# Memorandum

Date: December 1 , 2009

To: Ira Domsky, Deputy Director

Air Quality Division

Through : Steven Peplau, Section Manager

Air Assessment Section

From: Sandra Wardwell, Unit Manager

Data Management & QA Unit

Subject: Evaluation of QA/QC information fo r Pb samples collected by EPA in Hayden and

Winkelman

EPA Region 9 Superfund began environmental sampling in the Hayden

- Winkelman area in

November 2006 . Air quality samples of particulate matter were analyzed by a contract laboratory ( Chester LabN et) . The analytical results for lead (Pb) from samples collected in 2006

- 2008 were used by ADEQ to recommend the Hayden area as nonattainment for Pb under the revised NAAQS. ADEQ reported the se data collected at the EPA Superfund sites in Hayden and

Winkel man to the EPA Air Quality System (AQS) database on August 27, 2009, listing EPA Region 9 as the Primary Quality Assurance Organization (PQAO) and ADEQ as the Reporting Organization.

This document describes ADEQ's assessment of the quality assurance proc edures used by EPA Region 9 Superfund for collection and validation of the air quality samples.

DOCUMENTS

Project Plans

The EPA contracted CH2M Hill to conduct site characterization and remedial activities at the ASARCO LLC Hayden Plant Site in 2005. CH2 M Hill submitted a sampling and analyses p lan to EPA consisting of 3 documents in November 2005:

Q uality Assurance Project Plan (QAPP) Field Sampling Plan (FSP) Data Management Plan (DMP)

The QAPP was prepared following EPA guidelines: EPA guidance for Q uality Assurance Project Plans (2002) EPA Requirements for Quality Assurance Project Plans (2001)Ira Domsky

December 1, 2009

Pa ge 2 of 4

Collection of air samples began in November 2006. The QAPP describing Project Management/Data Quality Objectives, Measurement Data Acquisition, Assessment/Ov ersi gh t, and Data Validation and Usability was in place prior to the start of sampling.

CH2M Hill was the contractor for the remedial investigation from 2005 to 2009. ITSI assumed the contract in 2009. ITSI added addendums to the sampling and analysis pl an documents to change the responsible parties listed in the plans.

These documents were obtained from the ITSI ftp website.

INSTRUMENTATION

Two Partisol

- Plus Model 2025 Sequential Air Samplers are being used for this project. This sample r has an EPA P M10 reference designation of RFPS

- 1298

- 127. The designation was given in December, 1998. These samplers also meet the CFR requirements for PM 10 coarse samplers ( PM10 C ) since a Federal Register notice published June 2, 2009 (page 26395), announced this sampler received designation for coarse (PM10

- PM2.5) sampling as part of a pair of samplers with a new reference designation of RFPS

- 0509

- 176. This sampler meets the requirements of 40 CFR 50 Appendices Q and R.

Field Sheets

Calibration and flow checks for the air quality samplers at the Winkelman and Hayden monitoring sites were conducted as scheduled in the QAPP. Review of the field sheets indicate s

o ne monthly flow check could not be completed due to a pump failure at the Hayden monitor (August 21, 2 008). Chain of custody information for the samples collected since the last good check (August 18, 2008) were reviewed to determine if the prior samples were valid. All samples are valid; the pump failure occurred on the day of the check. Consequently, rep airs to the sampler were made and the next valid sample occurred on September 12, 2008.

These documents were obtained from the ITSI ftp website.

Chain of Custody Forms and Laboratory Reports.

C hain of custody information was collected for each sample

. T h is information is included in the Laboratory report s , which also include a statement certifyi ng the validity of the results, and precision, accuracy, and replicate results. The reports also include a Transmittal Memorandum

with each batch of filters from the consultant to the laboratory. This memorandum lists the valid filters to be processed and also lists the invalid filters.

These reports were obtained from ITSI.Ira Domsky

December 1, 2009

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DATA

The DMP states in Section D.1, 'All data for all parameters will undergo two l evels of review and validation: 1)at the laboratory, and 2) outside the laboratory by the EPA quality Assurance Manage ment Section or their designee.' The laboratory prepared and shipped all filters to the consultant. The consultant loaded the samplers an d collected the filters after the sampler ran. The consultant's transmittal memorandum accompanying the filters and chain of custody information to the laboratory lists valid and invalid filters. This indicates the field personnel were invalidating samples if the sampler was not operating correctly or if the filter was damaged during loading and unloading of the sampler. The laboratory analyzed the valid filters.

A spreadsheet of validated data was obtained from John Hillenbrand, EPA Region 9 in May,

2009 . This file lists analytical results for samples collected 10/22/2006 through May 13, 2009.

These results had been reviewed and certif ied by the contract laboratory (see Chain of Custody Forms and Laboratory Reports above). ADEQ assumed EPA reviewed the da ta results since validation flags, graphs and other information was included in the spreadsheet.

Preliminary Report CH2M Hill submitted a Technical Memorandum to EPA on December 31, 2008 entitled, "Preliminary Evaluation of PM10 and Metals Concentrations from October 2007 to December

2008 in Ambient Air at the H ayden and Winkelman Monitoring Stations". The report used results from samples collected 11/13/2007 through 11/30/ 2008. Several samples are label ed 'rejected' with no reason given in the tables of a nalytical and meteorological results. Footnote 28

to Tables 1 and 2 states: " This table should be considered preliminary and will be revised based on incoming data, final data validation and QAQC. "

The report identifies three 3

- month means in exceedance o f the NAAQS at the Hayden monitoring station in 2008.

The report was obtained from EPA Region 9, John Hillenbrand.

CONCLUSIONS

1. A QAPP was submitted to EPA in November 2005, prior to the start of sampling in October 2006. This complies with the EPA requirement for air monitoring programs to have an approved QAPP prior to the start of sampling.

2. Addendums to the QAPP documents were made by the new consultant in March 2009.

3. Instrument checks were performed as described in the Field Sampling Pl an. Copies of the

checks are available from ITSI.Ira Domsky

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4. Laboratory reports contain chain of custody information, transmittal information, and laboratory quality control data along with the analytical results.

5. ADEQ's review of the above information con cludes the lead data provided by Region 9 Superfund has experienced at least 3 levels of validation, (sampler field checks and verification of sample validity immediately after collection, laboratory analysis and quality control checks of laboratory proced ures, and review by EPA Superfund staff )

. These procedures are comparable to the procedures fol lowed by ADEQ air assessment staff.

6. The preliminary report by CH2M Hill omitted several sample results that were included in the EPA spreadsheet. CH2M Hill footnotes do not indicate why those samples were omitted but do state that additional validation and QA/QC could change the results included in the report. ADEQ review of all the QA/QC documentation supports EPA’s determination that the samples and the da ta generated from those samples were valid.

7. All violations of the 2008 Pb NAAQS calculated by ADEQ and included in the recommendation to designate the Hayden area as nonattainment are accurate and valid.