Sampling and Analysis Plan/Quality Assurance Project Plan ...Robert Medler, [email protected] (1 hard copy, electronic copy) Robert Marriam, [email protected] (electronic

SAMPLING AND ANALYSIS PLAN/ QUALITY ASSURANCE PROJECT PLAN:

OPERABLE UNIT 3 STUDY AREA, LIBBY ASBESTOS SUPERFUND SITE

Trespasser Activity-Based Sampling

Revision 0 – September 16, 2015

Prepared by:

U.S. Environmental Protection Agency

Region 8 Denver, CO

With Technical Assistance from:

CDM Federal Programs Corporation Denver, CO

Trespasser ABS QAPP Revision 0 – 9/16/15

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A2. TABLE OF CONTENTS

A1. TITLE AND APPROVAL SHEET ................................................................................... 3

A2. TABLE OF CONTENTS .................................................................................................. 5

A3. DISTRIBUTION LIST .................................................................................................. 11

A4. PROJECT TASK ORGANIZATION ............................................................................... 12 A4.1 Project Management ................................................................................................................................. 12 A4.2 QAPP Development .................................................................................................................................... 13 A4.3 Field Sampling Support ........................................................................................................................... 13 A4.4 On-Site Field Coordination .................................................................................................................... 13 A4.5 Analytical Support ...................................................................................................................................... 14 A4.6 Data Management ....................................................................................................................................... 14 A4.7 Quality Assurance ....................................................................................................................................... 14

A5. PROBLEM DEFINITION/BACKGROUND .................................................................. 15 A5.1 Site Background........................................................................................................................................... 15 A5.2 Reasons for this Project .......................................................................................................................... 15 A5.3 Applicable Criteria and Action Limits ............................................................................................. 17

A6. PROJECT DESCRIPTION ............................................................................................ 17 A6.1 Project Summary ......................................................................................................................................... 17 A6.2 Work Schedule ............................................................................................................................................. 17 A6.3 Location to be Studied .............................................................................................................................. 18 A6.4 Resources and Time Constraints ....................................................................................................... 18

A7. QUALITY OBJECTIVES AND CRITERIA ..................................................................... 18 A7.1 Data Quality Objectives ........................................................................................................................... 18 A7.2 Performance Criteria ................................................................................................................................ 18 A7.3 Precision .......................................................................................................................................................... 19 A7.4 Bias/Accuracy and Representativeness ........................................................................................ 19 A7.5 Completeness ................................................................................................................................................ 19 A7.6 Comparability ............................................................................................................................................... 20 A7.7 Method Sensitivity...................................................................................................................................... 20

A8. SPECIAL TRAINING/CERTIFICATIONS .................................................................... 20 A8.1 Field .................................................................................................................................................................... 20 A8.2 Soil Preparation Facility ......................................................................................................................... 21 A8.3 Analytical Laboratory............................................................................................................................... 21

A8.3.1 Certifications ........................................................................................................................................... 21 A8.3.2 Laboratory Team Training/Mentoring Program ..................................................................... 22 A8.2.3 Analyst Training .................................................................................................................................... 23

A9. DOCUMENTATION AND RECORDS ........................................................................... 24 A9.1 Field Documentation ................................................................................................................................ 24 A9.2 Laboratory ...................................................................................................................................................... 24 A9.3 Record of Modification ............................................................................................................................ 25

B1. STUDY DESIGN ........................................................................................................... 26


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B1.1 Sampling Locations .............................................................................................................................................. 26 B1.2 ABS Activities .......................................................................................................................................................... 26 B1.3 Soil Sampling ........................................................................................................................................................... 28 B1.4 Study Variables ...................................................................................................................................................... 28 B1.5 Critical Measurements ....................................................................................................................................... 29 B1.6 Data Reduction and Interpretation ............................................................................................................ 29

B2. SAMPLING METHODS, INSTRUMENTATION, AND DOCUMENTATION ................. 29 B2.1 Air Sample Collection ............................................................................................................................... 29 B2.2 Soil Sample Collection ........................................................................................................................................ 30 B2.3 Global Positioning System Coordinate Collection .............................................................................. 30 B2.4 Equipment Decontamination ......................................................................................................................... 31

B2.4.1 Sampling Equipment ............................................................................................................................ 31 B2.4.2 ATVs ............................................................................................................................................................ 31

B2.5 Handling Investigation-derived Waste .......................................................................................... 31

B3. SAMPLE HANDLING AND CUSTODY ......................................................................... 32 B3.1 Sample Documentation ........................................................................................................................... 32

B3.1.1 Field Sample Data Sheets and Logbooks ...................................................................................... 32 B3.1.2 Photographic and Video Documentation ..................................................................................... 32

B3.2 Sample Labeling and Identification ................................................................................................. 32 B3.3 Field Sample Custody................................................................................................................................ 33 B3.4 Chain of Custody .......................................................................................................................................... 33 B3.5 Sample Packaging and Shipping ......................................................................................................... 34 B3.6 Holding Times ............................................................................................................................................... 35 B3.7 Archival and Final Disposition ............................................................................................................ 35

B4. ANALYTICAL METHODS ............................................................................................ 35 B4.1 Analysis of LA in Air................................................................................................................................... 35

B4.1.1 Sample Preparation .............................................................................................................................. 36 B4.1.2 Analysis Method and Counting Rules ............................................................................................. 36 B4.1.3 Stopping Rules ........................................................................................................................................ 36

B4.2 Analysis of LA in Soil ........................................................................................................................................... 37 B4.2.1 Sample Preparation .............................................................................................................................. 37 B4.2.2 Analysis Method ..................................................................................................................................... 37

B4.3 Data Reporting ....................................................................................................................................................... 38 B4.4 Analytical Turn-around Time ........................................................................................................................ 38 B4.5 Custody Procedures .................................................................................................................................. 38

B5. QUALITY ASSURANCE/QUALITY CONTROL ............................................................ 39 B5.1 Field .................................................................................................................................................................... 39

B5.1.1 Training .................................................................................................................................................... 39 B5.1.2 Modification Documentation ............................................................................................................ 39 B5.1.3 Field QC Samples .................................................................................................................................... 39

B5.2 Soil Preparation Facility ......................................................................................................................... 41 B5.2.1 Training and Personnel Requirements .......................................................................................... 41 B5.2.2 Modification Documentation ............................................................................................................ 41 B5.2.3 Preparation QC Samples ..................................................................................................................... 41


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B5.2.4 Inter-laboratory Samples ................................................................................................................... 43 B5.2.5 Performance Evaluation Standards ............................................................................................... 44

B5.3 Analytical Laboratories ........................................................................................................................... 44 B5.3.1 Training/Certifications ....................................................................................................................... 44 B5.3.2 Modification Documentation ............................................................................................................ 45 B5.3.3 Laboratory QC Analyses ...................................................................................................................... 45

B6/B7. EQUIPMENT MAINTENANCE AND INSTRUMENT CALIBRATION ................... 46 B6/B7.1 Field Equipment ............................................................................................................................................ 46

B6/B7.1.1 Field Equipment Maintenance .................................................................................................... 46 B6/B7.1.2 Air Sampling Pump Calibration .................................................................................................. 46

B6/B7.2 SPF and Analytical Laboratory Instruments ................................................................................ 47

B8. INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES ............................ 47 B8.1 Field Supplies .......................................................................................................................................................... 47 B8.2 SPF and Analytical Laboratory Supplies .................................................................................................. 49

B9. NON-DIRECT MEASUREMENTS ................................................................................ 49

B10. DATA MANAGEMENT .............................................................................................. 49 B10.1 Roles and Responsibilities .................................................................................................................... 49

B10.1.1 Field Personnel ....................................................................................................................................... 49 B10.1.2 SPF Personnel ......................................................................................................................................... 50 B10.1.3 Laboratory Personnel .......................................................................................................................... 50 B10.1.4 Database Administrators ................................................................................................................... 51

B10.2 Master OU3 Project Database .............................................................................................................. 51 B10.3 Data Reporting ............................................................................................................................................. 51 B10.4 Data Storage ................................................................................................................................................... 51

C1. ASSESSMENT AND RESPONSE ACTIONS .................................................................. 52 C1.1 Assessments ............................................................................................................................................................ 52

C1.1.1 Field ............................................................................................................................................................ 52 C1.1.2 Laboratory ............................................................................................................................................... 52

C1.2 Response Actions ................................................................................................................................................ 53

C2. REPORTS TO MANAGEMENT .................................................................................... 54

D1. DATA REVIEW, VERIFICATION AND VALIDATION ................................................. 55 D1.1 Data Review ................................................................................................................................................... 55 D1.2 Criteria for LA Measurement Acceptability ................................................................................. 55

D2. VERIFICATION AND VALIDATION METHODS ......................................................... 56 D2.1 Data Verification ......................................................................................................................................... 56 D2.2 Data Validation ............................................................................................................................................ 56

D3. RECONCILIATION WITH USER REQUIREMENTS .................................................... 57

REFERENCES .................................................................................................................... 59


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LIST OF TABLES (provided in-text)

Table B-1 Overview of ABS Air Study Design………………………………………………………………………27 Table D-1 Data Quality Indicators for Asbestos Datasets…………………………………………….……….58 LIST OF FIGURES (provided at the end of the document)

Figure A-1 General Organizational Chart for the Trespasser ABS Figure A-2 Operable Unit 3 Study Area Figure A-3 Asbestos Levels in Source Materials, Phase 1 Figure A-4 Trespasser ABS Areas LIST OF APPENDICES (provided at the end of the document)

Appendix A Asbestos Laboratory Acceptance Criteria for the Libby Asbestos Superfund Site Appendix B Data Quality Objectives Appendix C Mine Trespasser ABS Scripts Appendix D Standard Operating Procedures Appendix E Decontamination Checklist Appendix F Field Sample Data Sheets Appendix G Analytical Requirements Summary Sheet Appendix H Record of Modification Forms


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LIST OF ACRONYMS AND ABBREVIATIONS % percent ≥ greater than or equal to µm micrometer ABS activity-based sampling ACM asbestos-containing material AHERA Asbestos Hazard Emergency Response Act AOC Administrative Order on Consent ASTM American Society for Testing and Materials ATV all-terrain vehicle CARB California Air Resources Board CB&I CB&I Federal Services, LLC cc-1 per cubic centimeter CDM Smith CDM Federal Programs Corporation CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CHISQ Chi-squared COC chain-of-custody DQO data quality objective EDD electronic data deliverable EDS energy-dispersive spectroscopy EPA United States Environmental Protection Agency ESAT Environmental Services Assistance Team FSDS Field Sample Data Sheet f/cc fibers per cubic centimeter FTL field team leader GPS global positioning system Grace W.R. Grace and Company H&S health and safety HASP Health and Safety Plan HAZWOPER Hazardous Waste Operations and Emergency Response ID identification IDW investigation-derived waste ISO International Organization for Standardization KDC Kootenai Development Corporation L/min liters per minute LA Libby amphibole asbestos LC Laboratory Coordinator MCE mixed cellulose ester MDEQ Montana Department of Environmental Quality mm millimeter mm2 square millimeter MWH MWH Americas, Inc. N number of asbestos fibers NIOSH National Institute of Occupational Safety and Health


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NIST National Institute of Standards and Technology NOAA National Oceanic Atmospheric Administration NPL National Priority List NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration OU operable unit OU3 Operable Unit 3 Study Area PCM phase contrast microscopy PCME phase contrast microscopy-equivalent PLM polarized light microscopy PLM-Grav polarized light microscopy using gravimetric methods PLM-VE polarized light microscopy using visual area estimation PRI-ER Project Resources, Inc. and Environmental Restoration QA quality assurance QA/QC quality assurance/quality control QAM quality assurance manager QAPP quality assurance project plan QATS Quality Assurance Technical Support QC quality control RI/FS Remedial Investigation/Feasibility Study ROM record of modification RPM Remedial Project Manager s/cc structures per cubic centimeter SAP sampling and analysis plan SAED selected area electron diffraction Site Libby Asbestos Superfund Site SOP standard operating procedure SPF Soil Preparation Facility SRM standard reference material STEL short-term exposure limit TEM transmission electron microscopy TWA time-weighted average USACE United States Army Corps of Engineers USFS United States Forest Service USGS United States Geological Survey


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A Project Management A3. DISTRIBUTION LIST Copies of this completed and signed sampling and analysis plan/quality assurance project plan (SAP/QAPP) should be distributed to:

U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129

Christina Progess, [email protected] (electronic copy) Deborah McKean, [email protected] (electronic copy) David Berry, [email protected] (electronic copy) Don Goodrich, [email protected] (electronic copy) Dania Zinner, [email protected] (electronic copy)

Montana Department of Environmental Quality 1225 Cedar Street Helena, Montana 59601

Lisa Dewitt, [email protected] (electronic copy) TechLaw, Inc. Environmental Services Assistance Team EPA Region VIII 16194 West 45th Drive Golden, Colorado 80403

Doug Kent, [email protected] (electronic copy) CDM Smith – Libby Field Office 60 Port Boulevard, Suite 201 Libby, Montana 59923

Terry Crowell, [email protected] (electronic copy) Tommy Cook (Project Manager), [email protected] (electronic copy)

CDM Smith – Denver Office 555 17th Street, Suite 110 Denver, Colorado 80202

Lynn Woodbury, [email protected] (electronic copy) Natalie Ross, [email protected] (electronic copy)

W.R. Grace and Company 6401 Poplar Avenue, Suite 301 Memphis, Tennessee 38119

Robert Medler, [email protected] (1 hard copy, electronic copy) Robert Marriam, [email protected] (electronic copy)

MWH Americas, Inc. 2890 East Cottonwood Parkway, Suite 300 Salt Lake City, Utah 84121

William Pickens, [email protected] (electronic copy) Paula Gellner, [email protected] (electronic copy) Emily Yeager, [email protected] (electronic copy)


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mailto:[email protected]
















HDR Engineering, Inc. 1715 South Reserve Street, Suite C Missoula, MT 59801-4708

Sean Everett, [email protected] (electronic copy) Derek Jennings, [email protected] (electronic copy)

CB&I Federal Services, LLC 20 George Street Cambridge, Massachusetts 02140

Mike Lenkauskas, [email protected] (electronic copy)

Copies of the SAP/QAPP will be distributed to the individuals above by CDM Federal Programs Corporation (CDM Smith), either in hard copy or in electronic format (as indicated above). The CDM Smith Project Manager (or their designee) will distribute updated copies each time a SAP/QAPP revision occurs. A copy of the final, signed SAP/QAPP (and any subsequent revisions) will also be posted to the project-specific website (http://cbec.srcinc.com/libby) and the project eRoom (https://team.cdm.com/eRoom/mt/LibbyOU3). eRoom user accounts are managed by Natalie Ross (CDM Smith) ([email protected]). A4. PROJECT TASK ORGANIZATION Figure A-1 presents an organizational chart that shows lines of authority and reporting responsibilities for this project. The following sections summarize the entities and individuals that will be responsible for providing project management, SAP/QAPP development, field sampling support, on-site field coordination, analytical support, data management, and quality assurance (QA) for this project. A4.1 Project Management The U.S. Environmental Protection Agency (EPA) is the lead regulatory agency for activities at the Libby Asbestos Superfund Site (Site). The EPA Remedial Project Manager (RPM) for the Operable Unit 3 Study Area1 (OU3) of the Site is Christina Progess. Ms. Progess is the principal data user and decision-maker for Superfund activities within OU3. The Montana Department of Environmental Quality (MDEQ) is the support regulatory agency for Superfund activities within OU3. The interim MDEQ Project Managers for OU3 is Lisa Dewitt. EPA will consult with MDEQ as provided for by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the National Contingency Plan, and applicable guidance in conducting Superfund activities within OU3. The U.S. Forest Service (USFS) is the land management agency for over 30,000 acres within OU3. As such, the USFS is a support agency for this site. The USFS Project Coordinators are Robert

1 At this time, the boundaries of OU3 have not yet been determined. EPA established a preliminary OU3 Study Area for the purpose of planning and developing the scope of the Remedial Investigation/Feasibility Study (RI/FS) for OU3. The OU3 Study Area may be revised as data are obtained on the nature and extent of environmental contamination associated with releases that may have occurred from the mine site. In this SAP/QAPP, when the term OU3 is used, it is referring to the OU3 Study Area.


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http://cbec.srcinc.com/libby

https://team.cdm.com/eRoom/mt/LibbyOU3


Wintergerst and Malcom Edwards. The local Supervisory Forester for the USFS is Seth Cole. EPA will consult with the USFS while operating on the USFS-managed land (none of the planned activities in this investigation will be performed on USFS-managed land). EPA has entered into an Administrative Order on Consent (AOC) (Docket No. CERCLA-08-2007-0012) with respondents W.R. Grace and Company (Grace) and Kootenai Development Corporation (KDC) for performance of a Remedial Investigation/Feasibility Study (RI/FS) for OU3. Under the terms of the AOC, Grace and KDC will implement the activities described in this SAP/QAPP, under EPA supervision. The designated Project Coordinator for Grace is Robert Medler; he is assisted by Robert Marriam. A4.2 QAPP Development This SAP/QAPP was developed by CDM Smith at the direction and oversight of the EPA under Contract No. EP-S8-11-02, Task Order No. 0001. This document contains all the elements required for both a SAP and a QAPP and has been developed in general accordance with the EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5 (EPA 2001) and the Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G4 (EPA 2006). Copies of the SAP/QAPP will be distributed to the individuals above by CDM Smith, either in hard copy of in electronic format (as indicated in Section A3). The CDM Smith Project Manager (or their designee) is responsible for maintaining the SAP/QAPP and will distribute updated copies each time a document revision occurs. As noted above, a copy of the final, signed SAP/QAPP (and any subsequent revisions) will also be posted to the OU3 website and the OU3 eRoom. A4.3 Field Sampling Support All field collection activities described in this SAP/QAPP will be performed by Grace and their contractors, in strict accordance with this SAP/QAPP. Grace will be supported in this field work by MWH Americas, Inc. (MWH) and the main point of contact for MWH is William Pickens. MWH will perform all sampling and will provide the necessary personal protective equipment for personnel that will support this sampling effort. Additionally, MWH will supply all equipment and supplies necessary for completing the sampling. MWH may also be supported by other field contractors as appropriate (i.e., Chapman Construction, Inc. and/or Billmayer & Hafferman, Inc.). A4.4 On-Site Field Coordination Access to the mine and other areas of OU3 via Rainy Creek Road is currently restricted and is controlled by EPA. The point of contact for access to the mine is controlled by United States Army Corp of Engineer’s (USACE) contractor Project Resources, Inc. and Environmental Restoration (PRI-ER):

USACE office (406-293-3567) Jeremy Ayala – USACE Project Engineer (402-594-1239) Brian Broekemeier – Construction Control Representative (402-253-6109) Jeff Hubbard – Construction Control Representative (402-216-4255) Harvey Fowler – PRI-ER Superintendent (406-291-7994)


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A4.5 Analytical Support All samples collected as part of this project for asbestos analysis will be sent for preparation and/or analysis to laboratories that meet the Libby-specific laboratory criteria that have been established for the project. These criteria are specified Appendix A. Grace may choose whether asbestos analytical laboratory services are procured directly or if services will be provided via EPA. For the purposes of this sampling effort, it is anticipated that laboratory support will be provided via EPA. The EPA Environmental Services Assistance Team (ESAT) is responsible for procuring all analytical and preparation laboratory services and providing direction to the analytical laboratories. Don Goodrich (EPA Region 8) is responsible for managing the ESAT laboratory support contract for asbestos. The ESAT Region 8 Team Manager is Mark McDaniel (TechLaw, Inc.). He is also the designated laboratory coordinator (LC) for the Libby project that is responsible for directing the analytical laboratories, prioritizing analysis needs, and managing laboratory capacity. A4.6 Data Management Administration of the master database for OU3 will be performed by EPA’s contractor, CDM Smith. The primary database administrator will be Natalie Ross. She (or her designee) will be responsible for sample tracking, uploading new data, performing data verification and error checks to identify incorrect, inconsistent, or missing data, and ensuring that all data are corrected as needed. When the OU3 database has been populated, verified, and validated, relevant asbestos data may be transferred into a Scribe project database, as directed by EPA, for final storage. A4.7 Quality Assurance There is no one individual designated as the EPA Quality Assurance Manager (QAM) for the Libby project. Rather, the Region 8 QA Program has delegated authority to the EPA RPMs. This means EPA RPMs that have completed the QA training have the ability to review and approve governing investigation documents developed by Site contractors. Thus, it is the responsibility of the EPA RPM for OU3 to designate an EPA QA reviewer, who is independent of the entities planning and obtaining the data, to ensure that this SAP/QAPP has been prepared in accordance with EPA’s QA guidelines and requirements. The EPA QA reviewer for this SAP/QAPP is Dania Zinner. The EPA RPM is also responsible for managing and overseeing all aspects of the quality assurance/quality control (QA/QC) program for OU3. In this regard, the RPM is supported by the EPA Quality Assurance Technical Support (QATS) contractor, CB&I Federal Services, LLC (CB&I). The QATS contractor will evaluate and monitor laboratory QA/QC sampling and is responsible for performing annual audits of each analytical laboratory and validating laboratory data packages. CB&I’s QAM for this project is Michael Lenkauskas. CDM Smith’s QA Director, Jo Nell Mullins, implements the CDM Smith QA program. She is independent of project technical staff and reports directly to the firm’s president on QA matters. The QA Director has the authority to objectively review projects and identify problems, and the authority to use corporate resources, as necessary, to resolve any quality-related problems.


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CDM Smith’s QAM for this project, Terry Crowell, reports to Ms. Mullins on QA matters. Under Ms. Mullin’s oversight, Ms. Crowell is responsible for monitoring and evaluating field QA/QC, providing oversight of field sampling and data collection activities, and coordinating field QA activities, including identifying qualified, independent personnel to conduct assessments of field activities (see Section C1.1). A5. PROBLEM DEFINITION/BACKGROUND A5.1 Site Background Libby is a community in northwestern Montana that is located near a large open-pit vermiculite mine. Vermiculite from the mine at Libby is known to contain amphibole asbestos that includes several different mineralogical classifications, including winchite, richterite, tremolite, and possibly actinolite (Meeker et al. 2003). For the purposes of EPA investigations at the Site, this mixture is referred to as Libby amphibole asbestos (LA). Historic mining, milling, and processing of vermiculite at the site are known to have caused releases of LA associated with vermiculite to the environment. Inhalation of LA associated with the vermiculite is known to have caused a range of adverse health effects in exposed humans, including workers at the mine and processing facilities (Amandus and Wheeler 1987; McDonald et al. 1986; McDonald et al. 2004; Sullivan 2007; Rohs et al. 2007; Larson et al. 2010, 2012a, 2012b), as well as residents of Libby (Peipins et al. 2003). Based on these adverse effects, EPA listed the Site on the National Priorities List (NPL) in October 2002. Starting in 2000, EPA began taking a range of cleanup actions at the site to eliminate sources of LA exposure to area residents and workers using CERCLA (or Superfund) authority. EPA has designated a number of OUs for the Site due to its size and complexity. This document presents an investigation for OU3. OU3 includes the property in and around the former vermiculite mine and certain areas surrounding the mine that have been impacted by releases and subsequent migration of hazardous substances and/or pollutants or contaminants from the mine. At this time, the boundaries of OU3 have not yet been determined. Figure A-2 shows the location of the mine and the preliminary OU3 Study Area. EPA established the preliminary Study Area for the purpose of planning and developing the scope of the RI/FS for OU3. This Study Area may be revised as data are obtained during the RI for OU3 on the nature and extent of environmental contamination associated with releases that may have occurred from the mine site. A5.2 Reasons for this Project The Phase I investigation for OU3 was conducted in October 2007 (EPA 2007a) and collected samples from source materials2 in the Former Mined Area (area disturbed by mining activities consisting of exposed outcrops, rock piles, waste materials, and soils without vegetation; also referred to as the mined area). Figure A-3 presents source material sample locations and results

2 For simplicity, soils, rock, tailings, and other mining materials that may occur within the Former Mined Area, which may be a source of airborne LA when disturbed, will be collectively referred to as “source materials”.


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from this investigation. The Phase 1 results show some source material samples have LA concentrations as high as 2 percent (%) to 8% (CDM Smith 2015). Because of these elevated LA levels, controls have been implemented to prevent access to the Grace property. Specifically, gates across Rainy Creek and Jackson Creek roads are intended to prevent unauthorized access to and around the mined area. Since property access is currently restricted, sampling has not been performed to date to quantify potential risks from receptor exposures on the mined area. However, a trespasser has been reported in the vicinity of the mined area and it is possible for trespassers on all-terrain vehicles (ATVs) to drive along unpaved roads and onto the mined area. In addition, it is possible that people may trespass on the mined area in order to collect rock and mineral specimens (referred to as “rock hounding”). As stated in the Framework for Investigating Asbestos-Contaminated Superfund Sites (EPA 2008a), asbestos fibers in source materials, are typically not inherently hazardous, unless the asbestos is released from the source material into air where it can be inhaled. If inhaled, asbestos fibers can increase the risk of developing lung cancer, mesothelioma, pleural fibrosis, and asbestosis. The evaluation of risks to humans from exposure to asbestos is most reliably achieved by the collection of data on the level of asbestos in breathing zone air during disturbances of asbestos-containing source materials, referred to as activity-based sampling (ABS) (EPA 2008a). While there have been several ABS studies conducted within OU3 to assess potential exposures under a variety of exposure conditions, at present, there are no ABS air data for the mined area. Specifically, trespassing or rock hounding in the mined area has been identified as a potential exposure pathway to human receptors, but quantitative risk estimates cannot be calculated because there are no measured ABS air concentrations during these types of scenarios. Therefore, measured ABS air data are needed to evaluate if human receptors could be exposed to unacceptable levels of LA on the mined area during these types of scenarios and if future response actions and/or additional controls are necessary to prevent these exposures. In the event that ABS air results indicate exposures during activities in and around the mined area result in unacceptable exposures, information on LA concentrations in source materials will be used to inform decisions on the specific areas where response actions would be most effective in reducing exposures. As noted above, source material samples from the mined area were collected in 2007 as part of the Phase 1 investigation (EPA 2007a). While these samples provide representative data on LA concentrations in source materials within the mined area, the extent of sampling along Rainy Creek Road and other unpaved roads and trails was limited (i.e., only three samples of road materials were collected from the lower unpaved sections of Rainy Creek Road) (CDM Smith 2015). Therefore, additional measurements of LA concentrations in road materials are needed to characterize the unpaved roads and trails in and around the mined area to inform decisions on the specific areas where response actions would be most effective in reducing exposures. The goal of this study is to provide sufficient data on LA concentrations in air, during activities that represent the types of human receptor activities that may occur in and around the mined area (i.e., trespasser ATV riding and rock hounding), to allow EPA to complete an exposure assessment. The exposure assessment will be used to determine potential risks to human health. The risk


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assessment will support decisions about whether or not response actions and/or additional controls are needed to protect human receptors in and around the mined area. A5.3 Applicable Criteria and Action Limits Criteria for exposure of workers to asbestos in workplace air have been established by the Occupational Safety and Health Administration (OSHA). The short-term (30-minute) exposure limit (STEL) is 1.0 fibers per cubic centimeter (f/cc), and the 8-hour time-weighted average (TWA) exposure limit is 0.1 f/cc. Both asbestos exposure limits are expressed in terms of phase contrast microscopy (PCM) fibers (OSHA 2002). Health and safety (H&S) worker monitoring will be performed in accordance with OSHA requirements as part of this study. These H&S personal air samples are collected in addition to the ABS air samples and will be analyzed by PCM for the purposes of OSHA compliance in accordance with Grace’s Health and Safety Plan (HASP) (see Section A8.1). However, because the PCM method does not distinguish between asbestos and non-asbestos fibers, air samples collected as part of this study, which are collected to determine exposures for use in risk assessment, will be analyzed by transmission electron microscopy (TEM) in accordance with EPA guidance (EPA 2008a). Final remedial action levels for OU3 will not be developed until completion of the RI/FS and the publication of the record of decision. Thus, there are no LA-specific criteria or action limits that apply to this sampling program. Data collected as part of this study will be used to characterize exposures and human health risks to trespassers; therefore, samples must be collected and analyzed in accordance with project-specific requirements specified in this SAP/QAPP to ensure results will be adequate to support risk. A6. PROJECT DESCRIPTION A6.1 Project Summary This document provides a plan for collecting data to evaluate potential LA inhalation exposures for people trespassing on Grace’s property and disturbing LA-containing source materials. This will be accomplished by conducting ABS air monitoring during simulated trespassing activities. Two types of trespassing activities will be evaluated – ATV riding and rock hounding. This document also provides a plan for the collection of road material samples along unpaved road and trails in and around the mined area that may be used by ATV riders. All field collection activities will be performed by Grace and their contractors, in strict accordance with this SAP/QAPP. Basic tasks that are required to implement this investigation are described in greater detail in subsequent sections of this SAP/QAPP. A6.2 Work Schedule It is anticipated ABS will be conducted in late-September 2015 over an approximate 1-week timeframe. The specific dates of the ABS are not important, provided that the environmental


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conditions are met to perform the ABS (i.e., ABS air samples must be collected under dry conditions when the potential for LA release from source materials is higher). A6.3 Location to be Studied All sampling will be performed within the Grace former mine property boundary shown on Figure A-4. The on-road ATV riding will be performed on existing unpaved roads and trails within the Grace property boundary both within the disturbed area of the mine and in the forested area surrounding the mined area. Road material samples will be collected along each of the on-road ATV routes. The off-road ATV riding and rock hound ABS scenarios will be performed within the disturbed area of the former mine (i.e., the yellow shaded “ABS Area” in Figure A-4). The disturbed area is where waste rock piles exist that are devoid of vegetation. As shown in Figure A-3, since the time of the Phase 1 investigation in 2007, there are several locations in the mined area where cover soils (generated from soil removals conducted in other operable units) have been placed. ABS activities will not be performed in areas where cover soils have been placed. A6.4 Resources and Time Constraints The greatest time constraint is that the sampling must be conducted when environmental conditions are amenable to conducting ABS and when appropriate personnel are available to conduct the work. ABS should be conducted when conditions are dryer (July-September) and LA is most likely to be released from source materials to the air. The goal is to conduct the ABS activities in 2015 to allow for these data to support the Site-wide human health risk assessment and decision-making as part of the RI/FS process for OU3. Road material sampling will be performed concurrent with the ABS to minimize mobilization costs. It is anticipated that the ABS activities and road material sampling will commence in late-September 2015, but it is possible that activities may be delayed if conditions are not optimal. A7. QUALITY OBJECTIVES AND CRITERIA A7.1 Data Quality Objectives Data quality objectives (DQOs) are statements that define the type, quality, quantity, purpose, and use of data to be collected. The design of a study is closely tied to the DQOs, which serve as the basis for important decisions regarding key design features such as the number and location of samples to be collected and the types of analyses to be performed. EPA has developed a seven-step process for establishing DQOs to help ensure that data collected during a field sampling program will be adequate to support reliable site-specific risk management decision-making (EPA 2001, 2006). Appendix B provides the detailed implementation of the seven-step DQO process associated with this SAP/QAPP. A7.2 Performance Criteria The range of LA concentrations that will occur in air during trespasser ABS activities in the mined area is not known. Previous outdoor ABS at OU3 has shown that LA concentrations in ABS air can


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be highly variable depending upon the type of activity conducted, the intensity of the activity, and the concentration and condition of the source materials disturbed. However, even if the expected ABS air concentrations are not known, it is possible to estimate the risk-based air concentrations that correspond to a level of human health concern. These calculations are provided in Appendix B. In brief, the risk-based air concentration is back-calculated such that the resulting air concentration corresponds to a target cancer risk of 1E-05 or non-cancer hazard of 1 based on the LA-specific toxicity values (EPA 2014). The analytical requirements for LA measurements in air as established in Section B4 ensure that, if air concentrations are present at these target risk levels, they will be reliably detected and quantified during the analysis. A7.3 Precision The precision of asbestos measurements is determined mainly by the number (N) of asbestos fibers counted in each sample. The coefficient of variation resulting from random Poisson counting error is equal to 1/N0.5. In general, when good precision is needed, it is desirable to count a minimum of 3-10 fibers per sample, with counts of 20-25 fibers per sample being optimal. Recount and re-preparation analyses will be performed as part of TEM analysis (see Section B5.2.3), duplicate analyses are also performed for source material samples (see Section B5). These analyses will provide information on analysis reproducibility and precision (both inter- and intra-laboratory). A7.4 Bias/Accuracy and Representativeness There is no established set of reference materials or spiked standards that can be used to assess accuracy of TEM analyses of LA. Results for field blanks and laboratory blanks will be utilized to ensure that air sample results are not biased as a consequence of cross-contamination due to field sampling procedures or preparation and analysis methods. It is expected that LA levels in air may vary widely as a function of LA levels in the source materials being disturbed, the nature of the materials being disturbed, the disturbance activities performed, and meteorological conditions. Locations selected for evaluation in this study are generally representative of the areas that may be encountered by trespassers in the mined area, but may be biased high due to preferential selection of areas where cover soils have not been placed. In addition, the measured levels of LA in ABS air samples may be biased high relative to long-term exposure scenarios, because the samples are only representative of exposures under dry conditions. A7.5 Completeness Target completeness for this project is 100% for all ABS air samples collected. If any ABS air samples are not collected, or if LA analysis is not completed successfully, data may not be adequate to support risk management decision-making. Target completeness for this project is 90% for all road material samples planned to be collected. These samples are useful in providing data on the nature and extent of LA in road materials, which


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will be useful in guiding potential response actions (if necessary), but risk estimates do not depend upon these data (i.e., air concentrations will not be quantitatively correlated or predicted from LA concentrations in road materials). A7.6 Comparability The data generated during this study will be obtained using sample collection, preparation, and analysis methods for measuring LA in air used previously at OU3. The use of consistent methods will yield data that are comparable to previous results of LA analyses. A7.7 Method Sensitivity The method sensitivity (analytical sensitivity) needed for the analysis of LA is discussed in Section B4. A8. SPECIAL TRAINING/CERTIFICATIONS A8.1 Field Asbestos is a hazardous substance that can increase the risk of cancer and serious non-cancer effects in people who are exposed by inhalation. Therefore, all individuals involved in the collection, packaging, and shipment of samples must have OSHA 40-hour H&S training, and respiratory protection training as required by 29 Code of Federal Regulations (CFR) 1910.134. Individuals must also have asbestos awareness training, as required by 29 CFR 1910.1001, as well as training in sample collection techniques and use of personal protective equipment. All training documentation will be stored in the appropriate field office. It is the responsibility of the field H&S manager to ensure that all training documentation is up-to-date and on-file for each field team member. It is the responsibility of Grace, or their contractors, to ensure that sampling is conducted in accordance with the project HASP, following all appropriate personnel protective equipment requirements, and to maintain appropriate documentation of training by active field personnel. The project HASP will be developed by Grace’s contractor prior to the ABS. The final, approved HASP will be available on the OU3 eRoom. Prior to beginning field sampling activities, a field planning meeting will be conducted to discuss and clarify the following: Objectives and scope of the fieldwork Equipment and training needs Field operating procedures, schedules of events, and individual assignments Required quality control (QC) measures H&S requirements

It is the responsibility of each field team member to review and understand all applicable governing documents associated with this sampling program.


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A8.2 Soil Preparation Facility All road material samples submitted for analysis by the Site-specific polarized light microscopy (PLM) methods are first processed in accordance with standard operating procedure (SOP) 16-ASB-06.02, Soil Sample Preparation at the Troy Soil Preparation Facility (see Appendix D). This processing includes drying, splitting, sieving, grinding, and archiving. Sample processing activities will be completed at the Soil Preparation Facility (SPF) located in Troy, Montana, referred to as the “Troy SPF”. The Troy SPF is staffed by EPA ESAT contractors. SPF personnel performing sample preparation activities must have read and understood the Soil Sample Preparation Work Plan, the SPF HASP, and all associated SOPs and governing documents for soil preparation (e.g., SOP 16-ASB-06.02). In addition, all personnel must have completed 40-hour OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) training, annual updates, annual respirator fit tests, and annual or semi-annual physicals, as required. Prior to performing activities at the Troy SPF, new personnel will be instructed by an experienced member of the SPF staff and training sessions will be documented in the SPF project files. It is the responsibility of the SPF QAM to ensure that all personnel have completed the required training requirements. A8.3 Analytical Laboratory A8.3.1 Certifications All analytical laboratories participating in the analysis of samples for the Libby project are subject to national, local, and project-specific certifications and requirements. Each laboratory is accredited by the National Institute of Standards and Technology (NIST) and National Voluntary Laboratory Accreditation Program (NVLAP) for the analysis of airborne asbestos by TEM and/or analysis of bulk asbestos by PLM. This includes the analysis of NIST/NVLAP standard reference materials (SRMs), or other verified quantitative standards, and successful participation in two proficiency rounds per year of bulk asbestos by PLM and airborne asbestos by TEM supplied by NIST/NVLAP. Copies of recent proficiency examinations from NVLAP or an equivalent program, as well as certifications from other state and local agencies, are maintained by each participating analytical laboratory. Copies of all proficiency examinations and certifications are also maintained by the LC. Each laboratory working on the Libby project is also required to pass an on-site EPA laboratory audit. The details of this EPA audit are discussed in Section C1.2. The LC also reserves the right to conduct any additional investigations deemed necessary to determine the ability of each laboratory to perform the work. Each laboratory also maintains appropriate certifications from the state and possibly other certifying bodies for methods and parameters that may also be of interest to the Libby project. These certifications require that each laboratory has all applicable state licenses and employs only qualified personnel. Laboratory personnel working on the Libby project are reviewed for requisite experience and technical competence to perform asbestos analyses. Copies of personnel resumes are maintained for each participating laboratory by the LC in the Libby project file.


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A8.3.2 Laboratory Team Training/Mentoring Program Training/Mentoring The orientation program to help new laboratories gain the skills needed to perform reliable analyses at the Site involves successful completion of a training/mentoring program that was developed for new laboratories prior to their analysis of Libby field samples. All new laboratories are required to participate in this program. The program includes training provided by the QATS contractor and/or senior personnel from other Libby team laboratories. The training/mentoring process includes a review of morphological, optical, chemical, and electron diffraction characteristics of LA, as well as training on project-specific analytical methodology, documentation, and administrative procedures used on the Libby site. The mentoring process also includes a general EPA audit, which is performed by the QATS contractor, to determine the general capabilities of the laboratory, the adequacy of facilities and instrumentation, and evaluate of the laboratory quality management system. The mentor will also review the analysis of at least one proficiency demonstration sample for each analytical method with the trainee laboratory. Once the laboratory has satisfactorily completed the training/mentoring program, they can begin to support the analysis of Libby field samples. Initially, all submitted analytical results will undergo a detailed data verification and validation review (see Section D2). The frequency of these reviews can be reduced if no issues are identified. The QATS contractor may also perform a subsequent EPA audit to evaluate analyses of Libby field samples. Site-Specific Reference Materials TEM. Because LA is not a common form of asbestos, the U.S. Geological Survey (USGS) prepared Site-specific reference materials using LA collected at the Libby mine site (Meeker et al. 2003). Upon entry into the Libby program, each laboratory is provided samples of these LA reference materials. Each laboratory is required to analyze multiple LA structures present in these samples by TEM in order to become familiar with the physical and chemical appearance of LA and to establish a reference library of LA energy dispersive spectroscopy (EDS) spectra. These laboratory-specific and instrument-specific LA reference spectra (EPA 2008b) serve to guide the classification of asbestos structures observed in Libby field samples during TEM analysis. PLM. USGS has also prepared site-specific reference materials of LA in soil for use during PLM visual area estimation analysis (EPA 2008c). These reference materials were prepared by adding aliquots of LA spiking material to uncontaminated Libby soils to obtain nominal LA concentrations of 0.2% and 1.0% (by weight). Each laboratory was provided with samples of these reference materials for use in training PLM analysts in the visual area estimation of LA levels in soil. In addition, aliquots of these reference materials (as well as other spiked soils) are also utilized as performance evaluation (PE) standards to evaluate PLM laboratory accuracy. Regular Technical Discussions Ongoing training and communication is an essential component of QA for the Libby project. To ensure that all laboratories are aware of any technical or procedural issues that may arise, a regular


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teleconference is held between EPA, their contractors, and each of the participating laboratories. Other experts (e.g., USGS) are invited to participate when needed. These calls cover all aspects of the analytical process, including sample flow, information processing, technical issues, analytical method procedures and development, documentation issues, project-specific laboratory modifications, and pertinent asbestos publications. Professional/Technical Meetings Another important aspect of laboratory team training has been the participation in technical conferences. The Libby laboratory team has convened on multiple occasions at the American Society for Testing and Materials (ASTM) Johnson Conferences in Vermont and at the ASTM Michael E. Beard Asbestos Conferences. These conferences enable the Libby laboratory and technical team members to have an on-going exchange of information regarding all analytical and technical aspects of the project, including the benefits of learning about developments by others. A8.2.3 Analyst Training TEM All TEM analysts for the Libby project undergo extensive training to understand TEM theory and the application of standard laboratory procedures and methodologies. The training is typically performed by a combination of personnel, including the laboratory manager, the laboratory QAM, and senior TEM analysts. In addition to the standard TEM training requirements, trainees involved with the Libby project must familiarize themselves with Site-specific method deviations, project-specific documents, and visual references. Standard samples that are often used during TEM training include known pure (traceable) samples of chrysotile, amosite, crocidolite, tremolite, actinolite and anthophyllite, as well as fibrous non-asbestos minerals, such as vermiculite, gypsum, antigorite, kaolinite, and sepiolite. New TEM analysts on the Libby project are also required to perform an EDS spectra characterization evaluation on the LA-specific reference materials provided during the initial training program to aide in LA mineralogy recognition and definition (similar to EPA 2008c). Satisfactory completion of each of these tasks must be approved by a senior TEM analyst. All TEM analysts are also trained in the Site-specific laboratory QA/QC program requirements for TEM (see Section B5.3.3). The entire program is discussed to ensure understanding of requirements and responsibilities. In addition, analysts are trained in the project-specific reporting requirements and data reporting tools utilized in transmitting results. Upon completion of training, the TEM analyst is enrolled as an active participant in the Libby laboratory program. A training checklist or logbook is used to assure that the analyst has satisfactorily completed each specific training requirement. It is the responsibility of the laboratory QAM to ensure that all TEM analysts have completed the required training requirements.


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PLM All PLM analysts for the Libby project are expected to be familiar with routine chemical laboratory procedures, principles of optical mineralogy, and proficient in EPA Method 600/R-93/116, National Institute of Occupational Safety and Health (NIOSH) Method 9002, California Air Resources Board (CARB) Method 435, and Site-specific SOPs SRC-LIBBY-01 and SRC-LIBBY-03. Analysts with less than one year of experience specific to the Libby project are required to participate in the laboratory mentoring program to obtain additional guidance and instruction. This training is provided by the laboratory managers and/or senior PLM analysts that are familiar with the types of asbestos and analytical challenges encountered at the Site. Before performing any Site analyses, the analyst must demonstrate the ability to generate acceptable accuracy and precision for the LA-specific reference materials.

Satisfactory completion of each of these training tasks must be approved by a senior PLM analyst. A training checklist or logbook is used to ensure that the analyst has satisfactorily completed each specific training requirement. It is the responsibility of the laboratory QAM to ensure that all analysts have completed the required training requirements. A9. DOCUMENTATION AND RECORDS A9.1 Field Documentation The field team will record sample information on the most current version of the Site-specific field sample data sheets (FSDSs)3 and chain-of-custodies (COCs)1. Section B3.1 provides detailed information on the sample documentation requirements for samples collected as part of this study. In brief, the FSDS forms document the unique sample number assigned to every sample collected as part of this program. In addition, the FSDSs provide information on whether the sample is representative of a field conditions or a field-based QC sample (e.g., field blank, field duplicate) as well as information used by the analyst to determine LA concentrations in air (i.e., pumping rate and duration). The field teams will also record information related to sample collection in a field logbook. A9.2 Laboratory All analytical data for asbestos generated in the analytical laboratory will be documented on Site-specific laboratory bench sheets. Section B4.3 provides detailed information on the requirements for laboratory documentation and records. In brief, the data recorded on the bench sheets are entered into a Site-specific electronic data deliverable (EDD) template spreadsheet developed for recording TEM and PLM results4. It is the responsibility of each laboratory to maintain logbooks and other internal records throughout the sample lifespan as a record of sample handling procedures. Upon completion of the appropriate analyses, the EDD spreadsheets, along with scanned copies of all analytical laboratory data packages, will be posted to the OU3 eRoom.

3 The most recent versions of the FSDS and COC templates are available in the Libby OU3 eRoom. 4 The most recent versions of the TEM and PLM EDDs are provided in the Libby Lab eRoom.


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A9.3 Record of Modification It is the responsibility of the field team, SPF personnel, and laboratory staff to maintain logbooks and other internal records throughout the sample lifespan as a record of sample handling procedures. Significant deviations (i.e., those that impact or have the potential to impact investigation objectives) from this SAP/QAPP, or any procedures referenced herein governing sample handling, will be discussed with the EPA RPM (or their designee) prior to implementation. Such deviations will be recorded on a Record of Modification (ROM) form. Section B5 provides detailed information on the procedures for preparing and submitting ROMs by field, SPF, and analytical laboratory personnel.


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B Data Generation and Acquisition B1. STUDY DESIGN The field investigation has been designed to determine concentrations of LA in air during source material disturbance activities in the mined area. Two trespassing ABS activities will be evaluated: 1) during ATV riding, both on-road on unpaved roads and trails and off-road in the disturbed area of the former mine, and 2) while rock hounding in the mined area. Personal air samples, representative of the breathing zone, will be collected during each ABS activity and analyzed for LA by TEM. Additionally, road material samples will be collected along the unpaved roads and trails travelled by the ATV riders, since there are limited or no data available on the nature and extent of LA in road materials. Detailed information on the sampling design is provided below. B1.1 Sampling Locations All ABS activities will be conducted within the Grace former mine property boundary. Figure A-4 identifies the disturbed area of the mine where the off-road ATV riding and rock hound ABS scenarios will be conducted (i.e., the yellow shaded “ABS Area”). To the extent practicable, ABS activities will be conducted such that the resulting data are representative of the entire disturbed area. However, ATV riding will not be performed on steep benches, tailings piles, and in impoundment areas where riding conditions would be unsafe. As noted previously, this ABS area does not include locations in the mined area where cover materials have been placed (these areas are shown in Figure A-3). The on-road ATV riding will take place along three different established routes, each encompassing a different section of the mined area. Figure A-4 identifies three ATV riding routes (i.e., Options A, B, and C) that will be travelled. Road material samples will also be collected along these three routes at 0.25-mile intervals (see Section B1.3 for details). B1.2 ABS Activities Personal air monitoring will be conducted during the ATV rider and rock hound ABS scenarios to provide measured concentrations of LA in air during representative trespasser activities in the mined area. Section B2.1 provides detailed information on how ABS air samples will be collected. Appendix C provides a detailed description of the ABS scripts that will be performed for each ABS scenario; an overview is provided below. Three ABS events will be performed on three separate days over an approximate 1-week duration. During each ABS event, both the ATV riding and rock hound scenarios will be performed. For each ABS scenario, there will be two field personnel. During ABS activities, each personnel will wear two air monitors during the activity (i.e., a high volume pump and a low volume pump) to allow for the collection of two replicate filters (i.e., each filter represents the same sample collection duration, but different total sample air volumes). Only one of the two resulting air filters will be selected for analysis, the other filter replicate will be archived (see Section B4). To minimize the potential for


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filter overloading during ABS, air cassettes will be changed every 15 minutes throughout each scenario. There will be two ATV riders during each ABS event, a leader and a follower. The distance between the leader and follower will also depend upon the terrain and amount of dust generated by the leader ATV; during previous ATV riding ABS activities, the following distances were typically between 50 and 200 yards. The ATV riders will travel at an approximate speed of 10 miles per hour or less, depending on terrain and safety considerations. Riders will follow each other throughout the duration of the ABS activity, and the leader and follower riders will switch positions every 7-8 minutes throughout the event. As such, each ATV riding air filter will be representative of a leader/follower composite exposure. Two types of ATV riding will be performed: 1) on existing roads and trails (on-road), and 2) on the disturbed area of the mine (off-road). Based on the length of the on-road ATV routes planned for travel during the ABS (see Options A, B, and C in Figure A-4), it is expected that each route can be travelled in approximately 20-30 minutes (one way). There is no set sampling duration for the on-road ATV riding scenario; the scenario will last as long as it takes to travel to the end of the route and return back to the amphitheater. Three on-road ATV riding ABS events will be performed, with each event conducted on one of the three routes. Three off-road ATV riding ABS events will be performed. Each off-road sampling event will have a total sampling duration of 45 minutes, with riders attempting to cover as much of the off-road ABS area (see yellow shaded area in Figure A-4) as possible during the sampling event. During the rock hound ABS scenario, two individuals will perform rock hound activities simultaneously. Each personnel will carry a rock hammer, or similar device, and will mimic people looking for interesting rock and mineral specimens by examining outcrops, rock faces, and waste rock piles, collecting rock specimens in a bag, and generally walking around the former mine. After conducting activities at a particular location, the personnel will drive to the next location in the ATV, leaving the sampling pumps running while driving between locations. All of the rock hound ABS will be performed on the disturbed area of the mine (see yellow shaded area in Figure A-4). Each rock hound sampling event will have a total sampling duration of 45 minutes, with ABS personnel attempting to cover as much of the ABS area as possible during each sampling event. Three rock hound ABS events will be performed. Table B-1 summarizes the basic study design and the anticipated number of ABS air samples that will be collected and analyzed for each scenario. Table B-1. Overview of the ABS Air Study Design

Scenario Location Number of ABS Air Samples Collected Total Number of ABS Air Samples

Analyzed Per Sampling Event Across All Events

ATV Riding On-road: On roads & trails (3 routes)

16 samples [2 people/event, 8 filters/person*]

48 samples [3 events (1 route per event)]

24 analyses†

Off-road: On disturbed area of mine

12 samples [2 people/event, 6 filters/person**]

36 samples [3 events] 18 analyses†


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Rock Hound On disturbed area of mine



* For each person, there will be four 15-minute filters (two high volume, two low volume) collected from the start to the end of the route and four 15-minute filters from the end of the route back to the start. This assumes it will take 30 minutes (one way) to travel the route; a total ABS scenario duration of 60 minutes. ** For each person, there will be six 15-minute filters (three high volume, three low volume) collected over the 45 minute sampling duration. † Either the high volume or the low volume filter of each sample pair will be analyzed; the remaining filter will be archived. B1.3 Soil Sampling Section B2.2 provides detailed information on how soil samples will be collected. In brief, road material samples will be collected during the first ABS event (either before or after the ABS activities) at 0.25-mile intervals from each of the three on-road ATV routes, starting at the gate on Rainy Creek Road and continuing through the end of the route. Based on the length of each route (see Figure A-4), it is anticipated that 12-15 samples will be collected from each route (approximately 42 samples total). B1.4 Study Variables ABS should be performed under conditions that have a high probability of resulting in measureable ABS air concentrations of LA. The level of LA in ABS air under source disturbance activities can depend on factors that vary seasonally (e.g., soil moisture, wind speed, humidity, etc.). It is preferable to conduct ABS sampling when the conditions for release of asbestos fibers are generally favorable, so outdoor ABS will be restricted to summer months (July-September) when rainfall and soil moisture levels are low. ABS sampling will not occur if rainfall in the past 36 hours has exceeded ¼-inch or if there is standing water present to ensure conditions are optimal for LA release from any source materials. Meteorological conditions are currently measured at the former mine by a National Oceanic Atmospheric Administration (NOAA) weather station. Each day ABS occurs, the field team leader (FTL) or data manager will download meteorological data from the local NOAA station, ZONM8, in order to document that sampling occurred during appropriate conditions. Meteorological conditions that will be reported are: Temperature (°F) Relative humidity (%) Wind speed (miles per hour [mph]) Wind gusts (mph) Wind direction Precipitation (inches)

The FTL will be responsible for evaluating environmental conditions each day sampling is to occur to determine if conditions will be appropriate to perform sampling.


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B1.5 Critical Measurements The critical measurements for this project are measurements of the concentration of LA in air during representative trespassing activities within the mined area. The analysis of LA in air may be achieved using several different types of microscopes, but EPA (2008a) recommends using TEM because this analytical method has the ability to clearly distinguish asbestos from non-asbestos structures, and to classify different types of asbestos (i.e., LA, chrysotile). In addition, analysis by TEM provides structure-specific dimensions that allow for the estimation of PCM-equivalent5 (PCME) concentrations, which is the concentration metric necessary to estimate exposure and risks. B1.6 Data Reduction and Interpretation Air samples collected in the field will be used to prepare grids for TEM examination (see Section B4). From this examination, the total number of PCME LA structures observed is recorded and the air concentration is calculated as follows:

Cair = (N ∙ EFA) / (GOx ∙ Ago ∙ V ∙ 1000 ∙ f) where:

Cair = Air concentration (structures per cubic centimeter [s/cc]) N = Number of PCME LA structures observed (structures) EFA = Effective filter area (square millimeters [mm2]) GOx = Number of grid openings examined Ago = Area of a grid opening (mm2) V = Sample air volume (liters [L])

1000 = conversion factor in liters per cubic centimeter (L/cc) f = Indirect preparation dilution factor (equal to 1 for direct preparation)

Data for PCME LA concentrations in air will be used to evaluate potential human health risks from LA for trespassers in the mined area. B2. SAMPLING METHODS, INSTRUMENTATION, AND DOCUMENTATION B2.1 Air Sample Collection Air samples will be collected, handled, and documented in basic accordance with the procedures specified in OU3-specific SOP ABS-LIBBY-OU3, Activity-based Sampling for Asbestos, (see Appendix D). In brief, a battery-powered air sampling pump (SKC model AirChek XR5000TM [0.005-5.0 L/min] or similar) will be worn by the ABS participant. The air sample cassette will be attached to

5 PCME structures have a length greater than 5 micrometers (µm), width greater than or equal to 0.25 µm, and aspect ratio (length:width) greater than or equal to 3:1.


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the pump via a plastic tube, and affixed such that the cassette is within the breathing zone of the ABS participant (approximately 5-6 feet from the ground surface). All air samples will be collected using cassettes that contain a 25-millimeter (mm) diameter mixed cellulose ester (MCE) filter with a pore size of 0.8-micrometers (µm). As noted above, each ABS personnel will wear two air monitors during the activity (i.e., a high volume pump and a low volume pump) to allow for the collection of two replicate filters; however, only one of the two resulting air filters will be selected for analysis. For all ABS scenarios, the low flow pump will be set to a flow rate of 2.0 liters per minute (L/min) and the high flow pump will be set to a flow rate of 4.0 L/min. Each air sampling pump will be calibrated at the start of each ABS period using a rotameter that has been that has been calibrated to a primary calibration source (e.g., BIOS DryCal® or similar). Section B6/B7.1.2 provides detailed information on calibrating the sampling pump. Flow checks will be performed each time a filter change occurs and at the end of the ABS period. Note this SAP/QAPP only discusses the collection of ABS air samples; as necessary, additional air samples may be collected for H&S monitoring in accordance with OSHA requirements. The sampling and analysis requirements for such samples are addressed under project HASP developed by Grace’s contractor (i.e., they are not discussed in this SAP/QAPP). B2.2 Soil Sample Collection Road material samples will be collected at 0.25-mile intervals from each of the three on-road ATV routes, starting at the gate on Rainy Creek Road and continuing through the end of the route. The distance between samples will be measured using a surveyor’s measuring wheel. At each sampling point, a single grab sample will be collected from the roadway surface to a depth of 6 inches and be free of twigs, leaves, and other vegetative material. Road material samples will only be collected during the first ABS event (either before or after the ABS activities). Grab soil samples will be collected in accordance with OU3 SOP No. 1, Soil Sampling for Non-Volatile Organic Compound Analysis (see Appendix D), with the following project-specific modifications:

• Enough material will be collected to fill about one-quarter to one-third of a gallon-size zip-top plastic bag; the goal is to collect about 700 grams of material per sample.

B2.3 Global Positioning System Coordinate Collection Global positioning system (GPS) coordinates will be recorded during the off-road ATV riding and rock hound ABS scenario track the locations were ABS activities were performed. Each ATV rider and rock hound will be equipped with a GPS unit. GPS coordinates will be automatically generated at regular intervals to document the actual locations traveled during each sampling event. Collection of GPS coordinates during the on-road ATV riding scenario is not necessary unless the routes travelled differ from those presented in Figure A-4. GPS coordinates will be collected by the field personnel for each road material sample; coordinates for each sampling location will be recorded on the Soil FSDS form.


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GPS location coordinates will be collected in general accordance with OU3-specific SOP No. 11, GPS Data Collection (see Appendix D). B2.4 Equipment Decontamination B2.4.1 Sampling Equipment Decontamination of non-disposable sampling equipment will be conducted in basic accordance with the procedures specified in OU3-specific SOP No. 7, Equipment Decontamination (see Appendix D). Materials used in the decontamination process will be disposed of as investigation-derived waste (IDW) as described below. B2.4.2 ATVs Before use in OU3, all ATVs will be thoroughly cleaned to reduce the level of effort and water needed for post-ABS decontamination. Field personnel will thoroughly decontaminate any vehicle or equipment prior to leaving the mine. A competent person will inspect decontaminated vehicles prior to leaving the decontamination pad. Before being taken off use from the project or before use in a clean area, all ATVs must undergo a full interior and exterior decontamination by the designated personnel. Full decontamination includes pressurized washing of all surfaces, cleaning the interior of the engine compartment, cleaning of the undercarriage, removing floor mats (if present), and an extensive cleaning and wipe-down of the interior surfaces. In addition, designated personnel will remove, replace, and dispose of any air filters (air-intake, cab, etc.). Filters will be disposed of as asbestos-containing material (ACM). An inspector will evaluate and document the decontamination before moving or using the equipment. The inspector will fill out a Decontamination Checklist (see Appendix E). A copy of this form will be posted to the OU3 eRoom along with the field sample documentation. B2.5 Handling Investigation-derived Waste Any disposable equipment or other IDW will be handled in basic accordance with the procedures specified in OU3-specific SOP No. 12, IDW Management (see Appendix D). In brief, IDW will be double bagged in clear heavy-weight trash bags with ‘IDW’ written, in large letters at least 3 inches high, in indelible ink on at least two sides of the outer bag. All IDW generated during this sampling program will enter the waste stream at the local class IV asbestos landfill.


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B3. SAMPLE HANDLING AND CUSTODY B3.1 Sample Documentation B3.1.1 Field Sample Data Sheets and Logbooks As noted previously in Section A9, the field team will record sample information for all ABS air samples in accordance with the procedures specified in OU3-specific SOP No. 9, Field Documentation (see Appendix D) with the following project-specific modifications:

• Samples for this project will be documented on the study-specific FSDS forms, as provided in Appendix F.

• Use of large container labels (in addition to sample identification [ID] labels) is not

required. The field logbook is an accounting of activities at the Site and will duly note problems or deviations from the governing SAP/QAPP or SOPs. Separate field logbooks will be kept for each study and the cover of each field logbook will clearly indicate the name of the associated study. FSDSs and field logbooks will be completed prior to leaving a sampling location. FSDSs and Field logbooks will be checked for completeness and correctness on a daily basis by the FTL or their designate. When an incorrect entry onto the FSDS or in the field logbook is discovered during these checks, the errors will be discussed with the author of the entry and corrected. Erroneous information recorded in a field logbook and FSDS will be corrected with a single line strikeout, initial, and date. The correct information will be entered in close proximity to the erroneous entry. In addition, the nature of the materials and conditions under which the study is conducted will be documented in the field logbook. This information includes but is not limited to, qualitative description of ABS area (e.g., dusty conditions, terrain), presence of materials which are likely high concentration sources of LA, wind direction, and meteorological conditions. B3.1.2 Photographic and Video Documentation Photographs will be taken to document representative examples of sampling locations and site conditions during air sampling activities, and at any other location the field sampling personnel determine necessary, using a digital camera. As appropriate, digital video may be captured to document representative examples of ABS activities. Electronic copies of all digital photographs and videos will be posted to the OU3 eRoom. The file name should include the corresponding sampling location and/or sample number and the photograph/video date (e.g., OU3ATV-0001_09-21-15). B3.2 Sample Labeling and Identification Samples will be labeled with sample ID numbers supplied by field administrative staff and will be signed out by the sampling teams. For air samples, one sample label will be placed on the sampling cassette, one sample label will be affixed to the inside of the plastic bag used to hold the sampling cassette during transport. In addition, the sample ID number will also be written on the outside of


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the plastic bag and on the FSDS. For road material samples, the labels will be affixed to the outside of both the inner and outer sample bags and the sample ID number will be written on the outside of each bag. Sample ID numbers will identify the samples collected during this sampling effort using the following format: TS-##### where:

TS- = A sample ID prefix to identify samples collected under this Trespasser ABS SAP/QAPP ##### = A sequential five-digit number B3.3 Field Sample Custody Field sample custody will follow the requirements specified in OU3-specific SOP No. 9 (see Appendix D). In brief, all teams will ensure that samples, while in their possession, are maintained in a secure manner to prevent tampering, damage, or loss. All samples and FSDSs will be relinquished by field staff to the field sample coordinator, the SPF, or a designated secure sample storage location at the end of each day. B3.4 Chain of Custody The COC record is employed as physical evidence of sample custody and control. This record system provides the means to identify, track, and monitor each individual sample from the point of collection through final data reporting and to identify the type of analysis requested. A completed OU3-specific COC form is required to accompany each shipment of samples. Sample custody will be maintained until final disposition of the samples by the laboratory and acceptance of analytical results by the EPA. OU3-specific COC forms can be obtained from the OU3 eRoom (an example of this form is provided OU3-specific SOP No. 9; see Appendix D). In brief, the field sample coordinator will prepare a hard copy COC form using the 3-page carbon copy forms developed specifically for use in OU3. One copy of the COC will be retained by the field sample coordinator and the other two copies (including the original) of the COC will accompany the sample shipment. All required paper work, including sample container labels, COC forms, custody seals, and shipping forms will be fully completed in indelible ink (or printed from a computer) prior to sending samples to the laboratory. No more than 12 samples may be included on a single COC form; a unique COC number will be assigned to each COC form (see SOP No. 9 for specific details on assigning a unique COC number). The appropriate analytical requirements summary sheet identifier and media code (see Section B4 and Appendix G) will be referenced on each COC. Each COC form will include signatures of the appropriate individuals indicated on the form. In addition, the air volume for each sample should be recorded on the COC form. All samples that may


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require special handling by laboratory personnel to prevent potential exposure to LA or other hazardous substances will be clearly labeled. If any errors are found on a COC after shipment, the hard copy of the COC retained by the field sample coordinator will be corrected and a corrected COC will be provided to the LC for distribution to the appropriate laboratory. All corrections to the COC form will be initialed and dated by the person making the corrections. B3.5 Sample Packaging and Shipping Samples will be packaged and shipped in basic accordance with the procedures specified in OU3-specific SOP No. 8, Sample Handling and Shipping (see Appendix D), with the following project-specific modifications:

• For ABS air samples, a custody seal will be applied to each cassette and the cassette will be placed into a plastic zip-top bag. All of the bagged cassettes associated with a single COC form will be placed into a larger gallon-size zip-top plastic bag. The associated COC form will be included in the bag.

• For soil samples, all of the bagged soil samples will be placed into a cooler (or large box). The associated COC forms for all the associated samples will be placed inside a gallon-size zip-top bag and included inside the cooler. Custody seals will be placed on opposites sides of the cooler across the seam of the lid and the cooler body.

The field sample coordinator will hand-deliver all samples to the SPF in Troy, Montana:

ESATR8-Troy Soil Prep Facility 303 N. 3rd Street Troy, Montana 59935 406-295-9151 Contact: Andrea Wandler

Prior to sealing the shipping container, the field sample coordinator will complete the bottom of the COC record and retain the bottom copy of the COC record for the project record. The LC will instruct the Troy SPF sample coordinator as to the appropriate laboratory for each sample shipment. For the purposes of this sampling investigation, it is anticipated that all samples will be shipped to one of the following labs for analysis:

Laboratory Contact Phone Address Contact email

ESATR8 Doug Kent / Nathan DelHierro

(303) 312-7725 / (303)-312-7790

16194 W 45th Drive Golden, CO 80403

[email protected] [email protected]

EMSL22 - Denver Barbara Shepherd (303) 740-5700 1010 Yuma Street Denver, CO 80204 [email protected]

EMSL04 - Cinnaminson

Robyn Ray / Steven Seigel

(856) 303-2556 / (856) 303-2555

200 Route 130 North Cinnaminson, NJ 08077



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Laboratory Contact Phone Address Contact email

EMSL03 - Manhattan

James Hall / Jose Arriaga

(646) 430-8584 / (866) 448-3675

307 W 38th Street, Suite 901 New York, NY 10018


EMSL45 – Sierra Madre

Kyeong Corbin / Arturo Casas (626) 355-4711 82 W. Sierra Madre Blvd

Sierra Madre, CA 91024 [email protected] [email protected]

Samples will be shipped via an overnight delivery service using a commercial carrier (e.g., FedEx). B3.6 Holding Times There are no holding time requirements for air and soil samples collected as part of this sampling investigation. B3.7 Archival and Final Disposition All samples, including air filters, TEM grids, and archived soil fractions, will be maintained in storage at the analytical laboratory unless otherwise directed by EPA. When authorized by EPA, the laboratory will be responsible for proper disposal of any remaining samples, sample containers, shipping containers, and packing materials in accordance with sound environmental practice, based on the sample analytical results. The laboratory will maintain proper records of waste disposal methods, and will have disposal company contracts on file for inspection. B4. ANALYTICAL METHODS This section discusses the analytical methods and requirements for samples collected in support of this investigation. This section includes detailed information on the analysis of air as well as the data reporting requirements, sample holding times, and custody procedures. An analytical requirements summary sheet (TRESOU3-0915), which details the specific preparation and analytical requirements associated with this investigation, is provided in Appendix G. The analytical requirements summary sheet will be reviewed and approved by all participating laboratories in this sampling program prior to any sample handling. The appropriate analytical requirements summary sheet identifier and media code (i.e., TRESOU3-0915, Media Code A) will be referenced on each COC. B4.1 Analysis of LA in Air The DQOs for this SAP/QAPP (see Appendix B) provide detailed information on the sample preparation, analysis method, counting rules, and stopping rules for air samples. All air samples collected during this investigation will be analyzed by TEM using International Organization for Standardization (ISO) Method 10312:1995(E) (ISO 1995). Analysis requirements for the TEM analysis are summarized below.


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B4.1.1 Sample Preparation As described above, for the personal ABS air samples, two filter replicates are collected for each sampling interval – a high volume filter and a low volume filter. The high volume filter will be analyzed in preference to the low volume filter. The high volume filter will be used to prepare a minimum of three grids using the grid preparation techniques described in Section 9.3 of ISO 10312:1995(E). If the high volume filter is deemed to be overloaded (i.e., > 25% particulate loading on the filter), the low volume filter will be analyzed in preference to performing an indirect preparation on the high volume filter. If the low volume filter is also deemed to be overloaded, an indirect preparation (with ashing) will be performed of the high volume filter in accordance with the procedures in Libby-specific SOP EPA-LIBBY-08, Indirect Preparation of Air and Dust Samples for Analysis by TEM (see Appendix D), as modified by Libby-specific laboratory ROM6 #LB-000091. The resulting secondary filter will be used to prepare a minimum of three grids using the grid preparation techniques described in Section 9.3 of ISO 10312:1995(E). B4.1.2 Analysis Method and Counting Rules Grids will be examined by TEM in basic accordance with the recording procedures described in Annex E of ISO 10312:1995(E), as modified by the most recent versions of Libby laboratory ROMs #LB-000016, LB-000029, LB-000066, LB-000067, and LB-000085. In brief, grids will be examined by TEM under low magnification (~5,000x), recording only those structures that meet PCME counting rules. All amphibole structures that have appropriate selected area electron diffraction (SAED) patterns and EDS spectra, and having length > 5 µm, width greater than or equal to (≥) 0.25 µm, and an aspect ratio (length:width) ≥ 3:1, will be recorded. Detailed structure results for each grid opening and structure examined will be recorded on the benchsheet and entered into the Site-specific TEM EDD spreadsheet developed for reporting air sample results. If observed, chrysotile structures will be recorded using the same procedures described above, but structure recording may stop after 25 chrysotile structures have been observed. B4.1.3 Stopping Rules Appendix B provides detailed information on the derivation of the stopping rules for ABS air field samples analyzed by TEM. The stopping rules are as follows:

1. Examine a minimum of two grid openings from each of two grids.

2. Continue examining grid openings until one of the following is achieved:

a. The target analytical sensitivity (0.006 per cubic centimeter [cc-1] for ATV rider ABS and 0.004 cc-1 for rock hound ABS) is achieved.

b. 25 PCME LA structures have been observed.

6 Copies of all Libby-specific laboratory ROMs are located on the Libby Lab eRoom. Trespasser ABS QAPP Revision 0 – 9/16/15

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c. A total filter area of 4.0 mm2 has been examined (this is approximately 400 grid openings).

When one of these criteria has been satisfied, complete the examination of the final grid opening and stop. For lot blanks and field blanks, the TEM analyst should examine an area of 0.1 mm2 (approximately 10 grid openings). For lot blanks, the TEM analysis should be performed using Asbestos Hazard Emergency Response Act (AHERA) counting and recording rules (EPA 1987), using a modified aspect ratio rule of 3:1. B4.2 Analysis of LA in Soil B4.2.1 Sample Preparation Prior to analysis, all soil samples will be prepared at the SPF in Troy, MT. All soil samples will be dried as detailed in Site-specific SOP 16-ASB-06.02, Soil Sample Preparation at the Troy Sample Preparation Facility (see Appendix D). To avoid burning of the soil samples during the drying process, the soil samples will be visually screened before they are loaded into the oven. Samples that appear to have elevated organic matter (i.e., a significant amount of vegetation/sticks/roots) pose a risk of igniting during the drying process. The samples will be checked every 4 hours to ensure that they are not burning. Each sample will be split into two approximately equal portions: 1) archive; 2) PLM aliquot. The PLM aliquot will be prepared in accordance with SOP 16-ASB-06.02. In brief, the PLM aliquot is sieved into coarse (greater than ¼ -inch) and fine fractions. The fine fraction is ground to reduce particles to a diameter of 250 μm or less; this fine-ground portion is then split into four aliquots. Thus, there will be multiple aliquots generated for each soil sample, all of which will be sent to the analytical laboratory. The analytical laboratory should do the following for each aliquot: A (archive) – place sample in archive C (coarse) – analyze sample by PLM (see Section B4.2.2) FG1 (fine ground aliquot #1) – analyze sample by PLM (see Section B4.2.2) FG2-4 (fine ground aliquots #2 to #4) – place samples in archive B4.2.2 Analysis Method One aliquot of the fine-ground sample will be analyzed for asbestos by PLM using visual area estimation (PLM-VE) in accordance with SOP SRC-LIBBY-03, as modified by the most recent version of Libby laboratory ROMs #LB-000073 and LB-000097. If there is a coarse fraction of the sample, it will be analyzed for asbestos by PLM using gravimetric analysis (PLM-Grav) in accordance with SOP SRC-LIBBY-01. The analysis request section of the COC record will indicate the requested analyses (e.g., PLM-VE/PLM-Grav). It is the responsibility of the SPF to specify the appropriate analytical method as it


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corresponds to the specific sample fraction being submitted for analysis (i.e., PLM-VE for fine-ground fractions or PLM-Grav for coarse fractions) on the COC record that is submitted to the analytical laboratory. B4.3 Data Reporting All TEM and PLM results, including analysis preparation information, structure-specific details, and air concentrations, will be submitted using the most recent version of the EDDs7 in use at the Libby site. Standard project data reporting requirements will be met for this dataset. Upon completion of the appropriate analyses, EDDs will be posted to the Libby OU3 eRoom within the appropriate turn-around time. Files should be posted to the folder titled “Trespasser ABS”. An analytical data report will be prepared by the laboratory after the completion of all required analyses within a specific laboratory job (or sample delivery group). This analytical data report may vary by laboratory and analytical method but generally includes a case narrative that briefly describes the number of samples, the analyses, and any analytical difficulties or QA/QC issues associated with the submitted samples. The data report will also include copies of the signed COC forms, analytical data summaries, a QC package, and raw data. Raw data is to consist of instrument preparation logs, instrument printouts, and QC sample results including, instrument maintenance records, COC check in and tracking, raw data instrument print outs of sample results, analysis run logs, and sample preparation logs. Hard copies of all analytical laboratory data packages will be scanned and posted as a pdf file to the Libby OU3 eRoom. File names for scanned analytical laboratory data packages will include the laboratory name and the job number to facilitate document organization (e.g., LabX_12345-A.pdf). If the analytical laboratory data package is revised, this should be denoted with a suffix in the file name (e.g., LabX_12345-A_Rev1.pdf). All original data records (both hard copy and electronic) will be cataloged and stored in their original form until otherwise directed by EPA. B4.4 Analytical Turn-around Time Analytical turn-around time will be negotiated between the EPA LC and the laboratory. It is anticipated that turn-around times of 2-4 weeks are acceptable, but this may be revised as determined necessary by EPA. B4.5 Custody Procedures Specific laboratory custody procedures are provided in each laboratory’s Quality Assurance Management Plan, which have been independently reviewed at the time of laboratory procurement. While specific laboratory sample custody procedures may differ between laboratories, the basic laboratory sample custody process is described briefly below. Upon receipt at the facility, each sample shipment will be inspected to assess the condition of the shipment and the individual samples. This inspection will include verifying sample integrity. The

7 The most current version of all EDDs are provided in the Libby Lab eRoom. Trespasser ABS QAPP Revision 0 – 9/16/15

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accompanying COC record will be cross-referenced with all of the samples in the shipment. The laboratory sample coordinator will sign the COC record and maintain a copy for their project files. Depending upon the laboratory-specific tracking procedures, the laboratory sample coordinator may assign a unique laboratory identification number to each sample on the COC. This number, if assigned, will identify the sample through all further handling at the laboratory. It is the responsibility of the laboratory manager to ensure that internal logbooks and records are maintained throughout sample preparation, analysis, and data reporting. B5. QUALITY ASSURANCE/QUALITY CONTROL B5.1 Field Field QA/QC activities include all processes and procedures that have been designed to ensure that field samples are collected and documented properly, and that any issues/deficiencies associated with field data collection or sample processing are quickly identified and rectified. The following sections describe each of the components of the field QA/QC program implemented at the Site. B5.1.1 Training

Before performing field work in Libby, field personnel are required to read all governing field guidance documents relevant to the work being performed and attend a field planning meeting specific to the trespasser ABS field event. Additional information on field training requirements is provided in Section A8.1. B5.1.2 Modification Documentation

Minor deviations (i.e., those that will not impact data quality or usability) encountered in day-to-day field work will be noted in the field logbook. Major deviations from this SAP/QAPP that modify the sampling approach and associated guidance documents will be recorded on a ROM form (see Appendix H). Field ROMs will be completed by the FTL, or by assigned field or technical staff. Each completed ROM is assigned a unique number that is specific to each investigation (e.g., OU3 Trespasser LFM-OU3-01) by the EPA RPM or their delegate. Once a form is prepared, it is submitted to the EPA RPM for review and approval. Copies of approved ROMs are available in the OU3 eRoom and are posted to the OU3 website. B5.1.3 Field QC Samples

Air Two types of field QC samples will be collected as part of the air sampling portion of this program – lot blanks and field blanks.


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Lot Blanks Lot blanks are collected to ensure air samples for asbestos analysis are collected on asbestos-free filters. This will be accomplished by selecting two lot blanks at random from the group of cassettes (manufactured lot) to be used for collection of air samples. It is the responsibility of the FTL to submit the appropriate number of lot blanks to the laboratory prior to cassette use in the field. Each lot blank will be analyzed for asbestos by TEM analysis as described above (see Section B4.1). Lot blank results will be reviewed by the FTL before any cassette in the lot is used for sample collection. The entire batch of cassettes will be rejected if any asbestos is detected on either lot blank. Once the lot is confirmed to be asbestos free (i.e., asbestos is not detected on either lot blank), that lot may be placed into use for sampling. Only filter lots with acceptable lot blank results are placed into use for the air sampling effort. Field Blanks Field blanks are collected to evaluate potential contamination introduced during sample collection, shipping and handling, or analysis. It is the responsibility of each field team to collect the appropriate number of field blanks. A field blank for air shall be prepared by removing the sampling cassette from the box, opening the cassette to the air in the area where the investigative samples will be taken for about 30 seconds, then closing the cassette and packaging for shipment and analysis. Field blanks will be collected at a rate of one field blank per day, when air sampling is occurring. It is anticipated that a total of three field blanks will be collected; one of the three field blanks will be randomly selected by the FTL for analysis, the other two samples will be archived for possible future analysis. Field blanks will be analyzed for LA by TEM analysis as described above (see Section B4.1). Field blank results will be evaluated by CDM Smith when they are summarized as part of the study data summary report. If any asbestos is observed on a field blank, the other two archived field blanks will be sent for analysis and the FTL and/or laboratory manager will be notified to take appropriate measures (e.g., re-training on sample collection and analysis procedures) to ensure staff are employing proper sample handling techniques for future studies8. A qualifier of “FB” will be added to the related field sample results in the project database to denote that the associated field blank had asbestos structures detected. Any assigned qualifiers will be included when results are reported. Soil Field duplicate samples of road materials will be collected at a frequency of 10% (1 per 10 field samples). The field duplicate is collected using the same collection technique as the parent sample. The field duplicate should be collected at the same approximate location as the parent sample (i.e., within one foot of the parent sampling location). It is the responsibility of the FTL to ensure that the appropriate number of field duplicates are collected. The field duplicate is given unique sample

8 Due to the short timeframe of this study, it will not be possible to use the results of field QC samples to make any real-time adjustments in this study. Field QC results will be used to qualify results for this study, as appropriate, and to identify potential sampling and analysis issues for future studies.


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number, and field personnel will record the sample number of the associated co-located sample in the parent sample number field of the FSDS. The same station location is assigned to the field duplicate sample as the parent field sample. Field duplicates will be sent for analysis by the same method as field samples and are blind to the analytical laboratories (i.e., the laboratory cannot distinguish between field samples and field duplicates). Field duplicate results will be evaluated by CDM Smith when they are summarized as part of the study data summary report. Field duplicate results analyzed by PLM-VE will be considered concordant if the reported semi-quantitative bin result for the field duplicate is within one bin of the original parent field sample. The variability between the field duplicate and the associated parent field sample reflects the combined variation in sample heterogeneity and the variation due to measurement error. Because field duplicate samples are expected to have inherent variability that is random and may be either small or large, typically, there is no quantitative requirement for the agreement of field duplicates. Rather, results are used to determine the magnitude of this variability to evaluate data usability. In general, if results are discordant, the data usability assessment should alert data users to this inherent variability. B5.2 Soil Preparation Facility B5.2.1 Training and Personnel Requirements Personnel performing sample preparation activities must have read and understood the Soil Sample Preparation Work Plan, the SPF HASP, and all associated SOPs and governing documents for soil preparation. Additional information on SPF personnel requirements is provided in Section A8.2. B5.2.2 Modification Documentation When changes or revisions are needed to improve or document specifics about sample preparation procedures used by the Troy SPF, these changes are documented using a laboratory ROM form (see Appendix H). The ROM form provides a standardized format for tracking procedural changes in sample preparation and allows project managers to assess potential impacts on the quality of the data being collected. SPF ROMs will be completed by the appropriate SPF or technical staff. Once a form is prepared, it is submitted to the ESAT QAM (or their designate) for review. Final review and approval is provided by the appropriate EPA RPM. Copies of approved SPF ROMs are available in the Libby Lab eRoom (https://team.cdm.com/eRoom/mt/LibbyLab). B5.2.3 Preparation QC Samples

Four types of preparation QC samples are collected during the soil preparation process: sand blanks, drying blanks, grinding blanks, and preparation duplicates. Each type of preparation QC sample is described in more detail below.


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https://team.cdm.com/eRoom/mt/LibbyLab

Sand Blank A sand blank is a sample of store-bought quartz sand that is analyzed to ensure that the quartz sand matrix used for drying and grinding blanks is asbestos-free. Detailed procedures for this certification process are provided in ESAT SOP PLM-02.00, Blank Sand Certification by Polarized Light Microscopy. In brief, for each bag of sand, about 800 grams of sand are removed and split into 40 sand blank aliquots of roughly equal size. Each sand blank is evaluated using stereomicroscopic examination and analyzed by PLM-VE. If a sand blank has detected asbestos, it is re-analyzed by a second PLM analyst to verify the presence of asbestos. The sand is certified as asbestos-free if all 40 sand blanks are non-detect for asbestos. The entire bag of sand is rejected for use if any asbestos is detected in the sand blanks. Only sand bags that are certified as asbestos-free will be utilized in the SPF. Drying Blank A drying blank consists of approximately 100 to 200 grams of asbestos-free quartz sand that is processed with each batch of field samples that are dried together (usually this is approximately 125 samples per batch). The drying blank is then processed identically to field samples. Drying blanks determine if cross-contamination between samples is occurring during sample drying. One drying blank will be processed with each drying batch per oven. It is the responsibility of the SPF QAM to ensure that the appropriate number of drying blanks is collected. Each drying blank is given unique sample number that is investigation-specific, as provided by the field sample coordinator (i.e., a subset of sample numbers for each investigation will be provided for use by the SPF). SPF personnel will record the sample number of the drying blank on the sample drying log sheet. It is the responsibility of the QATS contractor to review the drying blank results and notify the SPF QAM immediately if drying blank results do not meet acceptance criteria and if corrective actions are necessary. If asbestos is detected by PLM-VE in the drying blank, a qualifier of “DB” will be added to the related field sample results in the project database that were dried at the same time as the detected drying blank to denote that the associated drying blank had detected asbestos. In addition, the drying oven will be thoroughly cleaned. If asbestos continues to be detected in drying blanks after cleaning occurs, sample processing must stop and the drying method and decontamination procedures will be evaluated to rectify any cross-contamination issues. Grinding Blank A grinding blank consists of asbestos-free quartz sand and is processed along with the field samples on days that field samples are ground. Grinding blanks determine if decontamination procedures of laboratory soil processing equipment used for sample grinding and splitting are adequate to prevent cross-contamination. Grinding blanks are prepared at a frequency of one per grinding batch per grinder per day. It is the responsibility of the SPF QAM to ensure that the appropriate number of grinding blanks are collected. Each grinding blank is given unique sample number that is investigation-specific, as provided by the field sample coordinator. SPF personnel will record the sample number of the grinding blank on the sample preparation log sheet.


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It is the responsibility of the QATS contractor to review the grinding blank results and notify the SPF QAM immediately if drying blank results do not meet acceptance criteria and if corrective actions are necessary. If any asbestos is detected by PLM-VE in the grinding blank, a qualifier of “GB” will be added to the related field sample results in the project database that were ground at the same time as the detected grinding blank to denote that the associated grinding blank had detected asbestos. In addition, the grinder will be thoroughly cleaned. If asbestos continues to be detected in grinding blanks after cleaning occurs, sample processing must stop and the grinding method and decontamination procedures will be evaluated to rectify any cross-contamination issues. Preparation Duplicate Preparation duplicates are splits of field samples submitted for sample preparation. The preparation duplicates are used to evaluate the variability that arises during the soil preparation and analysis steps. After drying, but prior to sieving, a preparation duplicate is prepared by using a riffle splitter to divide the field sample (after an archive split has been created) into two approximately equal portions, creating a parent and duplicate sample. Preparation duplicate samples are prepared at a rate of 5% (1 per 20 samples) of samples prepared. It is the responsibility of the SPF QAM to ensure that the appropriate number of preparation duplicates is prepared. Each preparation duplicate is given unique sample number that is investigation-specific, as provided by the field sample coordinator. SPF personnel will record the sample number of the preparation duplicate and its associated parent field sample on the sample preparation log sheet. Preparation duplicates are submitted blind to the laboratory for analysis by the same analytical method as the parent sample. Preparation duplicate results will be considered concordant if the reported PLM bin for the preparation duplicate is within one bin of the original parent field sample. The variability between the preparation duplicate and the associated field sample reflects the combined variation due to sample preparation and due to measurement error. Results for preparation duplicate samples are evaluated by the QATS contractor or their designate. If the concordance rate for preparation duplicate samples is less than 10%, the QATS contractor will notify the SPF QAM to determine if corrective action is needed. B5.2.4 Inter-laboratory Samples

Beginning in 2015, inter-laboratory samples for PLM-VE analysis are selected automatically by the Troy SPF at the time of sample processing. One of the fine, ground aliquot is inserted into the sample train during soil sample processing. It is the responsibility of the SPF QAM to ensure that the appropriate number of inter-laboratory samples are inserted. Samples will be selected in accordance with the most recent version of Libby laboratory ROM #LB-000073.


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B5.2.5 Performance Evaluation Standards

The USGS has prepared several Site-specific reference materials of LA in soil that are utilized as PE standards to evaluate PLM-VE laboratory accuracy and precision. These PE standards are kept in storage at the Troy SPF and are inserted into the sample train during soil sample processing. PE standards of varying nominal levels will be inserted at a rate of at least one per month per PLM laboratory when soil processing is occurring. It is the responsibility of the SPF QAM to ensure that the appropriate number of PE standards is inserted. Each PE standard is given unique sample number that is investigation-specific, as provided by the field sample coordinator. SPF personnel will record the sample number of the PE standard, the nominal level of the PE standard, and whether it was inserted pre- or post-processing on the sample preparation log sheet. PE standards are submitted blind to the laboratory for analysis by the same analytical method as the field samples. Results for PE standards will be evaluated by the QATS contractor or their designate. PE standard results are ranked as acceptable if the correct semi-quantitative bin is reported, as determined by the nominal concentration of the PE standard. The LC should be notified if PE standard results do not meet acceptance criteria. Corrective action will be taken if the PE standards demonstrate issues with accuracy and/or bias in PLM-VE results reporting. Examples of corrective actions that may be taken include reanalysis and/or repreparation, collaboration between and among laboratories to address potential differences in analysis methods, and analyst re-training.

B5.3 Analytical Laboratories Laboratory QA/QC activities include all processes and procedures that have been designed to ensure that data generated by an analytical laboratory are of high quality and that any problems in sample preparation or analysis that may occur are quickly identified and rectified. The following sections describe each of the components of the analytical laboratory QA/QC program implemented at the Site. B5.3.1 Training/Certifications

All analytical laboratories participating in the analysis of samples for the Libby project are subject to national, local, and project-specific certifications and requirements. Additional information on laboratory training and certification requirements is provided in Section A8.3. Laboratories handling samples collected as part of this sampling program will be provided a copy of and will adhere to the requirements of this SAP/QAPP. Samples collected under this SAP/QAPP will be analyzed in accordance with standard EPA and/or nationally-recognized analytical procedures (i.e., Good Laboratory Practices) in order to provide analytical data of known quality and consistency.


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B5.3.2 Modification Documentation

When changes or revisions are needed to improve or document specifics about analytical methods or procedures used by the laboratory, these changes are documented using the Libby laboratory ROM form (see Appendix H). The ROM form provides a standardized format for tracking procedural changes in sample analysis and allows project managers to assess potential impacts on the quality of the data being collected. Laboratory ROMs will be completed by the appropriate laboratory or technical staff. Once a form is prepared, it is submitted to the EPA RPM and the LC for review and approval. Copies of approved laboratory ROMs are available in the Libby Lab eRoom. B5.3.3 Laboratory QC Analyses

Samples collected under this SAP/QAPP will be processed and analyzed in accordance with standard EPA and/or nationally-recognized analytical procedures (i.e., Good Laboratory Practices) in order to provide analytical data of known quality and consistency. Specific QA/QC procedures are provided in the respective QA management plan or facilities operations plan for each facility that processes or analyzes Site samples. Additionally, for asbestos analysis, the following laboratory QC analyses will be performed for TEM. TEM The Libby-specific QC requirements for TEM analyses of asbestos are patterned after the requirements set forth by NVLAP. In brief, there are three types of laboratory-based QC analyses that are performed for TEM – laboratory blanks, recounts, and repreparations. Detailed information on the Libby-specific requirements for each type of TEM QC analysis, including the minimum frequency rates, selection procedures, acceptance criteria, and corrective actions are provided in the most recent version of Libby laboratory ROM #LB-000029, with the following investigation-specific modification:

• The TEM QC frequency requirements specified in Libby laboratory ROM #LB-000029 are to be specific to each laboratory and applicable across all media and investigations conducted in OU3.

PLM Laboratory QC for PLM-Grav is ensured through compliance with laboratory-based QC requirements for the NIOSH Method 9002, as specified by NVLAP. No additional project-specific QC requirements have been established for PLM-Grav. Laboratory-based QC requirements for PLM-VE are specified in SOP SRC-LIBBY-03. Three types of laboratory-based QC analyses are performed for PLM-VE, including laboratory duplicates, inter-laboratory analyses (see Section B5.2.4), and PE standards (see Section B5.2.5). Detailed information on the Libby-specific requirements for each type of PLM-VE QC analysis, including the


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minimum frequency rates, selection procedures, acceptance criteria, and corrective actions are provided in SOP SRC-LIBBY-03, with the following investigation-specific modifications:

• The PLM laboratory QC frequency requirements are to be specific to each laboratory and applicable across all media and investigations conducted in OU3.

It is the responsibility of the laboratory manager to ensure that the proper number of PLM-VE laboratory duplicate analyses are completed. Inter-laboratory analyses and PE standards for PLM-VE are inserted automatically by the Troy SPF at the appropriate frequencies and are blind to the analytical laboratory. B6/B7. EQUIPMENT MAINTENANCE AND INSTRUMENT CALIBRATION

B6/B7.1 Field Equipment B6/B7.1.1 Field Equipment Maintenance

All field equipment (e.g., sampling pumps) will be maintained and calibrated in basic accordance with manufacturer specifications. When a piece of equipment is found to be operating incorrectly, the piece of equipment will be labeled “out of order” and placed in a separate area from the rest of the sampling equipment. The person who identified the equipment as “out of order” will notify the FTL overseeing the investigation activities. It is the responsibility of the FTL to facilitate repair of the “out of order” equipment. This may include having appropriately trained field team members complete the repair or shipping the malfunctioning equipment to the manufacturer. Field team members will have access to basic tools required to make field acceptable repairs. This will ensure timely repair of any “out of order” equipment. B6/B7.1.2 Air Sampling Pump Calibration

Each air sampling pump will be calibrated at the start of each ABS sampling period using the primary calibration source (e.g., BIOS DryCal® or similar) or a rotameter that has been that has been calibrated to a primary calibration source in accordance with manufacturer recommendations. For pre-sampling purposes, calibration will be considered complete when the measured flow is within ±5% of the target flow, as determined by the mean of three measurements with the calibrator using a cassette reserved for calibration (from the same lot as the sample cassettes to be used in the field). Additional calibration may be performed during sample collection as described below. If at any time the observed flow rates during sampling are greater than ±10% of the target rate, the sampling pump should be re-calibrated, if possible. If at any time an air sampling pump is found to have faulted or the observed flow rates are 25% below (due to heavy particulate loading or a pump malfunction) or 50% above the target rate, the pump will be replaced or the activity will be terminated. Collection of air samples will continue, regardless of the amount of particulate loading on the filters, unless the flow rate is affected. At the beginning of the sampling program, flow rates


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and particulate loading may be checked more frequently as conditions require, establishing expected conditions. To calculate the percentage of an observed flow to the target flow, the following formula is used:

100)/(

)/(% ⋅=inmLRateFlowgetTar

inmLRateFlowObservedX

For post-sampling calibration, three separate constant flow calibration readings will be obtained with the sampling cassette inline and those flow readings will be averaged. If the flow rate changes by more than 5% during the sampling period, the average of the pre- and post-sampling rates will be used to calculate the total sample volume. Samples for which there is more than a 30% difference from initial calibration to end calibration will be invalidated and recollected, if possible. The sample collector will record the pump serial number, sample number, initial flow rate, sample start/end times, sample locations, and final flow rate, as well as mark the sample "void" in the field logbook and FSDS. These samples will not be submitted for analysis. To prevent potential cross-contamination, each rotameter used for field calibration will be transported to and from each sampling location in a sealed zip-top plastic bag. The cap and calibration cassette used at the end of the rotameter tubing will be replaced each day after it is used. B6/B7.2 SPF and Analytical Laboratory Instruments The laboratory manager is responsible for ensuring that all laboratory instruments used for this project are maintained and calibrated in accordance with the manufacturer’s instructions. If any deficiencies in instrument function are identified, all analyses shall be halted until the deficiency is corrected. The laboratory shall maintain a logbook that documents all routine maintenance and calibration activities, as well as any significant repair events, including documentation that the deficiency has been corrected. B8. INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES B8.1 Field Supplies In advance of field activities, the FTL (or designee) will check the field equipment/supply inventory and procure any additional equipment and supplies that are needed. The FTL will also ensure any in-house measurement and test equipment used to collect data/samples as part of this SAP/QAPP is in good, working order, and any procured equipment is acceptance tested prior to use. Any items that the FTL determines unacceptable will be removed from inventory and repaired or replaced as necessary.


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The following list summarizes the general equipment and supplies required for most investigations: FSDSs – Medium-specific forms that are used to document sample details (i.e., sampling

location, sample number, medium, field QC type, etc.). See Section B3.1 for standard procedures for the completion of FSDSs.

COCs – OU3-specific form that are used to document the requested analysis for each sample and sample custody. See Section B3.4 for COC procedures.

Field logbook – Used to document field sampling activities and any problems in sample collection or deviations from the investigation-specific SAP/QAPPs. See Section B3.1 for standard procedures for field logbooks.

Sample number labels – Sample numbers are sequential numbers with investigation-

specific prefixes. Sample number labels are pre-printed and checked out to the field teams by the FTL or their designee. To avoid potential transcription errors in the field, multiple labels of the same sample number are prepared – one label is affixed to the collected sample and one label is affixed to the hard copy FSDS form. Labels may also be affixed to the field logbook.

Indelible ink pen – Used to complete information on the FSDS and in the field logbook

(pencil may not be used), and to write sample numbers on the sample containers. Personal protective equipment - As required by the project HASP.

Land survey map or aerial photo – Used to identify appropriate sampling locations. In some

cases, sketches may be added to the map/photo to designee sampling and visual inspection locations and other site features.

Digital camera – Used to document sampling locations and conditions. See Section B3.1.2 for

standard procedures in photographic documentation. GPS unit and stakes – Used to identify and record sampling locations. See Section B2.3 for

standard procedures in GPS documentation. Zip-top bags – Used as sample containers for most types of environmental samples. Sample

number labels will be affixed to the bags or the sample number will be hand-written in permanent marker on the bags.

Decontamination equipment – Used to remove any residual asbestos contamination on

reusable sampling equipment between the collection of road material samples. See Section B2.4 for standard decontamination procedures.

In addition to the generic equipment list, the following equipment will be required for sampling activities as part of this program:


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Air sampling equipment: 25-mm diameter MCE filter cassettes (0.8-µm pore size), high and

low flow rate battery-powered air sampling pumps, rotameter, Tygon tubing, belt or backpack to attach pumps to sampler

Two ATVs: Polaris Ranger 500® four-wheel drive “side-by-side”, or alternate vehicle of similar size and design, additional fuel

Rock hammer: rock or mason hammer, appropriate for breaking apart rock and mineral specimens

Bag for rock specimens: bag should be sturdy enough to hold at least 10 pounds of rock and be made out of canvas, plastic, or leather

Sample supplies: custody seals, tape, and coolers Trowel: metal trowel for the collection of soil samples

B8.2 SPF and Analytical Laboratory Supplies The laboratory manager is responsible for ensuring that all reagents and disposable equipment used in this project are free of asbestos contamination. This is demonstrated by the collection of blank samples by the Troy SPF and the analytical laboratory (see Section B5.2.3 and Section B5.3.3, respectively). B9. NON-DIRECT MEASUREMENTS In the event exposures and risks from trespasser activities in the mined area are determined to be unacceptable, EPA may use data on LA concentrations in source materials collected during this study (i.e., road materials) and during the Phase 1 investigation (see Figure A-3) to inform decisions on where response actions may be necessary. Both datasets have been collected under EPA-approved SAP/QAPPs, as such they have been collected in accordance with Site-specific sampling, preparation, and analysis methods, and are managed in the OU3 master project database (see Section B10.2). B10. DATA MANAGEMENT All data generated as part of this ABS program will be maintained in an OU3-specific Microsoft Access® database in accordance with the OU3-specific data management procedures specified below. The following sections provide a brief overview of the roles and responsibilities for data management and a summary of the data storage requirements for the OU3 project. B10.1 Roles and Responsibilities B10.1.1 Field Personnel Grace’s contractor will perform all field sample collection and ABS activities in strict accordance with this SAP/QAPP. In the field, sample details will be documented on hard copy media-specific FSDS forms (see Appendix F) and in field log books. COC information will be documented on hard copy forms (see


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Appendix D, OU3 SOP No. 9 for a template of the COC form). Grace’s field contractor will scan and post field documentation in an Adobe Acrobat® portable document format (.pdf) to the OU3 eRoom on a weekly basis. This eRoom has controlled access (i.e., user name and password are required) to ensure data access is limited to appropriate project-related personnel. File names for scanned documents will include the sample date in the format MMDDYY to facilitate document organization (e.g., “FSDS_091515.pdf”). FSDS and COC information will be manually entered into a field-specific9 OU3 database using electronic data entry forms. Use of electronic data entry forms ensures the accuracy of data entry and helps maintain data integrity. For example, data entry forms utilize drop-down menus and check boxes whenever possible. These features allow the data entry personnel to select from a set of standard inputs, thereby preventing duplication and transcription errors and limiting the number of available selections (e.g., media types). In addition, entry into a database allows for the incorporation of data entry checks. For example, the database will allow a unique sample ID to only be entered once, thus ensuring that duplicate records cannot be created. Entry of FSDS forms and COC information will be completed weekly, or more frequently as conditions permit. After FSDS data entry is completed, a copy of the field-specific OU3 database will be posted by the field data manager to the OU3 eRoom weekly, or more frequently as conditions permit. The field-specific OU3 database posted to the eRoom site will include the post date in the file name (e.g., FieldOU3TRES_20151509.mdb). B10.1.2 SPF Personnel The Troy SPF utilizes a local SPF Scribe project database to maintain soil sample preparation information specific to OU3. Soil preparation information from the preparation log sheets is entered into the OU3 Prep project database by SPF personnel. After the data entry is checked against the original forms, it is the responsibility of the SPF manager (or their designate) to post a copy of the OU3 Prep project database to the OU3 eRoom. It is the responsibility of the OU3 data manager (CDM Smith) to subscribe to upload relevant information on soil sample preparation (e.g., mass associated with each sample fraction) and COC tracking details for OU3 samples into the master OU3 project database. B10.1.3 Laboratory Personnel

Each of the laboratories performing asbestos analyses for this investigation are required to utilize all applicable Libby-specific Microsoft Excel® EDD spreadsheets for asbestos data recording and electronic submittals. Upon completion of the appropriate analyses, EDDs and scanned copies of all analytical laboratory data packages will be posted to the OU3 eRoom.

9 The field-specific OU3 database is a simplified version of the master OU3 database. This simplified database includes only the station and sample recording and tracking tables, as well as the FSDS and COC data entry forms.


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B10.1.4 Database Administrators

Day-to-day operations of the master OU3 project database will be under the control of EPA contractors. The primary database administrator (CDM Smith) will be responsible for sample tracking, uploading new field, preparation, and analytical data, performing error checks, and making any necessary data corrections. New records will be added to the master OU3 project database within an appropriate time period of data receipt. B10.2 Master OU3 Project Database The master OU3 project database is a relational Microsoft Access® database developed specifically for OU3. The Libby OU3 Database User’s Guide provides an overview of the master OU3 project database structure and content. The most recent version of this User’s Guide is provided on the OU3 website. The master OU3 project database is kept on the CDM Smith server in Denver, CO. Incremental backups of the master OU3 project database are performed daily Monday through Friday, and a full backup is performed each Saturday. B10.3 Data Reporting Field summary reports are prepared by Grace’s field contractor. These reports will summarize field collection activities, the number and types of samples collected, as well as any deviations from the governing SAP/QAPP or SOPs. (These field summary reports will not include any analytical results.) Tabular analytical results summaries are provided by CDM Smith to the EPA RPM on an investigation-specific basis and will be summarized in the comprehensive OU3 Data Summary Report (CDM Smith 2015), which is available on the OU3 website. The EPA RPM will be responsible for disseminating information regarding sampling and analysis results associated with this investigation. Specialized requests for data summaries may be submitted to the EPA RPM. B10.4 Data Storage All original data records (both hard copy and electronic) will be cataloged and stored in their original form until otherwise directed by the EPA RPM. At the termination of this project, all original data records will be provided to the EPA RPM for incorporation into the Site project files.


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C Assessment and Oversight C1. ASSESSMENT AND RESPONSE ACTIONS Assessments and oversight reports to management are necessary to ensure that procedures are followed as required and that deviations from procedures are documented. These reports also serve to keep management current on field activities. C1.1 Assessments C1.1.1 Field At the discretion of EPA, field oversight may be performed by EPA’s contractors (CDM Smith, HDR Engineering, or CB&I) to evaluate ABS activities. EPA’s field auditor has the authority to direct changes in field activities or to halt field activities if needed until a remedy to an unexpected problem can be identified. Field audit findings will be documented in audit reports issued by the entity performing the audit, and will be discussed with the project management team before the auditors leave the Site. Corrective actions will be immediately implemented, as appropriate. A copy of the field audit report will be provided to the EPA RPM. C1.1.2 Laboratory The Troy SPF and each analytical laboratory working on the Libby project is required to participate in an annual onsite laboratory audit carried out by the EPA through the QATS contract. These audits are performed by EPA personnel (and their contractors), that are external to and independent of, the Libby laboratory team members. These audits ensure that each analytical laboratory meets the basic capability and quality standards associated with analytical methods for asbestos used at the Libby site. They also provide information on the availability of sufficient laboratory capacity to meet potential testing needs associated with the Site. External Audits Audits consist of several days of technical and evidentiary review of each laboratory. The technical portion of the audit involves an evaluation of laboratory practices and procedures associated with the preparation and analysis of samples for the identification of asbestos. The evidentiary portion of the audit involves an evaluation of data packages, record keeping, SOPs, and the laboratory QA Management Plan. A checklist of method-specific requirements for the commonly used methods for asbestos analysis is prepared by the auditor before the audit, and used during the onsite laboratory evaluation. Evaluation of the capability for a laboratory to analyze a sample by a specific method is made by observing analysts performing actual sample analyses and interviewing each analyst responsible for the analyses. Observations and responses to questions concerning items on each method-specific checklist are noted. The determination as to whether the laboratory has the capability to analyze a sample by a specific method depends on how well the analysts follow the protocols


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detailed in the formal method, how well the analysts follow the laboratory-specific method SOPs, and how the analysts respond to method-specific questions. Evaluation of the laboratory to be sufficient in the evidentiary aspect of the audit is made by reviewing laboratory documentation and interviewing laboratory personnel responsible for maintaining laboratory documentation. This includes personnel responsible for sample check-in, data review, QA procedures, document control, and record archiving. Certain analysts responsible for method quality control, instrument calibration, and document control are also interviewed in this aspect of the audit. Determination as to the capability to be sufficient in this aspect is made based on staff responses to questions and a review of archived data packages and QC documents. It is the responsibility of the QATS contractor to prepare an On-site Audit Report for each analytical laboratory participating in the Libby program. These reports are handled as business confidential items. The On-site Audit Report includes both a summary of the audit results and completed checklist(s), as well as recommendations for corrective actions, as appropriate. Responses from each laboratory to any deficiencies noted in the On-site Audit Report are also maintained with the respective reports. It is the responsibility of the QATS contractor to prepare an On-Site Audit Trend Analysis Report on an annual basis. This report shall include a compilation and trend analysis of the onsite audit findings and recommendations. The purpose of this reported is to identify common asbestos laboratory performance problems and isolate the potential causes. Internal Audits Each laboratory will also conduct periodic internal audits of their specific operations. Details on these internal audits are provided in the laboratory QA Management Plan. The laboratory QAM should immediately contact the LC and the QATS contractor if any issues are identified during internal audits that may impact data quality for OU3 samples. C1.2 Response Actions Corrective response actions will be implemented on a case-by-case basis to address quality problems. Minor actions taken to immediately correct a quality problem will be documented in the applicable field or laboratory logbooks and a verbal report will be provided to the appropriate manager (e.g., the FTL or LC). Major corrective actions will be approved by the EPA RPM and the appropriate manager prior to implementation of the change. Major response actions are those that may affect the quality or objective of the investigation. The EPA RPM for OU3 will be notified when quality problems arise that that cannot be corrected quickly through routine procedures (contact information is provided below):


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Christina Progess U.S. EPA, Region 8 1595 Wynkoop Street Denver, CO 80202 Tel: (303) 312-6009 Fax: (303) 312-7151 E-mail: [email protected] In addition, when modifications to this SAP/QAPP are required, either for field or laboratory activities, a ROM must be completed and approved by the EPA RPM prior to implementation (see Appendix H for example ROM forms). C2. REPORTS TO MANAGEMENT No regularly-scheduled written reports to management are planned as part of this project. However, QA reports will be provided to management for routine audits and whenever quality problems are encountered. Field staff will note any quality problems on FSDSs or in field logbooks. Further, the field and laboratory managers will inform the EPA RPM upon encountering quality issues that cannot be immediately corrected.


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D Data Validation and Usability D1. DATA REVIEW, VERIFICATION AND VALIDATION D1.1 Data Review Data review of project data typically occurs at the time of data reporting by the data users and includes cross-checking that sample IDs and sample dates have been reported correctly and that calculated analytical sensitivities or reported values are as expected. If discrepancies are found, the data user will contact the database manager (CDM Smith), who will then notify the appropriate entity (field, SPF, or laboratory) in order to correct the issue. D1.2 Criteria for LA Measurement Acceptability Several factors will be considered in determining the acceptability of LA measurements in samples analyzed by TEM. This includes the following:

• Evenness of filter loading. This is evaluated using a Chi-squared (CHISQ) test, as described in ISO 10312 Annex F2. If a filter fails the CHISQ test for evenness, the result may not be representative of the true concentration in the sample, and the result should be given low confidence.

• Results of QC samples. This includes both field and laboratory QC samples, such as field and laboratory blank samples, as well as various types of recount and repreparation analyses. If significant LA contamination is detected in field or laboratory blanks, all samples prepared on that day should be considered to be potentially biased high. If agreement between original analyses and re-preparation or recount analyses is poor (per Libby laboratory ROM #LB-000029), results for those samples should be given low confidence.

For PLM analyses, the following factors will be considered in determining the acceptability of LA measurements in soil samples:

• Results of PE standard analyses. PLM-VE accuracy is evaluated using LA-specific PE standards. If the results for these PE standards show a lack of concordance with the expected nominal levels, PLM-VE results should be given low confidence.

• Results of QC samples. This includes both preparation and laboratory QC samples. If LA contamination is detected in any preparation blanks, associated samples should be considered to be potentially biased high. If agreement between original and repeat analyses (i.e., duplicate analyses, inter-laboratory analyses) is strongly discordant (meaning the reported semi-quantitative bin result for the repeat analysis is not within one bin of the original analysis), results for those samples should be given low confidence.


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D2. VERIFICATION AND VALIDATION METHODS D2.1 Data Verification Data verification includes checking that results have been transferred correctly from the original hand-written, hard copy field and analytical laboratory documentation to the project databases. The goal of data verification is to identify and correct data reporting errors. In the field, some data checking of reported sample information on the FSDS forms is performed during the data entry process (i.e., the electronic data entry forms only allow for the input of specific valid values and formats). In the analytical laboratory, data checking of reported analytical results begins with automatic QC checks that have been built into the Libby-specific spreadsheets. These automated checks help to ensure that field sample information and analytical results in the project databases are accurate and reliable. In addition to these automated checks, a detailed manual data verification effort will be performed for 100% of all samples and analytical results collected as part of this sampling effort. This data verification process utilizes Site-specific SOPs (see Appendix D) to check FSDS forms (SOP EPA-LIBBY-11), TEM bench sheets and analytical results (SOP EPA-LIBBY-09), and PLM data (SOP EPA-LIBBY-10) to ensure information in the project database is accurate and reliable. The data verification review ensures that any data reporting issues are identified and rectified to limit any impact on overall data quality. If issues are identified during the data verification, the frequency of these checks may be increased as appropriate. Data verification will be performed by appropriate CDM Smith staff that is familiar with project-specific data reporting, analytical methods, and investigation requirements. The data verifier will prepare a data verification report (template reports are included in the SOPs) to summarize any issues identified and necessary corrections. A copy of this report will be provided to the EPA RPM. It is the responsibility of the OU3 database manager (CDM Smith) to coordinate with the FTL, SPF personnel, and/or LC to resolve any database corrections and address any recommended field or laboratory procedural changes from the data verifier. The OU3 database manager is also responsible for electronically tracking in the project database which data have been verified, who performed the verification, and when verification occurred. D2.2 Data Validation Unlike data verification, where the goal is to identify and correct data reporting errors, the goal of data validation is to evaluate overall data quality and to assign data qualifiers, as appropriate, to alert data users to any potential data quality issues. Data validation will be performed by the QATS contractor (CB&I, or their designee), with support from technical support staff that are familiar with project-specific data reporting, analytical methods, and investigation requirements. As part of the data validation effort, the QATS contractor will review results for all field QC samples and inter- and intra-laboratory QC analyses on a quarterly basis. In addition, the QATS contractor will also perform a formal data validation of the TEM and PLM data packages submitted by the


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laboratory in accordance with Libby-specific SOPs QATS-70-095-01 (TEM) and QATS-70-094-01 (PLM), which was developed by the QATS contractor based on the draft National Functional Guidelines for Asbestos Data Review (EPA 2011). This data validation includes an assessment of the following: Internal and external field audit/surveillance reports Field ROMs Field QC sample results Internal and external laboratory audit reports Laboratory contamination monitoring results Laboratory ROMs Internal laboratory QC analysis results Inter-laboratory analysis results Performance evaluation results Instrument checks and calibration results Data verification results (i.e., in the event that the verification effort identifies a larger data

quality issue) A comprehensive data validation effort will be completed annually and results should be reported as a technical memorandum to the EPA. This technical memorandum shall detail the validation procedures performed and provide a narrative on the quality assessment for each type of asbestos analysis, including the data qualifiers assigned, and the reason(s) for these qualifiers. The technical memorandum shall detail any deficiencies and required corrective actions. For OU3 reviews, electronic files summarizing the records that have been validated, the date they were validated, any recommended data qualifiers and their associated reason codes should be posted to the OU3 eRoom. It is the responsibility of the OU3 database manager (CDM Smith) to ensure that the appropriate data qualifiers and reason codes recommended by the data validator are added to the project database, and to electronically track in the project database which data have been validated, who performed the validation, and when. In addition to performing regular data validation efforts, it is the responsibility of the QATS contractor (or their designee) to perform regular evaluations of all blanks, to ensure that any potential contamination issues are quickly identified and resolved. If any blank results are outside the acceptable limits, the QATS contractor should immediately contact the EPA RPM to ensure that appropriate corrective actions are made. D3. RECONCILIATION WITH USER REQUIREMENTS Once all samples have been collected and analytical data has been generated, data will be evaluated to determine if study objectives were achieved. It is the responsibility of data users to perform a data usability assessment to ensure that DQOs have been met, and reported investigation results are adequate and appropriate for their intended use. This data usability assessment should utilize results of the data verification and data validation efforts to provide information on overall data quality specific to each investigation.


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The data usability assessment should evaluate results with regard to several data usability indicators, including precision, accuracy/ bias, representativeness, comparability, completeness, and whether specified analytic requirements (e.g., sensitivity) were achieved. Table D-1 provides detailed information for how each of these indicators may be evaluated for the reported asbestos data. The data usability assessment results and conclusions should be included in any investigation-specific data summary reports.

Non-attainment of project requirements may result in additional sample collection or field observations in order to achieve project needs. Table D-1. Data Usability Indicators for Asbestos Datasets

Data Usability Indicator General Evaluation Method

Precision

Review results for TEM recounts and repreparations and PLM laboratory duplicates to provide information on variability arising from analysis methods. Review results for inter-laboratory analyses to provide information on variability and potential bias between laboratories. [See Libby Laboratory ROMs #LB-000029 and LB-000073 for detailed evaluation methods]

Accuracy/Bias Calculate the background filter loading rate and use results to assign detect/non-detect for TEM analyses in basic accordance with ASTM 6620-00. Determine the frequency of indirect preparation for air samples. Use field, lot, and laboratory blank results to identify potential cross-contamination.

Representativeness Review relevant field audit report findings and any field/laboratory ROMs for potential data quality issues.

Comparability Compare the sample collection SOPs, preparation techniques, and analysis methods to previous investigations.

Completeness Determine the percentage of samples that were able to be successfully collected and analyzed (e.g., 90 of 100 samples, 90%).

Sensitivity Determine the fraction of all TEM analyses that stopped based on the maximum filter area examined stopping rule (i.e., did not achieve the target sensitivity).


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REFERENCES Amandus HE, Wheeler R. 1987. The Morbidity and Mortality of Vermiculite Miners and Millers Exposed to Tremolite-Actinolite: Part II. Mortality. Am. J. Ind. Med. 11:15-26. CDM Smith. 2015. Libby Asbestos Superfund Site, Operable Unit 3, Data Summary Report: 2007 to 2013. January – Revision 2. EPA (U.S. Environmental Protection Agency). 1987. Appendix A to Subpart E of 40 CFR Part 763. Interim TEM Analytical Methods - Mandatory and Nonmandatory - and Mandatory Section to Determine Completion of Response Actions. Final Register 52:41857. October 30. http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol31/pdf/CFR-2011-title40-vol31-part763-subpartE.pdf _____. 2001. EPA Requirements for Quality Assurance Project Plans, QA/R-5. U.S. Environmental Protection Agency, Office of Environmental Information. March. http://www.epa.gov/quality/qs-docs/r5-final.pdf _____. 2006. Guidance on Systematic Planning Using the Data Quality Objective Process, QA/G-4. U.S. Environmental Protection Agency, Office of Environmental Information. February. http://www.epa.gov/quality/qs-docs/g4-final.pdf ______. 2007. Phase I Sampling and Analysis Plan, Libby Asbestos Superfund Site, Operable Unit 3. Revision 0 – September. _____. 2008a. Framework for Investigating Asbestos-Contaminated Sites. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Asbestos Committee of the Technical Review Workgroup. OSWER Directive #9200.00-68. http://www.epa.gov/superfund/health/contaminants/asbestos/pdfs/framework_asbestos_guidance.pdf _____. 2008b. Characteristic EDS Spectra for Libby-Type Amphiboles. Produced by Syracuse Research Corporation for EPA, Region 8. Final – March 18. _____. 2008c. Performance Evaluation of Laboratory Methods for the Analysis of Asbestos in Soil at the Libby, Montana Superfund Site. Produced by Syracuse Research Corporation for EPA, Region 8. Draft – October 7. _____. 2011. National Functional Guidelines for Asbestos Data Review. U.S. Environmental Protection Agency, Office of Superfund Remediation and Technology Innovation. Draft - August. _____. 2014. Toxicological Review of Libby Amphibole Asbestos. Washington D.C.: U.S. Environmental Protection Agency, Office of Research and Development, National Center for Environmental Assessment, Integrated Risk Information System. EPA/635/R-11/002F. December. http://www.epa.gov/iris/supdocs/1026index.html


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http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol31/pdf/CFR-2011-title40-vol31-part763-subpartE.pdf

http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol31/pdf/CFR-2011-title40-vol31-part763-subpartE.pdf

http://www.epa.gov/quality/qs-docs/r5-final.pdf

http://www.epa.gov/quality/qs-docs/r5-final.pdf

http://www.epa.gov/quality/qs-docs/g4-final.pdf

http://www.epa.gov/superfund/health/contaminants/asbestos/pdfs/framework_asbestos_guidance.pdf

http://www.epa.gov/superfund/health/contaminants/asbestos/pdfs/framework_asbestos_guidance.pdf

http://www.epa.gov/iris/supdocs/1026index.html

International Organization for Standardization (ISO). 1995. Ambient Air – Determination of asbestos fibers – Direct-transfer transmission electron microscopy method. ISO 10312:1995(E). Larson, TC, Meyer, CA, Kapil, V, Gurney, JW, Tarver, RD, Black, CB, and Lockey, JE. 2010. Workers with Libby amphibole exposure: retrospective identification and progression of radiographic changes. Radiology 255(3):924-933. Larson, TC, Lewin, M, Gottschall, EB, Antao, VC, Kapil, V, and Rose, CS. 2012a. Associations between radiographic findings and spirometry in a community exposed to Libby amphibole. Occup. Environ. Med. 69(5):361-6. Larson, TC, Antao, AC, Bove, FJ, and Cusack, C. 2012b. Association between cumulative fiber exposure and respiratory outcomes among Libby vermiculite workers. Occup. Environ. Med. 54(1):56-63. McDonald JC, Harris J, Armstrong B. 2004. Mortality in a cohort of vermiculite miners exposed to fibrous Amphibole in Libby, Montana. Occup. Environ. Med. 61:363-366. McDonald JC, McDonald AD, Armstrong B, Sebastien P. 1986. Cohort study of mortality of vermiculite miners exposed to tremolite. Brit. J. Ind. Med. 43:436-444. Meeker GP, Bern AM, Brownfield IK, Lowers HA, Sutley SJ, Hoeffen TM, Vance JS. 2003. The Composition and Morphology of Amphiboles from the Rainy Creek Complex, Near Libby, Montana. American Mineralogist 88:1955-1969. OSHA (Occupational Safety and Health Administration). 2002. OSHA 3096: Asbestos Standard for the Construction Industry (Revised). U.S. Department of Labor, Occupational Safety and Health Administration. https://www.osha.gov/Publications/OSHA3096/3096.html Peipins LA, Lewin M, Campolucci S, Lybarger JA, Miller A, Middleton D, et al. 2003. Radiographic abnormalities and exposure to asbestos-contaminated vermiculite in the community of Libby, Montana, USA. Environ. Health Perspect. 111:1753-1759. Rohs AM, Lockey JE, Dunning KK, Shulka R, Fan H, Hilbert T, Borton E, Wiot J, Meyer C, Shipley RT, LeMasters GK, Kapol V. 2007. Low level Fiber Induced Radiographic Changes Caused by Libby Vermiculite: A 25 year Follow-up Study. Am J Respiratory and Critical Care Medicine. Published online December 6 as doi:10.1164/rccm.200706-814OC. Sullivan, PA. 2007. Vermiculite, Respiratory Disease and Asbestos Exposure in Libby, Montana: Update of a Cohort Mortality Study. Environ. Health Perspect. doi:10.1289/ehp.9481 Available online at http://dx.doi.org.


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https://www.osha.gov/Publications/OSHA3096/3096.html

http://dx.doi.org/

SAP/QAPP:

LIBBY OU3 TRESPASSER ABS

FIGURES


Tommy CookProject Manager

CDM Smith

Terry CrowellQuality Assurance Manager

CDM Smith

Field Support Staff:

William Pickens, MWHSubcontract Field Staff, TBD

Lisa DeWittProject Manager

MDEQ

Deborah McKeanTechnical Assistance Unit Chief

EPA, Region 8

Don GoodrichESAT Laboratory Contract Manager

EPA, Region 8

Dania ZinnerQATS Libby Task Manager/Quality Assurance

ReviewerEPA, Region 8

Nikki MacDonaldESAT QA Manager

TechLaw, Inc.

Douglas KentESAT TEM Laboratory Manager

TechLaw, Inc.

Analytical Laboratory Management Staff:

Laboratory ManagerQuality Assurance ManagerSample CoordinatorSenior Analyst(s)

Troy Soil Preparation Facility Management Staff:

Laboratory ManagerQuality Assurance ManagerSample Coordinator

Michael LenkauskasQuality Assurance Manager

CB&I

Andrea WandlerProject Sample Coordinator

TechLaw, Inc.

Figure A-1. General Organizational Chart for the Trespasser ABS

EPA Region 8 StaffLines of authority

Lines of communicationUSACE Staff

MDEQ Staff

CDM Smith Staff

TechLaw Staff

TechLaw Subcontractors

CB&I Staff

Jo Nell MullinsQuality Assurance Director

CDM Smith

Gwen BakerFederal Services Group President

CDM Smith

Robert MedlerProject Coordinator

W. R. Grace

Lynn WoodburyProject Technical Lead

CDM Smith

Natalie RossProject Data Manager

CDM Smith

W.R. Grace Staff

Christina ProgessRemedial Project Manager

EPA, Region 8

W. R. Grace Subcontractor

Mark McDanielESAT Region 8 Team Manager/

Laboratory CoordinatorTechLaw, Inc.

Rebecca ThomasProject Team Leader

EPA, Region 8

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Service Layer Credits: Source: Esri,DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AEX,Getmapping, Aerogrid, IGN, IGP, swisstopo,and the GIS User Community

ATV Rider ABS Start/StopLocation at the Amphitheater

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B

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SAP/QAPP:

LIBBY OU3 TRESPASSER ABS

APPENDICES


A‐1

APPENDIX A:

ASBESTOS LABORATORY ACCEPTANCE CRITERIA

FOR THE LIBBY ASBESTOS SUPERFUND SITE

MINIMUM LABORATORY ACCEPTANCE CRITERIA

1. Must be certified by the National Institute of Standards and Technology (NIST) National Voluntary

Laboratory Accreditation Program (NVLAP) for the analysis of asbestos by PLM1 and/or TEM2.

2. Must have a laboratory‐specific Quality Management Plan and all relevant SOPs in place for asbestos

environmental sample processing and analysis.

3. Must have multiple experienced analysts on staff capable of running PLM visual area estimation methods

[NIOSH 9002, EPA 600] and/or TEM methods [ISO 10312, ISO 13794, AHERA, ASTM 5755, EPA Method

100.2] (a minimum of 2 analysts within each laboratory are needed to assess within‐laboratory

reproducibility). Must have documentation in place demonstrating all analysts work experience and

training related to analyses performed.

4. Must be familiar with standard TEM and PLM preparation methods. TEM laboratories must have ability

to perform indirect preparation and ashing (for the analysis of air, dust, other media) and/or

ozonation/UV/sonication treatment (for the analysis water). PLM laboratories must have the ability to dry

samples (for PLM‐NIOSH 9002 analysis). If the PLM laboratory wishes to perform soil sample preparation

in support of the Libby‐specific PLM methods (i.e., PLM‐VE and PLM‐Grav), the laboratory must have the

ability to sieve and grind soil samples in accordance with the Libby‐specific preparation method.

Note: Not all laboratory facilities need to have all preparation capabilities; media analysis could be

segregated based on facility capability (i.e. one laboratory does water, another does soil, etc.).

5. TEM laboratories must have Energy Dispersive Spectroscopy (EDS) and Selected Area Electron

Diffraction (SAED) capability incorporated into their microscope(s).

6. Must participate in monthly EPA laboratory calls for the Libby project.

7. Must participate in inter‐laboratory analyses with other Libby project laboratories.

8. Must participate in annual EPA (QATS) audits and in other laboratory and/or data audits if data quality

issues arise, as deemed appropriate by EPA.

9. Must be capable of using Libby‐specific bench sheets to record observations and utilizing Libby‐specific

electronic data deliverables (EDDs) to report analytical results.

10. Must have the capacity to meet the required delivery schedules and turn‐around times.

11. Must designate laboratory primary and secondary points of contact for discussion of EPA/laboratory

issues.

EPA APPROVAL PROCESS

1. Once potential laboratories are identified that meet the minimum acceptance criteria, they must show

proficiency in analysis of NIST/NVLAP performance evaluation samples and inter‐laboratory samples

1 http://www.nist.gov/nvlap/upload/NIST‐HB‐150‐3‐2006‐1.pdf 2 http://www.nist.gov/nvlap/upload/NIST‐HB‐150‐13‐2006‐1.pdf

A‐2

(standard PLM visual area estimation and TEM only, no Libby‐specific method modifications and

requirements).

2. If proficiency is documented, an EPA (QATS) audit will be performed.

3. If any deficiencies found during the audit are sufficiently resolved to EPA's satisfaction, then project‐

specific mentoring will be conducted to ensure laboratories are proficient in the Libby‐specific methods,

modifications, and requirements.

4. Once a laboratory has passed all of these steps, EPA will approve the use of the laboratory and

documentation to this effect will be sent to the laboratory. Samples can then be sent to the laboratory for

analysis.

B‐1

APPENDIXBDataQualityObjectives:MinedAreaTrespasserActivity‐BasedSamplingDataqualityobjectives(DQOs)arestatementsthatdefinethetype,quality,quantity,purpose,anduseofdatatobecollected.ThedesignofastudyiscloselytiedtotheDQOs,whichserveasthebasisforimportantdecisionsregardingkeydesignfeaturessuchasthenumberandlocationofsamplestobecollectedandtypesofanalysestobeperformed.TheU.S.EnvironmentalProtectionAgency(EPA)hasdevelopedaseven‐stepprocessforestablishingDQOstohelpensurethatdatacollectedduringafieldsamplingprogramwillbeadequatetosupportreliabledecision‐making(EPA2001,2006).Thefollowingsectionsimplementtheseven‐stepDQOprocessassociatedwiththissamplingandanalysisplan/qualityassuranceprojectplan(SAP/QAPP).Step1:StatetheProblemProblemDescriptionThePhaseIinvestigationforOperableUnit3StudyArea1(OU3)wasconductedinOctober2007(EPA2007a)andcollectedmultiplesourcematerial2samplesfromtheFormerMinedArea(areadisturbedbyminingactivitiesconsistingofexposedoutcrops,rockpiles,wastematerials,andsoilswithoutvegetation;alsoreferredtoastheminedarea).TheresultsofthisinvestigationshowedsourcematerialsampleshadLibbyamphiboleasbestos(LA)concentrationsashighas2percent(%)to8%(CDMSmith2015).BecauseoftheseelevatedLAlevels,controlshavebeenimplementedtopreventaccesstotheW.R.GraceandCompany(Grace)property.Specifically,gatesacrossRainyCreekandJacksonCreekroadsareintendedtopreventunauthorizedaccesstoandaroundtheminedarea.Sincepropertyaccessiscurrentlyrestricted,samplinghasnotbeenperformedtodatetoquantifypotentialrisksfromreceptorexposuresontheminedarea.However,atrespasserhasbeenreportedinthevicinityoftheminedareaanditispossiblefortrespassersonall‐terrainvehicles(ATVs)todrivealongunpavedroadsandontotheminedarea.Inaddition,itispossiblethatpeoplemaytrespassontheminedareainordertocollectrockandmineralspecimens(referredtoas“rockhounding”).AsstatedintheFrameworkforInvestigatingAsbestos‐ContaminatedSuperfundSites(EPA2008),asbestosfibersinsourcematerials,aretypicallynotinherentlyhazardous,unlesstheasbestosisreleasedfromthesourcematerialintoairwhereitcanbeinhaled.Ifinhaled,asbestosfiberscanincreasetheriskofdevelopinglungcancer,mesothelioma,pleuralfibrosis,andasbestosis.The

1Atthistime,theboundariesofOU3havenotyetbeendetermined.EPAestablishedapreliminaryOU3StudyAreaforthepurposeofplanninganddevelopingthescopeoftheRemedialInvestigation/FeasibilityStudy(RI/FS)forOU3.TheOU3StudyAreamayberevisedasdataareobtainedonthenatureandextentofenvironmentalcontaminationassociatedwithreleasesthatmayhaveoccurredfromtheminesite.InthisSAP/QAPP,whenthetermOU3isused,itisreferringtotheOU3StudyArea.2Forsimplicity,soils,rock,tailings,andotherminewastematerialsthatmayoccurwithintheFormerMinedArea,whichmaybeasourceofairborneLAwhendisturbed,willbecollectivelyreferredtoas“sourcematerials”.

B‐2

evaluationofriskstohumansfromexposuretoasbestosismostreliablyachievedbythecollectionofdataonthelevelofasbestosinbreathingzoneairduringdisturbancesofasbestos‐containingsourcematerials,referredtoasactivity‐basedsampling(ABS)(EPA2008).WhiletherehavebeenseveralABSstudiesconductedwithinOU3toassesspotentialexposuresunderavarietyofexposureconditions,atpresent,therearenoABSairdatafortheminedarea.Specifically,trespassingorrockhoundingintheminedareahasbeenidentifiedasapotentialexposurepathwaytohumanreceptors,butquantitativeriskestimatescannotbecalculatedbecausetherearenomeasuredABSairconcentrationsduringthesetypesofscenarios.Therefore,measuredABSairdataareneededtoevaluateifhumanreceptorscouldbeexposedtounacceptablelevelsofLAontheminedareaduringthesetypesofscenariosandiffutureresponseactionsand/oradditionalcontrolsarenecessarytopreventtheseexposures.IntheeventthatABSairresultsindicateexposuresduringactivitiesinandaroundtheminedarearesultinunacceptableexposures,informationonLAconcentrationsinsourcematerialswillbeusedtoinformdecisionsonthespecificareaswhereresponseactionswouldbemosteffectiveinreducingexposures.Asnotedabove,sourcematerialsamplesfromtheminedareawerecollectedin2007aspartofthePhase1investigation(EPA2007a).WhilethesesamplesproviderepresentativedataonLAconcentrationsinsourcematerialswithintheminedarea,theextentofsamplingalongRainyCreekRoadandotherunpavedroadsandtrailswaslimited(i.e.,onlythreesamplesofroadmaterialswerecollectedfromthelowerunpavedsectionsofRainyCreekRoad)(CDMSmith2015).Therefore,additionalmeasurementsofLAconcentrationsinroadmaterialsareneededtocharacterizetheunpavedroadsandtrailsinandaroundtheminedareatoinformdecisionsonthespecificareaswhereresponseactionswouldbemosteffectiveinreducingexposures.ProjectPlanningTeamThecurrentprojectstakeholdersaredescribedintheSectionA3ofthemainSAP/QAPPtext.Inbrief,EPAistheleadregulatoryagencyforactivitiesattheLibbyAsbestosSuperfundSite(Site).TheEPARemedialProjectManager(RPM)forOU3oftheSiteisChristinaProgess.Ms.Progessistheprincipaldatauseranddecision‐makerforSuperfundactivitieswithinOU3.In2007,EPAenteredintoanAdministrativeOrderonConsent(AOC)(DocketNo.CERCLA‐08‐2007‐0012)withrespondentsW.R.Grace(Grace)andKootenaiDevelopmentCorporation(KDC)forperformanceofaRemedialInvestigation/FeasibilityStudy(RI/FS)forOU3.UnderthetermsoftheAOC,underEPAsupervision,GraceandKDCwilljointlyperformRI/FSactivitiesincludingimplementationoftheactivitiesdescribedinthisSAP/QAPP.TheMontanaDepartmentofEnvironmentalQuality(MDEQ)andtheU.S.ForestService(USFS)aresupportagenciesfortheSite.EPAwillconsultwithMDEQasprovidedforbytheComprehensiveEnvironmentalResponse,Compensation,andLiabilityAct(CERCLA),theNationalContingencyPlan,andapplicableguidanceinconductingSuperfundactivitieswithinOU3.TheprojectteamorganizationchartispresentedinFigureA‐1inthemainSAP/QAPP.

B‐3

ResourcesandScheduleAvailableresourcesforthisprojectincludetheplanningteamentitieslistedabove,aswellastheEPAandGracesubcontractorsthatwillbeemployedtoperformtheactivitiesdescribedintheSAP/QAPP.Thescheduleforthisstudywilldependuponstaffavailabilityandmeteorologicalconditions.ThegoalistocollectdataforinclusionintheSite‐widehumanhealthriskassessment,whichisexpectedtobefinalizedinthefall/winterof2015;thus,datamustbecollectedduringthe2015fieldseason(ideallybytheendofSeptember2015toallowforadequateanalysistimeandincorporationintotheriskassessment).Theworkisanticipatedtobecompletedwithina1‐weektimeframestartinginlateSeptember2015.Theexactdatesarenotimportant,butenvironmentalconditionsshouldbeappropriateforABS(seeStep4,TemporalBounds,below).Step2:IdentifytheGoaloftheStudyThegoalofthisstudyistoprovidesufficientdataonLAconcentrationsinair,duringactivitiesthatrepresentthetypesofhumanreceptoractivitiesthatmayoccurinandaroundtheminedarea(i.e.,trespasserATVridingandrockhounding),toallowEPAtocompleteanexposureassessment.Theexposureassessmentwillbeusedtodeterminepotentialriskstohumanhealth.Theriskassessmentwillsupportdecisionsaboutwhetherornotresponseactionsand/oradditionalcontrolsareneededtoprotecthumanreceptorsinandaroundtheminedarea.PrincipalStudyQuestion:WouldairborneLAexposuresforhumanreceptorsinandaroundtheminedarearesultinunacceptablecumulativehumanhealthrisks?AlternativeOutcomes

a) Noresponseactionsand/oradditionalcontrolsareneeded.b) Responseactionsand/oradditionalcontrolsareneededtopreventLAexposures.The

natureoftheseactionsand/orcontrolswouldbedeterminedaspartoftheFSprocess.AsecondarygoalofthisstudyistocharacterizethelevelsofLAinroadmaterialstoinformdecisionsonthespecificareaswhereresponseactionsand/oradditionalcontrols,ifnecessary,wouldbemosteffectiveinreducingexposures.Step3:IdentifyInformationInputsReliableandrepresentativemeasurementsofLAconcentrationsinairareneededtoquantifypotentialexposuresduringhumanreceptoractivitiesthatmayoccurinandaroundtheminedarea.SuchmeasurementsareobtainedbydrawingaknownvolumeofairthroughafilterduringvariousactivitiesthatdisturbLAsourcematerialsandmeasuringthenumberofLAfibersthatbecomedepositedonthefiltersurface.Asnotedabove,intheeventthatABSairresultsindicateexposuresduringactivitiesinandaroundtheminedarearesultinunacceptableexposures,informationonLAconcentrationsinsourcematerialswillbeusedtoinformdecisionsonthespecificareaswhereresponseactionsand/or

B‐4

additionalcontrolswouldbemosteffectiveinreducingexposures.Whilesourcematerialsamplesfromtheminedareawerecollectedin2007aspartofthePhase1investigation,theextentofsamplingalongRainyCreekRoadandotherunpavedroadsandtrailswaslimited.Therefore,additionalmeasurementsofLAconcentrationsinroadmaterialsareneededtocharacterizetheunpavedroadsandtrailsinandaroundtheminedarea.Thefollowingsectionsdiscussthetypesofexposurescenariosanddisturbanceactivitiesthatshouldbeevaluated,thetypesofairandroadmaterialsamplesthatshouldbecollected,andtheanalyticalmethodsthatshouldbeusedtoanalyzethesamples.ExposureScenarioPeoplemightentertheminedarea,eitherinadvertentlyorintentionally,foravarietyofreasons,suchaswhilehunting,hiking,camping,ATVriding,birdwatching,etc.“Rockhounds”mayintentionallyaccesstheareainsearchofinterestingrockandmineralspecimens.Becauseitisnotpossibletoevaluateeverypossibleexposurescenario,twoscenarioswillbeselectedthatrepresentactivitiesthatmayoccurandwhichhaveahigherpotentialfordisturbingsoilandminewastematerialsintheminedarea,whichmayresultinhigherairbornereleasesofLA.Assuch,twoscenarioswillbeselectedforevaluation–anATVridingscenarioandarockhoundscenario.ATVridingScenario.ThispopulationincludesadolescentsandadultswhorideATVsforrecreationalpurposes.ATVriderscouldaccessthemineareabyridingaroundthegatesonJacksonCreekandRainyCreekroadsorfromotherUSFStrailsinthesurroundingforest.ThemineareacouldbeanattractivelocationforATVridersduetotheopenspace,rockpiles,andhaulroads,whichareconducivetoATVriding.ItisanticipatedATVridingcouldincludeboth“on‐road”riding,alongexistingroadsandtrails,and“off‐road”riding,withintheminedareaonpilesandinopenareas.RockhoundScenario.Thispopulationincludesadolescentsandadultswhotrespassontheminearealookingforinterestingrockandmineralspecimens.Themineareacouldbeanattractivelocationforrockhoundsbecauseminingactivitieshaveexposedoutcropsandconcentratedrocksatthesurface.TypesofAirSamplesExperienceatLibbyandatotherasbestossiteshasdemonstratedthat,ifapersonisengagedinanactivitythatdisturbsanasbestossourcematerial,personalairsamples(i.e.,samplesthatcollectairinthebreathingzoneofaperson)tendtohavehigherconcentrationsofasbestosthanairsamplescollectedfromanearbystationarymonitor(EPA2007b).Becausepersonalairsamplesaremorerepresentativeofbreathingzoneexposures,whicharemostrelevantforthepurposesofquantifyingexposuresandrisks,totheextentfeasible,ABSairsamplesshouldbecollectedusingpersonalairmonitors(withthemonitorworninthebreathingzoneoftheexposedindividual).

B‐5

AirSampleAnalysisMethodABSairconcentrationswillbeusedtodevelopexposureestimatesforuseinriskassessment,asrecommendedbyEPA(2008).ABSairsamplesshouldbeanalyzedforasbestosbytransmissionelectronmicroscopy(TEM)inbasicaccordancewiththecountingandrecordingrulesspecifiedbytheInternationalOrganizationforStandardization(ISO)Method10312:1995(E)(ISO1995).Becauseasbestostoxicitydependsontheparticlesizeandmineraltype,TEManalysisresultsshouldincludethesizeattributes(i.e.,length,width,aspectratio)ofeachasbestosstructureobserved,alongwiththemineralclassification(i.e.,LA,otheramphibole,chrysotile).Inaddition,becauseitispossiblethattherecouldbevarioussourcesofLApresent,informationonthesodiumandpotassiumcontentofeachLAstructureobserved,asdeterminedbyenergydispersivespectroscopy(EDS),shouldalsoberecorded.ThisrequirementisbasedontheobservationofMeekeretal.(2003)thatmostLAstructuresfromtheLibbyorebodycontaindetectablelevelsofbothsodiumandpotassium,whereasotherpotentialsourcesofLAmaynot.Calculationsofhumanexposureandriskfromasbestosinairareexpressedintermsofphasecontrastmicroscopy(PCM)fiberspercubiccentimeter(f/cc).WhenananalysisisperformedbyTEM,structuresthatsatisfyPCMcountingrulesarereferredtoasPCM‐equivalent(PCME)structures.PCMEstructuresaredefinedasstructureswithalengthgreaterthan(>)5micrometers(µm),awidthgreaterthanorequalto(≥)0.25µm,andanaspectratio(length:width)≥3:1.Becausetheseairsamplesarebeingcollectedtosupportexposureassessmentforriskcharacterization,theinstrumentmagnificationandthecountingandrecordingrulesusedduringtheTEManalysismustallowforthequantificationofairconcentrationsbasedonPCME.RoadMaterialSamplingandAnalysisMethodsRoadmaterialsamplesshouldbecollectedfromtheextentofalltheunpavedroadandtrailsthatwillbetraversedduringtheon‐roadATVridingscenario.ToensurecomparabilityofthesedatawithotherinvestigationsthathavebeenconductedintheOU3StudyArea,samplesshouldbecollected,prepared,andanalyzedusingthestandardmethodsandproceduresemployedattheSite.RoadmaterialsshouldbesampledusingamethodologysimilartowhatwasperformedduringthePhase1investigation(EPA2007a);i.e.,agrabsamplecollectedfromthetop6inchesatapproximate0.25‐mileintervals.SamplesshouldbepreparedattheSamplePreparationFacility(SPF)inTroy,MontanausingtheSite‐specificsievingandgrindingproceduresinaccordancewithstandardoperatingprocedure(SOP)16‐ASB‐06.02.Samplesshouldbeanalyzedbypolarizedlightmicroscopy(PLM),inaccordancewiththeSite‐specificPLMmethodsdevelopedforuseindeterminingLAlevelsinsoil(i.e.,SRC‐LIBBY‐01andSRC‐LIBBY‐03).Step4:DefinetheBoundsoftheStudySpatialBoundsAllsamplingshouldbeperformedwithintheGracepropertyboundaryshownonFigureA‐4inthemainSAP/QAPP.Theon‐roadATVridingshouldbeperformedonexistingunpavedroadsandtrailswithintheGracepropertyboundary,bothwithinthedisturbedareaofthemineandintheforestedareasurroundingtheminedarea.Theoff‐roadATVridingandrockhoundABSscenariosshouldbe

B‐6

performedwithinthedisturbedareaoftheformermine(seetheyellowshadedareainFigureA‐4inthemainSAP/QAPP).Thedisturbedareaiswherewasterockpilesexistthataredevoidofvegetation.AsshowninFigureA‐3ofthemainSAP/QAPP,sincethetimeofthePhase1investigationin2007,thereareseverallocationsintheminedareawherecoversoils(generatedfromsoilremovalsconductedinotheroperableunits)havebeenplaced.ABSactivitiesshouldnotbeperformedinareaswherecoversoilshavebeenplaced.TemporalBoundsGenerally,itisexpectedthatLAreleasestoairwillbehigherinthedrysummermonths(July‐September)thanduringwetconditionsinspringorfall.Ideally,ABSdatawouldbecollectedinthesummermonths,toensurethatmeasuredABSairdataobtainedduringdryperiodsismorelikelytooverestimatethanunderestimatetheactuallong‐termmeanexposure.Roadmaterialsamplingcouldbeperformedatanytime(LAconcentrationsarenotexpectedtochangeovertime);however,forconvenience,samplesshouldbecollectedconcurrentwiththeABS.ItisanticipatedthattheABSactivitiesandroadmaterialsamplingwillcommenceinlateSeptember2015.ThespecificdatesoftheABSarenotimportant,butthegoalistoconducttheABSactivitiesin2015toallowforthesedatatosupporttheSite‐widehumanhealthriskassessmentanddecision‐makingaspartoftheRI/FSprocessforOU3.Step5:DefinetheAnalyticalApproachTheABSairconcentrationsfromthisstudywillbeusedtocalculateanexposurepointconcentration(EPC)foreachABSscenario.InaccordancewithEPAguidance,theEPCwillbecalculatedastheaveragemeasuredABSairconcentrationtreatingnon‐detectsaszero(EPA2008).TheEPCwillbecombinedwithassumptionsaboutexposurefrequencyanddurationandtoxicityfactorsinahumanhealthriskassessmentthatisexpectedtoprovideabasisforEPAtodetermine,inconsultationwithotherSitestakeholders,whetherresponseactionsareneededtoprotecthumanhealth.TheLA‐specifictoxicityvalues(EPA2014)willbeusedtoestimatecancerrisksandnon‐cancerhazardquotients(HQs)fromexposurestoLAinair.Thelifetimeinhalationunitrisk(IUR)valueforcancereffectsis0.17(PCMf/cc)‐1andthelifetimereferenceconcentration(RfC)valuefornon‐cancereffectsis0.00009PCMf/cc(EPA2014).BasicmethodsforestimatinghumanhealthriskfromLAinairareprovidedbelow.EstimationofCancerRiskThebasicequationforestimatingcancerriskfromLAusingtheLA‐specificIURvalueisasfollows: Risk=EPC⋅TWF⋅IURLA

B‐7

where:

Risk=Lifetimeexcessriskofdevelopingcancer(lungcancerormesothelioma)asaconsequenceofLAexposureEPC=ExposurepointconcentrationofLAinair(PCMEstructurespercubiccentimeter[s/cc]).TheEPCisanestimateofthelong‐termaverageconcentrationofLAininhaledairforthespecificactivitybeingassessed.TWF=Time‐weightingfactor.ThevalueoftheTWFtermrangesfromzerotoone,anddescribestheaveragefractionofalifetimeduringwhichexposureoccursfromthespecificactivitybeingassessedandiscalculatedas: TWF=ET/24⋅EF/365⋅ED/70where: ET=Averageexposuretime(hours/day) EF=Averageexposurefrequency(days/year) ED=Exposureduration(years)

IURLA=LA‐specificlifetimeinhalationunitrisk(PCMf/cc)‐1

EstimationofNon‐CancerHazardQuotientThebasicequationforcharacterizingnon‐cancerriskfromLAusingtheLA‐specificRfCvalueisasfollows: HQ=EPC⋅TWF/RfCLAwhere:

HQ=Hazardquotientfornon‐cancereffectsfromLAexposureEPC=ExposurepointconcentrationofLAinair(PCMEs/cc)TWF=Time‐weightingfactorRFCLA=LA‐specificlifetimereferenceconcentration(PCMf/cc)

DecisionRuleEPAguidanceprovidedintheOfficeofSolidWasteandEmergencyResponseDirective#9355.0‐30,RoleoftheBaselineRiskAssessmentinSuperfundRemedySelectionDecisions(EPA1991),indicatesthatifthecumulativecancerrisktoanindividualbasedonreasonablemaximumexposure(RME)is

B‐8

lessthan1E‐04andthecumulativenon‐cancerHQislessthan1,thenremedialactionisgenerallynotwarrantedunlessthereareadverseenvironmentalimpacts.Theguidancealsostatesthatariskmanagermaydecidethatarisklevellowerthan1E‐04isunacceptableandthatremedialactioniswarrantedwherethereareuncertaintiesintheriskassessmentresults.UseofSourceMaterialDatainDecision‐Making

Asnotedpreviously,intheeventABSairresultsindicatethatexposuresduringactivitiesinandaroundtheminedarearesultinunacceptablecumulativecancerrisksornon‐cancerHQs,informationonLAconcentrationsinsourcematerialswillbeusedtoinformdecisionsonthespecificareaswhereresponseactionswouldbemosteffectiveinreducingexposures.Forexample,supposetheon‐roadATVridingABSairconcentrationsforaspecifictrailresultedinunacceptableexposures.Iftheroadmaterialsamplesshowedthatthemajorityofthetrailwasnon‐detectforLA,buta0.5‐milesectionofthetrailhadroadmaterialsampleswithLAconcentrationsof2‐3%,focusingtheresponseactionstothe0.5‐milesectionmaybesufficienttominimizeLAexposuresforthistrail.Step6:SpecifyPerformanceCriteriaInmakingdecisionsabouttheriskstohumantrespasserswithintheminedarea,twotypesofdecisionerrorsarepossible: AfalsenegativedecisionerrorwouldoccurifariskmanagerdecidesthatexposuretoLAis

notofhealthconcern,wheninfactitisofconcern. AfalsepositivedecisionerrorwouldoccurifariskmanagerdecidesthatexposuretoLAis

abovealevelofconcern,wheninfactitisnot.EPAismostconcernedaboutguardingagainsttheoccurrenceoffalsenegativedecisionerrors,sinceanerrorofthistypemayleavehumansexposedtounacceptablelevelsofLA.Tominimizechancesofunderestimatingthetrueamountofexposureandrisk,EPAgenerallyrecommendsthatriskcalculationsbebasedonthe95%upperconfidencelimit(95UCL)ofthesamplemean(EPA1992).Useofthe95UCLinriskcalculationslimitstheprobabilityofafalsenegativedecisionerrortonomorethan5%.EPAhasdevelopedasoftwareapplication(ProUCL)toassistwiththecalculationof95UCLvalues(EPA2010a).However,equationsandfunctionsinProUCLarenotdesignedforasbestosdatasetsandapplicationofProUCLtoasbestosdatasetsisnotrecommended(EPA2008).Becausethe95UCLcannotpresentlybecalculatedwithconfidence,EPCsshouldbecalculatedasthearithmeticmean,treatingnon‐detectsaszero,asrecommendedbyEPA(2008).Thismeansthatriskestimatesmaybeeitherhigherorlowerthantruevalues,andthisshouldbeidentifiedasasourceofuncertaintyintheriskassessment.EPAisalsoconcernedwiththeprobabilityofmakingfalsepositivedecisionerrors.Althoughthistypeofdecisionerrordoesnotresultinunacceptablehumanexposure,itmayresultinunnecessaryexpenditureofresources.Theriskoffalsepositivedecisionerrorscanbeminimizedbyincreasingthenumberofsamples.Thenumberofsamplesneededdependsonthemagnitudeofbetween‐samplevariabilityandtheproximityofEPCtothedecisionthreshold.Ifbetween‐samplevariability

B‐9

islow,oriftheEPCisnotnearadecisionthreshold,thenthenumberofsamplesneededisrelativelylow.However,ifbetween‐samplevariabilityishighandtheEPCisrelativelynearadecisionthreshold,thenthenumberofsamplesneededisusuallyhigher.BasedonmeasureddatafromotheroutdoorABSsamplingefforts,thereisoftensubstantialvariabilityinmeasuredoutdoorABSconcentrationsofLAinairundersourcedisturbanceactivitiesanditispossiblethatmeasuredconcentrationsmaybenearriskmanagementdecisionthresholds.Becauseitisnotpossibleatpresenttoquantifytheuncertaintyinthemeanofanasbestosdatasetasafunctionofthenumberofsamples,itisnotpossibletocalculatetheminimumnumberofsamplesrequiredtominimizetheriskoffalsepositivedecisionerrors.TherearenodataonpotentialLAairconcentrationsthatmayresultduringthetrespasserABSscenarios.However,otheroutdoorABSinvestigationshaveshownthatconcentrationscanvarywidely,evenspanningseveralordersofmagnitudedependingupontheenvironmentalconditionsandintensityofthedisturbanceactivities.ItmaynotbepossibletocollectenoughsamplestofullycharacterizetheextentofvariabilityanduncertaintyassociatedwitheachABSscenario.Totheextentfeasible,thisstudyshouldmaximizethenumberofsamplescollectedsuchthattherearemultipleairmeasurementsforeachscenario.Ataminimum,3to5samplesperscenarioshouldbecollected.IftheresultsofthisABSeffortshowthattheairdataarevariableand/orarenearadecisionthreshold,additionalsamplingand/oranalysismaybeconductedtosupportriskmanagementdecision‐making.Step7:DevelopthePlanforObtainingDataABSAreasFigureA‐4inthemainSAP/QAPPidentifiesdisturbedareaoftheminewheretheoff‐roadATVridingandrockhoundABSscenarioswillbeconducted.Totheextentpracticable,ABSactivitieswillbeconductedsuchthattheresultingdataarerepresentativeoftheentiredisturbedarea.However,ATVridingwillnotbeperformedonsteepbenches,tailingspiles,andinimpoundmentareaswhereridingconditionswouldbeunsafe.Asnotedpreviously,thisABSareadoesnotincludelocationsintheminedareawherecovermaterialshavebeenplaced.Theon‐roadATVridingwilltakeplacealongthreedifferentroutes,eachencompassingadifferentsectionoftheminedarea.FigureA‐4inthemainSAP/QAPPidentifiesthreeATVridingroutesthatwillbetravelled.OptimizingtheSampleCollectionStrategyforAirSamplesTwokeyvariablesthatmaybeadjustedduringcollectionofairsamplesaresamplingdurationandpumpflowrate.Theproductofthesetwovariablesdeterminestheamountofairdrawnthroughthefilter,whichinturnisanimportantfactorintheanalyticalcostandfeasibilityofachievingthetargetanalyticalsensitivity(TAS).Ingeneral,longersamplingtimesarepreferredovershortersamplingtimesbecausea)longertimeintervalsaremorelikelytoyieldrepresentativemeasuresoftheaverageconcentration(asopposedtoshort‐termfluctuations),andb)longercollectiontimes

B‐10

areassociatedwithhighervolumes,whichmakesiteasiertoachievetheTAS.Likewise,higherflowratesaregenerallypreferredoverlowerflowratesbecausehighflowresultsinhighvolumesofairdrawnthroughthefilterovershortersamplingtimes.However,thereisalimittohowmuchaircanbedrawnthroughafilter.Incaseswheretheairbeingsampledcontainsasignificantlevelofairborneparticulates(e.g.,dust),itispossiblethatparticulateloadingonthefiltercouldinfluencetheabilitytomaintaintheoptimalflowrate.Tominimizethispossibility,pumpflowratesshouldbecheckedregularlythroughoutthecollectionperiodandfiltercassettesshouldbechangedifflowratescouldbecomeimpacted.Whileparticulateloadingonthefiltermaynotimpactpumpflowrates,itispossiblethatthefilterwillbecomesooverloadedwithairborneparticulatesthatthefiltercannotbeexamineddirectlybytheTEManalyst.ThisisparticularlyofconcernduringATVriding,whichislikelytoresultinhigherlevelsofairbornedust.Ifthefilterbecomesoverloadedwithparticulates(i.e.,theparticulateloadingonthefilteris>25%)orifthereisloosematerialintheaircassettecowl,thefiltermustundergoanindirectpreparation.Duringanindirectpreparation,theoriginalfilterisashedandtheresultingresidueissuspendedinwaterandre‐depositedonasecondaryfilter,suchthatthesecondaryfilterisnotoverloaded.Site‐specificstudiesontheeffectofindirectpreparationonreportedLAairconcentrationsshowthatindirectpreparationusuallyincreasedreportedPCMELAairconcentrations,buttheconcentrationswerewithinafactorofabout2‐4comparedtodirectpreparation(GoldadeandO’Brien2014).Tominimizetheneedforindirectpreparation,eachABSindividualwillweartwodifferentsamplingpumps–onethatoperatesatahighflowrate(whichistheprimarysample)andonethatoperatesatalowflowrate(whichisusedthesampleback‐up).Wheneverpossible,thefilterfromthehighflowpumpwillbeselectedforanalysis.Incaseswherethehighflowfiltercannotbeprepareddirectly,thelowflowfilterwillbeanalyzed.Ifbothfilterscannotbeprepareddirectly,thehighflowfilterwillbepreparedindirectlyfollowingashing.ATVRidingSamplingDurationandFlowRatesDuringtheOU3PhaseIIIinvestigation(EPA2009),ATVridingABSscenarioswereconductedinforestedareassurroundingtheOU3StudyArea.ResultsofthePhaseIIIstudyshowedallATVABSairfilterswereabletobeprepareddirectlywhenthesamplingdurationwas20minutesandtheflowratesrangedfrom2.0to4.0litersperminute(L/min)(CDMSmith2015).Thus,theATVridingscenarioforthisstudywilluseanequivalentrangeoftargetflowrates.Becausetheamountofvegetativecoverintheminedareawillbelessthantheforestedareas,itispossiblethatATVridingconditionsmaybedustierduringthisstudy;therefore,thesamplingdurationwillbereducedto15minutesperfilter.AswasdoneinthePhaseIIIATVridingABSscenario,therewillbetwoATVridersduringeachsamplingevent,aleaderandafollower.RiderswillfolloweachotherthroughoutthedurationoftheABSactivity,andtheleaderandfollowerriderswillswitchingpositionsevery7‐8minutesthroughouttheevent.Assuch,eachATVridingairfilterwillberepresentativeofaleader/followercompositeexposure.

B‐11

Basedonthelengthoftheon‐roadATVroutesplannedfortravelduringtheABS(seeFigureA‐4inthemainSAP/QAPP),itisexpectedthateachroutecanbetravelledinapproximately20‐30minutes(oneway);therefore,itwillbenecessarytoswitchoutfiltercassettesevery15minutesthroughoutthescenariotoavoidfilteroverloading.Eachoff‐roadsamplingeventwillhaveatotalsamplingdurationof45minutes,withairfiltercassetteschangedevery15minutesthroughoutthescenario.RockHoundSamplingDurationandFlowRatesPrevioushikingABSinvestigationsalongRainyCreekconductedduringthePhaseIV‐Ainvestigation(EPA2010b)showthemajorityoffiltersrequiredindirectpreparationwhenthesamplingdurationwas60minutesandtheflowratesrangedfrom1.0to4.0L/min(CDMSmith2015).BecausetheactivitiesperformedandtypesofsourcematerialsthatmaybeencounteredduringtherockhoundscenariomaybesimilartotheRainyCreekhikingABS,toavoidpotentialfilteroverloading,eachrockhoundsamplingeventwillhaveatotalsamplingdurationof45minutes,withairfiltercassetteschangedevery15minutesthroughoutthescenario.Becausethesamplingdurationwasreduced,thereisnoneedtoalsodecreasethetargetflowrates;thus,targetflowrateswillrangefrom2.0to4.0L/min.AnalyticalRequirementsforABSAirSamplesIngeneral,threealternativestoppingrulesarespecifiedforTEManalysestoensureresultingdataareadequate:

1.TheTASisachieved2.Amaximumnumberofstructureshasbeencounted3.Amaximumareaoffilterhasbeenexamined

Thebasisforeachofthesevaluesforthisstudyispresentedbelow.TargetAnalyticalSensitivityThelevelofanalyticalsensitivityneededtoensurethatanalysisofABSairsampleswillbeadequateisderivedbyfindingtheconcentrationofLAinABSairthatmightbeofpotentialconcern,andthenensuringthatifanABSsamplewereencounteredthathadatrueconcentrationequaltothatlevelofconcern,itwouldbequantifiedwithreasonableaccuracy.Thisprocessisimplementedbelow:

Step1.CalculationofRisk‐BasedConcentrationsCancer.Thebasicequationforcalculatingtherisk‐basedconcentration(RBC)forcanceris: RBCcancer=TargetCancerRisk/(TWF⋅IURLA)

B‐12

where:

TWF=Time‐weightingfactor.ThevalueoftheTWFtermrangesfromzerotoone,anddescribestheaveragefractionofalifetimeduringwhichexposureoccursfromthespecificactivitybeingassessedandiscalculatedas: TWF=ET/24⋅EF/365⋅ED/70where: ET=Averageexposuretime(hours/day) EF=Averageexposurefrequency(days/year) ED=Exposureduration(years)

IURLA=LA‐specificlifetimeinhalationunitrisk(LAPCMs/cc)‐1

Forcancer,thetargetcancerriskisariskmanagementdecision.ForthepurposesofcalculatinganadequateTAS,avalueof1E‐05isassumed.TheexposureparametersneededtocalculateTWFarenotknownwithcertainty,sotheestimatesfortheABSscenariosevaluatedinthisQAPP/SAParebasedprimarilyonprofessionaljudgment,assumingthatbothreceptorsarelocalarearesidents,andintendedtoberepresentativeofreasonablemaximumexposure(RME)values.ThefollowingtablepresentstheRMEexposureparametersthatwereselectedforthepurposesofderivingtargetanalyticalrequirementsforthisstudy.Notethattheriskassessmentmayadjustthesepreliminaryexposureparametersasappropriateforthepurposesofcalculatingexposuresandrisks.

Scenario ExposureTime ExposureFrequency

ExposureDuration

Time‐WeightingFactor[TWF]

ATVRiding 4hours/day 10days/year 50years 0.0033Rockhound 6hours/day 10days/year 50years 0.0049

BasedontheTWFvaluespresentedabove,theRBCcanceris0.018LAPCMEs/ccfortheATVridingscenarioand0.012LAPCMEs/ccfortherockhoundscenario.Non‐Cancer.ThebasicequationforcalculatingtheRBCfornon‐cancereffectsis: RBCnon‐cancer=(TargetHQ⋅RfCLA)/TWFwhere:

TWF=Time‐weightingfactor(seeaboveforequation)

RfCLA=LA‐specificreferenceconcentration(LAPCMs/cc)

B‐13

Fornon‐cancer,thetargetHQis1.BasedontheTWFvaluespresentedabove,theRBCnon‐canceris0.028LAPCMEs/ccfortheATVridingscenarioand0.018LAPCMEs/ccfortherockhoundscenario.BecausetheRBCforcancerislowerthantheRBCfornon‐cancer,theRBCcancerisusedtoderivetheTAS.Step2:DeterminingtheTargetAnalyticalSensitivityTheTASisdeterminedbydividingtheRBCbythetargetnumberofstructurestobeobservedduringtheanalysisofasamplewithatrueconcentrationequaltotheRBC:TAS=RBC/TargetCountThetargetcountisdeterminedbyspecifyingaminimumdetectionfrequencyrequiredduringtheanalysisofsamplesattheRBC.Thisprobabilityofdetectionisgivenby:Probabilityofdetection=1‐POISSON(0,TargetCount,TRUE)Assumingaminimumdetectionfrequencyof95%,thetargetcountis3structures.Basedonthis,theTASis:TASATV=(0.018s/cc)/(3s)=0.006percubiccentimeter(cc‐1)TASRockhound=(0.012s/cc)/(3s)=0.004cc‐1Thus,ananalyticalsensitivityof0.006cc‐1fortheATVridingscenarioand0.004cc‐1forrockhoundscenariowillbeusedasthetargetforABSairsamplescollectedinthisstudy.

MaximumNumberofLAStructuresIdeally,allsampleswouldbeexaminedbyTEMuntiltheTASisachieved.However,forfiltersthathavehighasbestosloading,reliableestimatesofconcentrationmaybeachievedbeforeachievingtheTAS.ThisisbecausetheuncertaintyaroundaTEMestimateofasbestosconcentrationinasampleisafunctionofthenumberofstructuresobservedduringtheanalysis.The95%confidenceinterval(CI)aroundacountofNstructuresiscomputedasfollows:

Lowerbound(2.5%)=½∙CHIINV(0.975,2∙N+1)Upperbound(97.5%)=½∙CHIINV(0.025,2∙N+1)

AsNincreases,theabsolutewidthoftheCIrangeincreases,buttherelativeuncertainty(expressedastheCIrangedividedbyN)decreases.Thisconceptisillustratedinthefigurebelow.ThegoalistospecifyatargetNsuchthattheresultingPoissonvariabilityisnotasubstantialfactorintheevaluationofmethodprecision.

B‐14

RELATIONSHIP BETWEEN THE NUMBER OF STRUCTURES

OBSERVED AND RELATIVE UNCERTAINTY

CI=confidenceintervalAsshowninthefigure,aboveabout25structures,thereislittlechangeintherelativeuncertainty.Therefore,thecount‐basedstoppingruleforTEMshouldutilizeamaximumstructurecountof25structures.BecausetheABSairconcentrationswillbeusedtoestimatepotentialrisks,whicharederivedbasedonthetotalnumberofstructuresthatmeetPCMcountingrules,themaximumstructurecountisapplicabletoPCMELAstructures(nottotalLAstructures).MaximumAreatobeExaminedThenumberofgridopeningsthatmustbeexaminedtoachieveTASiscalculatedas:

GOx=EFA/(TAS∙Ago∙V∙1000∙f)where:

EFA=Effectivefilterarea(assumedtobe385squaremillimeters[mm2])TAS=Targetanalyticalsensitivity(cc)‐1Ago=Gridopeningarea(assumedtobe0.01mm2)V=Sampleairvolume(liters[L])1000=L/cc(conversionfactor,literstocubiccentimeters[L/cc])f=Indirectpreparationdilutionfactor(equalto1fordirectpreparation)

AssumingthehighvolumeABSairfilterisabletobeprepareddirectlyforTEManalysisandthatthesamplingdurationis15minutes,atotalofabout107gridopeningswillneedtobeexaminedfor

B‐15

eachsampletoachievetheTASfortheATVridingscenarioand161gridopeningswillneedtobeexaminedtoachievetheTASfortherockhoundscenario.Ifanindirectpreparationisnecessary,thenumberofgridopeningsthatwillneedtobeexaminedisinverselyproportionaltothedilutionneeded(i.e.,anf‐factorof0.1willincreasethenumberofgridopeningsbyafactorof10).Ifthef‐factorisverysmall,itispossiblethatthenumberofgridopeningsthatwouldneedtobeexaminedtoachievetheTASmaybecostortimeprohibitive.Inordertolimitthemaximumeffortexpendedonanyonesample,amaximumareaexaminedof4.0mm2isidentifiedforthisproject.Assumingthateachgridopeninghasanareaofabout0.01mm2,thiswouldcorrespondtoabout400gridopenings.SummaryofTEMStoppingRulesforAirSamplesTheTEMstoppingrulesforairsamplescollectedinthisstudyshouldbeasfollows:1.Examineaminimumoftwogridopeningsfromeachoftwogrids.2.Continueexamininggridopeningsuntiloneofthefollowingisachieved:

a.TheTASof0.006cc‐1isachievedforATVridingscenarioor0.004cc‐1isachievedforrockhoundscenario.

b.25PCMELAstructureshavebeenobserved. c.Atotalfilterareaof4.0mm2hasbeenexamined.Whenoneofthesecriteriahasbeensatisfied,completetheexaminationofthefinalgridopeningandstop.OverviewofSamplingDesignforAirSamplesThreeABSeventswillbeperformedonthreeseparatedaysoveranapproximate1‐weekduration.DuringeachABSevent,boththeATVridingandrockhoundscenarioswillbeperformed.ForeachABSscenario,therewillbetwofieldpersonnel.Eachindividualwillweartwoairsamplingpumps,whichwillresultintwocollectedfiltersforeachsamplingperiod–aprimaryhighvolumeairfilter(collectedatthehighertargetflowrate)andareplicatelowvolumeairfilter(collectedatthelowertargetflowrate).Theprimaryhighvolumesamplewillbeanalyzedinpreferencetothereplicatelowvolumesample;thereplicatelowvolumesampleswillbearchivedatthelaboratoryandonlyanalyzediftheprimaryfilterisdamagedordeterminedtobeoverloaded.TwotypesofATVridingwillbeperformed:1)onexistingroadsandtrails(“on‐road”),and2)onthedisturbedareaofthemine(“off‐road”).AlloftherockhoundABSwillbeperformedonthedisturbedareaofthemine.AppendixCprovidesdetailedscriptsforeachABSscenariothatwillbefollowedbytheABSpersonnelwhenperformingATVridingandrockhoundactivities.ThefollowingtablesummarizesthebasicstudydesignandtheanticipatednumberofABSairsamplesthatwillbecollectedandanalyzedforeachscenario.

B‐16



ATV Riding

On-road: On roads & trails (3 routes)

16 samples [2 people/event, 8 filters/person*]

48 samples [3 events (1 route per event)]

24 analyses†

Off-road: On disturbed area of mine



Rock Hound

On disturbed area of mine



*Foreachperson,therewillbefour15‐minutefilters(twohighvolume,twolowvolume)collectedfromthestarttotheendoftherouteandfour15‐minutefiltersfromtheendoftheroutebacktothestart.Thisassumesitwilltake30minutes(oneway)totraveltheroute;atotalABSscenariodurationof60minutes.**Foreachperson,therewillbesix15‐minutefilters(threehighvolume,threelowvolume)collectedoverthe45minutesamplingduration.†Eitherthehighvolumeorthelowvolumefilterofeachsamplepairwillbeanalyzed;theremainingfilterwillbearchived.SampleDesignforRoadMaterialSamplesRoadmaterialsampleswillbecollectedalongeachofthethreeATVridingroutesshowninFigureA‐4ofthemainSAP/QAPPtext.Sampleswillbecollectedatapproximate0.25‐mileintervalsalongtheentireroute.Basedonthelengthofeachsamplingroute,itisanticipatedthat12‐15sampleswillbecollectedfromeachroute(approximately42samplestotal).Eachroadmaterialsamplewillbeasinglegrabsamplecollectedfromthesurfacetoadepthof6inches.Foreaseofsamplecollection,samplingeffortswillfocusontheroadmarginareaswherethematerialsarelesscompacted.AllcollectedroadmaterialsampleswillbepreparedandanalyzedbyPLMinaccordancewiththeSite‐specificmethodsdevelopedforuseindeterminingLAlevelsinsoil.

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ReferencesCDMSmith.2015.LibbyAsbestosSuperfundSite,OperableUnit3,DataSummaryReport:2007to2013.January–Revision2.EPA(U.S.EnvironmentalProtectionAgency).1991.RoleoftheBaselineRiskAssessmentinSuperfundRemedySelectionDecision.Washington,D.C.:U.S.EnvironmentalProtectionAgency,OfficeofSolidWasteandEmergencyResponse.OSWERDirectiveNumber9355.0‐30.April.http://www.epa.gov/oswer/riskassessment/pdf/baseline.pdf .1992.SupplementalGuidancetoRAGS:CalculatingtheConcentrationTerm.U.S.EnvironmentalProtectionAgency,OfficeofSolidWasteandEmergencyResponse.Publication9285.7‐081.http://www.deq.state.or.us/lq/pubs/forms/tanks/UCLsEPASupGuidance.pdf .2001.EPARequirementsforQualityAssuranceProjectPlans,QA/R‐5.U.S.EnvironmentalProtectionAgency,OfficeofEnvironmentalInformation.March.http://www.epa.gov/quality/qs‐docs/r5‐final.pdf______.2007a.PhaseISamplingandAnalysisPlan,LibbyAsbestosSuperfundSite,OperableUnit3.Revision0–September.______.2007b.SummaryReportforDataCollectedundertheSupplementalRemedialInvestigationQualityAssuranceProjectPlanLibby,MontanaSuperfundSite.U.S.EnvironmentalProtectionAgency,Region8.October. .2006.GuidanceonSystematicPlanningUsingtheDataQualityObjectiveProcess,QA/G‐4.U.S.EnvironmentalProtectionAgency,OfficeofEnvironmentalInformation.February.http://www.epa.gov/quality/qs‐docs/g4‐final.pdf .2008.FrameworkforInvestigatingAsbestos‐ContaminatedSites.ReportpreparedbytheAsbestosCommitteeoftheTechnicalReviewWorkgroupoftheOfficeofSolidWasteandEmergencyResponse,U.S.EnvironmentalProtectionAgency.OSWERDirective#9200.0‐68.http://www.epa.gov/superfund/health/contaminants/asbestos/pdfs/framework_asbestos_guidance.pdf_____.2009.PhaseIII,LibbyAsbestosSuperfundSite,OperableUnit3.FieldModification#LFM‐OU3‐05.AttachmentA‐ABSScriptRevision3.August31.___.2010a.ProUCLVersion5.0TechnicalGuide(Draft).U.S.EnvironmentalProtectionAgency,OfficeofResearchandDevelopment.EPA/600/R‐07/041.May2010.http://www.epa.gov/esd/tsc/ProUCL_v4.00.05/ProUCL_v4.00.05_tech_guide(draft).pdf_____.2010b.PhaseIVSamplingandAnalysisPlan,PartA–DatatoSupportHumanHealthRiskAssessment,LibbyAsbestosSuperfundSite,OperableUnit3.Revision0–June14.

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_____.2014.ToxicologicalReviewofLibbyAmphiboleAsbestos.WashingtonD.C.:U.S.EnvironmentalProtectionAgency,OfficeofResearchandDevelopment,NationalCenterforEnvironmentalAssessment,IntegratedRiskInformationSystem.EPA/635/R‐11/002F.December.http://www.epa.gov/iris/supdocs/1026index.htmlGoldade,MP,andO’Brien,WP.2014.Useofdirectversusindirectpreparationdataforassessingriskassociatedwithairborneexposuresatasbestos‐contaminatedsites.JournalofOccupationalandEnvironmentalHygiene11(2):67‐76.

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APPENDIXC:MINEDAREATRESPASSERABSSCRIPTS

ATVRiding

Allall‐terrainvehicle(ATV)ridingwilloccurwithintheW.R.GraceandCompany(Grace)propertyboundary.TheATVridingactivity‐basedsampling(ABS)scenariowillbeconductedwithsingleridersontwoATVs.APolarisRanger500®four‐wheeldrive(4WD)“side‐by‐side”,oralternatevehiclesofsimilarsizeanddesign,willbeusedduringtheABS.Forboththeon‐roadandoff‐roadATVridingscenarios,thefirstATVwillbetheleaderandthesecondATVriderwillbethefollower.Theparticipantswillswitchtheleader/followerpositionsasdescribedbelow.Thefollowershallmaintainasafefollowingdistance,similartowhatwouldbeexpectedundernormalATVridingconditions(i.e.,asiftheywerenotwearingpersonalprotectiveequipment[PPE]).ThedistancebetweenATVswilldependontheterrainandamountofdustgeneratedbytheleadATV;duringthePhaseIIIATVridingABS,thefollowingdistancewastypicallylessthan50yardsunderlessdustyconditions,andasmuchas200yardsunderverydry,dustyconditions.ATVsshouldbeoperatedatspeedsof10milesperhour(mph)orless,dependingonterrainandsafetyconsiderations.

AtotalofthreeATVridingsamplingeventswillbeconductedforeachscenario(i.e.,on‐roadandoff‐road).Toensurethattheresultingdataencompassawiderangeofmeteorologicalconditions,totheextentpossible,samplingeventsshouldbeconductedondifferentdaysatdifferenttimes(e.g.,oneeventinthemorningonday1,oneeventintheafternoononday3).Intheeventthattheoff‐roadATV‐ridingandrockhoundscenariosareconductedonthesameday,therockhoundscenarioshouldbeperformedfirst,toavoidthepotentialthatthisscenarioisimpactedbyairbornedustgeneratedduringtheoff‐roadATVriding.

On‐roadATVRiding.Fortheon‐roadATVridingscenario,therearethreeroad/trailroutesthatwillbeevaluated.Forallroutes,theriderswillstartontheunpavedportionofRainyCreekRoadneartheamphitheater.Fromtheamphitheater,riderswilleither:

a) ContinuenorthuptheunpavedportionofRainyCreekRoaduntiltheintersectionwithJacksonCreekRoad.TheriderswillturnleftontoJacksonCreekRoadandcontinueridingforapproximatelyonemiletothepointwheretheroadleavestheGracepropertyboundary.ThisisreferredtoasOptionAonFigureA‐4.

b) ContinuenorthuptheunpavedportionofRainyCreekRoadtowardsthesparselyvegetateddisturbedareaofthemine.Oncetheridersareontheminedarea,theywillcontinueridingupthemainhaulroadtowardsthetopofthemine.ThisisreferredtoasOptionBonFigureA‐4.

c) HeadnorthonRainyCreekRoadforapproximately0.5milestowardsthedam.Asyouapproachthedamstayrightatthe‘Y’intheroadanddriveontheunpavedtrailtowardsthedam.Beforeyoureachthedam,stayontheunpavedtrailandturnrightandheadeastacrossrainycreektowardstheformermine.OnceacrossRainyCreek,stayontheunpavedtrailandheadsouthuntilthetrailintersectsNF‐401.OnceonNF‐401,headbacknorthtowardsthesparselyvegetateddisturbedareaofthemine.Onceonthemine,ATVriders

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willcontinueonNF‐401towardsthemainhaulroad.Onceonthemainhaulroadtheywillcontinuetothetopofthemine.ThisisreferredtoasOptionConFigureA‐4.

Foreachsamplingevent,theATVriderswilltravelthelengthoftherouteswitchingleader/followerpositionsevery7‐8minutes.Onceridersreachtheendoftheroute,theriderswillreturntotheamphitheaterfollowingthesamereturnroute.Thereisnoestablisheddurationforeachsamplingevent;samplingwillcontinueuntiltheentireATVroutehasbeentraveled.Itisanticipateditwilltakeapproximately20‐30minutestotravelthelengthoftherouteandanadditional20‐30minutestoreturntotheamphitheater.Whileriding,aircassettefilterswillbechangedoutevery15minutestoreducethepotentialforfilteroverloading.

Off‐roadATVRiding.Oncetheridershavearrivedbackattheamphitheater,theywillconducttheoff‐roadATVscenario,ridingatrandomwithinthedisturbedareasofthemineforatotalof45minutes.FigureA‐4illustratestheABSareawheretheoff‐roadABSactivitieswillbeperformed(seeyellowshadedarea).Asshown,activitieswillconductedinthedisturbedareasoftheminewherecoversoilshavenotbeenplaced.NotethatATVridershouldattempttocoverasmuchoftheABSareaaspossible,butavoidridingonsteepbenches,tailingspiles,andinimpoundmentareaswhereridingconditionswouldbeunsafe.

EachATVriderwillbeequippedwithaGlobalpositioningsystem(GPS)unit.GPScoordinateswillbeautomaticallygeneratedatregularintervalstodocumenttheactuallocationstraveledduringeachoff‐roadATVridingsamplingevent.

Rockhound

“Rockhound”ABSwillbeconductedbytwoindividualsperformingrockhoundactivitiessimultaneously.TherockhoundABSwillbeconductedonmineareaswherevegetationissparseandvermiculiteand/orLibbyamphiboleasbestos(LA)‐containingrocksareprevalent.EachABSpersonnelwillcarryacanvas/plastic/leatherbag(thatcanbedecontaminatedordisposedoffollowingABSactivities)forcollectingrocksandarockhammer,orsimilardevice,forbreakingrocksapart.[Note:Avoidpoundingonerockhammeragainstanotherrockhammer,asthiscanresultinchippingofthehammerfaceandcouldresultininjury.]TheABSpersonnelwillmimicpeoplelookingforinterestingrockandmineralspecimensbyexaminingoutcropsandwasterockpiles,collectingspecimensinabag,andgenerallywalkingaroundtheformermine.AtendoftheABSactivities,collectedspecimensshouldbeleftintheminedareainalocationwheresourcematerialsarepresent.

FigureA‐4illustratestheABSareawheretherockhoundABSactivitieswillbeperformed.Duringeachsamplingevent,therockhoundshouldattempttocoverasmuchoftheABSareaaspossible,focusingactivitiesinareaswhereLA‐containingrocksmayoccur(e.g.,outcrops,rockfaces,wasterockpiles).Afterexaminingaparticularlocation,thetwopersonnelwilldrivetothenextlocationinanATV,leavingthesamplingpumpsrunningwhiledrivingbetweenlocations.Vehiclesshouldbeoperatedatspeedsof10milesperhour(mph)orless,dependingonterrainandsafetyconsiderations.

EachrockhoundwillbeequippedwithaGPSunitandGPScoordinateswillbeautomaticallygeneratedatregularintervalstodocumentthelocationstraveledduringeachrockhoundsampling

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event.TheABSpersonnelwillstaywithineyecontactoffieldsupportpersonnelduringthesampling.

Atotalofthree45‐minuterockhoundsamplingeventswillbeconducted.Duringeachsamplingevent,aircassettefiltersshouldbechangedoutevery15minutestoreducethepotentialforfilteroverloading.Toensurethattheresultingdataencompassawiderangeofmeteorologicalconditions,totheextentpossible,samplingeventsshouldbeconductedondifferentdaysatdifferenttimes(e.g.,oneeventinthemorningonday1,oneeventintheafternoononday3).


APPENDIX D: STANDARD OPERATING PROCEDURES**

SOP ID SOP Description

OU3 No. 1 Soil Sampling for Non-Volatile Organic Compound Analysis

OU3 No. 7 Equipment Decontamination OU3 No. 8 Sample Handling and Shipping OU3 No. 9 Field Documentation OU3 No. 11 GPS Data Collection OU3 No. 12 Investigation Derived Waste (IDW) Management ABS-LIBBY-OU3 Activity-based Sampling for Asbestos

EPA-LIBBY-08 Indirect Preparation of Air and Dust Samples for TEM Analysis

SRC-LIBBY-01 PLM Gravimetric Evaluation SRC-LIBBY-03 PLM Visual Area Estimation

16-ASB-06.02 Soil Sample Preparation at the Troy Sample Preparation Facility

EPA-LIBBY-09 SOP for TEM Data Review and Data Entry Verification EPA-LIBBY-10 SOP for PLM Data Review and Data Entry Verification EPA-LIBBY-11 SOP for FSDS Data Review and Data Entry Verification QATS-70-095-01 SOP for the Validation of Libby TEM Data Deliverables QATS-70-094-01 SOP for the Validation of Libby PLM Data Deliverables

**The most recent versions of field SOPs are provided electronically in the OU3 eRoom (https://team.cdm.com/eRoom/mt/LibbyOU3). The most recent versions of laboratory and data verification SOPs are provided electronically in the Libby Lab eRoom (https://team.cdm.com/eRoom/mt/LibbyLab).


of Times:

:

g

APPENDIX E:Libby Asbestos Project Equipment Decontamination Checklist

Date: Site Location:

Removal Contractor : Owner of Equipment:

Type of Equipment: Odometer or Hour MeterEquipment Identification Number: USACE pre‐notification:

Purpose of Decontamination Check One Air Filtration Units Yes/NA Parts Number

End of Service Cab Filter Replaced

Change of Duty Engine Intake Filter Replaced

Repairs Main HEPA Filter Replaced Other: Prefilter on HEPA Replaced

General Requirements Yes/NA Water Truck (Mine Use) Yes/NA

Remove All Protective Plating Flush Water Delivery System Number y y

Pressurize Wash All Surfaces Water System SampledWash Engine Compartment Non‐detect Sample Results

Remove All Floor Mats Industrial Vacuum

Wet Wipe/ HEPA Vac Interior Hopper Decontamination

Comments:

Filter Disposal Information:

Sign below when the full decontamination has been performed per the RAWP standard.

Form Completed by: Signed: Date

RC Inspection Performed by : Signed: Date

TQA Inspection Performed by: Signed: DateUSACE Completion Notification: Rep: Time: Date:


APPENDIX F

TRESPASSER ABS FIELD SAMPLE DATA SHEETS


Trespasser Activity-Based Sampling Libby OU3 Personal Air Sample Field Sample Data Sheet (FSDS) FSDS# PA-___________ Field Logbook #___________________ Field Logbook Pages____________ Sampling Team MWH GPS Coordinate System UTM Zone 11 North, NAD83 datum, meters

For Field Team Completion: Completed by: _______ QC by:_______ For Data Entry: Entered by:________ QC by:_________

Sample 1 2 3

* Sample ID

* Sampler (initials)

* Sample Air Volume Type HV LV NA HV LV NA HV LV NA

* Sample Type (check one)

On-Road ATV Riding

Route A On-Road ATV

Riding

Route A On-Road ATV

Riding

Route A

Route B Route B Route B

Route C Route C Route C

Off-Road ATV Riding Off-Road ATV Riding Off-Road ATV Riding

Rock hound Rock hound Rock hound

NA NA NA

If HV, specify paired LV

* Field QC Type Field Sample Field Blank Lot Blank

Field Sample Field Blank Lot Blank

Field Sample Field Blank Lot Blank

* Flow Meter Type NA Rotameter DryCal NA Rotameter DryCal NA Rotameter DryCal

* (For Blanks, “Z” through “Pump ID” to “Sample Air Stop Flow” Cassette Lot No ____________ Flow Meter ID ____________ then check NA for “Pump Fault” & enter 0 for “Sample Total Time”)

* Pump ID

* Sample Air Start Date

* Sample Air Start Time

* Sample Air Start Flow (L/min)

* Sample Air Stop Date

* Sample Air Stop Time

* Sample Air Stop Flow (L/min)

* Pump Fault No Yes NA No Yes NA No Yes NA

Sample Total Time (min)

Sample Quantity (L)

Sample Field Comments

V090415 *Required Field Filter Diameter = 25mm; Pore Size=.8µm

Trespasser Activity-Based Sampling Libby OU3 Soil Sample Field Sample Data Sheet (FSDS) FSDS# S-____________ Field Logbook #___________________ Field Logbook Pages____________ Sample Date _______________ Sampling Team MWH Sampler(s) ____________________________________________________ GPS Coordinate System UTM Zone 11 North, NAD83 datum, meters

For Field Team Completion: Completed by: _______ QC by:_______ For Data Entry: Entered by:________ QC by:_________

Sample 1 2 3

* Sample ID

* Sample Location Route A Route B Route C

Route A Route B Route C


* Field QC Type Field Sample Field Duplicate

Field Sample Field Duplicate


Sample Parent ID

* Sample Type Grab Composite, # Aliquots: _____

Grab Composite, # Aliquots: _____


* Soil Depth Top Inches Inches Inches

* Soil Depth Bottom Inches Inches Inches

* Sample Time

* GPS Coordinates X: X: X:

Y: Y: Y:


Sample 4 5 6

* Sample ID

* Sample Location Route A Route B Route C



* Field QC Type Field Sample Field Duplicate



Sample Parent ID

* Sample Type Grab Composite, # Aliquots: _____



* Soil Depth Top Inches Inches Inches

* Soil Depth Bottom Inches Inches Inches

* Sample Time

* GPS Coordinates

X: X: X:

Y: Y: Y:


V 090415 *Required Field

Requirements Summary: #TRESOU3-0915 Requirements Revision #: 1

Effective Date: September 16, 2015

Page 1 of 3

APPENDIX G: ANALYTICAL REQUIREMENTS SUMMARY SHEET #TRESOU3-0915 SUMMARY OF PREPARATION AND ANALYTICAL REQUIREMENTS

Title: Trespasser Activity-Based Sampling, Operable Unit 3, Libby Asbestos Superfund Site SAP/QAPP Date/Revision: September 16, 2015 (Revision 0) EPA Technical Advisor: Christina Progess (303-312-6009, [email protected]) (contact to advise on DQOs of SAP related to preparation/analytical requirements) Sampling Program Overview: The purpose of this study is to collect samples of air during ATV riding and rock hound activities in the mined area of OU3. All air samples will be analyzed by TEM under low magnification. Samples of road materials from the ATV routes will be collected and analyzed by PLM. Index ID Prefix: TS-xxxxx Estimated number (excluding field QC) and timing of field samples: Samples will be collected in mid-late September timeframe (exact dates to be determined) >> ABS Air: 60 samples >> Road Materials: 45 samples TEM Preparation and Analytical Requirements for Air Samples [a]:

Medium Code Medium

Preparation Details [b] Analysis Details Applicable Laboratory Modifications

(current version of) Investi-gative?

Indirect Prep? Filter Archive? Method Recording

Rules Analytical Sensitivity/

Stopping Rules With Ashing

Without Ashing

A ABS Air, ATV

Yes Yes, if material is overloaded (>25%) or unevenly loaded on

filter

No Yes TEM – Modified

ISO 10312,

Annex E (Low Mag,

5,000X)

All PCME asbestos [c]; L: > 5 µm

W: > 0.25 µm AR: > 3:1

Count a minimum of 2 grid openings in 2 grids, then continue counting until one is achieved: i) target sensitivity is achieved [d] ii) 25 PCME LA structures are recorded iii) A total filter area of 7.0 mm2 has been examined (approx. 700 GOs)

LB-000016, LB-000029, LB-000066, LB-000067, LB-000085, LB-000091

B ABS Air,

Rock Hound



Page 2 of 3

[a] The high volume filter will be analyzed in preference to the low volume filter if direct preparation is possible. If the high volume filter is overloaded, use the low volume filter. If the low volume filter is overloaded, prepare indirectly (with ashing), calculate number of grid openings to analyze to reach target analytical sensitivity and contact EPA project managers or their designate before proceeding with analysis. [b] See most current version of SOP EPA-LIBBY-08 (as modified by LB-000091) for preparation details. [c] If observed, chrysotile structures should be recorded, but chrysotile structure counting may stop after 25 structures have been recorded. [d] The target analytical sensitivity is 0.006 cc-1 for ATV (Media Code A) and 0.004 cc-1 for rock hound (Media Code B). TEM Preparation and Analytical Requirements for Field Quality Control Samples:

Medium Code

Medium, Sample Type

Preparation Details Analysis Details Applicable Laboratory Modifications

(current version of)

Indirect Prep? Archive? Method Recording

Rules Stopping Rules With Ashing

Without Ashing

C Air, field blanks

No No Yes TEM – Modified

ISO 10312, Annex E

(Low Mag, 5,000X)

All PCME asbestos; L: > 5 µm

W: > 0.25 µm AR: > 3:1

Examine 0.1 mm2 of filter area. LB-000016, LB-000029, LB-000066, LB-000067,

LB-000085

E Air, lot blanks

No No Yes TEM – AHERA

All asbestos; L: > 0.5 µm AR: > 3:1

Examine 0.1 mm2 of filter area. LB-000031, LB-000029, LB-000067, LB-000085

PLM Preparation and Analytical Requirements:

Medium Code Sample Type Preparation Method Analysis Method Applicable Laboratory

Modifications (current version of)

D Soil – all field samples 16-ASB-06.02, Troy SPF Soil Preparation

PLM-Grav: SRC-LIBBY-01 Rev. 3 PLM-VE: SRC-LIBBY-03 Rev. 3

LB-000073, LB-000088, LB-000097, LB-000098

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ Laboratory Quality Control Sample Frequencies: TEM [e]: Lab Blank – 4% PLM [g]: Lab Duplicates – 10% (cross-check 8%; self-check 2%) Recount Same – 1% Interlab – 1% [h] Recount Different – 2.5% Verified Analysis – 1% Interlab – 1% [f] Repreparation – 1% [e] See LB-000029 for selection procedure and QC acceptance criteria; frequency specific to OU3. [f] Post hoc selection to be performed by the QATS contractor [g] See LB-000073 for selection procedure and QC acceptance criteria; frequency specific to OU3.



Page 3 of 3

[h] Selection to be performed by the Troy SPF at the time of preparation; as necessary, additional post hoc selection may be performed by the QATS contractor Requirements Revision:

Revision #: Effective Date: Revision Description 0 9/15/2015 -- 1 9/16/2015 Modified to include analysis of lot blank by TEM-AHERA (Media Code E).

Analytical Laboratory Review Sign-off:

EMSL04 – Cinnaminson [sign & date: Robyn Ray 15 September 2015] EMSL22 – Centennial [sign & date: William Nguyen 16 September

2015]

EMSL03 – Manhattan [sign & date: Jose Arriaga 16 September 2015] EMSL45 – Sierra Madre [sign & date: _________________________] ESATR8 [sign & date: __Douglas_Kent_14_September_2015___]

[Checking the box and initialing above indicates that the laboratory has reviewed and acknowledged the preparation and analytical requirements associated with the specified SAP.]


APPENDIX H

RECORD OF MODIFICATION FORMS


Requested by: Date: Description of Deviation: _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ EPA Region 8 has reviewed this field modification approves as proposed. EPA Region 8 has reviewed this field modification and approves with the following exceptions: _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ EPA Region 8 has reviewed this field modification and does not agree with the proposed approach for the following

reasons: _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ ______________________________________ _____________________ Christina Progess, EPA RPM Date

FIELD MODIFICATION APPROVAL FORM LFM-OU3-xx

Libby OU3 Trespasser ABS QAPP (Revision 0)

Libby Lab Modification Form LB-0000XXa Page 1 of 2

Instructions to Requester: E-mail form to contacts at bottom of form for review and approval. All Labs Applicable Forms – copies to: EPA LC, QATS contractor, All Project Labs

Individual Labs Applicable Forms – copies to: EPA LC, QATS contractor, Initiating Lab

Method (circle all applicable): TEM-AHERA TEM-ISO 10312 PCM-NIOSH 7400

EPA/600/R-93/116 ASTM 5755 TEM 100.2 SRC-LIBBY-03

SRC-LIBBY-01 NIOSH 9002 Other:

Requester: Title: Company: Date: Original Requester: Original Request Date: [only applicable if modification is a revision of an earlier modification]

Description of Modification: Reason for Modification: Potential Implications of this Modification:

Laboratory Applicability (circle one): All Individual(s)

This laboratory modification is (circle one): NEW APPENDS to ___________ SUPERCEDES Duration of Modification (circle one):

Temporary Date(s): Analytical Batch ID:

Temporary Modification Forms – Attach legible copies of approved form with all associated raw data packages

Permanent (Complete Proposed Modification Section) Effective Date:

Permanent Modification Forms – Maintain legible copies of approved form in a binder that can be accessed by analysts.

Proposed Modification to Method (attach additional sheets if necessary; state section and page numbers of method when applicable): REFERENCES

Request for Modification

to Laboratory Activities

LB-0000XX

Libby Lab Modification Form LB-0000XXa Page 2 of 2

Data Quality Indicator (circle one) – Please reference definitions below for direction on selecting data quality indicators:

Not Applicable Reject Low Bias Estimate High Bias No Bias DATA QUALITY INDICATOR DEFINITIONS:

Reject - Samples associated with this modification form are not useable. The conditions outlined in the modification form adversely affect the associated sample to such a degree that the data are not reliable. Low Bias - Samples associated with this modification form are useable, but results are likely to be biased low. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimated low. Estimate - Samples associated with this modification form are useable, but results should be considered approximations. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimates. High Bias - Samples associated with this modification form are useable, but results are likely to be biased high. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimated high. No Bias - Samples associated with this modification form are useable as reported. The conditions outlined in the modification form suggest that associated sample data are reliable as reported. Technical Review: Date: (Laboratory Manager or designate) Project Review and Approval: Date: (USEPA: Project Manager or designate) Approved By: Date: (USEPA: Technical Assistance Unit Chief or designate)

Documents

Sampling and Analysis Plan/Quality Assurance Project Plan ...Robert Medler, [email protected] (1 hard copy, electronic copy) Robert Marriam, [email protected] (electronic