Project Integration, Inc. 1097 Highway 101 South Suite D16 Greer, SC 29651
864

- 334

- 5085 sales@pintegration.com



# John Deere

Des Moines, Iowa



## Quality Assurance Project Plan (QAPP) For Delisting of F006
and F019 Sludge Filter Cake

June 2012John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 i John Deere 

# Table of Contents

Introduction

................................ ................................ ................................ ................................ ............................... iii

1. Project Description

................................ ................................ ................................ ................................ .......... 1

1.1 Overview

................................ ................................ ................................ ................................ ............... 1
1.2 Sampling Strategy

................................ ................................ ................................ ................................ 1

2. Project Organization and Responsibility

................................ ................................ ................................ ..... 2

2.1 Project Director

................................ ................................ ................................ ................................ ..... 2
2.2 Quality Assurance Officer

................................ ................................ ................................ .................. 2
2.3 Health and Safety Coordinator

................................ ................................ ................................ .......... 2
2.4 Laboratory Personnel

................................ ................................ ................................ .......................... 2

3. Quality Assurance Objectives for Measurement Data

................................ ................................ ............... 3

3.1 Precision

................................ ................................ ................................ ................................ ................ 4
3.2 Accuracy

................................ ................................ ................................ ................................ ................ 4
3.3 Completeness

................................ ................................ ................................ ................................ ....... 4
3.4 Representativeness

................................ ................................ ................................ .............................. 5
3.5 Comparability

................................ ................................ ................................ ................................ ....... 5

4. Sampling Procedures

................................ ................................ ................................ ................................ ...... 6

4.1 General Documentation Requirements

................................ ................................ ............................ 6
4.2 Sampling

................................ ................................ ................................ ................................ ............... 7
4.3 Sample Preparation and Handling

................................ ................................ ................................ .... 7
4.3.1 Sample Containers and Cleaning Requirements

................................ ............................... 7
4.3.2 Sample Preservation and Holding Times

................................ ................................ ........... 7
4.3.3 Sample Labeling and Handling

................................ ................................ ........................... 7
4.4 Documentation

................................ ................................ ................................ ................................ ..... 8

5. Sample Custody

................................ ................................ ................................ ................................ ............... 9

5.1 Field Procedures

................................ ................................ ................................ ................................ .. 9
5.2 Laboratory Procedures

................................ ................................ ................................ ...................... 10

6. Calibration Procedures

................................ ................................ ................................ ................................ . 11

7. Analytical Procedures

................................ ................................ ................................ ................................ ... 12

8. Data Reduction, Validation, and Reporting

................................ ................................ .............................. 13

8.1 Data Reduction

................................ ................................ ................................ ................................ ... 13
8.2 Data Validation and Assessment

................................ ................................ ................................ ..... 13
8.2.1 Field Blanks

................................ ................................ ................................ .......................... 14John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 ii John Deere 8.2.2 Holding Time

................................ ................................ ................................ ....................... 14
8.3 Data Reporting

................................ ................................ ................................ ................................ ... 14
8.3.1 Qualifiers

................................ ................................ ................................ .............................. 14
8.3.2 Data Reporting System

................................ ................................ ................................ ....... 14
8.4 QA Data Validation Summary Report

................................ ................................ ............................ 1 5

9. Quality Control

................................ ................................ ................................ ................................ .............. 16

9.1 Field Duplicate Samples

................................ ................................ ................................ ................... 16
9.2 Field Blanks

................................ ................................ ................................ ................................ ........ 16

10. Audits

................................ ................................ ................................ ................................ ............................. 16

10.1 Field Operations Audit

................................ ................................ ................................ ..................... 16
10.2 Audit Procedures

................................ ................................ ................................ ............................... 17

11. Preventive Maintenance

................................ ................................ ................................ ............................... 18

12. Specific Routine Procedures Used to Assess Data Precision, Accu racy, and Completeness

.............. 19

13. Nonconformance/Corrective Action

................................ ................................ ................................ ........... 20

13. 1 Nonconformance

................................ ................................ ................................ ................................ 20
13.2 Corrective Action

................................ ................................ ................................ ............................... 20

14. Quality Assurance Reports to Management

................................ ................................ .............................. 22

14.1 Measurement Data Reports

................................ ................................ ................................ .............. 22
14.2 Reports of Significant QA Problems and Recommended Solutions

................................ ........... 22



### Appendices Appe ndix A: Laboratory System Quality ManualJohn Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 iii John Deere 

# Introduction

This Quality Assurance Project Plan (QAPP) has been prepared to support the Sampling and Analysis Plan (SAP) for the delisting of F006 and F019 sludge filter cake at the John Deere facility in Des Moines, Iowa. The purpose of this plan is to specify the data quality objectives, sample collection procedures, data analysis procedures, and general project pro cedures such that the objectives of the SAP are achieved. In accordance with the SAP, this plan is designed to comply with the following:

• Section 10 of the USEPA publication, “Test Methods for Evaluating Solid Waste,” third edition (or as updated) (SW

- 846 );

• “EPA Requirements for Quality Assurance Project Plans” (EPA QQ

- R5); and

• EPA Region 6 Delisting Program Guidance Manual for the Petitioner, March 1996.

The change with this revision is to incorporate the delisting for F019 hazardous waste into the delisting plan.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 1 John Deere 

# 1. Project Description

1.1 Overview

A sa mpling and analysis plan has been developed for the purpose of characterizing sludge filter cake from the wastewater treatment system of the John Deere facility in Des Moines, Iowa. The results of this investigation will be used to determine if this RCRA

- listed waste (F006) can be delisted. This can be determined by demonstrating that this waste: 1

- does not exhibit any of the criteria for which it was listed;

2

- does not exhibit any other factors (including additional constituents) that could cause it to be hazardous;

3

- will not contribute to the contamination of ground water; and 4

- does not pose any other threat to human
health or the environment.

John Deere produces a dewatered sludge filter cake generated from wastewater treatment plant filter pres s. John Deere treats wastewater associated with an electroplating process, therefore the resultant filter cake from the wastewater treatment process is a listed hazardous waste according to RCRA (40 CFR 261.31). The

F006 and F019 filter cake drops from a filter press into a 25 cubic yard roll

- off container. The filter cake is a
reddish

- brown solid (approximately 40% solids) and has a density of approximately 80 to 85 pounds per cubic foot. The filter cake contains metal hydroxides.

The John Deere facility operates on a continuous basis (24 hours per day, 7 days per week). Wastewater from applicable processes and operations (e.g., washing, cleaning, painting, plating) flows to the WWTP continuously. The facility produces limited types of agricultu ral equipment with similar operations with limited changes throughout the year and over time. As a result, there is limited potential for variability from the incoming wastewater stream over time.

The WWTP treats and discharges approximately 110,000 gallo ns of wastewater per day. Typical filter cake produced includes two cycles per day for one or two days per week. The filter cake container will hold filter cake from about 12 treatment cycles and takes 2 to 3 weeks to fill.



## 1.2 Sampling Strategy

Table 1 of the Sampling and Analysis Plan identifies all raw materials used at the plant. Based on knowledge of raw materials as well as historical data on the sludge filter cake, a sampling strategy to be implemented for the purposes of this assessment is shown in Table 2 of the Sampling and Analysis Plan.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 2 John Deere 

# 2. Project Organization and Responsibility

Sampling activities will be initially performed by MWH Americas, Inc (MWH). MWH will train the John Deere staff on the sampling methodology and the John Deere staff will take over sampling after the initial sample collection. The following are definitions of the responsibilities of the key project personnel:



## 2.1 Project Director The project direct or will be responsible for all aspects of the project including overall quality assurance, technical, administrative, and budgeting objectives. The Project Director will also coordinate the interaction between the Task Managers that project deliverables a nd the project schedules are being met.



## 2.2 Quality Assurance Officer The Quality Assurance Officer (QAO) will be responsible for the following:

• Administration of the project QAPP

• Day

- to

- day supervision of quality assurance

• Notification of personnel of nonconf ormances and changes in quality assurance procedures

• Determination of audit schedules

The QAO will provide the necessary guidance and audits. The QAO has the authority and freedom to identify quality problems; to initiate, recommend, or provide corrective actions; to verify the implementation of the corrective actions; and will initiate project audits, as required for the project.



## 2.3 Health and Safety Coordinator The Health and Safety Coordinator is responsible for the development and implementation of the He alth and Safety Program, as applicable to this project.



## 2.4 Laboratory Personnel The key laboratory personnel for this project will be the Laboratory Director and the Laboratory Quality Assurance Manager. The analytical laboratory Technical Director will be r esponsible for execution of the analytical testing program for this project. John Deere has selected Test America of Chicago , located at 2417 Bond Street University Park, Illinois 60484 to conduct the sample analysis. A copy of laboratory qualification, capabilities, and certifications are included with their Laboratory System Quality Manual in Appendix A. (electronic copy enclosed).John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 3 John Deere



# 3. Quality Assurance Objectives for Measurement Data

The overall QA objective for the sampling and analysis progr am is to provide procedures which, when followed properly, will result in laboratory and field data generated during this investigation that are technically sound, statistically valid, and properly documented in order to demonstrate that the John Deere
fil ter cake does not meet the hazardous characteristic for which it has been listed. Specific procedures to be utilized for sampling, laboratory analyses, data reporting, and data validation, are presented in other sections of the QAPP. The primary purpose of this section is to define statistical acceptance criteria for chemical data generated by the analytical laboratory.

A primary component of data quality is selection of the appropriate quality assurance (QA) objective levels for the intended data use. Q A levels, as described in “Data Quality Objectives for Remedial Response Activities (EPA, March 1987) are as follows:

• Level I

– Field screening or analysis using portable instruments. Results are often not compound

specific and not quantitative, but are a vailable in real

- time.

• Level II

– Field analysis using more sophisticated portable analytical instruments; in some cases, the instruments may be set up in a mobile laboratory on site. There is a wide range in the quality of the data that can be generated that is dependent on the use of suitable calibration standards, reference materials and sample preparation equipment. Results are available in real

- time or several hours.

• Level III

– Analyses are performed in an off

- site analytical laboratory. Level III analyses may or may not use Contract Laboratory Program (CLP) procedures. The validation or documentation procedures required of CLP Level IV analyses are not required or are provided in a summary type
format.

• Level IV

– CLP routine analytical services. Analyses are performed in an off

- site CLP analytical laboratory following CLP protocols. Level IV is characterized by rigorous QA/QC protocols and
documentation.

Data collected as described in the SAP will be consistent with the Level III DQOs. The quali ty of data generated for this sampling program characterized in terms of precision, accuracy, completeness, representativeness, and comparability. Further discussion on the specific routine procedures used to document data precision, accuracy, and complet eness are presented later in this QAPP. These data characteristics are defined in the following subsections.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 4 John Deere 

## 3.1 Precision Precision is defined as a measure of mutual agreement among individual measurements of the same property, usually under prescribed conditions. Precision evaluation indicated whether the reproductibility of the analytical result is compromised due to analy tical techniques, sample matrix interferences, or other
factors.

Precision expected for the laboratory results is addressed in the discussion of analytical uncertainty below.



## 3.2 Accuracy Accuracy is defined as the degree of agreement of a measurement (or an a verage of measurements of the same thing) with an accepted true value, usually expressed as:

• The difference between two values,

• The difference relative to the reference or true value, or

• The ratio of the difference to the reference or true value

For the analytical uncertainty associated with the TCLP metals analyses, the greatest uncertainty is expected with the Matrix Spike (MS) recoveries. Other uncertainties, such as lab control samples and internal process check samples such as initial and con tinuing calibrations (ICV/CCV) are tighter than the MS/MSDs due to their absence of potential interference. The following control limits have been established for Metals

.
Matrix Spike Recovery: 75%

- 125% Lab Control Sample Recovery: 80%

- 120% ICV/CCV: 90 %

- 110% (Initial and Continuing Calibration)

The widest uncertainty will be associated with the MS at +/

- 25% of the true value. Given the TCLP waste criteria limits, and the sensitivity of the instrument, the laboratory is expected to generate reporting limits
well within the TCLP metals limits.

For the organics, low recoveries for MS and other internal matrix control compounds are more common, and
therefore the control limits are wider depending on the compound. However, the samples will be analyzed
for both Total and TCLP constituents which will furnish an additional check on results by using the 20

- times rule of dilution from the Total to TCLP (even with low MS recoveries).



## 3.3 Completeness Completeness is defined as a measure of the amount of valid data o btained from a measurement system compared to the amount that was expected under normal conditions. To determine completeness, theJohn Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 5 John Deere percentage of valid (i.e., acceptable) data obtained, as judged by the precision and accuracy objectives, is compared to the total amount to data collection, resulting in a validation percent.

Valid data are expected to exceed 90% of the collected data for the testing program.



## 3.4 Representativeness Representativeness expresses the degree to which data accurately and precisely rep resent a measured characteristic of a population, parameter variations at the sampling point, a process condition, or an
environmental condition.

The degree of representativeness is dependent upon the objectives of the measurement results. Thus, represent ativeness can be classified into the following four “objective levels”:

• Level 1

– Only representative of the point of sampling.

• Level 2

– Sample is part of a set and represents a defined area or portion of land or water

– not just the point of sampling.

• Le vel 3

– Sample represents a relationship between the source of contamination and the location sampled.

• Level 4

– Nonrepresentative sample

– the sample is used for assessment purposes only.

The project data are intended to demonstrate that the samples are r epresentative of the Filter Cake from the wastewater treatment facility filter press. This is classified as the Level 3 standard. The sampling method is discussed in the Sampling and Analysis Plan.



## 3.5 Comparability Comparability of the data to be collected during the assessment will be achievable. For this project, measurement data generally will be calculated and reported in units consistent with the USEPA CLP protocols and standard practice to allow comparability of data already collected with any new dat a. In addition, the data will be compared to RCRA hazardous waste toxicity characteristic concentrations as defined in 40 CFR 261 and those calculated using the USEPA Composite Model for Landfills (CML).John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 6 John Deere 

# 4. Sampling Procedures

The sampling and analysis program has been designed to meet the specific objectives identified in Section 3.0. The discussion in this section includes general documentation requirements as well as specific data forms required for the various types of samples. Sample prep aration and handling are addressed, as well as decontamination of sampling equipment. Sample locations are described in the Sampling and Analysis Plan for Delisting of F006 and F019 Sludge Filter Cake.



## 4.1 General Documentation Requirements For each day duri ng which samples are collected, a Field Activity Daily Log will be completed by the field staff. It will be the responsibility of the Project Director to verify that this record is completed. Information to be provided on the log includes, as appropriate :

• Field activity subject;

• General work activity;

• Unusual events;

• Changes to plans and specifications; and,

• Field reagents used.

The Field Activity Data Log will be signed by the individual who prepares it. Field Activity Daily Logs will
be submitted on a weekly basis to the Project Director. Following review, the logs will be placed in the project file.

A photographic record of site operations will be prepared. Photographs of the following may be obtained:

• General site layout;

• Waste stream generation poi nt;

• Sampling;

• Health and safety monitoring, if applicable; and

• Other items of interest.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 7 John Deere Photographs will be identified with the project number, date, and a brief description. The photographs will be placed in the project file.

Other data forms used for do cumenting sample data and field tests are described in the subsections which
follow: Chain

- of

- custody documentation is described in Section 5.0.



## 4.2 Sampling Sampling will be completed in accordance with the procedures and protocols specified in the Sampling and Analysis Plan for delisting of F006 and F019 Filter Cake.



## 4.3 Sample Preparation and Handling

4.3.1 Sample Containers and Cleaning Requirements Sample containers will be supplied by the analytical laboratory such that sufficient sample volume is
obtained for lab oratory analysis and associated laboratory QA/QC procedures. The containers which will be used for various sample types and analyses are indicated in Appendix A, Section 6. Lot numbers of the containers will be recorded by the analytical laboratory.



### 4.3.2 Samp le Preservation and Holding Times Since certain constituents can change chemically with time, it will be necessary to preserve individual samples to maintain the integrity of time

- dependent constituents. The preservation requirements for various types of samples are indicated in Appendix A, Section 6.

Preservation includes maintaining the samples in chilled conditions (4 o C) once they have been obtained.

The maximum recommended holding time for properly preserved samples are provided in Appendix A. All samples will require storage at 4 o C prior to analysis to prevent dehydration. The laboratory analysis will be performed within specified holding times to allow the validity of the analytical results.



### 4.3.3 Sample Labeling and Handling Sample containers will ha ve blank labels, as supplied by the laboratory. The labels will be filled out at the time of sample collection by the field personnel performing the sampling. Information marked on the label
will include:

• Sample Identification Number;

• Collector’s Name;

• D ate of Collection;

• Type of SampleJohn Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 8 John Deere • Preservatives Used;

• Analysis to be performed; and,

• Number of Bottles in Sample Set.

Samples will be transported to the laboratory in durable, secured metal or plastic coolers or laboratory

supplied, secured waterproof meta l or plastic containers. Containers will be shipped via common overnight
carrier or hand

- carried within 24 hours of collection. Chain

- of

- custody documentation (Section 5.0) will accompany the samples.



## 4.4 Documentation Decontamination of equipment used for s ampling will be carefully performed to minimize any possibility of cross contamination through the use of tools and equipment. Sampling equipment that is not disposable will be decontaminated prior to initial use in accordance with the details specified i n the Sampling and Analysis Plan for Delisting of F006 and F019 Filter Cake.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 9 John Deere 

# 5. Sample Custody

5.1 Field Procedures

A chain

- of

- custody record will be established and maintained to document sample possession from the time of collection to delivery to the laboratory. Once samples are received by the laboratory, they will be handled under the laboratory internal chain

- of

- custody procedures. Personnel obtaining samples in the field will
initiate a chain

- of

- custody record by reporting the following m inimum data as the samples are collected:

• Name of Sampler;

• Sample Identification;

• Data and Time Collected;

• Amount Collected; and

• Containers Used.

Other information such as preservatives used and analyses required shall be indicated as appropriate. Sample chain of custody forms will be placed in waterproof bags and taped to the underside of the cooler lids. In addition to the chain of custody record, a sample

- collection form will be completed at the time of the sampling to record sample location a nd other parameters associated with sample acquisition.

Subsequently, at each change of possession, the chain

- of

- custody record will be signed by the person relinquishing the samples and the person receiving the samples. This could occur as the samples ar e transported to the laboratory, or when the samples are received at the analytical laboratory.

Once the sample containers have been filed and labeled, custody seals will be placed around each individual sample container and cap, so that any disturbance to the sample prior to analysis can be detected. Samples will then be carefully packed in coolers made of waterproof metal or plastic. Cushioning material such as vermiculite will be added to the cooler to prevent breakage. Sufficient amounts of ice packs will be added to maintain a sample temperature of 4 o C. The shipping container (e.g., cooler, Styrofoam box) will be sealed with custody seals. At a minimum, a custody seal will be placed on the diagonal corners of the container lid
to seal the lid to th e main portion of the shipping container. Depending upon the shipping container, additional custody seals will be used as necessary to prevent unnoticed tampering with the samples. Coolers will be secured with nylon or fiber strapping tape in addition to custody seals and will be shipped within 24 hours of collection via an overnight carrier service.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 10 John Deere If samples on a chain

- of

- custody record are split and sent to separate destinations, multiple copies of the records will be generated with a clear indication of which sample went to which destination.

When the samples are received at the analytical laboratory, the person receiving the samples will note the condition of the custody seals found on both the coolers and sample containers. The person assuming

cust ody of the samples will do so by signing the chain of custody record after accounting for all samples indicated on the record. At this point, the chain

- of

- custody records will be placed in the laboratory project file and copies will be transmitted to the Project Director.



## 5.2 Laboratory Procedures The laboratory will designate a sample custodian for the project. This individual will be authorized to sign
chain

- of

- custody records upon sample receipt and will be responsible for verifying that the custody seals are
intact.

The project samples will be stored at the laboratory for a period of time related to they type and nature of the samples. Maximum laboratory holding times for various parameters are provided in Appendix A. When the storage times have expired, the laboratory will dispose of the samples in accordance with applicable regulations.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 11 John Deere 

# 6. Calibration Procedures

Calibration procedures which will be followed for sample analysis are discussed in Appendix A, Laboratory System Quality Manual. Calibration information is recorded in a laboratory log book. The laboratory’s calibration procedures for the analytes of interest are included in Appendix A.

.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 12 John Deere 

# 7. Analytical Procedures

Laboratory analysis will be completed in accordance with United States Environmental Protection Agency Test Methods for Evaluating Solid Waste (SW

- 846, most recent revision). Table 3 of the Sampling and Analysis Plan for Delisting of F006 and F019 Filter Cake lists the analytical methods to be followed in
evalu ating the sludge filter cake. Changes in methodology due to higher or lower than anticipated concentrations being detected may change the preparation or analytical method use.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 13 John Deere 

# 8. Data Reduction, Validation, and Reporting

8.1 Data Reduction

The analytical laboratory will utilize computer software to calculate sample concentrations for many parameters. A response factor or standard curve will be generated from the calibration standards and applied to, the absorbance, peak height, or area measured by the laboratory instrument to calculate the sample concentration. This value will be corrected for any dilutions or other preparations. Calculations that are not performed by computer programs will be performed manually by the analyst. The analyst wi ll employ the same methodology used in the computer software. Corrections for dilutions and other preparations will be done manually. The data reduction methods are described in Appendix A.



## 8.2 Data Validation and Assessment The primary objective of this pro ject is to provide data of sufficient quality for making quantitative determinations that demonstrate that the John Deere sludge filter cake does not exhibit the hazardous characteristic for which it has been listed. It is anticipated that by using USEPA SW

- 846 procedures the laboratory will provide reliable and acceptable data to adequately characterize the John Deere sludge filter
cake.

The analytical laboratory will perform review of the data prior to submittal to John Deere. After the laboratory revie w, validation of the sample results, independent of the laboratory, will be conducted. Guidelines described in USEPA Standard Operating Procedures, in the reference methods, CLP guidelines, and this plan will be used in the results validation by the labor atory.

The USEPA Standard Operating Procedure which will be utilized in the data validation is SOP No. HW

- 2, Evaluation of Metals Data for the Contract Laboratory Program, Revision 13, (9/06).

The laboratory will provide John Deere with a data summary pack age that will contain the following information when applicable:

• Analytical results,

• Initial and continuing calibration verification results;

• Laboratory control sample results,

• Method and field blank results,John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 14 John Deere • Duplicate sample analysis,

• Spike sample analysi s, and

• Holding times

The information in the data summary package will be used by an independent consultant to validate the results. A detailed description of the data summary package is provided in Appendix A.



### 8.2.1 Field Blanks In the validation process, field QC practices consisting of trip blanks and equipment blanks will also be reviewed. Due to the complexity of environmental samples, no formal evaluation procedures can be established for reviewing field QC, and only subjective guidelines are provided in t his section. The objective of field QC will be to monitor the performance of the field and laboratory personnel. Field blanks (trip and equipment) will be used to monitor for contamination introduced by sampling personnel, although laboratory

- introduced contamination will also be indicated.

Except in the case of gross errors, field blanks will not be the basis of acceptance or rejection of data, but
rather will serve as additional information for evaluation of the data.



### 8.2.2 Holding Time The holding time of sa mples (time of collection to time of sample preparation and analysis) will be reviewed to verify compliance with CLP requirements. If holding time is exceeded, the sample will be flagged as “estimated” in accordance with CLP guidelines.



## 8.3 Data Reporting

The analytical laboratory will follow CLP procedures for reporting compounds. In general, soil sample data will be reported on the basis in which it was disposed. Concentrations will be reported in accordance with the reference method. Reported concentrati ons will not be corrected for contaminants found in associated
blanks.



### 8.3.1 Qualifiers The analytical laboratory will use CLP

- defined qualifiers in reporting data.



### 8.3.2 Data Reporting System Sample data will be entered into a computerized sample data management syst em starting when the samples are received by the laboratory (Section 6.0). After analysis, results will be entered into the system by a chemist or technician. The laboratory data reporting system is described in Appendix A.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 15 John Deere John Deere will receive the sa mple results and a summary of the associated QC data. The QC data received will include results for method blanks, duplicates, matrix spike recovery, and surrogate recovery. After the data are validated the results will be reported in accordance with the guidelines previously discussed.



## 8.4 QA Data Validation Summary Report A QA Data Validation Summary Report will be prepared after the assessment is complete. This report will summarize QC data. Performance and system audits, significant QC problems encountered and corrective action taken, and QAPP modifications will be reported in the QA Data Validation Summary Report.

QA/QC values calculated by the laboratory will be compared to acceptable ranges in the data validation guidance.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 16 John Deere 

# 9. Quality Control

A quality control (QC) program will be implemented so that consistent results of known and documented quality can be obtained. Laboratory quality control measures are described in Appendix A. Laboratory QC procedures which will be used for this project i nclude:

• Initial calibration and calibration verification

• Laboratory Control Samples

• Matrix spikes analysis

• Duplicate analysis

• Method blanks

• ICP interference check sample

The above listed procedures are described in Appendix A.



## 9.1 Field Duplicate Samples

A fie ld duplicate sample is a sample prepared by dividing a sample into two aliquots. Duplicate samples will be handled as individual samples. The laboratory will not be made aware that a sample is a duplicate sample.



## 9.2 Field Blanks Field blanks are aliquots of analyte

- free water brought to the field in sealed containers and transported back to the laboratory with the sample containers. Equipment blanks are a check on sampling device cleanliness and will be used for this project. Equipment blanks will be opene d in the field and the contents will be poured over the sampling mixing bowls (disposable scoops will be used to collect the samples, and not reused; therefore their cleanliness is not an issue and returned to the laboratory as a sample). Sufficient

water will be taken to the field so that the equipment blank sample container is completely filled. The equipment blank will be handled in the same manner as the other samples, including to 4 o C.



# 10. Audits

10.1 Field Operations Audit A field operations audit will be co nducted during initial sampling/field activities to verify that sampling procedures are correctly followed. The field operations audit will involve an on

- site visit by the QualityJohn Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 17 John Deere Assurance Officer or designated representative. Items to be examined may, as appropriate, include the following: availability and implementation of approved work procedures; calibration and operation equipment; labeling, packaging storage, and shipping of sample obtained; performance of documentation and checking; subcontractor performance; and variance documentation.



## 10.2 Audit Procedures Audits will be performed on the basis of a written checklist prepared prior to the audit. The checklist shall be developed to allow the review of necessary items and to document the results of the audit. During the audit and upon its completion, the auditor will discuss any findings with the individuals audited and will

cite corrective actions to be initiated.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 18 John Deere 

# 11. Preventive Maintenance

The analytical laboratory will keep instrument log books which document maintenance schedules, dates, maintenance performed, and details of each maintenance action. Routine maintenance will be performed by laboratory personnel in accordance with manufacturer recommendations. Service agreements and preventative maint enance contracts are routinely secured by the laboratory for all critical instruments and equipment. These agreements provide for regular checks by qualified service personnel. Critical spare parts
are maintained in accordance with manufacturer recommend ations.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 19 John Deere 

# 12. Specific Routine Procedures Used to Assess Data Precision, Accuracy, and Completeness

Precision and accuracy for this project will be assessed through the analysis of duplicates, laboratory control samples, and spike samples. The Laboratory Syst em Quality Manual (Appendix A) summarizes the QC analyses including precision, accuracy and completeness of data.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 20 John Deere 

# 13. Nonconformance/Corrective Action

13.1 Nonconformance Nonconforming items and activities are those which do not meet the project requirements specified in the Quality Assurance Project Plan. Nonconformances may be detected and identified by:

• Project Staff

During investigation and testing, supervision of subc ontractors, and preparation and verification of analyses

• Laboratory Staff

During analysis, internal quality control, and data validation activities

• Quality Assurance Officer

As the result of audits and other quality assurance activities

Each nonconformance shall be documented by the personnel identifying or originating it. Documentation will, as appropriate, include:

• Identification of the individual(s) identifying or originating the nonconformance.

• Description of the nonconformance

• Method(s) for correcting the nonconformance (corrective action) or description of the variance granted.

• Schedule for completing corrective action.

The nonconformance documentation shall be submitted to the John Deere Project Director, who will be responsible for notification of o ther staff and regulatory agencies, as appropriate.



## 13.2 Corrective Action Corrective actions pertaining to field activities will be defined when specific nonconformances are identified
and documented.

Corrective actions pertaining to analytical procedures ar e directly related to the calibration, internal quality control, and data validation.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 21 John Deere The authority to implement planned corrective action when nonconformances are detected or control limits are exceeded rests with the Project Director for field and overal l project operations and with the Laboratory Quality Assurance Manager for laboratory operations.John Deere, Des Moines IA Revised June 2012

Project Integration, Inc. QAPP Project No. 101004C1 22 John Deere 

# 14. Quality Assurance Reports to Management

Reports detailing the results of audits and the performance of data measurement systems will be submitted to Project Director. These results will include:

• Assessments of measurement data accuracy, precision, and completeness

• Results of system audits

• Results of performance audits

• Significant QA problems and recommended solutions

A description of these reports is provided in the following paragraphs.



## 14.1 Measurement Data Reports An assessment of measurement data precision, accuracy and completeness will be summarized in a report. This report will be prepared by the analytical Laboratory Quality Assurance Manager and w ill be submitted to the Project Director. At the completion of the project, the results of previous reports will be summarized in a final report.



## 14.2 Reports of Significant QA Problems and Recommended Solutions Significant quality assurance problems will be d ocumented as finding in audit reports. Any such findings will require written documentation and solutions from the Project Director and the Quality Assurance
Officer.