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DSHW-2006-002861 - 0901a0688013e797
ATK ALUANT TECHSYSTEMS ATK Thiokollnc. P.O. Box 707 Brigham City, UT 84302-0707 Tel 435 863-3511 Fax 435 863-2234 22 August 2007 8200-FY07-ST039 Utah Department of Environmental Quality Division of Solid and Hazardous Waste 288 North 1460 West P. O. Box 144880 Salt Lake City, Utah 84114-4880 Attenfion: Dennis R. Downs 00.0^") 7/ AUG 3 1 2005 UTAH DIVISION OF SOLID & HAZARDOUS WASTE Subject: ATK Thiokol Inc. Promontory Facility Risk Assessment Process Description and Waste Characterizafion Reference: June 22, 2006 DSHW Letter Regarding Quality Assurance Project Plan for Emission Characterizafion of Open Buming Waste Propellant Materials Dear Mr. Downs Attached is the Final Quality Assurance Project Plan for Emission Characterizafion of Open Buming Waste Propellant Materials. In response to the Divisions June 22, 2006 letter. Table 3-2 has been updated to include the reporting limits for perchlorate, NH3, CEM gases, HCN, HCl, and CI2. Please contact Blair Palmer at (435) 863-2430 if you have any quesfions conceming these documents. My telephone number is (435) 863-8490. Sincerely David P. Gosen, P.E. Director, Environmental Services FINAL QUALITY ASSURANCE PROJECT PLAN for EMISSION CHARACTERIZATION OF OPEN BURNING WASTE PROPELLANT MATERIALS Prepared for: ATK Launch Systems Promontory Facility Brigham City, Utah Prepared by: URS Corporation 8181 East Tufts Avenue Denver, Colorado 80237 June 2006 QXIALllY AlsWANCE PROJECT PLAN for EMISSION Cm^RACTlEOZATIOM OF OPENBimi^INQ WASTEI^KOPELLANT MATERIALS Apprpvals: BAi Blair Patthet;.; ATK Lsuinch Systetrts Date; ^fllifm^ George Goach, ATK tauiicli Sy-siems i//<vr/^^&^Cp M Ghriis Falkenbtii'Sv AliKLaunch Systems Sloven L.Bac^0QA; URS (Sualiiy Assiiiance Officer Vl/^i •Jpd^ '1. )I fmif Dislribution: • Blair Palmer • George Gooch • iGliris Firlkenbcig; • Johnjp^ Ciirspn • SteveriGvBuCa 7\TK ATK ATK URS URS Final TABIE OF GONTENTS Section 1 Project Descnption...... 1-1 1.1 Background I-l 1.2 Tesfing Approach Summary 1-1 1.2.1 Open Detonafion Open Buming Improved Tesfing Chamber 1-2 1.3 Test Procedures 1-2 Section 2 Project Organization and Responsibility 2-1 2.1 ATK Launch Systems 2-1 2.2 URS Project Manager 2-1 2.3 URS QuaUty Assurance Officer 2-1 2.4 URS Technical SpeciaUst and Field Support Staff 2-2 2.5 UTAH Department of Environmental Quality 2-2 2.6 Analyfical Laboratories 2-2 Section 3 Quality Assurance Objectives for Measurement Data 3-1 3.1 Intended Data Usage 3-1 3.2 General Quality Assurance Considerafions 3-1 3.2.1 Precision 3-2 3.2.2 Accuracy 3-2 3.2.3 Representafiveness 3-2 3.2.4 ComparabiUty 3-2 3.2.5 Completeness 3-3 3.2.6 Sensifivity 3-3 Section 4 Sample Selection and Collection 4-1 4.1 Sampling Methods 4-1 4.1.1 Total Suspended Particulate 4-1 4.1.2 Particulate Metals Analysis 4-2 4.1.3 PmisandPmio 4-2 4.1.4 Carbonyls 4-2 4.1.5 Semivolafile Organic Compounds 4-2 4.1.6 Dioxins/Furans 4-3 4.1.7 Volafile Organic Compounds and Tracer Gas Analysis 4-3 4.1.8 Hydrogen Chloride/Chlorine Analysis 4-3 4.1.9 Confinuous Emission Monitoring 4-3 4.2 Sampling Preparafion, Quality Control, and Measurement 4-4 4.2.1 Calibrafion of Field Instrumentafion 4-4 4.2.2 Preparafion of Sampling Equipment and Containers and Field Decontaminafion 4-4 4.2.3 Field Blanks, Duplicates, Splits, and Quality Control 4-4 4.2.4 Preservafion, Transportafion, and Storage of Samples 4-5 C:\DOCUMENTS AND SETTINGSXPALMEBGMOCAL SETTINGSMEMPORARY INTERNET FILES\OLK860\OAPP_FINAL_07132006.DOC\24-JUL-06\\ 1 URS Final TABLE OF CONTENTS 4.3 Documentafion... 4-6 Sections Sample Analysis 5-1 5.1 Field Operations 5-1 5.1.1 Sample Container Labeling 5-1 5.1.2 Sample Custody (Custody Seals, Chain-Of-Custody, and Analysis Request) 5-1 5.2 Laboratory Operafions 5-1 Section 6 Laboratory Calibration Procedures and Frequency 6-1 Section 7 Analytical Procedures 7-1 Section 8 Data Reduction, Validation, and Reporting 8-1 8.1 DataReducfion 8-1 8.2 Data Validation 8-1 8.2.1 Field Data Validafion 8-1 8.2.2 Laboratory Data Reducfion and Review 8-2 8.2.3 Independent Review 8-3 8.3 Data Reporting 8-8 Section 9 Field and Laboratory Quality Control Checks 9-1 Section 10 Performance and System Audits 10-1 Section 11 Preventive (maintenance 11-1 11.1 Field Equipment 11-1 11.2 Laboratory Equipment 11-1 Section 12 Data Assessment Procedures 12-1 12.1 Precision 12-1 12.2 Accuracy 12-1 12.3 Completeness 12-1 12.4 Representafiveness 12-2 12.5 Comparability 12-2 Section 13 CorrectiveAction 13-1 13.1 Field Changes 13-2 13.2 Laboratory Data 13-2 C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ U URS Final TABIE OF CONTENTS Section 14 Quality Assurance Reports to Management 14-1 Section 15 Miscellaneous 15-1 15.1 Tumaround Time 15-1 Section 16 References 16-1 List of Tables Table 1-1 Sampling Analysis Methods Table 3-1 Measurement Quality Objectives Table 3-2 Maximum Reporting Limits by Analytical Method Table 4-1 Sample Preservafions and Holding Times Requirements List of Figures Figure 1-1 ODOBi Test Facility at DPG Figure 2-1 Project Organizational Chart List of Appendices Appendix A Lists of Analytes Appendix B Lisfing of Letter of Instmefions C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 111 URS Final list of Abhreviatidns ATK ATK Launch Systems CDD chlorinated dibenzodioxin CDF chlorinated dibenzofuran CEM continuous emission monitor CFR Code of Federal Regulations CI2 chlorine CO carbon monoxide COC chain of custody CO2 carbon dioxide CVAAS cold vapor atomic absorpfion spectroscopy DNPH 2,4-dinitrophenylhydrazine DoD U.S. Department of Defense DoT U.S. Department of Transportafion DPG U.S. Army Dugway Proving Ground DQO Data Quality Objecfive DSHW Division of Solid and Hazardous Waste ECD electron capture detector EPA U.S. Environmental Protecfion Agency FID flame ionizafion detection GC/MS gas chromatography/mass spectroscopy HCl hydrogen chloride HMX octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine HpCDD Heptachlorodibenzo-p-dioxin HPLC high-performance liquid chromatography HRGC high-resolufion gas chromatography HRMS high resolufion mass spectrometry HpCDF Heptachlorodibenzofuran HxCDD Hexachlorodibenzo-p-dioxin HxCDF Hexachlorodibenzofuran IAW in accordance with ICAP inducfively coupled argon plasma LCS laboratory control sample LOI letter of instmcfion MDL method detecfion limit MS/MSD matrix spike/matrix spike duplicate URS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 1V Final UstofAbareviatiqns NEW net explosive weight NOx iiitrogen oxides OB open buming ODOBi Open Detonafion Open Bum-improved OCDD octachlorodibenzo-p-dioxin OCDF octachlorodibenzofuran PARCC precision, accuracy, representativeness, comparability, and completeness PeCDD pentachlorodibenzo-p-dioxin PeCDF pentachlorodibenzofuran PETN pentaerythritoltetranitrate PM Project Manager PM2.5 particulate matter smaller than 2.5 microns PMio particulate matter smaller than 10 microns PUF polyeurethane foam plug QA quality assurance QAO Quality Assurance Officer QC quality control QAPP Quality Assurance Project Plan RCRA Resource Conservafion and Recovery Act RDX hexahydro-1,3,5-trinitro-1,35-triazine REC record of environmental considerafion RL reporting limit RPD relative percent difference RSD relafive standard deviation SDG sample delivery group SFe sulfur hexafluoride SO2 sulfur dioxide SOP standing operating procedure SRM standard reference material SVOC semivolafile organic compound TCDD tetrachlorodibenzo-p-dioxin TCDF tetrachlorodibenzofuran TIC tentafively idenfified compound TM Task Manager TSP total suspended particulate [matter] URS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ V Final ListofAaarcviations URS sampling and analysis contractor (formeriy Radian Int.) UV ultraviolet VOC volafile organic compound WDTC West Desert Test Center URS C:\D0CUMENTS AND SEmNGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ VI Final SiCTIOMONE Project Description 1.1 BACKGROUND ATK Launch Systems (ATK) operates several facilities within the State of Utah for the producfion of solid rocket motors. Rocket motors are produced for a variety of customers and generally contain either Class 1.1 or Class 1.3 propellant as defined by the Department of Transportafion (DoT). As part of these facilifies, ATK operates three different sites for open buming (OB) of explosive waste generated during producfion of these motors. These open bum units are currenfiy managed as interim status Resourcie Conservafion and Recovery Act (RCRA) units with preparations underway for obtaining full RCRA Subpart X pemiits. The Utah Department of Environmental Quality Division of Solid and Hazardous Waste (DSHW) requires human health and ecological risk assessments as part ofthe Subpart X permitting process. Understanding emissions from these units is a necessary component for the risk assessment process. In 1997, ATK corrunissioned the U.S. Army to test Class 1.1 materials at the BANGBOX facility located at the Dugway Proving Grounds in westem Utah. Materials tested included Class 1.1 propellants along with contaminated materials such as cloth and paper wipes, plastics, and cleaning items. The tests determined emission factors for airbome pollutants produced when these materials are bumed. These emission factors are used with air dispersion modeling to help determine downwind impact from open buming. ATK sfill requires emission factors for the other major class of propellant (Class 1.3) produced at the Utah facilities. Additional characterization tests are planned in the near future for Class 1.3 materials at the Dugway facilifies. This Quality Assurance Project Plan (QAPP) is to provide the quality assurance/quality control (QA/QC) required to idenfify and quantify emissions from open buming of these materials. 1.2 TESTING APPROACH SUiWMARY This Quality Assurance Project Plan (QAPP) is to provide the quality assurance/quality control (QA/QC) required to identify and quanfify the emissions resulfing from the open buming of three test materials using the Open Detonafion Open Buming Improved (ODOBi) tesfing chamber. Three test materials will be studied. The first material will be 100% Class 1.3 propellant. The other two test materials will consists of a mixture of Class 1.3 propellant blended with different percentages of materials such as cloth, paper, paper wipes, plastics, and cleaning items. The 85% propellant 15% trash sample was determined by doing a two-week-long survey of the types and quanfifies of contaminated waste coming and from each live-area waste dock. The Dock Quardinators responsible for those waste docks completed this survey. The 15% trash rafion was the result of an analysis of the past three years of bum data on a daily bum basis. This sample is intended to be representafive of the most of the 1.3 contaminated waste streams treated at Promontory. The 65% propellant 35% trash sample was determined very similar to the method for the sample described above. This is the same sample break-down that was used for the 1.1 propellant tesfing that ATK completed in the 1997-1998 fime frame. UICS C;\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132008.DOC\24-JUL-06\\ 1-1 Final SiCTlOHQNE Proiect Description 1.2.1 Open Detonation Open Burning Improved Testing Chamber The ODOBi site is located in the west desert area of the West Desert Test Center/Dugway Proving Ground. The ODOBi test facility, shown in Figure 1-1, includes a test chamber with a removable stack. The ODOBi test chamber and stack are made of 2.54-cm (l-in) and 0.63-cm (0.25-in) thick steel, respecfively. The chamber consists of top and bottom secfions that, when bolted together, give an ellipsoidal shape and a volume of approximately 36 m''. An altemate configurafion is to replace the stack with a venfilation cover. The ventilation cover is basically a framework of angle iron designed to keep shrapnel from the test within the chamber and prevent overpressure by releasing the gases at the fime of deployment. Test items are placed in the chamber or suspended in the center and remotely inifiated. Sample probes are inserted into the test chamber to convey the combusfion products to sampling trains and instmments for idenfificafion and quantificafion. There are 21 sampling ports in the chamber wall. The ports are used for manual method sampling: two ports for sampling TSP, one port for PM10/PM2.5, two ports for SVOCs, two ports for dioxins/furans, two ports for HCI/CI2, and one port for VOCs, carbonyls and tracer gas sampling. One port is used for continuous monitoring of CO, CO2, NOx, and SO2. An additional port has been installed for tracer gas injecfion. The sample media is located irrmiediately outside the chamber. An electrical firing circuit remotely deploys the test items and releases the SFe tracer gas. After sampling has concluded, the chamber door is opened to release the remaining gases. The chamber is then prepared for the next test. The sample results will be in the units of pounds of target compound per pound of test item. The samples with the quanfifies of trash will be used as emission factors for the 1.3 contaminated waste streams treated and the pure propellant sample will be used for waste streams that are primarily pure propellant such as waste rocket motors. 1.3 TEST PROCEDURES Continuous air analyzers will be used on-site to monitor each test bum. Additional air emissions samples will be collected and ship off-site for analyfical tesfing. Detonafions will be performed using various convenfional means, depending on the test item characterisfics. The quanfity of material will be chosen to achieve a net explosive weight per trial. The ATK materials to be tested are placed in the center of the chamber. The tracer gas is released into the chamber immediately after the deployment of the items. Samplers to measure total suspended particulate (TSP) matter, metals, particulate matter smaller than 10 microns (PMio), particulate matter smaller than 2.5 microns (PM2.5), SVOCs, dioxins/furans, HCl and CI2 are located just outside the chamber (except PM10/PM2.5, which is inside the chamber) and connected to the chamber by short probes. The sampling rate is monitored and recorded. Two other probes convey gases from the chamber into two separate manifolds located in a bunker adjacent to the test chamber. One manifold distributes the gases to the continuous analyzers (NOx, CO, CO2, SO2, and HCl), and the other manifold distributes gases to the VOCs, tracer, and carbonyls sampling lines in the bunker. UKM C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 1 -2 Final SECTIONTWO Proiect Organization and Responsibility The project organizafion chart is shown in Figure 2-1. 2.1 ATK LAUNCH SYSTEMS The ATK Launch Systems (ATK) Project Manager is responsible for the contracting of URS, Inc. and will oversee and approves work performed by URS in support of the Emission Characterization of Open Buming Waste Propellant Materials Project. 2.2 URS PROJECT MANAGER The URS Project Manager (PM) is responsible for overall project management, including planning, communicafion with clients and regulators, coordinafion of data acquisition/field acfivifies, the health and safety of project participants, and implementafion of the project quality assurance (QA) program as given in this QAPP. The PM works direcfiy with, and is advised by, the URS Quality Assurance Officer (QAO) in the implementafion ofthis plan. Additional responsibilifies include engineering capabilifies, safety, and test report preparation. 2.3 URS QUALITY ASSURANCE OFFICER The URS QAO communicates with the URS PM, and Task Managers (TMs) on project QA and addifionally has direct reporting access to the Corporate QA Officer on quality-related matters. The QAO is responsible for the development, implementafion, and maintenance of the comprehensive project QA program. The QAO communicates with all levels of program and project management to assure that a quality product is prepared for submittal. Specific responsibilifies of the QAO are as follows: • Prepare the project-specific QAPP and provide QA/guidance to the TMs in the development of any required task-specific instmefions. • Respond to QA needs, resolve problems, and answer requests for guidance or assistance. • Review audit and nonconformance reports to determine areas of poor quality or failure to adhere to established procedures. • Confer with an audited entity on the steps to be taken for corrective actions and track nonconformance unfil correcfion. Confer with the URS PM to resolve an inadequate corrective acfion. • Maintain, with the concurrence of the ATK PM, URS PM, URS Health and Safety Manager the authority to stop work on any task where a critical situafion requires stopping work to prevent further discrepancies, danger to personnel, loss ofdata, or other problems. • Establish and maintain a filing system (including LOIs and SOPs) and all correspondence between ATK and URS for audifing purposes. • Serve as the official contact for all QA matters with the ATK Project Manager. • Provide training on QA policies, procedures, and methodology as required. ^JjRS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 2- 1 Final SECTIONTWO Proiect Organization and Responsiiiiiity 2.4 URS TECHNICAL SPECIALIST AND FIELD SUPPORT STAFF URS will provide the technical specialists as required to prepare and finalize the test plan, the health and safety plan (describes the duties and responsibilities of the assigned URS Health and Safety Manager) and test report in accordance with the contract and this QAPP. URS will also provide the test personnel required to execute the approved test plan. 2.5 UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY Will provide regulatory oversight ofthe program, and will review and provide comments on the test plan, QAPP, and test report. 2.6 ANALYTICAL LABORATORIES Commercial laboratories will analyze sample media after tesfing. The lisfing of the required analytical testing and associated methodologies are provided in Table 1-1. The offsite laboratories and assigned analysis are identified as follows: • Sevem Trent Laboratories, Knoxville, TN • Eastem Research Group, Durban, NC • ALTA Labs, EC Darado Hills, CA • Air Toxics Limited, FoIsOrn, CA • Data Chem Laboratories, Salt Lake City, UT These laboratories were chosen because they have been approved by Dugway Proving Ground and have successfully demonstrated their capabilifies tesfing on these types of samples. All laboratories have NELAC certificafion with the exception of Eastem Research Group (ERG). ERG will perform the PM2.5 and PMio, cyclone/particulate filler tesfing. The state of Utah does not certify this method. As a result, certificafion of ERG by the state of Utah is not required. mCS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 2-2 Final SECTIONTHREE Quality Assurance Obiectives for Measurement Data The overall QA objecfive for this project is to develop and implement procedures for obtaining and evaluafing data that meet the DQOs to assure or confirm that the required decisions can be made at a specified and acceptable level of uncertainty. The procedures defined in this QAPP and Letter of Instmefions are established to assure that field measurements, sampling methods, and analyfical data provide informafion that is comparable and representative of the actual field condifions, and that the data generated are technically defensible. The analyfical QA objecfives are defined in terms of sensifivity and the PARCC parameters of precision, accuracy, representativeness, completeness, and comparability. The primary goal of this QAPP is to define procedures that assure the quality and integrity of the collected samples, the representativeness of the results, the precision and accuracy of the analyses, and the completeness of the data. Data that meet the QA objectives and goals will be deemed acceptable. Data that do not meet objecfives and goals will be reviewed on a case-by-case basis to ascertain usability. 3.1 INTENDED DATA USAGE To achieve project DQOs, this QAPP and associated LOIs are designed to assure that a sufficient number of samples will be collected using technically valid scientific procedures. Utilization of the QAPP requires implementation of procedures for obtaining and evaluating data in a manner that will result in a quanfitafive or qualitafive representafion of the PARCC parameters. The parameters of precision, accuracy, and completeness provide a quantitative measure of the quality of the data collected using the ODOBi. The parameters of representafiveness and comparability ufilize documentafion of the ODOBi and laboratory procedures to qualitatively evaluate the data. Specificafion of required sensifivity levels is also an integral component of obtaining data that will safisfy the DQOs. Following the collecfion and analysis of the samples, a determination will be made whether the DQOs established for the data-collection effort were satisfied. The data will be used to assess the human health and ecological assessment associated with open buming the hazardous waste that will be represented by the ODOBi test samples. The primary data quality objecfive is to produce data of sufficient quality to conduct the risk assessments. The data collected will be validated and determined by the validator if the assigned laboratory met the minimum quality control criteria ofthe respective analytical methodologies. The results of analyfical data will ulfimately be evaluated using professional judgment in the context of the project-specific data objecfives. Upon a safisfactory review a statement in each data package report will denote if data are of sufficient quality and if the data can be used for their intended use. 3.2 GENERAL QUALITY ASSURANCE CONSIDERATIONS Data quality indicators are defined in terms ofthe PARCC parameters in the following subsecfions. The assessment of the data quality indicators is necessary to determine data usability. The established precision and accuracy limits are listed in Table 3-1. The laboratory must meet the QC acceptance criteria presented in Table 3-1. The method duplicate (MD), matrix spike (MS), and matrix spike duplicate (MSD) limits given in Table 3-1 will be used for data verificafion. The method detecfion limits (MDLs) and reporting limits (RLs) for each URS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 3-1 Final SECTIONTHREE Quaiity Assurance Obiectiwes for iweasurement Data analytical method to be contracted by an off-site conmiercial laboratory are provided in Table 3- 2. 3.2.1 Precision Precision is a measure of mutual agreement among replicate (or between duplicate) or co-located sample measurements of the same analyte. The closer the numerical values of the measurements are to each other, the more precise the measurement. Precision for a single analyte will be expressed as a relative percent difference (RPD) between results of field duplicate samples, laboratory duplicate samples, or MSD samples for cases where both results are sufficiently large (i.e., > five fimes the RL). Otherwise, the absolute difference between the results is compared to a factor of the RL (the RL is used for nondetect results). In addifion, the lab will assess precision by conducfing roufine instmment checks to demonstrate that operafing characterisfics are within predetermined limits. 3.2.2 Accuracy Accuracy is a measure of bias in a measurement system. The closer the value of the measurement agrees with the tme value, the more accurate the measurement. This will be expressed as the percent recovery of a surrogate, LCS anaiyte, MS analyte, or of a standard reference sample. 3.2.3 Representativeness Representafiveness is a qualitative parameter that expresses the degree to which sample data accurately and precisely represents characterisfics of a population, parameter variations at a sampling point, or an environmental condition. The design of, and rationale for, the sampling program (in terms of the purpose for sampling, selecting the sampling locations, the number of samples to be collected, the ambient conditions for sample collection, the frequencies and timing for sampling, and the sampling techniques) assures that the environmental condition has been sufficientiy represented. The emission factors from these tests will be representative of the 1.3 propellant contaminated wastes and the 1.3 pure propellant wastes. 3.2.4 Comparability Comparability is a qualitative parameter expressing the confidence with which one data set can be compared to another. Data sets will be considered comparable only when precision and accuracy are considered acceptable during data validation. Sample data will be collected and reported in order to be comparable with other measurement data for similar samples and sample conditions. This goal will be achieved through following standard procedures to collect and then analyze representative samples and through reporting analytical results in appropriate and consistent units. Each analytical procedure selected from among the acceptable options will be used for all investigative analyses, unless rationale is provided for any alteration. In essence, comparability will be maintained by consistency in sampling conditions, selection of sampling procedures, saniple preservation methods, analytical methods, and data reporting units. mCS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 3-2 Final SECTIONTHREE Quaiity Assurance Obiectiwes for iweasurement Data 3.2.5 Completeness Completeness is a measure of the number of valid measurements obtained in relation to the total number of measurements planned. The closer the numbers are, the more complete the measurement process. Completeness will be expressed as the percentage of valid or usable measurements to planned measurements. An objective of the field-sampling program is to establish the quantity of data needed to support the investigation. This will be achieved by obtaining samples for all types of analyses required at each individual location, a sufficient volume of sample material to complete the analyses, samples that represent all possible contaminant situations under investigation, and samples at critical data locations, such as background and control samples. The overall completeness goal for investigative activities is 100% for each sampling event. The effect of any rejected data on project objectives will be evaluated in order to assess the need for recollection or reanalysis of these samples. 3.2.6 Sensitivity To evaluate the utility of the data for comparison to numeric standards or screening it is important that the sensitivity of the methods utilized is acceptable. This QAPP specifies the use of routine and commercially available U.S. Environmental Protection Agency (EPA) approved analytical methods. The project risk assessors have reviewed the laboratory reporting limits. Based on their review, the proposed reporting limits are within the normal detection limits for the organic and inorganic samples by USEPA air methods. As a result, the proposed reporting limits are considered acceptable and can be used based on their intended use. Table 3-2 identifies the analytical reporting limits by method. UKS C:\bOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 3-3 Final SECTIONFOUR Sample Selection and Coilection Air emissions samples generated from buming the ATK test materials using the ODOBi test chamber will be collected on-site and shipped off-site for analyfical testing. The ODOBi test chamber and stack are made of 2.54-cm (l-in) and 0.63-cm (0.25-in) thick steel, respectively. The chamber consists of top and bottom sections that, when bolted together, give an ellipsoidal shape and a volume of approximately 36 m . An altemate configuration is to replace the stack with a ventilation cover. The ventilation cover is basically a framework of angle iron designed to keep shrapnel from the test within the chamber and prevent overpressure by releasing the gases at the time of deployment. Test items are placed in the chamber or suspended in the center and remotely initiated. Sample probes are inserted into the test chamber to convey the combustion products to sampling trains and instmments for identification and quantification. There are 21 sampling ports in the chamber wall. The ports are used for manual method sampling: two ports for sampling TSP, one port for PM10/PM2.5, two ports for SVOCs, two ports for dioxins/furans, two ports for HCI/CI2/NH3, hydrogen cyanide, and one port for VOCs, carbonyls and tracer gas sampling. One port is used for continuous monitoring of CO, CO2, NOx, and SO2. An additional port has been installed for tracer gas injection. The sample media is located immediately outside the chamber. An electrical firing circuit remotely deploys the test items and releases the SFe tracer gas. After sampling has concluded, the chamber door is opened to release the remaining gases. The chamber is then prepared for the next test. All field-sampling methods that will be used during these tests are based on EPA methodologies [see letters of instmcfion (LOIs) in Detailed Test Plan for Phase IX Emission Characterization of Smoke/Pyrotechnics and Propellants, May 2006]. However, in order to be used in the ODOBi" test chamber, some procedure modificafions are needed (e.g., remote operafion and relatively short sampling period). Target sampling fimes for each type of sampler are presented in the LOIs. 4.1 SAMPLING METHODS A general summary of methods to be used to support this invesfigafion is provided in the following subsecfions and presented in Table 1-1. A list ofthe target analytes is presented in Appendix A. 4.1.1 Total Suspended Particulate The concentration of Total Suspended Particulate (TSP) is determined gravimetrically in accordance with (IAW) 40 Code of Federal Regulations (CFR) 60 (see DPG LOl-101 in Appendix B) Method 5. Each filter is weighed before and after testing to determine the net weight gain of particles. The concentration of the TSP is the mass of particles collected on the filter divided by the volume of air sampled, corrected to standard temperature and pressure condifions. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 4-1 Final SECTIONFOUR Sampie Selection and Collection 4.1.2 Particulate Metals Analysis The quartz/glass-fiber filter used for the determination of TSP will also be used for the determinafion of particulate metals. After the filter is weighed to determine the TSP concentrafion, the enfire filter will be digested with concentrated acid IAW EPA Method 29 (see DPG LOI-107 in Appendix B). The digestate will be analyzed for mercury, using cold vapor atomic absorption spectroscopy (CVAAS) modified Method 7470/7471 and all other metals by inductively coupled argon plasma (iCAP) emission spectroscopy IAW Method 6010 (DPG LOI- 107 in Appendix B). Appendix A presents the list of target metals. 4.1.3 PM2.5ANDPM10 PM2.5 and PMio will be sampled by using two cyclones and a filter IAW 40 CFR 51 Method 201A (see DPG LOI-304 in Appendix B). The sample is collected from the chamber using a short probe. The gases then pass through two cyclones in series. The first cyclone removes particles larger than 10 microns. Particles that pass through the first cyclone, but not the second, are between 2.5 microns and 10. PM2.5 pass through the second cyclone. Each fraction will be measured gravimetrically. The concentrafion of PM2.5 and PMio will be computed as the mass of collected particles in each range, divided by the volume of air sampled, corrected to standard condifions. 4.1.4 Carbonyls The concentrafion of formaldehyde and other TO-11 carbonyl compounds will be determined IAW EPA Compendium Method TO-11A (see DPG LOI-109 in Appendix B). A sample stream of gas will be drawn through tubes that contain sorbent and are coated with 2,4-dinitrophenyl- hydrazine (DNPH). The tubes will then be capped and shipped to the laboratory for analysis, using high-performance liquid chromatography with an ultraviolet absorpfion detector. 4.1.5 Semivolatile Organic Compounds Semivolafile organic compounds (SVOCs) are measured based on the procedure in SW-846 0010 (see DPG LOI-301 in Appendix B). Sorbent cartridges for the determinafion of SVOCs in air will be analyzed based on SW-846 Method 8270C (see DPG LOI-301 in Appendix B) plus tentafively idenfified compounds (TICs). The samples are collected by using a combination quartz filter/adsorbent cartridge. The cartridge contains XAD-2 polymeric resin beads. After sampling, the filters and adsorbent cartridge will be extracted with solvent. The effluent is then analyzed by gas chromatography (GC) equipped with mass spectrometry (MS) detection. TICs will be reported when the response of the compound is equal or greater than 10 percent of the response of the associated intemal standard and the mass spectra library match of the TIC compound is greater than or equal to a hit quality index factor of 90 or greater. Hard copy TIC reports and spectra will be placed in the appropriate data package. mCS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSVTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 4-2 Final SECTIONFOUR Sample Selection and Collection 4.1.6 Dioxins/Furans Dioxins/furans are measured based on the procedure in 40 CFR 60 Method 23 (see DPG LOI- 301 in Appendix B). Sorbent cartridges for the determination of dioxins/furans in air are analyzed based on SW-846 Method 8290 (see DPG LOI-301 in Appendix B). The samples are collected using a quartz filter and adsorbent cartridge. The cartridge contains XAD-2 resin beads. After sampling, the filters arid adsorbent cartridge are extracted with solvent. The effluent is analyzed by high-resolufion GC (HRGC) equipped with high-resolufion MS (HRMS) detection. Appendix A presents the target isomers for this determinafion. 4.1.7 Volatile Organic Compounds and Tracer Gas Analysis Gas samples collected in 6-L canisters will be analyzed for volafile organic compounds (VOCs) by using a GC and multiple detectors as described in EPA Compendium Method TO-14A (see DPG LOI-104 in Appendix B). Most compounds will be identified via GC/MS full scan. Light hydrocarbons (e.g., acetylene, ethane, ethylene, and propane) will be identified using GC/flame ionization detection (FID). The target analytes are listed in Appendix A. Total nonspeciated VOCs will be determined by using appropriate sections of EPA Compendium Method TO-12 (see DPG LOI-104 in Appendix B). A GC with an electron capture detector will be used to analyze for the tracer gas SFg in gas samples collected in 1.0-L canisters. 4.1.8 Hydrogen Chloride/Chlorine and Ammonia Analysis HCI/CI2/NH3 will be measured by using the EPA Method 26 sampling train (see DPG LOI-108 in Appendix B). Gas will be bubbled through dilute solutions of sulfuric acid and sodium hydroxide in series. The HCl and the NH3 and are absorbed in the sulfuric acid solution, while the C12 passes through and is absorbed by the sodium hydroxide solution. The chloride concentration in the liquid solutions will be measured with an ion chromatograph. For test items that contain significant amounts of chlorine, the particulate filter from the sampling train will be recovered and sent to the laboratory for analysis. The filter will be extracted using deion-ized water and the chlorine concentration will be measured with an ion chromatograph. HCl will also be measured using CEMS as described in secfion 4.1.9. 4.1.9 Continuous Emission Monitoring Real-time eniissions of NOx, CO, CO2, SO2, and HCl will be measured using CEMs (see DPG LOI-106 in Appendix B). Chamber gases will be continuously recirculated through a manifold in the bunker adjacent to the test chamber. A small slipstream will be pulled from the manifold into each analyzer. Multipoint calibrations will be performed on each instmment before the test series to verify that response is linear. As needed, zero and upscale calibration standards will be used to check for analyzer drift and bias (at least twice per day). The analyzer outputs during sampling will be stored by the data acquisition system. UKS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 4-3 Final SECTIONFOUR Sample Selection and Collection 4.1.10 Perchlorates The quartz/glass-fiber filter used for the determinafion of TSP will also be used for the determination of perchlorates. After the filter is weighed to determine the TSP concentration, perchlorates are leached from the filter by shaking the entire filter in reagent water for 1 hour. The digestate will be analyzed for perchlorates by using ion chromatography IAW EPA Method 314. 4.2 SAMPLING PREPARATION, QUAUTY CONTROL, AND MEASUREMENT 4.2.1 Calibration of Field Instrumentation Prior to actual sampling, all field instmments will be calibrated to assure that accurate and reliable measurements are obtained. Calibration procedures and criteria for sampling equipment are based on the sampling methods in Appendix B. For sampling trains, this primarily applies to gas sample volume. For CEMs, this primarily applies to concentration drift and span. For all analytical measurements, the range of the instmment calibration is specified to encompass the range of probable experimental values. This approach ensures that all results are based upon interpolative analyses rather than extrapolafive analyses. Calibrafions are designed to include, where pracficable, at least four measurement points evenly spaced over the range. This practice minimizes the probability that false assumpfions of calibrafion linearity will be made. In addifion, it is common practice to select, when pracficable, at least one calibrafion value that approximates the levels anficipated in the actual measurement. Typically, calibrafion frequency is dictated by the need to demonstrate the stability of the calibration value over the course of measurements. 4.2.2 Preparation of Sampling Equipment and Containers and Field Decontamination Sampling media such as polyurethane foam (PUF) plugs, Summa Canisters, sorbent traps, filters, will be provided by the corresponding commercial laboratories performing the contracted sample analyses. 4.2.3 Field Blanks, Duplicates, Splits, and Quality Control QC checks of both field sampling and laboratory sample analysis will be used to assess and document data quality and to idenfify irregularifies in the measurement process that need correcfion. QC samples will be employed to assess various data quality parameters such as representafiveness ofthe environmental samples, the precision of sample collecfion and handling procedures, the thoroughness of the field equipment decontaminafion procedures, and the accuracy of laboratory analysis. To evaluate bias and contamination from field collection procedures, blanks will be prepared from distilled or deionized water. In addifion to the field QC samples idenfified below, the analytical laboratory will use a series of QC samples as identified in the laboratory QA plan and specified in the standard analytical UKS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 4-4 Final SECTIONFOUR Sample Selection and Collection methods. The types of laboratory QC samples include method blank, LCS, MS, and laboratory duplicate Or MSD. A LCS will be analyzed for each method and batch. Analyses of QC samples will be performed for samples of similar matrix type and extracfion/analysis method and for each sample batch. To supplement the use of QC samples, the laboratory will generate and use control charts to assess performance on the QC samples. The following secfions describe field QC samples that will be collected. 4.2.3.1 Equipment Blanks Equipment decontaminafion rinsates will not be required because dedicated sampling equipment will be used. 4.2.3.2 Field Replicates Each ATK test material will be bumed three separate fimes for a total of nine separate tests. As a result triplicate samples representing each sample will be collected and submitted to the off-site commercial lab for tesfing. These samples will be analyzed for all parameters identified in Table 1-1. 4.2.3.3 Field Blanks Field blanks will be used to indicate the presence of extemal contaminants that may have been introduced into the samples during collecfion. Field blanks will be collected and analyzed for all parameters of interest. Field blanks will be prepared on site during the sampling event. At least one field blank sample will be analyzed for each group of samples of a similar matrix type per event (i.e., one field blank per investigation area per matrix analyzed). The field blanks will be handled and analyzed in the same manner as all environmental samples. The field blanks will be collected by assembling and recovering one complete sampling system. No gaseous samples will be passed through the sampling train. 4.2.3.4 ThpBlanks Trip blanks will not be prepared or analyzed specific to this invesfigafion. 4.2.3.5 Peiiormance Evaluation Samples PE samples will not be prepared or analyzed specific to this invesfigafion. 4.2.4 Preservation, Transportation, and Storage of Samples Preservation requirements and associated holding times will be in accordance with QC requirements specified in Tables 4-1 to ensure sample integrity. Samples collected during this investigation will be either shipped to the laboratory via an ovemight carrier or will be hand delivered to analytical laboratory if geographically possible. UKS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 4-5 Final SECTIONFOUR Sample Selection and Collection 4.3 DOCUMENTATION Field data measurements and observations will be recorded in field logbooks and the appropriate field forms. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 4-6 Final SECTIONFIVE Sample Analysis The laboratory QA/QC procedures in this QAPP are intended to be minimum requirements. The selected laboratories to perform the work will meet, at a minimum, the requirements of this QAPP and the QA/QC requirements specified in the labs specific laboratory standard operating procedures (SOPs). Written documentation of sample custody from the time of sample collection through the generation of data by analysis of the sample is recognized as a vital aspect of an environmental investigation. As described below, sample custody applies to both field and laboratory operations. Official custody of the sample and its corresponding documentation will be maintained throughout the handling of the sample, from the time of collection, through preparation and analysis, and until sample disposal. 5.1 FIELD OPERATIONS 5.1.1 Sample Container Labeling Sample labels will be filled out in the field. Minimum requirements for informafion to be included on sample container labels are included in Test Plan. 5.1.2 Sample Custody (Custody Seals, Chain-of-Custody, and Analysis Request) For field operafions, standard sample collecfion procedures have been developed for sample custody, labeling, analysis request, and tracking. All samples will be idenfified, labeled, and logged onto a COC form, as a part of an overall procedure designed to assure the integrity of the resulfing data. The record ofthe physical sample (locafion and time of sampling) will be joined with the analytical results through accurate accounfing of the sample custody. 5.2 LABORATORY OPERATIONS All laboratories complefing chemical analyses will be required to maintain samples in a secure locafion with limited access from the fime of sample receipt through sample disposal. Sample custody procedures within a laboratory will be dependent upon the laboratory quality assurance plan (QAP) and/or SOPs. The laboratory will be responsible for maintaining logbooks and records that provide an unintermpted custody record throughout sample preparafion and analysis. The general steps to be followed by the analyfical laboratory for sample receipt, sample labeUng, and sample custody are: • Laboratory receives samples • A sample receipt checklist is filled out. The following items are documented on the checklist. The temperature of the temperature blank (taken and recorded before the samples are unpacked), where applicable. - Containers are checked for breakage/damage. URS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 5- 1 Final SECTIONFIVE Sampie Analysis Preservafive use (once the cooler is unpacked, all bottles are checked to ensure that the samples have been preserved properly), where applicable. Agreement between botfie labels and the COC form. Verification that adequate sample volume for each analysis has been provided. • A lot number or sample delivery group (SDG) number is then assigned • The sarnple bottles are then labeled with the laboratory number • The sample bottle laboratory number labeling is verified • If any discrepancies were found during login, the laboratory PM will notify the URS QAO. • The samples are placed in refrigerators if applicable. • After the final report has been issued, samples are moved to archive. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 5-2 Final SECTIONSIX Laboratory Calibration Procedures and Frequency All laboratory instmments will be calibrated in accordance with the analyfical method requirements. All analytes reported will be present in the inifial and continuing calibrafions, and these calibrafions will meet the acceptance criteria specified in the method, at a minimum. All results reported will be within the calibrated range. Records of standards preparafion and instmment calibration will be maintained and submitted with the final data package. Calibration standards for all analyses shall be traceable to a certified Standard Reference Material (SRM) that idenfifies the chemical composition, purity, property, and expirafion date. The initial calibrafion will be checked at the frequency specified in the method using standard materials. Mulfipoint calibrafions will contain the minimum number of calibrafion points specified in the method. It is permissible to drop the highest and lowest concentration standards from the calibration as long as the calibration range is adjusted appropriately and as long as the adjusted calibration includes the minimum number of standards specified in the method. If the low point standard is omitted, the reporting limit for associated data must be adjusted accordingly. If linearity criteria cannot be met by dropping either the high or low point standard, the instmment must be recalibrated. UKS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSUEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 6" 1 Final SECTIONSEVEN Analytical Procedures Chemical analysis of samples for investigative activities will be completed using the methods (or equivalent methods with approval) listed in Table 1-1. During the field activities, samples will be collected and preserved as described in Table 4-1. Sample holding times listed are calculated from the date and time of collection. For organic analyses for which there are multiple surrogate standards analyzed (e.g.. Methods SW-846 8270C, 8290) and one of theses surrogates fail to fall within surrogate recovery limits, results may be reported without reextraction and/or reanalysis if all of the following criteria are met: • There must be objective evidence of sample matrix interferences (e.g., multiple interfering peaks visible on chromatograms, co-eluting peaks, documented evidence that extracts solidify before reaching final concentration volume, first hand observation such as the presence of mulfiple phases, or results from earlier tesfing). The laboratory PM must contact the Environmental Contractor Project Chemist to relay the information and get approval to report without reanalysis. • Surrogate recoveries in LCSs and method blanks from the same extraction batch must be within surrogate recovery limits for an exception to be considered. • One of the two surrogates for gas chromatographic methods must meet the surrogate recovery limits, and the recovery for both must be greater than 10%. • No more than one surrogate compound can be out of surrogate recovery limits for either the acid or base/neutral fracfion for 8270C, and all surrogate recoveries must be greater than 10%. The methods do not and cannot include all analytical situations. These additional criteria are provided as a means of applying technically jusfifiable evaluafion criteria in situafions where there is clear and documented evidence that a reextracfion and reanalysis will not improve the quality of the data. For SW-846 8000 series analyses. Method 8000B Sections 7.5.1.2.3 and 7.7 require that the data user must be provided with inifial calibrafion and/or calibrafion verificafion data or a specific list ofthose compounds for which the relative standard deviafion (RSD) exceeded 20% and/or a list of those analyses that exceeded the 15% percent difference or percent drift limits. For analyses conducted under this QAPP, those compounds outside ofthese criteria and the actual values of the RSD and/or percent differences outside of these criteria shall be provided in the laboratory case narrafive. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 7-1 Final SECTIONEIGHT Data Reduction, Walidation, and Reporting The following secfions describe the process of handling data in terms of data generation, checking, and formatted reports for both field sampling and laboratory analytical data. 8.1 DATA REDUCTION This section outlines the methodology for assuring the correctness of the data reduction process. The procedures describe steps for verifying the accuracy of data reducfion. Data will be reduced either manually on calculation sheets or by computer on formatted printouts. The following responsibilities will be delegated in the data reduction process: • Technical personnel will document and review their own work and are accountable for its correctness, • Selected calculations will receive both a method and an arithmetic check by an independent checker. The checker will be accountable for the correctness of the checking process, • An intemal technical review will be conducted to assure the consistency and defensibility ofthe concepts, methods, assumptions, calculations, etc., and • The data reduction will be performed in a manner that produces accurate data through review and approval of calculations. 8.2 DATA VALIDATION As appropriate and consistent with DQOs, decisions and recommendations will be based upon validated data. The process through which data will be accepted, qualified, or rejected will be based upon specific data validation criteria. These criteria are discussed in the following sections for both field and laboratory data. Personnel experienced with sampling and analytical protocols and procedures will perform the data validation in accordance with the established criteria and the intended use of the data. The continuous air monitoring data generated during this project will not be validated using EPA methodologies for data validation. However, bias and drift will be verified based on manufactures recommendations. These data will be verified for contract compliance, holding time compliance (as applicable), QC sample frequency and results, and overall data quality. Data validafion qualifiers will not be applied to screening data. An overall data usability assessment will be made. Qualified chemists not involved with the actual generation of data will conduct an analytical data validation for the definitive data. The data package will be validated using the criteria contained in EPA's Funcfional Guidelines (EPA 2002, EPA 1999) that are pertinent to the SW-846 analytical method and the QA acceptance criteria contained in this QAPP. 8.2.1 Field Data Validation The purpose of the field data validafion process is to evaluate the usability of field data that are collected or documented in accordance with specified protocols outlined in appropriate LOI. Field data documentafion will be validated against the following criteria, as appropriate: ^JACS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-1 Final SECTIONEIGHT Data Reduction, Validation, and Reporting Sample locafion and adherence to the plan Field instmmentation and calibration Sample collection protocol Sample volume Sample preservation Blanks collected and submitted with each respective sample set Duplicates collected and submitted with each respective sample set Sample documentation protocol Field COC protocol 8.2.2 Laboratory Data Reduction and Review Data reduction is the process of converting measurement system outputs to an expression of the parameter that is consistent with the comparable objective identified in this plan. Reduction of analytical data will be completed in accordance with the off-site analytical laboratory's Quality Assurance Plan (QAP) and SOPs. The first level of review, which may contain mulfiple sublevels, will be conducted by the analytical laboratory that has inifial responsibility for the correctness and completeness of the data. The laboratory data reviewer will evaluate the quality of the analyfical data based on an established set of laboratory guidelines (laboratory QAP and SOPs) and this QAPP. This person will review the data packages to confirm the following: Sample preparafion informafion is correct and complete Analysis information is correct and complete The appropriate laboratory SOPs have been followed Analyfical results are correct and complete QC sample results are within established control limits Blank results are within appropriate QC limits Analyfical results for QC sample spikes, sample dupUcates, inifial and confinuous calibrafion verifications of standards and blanks, standard procedural blanks, LCSs, and inductively coupled plasma (ICP) emission spectrometer interference check samples are correct and complete • Tabulafion of reporting limits related to the sample is correct and complete • Documentafion is complete (all anomalies in the preparation and analysis have been documented; holding fimes are documented) The laboratory will perform the in-house analyfical data reducfion and QA review under the direcfion of the laboratory PM or designee. The laboratory is responsible for assessing data UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\L0CAL SETTINGS\TEMP0RARY INTERNET FILES\OLK880\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-2 Final SECTIONEIGHT Data Reduction, Walidation, and Reporting quality and advising of any data that were rated "preliminary" or "unacceptable," or were flagged with any other notafions that would caution the data user of possible unreliability. Data reduction, QA review, and reporting by the laboratory will include the following: • Raw data produced by the analyst are processed and reviewed for attainment of QC criteria as outlined in this QAPP, the laboratory QAP, and/or established EPA methods. The raw data will also be reviewed for overall reasonableness. • The data reviewer will check all manually entered sample data for entry errors and will check for transfer errors in all data electronically uploaded from the instmment output into the software packages used for calculations and generafion of report forms. Based on these checks, the reviewer will decide whether any sample re-analysis is required. • The laboratory will review initial and continuing calibration data, and calculation of response factors, surrogate recoveries, MS/MSD recoveries, post-digestion (analytical) spike recoveries, intemal standard recoveries, LCS recoveries, sample results, and other relevant QC measures. • Upon acceptance of the preliminary reports by the laboratory data reviewer, the laboratory QA officer or designee will review and approve the data packages prior to the final reports being generated. The data reduction and the QC review steps will be documented, signed, and dated by the analyst and the laboratory project manager or designee. 8.2.3 Independent Review Section 8.2.2 describes the level of review of the analytical data by the off-site laboratory that has generated the data. The second level of review and verification of the analytical data will be performed by data verificafion personnel independent of the laboratory generating the data. The purpose of this second level of review is to provide an independent review of the data package and will include a review of laboratory performance criteria and sample-specific criteria. The following subsecfions discuss the process for independent review of laboratory performance criteria and sample-specific criteria. The amount and level of data validafion will be based on the end use of the data and nature of the decisions that will be based on the data. Since the data review by the off-site analytical laboratory includes a thorough review of laboratory performance criteria (which are independent ofthe field samples being analyzed), the independent verification will include evaluafion of QA/QC issues idenfified in the laboratory case narrafive. These QA/QC issues will be evaluated relafive to the laboratory performance criteria (e.g., initial calibrafion, confinuing calibration verificafion, LCS analysis, interference check sample analysis) to verify that the laboratory analyses are in compliance with method specifications. This will be conducted for 100% of data from the off-site laboratory. The review of laboratory performance criteria is discussed in Section 8.2.3.1. The independent verification will also include a review of sample-specific criteria for 100% of the data packages for each analysis type for those parameters that are sample-related. The parameters include: holding fimes, surrogate recoveries, MS recoveries, field duplicate agreement, MSD and laboratory duplicate precision, post digesfion (analytical) spike recoveries, UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-3 Final SECTIONEIGHT Data ReducUon, Validation, and Reporting ICP serial dilution analysis agreement, and qualificafion of sample data based on analytes reported as detected in blank analyses. All analytical data received from the laboratory shall meet the data package requirements specified in the URS terms and condifions contained in the lab contract. Fully validatable data packages will be submitted as appropriate. The laboratory will be contacted with regard to any missing or incorrect deliverables in the data packages noted during the validation process. The data reviewer will document all subsequent submittals and resubmittals from the laboratory, recalculations, and data reviewer corrections. The data package will be reviewed for evaluation and compliance with method specificafions. Method non-compliances idenfified during the review, professional judgments used, and conclusions reached conceming usability of non- compliant data will be described in data verification and completeness reports. These reports will also describe the results of the sample-specific review and the impact on the quality and usability of the data. Data verification and completeness reports will be completed for each data package reviewed and submitted to DSHW with associated sample results. 8.2.3.1 Review of Laboratoiy Peiiormance Criteria Results not meeting method acceptance criteria are documented by the laboratory in the case narrative. The subsecfions below discuss how each of the laboratory performance parameters reported as not meefing acceptance criteria would be identified and documented in the data review report. The lab performance parameters to be reviewed include: 8.2.3.1.1 Initial Calibration The analytical method shall be used to determine the QC acceptance criteria for inifial calibration for those methods covered under this QAPP. If the case narrative or data review process indicates that the initial calibrafion for any analyte did not meet the acceptance criteria, it will be documented in the data review report. 8.2.3.1.2 Initial and/or Continuing Calibration Verification The analyfical method will be used to determine the QC acceptance criteria for initial and continuing calibrafion verification for those methods covered under this QAPP. If the case narrative or data validation process indicates that the initial or continuing calibration verification for any analyte did not meet the acceptance criteria, it will be documented in the data review report. 8.2.3.1.3 Internal Standard Data The analyfical method will be used to detemiine the QC acceptance criteria for intemal standard area counts for gas chromatography/mass spectrometry (GC/MS) organic analysis and for intemal standard quanfitafion for methods covered under this QAPP. Intemal standard area counts are not a direct measure of the accuracy of the analysis. If the case narrafive or data review process indicates that the intemal standard data did not meet the acceptance criteria, it will be documented in the data review report. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-4 Final SECTIONEIGHT Data Reduction, Validation, and Reporting 8.2.3.1.4 Dual Column Confirmation Results None of the specified analytical methods require second column confirmafion as documented in this QAPP. 8.2.3.1.5 Laboratory Control Sample Analysis The analyte recoveries obtained for LCS analyses will be compared to analytical method requirements and to the acceptance range established by the contract laboratory. If the case narrafive or data review process indicates that the LCS did not meet the acceptance criteria, it will be documented in the data review report. 8.2.3.1.6 Inductively Coupled Plasma Interference Check Sample for Metals The analyfical method specifies the QC acceptance criteria for interference check sample (ICS) analysis for metals analysis methods covered under this QAPP. If the case narrative or data review process indicates that the ICS did not meet the acceptance criteria, it will be documented in the data review report. 8.2.3.2 Review of Method-Specific Requirements The data verificafion review will also include a review of method -specific criteria for all of the data packages for each analysis type for those parameters that are sample related. Data verificafion and completeness checks will be conducted and documented. No recalculafion of results from the raw data or transcription error checking will be performed during the review ofthe sample-specific criteria. 8.2.3.2.1 Other Items Identified in the Case Narrative If analytes idenfified in the case narrafive are not covered by the subsecfions below and are found to be noncompliant, the data reviewer shall evaluate the problem based on method requirements. If the analytical method does not specify requirements related to the criterion under evaluation, the data reviewer should utilize professional judgment to evaluate the effect of the reported item or condition on the associated analytical data. All uses of professional judgment shall be described in the report of the data validation process. 8.2.3.2.2 Blanks The results for background and ambient blanks, preparation blanks, calibration blanks, and other blanks reported in the data package will be reviewed. If the case narrative or data review process indicates that the blank results could impact the associated sample results, it will be documented in the data review report. Preparation blanks are associated with all samples prepared with that sample (preparation batch). Continuing calibration blank samples are considered to be associated with all samples in a given analytical mn. The highest continuing calibration blank samples concentration will be used in the data review assessment process. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-5 Final SECTIONEIGHT Data Reduction, Validation, and Reporting 8.2.3.2.3 Metals and Inorganic Analyses Metals data from ICP and other inorganic data will be evaluated for method compliance and will also undergo evaluation or for following specific criteria: Holding fimes Duplicate sample analysis MS sample analysis MSD or laboratory duplicate precision Post digesfion (analyfical) spike recoveries ICP serial dilufions Field duplicate result agreement Holding Times Holding times and sample temperatures will be compared to the holding fime and sample temperature requirements contained in Table 4-1 of this QAPP. Results for analyses not performed within holding time limits wili be identified and documented in the data review report. Duplicate Sample Analysis Results for the duplicate sample (laboratory duplicate or MSD) will be compared to the criteria in Table 3-1. If the duplicate results for an analyte do not satisfy the applicable evaluation criterion, results for that analyte in the sample that duplicate was performed on will be documented in the data review report. Matrix Spike Sample Analysis The analyte recoveries obtained for MS (or MSD) analyses will be compared to the acceptance range contained in Table 3-1 for cases in which the native sample concentration is less than four times the spike concentration, as specified in the EPA Functional Guidelines. When sample concentrations of an analyte are greater than four times the spiking concentration, the results are considered to be inappropriate for assessing accuracy. Data associated with MS recoveries that are outside the acceptance range will be identified and documented in the data review assessment report. Post-Digestion Spike Recovery The analyte recoveries obtained for post-digestion spike analyses will be compared to the acceptance range for accuracy in the analytical method. Under some circumstances, laboratories will quantify results by the method of standard additions to compensate for low post-digestion spike recovery. As such, the low spike recovery would not indicate poor accuracy. However, if the result for the sample on which the post-digestion spike analysis was performed was not obtained by the method of standard additions and the post-digestion spike recovery was outside ^JKS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-6 Final SECTIONEIGHT Data Reduction, Validation, and Reporting of the acceptance limits, the result for the sample on which the post-digestion spike was mn will be identified and documented in the data review assessment report. ICP Serial Dilution ICP serial dilutions are mn to help evaluate whether or not significant physical or chemical interferences exist due to the sample matrix. When analyte concentrafions are sufficiently high (the concentrafion in the original sample is minimally a factor of 50 above the instmment detection limit) the results obtained for a five fold-dilution of the original sample are compared to the original results by means of a percent difference (%D). The %D is compared to a precision acceptance limit of ±15%. If the absolute value of the percent difference between the diluted and original result is greater than 15%, all results for that analyte in that SDG will be identified and documented in the data assessment report. Field Duplicate Agreement Criteria in Table 3-1 will be used to assess the reported results. If the criteria are not met for an analyte, all associated sample data will be identified and documented in the data review assessment report. Replicate trains will be collected for some analytes. However, the purpose of collecting duplicate trains is to ensure that at least one useable sample is collected per mn. 8.2.3.2.4 Organic Analyses For organics by GC or GC/MS, the data will be evaluated for method compliance and will then also undergo evaluafion for following specific criteria: • Holding fimes • Laboratory Control Sample • Surrogate spike results • MS/MSD analyses • Intemal standard recoveries for isotopic dilufion GC/MS analyses • Tentatively identified compounds • Field duplicate result agreement The data reviewer should use guidance from EPA Functional Guidelines to address issues not covered by this QAPP. Holding Times The holding fimes will be compared to the holding fime requirements contained in Tables 4-1.. Results for analyses not performed within holding time limits will be idenfified and documented in the data review assessment report. ^JICS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-7 Final SECTIONEIGHT Data Reduction, Validation, and Reporting Laboratory Control Samples A laboratory control sample (LCS) is prepared by spiking an aliquot of the standard matrix with a known concentrafion of the analyte(s) of interest. The recovery of the target analyte (s) must be reported within a stafistical recovery Umit(s) range. The QC acceptance recovery is statistically calculated based upon historical lab performance. Typically, QC acceptable limits are reported within 80-100 %. The purpose of the LCS is to monitor laboratory performance for a specific method. Surrogate Spike Results The surrogate recoveries obtained for each sample analysis for which surrogates were analyzed will be compared to the laboratory historical limits to assess trending and if the percent recovery is reported within the limits specified in Table 3-1. Results for analytes in the sample associated with surrogate recoveries outside the acceptance range will be identified and documented in the data review assessment report. Matrix Spike/Matrix Spike Duplicate Sample Analysis The analyte recoveries obtained for MS and MSD analyses will be compared to the acceptance range contained in Table 3-1 for cases in which the native sample concentration is less than four times the spike concentrafion. When sample concentrations of an analyte are greater than four times the spiking concentration, the results are considered to be inappropriate for assessing accuracy. Data associated with MS or MSD recoveries outside the acceptance range will be idenfified and documented in the data review assessment report. 8.3 DATA REPORTING Field measurements and observations will be recorded in field logbooks. Laboratory data will be recorded in the standard formats described in the Laboratory Statement of Work. UKS C:\D6CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 8-8 Final SECTIONNINE Field and Laboratory Quality Control Checks QC checks of both field sampling and laboratory sample analysis will be used to assess and document data quality and to identify discrepancies in the measurement process that need correcfion. Field QC samples are discussed in detail in Section 4.2.3. The analyfical laboratory will use a series of QC samples as idenfified in the laboratory QA plan and specified in the standard analyfical methods. The types of laboratory QC samples include method blank, LCS, MS, and laboratory duplicate or MSD. A LCS will be analyzed for each method and batch. Analyses of QC samples will be performed for samples of similar matrix type and extracfion/analysis method, and for each sample batch. To supplement the use of QC samples, the laboratory will generate and use control charts to assess performance on the QC samples. UKS C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 9- 1 Final SECTIONTEN Performance and System Audits Performance or system audits will not be performed under this QAPP. UKS'^^OCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSXTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 10-1 Final SECTIONELEVEN Prewentiwe Maintenance 11.1 FIELD EQUIPMENT All field equipment and instmments used to generate data will be adjusted and maintained to operate within manufacturers' specificafions. Maintaining the necessary accuracy, precision, sensifivity, and traceability of theequipment helps assure that reliable measurements and representative data will be obtained. Methods and intervals of inspection and maintenance will be based on the type of equipment, stability characterisfics, required accuracy, intended use, and environmental factors (such as temperature, humidity, etc.). As appropriate, back-up equipment and critical spare parts will be maintained in order to quickly correct equipment malfuncfion. As appropriate, inspecfion records and maintenance schedules will be maintained for instmments and equipment and will be stored in the project files. Equipment that is identified to be malfunctioning will be removed from operafion and tagged until repaired. 11.2 LABORATORY EQUIPMENT Guidelines for inspecfion and prevendve maintenance of laboratory equipment will be established in the laboratory QAP. Essentially, inspection and preventive maintenance will be implemented on a scheduled basis to minimize downtime and to assure accurate measurements from laboratory equipment. This program is designed to achieve results commensurate with the specified capabilities of equipment operation, thus generating data of known quality without concem for misapplication. In addition, back-up equipment and critical spare parts will be maintained in order to quickly correct equipment malfunction. All equipment and instmments used to generate data will be adjusted and maintained to operate within manufacturers' specifications and the method requirements. Maintaining the necessary accuracy, precision, sensitivity, and traceability of the equipment helps assure that reliable measurements and representative data will be obtained. Methods and intervals of inspection and maintenance will be based on the type of equipment, stability characteristics, required accuracy, intended use, and environmental factors (such as temperature, humidity, etc.). Such an effort will be conducted by trained technicians using service manuals or through service agreements with a qualified maintenance contractor. In addition, procedures will assure that equipment is properiy used by trained personnel. Inspection and maintenance, schedules and records will be maintained for the equipment, as appropriate. Both equipment and equipment records will be located in a controlled access facility. Each instmment will be assigned a unique identificafion number to document and track usage and maintenance. Equipment that is idenfified to be malfunctioning will be removed from operafion unfil repaired. UKS^:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SEmNGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 11-1 Final SECTIONTWELVE Data Assessment Procedures All data generated for the project will be assessed for accuracy, precision, completeness, representativeness, and comparability. This secfion establishes the methods for calculafing accuracy, precision and completeness and for evaluating representativeness and comparability 12.1 PRECISION Precision examines the spread of data about their mean (Secfion 3.2.1). The spread represents how different the individual reported values are from the average reported values. Precision is thus a measure of the magnitude of errors and will be expressed as the RPD or the RSD for all methods. The lower these values are, the more precise are the data. These quanfities are defined as follows: RPD (%) RSD (%) 100 x |S-D| (S + D)/2 (s/X) x 100 where: D S X s Concentration or value of an analyte in a duplicate sample Concentration or value of an analyte in a original sample Mean of replicate analyses Standard deviafion 12.2 ACCURACY Accuracy measures the average or systematic error of an analytical method (Section 3.2.2). This measure is defined as the difference between the measured value and the actual value. Accuracy will be expressed as the percent recovery. This quanfity is defined as follows: Recovery (%) = |SC-UC| X 100 KC where: SC = UC KC 12.3 COMPLETENESS Measured concentration ofan analyte in spiked sample or LCS Measured unspiked concentration of an analyte (assume to be zero for LCS and surrogates) Known concentradon of an analyte added Completeness establishes whether a sufficient amount of valid measurements were obtained (Section 3.2.5). The closer this value is to 100%, the more complete the measurement process. The overall project completeness goal is 100%. Completeness will be calculated as follows: Completeness (%) V X R 100 where: V R Number of valid measurements (includes data qualified as estimated) Number of planned measurements URS OADOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 12- Final SECTIONTWELVE Data Assessment Procedures 12.4 REPRESENTATIVENESS Representafiveness expresses the degree to which data accurately and precisely represents the environmental condifion (Secfion 3.2.3). A statement on representafiveness will be presented in data validafion reports nofing the degree to which the data represents the emissions of the waste materials that will be tested. 12.5 COMPARABILITY Comparability expresses the confidence with which one set of data can be compared to another (Secfion 3.2.4). A statement on comparability noting the degree to which data meet the comparability goal will be presented in data validafion reports. UMCS-^OCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSXTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 1 2-2 Final SECTIONTHIRTEEN Correctiye Action Provisions for establishing and maintaining QA reporting to the appropriate management authority will be instituted to assure that early and effecfive correcfive action can be taken when data quality falls outside of established acceptance criteria. In this context, correcfive action involves the following steps: • Discovery of a nonconformance • Identification of the root cause of the problem and the responsible individual(s) • Discuss, plan and schedule corrective/preventive action • Review the corrective acfion taken • Confirmation that the desired results were achieved It is the intent of the QA process to minimize corrective actions through the development and implementafion of effective intemal controls. To accomplish this, procedures will be implemented as described in this secfion to acfivate a corrective action for each measurement system when acceptance criteria have been exceeded. In addition, reviews and audits will be conducted on a periodic basis to check this implementation. Results of QA reviews and audits typically identify the requirement for corrective action. When this occurs, a corrective action plan will be prepared to include: identification ofthe corrective action, organizational level responsible for the action taken, steps to be taken for correction, and approval for the corrective action. Activities subject to QA and QC will be evaluated for compliance with applicable standard procedures. This includes both field and laboratory operafions as described in this QAPP and LOIs. A lack of compliance with these procedures will consfitute a nonconformance. The URS Quality Assurance Officer (QAO), or any URS project member who discovers or suspects a nonconformance, is responsible for inifiafing a nonconformance report (NCR). The QAO will be responsible for reviewing all audit and NCRs to detemiine areas of poor quality or failure to adhere to established procedures. The QAO will report nonconformances to the URS PM. The PM will assure that no additional work, which is dependent on the nonconforming activity, is performed unfil a confirmed nonconformance is corrected. The URS PM will be responsible for evaluating all NCRs, conferring with the QAO on the steps to be taken for correction, and execufing the correcfive action as developed and scheduled. Correcfive action measures will be selected to prevent or reduce the likelihood of future nonconformances and address the causes to the extent idenfifiable. Selected measures will be appropriate to the seriousness of the nonconformance and realistic in terms of the resources required for implementation. Upon complefion of the corrective action, the QAO will evaluate the adequacy and completeness of the action taken. If the action is found to be inadequate, the QAO and URS PM will confer to resolve the problem and determine any further actions. Implementation of any further action will be scheduled by the URS PM. If the corrective action is found to be adequate, the QAO will notify the URS PM of the satisfactory corrective action and the completion of the audit. UKS^^^DOCUMENTS AND SETTINGS\PALMEBG\L0CAL SETTINGS\TEMP0RARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 13-1 Final SECTIONTHIRTEEN CorrectiveAction 13.1 FIELD CHANGES The URS PM is responsible for all investigative activities. In this role, the URS PM at times will adjust the field program to accommodate project-specific needs. When it becomes necessary to modify this program, the URS PM will notify the ATK PM and URS QAO. 13.2 LABORATORY DATA The laboratory will report the types of out-of-control occurrences, how these occurrences are documented, and who is responsible for correction and documentation. Generally, corrective acfion will be inifiated by out-of-control events such as: poor analysis replicafion, poor recovery, instmment calibrafion problems, blank contamination, etc. Appropriate laboratory personnel will initiate corrective action at any fime during the analytical process when deemed necessary based on analytical judgment, method requirements, or when QC data indicate a need for acfion. Corrective actions may include, but are not limited to: Re-analysis Calculation checks Instmment recalibration Preparation of new standards/blanks Re-ex trae ti on/di gesti on Dilufion Application of another analysis method Additional training of analysts The following items must be documented for out-of-control incidents so that corrective action may be taken to set the system back "in control." These items will typically constitute a corrective action report that is signed by the laboratory director and the laboratory QA contact: • Where the out-of-control incident occurred, • When the incident occurred and was corrected, • Who discovered the out-of-control incident, • Who verified the incident, and • Who corrected the problem? The laboratory will be responsible for re-sampling and re-analysis costs associated with gross failure to meet laboratory QA/QC objecfives. In consultation with the Environmental Contractor Project Chemist, wither the Environmental Contractor PM or the QAM may initiate a request for correcfive acfion. UICS-^DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSVTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132008.DOC\24-JUL-06\\ 13-2 Final SECTIONFOURTEEN Quality Assurance Reports to Management The investigation report (typically the Letter Report of Findings) will address the status and results of the sampling and associated QA/QC process for each data generation activity. The report will typically address and document the following QA/QC items: Measurement system performance and data quality. This secfion of the report will present the assessment of precision, accuracy, and completeness in relation to the specified field and laboratory data acceptance criteria and data assessment procedures. • Audit findings and corrective acfion measures. This secfion of the report will present the effectiveness of the data QA program and implementation, and include a summary of findings and observations resulting from audits, as appropriate. • Final laboratory QA assessment. This secfion of the report will present a summary of the laboratory results and performances based upon the data validafion process. • The routine evaluations of data quality described throughout this QAPP will be documented and filed along with the data in the project files. A summary of data quality and the results of checking the sample data against the quality assurance objectives will be presented in the final report that presents and summarizes the data generated. Reporting nonconformances and field changes to management is discussed in Secfion 13. An effecfive QC program should include formal and frequent reports to management and technical staff of progress in the on-going implementation of the QC plan. At a minimum, the following parties should receive updates on project status: 1) ATK Project Manager; 2) URS PM; 3) URS QAO; and 4) other technical staff. ^JKS-\D0CUMENTS AND SETTINGS\PALMEBG\L0CAL SETTINGS\TEMP0RARY INTERNET FILES\OLK860\QAPP_FINAL_071 32006.DOC\24-JUL-06\\ 14-1 Final SECTIONFIFTEEN Miscellaneous 15.1 TURNAROUND TIME Reporting of data will occur within the time frames specified in the Work Orders to the laboratory. In case of any anficipated delays, the laboratory PM for the project will nofify the Environmental Contractor Project Chemist. UKS':\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 15-1 Final SECTIONSIXTEEN References EPA, see U.S. Environmental Protection Agency. Headquarters, Department ofthe Army, Washington, DC, Technical Manual (TM) 9-1370-203- 34&P, Military Pyrotechnics, March 1996. Office of Solid Waste and Emergency Response, Washington, DC, Environmental Protection Agency Test Methods for Evaluafing Solid Waste Physical/Chemical Methods (SW-846), Methods 0010, 8270, and 8290,, November 1986. U.S. Army Defense Ammunifion Center and School, Logisfics Review & Assistance Office, Savanna, Illinois, Hazard Classification of United States Military Explosives and Munifions, Rev. 11, February 2001. U.S. Army Defense Ammunifion Center, McAlester, Oklahoma, MIDAS Home Page, http://206.37.241.30/. U.S. Army Developmental Test Command (DTC), Aberdeen Proving Ground, Maryland, Test Authorization in the Test Resource Management System for West Desert Test Center (WDTC), U.S. Army Dugway Proving Ground (DPG), Utah, to perform Emission Products Characterizafion of Munitions Study (Phase IV), Test Project No. 8-CO-160- 000-067, 14 March 2001. U.S. Army Dugway Proving Ground (DPG), Utah, Detailed Test Plan, Emission Characteri- zafion of Training Ordnance Phase I, II, III, & IV Smoke & Simulators in the BANGBOX™ Test Facilifies, DPG Document No. DPG-TP-98-026, March 1998. U.S. Army Dugway Proving Ground (DPG), Utah, Detailed Test Plan fir Phase IX, Emission Characterization of Smoke/Pyrotechnics and Propellants, WDTC-TP-06-031, June 2006. U.S. Army Dugway Proving Ground (DPG), Utah, Hazardous Waste Management Plan, Environmental Activities, June 2000. U.S. Army Dugway Proving Ground (DPG), Utah, Record of Environmental Consideration for Phase-V Emission Characterization for Exploding Ordnance and Smoke/Pyrotechnics (BangBox FY03) Testing at U.S. Army Dugway Proving Ground (DPG), Dugway, Utah. TRMS Number 8-CO-160-000-067, 30 July 2003. U.S. Army Dugway Proving Ground (DPG), Utah, Regulation 350-104, Training and Certi- fication Program for Conventional Ammunition, Chemical Laboratory, and Chamber Test Facility Operations, June 1996. U.S. Army Dugway Proving Ground (DPG), Utah, Standing Operating Procedure (SOP) DP- OOOO-P-851, Rev. 4, Propellant Explosive and Pyrotechnic Thermal Treatment Evaluation Test Facilities (PEP-TTET) (BANG BOXES), 1 August 2005. U.S. Army Dugway Proving Ground (DPG), Utah, Standing Operating Procedure (SOP) DP- OOOO-H-138, Rev. 6, Munitions Demilitarization - Open Buming of Propellant, Propellant Charges, Bulk Explosives (HMX or RDX), 4 June 2002. U.S. Army Dugway Proving Ground (DPG), Utah, Standing Operating Procedure (SOP) DP- OOOO-G-139, Rev. 8, Munitions Demilitarization - Open Detonation of Explosives, and Emergency Procedures, 13 December 2004. ^JICS^:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 16-1 Final SECTIONSIXTEEN References U.S. Army Environmental Center, Pollution Prevention & Environmental Technology Division FY99 Annual Report, Innovative Technology Demonstration, Evaluation and Transfer Activities, Doc. No. SFIM-AEC-ET-TR-99070, January 2000. U.S. Environmental Protection Agency (EPA). 1999. Final USEPA Contract Laboratory Program National Functional Guidelines for Organic Data Review. EPA 540-R-99-008, Office of Emergency and Remedial Response, Washington, D.C. U.S. Environmental Protection Agency (EPA). 2002. Final USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review. EPA 540-R-Ol- 008, Office of Emergency and Remedial Response, Washington, D.C. UDEQ, see Utah Department of Environmental Quality. USEPA QA/G-4. 2000. Guidance fro the Data Quality Objectives Process, U.S. Environmental Protection Agency Office of Research and Development, Washington, D.C, EPA/600/R-96/056. USEPA QA/R-5. 2001. EPA Requirements for Quality Assurance Project Plans for Environmental Data Operations. U.S. Environmental Protection Agency, Washington, D.C, EPA/240/B-01/003. USEPA QA/G-5. 2002. EPA Guidance for Quality Assurance Project Plans. U.S. Environmental Protection Agency Office of Research and Development, Washington, D.C, EPA/240/R-02/009. ^JICS':\D0CUMENTS AND SETTINGS\PALMEBG\L0CAL SEmNGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ 16-2 Final Figures Final "•••%T'W!^mmwwi Figure 1-1 ODOBi Test Facility at DPG Final URS QA Officer Steve Baca, CQA Alliant Thiokol Project Manager Blair Palmer URS Project Manager John Carson Commercial Laboratories URS Administrafive URS Health & Safety Sally Miller, CIH URS Technical Specialists (i.e.. Chemists, Data Managers) URS Field Support Staff Figure 2-1 Project Organizational Chart Final Tables Final Table 1-1 Sampling and Analysis Methods Analytical Target TSP Metals Perchlorates'^ PM10/PM2.5 Dioxins/ Furans SVOCs VOCs Tracer Compound (SFfi) HCI/CI2/NH3' HCN"^ Carbonyls CO, CO2, NOx, SO2, HCl Sampling Equipment Particulate filter Particulate filter Particulate filter Cyclones/particulate filters Modified Method 5 Modified Method 5 SUMMA® canisters Canisters Impinger train Soda lime sorbent tube DNPH-laced sorbent tube CEM Sampling Method'' Method 5 in Appendix A of 40 CFR 60 Method 5 in Appendix A of 40 CFR 60 Method 5 in Appendix A of40CFR60 Method 201A in 40 CFR 51 withPM|oandPM2.5 cyclones Method 23 in Appendix A of 40 CFR 60 SW-846 Method 0010 EPA Compendium Methods TO-12 and TO-14 Grab Method 26 in 40 CFR 60, and Conditional Test Method 027 NIOSH Method 6010 EPA Compendium Method TO-11A Methods 3A, 6C, 7E, and 10 in Appendix A of 40 CFR 60 Analytical Method Method 5 in Appendix A of 40 CFR 60 SW-846 Methods 6010/7470"' EPA Method 314" Method 201A in 40 CFR 51 SW-846 Method 8290' SW-846 Method 8270' plus TICs EPA Compendium Methods TO-12 and TO-14 plus TICs GC/Electron Capture Detector Method 26 in 40 CFR 60, and Conditional Test Method 027 NIOSH Method 6010 EPA Compendium Method TO-11A Methods 3A, 6C, 7E, and 10 in Appendix A of 40 CFR 60 Laboratory STL STL STL ERG Alta Labs STL ATL ATL ERG DataChem ATL None The sampling equipment and methods used during the tests will be based on standard methods, as indicated (see Appendix B for details). Method modifications will be necessary to accommodate the testing characteristics of the ODOBi. •"AnalysesofTSP. 'Analysis of soluble TSP fraction. "* Filter and adsorbent. ^Energetics, NH3, and HCN samples will not be collected for the ATK OB tests as requested by the customer (ATK). ATK = ATK Thiokol Propulsion ATL = Air Toxics Limited CEM = continuous emission monitor Final CFR = Code of Federal Regulations CI2 = chlorine CO = carbon monoxide CO2 = carbon dioxide DNPH = 2, 4-dinitrophenylhydrazine EPA = U.S. Environmental Protection Agency ERG = Eastem Research Group GC = gas chromatography HCl = hydrogen chloride HCN = tiydrogen cyanide NH3 = ammonia NIOSH = National Institute for Occupational Safety and Health NOx = nitrogen oxides OB = open bum ODOBi = open detonation/open bum-improved PMio = particulate matter smaller than 10 microns PM2.5 = particulate matter smaller than 2.5 microns SFs = sulfur hexafluoride SO2 = sulfur dioxide STEM = sampling train for energetic materials STL = Sevem Trent Laboratories SVOC = semivolatile organic compound TIC = tentatively identified compound TSP = total suspended particulate matter USACHPPM = U.S. Army Center for Health Promotion and Preventive Medicine voc = volatile organic compound Final Table 3-1 Measurement Quality Objectives Test Parameter TSP PM,(/PM2.5 Perchlorates Metals VOCs Tracer Compound SVOCs Dioxins/Furans HCI/CI2/NH3 HCN Carbonyls NOx, CO, CO2, SO2, HCl Accuracy Object!vCd) 95 to 105% accuracy of flow and filter-weighing devices 95 to 105% accuracy of flow and filter weighing devices 80 to 120% recovery of matrix spike 75 to 125% recovery of post digestion matrix spike from filter 70 to 130% recovery of laboratory media spike (laboratory calibration check material, transferred into a canister, and analyzed with the field samples) 60 to 140% for polar compounds 80 to 120% recovery of laboratory media spike 40 to 120% surrogate spike recoveries 40 to 135% surrogate spike recoveries 85-115% recovery for matrix spike 75 to 125% recovery for matrix spike 70 to 130% recovery of media spike ±5% of span for zero and upscale bias checks Precision Objective RPD <25% for multiple runs on a single event RPD <25% for multiple runs on a single event RPD <25% on MS/MSD <20% RPD for recovery of post digestion MS/MSD from filter <25% RPD for top ten peaks on laboratory duplicate analyses ±10% RPD for laboratory duplicate analyses <50% RPD for MS/MSD for all compounds <20% RPD for MS/MSD <25% RPD for MS/MSD <20% RPD for MS/MSD <25% RPD for duplicate media spikes ±3% of span for zero and upscale drift checks 1) Limits will be updated based on labs running averages in reference to surrogate recoveries CO = carbon monoxide CO2 = carbon dioxide CI2 = chlorine HCl = hydrogen chloride HCN = hydrogen cyanide MS/MSD = matrix spike/matrix spike duplicate NH3 = ammonia NO, = nitrogen oxides PM2.5 = particulate matter smaller than 2.5 microns PMio= particulate matter smaller than 10 microns RPD = relative percent difference SO2 = sulfur dioxide SVOC = semivolatile or ganic compound TSP = total suspended particulate [matter] VOC = volatile organic compound Final Table 3-2 Laboratory Identification, Analyses Method and Respective Reporting Liniits Air Toxics Limited Carbonyls Rep. Lmt (TO-11 A) (ug) Formaldehyde 0.05 Acetaldehyde 0.1 Propanal 0.25 Acetone 0.25 Crotonaldehyde 0.25 Methyl Ethyl Ketone/Butyraldehydes 0.25 Benzaldehyde 0.25 Isopentanal 0.25 Pentanal 0.25 o-Tolualdehyde 0.25 m,p-Tolualdehyde 0.25 Hexanal 0.25 2,5- Dimethyibenzaldehyde 0.5 Data CheiT) Laboratories HCN Rep. Lmt (NIOSH 6010) (ug) Cyanide 0.2 " HCl is reported as chloride in t ALTA Labs Dioxins/Furans (Method 8290) 2,3,7,8-TCDD 1,2,3,7,8-PeCDD 1,2,3,4,7,8-HxCDD 1,2,3,6,7,8-HxCDD 1,2,3,7,8,9-HxCDD 1,2,3,4,6,7,8-HpCDD OCDD 2,3,7,8-TCDF 1,2,3,7,8-PeCDF 2,3,4,7,8-PeCDF 1,2,3,4,7,8-HxCDF 1,2,3,6,7,8-HxCDF 2,3,4,6,7,8-HxCDF 1,2,3,7,8,9-HxCDF 1,2,3,4,6,7,8-HpCDF 1,2,3,4,7,8,9-HpCDF OCDF STL Perchlorates (Method 314) Perchlorate he acid samples, and Cl Rep. Lmt (pg) 10 50 50 50 50 50 100 10 50 50 50 50 50 50 50 50 100 Rep. Lmt (ug) 0.4 2 is reporte ERG HCI/CI2/NH3 Rep. (Method 26A Lmt &CTM-27) (ug) Chloride^ 10 Ammonium 10 URS Rep. CEM Gases Lmt (ppm) CO2 1.0 CO 0.04 NOx 0.20 SO2 0.20 HCl 0.20 d as chloride in the a STL Metals „^^, ^. (Method "7^^-* 7470/6010) ^"^' Aluminum 20 Antimony Arsenic Barium Beryllium Cadmium Chromium Cobalt Copper Lead Magnesium Manganese Mercury Nickel Phosphorus Selenium Silver Thallium Zinc kaline samples 6 1 20 0.5 0.5 1 5 2.5 1 500 1.5 0.2 4 30 1 2 3.5 2 Final Air Toxics Limited VOCs TNMOG 1,1,1-Trichloroethane 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene 1,2,3-Trichloropropane 1,2,3-Trimethylbenzene 1,2,4-Trichlorobenzene 1,2,4-Trimethylbenzene 1,2-Dibromoethane (EDB) 1,2-Dichlorobenzene 1,2-Dichloroethane 1,2-Dichloropropane 1,3,5-Trimethylbenzene 1,3-Butadiene 1,3-Dichlorobenzene 1,3-Diethylbenzene 1,4-Dichlorobenzene 1,4-Diethylbenzene 1,4-Dioxane 1-Butene 1-Hexene 1-Pentene 2,2,4-Trimethylpentane 2,2-Dimethylbutane 2,3,4-Trimethylpentane 2,3-Dimethylbutane 2,3-Dimethylpentane 2,4-Dimethylpentane 2-Butanone (Methyl Ethyl Ketone) 2-Ethyltoluene Rep Lmt (ppbv) 10 0.5 0.5 0.5 0.5 0.5 2 2 2 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 2 0.5 2 2 2 2 2 2 2 2 2 2 2 0.5 2 STL SVOCs 1,2,4,5-Tetrachlorobenzene 1,2,4-Trichlorobenzene 1,2-Dichlorobenzene 1,2-Diphenyihydrazine 1,3,5-Trinitrobenzene 1,3-Dichlorobenzene 1,3-Dinitrobenzene 1,4-Dichlorobenzene 1-Chloronaphthalene 1-Naphthylamine 2,3,4,6-Tetrachlorophenol 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol 2,4-Dichlorophenol 2,4-Dimethylphenol 2,4-Dinitrophenoi 2,4-Dinitrotoiuene 2,6-Dichlorophenol 2,6-Dinitrotoluene 2-Acetylaminofluorene 2-Chioronaphthalene 2-Chlorophenol 2-Methylnaphthalene 2-Methylphenol 2-Naphthylamine 2-Nitroaniline 2-Nitrophenol 3,3'-Dichlorobenzidine 3,3'-Dimethylbenzidine 3-Methylcholanthrene 3-Methylphenol & 4-Methylphenol 3-Nitroaniline Rep Lmt (ug) 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10 10 10 10 10 50 10 50 50 10 10 50 Final Air Toxics Liirnited VOCs 2-Hexanone 2-Methylheptane 2-Methylhexane 2-Methylpentane 2-Nitropropane 2-Propanol 3-Chloropropene 3-Ethyltoluene 3-Methylheptane 3-Methylhexane 3-Methylpentane 4-Ethyltoluene 4-Ethyltoluene 4-Methyl-2-pentanone Acetone Acetonitrile Acetylene Acrolein Acrylonitrile alpha-Chlorotoluene alpha-Pinene Benzene beta-Pinene Bromodichloromethane Bromoform Bromomethane Butanal Butane Carbon Disulfide Carbon Tetrachloride Chloroacetonitrile Chlorobenzene Rep Lmt (ppbv) 2 2 2 2 2 2 2 2 2 2 2 0.5 2 0.5 2 5 5 2 2 0.5 2 0.5 2 0.5 0.5 0.5 5 5 0.5 0.5 5 0.5 STL SVOCs 4,6-Dinitro-2-methylphenol 4-Aminobiphenyl 4-Bromophenyl phenyl ether 4-Chloro-3-methylphenol 4-Chloroaniline 4-Chlorophenyl phenyl ether 4-Nitroaniline 4-Nitrophenol 7,12-Dimethylbenz(a)anthracene Acenaphthene Acenaphthylene Acetophenone Aniline Anthracene Benzidine Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(ghi)perylene Benzo(k)fluoranthene Benzoic acid Benzyl alcohol bis(2-Chloroethoxy)methane bis(2-Chloroethyl) ether bis(2-Chloroisopropyl) ether bis(2-Ethylhexyl) phthalate Butyl benzyl phthalate Carbazole Chrysene CS Dibenz(a,h)anthracene Dibenzofuran Rep Lmt (ug) 50 10 10 10 20 10 50 50 10 10 10 10 20 10 100 10 10 10 10 10 100 100 10 10 10 20 10 10 10 10 10 10 Final Air Toxics Limited VOCs Chloroethane Chloroform Chloromethane cis-1,2-Dichloroethene cis-1,3-Dichloropropene cis-2-Butene cis-2-Pentene Cumene Cyclohexane Cyclopentane Decane Dibromochloromethane D-Limonene Ethane Ethanol Ethene Ethyl Benzene Ethyl Ether Ethyl Methacrylate Freon 11 Freon 113 Freon 114 Freon 12 Heptane Hexachlorobutadiene Hexane Isobutane Isopentane Isoprene m.p-Xylene Methacrylonitrile Methyl Acrylate Rep.Lmt (ppbv) 0.5 0.5 2 0.5 0.5 2 2 0.5 0.5 2 2 0.5 2 5 2 5 0.5 2 5 0.5 0.5 0.5 0.5 0.5 2 0.5 2 2 2 0.5 2 2 STL SVOCs Diethyl phthalate Dimethyl phthalate Di-n-butyl phthalate Di-n-octyl phthalate Dinoseb Diphenylamine Ethyl methanesulfonate Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclopentadiene Hexachloroethane Hexachloropropene lndeno(1,2,3-cd)pyrene Isophorone Isosafrole Methyl methanesulfonate Naphthalene Nitrobenzene N-Nitro-o-toluidine N-Nitrosodiethylamine N-Nltrosodimethylamine N-Nitrosodi-n-butylamine N-Nitrosodi-n-propylamine N-Nitrosodiphenylamine N-Nitrosomethylethylamine N-Nitrosomorpholine N-Nitrosopiperidine N-Nitrosopyrrolidine o-Toluidine p-Dimethylaminoazobenzene Rep Lmt (ug) 10 10 20 10 10 10 10 10 10 10 10 50 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Final VOCs Air Toxics Liniited Rep Lmt (ppbv) Methyl Methacrylate 2 Methyl tert-butyl ether 0.5 Methylcyclohexane 2 Methylcyclopentane 2 Methylene Chloride 0.5 Naphthalene 2 n-Butanol 2 n-Butylchloride 5 Nonane 2 Octane 2 o-Xylene 0.5 Pentane 2 Propane 5 Propylbenzene 0.5 Propylene 5 Styrene 0.5 Tetrachloroethene 0.5 Tetrahydrofuran 0.5 Toluene 0.5 trans-1,2-Dichloroethene 0.5 trans-1,3-Dichloropropene 0.5 trans-2-butene 2 trans-2-Pentene 2 Trichloroethene 0.5 Undecane 2 Vinyl Acetate 2 Vinyl Chloride 0.5 STL SVOCs Pentach lorobenzene Pentachloroethane Pentachloronitrobenzene Pentachlorophenol Phenacetin Phenanthrene Phenol Pyrene Pyridine Safrole Rep Lmt (ug) 10 10 50 50 10 10 10 10 20 10 Final Table 3-3 Listing of LOIs for Smoke and Pyrotechnics, and Exploding Ordnance Tests LOI Number 101 104 106 107 108 109 301 304 Revision Number 3 3 3 4 3 3 1 1 Revision Date 02 February 2005 02 February 2005 24 October 2005 02 February 2005 02 February 2005 02 February 2005 02 February 2005 02 February 2005 Test Cliamber ODOBi ODOBi ODOBi ODOBi ODOBi ODOBi ODOBi ODOBi Title TSP Sampling and Analysis Procedure VOCs and Tracer Compounds Sampling and Analysis Procedure CEM Sampling and Analysis Procedure Particulate Metals Sampling and Analysis Procedure HC1/C12/NH3 Sampling and Analysis Procedure Carbonyls Sampling and Analysis Procedure SVOCs & Dioxins/Furans Sampling and Analysis Procedure PM2.5/PM10 Sampling and Analysis Procedure using Cyclones Responsible Organization | URS URS URS URS URS URS URS URS OEM = Continuous Emission Monitor Cl2= Chlorine HCl = Hydrogen Chloride HCN = Hydrogen Cyanide NH3 = ammonia ODOBi = Open Detonation Open Bum-improved PM:5 = Particulate Matter < 2.5 microns PMIO = Particulate Matter < 10 microns SVOC = Semivolatile Organic Compound TSP = Total Suspended Parliculale Matter URS = sampling and analysis contractor (formerly Radian Int.) voc = Volatile Organic Compound Final Table 4-1 Sample Preservations and Holding Time Requirements Metals Perchlorates HCl/Cl2/NH3(„ HCN SVOCs VOCs Dioxins/furans Carbonyls Tracer Compound Preservation None None 4°C for acid samples None 4°C None 4°C None None Holding time Mercury - 28 days. All others- 180days. 28 days. Analyze acid samples within 14 days Analyze alkali samples within 28 days 14 days. Extract within 14 days; analyze within 40 days following extraction. 30 days. Extract within 14 days; analyze within 40 days following extraction. Extract within 14 days; analyze within 30 days following 1 extraction. 30 days. (1) Sodium thiosulfate will be added as a preservative for CI2 Cl2= Chlorine HCl - hydrogen chloride HCN = Hydrogen cyanide NH3 = Ammonia SVOC = semivolatile organic compound VOC = volatile organic compound AppendixA Lists Of Analytes Final AppendixA Lists of Anaiytes Table A.l. VOC Target Analyte List (EPA Compendium Method TO-14). VOCs 1 1,1,1-Trichloroethane 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene 1,2,3-Trimethylbenzene 1,2,4-Trichlorobenzene 1,2,4-Trimethylbenzene 1,2-Dibromoethane (EDB) 1,2-Dichlorobenzene 1,2-Dichloroethane 1,2-Dichloropropane 1,3,5-Trimethylbenzene 1,3-Butadiene 1,3-Dichlorobenzene 1,3-Diethylbenzene 1.4-Dichlorobenzene 1,4-Diethylbenzene 1,4-Dioxane 1-Butene 1-Hexene 1 1-Pentene 2,2-Dimethylbutane 2,3,4-Trimethylpentane 2,3-Dimethylbutane 2,3-Dimethylpentane 2,4-Dimethylpentane 2-Butanone (Methyl Ethyl Ketone) 2-Ethyltoluene 2-Hexanone 2-Methylheptane 2-Methylhexane 2-Methylpentane 2-Nitropropane 2-Propanol 3-Chloropropene 3-Ethyltoluene 3-Methylheptane 3-Methylhexane 3-Methylpentane 4-Ethyltoluene 4-Methyl-2-pentanone Acetone Acetonitrile Acetylene Acrylonitrile alpha-Chlorotoluene Benzene Bromodichloromethane Bromoform Bromomethane Butane Carbon Disulflde Carbon Tetrachloride Chloroacetonitrile Chlorobenzene Chloroethane Chloroform Chloromethane cis-1,2-Dichloroethene cis-1,3-Dichloropropene cis-2-Butene cis-2-Pentene Cumene Cyclohexane Cyclopentane Decane Dibromochloromethane Ethane Ethanol Ethene Ethyl Benzene Ethyl Ether Ethyl Methacrylate Freon 11 Freon 113 Freon 114 Freon 12 Heptane Hexachlorobutadiene Hexane Isobutane Isopentane Isoprene m,p-XyIene Methacrylonitrile Methyl Acrylate Methyl Methacrylate Methyl tert-butyl ether Methylcyclohexane Methylcyclopentane Methylene Chloride n-Butylchloride Nitrobenzene Nonane Octane o-Xylene Pentane Propane Propylbenzene Propylbenzene Propylene Styrene Tetrachloroethene Tetrahydrofuran TNMHC" Toluene trans-1,2- Dichloroethene trans-1,3- Dichloropropene trans-2-butene trans-2-Pentene Trichloroethene Undecane Vinyl Acetate Vinyl Chloride Vinyl Chloride "Total nonmethane hydrocarbon. UKSC:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSNTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ A" 1 Final AppendixA Lists of Anaiytes Table A.2. SVOC Target Analyte List (EPA SW-846 Method 8270). 1,2,4,5- Tetrachlorobenzene 1,2,4-Trichlorobenzene 1,2-Dichlorobenzene 1,2-Diphenylhydrazine 1,3,5-Trinitrobenzene 1,3-Dichlorobenzene 1,3-Dinitrobenzene 1,4-Dichlorobenzene 1-Chloronaphthalene 1-Naphthylamine 2,3,4,6- Tetrachlorophenol 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol 2,4-Dichlorophenol 2,4-Dimethylphenol 2,4-Dinitrophenol 2,4-Dinitrotoluene 2,6-Dichlorophenol 2,6-Dinitrotoluene 2-Acetylaminofluorene 2-Chloronaphthalene 2-ChIorophenol 2-Methylnaphthalene 2-Methylphenol 2-Naphthylamine 2-Nitroaniline 2-Nitrophenol 3,3'-Dichlorobenzidine 3,3'-Dimethylbenzidine SVOCs 3-Methylcholanthrene 3-Methylphenol & 4- Methylphenol 3-Nitroaniline 4,6-Dinitro-2-methylphenol 4-Aminobiphenyl 4-Bromophenyl phenyl ether 4-Chloro-3-methylphenol 4-Chloroaniline 4-Chlorophenyl phenyl ether 4-Nitroaniline 4-Nitrophenol 7,12- Dimethylbenz(a)anthracene Acenaphthene Acenaphthylene Acetophenone Aniline Anthracene Benz(a)anthracene Benzidine Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(ghi)perylene Benzo(k)fl uoranthene Benzoic acid Benzyl alcohol bis(2-Chloroethoxy)methane bis(2-Chloroethyl) ether bis(2-Chloroisopropyl) ether bis(2-Ethylhexyl) phthalate Butyl benzyl phthalate Carbazole Chrysene Dibenz(a,h)anthracene Dibenzofuran Diethyl phthalate Dimethyl phthalate Di-n-butyl phthalate Di-n-octyl phthalate Dinoseb Diphenylamine Ethyl methanesulfonate Fluoranthene Fluorene Hexach lorobenzene Hexachlorobutadiene Hexachloroethane Hex ach loropropene Indeno( 1,2,3-cd)pyrene Isophorone Isosafrole Methyl methanesulfonate Naphthalene Nitrobenzene N-Nitro-o-toluidine N-Nitrosodiethylamine N-Nitrosodimethylamine N-Nitrosodi-n-butylamine N-Nitrosodi-n-propylamine N-Nitrosodiphenylamine N-Nitrosomethylethylamine N-Nitrosomorpholine N-Nitrosopiperidine N-Nitrosopyrrolidine o-Toluidine Pentachlorobenzene Pentachloroethane Pentachloronitrobenzene Pentachlorophenol Phenacetin Phenanthrene Phenol Pyrene Pyridine Safrole URS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSVTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ A-2 Final AppendixA Lists of Analytes Table A.3. Carbonyls Target Analyte List (EPA Compendium Method TO-11 A). Carbonyls 2,5-Dimethylbenzaldehyde Acetaldehyde Acetone Benzaldehyde Crotonaldehyde Formaldehyde Hexanal Isopentanal M,p-Tolualdehyde MEK/Butyraldehydes o-Tolualdehyde Pentanal Propanal Table A.4. Metals Target Analyte List (EPA Method 29). Metals Aluminum Antimony Arsenic Barium Beryllium Cadmium Chromium Cobalt Copper Lead Magnesium Manganese Mercury Nickel Phosphorus Selenium Silver Thallium Zinc Table A.S. Dioxins/Furans Target Analyte List (EPA SW-846 Method 8290). Dioxins 2,3,7,8-Tetrachlorodibenzo- p-dioxin (TCDD) 1,2,3,7,8,9- Hexachlorodibenzo-p-dioxin (HxCDD) 1,2,3,7,8- Pentachlorodibenzo-p-dioxin (PeCDD) 1,2,3,4,6,7,8- Heptachlorod i benzo-p- dioxin (HpCDD) 1,2,3,4,7,8- Hexachlorodibenzo-p-dioxin (HxCDD) 1,2,3.4,6,7,8,9- Octachlorodibenzo-p-dioxin (OCDD) 1,2,3,6,7,8- Hexach lorodi benzo-p- dioxin (HxCDD) Furans | 2,3,7,8- Tetrachlorodibenzofuran (TCDF) 1,2,3,6,7,8- Hexachlorodibenzofuran (HxCDF) 1,2,3,4,7,8,9- Heptachlorodibenzofuran (HpCDF) 1,2,3,7,8- Pentachlorodibenzofuran (PeCDF) 2,3,4,6,7,8- Hexachlorodibenzofuran (HxCDF) 1,2,3,4,6,7,8,9- Octachlorodibenzofuran (OCDF) 2,3,4,7,8- Pentachlorodibenzofuran (PeCDF) 1,2,3,7,8,9- Hexachlorodibenzofuran (HxCDF) 1,2,3,4,7,8- Hexachlorodibenzofuran (HxCDF) 1,2,3,4,6,7,8- Heptachlorodibenzofuran (HpCDF) UICO C:\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ A-3 Final AppendixA Lists of Analytes Table A.6 Other Target Compounds Other Target Compounds Ammonia Hydrogen Chloride Particulate Matter (TSP, PM,o,PM2.5) Chlorine CEM gases (CO2, CO, SO2, and NOx) Perchlorate | Hydrogen cyanide CEM = continuous emission monitor CO = carbon monoxide CO, = carbon dioxide NO, = nitrogen oxides PM25 = particulate matter smaller than 2.5 microns PMio = particulate matter smaller than 10 microns SO2 = sulfur dioxide TSP = total suspended paniculate matter mC«*C.\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGS\TEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ A-4 Appendix B Listing of the Letters Of Instruction Final Appendix B Letters Of Instruction Table B.l. Listing of LOIs for Smoke and Pyrotechnics, and Exploding Ordnance Tests. » EOS "Nii'mberj*' ..•'•.^''•tiffiiy(i,|l;_s^H^;^lif ;Number-j P^^ponsil>lei EOrganization?!; 101 02 February 2005 Smoke Chamber, BANGBOX™ or ODOBi TSP Sampling and Analysis Procedure URS 104 02 February 2005 Smoke Chamber, BANGBOX™ or ODOBi VOCs and Tracer Compounds Sampling and Analysis Procedure URS 106 24 October 2005 Smoke Chamber, BANGBOX™ or ODOBi CEM Sampling and Analysis Procedure URS 107 02 February 2005 Smoke Chamber, BANGBOX™ or ODOBi Particulate Metals Sampling and Analysis Procedure URS 108 02 February 2005 Smoke Chamber, BANGBOX™ or ODOBi HCI/CI2/NH3 Sampling and Analysis Procedure URS 109 02 February 2005 Smoke Chamber, BANGBOX™ or ODOBi Carbonyls Sampling and Analysis Procedure URS 301 02 February 2005 Smoke Chamber, or ODOBi SVOC, Dioxins/Furans, Sampling and Analysis Procedure URS 304 02 February 2005' Smoke Chamber, or ODOBi PM2.5/PM10 Sampling and Analysis Procedure using Cyclones URS 305 02 February 2005 Smoke Chamber BANGBOX™, or ODOBi Perchlorates Sampling and Analysis Procedure URS 306 23 March 2006 Smoke Chamber or ODOBi Energetics Sampling and Analysis Procedure (Alternate) URS 307 23 March 2006 Smoke Chamber BANGBOX™, or ODOBi Hydrogen Cyanide (HCN) Sampling and Analysis Procedure (Alternate) URS (1) A complete copy ofthe LOIs can be found in the Detailed Test Plan for Phase IX Emission Characterization of Smoke/Pyrotechnics and Propellants, May 2006 CEM - Continuous Emission Monitor PM2.5 = Particulate Matter < 2.5 microns ^JICM C.\D0CUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSNTEMPORARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ B-l Final Appendix B Letters Of Instruction CI2 = Chlorine PMio = Particulate Matter < 10 microns HCl = Hydrogen Chloride SVOC = Semivolatile Organic Compound HCN = Hydrogen Cyanide TSP - Total Suspended Particulate Matter LOI = letter of instruction URS = sampling and analysis contractor (formerly Radian Int.) NH3 = ammonia VOC = Volatile Organic Compound ODOBi = open detonation/open burn- improved UKS C:\DOCUMENTS AND SETTINGS\PALMEBG\LOCAL SETTINGSNTEMPGRARY INTERNET FILES\OLK860\QAPP_FINAL_07132006.DOC\24-JUL-06\\ B-2 Summary Page 1 of 3 LIOIA Search Learning Disabilities AssoclaUbn cHAmatoa Find It Fast Le:irnlng Disabilities Association :.„-» AnniJalLGonrerenco V- • •I.:. ...-• • '.cjas«SM[^ats!t?*E:r_..#:...: [fi'^-'State-Ghaptm^-li ll.x,. • J - .: .:;.W,.»VM, fjMMfA.:!.^?^... 39 "4^Research-jnm»iiini»!T??j 'E:^ Bpokstorei:"^ .•sis: ..•.v.iaE!;*..:.-,.iiiS:ffi. i^f- •,-gai'?j?tta!iaiiiL'3fea: /?ri Summary In recent years, a problem-solving approach referred to as responsiveness to intervention (RTI) has received increased attention as a process of remedial interventions that can help generate data to guide instruction and identify students with learning disabilities (LD) who may require special education and related services. Core concepts include the systematic (1) application of scientific, research-based interventions in general education; (2) measurement of student responses to the interventions; and (3) use of the response data to change the intensity or type of subsequent intervention. Historically, RTI refines earlier initiatives such as prereferral intervention and teacher assistance teams. Recent interest in RTI has emerged from concern about the inadequacies of the ability-achievement discrepancy criterion for identifying LD, the need to reduce referrals to special education by using well-designed instruction and intensified interventions in general education, and the recent NICHD- coordinated research on early reading difficulties indicating that early intervention could significantly reduce reading problems in students. IDEA 2004 now includes language permitting the use of data from a process that determines if the child responds to scientific, research-based intervention as part of the evaluation procedures as an alternative criterion to the ability-achievement discrepancy. In addition, up to 15% of Part B funds can be used for "early intervening services... [for those needing] additional academic and behavioral support..." Although there is no universal RTI model, it is generally understood to include multiple tiers that provide a sequence of programs and services for students showing academic difficulties. Briefly, Tier 1 provides high-quality instruction and behavioral supports in general education. Tier 2 provides more specialized instruction for students whose performance and rate of progress lag behind classroom peers, and Tier 3 provides comprehensive evaluation by a multidisciplinary team to determine ifthe student has a disability and is eligible for special education and related services. Although parent participation is widely recognized as essential to improving educational outcomes for students, many parents express concern about whether ongoing, meaningful involvement will occur in an RTI model. How will they be included in state and local planning? Involved in all phases ofan RTI process? Informed of their referral rights? Will their child's education depend more on their own knowledge and initiative than on school efforts? Certainly, positive parent- school partnerships will depend on commitment by both home and education professionals. Potential benefits cited by RTI proponents include (1) earlier identification of students with LD using a problem-solving approach rather than an ability- achievement discrepancy formula with the expectation of minimizing "wait to http://www.ldaamerica.org/news/rti-summary.asp 8/28/2006 Summary Page 2 of 3 fail," (2) reduction in the number of students referred for special education, (3) reduction in the overidentification of minority students, (4) data that are maximally relevant to instruction, (5) focus on student outcomes with increased accountability, and (6) promotion of shared responsibility and collaboration. While RTI seems to encourage addressing the needs of students at risk, the use of RTI for eligibility purposes has raised questions about whether RTI is prone to systemic errors in identifying students with LD. For example, some high-ability students with intellectual strengths and support may achieve in the normal range and be denied the individualized instruction enabling them to make academic progress consistent with their ability. Although it is generally agreed that RTI can identify a pool of at-risk students, it does not appear to be sufficient to identify a specific learning disability. It may, however, serve as an important component of an evaluation for special education eligibility. Research data from large-scale implementation of RTI are needed to determine the efficacy of RTI for differentiating a specific learning disability from other disabilities and students without disabilities. Before implementation of an RTI approach, many issues about the structure and components to be used, as well as how students will move through the process, must be addressed and efficacy research conducted. In selecting the number of tiers and instructional options, and timelines to be used, models will vary along a flexibility-rigidity continuum. The result will affect such factors as degree of individualization, cost of staff resources, and likelihood of replication. Factors that affect movement within and between tiers, such as cut scores, timelines for team decision-making, and where interventions are provided must also be resolved so that access to services is maximized and delay of services, including special education, is avoided. Ensuring availability of needed resources is also an important step prior to implementation. What space and materials will be required? How will student and teacher schedules be affected? What time must be allowed for phase-in and professional development? How will the impact of increased documentation requirements be minimized? Especially unclear is the answer to the question of whether costs will increase or decrease and by how much. Although NJCLD has long been concerned about professional preparation, RTI approaches will require new or changed roles for administrators, general education and special education teachers, and related services personnel. Questions arise about how needed professional development will be determined, provided, and followed-up. What are the specific competencies required to provide high quality scientific, research-based interventions, continuous progress monitoring, and timely recognition of nonresponsiveness in general education? What types of field experience and mentoring are most helpful to novice and practicing teachers? How will collaborative skills be fostered within the culture ofthe school? Once vital competencies are determined, the question of what documentation can ensure that those competencies are actually in the repertoire of professionals must be asked. Does state licensure address the needed competencies or are alternate certification. Board certification, or other formal documentation of competence useful? A related, and growing, personnel problem is the difficulty recruiting and retaining highly qualified teachers, especially when career ladders have not proved effective and advanced certification often results in teachers moving out of the classroom. It is not yet known whether the new responsibilities of RTI will motivate teachers to stay in classrooms. Research on RTI has primarily focused on intervention studies that investigate the http://www.ldaamerica.org/news/rti-summary.asp 8/28/2006 Summary Page 3 of 3 delivery and efficacy of instructional methods and materials or on field studies that explore the instructional components that might be incorporated into an RTI approach. Intervention studies, many of which have been conducted by the NICHD, formed the basis for the provision in IDEA 2004 that permits "use of a process that determines if the child responds to scientific, research-based intervention as part of the evaluation procedures" for identifying LD. Focusing on early skills in decoding, these studies have shown that many evidence-based early reading programs are equally effective, if instruction is focused, uses small groups, ensures high response rates, includes immediate feedback, and follows a sequential mastery of topics. Field studies of RTI have explored the actual practices applied in problem-solving approaches using either standard protocols or individualized interventions. Although existing studies have found changes in the way support services were used and identified a lower proportion of minority students as having LD, many key questions have not yet been addressed. These include student success rates over time and the numbers of children beyond third grade receiving continued interventions or returning to general education, as well as the effects of various criteria for adequate response to intervention and achievement norms or benchmarks based on classroom, local, or state criteria on eligibility for tiers or for special education and related services. Of special interest is the work of the National Research Center on Learning Disabilities, which is seeking to identify and study medium- and large-scale RTI sites that use best practice and meet criteria enabling replication. Using these as pilot sites, the goal is to recognize RTI models that demonstrate improved achievement in students with and without disabilities beyond the primary years and assist others in adopting such proven models. While the need for such research and evaluation is pressing, it is also an enormously complex undertaking. Large-scale implementation of RTI will vary widely depending on factors such as the selection and fidelity of interventions, tiers, resources, timelines, and professional development. Careful reporting of such variables and adherence to established research standards will be critical to shaping RTI models that successfully inform and enhance instruction. The National Joint Committee on Learning Disabilities intends that this paper will encourage study and consideration ofthe information, issues, and research related to RTI in order to guide its thoughtful implementation, advance the field of special education, and enhance the academic outcomes and life success of all students, including students with learning disabilities. NOTE: This document was approved by the National Joint Committee on Learning Disabilities (NJCLD) as an official paper of the NJCLD in June 2005 Top L3 Print this paga (^ Share this Daae This page is Bobby Approved. Hprne | Contact Us | Linl< To. y.s | Disclaimer | P.riyacy Pol.i.cy I Donate Learning Disabilities Association of © 2005 LDA of America America 4155 Library Road Pittsburgh, PA 15234-1349 Phone (412) 341-1515 Fax (412) 344- 0224 http://www.ldaamerica.org/news/rti-summary.asp 8/28/2006