final activity-based sampling sampling and analysis …

FINAL ACTIVITY-BASED SAMPLING

SAMPLING AND ANALYSIS PLAN

FOR

OPERABLE UNIT 7 OF THE LIBBY ASBESTOS SUPERFUND SITE

July 12, 2011

Prepared for:

MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY Remediation Division

P.O. Box 200901 Helena, Montana 59620

Contract Number 407026 Contract Task Order Number 81

Prepared by:

TETRA TECH EM INC. Power Block Building, Suite 612

7 West 6th Avenue Helena, Montana 59601

(406) 442-5588

Activity-Based Sampling, SAP i OU7 – Libby Asbestos Superfund Site

ACTIVITY-BASED SAMPLING SAMPLING AND ANALYSIS PLAN

FOR

OPERABLE UNIT 7 OF THE LIBBY ASBESTOS SUPERFUND SITE

Prepared for:

MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY

REVIEWS AND APPROVALS

Tetra Tech Project Manage: _______________________ Date: July 12, 2011 J. Edward Surbrugg, Ph.D.

DEQ Project Officer: _______________________ Date: John Podolinsky

EPA Remedial Project Manager: _______________________ Date: Victor Kettelapper

Activity Based Sampling, SAP ii OU7 – Libby Asbestos Superfund Site

DISTRIBUTION LIST

Name Responsibility Affiliation

John Podolinsky DEQ Project Officer Montana Department of Environmental Quality – Helena, Montana

J. Edward Surbrugg Tetra Tech Project Manager Tetra Tech EM Inc. – Helena, Montana

Victor Kettelapper EPA Remedial Project Manager Environmental Protection Agency

Mike Noble EPA Technical Advisory Group Environmental Protection Agency

Michelle Carlson DEQ Troy Info Center Tetra Tech EM Inc. – Troy, Montana

Additional copies of the Operable Unit 7 Activity-Based Sampling investigation documents can be made available for further distribution.

Activity Based Sampling, SAP iii OU7 – Libby Asbestos Superfund Site

CONTENTS Section Page

DISTRIBUTION LIST ................................................................................................................... ii

ACRONYMS AND ABBREVIATIONS ..................................................................................... vii

1.0 INTRODUCTION ...............................................................................................................1

1.1 ACTIVITY-BASED SAMPLING PROJECT OBJECTIVES ..................................................2

1.2 PROJECT SCHEDULE AND DELIVERABLES .................................................................2

2.0 PROJECT BACKGROUND ...............................................................................................3

2.1 SITE LOCATION .........................................................................................................3

2.2 SITE HISTORY ...........................................................................................................3

2.3 OCCURRENCE OF LIBBY AMPHIBOLE ........................................................................5

2.4 DEVELOPMENT OF HHRA DATA GAPS .....................................................................5

3.0 DATA QUALITY OBJECTIVES .......................................................................................8

3.1 STEP 1 – STATE THE PROBLEM ..................................................................................8

3.2 STEP 2 – IDENTIFY THE DECISION .............................................................................9

3.3 STEP 3 – IDENTIFY THE INPUTS TO THE DECISION ...................................................10

3.3.1 Sampling Locations ...................................................................................11

3.3.2 Types of Air Samples.................................................................................11

3.3.3 Target Analyte List ....................................................................................11

3.3.4 Types of Soil Disturbances ........................................................................11

3.3.5 Soil Condition Data....................................................................................12

3.4 STEP 4 – DEFINE THE BOUNDARIES OF THE STUDY .................................................12

3.4.1 Spatial Bounds ...........................................................................................12

3.4.2 Temporal Bounds .......................................................................................12

3.5 STEP 5 – DEVELOP DECISION RULES .......................................................................13

3.6 STEP 6 – SPECIFY TOLERABLE LIMITS ON DECISION ERRORS .................................15

3.7 STEP 7 – OPTIMIZE THE INVESTIGATION DESIGN ....................................................16

4.0 SAMPLING PROGRAM ..................................................................................................18

4.1 ABS SCENARIOS .....................................................................................................18

4.1.1 ABS Scenario 1: Yard Work in Residential Yards ...................................18

4.1.2 ABS Scenario 2: Gardening in Residential Gardens ................................22

4.1.3 ABS Scenario 3: Bicycling and Playing on Unpaved Residential Driveways ..................................................................................................23

4.1.4 ABS Scenario 4: Driving on Paved and Unpaved Roads and Alleys .......23

TABLE OF CONTENTS (Continued)

Section Page

Activity Based Sampling, SAP iv OU7 – Libby Asbestos Superfund Site

4.1.5 ABS Scenario 5: Bicycling on Paved and Unpaved Roads, Alleys, and Trails ..........................................................................................................25

4.1.6 ABS Scenario 6: Recreational Activities at Parks and School Yards .......26

4.2 PRE-SAMPLING ACTIVITIES .....................................................................................27

4.2.1 Field Planning and Required Equipment and Supplies ..............................27

4.2.2 Identify Sampling Locations ......................................................................29

4.3 ACTIVITY-BASED SAMPLING INVESTIGATION .........................................................29

4.3.1 Scheduling ABS Visits ..............................................................................30

4.3.2 Soil Sample Collection ..............................................................................30

4.3.3 Visual Inspection .......................................................................................32

4.3.4 Pump Calibration .......................................................................................33

4.3.5 Air Sample Collection ................................................................................34

4.3.6 Health and Safety Air Monitoring .............................................................35

4.3.7 ABS Activities Documentation ..................................................................35

4.4 FIELD QUALITY CONTROL SAMPLES .......................................................................36

4.4.1 Lot blanks (Air) ..........................................................................................36

4.4.2 Field blanks (Air) .......................................................................................36

4.4.3 Equipment Blanks (Soil) ............................................................................37

4.4.4 Field Duplicate Samples (Soil) ..................................................................37

4.5 GENERAL PROCESSES .............................................................................................37

4.5.1 Equipment Decontamination .....................................................................37

4.5.2 Investigation-Derived Waste .....................................................................38

4.5.3 Recordkeeping and Chain of Custody .......................................................38

4.5.4 Field Logbooks ..........................................................................................39

4.5.5 Sample Labeling and Identification ...........................................................39

4.5.6 Photographic Documentation.....................................................................40

5.0 LABORATORY OPERATIONS ......................................................................................41

5.1 ANALYTICAL METHODS AND TURNAROUND TIMES ................................................41

5.1.1 Air Samples ................................................................................................41

5.1.1.1 Analytical Sensitivity for TEM Analyses ................................42

5.1.1.2 Sample Archival.......................................................................42

5.1.2 Soil Samples...............................................................................................42

5.2 HOLDING TIMES ......................................................................................................43

5.3 LABORATORY CUSTODY PROCEDURES ...................................................................43

TABLE OF CONTENTS (Continued)

Section Page

Activity Based Sampling, SAP v OU7 – Libby Asbestos Superfund Site

5.4 LABORATORY QA/QC ............................................................................................43

5.5 LABORATORY DOCUMENTATION AND REPORTING .................................................44

5.6 LABORATORY NONCONFORMANCE .........................................................................44

6.0 DATA MANAGEMENT...................................................................................................45

6.1 TABULAR DATA ......................................................................................................45

6.2 DOCUMENTS AND RECORDS ....................................................................................45

7.0 QA/QC PROCEDURES ....................................................................................................46

7.1 QA/QC OBJECTIVES ...............................................................................................46

7.2 INTERNAL QC CHECKS ...........................................................................................46

7.3 AUDITS, CORRECTIVE ACTIONS, AND QA REPORTS ...............................................46

7.3.1 Field Inspections and Sampling Procedures Audits ...................................47

7.3.2 Corrective Action Procedures ....................................................................47

8.0 REFERENCES ..................................................................................................................48

Appendix

A TETRA TECH SITE-SPECIFIC HEALTH AND SAFETY OU7 ACTIVITY-BASED SAMPLING

B FIELD FORMS AND LABORATORY FORMS

C STANDARD OPERATING PROCEDURES

Activity Based Sampling, SAP vi OU7 – Libby Asbestos Superfund Site

FIGURES

Figure Page

2-1 OPERABLE UNIT 7 BOUNDARY ....................................................................................4

2-2 OPERABLE UNIT 7 CSM ..................................................................................................7

4-1 RECREATIONAL SCENARIO SAMPLING LOCATIONS ...........................................28

TABLES

Table Page

3-1 PRINCIPAL STUDY QUESTIONS AND ALTERNATIVE ACTIONS...........................9

3-2 SUMMARY OF INPUTS TO RESOLVE STUDY QUESTIONS AND USE OF INFORMATION ACQUIRED FROM INPUTS...............................................................10

3-3 DECISION RULES ...........................................................................................................14

3-4 LIMITS ON DECISION ERRORS ...................................................................................17

4-1 EXPOSURE SCENARIOS, LOCATIONS, ACTIVITIES AND NUMBER OF SAMPLES..........................................................................................................................19

4-2 FIELD QUALITY CONTROL SAMPLES.......................................................................36

Activity Based Sampling, SAP vii OU7 – Libby Asbestos Superfund Site

ACRONYMS AND ABBREVIATIONS

µm Micrometer % Percent ABS Activity-Based Sampling ACM Asbestos-containing material AS Analytical sensitivity ASTM ASTM International (formerly the American) Society for Testing and Materials)

bgs Below ground surface

CDM Camp, Dresser & McKee COC Chain of custody CSM Conceptual site model

DEQ Montana Department of Environmental Quality DQO Data quality objective

EDD Electronic data deliverable EPA U.S. Environmental Protection Agency ESAT Environmental Services Assistant Team

f/cc Fibers per cubic centimeter FSP Field Sampling Plan

HASP Health and safety plan HHRA Human health risk assessment HQ Hazard Quotient

ISO International Organization for Standardization IRIS Integrated Risk Information System LA Libby Amphibole L/min Liters per minute

MCE Mixed-Cellulose Ester MET Meteorological mph Miles Per Hour

NA Not applicable ND Non-Detect

Activity Based Sampling, SAP viii OU7 – Libby Asbestos Superfund Site

ACRONYMS AND ABBREVIATIONS (Continued)

OU Operable unit

PCM Phase Contrast Microscopy PDA Personal digital assistant PDF Portable document format PEL Permissible exposure limit PLM Polarized light microscopy PLM-grav Polarized light microscopy - gravimetric PLM-VE Polarized light microscopy – visual estimation PPE Personal protective equipment

QA Quality Assurance QA/QC Quality assurance / quality control QAPP Quality assurance project plan QC Quality control

RDI Removal Design Investigation RPD Relative percent difference

s/cm2 Structures per square centimeter SAP Sampling and analysis plan SOP Standard operating procedure SRC Syracuse Research Corporation STEL Short term exposure limit

TAPE Troy Asbestos Property Evaluation TEM Transmission Electron Microscopy Tetra Tech Tetra Tech EM Inc. TFO Troy field office TWA Time weighted average TWF Time Weighting Factor

UCL Upper Confidence Limit USACE US Army Corps of Engineers

VWC Volumetric water content

WP Work Plan

Activity Based Sampling, SAP 1 OU7 – Libby Asbestos Superfund Site

1.0 INTRODUCTION

Tetra Tech EM Inc. (Tetra Tech) received Task Order 81 from the Montana Department of Environmental Quality, Remediation Division (DEQ), under DEQ Contract No. 407026, to complete an activity-based sampling (ABS) scenario sampling and analysis plan (SAP) in Operable Unit 7 (OU7) of the Libby Asbestos Superfund Site. The United States Environmental Protection Agency (EPA) is the lead agency for the Libby Asbestos Superfund Site. The United States Army Corp of Engineers (USACE) is supporting EPA with the removal activities in OU7 and DEQ is the lead agency for OU7 through a cooperative agreement with EPA.

The primary objective of this document is to define air and soil data collection efforts needed to support development of the Human Health Risk Assessment for OU7 (Tetra Tech 2011). This SAP will guide Tetra Tech ABS activities during the ABS scenarios identified in the OU7 Human health risk assessment (HHRA) Work Plan (WP). It includes collection and analysis of outdoor air samples at residential properties and community-based recreational areas within OU7. Similar tasks are being conducted concurrently in OU4 of the Libby Asbestos Superfund Site, so, this document has considered concerns and results of OU4 ABS efforts addressed in the OU4 Work Plan prepared by Camp Dresser & McKee (Camp Dresser & McKee [CDM] 2010).

This SAP includes all required elements for both a field sampling plan (FSP) and a quality assurance project plan (QAPP), and was developed in accordance with EPA guidance documents Environmental Protection Agency Requirements for Quality Assurance Project Plans, EPA QA/R-5 (EPA 2001) and Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G4 (EPA 2006).

This SAP describes the sampling objectives, data quality objectives (DQO), locations, and measurement methods to support the ABS project within OU7.

The SAP is organized as follows:

Section 1.0 – Introduction

Section 2.0 – Project Background

Section 3.0 – Data Quality Objectives

Section 4.0 – Sampling Program

Section 5.0 – Laboratory Operations

Section 6.0 – Data Management

Section 7.0 – QA/QC Procedures


Tables and figures in this document follow the first reference in the text. Appendix A contains the site-specific health and safety plan (HASP) and HASP Addendum, Appendix B contains field forms anticipated for use during the ABS project, and Appendix C contains project-specific standard operating procedures (SOP) that will be followed during the ABS project.

1.1 ACTIVITY-BASED SAMPLING PROJECT OBJECTIVES

The primary objective of the OU7 ABS project is to obtain the data needed to allow DEQ to complete a HHRA for OU7. The HHRA will be used to help evaluate whether the interim removals designed for OU7 were effective in reducing the threat to human health from exposure to LA in air at OU7 at residential properties and whether additional removal actions are needed. In addition, the HHRA will evaluate threats to human health from community-wide (nonresidence-specific) exposures to LA in air at OU7. The residential properties fall into two categories:

Properties for which soil removal is not required based on removal criteria described in EPA (2003) and DEQ (2009).

Properties for which soil removal has been completed.

The air data needed to complete the HHRA were identified in the HHRA work plan for OU7 (Tetra Tech 2011), and consist of ABS data for outdoor air, ABS data for indoor air, and ambient air data. ABS data for indoor air and ambient air data are available and usable for the HHRA; ABS data for outdoor air for the two residential property categories and for community areas were identified as a data gap (Tetra Tech 2011). The OU7 ABS project will obtain the outdoor air ABS data needed to complete the HHRA.

1.2 PROJECT SCHEDULE AND DELIVERABLES

The first phase of ABS field activities is expected to occur during May and June of 2011 and the second field phase is anticipated to occur during August and September 2011. A draft report summarizing the findings from ABS efforts will be completed later in 2011.


2.0 PROJECT BACKGROUND

From the 1920s until 1990, an active vermiculite mine and associated processing operations were located in Libby, Montana. While it was in operation, the mine may have produced 80 percent of the world’s supply of vermiculite (EPA 2005). The processed and exfoliated vermiculite was primarily used for insulation in buildings and as a soil amendment. The Libby vermiculite deposit includes amphibole asbestos. For decades, the processing of vermiculite ore and generation and disposal of waste materials resulted in the widespread presence of amphibole asbestos throughout the Libby community. In 1999, EPA Region 8 dispatched an emergency response team to investigate media reports of abundant amphibole asbestos and high rates of asbestos-related disease in Libby. Subsequent environmental investigations found asbestos throughout many areas in and around Libby that included a form of amphibole asbestos known as LA.

2.1 SITE LOCATION

Troy, Montana is located 18 miles northwest of Libby, Montana and was designated as OU7 of the Libby Asbestos Superfund Site. OU7 is located within the Kootenai River valley at an elevations ranging from 1,850 feet above mean sea level at the northern end to 2,500 feet above mean sea level on the mountain slopes surrounding the valley. OU7 is approximately 8 miles long and up to 1.8 miles wide. Topography of OU7 consists of relatively flat river valley terraces on both sides of the gently graded Kootenai River. Several tributaries flow into the Kootenai River along the 8-mile stretch of the river contained within OU7.

The OU7 boundary (Figure 2-1) was selected to ensure that investigations captured most of the older homes in and around Troy that are more likely to contain LA or LA source materials.

2.2 SITE HISTORY

Some of the vermiculite mine workers lived in Troy and commuted daily to work at the mine in Libby. The mine workers were exposed to asbestos-containing materials at the mine and processing facilities, and they transported asbestos-containing dust to their homes on clothes and equipment. Residents of Troy also traveled to Libby for everyday activities such as shopping, working (other than at the mine), and attending school sporting events. They likely came into contact with LA in Libby during these frequent visits. The asbestos-containing vermiculite ore and waste materials in varying forms may have been used for amending soils (as fill or as a conditioner), building materials (plaster, concrete, or chinking amendment), wood burning, spilled or placed in transportation corridors, and for insulating buildings in and around Troy.

K O O T E N A IN A T I O N A L

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TOWN OF TROY

KOOTENAI RIVER

KOOTENAI RIVER

K O O T E N A IN A T I O N A L

F O R E S T

Kootenai River

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Lake

Cree

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Callahan Creek

Iron Creek

Brush Creek

Lynx Creek

Ruby Creek

Falls Creek

Thre

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Rabbit Creek

Hummingbird Creek

July C

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LINCOLN

COUNTYLOCATION OFLARGER MAP

GIS map by Ed Madej TTEMI-HEFIG2-1_OU7_BOUNDARIES_041111.mxd

±0 1Miles

FIGURE 2-1LIBBY ASBESTOS SITE

OPERABLE UNIT 7BOUNDARY

ABS Sampling and Analysis PlanLegendOU7 BOUNDARY


2.3 OCCURRENCE OF LIBBY AMPHIBOLE

Typically, the LA found in southern Lincoln County comes from one, or some combination of, primary sources outside of OU7 including vermiculite mining waste, vermiculite ore, vermiculite processing waste, bulk residuals from vermiculite processing, LA-containing rock, or LA-containing vermiculite insulation. Although there are no major sources of LA within OU7, residential use of vermiculite from the Libby mine, primarily as building insulation and as a soil amendment, was common. In some cases, vermiculite insulation was found after it sifted from the attic into interior and exterior walls. In rare cases, vermiculite has been found as an additive in building materials such as plaster, mortar, and concrete.

The LA-containing soil is generally from vermiculite used as a soil amendment in flowerbeds and gardens, for leveling of low spots, and for backfilling of utilities.

2.4 DEVELOPMENT OF HHRA DATA GAPS

Since the nature of LA and associated exposure pathways in OU7 are similar to those observed in Libby, and the vermiculite insulation found in Troy is similar in both morphology and mineralogy to that found in Libby, a systematic screening of interiors and exteriors of Troy area residences, public areas, schools, and businesses was conducted to gather information to determine how many Troy area properties have LA present. This systematic screening is referred to as the Troy Asbestos Property Evaluation (TAPE) (Tetra Tech 2007).

Potentially complete and significant inhalation exposure pathways for LA and the data needed to quantify human health risks for exposure pathways were identified during development of the HHRA Work Plan (Tetra Tech 2011) and from available data compiled from ongoing investigations in OU7 and OU4. The HHRA will be used to help confirm that the TAPE investigation and interim removals performed in OU7 were effective in reducing or removing the threat to human health from exposure to LA and whether additional removal actions are necessary. A conceptual site model (CSM) for potential human inhalation exposure pathways to LA was prepared as part of the HHRA work plan development. Figure 2-2 provides the CSM. This SAP addresses only outdoor residential and community based recreational activities in OU7 because similar ABS scenarios have been performed for both interior and some exterior activities in OU4. Data from OU4, both interior and some exterior, can be used to assign human health risk in OU7. In addition, correlations between disturbed soil and nearby LA concentrations in ambient air continue to be evaluated. Previous attempts to develop correlations between soil and air during OU4 ABS events have provided inconclusive results. For this reason, the EPA has requested soil samples be collected in residential scenarios within OU7 and archived for future analysis. Soil samples from OU7 will be collected from 0-1 inches and 0-6 inches below ground surface (bgs) at each of the residential scenario locations and will be archived until further evaluation by EPA is requested.


Based on TAPE and the Removal Design Investigation (RDI) findings from 2007 through 2010, DEQ concluded that exterior removals were not necessary for 892 parcels. DEQ identified the need for exterior removals for 31 parcels at OU7; removals for 21 of the parcels were completed in 2010 and removals for the remaining 10 parcels are scheduled for future dates in 2011. The HHRA will evaluate potential human health inhalation exposure pathways for LA to evaluate (1) if there are acceptable risks or there are no threats to human health for parcels for which interim exterior removals were not required, and (2) if the interim exterior removals were effective in reducing the threat to human health to acceptable levels. The HHRA data gaps addressed by the ABS program include specific receptor and exposure locations as identified in Figure 2-1 that include:

1. Residential exposure to dust in the air of vehicles

2. Residential exposure to outdoor air near disturbed soil

3. Students and teachers exposure to outdoor air near disturbed soil

4. Outdoor and Tradesperson exposure to outdoor air near disturbed soil

5. Recreational users exposure to outdoor air near disturbed soil

The receptors and exposure locations to be evaluated and addressed through ABS activities are associated with six outdoor ABS scenarios. Although a wide variety of activities may result in outdoor disturbances of LA, it is not feasible to evaluate every type of disturbance. The six scenarios are considered realistic and representative examples of outdoor LA disturbances in OU7.

1. Yard work in residential yards

2. Gardening in residential gardens

3. Bicycling and playing on unpaved driveways

4. Driving on paved and unpaved roads and alleys

5. Bicycling on paved and unpaved roads, alleys, and trails

6. Recreational activities at parks and school yards

For each scenario, recommendations were developed regarding the sampling needed to obtain data for quantitative evaluation of the scenario in the HHRA. Property categories of LA, potential receptors and age groups, and temporal factors were considered for the recommended sampling. The descriptions and recommendations for sampling for the first five outdoor ABS scenarios are largely based on the supplemental outdoor ABS program planned for OU4 (CDM 2010). The description and recommendations for sampling the sixth outdoor ABS scenario are unique to OU7. Each of these outdoor ABS scenarios, including sampling recommendations and procedures, are described further in Section 4.0.

Receptor and Exposure Location(Current and Hypothetical Future)

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Contaminated MediaRelease and Transport PathwaysSources

Product(Vermiculite) Indoor Insulation

Unenclosed (Attic Spaces, Crawl Spaces)

Enclosed(Walls)

Indoor Dust

Carpets, Upholstery,Air Ducts, etc.

Spills

Dust on Workers' Clothing

Outdoor Air Near Fire Location

Air in Attic or Near Other Unenclosed

Vermiculite

Indoor AirNear Breached Walls

Indoor Air(Living and Workspaces)

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Leaks

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Historic and CurrentAirborne Releases

Outdoor Soil

Tree Bark

Surface Water Runoff

Contaminated Soil Along Highways, Rail Lines

BulkTransport

Outdoor Air Near Disturbed Soil

Outdoor AirNear Highways and

Rail Lines

Dust in Air of Vehicles

OutdoorAmbient Air

Ash from Burned Wood

Dust on Roofing or Other Outdoor Surfaces

Rain

Burning

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(1) Indoor dust disturbance may result from active behaviors (e.g., vacuuming, dusting, walking from room to room) and passive behaviors (e.g., reading, watching television, sleeping).

(2) Soil disturbance may result from outdoor active behaviors such as yard work, gardening, bicycling and playing on an unpaved driveway, driving and bicycling around town, and recreational activities at parks and school yards.

ABS Sampling and Analysis Plan

FIGURE 2-2Conceptual Site Model for

Potential Human Inhalation Exposure Pathways to Libby Asbestos

Operable Unit 7ABS Receptor and Exposure Locations

will be quantitatively evaluated in the Human Health Risk Assessment (HHRA).

Pathway is complete but is believed to be minor in comparison to other pathways;will be qualitatively evaluated in the HHRA.

? Pathway may be complete but magnitude of exposure is uncertain;will be qualitatively evaluated in the HHRA.

Pathway is incomplete or believed to be negligible;Further evaluation is not warranted.

Medium investigated by the Troy Asbestos Property Evaluation (TAPE), Outdoor Ambient Air (AA), and the Activity Based Sampling (ABS) programs.

Receptor and exposure locations evaluated by the ABS program for inclusion in the HHRA.


3.0 DATA QUALITY OBJECTIVES

The Data Quality Objectives (DQO) process is a series of planning steps designed to ensure that the type, quantity, and quality of environmental data used in decision-making are appropriate for the intended purpose. The DQOs presented in this section were developed in accordance with EPA guidance (EPA 2006).

DQOs help to clarify the study objectives, define the most appropriate data to collect and the conditions under which to collect the data, and specify tolerable limits on decision errors that will be used as the basis for establishing the quantity and quality of data needed to support decision-making. The DQOs are used to develop a scientific and resource-effective design for data collection.

The DQO process consists of seven steps; output from each step influences the choices that will be made later in the process. These steps include:

1. State the problem

2. Identify the decision

3. Identify the inputs to the decision

4. Define the study boundaries

5. Develop decision rules

6. Specify tolerable limits on decision errors

7. Optimize the investigation design

3.1 STEP 1 – STATE THE PROBLEM

This step describes the problem to be addressed. One issue of high priority to EPA is an evaluation of the efficacy of the current removal strategy – answers are needed for these questions:

Are there acceptable risks to residents and the community within OU7 at properties that DEQ and EPA has characterized as having no triggers sufficient to warrant removal actions under the approach described in (EPA 2003 and DEQ 2009)?

Are there acceptable risks to residents and the community within OU7 after a removal action is completed?

In this document, the phrase "post-removal property" is used to indicate any property where EPA investigated sources and has either taken removal action or tentatively determined that no removal action is needed. EPA has been working to remove both indoor and outdoor sources of vermiculite insulation, soil containing vermiculite, and LA at properties in OU7. To help evaluate the efficacy and protectiveness of these removal activities, information is needed to complete characterization of residual risk from outdoor exposures that may remain at post-


removal properties. The objective of this SAP is to specify how to obtain specific ABS outdoor air receptor and exposure location data (see Section 2.4 and Figure 2-2) to be used in the HHRA.

3.2 STEP 2 – IDENTIFY THE DECISION

This step identifies the questions the ABS project is designed to answer and what actions may result. The principal questions and possible alternative actions are included in Table 3-1:

TABLE 3-1 PRINCIPAL STUDY QUESTIONS AND ALTERNATIVE ACTIONS

Response Item Evaluated Principal Study Question Alternative Actions

Quantify airborne LA exposures during various outdoor activities involving simulated residential, recreational and commercial receptor categories where data gaps have been identified.

1. Is the current strategy for removal actions of outdoor soil in OU7 adequate to provide health protection from exposures to LA that occur when residents disturb the soil?

2. If not, what characteristics of the soil (e.g., presence of visible vermiculite and PLM-VE result) can be used to correlate area of disturbed soil and emission to nearby air that may require further removal actions?

Collect ABS outdoor air samples during various simulated work and play activities at OU7 properties that have undergone exterior removal actions.

Take no action Using TAPE protocol, collect and analyze

soil samples at the various use areas selected for ABS activities at OU7 residential and community properties

Take no action

1. At properties that underwent TAPE inspections and did not meet the removal criteria, was this decision adequate to provide health protection from exposures that occur when residents disturb the soil?

2. If not, what characteristics of the soil (e.g., presence of visible vermiculite and PLM-VE result) can be used to identify areas that require further removal actions?

Collect ABS outdoor air samples during various simulated work and play activities at OU7 properties that have not undergone exterior removal actions.

Take no action Using TAPE protocol, collect and analyze

soil samples at the various use areas selected for simulated work and play activities at OU7 properties

Take no action

Notes: The method that EPA currently recommends for estimating excess risk of lung cancer and mesothelioma from inhalation exposure to asbestos in air is described in EPA’s 2007 Integrated Risk Information System (IRIS). This method is currently undergoing review, and the approach may be revised as new methods are developed and as new toxicity data on asbestos are obtained. The EPA has not developed a method for assessing non-cancer risks from inhalation exposure to asbestos, so, all evaluations of protectiveness that are based on currently available risk assessment methods should be viewed as interim, and these interim decisions may be revised in the future as methods and data for assessing the cancer and non-cancer risks of asbestos are improved.

ABS Activity-based sampling LA Libby Amphibole OU7 Operable unit 7 PLM-VE Polarized Light Microscopy, Visual Estimation TAPE Troy Asbestos Property Evaluation


3.3 STEP 3 – IDENTIFY THE INPUTS TO THE DECISION

This step identifies the information and measurements needed to resolve the decision statements. The information needed to resolve the principal study questions is summarized in Table 3-2.

TABLE 3-2

SUMMARY OF INPUTS TO RESOLVE STUDY QUESTIONS AND USE OF INFORMATION ACQUIRED FROM INPUTS

Principal Study Question Input to Resolve

Question Use of Input to Resolve Question

1. Is the current strategy for removal actions of outdoor soil in OU7 adequate to provide health protection from exposures that occur when residents disturb the soil? 2. If not, what characteristics of the soil (e.g., presence of visible vermiculite and PLM-VE result) can be used to identify areas requiring further removal actions?

Samples in the breathing zone

At representative OU7 properties that underwent exterior removal actions, ABS outdoor air samples will be collected during various simulated work and play activities. The results of these air samples will be used to determine adequacy of health protection resulting from the soil removal.

Visual Inspection

At representative OU7 properties that underwent exterior removal actions, soil will be inspected using TAPE protocol, at the various use areas selected for simulated work and play activities. Depending on ABS results, the results of these soil inspections will be used to determine if further soil removal is needed.

Soil Sampling

At representative OU7 properties that underwent exterior removal actions, soil samples will be collected using TAPE protocol, at the various use areas selected for simulated work and play activities. Depending on ABS results, the results of these soil samples will be used to determine if further soil removal is needed.

1. At properties that underwent TAPE inspections and did not meet the removal criteria, was this decision adequate to provide health protection from exposures that occur when residents disturb the soil? 2. If not, what characteristics of the soil (e.g., presence of visible vermiculite and PLM-VE result) can be used to identify areas requiring further removal actions?

Samples in the breathing zone

At representative OU7 properties that did not meet the soil removal criteria, ABS outdoor air samples will be collected during various simulated work and play activities. The results of these air samples will be used to determine the adequacy of the health protection decision to not remove soil at these properties.

Visual Inspection

At representative OU7 properties that did not meet the soil removal criteria, soil will be inspected using TAPE protocol, at the various use areas selected for simulated work and play activities. Depending on ABS results, the results of these soil inspections will be used to determine if further soil removal is needed.

Soil Sampling

At representative OU7 properties that did not meet the soil removal criteria, soil samples will be collected using TAPE protocol, at the various use areas selected for simulated work and play activities. Depending on ABS results, the results of these soil samples may be used to determine if further soil removal is needed.

Notes:

LA Libby Amphibole ABS Activity-based sampling s/cm2 Structures per square centimeter PLM-VE Polarized Light Microscopy, Visual Estimation TAPE Troy Asbestos Property valuation


The data needed to achieve the objectives of this effort consist of accurate and reliable measures of LA in outdoor air during ABS activities at different locations. The following sections identify key attributes of the data needed for this effort.

3.3.1 Sampling Locations

The ABS sampling for OU7 is designed to characterize LA concentrations associated with outdoor ABS activities and inhalation exposure pathways. The locations for these activities include: (1) residential locations involving yard work, gardening, and playing outdoors on an unpaved driveway; and (2) community wide locations involving driving, bicycling and various recreational activities around town.

3.3.2 Types of Air Samples

Experience at Troy and Libby sites demonstrated that, in general, air samples collected from the breathing zone of a person tend to have higher concentrations of LA than air samples collected by stationary monitors, especially if the person is engaged in an activity that disturbs an asbestos source such as contaminated soil. Because of this, this SAP will focus on the collection of air samples from the breathing zone during simulated soil-disturbing activities.

3.3.3 Target Analyte List

Each air sample that is collected must be analyzed for asbestos particles. Specific methods and counting rules are provided in Section 5. Analytical results will include the size (length, width) of each particle, along with mineral classification (LA, other amphibole, chrysotile).

3.3.4 Types of Soil Disturbances

The data gaps targeted during the ABS project are associated with six outdoor ABS scenarios. Although a wide variety of activities may result in outdoor disturbances of LA, it is not feasible to evaluate every type of disturbance. The scenarios are considered realistic and representative examples of outdoor LA disturbances in OU7.

1. Yard work in residential yards

2. Gardening in residential gardens

3. Bicycling and playing on unpaved driveways

4. Driving on paved and unpaved roads and alleys

5. Bicycling on paved and unpaved roads, alleys, and trails

6. Recreational activities at parks and school yards


3.3.5 Soil Condition Data

It is expected that the amount of dust (and asbestos) released from an ABS event may depend in part on the condition of the soil at the time of the ABS event. To help characterize this source of variability, and potentially allow for some degree of normalization between locations, the following data items are needed for each ABS test area:

Nature and extent of soil vegetative cover (documented in field notes and photographs)

Soil moisture content

Soil texture (visual and hand texture estimation)

3.4 STEP 4 – DEFINE THE BOUNDARIES OF THE STUDY

This step specifies the spatial and temporal boundaries of the ABS.

3.4.1 Spatial Bounds

The spatial bounds of this study are restricted to selected properties and community areas located within OU7 of the Libby Superfund Site. OU7 includes most of the current residential, public, and commercial properties in the community of Troy and surrounding vicinity.

3.4.2 Temporal Bounds

Estimation of human health risk from exposure to LA in outdoor air following a series of active outdoor soil disturbances is based on the average concentration that occurs across the series of disturbances. Because the level of LA in outdoor ABS air samples may depend on factors that vary seasonally (disturbance patterns, soil moisture, wind speed, humidity, etc.), the data set needed for this effort should ideally consist of multiple samples from each area spanning a range of time and meteorological conditions. This will help ensure that reliable estimates of the long-term average concentrations may be computed from the individual short-term measurements. The exact dates of ABS field events are not important and may be selected at random (since the goal is to capture temporal variability). For samples collected in the late spring and late summer of 2011, ABS efforts should not occur if rainfall has exceeded 1/4-inch in the past 36 hours. Samples should be collected under conditions when the soil is relatively dry (less than 1/4-inch of rain within the past 36 hours), and a soil moisture content of less than 30% average or 50% maximum to help ensure that the data are not biased low.

Home owners will be asked to not water or irrigate the portion of the property where ABS will be occurring for 36 hours before sample collection. During days when outdoor ABS activities are scheduled, meteorological (MET) weather station data will be downloaded from the weather station located at the DEQ Information Office in Troy to calculate the total rain accumulation.


3.5 STEP 5 – DEVELOP DECISION RULES

This step describes the method to determine whether the data collected indicate acceptance and the resulting decision applied when acceptance is not obtained. The principal study questions, inputs to resolve study questions, action levels, and decision rules are summarized in Table 3-3.

The decision rule for evaluating residual risks from disturbance of outdoor soils at post-removal properties is:

If the level of risk to humans from exposure to ABS outdoor air at a post-removal location, or location that did not meet the exterior removal criteria, when combined with the level of risk which applies to the same individuals from other applicable exposure pathways, does not exceed a cancer risk of 1E-04 or a non-cancer Hazard Quotient (HQ) of 1.0, then risks at that location will be considered acceptable. If the total risk exceeds a cancer risk of 1E-04 or an HQ of 1.0, then the feasibility of further reducing exposure from either the outdoor soil disturbance pathway or the other applicable exposure pathways at that location shall be assessed.

EPA has not developed a quantitative procedure for evaluating non-cancer risks, but has developed a method for quantification of cancer risk (IRIS 2007).

The basic equation is:

Risk(i) = C(i) · TWF(i) · UR(i)

where:

Risk(i) = Risk of dying from a cancer that results as a consequence of exposure from specified exposure scenario “i”

C(i) = Average concentration of asbestos fibers in air in units of fibers per cubic centimeter (f/cc) during exposure scenario “i”

UR (i) = Unit Risk (f/cc)-1 that is appropriate for exposure scenario “i”

TWF(i) = Time weighting factor for exposure scenario “i”. This factor accounts for less than-continuous exposure during the exposure interval.

Because each person can be exposed to more than one source, the total cancer risk is calculated by summing the risks from each exposure pathway that applies:

Total risk = ∑ Risk(i)


TABLE 3-3

DECISION RULES

Principal Study Question Input to Resolve

Question Input Requirements Action Level Decision Rule

Is the current strategy for removal actions of outdoor soil in OU7 adequate to provide health protection from exposures that occur when residents disturb the soil? If not, what characteristics of the soil (e.g., presence of visible vermiculite or PLM-VE result) can be used to identify areas that require further removal actions?

Air samples in the breathing zone

ISO TEM Method 10312, also known as ISO 10312:1995(E) (CDM 2003b)

To be determined If air sample results from the breathing zone exceed a specified level (yet to be determined) and visual vermiculite remains on the property, additional removal action will be required. If air sample results from the breathing zone exceed a specified level (yet to be determined) and soil exceeding 0.2% LA remains on the property, additional removal action will be required.

Visual Inspection CDM-LIBBY-06 for Visual Analysis

Detectable quantities of visible vermiculite as defined in CDM-LIBBY-06

Soil Sampling

Laboratory Analysis by PLM-VE and PLM-Grav with project-specific modifications Reported Result: % LA AS: 0.2% LA

Any detectable LA in laboratory samples

At properties that underwent TAPE inspections and did not meet the removal criteria, was this decision adequate to provide health protection from exposures that occur when residents disturb the soil? If not, what characteristics of the soil (e.g., presence of visible vermiculite or PLM-VE result) can be used to identify areas that require further removal actions?

Air samples in the breathing zone

ISO TEM Method 10312, also known as ISO 10312:1995(E) (CDM 2003b)

To be determined If air sample results from the breathing zone exceed a specified level (yet to be determined) and visual vermiculite remains on the property, additional removal action will be required. If air sample results from the breathing zone exceed a specified level (yet to be determined) and soil exceeding 0.2% LA remains on the property, additional removal action will be required.

Visual Inspection CDM-LIBBY-06 for Visual Analysis

Detectable quantities of visible vermiculite as defined in CDM-LIBBY-06

Soil Sampling

Laboratory Analysis by PLM-VE and PLM-Grav with project-specific modifications Reported Result: % LA AS: 0.2% LA

Any detectable LA in laboratory samples

Notes: AS Analytical sensitivity ISO International Organization for Standardization LA Libby Amphibole % Percent PLM-VE Polarized Light Microscopy, Visual Estimation PLM-Grav Polarized Light Microscopy, Gravimetric TAPE Troy Asbestos Property Evaluation


This document is focused on methods for collecting data on the concentration of asbestos that occurs in the breathing zone of people who are engaged in activities that disturb outdoor soil. These data will be used to evaluate the risk from the soil-disturbance pathway. This risk estimate will be combined with risk estimates for other pathways to estimate total exposure. Because of limitations in the current methods for assessing risks from asbestos, all decisions regarding residual risk levels are considered interim and may be revisited as new methods and data become available.

3.6 STEP 6 – SPECIFY TOLERABLE LIMITS ON DECISION ERRORS

This step specifies the tolerable limits on decision errors, used to establish performance goals for the data collection design.

In making decisions about the long-term average concentration of LA in ABS outdoor air and the level of health risk associated with that exposure, two types of decision errors are possible:

A false negative decision error would occur if a risk manager decides that exposure to ABS outdoor air is not of significant health concern when in fact it is of concern.

A false positive decision error would occur if a risk manager decides that exposure to ABS outdoor air is above a level of concern when in fact it is not.

EPA and DEQ are most concerned about guarding against the occurrence of false negative decision errors because this error type may leave humans exposed to unacceptable levels of LA in outdoor air.

For this reason, it is anticipated that decisions regarding this pathway will be based not only on the best estimate of the long term average concentration, but will also consider the 95 percent upper confidence limit (UCL) of the long-term average concentration. Use of the UCL to estimate exposure and risk helps account for limitations in the data, and provides a margin of safety in the risk calculations, ensuring that risk estimates are unlikely to be too low.

EPA and DEQ are also concerned with the probability of making false positive decision errors. Although this type of decision error does not result in unacceptable human exposure, it may cause unnecessary expenditure of resources. For this effort, the strategy for controlling false positive errors is to set a goal that, if the exposure estimate based on the 95 percent UCL is above EPA’s level of concern for this pathway, then the UCL is not larger than three times the best estimate of the mean. If the 95 percent UCL is at or above the range of potential concern, and the UCL is greater than three times the best estimate of the mean, then it will be concluded that there is a substantial probability of a false positive decision error and that more data may be needed to strengthen decision-making.


For completing all seven steps of the DQO process, the null hypotheses and consequences of making an incorrect decision are summarized in Table 3-4. The gray region and tolerable limits on decision errors are not proposed because they are not applicable in this case.

3.7 STEP 7 – OPTIMIZE THE INVESTIGATION DESIGN

This step identifies a resource-effective data collection design for generating data to satisfy the DQOs. The data collection design is described in detail in the remaining sections of this SAP and other site documents referenced in Section 4.0.


TABLE 3-4

LIMITS ON DECISION ERRORS

Principal Study Question Null Hypothesis Type I Error

Will Result in: Type II Error Will Result in:

Is the current strategy for removal actions of outdoor soil in OU7 adequate to provide health protection from exposures that occur when residents disturb the soil? If not, what characteristics of the soil (e.g., presence of visible vermiculite and PLM-VE result) can be used to identify areas that require further removal actions?

Disturbance of soil at post removal properties exceeds a specified level Surface soils contain LA that can become airborne when disturbed

Determining that ABS air samples do not exceed a specified level when airborne LA actually does exceed this level would lead to an increased risk to human health. Determining that surface soils do not contain visible vermiculite or LA when they actually do. The LA-containing soils would not be included in additional removal action and in turn cause an increased risk to human health.

Determining that ABS outdoor air samples do exceed a specified level when airborne LA does not exceed this level would lead to unnecessarily performing additional removal action or inefficiency during removal that adds to removal costs. Determining that surface soils contain visible vermiculite or LA when they do not, overestimating the amount of LA-containing soils present, or incorrectly reporting the location of LA-containing soils. This would result in unnecessarily including an exterior excavation removal action, overestimating the amount of LA-containing soils present, or incorrectly reporting the location of LA-containing soils and adds unnecessary costs or inefficiency to the removal.

At properties that underwent TAPE inspections and did not meet the removal criteria, was this decision adequate to provide health protection from exposures that occur when residents disturb the soil? If not, what characteristics of the soil (e.g., presence of visible vermiculite and PLM-VE result) can be used to identify areas that require further removal actions?

Disturbance of soil at post removal properties exceeds a specified level Surface soils contain LA that can become airborne when disturbed

Determining that ABS air samples do not exceed a specified level when airborne LA actually does exceed this level would lead to an increased risk to human health. Determining that surface soils do not contain visible vermiculite or LA when they actually do. The LA-containing soils would continue to not be included in a removal action and in turn cause an increased risk to human health.

Determining that ABS outdoor air samples do exceed a specified level when airborne LA does not exceed this level would lead to unnecessarily performing initial removal action or inefficiency during removal that adds to removal costs. Determining that surface soils contain visible vermiculite or LA when they do not, overestimating the amount of LA-containing soils present, or incorrectly reporting the location of LA-containing soils. This would result in unnecessarily including an exterior excavation removal action, overestimating the amount of LA-containing soils present, or incorrectly reporting the location of LA-containing soils and adds unnecessary costs or inefficiency to the removal.

Notes: ABS Activity-based sampling LA Libby Amphibole PLM-VE Polarized Light Microscopy, Visual Estimation TAPE Troy Asbestos Property Evaluation


4.0 SAMPLING PROGRAM

This section summarizes the ABS scenarios developed for incorporation into the HHRA and field activities to be performed in support of the ABS program in OU7. This section also provides brief summaries of SOPs, including project-specific modifications and project-specific details not discussed in the SOPs.

The site-specific HASP and addendum (Appendix A) should be consulted to determine health and safety protocols for performing ABS work. Field forms and project-specific SOPs are included in Appendices B and C, respectively.

All sampling activities will be performed in accordance with this SAP. The SOPs and project-specific procedures to be employed are outlined in the following documents:

2009 Ambient Air WP for OU7

2010 Remedial Design Investigation WP for OU7

CDM-LIBBY-05, Revision 3, Soil Sample Collection at Residential and Commercial Properties

CDM-LIBBY-06, Revision 1, Semi-Quantitative Visual Estimation of Vermiculite in Soils at Residential and Commercial Properties

The following sections summarize field activities to be performed during the implementation of the sampling efforts described in this SAP.

Analytical methods for all samples collected in accordance with this SAP are discussed in detail in Section 5.0.

4.1 ABS SCENARIOS

The following sections provide a general summary of the six ABS scenarios to be evaluated under this SAP. Additional information related to receptors, duration of sampling, number of samples, and temporal considerations is also presented. Specific ABS details are provided beginning in Section 4.2. Table 4-1 provides a summary of the six ABS scenarios and sampling requirements.

4.1.1 ABS Scenario 1: Yard Work in Residential Yards

This scenario assumes three disturbance activities of residential yard soil that are considered realistic examples of relatively vigorous (high-end) disturbances:

Raking the lawn or yard with a metal-tined leaf rake

Digging in the soil with a shovel

Mowing the yard with a gasoline-powered rotary lawn mower


No. Description

Removal Not Required

10 1 2 20

Removal Completed

10 1 2 20


10 1 2 20

Removal Completed

10 1 2 20


10 1 2 20

Removal Completed

10 1 2 20

4 DrivingPaved and Unpaved Roads and Alleys

NA Driver/Passenger AdultBreathing Zone for

AdultDriving 60 Min (100%) 1 10 2 20

Adult, Teenager, Non-

Infant Child

Breathing Zone for Adult

Bicycling 60 Min (100%) 1 10 2 20

InfantBreathing Zone for

InfantPassenger in Bicycle

Trailer60 Min (100%) 1 10 2 20

Adult, Teenager Breathing Zone for

AdultRecreational Sports,

Ball Field Use60 Min (100%) 2 5 2 20

ChildBreathing Zone for

ChildPlayground Use 60 Min (100%) 2 5 2 20

Notes:

(a) One event for the wet spring season and one event for the dry late summer/early fall season are recommended.

ABS Activity-based samplingMin MinutesNA Not applicableNo. Number

5 BicyclingPaved and Unpaved

Roads, Alleys, and TrailsNA Recreational User

60 Mins Total Time of Combined Activities:

30 Min Biking (50%) +30 Min Digging/Playing (50%)

Breathing Zone for Child

Raking, Digging, Mowing

Digging (Trowel), Rototilling

Bicycling, Digging/Playing

3

Adult

Adult

Child

Resident, Outdoor Maintenance

Worker

ResidentBicycling and

PlayingResidential Unpaved

Driveway

6Recreational

ActivitiesParks and School Yards NA Recreational User

Table 4-1

Exposure Scenarios, Locations, Activities, and Number of Samples for Outdoor Activity-Based Sampling at OU7

1

2




21 Min Raking (35%) +18 Min Digging (30%) +21 Min Mowing (35%)


45 Min Digging (75%) +15 Min Rototilling (25%)

ABS Scenario

Yard Work

Gardening

Residential Yard

Residential Garden

Location Soil Category Receptor

Events per

Location (a)

Resident, Outdoor Maintenance

Worker

Total Samples per Scenario, Soil Category, and Age Group

Samples per

LocationAge

Group Sample Height Activity Activity Time

Locations per Scenario and Category

Activity-Based Sampling, SAP 20 OU7 – Libby Asbestos Superfund Site

Because risk is related to long-term average exposure across all of these activities, composite ABS samples will be collected across all three types of disturbance activities.

Property Categories – To complete this evaluation, collection of outdoor ABS Scenario 1 samples is needed from the following property categories:

Property Category A: Residential properties for which removal of soil in yards is not required

Property Category B: Residential properties for which removal of soil in yards is complete

There are some parcels where soil removal is needed but has not been completed. These parcels are not included for outdoor ABS because they will be characterized by Property Category B following removals.

The following presents the actor scripts for completion of ABS sampling for each of the three yard work scenarios:

Raking

The raking activity will be conducted at each area for a period of 21 minutes. During raking, one actor will use a metal leaf rake that is approximately 20 to 28 inches wide to disturb the top half inch of soil with an aggressive raking motion. Raking will occur in an arched motion raking from the left of the actor to the right, while raking the debris inward. Because it will not be possible in some cases to rake the entire area within the sampling period, there will be four intervals of 4 minutes to represent the larger activity area and the remaining 5 minutes of the sampling period are allocated for walking from one raking location to another. The actor will strive to equalize the time spent facing each of the four compass directions while raking and moving to new locations. The actor will pick up all debris piles created as part of the raking activity, and place them in plastic or poly bags for disposal in the regular waste stream. If visual vermiculite is identified during sampling activities, debris will be placed in asbestos-containing material (ACM) disposal bags and disposed of as ACM.

Digging

The digging activity will be conducted for 18 minutes at two locations within each area. The two locations will not overlap with the digging locations selected for other sampling events. The actor will use a long-handled shovel to remove soil from a 2- by 2-foot area to a depth of 6 inches below ground surface (bgs). The soil will temporarily be staged on a tarp adjacent to the digging site. Once the hole has been started, the actor will kneel down and continue digging with a trowel to a depth of 12 inches bgs. After the target depth is reached, the soil will be returned to the hole and tamped down with the shovel. The actor will rotate throughout the activity to face different compass directions at each digging location. The digging locations will be restored to original conditions (leveled and replanted as necessary) after sampling.


Mowing

The mowing activity will be conducted at each area for a period of 21 minutes. During mowing, one actor will operate a gas-powered walk-behind lawn mower (bagless, side discharge, 3- to 5-horsepower mower). The actor will adjust the height of the blade to approximately 2 to 2.5 inches above the ground surface. The actor will mow in straight lines, covering as much of the property’s yard as possible within the allotted timeframe. Only the high traffic yard areas of the property will be utilized during this scenario (i.e., no activity in limited-use areas). If the entire yard cannot be mowed within the allotted timeframe, the actor will mow sections of the yard evenly distributed throughout the property.

Receptors and Age Groups – Adult residents and groundskeepers are the most likely receptors and age group for this scenario, so, samples will be collected at the adult breathing height. Although teenagers may also participate in yard work, the breathing height of teenagers does not differ enough from that of adults to warrant collection of additional samples for teenager breathing height.

Duration of Sampling – One hour of sampling will be completed: 21 minutes of raking, 18 minutes of digging, and 21 minutes of mowing will be collected on a single filter cartridge.

Number of Samples – A minimum of 10 residential yard work samples for each of the two property categories will be collected. When temporal factors are considered, a minimum of 10 sample locations will result in 20 samples for each property category. Twenty to 30 samples were identified as the target number of samples for each ABS scenario in the OU4 SAP for collection of supplemental ABS data for OU4 (CDM 2010). Evaluation of the TAPE and RDI results for OU7 indicates that identification and inclusion of 10 parcels for Property Category A is likely. Identification and inclusion of 10 parcels for Property Category B is probable, but this sampling objective may not be achieved because a limited number of parcels (31) have had exterior removals.

Temporal Considerations – Seasonal variables, such as soil moisture, and atmospheric humidity, may influence LA levels from soil disturbance (EPA 2007, CDM 2010). The majority of exposures to LA from soil disturbance are likely to occur from late spring to early fall, when there is no snow cover or frozen ground. To account for seasonal factors and to provide ABS samples representative of potential exposures over multiple seasons, two sampling events will be conducted: one for the wet spring season and one for the dry late summer or early fall season.


4.1.2 ABS Scenario 2: Gardening in Residential Gardens

This scenario assumes two disturbance activities of residential garden soil that are considered realistic examples of relatively vigorous (high-end) disturbances:

Rototilling

Digging with a trowel


Property Category A: Residential properties for which removal of soil in gardens is not required

Property Category B: Residential properties for which removal of soil in gardens is complete

The following presents the actor scripts for completion of ABS sampling for both of the gardening scenarios.

Rototilling

The machine tilling activity will be conducted at each garden area for a period of 15 minutes. The actor will operate a walk-behind engine powered tiller (rototiller) to disturb the soil to a depth of 6 inches bgs. The actor will rototill in straight lines and cover the entire garden.

Digging (Trowel)

The digging activity will be conducted at each garden area for a period of 45 minutes. The actor will utilize hand tools (e.g., trowel, cultivator, soil rake, hands) to disturb the soil to a depth of 12 inches bgs. Soil will be moved to an area immediately adjacent to the digging site, and returned to its original location upon completion. This activity should be completed over approximately 5 minutes. The actor will repeat this activity until nine discrete locations within the garden are sampled. Locations shall be distributed evenly throughout the entire garden.

Similar to ABS Scenario 1, because risk is related to the long-term average exposure across both of these activities, composite ABS samples that include both types of disturbance activities will be collected. One hour of sampling will be completed: 45 minutes of digging and 15 minutes of rototilling will be collected on a single filter cartridge.


4.1.3 ABS Scenario 3: Bicycling and Playing on Unpaved Residential Driveways

This scenario assumes that a child bicycling and playing on an unpaved driveway may disturb the soil. Activities for this scenario include bicycling and digging.


Property Category A: Residential properties for which removal of soil in unpaved driveways is not required

Property Category B: Residential properties for which removal of soil in unpaved driveways is complete

The actor scripts for completion of ABS sampling for child playing in driveway scenarios are provide below.

Child Biking

The child biking activity will be conducted at each selected driveway for a period of 30 minutes. The actor will operate a small non-motorized vehicle (e.g., bicycle or tricycle) with minimal ground clearance. The actor will maneuver the vehicle across the driveway in straight lines covering the entire area of the driveway. This will be repeated for the duration of the time interval. All samples will be collected from the right shoulder of the actor.

Child Digging

The child digging activity will be conducted at each selected driveway for a period of 30 minutes. The actor will sit on ground while digging or scraping the top 2 to 6 inches of the soil, pushing soil and rock to the side, and then replacing it. This activity should be completed over approximately 5 minutes. The actor will then repeat this activity until six discrete locations in the driveway have been sampled. Locations shall be distributed evenly throughout the entire driveway.

Similar to ABS Scenario 1, because risk is related to long-term average exposure across bicycling and playing activities, composite ABS samples will be collected. A residential child is the primary receptor and age group for this scenario, so, samples will be collected at the child breathing height.

4.1.4 ABS Scenario 4: Driving on Paved and Unpaved Roads and Alleys

This scenario assumes that driving in a car on roads and alleys in OU7 (City of Troy and surrounding area) may result in exposure to LA from disturbing road surfaces. Because roads and alleys in OU7 include both paved and unpaved surfaces, composite ABS air samples will be collected to represent a combined exposure scenario across the variety of road surfaces. Property


categories are not applicable to this scenario. The following presents the actor script for completion of ABS sampling for the driving scenarios.

Driving Paved/Unpaved Roads

The driving activity will be conducted for a period of 60 minutes. The actor will drive a full size automobile (car or truck) within the OU7 boundary shown on Figure 2-1. The actor will ensure that both paved roads and unpaved roads and alleys are traveled during this time interval and that travel is evenly distributed throughout the bounded area. The actor will maintain a reasonable speed during the activity and attempt to drive at or near the legal speed limit. During sampling, the front two windows of the vehicle will be fully open, and the back two windows will be open approximately 1 inch. All samples will be collected from the right shoulder of the actor. It will not be possible to travel every road within the bounded area during the sampling period or to replicate the exact path traveled during each of the subsequent sampling events. Therefore, all specific driving routes will be documented. This will be accomplished by utilizing a portable GPS unit that records the route. The actor will set the GPS unit to record the route prior to the start of the activity.

The driving activity will be conducted on pavement or gravel roads free of rainwater runoff. Driving will not be conducted immediately following rainfall sufficient to create surface runoff. Sufficient time to allow for drying of roadways will occur prior to initiating the driving scenario. The driving scenario will be stopped if, during the sampling event, rainfall sufficient to cause surface runoff occurs.

Receptors and Age Groups – Adults (drivers and passengers) are the most frequent receptor and age group for this scenario based on length of exposure time and duration. Samples will be collected at the breathing height for an adult while seated in a vehicle. Although children and teenagers are also potential receptors for this scenario, the difference in breathing height between adults, children, and teenagers in a motor vehicle is not consider substantial enough to warrant additional samples.

Duration of Sampling – One hour of sampling will be completed; this amount of time is considered sufficient for driving once along most roads in OU7 and multiple times along commonly traveled roads in OU7.

Number of Samples – For the driving scenario, a sample collected over one hour of driving across multiple roads in OU7 is considered one sample. When coupled with recommendations for temporal factors, 10 sampling iterations will be completed to achieve the target number of samples.


Temporal Considerations – Similar to sampling recommended for residential ABS scenarios, two sampling events will be conducted: one for the wet spring season and one for the dry late summer or early fall season. This will result in a total of 20 ABS samples collected for the driving scenario.

4.1.5 ABS Scenario 5: Bicycling on Paved and Unpaved Roads, Alleys, and Trails

This scenario is based on riding bicycles on roads, alleys, and trails in OU7 (City of Troy and surrounding area), and assumes that soil disturbances associated with this activity will be at the high-end of the range of possible exposures when compared to other recreational activities such as walking or running. Similar to ABS Scenario 4, because roads, alleys, and trails in OU7 include both paved and unpaved surfaces, composite ABS samples will be collected so that samples represent a composite exposure scenario across the variety of road surfaces. Property categories are not applicable to this scenario. The following presents the actor scripts for completion of ABS sampling for the bicycling scenarios.

Bicycling

The biking activity will be conducted for a period of 60 minutes. Each actor will be assigned a non-motorized, 2-wheeled bicycle equipped for use on non-paved roads. In addition, a bicycle trailer, built to transport a 50-pound child, will be attached to the back of one of the bicycles and a personal air monitor will be mounted inside the trailer. For each predetermined route of paved and unpaved roads and trails, a pair of two riders, with air samplers mounted to the bicycle and the monitoring cassette affixed in the breathing zone, will travel in single file along the bicycle path. The cyclists will ride the entire route repeatedly for 60 minutes. The distance between the riders will be based on visibility, terrain, and safety considerations. Riders will alternate positions (lead and trailing) throughout the scenario. Trailing riders will ride in the dust cloud of the rider in front as much as is safe and practical. During these events, the bicycle riders will vary their speed between 3 and 15 miles per hour (mph). Riders will strive for an average speed of 8 mph. The average speed is a target speed only; bicycle speeds will be adjusted to meet path conditions. It will not be possible to travel every road within the bounded area during the sampling period or to replicate the exact path traveled during each of the subsequent sampling events. Therefore, all specific driving routes will be documented. This will be accomplished by utilizing a portable GPS unit that records the route. The actor will set the GPS unit to record the route prior to the start of the activity.

The bicycling activity will be conducted on pavement or gravel roads free of rainwater runoff. Bicycling will not be conducted immediately following rainfall sufficient to create surface runoff. Sufficient time to allow for drying of roadways will occur prior to initiating the bicycling scenario. The bicycling scenario will be stopped if, during the sampling event, rainfall sufficient to cause surface runoff occurs.


Receptors and Age Groups – Adults, teens, and children are all likely receptors in this scenario. The breathing height of very young children (infants), who are passengers in a bicycle trailer, is substantially closer to the ground than that of an adult, teenager, or non-infant child. To evaluate the effect breathing height has on exposure to LA; samples will be collected at two breathing heights for this scenario: breathing height for an adult while seated on a bicycle, and breathing height for an infant passenger in a bicycle trailer. Although the breathing height for teenagers and non-infant children seated on a bicycle differs from adults, the difference is not considered substantial enough to warrant additional samples for breathing height.

Duration of Sampling – One hour of sampling will be conducted; this amount of time is considered sufficient for bicycling along commonly used roads, alleys, and trails in OU7.

Number of Samples – For the bicycling scenario, a sample collected over one hour of bicycling is considered one sample. Ten sampling iterations will be conducted to achieve the target number of ABS samples for each of the adult and child receptor categories.

Temporal Considerations – Similar to sampling recommended for residential ABS scenarios, two sampling events will be conducted: one for the wet spring season and one for the dry late summer or early fall season. When coupled with temporal factors, a total of 20 ABS samples will be collected for each of the adult and child receptor categories,

4.1.6 ABS Scenario 6: Recreational Activities at Parks and School Yards

This scenario is based on recreational activities in playgrounds and ball fields at parks and school yards. Recreational activities at playgrounds may include playing on playground equipment such as swing sets, merry-go-rounds, jungle-gyms, and see-saws; and digging in sand boxes. These activities are most likely to occur at the Troy elementary school and at Roosevelt Park (Figure 4-1). Recreational activities at the ball fields and parks may include baseball, football, soccer, and Frisbee golf, and are mostly likely to occur at the Troy junior and senior high schools, Roosevelt Park, and the Timber Beast Disk Golf Course (Figure 4-1). Soil disturbances associated with these activities are assumed to be at the high-end of the range of possible exposures when compared to other recreational activities. Composite ABS samples representing a variety of playground activities will be collected to represent a combined playground exposure scenario. Separate composite ABS samples to represent a variety of ball field activities will also be collected for a combined recreational field exposure. Property categories are not applicable to this scenario.

Receptors and Age Groups – Adults, teenagers, and children are all likely receptors in this scenario. Recreational activities for adults and teenagers are more likely to occur at ball fields, while recreational activities for children are more likely to occur at playgrounds. The child breathing height will be used for playground activity samples because these activities involve sitting on or near the ground. The adult breathing height will be used for sampling ball field


activities. To evaluate the effect of recreational location and breathing height on exposure to LA, separate samples will be collected from playgrounds and ball fields.

Duration of Sampling – One hour of sampling will be conducted for adult and teenagers sports at ball fields and for child activities at a playground.

Number of Samples – For the recreational scenario, a sample collected over one hour is considered one sample. Ten sampling iterations will be conducted to achieve the target number of ABS samples for the children playground receptor and 10 samples will be collected for the adult playground and ball field receptor categories.

Temporal Considerations – Similar to sampling for residential ABS scenarios, two sampling events will be completed: one for the wet spring season and one for the dry late summer or early fall season. When coupled with temporal factors a total of 20 ABS samples will be collected for each of the playground and ball field receptor categories,

4.2 PRE-SAMPLING ACTIVITIES

Prior to beginning of field activities, a field kickoff meeting will be conducted, required training will be performed, and appropriate site specific instructions will be provided to the field team.

4.2.1 Field Planning and Required Equipment and Supplies

Before field crews mobilize, Tetra Tech will prepare detailed property maps identifying the OU7 properties to be included. Maps will be reviewed to examine recommended routes for the biking and driving ABS scenarios. The ABS activities schedule will be refined as Tetra Tech schedules the inspections at dates and times convenient to the property owners.

The Tetra Tech field manager will conduct an inventory of project-procured equipment and supplies prior to field work and obtain any additional required equipment or supplies. The following equipment is required for sampling activities conducted under this SAP:

Field logbooks Indelible ink pens Digital camera with memory card Sample paperwork and sample tags and labels Custody seals Plastic zip-top bags Soil sampling equipment Personal protective equipment (PPE) as required by site-specific HASP (Appendix A) Geo XT Personal Digital Assistant (PDA) Personal air sampling pumps (2 liter/min, 4 liter/min, and 10 liter/min)

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W.F. MORRISONELEMENTARY SCHOOL

TROY TIMBER BEASTDISK GOLF COURSE

TROY JUNIOR ANDSENIOR HIGH SCHOOLS

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LINCOLN

COUNTYLOCATION OFLARGER MAP

GIS map by Ed Madej TTEMI-HEFIG4-1_OU7_RECREATIONAL_ACTIVITIES_041911.mxd

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FIGURE 4-1LIBBY ASBESTOS SITE - OPERABLE UNIT 7ABS RECREATIONAL ACTIVITY SCENARIO

SAMPLING AREAS

ABS Sampling and Analysis PlanLegendOU7 BOUNDARYPARKS, PLAYGROUNDS,AND PUBLIC AREAS


Sample filter cassettes (0.8micrometers [µm]) Rotometer Field moisture meters Activity-specific equipment: rakes, shovels, tarps, lawn mowers, rototillers, bicycles,

bicycle trailers Location-specific air photos and site diagrams Standard hand tools (screwdrivers, hammer, pry-bar, etc.) Measuring wheel or tape

4.2.2 Identify Sampling Locations

Prior to the start of field activities, potential residential use area sampling locations for Scenarios 1, 2, and 3 will be identified through a query of the OU7 database using requirements identified in Table 4-1. To the extent possible, the residential locations for Scenarios 1, 2, and 3 will be selected to provide a represented distribution across OU7. Individual properties may be used for a combination of Scenarios 1, 2, and 3. Once the use areas are identified, property owner coordination efforts will begin. The property owner of each selected sampling location will be contacted to determine willingness to participate prior to the start of ABS collection. This process will continue until the desired number of sampling locations have been identified. Property-specific information will be collected for each sampling location and recorded on the OU7 ABS Field Form (Appendix C).

4.3 ACTIVITY-BASED SAMPLING INVESTIGATION

This section describes the sampling methods and procedures used to complete ABS activities to evaluate OU7 removal decisions and to capture additional information in support of the OU7 HHRA. Residential ABS will be conducted at two general property categories: (1) properties that have had a TAPE or RDI inspection and subsequently undergone exterior removal, and (2) properties that have had a TAPE inspection but were not designated for exterior removal. Recreational ABS will be conducted on paved and unpaved roads and alleys and in parks and is independent of removal or non-removal categories.

During the ABS, Tetra Tech will conduct the following field activities:

ABS sampling scheduling

Soil sample collection

Visual inspection

Pump calibration

Air sample collection

Health and safety air monitoring

ABS activities documentation


4.3.1 Scheduling ABS Visits

Prior to mobilization to each property where signed access agreements have been obtained, each property owner or tenant will be contacted by phone to determine a specific time for conducting ABS activities on their property. The ABS will be scheduled for a time convenient for the property owner or tenant. In general, it will not be necessary for the property owner or tenant to be present during the outdoor ABS activities. However, if the property owner or tenant needs to be present to allow access or requires their presence during sampling activities, arrangements will be made to accommodate their schedule.

4.3.2 Soil Sample Collection

Two (side by side) 30-point composite soil samples will be collected from 0-1 inch and 0-6 inch depths at each scenario area during each of the two sampling events associated with residential Scenarios 1, 2, and 3. Soil samples will not be collected from gravel alleys or unpaved roads that will be used during recreational Scenarios 4 and 5 or grass or dirt playing fields used for Scenario 6. To represent scenario areas that span an entire yard, composite locations will be collected from the entire yard regardless of previous sampling activities and results. At least five aliquots will be collected from the pre-selected locations where the digging activities will occur.

The list below outlines the areas where soil sampling is and is not anticipated:

Scenario 1: Yard Work – Entire use area*

Scenario 2: Gardening – Entire garden or flower bed

Scenario 3: Bicycling/Playing in Driveways – Entire driveway

Scenario 4: Driving on Paved/Unpaved Roads –No soil samples to be collected

Scenario 5: Biking on Paved/Unpaved Roads – No soil samples to be collected

Scenario 6: Recreational activities – No soil samples to be collected

* To include at least one aliquot from each pre-selected digging location

Soil samples will be collected and homogenized in accordance with the TAPE WP (Tetra Tech 2007). To ensure that sufficient sample material is available for potential future analysis, the mass of the composite sample should be about 2.5 kilograms. Composite points of each soil sample will be inspected for visible vermiculite in accordance with the Site-specific SOP CDM-LIBBY-06, Revision 1 with the following modifications:

The entire use area to be used for ABS will be inspected for visual vermiculite regardless of previous investigation results or removal activities.

The approximate location and level of any visible vermiculite will be documented on a field sketch that details the location of each scenario area. When available, land surveys will be used as the baseline for these sketches. If a survey is not available, an aerial photo may be used. Soil sampling and vermiculite observations will occur during each sampling event.


Field technicians will document square footage of each use area where ABS air and soil samples are collected.

Field technicians will document the predominant type of ground cover indentified at each use area where air and soil samples are collected. Ground-cover options will include: (a) grass, (b) bare soil, (c) gravel and rock, (d) post removal grass, (e) post removal bare soil, (f) post removal gravel and rock (See Assessment of Vegetative Cover).

Field technicians will document a perimeter GPS outline of each use area where air and soil samples are collected.

In situ soil moisture will be measured at each sampling area using a soil moisture meter prior to collection of ABS air samples. For each area, soil moisture will be collected from a minimum of 10 locations between 0 and 3 inches below ground surface. ABS activities will not be performed if average volumetric water content (VWC) is greater than 30 percent, or if the VWC for any of the measurement points is greater than 50 percent. The soil moisture result for each area will be recorded in the field logbook. During days when ABS activities are occurring, MET data will be downloaded from the local weather station located at the Troy DEQ Information Center and will be archived in electronic format for future reference. The parameters recorded hourly at this station are:

Temperature (degrees F) Relative humidity (percent) Wind speed (mph) Wind gusts (mph) Wind direction Precipitation (inches)

Assessment of Soil Cover – Photograph Method

The extent of soil cover will be estimated for each sampling event and will be recorded on the field forms and in the field logbook using the following method:

Digital photographs will be used for a qualitative estimation of vegetative cover for use areas. Individual sample quadrats of known area will be photographed. The percent of each quadrat covered by vegetation or other materials will be determined by superimposing a grid frame of 25 equal sized squares onto the digital picture. The methods used will be as follows:

1. Three sample quadrats will be randomly located within the use area by tossing the quadrat to three areas from the central area of the use area. The percent soil cover for a use area will be the average of the three estimates.


2. The quadrat will be labeled according to the AD and use area numbers, location, date, and quadrat number (1, 2, or 3). The full quadrat label will be written on a board and placed at the top frame of each photograph.

3. A tripod and camera bar will be used to position the camera vertically over the center of the quadrat at approximately 4 feet above the surface. A camera bar consists of a 3 foot bar mounted on the top of the tripod with the camera mounted on one end and a counter-weight equivalent to the weight of the camera attached to the opposite end.

A digital camera with a zoom lens will be used to take each picture. The picture area will be zoomed in or out to have the quadrat frame encompass the majority of the viewing area. The quadrat label should be visible in each picture.

The digital photographs will be analyzed by:

1. Superimposing a grid onto the digital picture to align exactly with the quadrat to have 25 equal-sized squares.

2. Randomly selecting five grid squares from each of the three quadrats (total of 15) for soil cover evaluation. The number of evaluated grid squares covered by grass, bare soil, gravel or rock, post removal grass, post removal bare soil, post removal gravel or rock will be counted. Any grid square with greater than 50 percent of one of the above categories will be counted as that category. Grid squares with less than 50 percent of any category will be assigned the category most represented by materials or vegetation present.

3. Summarizing percent soil cover values for each quadrat and the average cover values calculated for each use area.

4.3.3 Visual Inspection

Visual inspection of soils will be completed in accordance with CDM-LIBBY-06. During ABS activities, visual soil inspections will be completed for residential Scenario 1, 2 and 3 properties and will be designated as either Property Category A – Yards/gardens/driveways where removal is not required, or Property Category B – Yards/gardens/driveways where removal is completed. The visual inspection will be completed only within the area planned to be used during ABS activities. All visual inspections will be completed in accordance with the Site-specific SOP CDM-LIBBY-06, Revision 1 (Semi-Quantitative Visual Estimation of Vermiculite in Soil [Appendix C]) with the following modifications:

The entire use area to be used for ABS will be inspected for visual vermiculite regardless of previous investigation results or removal activities.

The approximate location and level of any visible vermiculite will be documented on a field sketch that details the location of each scenario area.


Soil texture classes, the relative proportions of silt-, sand-, and clay-sized particles will be assigned at each sampling area for Scenarios 1, 2, and 3. Soil texture is an important property from which many other soil parameters can be estimated or inferred. Soil textures will be assigned in the field using the United States Department of Agriculture soil texture classification system as: (1) Sandy (including sand and loamy sand), (2) Silty (including silt, silt loam, and silty clay), (3) Loamy (including silt loam, loam, clay loam, and silty clay loam) or, (4) Clayey (including sandy clay, silty clay, and clay) based on guidance provided in EPA 1991.

No visual inspection of soils will be completed for Scenarios 4, 5, and 6 (driving, biking, parks and playgrounds) because there will be no soil sampling.

4.3.4 Pump Calibration

Each air sampling pump will be calibrated at the start of each day's sampling period using a primary calibration source. The primary calibration standard used is a Bios DryCal® DC-Lite. Calibration will be considered complete when ±5 percent of the desired flow rate is attained, as determined by three measurements with the calibrator using a cassette reserved for calibration (from the same lot of the sample cassettes to be used in the field). Pump flow rates will be verified at 60-minute intervals or when actors are relieved from an activity by a backup actor. Field calibrations, taken between the pre and post-calibrations may be taken using a rotometer that has been calibrated using a primary calibration source. If at any time the observed flow rates are ±10 percent of the target rate, the sampling pump should be re-calibrated, if possible. If at any time an air sampling pump is found to have faulted or the observed flow rates are 25 percent below (due to heavy particulate loading or a pump malfunction) or 50 percent above the target rate, the pump will be replaced or the activity will be terminated. Collection of air samples will continue, regardless of the amount of particulate loading on the filters, unless the flow rate is affected.

At the beginning of the sampling program, flow rates and particulate loading may be checked more frequently as conditions require, establishing expected conditions. For post-sampling calibration, three separate constant flow calibration readings will be obtained using the Bios DryCal® DC-Lite primary calibration source. The sampling cassette will remain inline during calibration and those flow readings will be averaged. If the flow rate changes by more than 5 percent during the sampling period, the average of the pre- and post-sampling rates will be used to calculate the total sample volume. Samples for which there is more than a 30 percent difference from initial calibration to end calibration will be invalidated. For invalidated samples the sample collector will record the pump serial number, sample number, initial flow rate, sample start and end times, sample locations, and final flow rate, and will mark the sample "void," in the field logbook and OU7 Activity-Based Sampling Form (OU7 ABS Form). These invalidated samples will not be submitted for analysis and will be properly disposed of. To prevent potential cross-contamination, each rotometer used for field calibration will be transported to and from each sampling location in a sealed zip-top plastic bag. The cap and


calibration cassette used at the end of the rotometer tubing will be replaced each morning after it is used.

4.3.5 Air Sample Collection

ABS air sampling will occur over a 1-hour time interval for all scenarios and will be repeated two times at each sample location (wet season and dry season). Each time interval will be subdivided by the number of representative activities as detailed in Table 4-1. ABS air samples will be collected by actors performing activities in accordance with the scenarios provided in Section 4.1. At each location selected for evaluation, one or two actors will engage in the prescribed activities in each of the scenario areas. Activities will be conducted in the order outlined in the scenarios (e.g., activities in the yard scenario will begin with raking, followed by digging, then finish with mowing). Individual residential properties may meet the requirements of more than one property category and therefore multiple scenarios may be completed at those properties. No more than one activity will be conducted at any given time on one property, or adjacent properties. If multiple scenarios are being conducted at one property, the order of activities will proceed from the area of least contamination first. All ABS air samples will be collected using cassettes that contain a 25 millimeter diameter mixed cellulose ester (MCE) filter with a pore size of 0.8 μm. During residential ABS Scenarios 1, 2, and 3, one participant will perform the scripted activities and will wear two different air sample pumps calibrated at two flow rates. The primary sample will be collected using battery-powered sampling pumps capable of operating at 4 liters per minute (L/min). The specific model selected for this sampling event is the Sensidyne Gilian BDXII personal Air Sampling Pump. The pump flow rate will be adjusted to 4 L/min to obtain sample volumes of at least 240 L. In addition, a battery-powered sampling pump capable of operating at 2 L/min will be used to generate a backup air sample in the event the primary sample is damaged or overloaded. The specific model selected for this sampling event is also the Sensidyne Gilian BDXII. The backup pump flow rate will be adjusted to 2 L/min, to obtain sample volumes of at least 120 L.

During Scenario 4, Driving on Paved and Unpaved Roads and Alleys, one actor will perform the activities and will also wear two air sampling pumps. The primary sample will be collected using a GAST #1531 pump adjusted to 10 L/min, while the backup sample will be collected using the same pump and 2 L/min flow rates as the backup samples for Scenarios 1, 2, and 3. Due to the duration of this activity, the sample volumes will be 600 L for the primary sample and 120 L for the backup sample.

During Scenario 5, Bicycling on Paved and Unpaved Roads, Alleys, and Trails, two actors on separate bicycles will don air monitors while performing the scripted activities, taking turns leading and following during the 1-hour of riding. The air samples will be collected using the same battery powered sampling pumps and flow rates (4L/min) as in Scenarios 1, 2, and 3. One bicycle will be fitted with a child carrier trailer. One primary sample will be collected from within the trailer (no occupant, pump only) using the Sensidyne Gilian BDXII battery-powered sampling pump adjusted to 4 L/minute, to obtain a sample volume of at least 240 L. The adult


air sampling pumps will be carried in backpacks worn by the actors and the trailer pump will be placed in the bike trailer with the intake attached to where an infant would be sitting.

During Scenario 6, Recreational Activities at Parks and School Yards, one actor will perform the scripted adult activities and another actor will perform the scripted child activities. Each actor will wear two personal air sample pumps calibrated at two flow rates, as explained for Scenarios 1, 2 and 3.

The monitoring cassette will be affixed to the shoulder of the actor performing adult scenario activities so that the cassette is within the proper breathing zone. The breathing zone can be visualized as a hemisphere approximately 6 to 9 inches around an individual's face. The monitoring cassette will be affixed to the mid chest of the participant performing child scenario activities so that the cassette is within the simulated breathing zone of a child. The top cover from the cowl extension on the sampling cassette will be removed (i.e., open-face) and the cassette will be oriented face down. The actors will monitor the cassettes throughout the scenario to ensure that they remain directed toward the activity and are free of obstructions. If it is necessary to relieve an actor in a scenario, a relief actor will be properly suited in time to make the exchange. When the relief actor is ready, the active actor will stop, remove the backpack, pass it to the relief actor, and assist with donning and adjusting the backpack. The exchange is anticipated to take less than 60 seconds, so the sampling pumps and event time clock will not be halted during the exchange. If the exchange requires more than 60 seconds, the pump and event clock will be stopped until the activity is re-initiated. If the personnel exchange coincides with scheduled flow rate verification, the total exchange time must not exceed 120 seconds.

4.3.6 Health and Safety Air Monitoring

As part of this investigation, personal air samples will be collected on the first three days of sampling for ongoing health and safety monitoring. The health and safety samples will be collected using an additional low volume sampling pump and are not intended for use in the ABS sampling or with the risk assessment. To differentiate these samples from the other air samples, "Phase contrast microscopy (PCM)” will be used in the Sample Location Description field of the OU7 ABS Form. These samples will be collected and analyzed in accordance with the 2011 OU7 HASP and will represent both the 8-hour time-weighted average (TWA) and 30-minute short-term exposure limit (STEL) for each employee work category. The permissible exposure limit (PEL) is 0.1 f/cc for the 8-hour TWA, and the STEL is 1.0 f/cc over a 30-minute period as specified in 29 CFR Part 1910.1001 (j)(2)(iii).

4.3.7 ABS Activities Documentation

The PDA, logbook, and associated sketch(es) will be completed for each property inspected as part of this SAP. Sample information and visual inspection results will be recorded on property sketches. If available, a property survey should be used as the baseline for these sketches. If a property survey is not available, aerial photos, scaled graph paper, or an equivalent will be used.


Sample information and visual inspection results may be combined on one sketch if quality and clarity can be maintained. Property sketches will include visual inspection locations and results, soil sampling locations and results, and the approximate location of the ABS scenario area(s). Locations used for the digging activity in Scenario 1 will be clearly noted on the property sketch. Although sketches are not expected to be scaled drawings, the ABS team will estimate the percentage of the entire yard used in each scenario.

4.4 FIELD QUALITY CONTROL SAMPLES

Field quality control (QC) samples will be collected in association with both air and soil samples. Field duplicate QC samples associated with soil samples will be collected at a frequency of one per 20 samples. QC samples associated with air samples will include lot blanks and field blanks. These are described below and summarized in Table 4-3.

4.4.1 Lot blanks (Air)

Before any air sampling cassette is used, a cassette from each filter lot will be randomly selected and submitted for analysis. The lot blanks will be analyzed for asbestos fibers by the same method used for field sample analysis. The entire batch of cassettes will be rejected if any asbestos fiber is detected on a lot blank.

TABLE 4-2

FIELD QUALITY CONTROL SAMPLES

Sample Type

Associated QC Sample

Collection Frequency

Analysis Frequency

Analysis Request

Acceptance Criteria

Air Lot Blank 1 per case

(50 cassettes) 100% TEM

ND for all asbestos fibers

Air Field Blank 1 per day 100% TEM ND for all

asbestos fibers

Soil Field

Duplicate 1 per 20 field

samples Hold Only1

PLM-VE/PLM-Grav

<30% RPD

Notes: % Percent

1 Field duplicate samples will be collected, but will be held for analysis as necessary. TEM Transmission Electron Microscopy PLM-VE Polarized light microscopy visual area estimation method PLM-grav Polarized light microscopy gravimetric estimation method RPD Relative percent difference ND Non detect

4.4.2 Field blanks (Air)

One field air blank will be collected each day for the duration of this sampling program. The field blanks will be analyzed for asbestos fibers by the same TEM method used for field sample analysis. The field blanks will be collected by opening the sample cassette package and exposing the cassette to the full range of field efforts including sample handling, car travel,


attaching to the air sample pump for ten seconds (not turned on), retrieving the sample cassette, returning to the office, packaging, and transporting to the laboratory.

4.4.3 Equipment Blanks (Soil)

Equipment blanks are currently not required by EPA for soil sampling at the Site because: (1) detection levels for LA using current PLM analytical methods are not low enough to capture concentrations that would be expected in equipment blanks, and (2) the frequency of detection for LA in historically-collected project equipment blanks is extremely low.

4.4.4 Field Duplicate Samples (Soil)

Field duplicate samples for ABS soil sampling activities will be collected at a rate of 1 per 20 field samples. Field duplicate samples will be collected from areas that are being sampled during one of the ABS activities discussed in the previous sections. Individual composite points for the duplicate sample will be collected from different locations (within the same use area) than the original sample. Field duplicate samples will be collected in accordance with the TAPE WP (Tetra Tech 2007). Field duplicate samples will not be immediately sent for analysis but will be held along with real field samples for future analysis as necessary.

4.5 GENERAL PROCESSES

This section describes the general field processes used to support the sampling described in this SAP and includes references to the general and project-specific SOPs where applicable.

4.5.1 Equipment Decontamination

Air monitoring pumps, tubing and calibration equipment will be wet wiped with moistened disposable paper towels before and after each ABS sampling event. Stainless steel scoops and bowls will be used for soil sampling and will be decontaminated after use. If a small metal shovel is required to assist with sampling to 6 inches in hard, compacted soils, the shovel will be thoroughly cleaned and decontaminated. Decontamination will occur at the location where the sample was collected and will include spraying the equipment with regular tap water followed by drying with paper towels. The water will be allowed to fall on the ground within the area just sampled and the paper towels will be placed in a labeled asbestos waste bag.

Visible soil on hands or clothing will be removed by washing with soap and water. Additional personnel decontamination procedures, including requirements for decontamination zones, are described in Section 10.1 of the TAPE HASP (Appendix A). Personal protective equipment (PPE) will include disposable gloves, disposable protective outerwear, work boots, disposable boot covers, and respirators. The respirators will be cleaned and decontaminated as discussed in Section 10.2.1 of the ABS HASP (Appendix A).


4.5.2 Investigation-Derived Waste

Investigation-derived waste will include used wet wipes, wet paper towels, disposable gloves, used respirator cartridges, used plastic tubing, disposable protective outerwear, plastic coverings, and other minimal waste. Because it is possible, but not likely, that these investigation-derived waste materials may contain some asbestos, all investigation-derived waste will be double-bagged in appropriate asbestos bags, labeled with asbestos labels, and stored in an approved containment area at the DEQ Troy Information Center until it can be properly disposed of at an approved landfill. Non-sampling waste from the ABS field teams, such as food containers and waste paper, will be separately bagged and properly disposed of as solid waste.

4.5.3 Recordkeeping and Chain of Custody

At the end of each day, or more often if required, the ABS field teams will return to the DEQ Troy Information Center to download and transfer data recorded on the OU7 ABS Forms and GeoXT PDA, transfer the air and soil samples, transfer any QC samples, and provide copies of the appropriate logbook pages to the field sample coordinator (or the coordinator’s designee). Digital photographs will be downloaded daily to a computer at the DEQ Troy Information Center. Photographs will be electronically labeled and entered into the OU7 Document Management Archive (MARCH). MARCH is a Microsoft Access database that is used to manage electronic documents and associated metadata in accordance with EPA Appendix C requirements (EPA2010). Individual photographs will not be routinely printed from the DEQ Troy Information Center. Data from GeoXT PDAs and field forms will be downloaded or entered on a daily basis into a local field Scribe database. Once all data have been processed, the Scribe project will be informally published to Scribe.NET. The field database will be incorporated into the primary OU7 Scribe database, LibbyTTOU7Field, and will be formally published to Scribe.NET.

An individual file (paper and electronic) will be maintained for each ABS property and use area where the ABS activities were completed. Originals of all field forms will be kept in each individual property file in the DEQ Troy Information Center for the duration of the ABS project. Scanned Portable Document Format (PDF) copies of all field forms and appropriate logbook pages, and digital photographs will be stored in each individual electronic property file. A backup electronic copy of the individual electronic property files will be stored outside of the DEQ Troy Information Center, and will be updated periodically for the duration of the sampling, and reporting phases of the project. Copies of all field sketches, quality assurance/quality control (QA/QC) records, forms, and field logbooks will be available to DEQ, EPA, or to the Troy property owners at any time during the ABS project.

After the OU7 ABS Form electronic information and data are entered in the local field Scribe database, the field sample coordinator will check all property, use area and sample ID numbers for accuracy. The field sample coordinator will then print out a hard copy of the chain-of-custody (COC) form and store these records with the associated samples collected during ABS.


The COC report will be transferred to the Environmental Services Assistant Team (ESAT) Laboratory Coordinator.

Until samples have been transferred to the ESAT Laboratory Coordinator, all samples will be securely held by Tetra Tech. Samples may be stored in storage bins in locked vehicles or in a secured (locked) area of the DEQ Troy Information Center. All ABS samples collected from the OU7 properties, including QC samples, will be transferred to the ESAT Laboratory Coordinator on a regular basis. The ESAT Laboratory Coordinator will provide Tetra Tech with a copy of the released COC. The ESAT Laboratory Coordinator will transfer the samples to either the on-site laboratory for preparation, off-site laboratory for analysis, or to the storage archive.

Soil samples will be placed in storage bins in a secured area of the DEQ Troy Information Center and held briefly before being submitted under COC to the ESAT Laboratory Coordinator. Soil samples will be archived by ESAT until ABS analytical results are obtained and a determination is made if soil analysis will be required.

4.5.4 Field Logbooks

Documentation of ABS field activities will be recorded in field logbooks maintained specifically for this sampling program. Logbooks are controlled documentation (i.e., sequentially numbered) and maintained by DEQ and EPA.

The logbook is an accounting of activities at the site and will note problems or deviations from the governing plans and observations relating to the sampling and analysis program. A new logbook page will be completed for each ABS use area visited. The header information will include the address, and the property owner’s name. When closing out a logbook page with lineout and signature, the author will print their name underneath the signature. Original logbooks will be maintained in the DEQ Troy Information Center.

4.5.5 Sample Labeling and Identification

A unique alphanumeric code, or sample ID number, will identify each sample. The coding system will provide a tracking record to allow retrieval of information about a particular sample and to ensure that each sample is uniquely identified. Sample IDs will be sequential and not be representative of any particular ABS Scenario or use area. Sample IDs will correlate with sample location IDs, which will be identified in the field logbooks.

The sample labeling scheme will follow the format:

TB-XXXXX

where:

TB identifies that a sample is collected in accordance with this ABS SAP and XXXXX represents a 5-digit numeric code.


Preprinted adhesive sample labels will be signed out to sampling personnel by the sample database manager. The labels are controlled to prevent duplication in assigning sample IDs. The labels will be affixed to both the inner and outer sample bags for ABS air and soil samples.

4.5.6 Photographic Documentation

Photographs will be taken with a digital camera at all ABS scenario locations and during each sampling event. Photos will generally include an overview of the ABS area, close up shots of soil types and associated VV (if any), close up shots of ground-cover type, equipment and actor used during the ABS, and any other notable photo to support later health risk assessments that the sampler might identify, A description of each photograph will be recorded in the field logbook in accordance with photographic log protocol (Appendix I of TAPE work plan [Tetra Tech 2007]). A list of photographs in the field logbook will clearly state where each photograph was taken (e.g., ABS scenario or ABS use area). Electronic photograph files will be saved each day to a project-designated computer housed at the DEQ Troy Information Center and assigned appropriate metadata in MARCH so that photographs for a particular ABS property or scenario can easily be retrieved.


5.0 LABORATORY OPERATIONS

This section discusses the analytical methods, custody and documentation procedures, QA/QC requirements, and data management requirements to be followed by the laboratory in support of the OU7 ABS activities.

EPA’s ESAT will be responsible for all sample analysis, including any sample processing prior to analysis. Tetra Tech will relinquish the ABS samples to ESAT under COC protocol. The Sample Coordinator will be responsible for communicating with the ESAT Laboratory Coordinator to relay pertinent sample and analysis information including sample quantities; special sample handling requirements, processing, or analysis concerns; and requested turn-around times.

5.1 ANALYTICAL METHODS AND TURNAROUND TIMES

This section describes the analytical methods to be used for ABS samples. The Sample Coordinator will provide the EPA with requested turn-around times for all samples. In general, it is expected that analysis of ABS air samples will be completed within 2 months from the time the laboratory receives them.

5.1.1 Air Samples

All ABS outdoor air samples will be submitted to the ESAT sample coordinator for distribution to a subcontracted analytical laboratory. Analysis will be completed using the International Organization for Standardization (ISO) Method 10312, with all applicable project specific modifications, including LB-000016, LB-000019, LB-000028, LB-000029, LB-000029a, LB-000030, LB-000053, and LB-000066a (CDM 2003b). All asbestos structures (including LA and all other asbestos types) that have appropriate diffraction patterns and EDS spectra, and length greater than or equal to 0.5 µm and an aspect ratio greater than or equal to 3:1, will be counted.

The target analytical sensitivity for ABS air samples will range from 0.01 to 0.001 cc-1 based on sampling scenario, unless directed otherwise by EPA or DEQ. All field blanks collected as part of this program will be analyzed by counting a number of grid openings approximately equal to the number of grid openings analyzed for field samples. It is expected that this will require the counting of as many as 160 grid openings for sample volumes of 240 L (4 L/min samples) and 64 grid openings for sample volumes of 600 L (10 L/min samples).


As described in the latest version of laboratory modification LB-000029, the frequency for laboratory-based QC samples for TEM analysis is:

Lab blank = 4%

Recount same = 1%

Recount different = 2.5%

Re-preparation = 1%

Verified analysis = 1%

Inter-laboratory = 0.5%

5.1.1.1 Analytical Sensitivity for TEM Analyses

As discussed in Section 5.1.1, the target analytical sensitivity for outdoor ABS air samples will range from 0.01 to 0.001 cc-1, depending upon the sampling scenario. In the event of sample loading or other issues where an analytical sensitivity cannot be achieved, the laboratory may report a sample result with a higher (poorer) sensitivity only after consultation with EPA project personnel and preparation of a temporary modification form.

5.1.1.2 Sample Archival

All ABS air samples will be submitted to ESAT and may be distributed to a contracted laboratory for analysis. The 10 L/min and 4 L/min samples will be analyzed initially. If these samples are overloaded, the 2 L/min samples will be submitted for analysis. Once analyzed, all samples will be stored (archived) at the laboratory under COC until further notice. Aliquots of soil samples not sent for immediate analysis will be archived at the ESAT soil preparation laboratory.

5.1.2 Soil Samples

Soil sample will be placed in storage bins in a secured area of the DEQ Troy Information Center and held briefly before being submitted under COC to the ESAT Laboratory Coordinator. Soil samples will be archived in the ESAT preparation laboratory until ABS air sample analytical results are obtained and a determination is made whether soil analysis will be required.

Prior to analysis, all soil samples require a processing step. Soil samples will be processed using the current version of the Libby soil sample processing SOP (ISSI-LIBBY-01) (ISSI Consulting Group [ISSI] 2000) and the procedures in the Soil Preparation Work Plan (TechLaw 2007). Tetra Tech will indicate the current version of the soil sample processing SOP in the analysis request section of the COC. It is the responsibility of the soil preparation facility to specify the appropriate PLM method on their COCs as it corresponds to the specific sample fraction being submitted for analysis (i.e., fine ground or coarse fraction).


All soil samples collected as part of this ABS effort, including field duplicates, may be analyzed for asbestos by the PLM visual estimation method (PLM-VE) and the PLM gravimetric method (PLM-Grav) in accordance with SOPs SRC-LIBBY-03 (Syracuse Research Corporation [SRC] 2003) and SRC-LIBBY-01 (SRC 2002), respectively.

A random subset of about 10 percent of all soil samples may be analyzed for soil moisture content in accord with ASTM International (formerly the American) Society for Testing and Materials (ASTM) D2216-05: Standard Test Methods for Laboratory Determination of Water (Moisture) Content of Soil.

5.2 HOLDING TIMES

There will be no holding time requirements for samples collected under this SAP.

5.3 LABORATORY CUSTODY PROCEDURES

Laboratory custody procedures are described in the laboratory’s QA management plan.

In the basic laboratory sample custody process each sample, upon receipt at the laboratory, will be inspected to assess the condition of the shipment and the individual samples. This inspection will include verifying sample integrity. The accompanying COC will be cross-referenced with all of the samples in the shipment. The laboratory sample custodian will sign the COC and maintain a copy for their project files; the original COC will be appended to the hard copy data report. Next, the sample custodian may assign a unique laboratory number to each sample on receipt. This number will identify the sample through all further handling at the laboratory. It is the laboratory’s responsibility to maintain internal logbooks and records throughout sample preparation, analysis, data reporting, and sample archiving.

5.4 LABORATORY QA/QC

The Libby Asbestos Project laboratory QA program consists of laboratory certifications, team training and mentoring, analyst training, and laboratory audits. Subcontract laboratories that analyze field samples from any portion of the Libby Superfund project area must maintain particular certifications and must satisfactorily complete project-specific training requirements to ensure proper QA/QC practices are followed during sample analysis.

Each laboratory is required to participate in an onsite laboratory audit carried out by the EPA Superfund Analytical Services Branch that is independent from the Troy team members.

Analytical laboratories will be provided a copy of this SAP. Samples collected under this SAP will be analyzed in accordance with standard EPA or nationally-recognized analytical procedures to provide analytical data of known quality and consistency.


5.5 LABORATORY DOCUMENTATION AND REPORTING

All deviations from project-specific and method analytical guidance documents, or this SAP, will be recorded on a Troy Field Office (TFO) Record of Modification Form (Appendix C). Any deviations that impact, or have the potential to impact, investigation objectives will be discussed with the DEQ prior to preparing the TFO, and once completed, the TFO will be signed by DEQ. The Record of Modification Form will be used to document any information of interest as requested by DEQ. As modifications are approved by DEQ and implemented, the ESAT Laboratory Coordinator will communicate the changes to the ESAT laboratories as necessary.

Sample results data will be delivered to the EPA in accordance with the current version of the EPA Data Management Plan (EPA 2010).

5.6 LABORATORY NONCONFORMANCE

Laboratories will immediately notify the ESAT Laboratory Coordinator if major problems occur (e.g., catastrophic equipment failure). The ESAT Laboratory Coordinator will then notify the ABS Sample Coordinator of potential impacts to turn-around times. Other nonconformance issues, such as those found during performance evaluations or audits, will be addressed on a case-by-case basis by the EPA’s laboratory audit team.


6.0 DATA MANAGEMENT

Data management will be under the supervision of the Tetra Tech Database Manager in the DEQ Troy Information Center. ABS field crews will generate field data on paper copies, handheld computers, and digital photographs. All field data will be managed according to EPA reporting requirements specified in the EPA Data Management Plan (EPA 2010).

These reporting requirements were developed to help satisfy EPA’s removal objectives at the Libby Asbestos Superfund Site. The reporting requirements guide data collection processes and data reporting procedures for spatial information, tabular data, and documents (EPA 2010).

6.1 TABULAR DATA

The Tetra Tech Database Manager will be required to format and submit all tabular data in accordance with EPA reporting requirements (EPA 2010). Operational electronic data will be QC reviewed, entered into a local field Scribe database, and informally published to Scribe.Net within one day of data collection; and, after data auditor checks, formally published to Scribe.NET as part of the primary OU7 Scribe database, LibbyTTOU7Field. This will ensure that EPA has consistent and up-to-date information.

6.2 DOCUMENTS AND RECORDS

The Tetra Tech Database Manager will be required to format and submit all operations documents and records in accordance with EPA reporting requirements (EPA 2010). Hard copy documents will be stored in file cabinets at the DEQ Troy Information Center. Electronic copies will be barcoded and assigned the appropriate metadata in the MARCH database. When requested, these records and associated metadata will be delivered to EPA.


7.0 QA/QC PROCEDURES

The QA/QC objectives, internal QC checks, and audits completed for the OU7 ABS project are described in the sections below. Field QC control procedures are described in Sections 4.3 and 4.4.

7.1 QA/QC OBJECTIVES

The QA/QC objectives of the OU7 ABS project are to obtain 100 percent usable and accurate data. This will be achieved through inspection and sampling using standardized PDA data entry procedures, auditing field operations, observing COC procedures, and analyzing field quality control samples and laboratory quality control samples. The DQOs are described in detail in Section 3.0.

7.2 INTERNAL QC CHECKS

Tetra Tech’s Analytical Coordinator will conduct data verification on 10 to 25 percent of the data generated. This includes cross-checking that sample IDs and sampling dates have been reported correctly on the laboratory report, that calculated analytical sensitivities or detection levels are as expected, that results have been transferred correctly from laboratory bench sheets to the electronic data deliverable (EDD) to Scribe database, and that the laboratory reports and EDDs are complete. If discrepancies are found, Tetra Tech will notify DEQ and EPA. The data verification process includes reviewing field and laboratory QC sample results.

The DQOs presented in Section 3 will be reconciled during the data verification process. This entails comparing the reported results against the project-specific action levels discussed in Section 3. Attainment of project-specific DQOs is necessary to accurately determine HHRA goals including: (1) determining if no threat to human health exists for parcels where interim exterior removals were not required, and (2) determining if the interim exterior removals were effective in reducing the threat to human health from exposure to LA. Non-attainment of project DQOs may result in potential risks to human health.

Since soil samples will be analyzed by EPA ESAT in accordance with Libby Asbestos Superfund Site protocols, including EPA’s most recent protocols relating to QA/QC for the Libby Asbestos Superfund Site, the QA/QC protocols followed by the laboratories are not within Tetra Tech’s immediate control.

7.3 AUDITS, CORRECTIVE ACTIONS, AND QA REPORTS

Field audits will be an integral part of Tetra Tech’s field operations for the duration of the ABS project. Field audits and corrective actions will be the responsibility of DEQ and EPA and the Tetra Tech QA/QC manager. The field audit forms will be housed in the DEQ Troy Information Center for the duration of the project.


7.3.1 Field Inspections and Sampling Procedures Audits

The Tetra Tech QA/QC manager will be responsible for audits of field activities and sampling procedures. Audits will be conducted every two weeks for the duration of the ABS. Audits will consist of the QA/QC manager or his designee attending a sampling event and observing the field teams’ activities. The field teams will not be warned of the audit. The auditor will compare the field teams’ activities with the protocols provided in this SAP and the attached project-specific guidance and evaluate compliance with the protocols using the audit form in Appendix C. After the audit, the auditor will provide the completed audit form to the DEQ and EPA project managers.

7.3.2 Corrective Action Procedures

The QA/QC auditor may use their discretion to provide immediate verbal feedback to the ABS field team, to ensure that deficiencies are fixed as quickly as possible. The field team leader and QA/QC manager will review the report with the ABS field team within 48 hours of the audit to correct any deviations or deficiencies. If any deviations or deficiencies were noted, the field team will be audited again within one week of the original audit to ensure that any deficiencies have been fixed. If a field team member is rotated off the project after deviations or deficiencies were noted, the field team members will be audited again within one week of returning to Troy.

If gross deficiencies are noted, the Tetra Tech QA/QC manager will determine whether any additional ABS activities at any OU7 properties are required. Re-sampling will be required only if the field team failed to correctly complete the ABS, or collected samples incorrectly.


8.0 REFERENCES

Camp Dresser & McKee (CDM). 2003a. Final Sampling and Analysis Plan, Remedial Investigation, Contaminant Screening Study, Revision 1. April.

CDM. 2003b. Final Sampling and Analysis Plan, Remedial Investigation, Libby Asbestos Site. May.

CDM. 2010. Draft Final Sampling and Analysis Plan, General Property Investigation, Libby Asbestos Site, Operable Unit 4. March.

ISSI Consulting Group (ISSI). 2000. ISSI-LIBBY-01. Soil Sample Preparation. Revision 1 (original version). January 7. Revision 2 dated July 12, 2000. Revision 3 dated May 7, 2002. Revision 4 dated August 1, 2002. Revision 5 dated March 6, 2003. Revision 6 dated March 24, 2003. Revision 7 dated August 5, 2003. Revision 8 dated May 4, 2004. Revision 9 dated May 14, 2007. Revision 10 dated December 6, 2007.

Montana Department of Environmental Quality (DEQ). 2009. Libby Asbestos Site, Troy Operable Unit 07, Residential/Commercial Cleanup Criteria, Specific Use Area Visible Vermiculite Action Level Technical Memorandum. April 23.

Syracuse Research Corporation (SRC). 2002. SRC-LIBBY-01. Qualitative Estimation of Asbestos in Coarse Soil by Visual Examination Using Stereomicroscopy and Polarized Light Microscopy. November 12. Revision 1, dated May 20, 2003. Revision 2, dated April 21, 2004.

SRC 2003. SRC-LIBBY-03. Analysis of Asbestos Fibers in Soil by Polarized Light Microscopy. March 3. Revision 1, dated December 11, 2003. Revision 2 dated October 10, 2008.

TechLaw. 2007. Soil Preparation Work Plan. Libby Asbestos Site – Operable Unit 7. Revision D. March.

Tetra Tech EM Inc (Tetra Tech). 2007. Troy Asbestos Property Evaluation Work Plan (Field Sampling Plan and Quality Assurance Project Plan) for the Troy Asbestos Property Evaluation Project, Troy Operable Unit 7. July.

Tetra Tech. 2009. Final Remedial Investigation Work Plan, Outdoor Ambient Air Study, Operable Unit Number 7 of the Libby Asbestos Superfund Site. October 14.

Tetra Tech. 2011. Draft. Human Health Risk Assessment Work Plan, Operable Unit Number 7 of the Libby Asbestos Superfund Site. March 16.

U.S. Environmental Protection Agency (EPA). 1991. Description and Sampling of Contaminated Soils, A Field Pocket Guide. November.

EPA. 2001. Requirements for Quality Assurance Project Plans, QA/R-5. Final. March.

EPA. 2003. Draft Final. Libby Asbestos Site Residential/Commercial Cleanup Action Level and Clearance Criteria Technical memorandum. December 15.


EPA. 2005. Region 8 Background Factsheet, Libby Asbestos. Date accessed: July 5, 2005. Online address: http://www.epa/gov/region8/superfund/libby/lbybkgd.html.

EPA. 2006. Guidance on Systematic Planning Using the Data quality Objectives Process, EPA QA/G4.

EPA. 2007. Sampling and Analysis Plan for Activity-Based Outdoor Exposures, Operable Unit 4, Libby, Montana, Superfund Site. Final. July 6.

EPA. 2010. EPA Data Management Plan, Libby Asbestos Site. Version 2010.1. Prepared by EPA Region 8 and EPA Emergency Response and Removal DATA Team. March.

APPENDIX A

TETRA TECH SITE-SPECIFIC HEALTH AND SAFETY PLAN

OU7 ACTIVITY-BASED SAMPLING

(Available to Agencies upon Request)

APPENDIX B

FIELD FORMS AND LABORATORY FORMS

OU7 ACTIVITY BASED SAMPLING FORM AIR SAMPLING DATA

Tetra Tech EM, Inc. Activity Based Sampling Project (ABS) Page 1 / 2

Sample # Pump I.D.#

Date Collected

Rotometer I.D. #

Sample Type 1

ABS Scenario 2

Cassette Lot #

Time On Time Off Total Minutes

Flow Rate-Start Flow Rate-Stop Total Volume

ABS Use Area Location/Size 3

Personnel Sampled

ABS Activity 4

/ /

/ /

/ /

/ /

/ /

/ /

/ /

/ /

/ /

/ /

NOTES: All ABS samples will be collected on 25 mm diameter mixed cellulose ester (MCE) filter cassettes with a pore size of 0.8µm 1) Sample Type

FS = Field Sample

FB = Field Blank

FD = Field Duplicate

EB = Equipment Blank

FP = Field Split

LB = Lot Blank

3) ABS Use Area Location/Size

Use AD-OU7NA for multiple locations

2) ABS Scenario

a) Yard work in residential yards

b) Gardening in residential yards

c) Bicycling and playing on unpaved driveways

d) Driving on paved and unpaved roads and alleys

e) Recreational activities at parks and school yards

4) ABS Activity

a) Raking

b) Digging

c) Mowing

d) Rototilling

e) Playground activity

f) Bicycling

g) Driving

h) Recreational sports & ball field

ABS Category (check one): □ Residential □ Community

AD Number: AD-OU7NA

Collected By:

OU7 ACTIVITY BASED SAMPLING FORM (continued) GROUND COVER / SOIL DATA

Tetra Tech EM, Inc. Activity Based Sampling Project (ABS) Page 2 / 2

Sample # Use Area Ground Cover 5 Use Area Soil Moisture Content VWC% 6 Use Area Soil Texture 7

NOTES: GPS coordinates should be collected to depict the perimeter of each use area included in the ABS 5) Use Area Ground Cover

{ multiple designations may be used, follow letter with percentage:

ex: A75 B25 }

a) Grass

b) Bare Soil

c) Gravel / Rock

d) Miscellaneous vegetative cover

e) Post Removal Grass

f) Post Removal bare Soil

g) Post Removal Gravel / Rock

h) Post Removal Miscellaneous vegetative cover

6) Use Area Soil Moisture Content

{ Moisture readings will be taken with a Volumetric Water Content (VWC)

meter from between 0 to 3 inch soil depth. If the average reading exceeds

30% VWC, or a single reading exceeds 50% VWC then ABS activities will

not be completed that day}

7) Use Area Soil Texture

{Soil texture will be record using visual and hand texture testing.

Recording options include}

a) Moist

b) Slightly moist

c) Dry

d) Very Dry (Dusty)

ABS Category (check one): □ Residential □ Community

AD Number: AD-OU7NA

Collected By:

Instructions to Requester: Fax to contacts at bottom of form for review and approval. File approved copy with Data Manager at the Troy Field Office (TFO).

Data Manager will maintain legible copies in a binder that can be accessed by TFO personnel. If Modification is Temporary for a Single Parcel, Data Manager will scan this and place in parcel’s electronic file.

Project Work Plan/QAPP (check one):

o OU7 ABS Sampling & Analysis Plan

o Other (Title and approval date): Site-Specific Guidance/SOP:

Title Number/Revision): _________________ Requester: Title: Company: Date: Description of Modification (attach additional sheets if necessary; state section and page numbers of each document that are affected by the proposed modification): Field Sampling Data Sheet where Modification is documented (attach associated correspondence): Potential Implications of Modification: Duration of Modification (check one):

o Temporary Date(s): Station Number-_________________

TA-___________________

o Permanent (Proposed Text Modification Section) Effective Date: Proposed Text Modifications in Associated Document (attach additional sheets if necessary): Data Quality Indicator (circle one) – Please reference definitions on reverse side for direction on selecting data quality indicators:

Not Applicable Reject Low Bias Estimate High Bias No Bias Technical Review and Approval: _________________________________ Date: (DEQ Project Manager or designate) EPA Review and Approval: _____________________________________ Date: (USEPA RPM or designate) Revised April 29, 2007

Record of Modificationto the

OU7 Activity-Based Sampling TFO-__ __ __ __ __ (numbered by Data Manager)

DATA QUALITY INDICATOR DEFINITIONS

Reject - Samples associated with this modification form are not useable. The conditions outlined in the modification form adversely effect the associated sample to such a degree that the data are not reliable. Low Bias - Samples associated with this modification form are useable, but results are likely to be biased low. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimated low. Estimate - Samples associated with this modification form are useable, but results should be considered approximations. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimates. High Bias - Samples associated with this modification form are useable, but results are likely to be biased high. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimated high. No Bias - Samples associated with this modification form are useable as reported. The conditions outlined in the modification form suggest that associated sample data are reliable as reported.

APPENDIX C

STANDARD OPERATING PROCEDURES

Site-Specific Sampling Guidance Libby Superfund Site

Guidance No.: CDM-LIBBY-05, Revision 3 Guidance Title: Soil Sample Collection at Residential and Commercial Properties Approved by: _______________________________________________________________ Project Manager Date _______________________________________________________________ Technical Reviewer Date

_______________________________________________________________ QA Reviewer Date

_______________________________________________________________ EPA Approval Date

Α Page 1 of 9

S:\State\CECRA\Troy\Final Workplan-May-07\Appendix B SOPs\CDM-LIBBY-05_Rev3.doc

CDM-Libby-05 Soil Sample Collection

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Section 1 Purpose The goal of this standard operating procedure (SOP) is to provide a consistent method for the collection of 30-point composite surface soil sampling to support all investigations conducted at the Libby Superfund Site and specified in governing guidance documents. This SOP describes the equipment and operations used for sampling surface soils in residential and commercial areas, which will be submitted for the analysis of Libby amphibole asbestos. Refer to each investigation-specific guidance documents or work plan for detailed modifications to this SOP, where applicable. The EPA Team Leader or their designate must approve deviations from the procedures outlined in this document prior to initiation of the sampling activity.

Section 2 Responsibilities Successful execution of this SOP requires a clear hierarchy of assigned roles with different sets of responsibilities associated with each role. All staff with responsibility for the collection of soil samples is responsible for understanding and implementing the requirements contained herein as well as any other governing guidance documents.

Task Leader (TL) or Field Team Leader (FTL) - The TL or FTL is responsible for overseeing sample collection processes as described in EPA approved governing guidance documents (i.e., site-specific sampling and analysis plans [SAPs], quality assurance project plans [QAPPs], etc.). The TL or FTL is also responsible for checking all work performed and verifying that the work satisfies the specific tasks outlined by this SOP and all governing guidance documents. The TL or FTL will communicate with the field team members regarding the specific collection objectives and anticipated situations that require deviation from this SOP. It is also the responsibility of the TL or FTL to communicate the need for any deviations from the SOP with the appropriate EPA personnel (team leader or their designate), and document the deviations using a Field Modification Form provided in each SAP or QAPP.

Field team members - Field team members performing the sampling described in this SOP are responsible for adhering to the applicable tasks outlined in this procedure while collecting samples at properties associated with the Libby Superfund Site. The field team members should have limited discretion with regard to collection procedures but should exercise judgment regarding the exact location of sample points, within the boundaries outlined by the TL or FTL.

Α Page 2 of 9 S:\State\CECRA\Troy\Final Workplan-May-07\Appendix B SOPs\CDM-LIBBY-05_Rev3.doc


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Section 3 Equipment

Measuring tape or wheel – Used to estimate the square footage of each land use area.

Pin flags – Used to identify composite points within each sampling area.

Trowel or push probe - For collecting surface soil samples.

Shovel - For collecting surface soil samples.

Stainless steel mixing bowl - Used to mix and homogenize composite soil samples after collection. Zip-top bags may also be used for homogenization if approved by the governing guidance documents.

Gloves - For personal protection and to prevent cross-contamination of samples (disposable, powderless plastic or latex).

Sample container - Gallon-sized zip-top plastic bags (2 per sample).

Field clothing and personal protective equipment (PPE) - As specified in the current version of the site health and safety plan (HASP).

Field sprayers – Used to suppress dust during sample collection and to decontaminate nondisposable sampling equipment between samples.

Deionized (DI) water- Used in field sprayers to suppress dust and to clean and decontaminate sampling equipment.

Plastic bristle brush - Used to clean and decontaminate sampling equipment.

Wipes - Disposable, paper. Used to clean and decontaminate sampling equipment.

Aluminum foil – Used to wrap decontaminated sampling equipment in between uses to prevent contamination during transport.

Alconox – Used to clean and decontaminate sampling equipment weekly.

6-mil poly bag – Used to store and dispose of investigation-derived waste (IDW).

Trash bag - Used to store and dispose of general trash.

Field logbook/PDA - Used to record progress of sampling effort and record any problems and field observations.



Revision 3

Visual Vermiculite Estimation Form (VVEF) – Used to record semi-quantitative estimates of visual vermiculite at each sub-sample location and point inspection (PI).

Permanent marking pen - Used to label sample containers.

Sample ID Labels (Index IDs)– Pre-printed stickers used to label sample containers.

Cooler or other rigid container - Used to store samples while in the field.

Custody Seals - For ensuring integrity of samples while in the field and during shipping.

Section 4 Sampling Approach Upon arrival at each property, the field team will locate all parcels requiring sample collection depending on the investigation-specific objectives detailed in governing guidance documents. Parcels on a property will be sectioned into zones that share a similar land use. Zones established by land use areas may be subdivided based on site conditions (e.g., access, construction setup considerations, etc.). Use areas include:

Specific Use Area (SUA): flowerbed, garden, flowerpot, stockpile, play area, dog pen, driveway (non-paved), parking lot (non-paved), road (non-paved), alley (non-paved)

Common Use Area (CUA): yard, former garden, former flowerbed, walkway

Limited Use Area (LUA): pasture, maintained/mowed field, overgrown areas with trails/footpaths, overgrown areas in between SUAs/CUAs

Interior Surface Area (ISA): soil floor of garage, pumphouse, shed, crawlspace, earthen basement

Non-Use Areas(NUA): wooded lot, un-maintained field. NUAs will be identified but will not be sampled at this time because they are not presently considered a complete exposure pathway. However, to the extent that NUAs may become a complete exposure pathway in the future, EPA may revisit NUAs at a later date.

After areas have been designated as zones (i.e., SUA zones, CUA zones, LUA zones, NUA zones, ISA zones), the field team will measure the zones with a measuring wheel and label the zone type and approximate square footage on the field sketch and/or design drawings. There is not a minimum or maximum square footage restriction on any zone.

In establishing zones at the property, no area type may be combined with any other area type. For example, driveways and flowerbeds are both SUAs but will be



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separated into unique zones for soil sampling. Similarly, large CUAs such as yards may be subdivided into front yard, side yard, and back yard zones dependent on site conditions. Sectioning properties into additional zones will be at the discretion of the FTL but consistent among the teams. Conversely, not all land use areas previously mentioned will be applicable at every property.

It is anticipated that SUAs and ISA zones will generally tend to be smaller parcels. Combining small, proximal SUAs into one zone will be at the discretion of the FTL but consistent among teams. With the exception of proximal SUAs, all other land use areas will be contiguous when establishing zones at each property.

Composite sampling requires soil collection from multiple (sub-sample) points. Composite samples will be collected from similar land use areas (i.e., SUA, CUA, etc.) and will not be combined with any other use area. One composite sample will be collected from each zone.

For SUAs (e.g., driveway, garden, dog pen, etc.), composite samples will be collected from the 0- to 6–inch depth interval. If a depth of 6 in. cannot be attained given the varying levels of compaction in driveways, roads, etc. the maximum depth attainable will be documented in the field logbook/PDA. For non-SUAs (e.g., yard, former flowerbed, crawlspace, etc.), composite samples will be collected from 0 to 3 inches. All composite soil samples will have 30 sub-samples (i.e., 30-point composite sample) of approximately equal size for a final sample volume between 2,000 and 2,500 grams. Table 1 lists the sample depth for each type of land use area.

TABLE 1

SAMPLING AREA AND DEPTH

Land Use Area Label Sampling Depth (Inches)

Special Use Area SUA 0 – 6 Common Use Areas CUA 0 – 3 Limited Use Area LUA 0 – 3 Non-Use Area NUA Not Sampled Interior Surface Zone IS 0 – 3

As each sub-sample is collected, the soil will be inspected for visual vermiculite (VV) and the location and semi-quantitative estimates of VV will be recorded as prescribed in the SOP for Semi-Quantitative Visual Estimation of Vermiculite in Soil, Revision 1 (CDM 2007a).

Areas of SUAs with VV will not be sampled. Instead, the location will be recorded in the field logbook/PDA and on the field sketch or design drawing. If the SUA is of substantial size (greater than 1000 square feet [ft2]), and the VV is localized, additional PIs will be collected to determine the extent of VV and a sample will be collected from



Revision 3

the remainder of the zone that does not contain VV. If the SUA measures less than 1,000 ft2 and VV is present, a sample will not be collected from that SUA. Proximal SUAs will not be combined into a SUA zone if VV is present. If visible vermiculite is not observed, proceed with sample collection of the SUA zone

Section 5 Sample Collection Don the appropriate PPE as specified in the governing HASP. A new pair of disposable gloves is to be worn for each sample collected. Segregate land use areas on the property into zones as described in Section 4. To reduce dust generation during sampling, use a sprayer with DI water to wet each sub-sample location prior to collection. Use the trowel to check beneath the surface soil layer, but do not advance more than 6 inches. If VV is observed, record the information on the field sketch or design drawing. If VV is observed within a large SUA, do not collect a sample from the area containing VV as described above.

Within each zone, select 30 sub-sample locations equidistant from each other. These 30 sub-sample locations will comprise the 30-point composite sample for that zone. All composite sub-samples will originate from the same land use area. For example, do not mix sub-samples from SUAs with sub-samples from LUAs.

Clean the sub-sample locations of twigs, leaves, and other vegetative material that can be easily removed by hand. Using the trowel or push probe, excavate a hole in the soil approximately 2 inches in diameter and 6 inches deep for SUAs, or 3 inches deep for non-SUAs, while placing the excavated material directly inside the gallon-sized zip-top plastic bag. Repeat this step for each subsequent sub-sample until the appropriate number of composite sub-samples has been collected. As each sub-sample is collected, inspect the location for VV as prescribed in the SOP for Semi-Quantitative Visual Estimation of Vermiculite in Soil, Revision 1 (CDM 2007a).

Samples collected from zones measuring greater than 3,000 ft2 will require additional PIs to inspect the soil for VV, but no more than 30 sub-samples will be collected from a zone for each composite sample. Samples collected from zones measuring less than 3,000 ft2 will have the same number of sub-samples as PIs unless additional PIs are required to identify the extent of localized VV.

Homogenize the sample as required by governing guidance documents. Once the sample is homogenized, fill the zip-top plastic bag to 1/3rd full (approximately 2000 grams). Affix the sample index ID label to the inside of the bag and write the index ID number on the outside of the bag, or affix an additional label using clear packing tape. Sample index ID numbers will be assigned based on the investigation-specific guidance document. Double bag the sample and repeat the labeling process for the outer bag. Decontaminate equipment between composite samples as described in Section 8.



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Repeat steps outlined above until all samples from a property have been collected.

Soil field duplicate samples will be collected at the rate specified in governing guidance documents. Field duplicate samples will be collected as samples co-located in the same zone. The duplicate will be collected from the same number of sub-samples as the parent sample, but the sub-sample locations of the duplicate sample will be randomly located in the zone. The inspection for VV at each sub-sample location will follow the same protocol as referenced above. These samples will be independently collected with separate sampling equipment or with the original sampling equipment after it has been properly decontaminated. For tracking purposes, the parent/duplicate sample relationship will be recorded in accordance with sample documentation requirements stated in the governing guidance document. These samples will be used to determine the variability of sample results in a given land use area. These samples will not be used to determine variability in sampling techniques.

Section 6 Site Cleanup IDW will be managed as prescribed in Section 3.2.10 of the Site-wide QAPP [SWQAPP] (CDM 2007b) or other applicable governing guidance documents. In general, replace the soil plug with excess sample volume. The soil should be placed back into the hole and tamped down lightly. If sandy areas such as playgrounds are sampled, refilling the soil plug is not necessary.

Rinse water, the roots of vegetation removed during sampling, and any excess soil volume may be returned to the sampled area.

Section 7 Documentation A field logbook/PDA will be maintained by each individual or team that is collecting samples as prescribed in Section 3.2.4 of the SWQAPP (CDM 2007b) or other applicable governing guidance documents. Guidance documents will detail conditions which require attention, but at a minimum the following information should be collected:

Project name

Title of governing documents

Property address

Date

Time



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Team members

Weather conditions

PPE used

Locations of any samples or sub-samples that could not be acquired

Descriptions of any deviations to the SAP or SOP and the reason for the deviation

Relinquishment of samples to project sample coordinator

Complete required documentation as detailed in applicable governing guidance documents.

Section 8 Quality Assurance/Quality Control Quality control samples will include:

Field duplicates

Detailed information on QC sample collection and frequency is prescribed in Section 3.1.3.2 of the SWQAPP (CDM 2007b) or other applicable governing guidance documents.

Section 8 Decontamination All sampling equipment must be decontaminated prior to reuse. Specific instructions on sample equipment decontamination are included in the applicable governing guidance documents. In general, the procedure to decontaminate all soil sampling equipment is outlined below:

Remove all visible contamination with plastic brush

Use DI water and plastic brush to wash each piece of equipment

Remove excess water present on the equipment by shaking

Use a paper towel to dry each piece of equipment

Wrap dried equipment in aluminum foil

Once a week all soil sampling equipment will be cleaning using Alconox and DI water.



Revision 3

Spent wipes, gloves, aluminum foil, and PPE must be disposed of or stored properly as IDW, specified in Section 3.2.10 of the SWQAPP (CDM 2007b) or other applicable governing guidance documents.

Section 9 Sample Custody Field sample custody and documentation will follow the requirements described in Section 3.2.11 of the SWQAPP (CDM 2007b) or other applicable governing guidance documents.

Section 10 Glossary Governing guidance documents - The written document that spells out the detailed site-specific procedures to be followed by the project leader and the field personnel for completing specific investigations. These documents will clearly indicate specific requirements for the implementation of this SOP.

Libby Superfund Site – The Libby Superfund Site contains all buildings and land within the boundaries of each operable unit (OU) of the site and illustrated on the most recent version of the OU boundary map.

Sub-sample - The actual location at which the sample is taken. The dimension of a sample point is 2 inches across by 3 inches deep (6 inches for SUAs).

Composite Sampling - A sample program in which multiple sample points are compiled together and submitted for analysis as a single sample.

Land Use Area - A section of property segregated by how the property owner uses the area. The area can be classified as a SUA, LUA, CUA, ISA, or NUA.

Section 11 References CDM. 2007a. Semi-Quantitative Visual Estimation of Vermiculite in Soils at Residential and Commercial Properties, Revision 1. CDM-LIBBY-06.

CDM. 2007b. Site-Wide Quality Assurance Project Plan. Draft in review.


A Page 2 of 8 C:\Documents and Settings\bieleckint\Local Settings\Temporary Internet Files\OLKDF\SOP CDM-Libby-06 SemiQuant Verm_r1 _ver4 (2).doc

Section 1 Purpose EPA will identify and delineate the extent of any visible vermiculite (VV) present in soils as part of all investigations conducted at the Libby Superfund Site and specified in governing guidance documents. The goal of this standard operating procedure (SOP) is to provide a consistent approach to identify and characterize any VV present in soils. The semi-quantitative approach presented in this SOP for visually estimating VV in soil will be revised as required to optimize data collection as the sampling teams gain experience. This will be accomplished by expanding and/or improving this SOP, supporting pictorial standards, and additional electronic data acquisition efforts, as necessary. Section 2 Definitions Specific Use Area (SUA) – Discrete exterior parcels on a property with a designated specific use. Due to the nature of activities typically carried out in SUAs, residents may be especially vulnerable to exposures when Libby amphibole asbestos (LA) contaminated soil becomes airborne. SUAs may be bare or covered with varying amounts of vegetation. SUAs include:

Flower Pot Flowerbed Garden Stockpile Play Area Dog Pen Driveway (non-paved) Parking Lot (non-paved) Road (non-paved) Alley (non-paved)

Common Use Area (CUA) – Exterior parcels on a property with varied or generic use. CUAs may be bare or covered with varying amounts of vegetation. CUAs include:

Walkway Yard (front, back, side, etc.) Former Garden Former Flowerbed

CDM-LIBBY-06 Visual Estimation of Vermiculite in Soil

Revision 1


Limited Use Area (LUA) – Exterior parcels on a property that are accessed, utilized, and maintained on a very limited basis. LUAs may be bare or covered with varying amounts of vegetation. LUAs include:

Pasture Maintained/Mowed Fields Underneath porches/decks1 Overgrown Areas (with trails/footpaths, or between SUAs/CUAs)

1 Interior Surface Area (ISA) – Interior soil surfaces of buildings such as garages, pumphouses, sheds, and crawlspaces. Non-Use Area (NUA) – Exterior parcels on a property with no current use (e.g., areas that are un-maintained and not accessed). NUAs may be bare or covered with varying amounts of vegetation. NUAs include:

Wooded Lots Un-maintained Fields

Since NUAs are not currently accessed, they are not presently considered a complete exposure pathway. As such, semi-quantitative visual estimates of vermiculite in soil will not be captured at this time. However, to the extent that NUAs may become a complete exposure pathway in the future, EPA may revisit these NUAs at a later date. Zone2 – Parcels on a property that share a similar land use or subdivisions of a land use area based on site conditions (e.g., access, construction setup considerations, etc.) or sampling requirements. No area type may be combined with any other area type. For example, driveways and flowerbeds are both SUAs but will be separated into unique zones for visual inspection. Similarly, large CUAs such as yards may be subdivided into front yard, side yard, and back yard zones dependent on site conditions. Sectioning properties into additional zones will be at the discretion of the field team leader but consistent among the teams. It is anticipated that SUAs and ISA zones will generally tend to be smaller parcels. Combining small, proximal SUAs into one zone will be at the discretion of the field team leader but consistent among teams. No ISA will be combined with any other ISA for visual inspection. There is not a maximum square footage restriction on any zone.

1 The soils underneath porches and decks will be classified as LUAs depending on ground clearance and accessibility to homeowners and pets. If these areas are not accessible, they will be classified as NUAs. 2 The restriction on the maximum square footage of SUA zones (1,000 ft2) and non-SUA zones (2, 500 ft2) was eliminated from the previous iteration of this SOP after the data were reviewed by EPA and determined to sufficiently characterize the presence of VV regardless of zone square footage. Additionally, this will allow the flexibility necessary for field teams to identify areas of zones most cost effectively for removal purposes.


Revision 1


Point Inspection (PI) – Used in SUA, CUA, LUA, and ISA zones. A PI is an intrusive visual inspection of the top portions of the soil at a randomly selected point within a zone. A PI consists of the active displacement of the surface soil with a small shovel and visual inspection of the displaced soil to determine if VV is present. If VV is observed during the PI, the location and a semi-quantitative estimate of VV contamination will be recorded. Section 3 Applicability This SOP applies to properties within the Libby Superfund Site at varying stages of the removal process including, but not limited to, all screening and risk-based investigations, pre-design inspections, and removal actions. Investigation-specific modifications to this SOP are outlined in the governing guidance document for each investigation. The following locations on a property will be evaluated for the presence/absence of VV:

All parcels on a property where soil samples are being collected. All parcels on a property where soil was non-detect for LA during previous

sampling activities. All SUA parcels on a property that have not been previously characterized as

containing VV Section 4 Procedure Figure 1 illustrates the procedures and decision rules for this SOP. The three primary procedural steps are listed below:

Establish zones Perform PI Perform semi-quantification of visual vermiculite

Each is described in the following subsections. 4.1 Establish Zones Upon arrival at the property, the field team will locate all areas requiring sample collection (i.e., where previous soil sample results were non-detect for LA or SUAs have not been previously characterized for VV). Parcels will be identified as SUA zones, CUA zones, LUA zones, NUA zones, or ISA zones. The field team will measure the zone sizes and note them on the field sketch and/or design drawings. Zones will be assigned according to the definitions provided above.


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4.2 Point Inspections3 As defined above, a PI is an intrusive visual inspection performed for the entire surface of a zone. Professional judgment may be used to determine the exact location of PIs; however, the following guidelines will be implemented to maintain consistency. A minimum of 30 PIs will be evaluated per zone if sampling is required within that zone. If soil sampling is not required, a minimum of 5 PIs will be evaluated within each zone. Zones larger than 500 square feet (ft2) will require evaluation at a minimum of 1 PI per 100 ft2 (10 ft by 10 ft area). The PI locations will be randomly selected and will be spatially representative of the entire zone. Locations of the PIs and semi-quantitative estimates of VV (i.e., low, intermediate, or high) will be recorded on the field sketch for each PI. While a minimum of 5 PIs will be conducted per zone, there is no set maximum. Rather, the maximum number of PIs is variable—dependent upon the total area of the zone and achieving the minimum required frequency of 1 PI per 100 ft2. The following sections outline procedures for inspecting each use area (e.g., SUA, CUA, LUA, ISA). The procedure for semi-quantification of VV is provided in the next section. SUA Zone: Visually inspect the PI point using a spade or trowel to remove any cover material,

including excess debris (e.g., mulch, rock, etc.) and organic material, from the surface of the soil. Remove and visually inspect soil to a depth of 0-6 inches below ground surface4.

If a depth of 6 in. cannot be attained given the varying levels of compaction in driveways, roads, etc. the maximum depth attainable will be documented in the field logbook.

Record semi-quantitative estimate of VV observed as described in the following section.

Replace soil and cover material. Repeat as necessary employing procedure outlined above.

CUA and LUA Zones: Visually inspect the PI point using a spade or trowel, carefully removing organic

material, including grass, from the surface of the soil. Remove and visually inspect soil to a depth of 0 - 3 inches below ground surface5.

3 Surface Inspections- The non-intrusive visual inspection of the immediate surface of a zone was eliminated from the previous iteration of this SOP after their data were reviewed and determined by EPA to provide no additional information over that gained through Point Inspections. 4 A soil depth of 6 inches for SUAs was chosen to approximate the depths to which digging would be expected during typical activities occurring in these SUA zones (e.g., gardening, child digging in dirt, etc.) 5 A soil depth of 0-3 inches was chosen to approximate the depths to which soil disturbance would be most likely during typical activities occurring in these CUA and LUA zones (e.g., lawn mowing, etc.)


Revision 1


Record semi-quantitative estimate of VV observed as described in the following section.

Carefully replace all soil and organic material. Repeat as necessary employing procedure outlined above.

ISA Zone: Move items as necessary to access the soil surface. Visually inspect the PI points using a spade or trowel, remove and visually inspect

soil to a depth of 0 - 3 inches below ground surface6. Record semi-quantitative estimate of VV observed as described in the following

section. Repeat as necessary employing procedure outlined above.

If during the PI, VV is observed to be localized within a zone, the portion with vermiculite will be denoted on the field sketch. If additional PIs are necessary to determine the boundaries of the area, approximately 10 to 20% additional PIs will be evaluated to determine the extent of localized vermiculite. 4.3 Semi-Quantification of Visual Vermiculite During PI, the field team will estimate the quantity of vermiculite observed. Each PI location for all zones will be assigned a semi-quantitative estimate of visible vermiculite content using a 4-point scale: none (blank), low (L), intermediate (M), and high (H) 7. For PI locations where VV is observed, semi-quantitative estimates (e.g., L, M, or H) will be recorded on the field sketch. PI locations where VV is not observed will not be recorded on the field sketch. Photographs illustrating these quantities are attached to this SOP as Figure 2. Additionally, jars of vermiculite-containing soils representing these three levels will be available for training and reference. Under the current version of this SOP, there will be no effort to design an approach to combine vermiculite levels for PIs within or among zones. While the viability of combining semi-quantitative visual estimates within or among zones may be assessed as a pilot-scale evaluation, any PI with visible vermiculite qualifies as vermiculite-containing soil for the area represented by the inspection point or inspection zone.

6 A soil depth of 0-3 inches was chosen to approximate the depths to which soil disturbance would be most likely during typical activities occurring in these IS zones (e.g., entering crawlspace, retrieving items from shed, etc.) 7 Based on EPA’s review of previous data, the 5-level scale VV identification scheme was not meaningful and will be reduced to a 4-level scale. As such the quantity of “Gross” VV in the previous iteration of this SOP was combined with High. Previously collected data of Gross VV should be considered analogous to High VV under this revised SOP.


Revision 1


Section 5 Health & Safety/Engineering Controls All personnel will carry out visual inspections in accord with proper personal protective equipment (PPE) and other monitoring/governing requirements outlined in the most recent version of the Site Health and Safety Plan governing the work being conducted. All visual inspections will employ appropriate engineering controls to minimize dust (e.g., wetting soil during inspection) as prescribed in the Site-Specific Standard Operating Procedure for Soil Sample Collection (CDM-LIBBY-05, Revision 2). Section 6 Equipment Decontamination Equipment decontamination is not required between each PI from the same zone, but is required before moving to another inspection zone. Decontamination of equipment will be conducted as required by the governing guidance documents. Section 7 Documentation As noted above, information about the presence of vermiculite will be recorded on the field sketch or design drawing for the property under investigation. Each zone will be marked with:

Zone type (i.e., SUA, CUA, LUA, NUA, or ISA) Zone area in ft2 PI locations/points Semi-quantitative estimate of VV content for each PI (i.e., L, M, H)

In addition to field sketch/design drawing documentation, each field team will generate a Visual Vermiculite Estimation Form (VVEF) (Figure 3) to document the semi-quantitative visual estimates of VV for each PI for possible future information use. This form will be managed according to governing guidance documents. Section 8 Training Every effort will be made to ensure consistency in the semi-quantitative evaluation of VV in soil to the extent possible. This will include training (e.g., field calibration), specimen examples (i.e., jars/photographs of low, intermediate, and high quantities of vermiculite, etc.), designated field staff, and oversight by the field team leader. Figures illustrating none, low, intermediate, and high quantities of vermiculite are attached to this SOP for reference (Figure 2).


Revision 1


To ensure consistency over time, the field team leader will verify semi-quantitative assignments at a rate of one property per team per week. The field team leader will sign off on those field sketches that were verified. If inconsistencies are noted, the field team leader will hold re-training with all teams participating simultaneously. Updates to the SOP and its attached specimen examples will occur as necessary and the EPA Project Team Leader and Technical Assistance Unit will be notified when these updates are recommended by the field team leader or field investigation manager.

Establish Zones

Establish Point

Inspections

Notes: LV: Libby Vermiculite PI: Point Inspection

Mark Location and Quantities

Visible LV at PIs?

Use additional PIs to Further Delineate

Localized Vermiculite

Mark Localized Areas as “Containing Vermiculite”

YES

NO

Mark Entire Zone as “No

Visible Vermiculite”

Figure 1 – Visible Vermiculite Inspection Process

Figure 2a: Low Visible Vermiculite – A maximum of a few flakes of vermiculite observed within a given visual inspection point

Vermiculite

Figure 2b: Intermediate Visible Vermiculite – Vermiculite easily observed throughout visual inspection point, including the surface.

Figure 2c: Intermediate Visible Vermiculite – Vermiculite easily observed throughout visual inspection point, including the surface.

Figure 2d: High Visible Vermiculite – Vermiculite easily observed throughoutvisual inspection point, including the surface.

1 LIBBY SUPERFUND SITEVisual Vermiculite Estimation Form (VVEF)

Page No.: Site Visit Date: BD Number:

Property

Phone No.:

Phone No.:

Investigation Name:

Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8

Total 0 0 0 0 0 0 0 0

Areas previously identified for removal not inspected for visible vermiculite? Yes No NA Location(s):

Page 1 of :

Visual Verification by Field Team Leader (10% of forms):

General Comment(Cover, etc.)

Area Size(square feet)

Investigation Team:

Structure Description: Address:

Occupant:

Owner (If different than occupant):

PIs

(X=

Non

e, L

=Lo

w,

M=

Inte

rmed

iate

, H

=H

igh)

Field Form Check Completed by (100% of Forms):

X

H

Field Logbook No.:

Type(SUA/CUA/LUA/IS)

Description

M

L