appendix i – quality assurance project plan (qapp)...pia preliminary investigation area pm project...

Amended Master Excavation, Disposal, and Restoration Design Plan

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Appendix I – Quality Assurance Project Plan (QAPP)

Department of Toxic Substances Control

QUALITY ASSURANCE PROJECT PLAN (QAPP)

FOR SAMPLING AND ANALYSIS RELATED TO CLEANUP ACTIVITIES FOR PROPERTIES IN THE VICINITY OF THE EXIDE FACILITY (VERNON, CALIFORNIA)

Offsite Properties within the Exide Preliminary Investigation Area

Prepared by

The Department of Toxic Substances Control 8800 Cal Center Drive Sacramento, CA 95826

May 24, 2018

http://www.dtsc.ca.gov/index.cfm

http://www.dtsc.ca.gov/index.cfm

Quality Assurance Project Plan

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DTSC EXIDE SITE

QUALITY ASSURANCE PROJECT PLAN

REVISION HISTORY

Revision

No.

Date

Revised

By

Reason for Revision

Sections Revised


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TABLE OF CONTENTS

INTRODUCTION ..................................................................................................................1-1

1.1 PROJECT DESCRIPTION ...................................................................................................... 1-1

1.2 PURPOSE AND SCOPE OF QAPP ......................................................................................... 1-3

1.3 PROJECT OBJECTIVE ........................................................................................................... 1-3

1.4 PROJECT ORGANIZATION AND RESPONSIBILITIES ............................................................. 1-3

DTSC Key Points of Contact ............................................................................... 1-4

Contractor Key Points of Contact ...................................................................... 1-5

DATA QUALITY OBJECTIVES .................................................................................................2-1

2.1 ANALYTICAL DATA QUALITY LEVELS .................................................................................. 2-2

2.2 DATA QUALITY ASSESSMENT CRITERIA ............................................................................. 2-2

PRECISION ......................................................................................................... 2-3

ACCURACY ......................................................................................................... 2-3

COMPLETENESS ................................................................................................. 2-4

COMPARABILITY ................................................................................................ 2-5

REPRESENTATIVENESS ...................................................................................... 2-6

2.3 LABORATORY OBJECTIVES ................................................................................................. 2-6

LABORATORY STANDARD OPERATING PROCEDURES ....................................... 2-7

DEMONSTRATION OF CAPABILITY, ANALYST TRAINING ................................... 2-7

LABORATORY INTERNAL AUDITS ....................................................................... 2-7

FIELD DATA REDUCTION, VALIDATION, AND REPORTING .....................................................3-1

3.1 FIELD RECORD KEEPING ..................................................................................................... 3-1

3.2 CALIBRATION PROCEDURES AND FREQUENCY FOR FIELD TEST EQUIPMENT .................. 3-1

3.3 REVIEW OF FIELD RECORDS ............................................................................................... 3-2

COMPLETENESS OF FIELD RECORDS ................................................................. 3-2

IDENTIFICATION OF VALID SAMPLES ................................................................ 3-2

IDENTIFICATION OF ANOMALOUS FIELD TEST DATA ........................................ 3-2

ACCURACY AND PRECISION OF FIELD DATA AND MEASUREMENTS ................ 3-2

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

FIELD QC SAMPLES ..............................................................................................................4-1

4.1 FIXED LABORATORY DUPLICATE SAMPLES ........................................................................ 4-1


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4.2 BLANKS .............................................................................................................................. 4-1

SAMPLING PROTOCOLS .......................................................................................................5-1

5.1 SAMPLE CONTAINERS ........................................................................................................ 5-1

5.2 SAMPLE CONTAINMENT, PRESERVATION, AND LABELS ................................................... 5-1

5.3 FIELD SAMPLE IDENTIFICATION ......................................................................................... 5-1

Laboratory Soil Samples – Example Labeling: ................................................... 5-2

Other Quality Assurance samples – Example Labeling: .................................... 5-2

5.4 SAMPLE CHAIN-OF-CUSTODY ............................................................................................ 5-2

5.5 LABORATORY CUSTODY PROCEDURES .............................................................................. 5-2

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

5.7 LABORATORY REVIEW PROCEDURES FOR DEFINITIVE DATA ............................................ 5-3

FIXED-BASE LABORATORY ANALYTICAL PROCEDURES ..........................................................6-5

6.1 ANALYTICAL METHODS ..................................................................................................... 6-5

6.2 DETECTION AND QUANTITATION LIMITS .......................................................................... 6-6

METHOD DETECTION LIMIT .............................................................................. 6-6

PRACTICAL QUANTITATION LIMIT ..................................................................... 6-6

DETECTION LIMIT GOALS .................................................................................. 6-7

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

LABORATORY DATA REVIEW, REPORTING, AND ASSESSMENT ..............................................8-1

8.1 LABORATORY DATA REPORTING AND QUALIFIERS ........................................................... 8-1

8.2 CONTRACTOR ASSESSMENT OF DATA USABILITY ............................................................. 8-2

DATA VALIDATION QUALIFIERS ......................................................................... 8-3

ASSESSMENT OF USABILITY............................................................................... 8-4

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

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

AUDITS ............................................................................................................................. 11-1

11.1 LABORATORY AUDITS ...................................................................................................... 11-1

SYSTEM AUDITS ............................................................................................... 11-1

PERFORMANCE AUDITS .................................................................................. 11-1

DATA AUDITS ................................................................................................... 11-2

11.2 FIELD AUDITS ................................................................................................................... 11-2

PREVENTIVE MAINTENANCE .............................................................................................. 12-1


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12.1 PROCEDURES ................................................................................................................... 12-1

12.2 SCHEDULES ...................................................................................................................... 12-1

12.3 SPARE PARTS ................................................................................................................... 12-1

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

DATA DELIVERABLES ......................................................................................................... 14-1

14.1 HARDCOPY DATA DELIVERABLES ..................................................................................... 14-1

14.2 ELECTRONIC DATA DELIVERABLES ................................................................................... 14-1

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

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


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TABLES

Table 1 - Exide Facility Off-Site Laboratory Analytical Methods – Soil .................................................... ..6-5

Table 2 - Exide Facility Off-Site Laboratory Analytical Methods – Water .................................................. 6-6

Table 3 - Data Reporting Qualifiers ............................................................................................................ 8-2

Table 4 - Data Validation Qualifiers ........................................................................................................... 8-4


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FIGURES

Figure 1 - Precision ..................................................................................................................................... 2-3

Figure 2 - Accuracy ..................................................................................................................................... 2-4

Figure 3 - Completeness ............................................................................................................................ 2-5


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LIST OF APPENDICES

Appendix A Laboratory Quality Assurance Manuals

Appendix B Data Quality Objectives

Appendix C Requirements for Containers, Preservation Techniques, Sample Volumes and Holding Times

Appendix D CDPH Forms


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LIST OF ABBREVIATIONS AND ACRONYMS

%R percent recovery

µg/m3 micrograms per cubic meter

ANSI/ASQC American National Standards Institute/American Society of Quality Control

ASTM American Society for Testing and Materials

bgs below ground surface

Cal-EPA California Environmental Protection Agency

°C degrees Celsius

CLP Contract Laboratory Program

COC chain-of-custody

COPC chemical of potential concern

CDPH State of California Health and Human Services Agency, Department of Public Health

DCS duplicate control sample

DQA data quality assessment

DQO data quality objective

DRO diesel range organics

DTSC Department of Toxic Substances Control

EDD Electronic Data Deliverable

ELAP Environmental Laboratory Accreditation Program

EQuIS Environmental Quality Information System

Exide Exide Technologies

GPS global positioning system

GRO gasoline range organics

HERO DTSC’s Human and Ecological Risk Office

J estimated concentration

LAC Los Angeles County

LCS laboratory control sample

LBP lead-based paint

LOC letter of completion

MDL method detection limit

mg/kg milligrams per kilogram

MS/MSD matrix spike/matrix spike duplicate


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NC/CAR non-conformance/corrective action report

NIOSH National Institute of Occupational Safety and Health

ORO oil range organics

PARCC precision, accuracy, representativeness, completeness, and comparability

PC percent complete

PCB polychlorinated biphenyl

PDF portable data format

PDS post digestive spikes

PE performance evaluation

PIA Preliminary Investigation Area

PM project manager

ppm parts per million

PQL practical quantitation limit

PT&R Proven Technologies and Remedies

QAM quality assurance manual

QAPP quality assurance project plan

QA/QC Quality Assurance/Quality Control

RPD relative percent difference

SDG sample delivery group

SOP standard operating procedure

SWRCB California State Water Resources Control Board

SVOC semi-volatile organic compound

TAT turnaround time

TPH-g total petroleum hydrocarbons as gasoline-range organics)

TOC total organic carbon

U non-detect

UCL Upper Confidence Limit

USEPA United States Environmental Protection Agency

VOC volatile organic compound

Work Plan Master Excavation, Disposal and Restoration Design Plan

XRF X-ray fluorescence


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INTRODUCTION

This Quality Assurance Project Plan (QAPP) has been prepared for sampling conducted under the Removal Action Plan (Cleanup Plan), Offsite Properties within the Exide Preliminary Investigation Area, dated July 17, 2017, including any modifications, amendments or addenda thereto subsequently approved by DTSC (the Cleanup Plan), and the May 24, 2018 Master Excavation, Disposal and Restoration Design Plan, including any modifications, amendments or addenda thereto subsequently approved by DTSC (Work Plan) for the California Environmental Protection Agency (Cal-EPA) Department of Toxic Substances Control (DTSC) at sensitive land use properties (residential properties, schools, parks, day care centers, and child care facilities) subject to cleanup pursuant to the Cleanup Plan. The properties subject to the Cleanup Plan are located in the Preliminary Investigation Area (PIA). The PIA is the area within an approximately 1.7-mile radius the former Exide Technologies, Inc. (Exide) lead-acid battery recycling facility in Vernon, California (former Exide Facility). This QAPP presents the organization, objectives, functional activities, and specific quality assurance (QA) and quality control (QC) activities in support of anticipated sampling associated with soil excavation and disposal activities.

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

• United States Environmental Protection Agency (USEPA), Guidance on Systematic Planning Using the Data Quality Objectives Process (USEPA, 2006);

• USEPA, Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846, Revision 8 (USEPA, 2014);

• American National Standards Institute/American Society of Quality Control (ANSI/ASQC E4:1994), Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs, 1994; and

• USEPA, Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation 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 description.

1.1 PROJECT DESCRIPTION

The properties subject to this QAPP are located within the PIA. The past operational activities at the former Exide Facility resulted in releases of lead and other substances to the PIA. The PIA includes portions of the County of Los Angeles, and the Cities of Los Angeles, Commerce, Maywood, Bell and Huntington Park. The PIA encompasses approximately 10,129 sensitive land use properties.

Environmental investigations conducted to date have documented the presence of lead in soil at properties throughout much of the PIA. Using the sampling and analysis criteria for the initial prioritization, the Cleanup Plan provides for the following categories of properties within the PIA to be addressed during this phase of the cleanup:


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• Residential properties with a representative soil lead concentration1 of 400 parts per million (ppm) or higher; and

• Residential properties with a representative soil lead concentration of less than 400 ppm, but where any soil sampling result of 1,000 ppm or higher is detected; and

• Daycare and child care centers with a representative soil lead concentration of 80 ppm or higher that have not yet been cleaned up.

• All parks and schools that require cleanup will be cleaned up during this phase.

The following cleanup objectives are designed to address the impacts associated with lead-impacted soil at properties within the PIA and reduce or eliminate the potential for exposure: • Promptly clean up sensitive land use properties in the PIA in a manner that will achieve a

cleanup goal that is protective of public health and the environment. • Protect the current and future health of the residential population from exposure to lead in soil

that presents an unacceptable risk to sensitive individuals through ingestion, inhalation, and dermal or direct contact.

• Restore disturbed soils to a condition compatible with the existing and reasonably anticipated future land use.

• Minimize the volume of lead-impacted soil to be disposed in a landfill. • Minimize, to the extent practicable, the need for land use controls. • Minimize short-term adverse impacts to the residential community due to fugitive dust and soil

transport.

Sampling activities to be conducted pursuant to the Work Plan, will generally consist of the following steps:

• Collect representative pre-excavation confirmation discrete samples from locations on each property, predetermined prior to mobilizing for cleanup activities in the field. Sample locations and depths shall be selected based on the results of previous DTSC sampling efforts for each of the properties. In general, the samples will be collected from up to eight (8) sample locations at depths sufficient to determine target excavation depths for each property. The maximum excavation depth at any property shall be 18 inches below ground surface (bgs). In addition, the confirmation sample depths will be sufficient to evaluate each property’s target cleanup goal of 80 ppm in soil above the 18-inch maximum depth.

• The confirmation samples will be sent to a laboratory for analysis of total lead using U.S. EPA method 6010B with a laboratory turnaround time (TAT) of five (5) business days, 72 hours, 48 hours or 24 hours. A TAT of less than five (5) business days must be approved by the DTSC Project Manager or designee, in writing, prior to collecting samples.

• Waste profile samples will be collected from 4 locations in intervals of 0 to 6 inches bgs, 6 to 12 inches bgs, and 12 to 18 inches bgs. The soil for each 6-inch interval will be placed in a suitable container and homogenized in the field. Following homogenization, one composite sample,

1 A representative soil lead concentration is determined by the 95 percent upper confidence limit (UCL) of the mean lead concentration in soil.


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representing soil at the respective depth interval will be submitted to a laboratory for waste profile analysis. The three total composite samples (one for each depth interval representing 0 to 6 inches, 6 to 12 inches, and 12 to 18 inches) will be held by the laboratory until DTSC or the Contractor instructs the laboratory as to which sample(s) to analyze. Waste profile results will be used to identify an appropriate off-site disposal facility.

• Soil will be excavated to the excavation depths determined through discrete confirmation sample results from the laboratory. If the target excavation depths cannot be achieved due to obstructions such as tree roots or utilities, a post-excavation confirmation sample will be collected at the depth of excavation achieved.

• Soil samples of fill materials will be collected prior to use and will be submitted by the Contractor for laboratory analysis. The sampling procedures will follow DTSC’s Information Advisory for Clean Imported Fill Material, dated October 2001. Additional information about backfill source evaluation is included in Section 9.1 of the Work Plan.

In addition, the QAPP is designed to provide reliable data to support a post-removal cleanup evaluation in accordance with the Proven Technologies and Remedies (PT&R) Guidance (DTSC, 2008) to evaluate residual levels of lead. The Letter of Completion (LOC) will include a post cleanup evaluation using the pre-excavation confirmation samples.

1.2 PURPOSE AND SCOPE OF QAPP

This QAPP is designed to support sampling related to removal action activities. The scope of work for pre-excavation confirmation sampling will primarily focus on the collection of soil samples for metals (primarily lead) analysis, although other metals may also be targeted during sampling activities. The scope of work for removal action activities includes collecting confirmation soil samples and waste profiling samples.

This QAPP sets forth quality guidelines for all activities, products, and services and is designed to ensure that all activities are accomplished in an approved, prescribed manner by technically trained and competent staff. This document establishes the QA requirements and assigns responsibility to project personnel and subcontractors for ensuring that project objectives will be achieved. This QAPP consists of the QA program requirements that are responsive to all guidance documents referenced in Section 1.0. Quality requirements specified in this document are tailored to the needs of this project.

1.3 PROJECT OBJECTIVE

The objective of the removal action work is to clean up lead-impacted soils in accordance with the Work Plan and the Cleanup Plan.

1.4 PROJECT ORGANIZATION AND RESPONSIBILITIES

A qualified and experienced project team will execute the cleanup activities identified in the Work Plan. Compliance with the chain of command and lines of communication is critical for successful implementation of the Work Plan. The following subsections list the key points of contact associated


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with the project. The cleanup work will be managed by DTSC and the Contractor. A brief description of the responsibilities for each of the key points of contact is presented below.

DTSC KEY POINTS OF CONTACT

Project oversight will be provided by DTSC by personnel with the following key roles and responsibilities:

DTSC Residential Cleanup Project Director

DTSC’s Residential Cleanup Project Director is responsible for overall coordination and organization of the Exide Closure and Residential Cleanup Project. The Residential Cleanup Project Director may delegate authority to the Residential Cleanup Project Manager, the Field Operations Manager, or the Contract Manager for residential cleanup-related decisions.

DTSC Residential Cleanup Project Manager

DTSC’s Project Manager is responsible for coordination and organization of the Exide Residential Cleanup Project with the Field Operations Manager and Contracts Manager. The Project Manager will ensure compliance with the DTSC approved Cleanup Plan, manage project schedule, develop and coordinate work orders, coordinate between field staff and Contractors, coordinate and approve property-specific plans and LOCs, and pre-approve invoices.

DTSC Field Operations Manager

DTSC’s Field Operations Manager will be responsible for coordinating cleanup activities with the Contractor. The Field Operations Manager is the single point of contact for all the field work. All field work schedules, excavation limits and depths, grading permits and plans, field change orders, and other technical issues must be coordinated with the Field Operations Manager. As necessary, the Field Operations Manager may delegate authority to make field decisions to designated Zone Managers.

DTSC Contract Manager

DTSC’s Contract Manager is responsible for managing and coordinating all contract related requirements associated with the cleanup, reviewing and approving all work orders issued, approving any amendments to the contracts, if appropriate, and reviewing and approving invoice payments.

The names and contact information of the above and other keys points of contact will be provided to the Contractor during the kick-off meeting and will be updated as necessary.


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CONTRACTOR KEY POINTS OF CONTACT

The Contractor will provide overall project management and technical services on the project and will provide personnel for the following key roles and responsibilities:

Contractor Project Manager

The Contractor Project Manager (PM) will ensure adequate resources are provided to accomplish the Cleanup Plan tasks in accordance with DTSC-approved Project quality standards, Project schedule, and budget. The Contractor Project Manager reports to the DTSC Project Manager. This includes:

• Exercising project oversight of pre-excavation confirmation sampling, removal action activities and restoration activities. The Contractor PM oversees the day-to-day progress of the project, including manpower, scheduling, and compliance with the QAPP. The Contractor PM is also responsible to the DTSC PM to conduct the coordination and scheduling of subcontract support. Responsibilities of the Contractor PM include the following:

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

o Correcting non-conformance issues identified in field methods; o Implementing field health and safety protocols, and interacting in field procedure

training for all newly assigned field personnel; • Ensuring compliance with the QAPP in handling and recording field samples. • Ensuring overall adequacy of approaches, maintaining oversight of sampling and analysis

activities, performing technical review of deliverables, and coordinating other technical issues that arise on the project.

• Providing daily, weekly, and monthly progress reports including: Schedule tracking information, the number of properties sampled, the number of properties cleaned up, cost per property, data management updates, upcoming reports, schedule and budget updates, issues regarding the project performance, and any corrective action necessary to keep the project on schedule and within the budget.

• Providing daily field activity reports, summarizing each day’s progress. The daily field activity reports must include notice to the DTSC Contract Manager of any complaints received pertaining to project performance and personnel issues, as well as any corrective action taken. Notice must be provided within 24 hours of any complaint received.

Contractor Contract Manager

The Contractor Contract Manager will be responsible for all field work coordination. The Contract Manager reports to the Contractor Project Manager and procures equipment, manages subcontracts, coordinates hiring pursuant to the Project Labor Agreement and Targeted Hiring Program requirements, completes project invoicing, and accounts for costs.


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Contractor Data Manager

The Contractor Data Manager reports to the Contractor Project manager and will ensure all project data, and any other data specified by DTSC, is recorded and tracked for the purposes of data storage, searches, queries, retrieval, and other data management. Project data will include, but not be limited to, project and property descriptions, coordinates and elevations of surfaces, sampling locations and features of properties, results of environmental measurements, transportation and disposal receipts, removal action schedules, costs, obligation and outlay projections, and other financial information. The principal sources for the data are laboratory sample results and field documentation.

Contractor QA Officer

The Project QA Officer is responsible for ensuring that sufficient QA procedures are developed for the project, that adequate quality controls are imposed to achieve the required level of QC and that the controls are implemented properly. Each Contractor QA Officer has the authority to initiate nonconformance reports and corrective actions based on laboratory actions and information. Responsibilities of the QA Officer include the following:

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

• Working directly with the PM, field personnel, and the laboratory's PM to ensure that chemical 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 the subcontract laboratory;

• Acting as the PM’s point of contact with the subcontract laboratory; and • Ensuring adequate project preparation, quality review, and submittal of the data quality

assessment (DQA) report. Project Chemist

The Project Chemist will determine if data quality objectives (DQOs) for field data have been met, and also will calculate the percent complete (PC) for field data results. They will also will perform a review of the data consistent with the level of effort described in the National Functional Guidelines (2017a and 2017b).

California Licensed Civil Engineer

A California Licensed Civil Engineer with be in responsible charge of the project. The engineer must possess a valid certificate as a registered civil engineer issued by the California State Board of Registration for Professional Engineers. The engineer must have a minimum of five years of experience conducting engineering activities in connection with hazardous substances release investigation and/or construction oversight.


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Laboratory QA Officer The Laboratory QA Officer is responsible for ensuring that sufficient QA procedures are applied to laboratory analyses. The Laboratory QA Officer is also responsible for ensuring that adequate laboratory controls are utilized for a high level of data quality, and that data program requirements and 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 in

audits; • Reviewing all statistical data to verify that the analytical laboratories are meeting stated QC

goals; and • Coordinating with the Project Chemist and Laboratory Project Manager.

Laboratory Project Manager

Each Laboratory PM is the primary point-of-contact at the analytical laboratory for the project, and is responsible for ensuring project data meet the QA/QC objectives established herein. The Laboratory PM is also responsible for tracking the progress of testing in the laboratory and ensuring the timely delivery of data or other laboratory deliverables to the project team.


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DATA QUALITY OBJECTIVES

The objective of collecting and analyzing environmental samples for this project is to ascertain the distribution of chemicals of potential concern (COPCs), primarily lead for this project, in the subsurface soils at various sensitive land use properties where lead concentrations exceed established thresholds. Soil excavation and restoration activities will be performed, and environmental sampling will be performed to confirm the effectiveness of the cleanup. This QAPP has been developed for use in conjunction with the confirmation and waste profile sampling activities to be undertaken at properties in the PIA, and describes the QA/QC procedures and protocols that will be used during sample analysis. This QAPP does not apply to the initial sampling phase, only sampling performed during cleanup activities. The QAPP will serve as a controlling mechanism during the removal action to ensure that a sufficient quantity of data is 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 conditions in the various environmental media at the time of sampling and that the field analytical approach is properly implemented. Both field-based analytical and off-site fixed-based subcontract laboratory QA efforts will be aimed primarily at ensuring that analytical procedures provide sufficient accuracy and precision to reliably quantify contaminant levels in environmental samples. The subcontract laboratory will also ensure that analyzed portions are representative of each sample.

Per USEPA (2006), the DQO process is a seven-step systematic planning process used to develop sampling designs for data collection activities that support decision making. The systematic planning process is applied during the development of a sampling approach using qualitative or quantitative statements to clarify study objectives, define a sampling approach for collecting and analyzing data (e.g., location and number of samples to collect, field sampling methods, analytical methods, etc.), identify critical decision points, determine decision criteria and rules, and specify tolerable levels of potential decision errors. The seven steps of the DQO process are:

1 State the Problem;

2 Identify the Decision;

3 Identify the Decision Inputs;

4 Define the Boundaries of the Study (Cleanup);

5 Develop Decision Rules;

6 Specify Tolerance Limits on Decision Errors; and

7 Optimize the Design for Obtaining Data.


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The DQO process was applied during the development of the soil sampling approach and is summarized in Appendix B. The primary DQO decision question for the cleanup is to determine the appropriate excavation depth and to determine the appropriate waste disposal facility.

2.1 ANALYTICAL DATA QUALITY LEVELS

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

Screening Data - Screening data are generated by more rapid, generally less precise methods of analysis with less rigorous sample preparation. Sample preparation steps may be restricted to simple procedures such as removing non-soil particles (e.g., roots) within the soil matrix. Screening data generally provide less-certain quantification of contaminant concentrations.

Definitive Data - Definitive data are generated using rigorous analytical methods, such as approved USEPA reference methods. Data are analyte-specific, with confirmation of analyte 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 may be generated at a property or at an off-property location, as long as the QA/QC requirements are satisfied. For the data to be definitive, total measurement error must be addressed. Results of fixed-based laboratory analyses of samples collected at a property under this 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 worker breathing zones for health and safety purposes and are addressed in the Health & Safety Plan (Appendix B of the Work Plan).

• Screening perimeter monitoring for air emissions compliance are addressed in Sections 6.2 and 6.3 of the Work Plan.

• Definitive analyses from an off-site fixed laboratory will be used for confirmation samples. • Definitive analyses from an off-site fixed laboratory will be used to support waste

characterization requirements associated with off-site. • Definitive analyses from an off-site fixed laboratory will be used for backfill material samples.

2.2 DATA QUALITY ASSESSMENT CRITERIA

DQA criteria will be used to evaluate the quality of the field sampling efforts, field screening results, and fixed-base laboratory results for compliance with project DQOs. The DQA criteria are expressed in terms of analytical precision, accuracy, representativeness, completeness, and comparability (PARCC). Procedures used to assess data accuracy and precision are in accordance with USEPA's (2014) Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846.


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PRECISION

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

Analytical precision is a measurement of the variability associated with duplicate or replicate analyses of the same sample in the laboratory, and is determined by analysis of laboratory quality control samples, such as duplicate control samples (LCS or DCS), field designated matrix spike duplicates (MSD), or sample duplicates. If the recoveries of analytes in the specified control samples are comparable within established laboratory control limits, then precision is within limits.

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

Duplicate results are assessed using the relative percent difference (RPD) between duplicate measurements. If the RPD for laboratory quality control samples exceeds the laboratory’s statistically determined acceptance ranges, data will be qualified as described in the applicable validation procedure (i.e., The Laboratory’s Quality Assurance Manual [QAM] [Appendix A] or Section 8.2 below). 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 be calculated as:

Figure 1 - Precision

ACCURACY

Accuracy is a measure of the closeness of a reported concentration to the true value. Accuracy is expressed as a bias (high or low) and is determined by calculating percent recovery (%R) from matrix spike/matrix spike duplicates (MS/MSDs), post digestive spikes (PDSs), LCSs, and surrogate spikes. MS/MSDs, PDSs, and surrogate spike recoveries indicate accuracy relevant to a unique sample matrix. LCS recoveries indicate accuracy relevant to an analytical batch lot, and are strictly a measure of

RPD = (X1 - X2) × 100

X

where:

x1 = analyte concentration in the primary sample,

x2 = analyte concentration in the duplicate sample, and

X = average analyte concentration of the primary and the duplicate sample = (x1 + x2)/2 _


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accuracy conditions in preparation and analysis independent of samples and matrices. The %R of an analyte, and the resulting degree of accuracy expected for the analysis of spiked samples for QC, are dependent upon the sample matrix, method of analysis, and the compound or element being measured. The concentration of the analyte relative to the detection limit of the method is also a major factor in determining the accuracy of the measurement.

Accuracy expressed as %R is calculated as follows:

Figure 2 - Accuracy

The laboratory shall have procedures in place for establishing and updating accuracy control limits. Typical control limits for accuracy are based on the historical mean plus or minus three standard deviations. Statistically-derived laboratory accuracy limits are updated semiannually. If the percent recovery is determined to be outside of acceptance criteria, data will be qualified as 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, field contamination, sample preservation, and sample handling. The DQO for field equipment blanks is that all values are less than the practical quantitation limit (PQL) for each target constituent. If contamination is reported in a field equipment blank, data will be qualified as described in the applicable validation procedure (USEPA National Functional Guidelines, 2017a and 2017b).

COMPLETENESS

Completeness is defined as the percentage of laboratory measurements judged to be valid on a method-by-method basis. Valid data are defined as all data and/or qualified data considered to meet the DQOs for this project. The goal for data completeness is 100 percent and is expressed as PC, though that may not be achievable in all cases. If the data is not complete, DTSC will be consulted immediately to determine how to achieve the project objectives. The goal for meeting analytical holding times is 98 percent. At the end of each sampling event, the completeness of the data will be assessed. If any data omissions are apparent, new samples will be collected and reanalyzed for the parameter in question, if feasible. In addition, appropriate corrective action will be implemented to ensure that objectives are

A - B

%R = ( C ) × 100

where:

A = measured concentration in spiked sample,

B = measured sample concentration (without spike), and

C = concentration of spike added. _


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met in the future. Laboratory results will be monitored by the Contractor as they become available to assess laboratory performance and its effect on data completeness requirements. When appropriate, additional samples will be collected to ensure that laboratory performance meets PC requirements.

PC is calculated as follows:

Figure 3 - Completeness

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 is dependent upon sampling program design and time periods. Comparability during analysis is dependent upon analytical methods, detection limits, laboratories, units of measure, and sample preparation 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 collection procedures, standard fixed laboratory analytical methods, standard field measurement procedures, and standard reporting methods, including consistent units. For example, laboratory lead analyses will be performed on the same exact samples that were tested in the field using instant reading methods, such as X-ray fluorescence (XRF); or, concentrations will be reported in a manner consistent with general industry practice.

In addition, to support the comparability of fixed-base laboratory analytical results with those obtained from previous or future testing, all samples will be analyzed by USEPA-approved methods, where available. The USEPA-recommended maximum permissible sample holding times (Appendix C) for all parameters will not be exceeded. Whenever EPA methods are not appropriate or available, recognized methods published by American Standard for Testing and Materials (ASTM) or other recognized organizations with appropriate expertise will be used.

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

PC = NA × 100

Ni

where:

NA = Actual number of valid analytical results obtained, and

Ni = Theoretical number of results obtainable under ideal conditions. _


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REPRESENTATIVENESS

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

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

• Use of appropriate sampling procedures, including proper equipment and equipment decontamination;

• Use of appropriate analytical methods for the required parameters and adequate 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 to ensure that the reported results are representative of the sample received. Because many homogenization techniques may cause loss of contaminants through volatilization, homogenization will not be performed for any volatile organic compound (VOC) method analyses.

2.3 LABORATORY OBJECTIVES

All laboratory analyses will be performed by an analytical laboratory that has obtained accreditation through the Environmental Laboratory Accreditation Program (ELAP), administered by the California State Water Resources Control Board (SWRCB). The attached QAM (Appendix A) for the selected project laboratory defines internal laboratory procedures for QA/QC and includes 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 and electronic

formats; • Security; • Documentation of client-specific requirements; • QA audits; • QC; and • Non-conformance/corrective action report (NC/CAR) procedures.


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The laboratory QAM(s) in Appendix A of this QAPP will be considered the approved versions for this project.

LABORATORY STANDARD OPERATING PROCEDURES

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

• USEPA (2014) Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (SW-846), Revision 8; and

• USEPA (2007) Guidance for Preparing SOPs, EPA QA/G-6.

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

DEMONSTRATION OF CAPABILITY, ANALYST TRAINING

The laboratory QA department personnel shall maintain records documenting the ability of each analyst to perform applicable method protocols. Documentation will include a Method Detection Limit (MDL) study with other annual and quarterly checks for each method and analyst. In addition, internal, blind performance evaluation (PE) samples for each method and matrix demonstrating overall laboratory performance must be submitted semi-annually.

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.


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FIELD DATA REDUCTION, VALIDATION, AND REPORTING

The following sections describe calibration of field analytical instruments and field data reporting, validation, reduction, and review, where applicable.

3.1 FIELD RECORD KEEPING

Bound or digital field logbooks will be maintained by the field supervisor and other team members to provide a daily record of significant events, observations, and measurements during removal action. All entries will be signed and dated. All information pertinent to the 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 in the 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; and • Purpose of sampling activity.

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

• Sample location (e.g., street address); • Sample identification; • Sample location map or detailed sketch (including global positioning system [GPS] coordinates); • Date and time of sampling; • Sampling method; • Weather conditions (applies only to dust monitoring); • Sampler's identification; and • Any other relevant information (e.g., moisture content or other qualitative observations).

For lead-based paint (LBP) inspections, the State of California Health and Human Services Agency, Department of Public Health (CDPH) “Lead Hazard Evaluation Report” form 8552 will be used to document the inspection, and who conducted the inspection. A copy of this form is included in Appendix D.

3.2 CALIBRATION PROCEDURES AND FREQUENCY FOR FIELD TEST EQUIPMENT

Instruments and equipment used to gather, generate, or measure environmental data will be calibrated according to manufacturer’s specifications with sufficient frequency to ensure accuracy and reproducibility of results. At a minimum, monitoring equipment used in the field, such as dust meters, will be calibrated (cross-checked) daily according to the manufacturer’s recommended procedures.


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3.3 REVIEW OF FIELD RECORDS

Field record review is an ongoing process. Field team leaders will be responsible for ensuring that proper documentation is recorded during each properties' sampling activities. Field records include logbooks, log forms, and any documentation, whether electronic or hardcopy, that is used to record data, observations, assumptions, or other information in the field. The sections below describe the items used for evaluation.

COMPLETENESS OF FIELD RECORDS

The check of field record completeness will ensure that all requirements for field activities in the work plan have been fulfilled, complete records exist for each field activity, and the procedures specified in the work plan (or approved as field change requests) are implemented. Field documentation will ensure sample integrity and provide sufficient technical information to recreate each field event. The results of the completeness check will be documented, and environmental data affected by incomplete records will be identified in the technical report.

IDENTIFICATION OF VALID SAMPLES

The identification of valid samples involves interpretation and evaluation of the field records to detect problems affecting the representativeness of environmental samples. For example, field records can indicate if unanticipated environmental conditions were encountered during field activities. Records should note sample properties such as clarity, color, and odor. Photographs may show the presence or absence of obvious sources of potential contamination (during sampling). Judgments of sample validity will be documented in the LOC, and environmental data associated with any poor or incorrect field work will be identified. If any sample validity issues are identified for the pre-excavation confirmation samples, they will be reported to DTSC when the pre-excavation confirmation sampling data is provided.

IDENTIFICATION OF ANOMALOUS FIELD TEST DATA

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

ACCURACY AND PRECISION OF FIELD DATA AND MEASUREMENTS

Field preparation and analytical precision will be evaluated by collecting a Field Duplicate field sample from a jar containing the sample to be sent to the fixed laboratory for the analyses of lead. The Field Duplicate sample will be collected, sieved, cupped and analyzed in the same manner as the original sample. Further details regarding this process are described below in Section 4.2.

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


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3.4 FIELD DATA VALIDATION

The Project Chemist will determine if DQOs for field data have been met, and also will calculate the 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; and • Completeness of data.

Field data will be validated using the procedures described below:

• Routine checks (e.g., looking for errors in identification codes) will be made during the processing of data.

• Routine review and verification of field notebooks. • Checks for consistency of the data set over time will be performed by the Contractor in

consultation with DTSC. This can be accomplished by comparing data sets against gross upper limits obtained from historical data sets, or by testing for historical consistency. Anomalous data will be identified.

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


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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 FIXED LABORATORY DUPLICATE SAMPLES

Fixed laboratory duplicate samples will be collected and analyzed to evaluate sampling and analytical precision in the fixed laboratory. Fixed laboratory duplicates are collected and analyzed in the same manner as the primary samples. Agreement between duplicate sample results will indicate good sampling and analytical precision. Field duplicates will be collected at a frequency of one per property for the confirmation samples collected. Waste profile and air samples will not require field duplicates. The duplicate sample will be analyzed for all laboratory analyses requested for the primary sample collected. If the RPD between primary and duplicate samples exceeds 35 percent for soil, data will be qualified as described in the applicable validation procedure, and corrective actions will be implemented.

4.2 BLANKS

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

Equipment blanks will be prepared when a particular piece of sampling equipment was employed for 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 the equipment (e.g. hand auger bucket) in the appropriate pre-preserved container after execution of the last step of the field decontamination protocol. Equipment blanks will be collected once per day unless a reduced frequency is deemed satisfactory for project quality objectives. Each equipment blank will be stored on ice, and then analyzed for lead by EPA Method 6010B. The detection limit will be low enough to meet National Functional Guidelines validation guidance.

Lead air blanks will be collected for perimeter monitoring in accordance with National Institute of Occupational Safety and Health (NIOSH) 7300 or other method. One lead air blank will be collected for each sampling day at each property. The blank should be placed on hold and only analyzed if elevated concentrations are detected in the perimeter samples.

Trip blanks are used to measure potential contamination of samples by volatile organic compounds during transport. The trip blank consists of a vial filled by the laboratory with ASTM Type II water, shipped to the field, and returned to the laboratory in a cooler that contains samples for VOC analysis. A trip blank shall be included in every cooler containing samples for VOC analysis (Method 8260); the trip blank sample will be analyzed for VOCs. A trip blank shall be included in every cooler containing samples for analyses for total petroleum hydrocarbons as gasoline-range organics (TPH-g) (Method 8015) and


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analyzed for TPH-g (Method 8015). VOC and TPH analyses will not generally be performed on this project although may be required in certain instances for backfill sampling purposes.

If contamination is reported in the trip blanks and/or equipment blanks, data will be qualified as described in the applicable validation procedure per USEPA National Functional Guidelines (2017a and 2017b).


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SAMPLING PROTOCOLS

Detailed soil sampling protocols are provided in Sections 5.5 and 5.6 of the Work Plan.

5.1 SAMPLE CONTAINERS

The laboratory will provide sample containers, labels, chain-of-custody forms, and coolers to the contractor or to the project site. Properly cleaned sample containers must be used so that no target compound contamination occurs from contact with the sample container. The laboratory will provide documentation attesting to the cleanliness of the containers following their cleaning procedures. A certificate 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 other contaminants. The laboratory will provide documentation attesting to the purity and quality of the reagents being provided.

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

5.2 SAMPLE CONTAINMENT, PRESERVATION, AND LABELS

Sample containers and preservatives defined in Appendix C will ensure compatibility with USEPA protocols and will minimize breakage during transportation. Sample labels will be affixed to each container to identify the sample number, collector's name, date and time of collection, location of sampling point, analyses requested, and preservatives added. Primary soil samples collected for EPA 6010B analyses (including lead samples) do not need to be placed on ice. However, samples collected for all other analyses, 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 field investigations, including field QC samples. The numbering system will be a tracking mechanism to allow retrieval of information about a particular location and to ensure that each sample is uniquely numbered. A listing of sample numbers will be maintained by the field team leader.

Samples will be named in accordance with the Exide Electronic Data Deliverable (EDD) Specification Manual (DTSC, May 2018). Contractors will be provided with a list of Property IDs and Property Tax IDs (Assessor’s Parcel Number). Each sampling location at a property will include the property ID, a dash, a two-digit number starting with “01,” and incrementing one digit for each additional sampling location on that property, and letter “C.” There should be no spaces or underscores included in the name. Soil sample names will also include the bottom depth of the sampling interval. The following is an example of the sampling nomenclature:


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LABORATORY SOIL SAMPLES – EXAMPLE LABELING:

(Property ID – Sample Number “C” - Depth of Sample Interval)

• XXX0001-01C-06 (for 6-7 inches) • XXX0001-01C-12 (for 12- 13 inches) • XXX0001-01C-18 (for 18- 19 inches)

OTHER QUALITY ASSURANCE SAMPLES – EXAMPLE LABELING:

• Trip blanks – (Property ID-TP-Sample Number “B”-Date): XXX0001-TP-01C-111715 • Equipment Blanks – (Property ID-EB-Sample Number “B”-Date) XXX0001-EB-01C-111715 • Field Blanks – (Property ID-FB-Sample Number “B”-Date) XXX0001-FB-01C-111715 • Duplicates – (Property ID-Sample Number “B”-Depth-D) XXX0001-01C-03-D

5.4 SAMPLE CHAIN-OF-CUSTODY

Sample custody begins in the field at the time of collection and continues throughout the laboratory analytical process. Chain-of-custody forms will be prepared at the time of sample collection and will accompany the samples to the laboratory and through the laboratory sample processing. Chain-of-custody forms will be completed for each cooler in a shipment of samples to track the samples and provide a written record of all persons handling the samples. The following information 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 (selected by the laboratory from the samples submitted by DTSC); • Analyses required; • Name(s) of collector(s); • Custody transfer signatures (wet ink or electronic), and dates and times of sample transfer 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 by the project manager prior to shipping any samples to the laboratory. To facilitate the documentation 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 for label identification, chain-of-custody forms, and any discrepancies. The laboratory will also note and record cooler temperatures, physical damage, incomplete sample labels, incomplete paperwork, discrepancies between sample labels and paperwork, broken or leaking containers, and inappropriate caps or bottles. The laboratory


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will send signed facsimile copies of all chains- of-custody and sample log-in receipt forms to the Contractor PM within 24 hours of sample receipt in the laboratory. All discrepancies and/or potential problems (e.g., lack of sample volume) will be discussed immediately with the PM.

The laboratory sample custodian will provide a report to the PM of any problems observed with any of the samples received. This report will also document the condition of samples, sample numbers received, corresponding laboratory numbers, and the estimated date for completion of analysis. Written permission must be received from the PM before sending any samples originally scheduled to be analyzed at its facility to another laboratory. Analyses will not be performed on samples whose integrity has been compromised or is suspect, without prior approval from the PM. DTSC will be notified immediately.

5.6 SAMPLE HANDLING

Laboratory sample custody will be maintained by the procedures detailed in the laboratory QAM:

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

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

• Water samples will be stored in a secured area at a temperature of approximately 4 ± 2 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 analytical standards, 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 a minimum. Results of storage blank analyses must be maintained by the QA department. Corrective action is required if analyses provide evidence of cross contamination.

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

• Data generated from the analysis of samples also must be kept under proper custody by the laboratory.

Samples, remaining sample material and sample containers, will be retained indefinitely or until DTSC provides a written directive to dispose.

5.7 LABORATORY REVIEW PROCEDURES FOR DEFINITIVE DATA

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


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

Samples associated with out-of-control QC data shall be identified in the data package case narrative, and an assessment of the utility of such analytical results shall be made. The check of 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 review of all steps of the data processing. One hundred percent of all data shall be reviewed. All input parameters, 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 the verifier.

QC data must meet acceptance levels prior to processing the analytical data. If QC standards are not met, the cause shall be determined. If the cause can be corrected without affecting the integrity of the analytical data, processing of the data shall proceed. If the resolution jeopardizes the integrity of the data, reanalysis shall be performed, if still within holding time. If the holding time will be exceeded, the decision regarding reanalysis will be made upon conferring with the Contractor 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 data deliverables have been met and are complete.

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


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FIXED-BASE LABORATORY ANALYTICAL PROCEDURES

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

6.1 ANALYTICAL METHODS

Analytical procedures will follow established USEPA method protocols. Approved methods are summarized below in Tables 1 and 2. The referenced methods are defined in the USEPA Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (SW846) Revision 8 (2014). Whenever SW-846 methods are not appropriate, recognized methods from source documents published by USEPA, ASTM or other organizations with appropriate expertise 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 other project purposes (e.g., to support waste characterization or backfill sampling). Depending on waste disposal facility requirements, sample analysis may include some or all of the following methods:

Table 1 Exide Facility Off-Site Laboratory Analytical Methods - Soil

SOIL SAMPLES

PARAMETER PREPARATION 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 Range Organics (ORO)

EPA 3550B/ 3546 EPA 8015B

Chloride, Nitrate, Sulfate N/A EPA 300.0

Oil/Grease N/A EPA 9071B


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In addition, lead air analysis will be conducted in accordance with NIOSH 7300.

6.2 DETECTION AND QUANTITATION LIMITS

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

METHOD DETECTION LIMIT

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

PRACTICAL QUANTITATION LIMIT

The PQLs are the lowest matrix-specific concentrations that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. All sample results will be

Table 2 Exide Facility Off-Site Laboratory Analytical Methods – Water

WATER SAMPLES

PARAMETER PREPARATION 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

TOC N/A EPA 9060/ SM 5310B

SVOCs EPA 3510C/ 3520C EPA 8270C

VOCs EPA 5030C EPA 8260B

PCBs EPA 3510C EPA 8082

Organochlorine Pesticides EPA 3510C EPA 8081B

Chlorinated Herbicides EPA 8151A EPA 8151A

GRO EPA 5030C EPA 8015B

DRO, ORO EPA 3510C EPA 8015B

Chloride, Nitrate, Sulfate N/A EPA 300.0


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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 performing the initial calibration curve. The PQL is the value that indicates whether the analytical DQOs have been achieved for that sample.

DETECTION LIMIT GOALS

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

Equipment blank detection limits will follow National Functional Guidelines requirements. Lead air detection limit goals are 1.5 micrograms per cubic meter (µg/m3) for perimeter samples and 30 µg/m3 for personnel breathing zone samples.


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LABORATORY QC SAMPLES AND CRITERIA

In order to ascertain the precision and accuracy of the analysis, the analytical laboratory will analyze a routine set of QC samples. This does not apply to lead air samples (NIOSH method 7300 QA/QC will be followed for lead air samples). In addition to precision and accuracy, the QA system is designed to illuminate any issues which may be present due to matrix interferences and sample contamination. These procedures are detailed in the laboratory’s QAM. At a minimum, the laboratory must prepare and analyze a method blank, an LCS, and a laboratory sample duplicate. An MS/MSD shall be analyzed with each batch, providing sufficient sample was provided to the laboratory by the sampling team. The spike concentration for soil lead samples should generally be set near 80 ppm (the cleanup goal). If there is insufficient sample for MS/MSD, the laboratory will contact the Contractor PM. The Contractor PM, in consultation with the DTSC PM, may allow the laboratory to prepare and analyze the LCS in duplicate. In this manner, a measure of the precision pertaining to the specific analytical batch can be determined. In addition, for EPA 6010B, a PDS / PDS duplicate analysis shall be performed for those analytes that do not meet specified MS/MSD criteria; and a dilution test (1:5 serial dilution) shall be performed if the analyte concentration in the sample after dilution, is minimally 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 limits established semi-annually by the analytical laboratory. If a bias is determined, the associated data will be qualified (National Functional Guidelines) and the direction of the bias indicated in the data validation report. In addition, if a lack of required precision is determined for a batch, the associated data will be qualified.


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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 personnel performing each function.

8.1 LABORATORY DATA REPORTING AND QUALIFIERS

Laboratory analytical data will contain the necessary sample results and quality control data to evaluate the DQOs defined for the project. Documentation requirements for laboratory data are defined in USEPA Region 9 Laboratory Documentation Required for Data Evaluation (USEPA 2001b). The laboratory reports for the lead air samples will be consistent with USEPA Level I documentation. The laboratory reports for 100% of the remaining data will be consistent with USEPA Level 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 Calibration Summaries; • Instrument tuning summary (as applicable); • Internal standard area count and retention time summary (as applicable); • Interference check standards; • Degradation standards; • Second column confirmation; • 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 reports for 10% of the confirmation soil sampling data will be consistent with USEPA 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, bench sheets, and run logs in the data package. All sample receiving information, including the executed Chain-of-Custody (COC), air bill, sample receipt checklist, sample delivery group (SDG) assignment sheet, and any other correspondence relevant to the SDG, will be provided.


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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 results reported for each chemical compound for each sample.

The laboratory must only use the following qualifiers when reporting sample results. The laboratory will discuss all other QC non-conformances in the laboratory report narrative.

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

Table 3 - Data Reporting Qualifiers

Qualifier Description

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

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

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

8.2 CONTRACTOR ASSESSMENT OF DATA USABILITY

Quality assurance oversight will be performed by each DTSC Contractor to ensure that the established QC procedures are followed. Activities to be conducted as part of the QA objectives include data validation.

Data validation criteria are derived from the USEPA Contract Laboratory Program National Functional Guidelines for Laboratory Data Review, Organics and Inorganics (USEPA, 2017a and 2017b). The National Functional Guidelines provide specific data validation criteria that will be applied to data generated for this investigation.

Limited data validation (EPA Level III) will be performed on all laboratory data except for the lead air samples. Full data validation (EPA Level IV) will be performed on 10 percent of the laboratory data for confirmation samples. The limited data validation uses the same criteria contained in the USEPA Contract Laboratory Program National Functional Guidelines for Organic and Inorganic Data Review (USEPA 2016); however, the reviews do not include checking the raw data and calculations. Instead, limited data validation utilizes the data summary and QA/QC summary provided in the laboratory standard report. Full data validation includes checking the raw data, calibrations, and calculations is in accordance with the principles presented in USEPA National Functional Guidelines for Laboratory Data Review, Organics and Inorganics (EPA, 2017a and 2017b). Documentation requirements for level III and level IV validation are listed in Section 8.2.


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The laboratory data will be reviewed for quality and compliance with the applicable method and laboratory 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 Contractor QA 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 Validation Memorandum, which will be summarized in the LOC for each property cleaned up.

DATA VALIDATION QUALIFIERS

The following definitions provide explanations of the USEPA Contract Laboratory Program (CLP) National Functional Guidelines (2017a and 2017b) qualifiers to be assigned to analytical results during data validation. The data qualifiers described are applied to sample results.


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Table 4 - Data Validation Qualifiers

Qualifier Description

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

J The analyte was analyzed for and was positively identified, but the associated numerical value may not be consistent with the amount actually present in the environmental sample. The data should be considered as a basis for decision making 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 analyzed for, but the presence or absence of the analyte was not verified. Resampling and reanalysis are necessary to confirm the presence or absence of the analyte.

UJ The analyte analyzed for was not present above the reported sample quantitation limit. The associated numerical value may not accurately or precisely represent the concentration necessary to detect the analyte in the sample.

ASSESSMENT OF USABILITY

Data usability will be assessed by the Contractor QA Officer based on data evaluation results to determine whether the project PARCCs have been achieved. In consultation with DTSC, targeted data validation and evaluation will be performed on any result that appears to be unusual or outside the expected range. Any limitations on data use will be expressed quantitatively to the extent practicable. The outcome of this data review will be a data set appropriate to support project-specific DQOs. A DQA will be written, summarizing the findings of the data review, and providing an assessment of overall data quality and usability.


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QA REPORTS

The Contractor will submit a quarterly report that documents internal QA information that documents field and laboratory-related QA/QC issues to DTSC. Discussions of any conditions adverse or potentially adverse to quality will be included, such as:

• Responses to the findings of any internal or external systems or performance laboratory audits; • Any laboratory or sample conditions that necessitate a departure from the methods or

procedures 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 when timely notice can reduce the loss or potential loss of quality, time, effort, or expense. Appropriate steps will be taken to correct any QA/QC concerns as they are identified, with consultation with DTSC. The QA reports and a summary of the laboratory QA/QC program and results will be documented in the LOC as part of the laboratory reports provided with the sampling results.


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CORRECTIVE ACTION

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

When a significant condition adverse to data quality is noted at the laboratory or in the field, the cause of the condition will be determined, and corrective action will be taken to prevent repetition. Condition identification, cause, reference documents, and corrective action planned will be documented and reported to the Contractor QA Officer by the laboratory QC coordinator. Following implementation of corrective action, the laboratory QA Officer will report the actions taken and their results to the Contractor’s project manager and QA Officer. A record of the action taken and results will be attached to the data report package. If samples are reanalyzed, the assessment procedures will be repeated, and the control limits will be reevaluated to ascertain if corrective actions have been successful.

Implementation of corrective action is verified by documented follow-up action. All project personnel have the responsibility, as part of the normal work duties, to identify, report, and solicit 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 control personnel, and laboratory groups, will monitor work performance in the normal course of daily responsibilities.

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

The Contractor and laboratory QA Officers are responsible for documenting all out-of-control events or non-conformance with QA protocols. A nonconformance report will summarize each nonconformance


P a g e 10-2|

condition. The laboratory PM will notify the Contractor project manager or QA Officer of any laboratory QA/QC non-conformance issues upon their discovery. Copies of all field change requests and corrective action forms will be maintained in the project files. A stop-work order may be initiated by the Contractor if corrective actions are insufficient.


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AUDITS

This section describes participation in external and internal systems audits.

11.1 LABORATORY AUDITS

SYSTEM AUDITS

System audits review laboratory operations and the resulting documentation. An on-site audit ensures that the laboratory has all the personnel, equipment, and internal SOPs needed for performance of contract requirements in place and operating. The system audits ensure that proper analysis documentation procedures are followed, that routine laboratory QC samples are analyzed, and that any non-conformance issues are identified and resolved.

11.1.1.1 INTERNAL AUDITS

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

11.1.1.2 EXTERNAL AUDITS

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

In addition to this audit of the laboratory, various local, state, and/or federal agencies may conduct an audit prior to the commencement of the project, and/or may conduct audits as deemed necessary during project execution. The frequency and schedule of any such audits will be established by the auditing agency and coordinated directly with the laboratory.

PERFORMANCE AUDITS

Laboratory performance audits may be conducted to determine the accuracy and implementation of the QAPP by the Project QA Officer or designee at any time during field sampling and analysis. Unplanned audits may be implemented if requested by DTSC. The Project QA Officer will act to correct any laboratory performance problems.


P a g e 11-2|

DATA AUDITS

Data audits will be performed by the Contractor QA Officer on 10% of the analytical results received from the laboratories. These audits will be accomplished through the process of full data validation (outlined above), and involve a more detailed review of laboratory analytical records. Data audits require the laboratory to submit complete raw data files for validation and verification. Project chemists will perform a review of the data consistent with the level of effort described in the National Functional Guidelines (2016). This level of validation consists of a detailed review of sample data, including verification of data calculations for calibration and quality control samples to assess if these data are consistent with method requirements. Upon request, the laboratory will make available all supporting documentation in a timely fashion.

11.2 FIELD AUDITS

DTSC field oversight will be conducted to make sure project objectives are achieved. DTSC staff will confirm the pre-excavation confirmation sampling locations at each property. During excavation and restoration activities, DTSC staff may conduct unannounced visits. A minimum of one visit per day per property will be conducted, with a focus on oversight during excavation. The visits will be documented in oversight checklists. Whenever issues are identified, the Contractor and DTSC staff will correct them in the field and document the issue and resolution in the daily report.

DTSC will inspect the excavation area to confirm that the goals have been achieved prior to the start of backfill activities. The Contractor will provide DTSC a minimum of a two (2) hour notice of when they plan to complete excavation.


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PREVENTIVE MAINTENANCE

All instrumentation shall be maintained in a manner that produces consistent, quality data and that prevents possible limitations on analytical capacity in the laboratory.

12.1 PROCEDURES

Equipment, instruments, tools, gauges, and other items requiring preventive maintenance will be serviced in accordance with the manufacturers' specified recommendations and written procedures developed by the operators.

12.2 SCHEDULES

Manufacturers' procedures identify the schedule for servicing critical items to minimize downtime of the measurement system. It will be the responsibility of the individual operator assigned to a specific instrument to adhere to the instrument maintenance schedule and to promptly arrange any necessary service. Servicing of the equipment, instruments, tools, gauges, and other items will be performed by qualified personnel.

The laboratory will establish logs to record maintenance and service procedures and schedules. All maintenance records will be documented and will be traceable to the specific equipment, instruments, tools, and gauges. Records produced for laboratory instruments will be reviewed, maintained, and filed by the laboratories.

12.3 SPARE PARTS

A list of critical spare parts will be requested from manufacturers and identified by the operator. These spare parts will be stored for availability and use in order to reduce downtime due to equipment failure and repair.


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SECURITY

All access to the laboratory must be secured and controlled. The laboratory must have controlled access to sample storage and data handling areas. All computer systems must be electronically secured with a system of write access that can be fully documented with an audit trail. All laboratory visitors must sign in and out of the building and be escorted while on site.


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DATA DELIVERABLES

The deliverables required for this project are in both hard-copy and electronic format. These formats are described below.

14.1 HARDCOPY DATA DELIVERABLES

Level I data packages are required form the off-site fixed laboratories for all lead air samples. Level III data packages are required from the off-site fixed laboratories for all other samples. The laboratories will be expected to provide Level III data packages within 10 workings days from the time of receipt of samples unless otherwise specified on the COCs. In addition, the laboratories are required to provide Level IV data packages (Section 8.2) for 10% of the data within 15 working days from the time of receipt of the samples (Section 8.2). DTSC Contractors will determine and inform the laboratories which data sets require level IV deliverables within five working days from the time of receipt of the samples.

14.2 ELECTRONIC DATA DELIVERABLES

To facilitate data handling and management, laboratory data (except for lead air samples) will be provided to Contractors in an electronic format. All data contained in the electronic data files will correspond identically to the data contained in the original laboratory reports and other documents associated with sampling and the laboratory hardcopy data deliverable packages. The format of the laboratory electronic data deliverable will be arranged between the Contractor’s Data Manager and the laboratory data management personnel. The Contractor will submit the data to DTSC through Environmental Quality Information System (EQuISTM) using Electronic Data Deliverables (EDDs) in accordance with the Exide EDD Specification Manual (DTSC, May 2018).


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FINAL SAMPLE DISPOSITION

Samples, remaining sample material, and sample containers, must be stored indefinitely, or until the DTSC authorizes the disposal of the samples. If long-term storage at the laboratory becomes infeasible, the samples will be returned to the Contractor and/or DTSC for storage. The laboratory or Contractor shall maintain proper records of waste disposal and shall have disposal company contracts on file for inspection.

All raw and processed data generated during the analysis of project samples must be stored for a period of twenty years. Revised copies of the applicable SOPs and QAMs must also be maintained and available should the data be required. Should the laboratory go out of business, all original records related to project samples shall be provided to DTSC personnel.


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REFERENCES

American National Standards Institute/American Society of Quality Control (ANSI/ASQC), 1994. Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs. ANSI/ASQC E4:1994, July (Draft).

ASTM, 2000. D2488-00 Standard Practice for Description and Identification of Soils (Visual-Manual Procedures).

DTSC, 2001. Information Advisory Clean Imported Fill Material, October.

DTSC, 2008. Proven Technologies and Remedies Guidance, Remediation of Metals in Soil, August.

DTSC, 2017. Final Removal Action Plan (Cleanup Plan) Offsite Properties within the Exide Preliminary Investigation Area, July.

DTSC, 2018. Exide Electronic Data Deliverable (EDD) Specification Manual, May.

Los Angeles County (LAC) Health and Safety Code, Title 11, Chapter 11.28, Section 11.28.010.

Parsons, 2016. Quality Assurance Project Plan (QAPP) for Sampling and Analysis of Properties in the Vicinity of the Exide Facility, revised November 21.

U.S. Environmental Protection Agency (USEPA), 1989. 1991a, and 1991b (Parts A, B, and C). Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual.

USEPA, 2001a. EPA Requirements for Quality Assurance Project Plans. EPA/240/B-1/003 (EPA QA/R-5), March.

USEPA, 2001b. Laboratory Documentation Required for Data Validation, Region IX, August.

USEPA, 2002. EPA Guidance for Quality Assurance Project Plans. EPA/240/R-02/009 (EPA QA/G-5), December.

USEPA, 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process. EPA QA/G-4, February.

USEPA, 2007. Guidance for Preparing Standard Operating Procedures (SOPs), EPA QA/G6, April.

USEPA, 2009. Guidance for Labeling Externally Validated Laboratory Analytical Data for Superfund Use, USEPA 540-R08-005, January.

USEPA, 2011. Code of Federal Regulations Title 40 - Protection of Environment, Appendix B to Part 136—Definition and Procedure for the Determination of the Method Detection Limit—Revision 1.11, July 1.

USEPA, 2014. Test Methods for Evaluating Solid Waste: Physical/Chemical Methods Compendium (SW- 846), Revision 8, July.


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USEPA 2017a, National Functional Guidelines for Inorganic Superfund Methods Data Review. EPA-540- R-2017-001, January.

USEPA, 2017b. National Functional Guidelines for Organic Superfund Methods Data Review. USEPA-540-R-2017-002, January.


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Appendix A: Laboratory Quality Assurance Manual: The Test America QAM (dated 4/19/2018) will be attached once an uncontrolled (unsecured) copy is obtained.


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Appendix B: Data Quality Objectives


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Data Quality Objectives

Step 1: State the Problem

• Describe the problem and develop a conceptual site model (CSM).

• Identify planning team members and decision makers.

• The CSM for the former Exide Facility is described in detail in Section 2.3 of the Cleanup Plan (DTSC, 2017). Key information from the CSM are summarized below:

• Lead-acid battery recycling activities associated with past operations at the former Exide Facility between 1922 and 2014, coupled with insufficient air pollution control and inadequate waste management practices, likely resulted in the release of lead that contaminated properties within the PIA.

• Dust containing lead that settled onto impervious surfaces within the PIA, such as hardscape, plants, rooftops, sidewalks, and roadways is likely transported by wind or rain to settlement areas including yards, planters, and catch basins. The most likely ongoing source of potential lead exposure involving lead from past operations at the former Exide Facility is surface soil in yards and planters, as well as soil and dust on or immediately around plants.

• Populations could be exposed to lead via ingestion, inhalation, and dermal or direct contact. To decrease or eliminate the hazard the exposure pathway needs to be broken, by either covering or removing the soil.

• Based on sampling results for properties sampled through April 14, 2017, it is estimated that more than 98 percent of the properties in the PIA have a representative soil lead concentration that is greater than or equal to DTSC’s screening level for lead in residential soils of 80 ppm.

• Planning team and decision maker members include staff from the Department of Toxic Substances Control’s (DTSC’s) Hazardous Waste Management Program, Cleanup Program, Public Participation, and Human and Ecological Risk Office (HERO) and the Exide Technologies Advisory Group.


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Step 2: Identify the Decision

• Identify the principal decision question(s)

• Define alternative actions • Define a decision statement

• The principal study decision is to determine and support the appropriate excavation depth and identify the appropriate waste disposal facility.

• Pre-excavation confirmation discrete samples will be collected from up to eight (8) locations on each property to be cleaned up.

• Sample locations and depths will be selected based on the results of previous DTSC sampling efforts for each of the properties. In general, the samples will be collected from up to eight (8) sample locations at depths sufficient to determine target excavation depths for each property (up to a maximum excavation depth of 18 inches) and submitted to an offsite fixed laboratory for lead analysis. If the 95% UCL at 12” bgs exceeds 80 ppm for lead, soil will be excavated to 18” bgs.

• Waste profile samples will be collected from 4 locations in intervals of 0 to 6 inches bgs, 6 to 12 inches bgs, and 12 to 18 inches bgs. The soil for each 6-inch interval will be placed in a suitable container and homogenized in the field. Following homogenization, one composite sample, representing soil at the respective depth interval will be submitted to a laboratory for waste profile analysis. The three total composite samples (one for each depth interval representing 0 to 6 inches, 6 to 12 inches, and 12 to 18 inches) will be held by the laboratory until DTSC or the Contractor instructs the laboratory as to which sample(s) to analyze. Waste profile results will be used to identify an appropriate off-site disposal facility.

Step 3: Identify the Decision Inputs

• Identify the information needed and the corresponding sources.

• Define the basis for determining the action levels

• Identify sampling and analysis methods that can meet the data requirements.

• This QAPP and the associated Workplan includes the analytical methods to be used and the decision levels for each parameter being tested to obtain the desired cleanup objective. A California ELAP-accredited laboratory will prepare the samples and perform the analysis.

• The proposed soil investigation and sample collection will be conducted in accordance with pertinent DTSC and USEPA guidance. This includes, but is not limited to sample collection and analysis, decontamination procedures, and other QA/QC testing.

• The soil lead screening level of 80 mg/kg and representative soil lead concentration of 80 ppm cleanup goal were identified by DTSC and is protective of incidental ingestion, dermal contact, and inhalation of particulates.


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Step 4: Define the Boundaries of the Cleanup

• Define the target Cleanup area. Determine the time frame for collecting the data

• Determine the practical constraints on collecting the data.

• The areas subject to excavation are designated as portions of the incorporated and/or unincorporated cities of Maywood, Boyle Heights, East Los Angeles, Commerce, Bell, and Huntington Park and are included in the Cleanup Plan . Only properties with residential levels of exposure to lead above 80 ppm will be addressed under the Work Plan. Pre-excavation confirmation and waste profile samples will be collected prior to cleanup activities at each property. If post-excavation confirmation samples are required, they will be collected prior to backfilling.

• Cleanup activities will continue as funding allows until all properties with representative soil concentrations exceeding 80 ppm have been cleaned up.

• To obtain the most cost-effective technically defensible data, confirmation samples and waste profile samples will be submitted to an off-site fixed laboratory for analysis.

Step 5: Develop Decision Rules

• Specify an appropriate decision unit parameter (e.g., maximum or average soil-gas concentration).

• Confirm that the analytical detection limits are less than the Action Levels.

• Soil results from discrete samples within the decision unit will be used. • Representative soil lead concentrations will be determined by calculating a 95% upper confidence level

(UCL) of the mean concentration.


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Step 6: Specify Tolerable Limits on Decision Errors

• Decision errors should be minimized to ensure a low probability of a property exceeding the residential lead cleanup goal of 80 ppm after cleanup and a low probability of excavating areas that are clean. Sample data are subject to random and systematic errors during field collection and sample analysis. The combination of errors is referred to as “total study error.” The two contributors to the total study error are the statistical Sampling Design Error and the Measurement Error (USEPA, 2000a):

• Sampling Design Error, which is influenced by inherent variability over space and time, sample collection, and the number of samples.

• Measurement Error, which is influenced by random and systematic errors introduced during sample preparation, sample analysis, data reduction, transmission, and storage.

• Since the total study error directly affects the possibility of making a decision error, the total decision error must be managed by minimizing the sample design and measurement errors. To minimize the sampling error, the following procedures will be employed:

• Utilize discrete sampling procedures to obtain representative confirmation samples; and • Obtain a sufficient number of samples for robust statistical analysis (samples from at least 8 different

locations per residential property so that a 95% UCL can be calculated). • To minimize measurement error, the following procedures will be utilized: • Collect the samples in a standardized manner; • Label each sample and transport it to the laboratory under chain-of-custody; • Specify that the laboratory use accepted USEPA Methods and report the data using the proper unit; • Specify that the laboratory participates in regular performance testing, is certified in California, and has

ELAP certification; • Receive the analytical data from the laboratory in an electronic format to minimize transcription errors; • Perform a quantitative and qualitative review (data validation) of the analytical data to verify the

reliability of the data. Any qualified data need to be assessed for usability. Step 7: Optimize the Design for Obtaining Data

• Upon review of the analytical data, the sampling frequency, sampling locations, sample preparation procedures, and/or the number of samples analyzed may be changed to optimize the design.

• Confirmation samples will typically be collected in 8 locations per property (the number required for a robust statistical analysis), and the 95% UCL will be calculated using EPA’s ProUCL software.

• The design options will be evaluated based on cost and the ability to meet the DQOs.


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Appendix C: Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times for Soil Analysis in the Cleanup Phase


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Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times for Soil Analysis in the Cleanup Phase

Name

Preparation Method

Analytical Method

Matrix

Container2

Preservation3

Minimum Sample Volume

or Weight

Maximum Holding

Time Chloride, Nitrate, Sulfate

N/A EPA 300 Water P, G <6oC 50 milliliters (ml) 28 days for Cl- and SO4-2;

48 hours for NO3-

Total Organic Carbon

N/A EPA 9060A/ SM 5310B

Water GA, Teflon®-lined cap (Kept in Dark)

H2SO4 to pH <2,

6oC

250 ml 28 days

Soil T, G Teflon®-lined cap

<6oC 8 ounces (oz.) 28 days

Metals Mercury

EPA 3010A/ 3005A

EPA 6010B, 6020 EPA7470A/ 7471B

Water P HNO3 to pH <2 250 ml 180 days for Metals 28 days for Mercury

EPA 7470A Soil T, G <6oC 8 oz.

Chlorinated Herbicides

EPA 8151A EPA 8151A Water GA, Teflon®-lined cap

<6oC 1 liter (L) 7 days for extraction and 40 days after extraction for analysis

Soil T, G, Teflon®-lined cap

<6oC 8 oz. 14 days for extraction and 40 days after extraction for analysis

Volatile Organic Compounds

EPA 5030C EPA 8260B Water

GA, Teflon®-lined septum

<6oC, HCl to pH < 2, 0.008% Na2S2O3

4

5 x 40 ml 14 days; 7 days if unpreserved by acid

2 Polyethylene (P); glass (G); glass amber (GA), brass or stainless-steel sleeves in the sample barrel (T). 3 No pH adjustment for soil. 4 Preservation with 0.008 percent Na2S2O3 is only required when residual chlorine is present.


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Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times for Soil Analysis in the Cleanup

Phase

Name

Preparation

Method

Analytical Method

Matrix

Container2

Preservation3


or Weight

Maximum Holding

Time Soil T, G, Teflon®-lined

cap <6oC 4 oz. 14 days

Total Petroleum Hydrocarbons (GRO)

EPA 5030C EPA 8015B Water G, Teflon®-lined septum

<6oC, HCl to pH < 2, 0.008% Na2S2O3

4

5 x 40 ml 14 days; 7 days if unpreserved by acid


<6oC 4 oz. 14 days

Total Petroleum Hydrocarbons (DRO/ORO)

EPA 3510C EPA 8015B Water GA <6oC 1 L 7 days for extraction and 40 days after extraction for analysis



Organochlorine Pesticides

EPA 3510C EPA8081A/8081B

Water GA, Teflon®-lined cap

<6oC 1 L 7 days for extraction and 40 days after extraction for analysis

Soil T, G, Teflon®- lined cap


EPA 3510C/ 3520C

EPA 8270C Water GA, Teflon®-lined cap

<6oC, 0.008% Na2S2O3

4

1 L 7 days for extraction and 40 days after extraction


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Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times for Soil Analysis in the Cleanup

Phase

Name

Preparation

Method

Analytical Method

Matrix

Container2

Preservation3


or Weight

Maximum Holding

Time Semi-volatile Organic Compounds

Soil T, G w/ Teflon®-lined

<6oC 8 oz 14 days for extraction and 40 days after extraction for analysis

Polychlorinated Biphenyls (PCBs)

EPA 3510C EPA 8082 Water GA, Teflon®-lined cap

<6oC, 0.008% Na2S2O3

4

1 L 7 days for extraction and 40 days after extraction

Soil T, G w/ Teflon®-lined

<6oC 8 oz. 14 days for extraction and 40 days after extraction


Appendix D: CDPH Forms


)______________________________________________________________________________

m:________

ABATEMENT OF LEAD HAZARDS NOTIFICATION

POST AT ALL ENTRANCES TO WORK AREA AND STRUCTURE

Work is being conducted to abate lead-based paint or lead hazards in or on this structure. For more information, please contact the individuals or agencies listed below.

Section 1 — Structure Where Abatement of Lead-Based Paint or Lead Hazards is Scheduled

Address [number, street, apartment (if applicable)] City County Zip Code

Type of structure (check one box only)

Single family dwelling

Other (specify

Multi-family building School, daycare, or other child-occupied facility

Section 2 — Summary of Specific Work and Location(s) Where Lead-Based Paint or Lead Hazards Will Be Abated

Description of work to be performed: Interior Exterior Both interior and exterior

Type of Abatement (check all that apply): Permanent (> 20 years) Temporary (< 20 years)

Do any children reside on the premises? Yes No Don’t know

Section 3

Section 4 — Restrictions on Entering Work Area

List specific times and/or dates residents are not allowed to enter work areas, if applicable.

If you would like more information, please contact the following:

Section 5 — Property Owner or Manager

Section 6 — Individual Conducting Abatement (Supervisor or Company and Supervisor)

Name and company (if applicable) Telephone number CDPH certification number (if applicable)

Address [number, street, apartment (if applicable)] City State Zip Code

Section 7 — Local Environmental Health Agency

Telephone number

This form shall be mailed or faxed to:

California Department of Public Health Childhood Lead Poisoning Prevention Branch Reports 850 Marina Bay Parkway, Building P, 3rd Floor Richmond, CA 94804-6403 Fax: (510) 620-5656

( )

Projected starting date Projected ending date

Is this form a revision of a previously submitted abatement notification form?

Yes (Date of other for ) No Canceled project

Name Telephone number



_____________________

_____________________________

____________

___________________

State of California—Health and Human Services Agency California Department of Public Health

LEAD HAZARD EVALUATION REPORT

Section 2 — Type of Lead Hazard Evaluation (Check one box only)

Lead Inspection Risk assessment Clearance Inspection Other (specify)

Section 3 — Structure Where Lead Hazard Evaluation Was Conducted

Address [number, street, apartment (if applicable)] City County Zip Code

Construction date (year) of structure

Type of structure

Multi-unit building School or daycare

Single family dwelling Other

Children living in structure?

Yes No

Don’t Know

Section 4 — Owner of Structure (if business/agency, list contact person)



Section 5 — Results of Lead Hazard Evaluation (check all that apply)

No lead-based paint detected Intact lead-based paint detected Deteriorated lead-based paint detected

No lead hazards detected Lead-contaminated dust found Lead-contaminated soil found Other_

Section 6 — Individual Conducting Lead Hazard Evaluation



CDPH certification number Signature Date

Name and CDPH certification number of any other individuals conducting sampling or testing (if applicable)

Section 7 — Attachments

A. A foundation diagram or sketch of the structure indicating the specifc locations of each lead hazard or presence of lead-based paint;

B. Each testing method, device, and sampling procedure used; C. All data collected, including quality control data, laboratory results, including laboratory name, address, and phone number.

First copy and attachments retained by inspector

Second copy and attachments retained by owner

Third copy only (no attachments) mailed or faxed to:

California Department of Public Health Childhood Lead Poisoning Prevention Branch Reports 850 Marina Bay Parkway, Building P, Third Floor Richmond, CA 94804-6403 Fax: (510) 620-5656

Section 1 — Date of Lead Hazard Evaluation

appendix i – quality assurance project plan (qapp)...pia preliminary investigation area pm project...

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