DERR-2025-008674

WASATCH ENVIRONMENTAL, INC.
ENVIRONMENTAL SCIENCE AND ENGINEERING

2410 WEST CALIFORNIA AVENUE
SALT LAKE CITY, UTAH 84104
PHONE [phone]
e-mail: [e-mail]
www.wasatch-environmental.com

REVISED QUALITY ASSURANCE PROJECT PLAN
1300 SOUTH SLC PROPERTY
1215 SOUTH 400 WEST, 1225 SOUTH 400 WEST, AND
390 WEST 1300 SOUTH
SALT LAKE CITY, UTAH
VOLUNTARY CLEANUP PROGRAM SITE #C140

Project No. 2779-003C

Prepared for:

Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Voluntary Cleanup Program
Mr. Bill Rees, Section Manager
195 North 1950 West
Salt Lake City, Utah 84114

Prepared by:

Wasatch Environmental, Inc.
2410 West California Ave.
Salt Lake City, Utah 84104

October 29, 2025
Revised Quality Assurance Project Plan 1300 South SLC Property - Project No.: 2779-003C
Wasatch Environmental, Inc. Table of Contents
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TABLE OF CONTENTS

Section Page No.
1. INTRODUCTION .............................................................................................................................. 1
2. BACKGROUND ............................................................................................................................... 1
3. QUALITY ASSURANCE/QUALITY CONTROL ............................................................................... 2
4. PROJECT ORGANIZATION AND RESPONSIBILITIES ................................................................. 2
4.1 VCP/Utah Division of Environmental Response and Remediation (DERR) Project
Manager ........................................................................................................................................... 2
4.2 Project Manager .................................................................................................................. 2
4.3 Field Staff ............................................................................................................................ 3
4.4 Health and Safety Manager ................................................................................................ 3
4.5 Laboratory QA Manager ..................................................................................................... 3
4.6 Third-Party Data Validator .................................................................................................. 3
5. DATA GENERATION/ACQUISITION OBJECTIVE ......................................................................... 3
6. DATA QUALITY PARAMETERS AND OBJECTIVES ..................................................................... 4
6.1 Precision ............................................................................................................................. 4
6.1.1 Field Data Precision ............................................................................................... 4
6.1.2 Laboratory Data Precision ..................................................................................... 4
6.2 Accuracy ............................................................................................................................. 4
6.2.1 Field Data Accuracy ............................................................................................... 4
6.2.2 Laboratory Data Accuracy ..................................................................................... 5
6.3 Representativeness ............................................................................................................ 5
6.3.1 Field Data Representativeness .............................................................................. 5
6.3.2 Laboratory Data Representativeness .................................................................... 5
6.4 Completeness ..................................................................................................................... 5
6.4.1 Field Data Completeness ....................................................................................... 5
6.4.2 Laboratory Data Completeness ............................................................................. 5
6.5 Comparability ...................................................................................................................... 6
6.5.1 Field Data Comparability ........................................................................................ 6
6.5.2 Laboratory Data Comparability .............................................................................. 6
6.6 Sensitivity ............................................................................................................................ 6
6.7 Data Quality Objectives (DQOs) ......................................................................................... 6
7. QA/QC PROCEDURES ................................................................................................................... 7
7.1 Field QA/QC ........................................................................................................................ 8
7.1.1 Matrix Spike (MS)/Matrix Spike Duplicate (MSD) .................................................. 8
7.1.2 Field Duplicate ....................................................................................................... 8
7.1.3 Equipment Blank .................................................................................................... 8
7.1.4 Trip Blank ............................................................................................................... 8
7.1.5 Split Samples ......................................................................................................... 8
7.1.6 Field Quality Control Checks ................................................................................. 9
7.1.7 Field Chain-of-Custody (COC) Procedures ........................................................... 9
7.1.8 Field Logbook Records ........................................................................................ 10
7.1.9 Sample Labeling .................................................................................................. 11
7.1.10 Sample Handling and Transport .......................................................................... 11
7.1.11 Field Maintenance ................................................................................................ 11
7.2 Laboratory QA/QC Procedures ......................................................................................... 11
7.2.1 Laboratory QC Reporting Packages .................................................................... 11
7.2.2 Laboratory QC Checks ........................................................................................ 12
7.2.3 Laboratory Custody Procedures .......................................................................... 12
7.2.4 Laboratory Preventative Maintenance ................................................................. 13
7.2.5 Laboratory Equipment Maintenance .................................................................... 13
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8. DATA REDUCTION, VALIDATION, AND REPORTING ............................................................... 13
8.1 Data Reduction ................................................................................................................. 13
8.1.1 Field Data Reduction ........................................................................................... 13
8.1.2 Laboratory Data Reduction .................................................................................. 13
8.2 Data Validation .................................................................................................................. 14
8.2.1 Procedures Used to Validate Field Data .............................................................. 14
8.2.2 Procedures Used to Validate Laboratory Data .................................................... 14
8.3 Data Reporting .................................................................................................................. 15
8.3.1 Field Data Reporting ............................................................................................ 15
8.3.2 Laboratory Data Reporting ................................................................................... 16
8.3.3 Document and Data Retention ............................................................................. 16
9. SPECIFIC PROCEDURES USED TO ASSESS DATA PRECISION, ACCURACY,
COMPLETENESS, COMPARABILITY, AND SENSITIVITY ......................................................... 16
9.1 Precision Assessment ....................................................................................................... 17
9.2 Accuracy Assessment ....................................................................................................... 17
9.3 Representativeness Assessment ...................................................................................... 17
9.4 Completeness Assessment .............................................................................................. 18
9.5 Comparability Assessment ............................................................................................... 18
9.6 Sensitivity Assessment ..................................................................................................... 18
10. CORRECTIVE ACTION ................................................................................................................. 18
10.1 Field Corrective Action ...................................................................................................... 19
10.2 Laboratory Corrective Action ............................................................................................ 19
10.3 Corrective Action During Data Validation and Data Assessment ..................................... 20
10.4 Immediate Corrective Action ............................................................................................. 20
10.5 Long-Term Corrective Action ............................................................................................ 20
11. QUALITY ASSURANCE REPORTS TO MANAGEMENT ............................................................. 20
11.1 Contents of a Project QA Report ...................................................................................... 20
12. PERSONNEL, TRAINING, AND CERTIFICATION ....................................................................... 21
12.1 Field Sampling and Remediation Oversight Personnel .................................................... 21
12.2 Verification of Personnel Training and Certification .......................................................... 21

TABLES

Table 1 – Summary of DQOs
Table 2 – Summary of Field QC Sample Types and Quantities by Matrix

FIGURES

Figure 1 – Site Location Map
Figure 2 – Parcel Map
Figure 3 – Vicinity Property Use Map
Figure 4 – Historical Sample Location Map

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REVISED QUALITY ASSURANCE PROJECT PLAN
1300 SOUTH SLC PROPERTY
SALT LAKE CITY, UTAH
VOLUNTARY CLEANUP PROGRAM SITE #C140

1. INTRODUCTION

This Quality Assurance Project Plan (QAPP) describes the activities for collecting, handling, and
analyzing representative environmental samples at the 1300 South SLC property (Site). The Site has
been accepted into the Utah Voluntary Cleanup Program (VCP) as VCP Site #C140 to address
environmental impacts identified in the soil and groundwater at the Site.

All personnel involved with the collection and handling of environmental samples shall be required to read
this plan, and a copy of this plan will be available in the field during all sampling activities.

2. BACKGROUND

The Site is located at 1215 South 400 West, 1225 South 400 West, and 390 West 1300 South in Salt
Lake City, Utah (as shown on Figure 1). The Site consists of 0.80 acres and is developed with a single -
story 9,594-square-foot building located in the northern portion of the Site, a single-story 2,280-square-
foot building located in the central portion of the Site, and a single-story 2,400-square-foot building
located in the southern portion of the Site. The northern and central buildings are occupied by A.W. Fors
Machine & Welding Shop, a machine shop, and the southern building is occupied by W asatch Equipment
Sales and Service, a food packaging equipment service provider. The Site is comprised of four parcels
(as shown on Figure 2). The Site includes the following Salt Lake County Assessor’s Office parcel
numbers: 15-12-382-001, 15-12-382-002, 15-12-382-013, and 15-12-382-007. Current property use in
the vicinity of the Site is a mix of commercial, transportation corridors, storage yards, light industrial, and
some residential.

Property use at the Site and surrounding properties is a mix of commercial, light industrial, and limited
residential (as shown on Figure 3).

Our research indicates that the Site was vacant land with no structures as early as 1937. The current
southwestern (Wasatch Equipment) building was originally constructed in 1958 and has historically been
occupied by automotive repair shops and the current equipment service provider. The current northern
(northern A.W. Fors) building was constructed in 1975 to replace former structures (used by A.W. Fors
and Ballard Construction) in this area and has been occupied by the current machine shop since that
time. The current east-central (southern A.W. Fors) building was originally constructed in 1965 and has
been occupied by the current machine shop since that time.

Mr. Jason Martin, representative of the proposed purchaser of the Site, provided Wasatch with a May 23,
2024, Phase I Environmental Site Assessment prepared by Gordon Geotechnical Engineering, Inc.,
(Gordon Geotechnical) for the Site on behalf of Chelsea Investment Corporation.

The May 2024 Phase I Environmental Site Assessment identified the likely presence of releases to the
environment from the long-term use of the Site for automotive repair and as a machine shop as a
recognized environmental condition. Additionally, potential impacts from nearby properties identified on
the database report were identified as recognized environmental conditions in the 2024 report. Based on
the findings of the 2024 report, multiple rounds of subsurface investigations and sampling were
subsequently performed at the Site by Wasatch.

The analytical results from the subsurface investigations conducted at the Site indicated that benzene,
perfluorooctanoic acid (PFOA), and tetrachloroethene (PCE) impacts to groundwater; total recoverable
petroleum hydrocarbons (TRPH) and perfluorooctane sulfonate (PFOS) impacts to soil and groundwater;
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and PCE and trichloroethene (TCE) impacts to soil gas were discovered at the Site. PFOA and PFOS
are analytes associated with per- and poly fluoroalkyl substances (PFAS).

Given that the benzene and PFAS concentrations were higher in the groundwater samples collected
along the eastern (hydraulically upgradient) boundary of the Site relative to the benzene and PFAS
concentrations detected in the groundwater samples collected more hydraulically downgradient, it is
Wasatch’s and the Applicant’s opinion that these impacts are likely migrating onto the Site from an off -
Site source to the east and likely do not originate from an on-Site source. However, further data is
required to verify these opinions.

Given the presence of chlorinated solvent-impacted groundwater and soil gas on the Site beneath the
current structures, a vapor intrusion risk is present. Wasatch recommended the installation of vapor
mitigation systems for the current Site structures and future structures to reduce potential future health
risks to indoor occupants. If the future planned use of the Site changes, and in the event any on-Site
structures are to be demolished, Wasatch recommended an environmental professional be present at th e
Site to evaluate the soil beneath the building for impacts that could be present.

Wasatch recommended that these impacts be reported to the Utah DEQ VCP for regulatory oversight and
guidance to achieve closure of the releases that would facilitate redevelopment of the Site for residential
use. See Figure 4 for a historical sample location map.

The impacts at the Site have been reported to the Utah DEQ through submission of an application for an
Enforceable Written Assurance to the Utah VCP. As of September 17, 2025, the Site has been entered
into Utah VCP for regulatory oversight and has been assigned VCP Site #C 140.

3. QUALITY ASSURANCE/QUALITY CONTROL

Quality assurance (QA) is a management system for ensuring that all information, data, and decisions
resulting from the investigation are technically sound and properly documented. Quality control (QC) is
the functional mechanism through which quality assurance goals are achieved. All QA/QC procedures
described in this QAPP are structured in accordance with applicable technical standards, agency
requirements, regulations, and guidance. This QAPP is intended to be used in conjunction with the RAP
(to be completed in the future), individual work plans, and Sampling and Analysis Plan (SAP) prepared for
the Site. The QAPP will serve as a controlling mechanism during the performance of the environmental
sampling and analysis activities to ensure that the technical data gathered are precise, accurate,
comparable, complete, and representative of actual field conditions , and meet the minimum QA/QC
requirements for the project. The following information is presented to ensure that QA/QC procedures for
environmental sampling and analysis are performed in accordance with the data quality objectives
(DQOs) for environmental sampling and analysis at the Site.

4. PROJECT ORGANIZATION AND RESPONSIBILITIES
4.1 VCP/Utah Division of Environmental Response and Remediation (DERR) Project Manager

The VCP Project Manager is responsible for regulatory oversight of the project and regulatory review and
approval of project planning documents and reports.
4.2 Project Manager

The Project Manager is responsible for implementing the project and has the authority to commit the
resources necessary to meet project objectives and requirements. The Project Manager's primary
function is to ensure that technical, financial, and schedul ing objectives are achieved successfully. The
Project Manager will serve as primary point of contact and control for all matters concerning the project.
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The Project Manager will:

• Define project objectives;
• Establish project policy and procedures to address the specific needs of the project
as a whole;
• Acquire and apply resources as needed to ensure performance within budget and
schedule constraints;
• Review the work performed on each task to ensure its quality, responsiveness, and
timeliness;
• Review and analyze overall task performance with respect to planned requirements
and authorization;
• Approve all reports prior to their submission to agency representatives ;
• Ultimately be responsible for the preparation and quality of interim and final report ;
and
• Represent the project team at meetings and public hearings.
4.3 Field Staff

The Field Staff includes technicians, geologists, hydrogeologists, and environmental scientists reporting
to, and working under the direction of, the Project Manager. The Field Staff are responsible for the
execution of the field work and direct oversight of subcontractors performing field tasks such as drilling.
The Field Staff are responsible for completing field work in accordance with the RAP, SAP, QAPP, Site-
Specific Health and Safety Plan, and work plans.
4.4 Health and Safety Manager

The project Health and Safety Manager will be responsible for the development of the Site -Specific
Health and Safety Plan and related training of Field Staff. The Health and Safety Manager is also
responsible for ensuring that health and safety procedures are understood and followed by all Field Staff
and for reporting and correcting any violations of policy or regulation.
4.5 Laboratory QA Manager

The Laboratory QA Manager is responsible for validation of all laboratory analytical data before
submission of the data to the Project Manager.
4.6 Third-Party Data Validator

The Third-Party Data Validator is responsible for validation of all laboratory analytical data, with respect to
the stated data quality objectives and parameters, prior to use of the data in final reports.

5. DATA GENERATION/ACQUISITION OBJECTIVE

The data generation and acquisition objective of this project is to generate and acquire data in sufficient
quantity and of sufficient quality to complete Site characterization so that appropriate remedial
alternatives may be selected and implemented, and so that the results of the remediation and mitigation
efforts can be verified through confirmation sampling. Wasatch will compare future soil data to applicable
United States Environmental Protection Agency (U.S. EPA) Regional Screening Levels (RSLs) for
Residential and Commercial Soil and the Utah Initial Screening Levels (ISLs), where applicable. Wasatch
will compare future groundwater data to applicable U.S. EPA Maximum Contaminant Levels (MCLs) and
the Utah ISLs (where applicable). Wasatch will compare future soil gas data (if required) to applicable
U.S. EPA Vapor Intrusion Screening Levels (VISLs) for Residential Target Sub-Slab and Near-Source
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Soil Gas Concentrations (TSSGCs). Wasatch will compare future indoor air data (if required) to
applicable U.S. EPA RSLs for Residential and Commercial Air.

6. DATA QUALITY PARAMETERS AND OBJECTIVES

The overall QA/QC objective for this project is to develop and implement procedures for field sampling,
chain-of-custody (COC), laboratory analyses, and reporting that will provide results which are valid and
legally defensible in a court of law. The purpose of implementing these procedures is to assess the data
obtained with respect to the data quality parameters of precision, representativeness, accuracy,
completeness, and comparability for both the laboratory analytical program and field sample collection
activities. The primary goal of the program is to ensure that the data generated are representative of
environmental conditions at the Site. To achieve this goal, a combination of quantitative procedures and
qualitative evaluations will be used to assess the data quality. Precision, accuracy, representativeness,
completeness, comparability, and sensitivity (PARCCS) will be computed in the manner described in the
following paragraphs. A qualitative assessment of PARCCS parameters will be made documented.
Additionally, Wasatch will work to identify and mitigate field and analytical laboratory bias.

6.1 Precision

Precision is a measure of mutual agreement among individual measurements of the same Site, usually
under prescribed similar conditions, and typically expressed in terms of the standard deviation or relative
percent difference (RPD).

6.1.1 Field Data Precision

Field precision will be assessed through the collection and analysis of field duplicates and
comparing the analytical results of the field duplicates to the analytical results of the
environmental samples.

6.1.2 Laboratory Data Precision

Laboratory precision will be assessed through the calculation of RPD and/or relative standard
deviations (RSD) for duplicate samples. Analytical precision will be measured by comparing
analytical results for matrix spike (MS) and matrix spike duplicate (MSD) samples and internal
laboratory samples that may be analyzed according to analytical method or laboratory standard
operating procedure requirements. Acceptance criteria for analytical precision will be based on
established laboratory quality control limits for individual analytes. Applicable control limits are
based on statistically valid historical data compiled by the laboratory which meet or exceed
precision requirements specified by the analytical method. Standard operating procedures are on
file with the selected project laboratory.

6.2 Accuracy

Accuracy is the degree of agreement of a measurement with an accepted reference or true value. The
accuracy of the analytical data will be assessed by examining possible sources of error that may bias the
analytical results.

6.2.1 Field Data Accuracy

Sources of the errors in the field can occur during sampling (i.e., cross-contamination from
sampling equipment, etc.), field handling, and transportation. Accuracy in the field will be
assessed by documenting adherence to standard operating procedures for sample collection,
preservation, and handling, and through preparation and analysis of trip blanks and equipment
blanks.

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6.2.2 Laboratory Data Accuracy

Sources of errors in the laboratory can occur during sample preparation and analysis, duplicate
and control sample preparation, and due to instrument and quantification errors. Laboratory
accuracy is assessed through the analysis of standard reference materials (SRMs) in laboratory
control samples, MSs, MSDs, and surrogate compounds and the determination of their recoveries
in terms of percentage. Control limits are established by the laboratory for each analyte based on
statistically valid historical recovery results, which meet or exceed the requirements specified by
the analytical method. In addition, the project laboratory will analyze method blanks to determine
the potential for contamination introduced at any stage of sample preparation or analysis.
Laboratory control limits and frequency for spike recovery and method blank analysis are
specified in standard operating procedures for each analytical method, which are on file with the
selected project laboratory.

6.3 Representativeness

Representativeness is a qualitative parameter that expresses the degree to which sample data accurately
and precisely represent a characteristic of a population, parameter variations at a sampling point, or an
environmental condition. As such, representativeness requires the selection of appropriate analytical
methods, sampling protocols, and sampling locations such that results are representative of the media
being sampled and conditions being measured.

6.3.1 Field Data Representativeness

Representativeness is dependent upon the proper design of the sampling program and will be
satisfied by ensuring that the SAP, and the specific procedures contained therein, is followed.

6.3.2 Laboratory Data Representativeness

Representativeness in the laboratory is ensured by carefully following standard laboratory
analytical methods and procedures, meeting sample holding times, specifying detection limits that
are at or below regulatory standards, and analyzing method blanks to check for laboratory
contamination. Sample results will not be considered representative if contaminants are detected
in the method blanks, or if the reporting limits are above the specified screening levels.

6.4 Completeness

Completeness is an assessment of the number of valid measurements obtained in relation to the total
number of measurements planned for the successful achievement of the investigative objectives.
Completeness will be expressed as the percentage of valid measurements to the total number of
measurements. The closer the numbers, the more complete the measurement process.

6.4.1 Field Data Completeness

Field completeness evaluates the number of valid measurements obtained from all
measurements taken in the project. The intent of this program is to attempt to achieve a goal of
100 percent field completeness. Realizing that under normal conditions this goal may not be
achievable, the field completeness goal for this program is 90 percent. This completeness goal is
considered adequate to meet the DQOs for this Site based on prior consideration of PARCC
parameters, the sampling plan designs, and data collection activities proposed for each medium.

6.4.2 Laboratory Data Completeness

Laboratory completeness evaluates the number of valid measurements obtained from all the
measurements taken in the project. The intent of this program is to attempt to achieve a goal of
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100 percent laboratory completeness. Realizing that under normal conditions this goal may not
be achievable, the laboratory completeness goal for this program is 90 percent.

6.5 Comparability

Comparability is a qualitative parameter expressing the confidence with which one data set may be
compared to another. Data sets will be compared only when precision and accuracy meet the specified
acceptance criteria established in this section. Samples will be collected, and analytical results will be
reported according to standard procedures and methods to ensure comparability with other similar data
and results. The comparability goal will be achieved by following the SAP and the RAP, and the specific
procedures contained therein, and by collecting and analyzing representative samples, specifying
analysis by similar analytical procedures with comparable reporting limits and by reporting analytical
results in appropriate and consistent units.

6.5.1 Field Data Comparability

Comparability is dependent upon the proper design of the sampling program and will be satisfied
by ensuring that the SAP and RAP are followed and that proper sampling procedures are used.

6.5.2 Laboratory Data Comparability

Analytical data will be considered comparable when similar sampling and analytical methods are
used and documented. Similar QA objectives will be used throughout the project to ensure
comparability. At the discretion of the Utah DERR, split samples may be collected for submittal to
a third-party analytical laboratory to assist in evaluation of comparability. The frequency at which
split samples are collected and analyzed will be specified by the Utah DERR following the receipt
and approval of individual work plans for the project.
6.6 Sensitivity
Sensitivity is the capability of a method or instrument to discriminate between measurement response(s)
representing differing levels of the variable of interest. The analytical laboratory, as part of their standard
operating procedures, follows published, approved analytical methods which validate the methods
including an evaluation of sensitivity, precision, and accuracy to ensure that the equipment can operate
properly prior to sample analysis. Wasatch will review the laboratory detection and/or reporting limits to
verify these limits are below applicable screening levels. If sensitivity fails, Wasatch will evaluate the root
cause of the failure and correct that root cause to the extent it can be corrected (refer to Section 8.6)
6.7 Data Quality Objectives (DQOs)

DQOs are qualitative and quantitative statements that specify the quality of the data required to support
decisions made during project activities and are based on the end uses of the data to be collected. The
DQOs for samples collected for laboratory analysis are summarized in Table 1.

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Table 1
Summary of DQOs
QC Parameter DQO

Precision
Relative percent difference (RPD) of field and
laboratory duplicate (MS/MSD) samples. For
laboratory duplicates, the RPDs within established
laboratory control limits for each analyte are
acceptable. For soil and indoor air field duplicates, a
calculated RPD of 50% will be deemed acceptable.
For groundwater field duplicates, a calculated RPD of
25% will be deemed acceptable.

Accuracy
Spike recoveries from laboratory control samples
(LCSs), MS/MSDs, and surrogates within established
laboratory control limits for each analyte are
acceptable.

Representativeness
Environmental samples will be collected from locations
either reasonably believed to be, or established to be,
representative to identify source areas, evaluate the
nature of the release(s), and delineate the extent of
contamination. Standard field operating procedures will
be used, method blanks are to be free of target
analytes, sample holding times are not to be exceeded,
all samples are to be properly preserved, receiving
temperatures are not to be exceeded, 90% of all field
duplicates meet laboratory precision criteria, and
laboratory method detection limits must be below the
applicable screening levels.*

Completeness
An acceptable level of completeness will be defined as
90% of collected samples being deemed valid based
on precision, accuracy, representativeness, and
comparability acceptance criteria.

Comparability
Where feasible (where previous data exist as with
monitoring wells), analytical results for environmental
samples will be compared previous analyses for the
respective location. Measures of comparability will
include the use of standard analytical methods with
standard units of measure and consistent reporting
limits, and collection of field QC samples.

Sensitivity

Sensitivity is evaluated by the laboratory reporting
detection limit (RDL) and method detection limit (MDL).
The acceptable level of sensitivity is 100% of RDLs or
MDLs are less than performance standards.**

* The representativeness has been established requiring that 90% of all field duplicates meet the
established precision criteria and detection limits will be below applicable screening levels.
However, if sample dilution occurs because of elevated analyte concentrations, the results will not
be rejected.

** The sensitivity has been established requiring that 100% of all laboratory RDLs or MDLs meet
the established performance standards. However, if sample dilution occurs because of elevated
analyte concentrations, the results will not be rejected.

7. QA/QC PROCEDURES

QC checks will be performed for both field sampling and laboratory analysis of the environmental samples
to allow for the evaluation of data quality, documentation of data quality, and to help identify irregularities
in the field sampling or laboratory analyses that may require correction.
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7.1 Field QA/QC

A variety of QC samples will be collected to facilitate the evaluation of the data quality parameters. An
explanation of each type of field QC sample is provided below. A summary of the quantity of each QC
sample type to be collected for each environmental medium (matrix type) is presented as Table 2.
7.1.1 Matrix Spike (MS)/Matrix Spike Duplicate (MSD)

MS/MSDs are QC samples collected in the field for use by the analytical laboratory. The
MS/MSDs are selected to be representative of the environmental matrix at the Site. The
laboratory spikes the MS/MSDs with a known quantity of the analyte of interest. The MS and
MSD are then analyzed by the laboratory along with an un-spiked sample and the environmental
samples from the Site to evaluate the accuracy and precision of the analytical method for that
specific sample. One MS/MSD will be collected for each matrix (soil and groundwater samples
only) for each sample delivery group.
7.1.2 Field Duplicate

A field duplicate is a QC sample collected from the same location as an environmental sample,
and collected simultaneously, or immediately following, the collection of the environmental
sample. Field duplicates are collected, handled, and analyzed in an identical manner to the
environmental samples. The sample labeling and COC documentation will not indicate that a
sample is a field duplicate (they are blind duplicates), so the analytical laboratory is not aware
that the field duplicate is a QC sample. Field duplicates are analyzed by the laboratory along with
the environmental samples. The analytical results for the field duplicate are then compared to the
analytical results for the environmental sample as an indicator of the overall sampling and
analytical precision. One field duplicate will be collected for each matrix (soil, groundwater, and
indoor air samples only) for every 10 environmental samples for each matrix.
7.1.3 Equipment Blank

An equipment blank (also referred to as an equipment rinsate blank) is a QC sample collected by
pouring deionized water over sampling equipment after the sampling equipment has been
completely decontaminated. Equipment blanks will only be collected when non-dedicated and
non-disposable sampling equipment is used. Equipment blanks will be analyzed for the same
analytes as the environmental samples. The analytical results for the equipment blanks are used
to evaluate the adequacy of the decontamination procedures used to prevent cross-
contamination between sampling locations. One equipment blank will be collected for each
matrix (soil and groundwater only) for each sampling event (defined as work described within the
associated work plan or RAP).
7.1.4 Trip Blank

A trip blank is a QC sample prepared by the laboratory consisting of a set of sample vials filled
with deionized water. Trip blanks are transported and stored with environmental samples (soil
and groundwater samples only) that are to be analyzed for volatile organic compounds (VOCs).
Trip blanks are analyzed for VOCs only. Trip blanks are collected and analyzed to evaluat e for
cross-contamination of VOC samples due to diffusion that may occur during transport and
storage of environmental samples. One trip blank will be included in each cooler used to
transport VOC samples.
7.1.5 Split Samples

A split sample is a QC sample collected from the same location as an environmental sample, and
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collected simultaneously, or immediately following, the collection of the environmental sample.
Split samples are transported and analyzed separately (by Chem tech-Ford Laboratories) than the
environmental samples. The analytical results for the split sample are then compared to the
analytical results for the environmental sample as an indicator of the overall analytical accuracy
and precision. The Utah VCP may collect splits of soil and groundwater (if collected) samples at
their discretion.

Table 2
Summary of Field QC Sample Types and Quantities by Matrix

Environmental
Media (Matrix)
MS/MSD Field
Duplicate
Equipment
Blank
Trip Blank Split
Samples
Soil A minimum of
1 per sample
delivery group,
all analytes, or
1 per 20
environmental
samples,
whichever is
greater
1 per 10
environmental
samples, all
analytes
1 per sampling
event, all
analytes, only
if non-
dedicated
sampling
equipment is
used
1 in each
cooler
containing
VOC samples
At discretion
of DERR
Groundwater A minimum of
1 per sample
delivery group,
all analytes, or
1 per 20
environmental
samples,
whichever is
greater
1 per 10
environmental
samples, all
analytes
1 per sampling
event, all
analytes, only
if non-
dedicated
sampling
equipment is
used
1 in each
cooler
containing
VOC samples
At discretion
of DERR
Soil Gas None None None None None
Indoor Air None 1 per 10
environmental
samples,
VOCs only
None None At discretion
of DERR
7.1.6 Field Quality Control Checks

Internal QC procedures are designed to ensure and document the overall quality of data. The
QC checks represent system checks and controlled samples introduced into the sample analysis
stream that are used to validate the data and calculate the accuracy and precision of the
chemical analysis program. Field quality control will also be checked by equipment blanks and
field duplicates.
7.1.7 Field Chain-of-Custody (COC) Procedures

Custody is one of several factors which is necessary for the admissibility of environmental data as
evidence in a court of law. Custody procedures help to satisfy the two major requirements for
admissibility: relevance and authenticity. Sample custody is addressed in three parts: field
sample collection, laboratory analysis, and final evidence files. Final evidence files, including all
original laboratory reports, are maintained under document control in a secure area.
A sample or evidence file is under your custody if:

• the item is in actual possession of a person;
• the item is in the view of the person after being in actual possession of the person;
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• the item was in actual physical possession, but is locked up to prevent tampering; or
• the item is in a designated and identified secure area.

A COC form will be completed to record the custody of every sample collected for laboratory
analysis. A COC form will accompany every delivery of samples to the analytical laboratory in
order to establish the documentation necessary to trace sample possession from the time of
sample collection through sample analysis.

The sample portion of the COC form will include the following:

• project number, name, and location;
• sample identification;
• date and time of sample collection;
• sample type;
• number of containers;
• name of Project Manager, sampler, and recorder;
• sampling information (sampling area, depth, media type, type of sample, date, and
time of collection, etc.);
• analysis requested and specific analytical method;
• preservatives used, if any;
• filtering used, if any;
• signatures of persons involved in the COC possession, including dates and time; and
• condition of samples and sample bottles received by the laboratory.

When a COC form is filled out, a copy is retained for the client ’s file. The original form
accompanies the sample(s) until completion of laboratory analysis. The laboratory copies the
form and returns the original with the sample report. When the sample report is received, it is
cross-checked with the COC file record and both COC pages and the laboratory report are placed
in the client file.
7.1.8 Field Logbook Records

A field log of daily activities will be used to record sampling activities on a daily basis. This book
will be bound and have consecutively numbered pages. Entries in the field logbook will be made
in ink and will include:

• the project name/number;
• name of the author/sampling team;
• date and time of entry;
• location of activity;
• chronological record of field activities;
• names and affiliations of personnel on site;
• sample collection or measurement methods;
• number of samples collected;
• daily weather report;
• sample identification numbers;
• field observation and comments;
• sampling depth increment for field measurements;
• locations of photographs; and
• any deviations from the RAP, SAP, QAPP, or work plan.

All logbook entries will be signed, dated, and no erasures will be made. If an incorrect entry is
made, the information will be crossed out with a single strike mark, initialed, and dated by the
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sampler. Each logbook will be assigned to a specific field team member and given a project
specific project documentation number.
7.1.9 Sample Labeling

Sample labels are necessary to prevent misidentification of samples. Each label will contain
space for the following information:

• name of the site,
• sample identification,
• date and time of sample collection,
• media sampled,
• name of sampler,
• type of preservative,
• type of filtering, and
• types of analyses to be performed.
7.1.10 Sample Handling and Transport

For transport, all soil and groundwater samples will be stored on ice or dry ice (depending on the
sample type and cooling requirements) and packaged in such a manner as to prevent damage or
breakage during handling and transport to the laboratory. Samples delivered to the laboratory will
be delivered by sampling personnel. Sample containers will be labeled and placed into suitable
shipping containers. If samples are to be shipped, the shipping containers (i.e., coolers) will be
sealed with custody seals and taped closed. All sample holding times will be tracked and the
COC form will accompany the samples in a sealed plastic bag.

Custody seals will be placed on each sample cooler or container used to transport and/or store
samples that are shipped.
7.1.11 Field Maintenance

Logs or field notebooks will be used to record maintenance, service procedures and schedules
for the field equipment. All maintenance records will be documented and traceable to the specific
equipment, instruments, tools, and gauges. Any items found to be inoperable will be tak en out of
use. Records shall be reviewed and maintained by the Project Manager and field staff when
equipment, instruments, tools, and gauges are used at the site.
7.2 Laboratory QA/QC Procedures

The laboratories which will be performing analyses of environmental samples for this project are certified
by the State of Utah and/or have National Environmental Laboratory Accreditation Program (NELAP)
accreditation. The specific laboratories that will be used for the analysis of environmental samples will be
specified in the individual work plans. Each laboratory’s ability to meet the sensitivity requirements (i.e.,
detection and reporting limits) will be verified prior to using each laboratory.
7.2.1 Laboratory QC Reporting Packages

All laboratories will be required to provide Level 3 QC reporting packages (or their equivalent).
For the purposes of this QAPP, a Level 3 QC package includes:

• Analytical results,
• COC records,
• Case narratives,
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• Surrogate recoveries,
• Method blanks,
• Laboratory control samples (LCSs),
• Laboratory analysis of MS/MSDs collected from this project (not samples collected from
other projects included in the analytical batch), and
• Chromatograms for organic analyses and logbooks.
7.2.2 Laboratory QC Checks

Laboratory QC checks are accomplished through the use of system checks and QC samples that
are introduced into the same analysis stream as the environmental samples. Laboratory system
checks and QC samples for the inductively coupled plasma/mass spectrometer and gas
chromatograph/mass spectrometer are documented in the laboratory standard operating
procedures (SOPs). An example of laboratory system checks and QC samples for inorganics are
defined below.

• Calibration Blank - A volume of acidified deionized water.
• Continuing Calibration Blank - Analytical standard run every 10 analytical samples or
every two hours, whichever is more frequent, to verify the calibration of the analytical
system.
• Instrument Calibration - Analysis of analytical standards for a series of different
specified concentrations; used to define the quantitative response, linearity, and
dynamic range of the instrument to target compounds.
• Preparation Blank - An analytical control that contains deionized water and reagents,
carried through the entire analytical procedures. An aqueous method blank is treated
with the same reagents as a sample with a water matrix; a solid method blank is
treated with the same reagents as a soil sample.

Laboratory QC checks will be performed, and samples will be analyzed at a frequency
established by appropriate SW-846 and NELAP protocols for inorganics, organics, and the SOPs
for analytical methods used.
7.2.3 Laboratory Custody Procedures

Samples which are delivered by clients or received by courier are placed in locked sample control
area immediately upon delivery. Coolers containing samples are unpacked within 1 hour of
receipt or placed in the walk-in cooler until unpacked. The COC accompanying the samples will
be signed by the Sample Custodian or their designee at the time of delivery by the client, or in the
case of courier delivery, where the COC is sealed inside the cooler, at the time the samples are
unpacked.

At the time of arrival and/or unpacking, coolers will be inspected for evidence of damage. They
will be unpacked carefully, and samples will be organized on the lab bench in numerical order or
by sample sets and assigned a laboratory job number. The condition of the cooler(s) and sample
container(s) will be recorded on the COC form.

Information on the COC delivered with samples will be verified and recorded as to agreement or
non-agreement. Labels will be checked for notation of proper preservation. If there is an
apparent document non-agreement or incorrect preservation noted, the apparent problem will be
recorded, and the Project Manager notified. The samples will then be marked or labeled with
laboratory sample numbers. Laboratory project numbers are assigned serially, with each sample
numbered as a subset of the project number.

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Finally, samples will be placed in appropriate storage and/or secure areas and the location will be
noted on the Service Request Form. Samples received for VOC analysis and samples known to
be highly contaminated are stored separately.

Sample volumes, extracts, and digestates will be disposed of by the laboratory. The volumes are
typically held for 30-60 days after the release of the final report. All samples are segregated by
matrix and solvent used (if applicable), then placed in appropriate waste disposal bins for pickup.
7.2.4 Laboratory Preventative Maintenance

To minimize the occurrence of instrument failure and other system malfunction, a preventative
maintenance program for laboratory instruments will be implemented. Equipment, instruments,
tools, gauges, and other items requiring preventative maintenance will be serviced in accordance
with the manufacturer’s specified recommendations and written procedures developed by the
operators.
7.2.5 Laboratory Equipment Maintenance

The laboratory will be responsible for performing routine maintenance and will have available
tools and spare parts to conduct routine maintenance. Maintenance items that cannot be
performed by the laboratory technician will be performed by a person certified to repair the
instrument.

Manufacturer’s procedures identify the schedule for servicing critical items in order to minimize
the downtime for measurement system. It will be the responsibility of the laboratory to adhere to
this maintenance schedule and arrange any necessary and prompt service. In the absence of
any manufacturer-recommended maintenance criteria, a maintenance procedure will be
developed by the operator based upon experience and previous use of the equipment. Service to
the equipment, instruments, tools, gauges, etc., shall be performed by qualified personnel.
Records shall be reviewed, maintained, and filed by the operators at the laboratories, and will be
available upon request

8. DATA REDUCTION, VALIDATION, AND REPORTING

All data collected will be reduced, managed, distributed, and preserved in a manner which substantiates
and documents that data are of known quality. An outline of the QC data handling process for data
collection, reduction, validation, transfer, reporting, and storage for both field and laboratory data is
described below.

8.1 Data Reduction

8.1.1 Field Data Reduction

Field data collected with instruments such as pH, temperature, conductivity, specific conductivity,
dissolved oxygen, and photoionization detector (PID) are direct read devices. The direct reading
is recorded in the field logbook, or a groundwater/soil sampling form. No field data reduction is
anticipated.

8.1.2 Laboratory Data Reduction

Raw laboratory data will be recorded in a laboratory notebook along with other pertinent
information, such as the sample identification number. Other information to be recorded includes
laboratory procedure used, name of analyst, date of analysis, matrix sampled, reagent
concentrations, and instrument settings. Copies of any strip chart printouts, such as gas
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chromatograms, will be maintained on file. The laboratory QA Manager makes periodic reviews
of these notebooks prior to final data reporting. Equations to be employed in the data reduction
are those outlined in the approved method. Data from laboratory quality control samples will be
compared to the method acceptance criteria. Unacceptable data shall be appropriately qualified
on the results report.

8.2 Data Validation

Technical data, including field data and results of laboratory sample analysis, will be validated to monitor
the performance of the investigation activities. Procedures for validating field and laboratory data are
described below.

8.2.1 Procedures Used to Validate Field Data

Validation of data obtained from field measurements will be performed by the Project Manager.
Field data requiring validation includes the daily calibration of field instruments. Other field
validation procedures include a review of logbooks and proofing data entered and imported into
the computer database for transcription errors.

8.2.2 Procedures Used to Validate Laboratory Data

The Laboratory QA Manager will review all analytical data to ensure that sample results meet all
method-specified criteria.

The requirements to be checked in validation are:

• sample holding times,
• calibration,
• blanks,
• surrogate recovery,
• MS/MSDs,
• field duplicates,
• internal performance standards,
• target compound identification,
• interference check sample analysis,
• compound quantitation and reported detection limits,
• tentatively identified compounds,
• system performance,
• overall assessment of data,
• interference check sample analysis, and
• laboratory control sample analysis.

The Laboratory QA Manager will be responsible for assessing data quality and advising
appropriate laboratory section supervisors of any data that are questionable or have notations
that would caution the data user to possible unreliability.

Data reduction, validation, and reporting by the laboratory will be conducted as follows:

• Raw data produced by the analyst will be turned over to respective the supervisor.
• The supervisor will review the data for attainment of QC criteria as outlined in method
protocols and established United States Environmental Protection Agency (U.S.
EPA) Methods.
• Upon acceptance of the raw data by the supervisor, a computerized report will be
generated and sent to the QA Manager.
• The QA Manager will complete a thorough audit of all reports.
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The Laboratory QA Manager will conduct an evaluation of data reduction and reporting by the
laboratory. These evaluations will consider the finished data sheets, calculation sheets,
document control forms, blank data, duplicate data, and recovery data for matrix and surrogate
spikes. The material will be checked for legibility, completeness, and the presence of necessary
dates, initials, and signatures. The results of these checks will be assessed and reported, not ing
any discrepancies and their effect upon acceptability of the data. In addition, the Laboratory QA
Manager will check for data consistency by assessing comparability of duplicate analyses,
comparability to previous criteria, transmittal errors, and anomalously high or low parameter
values.

The following is a description of the validation steps that will be used by the third-party data
validator, if it is determined that one is needed to independently validate the laboratory data
because of irregularities with the data. If performed, these validation results will be summarized
in the final report. The validation steps are listed below:

• Compile a list of all samples;
• Compile a list of all QC samples;
• Review laboratory analytical procedures and instrument performance criteria ;
• Review of COC documents for completeness and correctness;
• Review transcription, calculation, completeness, and accuracy;
• Review of laboratory analytical procedures, appropriateness, and instrument
performance criteria;
• A data summary will be prepared and will include analytical results, media
identification, sample location and description, appropriate concentration units,
appropriate significant figures, data qualifiers, and definitions; and
• The laboratory data summary will be reviewed for potential data quality problems
including unexpected results, common laboratory contaminants, samples for which
dilution was necessary, and time and date of sample collection.

A sample data summary will be prepared to assess precision, accuracy, completeness , and
comparability of the analytical data. Laboratory records and data package requirements will be
checked to assess completeness of the data package. The validation will be performed by
personnel qualified and experienced in the field of laboratory data validation.

Despite all efforts to achieve the objectives of the project, the potential for error exists in
laboratory chemical analyses and in the data reporting process. Every reasonable effort will be
made to compare and double-check data reported from the laboratory with data entered into the
data management system.

8.3 Data Reporting

Data generated will be summarized in reports and included in the final report. The Project Manager will
develop a data storage and information system to facilitate tracking, data calculations, and transfer of
data to various forms and reports.

8.3.1 Field Data Reporting

Data reporting will be performed by the Project Manager. All data collected in the field will go
through data validation procedures and be put into a data management system in an organized
format so that intermittent and final summaries may be easily generated for data review and
project approval.

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8.3.2 Laboratory Data Reporting

The laboratories will submit the following reports to the Project Manager. The laboratory reports
will also be included in the final sampling reports. After laboratory data validation, the laboratory
will prepare reports that will include, at a minimum, the following components:

• Sample identification,
• Laboratory cross-reference numbers,
• Date of issuance,
• Analysis method numbers performed,
• Results from any analysis,
• Notation of any data qualifiers, and
• Quality control documentation.

Data validation packages are to be prepared for all samples submitted for laboratory analysis.
Sample results reported shall include:

• Summary page indicating dates of analyses for samples and laboratory QC checks;
• Cross-referencing of laboratory samples to project sample identification numbers;
• Data qualifiers to be used should be adequately described;
• Sample preparation and analytical methods; and
• QC sample results including MS/MSD RPD, MS/MSD recoveries, laboratory control
sample spike recoveries, method blank results, and surrogate recoveries.
8.3.3 Document and Data Retention

The standard document and data retention policy at Wasatch Environmental, Inc., is to retain all
laboratory data and project deliverables for 15 years in both paper and electronic storage formats.
During execution of projects, management of data and project deliverables is the responsibility of
the Project Manager. Following completion of projects, the responsibility for long-term storage of
data and deliverables shifts to an administrative assistant.

9. SPECIFIC PROCEDURES USED TO ASSESS DATA PRECISION, ACCURACY,
COMPLETENESS, COMPARABILITY, AND SENSITIVITY

This section summarizes the QA/QC procedures used in assessing the quality of the chemical data and
the format for presenting the results of the QA/QC evaluations. The data evaluation procedures will be
used by the QA Manager for assessing duplicate and s pike samples and checking blank samples that are
submitted blind to the analytical laboratories from the field or generated internally by the laboratory. The
purpose of implementing these procedures is to assess the chemical data generated with respect to the
PARCC parameters for both the laboratory analytical program and field sample collection activities.
The primary goal of the program is to ensure that the data generated are representative of environmental
conditions at the Site. To meet this goal, a combination of statistical procedures and qualitative
evaluations will be used to check the quality of data. Precision, accuracy, and completeness will be
computed in the manner described in the following paragraphs. A qualitative assessment of
representativeness and comparability will be made and will be documented. Complex statistical data
verification and a significance evaluation will not be performed. If a problem arises and the data are
found to deviate from previous analyses or surrounding conditions, the data will be annotated. Sample
recollection and analysis will be used only in extreme cases where significant QC problems are identified.

Data will be evaluated with respect to the PARCC parameters for both the field sample collection
activities and laboratory analytical programs. The QA/QC program will evaluate data based on QC
sample types discussed in Section 5. Because the QC samples are generated for analysis both in the
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field and internally by the laboratories, a system of cross -checking has been established that provides
independent evaluations of chemical data on the project level and the laboratory level.

9.1 Precision Assessment

Spiked samples are prepared by choosing a sample at random from each sample set submitted to the
laboratory, dividing the sample into equal aliquots, and then spiking each of the aliquots with a known
amount of analyte. The duplicate samples are then included in the analytical sample set. The splitting of
the sample allows the analyst to determine the precision of the preparation and analytical techniques
associated with the duplicate sample. The RPD between the spike and the duplicate spike are calculated
and plotted.

In addition, RPD will be calculated and reported for field duplicate samples.

The RPD is calculated according to the following formula:

Where:
x = First duplicate or analytical value
y = Second duplicate or analytical value

For the present program, a calculated relative percent difference that is below the control limits
established by the laboratory will be deemed acceptable.

9.2 Accuracy Assessment

In order to ensure the accuracy of the analytical procedures, an environmental sample is randomly
selected from each sample set submitted to the laboratory and spiked with a known amount of the analyte
to be evaluated. In general, a sample spike should be included in every set of 10 samples tested on each
instrument. The spike sample is then analyzed. The increase in concentration of the analyte observed in
the spiked sample, due to the addition of a known quantity of the analyte, compared to the reported value
of the same analyte in the unspiked sample determines the percent recovery. Daily control charts are
plotted for each commonly analyzed compound and recorded. The percent recovery for a spiked sample
is calculated according to the following formula:

Where:
Ms = Amount (mass) of analyte recovered from the spike sample
M = Amount (mass) of analyte recovered from the primary (non-spiked) sample
S = Known amount (mass) of analyte added to the spike sample

For the present program, control limits that have been established by the laboratory for individual spike
recovery percentages will be deemed acceptable.

9.3 Representativeness Assessment

Representativeness is a qualitative parameter that expresses the degree to which sample data accurately
and precisely represents a characteristic of a population, parameter variations at a sampling point, or an
environmental condition. The design of and r ationale for the sampling program (in terms of the purpose
for sampling, selection of sampling locations, the number of samples to be collected, the ambient
conditions for sample collection, the frequencies and timing for sampling, and the sampling techniq ues)
ensure that environmental conditions have been sufficiently represented.

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9.4 Completeness Assessment

Completeness is the ratio of the number of valid sample results to the total number of samples analyzed
with a specific matrix and/or analysis. Following completion of the analytical testing, the percent
completeness will be calculated by the following equation:

Where:
Zv = Number of valid measurements obtained
Zp = Number of measurements planned

A calculated completeness of 85% or greater will be considered acceptable.

9.5 Comparability Assessment

Comparability is a qualitative parameter expressing the confidence with which one data set may be
compared to another. Data sets will be compared only when precision and accuracy meet the specified
acceptance criteria established in this section. Samples will be collected, and analytical sample results
will be reported according to standard procedures and methods in order to be comparable with other
similar measurement data and sample results. The comparability goal will be achieved through the use of
standard procedures to collect and analyze representative samples, and by reporting analytical results in
appropriate and consistent units. Comparability will be maintained by consistency in sampling conditions,
selection of sampling procedures, sample preservation methods, analytical methods, and data reporting
units.
9.6 Sensitivity Assessment

Sensitivity is the capability of a method or instrument to discriminate between measurement response(s)
representing differing levels of the variable of interest. The analytical laboratory, as part of their standard
operating procedures, follows published, approved analytical methods which validate the methods
including an evaluation of sensitivity, precision, and accuracy to ensure that the equipment can operate
properly prior to sample analysis. Sensitivity is evaluated by the laboratory reporting detection limit
(RDL). The acceptable level of sensitivity for this project is 100% of RDLs below instrument internal
performance standards.

10. CORRECTIVE ACTION

The following procedures have been established to ensure that conditions adverse to quality, such as
malfunctions, deficiencies, deviations, and errors, are promptly investigated, documented, evaluated, and
corrected. When a significant condition adverse to quality is noted at the site, laboratory, or subcontractor
locations, the cause of the condition will be determined, and corrective action taken immediately. All
project personnel have the responsibility to promptly identify, solicit approved correctio n(s), and report
conditions adverse to quality. Conditions which warrant corrective action include:

• Predetermined acceptance standards are not attained,
• Procedures or data compiled are determined to be faulty,
• Equipment or instrumentation is found faulty,
• Samples and test results are questionably traceable,
• QA/QC requirements have been violated, and
• System and performance audits indicate problems.

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The Project Manager is ultimately responsible for field and QA/QC corrective actions. Any associate has
the authority to stop work if serious QA/QC or field-related issues arise. The Laboratory QA Manager will
be ultimately responsible for corrective actions concerning the laboratory.

10.1 Field Corrective Action

The need for corrective action will be identified as a result of field audits. If problems become apparent
that are identified as originating in the field, immediate corrective action will take place. If immediate
corrective action does not resolve the problem, appropriate personnel will be assigned to investigate and
evaluate the cause of the problem. When a corrective action is implemented, the effectiveness of the
action will be verified such that the end result is elimination of the problem.

Corrective action in the field may be needed when the sample network is changed, or sampling
procedures and field analytical procedures require modification due to unexpected conditions. In general,
any project personnel may identify the need for corrective action. The field staff will recommend the
corrective action. The Project Manager will approve the corrective measure, which will be implemented
by the field staff. It will be the responsibility of the Project Manager to verify that corrective action has
been implemented.

If the corrective action will supplement the existing sampling plan using existing and approved procedures
in the work plan, corrective action approved by the Project Manager will be documented. If a corrective
action will result in fewer samples being collected than was planned, alternate sample locations, etc.,
which may result in deviations from the DQOs; the corrective action should be reviewed and approved by
all levels of project management and the DERR Project Manager prior to implementation of the corrective
action.

Corrective action resulting from internal field audits will be implemented immediately if data may be
adversely affected due to unapproved methods or improper use of approved methods. The Project
Manager will identify deficiencies and mandate corrective action. Implementation of corrective actions will
be performed by the field staff. Corrective action will be documented in field notes and made available to
the Project Manager.

Corrective actions implemented will be documented in the field notes. No staff member will initiate
corrective action without prior communication with the Project Manager.

10.2 Laboratory Corrective Action

The need for corrective action resulting from QA audits will be initiated by the Laboratory QA Manager.
The corrective actions will be performed prior to the release of data from the laboratory. The corrective
action will be documented in the logbook and submitted to the data validator. If the corrective action does
not rectify the problem, the laboratory will contact the Project Manager. If the nonconformance causes
project objectives not to be achieved, it will be necessary to inform all levels of mana gement. Corrective
action may include, but is not limited to:

• Reanalyzing the samples, if holding time criteria permit;
• Evaluating and amending sampling and analytical procedures;
• Accepting data with an acknowledged level of uncertainty; and
• Resampling and analysis, if the completeness of the data set or intended use of the data is
recognized during a preliminary review to be insufficient to meet program DQOs.

If the above corrective actions are deemed unacceptable, an alternate laboratory will be selected to
perform necessary analyses.

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10.3 Corrective Action During Data Validation and Data Assessment

The need for corrective action during either the data validation or data assessment may be identified.
Potential types of corrective action may include resampling by the field staff or re-injection/re-analysis of
samples by the laboratory. These actions are dependent upon the ability to mobilize the field staff, and
whether the data to be collected is necessary to meet the required quality assurance objectives (e.g. the
holding time has not been exceeded, etc.). The Project Manager is responsible for identifying situations
requiring corrective action, documenting the problem, determining the course of action, and implementing
the corrective action.

10.4 Immediate Corrective Action

Any equipment and instrument malfunctions will require immediate corrective actions. The laboratory QC
charts are working tools that identify appropriate immediate corrective actions to be taken when a control
limit has been exceeded. They provide the framework for uniform actions as part of normal operating
procedures. The actions taken should be noted in field or laboratory logbooks. A detailed description of
method-specific corrective action limits is provided in the appropriate method. Any deviatio n from the
prescribed control limits must be approved in writing by the Laboratory QA Manager (for laboratory
problems) or Project Manager (for field problems).

10.5 Long-Term Corrective Action

The need for long-term corrective action may be identified by standard QC procedures, control charts,
and system audits. Any procedural or data quality problem that cannot be solved by immediate corrective
action becomes a long-term corrective action. The essential steps in a corrective action system are as
follows:

• Identification and definition of the problem,
• Investigation and determination of the cause of the problem,
• Determination and implementation of a corrective action to eliminate the problem, and
• Verification that the corrective action has eliminated the problem.

Documentation of the problem is important in corrective action. The responsible person may be a
laboratory analyst, Laboratory QA Manager, Project Manager, or field staff. The Project Manager will
verify that the corrective action has been taken, appears effective, and that the problem has been
resolved.

11. QUALITY ASSURANCE REPORTS TO MANAGEMENT

11.1 Contents of a Project QA Report

Analytical results of samples analyzed by the laboratory will be submitted to the Project Manager
following a QA/QC review by the laboratory. The results will include a tabulation of the analytical data
and an explanation of any field conditions or laboratory QA/QC problems and their effects on data quality.
Proposed corrective action will be recommended in the event that QA problems are identi fied during
review of data quality.

The final report prepared for the project will contain a discussion of QA/QC evaluations summarizing the
quality of the data collected and/or used as appropriate to each activity of the project. The objective of
the QA/QC summary will be to ensure that the data are representative of Site conditions and sufficient in
quality and quantity to support the field activities. The QA/QC summary will include:

• Tabulated results of all field and analytical data;
• A report from the Laboratory QA Manager evaluating the validity of the analytical data with
respect to accuracy, precision, completeness, and representativeness;
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• A report from the Project Manager evaluating the results of field and office audits;
• A discussion of field and laboratory QA/QC including PARCCS parameters and data
usability; and
• The laboratory’s Level 3 QC package (method blank results, surrogate recovery, laboratory
control sample results, and MS/MSD results).

A quality assurance report will be prepared by the Laboratory QA Manager upon receipt of sufficient QA
data from the laboratory. The report will be a summary of QA/QC results of the analytical work conducted
and will be included as part of the final report submitted for each data collection event.

12. PERSONNEL, TRAINING, AND CERTIFICATION

12.1 Field Sampling and Remediation Oversight Personnel

The following personnel could be utilized to complete field sampling and remediation oversight activities
at the Site during this project: Jacob Scott (Senior Field Geologist), Paxton Buboltz (Staff Geologist),
Daniel Weber (Staff Geologist), Ryan Panasy (Staff Geologist), Anna Redd (Staff Environmental
Scientist), Rachel Kubina (Staff Geologist), Blake Downey (Senior Project Hydrogeologist), Micheal
Cronin (Senior Project Geologist), and Audra Heinzel (Certified Hazardous Materials Manager and Project
Environmental Scientist).

12.2 Verification of Personnel Training and Certification

The Wasatch project manager is responsible for verifying that all field staff have been sufficiently trained
and/or certified to complete the tasks they are assigned. All field staff are required to have an up to date
40-hour/8hr Refresher OSHA HAZWOPER certification prior to working at the Site. This will be verified
by the project manager prior to sending field staff to the Site. Although it is not required, Wasatch will
require that all field staff have a current UST Groundwater and Soil Sampler certification prior to working
on the Site. Proof of certification will be housed within Wasatch’s server and available upon request.

The project manager will verify that any field staff used to complete work at the Site has sufficient
experience in the task to be performed prior to working at the Site. All field staff have been trained in-
house to complete all required tasks at the Site, prior to working at the Site. Additionally, the project
manager will review the field staff’s work history to determine what areas the field staff has been
sufficiently trained to complete through experience on other sampling or remediation job sites.

All project managers have completed numerous investigation and remediation projects over multiple
decades. Therefore, it is our opinion that the project managers involved have been sufficiently trained
and are qualified to complete this work.

The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
1300 SOUTH SLC PROPERTY WEI 2779-003C
Figure 1
Approximate Site Boundary
Lucy Ave.
Ch
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a
g
o

S
t
r
e
e
t
1300 South
I-
1
5
50
0

W
es
t
Lucy Ave.
1 inch = 516 feet Site Location Map
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 2 Parcel Map
1300 SOUTH SLC PROPERTY WEI 2779-003C
Approximate
Location of Site
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 3
1300 SOUTH SLC PROPERTY WEI 2779-003C
Vicinity Property Use Map
Approximate
Location of Site
Commercial
Commercial
Commercial
Commercial
Commercial or Industrial
Co
m
m
e
r
c
i
a
l

o
r

I
n
d
u
s
t
r
i
a
l
Commercial
Commercial or Industrial
Commercial
Residential
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
1300 SOUTH SLC PROPERTY WEI 2779-003C
Figure 4
Soil Gas Sample Location
Boring Location
LEGEND
GP-1
GP-2
GP-3
1 inch = 37 feet
Approximate Site Boundary
GP-4
GP-5
SG-5
SG-6
SG-3
SG-4
SG-1
SG-2
Lucy Ave.
1300 South
40
0

W
es
t
Floor Drain/Sump Location
Trench Floor Drain Location
Former Sealed
Floor Drain/Sump
Floor Drain/Sump
Sump Cleanout
Pizometer Location
Office
GP-8
GP-9
GP-6
GP-7
GP-16
GP-17
GP-14
GP-15
GP-12
GP-13
GP-10
GP-11
Historical Sample Location Map