Environmental Resources Management 7272 E. Indian School Road Suite 100 Scottsdale, Arizona 85251 (480) 998-2401 (480) 998-2106 (fax) 4 February 2013

ERM Project No. 0132320

Mr. Ken Wangerud Remedial Project Manager Superfund Remedial Program USEPA Region 8 – EPR-SR 1595 Wynkoop Street Denver, CO 80202-1129

RE: US Magnesium Comments on the USEPA Draft Air DMA Work Plan, December 2012

Dear Mr. Wangerud:

As you know, we held a conference call recently with technical air quality consultants and risk assessors on the US Magnesium Remedial Investigation/Feasibility Study project team to review our comments on the United States Environmental Protection Agency’s (USEPA’s) draft Air Demonstration of Method Applicability (DMA) Work Plan, issued in December 2012. During the 22 January 2013 call, we were able to obtain consensus on several items that will improve the technical basis for the Air DMA. This letter conveys our understanding of the matters discussed during the call, and how suitable changes will be made to the Work Plan.

Regarding ambient air sampling for volatile organic compounds (VOC) as a class of contaminants of potential concern (COPCs), the draft Work Plan indicated Organic Compendium Method TO-17 as the sole selected method. We propose that both TO-17 and the Summa canister sampling method, TO-15, be performed and compared during the DMA. There are technical advantages to both methods for this program, and, in most instances, TO-15 is the more generally accepted approach for ambient air VOC analyses. There was agreement on the call that a side-by-side comparison of TO-15 and TO-17 would be appropriate, and that this would be included in the Work Plan.

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For organic chemical discrete methods, the draft Work Plan specified that for each sample during the DMA, solid media samplers must be arranged in series (i.e., the use of so-called “stacked” media). The stated purpose was to avoid loss of data should saturation and breakthrough occur when using a single sample medium. In practice, some breakthrough tests would be reasonable, but we did not agree that it should be a requirement for each sample. Further, there are equipment limitations on the sampling apparatus for most of the methods. For example, the higher pressure drop for media samplers in series can make it impractical to maintain sufficient sample air flow. Our proposed approach is to use a single sampling medium, per standard industry practice for organic discrete methods, to collect the DMA samples. With these samples, Environmental Resources Management (ERM) will utilize accepted protocol implemented during laboratory analysis to assess whether saturation or breakthrough has occurred. In addition, some stacked media samples that can be accommodated by conventional equipment (e.g., Tisch samples for dioxins/furans) will be incorporated, if necessary, into the DMA test matrix. The revised Work Plan will identify these procedures.

The draft Work Plan stipulates that the written standard operating procedures (SOPs) for ambient air monitoring were to be subject to formal USEPA approval prior to and during implementation of the DMA. The draft SOPs are now being developed by ERM, based on the selected Compendium Methods, and will serve as a starting point for our DMA work. It is anticipated that the DMA results will necessitate the modification of the SOPs. In our view, it would be premature to conduct a formal approval process on the SOPs prior to completing the DMA, and there was agreement on the call that a formal process is not needed. ERM agreed to provide draft SOPs for USEPA review and reference prior to the start of the on-site DMA work.

The Work Plan stipulates that each sampling station must be equipped with sensors for the measurement of humidity and temperature. Per the Compendium Methods, local temperature and barometric pressure is recorded to verify air flow rate and sample volume in terms of standard temperature and pressure. We proposed during the call to use quality-assured data from the ATI meteorological tower, rather than monitoring at the sampling location, for temperature and barometric pressure. The ATI tower also has instruments that provide hourly

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Environmental Resources Management

relative humidity, should that factor be of interest during the DMA. Our discussion on the call resolved that use of the ATI tower data for this purpose would be sufficient, with no additional monitoring.

For all the selected discrete sampling methods from the Compendium, the standard sampling time is 24 hours. However, one recognized objective of the ambient air DMA is to evaluate the ability to achieve near-continuous coverage over time, even for the discrete sampling of chronic COPCs. In the draft Work Plan, the discussion of discrete sampling time settles on 3-day duration for all samples, as well as reducing air sample flow in proportion to keep total sample volume per the method, thereby avoiding breakthrough of the sampling media. During the call, we recounted our view of the rationale for extended times: 1) to achieve near-continuous sampling with acceptable cost, and 2) to reduce the analyte detection limits by sampling more air volume than prescribed by the standard procedures. We can foresee a variety of technical factors that must be balanced to determine an optimal duration of sampling times for the chronic COPCs. There was consensus on the call that this issue would be best resolved after we have some actual DMA samples. However, our understanding is that the discrete method sampling times and air flows will be retained in the Work Plan as test variables for the DMA, and not be limited or specified beforehand.

We discussed the schedule for the air DMA that was proposed in Table 5 of the draft Work Plan. In our view, this schedule must be revised to account for the analytical turnaround and the external data validation steps that will be implemented during the air DMA. We conveyed to the group on the call that, based on these considerations, we expect evaluation of the full set of DMA data could commence 4 to 6 weeks after the last field samples are obtained. However, we did not arrive at a conclusion on this point, since the project schedule will be determined in consultation with others on the project team and the team leadership.

As a follow-up to this conference call, ERM will make appropriate modifications, in redline strikeout, to the Wok Plan to incorporate the items discussed above. We appreciate the opportunity to have this discussion among the technical specialists for air quality monitoring. Please feel free to contact either of the undersigned at (480) 998-2401

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should you or others have comments regarding the understandings in this letter.

Sincerely, David J. Abranovic, P.E. Robert W. Farmer, Ph.D., P.E. Project Coordinator Senior Air Specialist cc: David Gibby, US Magnesium

Mark Ransom, ERM

Draft Air Demonstration of Methods Applicability

Work Plan

Preparatory to

Phase-1A Air Remedial Investigations

For

US MAGNESIUM NPL SITE

EPA Site Identification No. UTN000802704

TOOELE COUNTY, UTAH

February 2013

U.S. EPA Region VIII

Denver, Colorado

for: US Magnesium LLC

for: U.S. EPA Region VIII

Prepared in collaboration by:

Approved by: _______________________________________________________

U.S. EPA Region VIII Date

Ken Wangerud, RPM, EPR-SR

___________________________________________________

for implementation by:

Environmental Resources Management

7272 E. Indian School Road, Suite 100

Scottsdale, Arizona 85251

T: 480-998-2401

F: 480-998-2106

Under contract to: US Magnesium LLC

__________________________________

David Abranovic P.E.

Project Coordinator

_________________________________

Bob Farmer

AirTask Manager

___________________________________

Sandra Mulhearn

Quality Assurance Manager

i

TABLE OF CONTENTS

LIST OF FIGURES III

LIST OF TABLES IV

1.0 INTRODUCTION 1

2.0 DEMONSTRATION APPROACH 3

2.1 DMA OBJECTIVE 1 – ASSESS THE SUITABILITY AND PERFORMANCE

OF AIR SAMPLING METHODS 3

2.2 DMA OBJECTIVE 2 - DOCUMENT THE SUITABILITY AND

PERFORMANCE OF ANALYTICAL METHODS 4

2.3 DMA OBJECTIVE 3 - DETERMINE THE VIABILITY OF EXTENDED

THREE DAY SAMPLE COLLECTION INTERVALS 5

2.4 DMA OBJECTIVE 4 - SUPPORT THE DEVELOPMENT OF SITE

SPECIFIC STANDARD OPERATING PROCEDURES (SOPS) 5

2.5 DMA OBJECTIVE 5 - DEVELOP SITE SPECIFIC DATA MANAGEMENT

PROTOCOLS FOR AIR FOR INCLUDING INTO THE DMP 6

3.0 SCOPE OF WORK 7

3.1 DMA OBJECTIVE 1 – ASSESS THE SUITABILITY AND PERFORMANCE

OF AIR SAMPLING METHODS 7

3.1.1 Sample Locations and Access 7

3.1.2 Candidate Monitoring Technologies for Cl2 and HCl 8

3.1.4 Sampling Methods for Inhalable Particulates, Organics, and Metals 12

3.1.5 Laboratory Evaluation of Cl2 and HCL Monitoring Systems 15

3.1.6 DMA Evaluation of Cl2 and HCl Monitoring Systems 15

3.1.7 DMA Evaluation of Air Methods for Organics and Metals 16

3.2 DMA OBJECTIVE 2 - EVALUATE THE SUITBILITY AND

PERFORMANCE OF ANALYTICAL METHODS 17

3.2.1 Analytical Methods for Air Samples 17

3.2.2 Laboratory Quantitation Limits 18

3.2.3 Quality Assurance/Quality Control Samples 20

3.2.4 Field Quality Control 20

3.2.5 Laboratory Quality Control 20

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ii

3.2.6 Data Validation 21

3.3 DMA OBJECTIVE 3 – DETERMINE THE VIABILITY OF EXTENDED

THREE- DAY SAMPLING INTERVALS. 21

3.3.1 Evaluation of the Suitability of 3 Day Sampling Episodes Organics 22

3.4 DMA OBJECTIVE 4 – SUPPORT THE DEVELOP SITE SPECIFIC

STANDARD OPERATING PROCEDURES 23

3.5 DMA OBJECTIVE 5 - DEVELOP SITE SPECIFIC DATA MANAGEMENT

PROTOCOLS FOR AIR FOR INCLUSION INTO THE DMP 25

3.5.1 General Data Management Considerations 25

3.5.2 Field Documentation 26

3.5.3 Full Data Package 26

3.5.4 Lab Electronic Data Package Format 26

4.0 SCHEDULE 28

5.0 REFERENCES 29

APPENDIX A — UFP-QAPP WORKSHEETS

APPENDIX B — USEPA COMPENDIUM METHODS – FIELD PROCEDURES

APPENDIX C — USEPA COMPENDIUM LABORATORY METHODS AND

LABORATORY STANDARD OPERATING PROCEDURES

APPENDIX D — HONEYWELL ANALYTICS SPM VENDOR INFORMATION

APPENDIX E — INDUSTRIAL SCIENTIFIC BM25 VENDOR INFORMATION

APPENDIX F — DATA MANAGEMENT PLAN

APPENDIX G — LABORATORY ANALYTICAL SOPS

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iii

LIST OF FIGURES

Figure 1 Site Location

Figure 2 Site Layout

Figure 3 Preliminary Remedial Investigation (PRI) Areas

Figure 4 Proposed Air DMA Monitoring and Sampling Locations

Figure 5 Instrument Calibration Ranges and EPA Toxicity Values

iv

LIST OF TABLES

(Tables in text)

Table 1 Candidate Sampling Methods – Ambient Air PRI 4

Table 2 Cl2 and HCL Exposure Information 10

Table 3 Sample Media and Sample Volume Ranges - DMA for Chronic Toxicants 14

Table 4 Air DMA Laboratory QC Sample Summary 20

Table 5 Phase 1A DMA Schedule 27

1

1.0 INTRODUCTION

The US Magnesium facility (Site) is located in Rowley, Tooele County, Utah, approximately 15

miles north of Interstate 80 and 33 miles north of Grantsville near the southwest edge of the

Great Salt Lake. A site location map is provided as Figure 1.

The Site includes an active primary magnesium production facility, which has been in operation

since 1972. Magnesium is refined from brine obtained from the Great Salt Lake. The facility

includes employee offices and process buildings and other ancillary structures and facilities.

Surrounding the process buildings are a series of evaporation ponds, a concentrator pond, a

landfill, wastewater ditches and ponds, and solid waste disposal areas. Air pollutant emissions

sources are permitted under a Title V Operating Permit (No. 4500030001) issued by the Utah

Department of Environmental Quality, and consist of:

A group of six process stacks make up the main facility stack. The individual stacks consist

of three spray dryer stacks, the melt reactor stack, the emergency off-gas stack, and the

chlorine bypass scrubber stack;

A separate stack from a dust collector serving two magnesium chloride powder bins; and

Fugitive emissions from the reactor building, electrolytic process buildings and other process

and waste disposal areas.

Under sufficiently high wind conditions, materials from solid waste disposal areas can be sources

of wind-blown fugitive dust. A site layout diagram is provided as Figure 2.

The focus of the air demonstration of methods applicability (DMA) task will be the testing of

sample collection and analysis methods for contaminants suspected to be present at the Site.

Chlorine (Cl2) and hydrogen chloride (HCl) gases have been identified as contaminants of

potential concern at the Site and will be monitored on a nearly continuous basis to arrive at

short-term peak and long-term average concentrations.

In addition to monitoring for Cl2 and HCl, air sampling methods will be applied for analytical

suites of chemicals suspected to be present at the Site. For these chemicals, monitoring is needed

over long time periods to support the evaluation of chronic exposures The chemicals for which

sampling and analyses methods will be evaluated, in addition to Cl2 and HCl, during the DMA,

are listed below:

Volatile Organic Compounds (VOC); Polychlorinated Biphenyls (PCB);

Semi-Volatile Organic Compounds (SVOC, including hexachlorobenzene (HCB);

Polycyclic Aromatic Hydrocarbons (PAH);

2

Dioxin/Furan Congeners (D/F):

Inhalable Particulate Matter (PM10, less than 10 micron diameter); and,

Particulate-borne Toxic Metals.

An Administrative Settlement Agreement and Order on Consent (AOC) for Remedial

Investigation/Feasibility Study (RI/FS) was entered into by US Magnesium and the U.S.

Environmental Protection Agency (USEPA) on August 4, 2011. The AOC defines the roles,

responsibilities, schedule, and administration of the RI/FS to be performed at the Site. For

purposes of project planning during the initial phases of the RI, the Site has been divided into 18

Preliminary Remedial Investigation (PRI) areas, which are the focus of the Phase 1A site

investigation activities. The PRI areas are shown on Figure 3, one of which is identified as the

Ambient Air PRI encompassing a 5-mile radius area surrounding the US Magnesium plant.

For the Ambient Air PRI the objectives include the following:

1. Assess the suitability and performance of air sampling methods;

2. Document the suitability and performance of analytical methods;

3. Determine the viability of extended three day sampling intervals.

4. Support the development of site specific Standard Operating Procedures (SOPs);

5. Develop site specific data management protocols for air for inclusion into the Draft

Data Management Plan (DMP) for the RI/FS (ERM 2012).

This Work Plan presents the objectives, approach, equipment evaluation criteria, and scope of

work for the Air DMA. This Work Plan includes selected worksheets (see Appendix A)

developed following the Uniform Federal Program Quality Assurance Project Plan (UFP-QAPP)

guidance (USEPA 2005) to present quality assurance and control (QA/QC) elements of the Air

DMA scope of work. UFP-QAPP worksheets included in this Work Plan will be revised, as

necessary, and then used to inform the USEPA during the preparation of subsequent air

investigations including, but not limited to the Phase 1A SAP.

The results of the Air DMA will be documented in a Technical Memorandum. The Air DMA

Technical Memorandum will be prepared by ERM for EPA review and comment. It will

document the work that was completed and the performance of the air sampling methods. The

Technical Memorandum will include laboratory results and raw data, data validation reports,

data assessment results, and other information pertinent to meeting the above-stated objectives.

The Technical Memorandum will also include copies of revised/finalized UFP-QAPP

worksheets and site specific SOPs for USEPA’s use in finalizing the Phase 1A SAP. The Draft

DMP will also be modified based on the results of the Air DMA.

3

2.0 DEMONSTRATION APPROACH

This section describes how Objectives 1 through 5 of the Air DMA will be evaluated, and

provides the basis for the Scope of Work described in Section 3.0. Sample collection and

analyses shall be performed in accordance with the AOC Sec IX, Work to be Performed,

paragraph 32, and Section XI, Quality Assurance Sampling, and Access to Information,

paragraph 47. Accordingly, data collection will be in accordance with USEPA guidance,

including among other guidance, Guidance for Data Usability in Risk Assessment (USEPA

1992), OSWER Directive #9285.7-05, October 1990 or subsequently issued guidance.

Data shall meet the quality requirements of the USEPA’s quality program as outlined at

www.epa.gov/quality. Applicable documents defining USEPA quality requirements include:

Overview of the EPA Quality System for Environmental Data and Technology (USEPA

2002),

EPA Requirements for QA Project Plans (USEPA 2001),

Guidance on Systematic Planning using the Data Quality Objectives Process (USEPA

2006b), and

Data Quality Assessment: Statistical Tools for Practitioners (USEPA 2006a).

2.1 DMA OBJECTIVE 1 – ASSESS THE SUITABILITY AND PERFORMANCE OF

AIR SAMPLING METHODS

The first Air DMA objective is to evaluate the suitability and performance of standard air

sampling methods. The initial DMA testing for Cl2 and HCl will be performed in a laboratory

environment prior to deployment at a location on the US Magnesium facility. After the

deployment on the facility, a short-term deployment of the preferred methods identified during

the first month of DMA testing on the Site will be conducted at a single, more remote field

location within the 5-mile radius of the facility.

Table 1 lists air sampling methods and analytical techniques proposed for use during the DMA.

Standard USEPA Compendium Methods and other standard methods used in the industry and

included in Appendix B are favored by EPA as the basis for the development of site specific

sampling and analysis SOPs for use during subsequent field investigations.

4

Table 1. Candidate Sampling Methods – Ambient Air PRI

Toxicant USEPA Method Sampling

Method/Media

Analytical

Technique

VOC TO-17 Sorbent Tubes GC/MS

TO-15 Summa Canisters GC/MS

PCB TO-4A Polyurethane Foam

(PUF)

High-resolution GC

and High-resolution

MS

PAH/SVOC/HCB1 TO-13A

Quartz filter and

PUF/XAD layered

cartridge

High-resolution GC

and High-resolution

MS

Dioxins/Furans TO-9A Polyurethane Foam

(PUF)

High-resolution GC

and High-resolution

MS

Inhalable Particulate

(PM10) IO-2.1

8" x 10" quartz filter,

high-volume sampler Gravimetric

Particulate-borne

Metals IO-2.1, IO-3.5

8" x 10" quartz filter,

high-volume sampler

ICP or MS depending

on analyte

Chlorine and HCl

No EPA Method

Available (see

instrument and tape

specific methods

published by

manufacturer)

Continuous

Instrumental Analyzers

Electrochemical and

Chemical Cassettes

1 – HCB is included in the analytical suite for method TO-13A because the solvent extraction used for this compound is not

compatible with PCB analytes.

2.2 DMA OBJECTIVE 2 - DOCUMENT THE SUITABILITY AND PERFORMANCE

OF ANALYTICAL METHODS

Air DMA Objective 2 will be evaluated through the collection of analytical data using EPA

Compendium Methods (USEPA 1999a and 1999b) and other industry accepted methods

identified in Table 1. Analytical method performance will be evaluated relative to project

requirements for precision, accuracy, representativeness, completeness, comparability, and

sensitivity (PARCCs). The PARCCs requirements for the project are summarized in Appendix A

in the UFP QAPP Worksheets.

Evaluation of the impacts of potential interferences on analytical results will be evaluated

through the review of QC sample results such as blanks and spiked samples.

5

2.3 DMA OBJECTIVE 3 - DETERMINE THE VIABILITY OF EXTENDED SAMPLE

COLLECTION INTERVALS

For most contaminants (including VOCs, PCBs, PAHs, SVOCs, HCB, dioxins and furans, and

metals), long-term average concentrations values are needed to evaluate risks associated with

chronic exposure to airborne toxicants. Because of the known variability in releases at the Site,

as well as the effects of random variations in wind conditions, it is important to get a near

continuous record of the concentrations of chemicals in air over long enough time periods such

that average exposure concentrations can be reliably estimated. For this reason, it is desirable to

extend sampling times for these chemicals to the degree possible, given equipment and available

standard method constraints. Standard methods for sampling of air suggest that sampling times

can be extended provided flow rates can be calibrated and breakthrough does not bias sample

results. The planned DMA program will evaluate extended collection intervals for up to 7 days,

with appropriate comparisons to concentrations obtained from a concurrent set of shorter

duration samples.

Equipment limitations and method requirements for maximum sample volumes suggest that

extension of the normal 24-hour run times specified in some of the EPA Compendium Methods

may be acceptable, provided the potential for breakthrough is limited. For organic chemicals

breakthrough will be evaluated through sample analysis techniques to verify the sample media

(e.g., PUF cartridges) are not saturated, and the collection and analysis of stacked sampling

media aligned in series. Both the primary (first in series) and backup (second in series) sample

will be analyzed to quantify the concentrations of chemicals that are not captured on the primary

device. Based on the results of these breakthrough tests, recommendations will be made

concerning the need for modification of sampling trains, flow rates, and sample durations for use

in subsequent investigations.

Because of the nature of inorganic contaminant sample collection methods, run extension is

viable provided flow rates can be calibrated. Therefore, the evaluation of breakthrough for

metals and PM10 is not needed, however, the evaluation of volumetric flow rates over sampling

run times will be needed. The proposed methods for Cl2 and HCl are not susceptible to

breakthrough, but the range of calibrations, the stability of readings, and tape life will vary with

concentration and will need to be evaluated as described in Section 3.0.

2.4 DMA OBJECTIVE 4 - SUPPORT THE DEVELOPMENT OF SITE SPECIFIC

STANDARD OPERATING PROCEDURES (SOPS)

Based on DMA results, revisions will be made to Standard Operating Procedures (SOPs) for

sampling and analysis methods. As appropriate, the EPA Compendium and other methods will

be amended to include site-specific procedures. EPA Compendium Methods are identified in

Worksheet 21 (Appendix A) and provided in Appendix B. EPA Compendium Methods that

provide only analytical procedures, along with laboratory and manufacturers operation manuals

are listed in Worksheet 19 and provided in Appendix C, D, and E. UFP-QAPP worksheets are

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6

provided in Appendix A of this Plan. The UFP-QAPP Worksheets outline the DMA sampling

program parameters, and anticipated numbers of samples for the various techniques during the

DMA. Revision of these worksheets based on the Air DMA results is an essential outcome of the

DMA.

2.5 DMA OBJECTIVE 5 - DEVELOP SITE SPECIFIC DATA MANAGEMENT

PROTOCOLS FOR AIR FOR INCLUDING INTO THE DMP

Data management protocols for the storage and collection of data will be tested during the Air

DMA. The retrieval and storage of high density data from field instruments and standard

analytical method results will be tested. Revisions will be suggested concerning data collection

forms as well as changes to the flow of data and documentation described in the current version

of the DMP (Appendix F).

For Cl2 and HCl, data will be collected on as short a time frequency as possible using the

proposed sampling units. Measurements will be collected on the maximum frequency allowed by

the instrument sampling programs. Data for Cl2 and HCl will be collected such that long and

short term average concentration values may be calculated.

Sample results from extended sample interval episodes for constituents other than Cl2 and HCl

will also be entered into the Air DMA data management system and routines added to the DMP

to account for equipment calibrations as well as collection of analytical and QA/QC data needed

to support air related risk evaluations. As stipulated in the EPA Compendium Methods ambient

meteorological data will be gathered for temperature, humidity and barometric pressure that is

representative of the sampling period. These data are used for air sample volume calculations

and are essential to the evaluation of sampling performance. and will be obtained from the

quality-assured instrumentation on the ATI meteorological tower over the duration of the DMA

sampling efforts.

The management and storage of meteorological data is a secondary objective for the Air DMA.

The project team will evaluate and rectify any data retrieval and storage issues related to the

compilation of meteorological data. The processing and use of meteorological data is not part of

this Air DMA WP.

Deleted: three-day sampling

Deleted: each sampling station must be equipped with sensors for the measurement of humidity and

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7

3.0 SCOPE OF WORK

This section describes the Scope of Work necessary to meet the project objectives and perform

the stated tasks described in Section 2.0, Demonstration Approach.

The Air DMA activities will be performed in accordance with the appropriate Health and Safety

Plans (HASPs). The HASPs associated with the Air DMA will be signed by parties doing the

sampling and performing oversight activities.

3.1 DMA OBJECTIVE 1 – ASSESS THE SUITABILITY AND PERFORMANCE OF

AIR SAMPLING METHODS

3.1.1 Sample Locations and Access

Facility Location: During the initial phase of DMA activities, the air sampling location is

planned to be a secure area within the US Magnesium facility. This location is generally to the

southwest of the process area, near the existing office complex of the plant. The preferred

location is identified, along with other potential candidate locations, in Worksheet 18 (Appendix

A) and shown in Figure 2.

Multiple sampling apparatuses will be set up in a manner that will allow concurrent testing of

logistics, personnel support, tracking of sampling status, and power supply requirements to

operate multiple, high-volume air samplers and other automated systems.

Remote Location: A short-duration remote deployment will also be performed. The remote

location test will be conducted at one location south of the facility within the study area

boundary (5-mile radius). Several candidate locations are under consideration for this scenario,

as identified in Worksheet 18 (Appendix A) and shown in Figure 4. The criteria for the remote

sampling location include the likelihood that the location will be impacted by plant emissions

during the season in which the DMA is conducted, and accessibility for equipment and

personnel. The EPA shall approve the selection of the “remote-location” used in the Air DMA

prior to implementation of this phase of the plan.

The remote location sampling test will be performed after the methods evaluation activities have

been conducted on the Facility. This sampling episode will be conducted for a minimum of one

week and will offer an opportunity to field test the selected monitoring methods and the

logistical considerations for their use away from the US Magnesium facility. Such considerations

include the transport and set up of equipment, field assembly of equipment platforms, operation

of electrical generator and power systems, sampler operation and sample retrieval, data logging

and retrieval, and physical security of the equipment. The remote DMA test offers an opportunity

to test practical security measures for the field sampling equipment, with limited risk. The

remote location testing will include the operation of both a low and high level Cl2 and HCl

analyzer units at a location distant from the plant.

Moved (insertion) [1]

Moved up [1]: The remote location test will be conducted at one location south of the facility within

the study area boundary (5-mile radius).

8

The lessons learned from the remote deployment of air sampling units will be incorporated in

the ambient air sampling program SOPs that are a primary DMA deliverable.

3.1.2 Candidate Monitoring Technologies for Cl2 and HCl

An initial step of the Air DMA will involve the assembly and lab testing of monitoring hardware

for Cl2 and HCl. To be suitable for ambient monitoring, the selected technology must generally

satisfy several criteria:

The response level for the concentration sensors must be lower than the benchmark

concentrations shown in Appendix A on UFP-QAPP Work Sheet 15, and as summarized in

Table 2 below;

The sampling system must offer high data capture and completeness during unattended

operation;

Hardware must be suitable for remote installations, with either 110 volt AC power from a

generator, or solar-charged/remotely-charged battery power supply (12- or 24-volt DC);

The time interval between sampled data points needs to be sufficiently short to capture brief

“peak” events during passage of a plume;

The sensor and sampling mechanism must be calibrated to assure data quality; and

Monitor output must be able to be captured and down loaded periodically and processed prior

to review by stakeholders.

Commercially-available, continuous ambient air sensors that have the ability to measure low to

moderately high levels of Cl2 and HCl are either “electrochemical” or “Chemical Cassette”

types. The chemical cassette gas detection equipment uses an optical system to detect specific

color changes on chemically impregnated paper tapes that have varying sensitive to organic acids

and oxidants as described in Appendix D. The technology does have some cross-reactivity with

other compounds that are similar to Cl2 and HCl as noted in Appendix D. The paper tape is

installed as a cassette that contains sufficient tape for up to a minimum of 2 weeks under

frequent gas detection conditions or a month depending on the tape variety selected for use.

These chemical cassettes are manufactured to ISO 9000 manufacturing standards, with each

batch calibrated in a manner that is traceable to accepted standards.

The recommended candidate chemical cassette sensor is a Honeywell Analytics (HA) model

CM4®

Toxic Gas Monitor, or equivalent unit. Because of the wide range between acute and

chronic toxicity values (see Table 2), chemical cassettes will be run at two differing levels of

sensitivity for both Cl2 and HCl. The CM4 will accommodate for Cl2 a low (Tape A - 7 parts per

billion [ppb] to 2,000 ppb chemical cassette) and higher level chemical cassette (Tape B - 0.5

parts per million [ppm] to 5.0 ppm cassette). Individual cassettes will be placed into separate

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Deleted: the

Deleted: 4

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Deleted: 1.5

Deleted:

9

HA CM4®

units, along with the appropriate software key as specified in the Honeywell

Technical Handbook provided in Appendix D. These systems utilizes a cassette of coated thin-

film tape (Chemcasette®

) that is exposed to ambient air at a constant rate over the sampling

period. Reactions between both Cl2 and HCl cause a specific color change in the reagent coating

that is proportional to the measured concentration. A light-transmission sensor detects the

intensity of the tape color change and outputs a signal that is proportional to the concentration

reading.

Separate Chemcasettes®

and chemical software keys are needed for each gas sampled with this

unit. During the DMA tests, four CM4 or equivalent units will be operated in parallel for the

tests. The CM4 has the option of either a milliamp current output or millivolt output that is

proportional to sensed concentration, and this output will be mated with a data logger to provide

a continuous record of monitored concentrations.Based on the manufacturer specification, the

CM4 will be operated using 110-volt power, supplied by a portable generator located a suitable

distance from the sampler to avoid contamination.. For electrochemical sensors, another possible

option that will be considered during the DMA for this system will be the demonstration of a

solar-powered battery system to be adapted to provide the necessary power input during long-

term, day and night operation.

In industrial settings, electro-chemical sensors can also be used to measure moderate to high

levels of Cl2 and HCl. These low-cost gas detection sensors utilize electro-catalytic phenomena.

They consist of a very small sensing element sometimes called a “bead,” made of an electrically

heated platinum wire coil, covered first with a ceramic base such as alumina and then with a final

outer coating of palladium or rhodium catalyst dispersed in a substrate of thoria. This type of

sensor operates on the principle that when a given gas/air mixture passes over the hot catalyst

surface, oxidation/combustion reactions occur and the heat evolved increases the temperature of

the “bead.” This in turn alters the resistance of the platinum coil and can be measured by using

the coil as a temperature thermometer in a standard electrical bridge circuit. The resistance

change is then directly related to the gas concentration in the surrounding atmosphere.

Electro-chemical sensor technology has advanced to improve the accuracy and reliability of the

monitoring systems. To ensure temperature stability under varying ambient conditions, the best

catalytic sensors use thermally matched beads. The “sensitive” sensor (usually known as the “s”

sensor) will react to the combustible gases present, and the balancing, “inactive” or “non-

sensitive” (n-s) sensor will not. The response time for a catalytic sensor, specified in terms of the

time to reach 90 percent of its final reading, is typically between 20 and 30 seconds. Data will be

collected every 30 seconds and compiled to provide the data needed to calculate short-term and

long-term average results.

Ecological benchmarks for air are still under development. It is anticipated that the values

presented in Table 2 capture the range of values over exposure durations necessary to evaluate

potential impacts to ecological receptors. The EPA is concerned that the instruments proposed

Deleted: the Honeywell Analytics (

Deleted: )

Deleted: Single-point Monitor (SPM) unit

Deleted: For HCl the low (20 ppb to 600 ppb chemical cassette) and higher level chemical cassette (0.5 to 15 ppm chemical cassette) will be placed into

the HA SPM unit along with the appropriate

software key as specified in the Honeywell Technical Handbook provided in Appendix D.¶

Deleted: SPM

Deleted: ¶T

Deleted: SPM

Deleted: can be

Deleted: or for short times (8 to 9 hours) using a

remotely-charged battery with either 12- or 24-volt DC output

Deleted: A

Deleted: to the SPM

10

for use during the Air DMA will be capable of the reliable calibration over the entire range in

concentration required to evaluate risk threshold values shown in Table 2,

Table 2. Cl2 and HCl Exposure Information

Cl2 HCl

ppm μg/m3 ppm μg/m

3

Chronic exposures

EPA RSL Industrial 0.00022 0.64 0.06 88

EPA RSL Residential 0.00005 0.15 0.014 21

Mammals 10 12,300 To be determined To be determined

Birds 1.0 1,230 To be determined To be determined

Acute exposures

AEGL (Level 2) 10 minute 2.8 8,100 100 156,000

AEGL (Level 2) 8 hour 0.71 2,000 11 17,000

Mammals 95 117,000 410 503,000

Birds 9.5 11,700 41 50,300

Note: ppm – parts per million

μg/m3 – micrograms per cubic meter

Additionally, Figure 5 provides a comparison between the instrument calibration ranges and the

EPA toxicity values for ecological and human health receptors.

Deleted: P

11

Figure 5. Instrument Calibration Ranges and EPA Toxicity Values

Panel A: Chlorine

Panel B: HCl

Note: The EPA RSL values for residential chronic exposure to Cl2 and HCl are not shown.

0.0001

0.001

0.01

0.1

1

10

100

1000

Cl2

Co

nce

ntr

atio

n (

pp

m)

Tape A

Tape B

Human Toxicity Values

Industrial RfC

10 min. AEGL

8 hour AEGL

Electro- chemical

Mammal (acute)

Bird (acute) Mammal (chronic)

Bird (chronic)

Ecological Toxicity Values

0.01

0.1

1

10

100

1000

HC

l Co

nce

ntr

atio

n (p

pm

)

Tape A

Tape B

Human Toxicity Values

Industrial RfC

10 min. AEGL

8 hour AEGL

Electro- chemical

Mammal (acute)

Bird (acute)

Ecological Toxicity Values

12

For the Air DMA one recommended candidate electro-chemical unit is an Industrial Scientific

(IS) Model BM25, or equivalent, Transportable Multi-Gas Area Monitor. The advantages of this

specific unit for the US Magnesium study are:

Good low concentration resolution for the target gases (0.1 up to 10 ppm for Cl2 and 0.1 to

30 ppm for HCl);

The ability to simultaneously detect and log concentrations of two or more gases;

The unit can be calibrated in the field using a gas manifold and suitable certified gases; and,

Long battery life of up to 170 hours on a single charge, which allows remote deployment of

the BM25 for several days at a time

The IS BM25 unit has an internal data logging function, and will be periodically downloaded in

the field to capture each individual reading. Vendor information on the BM25 is provided in

Appendix E.

Also included in Appendix E are product data sheets that provide information concerning cross-

reactivities for the BM25 sensor. In addition to cross-reactivities provided in these product data

sheets, the manufacturer identified that unsaturated hydrocarbons can also impact the reliability

of instrument readings such as ketones. Preliminary results from other media sampled at the Site

indicate that these chemicals may not be present.

The most common failure in catalytic sensors is performance degradation caused by exposure to

certain poisons like unsaturated hydrocarbons. It is therefore essential that any gas monitoring

system should not only be calibrated at the time of installation, but also checked regularly and re-

calibrated as necessary. The design of the BM25 allows attachment of a sealed gas manifold over

the sensors to perform calibration checks using certified standard gas mixtures so that the zero

and “span” levels can be verified. Typically, checks should initially be made at weekly intervals

but the periods can be extended as operational experience is gained.

3.1.4 Sampling Methods for Inhalable Particulates, Organics, and Metals

The UFP-QAPP Worksheets describing the air sample collection and analyses requirements

include:

Worksheet 18 – Sampling Locations and Methods/SOP Requirements Table

Worksheet 21 – Project Sampling References SOP Table

Worksheet 26 – Sample Handling System

Worksheet 27 – Sample Custody Requirements

Deleted: the

Deleted: Relatively high detection limits f

Deleted: 0

Deleted: both

Deleted: will be mated with a simple electronic data logger to

Deleted: Checks must be made using an accurately calibrated

Deleted: set correctly on the controller.

13

For the proposed sampling methods for organics, two parameters under control of the operator

are sample flow rate (e.g., in cubic feet per minute or liters per minute), and the sample duration.

The product of flow rate and duration provides the air sample volume for a particular method. In

general, as total air sample volume increases the method sensitivity improves. Consequently, it is

an accepted practice to vary sample volumes and flow rates to meet project specific requirements

for method sensitivity.

Of the methods selected for this study, only the inhalable particulates (PM10) sampling method

has a prescribed sample flow that must be precisely maintained. This is because the PM10

sampling apparatus utilizes a cyclonic separator designed to separate the 10-micron particles. Air

velocity in the cyclone must be controlled within close tolerances to ensure that the size-specific

particle sample is obtained.

The general guideline for organic air methods is that sample collection flow rates should be

maintained at as high a level as practical throughout the selected sample duration to achieve a

high sample volume while not introducing sample bias. Practical limits may be encountered for

both organic and metals methods with extended sample duration. For example, flow rates

through sample media may be impeded due to build-up of particles interfering with media

porosity and reducing the sample air flow at longer sample duration.

Various sample media are to be used with the organic sampling methods: polyurethane foam

(PUF), quartz-fiber filter sheets, XAD-2 organic resin media in Method TO-13A for SVOCs, and

a series of sorbent mixtures specifically designed for VOCs in Method TO-17. Sample media are

listed in Table 3 along with the range of sampling volumes and range of extended duration that

will be tested during the DMA. Specific sorbents for VOCs are provided in Method TO-17.

The flow rates and sample volumes listed in Table 3 were developed based on a review of

technical information provided in the EPA Compendium Methods. A more detail discussion of

the rationale used to select the range of flow rates and sample volumes to be evaluated is

provided in Section 3.3.

Deleted: used

Deleted: ion of

Deleted: shown in Table 3

14

Table 3. Sample Media and Sample Volume Ranges - DMA for Chronic Toxicants

Toxicant

USEPA

Compendium

Methods and

Sample Media

Sampling

Duration for

DMA Tests

Anticipated Sample

Volume or Rate Range

for DMA Tests

VOC TO-17, Mixture of

sorbents as specified

in the method 1 to 7 days

20 milliliters per minute,

with final volume as a test

variable

TO-15, Summa

Canister

1 to 7 days 6 Liters total volume

PCB TO-4A,

Polyurethane Foam

(PUF)

1 to 7 days 4 - 10 scfm (8 scfm is

the method standard)

PPAH/SVOC

/HCB1

TO-13A, Quartz

filter and PUF/XAD

layered cartridge

1 to 7 days 4 - 10 scfm (8 scfm is

the method standard)

Dioxins/Furans TO-9A,Polyurethane

Foam (PUF)

1 to 7 days 4 - 10 scfm (8 scfm is

the method standard)

Inhalable

Particulate

(PM10)

IO-2.1,Quartz filter,

high-volume

sampler

Up to 3 days Fixed flow in 40 – 60

scfm range depending

on sampler

Particulate-borne

Metals

IO-2.1, IO-3.1, IO-

3.5,

Quartz filter, high-

volume sampler

Up to 3 days Fixed flow in 40 – 60

scfm range depending

on sampler

Chlorine (Cl2) Electrochemical or

chemical-sensitive

tape analyzers

15 seconds to

600 seconds

(low level)

Range specified by

manufacturer

HHydrogen

Chloride

(HCl)

EElectrochemical or

chemical-sensitive

tape analyzers

10 seconds to

240 seconds

(low level)

Range specified by

manufacturer

scfm = standard cubic feet per minute,

1 – HCB is included in the analytical suite for method TO-13A since the solvent extraction used for this compound is not

compatible with PCB analytes.

Deleted: not to exceed 100 liters final volume

Deleted: 3

Deleted: scfm – 300 to 400 cubic meters

Deleted: 3

Deleted: 4 scfm – 300 to 400 cubic meters

Deleted: 3

Deleted: 4 scfm – 300 to 400 cubic meters

Deleted: II

Deleted: and

Deleted: and

15

3.1.5 Laboratory Evaluation of Cl2 and HCL Monitoring Systems

The candidate monitoring technologies for Cl2 and HCl described in the preceding section will

initially be evaluated in a controlled ERM laboratory setting. The objectives of this test will

include:

Demonstration of system calibration procedures for field application, as described in

Worksheet 22 (Appendix A);

Assessments of instrument accuracy, sensitivity, and precision based on calibrations using

manufacturer recommended procedures. QC criteria for monitoring technologies are

provided in Worksheet 22 (Appendix A) and the manufacturer’s technical specifications

(Appendices D and E);

Evaluation of solar battery power system in terms of consistent voltage output and life of a

batter charge (if used);

Evaluation of instrument sensor drift during 24-hour and multiple day periods, based on

manufacturer-specific procedures and drift specification;

Verification of data logging and downloading procedures prescribed by the manufacturer;

Evaluate the need to extend the range of electrochemical sensor monitoringfor ambient air

detection up to 10 ppm for Cl2 and HCl; based on actual monitored concentrations; and

Identification of alternative sensor technologies for the reliable quantification over the entire

range of expected risk based thresholds shown in Table 2.

This short term hardware test will be conducted at the ERM Source Testing Group laboratory in

Ontario, California. It is anticipated that this aspect of the DMA process for the acute gas

continuous monitoring will be completed in two to three weeks after receipt of the equipment

hardware and support software.

3.1.6 DMA Evaluation of Cl2 and HCl Monitoring Systems

After the initial laboratory demonstration, ERM will package and ship the Cl2 and HCl sampling

hardware to the Site. A three week period of on-site demonstration will be conducted at a

location within the facility and at a location where both higher and lower level Cl2 and HCl

concentrations in the range of the instruments is expected, potentially near a chlorine discharge

area. A proposed location is shown on Figure 4, but the location is subject to change depending

on safety and logistical considerations and approval by EPA.

The Air DMA field test on the facility for Cl2 and HCl will include:

Deleted: <#>Evaluate potential interferences between HCl and Cl2 and other gases identified as

having a potential for cross-reactivity that may be encountered at the Site;¶

Deleted: use of

Deleted: technology to potential for extend

Deleted: the

Deleted: ing the calibratio

Deleted: n range of the BM25

Deleted:

Deleted: 0

16

Demonstration of system reliability under field conditions prior to mobilization to the

sampling sites;

Verification of field calibration of electrode method instrument to test accuracy, drift, and

precision based on calibrations. QC criteria for monitoring technologies are provided in

Worksheet 22 (Appendix A) and the manufacturer’s technical specifications (Appendices D

and E);

Evaluation of possible matrix interferences because of plant operations and fugitive

emissions that may bias the quantification;

Evaluate potential interferences between HCl and Cl2 identified as having a potential for

cross-reactivity;

Evaluation of solar battery power system performance, if appropriate for the candidate

sampling apparatus; and

Verification of data logging and field downloading procedures from a field location

following manufacturer recommendations.

It is anticipated that this aspect of the DMA process for Cl2 and HCl will be completed in

approximately three weeks after receipt of the equipment hardware and support software at the

Site.

3.1.7 DMA Evaluation of Air Methods for Organics and Metals

Assessment of inhalation risk for other organic and metal contaminants identified during

previous investigations at the Site include toxicants that are typically evaluated based on a robust

quantification of the long-term average exposure concentrations. To accomplish this, use of

standard EPA Compendium Methods for ambient air sampling is favored for the Site-wide Air

PRI. Consequently, an objective of the Air DMA for these toxicants is to evaluate the use of

EPA Compendium Methods to assess primarily the long-term average concentrations. Candidate

sampling and analytical techniques are listed in Table 1and in Worksheets 19 and 21 (Appendix

A).

The DMA sampling program for these toxicants will be conducted for an initial one week period,

and if necessary a second one week sampling period at a location within the US Magnesium

facility. The DMA will test the ability of the candidate methods to achieve acceptable detection

and quantification limits under the operating conditions of the facility. The DMA will be

conducted during a 7 to -10 day period of on-site sampling. Results of the initial samples will be

evaluated to determine if a second phase of DMA sampling is necessary to achieve the DMA

goals.

Deleted:

Deleted: is to

17

In order to evaluate the potential for breakthrough for organic air contaminants, stacked sorbents

and or filters run in series will be appended to selected sampling trains, as technically practical.

These backup or stacked sampling media will be collected and analyzed for each of the

appropriate methods and analyzed separately to evaluate the potential for breakthrough to occur.

Breakthrough of organic contaminants is dependent on size and configuration of the sampling

media, flow rate, concentration in the air, humidity, and temperature. The results from the Air

DMA will be used to evaluate the above conditions and the need for the collection and analysis

of backup or stacked sample media during subsequent air investigations at the Site.

The field demonstration portion of the Air DMA will also focus on the evaluation of the

adequacy of practical quantification limits (PQLs) that can be achieved based on the prevalent

ambient conditions, analytical detection limits, and practical sampling duration.

3.2 DMA OBJECTIVE 2 - EVALUATE THE SUITBILITY AND PERFORMANCE OF

ANALYTICAL METHODS

During the DMA for the Ambient Air PRI, samples will be collected and analyzed using

standard laboratory methods to evaluate DMA Objective 2.

Ambient air samples collected for the Phase 1A DMA will be analyzed by ALS laboratories ,

located in Southern California and Salt Lake City. Laboratory analysis information is provided in

the following applicable UFP-QAPP worksheets (Appendix A):

Worksheet 15 – Reference Limits Evaluation Table

Worksheet 19 – Analytical SOP Requirements

Worksheet 23 – Analytical SOP Reference Table

Worksheet 24 – Analytical Instrument Calibration Table

Worksheet 25 – Analytical Instrument and Equipment Maintenance, Testing, and Inspection

Table

Worksheet 26 – Sample Handling System

Worksheet 30 – Analytical Services Table

3.2.1 Analytical Methods for Air Samples

The analytical methods proposed for use during the DMA are identified for each sample location

in Worksheet 18. In general, the EPA Compendium Methods for ambient air specify for the

following analytical techniques:

Deleted: .

18

VOC (TO-17 and TO-15) GC/MS

PCB/(TO-4A) PUF Soxhlet extraction and High-Resolution GC/MS

SVOC/PAH/HCB (TO-13A) Filter and PUF Soxhlet extraction and High-Resolution

GC/MS

D/F (TO-9A) Filter and PUF 16-hr Soxhlet extraction and High-

Resolution GC/MS

PM10 (IO-2.1) Gravimetric analysis for net weight gain of tared filter

Metals (IO-3.1/IO-3.5) Acid digestion of filter, and ICP or MS (depending on

analyte)

Chlorine Chemcassette® tapes and/or electrochemical sensors

HCl Chemcassette® tapes and/or electrochemical sensors

With the exception Cl2 and HCl, the analyses listed above are routinely performed by the

primary laboratory and their SOPs are provided in Appendix G EPA Compendium Methods and

laboratory SOPs are identified in Worksheet 23, and are provided in Appendix C. The collection

and analysis of samples for Cl2 and HCl are not described in any standard EPA methods. The

DMA will attempt to validate the use of the candidate monitors to provide adequate data for the

assessment of both acute and chronic exposures to Cl2 and HCl.

3.2.2 Laboratory Quantitation Limits

UFP-QAPP Worksheet 15 (Appendix A) includes a sheet for each analytical group that will be

evaluated for the ambient air matrix. The worksheet provides the laboratory quantification limits

(QLs), laboratory detection limits (DLs), and target quantification limits (TQLs) for each

constituent. These are defined as follows:

PQL or QL - The minimum concentration of analyte that can be quantitatively estimated with

acceptable precision and bias.

DL - The minimum level at which the presence of an analyte can be reliably concluded, and

theoretically represents the concentration level for each analyte within a method at which the

analyst is 99 percent confident that the true value is not zero.

TQL - A project-specific value selected to assess whether analytical DLs are sensitive

enough to conclude that non-detected data does not present potential risk, with a high degree

of certainty.

Deleted:

19

TQLs are used in evaluating the adequacy of the proposed analytical methods and laboratory

with respect to data quality needs for the human and ecological risk assessments. For the Air

DMA, validation of PQLs will be one of the outcomes of the tests of extended-duration discrete

sampling. For purposes of this study, proposed air quality TQLs are based on the available risk-

based screening benchmarks for the inhalation pathway from a variety of publicly available

sources. The TQLs are not necessarily the benchmarks that will be selected for actual risk

evaluations in the Baseline Human Health Risk Assessment or the Screening Level Ecological

Risk Assessment (SLERA). Benchmarks for use in the SLERA will be selected in the SLERA

Technical Memorandum, with USEPA approval.

Worksheet 15 uses a color scheme to evaluate the adequacy of DLs and QLs. The colors indicate

the following:

No color – The QL and DL both are lower than the TQL.

Yellow – The PQL or QL exceeds the TQL, but the DL is lower than the TQL. Analytical

results that fall between the QL and DL will be “J-flagged” as estimated concentrations.

Orange – The QL and DL both exceed the TQL.

Values that fall into the orange category may necessitate additional consideration to determine

whether a) lower DLs can be achieved, b)TQLs should be revised to be more representative of

site conditions or c)a higher degree of uncertainty is unavoidable because currently available

analytical methods cannot achieve low enough DLs. An exceedance of a TQL by a DL will

therefore result in one of three interpretations:

1. The TQL is not achievable through currently available analytical methods.

2. The TQL may be achievable if the laboratory can improve its analytical method performance,

or selects an alternative method with a lower DL.

3. The TQL may be achievable through revision of the action level to a more relevant and

representative value that is less conservative but adequately protective.

It should be noted the TQLs currently identified on Worksheet 15 are intended to be conservative

and may not be the most appropriate for use in risk assessment. Because the level of effort

needed to refine TQLs for all human and ecological receptors is very large, and the effort can be

minimized by waiting until the Air DMA results are obtained by only focusing on the subset of

analytes where QLs or DLs may be an issue, the project TQLs for use in subsequent planning

documents will be refined after DMA results are obtained.

20

3.2.3 Quality Assurance/Quality Control Samples

As described in Worksheet 18, for the Air DMA a number of air samples will be collected and

analyzed to support an evaluation of data quality. The types and numbers of duplicate field

samples needed to meet method QA requirements are specified in the various USEPA

Compendium Methods or related laboratory SOPs. In addition, a number of the as-received

sample media may be split by the laboratory following their own SOPs to assess method

precision and/or spike recovery during analysis of a sample batch. Due to the nature of the

sampling methods, it is not feasible to generate split samples at the time of sample collection;

therefore, split samples will not be provided to USEPA during the Air DMA.

For air methods the collection of QC samples was designed to assure the reliability and

representativeness of reported results:

Collection and analysis of field blank samples for each sampling method for each set of

DMA test samples [Blank samples will consist of unexposed media (filters or PUF) that have

been physically transported to the monitoring location, briefly installed in the sample

apparatus, and removed from the apparatus without exposure to air flow, then transported

from the monitoring location.];

Performance of method blank, and field blank samples by the laboratories in accordance with

specifications in EPA Compendium Methods and laboratory SOPs;

Performance of PUF media spikes, and sample spikes by the laboratories in accordance with

specifications in EPA Compendium Methods and laboratory SOPs;

To conduct precision analyses for Cl2 and HCl by operation of co-located duplicate

analyzers during select DMA sampling periods to be agreed to by EPA prior to

implementation;

Laboratory QC analyses to assess data accuracy in accordance with the selected EPA

Compendium Methods and accepted laboratory SOPs, as outlined in Section 3.2.5.

3.2.4 Field Quality Control

The types and frequencies of field QC sample analyses are described in UFP-QAPP Worksheet

20 – Field QC Sample Summary Table (Appendix A).

3.2.5 Laboratory Quality Control

Laboratory QC criteria for analytical methods are provided in the applicable EPA Compendium

Methods (Appendix B), analytical lab SOPs (Appendix C) and in UFP-QAPP Worksheet 12

(Appendix A). The types, frequencies, and analyses for laboratory QC samples are described in

UFP-QAPP Worksheet 28 – QC Samples Table (Appendix A). For the Air DMA, select

Deleted: ¶

21

laboratory QC samples will be analyzed at increased frequencies. Table 3 provides a summary of

the modified laboratory QC sample frequencies for the Air DMA:

Table 4. Air DMA Laboratory QC Sample Summary

Laboratory QC Sample Phase 1A DMA Frequency

Ambient Air

Laboratory Duplicates One randomly selected field sample per week for each analytical

method

Matrix Spike

Conduct one matrix spike analysis per DMA sample set

(nominally 8 to 12 field samples) as specified in the EPA

Compendium Methods, depending on type of media.

Matrix Spike Duplicate Conduct one matrix duplicate spike analysis per DMA sample set

(nominally 8 to 12 field samples)

Blanks, Internal Standard Spikes,

Laboratory Control Samples,

Surrogate Standards, Dilution Tests,

Post Digestion Spikes

Frequency and type of QC samples are individually specified for

different EPA Compendium Methods, refer to Worksheet 12.

3.2.6 Data Validation

Full data packages (Level IV) will be generated for all laboratory analyses. Validation of

laboratory data will be performed in accordance with the recommended Analytical Data

Verification and Validation Stages described in the Guidance for Labeling Externally Validated

Laboratory Analytical Data for Superfund Use (USEPA 2009). Laboratory data will undergo a

Summary Data Quality Review (Stage 2B Data Validation) for 90 percent of the data and a full

(Stage 4) data validation for 10 percent of the data. Data validation will be performed by an

independent third party subcontractor, Laboratory Data Consultants (LDC) of Carlsbad,

California. Laboratory data will be validated per the analytical method SOPs, the laboratory’s

QA manual, and, as appropriate, per the applicable USEPA National Functional Guidelines for

data review (USEPA 2008a; USEPA 2010; USEPA 2011).

Data validation will include an assessment of data precision, accuracy, representativeness,

completeness, comparability, and sensitivity.

3.3 DMA OBJECTIVE 3 – DETERMINE THE VIABILITY OF EXTENDED

SAMPLING INTERVALS.

A key aspect of the method tests for organic methods will be the evaluation of the viability of

extended sampling durations for methods that involve the trapping of gases in sorbent and filter

sample media. In some of these methods, for example, the standard ambient methods for

dioxin/furan, EPA notes the loss of target analytes when normal flow rates are used over

Deleted: THREE- DAY

Deleted: of three days

22

extended sampling times. This can result in low bias due to “washout” or breakthrough of

analytes from the sample media during extended seven-day sampling durations. For this reason

EPA proposes to evaluate during the DMA a range of sampling flow rates and sampling

durations up to seven days to properly assess the potential for washout.

For semivolatiles/PAHs, Dioxins, and PCBs, high volume sampling methods use similar sample

collection devices. The EPA Compendium methods for these target analytes specify that samples

should be collected such that the volume of air sampled is somewhere between 300 and 400

cubic meters over a 24-hour period. However, for this risk assessment it may be advantageous to

extend the duration of the samples by either reducing the flow rates to approach the low end of

the capabilities of the high volume sampling equipment, or to increase the total volume of air

sampled. An increase in sampled air volume will have the benefit of reducing the quantitation

levels for the method. Through modifying the flow and volume sampled from those specified for

use in the EPA Compendium Methods, it may be possible to extend sampling duration, allowing

near-continuous sampling without resulting in media breakthrough or washing out sample spikes.

This evaluation is a component of the planned DMA tests during the on-site test period. For

VOC analyses using the EPA Compendium Method TO-17, the method specifies minimum flow

rates and types of sorbents that are most appropriate for collection of various chemical classes of

compounds. The method also specifies the size and configuration of sorbent tubes that should be

used to collect samples. Sampling durations for the TO-17 method are specified to be from 1 to 4

hours in duration with a maximum sample volume not to exceed a total volume of 4 liters. In the

case of TO-15 Summa canister sampling, use of flow regulators on the canisters can extend the

duration of the samples for up to several days. As part of the planned DMA evaluations,

modified sample volumes and/or duration of these VOC methods will be evaluated to investigate

the practicality of extended sample time.

In the case of TO-17, literature suggests that the extension of sampling runs to collect as much as

100 liter samples (Watson, no publishing date provided) for VOCs may also be viable. Because

chlorinated solvents are known to be present at the Site, it is estimated, that samples should be

collected so that saturation of the carbon adsorbent media does not become saturated, and this

may limit overall sample air volume. Sorbent tubes will also need to be designed and packed

according to method requirements and expected VOC contaminants.

3.3.1 Evaluation of the Suitability of Extended Sampling Episodes Organics

In order to evaluate the reliability of results collected from sample media exposed over a

multiple-day period for organic analytes, backup sorbents and/or filters will be analyzed for a

number of the samples collected during the Air DMA. The results of the backup analyses will be

assessed to evaluate the need for changes in sorbents, filters, flow rates, and other operating

conditions.

If results of backup or stacked sorbents run in series indicate breakthrough of greater than 10

percent of the total mass for any one chemical constituent, the standard SOPs for the Site may be

Deleted: reduce s

Deleted: to three days as opposed to

Deleted: limit

Deleted: standard

Deleted: they collect a

Deleted: of air

Deleted: ing

Deleted: for these methods

Deleted: times up to three consecutive days without substantively exceeding the method

recommended sampling volumes. ¶

Deleted: range

Deleted: However

Deleted: using flow rates of approximately 20 milliliters per minute based on the tables provided in

the TO-17 method. Based on a 3-day sampling period, this will result in a total sample volume of 86

liters.

Deleted: 3 Day

Deleted: three-

Deleted: each of the

23

modified to include the simultaneous extraction and analysis of backup or stacked sorbents and

filters on a routine basis during subsequent air investigations. Alternative methods may also be

considered if breakthrough is shown to be excessive.

3.4 DMA OBJECTIVE 4 – SUPPORT THE DEVELOP SITE SPECIFIC STANDARD

OPERATING PROCEDURES

The air SOPs must conform to the requirements and guidelines of the EPA quality system, as

established in EPA QA/G-6, Guidance for Preparing Standard Operating Procedures (USEPA

2007). The format for technical SOPs shall include the following elements:

1. Title Page

2. Table of Contents

3. Purpose

4. Scope and Applicability

5. Summary of Procedure/Method

6. Definitions of Terms, Acronyms, and Abbreviations

7. Equipment and Supplies

8. Personnel Qualifications and Responsibility

9. Health and Safety Warnings

10. Other Cautions (e.g., proper and improper equipment use, avoidance of equipment

damage, and data quality issues)

11. Detailed Procedures, identifying all pertinent steps in order, and the equipment and

materials needed to accomplish each step. SOPs covering field investigation and

sampling activities must include steps or subsections that address the following:

o Field instrument or method calibration and standardization

o sample collection

o sample handling and preservation

o sample processing and preparation

o troubleshooting

24

o data acquisition, recording, calculation, reduction, and reporting requirements

(such as listing any mathematical steps to be followed, and/or computer hardware

and software use)

12. QA and QC, describing the nature and frequency of QC protocols designed to allow self-

verification of the quality and consistency of the work

13. References, including full references (with version/revision numbers as applicable) to all

documents or procedures that interface with the SOP, such as related SOPs, published

literature, or methods manuals. Citations cannot substitute for the description of the

method being followed in the organization. References and citations to closely-related

SOPs should involve attaching a copy of the related SOP, and clearly documenting any

modifications to the related SOP if it is not to be exactly followed.

SOPs used during the Air DMA will be provided for review and comment to the EPA Project

QA and Regional Project Managers. It is anticipated that the air sampling SOPs will undergo

revision as needed during the DMA activities. The revised SOPs will also be provided to EPA

for review and comment. Each SOP will be assigned an identification number, which will be

included on the Title Page and all subsequent page headers along with the revision number and

approval date.

Below are the general requirements for sampling that will be included in the Air DMA SOPs.

The SOPs for air data collection must include methods for the near-continuous monitoring for

selected hazardous gases (Cl2 and HCl), collection of particulate samples for non-volatile

contaminants over discrete time periods, and the collection of samples for VOCs, SVOCs, PCBs,

HCB, and dioxin/furans over discrete time periods. The SOPs will include detailed procedures

for the following sampling and data collection activities:

Operation of continuous sensor monitors for Cl2 and HCl, including calibration,

maintenance, QC, and data downloading and management. Calibration and QC protocols

established in the SOP should be expanded beyond minimum manufacturer requirements

in order to support the reporting of defensible quantitative data, through multipoint initial

calibration as applicable, regular calibration checks, and challenge samples.

Sampling procedures for Summa canisters used to obtain ambient VOC by Compendium

Method TO-15.

Operation of particulate (filter), adsorbent media, and polyurethane foam (PUF) samplers

for the collection of other classes of contaminants, including sampling flow rates and

durations.

Operation of sampling pumps and handling of sorbent tubes for the collection of VOC by

Compendium Method TO-17.

Handling and preservation of sample media, and preparation for shipping to the analytical

laboratory.

Deleted: SOPs require signature approval of corporate and program QA managers.

Deleted: further require

Deleted: written approval of the

Deleted: require review,

Deleted: (

Deleted: )

Deleted: , and reauthorization on an as-needed basis.

Deleted: volatile contaminants.

Deleted:

25

Collection of field QC samples associated with air sampling as applicable, including:

o Trip blanks

o Field duplicates if collected.

The air sampling SOPs will incorporate by reference other SOPs addressing:

Field documentation (logbooks, labels, chain-of-custody, sample location forms, other

field forms, and associated document control),

Sample management and shipping; and

Collection of GPS coordinates at the sample location(s)

3.5 DMA OBJECTIVE 5 - DEVELOP SITE SPECIFIC DATA MANAGEMENT

PROTOCOLS FOR AIR FOR INCLUSION INTO THE DMP

Documentation and consistent reporting is critical for evaluating the success of any

environmental data collection activity. The information provided below is intended to provide a

general overview of what documents and data will be required to report and manage. More

specific details regarding how these deliverables must be formatted and reported will be

provided in a Site Data Management Plan (DMP). The DMP will be prepared by ERM prior to

implementation of the Air DMA, and will also be included once it has been modified in response

to the results of the DMA into the Phase 1A SAP. Documents, records, and data generated

during the Air DMA will be preserved and controlled in accordance with Section XIV of the

AOC. 3.5.1 General Data Management Considerations

Field and analytical data collected from this project are critical to Site characterization efforts.

An effective information management system is necessary to ensure efficient access to data so

that questions regarding data-acquisition and integrity can be made in a timely manner.

During the Air DMA electronic copies of field logs, notes and other field documentation will be

provided to EPA on a weekly basis during investigation activities. These documents will be

accompanied by metadata that meets the specifications detailed in the DMP and other relevant

methods. The DMP will be structured such that electronic data deliverables of sampling data are

provided at the end of the DMA.

Laboratory data and field documents must document sample custody, analytical responsibility,

analytical results, adherence to prescribed protocols and methods, nonconformity events,

corrective measures, and/or data deficiencies.

Deleted: Sample location surveying.

Deleted: ¶

26

3.5.2 Field Documentation

Complete and accurate documentation is essential to demonstrate that field measurement and

sampling procedures are carried out as described in the SOPs. Field personnel will use

permanently bound field logbooks with sequentially numbered pages to record and document

field activities. Each logbook will be assigned a unique identifier.

Specific data recording formats and parameters for logbooks will be provided in EPA’s Site Data

Management Plan. Logbooks will include, but may not be limited to, the following information:

Name and affiliation of all on-Site personnel or visitors

Weather conditions during the field activity

Summary of daily activities and significant events

Notes of conversations with coordinating officials

References to other field logbooks or forms that contain specific information

Discussions of problems encountered and their resolution

Discussions of deviations from the Air DMA WP. SOPs, or other governing documents

Record of photographs taken

The field team will also use the various field forms as specified in the DMP to record field

activities.

During the Air DMA the complete meteorological data collected by the ATI tower instruments

will be obtained. The average temperature and barometric pressure during each sampling

episode is used for standard air volume calculations. Monitored parameters, including relative

humidity, wind speed, and wind directions, will be logged as hourly averages and maintained in

the project record for the DMA.

3.5.3 Full Data Package

When a full data package is required, the laboratory will prepare data packages in accordance

with the instructions provided in the site specific SOPs. Full data packages will contain all of the

information from the summary data package and all associated raw data. Unless otherwise

requested one copy of each full data package will be provided to EPA at the end of the Air

DMA.

3.5.4 Lab Electronic Data Package Format

The laboratories will provide an Electronic Data Deliverable for all analytical results. Results

that should be included in are as follows:

Target analyte results for each sample and associated analytical methods requested on the

chain-of-custody form

Method and instrument blanks and preparation and calibration blank results reported for

the SDG

Percent recoveries for the spike compounds in the MS, MSD, blank spikes, or LCSs

27

Matrix duplicate results reported for the SDG

All re-analysis, re-extractions, or dilutions reported for the SDG, including any associated

with samples and the specified laboratory QC samples.

Deleted: Electronic and hard-copy data must be retained for a minimum of 3 and 10 years

respectively, after final data have been submitted.

The laboratories will use an electronic storage device capable of recording data for long-term, off-line

storage. Raw data will be retained on an electronic data archival system.

28

4.0 SCHEDULE

Table 5. Phase 1A Air DMA Schedule

Task Date

EPA Final Air-DMA Workplan, acquire Cl2 and HCl

candidate monitors

February 2013

Lab Testing of Cl2 and HCl monitors March 2013

Mobilize to Site to conduct the initial DMA testing at the

facility (approx.. 7 – 10 days)

Early April 2013

Complete the on-site DMA testing after review of initial

results (approx.. 8 – 10 days)

May 2013

Conduct off-site pilot sampling at “remote location” Late May 2013

Obtain validated analytical data for discrete sampling

methods

July 2013

Draft DMA Technical Memorandum August 2013

Deleted: M

Deleted: on the

Deleted: t “remote location”

Deleted: April-

Deleted: June

29

5.0 REFERENCES

ERM-West, Inc. (ERM). 2012. Draft Data Management Plan. US Magnesium, LLC. Rowley,

Utah.

U.S. Environmental Protection Agency (USEPA). 1992. Guidance for Data Useability in Risk

Assessment (Part A). Publication 9285.7-09A. April.

USEPA. 1995. Compilation of Air Pollutant Emission Factors Volume I: Stationary Point and

Area Sources, 5th

Edition, United States Environmental Protection Agency. January and

updates on EPA TTN Website: http://www.epa.gov/ttn/chief/ap42/index.html. January.

USEPA. 1999a. Compendium of Methods for the Determination of Inorganic Compounds in

Ambient Air. EPA/625/R-96-010a. June.

USEPA. 1999b. Compendium of Methods for the Determination of Toxic Organic Compounds

in Ambient Air. Second Edition. EPA/625/R-96-010b. January.

USEPA. 2001. EPA Requirements for QA Project Plans. (QA/R-5; EPA/240/8-01/003. March.

USEPA. 2002. Overview of the EPA Quality System for Environmental Data and Technology.

EPA/240/R02/003. November.

USEPA. 2005. Workbook for Uniform Federal Policy for Quality Assurance Project Plans. .

EPA-505-B-04-900. March.

USEPA. 2006a. Data Quality Assessment: Statistical Tools for Practitioners (QA/G-9S;

EPA/240/8-06/003. February.

USEPA. 2006b. Guidance on Systematic Planning using the Data Quality Objectives Process.

QAIG-4; EPA/240/13-06/001. February.

USEPA. 2007. Guidance for Preparing Standard Operating Procedures (SOPs), EPA QA/G-6 .

EPA/600/B-07/001. April.

USEPA. 2008a. USEPA Contract Laboratory Program National Functional Guidelines for

Superfund Organic Methods Data Review. USEPA-540-R-08-01. June.

USEPA. 2008b. Quality Assurance Handbook for Air Pollution Measurement Systems, Volume

IV: Meteorological Measurements Version 2.0 (Final), USEPA-454/B-08-002. March.

USEPA. 2009. Guidance for Labeling Externally Validated Laboratory Analytical Data for

Superfund Use. OSWER No. 9200.1-85 / USEPA 540-R-08-005. January 13.

30

USEPA. 2010. USEPA Contract Laboratory Program National Functional Guidelines for

Inorganic Superfund Data Review.

USEPA. 2011. Contract Laboratory Program National Functional Guidelines for Inorganic

Superfund Data Review OSWER 9240.1-51 EPA 540-R-10-011.

USEPA. 2011. USEPA Contract Laboratory Program (CLP) National Functional Guidelines for

Chlorinated Dibenzo-p-Dioxin (CDDs) and Chlorinated Dibenzofurans (CDFs) Data

Review. USEPA-540-R-11-016/EPA-540-R-11-016. September.

Watson, Nocola M. and Daniel Cooper. Tube Sampling Versus Canister Sampling-The Pros and

Cons of Each Approach, Poster, Markes International Ltd., Gwaun Elai Medi-Science

Campus, Llantrisant, RCT, CF39 8FL,UK

31

Figures

32

Appendix A

UFP-QAPP Worksheets

Complete UFP-QAPP Worksheets to be provided separately.

33

List of UFP-QAPP Worksheets

15 Reference Limits Evaluation Table

18 Sampling Locations and Methods/SOP Reqts Table

19 Analytical SOP Requirements

20 Field QC Sample Summary Table

21 Project Sampling References SOP Table

23 Analytical SOP Reference Table

24 Analytical Instrument Calibration Table

25 Analytical Instrument and Equipment Maintenance, Testing, and Inspection Table

26 Sample Handling System

27 Sample Custody Requirements

28 QC Samples Table

30 Analytical Services Table

ERM to provide revised worksheets as necessary prior to issuance by EPA of the Final Air DMA

Workplan

34

Appendix B

USEPA Compendium Methods - Field Procedures

35

List of USEPA Compendium Methods -

Field Procedures

Method IO-2.1: Sampling of Ambient Air for Total suspended Particulate Matter (PSM) and PM10

Using High Volume (HV) Sampler

Method TO-4A: Determination of Pesticides and Polychlorinated Biphenyls in Ambient Air Using

High Volume Polyurethane Foam (PUF) Sampling Followed by Gas Chromatographic/Multi-Detector

Detection (GC/MS)

Method TO-9A: Determination of Polychlorinated, Polybrominated and Brominated/Chlorinated

Dibenso-p-Dioxins and Dibenzofurans in Ambient Air

Method TO-13A: Determination of Polycyclic Aromatic Hydrocarbons (PAH) in Ambient Air Using

Gas Chromatography/Mass Spectroscopy (GC/MS)

Method TO-15: Determination of Volatile Organic Compounds (VOCs) in air Collected in Specially-

Prepared Canister and Analyzed by Gas Chromatography Mass Spectrometry (GC/MS)

36

Appendix C

USEPA Compendium Laboratory Methods and Laboratory

Standard Operating Procedures

37

List of USEPA Compendium Methods and Laboratory Standard Operating Procedures

Method IO-3.1: Selection, Preparation, and Extraction of Filter Material

Method IO-3.5: Determination of Metals in ambient Particulate Matter Using Inductively coupled

Plasma/Mass Spectrometry

Method IO-3.5: Determination of Metals in Ambient Particulate Matter Using Inductively

Coupled Plasma/Mass Spectrometry

Additional Laboratory SOPs will be provided separately.

38

Appendix D

Honeywell Analytics SPM Vendor Information

39

Appendix E

Industrial Scientific BM25 Vendor Information

40

Appendix F

Data Management Plan

ERM to provide revised Data Management Plan for air prior to issuance by EPA of Final Air DMA WP

41

Appendix G

Laboratory Analytical SOPs

ERM to provide analytical SOPs for air analyses prior to issuance by EPA of Final Air DMA WP