## Technical System Audit

ASARCO Hayden Plant Site

Ambient Air Monitoring Program

January 22

- January 2 8

, 2014

Conducted by

Quality Assurance Office

Management and Technical Services Division

US EPA Region 9

75 Hawthorne Street

San Francisco, California 94105

Final Report: April 2014ii INDEX

GLOSSARY OF ACRONYMS

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

EXECUTIVE SUMMARY ...............................................................................................2

TSA ACTIVITIES .............................................................................................................4

OVERVIEW OF AIR MONITOR ING PROGRAM

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

GENERAL / SIGNIFICANT FINDINGS .....................................................................10

NETWORK DESIGN FINDINGS

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

FIELD OPERATIONS FINDINGS

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

LABORATORY OPERATIONS FINDINGS

................................ . .............................4 4

DATA MANAGEMENT FINDINGS

...................... ....... ............................................... 5 6

QUALITY ASSURANCE FINDINGS

............................ ...... ......................................... 6 41 GLOSSARY OF ACRONYMS

ADEQ.........................................

. Arizona Department of Environmental Quality

ARARS........................................ Applicable or Relevant and Appropriate R equirements

AQS............................................. Air Quality System

CFR.............................................. Code of Federal Regulations

DMS............................................. Data Management System

DQO..........

................................... Data Quality Objective

EPA.............................................. Environmental Protection Agency

FEM............................................. Federal Equivalent Method

FRM.....................................

........ Federal Reference Method

IML............................................. Inter

- Mountain Laboratories

NAAQS........................................ National Ambient Air Quality Standard

NATTS......................................... National Air T oxics Trends Stations

NFG..............................................EPA National Functional Guidelines for Data Validation

Pb................................................. Lead

PM............................................... Particulate Matter

PM 2.5

............................................ Particulate Matter with aerodynamic diameter ≤ 2.5 μ m

PM 10

............................................. Particulate Matter with aerodynamic diameter ≤ 10 μ m

QA................................................ Quality Assurance

QAPP........................................... Quality Assurance Project Plan

QAO............................................. Quality Assurance Office

QC................................................ Quality Control

QMP...............

.............................. Quality Management Plan

SOP.............................................. Standard Operating Procedure

TSA.............................................. Technical System Audit

TSP.............................................. Total Suspended Particulate

XRF.............................................. X

- ray Fluorescence2 EXECUTIVE SUMMARY

This document is a report on the findings of the United States Environmental Protection Agency

(EPA) from a Technical Systems Audit (TSA ) o f the ASARCO Hayden , Arizona (AZ) Plant Site

Superfund ambient air monitoring program. This TSA included an on

- site and laboratory review

and inspection of ASARCO’s ambient air monitoring program to assess its compliance with

applicable or relevant and appropriate r equirements (ARARS) and other EPA Superfund

technical requirements governing the collection, analysis, validation, and reporting of ambient air

quality data. This TSA meets the requirements of 40 CFR p art 58, A ppendix A, § 2.5.

The TSA was conducted by EPA Region 9 Q uality A ssurance Office (QAO) staff on January 22

- 24

, 2014 on

- site and on January 28 , 2014 at Inter

- Mountain Laboratories (IML) in Sheridan

WY

. The audit team interviewed management and staff on specific aspects of the air monitoring

program including network design, field operations, laboratory operations, data handling, quality

assurance and quality control procedures. The audit team also inspected some of t he monitoring

sites operated by ASARCO’s support contracto r

, Haley & Aldrich . The site inspections consisted

of an in terview with the site operator s , review o f station and instrument documentation , and

evaluation of the station siting with respect to EPA requirements . The focus of the laboratory

inspection was on the total suspended particulate (TSP) Lead (Pb) monitoring program and

included some review of the particulate matter (PM) program for mass determinations of PM 10

and PM 2.5

.

The TSA is part of the system by which EPA provides oversight to ensure that ambient air

monitoring programs meet required mi nimum data quality objectives. Other assessments

, such as

network reviews and performance evaluations

, also provide information about the overall quality

of ambient air monitoring data. These assessments enab le organizations to identify and correct

those program elements that may be adversely affecting the quality of ambient air data. The

results of the T SA are summarized here and described in this report, along with recommended

actions to address the findings

. Appropriate use of data is determined based upon EPA’s

evaluation of the weight of evidence. The specific actions to be taken by ASARCO and its

contractor should be worked out with and approved by the EPA Superfund project manager and

documented in a co rrective action plan prepared by ASARCO and its contractor

.

EPA would like to thank ASARCO, Haley & Aldrich, and IML for their assistance and

cooperation during the audit.3

A. Program Strengths:

In a relatively short period of time

, Haley & Aldrich has established a new and complex ambient

air monitoring network that is well run.

 Systems were developed to manage and track a significant quantity of data and tasks

. W ith a few exceptions

, these are working effectively

.

 Systems have been created to handle data streams that are somewhat different than those

that are usually handled by a n environmental consulting firm.

 The project is o rganized so that resource s are managed efficiently to meet sampling

schedules.

 Haley & Aldrich met EPA ’s requests for information and documentation during the audit

.

 Monitoring stations and instruments are well maintained.

B. Program Major Findings:

EPA identified the following areas where ASARCO ’s monitoring program should be

strengthened.

 The documents supporting the program, the Quality Assurance Program Plan ( QAPP )

, Standard Operating Procedures ( SOPs ) , and the Network Design Plan, do not reflect the

current and planned operations and should be updated.

 P roject staff organization should b e realigned to ensure that quality management and data

validation are independent of data collection activities

.

 The chain

- of

- custody process for samples collected on filters is difficult to follow; it

should be better defined and simplified.

 The EPA air m onitoring program requirements , including quality control, data

management, and data validation, should be integrated into the program.

The individual findings are reported in the topic sections of this document

.4 TSA ACTIVITIES

EPA Region 9 Quality Assurance Office (QAO) conducted a Technical System Audit of

ASARCO ’s ambient air monitoring program January 22

– 2 8 , 2014 . The TSA covered the

following program areas:

 General / Quality Management

- Program organization

- Facilities

- Independent quality assurance and quality control

- Planning documents (including Quality Management Plan [ QMP ] , QAPPs, &

Standard Operating Procedures [ SOPs ] )

- General documentation policies

- Training

- Corrective action

- Quality improvement

- External performance audits

 Network Management / Field Operations

- Network design

- Change s to the network design

- Field support

 Laboratory Operations for PM and Pb

- Routine operations

- Quality control

- Laboratory preventive maintenance

- Laboratory record keeping

- Laboratory data acqu isition and handling

 Data and Data Management

- Data handling

- Software documentation

- Data validation and correction

- Data processing

- Internal reporting

- External reporting

EPA tracked supporting documentation for data collected in 2013

.

Joseph Eidelberg and Mathew Plate of the Region 9 QAO conducted the TSA. Participating

managers and supervisors included Bob Miller (ASARCO)

, Steve Rakowski (Haley & Aldrich),

and Mark Groseclose (Haley & Aldrich). Staff from Haley & Aldrich interviewed included

Dane An dersen (Field Technician), Suzanne Bell (Data Validator), Vanessa Boocher (Data &

Sample Management), Trevor Cole (Field Techician), Clayton Orwig (Technical Support), and

Alfredo Sanchez (Field Technician)

. The EPA project manager (John Hillenbrand), the ADEQ

project manager ( Sara Benovic ) , and staff from EPA’s support contract were present on January

22 , 2014 for the general program review and field evaluations.5

The following laboratory personnel were in terviewed at IML in Sheridan, Wyoming: Tom

Patton (Vice President), Michelle LaGory (Q uality A ssurance Manager), Lacy Ketron

(Supervisor), Mary Slipp (Analyst), Maggie Elliot (Quality Officer), and Crystal Bolt (Analyst).

The findings and recommendations in this report are grouped by program area and listed in order

of recommended priority for corrective action

. For each finding, EPA has provided a possible

corrective action. ASARCO / Haley & Aldrich may propose alternative corrective action for

EPA to e valuate. A corrective action plan with proposed resolutions and any applicable

workplan modifications to each finding should be submitted to EPA within 30 days of receipt of

the final TSA report.6 OVERVIEW OF AIR MONITORING PROGRAM

General Program

The ASARCO Hayden Plant Site Administrative Settlement Agreement and Order on Consent

(CERCLA

- 2008

- 13) Provision 32 (Quality Assurance and Sampling) and Appendix A

(ASARCO Hayden Plant Site Statement of Work), Task 2 (Remedial Investigation) and the Final

Sam pling and Analysis Plan, Ambient Air and Source Characterization, Appendix B to the Phase

II Remedial Investigation / Feasibility Study Work Plant Part 1 of 2 (Air), March 2012, specify

the requirement for air monitoring to be conducted by ASARCO. Indepen dent EPA oversight is

required to verify environmental data collection operations meet the requirements of the

Superfund and A ir M onitoring programs.

A mbien t air monitoring operations are managed by Bob Miller, ASARCO

, and Steve Rakowski

, Haley & Aldrich. The field technicians and the data/sample manger operate the network

.

Quality Management

Quality management is the system put in place to oversee quality assurance, quality control and

quality improvement activities. EPA requires that ambie nt air monitoring and Superfund data

collection conform to the quality policy (EPA Order CIO 2105.0) and other applicable policies

and regulations. Each monitoring organization must conform to certain quality management

practices. These include:

 A docume nted quality system in place that meets EPA requirements for QMPs and

QAPPs.

 A quality management function that is independent of air monitoring operations.

 Defined Data Quality Objectives (DQOs), or equivalent systematic planning procedures,

for all monit oring programs.

 Participation in Performance Evaluation Programs.

 Participation in Technical Systems Audits conducted by EPA.

 Use of certified reference materials to standardize monitoring equipment.

Adequate application of these quality management system components is integral to this

monitoring program. Insufficient quality management and control are vulnerabilities that may

prevent EPA from accepting data for use in regulatory decisions.

EPA staff interviewed field, data management, and data validation staff from Haley & Aldrich

on implementation of the q uality management program as la id out in the QAPP. Generally the

Quality Assurance ( QA ) system conformed to the QAPP. However, s everal activities were not

b eing conducted or need to be modified to be consistent with standard air monitoring and

Superfund data collection procedures. Other procedures may need to be revised in the project

QAPP. Most importantly, t he project organization currently does not inclu de independent QA

management. It was noted that EPA’s support contractor, Cornerstone, does provide routine

surveillance of field operations , which can be considered an independent check that partially

addresses this concern

.7

Network Management

The ASARCO Hayden air monitoring network consists of nine air monitoring sites th at house a

variety of air monitors. The following table , provided by Haley & Aldrich, summarizes the air

monitoring sites , instruments and the pollutants monitored.

The origin al QAPP and Network Design Plan specified 15 monitoring stat ions and a background

location. After discussion with ASARCO, nine of the original stations were installed and are

currently operating. An additional two stations are being evaluated for potenti al future

operation. The network design plan has not yet been updated to reflect the actual stations

installed.

EPA visited four monitoring sites ( ST

- 05, ST

- 14, ST

- 23, and ST

- 26)

. All four of these sites are

appropriately sited and meet the siting criteria of 40 CFR Part 58, A ppendix E. However,

several minor siting issues were noted.

Field Operations

EPA verified the adequacy of procedures for instrument operation and sampling media handling

, along with the completeness of required d ocumentation . EPA also verified whether appropriate

Quality Control ( QC ) checks and Q A audits were being performed

.8

Field monitoring is staged in a trailer next to the ASARCO administrative offices. The trailer is

well organized and the system used to track sampling activities is efficient. Monitoring sites are

visited weekly, based on the sampling schedule; additional maintenance is conducted monthly

and quarterly. All monitoring s ites visited were well maintained. Documentation contained

most of th e important details and was completed in a timely manner. However, documentation

that traces who handled samples / sampling media in each step of processing needs to be

improved. Station technicians demonstrated a good level of understanding of station a nd

instrument operations. However, s everal procedures documented in the QAPP were not followed

as specified and do not meet air monitoring requirements.

Inter

- Mountain Laboratories

EPA visited the Inter

- Mountain Laboratories (IML) on January 28, 2014 and interviewed

Michelle LaGory, QA Manager about the quality system and all analysts involved with reporting

lead on TSP filters

.

There was ample evidence that ILM has an adequate system in place to produce data of

acceptable quality for t his project. In addition, the quality system and culture at the laboratory is

excellent.

There are areas of concern having to do with chain of custody, data quality requirements for

subcontracting of PM X

- ray fluorescence ( XRF ) analysis , and data deliverables for pro ject

requirements (level 2 and level 4 definition). These concerns should be addressed by the

A SARCO project team working with the laboratory. There are no resulting deficiencies.

There are conce rns about the detail of the EPA

- approved SOP not being ad equate for a

Superfund project. Recommendations to supplement the ILM SOP are provided.

No technical deficiencies with sample analysis or preparation were found.

Data Management

Data management involves data collection, data validation process, and a data management

system. Haley & Aldrich manages continuous data, sample tracking data, data from PM

instruments and data produced by the laboratories.

Continuous Data

Air quality data measured by the continuous analyzers (PM 10 and meteorological) at the field

stations are transferred to a Haley & Aldrich server(s) on a regular basis. These data have not

been reviewed

.

Laboratory Data9

Laboratory data are received as electronic data deliverables (EDDs) which are tracked with

electronic data tracking and custody documents and uploaded to the Haley & Aldrich database.

Data Validation

Haley & Aldrich has recently initiated the data validation process . Th e original approach taken

was to request full d ata packages from the laboratories and to perform validation consistent with

the EPA National Functional Guidelines for Data Validation (NFGs) . This approach has not

been entirely successful because the labor atories had not had experience in preparing validation

packages for Superfund projects and the methods are not covered in the NFGs. Validation of air

monitoring data in accordance with EPA’s air monitoring Vali dation Templates, which include

field and lab oratory quality control and statistical evaluations, has not been completed to date.

Haley & Aldrich will need to develop standard operating procedures (SOPs) for validation of

data. Additionally, Haley & Aldrich will need to ensure that full data valid ation packages are

complete and the process is well defined.10 GENERAL / SIGNIFICANT

FINDINGS11

Finding # G1

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

The QAPP and SOPs have not been updated to reflect the current procedures being followed

.

Description:

The QAPP and SOPs for the air monitoring portion of the ASARCO RI/FS were prepared for

EPA in 2012, prior to commencement of the current air monitoring activities. These documents

have served their purpose by providing initial procedures for the on

- going air monitoring

activities. There have been modifications to the monitoring design and refinements to the air

monitoring activities that should be included in updates to these documents.

References:

40 CFR Part 300, Section 430

, Remedial investigation/feasibility study and selection of

remedy

(8) Develop sampling and analysis plans that shall provide a process for obtaining data of

sufficient quality and quantity to satisfy data needs. Sampling and analysis plans shall be re

viewed and approved by EPA. The sampling and analysis plans shall consist of two parts:

(i) The field sampling plan, which describes the number, type, and locati on of samples and the

type of analyses; and

(ii) The quality assurance project plan, which describes policy, organization, and functional

activities and the data quality objectives and measures necessary to achieve adequate data for

use in selecting the ap

propriate remedy.

EPA Requirements for QA Project Plans (QA/R

- 5), EPA/240/B

- 01/003, March 2001

For programs or projects of long duration, such as multi

- year monitoring programs or

projects using a generic QA Project Plan, the QA Project Plans shall be reviewed at least

annually by the EPA Project Manager (or authorized representative). When revisions are

necessary, the QA Project Plan must be revised and resubmitted for review and approval.

Guidance for Preparing Standard Operating Procedures , EPA Q A/G

- 6, EPA/600/B

- 07/001,

April 2007

Recommendation to Address Finding:

Update these documents to reflect current procedures.12

Finding # G2

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

The Chain of Custody procedures for tracking filters in the field and laboratory are not sufficient

to protect sample integrity

.

Description:

Samples should be handled under legal chain

- of

- custody procedures. Certified sample media

(i.e., filters and sorbent) should also be handled in a manner that preserves their integrity.

For air sampling methods, such as gravimetric particulate methods, it is unclear when a “filter”

becomes a “sample” (e.g., when it is pre

- weighed for sampling, when it is loaded in to a sampler,

when the sampler begins to operate, or when sample operation ends). For filter

- based air

sampling methods

, filter integrity sh ould be maintained from the time filters are pre

- processed in

the laboratory, and filters should be under chain

- of

- custody when placed in the sampling

instrument so that exposed filters will meet custody requirements.

The current system used by Haley & Aldrich to maintain control of filters is documented on a

number of forms. Some of these forms were not developed with the objective of preserving

sample custody integrity. As a result, sample custody and filter integrity is hard to verify with

existing documentation.

References:

Model Quality Assurance Project Plan for the PM2.5 Ambient Air Monitoring Program at

State and Local Air Monitoring Stations (SLAMS) , EPA

- 454/R

- 98

- 005, April 199813

Recommendation to Address Finding:

R eview the custody procedures so that they ensure that custody and sampling media integrity are

protected and documented through the laboratory and field. A system that simplifies the

sampling and analytical process while preserving integrity should be the goal of any

modif ications.14

Finding # G3

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

The organizational structure of the project does not provide for independent quality management

and data validation.

Description:

There is no independent quality management function identified in the organizational

information provided. Generally organizations conducting ambient air monitoring or Superfund

mon itoring are required to have an independent QA management function. Additionally, data

validation reporting is not currently independent of data collection.

For Superfund projects, data validation is usually pe rformed by an independent third party. In

cases where contractors perform their own validation, the data validators must be

organizationally independent. Independence is normally evaluated and approved by EPA in the

QAPP.

Note that for air monitoring project operations, project st aff typicall y perform initial validation;

final validation is completed by an independent validator and/or evaluated by the independent

QA manager.

References:

Q A Requirements for QA Project Plans (QA/R

- 5), EPA/240/B

- 01/003, March 2001

The project quality assurance manager must be independent of the unit generating the data.

(This does not include being independent of senior officials, such as corporate managers or

agency administrators, who are nominally, but not functionally, involved in data generation,

data use, or decision making.)

Guidance on Environmental Data Verification and Data Validation (QA/G

- 8), EPA/240/R

02/004, November 2002

Data validation is typically performed by person(s) independent of the activity which is being

validated. The appropriate degree of independence is an issue that can be determined on a

program specific basis. At a minimum, it is preferable that the validator does not belong to the

same organizational unit with immediate responsibility for producing the data set.

Recommendation to Address Finding:

S tructure the organization so as to ensure that quality management and Superfund validation

tasks are independent of data collection activities.15

Finding # G4

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

Data Validation does not integrate air monitoring (regulatory) and S uperfund QA elements.

Description:

Data validation for this project must meet the requi r ements of the National Functional Guidelines

for Superfund (NFG) and regulatory ambient air monitor ing . The Haley & Aldrich project

manager and data validator have identified this as an issue that was not properly addressed in the

QAPP. The QAPP does cite both requirements, but does not give guidance as to how both

requirements may be integrated n or does it inclu de SO Ps for performing validation.

For regulatory ambient air monitoring, validation closely evaluates field quality control and

looks at consistency within and between data sets. Laboratory data are validated by means of

stringent quality control and perfor mance evaluation samples. Generally

, all ambient air data

undergo the same degree of validation.

For Superfund, a general review of field quality control is done in conjunction with a rigorous

evaluation of laboratory summary and raw data. Generally

, a percentage of Superfund data is

reviewed in detail (EPA Region 9 Tier 3) and the remain d er undergo es a less in

- depth review

(Tier 1).

It was also noted that data deliverable requirements were not defined. A data deliverables

description should be develo ped for each method

, defining needs for Level 2 and Level 4 (or

EPA Region 9 Tier 1 and Tier 3) data validation packages.

Currently, the data packages for TSP Pb from IML do not include complete raw data that would

allow an independent recalculation of results and complete verification of chain of custody from

the time the filter is conditioned.

No clear deliverables or data validation process are defined for data being analyzed by Chester

LabNet.

For each method

, Haley & Aldrich may need to evaluate project objectives, availability of

established validation procedures, and the ability of the laboratories to develop raw data

packages. Based on this evaluation

, alternatives to performing validation that adheres strictly to

regulatory ambient air and S uperfund QA requirements might be evaluated.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

- 003, May,16

2013

National Functional Guidelines for Superfund Inorganic Methods for Data Review , EPA

540

- R10

- 011, January , 2010

Recommendation to Address Finding:

1) Work with EPA and propose a modified validation methodology that integrates

regulatory ambient air and S uperfund QA validation elements.

2) Define data validation levels and packages.

3) Develop SOPs for data validation and submit these to EPA for approval.17

Finding # G5

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

Oversight of Chester Lab N et Laboratory, a subcontractor to Inter

- Mountain Laboratories (IML),

has not been performed. Oversight of IML has been limited.

Description:

Haley & Aldrich elected to have project analyses performed by the laboratories pre

- selected by

EPA’s support contractor, IML and Chester Lab N et. This may have lead the contractor to

assume that these laboratories were pre

- screened by EPA and did not require substantial

oversight. Since this project has different objectives and scope than previous work performed by

EPA’s contractor, direct laboratory oversight is critical to this project.

Laboratory services from Chester LabNet were arranged as a subcontract to IML. However,

IML was not given specific instructions as to the level of sub

- contract laboratory oversight

required by the project.

Under the current arrangement it is appropriate for Haley & Aldrich to directly overs ee the work

performed by IML. Additionally, many of the methods being performed by IML have strictly

defined quality control standards and performance evaluation components. It should be not ed

that IML had to ob tain laboratory certifications in order to qualify for performing work for this

project.

IML or Haley & Aldrich working through IML could perform oversight of Chester LabNet

. Where methods are complex or not well defined (i.e., metals on filters by XRF)

, oversight,

including performance evaluatio n samples, raw data interpretation and/or onsite evaluations

should be conducted to ensure risk

- based decisions are supportable.

References:

EPA Requirements for QA Project Plans (QA/R

- 5), EPA/240/B

- 01/003, March 2001

It is the responsibility of monitoring organizations to implement quality assurance programs in

all phases of the data collection process, including the field, its own laboratories, and in any

consulting and contractor laboratories which it may use to obtain data.

Recommendation to Address Finding:

1) V erify that any data produced by Chester LabNet Laboratory will meet project

requirements. As appropriate, laboratory audits, assessments, and/or performance

evaluation samples should be arranged and documented corrective actions put in place, if

needed.

2) P ropose to EPA how oversight and validation of Chester LabNet will be accomplished.18

Finding # G6

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

The continuous meteorological and particulate data streams are not routinely reviewed and there

are no plans to validate this data set.

Description:

Data for the EBAM PM samplers and the Meteorological sensors are minimally handled and

stored in a database by Haley & Aldrich. There are currently no plans to review or validate these

data.

Although these data are of screening

- level quality, they do c ontribute to meeting the data quality

objectives of understanding sources of pollutants and pollutant expo sures. These data may

improve u nderstanding of the primary, definitive, data set.

Because the se data have value , they should undergo some level of automated and/or manual

review soon after collection to identify and correct problems with the instruments or the data

stream (See QA Handbook Volume IV, Section 10). Data validation should also be performed,

although t he level of validation should be appropriate for intended data use. At a minimum,

these data should be reviewed as supporting information for the primary data set.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

- 003, May,

2013

QA Handbook for Air Pollution Measurement Systems , Volume IV, EPA

- 454/B

- 08

- 002,

March, 2008

Recommendation to Address Finding:

1) Evaluate how continuous data may be used in decisions.

2) Develop a system to review continuous data for significant issues on a timely basis, e.g.,

weekly.

3) Integrate review of continuous data into the data validation and reporting process.19

Finding # G7

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: General / Significant

Finding:

There is no formal process to notify ASARCO and EPA of significant deviation from

procedures.

Description:

On several occasions Haley & Aldrich ha s encountered significant issues that needed formal

res olution. These issues have been raised with EPA and ASARCO on weekly calls. However,

the final resolutions were not clearly laid out and agreed to formally.

References:

Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA,

EPA/540/G

- 89/004, October 1988 ( Attachment I, Conditions for PRP Conduct of the RI/FS )

As part of the negotiation process PRPs must agree to follow the site

- specific Statement of Work

(SOW) as the basis for conducting an RI/FS. PRPs are required to submit an RI/FS Work Plan

setting forth detailed procedures and tasks necessary to accomplish the RI/FS activities

described in the SOW. EPA may approve reasonable modifications to the SOW and will reject

any requests for modifications that are not cons istent with CERCLA (as amended by SARA), the

NCP, the requirements set forth in this guidance document, the RI/FS Guidance, or other

relevant CERCLA guidance documents.

Recommendation to Address Finding:

I mplement a system to obtain formal, documented approval from all parties i n order to clarify the

process and ensure that both ASARCO and EPA agree on re solutions of major issues or

deviation from the sampling strategy

.20 NETWORK DESIGN

FINDINGS21

Finding # ND1

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Network Design

Finding:

The Network Design Plan does not reflect actual information from the installed monitoring sites.

Description:

The Network Design Plan prepared in 2012 does not reflect the specific details of the network

installed (i.e., probe heights, distance to roadways, monitor designations, etc .). Additionally,

network plans should be updated annually.

References:

40 C FR Part 58.10

Recommendation to Address Finding:

Update the project Network Design Plan annually and submit it to EPA by July 1 st of each year

until Superfund air monitoring is no longer required

.22

Finding # ND2

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Network Design

Finding:

The Hillcrest monitoring station (ST

- 23) has several siting issues, most notably its proximity to

an unpaved roadway.

Description:

Monitoring Station ST

- 23 is adjacent to a dusty roadway. The PM 10 Federal Reference Method

( FRM ) monitor is 2.8 meters from this potential particulate source. Contribution from the

roadway should be evaluated, as this may be a micro

- scale source that may change how pollution

sources are attributed to this location

. It is inconsistent with information presented in the

Network Design Plan

.

The Hillcrest site is slightly obstructed by a house to the south. T his obstruction is not expected

to have a significant impa ct on the data.

References:

40 CFR Part 58, Appendix E

Recommendation to Address Finding:

1) Characterize dust from this source to distinguish it from other sources on high PM days.

This request was made to ASARCO by the Superfund Remedial Project Manager.

2) Implement d ust suppression measures on the roadway

. 3) Relocate monitors further from the roadway within the station footprint.23

Finding # ND3

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Network Design

Finding:

Trees adjacent to s everal monitoring stations may impact siting effectiveness.

Description:

The Globe Highway (ST

- 05) and Parking Lot (ST

- 14) site, and other stations are sited such that

they may be impacted by trees.

At ST

- 05 there is a tree to the Northeast that may be a siting issue. However

, at the time of the

visit this tree had no foliage and due to a recent fire the condition of this tree is unknown.

At ST

- 14 there is a desert tree/bush to the Southeast with very few small leaves.

Trees are potential siting issues for several reasons:

1) They can be obstructions

. 2) Their leaves can act as surfaces where particulate s are deposited

, biasing data low

. 3) Certain trees can be signif icant sources of particulate (pollen) during certain times of the

year

.

References:

40 CFR Part 58, Appendix E

Recommendation to Address Finding:

E valuate the potential for the trees to bias data collection through out the project lifetime and

include it in the annual Network Design Plans.

If trees appear to be impacting siting more significantly than was obvious at this time, they

should be trimmed or monitors moved further away from trees within the site.24

Finding # ND4

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Meteorological Towers

Finding:

The meteorological towers installed at each monitoring station are too low to collect

representative data.

Description:

The standard height for collecting surface wind speed and direction measurement in open terrain

is ten meters. The station

- specific meteorological sites are approximately ten feet in height.

Based on the site visits

, EPA observed that d ata collected from heights of less than ten meters

may not be consistent, comparable, or representative.

The Asarco Hayden Plant Site Sampling and Analysis Plan, Ambient Air and Source

Characterization , Section A.6 notes that meteorological data is being co llected “to provide

accurate measurements of ambient meteorological parameters to air in understanding source

characterization and data analysis.” The current configuration of these stations severely limits

the possibility of attaining these goals.

Re ferences:

EPA Meteorological Monitoring Guidance for Regulatory Modeling Applications

, EPA

454/R

- 99

- 005 , February 2000

3.2.1.1 Probe placement

The standard exposure height of wind instruments over level, open terrain is 10 m above the

ground.

EPA Quality Assurance Handbook for Air Pollution Measurement Systems, Volume IV:

Meteorological Measurements Version 2.0 (Final), EPA

- 454/B

- 08

- 002, March 2008

Section 1.1

In most cases, to accommodate wind speed/wind direction sensors, a meteorological tower must

be able to reach a height of 10 m.

Recommendation to Address Finding:

R evise the meteorological data collection configuration to meet project goals

.25 FIELD OPERATIONS

FINDINGS26

Finding # FO1

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Routine flow checks are not being performed for the Pb TSP samplers.

Description:

The QAPP specifies that flow rate checks should be performed “prior to every other sample

collection,” and that calibrations should be performed quarterly for the TSP samplers. F low

checks are only performed e immediately after quarterly calibrations.

Fo r air monitoring networks, the minimum recommended frequency for TSP flow checks is

quarterly. However, post calibration flow checks do not evaluate the flow “as found. ”

References:

Final Sampling and Analysis Plan Ambient Air and Source Characteriza tion, Appendix b

to the Phase II Remedial Investigation/feasibility Study, Work Plan Part 1 of 2 (Air),

ASARCO Hayden Plant Site, March 201227

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

- 003, May,

2013

Recommendation to Address Finding:

Institute quarterly flow check s prior to calibration . If, based on these flow checks, the instrument

flow is found to be stable , the calibration frequency might be reduced. At a minimum

, calibrations must be performed annually and after motor maintenance or replacement.28

Finding # FO2

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Problems with the Pb collocated sampler prevented precision data from being collected over an

extended period.

Description:

For several months, collocated precision data was not collected for the TSP Pb monitoring

network due to problems with the sampler. For ambient air sampling, collecting collocated data

is required so that network precision can be evaluated on an on

- going basis. These data are used

to help verify that similar network monitors are operating correctly. Without this basic quality

control

, TSP Pb data q uality may be impacted

.

Generally, quarterly collocation completeness of 100% is not required. However, quarterly

completeness of less than 75% has an adverse impact on the ability to evaluate data quality.

Since Pb heath risk is assessed on a rolling t hree

- month average, the completeness of quarterly

collocated data should be evaluated over this period of time.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

- 003, May,

2013

Recommendation to Address Finding:

1) Determine completeness of collocated data for each rolling thre e

- month average.

2) Evaluate the impact of the missing collocated data on the data set using other quality

control checks and monitoring information

. 3) Develop a procedure that includes

, but is no t limited to

, the causes for past data gaps to

ensu re that collocated completeness for all methods will be met in the future.29

Finding # FO3

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

F ield blanks are not being collected for the Pb TSP sampling network.

Description:

F or TSP Pb

, field blanks should be collected at a ten percent frequency in Section B.11.3.2 of the

QAPP. Other sections of the QAPP and SOP do not specify collecting blanks for TSP Pb. This

discrepancy may have caused some confusion as to whether field blanks are required.

The QA Handbook Volume II recommends that a field blank be collected quarterly for each

instrument.

References:

Fi nal Sampling and Analysis Plan Ambient Air and Source Characterization, Appendix b

to the Phase II Remedial Investigation/feasibility Study, Work Plan Part 1 of 2 (Air),

ASARCO Hayden Plant Site, March 2012

QA Handbook for Air Pollution Measurement Sys tems , Volume II, EPA

- 454/B

- 13

- 003, May,

2013

Recommendation to Address Finding:

I mplement field blank collection for TSP Pb on a predetermined frequency.

Finding # FO4

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network30

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

The instrument/site information recorded is not clearly or easily traceable in some instances.

Description:

Generally, for ambient air monitoring, each monitoring station and each instrument will have its

own logbook. These logbooks will be used to document and track activities, operations,

individuals present, and maintenance.

In order to ensure that instrum ents are operating as expected, each instrument sh ould have a

unique identifier, either the instrument serial number or an identifier referenced to that serial

number.

Haley & Aldrich uses a “Daily Field Report” logbook to track activities at all monitori ng stations

each day. Other information is recorded on “Sample Deployment” and calibration worksheets.

Information included in the Daily Field Reports is minimal and is not always easy to follow.

Deployment and calibration worksheets include site

- specifi c instrument identifiers , but

i nstrument specific information in the Daily Field Report did not consistently include this

.

It is the understanding of the auditor that instruments have not been moved or replaced.

However, to ensure that information on i nstrument performance is properly documented, each

instrument should have a unique, non site

- specific identifier that is used consistently in the Daily

Field Reports, deployment forms, and calibration forms.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

- 003, May,

2013

Recommendation to Address Finding:

D evelop documentation procedures that identify specific instruments and are cross

- reference d

throughout various forms of documentation for tracking and validating data.31

Finding # FO5

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Forms may be filled out by several technicians on different dates without signature blocks or

time and date fields.

Description:

Per the example above, there are many operations where the date and/or technician performing

work are unknown. This information is required for the sampling process to be completely

traceable.32

As noted in General Finding G2, this form should contain accurate and complete information in

order to document maintenance of field custody of the filters.

References:

Recommendation to Address Finding:

Redesign forms so that it is easy to track the date and operator performing each step.33

Finding # FO6

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Thermo 2025i samplers have numerous performance issues which require formal corrective

actions.

Description:

Haley & Aldrich ha ve documented problems with the Thermo 2025i instruments which have

caused them to implement “work arounds” to continue to collect samples efficiently . Some of

these work arounds are documented on Daily Field Reports and o thers require adding

information to deployment forms. These changes should be formalized into the documentation

procedures.

EPA has consulted with the California Air Resources Board (ARB) on solutions for problems

with the 2025i. One issue highlighted b y the ARB is that the filter cassettes supplied by Thermo

may not consistently adhere to material and size and shape specification in 40 CFR Part 50.

References:

40 CFR Part 50, Appendix L34

(Specification from regulation included to help verify cas settes provided by the instrument

vendor are in compliance.)

Recommendation to Address Finding:

1) Update 2025i documentation to incorporate corrective actions for instrument problems

. 2) Evaluate the potential of changing filter cassettes to improve instrument reliability

.35

Finding # FO7

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

The temperature in the refrigerator where samples are stored is not trac ked regularly with an

accurate and NIST traceable thermometer.

Description:

In order to maintain integrity of the samples, especially those with temperature specific

preservation requirements (i.e., mercury and PM 2.5 ), storage temperature must be v erified and

recorded. This should be done at least daily, however continuous temperature logging is

preferred.

References:

2003 NELAC Standard , EPA 600/R

- 04/003, June 5, 200336

Recommendation to Address Finding:

Verify and record the temperature of the sample storage refrigerator each day with a NIST

traceable thermometer.37

Finding # FO8

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Logbooks are not peer reviewed in the field in a timely manner.

Description:

Haley & Aldrich has provided a signature line for peer review of some of the forms being used in

the field. However, this review is not conducted in a timely manner.

Because there is a potential to make error or not complete entries on field forms, they should be

reviewed by a second technician or a supervisor in the field within a reasonable amount of time.

This allows any corrections to be made in a timely manner.

References:

Recommendation to Address Finding:

Institute a weekly field peer review process for all forms.38

Finding # FO9

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Sampling media are not logged in and handling is not tracked until used for sample collection.

Description:

As noted in General Finding G2, sample media should be handled in a manner that preserves its

integrity. As such, they should be logged in, and pertinent information (filter numbers and/or lot,

receipt condition, storage location) recorded when received f rom the laboratory.

References:

2003 NELAC Standard , EPA 600/R

- 04/003, June 5, 2003

Recommendation to Address Finding:

Create a logbook to track sampling media.39

Finding # FO10

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Sample r maintenance is not performed at sites that regularly experience high particulate

concentrations, or on following days when particulate levels are high.

Description:

On several instances, a high concentration of particulates has been observed at several of the

sampling locations. When and where high particulates occur, there is the potential for samplers

to become contaminated or for cut point impactors to become loa ded with particulates.

H igh PM days are determined based on filter loading, physical observations, and by reviewing

the continuous PM 10 data streams.

It is recommended that sampler maintenance frequencies be increased when and/or where high

particulate conditions are experienced.

References:

Recommendation to Address Finding:

Consider revising maintenance frequencies as needed based on station conditions.40

Finding # FO11

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

The set points for the total suspended particulate (TSP) samples are established in standard

conditions but are not verified in actual conditions.

Description:

Haley & Aldrich has not calculated the flow set points in actual conditions.

Given the elevation of Hayden, AZ, standard and actual conditions differ significantly enough

such that the flow set points for operations and calibration, established for the TSP samplers

based on standard conditions, may need to be adjusted for actual conditions.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

- 003, May,

2013

Recommendation to Address Finding:

Verify and adjust the flow set points used for the TSP samplers.41

Finding # FO12

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Instrument calibration dates are not recorded on the field maintenance forms.

Description:

In order to ensure that the samplers have been calibrat ed and to ensure that the appropriate

instrument calibration is evaluated when the data set is validated or tracked, sample calibration

dates should be included on the field maintenance, flow verification, and flow audit forms.

References:

Recommendation to Address Finding:

Update forms to provide a space to record instrument calibration date s

.42

Finding # FO13

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

Sample control , which should be performed in the field , is performed at Haley & Aldrich’s

Tucson office

.

Description:

The Haley & Aldrich database manager is in charge of the sample control process from its

Tucson office. This system has the advantage of making sample delivery to the laboratory much

easier to track. However, the field technicians are the official sample custodians who release the

physical sample for shipping to the laboratory.

The current procedure leads to some ambiguity as to who is responsible for sample custody

verses sample tracking.

References:

Recommendation to Address Finding:

Review the current assignment of sample control responsibility to reduce errors in the sample

handling, custody, and tracking process.43

Finding # FO14

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Field Operations

Finding:

The MiniVol sampling “tree” vibrates significantly in wind.

Description:

EPA noted that the MiniVol sampling “tree” was vibrating due to a moderate wind. This

vibration may have an effect on the sampling results.

References:

Recommendation to Address Finding:

Consider bracing these sampling “trees” to minimize vibrations.44 LABORATORY OPERATIONS

FINDINGS45

Finding # LO1

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/28 / 2014

Program Area: Laboratory

Finding:

The actual method implemented by the laboratory is not consistent with the SOP with regard to

use of an internal standard.

Description:

The SOP IML 2009, Section 8.7, states that th e laboratory is using r henium (Re) as the internal

standard to calculate Pb in solution. This is an approved FEM method. Section 10.13 states that

r henium is the internal standard and that iridium is a potential internal standard.

During an interview on January 28, 2014, the analyst stated that t horium is used as an internal

standard and th at r henium is the potential backup internal standard.

In th e auditor’s opinion, iridium cannot be used as an internal standard without substantial

method performance demonstration

, as there is a chemical stability concern under the conditions

used for method IML 2009 . Therefore, Section 10.13 of the SOP shou ld remove references to

iridium

.

Thorium is a potentially acceptable internal standard

, however, the laboratory should scan the

A SARCO unfortified filter extract without thorium internal standard to rule out the presence of

thorium in the filter sample

, which would bias the Pb results. The abundance of thorium in

unfortified A SARCO samples should be less than 1% of the abundan ce of the internal standard

fortification; if it is greater , one of the EPA recommended internal standards should be used.

This additional step is required for thorium because it is not one of the recommended internal

standards (see 78 FR 40000).

The SO P should clarify under what circumstances an alternate internal standard is used. The use

of a n alternate internal standard is technically sound , however, the reason for the choice should

be documented

. Note that indium, holmium, and bismuth are alternat e internal standards that

should be acceptable to EPA. The u se of rhenium may require additional documentation if it has

not already been submitted as part of the previously approved FEM package approved by EPA

ORD.

This auditor believes that these inter nal standard concerns are significant and that the laboratory

should submit a “User Modification Request” to EPA ORD (attn: Robert Vanderpool. This is

required in 40 CFR 53

, however, the process and required submission documentation are not

described in detail. Under normal circumstances

, these modifications can be approved by EPA

in about one week. The required submission is a description of the change to the SOP with a

narrative as to why the change is technically acceptable.

There are no detrimental effects to the quality or usability of the A SARCO TSP Pb results should46

the unfortified scans of ASARCO filter samples show insignificant levels of thorium. The

laboratory should contact the EPA Region 9 QA Office if significant levels of thorium (>1% o f

the internal standard abundance) are found in unfortified A SARCO filter samples.

References:

Inter

- Mountain Labs Standard Operating Procedure IML 2009

78 FR 40000 (July 3, 2013)

Recommendation to Address Finding:

1) Revise the SOP to state clearly that thorium is the internal standard.

2) Revise the SOP to state which element is the alternate internal standard and the criteria

for using the substitute

. 3) Perform scans of a representative set of A SARCO filter samples not fortified w ith

thorium to establish that samples do not have significant levels of thorium relative to the

concentration used as an internal standard.

4) Submit a User Modification Request for approval of the changes to SOP IML 2009 with

regard to the internal standard( s).47

Finding # LO2

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/2 8/ 2014

Program Area: Laboratory

Finding:

Lot blanks are not included in the sampling procedure

.

Description:

The laboratory analyzed a lot blank on the day of the audit at the request of this auditor.

However, the lab oratory was relying on Haley & Aldrich to send in sufficient blanks for

analysis. Haley & Aldrich staff was not aware that all blank filters in their possession were of

the same lot. SOP IML 2009, Section 5.5, state s lot blank analyses “may” need to be performed.

The project team and the laboratory did not adequately consider this issue

.

EPA recommends that the filter lot analysis be performed to meet CERCLA document ation

requirements and to avoid false positive s or negative s

.

SOP IML 2009 states that guidance for this is in 40 CFR 50, Appendix G, Section 6.1.

A SARCO should modify the project QAPP if necessary and ensure that an adequate number of

lot blanks are ana lyzed so that TSP Pb results can be corrected if necessary.

References:

40 CFR Part 50 Appendix G

Inter

- Mountain Laboratory SOP IML 2009

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/B

13

- 003 (May 2013)

Recomm endation to Address Finding:

Work with Haley & Aldrich to ensure that an adequate number of filter blanks are analyzed and

perform filter blank corrections as prescribed by 40 CFR 50, Appendix G.48

Finding # LO3

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/2 8/ 2014

Program Area: Laboratory

Finding :

The laboratory SOP does not reflect actual practices and does not adequately document

equipment construction , procedure to handle artifacts

, such as insects, or document dislodging of

filter cake during cutting.

Description:

The laboratory uses a custom metal die for cutting of filters that is not fully described by the

SOP. The specific m etal used for the die should be documented. In addition, the cutting board

material should be documented in Section 7 of Appendix A of IML SOP 2009

.

The laboratory has an unwritten approach to handle the presence of insects on the filter , which is

to leave insects on the filter. For the purpose of TSP Pb , EPA ORD conside rs this to be

acceptable. As the purpose of the sampling is to capture particulate matter

, insects represent

anomal ies that should be discussed in the sampling methods.

During the hammering of the die into a filter, it was observed that filter cake p owder was

dispersed by the strong vibration. This dispersion probably only occurs on heavily caked filters.

As the disturbed filter cake could cause reproducibility errors in subsequent strip cuttings, it

should be noted in the sample preparation notes

. T here were no concerns about the

representativeness of the first cut strip used for the A SARCO project.

IML staff believe s that the SOP submitted for FEM approval cannot be modified in any way

without a demonstration of equivalency . This is not the c ase. The specific clarifications

recommended below may be made to the operating SOP used by the laboratory.

With regard to SOP concerns, there are no detrimental impacts to A SARCO TSP Pb results. In

addition, the laboratory generally has complete and well organized documentation.

References:

Email confirming compliance with FEM program requirements, Joseph Eidelberg, EPA Region

9 QA Office and Robert Vanderpool, EPA Office of Research and Development, February 27,

2014

Inter

- mountain Labs SOP IML 2009

Recommendation to Address Finding:

1) Describe the leather die cutter material in Section 7 of Ap pendix A to SOP IML 2009

, including a diagram or photo of the die.49

2) Describe the material used to fabricate the cutting board in Section 7 of Appendix A

, SOP IML 2009.

3) Provide an additional note in Step 11.3 that insects are not removed from the filter prior

to cutting and that any artifacts will be noted in the preparation logbook. Include the

information that the preparation logbook will be used to d ocument whether the filter cake

is visibly altered by the die cutting procedure.50

Finding # LO 4

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/28 / 2014

Program Area: Laboratory

Finding :

S taff does not initiate the chain of custody for filters t he laboratory condition s and send s to

ASARCO for sampling. I nternal chain of custody documentation is not maintained for transfers

between the two laboratory locations. Transfers of samples to Fed Ex are not well documented.

(Also see Concern G2)

Description:

Chain of custody documentation is not transparent for the filter sampling at ASARCO . A

complete set of documentation was gathered for a random filter sample picked as a test case,

however, multiple forms and lists were cross

- referenced.

T he fact that the initial and subsequent steps of the measurement process take place at different

locations is a concern

. In this case

, a transport step by car is required. I t is recommended that

IML maintain an internal chain of custody for location

- to

- location transfers. Not having come

across this situation before, EPA is willing to entertain i deas, from either the laboratory

(laboratory management perspective ) or from A SARCO (pr oject perspective ) as to how sample

integrity can best be maintained under these circumstances. Please send your ideas to the Region

9 QA Office.

The TSP Pb filters ar e conditioned and sent to the A SARCO site for sampling. Regional policy

is that the chain of custody should start at the point the filters are sent back to A SARCO after

conditioning. If A SARCO has a viable alternative

, it should be included in the QAPP and a

QAPP amendment submitted to the EPA RPM for approval.

The chain of custody form should indicate transfer to a Fed Ex tracking number. Similarly, if

samples are transferred from one chain of custody to another (for example, if samples are r e

batched), a chain of custody should indicate transfer of a sample to another chain of custody.

In order to document a chain of custody, multiple documents are necessary from ASARCO and

the laboratory . Other air pollution networks use a single chain of custody for each filter sample

. EPA recommends that the ASARCO consider the transparency and practicality of the single

chain of custody approach.

References:

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/B

13

- 0 03 (May 2013)

Recommendation to Address Finding:51

1) Use a single chain of custody for each filter that originates with the laboratory at that time

filters are conditioned

.

2) Modify the chain of custody documentation procedure to indicate transfer of custody

to/from Fed Ex by using the tracking number.52

Finding # LO5

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/2482014

Program Area: Laboratory

Finding :

D ata package contents for “Level 2” and “Level 4” are not well defined. SOP IML 2009 has not

been updated to include what information should be reported in the data packages.

Description:

The terms Level 2 and Level 4 are used by the project for validation and types of documentation

provided by the laboratory. Currently, the terms are not defined by the laboratory or project

QAPP.

For the purposes of CERCLA validation requirements, the L evel 4 data package should include

the calibration equation, the raw signal count (mass abundance) for the internal standard(s), and

the raw signal count for each isotope of Pb used to report the result.

References:

Quality Assurance Handbook for Air P ollution Measurement Systems, Volume II, EPA

- 454/B

13

- 003 (May 2013)

Inter

- Mountain Labs SOP IML 2009

Recommendation to Address Finding:

Define the contents of a Level 2 and Level 4 data package either in the project QAPP

(A SARCO ) or by the laboratory in an appropriate document. In either case, a copy of the

definition should be sent to the EPA RPM for approval as a QAPP amendment.53

Finding # LO6

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/2482014

Program Area: Laboratory

Finding :

The laboratory SOP does not explicitly state whether results are the sum of Pb isotopes 206, 207,

and 208. Further, with regard to isobaric interferences, the laboratory SOP does not indicate

whether or no t correction equations are used.

Description:

Section 4.3 of the SOP indicates that no equations for correction of isobaric polyatomic ion

interferences are recommended. The SOP should simply state that no corrections are performed

if this is the case. Nowhere in the SOP is it explained how the various lead isotope results relate

to the total Pb result.

The requested information is considered clarification and does not require application to the

FEM ap proval process.

References:

Inter

- Mountain Labs Standard Operating Procedure IML 2009

78 FR 40000 (July 3, 2013)

Recommendation to Address Finding:

Add the additional information to SOP ILM 2009.54

Finding # LO7

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/28/2014

Program Area: Laboratory

Finding:

The SOP IML 2009 does not provide specific details about the calibration

.

Description:

Section 9.0 of the SOP IML 2009 does not describe the type of calibration used. The SOP should

include the specific calibration algorithm and the SOP should require that the calibration curve

be reported so that results can be back calculated. Section 12.4 relates to this concern but refers

the reader t o SW

- 846

, which is inadequate

, as it refers the reader to general guidance.

References:

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/B

13

- 003 (May 2013)

Inter

- Mountain Labs SOP IML 2009

Recommendation to Address Finding:

Modify Section 9.0 of the SOP IML 2009 to include calibration algorithm

. The data report

should provide the mathematical formula derived from the calibration process.55

Finding # LO8

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/2482014

Program Area: Laboratory

Finding:

SOP IML 2009 is ambiguous as to whether the LLOQ quality control sample is analyzed.

Description:

Section 10.16 of SOP IML 2009 states that the lower limit of quantitation (LLOQ) sample can be

analyzed daily with an acceptance range of +/

- 50%. It is recommended that the SOP state

explicitly whether the LLOQ is or is not analyzed daily. If the LLOQ is only analyzed un der

certain conditions, describe those conditions

.

References:

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/B

13

- 003 (May 2013)

Inter

- Mountain Labs SOP IML 2009

Recommendation to Address Fi nding:

Revise section 10.16 of SOP IML 2009 to state that the LLOQ is analyzed at beginning of every

analytical sequence when a new calibration is performed (commonly referred to as a “run”).56 DATA MANAGEMENT

FINDINGS57

Finding # DM1

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Data Management

Finding:

Quality control information for air monitoring is not maintained in the database and there is no

plan to perform statistical analysis of this data.

Description:

In order to evaluate bias and precision from the ambient air monitors

, Haley & Aldrich should

have the ability to perform statistical analyses on these data, as specified in 40 CFR Part 58

Appendix A and in the Data Validation Templates. In addition to statistical analyses, the data

should be used to generate control charts of instrument and network performance. These tools

support appropriate data validation and data assessment, and are integral to maki ng the

determination as to whether the statistical data quality objectives for ambient air monitoring are

being met

.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

- 454/B

- 13

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40 CFR Part 58, Appendix A, Sect ion 4

Recommendation to Address Finding:

Develop a database for air monitoring quality control data and a process for incorporating

statistical analysis into data review.58

Finding # DM2

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Data Management

Finding:

Information on the Haley & Aldrich’s Tucson Server can be changed without being tracked.

Description:

Sample tracking forms, laboratory electronic data deliverables, and the results database are

store d on Haley & Aldrich’s Tucson Office Server. At times these files are corrected to correct

errors in data entry. Other operations, such as the application of data validation changes and

qualifiers, may be performed on these dat a. The data systems in use do not track each change

nor do they identify the individual making the change. Additionally, these data sources can be

accessed by multiple individuals in the Tucson office.

The database manager explain ed that the server unde rgoes a timed back up and, when there are

questions about changes made to data , the appropriate backup copy from the server can be

restored. This could work to undo incorrect changes made to data . However, original data

submittals are not preserved in th e current server for evaluation or comparison.

References:

2185

– Good Automated Laboratory Practices , USEPA, August 10, 1995

Recommendation to Address Finding:

Develop a system to document changes made to original data sets to ensure the integrity of the

data, and at a minimum keep original copies of data sources readily available for reference.59

Finding # DM3

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: D ata Management

Finding:

D ata reporting errors were found in the database.

Description:

Reported MiniVol sample data from Station ST

- 09 on 8/22/13 was found to be in error.

Several issues were noted:

1) The sampling crossbeam that holds the four MiniVol samplers had fallen to the ground.

The field technicians noted this, and processed and sent the samples for analysis. The

decision to analyze the samples may have been valid, however

, the resulting data

probably should have been withheld from the database and flagged as need ing additional

review for quality assurance purposes.

2) Upon receipt, IML inspected the filters and determined that the PM 10 filter was

contaminated with oil (probably as a result of the fall) and should not be weighed.

However, it was determined that the filter should be analyzed for metals analysis.

3) The laboratory reported a null (invalidated) result for the filter. When this information

was imported to the database, the system translated the null result as a non

- detect at the

detection limit.

4) The total mass of metals on the PM 10 filter reported by C hester LabNet was

approximately 133 μg/m 3 , however

, the total mass by the gravimetric method, recorded

in the database, was less than 2 μg/m 3 . The inconsistency of these data sets from the

same filter was not recognized or flagged by the database.

5) Ultimat ely, this information was reported, unqualified, as preliminary data. In general

some level of error is expected in preliminary data. However, this result was one of the

highest metals concentrations reported and should have been noted as erroneous in a

screening review of the data set.

References:

Recommendation to Address Finding:

E valuate data management, database importation, and data screening procedures to eliminate or

reduce data reporting errors

.60

Finding # DM4

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Data Management

Finding:

There is no policy or SOP to provide guidance as to whether invalidated data should be retained

or discarded.

Description:

Generally during the Superfund validation process, when data do meet quality requirements and

concentrations of pollutants are detected, data are not rejected but the reported values are

flagged. For ambient air monitoring data, when data are considered invalid, th ey are not reported

but instead replaced with a qualifier code

.

Haley & Aldrich should develop a policy and SOPs describing when invalid or rejected data are

to be reported and how they are to be qualified. In some cases, data values should be removed

an d replaced by a qualifier , as in the case of the fallen sampler. In other cases, data may be

considered invalid or rejected, but still may be useful as additional information when a required

QC was not performed.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

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National Functional Guidelines for Superfund Inorganic Methods for Data Review , EPA

540

- R10

- 011, January, 2010

Recommendation to Address Finding:

Develop a n SOP for reporting inval id and rejected data.61

Finding # DM5

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Data Management

Finding:

There is no records retention schedule for generated data

.

Description:

Record retention for this project is dictated by a 2008 Administrative Settlement Agreement and

Consent Order . This document specifies how long records are to be retained.

References:

USEPA Region IX, Administrative Settlement Agreement and Order on Consent,

ASARCO Hayden Plant Site, CERCLA

- 2008

- 13, April 2008

Recommendation to Address Finding:

Develop and f

ollow the project record retention schedule.62

Finding # DM6

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Data Management

Finding:

There is no plan for uploading data to the EPA Air Quality System (AQS) database.

Description:

The QAPP specifies that air monitoring data will be uploaded to AQS.

References:

40 CFR Part 58.16

Recommendation to Address Finding:

P ut systems in place to upload data to AQS

.63

Finding # DM7

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Data Management

Finding:

The database is not set up to perform some automated data checks/validation.

Description:

As noted in finding DM3, there are some automated checks that could be performed in the

database to help screen for data quality issues. This could be comparison of data, screening for

values outside of ranges, and/or identification of outliers for further review.

References:

Recommendation to Address Finding:

Consider enhancing the database with automated data screening.64 QUALITY ASSURANCE

FINDINGS65

Finding # QA1

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Quality Assurance

Finding:

Independent flow audits are not being conducted for TSP Pb, PM 10 , and PM.

Description:

Independent flow audits are specified in the QAPP to be conducted quarterly . For ambient air

monitoring networks

, these audit s are usually required at least every six months. They are

similar to the monthly/quarterly flow verifications whe re the system is examined for leaks and

pressure and temperature sensors are checked, with the exception that it is required that they be

performed using an independent flow standard and should be completed by an independent

technician.

Haley & Aldrich st aff has two sets of standards for flow verification For the PM 2.5 and PM 10 Federal Reference Method (FRM) samplers , and could, by modifying the current procedures,

meet the requirement for flow audits. For example

, the calibration frequency could be chang ed

to every six months; calibrations and monthly flow checks could be perf ormed using the same

standard; an d flow audits could be performed using the second source standard between each

calibration. This approach would not substantial ly change the current program design.

Haley & Aldrich has only one high volume orifice for TSP Pb, and will need to obtain another

standard to meet these requirements. Flow audits using this second source standard would need

to be implemented every six months. Pressure and temperature could be audited using the

PM 2.5 /PM 10 audit standard.

From Table B2.2 in the QAPP (TSP Pb)

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

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2013

Recommendation to Address Finding:

Implement a flow audit program for TSP, PM 2.5 , and PM 10 FRM monitors

.66

Finding # QA2

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Quality Assurance

Finding:

The EPA performance evaluation program (PEP) has not been incorporated into the program.

Description:

The PEP is required for ambient air monitoring networks to independently assess the monitoring

organization’s precision and bias and to collect performanc e information on FRM or Federal

Equivalent Method (FEM) designated monitors. The PEP involves collocating audit monitors

several times per year for the PM 2.5 monitoring and at least once per year for Pb monitoring.

Additionally, four filters from the col located site should be submitted to the EPA PEP laboratory

in Richmond, CA for analysis throughout each year.

Collocated monitors must be set up between one and four meters from the primary monitor for

PM 2.5 and between two and four meters from the primar y monitor for TSP Pb. The monitors

should be at a similar height. A power source must be provided for the TSP audit sampler.

With the current configuration of the monitoring sites, there is no room for a collocated Pb TSP

sampler. Haley & Aldrich has noted that it may be possible to secure a location outside the

fenced area that meets these requirements at most of the monitoring sites if needed.

References:

QA Handbook for Air Pollution Measurement Systems , Volume II, EPA

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2013

Recommendation to Address Finding:

Haley & Aldrich should accommodate on

- site PEP audits and submit four TSP filters per year

from collocat ed monitors to the EPA PEP laboratory.67

Finding # QA3

Organization: Haley & Aldrich

– ASARCO Hayden Air Monitoring Network

Date of Audit: 1/24/2014

Program Area: Quality Assurance

Finding:

There is no formal corrective action program.

Description:

Several issues have been encountered by Haley & Aldrich that should have been handled through

a formal corrective action program. EPA did note that the data management and field staff

generally performed very well

, documenting and correcting routine issues. Problems that were

not routine also were handled effectively. However, better documentation of these issues, their

solutions and the evaluation of related issues using root cause analyses would improve the

quality of the monitoring program overall.

References:

Recommendation to Address Finding:

I mplement a formal, documented corrective action program for this project.