QUALITY ASSURANCE PROJECT PLAN: OPERABLE · PDF fileAppendix E Record of Modification Forms . ... QA/QC quality assurance/quality control . ... Bone Piling: The stacking of black chunks,

Low-Intensity Prescribed Understory Burn ABS QAPP

Revision 0 – 5/15/15 Page 1 of 68

QUALITY ASSURANCE PROJECT PLAN:

OPERABLE UNIT 3 STUDY AREA,

LIBBY ASBESTOS SUPERFUND SITE

Low-Intensity Prescribed Understory Burn Activity-Based Sampling

Revision 0 – May 15, 2015

Project Period: 09/17/2013 to 08/29/2016

Contract No. W9128F-11-D-0023 Task Order No. 0005

Prepared for:

U.S. Environmental Protection Agency

Region VIII 1595 Wynkoop Street

Denver, Colorado 80202

Prepared under Libby Asbestos Interagency Agreement, Libby, MT (DW96954027) by:

U.S. Army Corps of Engineers

Omaha District Rapid Response Program

Offutt AFB, Nebraska 68113

With technical support from:

CDM Federal Programs Corporation 555 17th Street, Suite 1100

Denver, Colorado 80202

Low‐IntensityPrescribedUnderstoryBurnABSQAPP

Revision0–5/15/15Page2of68

A1.TITLEANDAPPROVALSHEET

QualityAssuranceProjectPlan:Low‐IntensityPrescribedUnderstoryBurnActivity‐BasedSampling

OperableUnit3StudyArea,LibbyAsbestosSuperfundSiteREVISIONLOG:Revision# RevisionDate Description

0 5/15/15 ‐‐‐



A2. TABLE OF CONTENTS

A1. TITLE AND APPROVAL SHEET............................................................................................ 2

A2. TABLE OF CONTENTS ........................................................................................................... 3

A3. DISTRIBUTION LIST ........................................................................................................... 12

A4. PROJECT TASK ORGANIZATION ....................................................................................... 14

A4.1 Project Management ................................................................................................. 14

A4.2 QAPP Development ................................................................................................... 14

A4.3 Field Sampling Support ............................................................................................ 15

A4.4 On-Site Field Coordination ...................................................................................... 15

A4.5 Analytical Support .................................................................................................... 16

A4.6 Data Management ..................................................................................................... 16

A4.7 Quality Assurance ..................................................................................................... 16

A5. PROBLEM DEFINITION/BACKGROUND .......................................................................... 17

A5.1 Site Background ........................................................................................................ 17

A5.2 Reasons for this Project ........................................................................................... 17

A5.3 Applicable Criteria and Action Limits ................................................................... 19

A6. PROJECT DESCRIPTION ..................................................................................................... 19

A6.1 Project Summary ....................................................................................................... 19

A6.2 Work Schedule ........................................................................................................... 20

A6.3 Location to be Studied .............................................................................................. 20

A6.4 Resources and Time Constraints ........................................................................... 20

A7. QUALITY OBJECTIVES AND CRITERIA ............................................................................ 20

A7.1 Data Quality Objectives ............................................................................................ 20

A7.2 Performance Criteria ............................................................................................... 20

A7.3 Precision ..................................................................................................................... 21

A7.4 Bias/Accuracy and Representativeness ............................................................... 21

A7.5 Completeness ............................................................................................................. 21

A7.6 Comparability ............................................................................................................ 21

A7.7 Method Sensitivity .................................................................................................... 22

A8. SPECIAL TRAINING/CERTIFICATIONS ............................................................................ 22

A8.1 Field ............................................................................................................................. 22

A8.2 Laboratory .................................................................................................................. 22

A8.2.1 Certifications ........................................................................................................ 22

A8.2.2 Laboratory Team Training/Mentoring Program ............................................... 23

A8.2.3 Analyst Training ................................................................................................... 24

A9. DOCUMENTATION AND RECORDS ................................................................................... 25

A9.1 Field Documentation ................................................................................................ 25



A9.2 Laboratory .................................................................................................................. 25

A9.3 Record of Modification ............................................................................................. 25

B1. STUDY DESIGN .................................................................................................................... 27

B1.1 Sampling Location ..................................................................................................... 27

B1.2 Construction of Prescribed Understory Burn Area ............................................ 28

B1.3 Personal Air Monitoring .......................................................................................... 29

B1.3.1 During the Fire ..................................................................................................... 29

B1.3.2 During Mop-Up Activities ..................................................................................... 29

B1.4 Perimeter Air Monitoring ........................................................................................ 30

B1.4.1 Pre-Burn Sampling ............................................................................................... 30

B1.4.2 During-Burn Sampling ......................................................................................... 31

B1.4.3 Post-Burn Sampling ............................................................................................. 31

B1.5 Duff, Tree Bark, Ash, and Soil Sampling ............................................................... 31

B1.6 Study Variables .......................................................................................................... 31

B1.7 Critical Measurements ............................................................................................. 32

B1.8 Data Reduction and Interpretation ....................................................................... 32

B2. SAMPLING METHODS, INSTRUMENTATION, AND DOCUMENTATION ..................... 33

B2.1 Air Sample Collection ............................................................................................... 33

B2.2 Duff, Tree Bark, Ash, and Soil Sample Collection ................................................ 33

B2.2.1 Duff Sampling ....................................................................................................... 33

B2.2.2 Tree Bark Sampling ............................................................................................. 34

B2.2.3 Ash Sampling ........................................................................................................ 34

B2.2.4 Soil Sampling ........................................................................................................ 35

B2.3 Meteorological Data ................................................................................................. 35

B2.4 Fuel Characterization ............................................................................................... 35

B2.4.1 Fuel Moisture ........................................................................................................ 35

B2.4.2 Fuel Load .............................................................................................................. 36

B2.5 Global Positioning System Coordinate Collection .............................................. 36

B2.6 Equipment Decontamination ................................................................................. 37

B2.6.1 Sampling Equipment ............................................................................................ 37

B2.6.2 Heavy Equipment ................................................................................................. 37

B2.7 Handling Investigation-derived Waste ................................................................. 37

B3. SAMPLE HANDLING AND CUSTODY ................................................................................ 38

B3.1 Sample Documentation ............................................................................................ 38

B3.1.1 Field Sample Data Sheets and Logbooks ............................................................. 38

B3.1.2 Photographic and Video Documentation ............................................................ 38

B3.2 Sample Labeling and Identification ....................................................................... 39

B3.3 Field Sample Custody ............................................................................................... 40

B3.4 Chain of Custody ........................................................................................................ 40

B3.5 Sample Packaging and Shipping ............................................................................ 40

B3.6 Holding Times ............................................................................................................ 41

B3.7 Archival and Final Disposition ............................................................................... 41



B4. ANALYTICAL METHODS .................................................................................................... 41

B4.1 Analysis of LA in Air .................................................................................................. 42

B4.1.1 Sample Preparation ............................................................................................. 42

B4.1.2 Analysis Method and Counting Rules .................................................................. 42

B4.1.3 Stopping Rules ...................................................................................................... 43

B4.2 Analysis of LA in Ash ................................................................................................. 43

B4.2.1 Sample Preparation ............................................................................................. 43

B4.2.2 Analysis Method and Counting Rules .................................................................. 43

B4.2.3 Stopping Rules ...................................................................................................... 43

B4.3 Analysis of LA in Duff ................................................................................................ 44

B4.3.1 Sample Preparation .................................................................................................. 44

B4.3.2 Analysis Method and Counting Rules ....................................................................... 44

B4.3.3 Stopping Rules ........................................................................................................... 44

B4.4 Analysis of LA in Tree Bark ..................................................................................... 45



B4.4.3 Stopping Rules ........................................................................................................... 45

B4.5 Analysis of LA in Soil ................................................................................................. 46


B4.5.2 Analysis Method ........................................................................................................ 46

B4.6 Analysis of LA in Equipment Rinsates ................................................................... 46



B4.6.3 Stopping Rules ........................................................................................................... 47

B4.7 Data Reporting ........................................................................................................... 47

B4.8 Analytical Turn-around Time ................................................................................. 48

B4.9 Custody Procedures .................................................................................................. 48

B5. QUALITY ASSURANCE/QUALITY CONTROL ................................................................... 48

B5.1 Field ............................................................................................................................. 48

B5.1.1 Training ................................................................................................................ 48

B5.1.2 Modification Documentation ............................................................................... 49

B5.1.3 Field QC Samples .................................................................................................. 49

B5.2 Laboratory .................................................................................................................. 52

B5.2.1 Training/Certifications ........................................................................................ 52

B5.2.2 Modification Documentation ............................................................................... 52

B5.2.3 Laboratory QC Analyses ....................................................................................... 52

B6/B7. EQUIPMENT MAINTENANCE AND INSTRUMENT CALIBRATION ........................ 53

B6/B7.1 Field Equipment .................................................................................................... 53

B6/B7.1.1 Field Equipment Maintenance ......................................................................... 53

B6/B7.1.2 Air Sampling Pump Calibration ....................................................................... 53

B6/B7.2 Laboratory Instruments ...................................................................................... 54



B8. INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES ................................. 54

B8.1 Field Supplies ................................................................................................................ 54

B8.2 Laboratory Supplies .................................................................................................... 56

B9. NON-DIRECT MEASUREMENTS ........................................................................................ 56

B10. DATA MANAGEMENT ....................................................................................................... 56

B10.1 Roles and Responsibilities .................................................................................. 57

B10.1.1 Field Personnel ..................................................................................................... 57

B10.1.2 Laboratory Personnel .......................................................................................... 57

B10.1.3 Database Administrators ..................................................................................... 58

B10.2 Master OU3 Project Database ............................................................................. 58

B10.3 Data Reporting ....................................................................................................... 58

B10.4 Data Storage ........................................................................................................... 58

C1. ASSESSMENT AND RESPONSE ACTIONS ......................................................................... 59

C1.1 Assessments ................................................................................................................. 59

C1.1.1 Field ...................................................................................................................... 59

C1.1.2 Laboratory ............................................................................................................ 59

C1.2 Response Actions ........................................................................................................ 60

C2. REPORTS TO MANAGEMENT ............................................................................................ 61

D1. DATA REVIEW, VERIFICATION AND VALIDATION ....................................................... 62

D1.1 Data Review ................................................................................................................ 62

D1.2 Criteria for LA Measurement Acceptability ......................................................... 62

D2. VERIFICATION AND VALIDATION METHODS ............................................................... 63

D2.1 Data Verification ....................................................................................................... 63

D2.2 Data Validation .......................................................................................................... 64

D3. RECONCILIATION WITH USER REQUIREMENTS ........................................................... 65

REFERENCES ............................................................................................................................... 66



LIST OF FIGURES

Figure A-1 Organizational Chart for Understory Burn ABS

Figure B-1 Illustration of Understory Burn ABS Study Design

Figure B-2 ABS Area

LIST OF TABLES

Table B-1 Understory Burn Sample Summary

Table D-1 Data Usability Indicators for Asbestos Datasets

LIST OF APPENDICES

Appendix A Data Quality Objectives

Appendix B Standard Operating Procedures

Appendix C Analytical Requirements Summary Sheet [BURNOU3-0515]

Appendix D Decontamination Checklist for Vehicles and Heavy Equipment

Appendix E Record of Modification Forms

Appendix F Asbestos Laboratory Acceptance Criteria for the Libby Asbestos Superfund Site

Appendix G Prescribed Burn Plan

Appendix H Study-specific Field Sample Data Sheets

Low-Intensity Prescribed Understory Burn ABS QAPP Revision 0 – 5/15/15

Page 8 of 68

LIST OF ACRONYMS AND ABBREVIATIONS

>

≥

°

°F

%

ABS

AOC

BHI

cc

CB&I

CDM Smith

CERCLA

CFR

Chapman

CHISQ

COC

DQO

EDD

EDS

EPA

f/cc

FMC

FS

FSDS

FTL

GPS

Grace

H&S

HASP

ID

IDW

ISO

KDC

L/min

LA

LC

MCE

MDEQ

ml

mm

mm2

MWH

greater than

greater than or equal to

degrees

degrees Fahrenheit

percent

activity-based sampling

administrative order on consent

Billmayer & Hafferman, Inc.

cubic centimeters

CB&I Federal Services

CDM Federal Programs Corporation

Comprehensive Environmental Response, Compensation, and Liability Act

Code of Federal Regulations

Chapman Construction, Inc.

chi-squared

chain-of-custody

data quality objective

electronic data deliverable

energy dispersive spectroscopy

U.S. Environmental Protection Agency

fibers per cubic centimeter

fuel moisture content

feasibility study

field sample data sheet

field team leader

global positioning system

W.R. Grace and Company

health and safety

health and safety plan

identification

investigative-derived waste

International Organization for Standardization

Kootenai Development Corporation

liters per minute

Libby amphibole

laboratory coordinator

mixed cellulose ester

Montana Department of Environmental Quality

milliliter

millimeter

square millimeters

MWH Americas, Inc.


Page 9 of 68

N number of asbestos fibers

NIST National Institute of Standards and Technology

NVLAP National Voluntary Laboratory Accreditation Program

OSHA Occupational Safety and Health Administration

OU operable unit

OU3 Operable Unit 3 Study Area

PCM phase contrast microscopy

PCME phase contrast microscopy-equivalent

pdf portable document format

PE performance evaluation

PLM polarized light microscopy

PLM-VE polarized light microscopy-visual area estimation

PLM-Grav polarized light microscopy-gravimetric

PRI-ER Project Resources Inc. and Environmental Restoration

QA quality assurance

QA/QC quality assurance/quality control

QAM quality assurance manager

QAPP quality assurance project plan

QATS quality assurance technical support

QC quality control

RI remedial investigation

ROM record of modification

RPM Remedial Project Manager

s/cc structures per cubic centimeter

SAED selected area electron diffraction

Site Libby Asbestos Superfund Site

SOP standard operating procedure

SPF sample preparation facility

STEL short-term exposure limit

TAS target analytical sensitivity

TEM transmission electron microscopy

µm micrometer

USACE U.S. Army Corps of Engineers

USFS U.S. Forest Service

USGS U.S. Geological Survey


Page 10 of 68

DEFINITION OF COMMON TERMS

[Note: Definitions as provided by the U.S. Forest Service, which are based on information in the Glossary of Wildland Fire Terminology (PMS 205) (National Wildfire Coordinating Group [NWCG] 2014)]

Aerial Fuels: All live and dead vegetation in the forest canopy or above surface fuels, including tree branches, twigs and cones, snags, moss, and high brush.

Burning Conditions: The state of the combined factors of the environment that affect fire behavior in a specified fuel type.

Bone Piling: The stacking of black chunks, limbs, etc., gathered in burned areas to prevent embers from scattering or being blown into unburned areas.

Cold Trailing: A method of controlling a partly dead fire edge by carefully inspecting and feeling with the hand for heat to detect any fire, digging out every live spot, and trenching any live edge.

Fire Behavior: The manner in which a fire reacts to the influences of fuel, weather and topography.

Fire Break: A natural or constructed barrier used to stop or check fires that may occur, or to provide a control line from which to work.

Fire Line: A linear fire barrier that is scraped or dug to mineral soil.

Flash Fuels: Fuels such as grass, leaves, draped pine needles, fern, tree moss and some kinds of slash, that ignite readily and are consumed rapidly when dry. Also called fine fuels.

Fuel: Combustible material. Includes, vegetation, such as grass, leaves, ground litter, plants, shrubs and trees, that feed a fire. (See Surface Fuels.)

Ground Fuel: All combustible materials below the surface litter, including duff, tree or shrub roots, punchy wood, peat, and sawdust, that normally support a glowing combustion without flame.

Mineral Soil: Soil layers below the predominantly organic horizons; soil with little combustible material.

Mop-up: To make a fire safe or reduce residual smoke after the fire has been controlled by extinguishing or removing burning material along or near the control line, felling snags, or moving logs so they won’t roll downhill.

Prescribed Fire: Any fire ignited by management actions under certain, predetermined conditions to meet specific objectives related to hazardous fuels or habitat improvement. A written, approved prescribed fire plan must exist, and NEPA requirements must be met, prior to ignition.

Prescribed Fire Plan (Burn Plan): This document provides the prescribed fire burn boss information needed to implement an individual prescribed fire project.


Page 11 of 68

Prescription: Measurable criteria that define conditions under which a prescribed fire may be ignited, guide selection of appropriate management responses, and indicate other required actions. Prescription criteria may include safety, economic, public health, environmental, geographic, administrative, social, or legal considerations.

Pulaski: A combination chopping and trenching tool, which combines a single-bitted axe-blade with a narrow adze-like trenching blade fitted to a straight handle. Useful for grubbing or trenching in duff and matted roots. Well-balanced for chopping.

Smoldering Fire: A fire burning without flame and barely spreading.

Spot Fire: A fire ignited outside the perimeter of the main fire by flying sparks or embers.

Suppression: All the work of extinguishing or containing a fire, beginning with its discovery.

Surface Fuels: Loose surface litter on the soil surface, normally consisting of fallen leaves or needles, twigs, bark, cones, and small branches that have not yet decayed enough to lose their identity; also grasses, forbs, low and medium shrubs, tree seedlings, heavier branchwood, downed logs, and stumps interspersed with or partially replacing the litter.


Page 12 of 68

A Project Management

A3. DISTRIBUTION LIST

Copies of this completed and signed quality assurance project plan (QAPP) should be distributed to:

U.S. Environmental Protection Agency, Region VIII

1595 Wynkoop Street

Denver, Colorado 80202-1129

Christina Progess, [email protected] (electronic copy) Don Goodrich, [email protected] (electronic copy)

Montana Department of Environmental Quality

1225 Cedar Street

Helena, Montana 59601

Lisa Dewitt, [email protected] (electronic copy)

U.S. Army Corps of Engineers

Rapid Response Program Office

Offutt AFB, Nebraska 68113

Mary Darling, [email protected] (electronic copy) Jeremy Ayala, [email protected] (electronic copy) Brian Broekemeier, [email protected] (electronic copy)

TechLaw, Inc.

Environmental Services Assistance Team

EPA Region VIII

16194 West 45th Drive

Golden, Colorado 80403

Doug Kent, [email protected] (electronic copy)

CDM Smith – Libby Field Office

60 Port Boulevard, Suite 201

Libby, Montana 59923 Dominic Pisciotta, [email protected] (electronic copy) Terry Crowell, [email protected] (electronic copy) Scott Felton, [email protected] (electronic copy)

CDM Smith – Denver Office 555 17th Street, Suite 110 Denver, Colorado 80202

Lynn Woodbury, [email protected] (electronic copy) Natalie Ross, [email protected] (electronic copy)

W.R. Grace and Company (Grace) 6401 Poplar Avenue, Suite 301 Memphis, Tennessee 38119

Robert Medler, [email protected] (2 hard copies; electronic copy) Robert Marriam, [email protected] (electronic copy)

mailto:[email protected]















Page 13 of 68

United States Forest Service – Libby Ranger District, Canoe Gulch (406-293-7773) 12557 Mt. Highway 37 Libby, Montana 59923

Seth Cole, [email protected] (electronic copy)

United States Forest Service – Northern Region (406-329-3634) 200 East Broadway Missoula, Montana 59802

Malcom Edwards, [email protected] (electronic copy) Robert Wintergerst, [email protected] (electronic copy)

MWH Americas 2890 East Cottonwood Parkway, Suite 300 Salt Lake City, Utah 84121

William Pickens, [email protected] (electronic copy)

Wildland Fire Associates 2006 Saint Clair Avenue Brentwood, Missouri 63144

Darrell Schulte, [email protected] (electronic copy)

Wildland Fire Associates 523 E. Central Ave. Missoula, Montana 59801

Kevin Ryan, [email protected] (electronic copy)

Chapman Construction, Inc. P.O. Box 516 Libby, Montana 59923

Mike Chapman, [email protected] (electronic copy)

Reax Engineering 1921 University Avenue Berkeley, California 94704

Chris Lautenberger, [email protected] (electronic copy)

Billmayer & Hafferman, Inc. 2191 Third Avenue East Kalispell, Montana 59901

Kurt Hafferman, [email protected] (electronic copy)

Copies of the QAPP will be distributed to the individuals above by CDM Federal Programs

Corporation (CDM Smith), either in hard copy or in electronic format (as indicated above). The CDM

Smith Project Manager (or their designee) will distribute updated copies each time a QAPP revision

occurs. A copy of the final, signed QAPP (and any subsequent revisions) will also be posted to the

Libby Operable Unit (OU) 3 Study Area (OU3) website (http://cbec.srcinc.com/libby) and the OU3

eRoom (https://team.cdm.com/eRoom/mt/LibbyOU3). Libby OU3 eRoom user accounts are

managed by Natalie Ross (CDM Smith) ([email protected]).










http://cbec.srcinc.com/libby

https://team.cdm.com/eRoom/mt/LibbyOU3



Page 14 of 68

A4. PROJECT TASK ORGANIZATION

Figure A-1 presents an organizational chart that shows lines of authority and reporting

responsibilities for this project. The following sections summarize the entities and individuals that

will be responsible for providing project management, QAPP development, field sampling support,

on-site field coordination, analytical support, data management, and quality assurance (QA) for this

project.

A4.1 Project Management

The U.S. Environmental Protection Agency (EPA) is the lead regulatory agency for activities at the

Libby Asbestos Superfund Site (Site). The EPA Remedial Project Manager (RPM) for OU3 of the Site

is Christina Progess. Ms. Progess is the principal data user and decision-maker for Superfund

activities within OU3.

The Montana Department of Environmental Quality (MDEQ) is the support regulatory agency for

Superfund activities within OU3. The interim MDEQ Project Managers for OU3 is Lisa Dewitt. EPA

will consult with MDEQ as provided for by the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA), the National Contingency Plan, and applicable guidance

in conducting Superfund activities within OU3.

The U.S. Forest Service (USFS) is the land management agency for over 30,000 acres within OU3. As

such, the USFS is a support agency for this site. The USFS Project Coordinators are Robert

Wintergerst and Malcom Edwards. The local Supervisory Forester for the USFS is Seth Cole. EPA

will consult with the USFS while operating on the USFS-managed land.

The U.S. Army Corps of Engineers (USACE), Omaha District, is the contracting agency providing

project management, environmental engineering, and remediation support at the Site on behalf of

EPA. USACE has an interagency agreement with EPA, number DW96954027. Support services will

be performed by USACE’s architect and engineering firm, CDM Smith, via Contract No. W9128F-11-

D-0023, Task Order No. 0005. The USACE Program Manager is Mary Darling.

EPA has entered into an Administrative Order on Consent (AOC) (Docket No. CERCLA-08-2007-

0012) with Respondents Grace and Kootenai Development Corporation (KDC) for performance of a

Remedial Investigation/Feasibility Study (RI/FS) at OU3. Under the terms of the AOC, Grace and

KDC will implement the activities described in this QAPP, under EPA supervision. The designated

Project Coordinator for Respondents Grace and KDC is Robert Medler; he is assisted by Robert

Marriam.

A4.2 QAPP Development

This QAPP was developed by CDM Smith at the direction of USACE, and with oversight by EPA in

consultation with USFS, under their USACE contract. This QAPP contains all the elements required

for both a sampling and analysis plan and a QAPP and has been developed in general accordance


Page 15 of 68

with the EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5 (EPA 2001) and the

Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G4 (EPA 2006).

Copies of the QAPP will be distributed to the individuals above by CDM Smith, either in hard copy of

in electronic format (as indicated in Section A3). The CDM Smith Project Manager (or their

designee) is responsible for maintaining the QAPP and will distribute updated copies each time a

document revision occurs. As noted above, a copy of the final, signed QAPP (and any subsequent

revisions) will also be posted to the OU3 website and the OU3 eRoom.

A4.3 Field Sampling Support

All field collection activities described in this QAPP will be performed by Grace and their

contractors, in strict accordance with this QAPP. Grace will be supported in this field work by

several subcontractors, including MWH Americas, Inc. (MWH), Chapman Construction, Inc.

(Chapman), Wildland Fire Associates, Reax Engineering, and Billmayer & Hafferman, Inc. (BHI). The

main point of contact for each subcontractor is listed below:

MWH: William Pickens

Chapman: Mike Chapman

Wildland Fire Associates: Darrell Schulte, Kevin Ryan

Reax Engineering: Chris Lautenberger

BHI: Kurt Hafferman

MWH, Chapman, and BHI will be responsible for firefighting support, will perform all air, soil, duff,

bark, and ash sampling, and will provide the necessary personal protective equipment for

personnel that will support this sampling effort. Wildland Fire Associates and Reax Engineering will

be responsible for collecting and analyzing fuel moisture samples, weather monitoring,

photographic/video documentation of the burn, and fire supervision. The Prescribed Fire Burn

Boss is Darrell Schulte of Wildland Fire Associates; Mr. Schulte will be responsible for determining

when and if the burn area is safe for personnel to enter following the burn activity.

A4.4 On-Site Field Coordination

Access to the mine and other areas of OU3 via Rainy Creek Road is currently restricted and is

controlled by EPA. The point of contact for access to the mine is USACE’s contractor, Project

Resources, Inc. and Environmental Restoration (PRI-ER):

USACE office (406-293-3567)

Jeremy Ayala – USACE Project Engineer (402-594-1239)

Brian Broekemeier – Construction Control Representative (402-253-6109)

Jeff Hubbard – Construction Control Representative (402-216-4255)

Harvey Fowler – PRI-ER Superintendant (406-291-7994)



A4.5 Analytical Support

All samples collected as part of this project for asbestos analysis will be sent for preparation and/or

analysis to laboratories that meet the Libby-specific laboratory criteria that have been established

for the project. These criteria are specified Appendix F. Grace may choose whether asbestos

analytical laboratory services are procured directly or if services will be provided via EPA.

A4.6 Data Management

Administration of the master database for OU3 will be performed by USACE’s contractor, CDM

Smith. The primary database administrator will be Lynn Woodbury. She (or her designee) will be

responsible for sample tracking, uploading new data, performing data verification and error checks

to identify incorrect, inconsistent, or missing data, and ensuring that all data are corrected as

needed. When the OU3 database has been populated, verified, and validated, relevant asbestos data

may be transferred into a Scribe project database, as directed by EPA, for final storage.

A4.7 Quality Assurance

There is no one individual designated as the EPA Quality Assurance Manager (QAM) for the Libby

project. Rather, the Region 8 Quality Assurance (QA) Program has delegated authority to the EPA

RPMs. This means EPA RPMs that have completed the QA training have the ability to review and

approve governing investigation documents developed by Site contractors. Thus, it is the

responsibility of the EPA RPM for OU3 to designate an EPA QA reviewer, who is independent of the

entities planning and obtaining the data, to ensure that this QAPP has been prepared in accordance

with EPA’s QA guidelines and requirements. The EPA QA reviewer for this QAPP is Dania Zinner.

The EPA RPM is also responsible for managing and overseeing all aspects of the quality

assurance/quality control (QA/QC) program for OU3. In this regard, the RPM is supported by the

EPA Quality Assurance Technical Support (QATS) contractor, CB&I Federal Services, LLC (CB&I).

The QATS contractor will evaluate and monitor laboratory QA/QC sampling and is responsible for

performing annual audits of each analytical laboratory and validating laboratory data packages.

CB&I’s QAM for this project is Michael Lenkauskas.

CDM Smith’s QA Director, Jo Nell Mullins, implements the CDM Smith QA program. She is

independent of project technical staff and reports directly to the firm’s president on QA matters.

The QA Director has the authority to objectively review projects and identify problems, and the

authority to use corporate resources, as necessary, to resolve any quality-related problems.

CDM Smith’s QAM for this project, Terry Crowell, reports to Ms. Mullins on QA matters. Under Ms.

Mullin’s oversight, Ms. Crowell is responsible for monitoring and evaluating field QA/QC, providing

oversight of field sampling and data collection activities, and coordinating field QA activities,

including identifying qualified, independent staff to conduct assessments of field activities (see

Section C1.1).



A5. PROBLEM DEFINITION/BACKGROUND

A5.1 Site Background

Libby is a community in northwestern Montana that is located near a large open-pit vermiculite

mine. Vermiculite from the mine at Libby is known to contain amphibole asbestos that includes

several different mineralogical classifications, including winchite, richterite, tremolite, and possibly

actinolite (Meeker et al. 2003). For the purposes of EPA investigations at the Site, this mixture is

referred to as Libby amphibole asbestos (LA).

Historic mining, milling, and processing of vermiculite at the site are known to have caused releases

of LA associated with vermiculite to the environment. Inhalation of LA associated with the

vermiculite is known to have caused a range of adverse health effects in exposed humans, including

workers at the mine and processing facilities (Amandus and Wheeler 1987; McDonald et al. 1986;

McDonald et al. 2004; Sullivan 2007; Rohs et al. 2007; Larson et al. 2010, 2012a, 2012b), as well as

residents of Libby (Peipins et al. 2003). Based on these adverse effects, EPA listed the Libby

Asbestos Superfund Site (Site) on the National Priorities List (NPL) in October 2002. Starting in

2000, EPA began taking a range of cleanup actions at the site to eliminate sources of LA exposure to

area residents and workers using CERCLA (or Superfund) authority.

EPA has designated a number of operable units (OUs) for the Site due to its size and complexity.

This document focuses on investigations at OU3. OU3 includes the property in and around the

former vermiculite mine and certain areas surrounding the mine that have been impacted by

releases and subsequent migration of hazardous substances and/or pollutants or contaminants

from the mine. Figure A-2 shows the location of the mine and the preliminary study area for OU3.

EPA established the preliminary study area for the purpose of planning and developing the scope of

the RI/FS for OU3. This study area may be revised as data are obtained during the RI for OU3 on the

nature and extent of environmental contamination associated with releases that may have occurred

from the mine site.

A5.2 Reasons for this Project

Extensive data on LA levels on the bark surface of trees and in duff materials1 have been collected in

the forested area near the mine (CDM Smith 2013a) and in the forested area near the current NPL

boundary for the Site (CDM Smith 2013b). These data show that LA fibers are present on the outer

bark surface of trees and in duff material at the Site. In general, LA levels in bark and duff tend to be

highest closest to the mine (within about 3-4 miles), but LA fibers have been detected in bark and

duff 13 or more miles from the mine (CDM Smith 2013b). As stated in the Framework for

Investigating Asbestos-Contaminated Superfund Sites (EPA 2008a), asbestos fibers in source

materials, such as bark and duff, are typically not inherently hazardous, unless the asbestos is

released from the source material into air where it can be inhaled. If inhaled, asbestos fibers can

increase the risk of developing lung cancer, mesothelioma, pleural fibrosis, and asbestosis.

1 Duff consists of the un-decomposed twigs, needles, and other vegetation and the layer of partially- to fully-decomposed litter that occurs on top of the mineral soil in forested areas.



Fires that occur in the forested areas of the Site may result to the release of LA fibers into air that

could expose responding firefighters result in unacceptable risks. The evaluation of risks to humans

from exposure to asbestos is most reliably achieved by the collection of data on the level of asbestos

in breathing zone air during disturbances of asbestos-containing source materials, referred to as

activity-based sampling (ABS) (EPA 2008a). While there have been several ABS studies conducted

at the Site to assess potential exposures under a variety of exposure conditions, at present, there

are limited ABS data to evaluate exposures during fire.

In the event of an authentic wildfire that is in or near the current Site boundary, there are sampling

plans in place (EPA 2013; CDM Smith 2013c) to collect opportunistic air samples, both at stationary

monitors throughout the Libby community and near the wildfire (to evaluate exposures to

firefighters).

To date, air samples have only been collected during one wildfire event. In late July 2013, a small

(1.5 acre) low-intensity wildfire occurred in the Souse Gulch day-use recreation area on Lake

Koocanusa behind Libby Dam. During this fire, air samples were collected to provide data on LA

exposures of responding firefighters (both to the ground crews and the aircraft support pilot) and

downwind LA concentrations in ambient air during the fire. In the draft Site-wide Human Health

Risk Assessment (EPA 2014a), exposure estimates based on the Souse Gulch wildfire data showed

that estimated cancer risks and non-cancer hazards for responding firefighters and in the nearby

community were below a level of concern. However, the Souse Gulch day-use recreation area is

located approximately 4.5 miles southeast from the mine, in a crosswind direction from the mine.

No measured data are available on potential airborne concentrations of LA during wildfires that

may occur closer to the mine, where LA levels in source materials are higher. Therefore, it is

currently unknown whether higher LA concentrations in tree bark and duff, such as those

measured near the mine, would present an unacceptable risk in the event of a fire.

Rather than wait for an authentic wildfire to occur (which may or may not be in an area that is

relevant), Grace will conduct an ABS investigation to simulate potential exposures during the initial

attack on a low-intensity, small-scale wildfire that occurs in the forest near the mine. Larger-scale,

high-intensity wildfires could exhibit extreme fire behavior across multiple days or weeks because

of the complex interaction between fuels, weather, topography, and other factors. As such, the

results of this ABS investigation may not be representative of the amount of LA that could be

released into the air during such a fire.

The goal of this study is to provide sufficient data on LA concentrations in air to allow EPA to

complete an exposure assessment for firefighters during the initial attack on a low-intensity, small-

scale wildfire in the forest near the mine. EPA will use the exposure assessment to evaluate

potential risks to responding firefighters. The risk assessment will be included in the RI/FS process

for decision making and alternatives analysis for OU3 and will support decisions about whether or

not response actions are needed to protect firefighters from unacceptable risks during a low-

intensity, small-scale fire.



A5.3 Applicable Criteria and Action Limits

At present, there are no criteria or action limits that apply specifically to individuals potentially exposed to LA from forest fires.

Criteria for exposure of workers to asbestos in workplace air have been established by the

Occupational Safety and Health Administration (OSHA). The short-term (30-minute) exposure limit

(STEL) is 1.0 fibers per cubic centimeter (f/cc), and the 8-hour time-weighted average (TWA)

exposure limit is 0.1 f/cc. Both asbestos exposure limits are expressed in terms of phase contrast

microscopy (PCM) fibers (OSHA 2002). Health and safety (H&S) worker monitoring will be

performed in accordance with OSHA requirements as part of this study. These H&S personal air

samples are collected in addition to the ABS air samples and analyzed by PCM for the purposes of

OSHA compliance in accordance with the project Health and Safety Plan (HASP) (see Section A8.1).

However, because the PCM method does not distinguish between asbestos and non-asbestos fibers,

air samples collected as part of this study, which are collected to determine exposures for use in

risk assessment, will be analyzed by transmission electron microscopy (TEM) in accordance with

EPA guidance (EPA 2008a).

At the Site, EPA has developed action levels and cleanup criteria for LA that are applicable to

emergency response actions performed at residential/commercial properties (EPA 2003).

However, these criteria are not applicable to bark and duff, nor would they apply to forested areas.

In addition, final remedial action levels for the Site will not be developed until completion of the

RI/FS and the publication of the record of decision. Thus, there are no LA-specific criteria or action

limits that apply to this sampling program.

Data collected as part of this study will be used to characterize exposures and human health risks to

firefighters; therefore, samples must be collected and analyzed in accordance with project-specific

requirements (see Section B2 and Section B4) to ensure results will be adequate to support risk

management decision-making.

A6. PROJECT DESCRIPTION

A6.1 Project Summary

This document provides a plan for collecting data to evaluate potential LA inhalation exposures of

ground-based firefighters from smoke and as a result of source material (soil, bark, duff, and ash)

disturbances during the initial attack on a low-intensity, small-scale forest fire. This will be

accomplished by conducting ABS air monitoring during a low-intensity, controlled prescribed

understory burn to simulate potential firefighter exposures. This document also provides a plan for

the collection of soil, bark, and duff samples prior to the burn to provide information on the nature

of the source materials being burned and residual ash and soil samples from the burn area

following the fire.



All field collection activities will be performed by Grace and their contractors, in strict accordance

with this QAPP. Basic tasks that are required to implement this investigation are described in

greater detail in subsequent sections of this QAPP.

A6.2 Work Schedule

The specific timing of the ABS event has not yet been determined, but ABS is expected to occur in

late May, early June of 2015.

A6.3 Location to be Studied

The location where the controlled prescribed understory burn activities will be performed is

described in Section B1.1.

A6.4 Resources and Time Constraints

The greatest time constraint is that the burn activities must be conducted when conditions are

amenable to a controlled prescribed understory burn and when appropriate personnel are

available to ensure the burn can be completed safely.

A7. QUALITY OBJECTIVES AND CRITERIA

A7.1 Data Quality Objectives

Data quality objectives (DQOs) are statements that define the type, quality, quantity, purpose, and

use of data to be collected. The design of a study is closely tied to the DQOs, which serve as the basis

for important decisions regarding key design features such as the number and location of samples

to be collected and the types of analyses to be performed. EPA has developed a seven-step process

for establishing DQOs to help ensure that data collected during a field sampling program will be

adequate to support reliable site-specific risk management decision-making (EPA 2001, 2006).

Appendix A provides the detailed implementation of the seven-step DQO process associated with

this QAPP.

A7.2 Performance Criteria

The range of LA concentrations that will occur in air during controlled prescribed understory burn

activities is not known. However, it is possible to estimate the risk-based air concentrations that

correspond to a level of human health concern. These calculations are provided in Appendix A. In

brief, the risk-based air concentration is back-calculated such that the resulting air concentration

corresponds to a target cancer risk of 1E-05 or non-cancer hazard of 1 based on the LA-specific

toxicity values (EPA 2014b). The analytical requirements for LA measurements in air as established

in Section B4 ensure that, if air concentrations are present at these target risk levels, they will be

reliably detected and quantified during the analysis.



A7.3 Precision

The precision of asbestos measurements is determined mainly by the number (N) of asbestos fibers

counted in each sample. The coefficient of variation resulting from random Poisson counting error

is equal to 1/N0.5. In general, when good precision is needed, it is desirable to count a minimum of

3-10 fibers per sample, with counts of 20-25 fibers per sample being optimal.

Recount and re-preparation analyses will be performed as part of TEM analysis (see Section

B5.2.3). These analyses will provide information on analysis reproducibility and precision (both

inter- and intra-laboratory).

A7.4 Bias/Accuracy and Representativeness

There is no established set of reference materials or spiked standards that can be used to assess

accuracy of TEM analyses of LA. Results for field blanks and laboratory blanks will be utilized to

ensure that sample results are not biased as a consequence of cross-contamination due to field

sampling procedures or preparation and analysis methods.

It is expected that LA levels in air may vary widely as a function of LA levels in the materials being

burned, fire behavior, the disturbance activities performed, and meteorological conditions. The ABS

location selected for evaluation is intended to represent an area of high potential LA exposure (e.g.,

in an area near the mine that is predominantly downwind from the mine where the highest levels of

LA have been reported in tree bark and duff) (CDM Smith 2013a), so the measured concentrations

of LA in ABS air are likely to be biased high relative to other areas in the forest located further from

the mine. Thus, measured LA concentrations in ABS air are likely to represent worst case exposure

conditions during the initial attack on a small-scale, low-intensity fire.

A7.5 Completeness

Target completeness for this project is 100 percent (%) for all air samples collected. If any air

monitoring samples are not collected, or if LA analysis is not completed successfully, data may not

be adequate to support risk management decision-making.

Target completeness is also 100% for all duff, tree bark, ash, and soil samples collected; these

samples are useful in providing data on the nature of the source materials being burned and LA

levels in the burn area following the fire, but risk estimates do not depend upon these data (i.e., air

concentrations will not be quantitatively correlated or predicted from LA concentrations in source

materials).

A7.6 Comparability

The data generated during this study will be obtained using sample collection, preparation, and

analysis methods for measuring LA in air, duff, tree bark, ash, and soil used previously at the Site.

The use of consistent methods will yield data that are comparable to previous results of LA

analyses.



A7.7 Method Sensitivity

The method sensitivity (analytical sensitivity) needed for the analysis of LA is discussed in Section

B4.

A8. SPECIAL TRAINING/CERTIFICATIONS

A8.1 Field

Asbestos is a hazardous substance that can increase the risk of cancer and serious non-cancer

effects in people who are exposed by inhalation. Therefore, all individuals involved in the collection,

packaging, and shipment of samples must have OSHA 40-hour health and safety training, and

respiratory protection training as required by 29 Code of Federal Regulations (CFR) 1910.134.

Individuals must also have asbestos awareness training, as required by 29 CFR 1910.1001, as well

as training in sample collection techniques and use of personal protective equipment. All training

documentation will be stored in the appropriate field office. It is the responsibility of the field H&S

manager to ensure that all training documentation is up-to-date and on-file for each field team

member.

It is the responsibility of Grace, or their contractors, to ensure that sampling is conducted in

accordance with the project HASP and to maintain appropriate documentation of training by active

field personnel. The project HASP will be developed by Grace’s contractor prior to the ABS. The

final, approved HASP will be available on the OU3 eRoom.

Prior to beginning field sampling activities, a field planning meeting will be conducted to discuss

and clarify the following:

Objectives and scope of the fieldwork

Equipment and training needs

Field operating procedures, schedules of events, and individual assignments

Required quality control (QC) measures

Health and safety requirements

It is the responsibility of each field team member to review and understand all applicable governing

documents associated with this sampling program.

A8.2 Laboratory

A8.2.1 Certifications

All analytical laboratories participating in the analysis of samples for the Libby project are subject

to national, local, and project-specific certifications and requirements. Each laboratory is accredited

by the National Institute of Standards and Technology (NIST) and National Voluntary Laboratory

Accreditation Program (NVLAP) for the analysis of airborne asbestos by transmission electron



microscopy (TEM). This includes the analysis of NIST/NVLAP standard reference materials (SRMs),

or other verified quantitative standards, and successful participation in two proficiency rounds per

year of airborne asbestos by TEM supplied by NIST/NVLAP.

Copies of recent proficiency examinations from NVLAP or an equivalent program, as well as

certifications from other state and local agencies, are maintained by each participating analytical

laboratory. Copies of all proficiency examinations and certifications are also maintained by the

laboratory coordinator (LC).

Each laboratory working on the Libby project is also required to pass an on-site EPA laboratory

audit. The details of this EPA audit are discussed in Section C1.1. The LC also reserves the right to

conduct any additional investigations deemed necessary to determine the ability of each laboratory

to perform the work. Each laboratory also maintains appropriate certifications from the state and

possibly other certifying bodies for methods and parameters that may also be of interest to the

Libby project. These certifications require that each laboratory has all applicable state licenses and

employs only qualified personnel. Laboratory personnel working on the Libby project are reviewed

for requisite experience and technical competence to perform asbestos analyses. Copies of

personnel resumes are maintained for each participating laboratory by the LC in the Libby project

file.

A8.2.2 Laboratory Team Training/Mentoring Program

Training/Mentoring

The orientation program to help new laboratories gain the skills needed to perform reliable

analyses at the Site involves successful completion of a training/mentoring program that was

developed for new laboratories prior to their analysis of Libby field samples. All new laboratories

are required to participate in this program. The program includes training provided by the QATS

contractor and/or senior personnel from other Libby team laboratories. The training/mentoring

process includes a review of morphological, optical, chemical, and electron diffraction

characteristics of LA, as well as training on project-specific analytical methodology, documentation,

and administrative procedures used on the Libby site. The mentoring process also includes a

general EPA audit, which is performed by the QATS contractor, to determine the general

capabilities of the laboratory, the adequacy of facilities and instrumentation, and evaluate of the

laboratory quality management system. The mentor will also review the analysis of at least one

proficiency demonstration sample for each analytical method with the trainee laboratory.

Once the laboratory has satisfactorily completed the training/mentoring program, they can begin to

support the analysis of Libby field samples. Initially, all submitted analytical results will undergo a

detailed data verification and validation review (see Section D2). The frequency of these reviews

can be reduced if no issues are identified. The QATS contractor may also perform a subsequent EPA

audit to evaluate analyses of Libby field samples.



Site-Specific Reference Materials

Because LA is not a common form of asbestos, the U.S. Geological Survey (USGS) prepared Site-

specific reference materials using LA collected at the Libby mine site (EPA 2008b). Upon entry into

the Libby program, each laboratory is provided samples of these LA reference materials. Each

laboratory is required to analyze multiple LA structures present in these samples by TEM in order

to become familiar with the physical and chemical appearance of LA and to establish a reference

library of LA energy dispersive spectroscopy (EDS) spectra. These laboratory-specific and

instrument-specific LA reference spectra (EPA 2008c) serve to guide the classification of asbestos

structures observed in Libby field samples during TEM analysis.

Regular Technical Discussions

Ongoing training and communication is an essential component of QA for the Libby project. To

ensure that all laboratories are aware of any technical or procedural issues that may arise, a regular

teleconference is held between EPA, their contractors, and each of the participating laboratories.

Other experts (e.g., USGS) are invited to participate when needed. These calls cover all aspects of

the analytical process, including sample flow, information processing, technical issues, analytical

method procedures and development, documentation issues, project-specific laboratory

modifications, and pertinent asbestos publications.

Professional/Technical Meetings

Another important aspect of laboratory team training has been the participation in technical

conferences. The Libby laboratory team has convened on multiple occasions at the American

Society for Testing and Materials (ASTM) Johnson Conferences in Vermont and at the ASTM Michael

E. Beard Asbestos Conferences. These conferences enable the Libby laboratory and technical team

members to have an on-going exchange of information regarding all analytical and technical aspects

of the project, including the benefits of learning about developments by others.

A8.2.3 Analyst Training

All TEM analysts for the Libby project undergo extensive training to understand TEM theory and

the application of standard laboratory procedures and methodologies. The training is typically

performed by a combination of personnel, including the laboratory manager, the laboratory QAM,

and senior TEM analysts.

In addition to the standard TEM training requirements, trainees involved with the Libby project

must familiarize themselves with Site-specific method deviations, project-specific documents, and

visual references. Standard samples that are often used during TEM training include known pure

(traceable) samples of chrysotile, amosite, crocidolite, tremolite, actinolite and anthophyllite, as

well as fibrous non-asbestos minerals, such as vermiculite, gypsum, antigorite, kaolinite, and

sepiolite. New TEM analysts on the Libby project are also required to perform an EDS spectra

characterization evaluation on the LA-specific reference materials provided during the initial



training program to aide in LA mineralogy recognition and definition (similar to EPA 2008c).

Satisfactory completion of each of these tasks must be approved by a senior TEM analyst.

All TEM analysts are also trained in the Site-specific laboratory QA/QC program requirements for

TEM (see Section B5.2.3). The entire program is discussed to ensure understanding of requirements

and responsibilities. In addition, analysts are trained in the project-specific reporting requirements

and data reporting tools utilized in transmitting results. Upon completion of training, the TEM

analyst is enrolled as an active participant in the Libby laboratory program.

A training checklist or logbook is used to assure that the analyst has satisfactorily completed each

specific training requirement. It is the responsibility of the laboratory QAM to ensure that all TEM

analysts have completed the required training requirements.

A9. DOCUMENTATION AND RECORDS

A9.1 Field Documentation

Field teams will record sample information on the most current version of the Site-specific field

sample data sheets (FSDSs)2. Section B3.1 provides detailed information on the sample

documentation requirements for samples collected as part of this study. In brief, the FSDS forms

document the unique sample number assigned to every sample collected as part of this program. In

addition, the FSDSs provide information on whether the sample is representative of a field sample

or a field-based QC sample (e.g., field blank, field duplicate). The field teams will also record

information related to sample collection in a field logbook.

A9.2 Laboratory

All analytical data for asbestos generated in the analytical laboratory will be documented on Site-

specific laboratory bench sheets. Section B4.3 provides detailed information on the requirements

for laboratory documentation and records. In brief, the data recorded on the bench sheets are

entered into a Site-specific electronic data deliverable (EDD) template spreadsheet developed for

recording TEM results3. It is the responsibility of each laboratory to maintain logbooks and other

internal records throughout the sample lifespan as a record of sample handling procedures. Upon

completion of the appropriate analyses, the EDD spreadsheets, along with scanned copies of all

analytical laboratory data packages, will be posted to the OU3 eRoom.

A9.3 Record of Modification

It is the responsibility of the field team and laboratory staff to maintain logbooks and other internal

records throughout the sample lifespan as a record of sample handling procedures. Significant

deviations (i.e., those that impact or have the potential to impact investigation objectives) from this

QAPP, or any procedures referenced herein governing sample handling, will be discussed with the

2 The most recent versions of the FSDS templates are available in the Libby OU3 eRoom. 3 The most recent version of the TEM EDDs is provided in the Libby Lab eRoom.



EPA RPM (or their designee) prior to implementation. Such deviations will be recorded on a Record

of Modification (ROM) form. Sections B5.1.2 and B5.2.2 provide detailed information on the

procedures for preparing and submitting ROMs by field and analytical laboratory personnel,

respectively.



B Data Generation and Acquisition B1. STUDY DESIGN

The basic study design will be to perform a small-scale, low-intensity controlled prescribed

understory burn and to collect samples to measure LA concentrations in the air that result from the

fire and associated firefighter disturbance activities. The basic study design is illustrated in Figure

B-1 and summarized in Table B-1. In brief, prior to the burn, soil, duff, and tree bark samples will

be collected to represent the materials burned. During the burn and mop-up activity, personal air

samples will be collected for individuals performing simulated ground-based firefighter activities to

measure LA air concentrations in the breathing zone during these activities. Perimeter air samples

will be collected before, during, and after the fire to measure LA concentrations in air at varying

distances in close proximity to the prescribed understory burn area to provide information on the

potential for offsite migration of LA. Soil samples will be collected prior to the burn and following

the mop-up activities to provide measured data on LA concentrations in soil under pre- and post-

burn conditions. Finally, ash samples will be collected from the burn area prior to conducting mop-

up activities to provide measured data on LA levels in the ash following the burn.

The burn will be performed in accordance with all requirements and recommendations of the USFS

for conducting controlled prescribed understory burns and in basic accordance with the Prescribed

Fire Guidelines established by the Montana Department of Natural Resources and Conservation

(MDNRC 2007). Appendix G (Prescribed Burn Plan) provides specific details on how the burn will

be conducted. All sampling and burn activities will be performed by Grace’s contractors in strict

adherence with this QAPP.

Detailed information on the sampling design is provided below. As appropriate, Grace may collect

duplicate samples for their own use and evaluation; collection, preparation, and analysis methods

for these duplicate samples are not discussed in this QAPP.

B1.1 Sampling Location

Available data on levels of LA measured in tree bark, soil, and duff indicate that the levels of LA tend

to decrease with distance away from the mine. The approach that will be taken is to collect ABS

samples in an area that is representative of high potential LA exposure (e.g., in an area of OU3 that

is predominantly downwind from the mine where the highest concentrations of LA have been

reported in tree bark and duff). It is assumed that the risks calculated at this location are equal to or

greater than the risks at equal distances from the mine in the crosswind and upwind directions at

distances that are further from the mine. This approach will help ensure that assumed risks at other

OU3 locations under similar burn conditions are more likely to be overestimated than

underestimated.

Figure B-2 presents the general area identified for conducting the controlled prescribed

understory burn activities. The ABS area is located about 1 mile downwind (northeast) from the

mine and is bounded by four sampling stations where some of the highest LA concentrations have



been measured in duff. This area also coincides with the location where the commercial logging

ABS investigation was conducted in 2012. The actual location selected within this area will depend

upon the ease of access, availability of material utilized for prescribed understory burn activities,

and area requirements to safely conduct a controlled prescribed understory burn. In general, an

area of approximately 0.1 acres (4,356 ft2) in size will be constructed for the prescribed understory

burn activities. Details on the construction of the burn area and performance standards are detailed

below.

If deemed to be needed to support risk management decisions, additional ABS at locations further

from the mine (i.e., with lower potential LA exposures) may be evaluated in the future. If any

additional sampling efforts are needed, investigation-specific QAPPs for these efforts will be

generated prior to sample collection.

B1.2 Construction of Prescribed Understory Burn Area

Prescribed Understory Burn Area

As stated previously, a 0.1-acre area will be demarcated for the prescribed understory burn

activities. Guidelines detailed in the Prescribed Burn Plan (Appendix G) shall be followed at all

times (pre-fire, during-fire, post-fire). In general, the prescribed understory burn area will consist

of primarily flash fuels and ground fuels. Because this study is to represent an understory burn,

caution should be taken as to ensure ignition of aerial fuels do not occur in the specific area

selected.

Fire Line

In areas where fire line will be constructed, a continuous mineral soil line one bulldozer blade-

width wide (approximately 8 feet) will be cleared completely to expose mineral soil. The maximium

size of the fire line and fire break (see below) is dependant upon the fire behavior and fuels present

at the burn area. The Prescribed Burn Plan (Appendix G) will be consulted regarding information

on fire line, fire break, fire behavior, and fuels present. In general, the mineral soil line will not be

any deeper than to expose mineral soil. All material removed in the construction of the fire line will

be placed outside of the fire line and scattered so combustable materials do not exist next to the fire

line. Acceptable equipment for fire line and fire break construction is an excavator or bulldozer

equipped with an approved bucket and a thumb.

Fuel Break

Construction of a fuel break may not be necessary to complete this study and is dependent upon

fuels and conditions present at the selected site. The Prescribed Burn Plan (Appendix G) should be

reviewed prior to constructing the fuel break. If necessary, fuel breaks will be constructed to a

minimum width of 20 feet, where all woody debris (fuels larger than 1 inch in diameter and 4 feet

in length) are removed to break the continuity of the fuel bed. Material cleared in the fuel break

construction will be placed on a designated side of the fire line, and be relatively free of mineral soil,



and scattered to ensure combustible materials are not greater than 2 feet in height near the fire

line.

B1.3 Personal Air Monitoring

The purpose of the personal air monitoring is to measure LA levels in air to characterize exposures

associated with firefighting activities. As described above, this will be achieved by conducting a

controlled prescribed understory burn. There are two different ABS activities for which personal

air monitoring will be performed: during the burn and during mop-up activities. Each of these ABS

activities are described in more detail below.

For both personal monitoring ABS activities, personnel will wear two air monitors during the

activity (i.e., a high volume pump and a low volume pump) to allow for the collection of two

replicate filters (i.e., each filter represents the same sample collection duration, but different total

sample air volumes). Only one of the two resulting air filters will be selected for analysis (see

Section B4), the other filter replicate will be archived. Initially, the low flow pump will be set to a

flow rate of 2 liters per minute (L/min) and the high flow pump will be set to a flow rate of 4 L/min.

At the beginning of the sampling program, flow rates may be checked more frequently as conditions

permit to establish expected conditions.

B1.3.1 During the Fire

The primary purpose of this ABS activity is to capture LA exposures related to smoke releases and

to characterize exposures representative of initial attack firefighting activities.

Personal air sampling pumps (i.e., a high volume pump and a low volume pump) will be activated

once the fire is ignited. Two ABS personnel will move around the edges of the fire line, monitoring

for spot fires, and ensuring the fire perimeter is not compromised during the prescribed fire. ABS

personnel will be equipped with hand tools (e.g., Pulaski, lady shovel, rhino, combi tool, Mcleod

tool) during this activity for fire suppression. ABS personnel will wear thermometers to monitor

temperatures during the burn activity. Personnel will move no closer to the fire than the distance

where the temperature is at or below 120 degrees Fahrenheit (°F).

Air cassettes will be changed out every 15 minutes throughout the duration of the ABS activity to

avoid overloaded filters. Based on an anticipated burn time of one hour, it is expected that a total of

8 personal ABS air samples will be collected (4 high volume filters and 4 low volume filter

replicates) and 4 samples will be analyzed (the other 4 replicate filters will be archived).

B1.3.2 During Mop-Up Activities

The primary purpose of this ABS activity is to capture LA exposures related to disturbances of ash

and soil in the burn area to characterize exposures representative of mop-up firefighting activities.

[Note: Prior to conducting mop-up activities, a representative sample of the ash material should be

collected (see Section B2.2.3).]



Once all creeping flames have been extinguished and the entire burn area has been deemed safe for

personnel to enter by the Prescribed Burn Fire Boss, the two ABS personnel (trained Grace

contractors) will activate their air sampling pumps (i.e., a high volume pump and a low volume

pump) and will enter the burn area and simulate mop-up fire suppression activities using hand

tools (i.e., a Pulaski axe, fire rake, Mcleod tool). The mop-up activity will consist of bone piling; cold

trailing; and mixing, stirring, and digging up the mineral soil. This ABS activity will be performed for

a total of one hour and will include both a dry mop-up scenario (i.e., where no water is applied

during the mop-up activity) and a wet mop-up scenario (i.e., where water is applied during the

mop-up activity). The first 30 minutes of the activity two ABS personnel will conduct dry mop-up

activities. The last 30 minutes, mop-up activities will be conducted with additional water being

applied as needed to simulate wet mop-up conditions.

Air cassettes will be changed out every 15 minutes to avoid overloading filters. It is expected that a

total of 16 personal ABS air samples will be collected and 8 samples will be analyzed (4 samples

during dry mop-up and 4 samples during wet mop-up); the remaining 8 filter replicates will be

archived.

B1.4 Perimeter Air Monitoring

The purpose of the perimeter air monitoring is to measure LA levels in air near the burn to monitor

if there is potential for offsite migration of LA in smoke. A number of perimeter monitors will be

used to collect air samples before, during, and after the burn event. These perimeter monitors will

be mounted on a tripod to collect samples within the typical breathing zone at a height of

approximately 5-6 feet from the ground.

Because it is possible that wind direction may vary during the ABS activities, a total of 12

monitoring stations will be placed around the perimeter of the burn area. The stations will be

placed approximately 50, 100, and 200 feet away from the edge of the fire line nearest to the burn

area. Four monitoring stations for each distance interval will be positioned at approximately each

compass direction. Each monitoring station at a distance of 50 feet will have both a high volume

pump and a low volume pump – to allow for the collection of two replicate filters (i.e., each filter

represents the same sample collection duration, but different total sample air volumes). Only one of

the two resulting air filters will be selected for analysis (see Section B4). Initially, the low flow

pumps will be set to a flow rate of 2 L/min and the high flow pumps will be set to a flow rate of 4

L/min. Each monitoring station at a distance of 100 feet and 200 feet will have a single high volume

pump set to a flow rate of 4 L/min.

B1.4.1 Pre-Burn Sampling

To provide measured data on air concentrations prior to the burn (i.e., under baseline conditions),

the perimeter air monitors will be activated one day prior to the actual burn event (after the

creation/demarcation of the controlled prescribed understory burn area). During pre-fire sampling,

only the four monitoring stations located 50 feet from the edge of the fire line will be activated. The

pre-fire sampling event will have a sampling duration of approximately four hours.



B1.4.2 During-Burn Sampling

During the controlled prescribed understory burn activity, all 12 perimeter monitoring stations

(four monitoring stations at each of three distances – 50, 100, and 200 feet) will be activated when

the fire is ignited. Temperature will be monitored at each 50-foot perimeter monitor to ensure that

the temperature is at or below 120°F. This monitoring can be accomplished either using a hand-

held temperature gauge or small dedicated thermometers attached to the sampling pumps. As

necessary, to avoid damaging the air sampling equipment, the monitors may be moved further

away from the fire if temperatures become too high. To limit the amount of particulate loading on

the filter, air cassettes will be changed out every two hours throughout the duration of the burn and

the subsequent mop-up ABS activities.

On the day of the burn, meteorological data should be used to determine the predominant wind

direction (see Section B2.3); this information should be recorded in the field logbook. For samples

collected from stations located 100 feet and 200 feet from the edge of the fire line, analysis priority

should be given to those samples collected in the downwind direction (i.e., air samples in the

downwind direction should be analyzed first and samples in the upwind or crosswind direction

should be analyzed only after the downwind samples have been completed).

B1.4.3 Post-Burn Sampling

Following the fire, perimeter air samples will be collected for two additional days from each of the

four sampling stations located 50 feet from the edge of the fire line to determine if LA fibers remain

in the air or are dispersed by the wind, or if continuing releases are occurring from the burn area.

On each day, two samples will be collected from each of the four perimeter air monitors. One set of

samples will be collected during the morning (e.g., at approximately 8:00 AM) and the second set

will be collected during the afternoon (e.g., approximately 1:00 PM). Each sample will be collected

for a duration of four hours.

B1.5 Duff, Tree Bark, Ash, and Soil Sampling

Section B2.2 provides detailed information on how duff, tree bark, ash, and soil samples will be

collected. Figure B-1 illustrates the timing of the media collection. As illustrated, in the week prior

to the prescribed understory burn activities, a total of five duff samples, five tree bark samples, and

three soil samples will be collected from the immediate prescribed burn area. Once the prescribed

burn has been completely extinguished and the entire burn area has been deemed safe for

personnel to enter, an ash sample from within the burn area will be collected prior to mop-up

activities. Following mop-up activities, three soil samples will be collected from the burn area.

B1.6 Study Variables

The level of LA in air under source disturbance activities could depend on factors that vary (e.g., fire

intensity, moisture content of the source materials, wind speed, humidity, etc.). ABS will be

performed under conditions that have a high probability of resulting in measureable ABS air



concentrations of LA (i.e., activities will be performed in an area with higher LA source material

concentrations). As discussed in Section B2.3, a variety of meteorological data will be collected to

document these factors. In addition, data will be collected to characterize the nature of the source

material that will be burned (see Section B3.1.1).

B1.7 Critical Measurements

The critical measurements for this project are measurements of the concentration of LA in air

during a low-intensity, controlled prescribed understory burn within OU3 at a location that is

expected to have high-end levels of LA contamination in source materials (i.e., duff, soil, tree bark,

ash). The analysis of LA may be achieved using several different types of microscopes, but EPA

(2008a) recommends using TEM because this analytical method has the ability to clearly

distinguish asbestos from non-asbestos structures, and to classify different types of asbestos (i.e.,

LA, chrysotile). In addition, analysis by TEM provides structure-specific dimensions that allow for

the estimation of PCM-equivalent4 (PCME) concentrations, which is the concentration metric

necessary to estimate exposure and risks.

B1.8 Data Reduction and Interpretation

Air samples collected in the field will be used to prepare grids for TEM examination (see Section

B4). From this examination, the total number of PCME LA structures observed is recorded and the

air concentration is calculated as follows:

Cair = (N ∙ EFA) / (GOx ∙ Ago ∙ V ∙ 1000 ∙ f)

where: Cair = Air concentration (structures per cubic centimeter [s/cc])

N = Number of PCME LA structures observed (structures)

EFA = Effective filter area (square millimeters, mm2)

GOx = Number of grid openings examined

Ago = Area of a grid opening (mm2)

V = Sample air volume (liters, L)

1000 = L/cc (conversion factor in liters per cubic centimeter)

f = Indirect preparation dilution factor (equal to 1 for direct preparation)

Data for PCME LA concentrations in air will be used to evaluate potential human health risks from

LA for firefighters responding to low-intensity, small-scale wildfires in the forest downwind of the

mine.

4 PCME structures have a length greater than 5 micrometers (µm), width greater than or equal to 0.25 µm, and aspect ratio (length:width) greater than or equal to 3:1.



B2. SAMPLING METHODS, INSTRUMENTATION, AND DOCUMENTATION

B2.1 Air Sample Collection

Air samples will be collected, handled, and documented in basic accordance with the procedures

specified in OU3-specific standard operating procedures (SOP) ABS-LIBBY-OU3, Activity-based

Sampling for Asbestos, (see Appendix B). In brief, a battery-powered air sampling pump (SKC

model AirChek XR5000 TM [0.005-5.0 L/min] or similar) will be worn by the ABS participant or set

on stationary stands around the perimeter of activities. The monitoring cassette will be attached to

the pump via a plastic tube, and affixed such that the cassette is within the breathing zone

(approximately 5-6 feet from the ground surface). All air samples will be collected using cassettes

that contain a 25-millimeter (mm) diameter mixed cellulose ester (MCE) filter with a pore size of

0.8 micrometers (μm).

As described above, two different sampling pumps will be used – a high volume pump and a low

volume pump – to allow for the collection of two replicate filters (i.e., each filter represents the

same sample collection duration, but different total sample air volumes). Only one of the two

resulting air filters will be selected for analysis (see Section B4). Initially, the low flow pumps will

be set to a flow rate of 2 L/min and the high flow pumps will be set to a flow rate of 4 L/min.

Each air sampling pump will be calibrated at the start of each ABS sampling period using a

rotameter that has been that has been calibrated to a primary calibration source (e.g., BIOS

DryCal® or similar). Section B6/B7.1 provides detailed information on calibrating the sampling

pump. At the beginning of the sampling program, flow rates may be checked more frequently as

conditions permit to establish expected conditions.

B2.2 Duff, Tree Bark, Ash, and Soil Sample Collection

The following sections describe the sample collection procedures for the collection of duff, bark,

ash, and soil. Note that source material sampling should be conducted in a way that minimizes

trampling or disturbance of duff, litter, and surface fuels because such trampling may impact the

behavior of low-intensity fires.

B2.2.1 Duff Sampling

Within the selected area for prescribed burn activities, five 5-point composite samples of duff

material will be collected, handled, and documented in general accordance with SOP EPA-LIBBY-

2012-11, Sampling and Analysis of Duff for Asbestos (see Appendix B), with the following project

modifications:

Each 5-point aliquot sampling point should be chosen randomly such that the entire burn

area is represented without duplicating any sample points.

Enough duff material will be collected from each sub-location such that the composite

sample fills a one-gallon zip-top bag.



In brief, at each specified sampling point, any fresh or partially decayed organic debris (e.g., twigs,

leaves, pine needles, fallen tree bark) will be collected by hand from the soil surface, taking care to

ensure that the top layer of soil beneath the organic debris is not included in the duff material

sample.

B2.2.2 Tree Bark Sampling Within (or as near as possible to) the selected area for prescribed burn activities, a hole saw will be

used to collect a circular bark cores for analysis of LA by TEM. A total of five tree bark samples

(representing 15 individual trees) will be collected, handled, and documented in general

accordance with standard operating procedure (SOP) EPA-LIBBY-2012-12, Sampling and Analysis of

Tree Bark for Asbestos (see Appendix B), with the following project modifications:

Trees selected for sampling will be selected such that trees within entire burn area are

represented. If available, representative trees with a large diameter and rough bark will be

selected preferentially.

Each tree bark sample will consist of a three-tree composite (i.e., the cores from three

individual trees will be placed into a single zip-top bag). If possible, cores from similar trees

should be composited together.

Sampling will be conducted at a height of approximately two feet above the ground surface

to represent the area of the tree likely to be burned during the understory burn. Cores

should be collected from the side of the tree facing the mine (i.e., the windward side).

Decontamination or use of new hole saws is not necessary between collecting cores for the

three trees within the same composite sample. Decontamination or the use of a new hole

saws is required between composite samples.

It is not anticipated that the same tree will need to be located for future sampling activities,

so flagging tape/identification (ID) tags will not be left on the tree. Global positioning

system (GPS) coordinates will be collected for each tree sampled.

The collection of tree age cores is not necessary for this project.

B2.2.3 Ash Sampling

There is no existing SOP for the collection of ash material. Once the burn area is safe to enter

following the burn event by the Prescribed Fire Burn Boss, ash will be collected manually using a

trowel, in basic accordance with OU3 SOP No. 1, Soil Sampling for Non-Volatile Organic Compound

Analysis (see Appendix B). In brief, prior to conducting the mop-up ABS scenario, representative

ash material should be collected from the ground surface (approximately 0-1 inches) and placed in

a lidded one-gallon capacity metal container. Material should be collected from a minimum of 30

sampling points across the burn area; a minimum of 300 grams of ash should be collected.

After collection, the container should be delivered (under chain-of-custody [COC]) to the Sample

Preparation Facility (SPF) in Troy, MT. At the SPF, the contents of the container will be

homogenized by rolling the closed container back and forth on the ground. After homogenization,

three samples of approximately 50 grams of ash will be removed from the container and placed into

a zip-top bag for analysis of LA by TEM (see Section B4). Each ash sample will be assigned a unique



sample ID label, which will be provided by the field team (see Section B3.2). The remaining ash

material archived in the one-gallon container will be for possible future use in ABS or additional

TEM analysis. Ash sample information will be recorded on the soil-like FSDS form.

B2.2.4 Soil Sampling Prior to conducting the burn and following the mop-up scenario, surface soil will be collected

manually using a shovel/trowel, in basic accordance with OU3 SOP No. 1, Soil Sampling for Non-

Volatile Organic Compound Analysis (see Appendix B). In brief, three 30-point composite samples

will be collected from within the burn area. Each 30-point aliquot sampling point should be chosen

randomly such that the entire burn area is represented without duplicating any sample points.

Sample aliquots will be collected from a depth of 0-6 inches below ground surface and be free of

twigs, leaves, and any other vegetative material. Each 30-point composite sample will be

homogenized by hand and will fill the zip-top bag approximately one quarter to one third full

(between 40 and 58 cubic inches of material).

B2.3 Meteorological Data

Meteorological data will be collected for each day that sampling occurs (i.e., pre-burn, during burn,

post-burn). Meteorological data will be collected using a Davis Instruments 6250 Vantage Vue

wireless weather station and associated WeatherLink data logger (or similar). The following

parameters will be recorded at approximately 2-minute intervals at the burn location:

Temperature (F)

Relative humidity (percent)

Wind speed (miles per hour [mph])

Wind direction

Precipitation (inches)

Barometric pressure

Dew point (F)

Although wind speeds are normally measured at 20 feet (in the U.S.) or 10 meters (internationally),

in this case, a Davis Instruments mounting tripod will be used to mount the weather station in close

proximity to the burn site at a height of approximately 5-6 feet above ground level (head height).

This will provide measurements that are more representative of wind conditions affecting the fire

front and personnel on the ground than would measurements at a height of 20 feet. Manual

measurements will be made by a fire observer using a sling psychrometer and hand held

anemometer (e.g., Kestrel) during the prescribed burn and mop up activities.

B2.4 Fuel Characterization

B2.4.1 Fuel Moisture

Fuel moisture content will be characterized following USFS recommendations (Zahn and Henson

2011). Fuel moisture samples will be collected from inside the burn area in a way that minimizes



trampling or disturbance of duff, litter, and surface fuels because such trampling may impact the

behavior of low-intensity fires. High temperature polypropylene bottles (e.g., 250-ml to 500-ml

capacity) will be used to collect samples of dead and down fuels, live fuels, and duff. For dead fuels,

at least three samples and as many as 10 samples (time and conditions permitting) will be collected

for each time lag size class (1-hour, 10-hour, 100-hour, and 1,000-hour). One-hour time lag fuels

will be collected immediately before ignition. Supplemental fine fuel moisture samples will be

collected if meteorological or fire behavior evidence suggests a significant change in 1-hour

moisture contents may be occurring. For live fuels, at least three samples will be collected for each

predominant live species present in the understory. The latitude and longitude of each sampling

location will be recorded. After collection, samples will be tightly sealed in individually and

uniquely labeled sample containers. The bottle and the sample will be weighed on a scale with a

resolution of 0.1 g or better. The sample containers will then be opened and dried in a mechanical

convection oven, located at the Grace Flyway property by BHI, at 105 ºC for 24 hours. After samples

have been removed from the oven and cooled, they will be re-weighed and fuel moisture content

(FMC) of each sample will be calculated as:

weighttarecontainer - sampledry ofweight

sampledry of weight - sample wet ofweight 100FMC

Fuel moisture bottles should be resealed immediately upon removal from the oven and cooled in a

sealed condition to preclude reabsorption of moisture from the atmosphere. Fuel moisture samples

will be analyzed by the methods specified in A Synthesis of Fuel Moisture Collection Methods and

Equipment – A Desk Guide (Zahn and Henson 2011). All analysis for fuel moisture content will be

performed by Wildland Fire Associates at the Grace Flyway property located in Lincoln County,

Montana.

Fuel moisture samples will follow the same sample and labeling requirements as described in

Section B3.2. All fuel moisture content sample and analysis information will be documented in the

field logbook and uploaded to the OU3 eRoom.

B2.4.2 Fuel Load

In addition to fuel moisture content, fuel load characterization will be documented. Pre-fire fuel

load inside the burn area will be documented with a photographic series and conducted in a way

that minimizes trampling or disturbance of fuels (see Section B3.1.2 for details on photographic

documentation requirements). Fire personnel will determine a representative fire behavior fuel

model or fuel models.

B2.5 Global Positioning System Coordinate Collection

Global Positioning System (GPS) coordinates will be recorded for each stationary perimeter

monitor, each sampled tree, and at a central location for composite samples of duff, soil, and ash. In

addition, GPS coordinates should be obtained to provide the spatial extent of the burn area and key



features (i.e., fire line, fuel break locations). GPS location coordinates will be collected in general

accordance with OU3-specific SOP No. 11, GPS Data Collection (see Appendix B).

B2.6 Equipment Decontamination

B2.6.1 Sampling Equipment

Decontamination of non-disposable sampling equipment will be conducted in basic accordance

with the procedures specified in OU3-specific SOP No. 7, Equipment Decontamination (see

Appendix B). Materials used in the decontamination process will be disposed of as investigation-

derived waste (IDW) as described below.

B2.6.2 Heavy Equipment

Before use on OU3, all vehicles and equipment will be thoroughly cleaned to reduce the level of

effort and water needed for post-ABS decontamination. Field personnel will thoroughly

decontaminate any vehicle or equipment prior to leaving the mine. A competent person will inspect

decontaminated vehicles prior to leaving the decontamination pad.

Before being taken off use from the project or before use in a clean area, all heavy equipment must

undergo a full interior and exterior decontamination by the designated personnel. Full

decontamination includes removing protective plating (skid plates), pressurized washing of all

surfaces, cleaning the interior of the engine compartment, cleaning of the undercarriage, cleaning of

the track adjusters, removing floor mats, and an extensive cleaning and wipe-down of the cab. In

addition, designated personnel will remove, replace, and dispose of any air filters (air-intake, cab,

etc.) from equipment and vehicles that have been in OU3. All filters from equipment that have been

in OU3 will be disposed of as asbestos-containing material (ACM).

An inspector will evaluate and document the decontamination before moving or using the

equipment. The inspector will fill out a Decontamination Checklist (see Appendix D). A copy of this

form will be posted to the OU3 eRoom along with the field sample documentation.

B2.7 Handling Investigation-derived Waste

Any disposable equipment or other IDW will be handled in basic accordance with the procedures

specified in OU3-specific SOP No. 12, IDW Management (see Appendix B). In brief, IDW will be

double bagged in clear heavy-weight trash bags with ‘IDW’ written, in large letters at least 3 inches

high, in indelible ink on at least two sides of the outer bag. All IDW generated during this sampling

program will enter the waste stream at the local class IV asbestos landfill.



B3. SAMPLE HANDLING AND CUSTODY

B3.1 Sample Documentation

B3.1.1 Field Sample Data Sheets and Logbooks

As noted previously in Section A9, the field team will record sample information for all air, soil,

bark, duff, and ash samples in accordance with the procedures specified in OU3-specific SOP No. 9,

Field Documentation (see Appendix B), with the following project-specific modifications:

Samples for this project will be documented on the study-specific FSDS forms for each type

of sample, as provided in Appendix H.

Use of large container labels (in addition to sample ID labels) is not required.

On the perimeter air FSDS form, the location ID should specify the distance and the compass

direction from the burn area for each station (e.g., 50-N would be the location 50 feet from

the burn area that is to the north, 100-S would be the location 100 feet from the burn area

that is to the south).

The field logbook is an accounting of activities at the Site and will duly note problems or deviations

from the governing QAPP or SOPs. Separate field logbooks will be kept for each study and the cover

of each field logbook will clearly indicate the name of the associated study. Field logbooks will be

completed prior to leaving a sampling location. Field logbooks will be checked for completeness on

a daily basis by the FTL or their designate. When incorrect field logbook completion procedures are

discovered during these checks, the errors will be discussed with the author of the entry and

corrected. Erroneous information recorded in a field logbook will be corrected with a single line

strikeout, initial, and date. The correct information will be entered in close proximity to the

erroneous entry.

In addition, the nature of the materials and conditions under which the study is conducted will be

documented in the field logbook. This information includes but is not limited to, qualitative

description of burn area (e.g., fuels present), flame height, wind direction, and meteorological

conditions.

B3.1.2 Photographic and Video Documentation

Photographs will be taken to document representative examples of sampling locations and site

conditions during air sampling activities, and at any other location the field sampling personnel

determine necessary, using a digital camera.

Digital video will be captured to document representative examples of smoke movement during the

fire and ABS activities. Prescribed burn and mop-up activities will be documented with four

stationary high definition (1080p) digital video cameras. Local smoke movement will be recorded

with three local cameras positioned on tripods mounted along the perimeter of the burn area. The



purpose of these cameras is to capture local smoke transport in the vicinity of the fire line and the

firefighting activities. Although nominally equal spacing between cameras may be desirable, siting

of these cameras is deferred until immediately prior to the burn so that considerations related

topography, predominant wind direction, and visibility obstruction may be adequately considered

in order to determine optimal camera locations. Large-scale smoke transport will be captured with

a fourth camera positioned near the top of Vermiculite Mountain (or another nearby

summit/ridge). In addition to the four fixed cameras, each firefighter participating in the activity-

based sampling will be fit with a mobile GoPro Hero 4 (or similar) camera. These mobile cameras

provide a first person perspective to potential smoke and dust/ash exposure during the prescribed

burn, dry mop up, and wet mop up activities and complement the perspective obtained from the

fixed cameras.

Electronic copies of all digital photographs and video will be posted at the end of the simulated fire

event to the OU3 eRoom. The file name should include the corresponding sampling location and/or

sample number and the photograph date (e.g., OU3Burn_UB-00001_05-05-15).

B3.2 Sample Labeling and Identification

Samples will be labeled with sample ID numbers supplied by field administrative staff and will be

signed out by the sampling teams. For air samples, one sample label will be placed on the sampling

cassette, one sample label will be affixed to the inside of the plastic bag used to hold the sampling

cassette during transport. In addition, the sample ID number will also be written on the outside of

the plastic bag. For duff, tree bark, and soil samples, the labels will be affixed to the outside of both

the inner and outer sample bags and the sample ID number will be written on the outside of each

bag.

Sample ID numbers will identify the samples collected during this sampling effort using the

following format:

UB-0####

where:

UB-0 = A sample ID prefix to identify samples collected under this prescribed Understory

Burn effort #### = A sequential four-digit number

At the time of ash collection, the field team will assign three unique sample ID numbers to the one-

gallon container. These three sample IDs will be recorded on the FSDS and the COC. The field teams

will relinquish the ash container to the SPF in Troy. SPF personnel will collect three 50-gram

samples from the ash container and assign these samples the three sample IDs as provided on the

ash container. (The field team should provide sample labels to the SPF for this purpose at the time

custody is transferred for the one-gallon ash container.) For ash samples, the sample ID label will be

affixed to the outside of both the inner and outer sample bags and the sample ID number will be

written on the outside of each bag.



B3.3 Field Sample Custody

Field sample custody will follow the requirements specified in OU3-specific SOP No. 9 (see

Appendix B). In brief, all teams will ensure that samples, while in their possession, are maintained

in a secure manner to prevent tampering, damage, or loss. All samples and FSDSs will be

relinquished by field staff to the field sample coordinator, the SPF, or a designated secure sample

storage location at the end of each day.

B3.4 Chain of Custody

The COC record is employed as physical evidence of sample custody and control. This record

system provides the means to identify, track, and monitor each individual sample from the point of

collection through final data reporting and to identify the type of analysis requested. A completed

COC form specific to the Libby OU3 sampling is required to accompany each shipment of samples.

Sample custody will be maintained until final disposition of the samples by the laboratory and

acceptance of analytical results by the EPA.

OU3-specific COC forms can be obtained from the OU3 eRoom (an example of this form is provided

OU3-specific SOP No. 9; see Appendix B). In brief, the field sample coordinator will prepare a hard

copy COC form using the 3-page carbon copy forms developed specifically for use in OU3. One copy

of the COC will be retained by the field sample coordinator and the other two copies (including the

original) of the COC will accompany the sample shipment. All required paper work, including

sample container labels, COC forms, custody seals and shipping forms will be fully completed in

indelible ink (or printed from a computer) prior to shipping of the samples to the laboratory. Each

COC form will include signatures of the appropriate individuals indicated on the form. In addition,

the air volume for each sample should be recorded on the COC form. All samples that may require

special handling by laboratory personnel to prevent potential exposure to LA or other hazardous

substances will be clearly labeled. In addition, for perimeter air samples collected from stations

located 100 feet and 200 feet from the edge of the fire line, the COC should specify the analysis

priority (i.e., samples collected in the downwind direction should be analyzed first).

If any errors are found on a COC after shipment, the hard copy of the COC retained by the field

sample coordinator will be corrected and a corrected COC will be provided to the LC for

distribution to the appropriate laboratory. All corrections to the COC form will be initialed and

dated by the person making the corrections.

B3.5 Sample Packaging and Shipping

Samples will be packaged and shipped in basic accordance with the procedures specified in OU3-

specific SOP No. 8, Sample Handling and Shipping (see Appendix B). The field sample coordinator

will deliver all samples to the SPF in Troy, Montana (see below). Prior to sealing the shipping

container, the field sample coordinator will complete the bottom of the COC record and retain the

bottom copy of the COC record for the project record.



ESATR8-Troy Soil Prep Facility

303 N. 3rd Street

Troy, Montana 59935

406-295-9151

Contact: Andrea Wandler

The LC will instruct the Troy SPF sample coordinator as to the appropriate laboratory for each

sample shipment. For the purposes of this sampling investigation, it is anticipated that all samples

will be shipped to one of the following labs for analysis:

Laboratory Contact Phone Address Contact email

ESATR8-Golden Doug Kent / Nathan DelHierro

(303) 312-7725 / (303)-312-7790

16194 W 45th Drive Golden, CO 80403

[email protected] [email protected]

EMSL22 - Denver Barbara Shepherd (303) 740-5700 1010 Yuma Street Denver, CO 80204

[email protected]

EMSL04 - Cinnaminson

Robyn Ray / Steven Seigel

(856) 303-2556 / (856) 303-2555

200 Route 130 North Cinnaminson, NJ 08077


EMSL03 - Manhattan

James Hall / Jose Arriaga

(646) 430-8584 / (866) 448-3675

307 W 38th Street, Suite 901 New York, NY 10018


Samples will be shipped via an overnight delivery service using a commercial carrier (e.g., FedEx).

B3.6 Holding Times

There are no holding time requirements for the air, duff, tree bark, soil, or ash samples collected as

part of this sampling investigation.

B3.7 Archival and Final Disposition

All sample materials, including air filters and TEM grids will be maintained in storage at the

analytical laboratory unless otherwise directed by EPA. When authorized by EPA, the laboratory

will be responsible for proper disposal of any remaining samples, sample containers, shipping

containers, and packing materials in accordance with sound environmental practice, based on the

sample analytical results. The laboratory will maintain proper records of waste disposal methods,

and will have disposal company contracts on file for inspection.

B4. ANALYTICAL METHODS

This section discusses the analytical methods and requirements for samples collected in support of

this sampling investigation during a simulated forest fire. This section includes detailed information

on the analysis of air as well as the data reporting requirements, sample holding times, and custody

procedures.

An analytical requirements summary sheet (BURNOU3-0515), which details the specific

preparation and analytical requirements associated with this sampling program, is provided in

Appendix C. The analytical requirements summary sheet will be reviewed and approved by all








participating laboratories in this sampling program prior to any sample handling. The appropriate

analytical requirements summary sheet identifier and media code (i.e., BURNOU3-0515, Media

Code A) will be included on each COC.

B4.1 Analysis of LA in Air

The DQOs for this QAPP (see Appendix A) provide detailed information on the sample preparation,

analysis method, counting rules, and stopping rules for air samples. All air samples collected during

this investigation will be analyzed by TEM using International Organization for Standardization

(ISO) Method 10312:1995(E) (ISO 1995). Analysis requirements for the TEM analysis are

summarized below.

B4.1.1 Sample Preparation

As described above, for the personal and perimeter ABS air samples, two filters are collected – a

high volume filter and a low volume filter. The high volume filter will be analyzed in preference to

the low volume filter. The high volume filter will be used to prepare a minimum of three grids using

the grid preparation techniques described in Section 9.3 of ISO 10312:1995(E).

If the high volume filter is deemed to be overloaded (i.e., > 25% particulate loading on the filter),

the low volume filter will be analyzed in preference to performing an indirect preparation on the

high volume filter. If the low volume filter is also deemed to be overloaded, an indirect preparation

(with ashing) will be performed of the high volume filter in accordance with the procedures in

Libby-specific SOP EPA-LIBBY-08, Indirect Preparation of Air and Dust Samples for Analysis by TEM

(see Appendix B), as modified by Libby-specific laboratory modification5 #LB-000091. The

resulting secondary filter will be used to prepare a minimum of three grids using the grid

preparation techniques described in Section 9.3 of ISO 10312:1995(E).

B4.1.2 Analysis Method and Counting Rules

Grids will be examined by TEM in basic accordance with the recording procedures described in

Annex E of ISO 10312:1995(E), as modified by the most recent versions of Libby laboratory

modifications LB-000016, LB-000029, LB-000066, LB-000067, and LB-000085.

In brief, grids will be examined by TEM under low magnification (~5,000x), recording only those

structures that meet PCME counting rules. All amphibole structures that have appropriate selected

area electron diffraction (SAED) patterns and EDS spectra, and having length > 5 µm, width greater

than or equal to (≥) 0.25 µm, and an aspect ratio (length:width) ≥ 3:1, will be recorded. Detailed

structure results for each grid opening and structure examined will be recorded on the benchsheet

and entered into the Site-specific TEM EDD spreadsheet developed for reporting air sample results.

If observed, chrysotile structures will be recorded using the same procedures described above, but

structure recording may stop after 25 chrysotile structures have been observed.

5 Copies of all Libby-specific laboratory modifications are located on the Libby Lab eRoom.



B4.1.3 Stopping Rules

Appendix A provides detailed information on the derivation of the stopping rules for air field

samples analyzed by TEM. The stopping rules are as follows:

1. Examine a minimum of two grid openings from each of two grids.

2. Continue examining grid openings until one of the following is achieved:

a. The target analytical sensitivity (0.002 per cubic centimeter [cc-1]) is achieved.

b. 25 PCME LA structures have been observed.

c. A total filter area of 7 mm2 has been examined (this is approximately 700 grid

openings).

When one of these criteria has been satisfied, complete the examination of the final grid opening and stop. For lot blanks and field blanks, the TEM analyst should examine an area of 0.1 mm2 (approximately 10 grid openings). B4.2 Analysis of LA in Ash


Ash samples will be prepared and analyzed in basic accordance with the procedures specified in

Section 6.2 of SOP EPA-LIBBY-2012-11, Sampling and Analysis of Duff for Asbestos (see Appendix

B). In brief, an aliquot of the ash material is acidified, suspended in water, and filtered. A total of

three replicate filters will be created and analyzed for each ash sample using additional aliquots of

the ash residue. Each filter will be used to prepare a minimum of three grids using the grid

preparation techniques described in Section 9.3 of ISO 10312:1995(E).


Grids will be examined by TEM using high magnification (~20,000x) in basic accordance with the

recording procedures described in ISO 10312:1995(E), as modified by SOP EPA-LIBBY-2012-11

and the most recent versions of Libby Laboratory Modifications LB-000016, LB-000029, LB-

000066, LB-000067, LB-000085, and LB-000091. In brief, all fibrous amphibole structures that

have appropriate SAED patterns and EDS spectra, and having length ≥ 0.5 µm and an aspect ratio

(length: width) ≥ 3:1, will be recorded. If observed, chrysotile structures will be recorded using the

same procedures described above, but structure recording may stop after 25 chrysotile structures

have been observed.


The stopping rules for the TEM analysis of ash materials are as follows:





a. The target analytical sensitivity (1E+07 per gram, dry weight [g-1]) is achieved.

b. 25 LA structures have been observed.

c. A total filter area of 1.0 mm2 has been examined (this is approximately 100 grid

openings).

When one of these criteria has been satisfied, complete the examination of the final grid opening and stop.

The results for each ash replicate analysis will be expressed in terms of LA structures per gram of

ash (dry weight).

B4.3 Analysis of LA in Duff

B4.3.1 Sample Preparation Duff samples will be prepared and analyzed in basic accordance with the procedures specified in

SOP EPA-LIBBY-2012-11, Sampling and Analysis of Duff for Asbestos (see Appendix B). In brief, each

sample is dried and ashed, and an aliquot of the resulting ash residue is acidified, suspended in

water, and filtered. The resulting filter will be used to prepare a minimum of three grids using the

grid preparation techniques described in Section 9.3 of ISO 10312:1995(E). Any remaining ash

material will be archived for possible future analysis.

B4.3.2 Analysis Method and Counting Rules Grids will be examined by TEM using high magnification (~20,000x) in basic accordance with the

recording procedures described in ISO 10312:1995(E), as modified by SOP EPA-LIBBY-2012-11. In

brief, all fibrous amphibole structures that have appropriate SAED patterns and EDXA spectra, and

having length ≥ 0.5 µm and an aspect ratio (length: width) ≥ 3:1, will be recorded.

B4.3.3 Stopping Rules The stopping rules for the TEM analysis of duff materials are as follows:



a. The target analytical sensitivity (1E+07 grams, dry weight-1) is achieved.



openings).

When one of these criteria has been satisfied, complete the examination of the final grid opening

and stop.



The results for each duff sample will be expressed in terms of LA structures per gram duff (dry

weight).

B4.4 Analysis of LA in Tree Bark


Tree bark samples will be prepared and analyzed in basic accordance with the procedures specified

in SOP EPA-LIBBY-2012-12, Sampling and Analysis of Tree Bark for Asbestos (see Appendix B), with

the following project modifications:

Only one 0.25-gram aliquot of the resulting ash residue (rather than the total mass) will be

filtered.

In brief, the three cores for each sample will be combined, dried, and ashed, and an aliquot of the

resulting ash residue will be acidified, suspended in water, and filtered. The resulting filter will be

used to prepare a minimum of three grids using the grid preparation techniques described in

Section 9.3 of ISO 10312:1995(E). Any remaining ash material will be archived for possible future

analysis.



recording procedures described in ISO 10312:1995(E), as modified by SOP EPA-LIBBY-2012-12. In

brief, all fibrous amphibole structures that have appropriate SAED patterns and EDXA spectra, and

having length ≥ 0.5 µm and an aspect ratio (length: width) ≥ 3:1, will be recorded.


The stopping rules for the TEM analysis of tree bark are as follows:



a. The target analytical sensitivity (100,000 cm-2) is achieved.



openings).


and stop.

The results for each tree bark sample will be expressed in terms of LA structures per cm2 of tree

bark (i.e., a surface area loading).



B4.5 Analysis of LA in Soil


Prior to analysis, all soil samples will be prepared at the SPF in Troy, MT. All soil samples will be

dried as detailed in Site-specific SOP 16-ASB-06.02, Soil Sample Preparation at the Troy Sample

Preparation Facility (see Appendix B). To avoid burning of the soil samples during the drying

process, the soil samples will be visually screened before they are loaded into the oven. Samples

that appear to have elevated organic matter (i.e., a significant amount of vegetation/sticks/roots)

pose a risk of igniting during the drying process. The samples will be checked every 4 hours to

ensure that they are not burning.

Each sample will be split into two approximately equal portions: 1) archive; 2) polarized light

microscopy (PLM) aliquot. The archive aliquot will be stored in accordance with SOP 16-ASB-06.02.

The PLM aliquot will be prepared using SOP 16-ASB-06.02. In brief, the PLM aliquot is sieved into

coarse (greater than ¼ -inch) and fine fractions. The fine fraction is ground to reduce particles to a

diameter of 250-μm or less; this fine-ground portion is then split into four aliquots.

B4.5.2 Analysis Method

One aliquot of the fine-ground sample will be analyzed for asbestos by PLM using visual area

estimation (PLM-VE) in accordance with SOP SRC-LIBBY-03, as modified by the most recent version

of Libby laboratory modification LB-000073. If there is a coarse fraction of the sample, it will be

analyzed for asbestos by PLM using gravimetric analysis (PLM-Grav) in accordance with SOP SRC-

LIBBY-01.

The analysis request section of the COC record will indicate the requested analyses (e.g., PLM-

VE/PLM-Grav). It is the responsibility of the soil preparation facility to specify the appropriate

analytical method as it corresponds to the specific sample fraction being submitted for analysis (i.e.,

PLM-VE for fine-ground fractions or PLM-Grav for coarse fractions) on the COC record that is

submitted to the analytical laboratory.

B4.6 Analysis of LA in Equipment Rinsates


Equipment rinsate samples will be prepared for asbestos analysis in basic accordance with the

techniques in EPA Method 100.2, as modified by the most recent version of Libby Laboratory

Modification LB-000020. In brief, water samples will be prepared using an ozone/ultraviolet

treatment that oxidizes organic matter that is present in the water or on the walls of the bottle,

destroying the material that causes clumping and binding of asbestos structures. Following

treatment, an aliquot of water (generally about 50 milliliters) will be filtered through a 25-mm

diameter polycarbonate filter with a pore size of 0.1 µm with an MCE filter (0.45-µm pore size) used

as a support filter.





recording procedures described in ISO 10312:1995(E), as modified by SOP EPA-LIBBY-2012-11

and the most recent versions of Libby Laboratory Modifications LB-000016, LB-000029, LB-

000066, LB-000067, LB-000085, and LB-000091. In brief, all fibrous amphibole structures that

have appropriate SAED patterns and EDS spectra, and having length ≥ 0.5 µm and an aspect ratio

(length: width) ≥ 3:1, will be recorded. If observed, chrysotile structures will be recorded using the

same procedures described above, but structure recording may stop after 25 chrysotile structures

have been observed.


The stopping rules for all equipment rinsate samples are as follows:



a. The target analytical sensitivity (50,000 L-1) is achieved.



openings).


and stop.

B4.7 Data Reporting

All TEM and PLM results, including analysis preparation information, structure-specific details, and

air concentrations, will be submitted using the most recent version of the EDDs6 in use at the Libby

site. Standard project data reporting requirements will be met for this dataset. Upon completion of

the appropriate analyses, EDDs will be posted to the Libby OU3 eRoom within the appropriate turn-

around time. Files should be posted to the folder titled “Understory Burn”.

An analytical data report will be prepared by the laboratory after the completion of all required

analyses within a specific laboratory job (or sample delivery group). This analytical data report may

vary by laboratory and analytical method but generally includes a case narrative that briefly

describes the number of samples, the analyses, and any analytical difficulties or QA/QC issues

associated with the submitted samples. The data report will also include copies of the signed COC

forms, analytical data summaries, a QC package, and raw data. Raw data is to consist of instrument

preparation logs, instrument printouts, and QC sample results including, instrument maintenance

records, COC check in and tracking, raw data instrument print outs of sample results, analysis run

logs, and sample preparation logs. Hard copies of all analytical laboratory data packages will be

scanned and posted as a pdf file to the Libby OU3 eRoom. File names for scanned analytical

6 The most current version of all EDDs are provided in the Libby Lab eRoom.



laboratory data packages will include the laboratory name and the job number to facilitate

document organization (e.g., LabX_12345-A.pdf). If the analytical laboratory data package is

revised, this should be denoted with a suffix in the file name (e.g., LabX_12345-A_Rev1.pdf).

All original data records (both hard copy and electronic) will be cataloged and stored in their

original form until otherwise directed by EPA.

B4.8 Analytical Turn-around Time

Analytical turn-around time will be negotiated between the EPA LC and the laboratory. It is

anticipated that turn-around times of 2-4 weeks are acceptable, but this may be revised as

determined necessary by EPA.

B4.9 Custody Procedures

Specific laboratory custody procedures are provided in each laboratory’s Quality Assurance

Management Plan, which have been independently reviewed at the time of laboratory procurement.

While specific laboratory sample custody procedures may differ between laboratories, the basic

laboratory sample custody process is described briefly below.

Upon receipt at the facility, each sample shipment will be inspected to assess the condition of the

shipment and the individual samples. This inspection will include verifying sample integrity. The

accompanying COC record will be cross-referenced with all of the samples in the shipment. The

laboratory sample coordinator will sign the COC record and maintain a copy for their project files.

Depending upon the laboratory-specific tracking procedures, the laboratory sample coordinator

may assign a unique laboratory identification number to each sample on the COC. This number, if

assigned, will identify the sample through all further handling at the laboratory. It is the

responsibility of the laboratory manager to ensure that internal logbooks and records are

maintained throughout sample preparation, analysis, and data reporting.

B5. QUALITY ASSURANCE/QUALITY CONTROL

B5.1 Field

Field QA/QC activities include all processes and procedures that have been designed to ensure that

field samples are collected and documented properly, and that any issues/deficiencies associated

with field data collection or sample processing are quickly identified and rectified. The following

sections describe each of the components of the field QA/QC program implemented at the Site.

B5.1.1 Training

Before performing field work in Libby, field personnel are required to read all governing field

guidance documents relevant to the work being performed and attend a field planning meeting



specific to the wildfire monitoring effort. Additional information on field training requirements is

provided in Section A8.1.

B5.1.2 Modification Documentation

Minor deviations (i.e., those that will not impact data quality or usability) encountered in day-to-

day field work will be noted in the field logbook. Major deviations from this QAPP that modify the

sampling approach and associated guidance documents will be recorded on a ROM form (see

Appendix E). Field ROMs will be completed by the FTL, or by assigned field or technical staff. Each

completed ROM is assigned a unique number that is specific to each investigation (e.g., OU3 Burn

LFM-OU3-01) by the EPA RPM or their delegate. Once a form is prepared, it is submitted to the EPA

RPM for review and approval. Copies of approved ROMs are available in the OU3 eRoom and are

posted to the OU3 website.

B5.1.3 Field QC Samples

Air

Two types of field QC samples will be collected as part of the air sampling portion of this program –

lot blanks and field blanks.

Lot Blanks

Lot blanks are collected to ensure air samples for asbestos analysis are collected on asbestos-free

filters. This will be accomplished by selecting two lot blanks at random from the group of cassettes

(manufactured lot) to be used for collection of air samples. It is the responsibility of the FTL to

submit the appropriate number of lot blanks to the laboratory prior to cassette use in the field. Each

lot blank will be analyzed for asbestos by TEM analysis as described above (see Section B4.1). Lot

blank results will be reviewed by the FTL before any cassette in the lot is used for sample collection.

The entire batch of cassettes will be rejected if any asbestos is detected on either lot blank. Once the

lot is confirmed to be asbestos free (i.e., asbestos is not detected on either lot blanks), that lot may

be placed into use for sampling. Only filter lots with acceptable lot blank results are placed into use

for the air sampling effort. Field Blanks Field blanks are collected to evaluate potential contamination introduced during sample collection,

shipping and handling, or analysis. It is the responsibility of each field team to collect the

appropriate number of field blanks. A field blank for air shall be prepared by removing the

sampling cassette from the box, opening the cassette to the air in the area where the investigative

samples will be taken for about 30 seconds, then closing the cassette and packaging for shipment

and analysis. Field blanks will be collected at a rate of one field blank per day, when air sampling is

occurring. It is anticipated that a total of four field blanks will be collected; two of the four field

blanks will be randomly selected by the FTL for analysis, the other two samples will be archived for



possible future analysis. The field blanks are analyzed for asbestos by TEM analysis as described

above (see Section B4.1).

Field blank results will be evaluated by CDM Smith when they are summarized as part of the study

data summary report. If any asbestos is observed on a field blank, the other two archived field

blanks will be sent for analysis and the FTL and/or laboratory manager will be notified to take

appropriate measures (e.g., re-training on sample collection and analysis procedures) to ensure

staff are employing proper sample handling techniques for future studies7. A qualifier of “FB” will

be added to the related field sample results in the project database to denote that the associated

field blank had asbestos structures detected. Any assigned qualifiers will be included when results

are reported.

Duff Material

Only one type of field QC sample will be collected as part of the duff sampling portion of this

program – field duplicates.

One field duplicate sample of duff material will be collected as part of this sampling program. The

duff field duplicate should be collected at the same approximate location as the five duff sampling

points as the parent sample (i.e., within 12 inches of the parent sampling points). It is the

responsibility of the FTL to ensure that the field duplicate is collected. The field duplicate is given a

unique sample number, and field personnel will record the sample number of the associated co-

located sample in the parent sample number field of the FSDS. The same station location is assigned

to the field duplicate sample as the parent field sample. Field duplicates will be sent for analysis by

the same method as field samples and are blind to the laboratories (i.e., the laboratory cannot

distinguish between field samples and field duplicates).

Field duplicate results will be evaluated by CDM Smith when they are summarized as part of the

study data summary report. Field duplicate results will be compared to the original parent field

sample using the Poisson ratio test using a 90% confidence interval (CI) (Nelson 1982). Because

field duplicate samples are expected to have inherent variability that is random and may be either

small or large, typically, there is no quantitative requirement for the agreement of field duplicates.

Rather, results are used to determine the magnitude of this variability to evaluate data usability.

Tree Bark

Two types of field QC samples may be collected as part of the tree bark sampling portion of this

program – equipment rinsates (if necessary) and field duplicates.

7 Due to the short timeframe of this study, it will not be possible to use the results of field QC samples to make any

real-time adjustments in this study. Field QC results will be used to qualify results for this study, as appropriate, and

to identify potential sampling and analysis issues for future studies.



Equipment Rinsates

Equipment rinsates are collected to evaluate potential contamination that arises to due inadequate

decontamination of sampling equipment. Equipment rinsates will only be collected if re-usable field

sampling equipment (i.e., hole saws, chisels) is utilized. Following decontamination efforts, the

decontaminated equipment (i.e., hole saw, chisel) should be rinsed with clean water (e.g., store-

bought drinking water), and the resulting rinsate should be collected in a certified clean 500-

milliliter [mL] capacity high-density polyethylene container. Approximately 100-200 mL of

headspace must be left in the collection container to allow for the ozonation/ultraviolet treatment

and sonication of the sample by the analytical laboratory prior to analysis. At least one equipment

rinsate blank should be collected per equipment decontamination effort. It is the responsibility of

each field team to collect the appropriate number of equipment rinsate blanks. Equipment rinsate

blanks should be labeled with a unique sample number and submitted for analysis by TEM (see

Section B4.6).

Equipment rinsate blank results will be evaluated by CDM Smith when they are summarized as part

of the study data summary report. If any asbestos structures are observed in an equipment rinsate,

the FTL and/or laboratory manager will be notified and will take appropriate measures to ensure

staff are employing proper sample handling techniques in future studies. In addition, a qualifier of

“EB” will be added to the related field sample results in the project database to denote that the

associated equipment rinsates had asbestos structures detected.

Field Duplicates

One field duplicate sample of tree bark will be collected as part of this sampling program. Field

duplicates for tree bark are collected from the same tree as and in close proximity to (within 6

inches) the parent field sample. The field duplicate is collected using the same collection technique

as the parent sample. It is the responsibility of the FTL to ensure that the field duplicate is collected.

The field duplicate is given unique sample number, and field personnel will record the sample

number of the associated co located sample in the parent sample number field of the FSDS. The

same station location is assigned to the field duplicate sample as the parent field sample. Field

duplicates will be sent for analysis by the same method as field samples and are blind to the

analytical laboratories (i.e., the laboratory cannot distinguish between field samples and field

duplicates).

Field duplicate results will be evaluated by CDM Smith when they are summarized as part of the

study data summary report. Field duplicate results will be compared to the original parent field

sample using the Poisson ratio test using a 90% CI (Nelson 1982). Because field duplicate samples

are expected to have inherent variability that is random and may be either small or large, typically,

there is no quantitative requirement for the agreement of field duplicates. Rather, results are used

to determine the magnitude of this variability to evaluate data usability.

Ash and Soil

There are no field QC samples required for ash or soil.



B5.2 Laboratory

Laboratory QA/QC activities include all processes and procedures that have been designed to

ensure that data generated by an analytical laboratory are of high quality and that any problems in

sample preparation or analysis that may occur are quickly identified and rectified. The following

sections describe each of the components of the analytical laboratory QA/QC program implemented

at the Site.

B5.2.1 Training/Certifications

All analytical laboratories participating in the analysis of samples for the Libby project are subject

to national, local, and project-specific certifications and requirements. Additional information on

laboratory training and certification requirements is provided in Section A8.2.

Laboratories handling samples collected as part of this sampling program will be provided a copy of

and will adhere to the requirements of this QAPP. Samples collected under this QAPP will be

analyzed in accordance with standard EPA and/or nationally-recognized analytical procedures (i.e.,

Good Laboratory Practices) in order to provide analytical data of known quality and consistency.

B5.2.2 Modification Documentation

When changes or revisions are needed to improve or document specifics about analytical methods

or procedures used by the laboratory, these changes are documented using the Libby laboratory

ROM form (see Appendix E). The ROM form provides a standardized format for tracking

procedural changes in sample analysis and allows project managers to assess potential impacts on

the quality of the data being collected. Laboratory ROMs will be completed by the appropriate

laboratory or technical staff. Once a form is prepared, it is submitted to the EPA RPM and the LC for

review and approval. Copies of approved laboratory ROMs are available in the Libby Lab eRoom.

B5.2.3 Laboratory QC Analyses

Samples collected under this QAPP will be processed and analyzed in accordance with standard

EPA and/or nationally-recognized analytical procedures (i.e., Good Laboratory Practices) in order

to provide analytical data of known quality and consistency. Specific QA/QC procedures are

provided in the respective QA management plan or facilities operations plan for each facility that

processes or analyzes Site samples. Additionally, for asbestos analysis, the following laboratory QC

analyses will be performed for TEM and PLM.

TEM

The Libby-specific QC requirements for TEM analyses of asbestos are patterned after the

requirements set forth by NVLAP. In brief, there are three types of laboratory-based QC analyses

that are performed for TEM – laboratory blanks, recounts, and repreparations. Detailed information

on the Libby-specific requirements for each type of TEM QC analysis, including the minimum



frequency rates, selection procedures, acceptance criteria, and corrective actions are provided in

the most recent version of Libby laboratory modification LB-000029, with the following

investigation-specific modification:

The TEM QC frequency requirements specified in Libby laboratory modification LB-000029

are to be specific to each laboratory and applicable across all media and investigations

conducted in OU3.

PLM

The Libby-specific QC requirements for PLM analyses include both preparation laboratory and

analytical laboratory QC analyses. During preparation at the Troy SPF, preparation blanks and

preparation splits will be inserted into the sampling train. Detailed information on the frequency of

preparation QC samples and interpretation of results is provided in the preparation SOP 16-ASB-

06.02. During the PLM analysis, the analytical laboratory will perform intra- and inter-laboratory

duplicate analyses in accordance with the Site-specific PLM methods, as modified by the most

recent version of Libby laboratory modification LB-000073. However, the laboratory QC frequency

requirements are to be applied across investigations conducted for OU3.

B6/B7. EQUIPMENT MAINTENANCE AND INSTRUMENT CALIBRATION B6/B7.1 Field Equipment

B6/B7.1.1 Field Equipment Maintenance

All field equipment (e.g., GPS units, sampling pumps) will be maintained and calibrated in basic

accordance with manufacturer specifications. When a piece of equipment is found to be operating

incorrectly, the piece of equipment will be labeled “out of order” and placed in a separate area from

the rest of the sampling equipment. The person who identified the equipment as “out of order” will

notify the FTL overseeing the investigation activities. It is the responsibility of the FTL to facilitate

repair of the “out of order” equipment. This may include having appropriately trained field team

members complete the repair or shipping the malfunctioning equipment to the manufacturer. Field

team members will have access to basic tools required to make field acceptable repairs. This will

ensure timely repair of any “out of order” equipment.

B6/B7.1.2 Air Sampling Pump Calibration

Each air sampling pump will be calibrated at the start of each ABS sampling period using the

primary calibration source (e.g., BIOS DryCal® or similar) or a rotameter that has been that has

been calibrated to a primary calibration source in accordance with manufacturer

recommendations. For pre-sampling purposes, calibration will be considered complete when the

measured flow is within ±5% of the target flow, as determined by the mean of three measurements

with the calibrator using a cassette reserved for calibration (from the same lot as the sample

cassettes to be used in the field). Additional calibration may be performed during sample collection

as described below.



If at any time the observed flow rates are ±10% of the target rate, the sampling pump should be re-

calibrated, if possible. If at any time an air sampling pump is found to have faulted or the observed

flow rates are 25% below (due to heavy particulate loading or a pump malfunction) or 50% above

the target rate, the pump will be replaced or the activity will be terminated. Collection of air

samples will continue, regardless of the amount of particulate loading on the filters, unless the flow

rate is affected. At the beginning of the sampling program, flow rates and particulate loading may be

checked more frequently as conditions require, establishing expected conditions.

To calculate the percentage of an observed flow to the target flow, the following formula is used:

100)/(

)/(%

inmLRateFlowgetTar

inmLRateFlowObservedX

For post-sampling calibration, three separate constant flow calibration readings will be obtained

with the sampling cassette inline and those flow readings will be averaged. If the flow rate changes

by more than 5% during the sampling period, the average of the pre- and post-sampling rates will

be used to calculate the total sample volume.

Samples for which there is more than a 30% difference from initial calibration to end calibration

will be invalidated. The sample collector will record the pump serial number, sample number,

initial flow rate, sample start/end times, sample locations, and final flow rate, as well as mark the

sample "void" in the field logbook and FSDS. These samples will not be submitted for analysis.

To prevent potential cross-contamination, each rotameter used for field calibration will be

transported to and from each sampling location in a sealed zip-top plastic bag. The cap and

calibration cassette used at the end of the rotameter tubing will be replaced each day after it is

used.

B6/B7.2 Laboratory Instruments

The laboratory manager is responsible for ensuring that all laboratory instruments used for this

project are maintained and calibrated in accordance with the manufacturer’s instructions. If any

deficiencies in instrument function are identified, all analyses shall be halted until the deficiency is

corrected. The laboratory shall maintain a logbook that documents all routine maintenance and

calibration activities, as well as any significant repair events, including documentation that the

deficiency has been corrected.

B8. INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES

B8.1 Field Supplies

In advance of field activities, the FTL (or designee) will check the field equipment/supply inventory

and procure any additional equipment and supplies that are needed. The FTL will also ensure any



in-house measurement and test equipment used to collect data/samples as part of this QAPP is in

good, working order, and any procured equipment is acceptance tested prior to use. Any items that

the FTL determines unacceptable will be removed from inventory and repaired or replaced as

necessary.

The following list summarizes the general equipment and supplies required for most

investigations:

Field logbook – Used to document field sampling activities and any problems in sample

collection or deviations from the investigation-specific QAPPs. See Section B3.1 for standard

procedures for field logbooks.

FSDSs – Medium-specific forms that are used to document sample details (i.e., sampling

location, sample number, medium, field QC type, etc.). See Section B3.1 for standard

procedures for the completion of FSDSs.

Sample number labels – Sample numbers are sequential numbers with investigation-

specific prefixes. Sample number labels are pre-printed and checked out to the field teams

by the FTL or their designee. To avoid potential transcription errors in the field, multiple

labels of the same sample number are prepared – one label is affixed to the collected sample

and one label is affixed to the hard copy FSDS form. Labels may also be affixed to the field

logbook.

Indelible ink pen – Used to complete information on the FSDS and in the field logbook

(pencil may not be used), and to write sample numbers on the sample containers.

Personal protective equipment - As required by the project HASP.

Land survey map or aerial photo – Used to identify appropriate sampling locations. In some

cases, sketches may be added to the map/photo to designee sampling and visual inspection

locations and other site features.

Digital camera – Used to document sampling locations and conditions. See Section B3.1.2 for

standard procedures in photographic documentation.

GPS unit, measuring wheel, stakes – Used to identify and record sampling locations. See

B2.5 for standard procedures in GPS documentation.

Zip-top bags – Used as sample containers for most types of environmental samples. Sample

number labels will be affixed to the bags or the sample number will be hand-written in

permanent marker on the bags.

Decontamination equipment – Used to remove any residual asbestos contamination on

reusable sampling equipment between the collection of samples. See Section B2.6 for

standard decontamination procedures.



In addition to the generic equipment list, the following equipment will be required for sampling

activities as part of this program:

Air sampling equipment: 25-mm diameter MCE filter cassettes (0.8-µm pore size), high and

low flow rate battery-powered air sampling pumps, rotameter, Tygon tubing, belt or

backpack to attach pumps to sampler, tripod stands

Tree bark sampling equipment: hole saws, battery-powered drills, equipment rinsate

supplies (as necessary)

Video equipment (stationary and personal)

Davis Instruments 6250 Vantage Vue® wireless weather station and associated

WeatherLink® data logger; sling psychrometer; hand-held anemometer; temperature

gauge(s)

One-gallon metal container (for ash sample collection); 250-ml to 500-ml capacity high-

temperature polypropylene bottles (for fuel moisture samples)

Custody seals

Fire suppression equipment

Fire line and fire break construction equipment

B8.2 Laboratory Supplies

The laboratory manager is responsible for ensuring that all reagents and disposable equipment

used in this project is free of asbestos contamination. This is demonstrated by the collection of

laboratory blank samples (see Section B5.2.3).

B9. NON-DIRECT MEASUREMENTS

There are no non-direct measurements that are anticipated for use in this project.

B10. DATA MANAGEMENT

All data generated as part of this ABS program will be maintained in an OU3-specific Microsoft

Access® database in accordance with the OU3-specific data management procedures specified

below. The following sections provide a brief overview of the roles and responsibilities for data

management and a summary of the data storage requirements for the OU3 project.



B10.1 Roles and Responsibilities

B10.1.1 Field Personnel

Grace’s contractor will perform all field sample collection and ABS activities in strict accordance

with this QAPP.

In the field, sample details will be documented on hard copy media-specific FSDS forms and in field

log books. COC information will be documented on hard copy forms. See Appendix B, OU3 SOP No.

9 for templates of FSDS and COC forms. Grace’s field contractor will scan and post field

documentation in an Adobe Acrobat® portable document format (.pdf) to the Libby OU3 eRoom on

a daily basis. This eRoom has controlled access (i.e., user name and password are required) to

ensure data access is limited to appropriate project-related personnel. File names for scanned

documents will include the sample date in the format MMDDYY to facilitate document organization

(e.g., “FSDS_050515.pdf”).

FSDS and COC information will be manually entered into a field-specific8 OU3 database using

electronic data entry forms. Use of electronic data entry forms ensures the accuracy of data entry

and helps maintain data integrity. For example, data entry forms utilize drop-down menus and

check boxes whenever possible. These features allow the data entry personnel to select from a set

of standard inputs, thereby preventing duplication and transcription errors and limiting the

number of available selections (e.g., media types). In addition, entry into a database allows for the

incorporation of data entry checks. For example, the database will allow a unique sample ID to only

be entered once, thus ensuring that duplicate records cannot be created.

Entry of FSDS forms and COC information will be completed weekly, or more frequently as

conditions permit. After FSDS data entry is completed, a copy of the field-specific OU3 database will

be posted by the field data manager to the Libby OU3 eRoom weekly, or more frequently as

conditions permit. The field-specific OU3 database posted to the eRoom site will include the post

date in the file name (e.g., FieldOU3DB_20150505.mdb).

B10.1.2 Laboratory Personnel

Each of the laboratories performing asbestos analyses for this investigation are required to utilize

all applicable Libby-specific Microsoft Excel® EDD spreadsheets for asbestos data recording and

electronic submittals. Upon completion of the appropriate analyses, EDDs and scanned copies of all

analytical laboratory data packages will be posted to the OU3 eRoom.

8 The field-specific OU3 database is a simplified version of the master OU3 database. This simplified database includes only the station and sample recording and tracking tables, as well as the FSDS and COC data entry forms.



B10.1.3 Database Administrators

Day-to-day operations of the master OU3 project database will be under the control of EPA

contractors. The primary database administrator (CDM Smith) will be responsible for sample

tracking, entering new field data, uploading new analytical data, performing error checks, and

making any necessary data corrections. New records will be added to the master OU3 project

database within an appropriate time period of data receipt. B10.2 Master OU3 Project Database

The master OU3 project database is a relational Microsoft Access® database developed specifically

for OU3. The Libby OU3 Database User’s Guide provides an overview of the master OU3 project

database structure and content. The most recent version of this User’s Guide is provided on the OU3

website.

The master OU3 project database is kept on the CDM Smith server in Denver, CO. Incremental

backups of the master OU3 project database are performed daily Monday through Friday, and a full

backup is performed each Saturday.

B10.3 Data Reporting

Field summary reports are prepared by Grace’s field contractor. These reports will summarize field

collection activities, the number and types of samples collected, as well as any deviations from the

governing QAPP or SOPs. (These field summary reports will not include any analytical results.)

Tabular analytical results summaries are provided by CDM Smith to the EPA RPM on an

investigation-specific basis and will be summarized in the comprehensive OU3 Data Summary

Report (CDM Smith 2013a), which is available on the OU3 website. The EPA RPM will be

responsible for disseminating information regarding sampling and analysis results associated with

this investigation. Specialized requests for data summaries may be submitted to the EPA RPM.

B10.4 Data Storage

All original data records (both hard copy and electronic) will be cataloged and stored in their

original form until otherwise directed by the EPA RPM. At the termination of this project, all

original data records will be provided to the EPA RPM for incorporation into the Site project files.



C Assessment and Oversight

C1. ASSESSMENT AND RESPONSE ACTIONS

Assessments and oversight reports to management are necessary to ensure that procedures are

followed as required and that deviations from procedures are documented. These reports also

serve to keep management current on field activities.

C1.1 Assessments

C1.1.1 Field

At the discretion of EPA, field oversight may be performed by EPA’s contractors (CDM Smith, HDR

Engineering, or CB&I) to evaluate ABS activities. EPA’s field auditor has the authority to direct

changes in field activities or to halt field activities if needed until a remedy to an unexpected

problem can be identified. Field audit findings will be documented in audit reports issued by the

entity performing the audit, and will be discussed with the project management team before the

auditors leave the Site. Corrective actions will be immediately implemented, as appropriate. A copy

of the field audit report will be provided to the EPA RPM and the USACE Program Manager.

C1.1.2 Laboratory

Each laboratory working on the Libby project is required to participate in an annual onsite

laboratory audit carried out by the EPA through the QATS contract. These audits are performed by

EPA personnel (and their contractors), that are external to and independent of, the Libby

laboratory team members. These audits ensure that each analytical laboratory meets the basic

capability and quality standards associated with analytical methods for asbestos used at the Libby

site. They also provide information on the availability of sufficient laboratory capacity to meet

potential testing needs associated with the Site.

External Audits

Audits consist of several days of technical and evidentiary review of each laboratory. The technical

portion of the audit involves an evaluation of laboratory practices and procedures associated with

the preparation and analysis of samples for the identification of asbestos. The evidentiary portion

of the audit involves an evaluation of data packages, record keeping, SOPs, and the laboratory QA

manual. A checklist of method-specific requirements for the commonly used methods for asbestos

analysis is prepared by the auditor before the audit, and used during the onsite laboratory

evaluation.

Evaluation of the capability for a laboratory to analyze a sample by a specific method is made by

observing analysts performing actual sample analyses and interviewing each analyst responsible

for the analyses. Observations and responses to questions concerning items on each method-

specific checklist are noted. The determination as to whether the laboratory has the capability to

analyze a sample by a specific method depends on how well the analysts follow the protocols



detailed in the formal method, how well the analysts follow the laboratory-specific method SOPs,

and how the analysts respond to method-specific questions.

Evaluation of the laboratory to be sufficient in the evidentiary aspect of the audit is made by

reviewing laboratory documentation and interviewing laboratory personnel responsible for

maintaining laboratory documentation. This includes personnel responsible for sample check-in,

data review, QA procedures, document control, and record archiving. Certain analysts responsible

for method quality control, instrument calibration, and document control are also interviewed in

this aspect of the audit. Determination as to the capability to be sufficient in this aspect is made

based on staff responses to questions and a review of archived data packages and QC documents.

It is the responsibility of the QATS contractor to prepare an On-site Audit Report for each analytical

laboratory participating in the Libby program. These reports are handled as business confidential

items. The On-site Audit Report includes both a summary of the audit results and completed

checklist(s), as well as recommendations for corrective actions, as appropriate. Responses from

each laboratory to any deficiencies noted in the On-site Audit Report are also maintained with the

respective reports.

It is the responsibility of the QATS contractor to prepare an On-Site Audit Trend Analysis Report on

an annual basis. This report shall include a compilation and trend analysis of the onsite audit

findings and recommendations. The purpose of this reported is to identify common asbestos

laboratory performance problems and isolate the potential causes.

Internal Audits

Each laboratory will also conduct periodic internal audits of their specific operations. Details on

these internal audits are provided in the laboratory QA Management Plan. The laboratory QAM

should immediately contact the LC and the QATS contractor if any issues are identified during

internal audits that may impact data quality for OU3 samples.

C1.2 Response Actions

Corrective response actions will be implemented on a case-by-case basis to address quality

problems. Minor actions taken to immediately correct a quality problem will be documented in the

applicable field or laboratory logbooks and a verbal report will be provided to the appropriate

manager (e.g., the FTL or LC). Major corrective actions will be approved by the EPA RPM and the

appropriate manager prior to implementation of the change. Major response actions are those that

may affect the quality or objective of the investigation. The EPA RPM for OU3 will be notified when

quality problems arise that that cannot be corrected quickly through routine procedures (contact

information is provided below):



Christina Progess U.S. EPA, Region 8 1595 Wynkoop Street Denver, CO 80202 Tel: (303) 312-6009 Fax: (303) 312-7151 E-mail: [email protected] In addition, when modifications to this QAPP are required, either for field or laboratory activities, a

ROM must be completed and approved by the EPA RPM prior to implementation (see Appendix E

for example ROM forms).

C2. REPORTS TO MANAGEMENT

No regularly-scheduled written reports to management are planned as part of this project.

However, QA reports will be provided to management for routine audits and whenever quality

problems are encountered. Field staff will note any quality problems on FSDSs or in field logbooks.

Further, the field and laboratory managers will inform the EPA RPM upon encountering quality

issues that cannot be immediately corrected.




D Data Validation and Usability

D1. DATA REVIEW, VERIFICATION AND VALIDATION

D1.1 Data Review

Data review of project data typically occurs at the time of data reporting by the data users and

includes cross-checking that sample IDs and sample dates have been reported correctly and that

calculated analytical sensitivities or reported values are as expected. If discrepancies are found, the

data user will contact the database manager (CDM Smith), who will then notify the appropriate

entity (field or laboratory) in order to correct the issue.

D1.2 Criteria for LA Measurement Acceptability

Several factors will be considered in determining the acceptability of LA measurements in samples

analyzed by TEM. This includes the following:

Evenness of filter loading. This is evaluated using a Chi-squared (CHISQ) test, as described in

ISO 10312 Annex F2. If a filter fails the CHISQ test for evenness, the result may not be

representative of the true concentration in the sample, and the result should be given low

confidence.

Results of QC samples. This includes both field and laboratory QC samples, such as field and

laboratory blank samples, as well as various types of recount and repreparation analyses. If

significant LA contamination is detected in field or laboratory blanks, all samples prepared

on that day should be considered to be potentially biased high. If agreement between

original analyses and re-preparation or recount analyses is poor, results for those samples

should be given low confidence.

For PLM analyses, the following factors will be considered in determining the acceptability of LA

measurements in soil samples:

Results of Performance Evaluation (PE) standard analyses. PLM-VE accuracy is evaluated

using LA-specific PE standards. If the results for these PE standards are not within the

project-specific acceptance criteria, results should be given low confidence.

Results of QC samples. This includes both preparation and laboratory QC samples. If LA

contamination is detected in any preparation blanks, associated samples should be

considered to be potentially biased high. If agreement between original and repeat analyses

(i.e., duplicate analyses, inter-laboratory analyses) is strongly discordant, results for those

samples should be given low confidence.



D2. VERIFICATION AND VALIDATION METHODS

D2.1 Data Verification

Data verification includes checking that results have been transferred correctly from the original

hand-written, hard copy field and analytical laboratory documentation to the project databases.

The goal of data verification is to identify and correct data reporting errors.

In the field, some data checking of reported sample information on the FSDS forms is performed

during the data entry process (i.e., the electronic data entry forms only allow for the input of

specific valid values and formats). In the analytical laboratory, data checking of reported analytical

results begins with automatic QC checks that have been built into the Libby-specific spreadsheets.

These automated checks help to ensure that field sample information and analytical results in the

project databases are accurate and reliable.

In addition to these automated checks, a detailed manual data verification effort will be performed

for 100% of all samples and analytical results collected as part of this sampling effort. This data

verification process utilizes Site-specific SOPs (see Appendix B) developed to ensure results and

field sample information in the project databases is accurate and reliable:

EPA-LIBBY-09: SOP for TEM Data Review and Data Entry Verification – This Site-specific SOP

describes the steps for the verification of TEM analyses, based on a review of the laboratory

benchsheets, and verification of the transfer of results from the benchsheets into the project

database.

EPA-LIBBY-10: SOP for PLM Data Review and Data Entry Verification – This Site-specific SOP

describes the steps for the verification of PLM analyses, based on a review of the laboratory

benchsheets, and verification of the transfer of results from the benchsheets into the project

database.

EPA-LIBBY-11: SOP for FSDS Data Review and Data Entry Verification – This Site-specific

SOP describes the steps for the verification of field sample information, based on a review of

the FSDS form, and verification of the transfer of results from the FSDS forms into the

project database. An FSDS review is performed on all samples selected for TEM data

verification.

The data verification review ensure that any data reporting issues are identified and rectified to

limit any impact on overall data quality. If issues are identified during the data verification, the

frequency of these checks may be increased as appropriate.

Data verification will be performed by appropriate CDM Smith staff that is familiar with project-

specific data reporting, analytical methods, and investigation requirements. The data verifier will

prepare a data verification report (template reports are included in the SOPs) to summarize any

issues identified and necessary corrections. A copy of this report will be provided to the EPA RPM.

It is the responsibility of the OU3 database manager (CDM Smith) to coordinate with the FTL



and/or LC to resolve any database corrections and address any recommended field or laboratory

procedural changes from the data verifier. The OU3 database manager is also responsible for

electronically tracking in the project database which data have been verified, who performed the

verification, and when verification occurred.

D2.2 Data Validation

Unlike data verification, where the goal is to identify and correct data reporting errors, the goal of

data validation is to evaluate overall data quality and to assign data qualifiers, as appropriate, to

alert data users to any potential data quality issues. Data validation will be performed by the QATS

contractor (CB&I, or their designee), with support from technical support staff that are familiar

with project-specific data reporting, analytical methods, and investigation requirements.

As part of the data validation effort, the QATS contractor will review results for all field QC samples

and inter- and intra-laboratory QC analyses on a quarterly basis. In addition, the QATS contractor

will also perform a formal data validation of the TEM and PLM data packages submitted by the

laboratory in accordance with Libby-specific SOP QATS-70-095-01, which was developed by the

QATS contractor based on the draft National Functional Guidelines for Asbestos Data Review (EPA

2011). This data validation includes an assessment of the following:

Internal and external field audit/surveillance reports

Field ROMs

Field QC sample results

Internal and external laboratory audit reports

Laboratory contamination monitoring results

Laboratory ROMs

Internal laboratory QC analysis results

Inter-laboratory analysis results

Performance evaluation results

Instrument checks and calibration results

Data verification results (i.e., in the event that the verification effort identifies a larger data

quality issue)

A comprehensive data validation effort will be completed annually and results should be reported

as a technical memorandum to the EPA. This technical memorandum shall detail the validation

procedures performed and provide a narrative on the quality assessment for each type of asbestos

analysis, including the data qualifiers assigned, and the reason(s) for these qualifiers. The technical

memorandum shall detail any deficiencies and required corrective actions.

For OU3 reviews, electronic files summarizing the records that have been validated, the date they

were validated, any recommended data qualifiers and their associated reason codes should be

posted to the OU3 eRoom. It is the responsibility of the OU3 database manager (CDM Smith) to

ensure that the appropriate data qualifiers and reason codes recommended by the data validator

are added to the project database, and to electronically track in the project database which data

have been validated, who performed the validation, and when.



In addition to performing regular data validation efforts, it is the responsibility of the QATS

contractor (or their designee) to perform regular evaluations of all blanks, to ensure that any

potential contamination issues are quickly identified and resolved. If any blank results are outside

the acceptable limits, the QATS contractor should immediately contact the EPA RPM to ensure that

appropriate corrective actions are made.

D3. RECONCILIATION WITH USER REQUIREMENTS

Once all samples have been collected and analytical data has been generated, data will be evaluated

to determine if study objectives were achieved. It is the responsibility of data users to perform a

data usability assessment to ensure that DQOs have been met, and reported investigation results

are adequate and appropriate for their intended use. This data usability assessment should utilize

results of the data verification and data validation efforts to provide information on overall data

quality specific to each investigation.

The data usability assessment should evaluate results with regard to several data usability

indicators, including precision, accuracy/ bias, representativeness, comparability, completeness,

and whether specified analytic requirements (e.g., sensitivity) were achieved. Table D-1 provides

detailed information for how each of these indicators may be evaluated for the reported asbestos

data. The data usability assessment results and conclusions should be included in any investigation-

specific data summary reports.

Non-attainment of project requirements may result in additional sample collection or field

observations in order to achieve project needs.



REFERENCES

Amandus HE, Wheeler R. 1987. The Morbidity and Mortality of Vermiculite Miners and Millers

Exposed to Tremolite-Actinolite: Part II. Mortality. Am. J. Ind. Med. 11:15-26.

CDM Smith. 2013a. Data Summary Report: 2007 to 2012, Libby Asbestos Superfund Site, Operable

Unit 3. Denver, Colorado: CDM Federal Programs Corporation. Report prepared for U.S.

Environmental Protection Agency. Revision 0 – November 2013; Revision 1 – July 2014; Revision 2

- 2015.

_____. 2013b. Data Summary Report: Nature and Extent of LA Contamination in the Forest, Libby

Asbestos Superfund Site. Denver, Colorado: CDM Federal Programs Corporation. Report prepared for

U.S. Environmental Protection Agency. August.

_____. 2013c. Libby Asbestos Response Plan: Wildfire Quality Assurance Project Plan. Denver,

Colorado: CDM Federal Programs Corporation and U.S. Army Corps of Engineers. Report prepared

for U.S. Environmental Protection Agency. Revision 0 - August.

_____. 2014. Sampling and Analysis Plan/ Quality Assurance Project Plan: Wildfire Contingency

Monitoring Plan. Denver, Colorado: CDM Federal Programs Corporation. Report prepared for U.S.

Environmental Protection Agency. Revision 2 – June.

EPA (U.S. Environmental Protection Agency). 2001. EPA Requirements for Quality Assurance Project

Plans, QA/R-5. Final. March.

_____. 2003. Technical Memorandum: Libby Asbestos Site Residential/Commercial Cleanup Action Level and Clearance Criteria. U.S. Environmental Protection Agency, Region 8. Draft Final – December 15, 2003.

_____. 2006. Guidance on Systematic Planning Using the Data Quality Objective Process, QA/G-4.

February.

_____ 2008a. Framework for Investigating Asbestos-Contaminated Sites. Report prepared by the

Asbestos Committee of the Technical Review Workgroup of the Office of Solid Waste and

Emergency Response, U.S. Environmental Protection Agency. OSWER Directive #9200.0-68.

http://epa.gov/superfund/health/contaminants/asbestos/pdfs/framework_asbestos_guidance.pdf

_____ 2008b. Performance Evaluation of Laboratory Methods for the Analysis of Asbestos in Soil at the Libby, Montana Superfund Site. Produced by Syracuse Research Corporation for EPA, Region 8. Draft – October 7, 2008. _____ 2008c. Characteristic EDS Spectra for Libby-Type Amphiboles. Produced by Syracuse Research Corporation for EPA, Region 8. Final – March 18, 2008.

_____. 2011. National Functional Guidelines for Asbestos Data Review. U.S. Environmental Protection Agency, Office of Superfund Remediation and Technology Innovation. Draft - August.

http://epa.gov/superfund/health/contaminants/asbestos/pdfs/framework_asbestos_guidance.pdf



_____. 2013. Sampling and Analysis Plan/Quality Assurance Project Plan Operable Unit 3, Libby Asbestos Superfund Site Wildfire Contingency Monitoring Plan. U.S. Environmental Protection Agency with technical assistance from CDM Federal Programs. Revision 1 - August. _____. 2014a. Libby Asbestos Superfund Site, Site-wide Human Health Risk Assessment. Denver, Colorado: CDM Federal Programs. Report prepared for U.S. Environmental Protection Agency. December. _____. 2014b. Toxicological Review of Libby Amphibole Asbestos. Washington D.C.: U.S. Environmental Protection Agency, Office of Research and Development, National Center for Environmental Assessment, Integrated Risk Information System. EPA/635/R-11/002F. December.

International Organization for Standardization (ISO). 1995. Ambient Air – Determination of asbestos

fibers – Direct-transfer transmission electron microscopy method. ISO 10312:1995(E).

Larson, TC, Meyer, CA, Kapil, V, Gurney, JW, Tarver, RD, Black, CB, and Lockey, JE. 2010. Workers with Libby amphibole exposure: retrospective identification and progression of radiographic changes. Radiology 255(3):924-933. Larson, TC, Lewin, M, Gottschall, EB, Antao, VC, Kapil, V, and Rose, CS. 2012a. Associations between radiographic findings and spirometry in a community exposed to Libby amphibole. Occupational and Environmental Medicine 69(5):361-6. Larson, TC, Antao, AC, Bove, FJ, and Cusack, C. 2012b. Association between cumulative fiber exposure and respiratory outcomes among Libby vermiculite workers. Journal of Occupational and Environmental Medicine 54(1):56-63.

Meeker GP, Bern AM, Brownfield IK, Lowers HA, Sutley SJ, Hoeffen TM, Vance JS. 2003. The

Composition and Morphology of Amphiboles from the Rainy Creek Complex, Near Libby, Montana.

American Mineralogist 88:1955-1969.

McDonald JC, Harris J, Armstrong B. 2004. Mortality in a cohort of vermiculite miners exposed to

fibrous Amphibole in Libby, Montana. Occup. Environ. Med. 61:363-366.

McDonald JC, McDonald AD, Armstrong B, Sebastien P. 1986. Cohort study of mortality of

vermiculite miners exposed to tremolite. Brit. J. Ind. Med. 43:436-444.

MDNRC (Montana Department of Natural Resources). 2007. 400 – Prescribed Fire Guidelines.

September. https://dnrc.mt.gov/Forestry/Fire/Manuals/Documents/400Manual/400Manual.pdf

NWCG (National Wildfire Coordinating Group). 2014. Glossary of Wildland Fire Terminology, PMS

205. October. http://www.nwcg.gov/pms/pubs/glossary/pms205.pdf

OSHA (Occupational Safety and Health Administration). 2002. OSHA 3096: Asbestos Standard for the

Construction Industry (Revised). U.S. Department of Labor, Occupational Safety and Health

Administration. http://www.osha.gov/Publications/OSHA3096/3096.html

https://dnrc.mt.gov/Forestry/Fire/Manuals/Documents/400Manual/400Manual.pdf

http://www.nwcg.gov/pms/pubs/glossary/pms205.pdf

http://www.osha.gov/Publications/OSHA3096/3096.html



Peipins LA, Lewin M, Campolucci S, Lybarger JA, Miller A, Middleton D, et al. 2003. Radiographic

abnormalities and exposure to asbestos-contaminated vermiculite in the community of Libby,

Montana, USA. Environ. Health Perspect. 111:1753-1759.

Rohs AM, Lockey JE, Dunning KK, Shulka R, Fan H, Hilbert T, Borton E, Wiot J, Meyer C, Shipley RT,

LeMasters GK, Kapol V. 2007. Low level Fiber Induced Radiographic Changes Caused by Libby

Vermiculite: A 25 year Follow-up Study. Am J Respiratory and Critical Care Medicine. Published

online December 6, 2007 as doi:10.1164/rccm.200706-814OC.

Sullivan, PA. 2007. Vermiculite, Respiratory Disease and Asbestos Exposure in Libby, Montana:

Update of a Cohort Mortality Study. Environmental Health Perspectives doi:10.1289/ehp.9481

Available online at http://dx.doi.org.

Zahn, S., and Henson, C. 2011. A Synthesis of Fuel Moisture Collection Methods and Equipment - A

Desk Guide. U.S. Department of Agriculture Forest Service, May 2011, 40 pp.

http://dx.doi.org/

FIGURES

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Mary DarlingProgram Manager

USACE

Jeremy Ayala, Brian BroekemeierConstruction Control Representatives

USACE

Scott FeltonSite/USACE Project Manager

CDM Smith

Terry CrowellQuality Assurance Manager

CDM Smith

Field Support Staff:

William Pickens, MWHMike Chapman, ChapmanDarrell Schulte, Kevin Ryan, Wildland Fire Assoc.Chris Lautenberger, Reax EngineeringKurt Hafferman, BHI

Lisa DeWittProject Manager

MDEQ

Deborah McKeanTechnical Assistance Unit Chief

EPA, Region 8

Don GoodrichESAT Laboratory Contract Manager

EPA, Region 8

Dania ZinnerQATS Libby Task Manager/Quality Assurance

ReviewerEPA, Region 8

Nikki MacDonaldESAT QA Manager

TechLaw, Inc.

Douglas KentESAT TEM Laboratory Manager

TechLaw, Inc.

Analytical Laboratory Management Staff:

Laboratory ManagerQuality Assurance ManagerSample CoordinatorSenior Analyst(s)

Troy Soil Preparation Facility Management Staff:

Laboratory ManagerQuality Assurance ManagerSample Coordinator

Michael LenkauskasQuality Assurance ManagerShaw Environmental, Inc.

Andrea WandlerProject Sample Coordinator

TechLaw, Inc.

Figure A-1. General Organizational Chart for the Understory Burn ABS

EPA Region 8 Staff Lines of authority

Lines of communicationUSACE Staff

MDEQ Staff

CDM Smith Staff

TechLaw Staff

TechLaw Subcontractors

CB&I Staff

Jo Nell MullinsQuality Assurance Director

CDM Smith

Darwin NelsonFederal Services Group President

CDM Smith

Robert MedlerProject Coordinator

W. R. Grace

David RayQuality Assurance Manager

USACE

Lynn WoodburyProject Technical Lead

CDM Smith

Natalie RossProject Data Manager

CDM Smith

Malcolm Edwards, Robert WintergerstOn-Scene Coordinators

Seth ColeSupervisory Forester

USFS

USFS Staff

W.R. Grace Staff

Christina ProgessRemedial Project Manager

EPA, Region 8

W. R. Grace Subcontractor

Mark McDanielESAT Region 8 Team Manager/

Laboratory CoordinatorTechLaw, Inc.

Rebecca ThomasProject Team Leader

EPA, Region 8

Figure B‐1. Illustration of Understory Burn ABS Study Design

Week prior to burn Day 1 Day 4

construct firelines & fuel breaks

ashsoil soil

duff

bark

field blank field blank field blank field blank

+Samples will be collected from the 4 perimeter air monitors closest to the burn area (i.e., 50‐foot interval only)++Samples will be collected from all 12 perimeter air monitors (i.e., 50‐foot, 100‐foot, and 200‐foot intervals)

*For the ABS and 50‐foot perimeter air samples, a high volume and low volume filter will be collected. For the 100‐foot and 200‐foot perimeter air samples, only a high volume filter will be collected.

pre‐fire perimeter air[4 stations]*+

Day 2 Day 3

post‐fireperimeter air[4 stations]*+

post‐fireperimeter air[4 stations]*+

personal ABS, during fire[2 people]*

personal ABS, during dry mop‐up[2 people]*

personal ABS, during wet mop‐up[2 people]*

during perimeter air[12 stations]*++

OU 3

OU 4

Lake

Koo

canusa

Vermiculite Mtn.

"Near Mine" Location

Kootena

i Rive

r

Barron Creek

Bristow Creek

Rainy Creek

Blue Creek

Alexander Creek

Peace Creek

Kennedy Gulch

Tu b Gulch

Jackson Creek

Souse Creek

Little Jackson Creek

Dunn Cree

k

North Fork Jackson Creek

Fleetwood Creek

Canoe Gulch

Hickey Creek

Doak Creek

South Fork Jackson Creek

Reinshagen Gulch

Carney Creek

North Fork Bristow Creek

CampC reek

Rice Creek

South Fork Bristow Creek

Canyon Creek

North Fork Jackson Creek

Service Layer Credits: Sources: Esri, HERE, DeLorme, TomTom, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China(Hong Kong), swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GIS User Community

LegendABS AreaOperable Unit 3 Study AreaStreams

1.5 0 1.50.75 Miles

± 1:100,0001 inch = 8,333 feet

Site

Figure B-2 ABS Area


TABLES


TableB‐1.UnderstoryBurnSampleSummary

PanelA:AirSamples

HVFilters LVFilters

Pre‐burn4stationsat50ft,1daypriortoburn[a]

4hours 1per4hours 4 4 4

Duringburn4stationsat50ft[a]

4stationsat100ft[b]

4stationsat200ft[b]2hours(1‐hourburn&1‐hourmop‐up) 1per2hours 12 4 12

Post‐burn 4stationsat50ftonly,2daysfollowingburn 8hoursperday 1per4hours 16 16 16

32

Duringburn 2peopleperformingfiremaintenance 1hourduringburn 1per15minutes 8 8 8

Duringmop‐up,dry

2peopleperformingdrymop‐up

30minutesduringmop‐up 1per15minutes 4 4 4

Duringmop‐up,wet

2peopleperformingwetmop‐up

30minutesduringmop‐up 1per15minutes 4 4 4

16

48*Eitherhighvolume(HV)orlowvolume(LV)filterwillbeselectedforanalysis;otherfilterwillbearchived.

[a]BothanHVfilterandanLVfilterwillbecollected(i.e.,twosamplingpumpsperstationorperson)[b]OnlyanHVfilterwillbecollected(i.e.,onesamplingpumpperstation)

PanelB:SourceMaterialSamples

NumberofSamples

NumberofAnalyses

AnalysisType

Pre‐burn 3 3 PLM

Post‐burn 3 3 PLM

Bark Pre‐burn 5 5 TEM

Duff Pre‐burn 5 5 TEM

Ash Post‐burn 3 9+ TEM

+Eachsampleanalyzedintriplicate

Perimeter

Personal

SampleType SamplingDuration FilterChangeOutFrequencySamplingDescription

Total

Total

NumberofSamplesCollected

NumberofFiltersAnalyzedby

TEM*

56

32

88OVERALL

SampleType

Soil

SamplingDescription

30samplingpointscompositedinto5‐galloncontainer,post‐burnbutpre‐mop‐up

5samples(5‐pointcomposites)fromburnareapriortoburn

5samples(3‐treecorecomposites)fromburnareapriortoburn

3samples(30‐pointcomposites)fromburnareaaftermop‐up

3samples(30‐pointcomposites)fromburnareapriortoburn

TABLED‐1DATAUSABILITYINDICATORSFORASBESTOSDATASETS

LibbyAsbestosSuperfundSite

DataUsabilityIndicator GeneralEvaluationMethod

Precision

ReviewresultsforTEMrecountsandrepreparationsandPLMduplicatestoprovideinformationonvariabilityarisingfromanalysismethods.Reviewresultsforinter‐laboratoryanalysestoprovideinformationonvariabilityandpotentialbiasbetweenlaboratories.[SeeLibbyLaboratoryROMLB‐000029andLB‐000073fordetailedevaluationmethods.]

Accuracy/Bias

Calculatethebackgroundfilterloadingrateanduseresultstoassigndetect/non‐detectforTEManalysesinbasicaccordancewithASTM6620‐00.Forairsamples,determinethefrequencyofindirectpreparation.ReviewresultsforPLMperformanceevaluationstandardstoassessresultaccuracy.

Representativeness Reviewrelevantfieldauditreportfindingsandanyfield/laboratoryROMsforpotentialdataqualityissues.

Comparability ComparethesamplecollectionSOPs,preparationtechniques,andanalysismethodstopreviousinvestigations.

CompletenessDeterminethepercentofsamplesthatwereabletobesuccessfullycollectedandanalyzed(e.g.,99of100samples,99%).

SensitivityDeterminethefractionofallTEManalysesthatstoppedbasedonthemaximumfilterareaexaminedstoppingrule(i.e.,didnotachievethetargetsensitivity).

Notes:ASTM=AmericanSocietyofTestingandMaterialsLA=LibbyamphiboleQATS=QualityAssuranceTechnicalSupportROM=recordofmodificationSOP=standardoperatingprocedureTEM=transmissionelectronmicroscopyPLM=polarizedlightmicroscopy

APPENDIX A

DATA QUALITY OBJECTIVES


Appendix A: DQOs Page A‐1

APPENDIXA:DATAQUALITYOBJECTIVESDataqualityobjectives(DQOs)arestatementsthatdefinethetype,quality,quantity,purpose,anduseofdatatobecollected.ThedesignofastudyiscloselytiedtotheDQOs,whichserveasthebasisforimportantdecisionsregardingkeydesignfeaturessuchasthenumberandlocationofsamplestobecollectedandtypesofanalysestobeperformed.TheU.S.EnvironmentalProtectionAgency(EPA)hasdevelopedaseven‐stepprocessforestablishingDQOstohelpensurethatdatacollectedduringafieldsamplingprogramwillbeadequatetosupportreliabledecision‐making(EPA2001,2006).Thefollowingsectionsimplementtheseven‐stepDQOprocessassociatedwiththisqualityassuranceprojectplan(QAPP).Step1:StatetheProblemProblemDescriptionExtensivedataonLibbyamphiboleasbestos(LA)levelsonthebarksurfaceoftreesandinduffmaterials11havebeencollectedintheforestedareanearthemine(CDMFederalProgramsCorporation[CDMSmith]2013a)andintheforestedareanearthecurrentboundaryfortheLibbyAsbestosSuperfundSite(Site)(CDMSmith2013b).ThesedatashowthatLAfibersarepresentontheouterbarksurfaceoftreesandinduffmaterialattheSite.Ingeneral,LAlevelsinbarkanddufftendtobehighestclosesttothemine(withinabout3‐4miles),butLAfibershavebeendetectedinbarkandduff13ormoremilesfromthemine(CDMSmith2013b).AsstatedintheFrameworkforInvestigatingAsbestos‐ContaminatedSuperfundSites(EPA2008),asbestosfibersinsourcematerials,suchasbarkandduff,aretypicallynotinherentlyhazardous,unlesstheasbestosisreleasedfromthesourcematerialintoairwhereitcanbeinhaled.Ifinhaled,asbestosfiberscanincreasetheriskofdevelopinglungcancer,mesothelioma,pleuralfibrosis,andasbestosis.WildfiresthatoccurintheforestedareasoftheSitemayresultinthereleaseofLAfibersintoair.ThereleaseofLAfiberstoairasaresultofawildfirecouldexposerespondingfirefightersandindividualsinthevicinityofthefire.Theevaluationofriskstohumansfromexposuretoasbestosismostreliablyachievedbythecollectionofdataonthelevelofasbestosinbreathingzoneairduringdisturbancesofasbestos‐containingsourcematerials,referredtoasactivity‐basedsampling(ABS)(EPA2008).WhiletherehavebeenseveralABSstudiesconductedattheSitetoassesspotentialexposuresunderavarietyofexposureconditions,atpresent,therearelimitedABSdatatoevaluateexposuresduringwildfires.IntheeventofanauthenticwildfirethatisinornearthecurrentSiteboundary,therearesamplingplansinplace(EPA2013;CDMSmith2013c)tocollectopportunisticairsamples,bothatstationarymonitorsthroughouttheLibbycommunityandnearthewildfire(toevaluateexposurestofirefighters).Todate,airsampleshaveonlybeencollectedduringonewildfireevent.InlateJuly2013,asmall(1.5acre)low‐intensitywildfireoccurredintheSouseGulchday‐userecreationareaonLakeKoocanusabehindLibbyDam.Duringthisfire,airsampleswerecollectedtoprovidedataonLAexposuresofrespondingfirefighters(bothtothegroundcrewsandtheaircraftsupportpilot)and

1Duffconsistsoftheun‐decomposedtwigs,needles,andothervegetationandthelayerofpartially‐tofully‐decomposedlitterthatoccursontopofthemineralsoilinforestedareas.


downwindLAconcentrationsinambientairduringthefire.InthedraftSite‐wideHumanHealthRiskAssessment(EPA2014),exposureestimatesbasedontheSouseGulchwildfiredatashowedthatestimatedcancerrisksandnon‐cancerhazardsforrespondingfirefightersandinthenearbycommunitywerebelowalevelofconcern.However,theSouseGulchday‐userecreationareaislocatedapproximately4.5milessoutheastfromthemine,inthecrosswinddirectionfromthemine.NomeasureddataareavailableonpotentialairborneconcentrationsofLAduringwildfiresthatmayoccurclosertothemine,whereLAlevelsinsourcematerialsarehigher.Therefore,itiscurrentlyunknownwhetherhigherLAconcentrationsintreebarkandduff,suchasthosemeasurednearthemine,wouldpresentanunacceptablerisktofirefightersintheeventofawildfire.Larger‐scale,high‐intensitywildfirescouldexhibitextremefirebehavioracrossmultipledaysorweeksbecauseofthecomplexinteractionoffuels,weather,andtopography.Assuch,itisdifficulttoaccuratelypredicttheamountofLAthatwouldbereleasedintotheairduringsuchafire.However,itispossibletoconductanABSinvestigationtosimulatepotentialexposuresduringtheinitialattackonalow‐intensity,small‐scalewildfireusingacontrolledprescribedunderstoryburn.Thus,ratherthanwaitforanauthenticwildfiretooccur(whichmayormaynotbeinanareathatisrelevant),anABSinvestigationwillbeconductedtosimulatepotentialexposuresduringalow‐intensitywildfirethatoccursintheforestnearthemine.However,datafromthissmall‐scale,low‐intensityburnwillnotbeusedintheriskassessmenttopredictormodelpotentialexposuresunderlarge‐scale,high‐intensitywildfirescenario.ProjectPlanningTeamThecurrentprojectstakeholdersaredescribedintheSectionA3ofthemaintext.Inbrief,EPAistheleadregulatoryagencyforactivitiesattheSite.TheEPARemedialProjectManager(RPM)forOperableUnit3(OU3)oftheSiteisChristinaProgess.Ms.Progessistheprincipaldatauseranddecision‐makerforSuperfundactivitieswithinOU3.EPAhasenteredintoanAdministrativeOrderonConsent(AOC)(DocketNo.CERCLA‐08‐2007‐0012)withRespondentsW.R.GraceandCompany(Grace)andKootenaiDevelopmentCorporation(KDC)forperformanceofaRemedialInvestigation/FeasibilityStudy(RI/FS)atOU3.UnderthetermsoftheAOC,GraceandKDCwillimplementtheactivitiesdescribedinthisQAPP,underEPAsupervision.TheMontanaDepartmentofEnvironmentalQualityandU.S.ForestServicearesupportagenciesfortheSite.TheU.S.ArmyCorpsofEngineers(USACE),OmahaDistrict,isthecontractingagencyprovidingprojectmanagement,environmentalengineering,andremediationsupportattheSiteonbehalfofEPA;supportserviceswillbeperformedbyUSACE’sarchitectandengineeringfirm,CDMSmith.TheprojectteamorganizationchartispresentedinFigureA‐1inthemainQAPP.ResourcesandScheduleAvailableresourcesforthisprojectincludetheplanningteamentitieslistedaboveaswellastheGracesubcontractorsthatwillbeemployedtoimplementtheactivitiesdescribedintheQAPP.Thescheduleforthisstudywilldependuponstaffavailabilityandenvironmentalconditions(mustallowforaburntobeconductedsafely).ThegoalistocollectdataforinclusionintheSiteriskassessment,whichisexpectedtobefinalizedinthesummerof2015;thus,datamustbecollectedduring


the2015fieldseason(beforetheendofJune2015toallowforadequateanalysistimeandincorporationintotheriskassessment).Step2:IdentifytheGoaloftheStudyTheprimarygoalofthisstudyistoprovidesufficientdataonLAconcentrationsinairtoallowEPAtocompleteanexposureassessmentforfirefightersrespondingtoalow‐intensitywildfireintheforestnearthemine.EPAwillusetheexposureassessmenttoevaluatepotentialriskstohumanhealth.TheriskassessmentwillsupportdecisionsaboutwhetherornotresponseactionsareneededtoprotectfirefightersfromunacceptablerisksfromLAattheSiteduringalow‐intensitywildfire.Thefollowingtablesummarizestheprinciplestudyquestionandpotentialalternativeactions:PrincipleStudyQuestion AlternativeOutcomesWouldairborneLAexposuresforfirefightersrespondingtoalow‐intensitywildfireintheforestnearthemineresultinunacceptablecumulativehumanhealthrisks?

Noresponseactionsneeded.

Responseactionsareneeded.ThenatureoftheseactionswouldbedeterminedaspartoftheFS.TheextentoftheseactionsmayrequirethecollectionofadditionalABSeffortsatalocation(s)furtherfromthemine,whereLAlevelsinsourcematerialsarelower.

AsecondarygoalofthisstudyistocharacterizethelevelsofLAinvariousenvironmentalmediawithintheburnareabothbeforeandaftertheburn.Step3:IdentifyInformationInputsDataNeedsAir.ReliableandrepresentativemeasurementsofLAinairareneededtoquantifypotentialexposurestofirefightersrespondingtolow‐intensitywildfiresattheSite.SuchmeasurementsareobtainedbydrawingaknownvolumeofairthroughafilterduringvariousactivitiesthatdisturbLAsourcematerialsandmeasuringthenumberofLAfibersthatbecomedepositedonthefiltersurface.BarkandDuff.ExtensivedataarealreadyavailableontreebarkandduffmaterialsintheforestedareasattheSite,includingtheareaswhereABSactivitiesareplanned(seeStep4).Inaddition,dataonsourcematerialconcentrationsofLAarenotnecessarytoquantifyexposuresandcharacterizerisks(i.e.,airconcentrationswillnotbequantitativelycorrelatedorpredictedfromLAconcentrationsinsourcematerials);however,LAlevelsintreebarkandduffmaterialshouldbemeasuredtoprovideinformationonthenatureofthesourcematerialsbeingburnedduringtheABSactivities.AshandSoil.Trialburnexperimentsinwoodstoves(Wardetal.2009)andintestburnchambers(EPA2012)indicatethatthemajorityofLAfibersareretainedintheashwhenwoodandduffmaterialsareburned.BecausetheLAbecomesconcentratedinash,thishasthepotentialtobeanimportantsourcemediumforLAexposure.AlthoughmeasuredLAashconcentrationsarenotneededtoquantifyhumanexposures(i.e.,risksarecalculatedbasedonmeasuredairconcentrations),theLAconcentrationsinresidualashwithintheburnareashouldbemeasuredtocharacterizetheLAlevelsinburnareasfollowingawildfire.Inaddition,soilsamplesshouldbecollectedfromtheburnareapriortoconductingtheburnandfollowingmop‐upactivitiestoprovidemeasureddataonhowLAlevelsinsoilchangedue


totheadditionofash.OtherData.Meteorologicaldatashouldberecordedforeachdaythatsamplingoccursinordertocapturecurrentweatherconditions.Informationrecordedshouldinclude:temperature,dewpoint,relativehumidity,windspeed,windgusts,winddirection,andprecipitation.Becauseitispossiblethatmeteorologicalconditionscanchangethroughouttheday,ataminimum,informationshouldberecordedhourly.Thefollowingsectionsdiscussthetypesofexposurescenariosanddisturbanceactivitiesthatshouldbeevaluated,thetypesofairsamplesthatshouldbecollected,andtheanalyticalmethodsthatshouldbeusedtoanalyzethecollectedsamples.ExposureScenariosDuringwildfireresponses,ground‐basedfirefightersmaydisturbLA‐containingsourcematerials(soil,duff,treebark,ash)byavarietyofdifferentactivities(e.g.,cuttingfirelines,clearingbrush,performingmop‐upactivities).Inaddition,LAmayalsobereleasedtoairasacomponentofthesmokeresultingfromthefirewhichcouldexposeindividualsincloseproximitytothewildfire.Dependinguponthetypeofwildfire,itispossiblethatfixed‐wingaircraftorhelicoptersmaybeusedtodropwaterorfireretardantonburningareas.Inthisevent,pilotsmaybeexposedtoLAthathasbeenreleasedintotheairbythefire.Althoughthecollectionofairsamplesfromthecockpitsofrespondingaircraftwasconsideredforthisstudy,itwasdeterminedthatmeasuredairdatawouldnotbecollectedbecause:

InorderforLAexposurestoposeapotentialrisktopilots,airconcentrationsofLAwithinthecockpitwouldneedtoapproach0.02structurespercubiccentimeter(s/cc),expressedintermsofphasecontrastmicroscopy‐equivalent(PCME)LAstructures,forsustainedperiodsoftime22.Duringtheburnchamberstudy,whichburnedduffmaterialscollectednearthemine,theaverageestimatedPCMELAairconcentrationsinthefluegasexhaustrangedfrom0.16to1.71PCMELAs/cc(EPA2012).Therefore,itisunlikelythatconcentrationsinairinsidethecockpitflyingatanelevationabovethissmallscaleburnwillreachlevelsofpotentialconcernforanyextendedduration.

Figure1presentsmeasuredambientairconcentrationsinLibbycollectedduringauthentic

wildfireevents(SRC,Inc.2010).Asshown,measuredambientairconcentrationsaretypicallywellbelow0.0002s/ccbasedontotalLA;thehighestmeasuredairconcentrationwasabout0.0016totalLAs/cc(thePCMELAairconcentrationwouldbeevenlower).Therefore,evenifitwerepresumedthatairconcentrationsinsidethecockpitwereequaltoambientairlevelsmeasuredduringactualwildfire,itisunlikelythatconcentrationswouldreachlevelsofpotentialconcernforanyextendeddurationduringthissmallscaleburn.

DuringtheSouseGulchwildfire,airmonitorswereplacedinsidethecockpitoftheresponding

helicopter.NoLAstructureswereobservedduringtheanalysisoftheairfilterfrominsidethe

2 Thisrisk‐basedthresholdwasderivedassumingapilotexposurescenarioof8hoursperday,14daysperyear,for25years,basedonatargetcancerriskof1E‐04andtargetnon‐cancerhazardquotientof1,andtheLA‐specifictoxicityvalues(EPA2014).


helicopter(i.e.,resultwasnon‐detect;achievedanalyticalsensitivityof0.0024cc‐1),butLAwasdetectedin2of14ground‐basedfirefighterABSairsamples.Theseresultssupporttheconclusionthatground‐basedfirefightershaveahigherpotentialforexposurescomparedtopilots.

Asnotedpreviously,burnstudieshaveshownthatthemajority(92‐99percent[%])ofLAfibers

areretainedintheresultingashandarenotreleasedtoairinsmoke(EPA2012).Becausepilotswouldonlybeexposedtosmokeinair,theirexposureislikelytobemuchlowerthanwhatwouldbeexpectedforaground‐basedfirefighter,whowouldalsobeexposedtoLAresultingfromsoil,duff,treebark,andashdisturbances.Thus,itisappropriatetofocustheABSstudyonthemaximally‐exposedreceptorduringthissmall‐scaleburn.

Thesmall‐scaleburnthatisplannedaspartofthisABSactivityisnotlikelytogenerate

significantamountsofsmokewhichmaybeinterceptedbyrespondingaircraft.Thus,cockpitmeasurementswouldnotbelikelytorepresentexposuresunderauthenticwildfireconditions.

Finally,thecostandlogisticsassociatedwithcommissioninganaircrafttoperformfly‐overs

duringthissmallscaleburnweredeemedunjustifiablegiventhelowlikelihoodofacompleteexposurepathwayunderthelow‐smokeconditionsofthisstudy.

Itisimportanttonotethat,inalargerwildfirescenario,significantlymoresmokecouldbegenerated.Inthatscenario,LAexposuretofirefightersinhelicopterscouldbesignificant,particularlyiftheyflywithwindowsopenand/ordoorsremoved.Inalargerfire,ashandsootcancontaminateboththeinsideandoutsideoftherespondingaircraft,whichcouldincreasepilotandfirefighterexposuretoLA.Inaddition,localresidentsandworkersintheLibbycommunitycouldbeexposedtoLAinambientairintheeventthatawildfiregeneratessignificantlevelsofsmoke.Ground‐basedFirefighterDisturbanceActivitiesInordertosimulateexposureconditionsduringalow‐intensity,small‐scalewildfire,activitiesshouldbeconductedduringacontrolledprescribedunderstoryburn.AvailablefiredatafortheLibbyareasuggestthatabout60%ofwildfirethatoccurintheareaarefrom0.1to0.25acresinsize(USFS,personalcommunication).Thus,theunderstoryburnshouldberepresentativeofanareawithinthissizerange.Totheextentpossible,ground‐basedfirefighteractivitiesshouldattempttomimicauthenticactivitiesthatmaybeperformedduringawildfireresponse.Thiswouldincludeexposuresduringinitialattackfirefightingactivities,whereexposuresarerelatedprimarilytosmokereleaseswhileapplyingwater,whileclearingbrushandcuttingfirelines,aswellasduringmop‐upactivities,wherefirefightersentertheburnareatoaddresshotspotsusingaPulaskitoolorshovel.BasedondiscussionswiththeU.S.ForestService,duringanactualwildfireresponse,twotypesofmop‐upactivitiesarepossibledependingupontheavailabilityofwater.Adrymop‐upscenarioisperformedincaseswhereaccesstowaterislimited;drymop‐upactivitiesconsistofusingaPulaskitoolorshoveltocoverhotspotswithsoiltoextinguishfireandembers.Awetmop‐upscenarioisperformedwherewaterisreadilyavailable;awetmop‐upincludesthesameactivitiesasthedrymop‐up(i.e.,usinghandtoolstocoverhotspotswithsoil),butalsoincludestheapplicationofwatertoextinguishfireandembers.ItisanticipatedthatLAreleasesduringwetmop‐upactivitiesarelikelytobelowerthanduringdrymop‐upbecausetheapplicationofwaterwilllimitairbornereleasesofdust(andLA).However,


bothmop‐upscenariosshouldbeevaluatedintheABStoprovidemeasuredexposuredatathatcanbeusedtoinformwildfireresponsedecision‐making.TypeofAirSampleExperienceatLibbyandatotherasbestossiteshasdemonstratedthat,ifapersonisengagedinanactivitythatdisturbsanasbestossourcematerial,personalairsamples(i.e.,samplesthatcollectairinthebreathingzoneofaperson)tendtohavehigherconcentrationsofasbestosthanairsamplescollectedfromanearbystationarymonitor(EPA2007).Becausepersonalairsamplesaremorerepresentativeofbreathingzoneexposures,whicharemostrelevantforthepurposesofquantifyingexposuresandrisks,totheextentfeasible,firefighterABSairsamplesshouldbecollectedusingpersonalairmonitors(withthemonitorworninthebreathingzoneoftheexposedindividual).Becauseofthelow‐intensity,small‐scalenatureoftheburn,itisnotanticipatedthatsignificantamountsofsmokewillbegenerated;thus,ambientairmonitoringwithintheLibbycommunityisnotdeemedtobenecessary.However,toprovideinformationonthepotentialforoffsitemigrationofLAinairduringaslashpileburn,perimeterairsamplesshouldbecollectedusingstationaryairmonitorsinlocationsthatareneartheburnarea(e.g.,withinabout200feet).Themonitorsshouldbeplacedataheightwithinthetypicalbreathingzone(i.e.,5‐6feet).Totheextentpossible,monitorsshouldbeplacedinlocationswhereother(non‐firerelated)LAsourcedisturbanceactivitiesarelimited.Becauseitispossiblethatwinddirectionmayvaryduringtheburn,stationsshouldbepositionedatapproximatelyeachcompassdirectionaroundtheburnarea.AirSampleAnalysisMethodBecausetheresultingABSairconcentrationswillbeusedtodevelopexposureestimatesforuseinriskassessment,asrecommendedbyEPA(2008),ABSairsamplesshouldbeanalyzedforasbestosbytransmissionelectronmicroscopy(TEM)inbasicaccordancewiththecountingandrecordingrulesspecifiedbytheInternationalOrganizationforStandardization(ISO)Method10312:1995(E)(ISO1995).Becauseasbestostoxicitydependsontheparticlesizeandmineraltype,TEManalysisresultsshouldincludethesizeattributes(i.e.,length,width,aspectratio)ofeachasbestosstructureobserved,alongwiththemineralclassification(i.e.,LA,otheramphibole,chrysotile).Inaddition,becauseitispossiblethattherecouldbevarioussourcesofLApresentintheforestedarea,informationonthesodiumandpotassiumcontentofeachLAstructureobserved,asdeterminedbyenergydispersivespectroscopy(EDS),shouldalsoberecorded.ThisrequirementisbasedontheobservationofMeekeretal.(2003)thatmostLAstructuresfromtheLibbyorebodycontaindetectablelevelsofbothsodiumandpotassium,whereasotherpotentialsourcesofLAmaynot.Calculationsofhumanexposureandriskfromasbestosinairareexpressedintermsofphasecontrastmicroscopy(PCM)s/cc.WhenananalysisisperformedbyTEM,structuresthatsatisfyPCMcountingrulesarereferredtoasPCM‐equivalent(PCME)structures.PCMEstructuresaredefinedasstructureswithalengthgreaterthan(>)5micrometers(µm),awidthgreaterthanorequalto(≥)0.25um,andanaspectratio(length:width)≥3:1.Becausetheseairsamplesarebeingcollectedtosupportexposureassessmentforriskcharacterization,theinstrumentmagnificationandthecountingandrecordingrulesusedduringtheTEManalysismustallowforthequantificationofairconcentrationsbasedonPCME.


SourceMaterialSamplesAllsourcematerialsamplesshouldbecollectedsuchthattheresultingLAconcentrationsarerepresentativeoftheaverageLAlevelsinthematerialsacrosstheburnarea.Treebark,duff,andashsamplesshouldbesampledandanalyzedforasbestosbyTEMfollowingstandardsampling,preparation,andanalysisproceduresspecificallydevelopedforuseattheSite(i.e.,standardoperatingprocedure[SOP]EPA‐LIBBY‐2012‐11andEPA‐LIBBY‐2012‐12).SoilsamplesshouldbesampledusingthestandardsamplingmethodsemployedattheSite(e.g.,30‐pointcomposites),preparedusingtheSite‐specificsievingandgrindingmethods(i.e.,SOP16‐ASB‐06.02),andanalyzedbypolarizedlightmicroscopy(PLM),inaccordancewiththeSite‐specificPLMmethodsdevelopedforuseindeterminingLAlevelsinsoil(i.e.,SRC‐LIBBY‐01andSRC‐LIBBY‐03).UseoftheSite‐specificSOPswillensurecomparabilityoftheresultswithotherinvestigationsthathavebeenconductedattheSite.Step4:DefinetheBoundsoftheStudySpatialBoundsIdeally,inconcept,ABSwouldoccuratmultipleareasacrosstheSitetoallowriskstobecalculatedatvariousdistancesfromthemineinalldirectionstoencompasstherangeofexposureconditions.However,thiswouldrequireperformingABSoveranareaofhundredsofsquaremiles,whichisnotfeasible,andsettingcontrolledburnsatvariouslocationsthroughouttheforest,whichisnotpracticalorsafe.Asnotedabove,availabledataonlevelsofLAmeasuredinbark,soil,andduffindicatethatthelevelsofLAinthesesourcematerialstendtodecreasewithdistanceawayfromthecenterofthemine.Therefore,theapproachthatwillbetakenforthisstudyistoconductABSinanareaneartheminethatisrepresentativeofhighpotentialLAexposure(e.g.,inanareathatisdownwindfromtheminewherethehighestconcentrationsofLAhavebeenreportedintreebarkandduff).Thereisanarealocatedabout1miledownwindfromtheminethatisboundedbyfoursamplingstationswheresomeofthehighestLAconcentrationshavebeenmeasuredinduff(seeFigureB‐2ofmainQAPP).ThisareaalsocoincideswiththelocationwherethecommercialloggingABSinvestigationwasconductedin2012(CDMSmith2013a).Therefore,theburnshouldbeconductedwithinthisABSareanearthemine(seeFigureB‐2ofmainQAPP).TheactualABSlocationselectedwithinthisareawilldependupontheeaseofaccessandarearequirementstosafelyconductacontrolledprescribedunderstoryburn.IfpotentialrisksinthisnearABSareaareabovealevelofconcern,additionalsimulatedfirefighterABSeffortsatalocation(s)furtherfromthemine,whereLAlevelsinsourcematerialsarelower,maybenecessarytosupportriskmanagementdecisions.TemporalBoundsThereleaseofLAfromsourcematerials(soil,duff,bark,ash)intoairduringawildfireisexpectedtodependonseveralfactorsthatmaytendtovaryovertime,including,forexample,themoisturecontentofthesourcematerials,theintensityofthefire,andthewindspeedanddirection.Ingeneral,itisexpectedthatLAreleasestoairwilltendtobehigherinthedrysummermonths(July‐September)thanduringwetconditionsinspringorfall.Additionally,itiswithinthistimeperiodthatauthenticwildfiresmayactuallyoccur.Thus,ideally,ABSdatawouldbecollectedinthesummermonths,toensurethat


measuredABSairdataobtainedduringdryperiodsismorelikelytooverestimatethanunderestimatetheactuallong‐termmeanexposure.However,thissamplingtimewillbeadjustedasnecessarytoensurethatthecontrolledprescribedunderstoryburncanbesafelyconducted(i.e.,setfiresmustbeabletobecontrolledwithintheestablishedburnareaandappropriatepersonnelmustbeavailabletoensurefireremainscontained).ItisanticipatedthattheburnwouldneedtooccurinMayorOctobertobeperformedsafely.ThespecificdatesoftheABSarenotimportant,butthegoalistoconducttheABSactivitiesin2015toallowforthesedatatosupportSiteriskassessmentanddecision‐makingaspartoftheRI/FSprocessforOU3.Step5:DefinetheAnalyticalApproachRiskAssessmentTheABSairconcentrationsfromthisstudywillbeusedtocalculateanexposurepointconcentration(EPC).InaccordancewithEPAguidance,theEPCwillbecalculatedastheaveragemeasuredABSairconcentrationtreatingnon‐detectsaszero(EPA2008).TheEPCwillbecombinedwithassumptionsaboutexposurefrequencyanddurationandtoxicityfactorsinahumanhealthriskassessmentthatisexpectedtoprovideabasisforEPAtodetermine,inconsultationwithotherSitestakeholders,whetherresponseactionsareneededtoprotecthumanhealth.TheLA‐specifictoxicityvalues(EPA2014)willbeusedtoestimatecancerrisksandnon‐cancerhazardquotients(HQs)fromexposurestoLAinair.Thelifetimeinhalationunitrisk(IUR)valueis0.17(PCMs/cc)‐1andthelifetimereferenceconcentration(RfC)valueis0.00009PCMs/cc(EPA2014).BasicmethodsforestimatinghumanhealthriskfromLAinairareprovidedbelow.EstimationofCancerRiskThebasicequationforestimatingcancerriskfromLAusingtheLA‐specificIURvalueisasfollows: Risk=EPC⋅TWF⋅IURLAwhere:

Risk=Lifetimeexcessriskofdevelopingcancer(lungcancerormesothelioma)asaconsequenceofLAexposureEPC=ExposurepointconcentrationofLAinair(PCMorPCMEs/cc).TheEPCisanestimateofthelong‐termaverageconcentrationofLAininhaledairforthespecificactivitybeingassessed.TWF=Time‐weightingfactor.ThevalueoftheTWFtermrangesfromzerotoone,anddescribestheaveragefractionofalifetimeduringwhichexposureoccursfromthespecificactivitybeingassessedandiscalculatedas: TWF=ET/24⋅EF/365⋅ED/70


where: ET=Averageexposuretime(hours/day) EF=Averageexposurefrequency(days/year) ED=Exposureduration(years)

IURLA=LA‐specificlifetimeinhalationunitrisk(LAPCMs/cc)‐1

EstimationofNon‐CancerHazardQuotientThebasicequationforcharacterizingnon‐cancerriskfromLAusingtheLA‐specificRfCvalueisasfollows: HQ=EPC⋅TWF/RfCLAwhere:

HQ=Hazardquotientfornon‐cancereffectsfromLAexposureEPC=ExposurepointconcentrationofLAinair(PCMorPCMEs/cc)TWF=Time‐weightingfactorRFCLA=LA‐specificlifetimereferenceconcentration(LAPCMs/cc)

DecisionRuleEPAguidanceprovidedintheOfficeofSolidWasteandEmergencyResponseDirective#9355.0‐30,RoleoftheBaselineRiskAssessmentinSuperfundRemedySelectionDecisions(EPA1991)indicatesthatifthecumulativecancerrisktoanindividualbasedonreasonablemaximumexposure(RME)islessthan1E‐04andthecumulativenon‐cancerHQislessthan1,thenremedialactionisgenerallynotwarrantedunlessthereareadverseenvironmentalimpacts.Theguidancealsostatesthatariskmanagermaydecidethatarisklevellowerthan1E‐04isunacceptableandthatremedialactioniswarrantedwherethereareuncertaintiesintheriskassessmentresults.SourceMaterialCharacterizationAsnotedabove,dataonsourcematerialconcentrationsofLAarenotnecessarytoquantifyexposuresandcharacterizerisks(i.e.,airconcentrationswillnotbequantitativelycorrelatedorpredictedfromLAconcentrationsinsourcematerials).However,LAlevelsintreebarkandduffmaterialwillbesummarizedtoprovideinformationonthenatureofthesourcematerialsbeingburnedduringtheABSactivitiesandLAconcentrationsinresidualashwithintheburnareawillbesummarizedtocharacterizetheLAlevelsinburnareasfollowingawildfire.Inaddition,LAconcentrationsinsoilsamplescollectedpriortoconductingtheburnandfollowingmop‐upactivitieswillalsobesummarizedtoillustratehowLAlevelsinsoilchangeduetotheadditionofash.


Step6:SpecifyPerformanceCriteriaInmakingdecisionsabouttheriskstohumansattheSite,twotypesofdecisionerrorsarepossible: AfalsenegativedecisionerrorwouldoccurifariskmanagerdecidesthatexposuretoLAisnotof

healthconcern,wheninfactitisofconcern. AfalsepositivedecisionerrorwouldoccurifariskmanagerdecidesthatexposuretoLAisabove

alevelofconcern,wheninfactitisnot.EPAismostconcernedaboutguardingagainsttheoccurrenceoffalsenegativedecisionerrors,sinceanerrorofthistypemayleavehumansexposedtounacceptablelevelsofLA.Tominimizechancesofunderestimatingthetrueamountofexposureandrisk,EPAgenerallyrecommendsthatriskcalculationsbebasedonthe95%upperconfidencelimit(95UCL)ofthesamplemean(EPA1992).Useofthe95UCLinriskcalculationslimitstheprobabilityofafalsenegativedecisionerrortonomorethan5%.Tosupportthisapproach,EPAhasdevelopedasoftwareapplication(ProUCL)toassistwiththecalculationof95UCLvalues(EPA2010).However,equationsandfunctionsinProUCLarenotdesignedforasbestosdatasetsandapplicationofProUCLtoasbestosdatasetsisnotrecommended(EPA2008).Becausethe95UCLcannotpresentlybecalculatedwithconfidence,EPCsshouldbecalculatedasthearithmeticmean,treatingnon‐detectsaszero,asrecommendedbyEPA(2008).Thismeansthatriskestimatesmaybeeitherhigherorlowerthantruevalues,andthisshouldbeidentifiedasasourceofuncertaintyintheriskassessment.EPAisalsoconcernedwiththeprobabilityofmakingfalsepositivedecisionerrors.Althoughthistypeofdecisionerrordoesnotresultinunacceptablehumanexposure,itmayresultinunnecessaryexpenditureofresources.Theriskoffalsepositivedecisionerrorscanbeminimizedbyincreasingthenumberofsamples.Thenumberofsamplesneededdependsonthemagnitudeofbetween‐samplevariabilityandtheproximityofEPCtothedecisionthreshold.Ifbetween‐samplevariabilityislow,oriftheEPCisnotnearadecisionthreshold,thenthenumberofsamplesneededisrelativelylow.However,ifbetween‐samplevariabilityishighandtheEPCisrelativelynearadecisionthreshold,thenthenumberofsamplesneededisusuallyhigher.BasedonmeasureddatafromotheroutdoorABSsamplingefforts,thereisoftensubstantialvariabilityinmeasuredoutdoorABSconcentrationsofLAinairundersourcedisturbanceactivitiesanditispossiblethatmeasuredconcentrationsmaybenearriskmanagementdecisionthresholds.Becauseitisnotpossibleatpresenttoquantifytheuncertaintyinthemeanofanasbestosdatasetasafunctionofthenumberofsamples,itisnotpossibletocalculatetheminimumnumberofsamplesrequiredtominimizetheriskoffalsepositivedecisionerrors.DuetothenatureofthisABSeffort–asmall‐scale,controlledunderstoryburnwithalimitednumberofparticipatingfirefighters–itmaynotbepossibletocollectenoughsamplestofullycharacterizetheextentofvariabilityanduncertaintyassociatedwiththisexposurescenario.Totheextentfeasible,thisstudyshouldmaximizethenumberofsamplescollectedsuchthattherearemultipleairmeasurementsacrossmultipleindividualsandactivities.IftheresultsofthisABSeffortshowthattheairdataarevariableand/orarenearadecisionthreshold,additionalsamplingand/oranalysismaybeneededtosupportriskmanagementdecision‐making.


Step7:DevelopthePlanforObtainingDataAdetailedstudydesignforthecollectionofunderstoryburnABSdataattheSiteisprovidedinSectionB1ofthisQAPP.Keyfeaturesofthesamplecollectionstrategyandanalyticalrequirementsarediscussedbelow.OptimizingtheSampleCollectionStrategyTwokeyvariablesthatmaybeadjustedduringcollectionofairsamplesaresamplingdurationandpumpflowrate.Theproductofthesetwovariablesdeterminestheamountofairdrawnthroughthefilter,whichinturnisanimportantfactorintheanalyticalcostandfeasibilityofachievingthetargetanalyticalsensitivity(TAS).Ingeneral,longersamplingtimesarepreferredovershortersamplingtimesbecausea)longertimeintervalsaremorelikelytoyieldrepresentativemeasuresoftheaverageconcentration(asopposedtoshort‐termfluctuations),andb)longercollectiontimesareassociatedwithhighervolumes,whichmakesiteasiertoachievetheTAS.Likewise,higherflowratesaregenerallypreferredoverlowerflowratesbecausehighflowresultsinhighvolumesdrawnthroughthefilterovershortersamplingtimes.However,thereisalimittohowmuchaircanbedrawnthroughafilter.Incaseswheretheairbeingsampledcontainsasignificantlevelofairborneparticulates(e.g.,dust,smoke),itispossiblethatparticulateloadingonthefiltercouldinfluencetheabilitytomaintaintheoptimalflowrate.Tominimizethispossibility,pumpflowratesshouldbecheckedregularlythroughoutthecollectionperiodandfiltercassettesshouldbechangedifflowratesbecomeimpacted.Whileparticulateloadingonthefiltermaynotimpactpumpflowrates,itispossiblethatthefilterwillbecomesooverloadedwithairborneparticulatesthatthefiltercannotbeexamineddirectlybytheTEManalyst.Inthisevent,thefiltermustundergoanindirectpreparationinwhichtheoriginalfilterisashedandtheresultingresidueissuspendedinwaterandre‐depositedonasecondaryfilter,suchthatthesecondaryfilterisnotoverloaded.Site‐specificstudiesontheeffectofindirectpreparationonreportedLAairconcentrationsshowthatindirectpreparationusuallyincreasedreportedPCMELAairconcentrations,buttheconcentrationswerewithinafactorofabout2‐4comparedtodirectpreparation(GoldadeandO’Brien2014).However,toreducethefrequencyofindirectpreparations,ABSairfiltercassetteswillbechangedoutfrequently(e.g.,every15minutes)tominimizepotentialoverloading.Inaddition,eachABSairsamplewillbecollectedusingtwodifferentsamplingpumps–onethatoperatesatahighflowrate(whichistheprimarysample)andonethatoperatesatalowflowrate(whichisusedasasampleback‐up).Wheneverpossible,thefilterfromthehighflowpumpwillbeselectedforanalysis.Incaseswherethehighflowfilterisdeemedtobeoverloaded(i.e.,theparticulateloadingonthefilteris>25%),thenthelowflowfilterwillbeanalyzed.Ifbothfiltersaredeemedtobeoverloaded,thehighflowfilterwillbepreparedindirectlyfollowingashing.AnalyticalRequirementsforABSAirSamplesIngeneral,threealternativestoppingrulesarespecifiedforTEManalysestoensureresultingdataareadequate:


1.TheTAStobeachieved2.Amaximumnumberofstructurestobecounted3.Amaximumareaoffiltertobeexamined

Thebasisforeachofthesevaluesforthisstudyispresentedbelow.TargetAnalyticalSensitivityThelevelofanalyticalsensitivityneededtoensurethatanalysisofABSairsampleswillbeadequateisderivedbyfindingtheconcentrationofLAinABSairthatmightbeofpotentialconcern,andthenensuringthatifanABSsamplewereencounteredthathadatrueconcentrationequaltothatlevelofconcern,itwouldbequantifiedwithreasonableaccuracy.Thisprocessisimplementedbelow:

Step1.CalculationofRisk‐BasedConcentrationsCancer.Thebasicequationforcalculatingtherisk‐basedconcentration(RBC)forcanceris: RBCcancer=TargetCancerRisk/(TWF⋅IURLA)Forcancer,thetargetcancerriskisariskmanagementdecision.ForthepurposesofcalculatinganadequateTAS,avalueof1E‐05isassumed.TheexposureparametersneededtocalculateTWFarenotknownwithcertainty,sothefollowingRMEexposureparameterswereselectedbasedoninformationprovidedbylocalU.S.ForestServicepersonnel.

ExposureParameter Value

ExposureTime 15hours/dayExposureFrequency 14days/yearExposureDuration 25years

RME TWF 0.0086BasedontheRMETWFvaluespresentedabove,theRBCcanceris0.0069LAPCMEs/ccforthefirefighterscenario.Non‐Cancer.ThebasicequationforcalculatingtheRBCfornon‐cancereffectsis: RBCnon‐cancer=(TargetHQ⋅RfCLA)/TWFFornon‐cancer,thetargetHQis1.BasedontheTWFvaluespresentedabove,theRBCnon‐canceris0.011LAPCMEs/ccforthefirefighterscenario.BecausetheRBCforcancerislowerthantheRBCfornon‐cancer,theRBCcancerisusedtoderivetheTAS.


Step2:DeterminingtheTargetAnalyticalSensitivityTheTASisdeterminedbydividingtheRBCbythetargetnumberofstructurestobeobservedduringtheanalysisofasamplewithatrueconcentrationequaltotheRBC: TAS=RBC/TargetCountThetargetcountisdeterminedbyspecifyingaminimumdetectionfrequencyrequiredduringtheanalysisofsamplesattheRBC.Thisprobabilityofdetectionisgivenby: Probabilityofdetection=1‐Poisson(0,TargetCount)Assumingaminimumdetectionfrequencyof95%,thetargetcountis3structures.Basedonthis,theTASis: TAS=(0.0069s/cc)/(3s)=0.0023cc‐1Thus,ananalyticalsensitivityof0.002cc‐1(roundedvalue)willbeusedasthetargetforallairsamplescollectedinthisABSstudy.

MaximumNumberofLAStructuresIdeally,allsampleswouldbeexaminedbyTEMuntiltheTASisachieved.However,forfiltersthathavehighasbestosloading,reliableestimatesofconcentrationmaybeachievedbeforeachievingtheTAS.ThisisbecausetheuncertaintyaroundaTEMestimateofasbestosconcentrationinasampleisafunctionofthenumberofstructuresobservedduringtheanalysis.The95%confidenceinterval(CI)aroundacountofNstructuresiscomputedasfollows:

Lowerbound(2.5%)=½∙CHIINV(0.975,2∙N+1)Upperbound(97.5%)=½∙CHIINV(0.025,2∙N+1)

AsNincreases,theabsolutewidthoftheCIrangeincreases,buttherelativeuncertainty(expressedastheCIrangedividedbyN)decreases.ThisconceptisillustratedinFigure2.ThegoalistospecifyatargetNsuchthattheresultingPoissonvariabilityisnotasubstantialfactorintheevaluationofmethodprecision.AsshowninFigure2,aboveabout25structures,thereislittlechangeintherelativeuncertainty.Therefore,thecount‐basedstoppingruleforTEMshouldutilizeamaximumstructurecountof25structures.BecausetheABSairconcentrationswillbeusedtoestimatepotentialrisks,whicharederivedbasedonthetotalnumberofstructuresthatmeetPCMcountingrules,themaximumstructurecountisapplicabletoPCMELAstructures(nottotalLAstructures).MaximumAreatobeExaminedThenumberofgridopeningsthatmustbeexaminedtoachievethetargetanalyticalsensitivityiscalculatedas:


GOx=EFA/(TAS∙Ago∙V∙1000∙f)

where:

EFA=Effectivefilterarea(assumedtobe385squaremillimeters[mm2])TAS=Targetanalyticalsensitivity(cc)‐1Ago=Gridopeningarea(assumedtobe0.01mm2)V=Sampleairvolume(liters[L])1000=L/cc(conversionfactor,literstocubiccentimeters[L/cc])f=Indirectpreparationdilutionfactor(equalto1fordirectpreparation)

Atotalofabout320gridopeningswillneedtobeexaminedtoachievetheTAS,assuminganairsamplevolumeof60liters(15minutesampledurationx4liters/minuteflowrate)andthatthefilterisabletobeprepareddirectly.Ifanindirectpreparationisnecessary,thenumberofgridopeningsthatwillneedtobeexaminedisinverselyproportionaltothedilutionneeded(i.e.,anf‐factorof0.1willincreasethenumberofgridopeningsbyafactorof10).Ifthef‐factorisverysmall,itispossiblethatthenumberofgridopeningsthatwouldneedtobeexaminedtoachievetheTASmaybecostortimeprohibitive.Inordertolimitthemaximumeffortexpendedonanyonesample,amaximumareaexaminedof7mm2isidentifiedforthisproject.Assumingthateachgridopeninghasanareaofabout0.01mm2,thiswouldcorrespondtoabout700gridopenings.SummaryofTEMStoppingRulesforAirSamplesTheTEMstoppingrulesforairsamplescollectedinthisstudyshouldbeasfollows:1.Examineaminimumoftwogridopeningsfromeachoftwogrids.2.Continueexamininggridopeningsuntiloneofthefollowingisachieved: a.TheTASof0.002cc‐1isachieved. b.25PCMELAstructureshavebeenobserved. c.Atotalfilterareaof7mm2hasbeenexamined.Whenoneofthesecriteriahasbeensatisfied,completetheexaminationofthefinalgridopeningandstop.SourceMaterialSamplesAsnotedpreviously,ensurecomparabilityoftheresultswithotherinvestigationsthathavebeenconductedattheSite,treebark,duff,ash,andsoilsamplesshouldbesampledandanalyzedforasbestosfollowingstandardsampling,preparation,andanalysisproceduresspecificallydevelopedforuseattheSite.BecausetheobjectiveisprovideLAconcentrationsrepresentativeoftheaverageLAlevelsinthematerialsacrosstheburnarea,thisshouldbeaccomplishedbythecollectionofseveralmulti‐pointcompositesamples,with3‐5compositesamplescollectedforeachmedium.ThefollowingtablesummarizestheSite‐specificsamplingandanalysisproceduresforeachmediumthathavebeenemployedinpaststudiesthatshouldalsobeusedinthisstudy.


Medium SamplingMethod AnalysisMethodTreebark 3‐5pointcomposite collectedusinga

holesaw,seeSOPEPA‐LIBBY‐2012‐12forspecificsamplingprocedures

TEM,seeSection6.2ofSOPEPA‐LIBBY‐2012‐12forspecificpreparationprocedures,analysismethods,andstoppingrules

Duff 5pointcomposite,seeSOPEPA‐LIBBY‐2012‐11forspecificsamplingprocedures


Ash 30‐pointcompositeplacedintoacontainerandhomogenized,3aliquotssub‐sampledforanalysis


Soil 30‐pointcomposite,seeSOPNo.1forspecificsamplingproceduresandSOP16‐ASB‐06.02forspecificsievingandgrindingprocedures

PLM,seeSOPsSRC‐LIBBY‐01andSRC‐LIBBY‐03forspecificanalysisprocedures

REFERENCESCDMSmith.2013a.DataSummaryReport:2007to2012,LibbyAsbestosSuperfundSite,OperableUnit3.Denver,Colorado:CDMFederalProgramsCorporation.ReportpreparedforU.S.EnvironmentalProtectionAgency.Revision0–November2013;Revision1–July2014. .2013b.DataSummaryReport:NatureandExtentofLAContaminationintheForest,LibbyAsbestosSuperfundSite.Denver,Colorado:CDMFederalProgramsCorporation.ReportpreparedforU.S.EnvironmentalProtectionAgency.August. .2013c.LibbyAsbestosResponsePlan:WildfireQualityAssuranceProjectPlan.Denver,Colorado:CDMFederalProgramsCorporationandU.S.ArmyCorpsofEngineers.ReportpreparedforU.S.EnvironmentalProtectionAgency.Revision0‐August.EPA(U.S.EnvironmentalProtectionAgency).1991.RoleoftheBaselineRiskAssessmentinSuperfundRemedySelectionDecision.Washington,D.C.:U.S.EnvironmentalProtectionAgency,OfficeofSolidWasteandEmergencyResponse.OSWERDirectiveNumber9355.0‐30.April.http://www.epa.gov/oswer/riskassessment/pdf/baseline.pdf .1992.SupplementalGuidancetoRAGS:CalculatingtheConcentrationTerm.UnitedStatesEnvironmentalProtectionAgency,OfficeofSolidWasteandEmergencyResponse.Publication9285.7‐081. .2001.EPARequirementsforQualityAssuranceProjectPlans,QA/R‐5.Final.March. .2006.GuidanceonSystematicPlanningUsingtheDataQualityObjectiveProcess,QA/G‐4.February. .2007.SummaryReportforDataCollectedundertheSupplementalRemedialInvestigationQualityAssuranceProjectPlanLibby,MontanaSuperfundSite.U.S.EnvironmentalProtectionAgency,Region8.


October. .2008.FrameworkforInvestigatingAsbestos‐ContaminatedSites.ReportpreparedbytheAsbestosCommitteeoftheTechnicalReviewWorkgroupoftheOfficeofSolidWasteandEmergencyResponse,U.S.EnvironmentalProtectionAgency.OSWERDirective#9200.0‐68.___.2010.ProUCLVersion5.0TechnicalGuide(Draft).U.S.EnvironmentalProtectionAgency,OfficeofResearchandDevelopment.EPA/600/R‐07/041.May2010.http://www.epa.gov/esd/tsc/ProUCL_v4.00.05/ProUCL_v4.00.05_tech_guide(draft).pdf .2012.EmissionsofLibbyAmphiboleAsbestosfromtheSimulatedOpenBurningofDufffromLibby,MT.PreparedforEPARegion8byEPAOfficeofResearchandDevelopment.EPA/600/R‐12/063.December.http://cfpub.epa.gov/si/si_public_record_report.cfm?dirEntryId=246451 _.2013.WildfireContingencyMonitoringPlan,OperableUnit3,LibbyAsbestosSuperfundSite.U.S.EnvironmentalProtectionAgencywithtechnicalassistancefromCDMFederalPrograms.Revision1‐August. _.2014.LibbyAsbestosSuperfundSite,Site‐wideHumanHealthRiskAssessment.Denver,Colorado:CDMFederalPrograms.ReportpreparedforU.S.EnvironmentalProtectionAgency.December.Goldade,MP,andO’Brien,WP.2014.Useofdirectversusindirectpreparationdataforassessingriskassociatedwithairborneexposuresatasbestos‐contaminatedsites.JournalofOccupationalandEnvironmentalHygiene11(2):67‐76.MeekerGP,BernAM,BrownfieldIK,LowersHA,SutleySJ,HoeffenTM,VanceJS.2003.TheCompositionandMorphologyofAmphibolesfromtheRainyCreekComplex,NearLibby,Montana.AmericanMineralogist88:1955‐1969.SRC,Inc.2010.EvaluationofAvailableAmbientAirDataCollectedDuringFireIncidentswithinOperableUnit3oftheLibbyAsbestosSuperfundSite.Denver,Colorado:SRC,Inc.ReportpreparedfortheU.S.EnvironmentalProtectionAgency.WardTJ,HartJF,SpearTM,MeyerBJ,andWebberJS.2009.FateofLibbyamphibolefiberswhenburningcontaminatedfirewood.EnvironmentalScienceandTechnology43(8):2878–2883.


Source:SRC,Inc.(2010)

Incident # Incident Name Start Stop1* Alexander 5/7/07 5/7/072* Upper Pipe 11A 5/9/07 5/9/073 Kennedy Gulch 7/17/07 7/25/074 Ranger's Backyard 7/17/07 7/25/075 Osprey Cliff 7/17/07 7/25/076 Water Dog 7/17/07 7/25/077 Reinshagen Gulch 7/17/07 7/25/078 Sheldon Bench 7/18/07 7/25/079 Little Jackson 7/19/07 9/6/07

10 Gulcher 7/20/07 7/25/0711 Rainy Ridge 7/24/07 8/7/0712 Jackson Jean 7/27/07 8/1/0713 Gulch Ridge 7/28/07 7/29/0714 Alexander Powertrail 9/14/07 10/9/0715* Jackson Creek 5/19/08 5/19/0816 Big Bend 7/2/08 7/3/0817 Souse Ridge 8/9/08 8/11/0818 Alexander 8/9/08 8/21/0819 MRE 8/9/08 8/12/08

* Prescribed fire

FIGURE 1Measured Ambient Air Data and Fire Incident Occurrences

Average ambient air concentrations for OU2, OU4, and OU6 are based on data available in Libby2 as of 9/30/08. Average ambient air concentrations for OU3 are based on data available as of 7/16/09.

1 345678

9101112

13

14 15 16 171819

2

-0.00160

-0.00110

-0.00060

-0.00010

0.00040

0.00090

0.00140

09/30

/06

11/14

/06

12/29

/06

02/12

/07

03/29

/07

05/13

/07

06/27

/07

08/11

/07

09/25

/07

11/09

/07

12/24

/07

02/07

/08

03/23

/08

05/07

/08

06/21

/08

08/05

/08

09/19

/08

11/03

/08

Me

an

To

tal L

A A

ir C

on

c (

s/c

c) OU4

OU2OU6OU3

Incide

nt # and

duratio

n


FIGURE2

RELATIONSHIPBETWEENTHENUMBEROFSTRUCTURESOBSERVEDANDRELATIVEUNCERTAINTY

CI=confidenceinterval

APPENDIX B

STANDARD OPERATING PROCEDURES**

SOP ID SOP Description

OU3 No. 1 Soil Sampling for Non-Volatile Organic Compound Analysis

OU3 No. 7 Equipment Decontamination OU3 No. 8 Sample Handling and Shipping OU3 No. 9 Field Documentation OU3 No. 11 GPS Data Collection OU3 No. 12 Investigation Derived Waste (IDW) Management EPA-LIBBY-2012-11 Sampling and Analysis of Duff for Asbestos EPA-LIBBY-2012-12 Sampling and Analysis of Tree Bark for Asbestos ABS-LIBBY-OU3 Activity-based Sampling for Asbestos

EPA-LIBBY-08 Indirect Preparation of Air and Dust Samples for TEM Analysis

SRC-LIBBY-01 PLM Gravimetric Evaluation SRC-LIBBY-03 PLM Visual Area Estimation

16-ASB-06.02 Soil Sample Preparation at the Troy Sample Preparation Facility

EPA-LIBBY-09 SOP for TEM Data Review and Data Entry Verification EPA-LIBBY-10 SOP for PLM Data Review and Data Entry Verification EPA-LIBBY-11 SOP for FSDS Data Review and Data Entry Verification

**The most recent versions of field SOPs are provided electronically in the OU3 eRoom (https://team.cdm.com/eRoom/mt/LibbyOU3). The most recent versions of laboratory and data verification SOPs are provided electronically in the Libby Lab eRoom (https://team.cdm.com/eRoom/mt/LibbyLab).


APPENDIX C

ANALYTICAL REQUIREMENTS SUMMARY SHEET

[BURNOU3-0515]

**The most recent version of the summary sheet for this investigation is available in the OU3 eRoom.


Requirements Summary: #BURNOU3-0515 Requirements Revision #: 1

Effective Date: May 15, 2015

Page 1 of 4

SAP/QAPP ANALYTICAL SUMMARY # BURNOU3-0515 SUMMARY OF PREPARATION AND ANALYTICAL REQUIREMENTS

Title: Low-Intensity Prescribed Understory Burn Activity-Based Sampling, Operable Unit 3, Libby Asbestos Superfund Site SAP/QAPP Date/Revision: May 15, 2015 (Revision 0) EPA Technical Advisor: Christina Progess (303-312-6009, [email protected]) (contact to advise on DQOs of SAP related to preparation/analytical requirements) Sampling Program Overview: The purpose of this study is to collect samples of air during a prescribed understory burn in the forest area near OU3. All air samples will be analyzed by TEM under low magnification. Samples of bark and duff will be collected prior to the burn and ash will be collected after the burn; all samples will be analyzed by TEM. In addition, samples of soil from the burn area will be collected before and after the fire and analyzed by PLM. Index ID Prefix: UB-0xxxx Estimated number (excluding field QC) and timing of field samples: Samples will be collected in late May-early June timeframe (exact dates to be determined) >> Air: ABS Air = 16 samples; Perimeter Air = 32 samples >> Source Media: Bark = 5 samples; Duff = 5 samples; Ash = 3 samples; Soil = 6 samples TEM Preparation and Analytical Requirements for Air Samples [a]:

Medium Code Medium

Preparation Details [b] Analysis Details Applicable Laboratory Modifications

(current version of) Investi-gative?

Indirect Prep? Filter Archive? Method Recording

Rules Analytical Sensitivity/

Stopping Rules With Ashing

Without Ashing

A ABS Air*

Yes Yes, if material is overloaded (>25%) or unevenly loaded on

filter

No Yes TEM – Modified

ISO 10312,

Annex E (Low Mag,

5,000X)

All PCME asbestos [c]; L: > 5 µm

W: > 0.25 µm AR: > 3:1

Count a minimum of 2 grid openings in 2 grids, then continue counting until one is achieved: i) target sensitivity of 0.002 cc-1 is achieved ii) 25 PCME LA structures are recorded iii) A total filter area of 7.0 mm2 has been examined (approx. 700 GOs)

LB-000016, LB-000029, LB-000066, LB-000067, LB-000085, LB-000091

B Perim. Air

*ABS air samples should be analyzed first (in preference to perimeter air samples and source media samples)



Page 2 of 4

[a] The high volume filter will be analyzed in preference to the low volume filter if direct preparation is possible. If the high volume filter is overloaded, use the low volume filter. If the low volume filter is overloaded, prepare indirectly (with ashing), calculate number of grid openings to analyze to reach target analytical sensitivity and contact EPA project managers or their designate before proceeding with analysis. [b] See most current version of SOP EPA-LIBBY-08 (as modified by LB-000091) for preparation details. [c] If observed, chrysotile structures should be recorded, but chrysotile structure counting may stop after 25 structures have been recorded. TEM Preparation and Analytical Requirements for Field Quality Control Samples:

Medium Code

Medium, Sample Type

Preparation Details Analysis Details Applicable Laboratory Modifications

(current version of)

Indirect Prep? Archive? Method Recording

Rules Stopping Rules With Ashing

Without Ashing

C Air, lot & field

blanks

No No Yes TEM – Modified

ISO 10312, Annex E

(Low Mag, 5,000X)

All PCME asbestos; L: > 5 µm

W: > 0.25 µm AR: > 3:1

Examine 0.1 mm2 of filter area. LB-000016, LB-000029, LB-000066, LB-000067,

LB-000085

H Water, equipment

rinsate

--[d] Yes TEM – ISO 10312 (High

Mag, 20,000X)

All asbestos; L: > 0.5 µm AR: > 3:1

Count a minimum of 2 grid openings in 2 grids, then continue counting until one is achieved: i) sensitivity of 50,000 L-1 is achieved ii) 25 structures are recorded iii) A total filter area of 1.0 mm2 has been examined (approx. 100 grid openings)

LB-000016, LB-000029, LB-000066, LB-000067, LB-000085, LB-000091

[d] Sample and filter preparation should be performed in basic accordance with EPA Method 100.2 (as modified by the most current version of LB-000020). Grid preparation should be performed in basic accordance with Section 9.3 of ISO 10312:1995(E).



Page 3 of 4

TEM Preparation and Analytical Requirements for Bark, Duff, Ash Samples:

Medium Code Medium

Preparation Details Analysis Details Applicable Laboratory Modifications

(current version of) Investi- gative?

Indirect Prep? Filter Archive? Method Recording

Rules Analytical Sensitivity/

Prioritized Stopping Rules With Ashing

Without Ashing

D Bark Yes --- [e] --- Yes TEM – Modified

ISO 10312 (see Section 6.2 of SOP

EPA-LIBBY-2012-12)


Count a minimum of 2 grid openings in 2 grids, then continue counting until one is achieved: i) sensitivity of 100,000 cm-2 is achieved ii) 25 LA structures are recorded iii) 1.0 mm2 of filter has been examined

LB-000016, LB-000029, LB-000066, LB-000067, LB-000085, LB-000091

E Duff Yes --- [e] --- Yes TEM – Modified


EPA-LIBBY-2012-11)


Count a minimum of 2 grid openings in 2 grids, then continue counting until one is achieved: i) sensitivity of 1E+07 g-1 is achieved ii) 25 LA structures are recorded iii) 1.0 mm2 of filter has been examined

LB-000016, LB-000029, LB-000066, LB-000067, LB-000085, LB-000091

F Ash Yes --- [f] --- Yes TEM – Modified


EPA-LIBBY-2012-11)


Count a minimum of 2 grid openings in 2 grids, then continue counting until one is achieved: i) sensitivity of 1E+07 g-1 is achieved ii) 25 LA structures are recorded iii) 1.0 mm2 of filter has been examined

LB-000016, LB-000029, LB-000066, LB-000067, LB-000085, LB-000091

[e] Prepare samples in accordance with the procedures in SOP EPA-LIBBY-2012-11 or SOP EPA-LIBBY-2012-12 as appropriate (see Section 6). One filter will be created for each sample and analyzed. Any remaining ash material should be archived for possible future analysis. [f] Prepare samples in accordance with the procedures in SOP EPA-LIBBY-2012-11 (see Section 6). A total of three replicate filters will be created and analyzed for each ash sample using separate aliquots of the ash residue. Any remaining ash material should be archived for possible future analysis.



Page 4 of 4

PLM Preparation and Analytical Requirements: Medium

Code Sample Type Preparation Method Analysis Method Applicable Laboratory Modifications (current version of)

G Soil – all field samples 16-ASB-06.02 PLM-Grav: SRC-LIBBY-01 Rev. 3 PLM-VE: SRC-LIBBY-03 Rev. 3

LB-000073, LB-000088, LB-000097, LB-000098

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ Laboratory Quality Control Sample Frequencies: TEM [g]: Lab Blank – 4% PLM [i]: Lab Duplicates – 10% (cross-check 8%; self-check 2%) Recount Same – 1% Interlab – 1% [j] Recount Different – 2.5% Verified Analysis – 1% Interlab – 1% [h] Repreparation – 1% [g] See LB-000029 for selection procedure and QC acceptance criteria; frequency specific to OU3. [h] Post hoc selection to be performed by the QATS contractor [i] See LB-000073 for selection procedure and QC acceptance criteria; frequency specific to OU3. [j] Selection to be performed by the Troy SPF at the time of preparation; as necessary, additional post hoc selection may be performed by the QATS contractor Requirements Revision:

Revision #: Effective Date: Revision Description 0 5/8/2015 -- 1 5/15/2015 Corrected area examined for lot/field blanks.

Added preparation and analytical requirements for equipment rinsates.

All laboratories signed the original version of this analytical summary sheet (Rev 0); this revision (Rev 1) did not require another signature process.

APPENDIX D

DECONTAMINATION CHECKLIST FOR VEHICLES AND HEAVY EQUIPMENT


of Times:

:

g

Libby Asbestos Project Equipment Decontamination Checklist Date: Site Location:

Removal Contractor : Owner of Equipment:

Type of Equipment: Odometer or Hour MeterEquipment Identification Number: USACE pre‐notification:

Purpose of Decontamination Check One Air Filtration Units Yes/NA Parts Number

End of Service Cab Filter Replaced

Change of Duty Engine Intake Filter Replaced

Repairs Main HEPA Filter Replaced

Other: Prefilter on HEPA Replaced

General Requirements Yes/NA Water Truck (Mine Use) Yes/NA

Remove All Protective Plating Flush Water Delivery System Number y y

Pressurize Wash All Surfaces Water System Sampled Wash Engine Compartment Non‐detect Sample Results

Remove All Floor Mats Industrial Vacuum

Wet Wipe/ HEPA Vac Interior Hopper Decontamination

Comments:

Filter Disposal Information:

Sign below when the full decontamination has been performed per the RAWP standard.

Form Completed by: Signed: Date

RC Inspection Performed by : Signed: Date

TQA Inspection Performed by: Signed: DateUSACE Completion Notification: Rep: Time: Date:


APPENDIX E

RECORD OF MODIFICATION FORMS


Requested by: Date: Description of Deviation: _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ EPA Region 8 has reviewed this field modification approves as proposed. EPA Region 8 has reviewed this field modification and approves with the following exceptions: _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ EPA Region 8 has reviewed this field modification and does not agree with the proposed approach for the following

reasons: _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ _______________________________________________________________________________________ ______________________________________ _____________________ Christina Progess, EPA RPM Date

FIELD MODIFICATION APPROVAL FORM LFM-OU3-xx

Libby OU3 Understory Burn ABS QAPP (Revision 0)


Libby Lab Modification Form LB-0000XXa Page 1 of 2

Instructions to Requester: E-mail form to contacts at bottom of form for review and approval. All Labs Applicable Forms – copies to: EPA LC, QATS contractor, All Project Labs

Individual Labs Applicable Forms – copies to: EPA LC, QATS contractor, Initiating Lab

Method (circle all applicable): TEM-AHERA TEM-ISO 10312 PCM-NIOSH 7400 EPA/600/R-93/116 ASTM 5755 TEM 100.2 SRC-LIBBY-03 SRC-LIBBY-01 NIOSH 9002 Other:

Requester: Title: Company: Date: Original Requester: Original Request Date: [only applicable if modification is a revision of an earlier modification]

Description of Modification: Reason for Modification: Potential Implications of this Modification: Laboratory Applicability (circle one): All Individual(s) This laboratory modification is (circle one): NEW APPENDS to ___________ SUPERCEDES Duration of Modification (circle one):

Temporary Date(s): Analytical Batch ID:

Temporary Modification Forms – Attach legible copies of approved form with all associated raw data packages

Permanent (Complete Proposed Modification Section) Effective Date: Permanent Modification Forms – Maintain legible copies of approved form in a binder that can be accessed by analysts.

Proposed Modification to Method (attach additional sheets if necessary; state section and page numbers of method when applicable): REFERENCES

Request for Modification

to Laboratory Activities

LB-0000XX

Libby Lab Modification Form LB-0000XXa Page 2 of 2

Data Quality Indicator (circle one) – Please reference definitions below for direction on selecting data quality indicators:

Not Applicable Reject Low Bias Estimate High Bias No Bias DATA QUALITY INDICATOR DEFINITIONS:

Reject - Samples associated with this modification form are not useable. The conditions outlined in the modification form adversely affect the associated sample to such a degree that the data are not reliable. Low Bias - Samples associated with this modification form are useable, but results are likely to be biased low. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimated low. Estimate - Samples associated with this modification form are useable, but results should be considered approximations. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimates. High Bias - Samples associated with this modification form are useable, but results are likely to be biased high. The conditions outlined in the modification form suggest that associated sample data are reliable, but estimated high. No Bias - Samples associated with this modification form are useable as reported. The conditions outlined in the modification form suggest that associated sample data are reliable as reported. Technical Review: Date: (Laboratory Manager or designate) Project Review and Approval: Date: (USEPA: Project Manager or designate) Approved By: Date: (USEPA: Technical Assistance Unit Chief or designate)

APPENDIX F

ASBESTOS LABORATORY ACCEPTANCE CRITERIA

FOR THE LIBBY ASBESTOS SUPERFUND SITE


APPENDIX F

ASBESTOS LABORATORY ACCEPTANCE CRITERIA

FOR LIBBY ASBESTOS SUPERFUND SITE

MINIMUM LABORATORY ACCEPTANCE CRITERIA

1. Must be certified by the National Institute of Standards and Technology (NIST) National Voluntary

Laboratory Accreditation Program (NVLAP) for the analysis of asbestos by PLM1 and/or TEM2.

2. Must have a laboratory‐specific Quality Management Plan and all relevant SOPs in place for asbestos

environmental sample processing and analysis.

3. Must have multiple experienced analysts on staff capable of running PLM visual area estimation methods

[NIOSH 9002, EPA 600] and/or TEM methods [ISO 10312, ISO 13794, AHERA, ASTM 5755, EPA Method

100.2] (a minimum of 2 analysts within each laboratory are needed to assess within‐laboratory

reproducibility). Must have documentation in place demonstrating all analysts work experience and

training related to analyses performed.

4. Must be familiar with standard TEM and PLM preparation methods. TEM laboratories must have ability

to perform indirect preparation and ashing (for the analysis of air, dust, other media) and/or

ozonation/UV/sonication treatment (for the analysis water). PLM laboratories must have the ability to dry

samples (for PLM‐NIOSH 9002 analysis). If the PLM laboratory wishes to perform soil sample preparation

in support of the Libby‐specific PLM methods (i.e., PLM‐VE and PLM‐Grav), the laboratory must have the

ability to sieve and grind soil samples in accordance with the Libby‐specific preparation method.

Note: Not all laboratory facilities need to have all preparation capabilities; media analysis could be

segregated based on facility capability (i.e. one laboratory does water, another does soil, etc.).

5. TEM laboratories must have Energy Dispersive Spectroscopy (EDS) and Selected Area Electron

Diffraction (SAED) capability incorporated into their microscope(s).

6. Must participate in monthly EPA laboratory calls for the Libby project.

7. Must participate in inter‐laboratory analyses with other Libby project laboratories.

8. Must participate in annual EPA (QATS) audits and in other laboratory and/or data audits if data quality

issues arise, as deemed appropriate by EPA.

9. Must be capable of using Libby‐specific bench sheets to record observations and utilizing Libby‐specific

electronic data deliverables (EDDs) to report analytical results.

10. Must have the capacity to meet the required delivery schedules and turn‐around times.

11. Must designate laboratory primary and secondary points of contact for discussion of EPA/laboratory

issues.

EPA APPROVAL PROCESS

1. Once potential laboratories are identified that meet the minimum acceptance criteria, they must show

proficiency in analysis of NIST/NVLAP performance evaluation samples and inter‐laboratory samples

1 http://www.nist.gov/nvlap/upload/NIST‐HB‐150‐3‐2006‐1.pdf 2 http://www.nist.gov/nvlap/upload/NIST‐HB‐150‐13‐2006‐1.pdf

(standard PLM visual area estimation and TEM only, no Libby‐specific method modifications and

requirements).

2. If proficiency is documented, an EPA (QATS) audit will be performed.

3. If any deficiencies found during the audit are sufficiently resolved to EPA's satisfaction, then project‐

specific mentoring will be conducted to ensure laboratories are proficient in the Libby‐specific methods,

modifications, and requirements.

4. Once a laboratory has passed all of these steps, EPA will approve the use of the laboratory and

documentation to this effect will be sent to the laboratory. Samples can then be sent to the laboratory for

analysis.

APPENDIX G

PRESCRIBED BURN PLAN


SALE NAME: Libby WR MOU3

BURNING UNIT#: MOU3 1 LAND OFFICE NUMBER:

BURN TYPE: Broadcast RISK RATING: (L) (M) (H) MOP-UP CATEGORY: 100% STAG #:

Prepared By: Darrell L. Schulte Position: Fire Planner Date: 05/15/2015

Approvals:

This Prescribed Fire Burn Plan is approved for implementation without conditions.

Robert J. Medler Date W.R. Grace & Co.-Conn.

Project Coordinator

Director of Remediation, Environment, Health, and Safety

William Pickens, PG Date MWH Americas, Inc.

Project Manager

Aaron T. Burns, PE, PG Date MWH Americas, Inc.

Project Technical Lead

Revision Log:

Revision No. Date Description

1 April 21, 2015 First Draft of Work Plan sent to EPA Region 8 for review

2 May 15, 2015 Changes based on EPA, USFS, and Grace reviews incorporated

1

PRESCRIBED FIRE BURN PLAN

05/15/2015

05/15/2015

yeagerey

Stamp

3

UNIT DESCRIPTION AND OBJECTIVES

UNIT NAME MOU3 1 UNIT ACRES <1 STAND ID UNIT LOCATION N48 26 50.8 W 115 23 25.2

DRAINAGE SLOPE 10-15%ELEV. RANGE 3600 ASPECT W - SWAIRSHED/IMPACT ZONE NFFL FUEL MODEL IN/OUT 11/8YR.ACTIVITY FUEL CREATED 1990’s FIRELINE TYPE DozerDOWN WOODY FUEL LOADING (TONS/ACRE) Estimated

1 HOUR 1.5 tons per acre 1000 HOUR 5 tons per acre10 HOUR 4.5 tons per acre DUFF DEPTH 0.5”

100 HOUR 5.5 tons per acre TOTAL FUEL LOADING 15 tons per acre

RESOURCE OBJECTIVES Test burn to simulate wildland fire suppression in USFS Management Operable Unit (MOU3) 3

Onsite fuel loadings will be determined using the Photo Series prior to the burn.

SENSITIVE FEATURES

NARRATIVE: (Brief Description of the Project Area

The proposed burn location, as defined in Figure A-2 of the 18 February 2015 EPA draft Quality Assurance Project Plan (QAPP) for the OU3 Study Area, has approximate latitude and longitude of N48º 26’ 50.8” and W 115º 23’ 25.2”. MOU 3 is an area that has been previously logged in the 1990s with scattered reproduction in the understory with mature trees in the overstory. Douglas-fir, Ponderosa Pine, Western Larch are dominant in the overstory/understory of the study area. Understory is a mixture of grasses and shrubs.

PRESCRIPTION PARAMETERS

SEASON(S) Spring, early summer, or fall IGNITION TIME RANGE 1200 to 1800FIRE PATTERNS(S) Line IGNITION METHOD Drip torch, handTEMPERATURE RANGE oF 45 to 90 degrees F RH RANGE % 15 to 45% RH WIND SPEED RANGE MPH (eye level)

0-5 mph

SURFACE DIRECTION PREFERRED: W to STRANSPORT DIRECTION PREFERRED: N to E FLAME LENGTH LIMIT Upper limit of 4 feetFUEL MOISTURE CONTENT RANGES %

1 HOUR 3 - 15 UPPER DUFF 100 - 20010 HOUR 3 - 15 LOWER DUFF 100 - 200

1000 HOUR 10 -25 *SEE ATTACHED FIRE BEHAVE RUNS AND FIRE FAMILY PLUS WEATHER ANALYSIS OUTPUTS

4

SAFETY (REFERENCE OPERATIONAL PLAN)

Safety Concerns Unique to This Project Follow and use all OSHA procedures and techniques for performing wildland fire duties and mitigating exposure to asbestos while in MOU 3 FIRING, CONTAINMENT, MOP-UP AND PATROL

PERSONNEL REQUIREMENTS FIRING CONTAINMENT MOP-UP CONTROL

DAY 1 1 – 2 1-4 1-2 5 DAY 2 DAY 3 DAY 4

TREATMENT OBJECTIVES & DESIRED QUANTIFIED RESULTS HAZARD REDUCTION 0-1/4” Fuel ______to_______% 1/4”-1” Fuel_______to_______% 1-3” Fuel_______to_______% 3”+ Fuel_______to_______%

No hazard reduction objectives have been identified as this is a test burn to replicate wildland fire suppression techniques in MOU 3.

SITE PREPARATION Not applicable

WILDLIFE Not applicable

OTHER Not applicable

5

PROJECT IMPLEMENTATION: IGNITION PLAN:

Ignition Instructions: (Method, Pattern, and Procedures) One strip will be ignited along the downwind side of the unit adjacent to the dozer line. The strip fire will be allowed to back into the wind until it ignites the entire 65ft X 65ft area. If ignition via this method is not successful, additional ignition strips may be necessary due to high relative humidities and/or high fuel moistures in the test burn area. This determination will be made on the day of the burn, by the burn boss, as actual burning conditions are observed.

HOLDING PLAN:

Holding Instructions: (include placement of engines, port a’tanks, hoselays, etc.) A hose lay along the back up dozer line will be installed along all 4 sides of the burn unit. A port a’tank or drop tank will be stationed on the upwind side prior to ignition, and a pressure pump will be used to charge the hose line and sprinklers. The sprinklers should be “rain bird” type on a 6 foot tall hollow post with a ¾” female hose fitting at the base (see attachment 1). The hose lay and sprinklers may be used for mop up after the initial test procedures have been completed. Hoses will have a gated wye every 50 feet, one connection to go to the sprinkler heads, one connection to a hose and nozzle. Dozer and engines/skid-gine will be staged along the secondary dozer line during ignition phase in case they are needed for holding duty. Water sources will be identified and flagged prior to the burn day

MOP-UP PLAN:

Holding Instructions: Half of the unit is to be dry mopped, the remaining half will be wet mopped. Dry mop up will occur first, only dry mixing of soil with shovels and pulaskis will be done to extinguish the fire. Dry mop up will start on the half of the unit furthest from the water source corner. Wet mop up will occur over the remaining half of the unit, once the dry mop up portion is completed. Water will be mixed with soil by using shovels and pulaskis to churn up the soil. The unit will be mopped up 100%, i.e., every inch of ground will be manipulated and or cold trailed to insure the area is “dead out.” After the study is completed, the rain bird sprinklers will be moved into the immediate perimeter of the 65X65 ft area, nozzles will be trained over the burned area and the pumps run for the remainder of the day, and most likely the next day to insure the fire is completely out.

6

MOP-UP INSTRUCTIONS: Mop-up Instructions: (include engines assigned, organizational structure, standards to be met, and patrol schedule until Rx Burn is declared out). Grace will provide 2 engines with 2,500 gallon capacity will be used on the test unit. This includes a Skid-gine, with a 2,500 gallon tank that will be assigned to the burn for use during mop up. These units will be full and will have a refill point established as close to the burn unit as possible. In addition, there will be 2 – 1500 gallon portatanks onsite.

The unit must be smoke free for at least 24 hours before it can be declared dead out. Patrols the immediate day after the burn should be carried out at least once before the heat of the day (1400) and hourly until 2000 after that. If no smoke is observed the morning of the second day, a return patrol at 1500 – 1600 should occur to double check for smoke. After the unit is declared out, it is suggested that a patrol should occur at least daily over the next week to insure the unit is completely mopped up and dead out.

Vicinity map

7

SMOKE MANAGEMENT:

Atmospheric Stability: (Describe acceptable wind speed, direction and atmospheric stability conditions) Preferred 20 foot winds from the West to South West at between 0 and 10 mph are acceptable. Atmospheric stability should be neutral to unstable to insure adequate lift of the column and smoke dispersal.

Sensitive Receptors: (Homeowners, towns, etc.) Libby and its surrounding home owners

Visibility: (Impacts to visibility, duration and significance) Smoke duration should be no more than 5 hours from ignition to completed mop up of the test fire area.

Regulatory Compliance: (Required permits, and standards) The prescribed burn site is part of the OU3 Study Area of the Libby Superfund Site.

Other Conditions: (Safety of air operations, personnel exposure to smoke, etc.)

CONTINGENCY PLAN: (What is your fall back plan if the Rx Burn escapes initial actions)

Contingency forces will be USFS personnel and equipment stages at the canoe Gulch and Libby Ranger Districts. These personnel are qualified and equipped to fight wildland fire in MOU3. Any requested assistance from the USFS, Kootenai National Forest, will adhere to the Wildfire Response Guide for Fire Management Unit (FMU3): EPA OU3, 2014 (see Attachment A). This may include the use of aerial delivery (helicopter) water drops to saturate the fire area.

8

PUBLIC INFORMATION AND INVOLVEMENT: CONTACTS CONTACT METHOD CONTACT DATE Unit Manager Personal Contact Prior to Ignition Kootenai Dispatch Personal Contact Prior to Ignition Unit Receptionist Personal Contact Prior to Ignition

CONTACTS PHONE OR PERSONAL CONTACT

CONTACT PRIOR TO, AND POSSIBLY A.M., OF BURN

Sheriff’s Department (911 Center/Dispatch)

Phone or Personal Contact Prior to Ignition

Local Print Media Press Release/Personal Contact One week prior to meet deadlines

Local Radio/TV Media Press Release/Personal Contact One day prior EXAMPLE PRESCRIBED FIRE ORGANIZATION (Intermediate or Complex Burns) PROJECT ORGANIZATION Personnel assigned to the positions in the prescribed fire organization will meet all qualifications for their position for the appropriate prescribed fire burn type. This project organization chart will be completed for each position identified prior to implementation, using available and qualified personnel. Those positions in parenthesis are 310-1 qualified positions. ORGANIZATION CHART

Robert Medler

Darrell Schulte Prescribed Fire Burn Boss

Safety Kester

Firing Boss (FIRB) Schulte

Mop-up & Patrol Chapman

Weather Schulte/Ryan

Holding Chapman

9

PRESCRIBED FIRE PERSONNEL BRIEFING The prescribed Fire briefing will be conducted by the Burn Boss and include all personnel involved in the execution of this prescribed fire plan. Content for the briefing will include: Introduction of all personnel, their position and responsibilities Purpose and objectives of the prescribed fire. Communications Plan and radio assignments Prescription parameters and expected fire behavior; including expected fire behavior outside the unit and spotting

potential. Today’s general forecast and special fire weather (spot) forecast for the project area. Ignition plan, organization, resources and standards. If this is an aerial ignition prescribed fire, review the aerial

ignition plan. If possible, display the unit and ignition sequence on a flip chart or black board. Holding plan, organization, resources and standards. Emphasize conditions and locations where holding problems

could occur. Escape Contingency Plan Mop-up plan, organization, resources and standards. Safety Plan

BURN EVALUATION

PRE-BURN FUEL MOISTUREDATE 1 HOUR 10 HOUR 1000 HOUR DUFF

BURN MONITORING IGNITION DATE IGNITION START TIME IGNITION STOP TIME

TIME TEMP. RH WIND/SPEED DIRECTIONFLAME LENGTH Start 1/2 Hr. 1 Hr. 1-1/2 Hr. 2 Hr. 2-1/2 Hr. 3 Hr. 3-1/2 Hr/

COMMUNICATION PLAN All Prescribed Fire overhead identified in the organizational chart, the ignition crew, and the holding crew will be in radio contact on the project site. Other personnel may be specifically required to maintain radio contact by the Burn Boss. The Burn Boss will notify FIDC prior to implementation to arrange necessary staffing beyond normal hours of operation to ensure communications between project site, and coordination and support resources.

10

RADIO FREQUENCY PLAN FREQUENCIES

CHANNEL RECEIVE TRANSMIT TONETACTICAL AIR TO GROUND DISPATCH OTHER

RISK ASSESSMENT (See Risk Rating Form)

RATING LOW SEE ATTACHMENT B: CONSEQUENCES: (Brief explanation of consequences of an escape) An escape outside the immediate perimeter of the test area will have a very low surface rate of spread and flame lengths will be less than 4 feet. With 7,500 gallons of water available, including the skid-gine, and trained and equipped operators/firefighters available on scene the probability of any escape very, very low. To insure adequate resources for suppression, a bulldozer with scraping blade will be on sight for the entire burn test and sampling. This will include ignition, mop up and having the dozer staged on sight for 3 days after the burn. Mechanical line construction in fuel model 8, on slopes up to 25%, for a type 2 dozer ranges from 70 to 120 chains per hour.

POST BURN EVALUATION:

1. Narrative: (include ignition techniques and patterns used, fire behavior observed, smoke production/dispersal)

2. Prescribed Fire Effects: (describe the fire effects of the prescribed fire on targeted indicators/objectives)

FUNDING Estimated Code/Acre: ___________________________________ Org. Center: __________________________________ All Prescribed Fire overhead identified in the organizational chart, the ignition crew, and the holding crew will be in radio contact on the project site. Other personnel may be specifically required to maintain radio contact by the Burn Boss. The Burn Boss will notify FIDC prior to implementation to arrange necessary staffing beyond normal hours of operation to ensure communications between project site, and coordination and support resources.

11

PRESCRIBED BURN PROJECT MAP (Include vicinity map and detailed site map)

This map is not to scale, but represents the 65 foot by 65 foot test fire area.

12

PRE-IMPLEMENTATION CHECKLIST

This checklist is intended to aid the burn boss in accurately assessing the feasibility of meeting resource objectives against an evaluation of management constraints immediately prior to ignition of a prescribed fire. A "NO" response to any one of the items listed requires the appropriate action be initiated and issue or concern satisfied before ignition will be approved to proceed.

Are all fire prescription parameters met, including smoke YES_____ NO_____ management specifications?

YES_____ NO_____ Are burning and smoke management permits secured?

YES_____ NO_____ Is the weather forecast and outlook favorable?

YES_____ NO_____ Are the individuals and qualification standards, as specified in the burn plan, on site?

YES_____ NO_____ Have all individuals been briefed on burn objectives and their respective assignments or responsibilities?

YES_____ NO_____ Have all individuals been briefed on safety concerns, escape routes, safety zones, and unique hazards?

YES_____ NO_____ Is all equipment, as specified in the burn plan, in place and operable?

YES_____ NO_____ Has contingency planning been discussed and made known to key individuals?

YES_____ NO_____ Have all the public and private project related contacts been made?

YES_____ NO_____ Can the prescribed burn be successfully completed within the parameters described in the burn plan, and will the stated objectives be met?

Prescribed Fire Burn Boss Date

Attachment 1, Page 1

ATTACHMENT 1 Sprinkler system example. http://www.amleo.com/Tripod-Sprinkler-Stand-With-Brass-Impulse-Sprinkler-Head-1%2F2in/p/222TP/

The systems typically used are this tall, but with a spike on the bottom to drive into the ground and hold the sprinkler upright. Easier to set up than leveling a tripod. Use ¾” garden style fire hose to hook to the bottom of the sprinkler, this would be from fittings on the gated wye’s called for in the prescribed burn plan.


ATTACHMENT 2 BEHAVE PLUS OUTPUTS






ATTACHMENT A: Wildfire Response Guide for Fire Management Unit 3 (FMU3): EPA OU3

08/11/2014 Date/Time: Fire Name/P# : Libby Superfund #

Objectives:

1. Provide for the safety of firefighting personnel. a. Manage risk to firefighting personnel from LA (Libby Amphibole) exposure to an

acceptable level that will allow for wildfire suppression activities.

2. Provide for public safety. a. Minimize fire size and smoke production to reduce the potential of harmful

exposure to LA.

Libby Amphibole (LA) Concerns: Firefighting personnel must be briefed regarding the potential hazards/risks of exposure to LA in FMU3 prior to any assignment. The risks to firefighters and pilots from exposure to LA in FMU3 are unknown at this time. Due to this unknown risk, employees may elect to refuse assignment in FMU3.

Large wildfires may expose the public to LA. Firefighting activities may expose firefighters to LA. The combustion process as well as the disturbance of dry duff and tree bark may liberate LA into the air. Because of these concerns, mitigation measures will be employed to reduce the potential exposure to LA.

Mitigation Measures for FMU3: The use of aviation resources to contain a wildfire will be the first response considered. Pilots utilized will be briefed on the issues regarding LA. Pilots always have the right to refuse a mission. If the helicopter was exposed to smoke at any point during operations then consider decontaminating the aircraft.

Personnel who perform wildfire suppression activities on the fireline or those who may be exposed to smoke will utilize a PAPR (powered air purifying respirator) and go through decontamination procedures to minimize any potential for secondary exposures to LA. Those procedures will include the disposal of fire clothes and showering. Activities that are not ground disturbing and do not expose personnel to smoke (i.e. monitoring a fire from a distance or hiking to a vantage point) will not require a PAPR nor decontamination unless the activity occurs in the Rainy Creek Watershed.

Fire supervisors will track personnel assigned to fires within FMU3. Names of personnel, hours worked, fire name and location will be documented. Management will monitor employee time spent on fires. The tracking of personnel assigned to fire suppression activities is intended to minimize potential exposure to individuals by monitoring time spent in the area and should include consideration of other factors such as levels of smoke exposure, extent of ground disturbing activities, use of chainsaws, etc.

All equipment and supplies will be decontaminated. Establish a washing area for each incident. Utilize FS or contract engine/tender to rinse equipment and flag off the area so it can be tested for LA.

Fire hose and other equipment that cannot be decontaminated, will be placed in plastic hazmat bags, or disposed of. Equipment and supplies that cannot be decontaminated will not be used for any purposes other than for wildfire suppression in FMU3.

Rainy Creek and the ponds at the mine site will NOT be used as water sources.

Vehicles used to transport firefighters that performed fireline fire suppression activities will be decontaminated.

Mitigation Measures for FMU3: Incident Commanders, fireline supervisors, and firefighters who elect to respond to fires that occur within FMU3 should consider the following mitigations:

Remain outside the fire perimeter. Saturate the fire area as much as possible. Utilize a wet-line to contain and control the fire. Avoid working in smoke. Minimize the disturbance of duff. If duff must be disturbed it should be wet down prior to

disturbance. If large amounts of line construction are required, consider the use of equipment. Minimize the use of chainsaws. If chainsaws must be used, the material to be sawn should be

thoroughly wet down, or the bark should be removed. Take rest breaks away from and upwind of the fire. When the extended application of water is required consider the use of sprinkler systems. Consider a Palm IR for patrolling actions.

When a wildfire escapes initial attack, air monitors at 4 locations will be turned on to gather ambient air samples for 24 hours. After this 24 hour period, the samples will be analyzed for LA. Within 4 hours a determination may be made regarding the potential hazards of LA exposure from smoke from FMU3.

Initial and Extended Attack Responses:

Aviation resources (helicopter with tank or bucket / airtankers) may be used for initial attack.

A PAPR (powered air purifying respirator) is required for personnel performing any fireline suppression activities in FMU3.

FMU3 contracted equipment should be ordered/mobilized as needed.

Wildfire Management Actions:

Detection: Fly air patrol as soon as possible following lightning in the area unless otherwise directed by DO.

Initial Attack / Fire Report

KDC Actions: 1) Determine fire location via latitude and longitude coordinates if possible.

2) Contact the Libby District Duty Officer.

3) Determine from the District Duty Officer if a helicopter with bucket (or tank) for water delivery will be dispatched.

o If a helicopter is mobilized, contact Thomas Cook (291-1149) or Damon Repine (293-61374) or Nic Pisciotta (291-4249) to install air monitor in helicopter. If conditions allow (i.e. spread potential is low due to time of year or moisture received on the fire) and the fire is burning on the ground, the air monitor should be placed on the helicopter prior to the first fuel cycle of bucket work. The intent is to start collecting valuable data on whether or not LA is present in the smoke.

4) Determine from the District Duty Officer if any FMU3 equipment (dozers, excavators, tenders, skidgines, etc) should be ordered/staged/mobilized for initial attack.

5) Determine from the District Duty Officer if the use of a hose lay to deliver water will be utilized. If so, determine if water tender(s) should be mobilized.

6) If firefighters will be assigned on the ground then contact Thomas Cook (291-1149) or Damon Repine (293-61374) or Nic Pisciotta (291-4249) for opportunistic smoke sampling.

7) Establish a separate P number and enter in WFDSS.

8) Order air tanker if in Staffing Class 4 or 5. Review order with District Duty Officer.

9) Notify the following individuals or their designated acting: o Libby District FMO o Libby District Ranger o Forest FMO (Forest FMO will Contact Vic White of Lincoln County EMA) o Forest Aviation Officer o Forest Supervisor

10) Order a Type I, Type II, or Type III helicopter when bucket work is expected to continue into the next operational period or when other fires in the KDC zone require helicopter support.

11) Order a dip site observer when no other on-site personnel (ground or air) are planned.

12) When in the vicinity of Libby Dam notify the COE (293-7751) of any helicopter bucket operations.

13) Contact the EPA, CDM, or USACE (U.S. Army Corp of Engineers). Advise them of the fire; request a primary contact and all contact information. Only one contact listed below needs to be contacted. Notification to W.R. Grace will be the responsibility of the primary contact. Priority order call list is as follows:

1. EPA – OU3 Superfund Project Manager: Christina Progess 720-951-0961 (cell phone) 303-312-6009 (office)

2. EPA – Mike Cirian, Libby Project Manager 406-202-3791 (cell phone) 406-293-6194 (office) 406-293-4608 (home)

3. CDM – Damon Repine, Health & Safety 406-293-1374 (cell phone) 406-293-8595 ext. 23 (office)

4. USACE – Mark Buss/Jeremy Ayala, Libby Construction Rep. 406-293-6745

5. CDM – Tommy Cook, CDM Project Manager (Libby) 406-293-8595 ext. 24 (Libby office) 406-291-1149 (mobile phone) 406-293-5121 (home)

6. PRI– Harvey Fowler, Site Superintendant 406-291-7994

7. EPA – National Response Center, Region 8 Denver (24hrs) 800-424-8802

Initial Attack

Duty Officer Actions: 1) Assign an ICT3 or ICT4. Consider an ICT5 after the fire has been contained.

2) Determine the need for a helicopter with bucket. If helicopter is requested then work with KDC to determine if the air monitor for the helicopter can be put into place before the first fuel cycle of bucket drops.

3) Determine the need for any heavy equipment.

4) If an initial attack fire has significant potential for a high rate of spread (i.e. grass fuel model) and it is near a drivable road then consider the use of an engine with one of the designated volunteers as the initial response utilizing any of the approved respirators (PAPR or ½ mask). The initial response engine would only be allowed to use water from a simple hoselay (i.e. hard line). No other ground disturbing activities would be allowed. The intent of this response is to provide a quick initial response to a fire to try to keep it small. The volunteer(s) would be relieved as soon as other personnel in full PPE showed up to relieve them. They would be required to go through full decontamination.

5) Work with the IC to determine if the use of a hoselay and the ground application of water to suppress the fire are warranted to reduce potential for long term exposure to smoke/PM coming from FMU 3.

6) Determine the need for a fixed wing or light helicopter for use as an aerial observation platform.

7) Determine need for an Aerial Observer or Air Attack Group Supervisor. If aerial supervision or observer is dispatched, request that a camera or video camera be used to gather information.

8) If ground resources are utilized then order the decontamination team or decide if the contracted Decon Unit will be ordered and utilized. Coordinate transportation.

9) Ensure contractors are briefed on the potential hazards.

10) Ensure an AAR is conducted.

Extended Attack

KDC Actions: 1) Contact 911 to notify about a “fire with potential” in OU3. 911 will make contacts to

County officials as needed.

Duty Officer Actions: 1) Place order for additional resources.

2) Document key decisions in the Wildland Fire Decision Support System (WFDSS).

Forest FMO Actions:

1) Ensure the following individuals, or their designated acting’s, are notified:

o OU3 Smoke Monitoring: Thomas Cook- CDM (See attached phone tree) 291-1149 (cell) 293-5121 (home) Damine Repine 293-1374 (cell) 291-8686 (home) Nic Pisciotta 291-4249 Scott Felton 291-9898 (cell) 293-3718 (Home)

o Northern Rockies Coordination Center Manager: 329-4708

o Northern Region Safety and Occupational Health Manager: Dave Goodin Office: 329-3237 Cell: 544-3597

o R1 Director of Fire and Aviation: Patti Koppenol 329-3402 241-1136 (cell)

o Lincoln County Emergency Management: Vic White 293-6295 293-1129 (cell) 293-4112 (Sheriff’s Office) or 911

o R1 Assistant Director of Engineering: Bob Kirkpatrick 329-3307

o Libby OU3 Superfund Project Manager: Christina Progess 303-312-6009 (office) 720-951-0961 (cell)

o LRVFD Chief or Assistant Chief: Tom Wood 293-1606 (cell) 293-4112 (Sheriff’s Office) or 911

o BPA (if powerline is threatened): Mike Stoflus 751-7871

o Libby Dam/Army Corps: Ken Swanda (interim thru August 2012) 293-7751

Escaped Fire or Long Duration Event:

1. Establish Unified Command: LRVFD, County EMS 2. Consider ordering NIMO or other short Incident Management Team

USFS to call CDM Smith in lieu of Mike

Chapman upon fire within OU3

Call in order of succession, if number (1) is not available.

CDM Smith1. Thomas Cook

(Cell) 406‐291‐1149(Home) 406‐293‐51212. Damon Repine(Cell) 406‐293‐1374(Home) 406‐291‐8686

3. Nic Pisciotta(Cell) 406‐291‐42494. Scott Felton

(Cell) 406‐291‐9898(Home) 406‐293‐3718

CDM Smith project management team to call and designate (2) staff memebers from this list to

conduct sampling

CDM Smith / Fire Line Sampling Staff

1. Damon Repine(Cell) 406‐293‐1374(Home) 406‐291‐8686

2. Nic Pisciotta(Cell) 406‐291‐42493. Kara McKenzie(Cell) 406‐291‐74674. Simon Wilson

(Cell) 406‐291‐9798(Home) 406‐293‐1591

5. Andy Vivian(Cell) 832‐849‐9516(Home) 406‐293‐6067

CDM Smith project management team to call and designate (1) staff memeber from this list to conduct

sampling

CDM Smith / Ambient Air Sampling Staff

1. Keeli Anderson(Cell) 406‐293‐1976(Home) 406‐293‐6716

2. Kris Beaudoin(Cell) 406‐291‐6309

3. Jim Sabo(Cell) 406‐291‐1011

EPA OU3 Project Manager

1. Christina Progess(Cell) 303‐520‐5205(Office) 303‐312‐6009

Project Name: MOU3

ATTACHMENT B: RISK ASSESSMENT INDICATORS FOR BROADCAST BURNING

Relative Leveling Points 0 1 2 3 4 5 Tallied Points

SITE SPECIFICS

Slope% <15 15-30 - 31-45 46-60 >60 0

Aspect N,NE,E NW SE W SW S 4

Fuel Model in Unit 11-L 11-H 12-L 12-H 13-L 13-H 0

Age of Fuel (years down) <0.5 >4.0 3.1 – 4.0 2.1 – 3.0 1.6 – 2.0 0.5 – 1.5 5

Proximity to other ownership

None

Other ownership within spotting distance

Adjacent One side

Adjacent Two sides

Adjacent prvt One side

Adjacent prvt or other

2 or more sides

0

CONTAINMENT FACTORS Subtotal 9

Projected Flame Length (ft) <1.0 1.1-2.0 2.1-4.0 - 4.1-8.0 >8.0 2

Projected R.O.S. (ch/hr) <1.0 1.1-3.0 3.1-4.9 - 5.0-9.9 >10 1

Line Prod. Rate (ch/hr) >5 4.9-3.1 3.0-2.1 - 2.0-1.5 <1.5 0 Proximity of Fuel to Perimeter (ft) >10 10-6.1 6.0-3.1 - 3.0-1.6 <1.5 0

Fuel Model Outside 9 8/2 10 11 12 13 1

Position on Slope Top Upper 1/3 - Middle 1/3 Lower 1/3 Bottom 3

Unit Configuration V C U 1

Unit Size >40 40-30 - 29-20 19-10 <10 5 Continuity of Fuel Outside Unit (% Cover) <15 15-25 - 26-35 36-50 >50 2

Time of Ignition After 2100

1800- 2100

0600- 1000 - 1000-1400 1400-

1600 4

PRESCRIPTION PARAMETERS Subtotal 19 Effective Mid-Flame Windspeed <2.0 2.1-5.0 - 5.1-7.0 7.1-10 >10 1

10 Hr Fuel Moisture % >20 20-14 - 13-9 8-5 <5 2

1000 Hr Fuel Moisture % >30 26-30 21-25 - 15-20 <15 2

Live Fuel Moisture % >300 300-200 200-150 150-100 100-50 <50 1

Lower Duff Moisture % >150 150-101 100-76 75-51 50-30 <30 1

Prescribed Scarification % <20 - 21-40 41-60 61-70 >70 0 SUBTOTAL 7

0-40 = LOW RISK 40-70 = MODERATE RISK >70 = HIGH RISK

TOTAL 35

ATTACHMENT C: JHA Prescribed Burn

3722834.1

FS-6700-7 (11/99) U.S. Department of Agriculture 1. WORK PROJECT/ACTIVITY 2. LOCATION 3. UNIT Forest Service (Standard text modified by Grace to reflect site conditions) Prescribed Fire MOU3 JOB HAZARD ANALYSIS (JHA) 4. NAME OF ANALYST 5. JOB TITLE 6. DATE PREPARED References-FSH 6709.11 and -12 (Instructions on Reverse) Schulte 04/21/2015 7. TASKS/PROCEDURES

8. HAZARDS

9. ABATEMENT ACTIONS Engineering Controls * Substitution * Administrative Controls * PPE

Travel to, from and on project Motor vehicle accidents, slippery road surfaces,soft shoulders, unimproved narrow roadways weather, darkness,smoke

Driving defensively. Use seat belts. Identify road conditions during briefings. Post road guards. Mark hazards. Use headlights. Perform pre-use inspections on equipment. Scout roads and identify turnouts before ignition of project. Maintain communications. Provide road system map for project. Use backers and chock vehicle tires. Have vehicles facing out.

Qualifications for assigned position Lack of experience, injuries

Workers recruited for burn assignments shall meet age, health, and physical requirements established for regular firefighting duties(FSH 5109.16). Also meet Prescribed Burn qualifications.

Briefing Lack of communications

Project briefing before burning will clarify firing order, organization responsibilities, communications, hazards, weather, and expected fire behavior.

Protective clothing and equipment Injuries, burns and death

Wear hard hat with chin strap, safety glasses, Nomex Fire resistant pants and shirts NFPA 1977 compliant. Keep sleeves rolled down. Wear leather, lace type, boots with skid resistant soles, and tops at least 8 inches high. Carry drinking water and fire shelter. Wear OSHA approved firefighting gloves. Wear any of the approved respirators. Wear hearing protection when working around equipment where noise level exceeds 85 dba. Wear additional protective equipment as dictated by local conditions and exposure to special equipment.

Lighters Injuries and death, falls, snags, bees, snakes, smoke, burns, rolling material

Always have an escape route. Maintain LCES. Follow the Standard Fire Orders and Watch Out Situations. Maintain communications with other lighters and RX Fire Ignition specialist. Hand held radios shall be provided to all lighters. Do not fill drip torches near ignition sources. Do not spill burn mix on clothing

Fuel Mixing Burns, spills, fuel saturated clothing and boots

No smoking within 25 feet of mixing and filling area. Do not fill or mix in pick up beds with bed liners. Avoid the use of cellular telephones in and around fill or mixing area. Avoid fuel contact with bare hands, clothing and boots. Provide pour spouts. Use only approved fuel containers. Follow fuel mixture ratio in the Health and Safety Code Handbook.

10. LINE OFFICER SIGNATURE 11. TITLE 12. DATE

Holding/Mop Up/Patrol Crews Smoke, burns, falls, back injuries, bees, posion oak, snags, rolling material, eye injuries, heat stress. dehydration, CO poisoning

Wear PPE listed above. LCES, Follow Standard Fire Orders and Watch out Situations. Receive briefing from Holding and Mop Up Boss. Identify hazards in work area. Flag hazards for others. Use warning lights and provide traffic control on roadways during smoky and nights operations. Maintaining a high level of aerobic fitness is one of the best ways to protect yourself against heat stress. Drink lots of fluids before, during and after work. Periodically rotate crews from work sites with high smoke levels to areas of less smoke or smoke free areas. Protective clothing and equipment shall be the same as required for firefighting. Crews shall follow all guidelines in the NWCG Fireline Handbook Chapter 5 Firefighting Safety ( Rev. 9/98 ). Maintain communications with the GDC.

Aerial ignition (if used) See Prescribed Burn Aviation Plan for JHA’s (enter project specific items)

JHA Instructions (References-FSH 6709.11 and .12) The JHA shall identify the location of the work project or activity, the name of employee(s) involved in the process, the date(s) of acknowledgment, and the name of the appropriate line officer approving the JHA. The line officer acknowledges that employees have read and understand the contents, have received the required training, and are qualified to perform the work project or activity. Blocks 1, 2, 3, 4, 5, and 6: Self-explanatory. Block 7: Identify all tasks and procedures associated with the work project or activity that have potential to cause injury or illness to personnel and damage to property or material. Include emergency evacuation procedures (EEP). Block 8: Identify all known or suspect hazards associated with each respective task/procedure listed in block 7. For example: a. Research past accidents/incidents. b. Research the Health and Safety Code, FSH 6709.11 or other appropriate literature. c. Discuss the work project/activity with participants. d. Observe the work project/activity. e. A combination of the above.

Emergency Evacuation Instructions (Reference FSH 6709.11) Work supervisors and crew members are responsible for developing and discussing field emergency evacuation procedures (EEP) and alternatives in the event a person(s) becomes seriously ill or injured at the worksite. Be prepared to provide the following information: a. Nature of the accident or injury (avoid using victim’s name). b. Type of assistance needed, if any (ground, air, or water evacuation). c. Location of accident or injury, best access route into the worksite (road name/number), identifiable ground/air landmarks. d. Radio frequencies. e. Contact person. f. Local hazards to ground vehicles or aviation. g. Weather conditions (wind speed & direction, visibility, temperature). h. Topography. i. Number of individuals to be transported. j. Estimated weight of individuals for air/water evacuation. The items listed above serve only as guidelines for the development of emergency evacuation procedures. JHA and Emergency Evacuation Procedures Acknowledgment

Block 9: Identify appropriate actions to reduce or eliminate the hazards identified in block 8. Abatement measures listed below are in the order of the preferred abatement method:

We, the undersigned work leader and crew members, acknowledge participation in the development of this JHA (as applicable) and accompanying emergency evacuation procedures. We have thoroughly discussed and understand the provisions of each of these documents:

a. Engineering Controls (the most desirable method of abatement).

ATTACHMENT C: JHA Prescribed Burn

For example, ergonomically designed tools, equipment, and SIGNATURE DATE SIGNATURE DATE furniture.

b. Substitution. For example, switching to high flash point, non-toxic solvents. Work Leader c. Administrative Controls. For example, limiting exposure by reducing the work schedule; establishing appropriate procedures and practices. d. PPE (least desirable method of abatement). For example, using hearing protection when working with or close to portable machines (chain saws, rock drills, and portable water pumps). e. A combination of the above. Block 10: The JHA must be reviewed and approved by a line officer. Attach a copy of the JHA as justification for purchase orders when procuring PPE. Blocks 11 and 12: Self-explanatory.

APPENDIX H

UNDERSTORY BURN FIELD SAMPLE DATA SHEETS


Personal Air FSDS Rev0 FSDS # PA - ______ OU3 Understory Burn Activity-Based Sampling (ABS)

Libby Personal Air Sample Field Sample Data Sheet (FSDS)

Field Logbook #_______________ Field Logbook Pages _____________ Sampling Team MWH Data Item 1 2 3

* Sample ID

* Person ID

* Sample Type (check one)

During burn During mop-up, dry During mop-up, wet NA



* Field QC Type (check one)

Field Sample Field Blank Lot Blank



Sample Parent ID (HV Parent ID = LV Sample ID)

* Sample Air Volume Type (if both HV & LV are collected) NA LV HV NA LV HV NA LV HV

* Cassette Lot No ________________ Flow Meter ID _______________ (For Blanks “Z” through “Pump ID” to “Sample Air Stop Flow” then select NA for “Pump Fault” & enter 0 for Total Time & Quantity)

* Flow Meter Type NA Rotameter DryCal NA Rotameter DryCal NA Rotameter DryCal * Pump ID * Sample Air Start Date * Sample Air Start Time * Sample Air Start Flow (L/min) * Sample Air Stop Date * Sample Air Stop Time * Sample Air Stop Flow (L/min) * Pump Fault No NA Yes No NA Yes No NA Yes Sample Total Time (min) Sample Quantity (L)

Sample Field Comments

*Required Field Filter Diameter = 25mm; Pore Size=.8µ

For Field Team Completion: Completed by: _______ QC by:_______ For Data Entry: Entered by:________ QC by:_________

Stationary Air FSDS Rev0 FSDS # SA - ______ OU3 Understory Burn Activity-Based Sampling (ABS)

Libby Stationary Air Sample Field Sample Data Sheet (FSDS)

Field Logbook #_______________ Field Logbook Pages _____________ GPS Coordinate System: UTM Zone 11 North, NAD83 datum, meters X coord ________________ Y coord ________________ Elevation (meters)_______________ Sampling Team MWH Sampler Initials ____________________________ Data Item 1 2 3

* Sample ID

* Location ID

* Sample Type and Location (check one)

Sample Type Location Sample Type Location Sample Type Location Pre-burn 50 feet Pre-burn 50 feet Pre-burn 50 feet

During burn 50 feet

During burn 50 feet

During burn 50 feet

100 feet 100 feet 100 feet 200 feet 200 feet 200 feet

Post-burn 50 feet Post-burn 50 feet Post-burn 50 feet NA NA NA





Sample Parent ID (HV Parent ID = LV Sample ID)

* Sample Air Volume Type (if both HV & LV are collected) NA LV HV NA LV HV NA LV HV

* Cassette Lot No _______________ Flow Meter ID _______________ (For Blanks “Z” through “Pump ID” to “Sample Air Stop Flow” then select NA for “Pump Fault” & enter 0 for Total Time & Quantity)

* Flow Meter Type NA Rotameter DryCal NA Rotameter DryCal NA Rotameter DryCal * Pump ID * Sample Air Start Date * Sample Air Start Time * Sample Air Start Flow (L/min) * Sample Air Stop Date * Sample Air Stop Time * Sample Air Stop Flow (L/min) * Pump Fault No NA Yes No NA Yes No NA Yes Sample Total Time (min) Sample Quantity (L)


*Required Field Filter Diameter = 25mm; Pore Size=.8µ For Field Team Completion: Completed by: _______ QC by:_______ For Data Entry: Entered by:________ QC by:_________

Tree Bark FSDS Rev0 FSDS # TB - ______ OU3 Understory Burn Activity-Based Sampling (ABS)

Libby Tree Bark Sample Field Sample Data Sheet (FSDS)

Field Logbook #_______________ Field Logbook Pages _____________ Sample Date _______________ GPS Coordinate System: UTM Zone 11 North, NAD83 datum, meters Sampling Team MWH Sampler Initials ____________________________

For Field Team Completion: Completed by: _______ QC by:_______ For Data Entry: Entered by:________ QC by:_________

Data Item 1 2

* Sample ID

* Sample Time


Field Sample Field Duplicate Equipment Rinsate Blank

Field Sample Field Duplicate Equipment Rinsate Blank

Sample Parent ID

* Composite No Yes No Yes

* Number of Composites 3 Other ______ 3 Other ______ Tree 1 Tree 2 Tree 3 Tree 1 Tree 2 Tree 3

* Tree species

* Tree diameter (in.)

* Sample collection height (in.) above ground surface

* X coordinate

* Y coordinate

Elevation (m)

* Core diameter units __________ units __________

* Pilot hole diameter units __________ units __________


*Required Field

Soil-Duff-Ash FSDS Rev0 FSDS # S - ______ OU3 Understory Burn Activity-Based Sampling (ABS)

Libby Soil-like Sample Field Sample Data Sheet (FSDS)

Field Logbook #_______________ Field Logbook Pages _____________ Sample Date ________________ GPS Coordinate System: UTM Zone 11 North, NAD83 datum, meters Sampling Team MWH Sampler Initials ____________________________

For Field Team Completion: Completed by: _______ QC by:________ For Data Entry: Entered by:________ QC by:_________

Data Item 1 2 3

* Sample ID

* Sample Time

* Matrix (check one) Soil Duff Ash

Soil Duff Ash

Soil Duff Ash


Field Sample Field Duplicate**



Sample Parent ID

* Composite No Yes No Yes No Yes

* Number of Composites

5 30 Other ______ 5 30 Other ______ 5 30 Other ______

* Sample Depth (for soil only)

Start Depth (in.) _________

End Depth (in.) __________


End Depth (in.) __________


End Depth (in.) __________

* X coordinate***

* Y coordinate***

Elevation (m)***


* Required Field ** Field duplicate samples should be collected for duff samples only. *** Collected from the center point of the composite sample.