HUMAN HEALTH RISK ASSESSMENT QUALITY ASSURANCE … · Human Health Risk Assessment Quality...

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Human Health Risk Assessment

Quality Assurance Project Plan

Tar Creek Superfund Site, Operable Unit No. 4

Ottawa County, Oklahoma

Response Action Contract No. 68-W6-0025

EPA Work Assignment No. 233-RKED-06JW

CH2M HILL Project Number: 317950

Prepared for

U.S. Environmental Protection Agency

Prepared by

CH2M HILL, INC.

May 2005

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TAR CREEK OU4 HUMAN HEALTH RISK ASSESSMENT QUALITY ASSURANCE PROJECT PLAN

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QUALITY ASSURANCE PROJECT PLAN (QAPP)

APPROVAL SHEET


Tar Creek Superfund Site OU 4


Prepared by: CH2M HILL Date: May 2005

Approved by:

__________________________________________ ____________________

Ursula Lennox Date

U.S. EPA, Region 6, Work Assignment Manager

__________________________________________ ____________________

Scott Irving Date

CH2M HILL, Project Manager

__________________________________________ ____________________

John Ynfante Date

CH2M HILL, Project Chemist

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QUALITY ASSURANCE PROJECT PLAN (QAPP)

DISTRIBUTION LIST


Tar Creek Superfund Site OU 4


Copies of this QAPP have been distributed to the following people:

• Ursula Lennox – U.S. EPA, Region 6, Work Assignment Manager

• Christy Warren – U.S. EPA Region 6 Regional Laboratory Manager

• Myra Perez – USEPA Region 6 Regional Sample Control Coordinator

• Scott Irving - CH2M HILL, Project Manager

• Barrie Selcoe - CH2M HILL, Lead Human Health Risk Assessor

• John Ynfante - CH2M HILL, Project Chemist

• Rick Dobbins - CH2M HILL, Project Data Manager

• Jennifer Luffy – CH2M HILL, Field Team Leader

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Table of Contents

Table of Contents.............................................................................................................................i Acronyms and Abbreviations...................................................................................................... iii 1.0 Project Management ..................................................................................................... 1-1

1.1 Introduction ........................................................................................................... 1-1 1.2 Project / Task Organization ................................................................................... 1-1 1.3 Site Background .................................................................................................... 1-6 1.4 Project Description ................................................................................................ 1-7 1.5 Quality Objectives and Criteria for Measurement Data ........................................ 1-9

1.5.1 Data Quality Objectives ....................................................................... 1-12 1.5.2 Measurement Performance Criteria ..................................................... 1-15

1.6 Special Training Requirements............................................................................ 1-16 1.7 Documents and Records ...................................................................................... 1-16

1.7.1 Field Sampling Documentation ........................................................... 1-16 1.7.2 Sample Identification System .............................................................. 1-17 1.7.3 Hard Copy Analytical Records ............................................................ 1-18 1.7.4 Electronic Analytical Records ............................................................. 1-19 1.7.5 Project Record Maintenance and Storage ............................................ 1-20

2.0 Data Generation and Acquisition ................................................................................ 2-1 2.1 Sampling Design.................................................................................................... 2-1 2.2 Sampling Methods................................................................................................. 2-2 2.3 Sample Handling and Custody .............................................................................. 2-2

2.3.1 Sample Preservation and Holding Time ................................................ 2-2 2.3.2 Sample Custody and Shipping Requirements ........................................ 2-4

2.4 Analytical Methods................................................................................................ 2-7 2.4.1 Total Metals Analysis by ICP-MS and CVAA...................................... 2-7 2.4.2 Particle Size Distribution ....................................................................... 2-8 2.4.3 Radionuclide Analysis ........................................................................... 2-8 2.4.4 General Chemistry ................................................................................. 2-9 2.4.5 Field Data Acquisition ........................................................................... 2-9

2.5 Quality Control .................................................................................................... 2-10 2.5.1 Quality Control Samples...................................................................... 2-10 2.5.2 Field and Laboratory Corrective Action .............................................. 2-11

2.6 Equipment Testing, Inspection, and Maintenance............................................... 2-13 2.7 Equipment Calibration and Frequency ................................................................ 2-13

2.7.1 Field Instruments ................................................................................. 2-13 2.7.2 Laboratory Equipment ......................................................................... 2-13

2.8 Inspection / Acceptance of Supplies and Consumables....................................... 2-13 2.9 Non-Direct Measurements................................................................................... 2-14 2.10 Data Management................................................................................................ 2-14

2.10.1 Data Types ......................................................................................... 2-14 2.10.2 Data Tracking and Management ........................................................ 2-15 2.10.3 Computer Database ............................................................................ 2-16 2.10.4 Documentation ................................................................................... 2-16 2.10.5 Evidence File ..................................................................................... 2-16 2.10.6 Presentation of Analytical Data ......................................................... 2-17

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3.0 Assessment and Oversight ............................................................................................ 3-1 3.1 Assessments and Response Actions ...................................................................... 3-1 3.2 Reports to Management......................................................................................... 3-1

4.0 Data Evaluation and Usability ..................................................................................... 4-1 4.1 Data Review, Verification, and Evaluation ........................................................... 4-1

4.1.1 Precision................................................................................................. 4-1 4.1.2 Accuracy ................................................................................................ 4-1 4.1.3 Completeness ......................................................................................... 4-2 4.1.4 Sensitivity .............................................................................................. 4-2

4.2 Data Types............................................................................................................. 4-2 4.2.1 Screening Data ....................................................................................... 4-2 4.2.2 Definitive Data....................................................................................... 4-3

4.3 Validation and Evaluation Methods ...................................................................... 4-3 4.4 Reconciliation with User Requirements ................................................................ 4-4

List of Figures Figure 1 Proper Labeling of Sample Coolers

List of Tables Table 1 Project Personnel Telephone Numbers Table 2 Data Quality Objectives Table 3 Summary of Deliverables for Laboratory Analytical Reports Table 4 Sample Containers, Preservatives, and Holding Times Table 5 Target Analyte List Metals and Reporting Limits Table 6 General Chemistry List and Reporting Limits Table 7 Field Analytical Measurements and Reporting Limits

List of Appendices Appendix A Quality Control Corrective Action Form

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Acronyms and Abbreviations

%R Percent Recovery ARAR Applicable and Relevant or Appropriate Requirements ASTM American Society for Testing and Materials CFR Code of Federal Regulations CLASS Contract Laboratory Analytical Services Support CLP Contract Laboratory Program COC Chain of Custody CVAA cold-vapor atomic absorption DQI Data Quality Indicator DQO Data Quality Objective EB Equipment Blank EDD Electronic Data Deliverable EDMS Environmental Data Management System EPA United States Environmental Protection Agency ESAT Environmental Services Assistance Team FD Field Duplicate FSP Field Sampling Plan FTL Field Team Leader GFAA Graphite Furnace Atomic Absorption GIS Geographical Information System HHRA Human Health Risk Assessment HSM Health and Safety Manager HSP Health and Safety Plan ICP-MS inductively-coupled plasma–mass spectrometry ID Identification Number LCS Laboratory Control Sample MCAWW Methods for the Chemical Analysis of Water and Wastes MDL Method Detection Limit MS Matrix Spike MSD Matrix Spike Duplicate NPL National Priorities List OU1 Operable Unit 1 OU4 Operable Unit 4 PC Project Chemist PDM Project Database Manager PM Project Manager PQL Practical Quantitation Limit PRP Potentially Responsible Party QA Quality Assurance QAP Quality Assurance Plan QAPP Quality Assurance Project Plan QC Quality Control QCCAF Quality Control Corrective Action Form RAC Response Action Contract RFP Request for Proposal RI/FS Remedial Investigation / Feasibility Study

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RL Reporting Limit ROD Record of Decision RPD Relative Percent Difference RSCC Regional Sample Control Coordinator RTL Review Team Leader SA Spike Added Site Tar Creek Superfund Site SOP Standard Operating Procedure SOW Statement of Work SQL Structured Query Language SR Sample Result SSC Site Safety Coordinator SSR Spiked Sample Result TAL Target Analyte List TDS Total Dissolved Solids TR Traffic Report TSS Total Suspended Solids USGS United States Geological Survey WAM Work Assignment Manager WPRR Work Plan Revision Request

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1.0 Project Management

1.1 Introduction

Under the direction of the United States Environmental Protection Agency (EPA), Region 6, CH2M

HILL is completing the Human Health Risk Assessment (HHRA) for the Operable Unit 4 (OU4)

portion of the Tar Creek Superfund Site (Site) located in Ottawa County, Oklahoma. The Tar Creek

site is located in the extreme northeastern corner of Oklahoma and encompasses the towns of Miami,

North Miami, Picher, Cardin, Quapaw, and Commerce.

The purpose of this Quality Assurance Project Plan (QAPP) is to present the quality assurance/quality

control (QA/QC) requirements for the collection and analysis of split samples and independent

samples in support of this investigation.

Section 1 of the QAPP presents information regarding the management of the project. Aspects of

project management discussed include:

• Project organization, roles, and responsibilities

• Problem definition and background

• Project task description

• Project data quality objectives (DQOs)

• Special training requirements

• Documentation and records management

This QAPP was written according to guidelines set forth in EPA Requirements for QA Project Plans

(QA-R5).

1.2 Project / Task Organization

CH2M HILL is the prime contractor and is responsible for all phases of the investigation activities at

the site as described in the Work Plan Revision Request (WPRR) No. 1 submitted to EPA on

February 25, 2005. The various QA and management responsibilities of key project personnel are

defined below. Table 1 provides a list of project personnel and their telephone numbers.

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EPA Region 6 Work Assignment Manager

The EPA Work Assignment Manager (WAM) is Ursula Lennox. Ms. Lennox serves as the EPA

liaison for the project and has the ultimate responsibility for overall EPA project management.

CH2M HILL Project Manager

The CH2M HILL Project Manager (PM) is Scott Irving. Mr. Irving is responsible for implementing

the project and is authorized to commit resources to meet project objectives and requirements. The

PM’s primary function is to achieve technical, financial, and scheduling objectives. Specific duties of

the PM include:

• Defining project objectives and developing a detailed Work Plan and schedule

• Establishing project policies and procedures to address the specific needs of the project, as a

whole, as well as the objectives of each task

• Familiarizing field leaders, task leaders, and support staff with the project’s special

considerations

• Acquiring and applying technical and corporate resources to meet budget and schedule

constraints

• Monitoring and directing the progress of other team members

• Reviewing the work performed on each task to ensure quality, responsiveness, and timeliness

• Reviewing and analyzing overall task performance with regard to planned schedule and

budget

• Reviewing external reports (deliverables) before submission to EPA

• Representing the project team at meetings and public hearings

CH2M HILL Project Review Team Leader

The CH2M HILL Project Review Team Leader (RTL) is Patricia Cline. Ms. Cline shall remain

independent of day-to-day operations and shall supervise and/or perform the tasks of the project

review team. Some specific duties include:

• Review all major project deliverables prior to submittal to EPA

• Provide technical assistance to members of the project team

• Serve as technical resource to the PM

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CH2M HILL RAC 5 Program Manager

The CH2M HILL Response Action Contract (RAC) 5 Program Manager is Ike Johnson. Mr. Johnson

is responsible for the overall coordination of all CH2M HILL project efforts supporting the RAC 5

program.

Senior Human Health Risk Assessor

The CH2M HILL Lead Human Health Risk Assessor is Barrie Selcoe. Ms. Selcoe will be responsible

for performing the HHRA.

Specific responsibilities of the Lead Human Health Risk Assessor include:

• Evaluating potential exposure areas and providing input on sampling locations

• Performing or overseeing chemical intake and risk calculations for the risk assessment

CH2M HILL Senior Air Modeler

The CH2M HILL Senior Air Modeler is Dan Caniparoli. Specific responsibilities of the Senior Air

Modeler include:

• Discuss air modeling scope with EPA project toxicologist to develop a work plan

• Oversee the estimation of emissions, identification of receptors, development of source treatment

method and soil depletion method, execution of dispersion model, and preparation of air

modeling report

CH2M HILL Senior Data Manager

The CH2M HILL Senior Data Manager is Rick Dobbins. Mr. Dobbins will be responsible for the

overall management of the flow of data throughout the project. Specific responsibilities of the Senior

Data Manager include:

• Monitoring and managing the flow of data throughout the project

• Creating and maintaining the project database which will contain project analytical data

• Working with the Project Chemist (PC) to ensure the development of a complete and accurate

project database

• Overseeing the production of data tables or other required output of the project database

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CH2M HILL Senior Statistician

The CH2M HILL Senior Statistician is Larry Hilscher. Mr. Hilscher will be responsible for

supporting the statistical evaluation needs of the project. For this project, specific responsibilities of

the Senior Statistician include:

• Overseeing the statistical comparison of the split-sample data set with the associated potentially

responsible party (PRP) data set.

• Preparing a technical memorandum detailing the findings of the split-sample data comparison

CH2M HILL Project Chemist

The CH2M HILL PC is John Ynfante. Mr. Ynfante will be responsible for all technical chemistry

issues relating to data quality, laboratory performance, and sampling. Specific responsibilities of the

PC include:

• Drafting and maintaining the QAPP

• Procuring subcontract services for sample analysis, if needed

• Addressing technical issues and problems encountered by the laboratory

• Evaluating data usability

• Working with the Senior Data Manager to ensure the development of a complete and accurate

project database

CH2M HILL Field Team Leader / Site Sample Coordinator

The CH2M HILL Field Team Leader (FTL) / Site Sample Coordinator (SSC) is Jennifer Luffy. As

FTL, Ms. Luffy will be responsible for coordinating field efforts, and providing and maintaining

sampling equipment and materials, and shipping and packing materials. The FTL supervises the

handling and shipping of samples, the completion of traffic reports (TRs) / chains-of-custody (COCs)

and the completion of the field notebooks. As the lead field representative, the FTL is responsible for

implementing the required field QA/QC measures and ensuring that the sampling team follows

approved policies and field procedures. As SSC, Ms. Luffy will be responsible for creating and

maintaining the FORMS II Lite sample tracking database during sampling activities and ensuring that

proper contract laboratory program (CLP) protocol is followed throughout the sampling event for all

samples being shipped to either a CLP laboratory or the EPA Region 6 Houston Laboratory.

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CH2M HILL Regional Health and Safety Manager

The CH2M HILL Regional Health and Safety Manager (HSM) is Michael Goldman. Mr. Goldman is

responsible for reviewing and approving the project-specific Health and Safety Plan (HSP). The HSM

serves as the point of contact for the SSC for any health and safety-related issues, and may conduct

project audits. The HSM is also responsible for investigating accidents should any occur during the

course of the project.

CH2M HILL RAC 5 Contract Specialist

The CH2M HILL RAC 5 Contract Specialist is Matt Kluge. Mr. Kluge will be responsible for any

contract documents created in support of the project. Specific responsibilities of the Contract

Specialist include:

• Contracting the subcontractors

• Procuring necessary equipment and materials from the vendor

• Resolving any contract disputes

CH2M HILL Project GIS Specialist

The CH2M HILL Project Geographical Information System (GIS) Specialist is Jason Rivers. Mr.

Rivers will be responsible for supporting the GIS needs of the project including the planning and

preparation of maps and figures.

CH2M HILL RAC 6 Project Assistant

The CH2M HILL RAC 6 Project Assistant is Lisa Hein. Ms. Hein will be responsible for addressing

the day-to-day administrative needs of the project including data archive, meeting scheduling, and

report production.

CH2M HILL Technical Resources

CH2M HILL will draw upon its various corporate technical resources to gather and analyze data and

prepare various task reports and support materials.

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Table 1 Project Personnel and Telephone Numbers Tar Creek Superfund Site Ottawa County, Oklahoma

Name Role Telephone Number

Ursula Lennox EPA Region 6 Work Assignment Manager 214-665-6743

Scott Irving CH2M HILL PM 972-980-2188, ext. 296

Barrie Selcoe CH2M HILL Lead Human Health Risk Assessor 713-462-0161, ext. 292

Don Caniparoli CH2M HILL Senior Air Modeler 503-235-5000, ext. 4320

Rick Dobbins CH2M HILL Senior Data Manager 352-335-5877, ext. 2277

John Ynfante CH2M HILL PC 713-462-0161, ext. 285

Jennifer Luffy CH2M HILL FTL, SSC 972-980-2188, ext. 287

Larry Hilscher CH2M HILL Senior Statistician 512-365-8244

Patricia Cline CH2M HILL RTL 352-335-5877, ext. 2684

Matt Kluge CH2M HILL RAC 5 Contract Specialist 414-272-2426

Ike Johnson CH2M HILL RAC 5 Program Manager 414-272-2426, ext. 304

Jason Rivers CH2M HILL GIS Specialist 713-462-0161, ext. 259

Lisa Hein CH2M HILL RAC 6 Project Assistant 972-980-2188, ext. 212

Michael Goldman CH2M HILL Regional H&S Manager 770-604-9095, ext. 396

1.3 Site Background

The Tar Creek Superfund Site is located in the extreme northeastern corner of Oklahoma in Ottawa

County and encompasses the towns of Miami, North Miami, Picher, Cardin, Quapaw, and Commerce.

Approximately 30,000 people currently live in the area.

The rich deposits of lead and zinc in the region began to be mined around 1890. The mining industry

prospered in the Tri-State Mining District, and by the early 1900’s the Tar Creek area was a major

producer of lead and zinc for the country. Meanwhile, the various mills were producing large

amounts of chat, a mining waste that remains after the extraction of lead and zinc. The chat material,

some of which contained substantial concentrations of lead, was discarded in nearby piles.

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By the 1960’s, most major mining facilities in the area had ceased operations, leaving behind the

enormous piles of chat waste material. The cessation of the mining pumps’ de-watering activities

allowed the mines to begin filling with groundwater. The water reacted with the mine contents and

slowly became acidic, dissolving substantial concentrations of heavy metals into solution. The acidic

mine water eventually began contaminating the rest of the Boone Aquifer and began discharging into

Tar Creek around 1979.

The EPA added Tar Creek to the National Priorities List (NPL) of Superfund sites in 1981. The

initial project, Operable Unit 1 (OU 1), began in 1982, and focused on the acid water contamination

in Tar Creek and in the local groundwater.

In 1994, EPA began investigating the chat waste piles as a source of contamination.

In 2000, it was estimated that 50 million tons of chat waste remained in Ottawa County. According

to historical information, locals utilized the chat as alley and road-building material, surface for

driveways, and general fill material for residential areas. This usage of chat may have inadvertently

spread a lead contaminant throughout the area, which could potentially threaten human health or the

environment.

1.4 Project Description

This investigation is designed to obtain the data necessary to perform a HHRA for OU 4 at the Site

and also to evaluate the sampling and analysis activities performed by the PRP by means of a split-

sampling effort. It is assumed that existing Tar Creek field office, laboratory trailer space, sampling

equipment, and other related facilities accountable under Contract No. 68-W6-0036, will be used to

support this project. EPA is the lead agency for the site. The investigation will include the following

events:

Potentially Responsible Party Split Sampling:

The PRP will be collecting approximately 753 normal samples of various matrices in support of

the remedial investigation/feasibility study (RI/FS). CH2M HILL will obtain split samples for 10

percent of all water samples (divided proportionally among surface water and ground water) and

20 percent of solid samples (divided proportionally among soil, sediment, chat, mill residue, and

smelter waste) for separate analysis for an estimated total of 168 split samples. The analytical

results for the split samples will be statistically compared with the analytical results obtained

from the PRP’s samples to evaluate the PRP’s sampling and analysis program. It is assumed that

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all split samples will be analyzed by either the EPA Region 6 Houston Laboratory or by a

designated CLP laboratory. The stream metal-loading samples will be collected for the PRP by

the United States Geological Survey (USGS) and it is expected that CH2M HILL will not collect

splits of these samples; however, if splits of stream samples are collected they will be analyzed

for total and dissolved target analyte list (TAL) metals, iron, sulfate, total suspended solids (TSS),

total dissolved solids (TDS), and hardness. Chat split-samples will be sieved through a #60 mesh

sieve and the sieved material will be analyzed for TAL metals. Soil split-samples will be analyzed

for TAL metals (some soils may be analyzed only for the three specific metals of interest – lead,

cadmium, and zinc). Split samples of storm water runoff from chat piles will be analyzed for total

and dissolved TAL metals, sulfate, TSS, TDS, and hardness. Split samples of surface water from

tailing ponds will be collocated with sediment and biota samples and will be analyzed for total

and dissolved TAL metals, pH, sulfate, specific conductance, dissolved oxygen, temperature,

alkalinity, TSS, TDS, and hardness. Split samples of ground water will be analyzed for total TAL

metals, sulfate, TDS, and hardness. The sediment split sample will be analyzed for TAL metals.

Independent Mill Waste Sampling:

CH2M HILL will collect approximately 20 mill waste samples which will be analyzed for

particle size distribution (including with hydrometer for particles that pass through the #200

sieve). As a separate analysis, these samples will be sieved through a #60, #140, and #200 mesh

sieves with a metals analysis being performed on the sieved material that passes through the #60

and retains on the #140, the material that passes through the #140 and retains on the #200, and the

material that passes through the #200 and retains in the pan. Eighty percent of the samples will be

analyzed for total cadmium, total lead, and total zinc and twenty percent of the samples will be

analyzed for the full CLP TAL metals list. These efforts will focus on chat, screened chat, chat

bases, and fine tailings. It is assumed that a Tier IV commercial laboratory will perform these

analyses.

Independent Surface Water and Sediment Sampling (If directed by EPA):

If directed by EPA, CH2M HILL (or possibly USGS) will collect 16 additional collocated surface

water and sediment samples that will be analyzed for TAL metals. If collected, it is assumed that

these samples will be analyzed by either the EPA Region 6 Houston Laboratory or a CLP

laboratory.

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Independent Biota and Soil Sampling:

CH2M HILL will collect 4 types of samples (washed leaves, unwashed leaves, washed roots,

unwashed roots) from 54 plants for a total of 216 plant samples. A total of 54 collocated soil

samples will also be collected from soil in contact with the plant roots. A member of the Quapaw

Tribe will work with CH2M HILL to locate and identify the desired plant species in the field. The

216 plant and 54 soil samples will be analyzed for TAL metals. It is assumed that the soil

samples will be submitted to a CLP laboratory for analysis. If the CLP program agrees to accept

the plant samples then they will also be submitted to a CLP laboratory; otherwise, they will be

submitted to a Tier IV commercial laboratory for analysis.

Radionuclide Sampling (If directed by EPA):

If directed by EPA, CH2M HILL will perform a radionuclide screening of 30 percent of the plant

samples (i.e. 65 plant samples) and 8 additional sediment samples for the analysis of isotopic

uranium (U233/U234, U235, U238), isotopic thorium (Th227, Th228, Th230, Th232), and gross

alpha and beta emitters. If collected, the radionuclide data will not be evaluated and assessed as

part of the HHRA.

The expected turnaround time for samples sent to either a CLP laboratory or the EPA Region 6

Houston Laboratory is approximately 28-35 days.

The expected turnaround time for samples sent to a Tier IV commercial laboratory is approximately

21 days.

Site activities are expected to begin on or about May 13, 2005.

1.5 Quality Objectives and Criteria for Measurement Data

The objectives of this investigation include the following:

• Collect and analyze 168 split-samples to evaluate the quality of the PRP’s RI/FS sampling and

analysis program.

• Collect and analyze soil, mill waste, and biota in support of the HHRA.

• Potentially (if directed by EPA) collect and analyze surface water and sediment samples in

support of the HHRA

• Potentially (if directed by EPA) collect and analyze plant and sediment samples for radionuclides.

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These project objectives have been used to develop specific DQOs which are both qualitative and

quantitative statements that describe the type and quality of data needed to determine the current state

of the contaminant distribution and assess the effectiveness of the selected remedy. The DQO process

used for this project follows the EPA QA/G4 guidance (EPA, 1994) and uses the seven-step DQO

development process. The DQOs provide a basis for the investigation activities to be performed, and

ensure that data collected during the investigation will be of sufficient and adequate quality for their

intended use. The DQOs and associated investigation activities established for the Site are presented

in Table 2.

Table 2 Data Quality Objectives Tar Creek Superfund Site Ottawa County, Oklahoma

Media of Interest

Data Quality Objective Investigation Activity Analytes Data

Level

SPLIT SAMPLES

Chat Splits Evaluate quality of PRP’s analytical data for chat.

Chat split samples will be collected at a 20% frequency, sieved through a #60 sieve onsite, and submitted to CLP for analysis.

TAL metals III

Soil Splits Evaluate quality of PRP’s analytical data for soil.

Soil split samples will be collected at a 20% frequency and submitted to CLP for analysis.

TAL metals III

Chat Runoff-Seep Splits

Evaluate quality of PRP’s analytical data for storm water runoff from chat.

Split samples of storm water runoff from chat piles will be collected at a 10% frequency and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis.

TAL metals (total),

TAL metals (dissolved),

sulfate, TSS, TDS, hardness

III

Stream Splits

Evaluate quality of PRP’s analytical data for stream water samples.

Stream split samples (if collected) will be collected at a 10% frequency and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis.

TAL metals (total)

TAL metals (dissolved),

sulfate, TSS, TDS, hardness

III

Ground Water Splits

Evaluate quality of PRP’s analytical data for surface water from tailing ponds samples.

Ground water split samples will be collected at a 10% frequency and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis.

TAL metals, sulfate, TDS, hardness

III

Sediment Splits


Sediment split samples will be collected at a 20% frequency and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis. Only 1 sediment split is expected to be collected.

TAL metals III

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Media of Interest


Level

TAL metals (total),

TAL metals (dissolved), sulfate, alkalinity, TSS, TDS, hardness

III

Surface Water From Tailing Ponds Splits


Split samples of surface water from tailing ponds will be collocated with sediment and biota samples and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis. Level I analyses will be performed in the field.

pH, specific conductance, dissolved oxygen, temperature

I

INDEPENDENT SOIL AND MILL WASTE SAMPLING FOR HHRA

Particle size distribution (including hydrometer for < #200 sieve)

I Mill Waste Samples

Determine risk to human health (HHRA).

Approximately 20 mill waste samples will be collected and submitted to a Tier IV laboratory for particle size distribution. Samples will also be sieved through #60, #140, and #200 sieves to obtain metals analysis on sieved fractions. 80% of the samples will be analyzed for total lead, cadmium, and zinc and 20% of the samples will be analyzed for TAL metals.

TAL Metals

Total lead, cadmium, zinc

III

III

INDEPENDENT SURFACE WATER AND SEDIMENT SAMPLING FOR HHRA (IF DIRECTED BY EPA)

Surface Water Samples


If directed by EPA, 16 surface water samples will be collected collocated with 16 sediment samples (see below) and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis.

TAL metals III

Sediment Samples


If directed by EPA, 16 sediment samples will be collected collocated with 16 surface water samples (see above) and submitted to CLP and/or the EPA Region 6 Houston Laboratory for analysis.

TAL metals III

INDEPENDENT BIOTA AND SOIL SAMPLING FOR HHRA

Washed Leaves

Determine risk to human health (HHRA) via ingestion.

Washed leaf samples will be collected from 54 plants and submitted to a CLP laboratory for analysis.

TAL metals III

Unwashed Leaves


Unwashed leaf samples will be collected from 54 plants and submitted to a CLP laboratory for analysis.

TAL metals III

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Media of Interest


Level

INDEPENDENT BIOTA AND SOIL SAMPLING FOR HHRA

Washed Roots


Washed root samples will be collected from 54 plants and submitted to a CLP laboratory for analysis.

TAL metals III

Unwashed Roots


Unwashed root samples will be collected from 54 plants and submitted to a CLP laboratory for analysis.

TAL metals III

Root-Associated Soil

Model plant uptake of metals to support HHRA.

54 soil samples will be collected from soil in contact with the roots of the 54 collocated plants above and submitted to a designated CLP laboratory for analysis.

TAL metals III

RADIONUCLIDE SAMPLING (IF DIRECTED BY EPA)

Plant Samples

Provide radionuclide screening results to Quapaw Tribe

If directed by EPA, 65 (30 percent) of the plant samples collected in the Independent Biota Sampling will be submitted to a Tier IV laboratory for radionuclide analysis.

Isotopic uranium (U233/U234, U235, U238)

Isotopic thorium (Th227, Th228, Th230, Th232)

Gross alpha emitters

Gross beta emitters

II

Sediment Samples

Provide radionuclide screening results to Quapaw Tribe

If directed by EPA, 8 additional sediment samples will be collected and submitted to a Tier IV laboratory for radionuclide analysis.

Isotopic uranium (U233/U234, U235, U238)

Isotopic thorium (Th227, Th228, Th230, Th232)

Gross alpha emitters

Gross beta emitters

II

1.5.1 Data Quality Objectives

Step 1: State the Problem

The chat waste material is a source of lead contamination; of specific concern are the fine particles

that reside on the external surface area of the chat waste. With regard to the chat particles, the fines

contain the highest concentration of lead. Also, the fines are considered environmentally mobile and

their susceptibility to wind deposition, dermal adherence and other transport can increase their

potential threat to human health or the environment. This risk must be assessed with a HHRA.

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Step 2: Identify the Decision

The primary goals of this project are to perform a HHRA for OU 4 at the Site and also to evaluate the

sampling and analysis activities performed by the PRP by means of a split-sampling effort. In order to

complete these activities several questions were either answered during the planning phase or must be

answered during the course of this project:

• Do the concentrations of metals in the various matrices being investigated pose a risk to human

health?

• Is the new analytical data being collected of sufficient quality to support the HHRA?

• What historical data is available that can be used to support the HHRA and what additional data

is needed?

• Is the storm water runoff and seeps from chat piles impacting area water quality?

• What is the correlation between the root soil metals concentrations and the concentrations found

in the roots and leaves?

• Given the various matrices being collected by the PRPs, at what percentages will the split

samples be collected to evaluate the PRP’s analytical program?

• Analysis of only the fines portion of the chat particles for the HHRA presents difficulties in

obtaining representative split samples. How will the analysis of the chat be performed so that the

data can support the HHRA and also be considered comparable to the PRP’s data for comparison

purposes?

Step 3: Identify Inputs to the Decision

Historical site information provided background data that was utilized during the planning phase of

the project. As part of the scope development, project team members reviewed reports prepared by

the PRP including the Draft Data Gap Analysis Report, Draft RI/FS Work Plan, Draft Sampling and

Analysis Report and QAPP.

New analytical data obtained from both independent samples and the split samples will be used to

support the HHRA. Historical data obtained at the site may also be used.

Step 4: Define the Boundaries of the Study

The Site encompasses nearly 40 square miles in the northern part of Ottawa County, located in the

extreme northeastern corner of Oklahoma. This area is the Oklahoma portion of the former Tri-State

Mining District. Sampling activities will take place within the boundaries of the site and will include

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the collection of soil, sediment, surface water, ground water, biota, dust, mill residue, and smelter

waste.

All analytical data will be obtained utilizing EPA-approved methodology.

CLP laboratories and/or the EPA Region 6 Houston Laboratory shall be used wherever analytically

possible to maximize data quality and defensibility.

Data reviews performed by CH2M HILL and the Environmental Services Assistance Team (ESAT)

will conducted in accordance with EPA’s National Functional Guidelines.

Step 5: Develop a Decision Rule

The analytical results obtained from this project must achieve project DQOs to support the HHRA;

therefore, the analytical data obtained must not only be complete and of sufficient quality, but must

also achieve reporting limits (RLs) that are sufficiently low enough to be compared with the

applicable and relevant or appropriate requirements (ARARs) that the risk assessment requires.

The QC requirements specified in this QAPP and the Field Sampling Plan (FSP) will be followed to

aid in the establishment of analytical quality. Appropriate EPA-approved analytical methods and

laboratories will be utilized to ensure sufficient analytical sensitivity.

Some specific data interpretation decisions are as follows:

• The PC will perform a level III review on all non-CLP analytical data to assess whether the data

meet project DQOs and may be used for project decisions. If any data are rejected as a result of

the review it will not be used for project decisions.

• It is assumed that the PRP will validate their analytical data and prepare a data quality evaluation

report to document the quality of the data. The PC will review the data quality evaluation report

prepared by the PRP to assess if the data is of acceptable quality. If the PRP’s data is deemed of

insufficient quality this will be noted in the split-sample data comparison report.

• Split samples will be obtained from 10 percent of the water samples and 20 percent of the solid

samples collected by the PRP. The data for the split samples will be statistically compared with

the associated samples collected and analyzed by the PRP to help evaluate the quality of their

analytical data. If the split-sample data comparison indicates insufficient agreement between the

data sets, this will be detailed in the data comparison report.

• The project team will review and evaluate new site analytical data to assess the potential risk to

human health. Findings will be presented in the HHRA.

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Step 6: Specify Limits on Decision Errors

Random and/or systematic errors may be introduced during sample collection, sample handling and

storage, sample analysis, data reduction, and data reporting. The QC measures set forth in this QAPP,

project standard operating procedures (SOPs), the FSP, analytical methods, and other project

documents serve to minimize these errors. Sampling techniques are specified in the FSP and each

member of the field team must follow the same SOPs in order to minimize field errors. QC samples

are also used to monitor the accuracy and precision of the sampling activity as well as the analytical

process.

The PC will review all non-CLP analytical data based on criteria analogous to the EPA’s National

Functional Guidelines in order to determine if the data meets project DQOs. If the Data Quality

Indicators (DQIs) of precision, bias, accuracy, representativeness, comparability, completeness, and

sensitivity do not achieve project DQOs then the analytical results will be qualified accordingly and

the data’s usability to support project goals may be impacted.

Step 7: Optimize the Design

The primary goals of this investigation are to obtain analytical data necessary to support a HHRA and

to obtain and analyze split samples to evaluate the PRP’s sampling and analysis program.

Data gaps for achieving the former goal have been minimized by considering a substantial amount of

historical information available to the project team during the project planning process. This

investigation is designed to collect only the additional data needed to support the HHRA, avoiding

any unnecessary sample collection.

Split-samples will be collected for the PRP’s solid samples at a 20 percent frequency; however, since

water samples present much less matrix variability, the split-sampling frequency for the water

samples was reduced to 10 percent.

CLP laboratories and/or the EPA Region 6 Houston Laboratory will be utilized wherever analytically

possible in order to reduce project costs while still providing defensible quality data.

The existing Tar Creek field office, laboratory trailer space, sampling equipment, and other related

facilities accountable under Contract No. 68-W6-0036, will be used to support this project in order to

reduce project costs while still providing defensible quality data.

1.5.2 Measurement Performance Criteria

Project DQOs require that certain measurement performance criteria be met, including the following:

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• Peer and senior review of data and documents

• QC standards

• Management controls

The analytical data shall undergo three levels of review – an initial review by the analytical chemist, a

subsequent review by the laboratory QA manager, and a final data validation review by the CH2M

HILL PC. For CLP data, the data validation review is performed by ESAT, followed by a cursory

review of their findings by the CH2M HILL PC.

All documents pertaining to the quality standards of the project are drafted and reviewed internally by

CH2M HILL staff with relevant technical experience. Also, the RTL and the PM shall review all

project deliverables prior to submittal to the client.

All analytical data must meet the QC standards set forth in this QAPP, the applicable SOPs, and the

applicable analytical methods. If these standards are not met, the data is appropriately qualified

during the data review process. In cases where the data is deemed of insufficient quality to satisfy

project DQOs, the data will be rejected and will not be used to support project decisions.

While performing field activities, the FTL will manage the field activities to ensure that SOPs are

being followed including the proper adherence to CLP sampling protocol where applicable. The SSC

will manage the FORMS II Lite database to ensure that it is properly utilized as required by CLP.

1.6 Special Training Requirements

Project team members have been chosen with the necessary experience and technical skills to perform

required project tasks. The only additional training required is a mandatory review of the project HSP

by all project personnel expected to work in the field.

All field staff for the project must meet the requirements specified in the FSP and the HSP.

1.7 Documents and Records

1.7.1 Field Sampling Documentation

Field team members will keep a daily record of significant events, observations, and measurements

during sampling. The required contents of the field logbook are specified in the FSP. A bound field

logbook with numbered pages will be initiated at the start of field activities and maintained to record

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onsite activities during all sampling events. The field logbook will be supplemented by sampling

chain of custody (COC) forms and/or notes recorded onto site maps or maps of adjoining properties.

All documents generated during the field effort are controlled documents that become part of the

project file. All entries in the field logbooks should be signed and dated and should include the

following information:

• Name and title of author, field crew, and site visitors present

• Weather and environmental conditions during the field activity

• Date and time of sample collection and/or logbook entry

• Location of sampling activity

• Sample media (e.g. ground water)

• Sample collection method

• Number of sample taken

• Sample identification numbers (IDs)

• Field observations and measurements (e.g. pH, temperature, core description, etc.)

If a logbook entry is recorded in error, personnel shall not obliterate the mistake. Personnel shall

mark a single line through the mistake and initial and date the cross-out.

1.7.2 Sample Identification System

Unique sample IDs will be assigned to all samples collected to prevent sample ID duplication in the

database. A record of the unique sample ID, date, and time of sample collection will be recorded in

the field notebook. The sampling team shall record any field analytical data in bound field logbooks

or on organized data sheets.

Sample IDs will be assigned to all non-CLP samples according to the protocol discussed in the

project FSP. Low-concentration ground water samples to be sent to a CLP laboratory will be

assigned sample IDs according to the protocol discussed in EPA’s Sampler’s Guide to the Contract

Laboratory Program. The sample IDs required to be used for the CLP samples will be provided by

the USEPA Region 6 Regional Sample Control Coordinator (RSCC), Myra Perez. CLP sample

numbers must NOT be used to identify soil or water samples that are to be sent to the EPA Region 6

Houston Laboratory.

Sample labels and COCs will list the unique sample ID as well as the appropriate sample location,

date, time, sampler, and other relevant information. Samples that are to be sent to either the EPA

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Region 6 Houston Laboratory or a CLP laboratory for analysis must adhere to the guidelines set forth

in the EPA’s Sampler’s Guide to the Contract Laboratory Program.

1.7.3 Hard Copy Analytical Records

The analytical laboratories shall provide the appropriate level of data package as listed in Table 2.

This shall include a Level I data package for the particle size distribution results, a Level II data

package for the radionuclide results (if collected), and a Level III data package for all other laboratory

results. Field analytical determinations shall provide Level I data. The data package requirements of

the three levels are defined in Table 3. Hardcopy data shall include all items listed in the appropriate

level in Table 3 and should be unbound for the purpose of data validation.

Any deviations from the analytical method or this QAPP shall be fully detailed in the case narrative,

along with a description of any corrective actions taken. The case narrative will address the following

aspects of the analysis at a minimum:

• Sample receipt conditions and completeness

• Holding times

• Blank samples

• Matrix spikes (MSs) and matrix spike duplicates (MSDs)

• Laboratory control samples (LCSs)

Table 3 Summary of Deliverables for Laboratory Analytical Reports Tar Creek Superfund Site Ottawa County, Oklahoma

All Analytical Fractions (all pages of data package numbered) Case Narrative – A detailed case narrative per analytical fraction is required and will include explanation of

any non-compliance and/or exceptions and corrective action. Exceptions will be noted for receipt, holding

times, methods, preparation, calibration, blanks, spikes, surrogates (if applicable), and sample exceptions.

•

Sample ID Cross Reference Sheet (Laboratory ID’s and Client ID’s) •

Completed COC and any sample receipt information •

Applicable MDLs/Practical Quantitation Limits (PQLs) – generally at beginning of project or when updated (if

not provided in data package) •

Copies of non-conformance memos and corrective actions •

Electronic Data Deliverable (EDD) in specified format by email or on floppy diskette or CD •

Form * Metals Inorganic Fractions Level I Level II Level III

1 Sample Results • • •

2A Initial and Continuing Calibration Summary •

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Table 3 Summary of Deliverables for Laboratory Analytical Reports Tar Creek Superfund Site Ottawa County, Oklahoma

3 Initial and Continuing Calibration Blanks and Method Blanks Summary • •

4 Interference Check Standard Summary •

5A Pre-digestion MS Recoveries Summary • •

6 Native Duplicate or MS/MSD Precision Summary * • •

7 LCS Recovery Summary • •

8 Method of Standard Addition (if necessary) •

8 Serial Dilution •

10 Instrument or Method Detection Limit (MDL) Summary •

12 Linear Range Summary •

13 Preparation Log Summary •

14 Analytical Run Sequence and Graphite Furnace Atomic Absorption (GFAA)

Post-spike Recovery Summary •

Form * General Chemistry Fractions

(sulfate, TSS, TDS, hardness, alkalinity) Level I Level II Level III



3 Initial and Continuing Calibration Blanks and Method Blanks Summary • •

5A Pre-digestion MS Recoveries Summary • •

6 Native Duplicate or MS/MSD Precision Summary • •


10 Instrument or MDL Summary •

Form * MISC Fractions

(radionuclides (if directed by EPA), particle size analysis) Level I Level II Level III



3 Blank Summary • •

6 Duplicate Precision Summary • •


10 Instrument or MDL Summary •

* CLP Form or summary form with equivalent information

1.7.4 Electronic Analytical Records

CH2M HILL requires subcontracted laboratories to submit an electronic data deliverable (EDD). The

EPA Region 6 Houston Laboratory shall provide EDDs in a Microsoft Access database format (.dbf).

The assigned CLP laboratory shall submit EDDs in a Microsoft Excel format (.xls). Tier IV

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commercial laboratories shall submit EDDs in a comma-delimited text file (.txt) or comma-separated

value (.csv) file format consistent with the CH2M HILL Environmental Data Management System

(EDMS) LabSpec7 format. Specific instructions regarding the EDD format will be communicated to

the laboratory within the laboratory statement of work (SOW) or by the Project Database Manager

(PDM). The laboratory’s QC Officer or appointed deputy shall verify that the hard copy and

electronic deliverable match each other and provide the requested analytical results to CH2M HILL.

The product of this activity is accurate and complete analytical information ready for data evaluation

and database entry.

1.7.5 Project Record Maintenance and Storage

Each project team member is responsible for filing all project information or providing it to the

administrative assistant familiar with the project filing protocol. Individual team members may

maintain separate files or notebooks for individual tasks but must provide such files to the project file

room upon completion of each task.

General project file categories may include:

• Correspondence

• Non-Laboratory Project Invoices and Approvals by Vendor

• Original Unbound Reports

• Non-laboratory Request for Proposals (RFPs), Bids, Contracts, SOWs

• Field Data

• Data Evaluation and Calculations

• Site Reports from Others

• Photographs

• Insurance Documentation

• Laboratory Analytical Data and associated Documents/Memos

• Regulatory Submittals, Licensing, and Permitting Applications

• Site and Reference Material

• Health and Safety Plans

• Figures and Drawings

A project-specific index of file contents should be kept with the project files at all times.

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2.0 Data Generation and Acquisition

Section 2 of the QAPP describes the procedures for the measurement, acquisition, handling, review,

and management of data that is to be performed in support of the subsurface investigation.

This section addresses the following aspects of measurement and data acquisition:

• Sampling process design

• Sampling method requirements

• Sample handling and custody requirements

• Laboratory analytical method requirements

• Laboratory QC requirements

• Field and laboratory instrument testing, inspection, maintenance, and calibration

• Inspection and acceptance requirements for supplies and consumables

• Data acquisition requirements

• Data management

2.1 Sampling Design

The FSP provides the sampling requirements and design for this project. SOPs for each sampling

method are provided either within the FSP or as an attachment. The following media may be sampled

and analyzed as part of this project:

• Soil samples

• Ground water samples

• Sediment samples

• Chat samples

• Mill waste samples

• Surface water samples from streams and tailing ponds

• Washed and unwashed leaf samples from designated plant species

• Washed and unwashed root samples from designated plant species

• Root-associated soil samples from the designated plants

• Storm water runoff samples from the chat piles

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The planned sampling locations, rationale for selection, and analytical parameters for each location

are detailed in the FSP. It should be noted that the exact sample locations and the total number of

samples might change from those described in the FSP or this QAPP, depending on the field

conditions encountered.

2.2 Sampling Methods

Field sampling shall be performed in accordance with protocol discussed in the FSP and/or attached

SOPs. Some examples of sampling procedures that may be used in this project are listed below:

• Ground water well sampling by purge and pump

• Subsurface soil sampling by Geoprobe

• Surface soil collection by hand-auger

• Plant biota collection by grab sampling

• Preservation of samples

• QC sample collection procedure

• Personnel and equipment decontamination

2.3 Sample Handling and Custody

2.3.1 Sample Preservation and Holding Time

Table 4 summarizes the project requirements for sample containers, preservatives, and holding times

for individual analytical methods and media to be sampled. All analytical methods can be found in

one or more of the following sources:

• SW-846 Test Methods for the Evaluation of Solid Waste

• EPA Methods for the Chemical Analysis of Water and Wastewater (MCAWW)

• EPA 900 series methods

• Multi-Media, Multi-Concentration Inorganic Analysis CLP SOW ILMO5.3

• American Society for Testing and Materials (ASTM) methods

• Code of Federal Regulations (CFR)

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Table 4 Sample Containers, Preservatives, and Holding Times Tar Creek Superfund Site Ottawa County, Oklahoma

Analysis Method Container Preservation/

Storage Maximum Hold Time

Water Samples (Surface Water, Ground Water)

pH Horiba Model U-22* — — —

Specific Conductance

Horiba Model U-22* — — —

Dissolved Oxygen Horiba Model U-22* — — —

Temperature Horiba Model U-22* — — —

TAL Metals (total) CLP ILMO5.3 1000 ml HDPE pH ≤ 2 (HNO3), Cool 4°C

28 days – mercury

180 days – other metals

TAL Metals (dissolved) CLP ILMO5.3 1000 ml HDPE

Field-filter, pH ≤ 2 (HNO3), Cool 4°C

28 days – mercury


Alkalinity EPA 310.1 1000 ml HDPE Cool 4°C 14 days

Sulfate EPA 300 1000 ml HDPE Cool 4°C 28 days

TSS EPA 160.2 1000 ml HDPE Cool 4°C 7 days

TDS EPA 160.1 1000 ml HDPE Cool 4°C 7 days

Hardness EPA 130.2 1000 ml HDPE pH ≤ 2 (HNO3), Cool 4°C 180 days

Sieved Mill Waste Samples for CLP

TAL Metals CLP ILMO5.3 4 oz glass jar (with approval from CLP)

Cool 4°C

28 days – mercury


Soil Samples, Sediment Samples

Alpha and Beta Particles E900 8 oz container Cool 4°C —

Isotopic Uranium and Isotopic Thorium E907 8 oz container Cool 4°C —

TAL Metals CLP ILMO5.3 (for CLP) 8 oz glass jar Cool 4°C

28 days – mercury


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Table 4 Sample Containers, Preservatives, and Holding Times Tar Creek Superfund Site Ottawa County, Oklahoma

Analysis Method Container Preservation/

Storage Maximum Hold Time

Mill Waste - Washed Fines Samples for Tier IV Laboratory

Particle Size Distribution (hydrometer)

ASTM D422 — —

Total Cd, Pb, and Zn or TAL Metals

SW-846 6010B and 7471A

16 oz jar

Cool 4°C

28 days – mercury


Mill Waste - Chat Samples for Tier IV Laboratory

Particle Size Distribution (hydrometer)

ASTM D422 — —

Total Cd, Pb, and Zn or TAL Metals

SW-846 6010B and 7471A

5-gallon bucket with lid

Cool 4°C

28 days – mercury


Plant Samples (Roots, Leaves)

TAL Metals

CLP ILMO5.3 (ICP-MS) or SW-846 6020 and 7471A

4 oz glass jar or Ziploc bag (if approved by CLP)

Cool 4°C

28 days – mercury


Alpha and Beta Particles E900 Ziploc bag Cool 4°C —

Isotopic Uranium and Isotopic Thorium E907 Ziploc bag Cool 4°C —

— = Not applicable

* = or equivalent

2.3.2 Sample Custody and Shipping Requirements

Sample Custody

Sample custody procedures include the use of field logbooks, sample labels, custody seals, and COC

forms (using FORMS II Lite). Each person involved with sample handling shall be familiar with

COC procedures prior to the start of field operations. The COC form must accompany the samples

during shipment from the field to the laboratory. Samples sent to a CLP laboratory for analysis must

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adhere to the custody and shipping requirements set forth in the EPA’s Sampler’s Guide to the

Contract Laboratory Program.

A sample is considered to be in one’s custody under the following circumstances:

• It is in one’s actual possession.

• It is in one’s view, after being in one’s physical possession.

• It was in one’s physical possession and that person locks it up to prevent tampering.

• It is in a designated and identified secure area.

Sample Shipping and Chain of Custody

Proper sample handling, shipment, and maintenance of a COC are key components of the quality

system designed to obtain data that can be used to make project decisions. It is very important that all

sample handling protocols and COC requirements be followed completely, accurately, and

consistently. A properly completed COC form / TR must accompany all samples to the laboratory.

The FORMS II Lite sample tracking software shall be utilized in the field to track samples, assign

sample IDs, and produce COC form / TR.

• Samples being shipped to the EPA Region 6 Houston Laboratory shall be accompanied by both

the “Regional Copy” and the “Laboratory Copy” of the COC form / TR.

• Samples being shipped to a CLP laboratory shall be accompanied by only the “Laboratory Copy”

of the COC form / TR – the “Regional Copy” of the COC form / TR must NEVER be sent to the

CLP laboratory because the site name is present on the “Laboratory Copy” and this information

must not be provided to the CLP laboratory.

• Samples sent to a Tier IV laboratory must be accompanied by a COC (no specific type required

but a FORMS II Lite COC form / TR is anticipated).

The unique sample IDs and descriptive information (site location, date, time, etc.) will be listed on the

COC or TR. Individuals relinquishing and receiving possession of samples will sign, and note the

time on the COC form. The COC or TR documents the transfer of sample custody from the sampler

to the offsite laboratory.

Field samples should be sealed in individual plastic Ziploc bags and positioned within the cooler to

prevent damage and maintain sample integrity. Hard plastic ice chests or coolers with similar

durability will be utilized for shipping samples. A signed COC will be included in each sample cooler

and then the cooler is closed and secured with strapping tape and custody seals for shipment to the

laboratory. The preferred procedure involves attaching custody seals to two sides of the cooler and

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then covering the seals with clear plastic tape. The cooler is then strapped shut with strapping tape in

at least two locations and shipped by priority overnight delivery service (Federal Express or

equivalent) to the laboratory for analysis. If Saturday delivery is required for samples being shipped

to a CLP laboratory, the designated Contract Laboratory Analytical Services Support (CLASS)

contact must be notified on Friday in order to schedule receipt with the laboratory. The EPA Region

6 Houston Laboratory does NOT accept Saturday deliveries; therefore, samples will be shipped to the

Houston Laboratory from Monday through Thursday only. Typical labeling requirements are shown

below in Figure 1.

When samples are relinquished to the shipping company for transport, the shipping bill tracking

number will be recorded on the COC form. Commercial carriers are not required to sign off on the

custody form as long as the custody forms are sealed inside the sample cooler and the custody seals

remain intact. The COC record identifying the contents will accompany all shipments. The original

record will accompany the shipment, with field copies being retained by the sampler. The FTL shall

provide the PC with a copy of the COC or TR on a daily basis to allow the PC to coordinate sample

tracking and to answer any questions from the analytical laboratory regarding that day’s sample

shipment.

FIGURE 1

Proper Labeling of Sample Coolers

Fiber Tape Seal

Chest Number

This Side Up

Address Label

Do Not Tamper

Environmental Lab Samples

Up Arrow

F D CBC

G

2 of 5

UP

ETop End

Side

A

B

C

D

E

F

G

A

UP

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Upon receipt of field samples, the analytical laboratory representative will sign the COC or TR to

accept custody of the samples and will then properly store them to await analysis.

2.4 Analytical Methods

The primary contaminants of concern at the site are metals – specifically lead, cadmium, and zinc.

Samples will be analyzed for the full TAL list of 23 metals which includes the three metals of

primary concern.

In addition, water quality analyses, particle size distribution, and radionuclide analysis will be

performed.

Samples will be analyzed utilizing EPA-approved methods from one or more of the following

sources:

• SW-846 Test Methods for the Evaluation of Solid Waste

• EPA MCAWW

• EPA 900 series methods

• Multi-Media, Multi-Concentration Inorganic Analysis CLP SOW ILMO5.3

• ASTM methods

• CFR

The analytical scope and a summary of the QA/QC protocol are provided in this document. Method-

specific QC requirements are provided in the referenced analytical methods.

2.4.1 Total Metals Analysis by ICP-MS and CVAA

Samples from all matrices collected will be analyzed for the CLP TAL of 23 metals by inductively-

coupled plasma–mass spectrometry (ICP-MS) and cold-vapor atomic absorption (CVAA). Samples

analyzed by a CLP laboratory or by the EPA Region 6 Houston Laboratory for TAL metals will be

analyzed in accordance with CLP ILMO5.3. Samples analyzed by a Tier IV commercial laboratory

will be analyzed in accordance with SW-846 Method 6020 and 7470A/7471A for mercury. Some

samples will only be analyzed for the three metals of particular interest – cadmium, lead, and zinc.

The TAL list of metals and required RLs are listed in Table 5.

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Table 5 TAL Metals List and Reporting Limits Tar Creek Superfund Site Ottawa County, Oklahoma

Analyte

Water RL

(mg/L)

Soil/WasteRL

(mg/kg)

Biota RL

(mg/kg)

Analyte

Water RL

(mg/L)

Soil/WasteRL

(mg/kg)

Biota RL

(mg/kg)

1 Aluminum 0.05 3.0 3.0 13 Magnesium 5.0 20 20

2 Antimony 0.006 0.2 0.2 14 Manganese 0.015 0.5 0.5

3 Arsenic 0.01 0.1 0.1 15 Mercury 0.002 0.005 0.005

4 Barium 2.0 0.3 0.3 16 Nickel 0.04 1.0 1.0

5 Beryllium 0.004 0.2 0.2 17 Potassium 5.0 30 30

6 Cadmium 0.003 0.3 0.01 18 Selenium 0.05 4.0 4.0

7 Calcium 5.0 20 20 19 Silver 0.01 0.5 0.5

8 Chromium 0.1 1.0 1.0 20 Sodium 5.0 30 30

9 Cobalt 0.05 1.0 1.0 21 Thallium 0.001 2.5 2.5

10 Copper 1.0 1.0 1.0 22 Vanadium 0.05 0.5 0.5

11 Iron 0.01 1.0 1.0 23 Zinc 0.01 1.0 0.2

12 Lead 0.0001 4.0 0.01

2.4.2 Particle Size Distribution

Mill waste samples will be collected and analyzed for particle size distribution (i.e. grain size) in

accordance with ASTM method D4222. This analysis will be performed by a Tier IV commercial

laboratory.

2.4.3 Radionuclide Analysis

If directed by EPA, CH2M HILL will collect plant and sediment samples and submit them to a Tier

IV commercial laboratory for radionuclide analysis. These analyses will include isotopic uranium and

isotopic thorium in accordance with method E907, and gross alpha and beta emitters in accordance

with method E900.

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2.4.4 General Chemistry

Some water samples will be submitted to the EPA Houston Region 6 laboratory for general chemistry

analysis. The list of general chemistry parameters and the required RLs are listed in

Table 6.

Table 6 General Chemistry List and Reporting Limits Tar Creek Superfund Site Ottawa County, Oklahoma

Compound Water RL

(mg/L)

1 Alkalinity 0.2

2 TSS 5.0

3 TDS 10

4 Hardness 1.0

5 Sulfate 0.5

2.4.5 Field Data Acquisition

During field data acquisition, the field team will perform activities such as sample collection and

analytical work utilizing field SOPs, field instruments, and field-test kits. Field data acquisition for

this project will include water level measurement, and field analytical measurements for temperature,

pH, specific conductivity, and dissolved oxygen. All field data acquisition shall be Level I quality.

The field analyses and their required minimum quantitation limits are listed below in Table 7.

Table 7 Field Analytical Measurements and Reporting Limits Tar Creek Superfund Site Ottawa County, Oklahoma

Compound Ground Water Reporting Limit

1 Temperature 0 degrees Celsius

2 pH 0.1 standard units

3 Conductivity 50 µS/cm2

4 Dissolved Oxygen 0.2 mg/L

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2.5 Quality Control

All project members will adhere to a QA Program to ensure the reliability and validity of the

activities being performed. The QA Program will include a wide variety of QC measures, one of

which is the analysis of various QC samples. Applicable QC samples are discussed below and the

field procedures for obtaining them are presented in the FSP.

2.5.1 Quality Control Samples

Field Duplicates

Field duplicates (FDs) are samples that are collected at the same time and location in an effort to

duplicate the collection of a particular sample. FDs are used to monitor the precision of the field

sampling process. The identity of the duplicate samples will be recorded in the field-sampling

logbook, and this information is forwarded to the data quality evaluation team to aid in the review and

evaluation of the data. FDs will be collected at a rate of 1 per 10 field samples, or 10 percent, per

matrix for all independent analyses.

Equipment Rinsate Blanks

After the sampling equipment is fully decontaminated, it is rinsed with deionized water and a sub-

sample of this rinsate is collected as the equipment blank (EB). The EB is preserved, handled, and

stored in the same manner as the normal field samples. The EB is then sent to the laboratory and

typically analyzed for the same analytical parameters as the corresponding normal samples that were

taken with that equipment that day. The EB is used to monitor potential cross-contamination caused

by improper equipment decontamination. EBs will be collected at a rate of 1 per week per matrix for

samples that do not involve dedicated or disposable sampling equipment and thus are at risk for cross-

contamination due to improper equipment decontamination. No EBs are expected to be collected for

biota samples or chat samples.

Temperature Blanks

Temperature blanks are sent with each cooler shipped to the offsite laboratory containing soil or

ground water samples requiring preservation at 4º C. Temperature blanks consist of a non-preserved

VOC vial or similar laboratory container filled with reagent grade water. Temperature blanks are

measured with a thermometer at the laboratory upon receipt to verify the temperature of the samples

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contained in that cooler. One temperature blank will be shipped with each cooler to each offsite

laboratory.

Matrix Spike / Matrix Spike Duplicate

A MS is a normal field sample that is spiked by the analytical laboratory with a known concentration

of target analyte(s) prior to sample preparation and then carried through the entire preparatory and

analytical procedure. The MSD is an intra-laboratory split of the same sample used for the MS that is

also spiked with identical concentrations of target analyte(s) and treated just as the MS sample.

MS/MSDs are used to monitor and document possible bias for a given analytical method in a given

sample matrix. MS/MSDs are also used to measure the precision and accuracy of the laboratory

analytical procedure.

CLP laboratories require a MS/MSD (or MS/laboratory duplicate) to be analyzed at a frequency of

5%, or 1 MS/MSD per 20 samples of similar matrix per week. The EPA Region 6 Houston

Laboratory requires a MS/MSD (or MS/laboratory duplicate) to be analyzed at a frequency of 10%,

or 1 MS/MSD per 10 samples of similar matrix per week. Project-specific MS/MSDs shall also be

performed on the samples that are submitted to a Tier IV commercial laboratory.

2.5.2 Field and Laboratory Corrective Action

Field Corrective Action

Any project team member may initiate a field corrective action process. The corrective action process

consists of identifying a problem, acting to eliminate the problem, monitoring the effectiveness of the

corrective action, verifying that the problem has been eliminated, and documenting the corrective

action. A copy of a corrective action form is presented in Appendix A.

Field corrective actions may include such activities as correcting COC forms, solving problems

associated with sample collection, re-packing samples to ensure sample integrity, correcting an entry

in a field logbook, or providing a team member with additional training in sampling procedures. More

extensive corrective actions may involve re-sampling or evaluating and revising sampling procedures.

The FTL will summarize the problem, establish possible causes, and designate the person responsible

for a corrective action. The FTL will then verify that the initial action has been taken and that it

appears to be effective. Finally, the FTL will follow up at a later time to verify that the problem has

been resolved.

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If a corrective action could potentially impact the quality of the analytical process, the FTL must

notify the CH2M HILL PC immediately and inform him of the situation.

Laboratory Corrective Action

The analytical laboratories analyze samples according to specific methods with required QC

standards. All analytical data is reviewed to ensure that the required QC measures are taken and that

all specified QC standards are met. Some examples of situations that may require laboratory

corrective action include:

• QC data are outside the control limit ranges for precision and accuracy established for laboratory

samples

• Blanks contain target analytes above acceptable levels

• Deficiencies are detected by the laboratory QA director during internal or external audits, or from

the results of performance evaluation samples

• Undesirable trends are detected in QC data

• There are unusual changes in detection limits

• Inquiries concerning data quality are received

If the bench analyst identifies a QC violation, then corrective action is taken immediately. The analyst

immediately notifies his or her supervisor of the problem and the investigation being performed.

Some examples of analyst-level corrective action can include:

• Recalculating mathematical calculations

• Reanalyzing suspect samples

• Recalibrating analytical instruments

• Recalibrating with new standards

If the problem persists or cannot be identified, the matter must be referred to the laboratory supervisor

and QA/QC officer for further investigation. All laboratory QC problems that will affect the quality

of the final data should be discussed with the CH2M HILL PC as part of the corrective action process.

Some examples of managerial-level corrective action include:

• Evaluating and amending sub-sampling or analytical procedures

• Re-sampling and analyzing new samples

• Qualifying or rejecting the data

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Once a problem is resolved, full documentation of the corrective action must be included with the

applicable data package prior to submittal to the CH2M HILL PC.

2.6 Equipment Testing, Inspection, and Maintenance

Field equipment testing, inspection, and maintenance will be in accordance with the SOPs in the FSP.

Laboratory equipment testing, inspection, and maintenance will be in accordance with the

laboratory’s QAP.

2.7 Equipment Calibration and Frequency

2.7.1 Field Instruments

Field analytical work for this investigation is expected to include field instrumental analysis (Horiba

Model U-22 or equivalent). Any field instruments utilized will be calibrated in accordance with

manufacturers’ specifications before the beginning of sampling activities and at specified intervals

thereafter. For field instruments calibrated by the manufacturer, calibration will be verified daily. If a

field instrument cannot be properly calibrated, the instrument must not be used and must be replaced

with a functioning instrument.

2.7.2 Laboratory Equipment

All laboratory instruments will be calibrated in accordance with manufacturers’ directions, method

requirements, and SOP specifications.

2.8 Inspection / Acceptance of Supplies and Consumables

CH2M HILL is responsible for supplying all required supplies and consumables for the duration of

the project. Any purchased supplies or other subcontract service must meet the project scope,

specified levels of quality, and the submittal schedule. Project contractors should have contractual

arrangements with their suppliers of materials.

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2.9 Non-Direct Measurements

This subsection discusses the types of data that will be used to make project decisions that are

obtained from non-measurement sources.

Project objectives were outlined and summarized in Section 1 of this QAPP. Typically, the data

needed to achieve the project objectives include site maps, sampling location selection and sample

identifiers, laboratory method selection, detection limit verification, analytical parameter lists and

critical values, field parameter measurement list, and a project schedule. This information is typically

included in several project documents such as the FSP, and this QAPP.

As part of the data acquisition planning activity, the team defined the historical and reference

information to be used. The project team reviewed the historical data and evaluated its data quality. A

similar QC review will be performed on the new analytical data obtained during this investigation.

The product of this activity is a database containing complete and accurate analytical information that

can be used for project decision-making and report production.

2.10 Data Management

Typically, data gathered during the investigation, as well as any gathered during previous site

investigations, are consolidated and compiled into a project environmental database system, which is

used to evaluate site conditions and data trends.

Project data management generally includes the following project-specific objectives:

• Establish a controlled, functional, and efficiently operated data management system and

accompanying procedures to manage, analyze, document, and transfer the environmental data that

are collected and generated.

• Maintain a usable and accurate database throughout the life of the project.

• Process specific data requests from project team members.

• Transfer the database or specific data components to other parties, as appropriate.

• Archive the database and related documentation upon project closeout.

2.10.1 Data Types

Activities performed during site investigations generally involve accessing a number of different

types of data. Typical contents of a project database are described below.

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Historical Data

Sources of historical data for an investigation site include any information collected by CH2M HILL

and other parties that can be used to aid in the achievement of project objectives. That information

can include chemical and physical data from previous investigations, historical accounts, and various

other types of data. Since this project is well into the remedial action phase, there is a substantial

amount of historical data available.

Investigative Analytical Data

The FSP will identify the additional data to be collected for the achievement of project objectives.

These data will be added to the project database as they become available. The data may include

screening and engineering data collected in the field, as well as evaluated laboratory analytical data.

2.10.2 Data Tracking and Management

Hardcopy

Measurements made during field data collection activities will be recorded in field logbooks. Field

data will be reduced, summarized, and stored along with the field logbooks.

All hardcopy analytical laboratory data will be stored. This may include chain-of-custody forms, case

narratives, analytical bench sheets and reports, instrument printouts and chromatograms, certificates

of analyses, and QA/QC report summaries.

Data Input Procedures

Sampling information shall be entered into an environmental database electronically by uploading the

information from the FORMS II Lite exportable files.

Analytical data obtained from the EPA Region 6 Houston Laboratory shall be electronically uploaded

to the project database from a Microsoft Access database file (.dbf). Analytical data obtained from a

CLP laboratory shall be electronically uploaded from a Microsoft Excel file (.xls). Analytical data

obtained from Tier IV commercial laboratories shall be electronically uploaded from either a comma-

delimited text file (.txt) or comma-separated value (.csv) file in the format specified by the CH2M

HILL EDMS LabSpec7 requirements.

Data validation qualifiers determined by the project chemist shall be manually entered into the project

database by a database manager overseen by the Senior Data Manager.

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The final electronic result of any data upload to the project database will be verified against the

original hardcopy reports to ensure the accuracy of the EDD and of any manual transcription. All

data entry evaluation procedures and results will be appropriately documented. The product of this

activity is an accurate and complete project database ready to support project data evaluation.

2.10.3 Computer Database

The computer database system utilizes Microsoft Access 97 or 2000 and combines a macro-

programming language and software tools to build menus, online forms, and report formats. The

database will be based upon a relational model, in which independent tables containing fields of data

can be linked through selected fields that are common to two or more tables. This database design

allows inclusion of the historical data, and allows users to effectively conduct trend analysis, and

generate a variety of data reports to aid in data interpretation and report generation.

The database should be protected from unauthorized access, tampering, accidental deletions or

additions, and data or program loss that can result from power outages or hardware failure.

2.10.4 Documentation

Documentation of data management activities is critical because it provides:

• A record of project data management activities

• Reference information critical for database users

• Evidence that the activities have been properly planned, executed, and verified

• Continuity of data management operations when personnel changes occur

Additional documentation will be maintained to document specific issues such as database structure

definitions, database inventories, database maintenance, user requests, database issues and problems,

and client contact.

2.10.5 Evidence File

The final evidence file will be the central repository for all documents that constitute evidence

relevant to sampling and analysis activities. CH2M HILL is the custodian of the evidence file and

maintains the contents of the evidence files for the project, including all relevant records, reports,

logs, field notebooks, pictures, contractor reports, and data reviews in a secured, limited access area

under the custody of CH2M HILL.

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CH2M HILL shall retain all records until project completion and closeout. Records may be

transferred to an offsite record storage facility, if necessary. The record storage facility should

provide secure, access-controlled storage of records. Subcontract laboratories shall retain all records

of raw analytical laboratory data, QA data, and reports for a minimum of 5 years.

The central repository for electronic files will be located in the project directory of the Dallas server.

2.10.6 Presentation of Analytical Data

In addition to laboratory data, other physical data may be collected during field efforts including

water level data, well construction details, boring stratigraphy, and field measurements of pH,

conductivity, or temperature. This information will be stored in the project database. Other types of

data elements may be added as the field investigation needs and activities evolve.

Data presentation will vary depending on the data user needs. Some examples of data presentation

formats are the following:

• Tabulated results of data summaries or raw data

• Figures showing concentration isopleths or location-specific concentrations

• Tables providing statistical evaluation results or calculation results

• Presentation tools such as ARC/INFO or other similar analysis/presentation aids

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005506


3.0 Assessment and Oversight

3.1 Assessments and Response Actions

Assessment and oversight activities are performed to determine whether the QC measures identified

in the FSP and this QAPP are implemented and documented as required. The PM and the FTL will

perform assessment and oversight activities to monitor conformance to plans. For example, during a

field review, the FSP may be checked to verify that a monitor well has been correctly sampled or that

the field QC samples were collected at the appropriate frequency. Additional checks may address the

questions:

• Is the FSP being adhered to?

• Is non-conformance being identified, resolved, and documented with a process or system?

• Are identified deficiencies being corrected?

• Are the sample labels being filled out completely and accurately?

• Are the COC records complete and accurate?

• Are the field notebooks being filled out completely and accurately?

• Are the documents generated during assessment activities being stored as described in the QAPP?

The need for a check can be determined independently by the PM or assigned by the PM to another

team member. Assessment activities may include surveillance, inspection, peer review, management

system review, performance evaluation, and data quality assessment. The results of the assessment

and oversight activities will be reported to the PM, who will be responsible for ensuring that the

corrective action response is completed, verified, and documented.

3.2 Reports to Management

Effective communication among all project team members shall be established and maintained

throughout the course of the project.

The PM will coordinate any status reports to the EPA WAM as necessary. Status reports will discuss

current activities, problems encountered and their resolution, and planned work.

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005508


4.0 Data Evaluation and Usability

4.1 Data Review, Verification, and Evaluation

Data review or validation is the process by which data generated in support of a project are reviewed

against the data QA/QC requirements. For this project, the QA/QC requirements are those specified

by applicable EPA methods, SOPs, and this QAPP. In cases where the data is deemed of insufficient

quality to satisfy project DQOs, the data will be rejected and will not be used to support project

decisions.

Several key statistical QC measurements that are used in the data review are discussed below.

4.1.1 Precision

Precision is a measure of the agreement or reproducibility of a set of replicate results obtained from

duplicate analyses made under identical conditions. Precision is estimated from analytical data and

cannot be measured directly. The precision of a duplicate determination can be expressed as the

relative percent difference (RPD), as calculated as

RPD = {(|X1 - X2|)/(X1 + X2)/2} x 100 = ( )X X

X Xx1 2

1 2

2

100−

+

where X1 is the result from the native sample, and X2 is the result from the duplicate sample.

4.1.2 Accuracy

Accuracy is a measure of the agreement between an experimental determination and the true value of

the parameter being measured. Accuracy is estimated through the use of known reference materials or

MSs. It is calculated from analytical data and is not measured directly. Spiking of reference materials

into a sample matrix is the preferred technique because it provides an assessment of the matrix effects

on analytical accuracy. Accuracy, defined as percent recovery (%R), is calculated as:

( ) 100 x SA

SR-SSR = R

%

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where SSR is the spiked sample result, SR the sample result (native), and SA the spike concentration

added to the spiked sample.

4.1.3 Completeness

The completeness of the field and laboratory-generated analytical data will be assessed for

compliance with the amount of data required for decision-making. The calculation for determining

completeness is:

% Completeness = Valid Data Obtained × 100

Total Data Obtained

The completeness goal for the project data set is 95 percent.

4.1.4 Sensitivity

Sensitivity is a measure of how low of a concentration an analysis can reliably detect and report a

particular analyte. Higher sensitivities allow the laboratory to establish method detection limits

(MDLs) and reporting limits (RLs) at sufficiently low levels so that the project DQOs can be

achieved.

4.2 Data Types

4.2.1 Screening Data

Screening data generally includes field measurements that are analyzed with a minimal level of QC to

produce approximate numbers for screening purposes. Screening data are generally used based upon

very limited QA/QC and documentation in contrast to the rigorous review of data quality required for

the definitive data sets. Screening data for this project will include field measurements of

temperature, pH, dissolved oxygen, and specific conductivity.

The FTL or PC will normally review the screening data and accept or reject them. Unusual readings

are recorded in the field logbook, along with the rationale for accepting or rejecting the data. The

following types of field data are generally recorded in the site logbooks for the FTL’s review:

• Instrument identification

• Calibration information and/or verification (standards utilized and results)

• Date and time of calibration and sample measurement

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• Sample results

• Supporting information (e.g., temperature for pH reading)

4.2.2 Definitive Data

Definitive data are data of known quality with a substantial level of associated QA/QC. The definitive

data results undergo an extensive quality system of data review and data evaluation. Definitive data

can be used for the following:

• Investigate the nature and extent of site-related constituents

• Support remedial action design

• Support risk assessment tasks

Definitive data can be generated by various measurements, ranging from onsite field analyses to

laboratory analyses. Definitive data for this project will include all soil analyses and ground water

analyses that are not performed by field measurements.

4.3 Validation and Evaluation Methods

The data validation or data review process is conducted to assess the effect of sampling and analytical

processes on the usability of the data. There are two areas of review: laboratory performance

evaluation and the effect of matrix interference or sampling error. Evaluation of laboratory

performance is a relatively straightforward examination that determines whether or not the laboratory

met the QC requirements of the analytical methods and other project-specific protocol requirements

stated in this QAPP or in the Laboratory SOW. The assessment of potential matrix effects and

sampling error consists of an evaluation of the analytical results for the samples, as well as a number

of QC measures such as blank samples, duplicates, MS/MSDs, LCSs, etc. and then assessing if this

could affect the usability of the data.

All analytical data will be supported by the appropriate level of data package as listed in Table 2.

Field analytical determinations shall provide Level I reports. The data package requirements of the

three levels are defined in Table 3 and discussed in Section 1.7.3 of this QAPP. Hardcopy data shall

include all items listed in the appropriate level in Table 3 and should be unbound for the purpose of

data validation.

Before the laboratory will release each data package, the laboratory QA officer (or the analytical

section supervisor) must carefully review the sample and laboratory performance QC data to verify

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sample identity, the completeness and accuracy of the sample and QC data, and compliance with

method specifications.

Analytical data will be evaluated against the analytical QC standards set forth in the applicable SOPs,

this QAPP, and applicable methods. If these standards are not met, the data is appropriately qualified

during the evaluation process. In cases where the data is deemed of insufficient quality to satisfy

project DQOs, the data will be rejected and will not be used to support project decisions.

Any analytical data provided by a CLP laboratory in support of this project will undergo a data

validation by the EPA Region 6 ESAT Review Team according to EPA’s Functional Guidelines prior

to submittal to CH2M HILL and will therefore not require a further validation by the PC. The PC will

review the findings of the ESAT review.

All non-CLP analytical data obtained in support of this project shall be reviewed by the PC according

to criteria analogous to that set forth in EPA’s National Functional Guidelines. Sample results will

then be assigned a degree of usability based upon overall data quality. After the completion of the

data evaluation effort, a data review technical memorandum will be prepared for internal project use.

The CH2M HILL project team will evaluate the results of the data validation. This evaluation will

assess how the data, as qualified by the data evaluation, can be used on the project.

4.4 Reconciliation with User Requirements

The final data evaluation task is to assess whether the data meet the project DQOs. The final validated

analytical results, which may have been modified during the data evaluation process, will be checked

against the DQOs, and an assessment will be made as to whether or not the data are of sufficient

quality to support them.

Finally, the project database will be updated with the newly validated data and any qualifiers or

comments that were applied during the course of the data review. The PDM will then produce data

presentations based upon the data user needs of the project team.

005512

Appendix A

Quality Control Corrective Action Form

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005514

Quality Control Corrective Action Form

QCCAF Originator: ____________________________ Date: _________________

Description of problem: _________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

Corrective action taken:

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

Corrective action results:

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

CA initially approved by: _________________________________ on Date: _________________

Follow-up date: ___________________

Final CA approval by: _________________________________ on Date: _________________

SEND COPIES TO:

Responsible Person, PC, FTL, PM

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005516

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