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 for 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 LabNet). 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 these data collected at the EPA Superfund sites in Hayden and 

Winkelman 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 procedures 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. CH2M Hill submitted a sampling and analyses plan

to EPA consisting of 3 documents in November 2005:

Quality Assurance Project Plan (QAPP)

Field Sampling Plan (FSP)

Data Management Plan (DMP) 

The QAPP was prepared following EPA guidelines:

EPA guidance for Quality Assurance Project Plans (2002)

EPA Requirements for Quality Assurance Project Plans (2001)
Ira Domsky

December 1, 2009

Page 2 of 4

Collection of air samples began in November 2006. The QAPP describing Project 

Management/Data Quality Objectives, Measurement Data Acquisition, Assessment/Oversight, 

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 plan 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 

sampler has an EPA PM10 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 

( PM10C ) 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 indicates

one monthly flow check could not be completed due to a pump failure at the Hayden monitor 

(August 21, 2008). 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, repairs 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. 

Chain of custody information was collected for each sample. This information is included in the 

Laboratory reports, which also include a statement certifying 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

Page 3 of 4

DATA

The DMP states in Section D.1, 'All data for all parameters will undergo two levels of review 

and validation: 1)at the laboratory, and 2) outside the laboratory by the EPA quality Assurance 

Management Section or their designee.' The laboratory prepared and shipped all filters to the 

consultant. The consultant loaded the samplers and 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 certified by the contract laboratory (see Chain of Custody 

Forms and Laboratory Reports above). ADEQ assumed EPA reviewed the data 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 Hayden and Winkelman Monitoring Stations". The report used 

results from samples collected 11/13/2007 through 11/30/2008. Several samples are labeled 

'rejected' with no reason given in the tables of analytical 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 of 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 Plan. Copies of the 

checks are available from ITSI.
Ira Domsky

December 1, 2009

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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 concludes 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 procedures, and review by EPA Superfund staff). These 

procedures are comparable to the procedures followed 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 data 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.