Technical System Audit

ASARCO Hayden Plant Site

Ambient Air Monitoring Program

January 22 - January 28, 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 2014
ii

INDEX

GLOSSARY OF ACRONYMS........................................................................................1

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

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

OVERVIEW OF AIR MONITORING PROGRAM ....................................................6

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

NETWORK DESIGN FINDINGS................................................................................20

FIELD OPERATIONS FINDINGS..............................................................................22

LABORATORY OPERATIONS FINDINGS..............................................................44

DATA MANAGEMENT FINDINGS............................................................................56

QUALITY ASSURANCE FINDINGS...........................................................................64
1

GLOSSARY OF ACRONYMS

ADEQ.......................................... Arizona Department of Environmental Quality

ARARS........................................ Applicable or Relevant and Appropriate Requirements 

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 Toxics Trends Stations

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

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

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

PM2.5............................................ Particulate Matter with aerodynamic diameter ≤ 2.5 μm

PM10............................................. Particulate Matter with aerodynamic diameter ≤ 10 μm

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 Fluorescence
2

EXECUTIVE SUMMARY

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

(EPA) from a Technical Systems Audit (TSA) of 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 requirements (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 part 58, Appendix A, §2.5.

The TSA was conducted by EPA Region 9 Quality Assurance 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 the monitoring 

sites operated by ASARCO’s support contractor, Haley & Aldrich. The site inspections consisted 

of an interview with the site operators, review of 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 PM10

and PM2.5.

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

monitoring programs meet required minimum 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 enable organizations to identify and correct 

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

results of the TSA 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 corrective 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.

With 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 an environmental consulting firm.

 The project is organized so that resources 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.

 Project staff organization should be 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 monitoring 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 – 28, 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

- Changes to the network design

- Field support

 Laboratory Operations for PM and Pb

- Routine operations

- Quality control

- Laboratory preventive maintenance

- Laboratory record keeping

- Laboratory data acquisition 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 Andersen (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 interviewed at IML in Sheridan, Wyoming: Tom 

Patton (Vice President), Michelle LaGory (Quality Assurance 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 evaluate. 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 

Sampling 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. Independent EPA oversight is 

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

Superfund and Air Monitoring programs. 

Ambient 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 ambient 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 documented 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 monitoring 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 quality management program as laid out in the QAPP. Generally the 

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

being 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, the project organization currently does not include 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 that house a 

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

monitoring sites, instruments and the pollutants monitored.

The original QAPP and Network Design Plan specified 15 monitoring stations 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 potential 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, Appendix 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 documentation. EPA also verified whether appropriate 

Quality Control (QC) checks and QA 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 sites visited were well maintained. Documentation contained 

most of the 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 and 

instrument operations. However, several 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 this 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 project 

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

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

There are concerns about the detail of the EPA-approved SOP not being adequate 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 (PM10 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 Data
9

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. The original approach taken 

was to request full data 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 laboratories 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 Validation Templates, which include

field and laboratory 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 validation packages are 

complete and the process is well defined. 
10

GENERAL / SIGNIFICANT

FINDINGS
11

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 reviewed 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 location 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 appropriate 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 QA/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 should 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 1998
13

Recommendation to Address Finding:

Review 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 

modifications.
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 

monitoring 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 performed 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 staff typically perform initial validation; 

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

QA manager. 

References:

QA 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/R02/004, 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:

Structure 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 Superfund QA elements.

Description:

Data validation for this project must meet the requirements of the National Functional Guidelines 

for Superfund (NFG) and regulatory ambient air monitoring. 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 nor does it include SOPs 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 performance 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 remainder undergoes a less in-depth review 

(Tier 1).

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

description should be developed 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 Superfund 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, EPA540-R10-011, January, 2010

Recommendation to Address Finding:

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

regulatory ambient air and Superfund 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 LabNet 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 LabNet. 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 oversee 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 noted 

that IML had to obtain 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 evaluation 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) Verify 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) Propose 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 contribute to meeting the data quality 

objectives of understanding sources of pollutants and pollutant exposures. These data may 

improve understanding of the primary, definitive, data set.

Because these 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 the 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 has encountered significant issues that needed formal 

resolution. 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 consistent 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:

Implement a system to obtain formal, documented approval from all parties in order to clarify the 

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

deviation from the sampling strategy. 
20

NETWORK DESIGN

FINDINGS
21

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 CFR Part 58.10

Recommendation to Address Finding:

Update the project Network Design Plan annually and submit it to EPA by July 1st 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 PM10 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. This obstruction is not expected 

to have a significant impact 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 dust 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 several 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 particulates are deposited, biasing data low.

3) Certain trees can be significant sources of particulate (pollen) during certain times of the 

year.

References:

40 CFR Part 58, Appendix E

Recommendation to Address Finding:

Evaluate the potential for the trees to bias data collection throughout 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 data 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 collected “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.

 

References:

EPA Meteorological Monitoring Guidance for Regulatory Modeling Applications, EPA454/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:

Revise the meteorological data collection configuration to meet project goals.
25

FIELD OPERATIONS

FINDINGS
26

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. Flow 

checks are only performed e immediately after quarterly calibrations.

For 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 Characterization, Appendix b 

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

ASARCO Hayden Plant Site, March 2012
27

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B-13-003, May, 

2013

Recommendation to Address Finding:

Institute quarterly flow checks 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 quality 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 three-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 three-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 not limited to, the causes for past data gaps to 

ensure 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: 

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

Description:

For 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:

Final 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 Systems, Volume II, EPA-454/B-13-003, May, 

2013

Recommendation to Address Finding:

Implement field blank collection for TSP Pb on a predetermined frequency.

Finding # FO4

Organization: Haley & Aldrich – ASARCO Hayden Air Monitoring Network
30

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 instruments are operating as expected, each instrument should 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 monitoring 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-specific instrument identifiers, but 

instrument 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 instrument 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:

Develop documentation procedures that identify specific instruments and are cross-referenced

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 have 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 others 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 by 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 L
34

(Specification from regulation included to help verify cassettes 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 tracked 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 PM2.5), storage temperature must be verified 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, 2003
36

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 from 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: 

Sampler 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 loaded with particulates. 

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

the continuous PM10 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 calibrated 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 dates.
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

FINDINGS
45

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 the laboratory is using rhenium (Re) as the internal 

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

rhenium is the internal standard and that iridium is a potential internal standard.

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

standard and that rhenium is the potential backup internal standard.

In the 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 should remove references to 

iridium.

Thorium is a potentially acceptable internal standard, however, the laboratory should scan the 

ASARCO 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 ASARCO samples should be less than 1% of the abundance 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 SOP should clarify under what circumstances an alternate internal standard is used. The use 

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

be documented. Note that indium, holmium, and bismuth are alternate internal standards that 

should be acceptable to EPA. The use 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 internal 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 ASARCO TSP Pb results should 
46

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% of 

the internal standard abundance) are found in unfortified ASARCO 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 ASARCO filter samples not fortified with 

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: 1/28/2014

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 laboratory 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, states 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 documentation 

requirements and to avoid false positives or negatives.

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

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

lot blanks are analyzed 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/B13-003 (May 2013)

Recommendation 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: 1/28/2014

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 metal 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 considers this to be

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

anomalies that should be discussed in the sampling methods. 

During the hammering of the die into a filter, it was observed that filter cake powder 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. There were no concerns about the 

representativeness of the first cut strip used for the ASARCO project.

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

without a demonstration of equivalency. This is not the case. 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 ASARCO 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 Appendix 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 document whether the filter cake 

is visibly altered by the die cutting procedure. 
50

Finding # LO4

Organization: Haley & Aldrich – ASARCO Hayden Air Monitoring Network

Date of Audit: 1/28/2014

Program Area: Laboratory 

Finding:

Staff does not initiate the chain of custody for filters the laboratory conditions and sends to 

ASARCO for sampling. Internal 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. 

The 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. It 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 ideas, from either the laboratory 

(laboratory management perspective) or from ASARCO (project 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 are conditioned and sent to the ASARCO site for sampling. Regional policy 

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

conditioning. If ASARCO 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 rebatched), 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/B13-003 (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: 

Data 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 Level 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 Pollution Measurement Systems, Volume II, EPA-454/B13-003 (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 

(ASARCO) 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 not 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 approval 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 to 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/B13-003 (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 under 

certain conditions, describe those conditions. 

References:

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B13-003 (May 2013)

Inter-Mountain Labs SOP IML 2009

Recommendation to Address Finding:

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

FINDINGS
57

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 making 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-13-003, May, 

2013

40 CFR Part 58, Appendix A, Section 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 

stored 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 data. 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 explained that the server undergoes 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 the 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: Data Management

Finding: 

Data 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 needing additional 

review for quality assurance purposes.

2) Upon receipt, IML inspected the filters and determined that the PM10 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 PM10 filter reported by Chester LabNet was 

approximately 133 μg/m3, however, the total mass by the gravimetric method, recorded 

in the database, was less than 2 μg/m3. The inconsistency of these data sets from the 

same filter was not recognized or flagged by the database.

5) Ultimately, 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:

Evaluate 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, they 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 

and 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-454/B-13-003, May, 

2013

National Functional Guidelines for Superfund Inorganic Methods for Data Review, EPA540-R10-011, January, 2010

Recommendation to Address Finding:

Develop an SOP for reporting invalid 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 follow 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:

Put 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

FINDINGS
65

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, PM10, and PM.

Description:

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

monitoring networks, these audits are usually required at least every six months. They are 

similar to the monthly/quarterly flow verifications where 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 staff has two sets of standards for flow verification For the PM2.5 and PM10

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 changed 

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

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

calibration. This approach would not substantially 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 

PM2.5/PM10 audit standard.

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

References:

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B-13-003, May, 

2013

Recommendation to Address Finding:

Implement a flow audit program for TSP, PM2.5, and PM10 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 performance information on FRM or Federal 

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

several times per year for the PM2.5 monitoring and at least once per year for Pb monitoring. 

Additionally, four filters from the collocated 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 

PM2.5 and between two and four meters from the primary 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-454/B-13-003, May, 

2013

Recommendation to Address Finding:

Haley & Aldrich should accommodate on-site PEP audits and submit four TSP filters per year 

from collocated 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:

Implement a formal, documented corrective action program for this project.