sheet and recorded "LP" for both
"Not OA" and "LP" samples. The laboratory should verify the correct OA Type and make revisions on the bench
sheet.
Recommendations for future review and verification: The error rates in the validation were low and the issues
found were not critical. Therefore, future validation is not needed.
-------
PLM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
PLM SELECTION AND CONSISTENCY REVIEW RESULTS
Summary of available analyses for samples specified -
Analyst, Lab
Number of PLM Analyses
Number of Analyses Selected for Review
Detect
Non-Detect
(Bin A)
Total
Detect
Non-Detect
(Bin A)
Total
AK, Batta
0
71
71
0
4
4
JT, Batta
1
47
48
1
3
4
Douglas Kent, ESAT
5
9
14
4
1
5
Nikki McDonald, ESAT
21
20
41
18
1
19
Talena Oliver, ESAT
4
14
18
3
1
4
A. Casas, Hygeia
0
16
16
0
1
1
F. Guiierrez, Hygeia
0
1
1
0
1
1
G. Hernandez, Hygeia
2
130
133
2
7
9
H. Espinoza, Hygeia
0
1
1
0
1
1
Derrill Duncan, MAS
0
26
26
0
1
1
Kevin Simpson, MAS
0
11
11
0
1
1
PMHess, MAS
0
34
34
0
2
2
WB Egeland, MAS
0
62
62
0
3
3
Mobile Lab
5
17
22
4
1
5
LW, RESI
0
2
2
0
1
1
NRA, RESI
0
1
1
0
1
1
PDL, RESI
0
1
1
0
1
1
PFK, RESI
0
1
1
0
1
1
RSW, RESI
21
461
480
18
25
43
D. Beard, Westmont
0
1
2
0
1
1
Total
59
926
985
50
58
108
Goal Actual
Selected Total 99 108*
Selected Detects 50 50
Selected Non-Detects 50 58
*Note: Analysis SL-70071 was not included in the original selection but added after errors were found in another analysis
Detailed summary of bench sheet consistency review -
Number of analyses reviewed: 108 (10% of total analyses selected)
If not all analyses could be reviewed, provide a brief explanation for why: N/A
-------
PLM CONSISTENCY REVIEW AND DATA TRANSFER VERIFICATION REPORT
Number of analyses with recording and data transfer issues identified: 16 (15% of total analyses reviewed)
Types of recording issues identified (indicate the number of analyses):
7 Incorrect/missing information on analysis details (e.g., lab job number, analysis date)
Reported value does not use correct binning category.
Data Transfer issues identified:
7 Incorrect/missing information on analysis details (e.g., lab job number, analysis date)
2 Reported value does not use correct binning category.
Do the recording or data transfer issues identified appear to be associated with a particular analyst or laboratory?
Yes
If yes, identify the analyst and/or laboratory:
ISSUE RESOLUTION AND STATUS
A summary of the EDD/bench sheet revisions can be found in Table 1 below.
Table 1. Requested Revisions for OU5 ABS Samples
Sample
ID
Laboratory Name
Laboratory
Job Number
SRC Notes
2R-05230
2R-05282
Mobile Lab
270900114
Analyst name written on the bench sheet but not entered in the EDD
2R-05283
1-09011
1-09013
Mobile Lab
270900476
Analyst name written on the bench sheet but not entered in the EDD
CS-09300
Reservoirs Environmental Services
102783
QA Type on bench sheet does not match the EDD.
CS-09596
Reservoirs Environmental Services
102783
QA Type on bench sheet does not match the EDD.
CS-09705
Reservoirs Environmental Services
103573
Analysis date on bench sheet (4/10/2004) does not match the date in
the EDD (4/9/2004)
CS-18489
Reservoirs Environmental Services
105080
QA Type on bench sheet does not match the EDD.
CS-18583
Reservoirs Environmental Services
107324
QA Type on bench sheet does not match the EDD.
SL-70071
Reservoirs Environmental Services
146149
Reported value should be " 1" not "ND"
SL-70072
Reservoirs Environmental Services
146149
Reported value should be "ND" not "1"
SL-70295
Reservoirs Environmental Services
148239
QA Type on bench sheet does not match the EDD.
SL-70335
Reservoirs Environmental Services
149474
QA Type on bench sheet does not match the EDD.
SL-00634
Reservoirs Environmental Services
164190
QA Type on bench sheet does not match the EDD.
SL-70057
Westmont
40809060
Laboratory job number on bench sheet is written as both 04080960
and 040809060
-------
Appendix F
Supplemental Investigation Reports
-------
Appendix F1
Wood Chip ABS
-------
CDM .
ฆฆ ฆ
Smith
Memorandum
To: Rebecca Thomas, EPA Remedial Project Manager
From: Nick Raines, CDM Smith Project Manager
Date: January 9, 2012
Subject: OU5 Wood Chip Activity-base Sampling Summary
Background
Operable Unit 5 (OU5) of the Site, the former Stimson Lumber Mill site, is located in the
eastern portion of Libby. Historically, a variety of wood treatment and lumber milling processes
were performed at OU5. The majority of lumber production activities ceased in 2003. Several
wood chip piles from historical lumber processing activities were left at OU5. Wood chips from
these piles have been sold and given away for use as landscaping mulch in gardens, flowerbeds,
playgrounds, etc.
Results from previous sampling events indicate that Libby amphibole asbestos (LA) is present
within the wood chip material (CDM 2008). However, results based on this qualitative analysis
method do not provide information on whether or not disturbances of wood chips under typical
residential disturbance scenarios would result in unacceptable inhalation exposures.
In August 2011, the United States Environmental Protection Agency EPA and its contractors
conducted activity-based sampling (ABS) over a subset of the wood chip material. The primary
goal of this study was to answer the question:
"Do concentrations of LA in air within the breathing zone of individuals that disturb OU5-
derived wood chip materials exceed risk-based levels of concern?"
The data collected during this event will be used to estimate exposure and risk from LA due to
disturbances of wood chips derived from the OU5 wood chip piles, and to determine whether
response actions are needed to protect individuals from unacceptable risks.
Sample Collection Summary
ABS was completed in August 2011 in accordance with the 2011 Miscellaneous ABS Sampling
Analytical Plan (ABS SAP) (CDM 2011). Due to the potential variability in LA levels within the
wood chips, material was evaluated from five separate sub-locations and varied depths across
-------
0U5 Wood Chip Activity-based Sampling Summary
January 9, 2012
Page 2
the existing wood chip at OU5. Figure 1 indicates the approximate location of the five wood
chip material draws. To begin the event, approximately two cubic yards of wood chips were
collected from the five locations and transported to a neutral location on OU5, near the former
plywood plant. The wood chips were then spread out on plastic sheeting. The wood chips were
then allowed to dry for a minimum of 24 hours prior to the start of sampling activities. Soil
moisture readings were not collected as part of this event as the soil moisture meter was unable
to accurately read moistures within the wood chip material, as documented within a field
modification to the ABS SAP (CDM 2011). In addition, wood chip samples were collected during
dry and warm weather conditions in August.
A total of three ABS events were conducted over each of the five wood chip piles. At the start of
each event, one 30-point composite sample of wood chips was collected. The wood chips were
then shoveled into a pile near the center of the plastic sheeting.
Two ABS air samples (high volume primary and low volume backup) were then collected while
scripted activities were conducted over a one hour period. These activities were conducted in
accordance with Appendix A of the ABS SAP (CDM 2011) and included:
1. Spread the wood chips out using a long handled shovel - 10 minutes
2. Rake the wood chips out to approximately 10 feet by 10 feet by 6 inch deep - 20 minutes
3. While seated, dig with a trowel at 6 separate locations - 30 minutes (6 minutes at each
location)
After completing three events over each pile, the wood chip material was returned to the
approximate location where it was originally retrieved from.
Analytical Summary and Results
Wood chip ABS was completed August 30, 2011. Bulk material samples and air samples were
submitted for analysis as outlined in the ABS SAP.
Wood chip samples were prepared in accordance with Section 6.0 of Standard Operating
Procedure (SOP) DUFF-LIBBY-OU3. The resulting filters were analyzed for LA using
Transmission Electron Microscopy (TEM) in basic accordance with International Organization
for Standardization (ISO) ic>3i2:i995(E) (ISO 1995) protocols, except that the aspect ratio
criterion will be 3:1 to allow for the estimation of phase contrast microscopy - equivalent. In
addition, all project specific modifications were applied. Results for the wood chip samples are
presented in Table 1.
ABS air samples were analyzed for LA using TEM in basic accordance with ISO ic>3i2:i995(E)
(ISO 1995) and all applicable project-specific laboratory modifications. The analytical sensitivity
-------
0U5 Wood Chip Activity-based Sampling Summary
January 9, 2012
Page 3
was sufficient to support risk-based decisions based on the draft toxicity values for LA. Results
for the ABS air samples are presented in Table 2.
One bulk wood chip sample result indicated the presence of LA (1/15), while all other wood chip
samples were non-detect. All of the ABS air sample results were non-detect for LA (0/15). Based
on the wood chip ABS sampling data, disturbance of the wood chips did not result in detectable
fiber emissions from the material and thus the EPA determined there was no potential human
exposure to LA from the material. Without fibers being detected, risks were not estimated as
there was no exposure.
References
CDM. 2008. Final Sampling Summary Report 2007 Investigations Operable Unit 5 - Former
Stimson Lumber Company. July 25.
. 2011. Sampling and Analysis Plan 2011 Miscellaneous Activity-based Sampling, Revision 1.
September.
ISO. 1995. International Organization for Standardization Ambient Air. Determination of
asbestos fibres - Direct-transfer transmission electron microscopy method. ISO ic>3i2:i995(E).
http://www.iso.org/iso/catalogue detail.htm?csnumber=i83s8
-------
0U5 Wood Chip Activity-based Sampling Summary
January 9, 2012
Page 4
Table 1:
2011 OU4 MISCELLANEOUS ACTIVITY-BASED SAMPLING WOOD CHIP RESULTS
SCENARIO 3: OU5 WOOD CHIP DISTURBANCE ACTIVITIES
Wood Chip
Material
Draw
Event #
Sample
Mass
Ashed
Residue
Mass
EFA
GOs
GO Area
Ashed residue
mass [ g j,
aliquot used in
Resusp.
volume
Volume
applied to
Sensitivity
NLA
Structures
LA Cone.
Est. LA Cone.
Index ID
(g dw)
(g dw)
(mm2)
Conn led
(mm2)
dilution
(mL)
filter (mL)
F-factor
d/g)
Observed
(s/g dw)
(mass %)
1
EX-30201
12.68
0.11
1280
4
0.013
0.05
100
1
4.5E-03
4.3E+05
0
0.0E+00
0.0%
1
2
EX-30202
24.45
0.28
1280
4
0.013
0.15
100
0.8
4.3E-03
2.3E+05
1
2.3E+05
0.000012%
3
EX-30203
51.94
0.74
1280
4
0.013
0.25
100
0.5
1.7E-03
2.8E+05
0
0.0E+00
0.0%
1
EX-30209
35.52
0.5
1280
4
0.013
0.25
100
0.5
2.5E-03
2.8E+05
0
0.0E+00
0.0%
2
2
EX-30210
48.78
0.9
1280
4
0.013
0.25
100
0.5
1.4E-03
3.6E+05
0
0.0E+00
0.0%
3
EX-30211
47.45
0.52
1280
4
0.013
0.25
100
0.5
2.4E-03
2.2E+05
0
0.0E+00
0.0%
1
EX-30205
64.04
1.22
1280
4
0.013
0.25
100
0.5
1.0E-03
3.8E+05
0
0.0E+00
0.0%
3
2
EX-30207
72.69
1.43
1280
4
0.013
0.25
100
0.5
8.7E-04
3.9E+05
0
0.0E+00
0.0%
3
EX-30208
50.7
0.83
1280
4
0.013
0.25
100
0.5
1.5E-03
3.2E+05
0
0.0E+00
0.0%
1
EX-30212
46.47
4.36
1280
4
0.013
0.25
100
0.5
2.9E-04
1.8E+06
0
0.0E+00
0.0%
4
2
EX-30213
43.58
12.77
1280
4
0.013
0.25
100
0.5
9.8E-05
5.8E+06
0
0.0E+00
0.0%
3
EX-30214
38.88
9.43
1280
4
0.013
0.25
100
0.5
1.3E-04
4.8E+06
0
0.0E+00
0.0%
1
EX-30215
48.69
0.8
1280
4
0.013
0.25
100
0.5
1.6E-03
3.2E+05
0
0.0E+00
0.0%
5
2
EX-30216
56.15
0.74
1280
4
0.013
0.25
100
0.5
1.7E-03
2.6E+05
0
0.0E+00
0.0%
3
EX-30217
67.86
1.28
1280
4
0.013
0.25
100
0.5
9.8E-04
3.7E+05
0
0.0E+00
0.0%
Field Duplicates
EX-30204
49.05
0.81
1280
4
0.013
0.25
10
0.5
1.5E-02
3.3E+04
0
0.0E+00
0.0%
EX-30206
71.78
1.33
1280
4
0.013
0.25
10
0.5
9.4E-03
3.6E+04
0
0.0E+00
0.0%
Laboratory QC Analyses
Lab Blank
1280
10
0.013
1.0E+00
1.1E+06
0
mean:
1.6E+04
0.0000008%
Note:
dw = dry weight
g = gram
GO = grid openeing
ID = identification
LA = Libby amphibole asbestos
mm2 = square milimeters
mL = mililiter
N = number
-------
0U5 Wood Chip Activity-based Sampling Summary
January 9, 2012
Page 5
Table 2:
2011 OU4 MISCELLANEOUS ACTIVITY-BASED SAMPLING AIR RESULTS
SCENARIO 3: OU5 WOOD CHIP DISTURBANCE ACTIVITIES
Wood
Chip
Material
Draw
Event #
ABS Air
Sample ID*
Sample
Collection
Date
Sample Collection
Time
Sample
Air
V olume
(L)
Number
Grid
Openings
Examined
Analysis
Sensitivity**
(1/cc)
Number of
PCME LA
Structures
PCME LA
ABS Air
Cone, (s/cc)
1
1
EX-30222
8/24/11
9:11 AM - 10:12 AM
347
200
0.00043
0
0.0
2
EX-30223
8/24/11
10:43 AM - 11:43 AM
341
200
0.00043
0
0.0
3
EX-30226
8/24/11
1:53 PM - 2:53 PM
341
200
0.00043
0
0.0
2
1
EX-30238
8/25/11
8:51 AM - 9:51 AM
332
105
0.00085
0
0.0
2
EX-30241
8/25/11
10:16 AM - 11:16 AM
328
105
0.00086
0
0.0
3
EX-30243
8/25/11
3:10 PM - 4:10 PM
328
200
0.00045
0
0.0
3
1
EX-30231
8/24/11
3:15 PM - 4:15 PM
341
105
0.00083
0
0.0
2
EX-30235
8/24/11
4:55 PM - 5:55 PM
338
105
0.00083
0
0.0
3
EX-30237
8/24/11
6:28 PM - 7:28 PM
328
105
0.00086
0
0.0
4
1
EX-30245
8/25/11
4:20 PM - 5:20 PM
328
200
0.00045
0
0.0
2
EX-30248
8/26/11
8:27 AM - 9:27 AM
335
200
0.00044
0
0.0
3
EX-30250
8/26/11
9:45 AM - 10:45 AM
338
200
0.00044
0
0.0
5
1
EX-30252
8/30/11
1:47 PM - 2:47 PM
328
200
0.00045
0
0.0
2
EX-30254
8/30/11
3:16 PM - 4:16 PM
328
200
0.00045
0
0.0
3
EX-30256
8/30/11
4:35 PM - 5:35 PM
328
105
0.00086
0
0.0
*High volume filter was able to be directly prepared for all samples.
**Target analysis sensitivity changed from 0.00044 to 0.00088 cc-1 during the course of the analyses.
Note:
ABS = activity-based sampling
cc = cubic centimeters
Cone. = concentration
ID = identification
L = liters
LA = Libby amphibole
PCME = phase contrast microscopy equivalent
s/cc = structures per cubic centimeter
-------
ซ
Detail
Materia
%
Power House and
s - ?
Power House Office
K
Storage and
.. .Locomotive She'd
9JSซI
Jointer
\ \Processing
wood Chip
Material
. Draw #4
ฆ
ฆ Shed 12
Wood Chip Material
Material Draw #3
Draw #1 Q
Legend
-------
Appendix F2
Proposed Fishing Pond Pre-design Investigation
(at Former Tree Nursery)
-------
PLM-VE
875 US Highway 2
Proposed Fishing Pond Location
AD-000686
6/6/12, 6/7/12, 6/15/12, 6/18/12. 6/19/12. 6/27/12
Dl Visible and Analytical Sketch
M. Jackson, M. Luick, D. Coleman, J. Peltier
K. Anderson, A. Vivian, C. Hislop (CDM Smith)
Blue areas sampled
during 2008 visit
Approximate location
fence line.
B
0 / '
* |