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QUALITY ASSURANCE PROJECT PLAN (QAPP)FOR SAMPLING AND ANALYSIS OF PROPERTIES

IN THE VICINITY OF THE EXIDE FACILITY(VERNON, CALIFORNIA)

Prepared for:

The Department of Toxic Substances Control8800 Cal Center DriveSacramento, CA 95826

Originated by:

PARSONS100 West Walnut StreetPasadena, CA 91124

November 18, 2015

Revised: November 21, 2016

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QUALITY ASSURANCE PROJECT PLAN (QAPP)FOR SAMPLING AND ANALYSIS OF PROPERTIES IN THE VICINITY

OF THE EXIDE FACILITY (VERNON, CALIFORNIA)

Prepared for:

Reviewed by:

11/21/16

Christine Rink-Ashdown, Project Chemist

11/21/16Scott Myers, Project Technical ManagerCertified Lead Inspect / Assessor No. 20633

11/21/16Shayan Simantob, Project ManagerProfessional Geologist No. 9296

11/21/16

Dennis Ironi, Certified Industrial Hygienist No. 9983

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QUALITY ASSURANCE PROJECT PLAN (QAPP)FOR SAMPLING AND ANALYSIS OF PROPERTIES IN THE VICINITY OF

THE EXIDE FACILITY (VERNON, CALIFORNIA)

Prepared for:

Melissa Blanchette, P.G.

David Kudlinski, C.I.H.

Reviewed by:

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DTSC EXIDE SITEQUALITY ASSURANCE PROJECT PLAN

REVISION HISTORY

RevisionNo. Date

RevisedBy Reason for Revision

SectionsRevised

0 11/18/15 Original Document All

1 11/21/16 Update revisions All

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TABLE OF CONTENTS

Section Title Page

1.0 INTRODUCTION ................................................................................................................... 1-11.1 PROJECT DESCRIPTION .......................................................................................... 1-11.2 PURPOSE AND SCOPE OF QAPP ............................................................................ 1-21.3 PROJECT OBJECTIVE .............................................................................................. 1-21.4 PROJECT ORGANIZATION AND RESPONSIBILITIES .......................................... 1-2

2.0 DATA QUALITY OBJECTIVES ............................................................................................ 2-12.1 ANALYTICAL DATA QUALITY LEVELS .............................................................. 2-22.2 DATA QUALITY ASSESSMENT CRITERIA ........................................................... 2-3

2.2.1 Precision ......................................................................................................... 2-32.2.2 Accuracy ........................................................................................................ 2-42.2.3 Completeness .................................................................................................. 2-42.2.4 Comparability ................................................................................................. 2-52.2.5 Representativeness .......................................................................................... 2-6

2.3 LABORATORY OJECTIVES..................................................................................... 2-62.3.1 Laboratory Standard Operating Procedures (SOPs) ......................................... 2-72.3.2 Demonstration of Capability, Analyst Training ............................................... 2-72.3.3 Laboratory Internal Audits .............................................................................. 2-8

3.0 FIELD DATA REDUCTION, VALIDATION, AND REPORTING ........................................ 3-13.1 FIELD RECORD KEEPING ....................................................................................... 3-13.2 CALIBRATION PROCEDURES AND FREQUENCY FOR FIELD TEST

EQUIPMENT ............................................................................................................. 3-23.3 REVIEW OF FIELD RECORDS................................................................................. 3-2

3.3.1 Completeness of Field Records ....................................................................... 3-23.3.2 Identification of Valid Samples ....................................................................... 3-33.3.3 Identification of Anomalous Field Test Data ................................................... 3-33.3.4 Accuracy and Precision of Field Data and Measurements ................................ 3-3

3.4 FIELD DATA VALIDATION .................................................................................... 3-3

4.0 FIELD QC SAMPLES ............................................................................................................. 4-14.1 CONFIRMATORY DUPLICATE SAMPLES ............................................................. 4-14.2 XRF FIELD DUPLICATE SAMPLES ........................................................................ 4-14.3 FIXED LABORATORY DUPLICATE SAMPLES ..................................................... 4-14.4 BLANKS .................................................................................................................... 4-2

5.0 SAMPLING PROTOCOLS ..................................................................................................... 5-15.1 SAMPLE CONTAINERS ........................................................................................... 5-15.2 SAMPLE CONTAINMENT, PRESERVATION, AND LABELS ............................... 5-15.3 FIELD SAMPLE IDENTIFICATION ......................................................................... 5-15.4 SAMPLE CHAIN-OF-CUSTODY .............................................................................. 5-25.5 LABORATORY CUSTODY PROCEDURES ............................................................. 5-3

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TABLE OF CONTENTS

Section Title Page

5.6 SAMPLE HANDLING ............................................................................................... 5-3

6.0 FIXED-BASE LABORATORY ANALYTICAL PROCEDURES ........................................... 6-16.1 ANALYTICAL METHODS........................................................................................ 6-16.2 DETECTION AND QUANTITATION LIMITS ......................................................... 6-2

6.2.1 Method Detection Limit .................................................................................. 6-26.2.2 Practical Quantitation Limit ............................................................................ 6-36.2.3 Detection Limit Goals ..................................................................................... 6-3

7.0 LABORATORY QC SAMPLES AND CRITERIA .................................................................. 7-1

8.0 LABORATORY DATA REVIEW, REPORTING, AND ASSESSMENT ................................ 8-18.1 LABORATORY REVIEW PROCEDURES FOR DEFINITIVE DATA ...................... 8-18.2 LABORATORY DATA REPORTING AND QUALIFIERS ....................................... 8-28.3 CONTRACTOR ASSESSMENT OF DATA USABILITY .......................................... 8-3

8.3.1 Data Validation Qualifiers............................................................................... 8-48.3.2 Assessment of Usability .................................................................................. 8-5

9.0 QA REPORTS ......................................................................................................................... 9-1

10.0 CORRECTIVE ACTION ....................................................................................................... 10-1

11.0 AUDITS ................................................................................................................................ 11-111.1 SYSTEM AUDITS.................................................................................................... 11-1

11.1.1 Internal Audits .............................................................................................. 11-111.1.2 External Audits ............................................................................................. 11-1

11.2 PERFORMANCE AUDITS ...................................................................................... 11-111.3 DATA AUDITS ........................................................................................................ 11-1

12.0 PREVENTIVE MAINTENANCE.......................................................................................... 12-112.1 PROCEDURES ......................................................................................................... 12-112.2 SCHEDULES ........................................................................................................... 12-112.3 SPARE PARTS ......................................................................................................... 12-1

13.0 SECURITY ........................................................................................................................... 13-1

14.0 DATA DELIVERABLES ...................................................................................................... 14-114.1 HARDCOPY DATA DELIVERABLES .................................................................... 14-114.2 ELECTRONIC DATA DELIVERABLES ................................................................. 14-1

15.0 FINAL SAMPLE DISPOSITION .......................................................................................... 15-1

16.0 REFERENCES ...................................................................................................................... 16-1

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TABLE OF CONTENTS

Section Title Page

LIST OF TABLES

Table 1 Data Quality Objectives (DQO) for Off-Site Soil Sampling and CleanupUSEPA’s (2000) Seven-step Systematic Planning Process

Table 2 Requirements for Containers, Preservation Techniques, Sample Volumes, andHolding Times

LIST OF APPENDICES

Appendix A Laboratory Quality Assurance Manuals1 Eurofins/Calscience Quality Assurance Manual2 TestAmerica Quality Assurance Manual3 PACE Analytical Quality Assurance Manual4 EMSL/LA Testing Quality Assurance Manual

Appendix B EPA Method 6200, ASTM E1727-16Appendix C Forms

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LIST OF ABBREVIATIONS AND ACRONYMS

AL Action LevelASTM American Society for Testing and MaterialsCal-EPA California Environmental Protection AgencyCCR California Code of RegulationsCFR Code of Federal Regulations°C degrees CelsiusCOC chain-of-custodyCOPC chemical of potential concernCDPH State of California Health and Human Services Agency, Department of

Public HealthDF dilution factorDL detection limitDQA data quality assessmentDQO data quality objectiveDTSC Department of Toxic Substances ControlELAP Environmental Laboratory Accreditation ProgramFM field managerft feetft2 square feetGPS global positioning systemHASP Health and Safety PlanHUD Department of Housing and Urban DevelopmentIMWP Interim Measures WorkplanJ estimated concentrationLAC Los Angeles CountyLCS laboratory control sampleLBP lead-based paintMDL method detection limitmg/kg milligrams per kilogrammg/cm2 milligrams per square centimeterMS/MSD matrix spike/matrix spike duplicateNC/CAR non-conformance/corrective action reportNIST National Institute of Standards and TechnologyOEHHA Office of Environmental Health Hazard AssessmentOSHA Occupational Safety and Health AdministrationPAH polynuclear aromatic hydrocarbonPARCC precision, accuracy, representativeness, completeness, and comparabilityPC percent completePCB polychlorinated biphenylPE performance evaluationPM project managerPOC point of contactPQL practical quantitation limit

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QAM quality assurance manualQAPP quality assurance project planQA/QC Quality Assurance/Quality ControlRFD relative percent differenceSD sample duplicateSI Site InvestigationSOP standard operating procedureSOW scope of workSQL sample quantitation limitSCAQMD South Coast Air Quality Management DistrictSVOC semi-volatile organic compoundTPH-d total petroleum hydrocarbons (diesel-range organics)TPH-g total petroleum hydrocarbons as gasoline-range organics)TPH-o total petroleum hydrocarbons as gasoline (oil-range organics)U non-detectUSA Underground Services AlertUSEPA United States Environmental Protection AgencyVOC volatile organic compoundWorkplan Site Characterization WorkplanXRF X-ray fluorescence

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1.0 INTRODUCTION

This Quality Assurance Project Plan (QAPP) has been prepared to support site assessmentand clean up activities being conducted for the California Environmental Protection Agency(Cal-EPA) Department of Toxic Substances Control (DTSC) for residential and sensitive-useproperties located in the vicinity of the Exide Metals facility (site) in Vernon, California. Thepurpose of this QAPP is to present the organization, objectives, functional activities, andspecific quality assurance (QA) and quality control (QC) activities in support of anticipatedsampling activities.

This QAPP incorporates the following references in establishing the project criteria:

United States Environmental Protection Agency (USEPA), Guidance for the DataQuality Objectives Process (USEPA, 2006);USEPA, Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods,SW-846, Third Edition, Update III (USEPA, 1996);American National Standards Institute/American Society of Quality Control(ANSI/ASQC E-4-1994), Specifications and Guidelines for Quality Systems forEnvironmental Data Collection and Environmental Technology Programs, July1995; andUSEPA, Risk Assessment Guidance for Superfund, Volume 1: Human HealthEvaluation Manual [Parts A, B, and C] (USEPA, 1989, 1991a, and 1991b).

The procedures described herein will be performed in accordance with the guidance,regulations, and documents presented in the project statement of work.

1.1 PROJECT DESCRIPTION

Arcadis and EFI Global have been tasked by the DTSC with the investigation and cleanup ofresidential and sensitive-use properties located near the former Exide Technologies (Exide)battery recycling facility in Vernon, California. Lead emissions from the former Exide facilityare suspected of affecting surface and near-surface soils in surrounding areas as a result ofaerial deposition.

The initial phase of assessment work will evaluate soil lead concentrations at up to 1,000residential and sensitive-use properties to ascertain the need for soil removal. The goal of thisinvestigation is to identify those residential properties that contain lead soil concentrationsequal to or greater than 80 mg/kg. Properties with these lead concentrations in soil areconsidered having the greatest lead exposure potential and will be prioritized for cleanup. Fieldanalyses will be performed using an X-ray fluorescence (XRF) analyzer to allow for rapidevaluation of multiple properties; confirmation sampling of a selected subset of samples will beperformed by an off-site fixed laboratory.

The fixed laboratories will include: Eurofins/Calscience located in Garden Grove, California,and TestAmerica (TA) located in Irvine, California, as the primary off-site fixed laboratories


that will analyze soil samples collected for all analyses. In case of overflow from the primarylaboratories, EMSL/ LA Testing Laboratories (EMSL) located in Huntington Beach, California,and Pace Analytical Services (PACE) located in Davis, California, will be used as off-site fixedlaboratories. Eurofins/Calscience, TA, EMSL, and Pace are State of California certifiedlaboratories (ELAP certified). Copies of the Laboratory’s QAM are included in Appendix A.

Eurofins/Calscience located in Garden Grove, California, and TestAmerica (TA) located inIrvine, California, are the off-site fixed laboratories that will analyze soil samples collectedmetals analyses (EPA method 6010B). Eurofins/Calscience, and TA are State of Californiastate-certified laboratories. Copies of the laboratory’s QAM are included as Attachment 1and 2, respectively.

This QAPP is designed to support both site characterization and remedial action activities. Thescope of work for site characterization sampling will primarily focus on the collection of soilsamples for metals (primarily lead) analysis, although other metals may also be targeted duringsampling activities. In addition, limited XRF field screening of painted surfaces for the presenceof lead-based paint (LBP) will also be performed. The scope of work for remedial actionactivities is to collect confirmation soil samples and waste profiling samples.

1.2 PURPOSE AND SCOPE OF QAPP

This QAPP sets forth quality guidelines for all activities, products, and services and is designedto ensure that all activities are accomplished in an approved, prescribed manner by technicallytrained and competent staff. This document establishes the QA requirements and assignsresponsibility to project personnel and subcontractors for ensuring that project objectives willbe achieved. This QAPP consists of the QA program requirements that are responsive to allguidance documents referenced in Section 1.0. Quality requirements specified in this documentare tailored to the needs of this assessment project.

1.3 PROJECT OBJECTIVE

The objective of the assessment work is to characterize the presence of lead in soil at multipleoff-site residential and sensitive-use properties to determine if aerially deposited lead may bepresent at concentrations of potential concern from a human health perspective. The objectiveof the characterization and remediation work is to clean up lead-impacted soils in accordancewith the Sampling and Analysis Plan (SAP) and the Remedial Action Plan (RAP) prepared forthe off-site residential areas.

1.4 PROJECT ORGANIZATION AND RESPONSIBILITIES

Due to the number of stakeholders on this public project, compliance with the chain ofcommand and lines of communication is an absolute necessity for proper implementation of theWorkplan. The following subsections list the authority points of contact (POCs) to beconsidered during the course of work. The site investigation (SI) will be collectively managedby the DTSC. The nature of each party’s responsibilities is discussed below.


DTSC Contract Management Representative

Ms. Tamara Zielinski, PE, of the DTSC is responsible for overall coordination and organizationof the Exide Residential Cleanup project, including this investigation work. She can be reachedat (916) 255-6419. Ms. Zielinski may delegate authority to other DTSC field representative(s)for field-related decisions.

DTSC Project Manager

Mr. Rafat Abbasi, PE, will represent the DTSC. He will review and approve the QAPP and willcoordinate all environmental activities with the contractors. . He can be reached at (714) 484-5449.

Contractors

Ms. Nichole Pagano (Arcadis) and Mr. Shayan Simantob (EFI Global) are the contractorProject Managers (PMs) for providing environmental services to the Design Team. In thiscapacity, they will be the primary liaison between the DTSC and Arcadis/EFI Global.

Contractor Technical Manager

The Contractor Technical Manager will be responsible for all field work coordination. TheTechnical Manager reports to the Project Manager and provides support in terms of ensuringoverall adequacy of approaches, maintaining oversight of sampling and analysis activities, andperforming technical review of deliverables, and coordination of other technical issues that mayarise on the project.

The Contractor Technical Manager for Arcadis is Ms. Sonal Patil, and the Contractor TechnicalManager for EFI Global is Mr. Scott Myers.

Contractor Field Manager (FM)

The Contractor FM exercises project oversight of the field investigation/remedial actionactivities and reports to the project manager. The FM oversees the day-to-day progress of theinvestigation/remedial action, including manpower, scheduling, and compliance with theQAPP. The FM is also responsible to the PM for the conduct of site investigation/remedialaction activities and the coordination and scheduling of subcontract support. Responsibilities ofthe FM include the following:

Supervising the field team, including field geologists, technicians, and subcontractors;

Correcting non-conformance issues identified in field methods;

Implementing field health and safety protocols, and interacting in field proceduretraining for all newly assigned field personnel; and

Ensuring compliance with the QAPP in handling and recording field samples.


The Field Manager for Arcadis is Mr. Eugene Sulyma, and the Field Manager for EFI Global isMr. Steven Perez.

Contractor QA Officer

The Contractor QA Officer reports to the contractor PM and coordinates directly with thecontractor FM. The Project QA Officer is responsible for ensuring that sufficient QAprocedures are developed for the project, that adequate quality controls are imposed to achievethe required level of QC and that the controls are implemented properly. Each contractor QAManager has the authority to initiate nonconformance reports and corrective actions based onlaboratory actions and information. Responsibilities of the QA Officer include the following:

Ensuring that project-required QA/QC procedures are clearly specified for field andlaboratory activities;

Working directly with the PM, field personnel, and the laboratory's PM to ensure thatchemical data collection and analytical procedures are adequate for the project-specified level of data quality;

Ensuring that system and performance audits are routinely performed by thesubcontract laboratory;

Acting as the PM’s point of contact with the subcontract laboratory; and

Ensuring adequate project preparation, quality review, and submittal of the dataquality assessment (DQA) report.

The Contractor QA Officer for Arcadis is Ms. Nichole Woods, and the Contractor QA Officerfor EFI Global is Mr. Scott Myers.

Laboratory QA Officer

The Laboratory QA Officer is responsible for ensuring that sufficient QA procedures areapplied to laboratory analyses. The Laboratory QA Officer is also responsible for ensuring thatadequate laboratory controls are utilized for a high level of data quality, and that data programrequirements and data quality objectives (DQOs) are met.

Responsibilities of the Laboratory QA Officer include the following:

Initiating nonconformance reports and/or corrective actions as necessary;

Verifying completion of corrective actions for major non-conformances issues cited inaudits;

Reviewing all statistical data to verify that the analytical laboratories are meetingstated QC goals; and


Coordinating with the Project Chemist and Laboratory Project Manager.

Mr. Lawrence Lem (Eurofins/ Calscience), and Mr. David Dawes (TestAmerica) are theLaboratory QA Officers for the primary laboratories.

For overflow labs, Mr. Oommen Kappil (EMSL) and Ms. Kathy Nguyen (Pace Analytical) arethe Laboratory QA officers.

Laboratory Project Manager

Each Laboratory Project Manager (PM) is the primary point-of-contact at the analyticallaboratory for the project, and is responsible for ensuring project data meet the QA/QCobjectives established herein. The Laboratory PM is also responsible for tracking the progressof testing in the laboratory and ensuring the timely delivery of data or other laboratorydeliverables to the project team.

Mr. Stephen Nowak (Eurofins/ Calscience), and Ms. Lena Davidkova (TestAmerica) are theprimary Laboratory PMs.

For overflow labs, Mr. Michael Chapman (EMSL) and Mr. Scott Forbes are the LaboratoryPMs.


2.0 DATA QUALITY OBJECTIVES

The objective of collecting and analyzing environmental samples for this project is to ascertainthe distribution of chemicals of potential concern (COPCs), primarily lead for this project, insurface and near-surface soils at various residential and sensitive-use properties near the Site.At those properties where lead concentrations exceed established thresholds, soil removal andrestoration activities will be performed and environmental sampling will be performed toconfirm the effectiveness of the cleanup. This QAPP has been developed for use in conjunctionwith sampling activities to be undertaken at the site, and describes the QA/QC procedures andprotocols that will be used during sample analysis. The QAPP will serve as a controllingmechanism during the investigation/remedial action to ensure that a sufficient quantity of datais collected and that all data collected are valid, reliable, and defensible.

An effective QA program addresses DQOs for both field sampling and laboratory methods.The field QA efforts will focus on ensuring that samples are representative of the conditionsin the various environmental media at the time of sampling and that the field analyticalapproach is properly implemented. Both field-based analytical and off- site fixed-basedsubcontract laboratory QA efforts will be aimed primarily at ensuring that analyticalprocedures provide sufficient accuracy and precision to reliably quantify contaminant levelsin environmental samples. The subcontract laboratory will also ensure that analyzed portionsare representative of each sample.

Per USEPA (2000), the DQO process is a seven-step systematic planning process used todevelop sampling designs for data collection activities that support decision making. Thesystematic planning process is applied during the development of a sampling approach usingqualitative or quantitative statements to clarify study objectives, define a sampling approach forcollecting and analyzing data (e.g., location and number of samples to collect, field samplingmethods, analytical methods, etc.), identify critical decision points, determine decision criteriaand rules, and specify tolerable levels of potential decision errors. The seven steps of the DQOprocess are:

1. State the Problem

2. Identify the Decision

3. Identify the Decision Inputs

4. Define the Boundaries of the Study

5. Develop Decision Rules

6. Specify Tolerance Limits on Decision Errors

7. Optimize the Design for Obtaining Data


The DQO process was applied during the development of the soil sampling approach and issummarized in Table 1. The primary DQO decision question for the soil investigation is todetermine if soil concentrations at individual properties exceed the site-specific soil screeninglevel for lead of 80 mg/kg, which is protective of incidental ingestion, dermal contact, andinhalation of particulates (see Step 2 in Table 1).

2.1 ANALYTICAL DATA QUALITY LEVELS

The analytical levels for this project’s DQOs will conform to the two USEPA-definedcategories of data. These data categories are defined below:

Screening Data - Screening data are generated by more rapid, generally less precisemethods of analysis with less rigorous sample preparation. Sample preparation steps may berestricted to simple procedures such as removing non-soil particles (e.g., roots) within the soilmatrix. Screening data generally provide less-certain quantification of contaminantconcentrations.

Definitive Data - Definitive data are generated using rigorous analytical methods, such asapproved USEPA reference methods. Data are analyte-specific, with confirmation ofanalyte identity and concentration. Methods produce tangible raw data (e.g., chromatograms,spectra) in the form of hard-copy printouts or computer-generated electronic files. Data maybe generated at the site or at an off-site location, as long as the QA/QC requirements aresatisfied. For the data to be definitive, either analytical or total measurement error must bedetermined. Results of fixed-based laboratory analyses of samples collected at the site underthis QAPP will be considered definitive data.

Screening data and definitive data quality levels will be used as indicated below:

Screening analyses will be used for screening air in worker breathing zones for healthand safety purposes.

Screening XRF analyses will be used to rapidly characterize concentrations of lead (andother metals as necessary) in soil at the large number of properties that will be evaluatedduring anticipated sampling efforts.

Definitive analyses from an off-site fixed laboratory will be used to confirm the XRFresults and provide data to support a performance evaluation study with regards to theaccuracy and representativeness of the XRF results.

Definitive analyses from an off-site fixed laboratory will be used on an as-needed basisto support waste characterization requirements associated with off-site disposal of lead-impacted soils from the remediation phase of the work.


2.2 DATA QUALITY ASSESSMENT CRITERIA

DQA criteria will be used to evaluate the quality of the field sampling efforts, fieldscreening results, and fixed-base laboratory results for compliance with project DQOs. TheDQA criteria are expressed in terms of analytical precision, accuracy, representativeness,completeness, and comparability (PARCC). Procedures used to assess data accuracy andprecision are in accordance with USEPA's (1996) Test Methods for Evaluating Solid Waste:Physical/Chemical Methods, SW-846.

2.2.1 PRECISION

Precision measures the reproducibility of repetitive measurements. It is strictly defined as thedegree of mutual agreement among independent measurements as the result of repeatedapplication of the sample process under similar conditions.

Analytical precision is a measurement of the variability associated with duplicate or replicateanalyses of the same sample in the laboratory, and is determined by analysis of laboratoryquality control samples, such as duplicate control samples (LCSD or DCS), field designatedmatrix spike duplicates (MSD), or sample duplicates. If the recoveries of analytes in thespecified control samples are comparable within established laboratory control limits, thenprecision is within limits.

Total precision is a measurement of the variability associated with the entire sampling andanalytical process. It is determined by analysis of duplicate or replicate field samples, andmeasures variability introduced by both the laboratory and field operations. Field duplicatesamples are analyzed to assess field and analytical precision.

Duplicate results are assessed using the relative percent difference (RPD) between duplicatemeasurements. If the RPD for laboratory quality control samples exceeds the laboratory’sstatistically determined acceptance ranges, data will be qualified as described in the applicablevalidation procedure. If the RPD between Field duplicate samples exceeds 35 percent for soil,data will be qualified as described in the applicable validation procedure. The RPD will becalculated as:

RPD = × 100

where:

x1 = analyte concentration in the primary sample,x2 = analyte concentration in the duplicate sample, andX = average analyte concentration of the primary and the duplicate

sample = (x1 + x2)/2


2.2.2 ACCURACY

Accuracy is a measure of the closeness of a reported concentration to the true value. Accuracyis expressed as a bias (high or low) and is determined by calculating percent recovery (%R)from MS/MSDs, post digestive spikes (PDSs), LCSs, and surrogate spikes. MS/MSD, PDSs,and surrogate spike recoveries indicate accuracy relevant to a unique sample matrix. LCSrecoveries indicate accuracy relevant to an analytical batch lot, and are strictly a measure ofaccuracy conditions in preparation and analysis independent of samples and matrices. The %Rof an analyte, and the resulting degree of accuracy expected for the analysis of spiked samplesfor QC, are dependent upon the sample matrix, method of analysis, and the compound orelement being measured. The concentration of the analyte relative to the detection limit of themethod is also a major factor in determining the accuracy of the measurement.

Accuracy expressed as %R is calculated as follows:

%R = × 100

where:

A = measured concentration in spiked sample,B = measured sample concentration (without spike), andC = concentration of spike added.

The laboratory shall have procedures in place for establishing and updating accuracy controllimits. Typical control limits for accuracy are based on the historical mean plus or minus threestandard deviations. Statistically-derived laboratory accuracy limits are updated semiannually.If the percent recovery is determined to be outside of acceptance criteria, data will be qualifiedas described in the applicable validation procedure.

Field accuracy will be assessed in the laboratory through the analysis of field equipment blanks.Analysis of blanks will monitor errors associated with the sampling process, fieldcontamination, sample preservation, and sample handling. The DQO for field equipmentblanks is that all values are less than the practical quantitation limit (PQL) for each targetconstituent. If contamination is reported in a field equipment blank, data will be qualified asdescribed in the applicable validation procedure (USEPA National Functional Guidelines,2016).

2.2.3 COMPLETENESS

Completeness is defined as the percentage of laboratory measurements judged to be valid on amethod-by-method basis. Valid data are defined as all data and/or qualified data considered to


meet the DQOs for this project. Data completeness is expressed as percent complete (PC) andshould be 90 percent. The goal for meeting analytical holding times is 90 percent. At the endof each sampling event, the completeness of the data will be assessed. If any data omissions areapparent, new samples will be collected and reanalyzed for the parameter in question, iffeasible. In addition, appropriate corrective action will be implemented to ensure that objectivesare met in the future. Laboratory results will be monitored as they become available to assesslaboratory performance and its effect on data completeness requirements. When appropriate,additional samples will be collected to ensure that laboratory performance meets PCrequirements.

PC is calculated as follows:

= × 100

where:

NA = Actual number of valid analytical results obtained, and

Ni = Theoretical number of results obtainable under ideal conditions.

2.2.4 COMPARABILITY

Comparability expresses the confidence with which data from one sample, sampling round, site,laboratory, or project can be compared to those from another. Comparability during sampling isdependent upon sampling program design and time periods. Comparability during analysis isdependent upon analytical methods, detection limits, laboratories, units of measure, and samplepreparation procedures.

Comparability is determined on a qualitative rather than quantitative basis. For this project,comparability of all data collected will be ensured by adherence to standard sample collectionprocedures, standard fixed laboratory analytical methods, standard field measurementprocedures, and standard reporting methods, including consistent units. For example, laboratorylead analyses will be performed on the same exact samples that were tested in the field usinginstant reading methods, such as X-ray fluorescence; or, concentrations will be reported in amanner consistent with general industry practice.

In addition, to support the comparability of fixed-base laboratory analytical results with thoseobtained from previous or future testing, all samples will be analyzed by USEPA-approved methods, where available. The USEPA-recommended maximum permissible sampleholding times (Table 2) for all parameters will not be exceeded. Whenever EPA methods arenot appropriate or available, recognized methods published by American Standard for Testing


and Materials (ASTM) or other recognized organizations with appropriate expertise will beused.

All analytical standards will be traceable to standard reference materials. Initial instrumentcalibrations shall be first order linear, and shall be checked at the frequency specified for themethods.

2.2.5 REPRESENTATIVENESS

Representativeness expresses the extent to which collected data define site chemical impact.Where appropriate, sample results will be statistically characterized to determine the degree towhich the data accurately and precisely represent a characteristic of a population, parametervariation at a sampling point, a process, or an environmental condition. Sample collection,handling, and analytical procedures are designed to obtain the most representative samplepossible. Representative samples will be achieved by the following:

Collection of samples from locations that are most likely to be representative of siteconditions (based on site scoping, previous results, statistically random sample, etc.);

Use of appropriate sampling procedures, including proper equipment and equipmentdecontamination;

Use of appropriate analytical methods for the required parameters and adequate practicalquantitation limits (PQLs); and

Analysis of samples within the required holding times.

Sample representativeness is also affected by the portion of each sample chosen for analysis.The laboratory will adequately homogenize all samples prior to taking aliquots for analysis toensure that the reported results are representative of the sample received. Because manyhomogenization techniques may cause loss of contaminants through volatilization,homogenization will not be performed for any volatile organic compound (VOC) methodanalyses.

2.3 LABORATORY OJECTIVES

All laboratory analyses will be performed by an analytical laboratory that has obtainedaccreditation through the Environmental Laboratory Accreditation Program (ELAP),administered by the California Department of Public Health (CDPH). The attached QAM forthe selected project laboratories define internal laboratory procedures for QA/QC and shallinclude descriptions of the following:

QA policies and objectives;

Organization and personnel;


Document control;

Analytical methodology standard operating procedures (SOPs);

Data generation;

Sample custody, preservation and tracking;

Data recording, reduction, review, reporting, and validation for both hard copy andelectronic formats;

Security;

Documentation of client-specific requirements;

QA audits;

QC; and

Non-conformance/corrective action report (NC/CAR) procedures.

The laboratory QAMs in Appendix A of this QAPP will be considered the approved versionsfor this project.

2.3.1 LABORATORY STANDARD OPERATING PROCEDURES (SOPS)

The laboratory must maintain SOPs for all analytical methods and laboratory operations. Theformat for SOPs must conform to the following references:

USEPA (1996) Test Methods for Evaluating Solid Waste, Physical and ChemicalMethods, SW846, 3rd Edition, Update IIB, Section One; and

USEPA (2007) Guidance for Preparing Standard Operating Procedures (SOPs), EPAQA/G6.

All SOPs must have a unique identification number that is traceable to previous revisions ofthe same document.

2.3.2 DEMONSTRATION OF CAPABILITY, ANALYST TRAINING

The laboratory QA department personnel shall maintain records documenting the ability of eachanalyst to perform applicable method protocols. Documentation will include an MDL studywith other annual and quarterly checks for each method and analyst. In addition, internal, blindperformance evaluation (PE) samples for each method and matrix demonstrating overalllaboratory performance must be submitted semi-annually.


2.3.3 LABORATORY INTERNAL AUDITS

At a minimum, the laboratory QA department personnel shall perform an annual internal(systems) audit. The internal audit will document compliance with all QAM methods, policies,and procedures. Corrective action must be implemented where required.


3.0 FIELD DATA REDUCTION, VALIDATION, AND REPORTING

The following sections describe calibration of field analytical instruments and field datareporting, validation, reduction, and review, with reference to Method 6200 or ASTM E1727-16 (Appendix B) where applicable.

3.1 FIELD RECORD KEEPING

Bound field logbooks will be maintained by the field supervisor and other team members toprovide a daily record of significant events, observations, and measurements during the fieldinvestigation/remedial action. All entries will be signed and dated. All information pertinent tothe field survey and/or sampling will be recorded in the logbooks. The logbooks will be bound,with sequentially numbered pages. Waterproof ink will be used in making all entries. Entries inthe logbook will include, at a minimum, the items listed below:

General information:

Names and titles of author and assistants;Date and time of entry;Physical/environmental conditions during field activity; andPurpose of sampling activity.

In order to provide complete documentation of the sampling event, detailed records will bemaintained by the field sampling crew. At a minimum, these records will include the followinginformation:

Sample location (e.g., street address);Sample identification;Sample location map or detailed sketch (including GPS coordinates);Date and time of sampling;Sampling method;Field observations of sample appearance and sample odor;Weather conditions;Sampler's identification;XRF readings; andAny other relevant information (e.g., moisture content).

For LBP inspections, the California Department of Public Health (CDPH) “Lead HazardEvaluation Report” form 8552 should be used to document the inspection, and who conductedthe inspection. A copy of this form is included in Appendix C.


3.2 CALIBRATION PROCEDURES AND FREQUENCY FOR FIELD TESTEQUIPMENT

Instruments and equipment used to gather, generate, or measure environmental data will becalibrated according to manufacturer’s specifications with sufficient frequency to ensureaccuracy and reproducibility of results. At a minimum, monitoring equipment used in the field,including the XRF and dust meters, will be calibrated (cross-checked) daily against a knownstandard. If the results show that the concentration is within 20 percent of the known standard,the equipment will be considered calibrated.

The XRF’s calibration will be crosschecked by analyzing Standard Reference materials (SRMs)obtained from the National Institute of Standards and Technology (NIST) for lead that includeSRM Blank (180-428) or equivalent, SRM 2709a, SRM 2586 and SRM 2710a which containlead in concentrations of approximately


3.3.2 IDENTIFICATION OF VALID SAMPLES

The identification of valid samples involves interpretation and evaluation of the field records todetect problems affecting the representativeness of environmental samples. For example, fieldrecords can indicate if unanticipated environmental conditions were encountered during fieldactivities. Records should note sample properties such as clarity, color, and odor. Photographsmay show the presence or absence of obvious sources of potential contamination (duringsampling). Judgments of sample validity will be documented in the technical report, andenvironmental data associated with any poor or incorrect field work will be identified.

3.3.3 IDENTIFICATION OF ANOMALOUS FIELD TEST DATA

Anomalous field data will be identified and explained to the extent possible. Anomalous datawill be assessed for usability and explained in the technical report.

3.3.4 ACCURACY AND PRECISION OF FIELD DATA AND MEASUREMENTS

The evaluation of the XRF’s accuracy will primarily be based on the results of the calibrationchecks completed in the field as described in Section 3.2 and a comparison of the resultsobtained from the samples analyzed by XRF in the field compared to the results obtained fromthe analysis of the confirmatory samples sent to the fixed laboratory This assessment should becompleted using correlation coefficients applied to data appropriately grouped into data setswhich may include consideration of site related variables such as spatial proximity, temporalconsiderations and/or those variables related to the sampling and analytical process such as canbe obtained by separating the data based on contractor teams(s) and/or the XRF used togenerate the data. Per EPA Method 6200, correlation coefficients will need to be above 0.7 tobe considered valid as screening level data

Field preparation and analytical precision will be evaluated by collecting a XRF Field Duplicatefield sample from Ziploc bag or jar containing the sample to be sent to the fixed laboratory forthe analyses of lead. The XRF Field Duplicate sample will be sieved, cupped and analyzed inthe same manner as original sample. Further details regarding this process are described belowin Section 4.2.

In addition to the above, evaluations of accuracy and precision may also be influenced by areview of any field corrective actions.

3.4 FIELD DATA VALIDATION

Screening data will constitute all analytical method results from analyses performed in a fieldlaboratory environment including XRF analyses. The Project Chemist will determine if DQOs forfield data have been met, and also will calculate the percent complete (PC) for field data results.

At a minimum, the review of screening data will focus on the following topics:


Holding times;Method blanks;

Field instrumentation calibration and detection limits; andCompleteness of data.

Field data will be validated using the procedures described below:

Routine checks (e.g., looking for errors in identification codes) will be madeduring the processing of data.Routine review and verification of field notebooks.

Internal consistency of a data set will be evaluated. This step will involve plotting thedata and testing for outliers.

Checks for consistency of the data set over time will be performed. This can beaccomplished by comparing data sets against gross upper limits obtained fromhistorical data sets, or by testing for historical consistency. Anomalous data will beidentified.

Checks may be made for consistency with parallel data sets. An example of such acheck would be comparing data from the same volume of soil.

LBP results will be checked against United States Department of Housing and UrbanDevelopment’s (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazardsin Houston, Second Edition (2012), as well as Los Angeles County (LAC) Title 11 Health andSafety Code.


4.0 FIELD QC SAMPLES

As a check on field sampling, QA/QC samples will be collected during each sampling event.Definitions for field QA/QC samples are presented below.

4.1 CONFIRMATORY DUPLICATE SAMPLES

Approximately 10% of the XRF soil samples (up to two per property) will be sent to the off-sitefixed laboratory for analysis. These field samples will be analyzed for lead, arsenic, copper, zinc,antinomy, and cadmium by EPA method 6010B. Confirmatory samples collected will be co-located samples as XRF samples and will be given the sample designation “D” to indicate that itis a duplicate sample. While soil samples are not considered true duplicates, the confirmatorysample results serve to evaluate and assess the XRF sample result. A comparison and assessmentof the correlation between the fixed laboratory results and XRF results will be used to evaluate theXRF results (EPA method 6020, section 9.8)

4.2 XRF FIELD DUPLICATE SAMPLES

XRF Field duplicate samples will be collected from the same sample material used for the twoconfirmatory samples sent to the fixed laboratory. They are primarily intended to show that thesoil samples were properly homogenized, however, information regarding analytical precision isindicated as well. XRF Field duplicates are separately collected from the same Ziploc bagcontaining the primary sample, sieved, cupped and analyzed in the same manner as the primarysamples using the XRF. To be acceptable the result from the sample showing the lowerconcentration should be within 20% of the sample showing the higher concentration. One or moreof these cupped samples may be sent to the fixed laboratory for the analyses of lead which shouldgive a better correlation between the XRF Field data and the fixed laboratory data than sending ina jar containing the unsieved sample. However, because the cupped samples are the result of apartial sieving process, they should not be considered as representative as the unsieved material. Itis possible that after some period of evaluation , depending on the consistency of performancewith respect to comparisons between the XRF Field Duplicate pairs, that the requirement toanalyze both of the samples may be reduced to one per site or even less. It is notable, that anymaterial remaining after partial sieving should be discarded and not returned to the Ziploc bag.

4.3 FIXED LABORATORY DUPLICATE SAMPLES

Fixed laboratory duplicate samples will be collected and analyzed to evaluate sampling andanalytical precision in the fixed laboratory. Fixed laboratory duplicates are collected and analyzedin the same manner as the primary samples. Agreement between duplicate sample results willindicate good sampling and analytical precision. Field duplicates will be collected at a frequencyof 10 percent of the primary laboratory samples collected. The duplicate sample will be analyzedfor all laboratory analyses requested for the primary sample collected. If the RPD betweenprimary and field duplicate samples exceeds 35 percent, data will be qualified as described in theapplicable validation procedure and corrective actions will be implemented.


4.4 BLANKS

Equipment blanks consist of ASTM Type II water (or equivalent) poured into or pumped throughthe sampling device following decontamination. This blank is transferred to a sample bottleappropriate for the analysis and transported to the laboratory.

Equipment blanks will be prepared when a particular piece of sampling equipment was employedfor sample collection and subsequently decontaminated in the field for use in additional sampling.The equipment blank will be taken in the field by collecting a blank water rinse from theequipment (e.g. hand auger bucket) in the appropriate pre-preserved container after execution ofthe last step of the field decontamination protocol. Equipment blanks will be collected once perday unless a reduced frequency is deemed satisfactory for project quality objectives. Eachequipment blank will be stored on ice, and then analyzed for lead, arsenic, copper, zinc, antinomy,and cadmium by EPA Method 6010B.

Trip blanks are used to measure potential contamination of samples by volatile organiccompounds during transport. The trip blank consists of a vial filled by the laboratory with ASTMType II water, shipped to the field, and returned to the laboratory in a cooler that contains samplesfor VOC analysis. A trip blank shall be included in every cooler containing samples for VOCanalysis (Method 8260); the trip blank sample will be analyzed for VOCs. A trip blank shall beincluded in every cooler containing samples for analyses for TPH-g (Method 8015) and analyzedfor TPH-g (Method 8015). VOC and TPH analyses will not generally be performed on this projectalthough may be required in certain instances for waste characterization or backfill samplingpurposes.

If contamination is reported in the trip blanks and equipment blanks, data will be qualified asdescribed in the applicable validation procedure per USEPA National Functional Guidelines(2016).


5.0 SAMPLING PROTOCOLS

Detailed soil sampling protocols are provided in the final Sampling and Analysis Workplan(Parsons, 2016).

5.1 SAMPLE CONTAINERS

The laboratory will provide sample containers, labels, chain-of-custody forms, and coolers to theproject site. Properly cleaned sample containers must be used so that no target compoundcontamination occurs from contact with the sample container. The laboratory will providedocumentation attesting to the cleanliness of the containers following their cleaning procedures. Acertificate of cleanliness will be provided for any commercially purchased sample containers.

It is equally important to use preservative reagents that are free of target analytes or othercontaminants. The laboratory will provide documentation attesting to the purity and quality of thereagents being provided.

Table 2 lists the types of sample containers, sample volumes, methods of preservation, andholding times for each parameter. Field team members will ship or courier samples directly to thelaboratory at the end of each sampling day, which will enable the laboratory to analyze thesamples within the specified holding times.

5.2 SAMPLE CONTAINMENT, PRESERVATION, AND LABELS

Sample containers and preservatives defined in Table 2 will ensure compatibility with USEPAprotocols and will minimize breakage during transportation. Sample labels will be affixed to eachcontainer to identify the sample number, collector's name, date and time of collection, location ofsampling point, analyses requested, and preservatives added. Primary soil samples collected forEPA 6010B analyses do not need to be placed on ice. However, samples collected for all otheranalyses, including equipment blanks and trip blanks do require ice preservation.

5.3 FIELD SAMPLE IDENTIFICATION

A sample numbering system will be used to identify each sample collected during fieldinvestigations, including field QC samples. The numbering system will be a tracking mechanismto allow retrieval of information about a particular location and to ensure that each sample isuniquely numbered. A listing of sample numbers will be maintained by the field team leader.

Samples will be identified first by a unique property number and a unique sample identificationnumber. Soil samples will also include the bottom depth of the sampling interval. The followingis an example of the sampling nomenclature:

XRF and Laboratory Soil Samples

(Property Number – Sample Number - Bottom Depth of Sample Interval)


PIA0001-01-03 (for 0 to 3 inches)




XRF and Laboratory Paint Samples

(Property Number – Sample Number)

PIA0001-01-LBP

Duplicate samples will be collected for samples submitted to the laboratory. All duplicatesamples will be identified with a “D”, for example, PIA0001-01-3D.

Other quality assurance samples will have the following IDs:

Trip blanks – (TP-Property Number-Date) TP-PIA0001-111715

Equipment Blanks – (EB-Property Number-Date) EB-PIA0001-111715

Field Blanks – (FB-Property Number-Date) FB-PIA0001-111715

5.4 SAMPLE CHAIN-OF-CUSTODY

Sample custody begins in the field at the time of collection and continues throughout thelaboratory analytical process. Chain-of-custody forms will be prepared at the time of samplecollection and will accompany the samples to the laboratory and through the laboratory sampleprocessing. Chain-of-custody forms will be completed for each cooler in a shipment of samples totrack the samples and provide a written record of all persons handling the samples. The followinginformation for each sample will be documented on the chain-of-custody form:

Unique sample identification;

Date and time of sample collection;

Source of sample (including name, location, and sample type);

Designation of MS/MSD;

Analyses required;

Name(s) of collector(s);

Custody transfer signatures (wet ink or electronic), and dates and times of sampletransfer from the field to couriers and to the laboratory; and


Bill of lading or transported tracking number (if applicable).

Shipments will be sent by courier for daily delivery to the laboratory.

5.5 LABORATORY CUSTODY PROCEDURES

Laboratory sample custody procedures must be presented in the laboratory QAM and approved bythe project manager prior to shipping any samples to the laboratory. To facilitate thedocumentation of sample custody, the laboratory will track the progress of sample preparation,analysis, and report preparation. Samples received by the laboratory will be checked carefully forlabel identification, chain-of-custody forms, and any discrepancies. The laboratory will also noteand record cooler temperatures, physical damage, incomplete sample labels, incompletepaperwork, discrepancies between sample labels and paperwork, broken or leaking containers,and inappropriate caps or bottles. The laboratory will send signed facsimile copies of all chains-of-custody and sample log- in receipt forms to the c o n t r a c t o r field manager (FM) within 24hours of sample receipt in the laboratory. All discrepancies and/or potential problems (e.g., lackof sample volume) will be discussed immediately with the FM.

The laboratory sample custodian will provide a report to the FM of any problems observed withany of the samples received. This report will also document the condition of samples, samplenumbers received, corresponding laboratory numbers, and the estimated date for completion ofanalysis. Written permission must be received from the FM before sending any samples originallyscheduled to be analyzed at its facility to another laboratory. Analyses will not be performed onsamples whose integrity has been compromised or is suspect, without prior approval from the FM.

5.6 SAMPLE HANDLING

Laboratory sample custody will be maintained by the procedures detailed in the laboratoryQAM.

If the chain-of-custody and samples correlate, and there has been no tampering withthe custody seals, the "received by laboratory" box on the chain-of-custody form willbe signed and dated (wet ink or electronically).

The samples will be logged into the laboratory information management system insuch a manner that tracking the status of the samples (extraction, analysis dates) canbe readily accomplished.

Water samples will be stored in a secured area at a temperature of approximately 42 degrees Celsius (°C) for all analytical fractions except for metals. Soil samples

may be stored at lower temperature (as applicable) until analyses commence.Samples must be stored in coolers separate from those used to store analyticalstandards, reagents, and/or QC samples.

Volatile samples will be stored separately from other samples. A storage blank


must be present in the cooler storing volatile samples and analyzed weekly at aminimum. Results of storage blank analyses must be maintained by the QAdepartment. Corrective action is required if analyses provide evidence of crosscontamination.

The original chain-of-custody form will accompany the laboratory reportsubmittal and will become a permanent part of the project records.

Data generated from the analysis of samples also must be kept under propercustody by the laboratory.

Samples, remaining sample material and sample containers, including XRF cups, will be retainedindefinitely or until DTSC provides a written directive to dispose.


6.0 FIXED-BASE LABORATORY ANALYTICAL PROCEDURES

Application of a specific analytical method depends on the sample matrix and the analytes to beidentified. Methods for each of the parameters likely to be included in the analytical program, aswell as detection limits, are discussed in the following subsections. All analytical methods areUSEPA approved. Samples will be maintained for an extended period before disposal to allowreview of data and to maintain the option of reanalysis if the results are suspect. Samples will bemaintained under a laboratory internal chain of custody system, in order to retain sample integritydocumentation.

6.1 ANALYTICAL METHODS

Analytical procedures will follow established USEPA method protocols. Approved methods arepresented in summarized below. The referenced methods are defined in the USEPA TestMethods for Evaluating Solid Waste, Physical and Chemical Methods, SW846, 3rd Edition,Update III (1996). Whenever SW-846 methods are not appropriate, recognized methods fromsource documents published by USEPA, ASTM or other organizations with appropriateexpertise will be used. While most analyses required for this project will focus on metals,particularly lead, it is anticipated that other analytical methods will be required for otherproject purposes (e.g., to support waste characterization or backfill sampling). Depending onwaste disposal facility requirements, sample analysis may include some or all of the followingmethods:

Exide Facility Off-Site Laboratory Analytical Methods

SOIL SAMPLES

PARAMETER PREPERATION METHOD ANALYSIS METHOD

Lead, Copper, Zinc, Antimony, Cadmium EPA 3050B EPA 6010B

Mercury EPA 7471B EPA 7471B

Total Metals EPA 3050B EPA 6010B/ 6020

Total Organic Carbon (TOC) N/A EPA 9060A/ SM 53110B

Semivolatile Organic Compounds(SVOCs)

EPA 3545/ 3546 EPA 8270C

Volatile Organic Compounds (VOCs) EPA 5030C EPA 8260B

Polychlorinated Biphenyls (PCBs) EPA 3545/ 3546 EPA 8082

Organochlorine Pesticides EPA 3545/ 3546 EPA 8081A/ 8081B

Chlorinated Herbicides EPA 8151A EPA 8151A

Total Petroleum Hydrocarbons –Gasoline Range Organics (GRO)

EPA 5030C EPA 8015B

Total Petroleum Hydrocarbons –Diesel Range Organics (DRO), Oil

EPA 3550B/ 3546 EPA 8015B


Range Organics (ORO)Chloride, Nitrate, Sulfate N/A EPA 300.0

WATER SAMPLES

PARAMETER PREPERATION METHOD ANALYSIS

Lead, Copper, Zinc, Antimony, Cadmium EPA 3010A/ 3005A EPA 6010B

Mercury EPA 7470A EPA 7470A

Total Metals EPA 3010A/ 3005A EPA 6010B/ 6020

Total Organic Carbon (TOC) N/A EPA 9060/ SM 5310B

Semivolatile Organic Compounds(SVOCs)

EPA 3510C/ 3520C EPA 8270C

Volatile Organic Compounds (VOCs) EPA 5030C EPA 8260B

Polychlorinated Biphenyls (PCBs) EPA 3510C EPA 8082

Organochlorine Pesticides EPA 3510C EPA 8081B

Chlorinated Herbicides EPA 8151A EPA 8151A

Total Petroleum Hydrocarbons – GasolineRange Organics (GRO)

EPA 5030C EPA 8015B

Total Petroleum Hydrocarbons – DieselRange Organics (DRO), Oil RangeOrganics (ORO)

EPA 3510C EPA 8015B

Chloride, Nitrate, Sulfate N/A EPA 300.0

6.2 DETECTION AND QUANTITATION LIMITS

This section describes the terms, definitions, and formulas that will be used for detection andquantitation limits.

6.2.1 METHOD DETECTION LIMIT

The MDL is defined as the minimum concentration of a substance in a sample that can bemeasured and reported with 99 percent confidence that the analyte concentration is greater thanzero and is determined from analysis of a sample in a given matrix containing the analyte. Thelaboratories shall establish MDLs for each method, matrix, and analyte for each instrument thelaboratories plans to use for the project. The laboratories shall revalidate these MDLs at leastonce per 12-month period. For this project, the MDL verifications will be performed prior to theanalysis of the first sample delivery group.

.


6.2.2 PRACTICAL QUANTITATION LIMIT

The practical quantitation limits (PQL) are the lowest matrix-specific concentrations that can bereliably achieved within specified limits of precision and accuracy during routine laboratoryoperating conditions. All sample results will be reported at or above the PQL for each analyte.Where practical, PQLs must be lower than the risk-based criteria determined for the project.Laboratories must verify the PQLs by analyzing a standard at or below the PQL when performingthe initial calibration curve. The PQL is the value that indicates whether the analytical DQOs havebeen achieved for that sample.

6.2.3 DETECTION LIMIT GOALS

To define analytical data PQLs that meet project DQOs, potential risk-based screening criteriathat the DTSC has adopted for the Exide project were considered. For lead, the risk-based soilscreening criteria of 80 mg/kg will serve as the primary residential soil cleanup goal. This levelwill be easily achieved by the indicated analytical method. However, a lower PQL is necessary tosupport the statistical evaluations that will be utilized to estimate average soil-lead concentrationsat individual residential properties. Therefore, in order to characterize the potential full range oflead concentrations that may be encountered, a lead PQL of 1.0 mg/kg is specified.


7.0 LABORATORY QC SAMPLES AND CRITERIA

In order to ascertain the precision and accuracy of the analysis, the analytical laboratory willanalyze a routine set of QC samples. In addition to precision and accuracy, the QA system isdesigned to illuminate any issues which may be present due to matrix interferences andsample contamination. These procedures are detailed in the laboratory’s Quality AssuranceManual (QAM). At a minimum, the laboratory must prepare and analyze a method blank, alaboratory control sample (LCS), and a laboratory sample duplicate. A matrix spike/matrixspike duplicate (MS/MSD) shall be analyzed with each batch, providing sufficient samplewas provided to the laboratory by the sampling team. If there is insufficient sample forMS/MSD, the laboratory will prepare and analyze the LCS in duplicate. In this manner, ameasure of the precision pertaining to the specific analytical batch can be determined. Inaddition, for EPA 6010B, a post digestion (PDS)/ PDS duplicate analyses shall be performedfor those analytes that do not meet specified MS/MSD criteria; and a dilution test (1:5 serialdilution) shall be performed if the analyte concentration in the sample after dilution, isminimally a factor of ten above the PQL (EPA method 6010B, section 8.5.1).

Precision objectives and accuracy objectives will be based on statistically generated limitsestablished semi-annually by the analytical laboratory. If a bias is determined, the associateddata will be qualified (National Functional Guidelines) and the direction of the bias indicatedin the data validation report.


8.0 LABORATORY DATA REVIEW, REPORTING, AND ASSESSMENT

The following sections describe the project minimum requirements for laboratory data review,reduction, and reporting. The laboratory through its QAM and SOPs shall specify the personnelperforming each function.

8.1 LABORATORY REVIEW PROCEDURES FOR DEFINITIVE DATA

The laboratory review of definitive data shall be a four-step process involving an evaluation bythe analyst, a peer review, an administrative review, and a QA review. A checklist to documenteach of the review processes will be required and must be included as part of the final datadeliverable. All steps are described below.

The analyst shall review 100 percent of all definitive data prior to reporting. The establishment ofmethod detection and control limits shall be verified. Any control limit outside the acceptableranges specified in the analytical methods shall be identified. Any trends or problems with thedata shall be evaluated. The absence of records supporting the establishment of controlcriteria or detection limits shall be noted and explained. Analytical batch QC, calibrationcheck samples, initial and continuing calibrations, corrective action reports, the results ofreanalysis, sample holding times, and sample preservations shall be evaluated.

Samples associated with out-of-control QC data shall be identified in the data package casenarrative, and an assessment of the utility of such analytical results shall be made. The checkof laboratory data completeness must be documented and will ensure that:

All samples and analyses specified in the chain-of-custody have been processed;

Complete records exist for each analysis and the associated QC samples; and

Procedures specified in this QAPP have been implemented.

An analyst other than the original data processor shall be responsible for performing a peer reviewof all steps of the data processing. One hundred percent of all data shall be reviewed. All inputparameters, calibrations, and transcriptions will be checked. All manually input, computer-processed data will be checked. Each page of checked data shall be signed and dated by theverifier.

QC data must meet acceptance levels prior to processing the analytical data. If QC standards arenot met, the cause shall be determined. If the cause can be corrected without affecting theintegrity of the analytical data, processing of the data shall proceed. If the resolution jeopardizesthe integrity of the data, reanalysis shall be performed, if still within holding time. If the holdingtime will be exceeded, the decision regarding reanalysis will be made upon conferring with theContractors PM or designee.

An administrative review will be performed by the laboratory project manager on each data


deliverable package. The review will ensure that all requirements of the laboratory and the datadeliverables have been met and are complete.

A review of at least 10 percent of all data deliverable packages by a laboratory QA Officer musttake place prior to the administrative review and final release of the data deliverable. The datapackages will be randomly selected for review.

8.2 LABORATORY DATA REPORTING AND QUALIFIERS

Laboratory analytical data will contain the necessary sample results and quality control data toevaluate the DQOs defined for the project. Documentation requirements for laboratory data aredefined in USEPA Region 9 Draft Laboratory Documentation Requirements for Data Validation(USEPA 2001b). The laboratory reports for 100% of the data will be consistent with USEPALevel III documentation and include the following data and summary forms:

Narrative, cross-reference, chain of custody, and method references;

Analytical results;

Surrogate recoveries (as applicable);

Blank results;

Initial and continuing Calibration Blank Summaries

Initial Calibration Check Summary;

Continuing Calibration Check Summaries

Instrument tuning summary (as applicable);

Internal standard area count and retention time summary (as applicable);

Laboratory control sample recoveries;

Sample Preparation Summary

Analysis Sequence Log;

Matrix spike recoveries;

Post Digestion Spike recoveries(as applicable);

Duplicate sample results and duplicate spike recoveries;

Serial Dilution(as applicable); and

If multiple dilutions are performed, the results of each dilution are to be reported.

In addition, for EPA 6010B, the laboratory report for 10% of the data will be consistent withUSEPA Level IV documentation: In addition to the summary information, the laboratory will


provide all supporting raw data for all samples, standards, QC samples, digestion logs, benchsheets, and run logs will be included in the data package. All sample receiving information,including the executed COCs, air bills, sample receipt checklist, SDG assignment sheet, and anyother correspondence relevant to the SDG, will be provided.

Data will be provided by the laboratory in electronic format on CD in a portable data format(PDF). The PDF will contain all information necessary to reproduce the analytical resultsreported for each chemical compound for each sample.

The laboratories must only use the following qualifiers when reporting sample results. However,the laboratories may provide footnotes for other QC non-conformances.

The following qualifiers must be used by the laboratory when reporting sample results.

Qualifier Description

J The analyte was positively identified; the quantitation is an estimation.

U The analyte was analyzed for, but not detected. The associatednumerical value is at or below the PQL.

B The analyte was found in an associated blank, as well as in the sample.

8.3 CONTRACTOR ASSESSMENT OF DATA USABILITY

Quality assurance oversight will be performed by each DTSC contractor to ensure that theestablished QC procedures are followed. Activities to be conducted as part of the QA objectivesinclude data validation.

Data validation criteria are derived from the USEPA Contract Laboratory Program NationalFunctional Guidelines for Laboratory Data Review, Organics and Inorganics (USEPA 2016). TheNational Functional Guidelines provide specific data validation criteria that will be applied to datagenerated for this investigation.

Limited data validation (EPA stage 2B) will be performed on all laboratory data. Full datavalidation (EPA stage 4) will be performed on 10 percent of the laboratory data. The limited datavalidation uses the same criteria contained in the USEPA Contract Laboratory Program NationalFunctional Guidelines for Organic and Inorganic Data Review (USEPA 2016); however, thereviews do not include checking the raw data, and calculations. Instead, limited data validationutilizes the data summary and QA/QC summary provided in the laboratory standard report. Fulldata validation includes checking the raw data, calibrations, and calculations is in accordance withthe principles presented in USEPA National Functional Guidelines for Laboratory Data Review,Organics and Inorganics (EPA 2016).


Documentation requirements for level III and level IV validation are listed in section 8.2.

The laboratory data will be reviewed for quality and compliance with the applicable method andlaboratory analytical SOPs. The following summarizes the areas of data validation:

Data Completeness;

Holding Times;

Blanks;

Calibrations;

Laboratory Control Samples;

Matrix Spike/Matrix Spike Duplicates;

Post Digestion Spike/ Post Digestion Spike Duplicates;

Interference Check Samples (Full Validation);

Serial Dilutions;

Surrogate recoveries;

Field Quality Control Samples; and

Compound Identification and Quantification.

The application of data validation criteria is a function of project-specific DQOs. The contractorQA Officer will determine if the data quality objectives for the analytical data have been met.Results of the data validation review will be documented and summarized in a Data ValidationMemorandum, which is summarized in the final investigation report.

8.3.1 DATA VALIDATION QUALIFIERS

The following definitions provide explanations of the USEPA CLP National FunctionalGuidelines (2016) qualifiers to be assigned to analytical results during data validation. The dataqualifiers described are applied to sample results.

Qualifier Description

U The analyte was analyzed for and is not present above the reported samplequantitation limit.

J The analyte was analyzed for and was positively identified, but the associatednumerical value may not be consistent with the amount actually present in the


environmental sample. The data should be considered as a basis for decisionmaking and are usable for many purposes.

J+ The result is an estimated quantity, but the result may be biased high.

J- The result is an estimated quantity, but the result may be biased low.

R The data are rejected as unusable for all purposes. The analyte was analyzedfor, but the presence or absence of the analyte was not verified. Resamplingand reanalysis are necessary to confirm the presence or absence of the analyte.

UJ The analyte analyzed for was not present above the reported samplequantitation limit. The associated numerical value may not accurately orprecisely represent the concentration necessary to detect the analyte in thesample.

8.3.2 ASSESSMENT OF USABILITY

Data usability will be assessed by the contractor QA Officer based on data evaluation results todetermine the project PARCCs. Targeted data validation and evaluation will be performed onany result that appears to be unusual or outside the expected range. Any limitations on datause will be expressed quantitatively to the extent practicable. The outcome of this datareview will be a data set appropriate to support project-specific DQOs. A DQA will bewritten, summarizing the findings of the data review, and providing an assessment of overalldata quality and usability.


9.0 QA REPORTS

At intervals recommended by DTSC, beginning with the initiation of sampling activities, thelaboratory will submit an internal QA report that documents laboratory-related QA/QC issues tothe contractor’s project manager. These reports will include discussions of any conditions adverseor potentially adverse to quality, such as:

Responses to the findings of any internal or external systems or performance laboratoryaudits;

Any laboratory or sample conditions that necessitate a departure from the methods orprocedures specified in this QAPP;

Any missed holding times or problems with laboratory QC acceptance criteria; and

The associated corrective actions taken.

Submittal of QA reports will not preclude earlier contractor notification of such problems whentimely notice can reduce the loss or potential loss of quality, time, effort, or expense. Appropriatesteps will be taken to correct any QA/QC concerns as they are identified. The QA reports and asummary of the laboratory QA/QC program and results will be included in the final project report.


10.0 CORRECTIVE ACTION

The following procedures have been established to assure that conditions adverse to dataquality are promptly investigated, evaluated, and corrected. Adverse conditions mayinclude malfunctions, deficiencies, deviations, and errors.

When a significant condition adverse to data quality is noted at the laboratory, the cause of thecondition will be determined, and corrective action will be taken to prevent repetition. Conditionidentification, cause, reference documents, and corrective action planned will be documentedand reported to the contractor QA Officer by the laboratory QC coordinator. Followingimplementation of corrective action, the laboratory QA Officer will report the actions taken andtheir results to the contractor project manager and QA Officer. A record of the action taken andresults will be attached to the data report package. If samples are reanalyzed, the assessmentprocedures will be repeated, and the control limits will be reevaluated to ascertain if correctiveactions have been successful.

Implementation of corrective action is verified by documented follow-up action. All projectpersonnel have the responsibility, as part of the normal work duties, to identify, report, andsolicit approval of corrective actions for conditions adverse to data quality.

Corrective actions will be initiated in the following instances:

When predetermined acceptance criteria are not attained (objectives for precision,accuracy, and completeness);

When the prescribed procedure or any data compiled are faulty;

When equipment or instrumentation is determined to be faulty;

When the traceability of samples, standards, or analysis results is questionable;

When QA requirements have been violated;

When designated approvals have been circumvented;

As a result of systems or performance audits;

As a result of regular management assessments;

As a result of intra-laboratory or inter-laboratory comparison studies; and

At any other instance of conditions significantly adverse to quality.

Laboratory project management and staff, such as QA auditors, document and sample controlpersonnel, and laboratory groups, will monitor work performance in the normal course of dailyresponsibilities.


The laboratory QA Officer or designated alternate will audit work at the laboratory. Items,activities, or documents ascertained to be compliant with QA requirements will be documented,and corrective actions will be mandated in the audit report. The contractor and laboratory QAOfficers r will log, maintain, and control the audit findings.

The contractor and laboratory QA Officers are responsible for documenting all out-of-controlevents or non-conformance with QA protocols. A nonconformance report will summarize eachnonconformance condition. The laboratory PM will notify the contractor project manager or QAOfficer of any laboratory QA/QC non- conformance issues upon their discovery. Copies of allfield change requests and corrective action forms will be maintained in the project files. Astop-work order may be initiated by the contractor if corrective actions are insufficient.


11.0 AUDITS

This section describes participation in external and internal systems audits.

11.1 SYSTEM AUDITS

System audits review laboratory operations and the resulting documentation. An onsite auditensures that the laboratory has all the personnel, equipment, and internal SOPs needed forperformance of contract requirements in place and operating. The system audits ensure thatproper analysis documentation procedures are followed, that routine laboratory QC samples areanalyzed, and that any non-conformance issues are identified and resolved.

11.1.1 INTERNAL AUDITS

The laboratory must conduct internal system audits on a periodic basis. The results of these auditswill be documented by the Laboratory QA Officer, and the laboratory will provide the ProjectChemist and Task Manager with the results of these internal audits.

11.1.2 EXTERNAL AUDITS

The Project QA Officer or Task Manager may conduct an external on-site system audit of thelaboratory prior to the analysis of project samples. This audit would evaluate the capabilities andperformance of laboratory personnel, equipment, and procedures. It also documents themeasurement systems and identifies deficiencies to be corrected by the laboratory. The QAManager acts on audit results by documenting deficiencies and informing the Task Manager ofthe need for corrective action. The Task Manager may suspend operations until problems areresolved. If conditions adverse to quality are detected, or if the Task Manager requests additionalaudits, additional unscheduled audits may be performed.

In addition to this audit of the laboratory, various local, state and/or federal agencies may conductan audit prior to the commencement of the project, and/or may conduct audits as deemednecessary during project execution. The frequency and

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