A7+-+Brownfields+QAPP.pdf

AUTHORIZATIONS

Quality Assurance / Quality Control Documentation

TITLE: Brownfields Assessment Quality Assurance Program Plan

TYPE: Quality Assurance Project Plan

PROGRAM: Brownfields Response Program

VERSION: 1.1

VERSION DATE: January 29, 2025

AUTHOR(S): Derek Hall

Revision Change Description Date Authorization

1.1 Updated signature

and authorization blocks.

1/29/25

Table of Contents

A1. Introduction

A2. Distribution List

A3. Project/Task Organization

A4. Problem Definition/Background

A5. Project/Task Description

A6. Quality Objectives and Criteria

A6.1 Asbestos Data

A6.2. Laboratory Analysis Data

A6.3. Environmental Site Assessments

A6.4. Precision, Bias, and Representativeness

A7. Special Training/Certifications

A8. Documentation and Records

B. DATA GENERATION/ACQUISITION

B1. Sampling Process Design

B1.1 Introduction

B1.2 Quality Assurance/Control

B1.3 Regulatory Criteria

B2. Sampling Methods

B3. Sample Handling and Custody

B4. Analytical Methods

B5. Quality Control

B6. Instrument/Equipment Testing, Inspection, and Maintenance

B7. Instrument/Equipment Calibration and Frequency

B8. Inspection/Acceptance for Supplies and Consumables

B9. Use of Existing Data (Non-Direct Measurements)

B10. Data Management

C. ASSESSMENT AND OVERSIGHT

C1. Assessments and Response Actions

C2. Reports to Management

D. DATA VALIDATION AND USABILITY

D1. Data Review, Verification, and Validation

D2. Unfit Data

D3. Dispute Resolution

Attachments

Attachment A: Site-specific Sampling and Analysis Plan (SAP)

Attachment B: Hazardous Waste Program Document Storage Standard Operating Procedure (SOP)

Attachment C: ASTM Standards for Phase I/II ESAs

QAPP for Brownfields State Response Program Operations – v1.1 January 2025

A1. Introduction This Quality Assurance Program Plan (QAPP) is intended to satisfy U.S. Environmental Protection Agency (EPA) requirements for the collection of data of known and documented quality needed for North Dakota Brownfields State Response Program field activities and to describe the methods for collecting and assessing those data. This QAPP was developed by the North Dakota Department of Environmental Quality (NDDEQ), Hazardous Waste Program, as a programmatic QAPP for the Brownfields State Response Program (Program) conforming to applicable EPA requirements stated in the document Requirements for Quality Assurance Project Plans, QA/R-5, (EPA document EPA/240/B-01/003) dated March 2001 and re-issued May 31, 2006.

The Quality Management Plan for the Department of Environmental Quality (QMP), dated January 9, 2021, describes the NDDEQ quality management processes that are used to maintain NDDEQ’s data quality management system. This QAPP is consistent with the QMP and applicable EPA guidelines. This QAPP is considered the “blueprint” by which individual projects within the Program involving environmental data operations are implemented and assessed and specifies how quality assurance and quality control activities will be applied during a particular project. The Program will assure its contractors are familiar with and will comply with the requirements of the QMP and QAPP when collecting and evaluating data.

By federal law, EPA-funded entities where environmental data is collected must have an approved QAPP before data collection begins. The purpose of this requirement is to ensure that the data collected are of known and suitable quality and quantity. The QAPP is a written document that outlines the procedures to ensure data is collected, analyzed, stored, managed, and reported in a manner of high enough quality to meet Data Quality Objectives (DQO) for a specific project.

This QAPP is intended to serve as the basic umbrella document for all Program activities related to the collection of environmental data for asbestos and hazardous material assessment activities with specific details for each project to be outlined in a site-specific Sampling and Analysis Plan (SAP) (Attachment A). SAPs will be prepared in accordance with the DQOs, practices, and standards within this QAPP.

A2. Distribution List The following NDDEQ personnel will receive copies of the Quality Assurance Project Plan for Brownfields State Response Program Site Asbestos/Hazardous Materials Assessments:

1. L. David Glatt, Director, NDDEQ;

2. Charles R. Hyatt, Director, Division of Waste Management;

3. Derek Kannenberg, Hazardous Waste Program Manager, Division of Waste Management;

4. Derek Hall, Hazardous Waste Program Staff, Division of Waste Management;

5. Frederick Ilunga, Hazardous Waste Program Staff, Division of Waste Management;

6. Ted Poppke, Quality Assurance Manager, Division of Waste Management; and

7. Contractors/Service Providers as Needed.

A3. Project/Task Organization The Program is housed within the Hazardous Waste Program, which operates within the Division of Waste Management of the NDDEQ. Program operations will be conducted by the Hazardous Waste Program Manager and Hazardous Waste Program Staff. The NDDEQ and Division of Waste Management Directors have final authority to assign, approve, or deny Program activities.

Within the Program, the Designated Project Manager is assigned responsibility for Program activities. The Hazardous Waste Program Manager is responsible for ensuring all QA documents (including this QAPP) are maintained and updated as needed.

Figure 1. Organization of the Brownfields Assistance Program.

Within the Program, there are two distinct project areas:

1. Asbestos/hazardous materials assistance; and

2. Petroleum assistance.

These project areas are similar in scope and organization, but differ in application.

Asbestos/hazardous materials assistance focuses on assessment and abatement of structure containing hazardous building materials, such as asbestos, but may also assist with the characterization and management of hazardous waste materials. Petroleum assistance focuses on assessing petroleum contamination at project sites, and preparing management or remedial strategies. Each project area has a Designated Project Manager, as shown in Table 1.

Project Area Designated Project Manager Asbestos/Hazardous Materials Assistance Derek Hall

Petroleum Assistance Frederick Ilunga Table 1. Brownfields State Response Program Project Areas.

Contractors will also be hired by the Program to conduct field activities. Those contractors will report directly to the Project Manager for each project.

The Quality Assurance Manager (QAM) for all Division of Waste Management Projects is housed in the Solid Waste Program – independent of any data generation activities for the Program. The QAM will be responsible for reviewing and approving all QA documents prepared by the Designated Project Manager or Program Manager.

A4. Problem Definition/Background Brownfield sites are abandoned sites with environmental concerns acting as a barrier to reuse.

The Program aims to reduce, or eliminate, environmental concerns at a subject property in order to encourage reuse of the property. Each property will have site-specific problem(s) to address.

The most common problems involve asbestos-containing materials, but other issues exist as well. These issues may include other hazardous materials/wastes present at a site, known or suspected petroleum contamination, or others. A5. Project/Task Description.

The extent and magnitude of contamination at brownfield sites is not always known. The primary goals of an assessment are to determine what contamination or hazardous material/waste is present, the spatial extent of the contamination or amount of hazardous material/waste present on site, and identify any receptors who may be affected by the contamination. Additional assessment goals may include identification of a source of contamination and/or an assessment of human or environmental health risk.

A5. Project/Task Description The nature and scope of the assessments is variable. For example, asbestos assessments focus on the identification and quantification of asbestos-containing materials at a property. Asbestos assessments involve material samples from building materials of the property, which are then inspected for the presence of asbestos-containing material. Petroleum assessments focus on delineating the horizontal and vertical extent of petroleum contamination in soils and groundwater, and may involve additional human or environmental health risk assessments.

While the assessments have similar goals, the methods and expertise required are unique to each project. Table 2 gives a brief explanation of the most common assessment types.

Assessment Type Typical Contaminant of Concern Media Assessed

Asbestos Asbestos-containing materials. Building media, floor tiles, roofing, etc.

Hazardous Materials Various.

Unlabeled containers, unknown materials, abandoned equipment/supplies, etc.

Petroleum Petroleum hydrocarbons Soil, groundwater, soil vapors, etc.

Table 2. Types of assessments conducted.

To address the varied nature of assessments, the Program utilizes Sampling and Analysis Plans (SAPs) for each project to ensure project activities are appropriate. More information on SAPs is provided in Data Generation and Acquisition., A6. Quality Objectives and Criteria The three primary assessment types involve a wide-range of data collection activities. Some data collection activities, such as asbestos tests, involve few measurable data quality indicators and data validation methods. Others, such as petroleum sampling, have well-defined data quality standards and criteria established within laboratory analytical methods. All data collected will be complete and comparable as defined by the needs of the assessment.

A6.1 Asbestos Data Analytical asbestos testing is done on a visual basis at testing laboratories, and no testing equipment requiring calibration is used during sampling. Only in cases of lead-based X-Ray Fluorescence paint sampling or final asbestos air clearance by the contractor would a statement of the project DQO’s and measurement performance criteria be needed and would be included in the SAP.

Laboratories that analyze asbestos samples must be certified by the National Institute of Standards and Technology (NIST) National Voluntary Laboratory Accreditation Program. All asbestos analysis must be conducted pursuant to the methods listed in NDAC 33.1-15-24; 40 CFR § 745.227; and 40 CFR § 763.87. Samples analyzed using these methods must meet the data quality requirements of the identified methods.

A6.2. Laboratory Analysis Data Program staff may receive or review laboratory data. Laboratory data is used to characterize wastes, identify unknown materials, conduct lead paint analysis, or to environmental contamination. All laboratory waste analysis must be conducted pursuant to the following methods listed in the North Dakota Administrative Code (NDAC), the Code of Federal

Regulations (CFR), the Toxic Substances Control Act (TSCA) rules, and the Department of Housing and Urban Development (HUD).

Laboratories that analyze hazardous wastes in North Dakota must be certified by the NDDEQ, Division of Chemistry. All hazardous waste analysis must be conducted pursuant to the methods listed in NDAC 33.1-24-01.

Laboratories that analyze paint chips, dust, or soil samples for lead must be certified by the National Lead Laboratory Accreditation Program (NLLAP). All lead-paint related analysis must be conducted pursuant to the methods listed in 40 CFR § 763.31 and TSCA § 405(b).

Quality assurance samples, such as field blanks, duplicates, equipment blanks, and matrix spike samples must meet laboratory quality standards. Due to the variable nature of the projects conducted by the program, the frequency of quality assurance samples must be addressed in the SAP.

Blank samples are field samples collected in the same manner and with the same equipment as a field sample but using clean media. These samples should contain non-detect or background levels of the contaminant of concern. Samples with elevated levels of the contaminant of concern indicate the potential for cross contamination of field samples.

Duplicate samples are field samples taken using the same procedures and equipment as a field sample. They are collected at the same time as the field sample, and the analytical results should be closely related. If a duplicate sample and the corresponding sample differ greatly, there may issues with the sampling methodology.

Matrix spike samples are field samples that are spiked (contaminant added) with a known concentration of contaminant. These samples are analyzed for the recovery “recovery” of the known analyte. Matrix spike samples are typically reported in “percent recovery”. Low recovery means an analysis result may be biased low, while high recovery means an analysis result may be biased high.

Data quality objectives for laboratory analysis vary depending on the contaminant of concern, the media samples, the sampling conditions, sample and analysis methodology, and other factors. All data quality objectives must be discussed and established prior to sampling activities beginning. The SAP will detail all relevant data quality objectives. Program staff and contractors are responsible for ensuring all collected data meets the data quality objectives for the specific project. Failure to meet any of the data quality objectives will result in data that is not considered “accurate” and is therefore unusable.

A6.3. Environmental Site Assessments Environmental site assessments will be conducted in accordance with ASTM standards for Phase I and Phase II environmental site assessments (Phase I/II ESAs). Some information collected during a Phase I/II ESA may have been collected from a third party source (I.e.; record reviews, historical records, aerial photography). In these cases, the data will be assumed to have been collected following industry standards as long as the ESA has a statement of quality (or similar provision). Substandard third party data, such as evidence of inaccurate data collection, improper or doctored photographs, or other data oddities must be identified by Program staff.

A6.4. Precision, Bias, and Representativeness All samples will be collected in ways that ensure high levels of precision, control for bias, and are representative. Precision is defined as the agreement among repeated measurements of the same property under identical or similar conditions. Bias is defined as the positive or negative deviation from a true value. Representativeness discusses whether a sample is representative of the assessed component.

Due to the varied nature of the samples collected and taken, all aspects will be assessed to the level reasonable for the nature of the sample/analysis. In laboratory methods, QA procedures will be utilized, as well as reviewing the collection and analysis of samples as appropriate.

A7. Special Training/Certifications All on-site employees of hazardous waste contractors and Program staff must have completed the 40-hour Hazardous Waste Operations (HAZWOPER) certification as well as annual 8-hour HAZWOPER refreshers. Program staff must also complete the training requirements documented in any SOPs that must be used during Program operations.

All on-site employees of asbestos contractors must comply with all certification and licensure requirements, notification requirements, and emission standards for hazardous air pollutants listed in NDAC 33.1-15-13-01.2.

All on-site employees of lead based paint contractors must comply with all certification and licensure requirements, notification requirements, and lead-based paint standards listed in

NDAC 33.1-15-24-02.

It is the duty of the Hazardous Waste Program Manager to ensure all NDDEQ staff have received the appropriate training. NDDEQ training records are maintained in the PeopleSoft system. The Project Manager will be responsible for ensuring that all contractors have received the necessary training. Any contractors or third parties without required training must ensure staff are properly trained as it will not be provided by the NDDEQ. Documentation of training records must be maintained by the contractor and provided to the NDDEQ upon request. Any contractor training documents will be maintained in the project file.

A8. Documentation and Records All documentation must be maintained in accordance with the Program document retention policy. Records are maintained in an electronic format whenever possible. All electronic documents are maintained in the Hazardous Waste Archive with procedures described in the Hazardous Waste Program Document Storage SOP (Attachment B). Records retention policies are maintained by the North Dakota Department of Information Technology and can be found at https://apps.nd.gov/itd/recmgmt/rm/recSer/search/.

B. DATA GENERATION/ACQUISITION

B1. Sampling Process Design Program staff do not conduct any Brownfields sampling. Instead, contractors are hired for all sampling and assessment activities. When conducting sampling activities, an SAP for each individual site is prepared by Program staff and the contractor. The SAP is a site-specific document created by the contractor that identifies the site and project-specific information. The components of an SAP are discussed in sections B1.1 through B1.4. An example/template SAP for asbestos and hazardous material assessments has been included as Attachment A.

B1.1 Introduction The Introduction identifies site-specific information for the project. This includes:

1. Site description and history;

2. Health and safety concerns;

3. Contaminants of concerns;

4. Scope of work; and

5. Project objectives.

These sections are identified in the example SAP included with this document. However, documents that use other terms for the same information may also be acceptable.

B1.2 Quality Assurance/Control The SAP should address all quality assurance/quality control (QA/QC) concerns for the project.

This includes:

1. Special Training/Certification Requirements;

2. Sampling Methods & Locations;

3. QA/QC Methods; and

4. Instrument Calibration/Maintenance.

These sections are included in the example SAP. Other sections may need to be added, or some sections may be modified as needed. The Project Manager will be responsible for ensuring SAPs https://apps.nd.gov/itd/recmgmt/rm/recSer/search/ are completed as appropriate for the project. At a minimum, the four categories of QA/QC must be addressed in an SAP.

B1.3 Regulatory Criteria All applicable regulatory criteria must be listed in the SAP. This section is variable, but will commonly include information about the definition of asbestos-containing materials, delineation requirements, corrective action goals, hazardous materials/wastes determinations, and lead-based paint regulatory levels. The SAP must be reviewed by the Project Manager to ensure appropriate regulatory levels have been identified for the project. Table 3 gives a brief summary of common regulatory criteria considered during assessments.

Assessment Type Criteria of Concern Regulatory Limit Note

Asbestos Percent regulated asbestos containing material (ACM)

Contains greater than 1% friable asbestos

Asbestos-containing material may be considered friable or non-friable.

Hazardous Wastes Hazardous waste characteristics

Meets the regulatory definition of a hazardous waste as defined in NDAC 33.1- 24-02.

Hazardous wastes may be listed or characteristic. See Hazardous Waste Program Staff for guidance.

Petroleum Petroleum concentrations

NDDEQ Risk-Based Corrective Action Levels

Refer to NDRBCA guidance documents for site-specific requirements.

Hazardous Materials Hazardous material concentrations

NDDEQ Risk-Based Corrective Action Levels

Refer to NDRBCA guidance documents for site-specific requirements.

Lead-Based Paint Lead

Contains lead equal to or exceeding 5000 ppm, 1.0 mg/cm2, or 0.5% by weight.

May be present in paint or other surface coatings.

Table 3. Common regulatory limits for different assessments.

B2. Sampling Methods The SAP should describe the procedures for collecting samples. Where appropriate, the SAP will identify approved sampling and analytical methods. The SAP should indicate that the disposal of investigation derived waste will be performed in accordance with current EPA guidance.

If instruments are needed for sampling, the SAP should indicate that the instrument(s) must be calibrated, deployed, operated, and maintained to avoid cross-contamination and to ensure reliable information is collected.

EPA approved bulk sampling methods for asbestos can be found in 40 CFR § 763.86.

EPA approved methods for lead paint chip, dust, and soil sampling can be found in 40 CFR §

745.227. HUD approved methods for X-ray Fluorescence (XRF) sampling can be found EPA publication 747-R-95-0008 (1997).

B3. Sample Handling and Custody Contractors will comply with sample handling and custody procedures required by the receiving laboratory. Sample handling includes packaging, shipment from the site, chain-of-custody, and storage at the laboratory.

B4. Analytical Methods All analytical methods must be EPA approved. Laboratories conducting the analysis must be certified by the NDDEQ Division of Chemistry.

B5. Quality Control Quality control is a continuous process. The Program Manager is responsible for ensuring all projects meet all quality objectives.

B6. Instrument/Equipment Testing, Inspection, and Maintenance Equipment must be inspected and tested prior to use in the field.

B7. Instrument/Equipment Calibration and Frequency Instruments must be calibrated before each use or in compliance with manufacturer recommendations.

B8. Inspection/Acceptance for Supplies and Consumables Contractors are responsible for all supplies and consumables they use on site. Materials with an expiration date may not be used once the expiration date has passed. Contractors are required to dispose of all waste material appropriately.

B9. Use of Existing Data (Non-Direct Measurements) Existing data (prior assessments) may be used if it meets the data quality standards of complete, accurate, and verifiable. One other consideration for existing data is timeliness. If the data is existing, it may have met the data quality standards at the time of collection. However, if an extended period has passed, the data may no longer be representative. Due to the variable nature of projects, it will be up to the Program staff to determine if existing data meets the additional requirement of timeliness.

B10. Data Management All data will be summarized in reports which will be stored in the Hazardous Waste Archive. Raw sample results, measurements, and other datapoints will be maintained in project files by Program staff.

C. ASSESSMENT AND OVERSIGHT

C1. Assessments and Response Actions The SAP will identify the type of assessment activities needed for the project. All SAPs generated by the Program will be peer-reviewed by a Program QAO prior to completion of the document and all data collected under the SAP will undergo data quality assessment in accordance with this QAPP.

C2. Reports to Management All assessments must be summarized in a final report. The final report will include the following sections:

1. Introduction;

2. Site History and purpose of the assessment;

3. Summary of work completed and relevant findings of the assessment;

4. Sampling and analytical procedures used;

5. Pictures and location descriptions of all samples taken;

6. Description of all material sampled including approximate quantities identified;

7. Conclusions and Discussion;

8. Pictures and detailed map of site;

9. Laboratory analysis results and chain of custody paperwork; and

10. Copies of contractor and laboratory asbestos/hazardous material certifications and accreditations.

This final report will be prepared by the contractor and approved by Program staff.

D. DATA VALIDATION AND USABILITY

D1. Data Review, Verification, and Validation Data will be continually reviewed to ensure it meets all quality objectives. The data will be verified using documentation of sampling procedures and final reports, and it will be validated through the meeting of quality objectives.

D2. Unfit Data Data found to be unfit for any purpose must not be accepted by the Program. Data that is determined to not meet QA/QC, DQOs, or other concerns must be omitted from consideration during site management activities. Rejection of unfit data may result in a site having insufficient data to meet the goals of the project. In such a case, it will be up to the contributing parties to identify acceptable alternatives. If it is discovered that unfit data was used in project management, the Program Manager must immediately notify the Director of the Division of Waste Management and conduct an audit of the affected project.

D3. Dispute Resolution If the Program determines data is unfit for use, the contractor may dispute the claim. In this case, the contractor and Program will review all applicable information relating to the collection of the data in question, the data quality standards, the QA/QC practices, and all other information to make a joint determination. If the Program and the contractor are unable to come to a consensus, the dispute will be elevated to the appropriate procurement dispute resolution practices.

Attachment A

Site-Specific Sampling and Analysis Plan (SAP)

SAMPLING AND ANALYSIS PLAN

for

BROWNFIELDS STATE RESPONSE PROGRAM SITE

ASBESTOS/HAZARDOUS MATERIALS ASSESSMENTS

Prepared by:

Derek Hall, Environmental Scientist

Hazardous Waste Program Brownfields State Response Program

Division of Waste Management North Dakota Department of Environmental Quality

April 2023

Revision No. 1.0

Table of Contents

A. INTRODUCTION……………………………………………………………………………………………………………………..3

A1. Site Location

A2. Health and Safety

A3. Contaminants of Concern

A4. Scope of Work

A5. Project Objectives

B. QUALITY ASSURANCE/CONTROL

B1. Sampling Methods

B2. Instrumentation

C. REGULATORY CRITERIA

C1. Asbestos

C2. Lead Based Paint

C3. Hazardous Materials/Wastes…………….…………………………..……………………………………………………5

D. REPORTING

Attachments

Attachment A: Site Map

Attachment B: Copy of ND Brownfields Assistance Application for Project Site

Attachment C: Copy of Consultant Asbestos/Lead Paint Employee Certifications (if applicable)

Attachment D: Consultant Instrument Calibration and Inspection Plan (if applicable)

Attachment E: Copy of Previous Assessment Work at Project Site (if available)

A. INTRODUCTION

This Sampling and Analysis Plan (SAP) was prepared for use on all site assessments utilizing US Environmental Protection Agency (EPA) Brownfields funding. This SAP was developed as part of the North Dakota Brownfields State Response Program (Program) Quality Assurance Project Plan

(QAPP).

Contaminants that may be found at this site include asbestos containing materials (ACM), lead based paint (LBP), polychlorinated biphenyls (PCBs), hazardous and universal wastes, petroleum hydrocarbons, and other environmental contaminants.

A1. Site Description and History

Site Name: <Enter Site/Project Name>

Address: <911 Address of the Site>

County: <County Name>

Site Acreage: <Area of Site in Acres>

Latitude/Longitude: <Lat/Long of approximate center of site in Decimal Degrees using WGS84>

<Insert description of the site location and history. Include any plans for development or possible development. If a previous site investigation has been completed, it may be included as an attachment and referenced in this section instead. >

<If a previous site investigation is included but was completed more than 3 years ago at the time of the SAP, a description of why the investigation is still valid will be required. If the investigation has been accepted by Brownfields Program Staff, state when the approval was given and why.>

A2. Health and Safety <Name of Contractor> is responsible for making sure all required certifications, depending upon the contaminates of concern, are up to date. Compliance with all Occupational Safety and Health Administration (OSHA) rules onsite and providing employees with the correct Personal Protective Equipment (PPE) are also the responsibility of the contractor.

A3. Contaminants of Concern Potential environmental concerns for this project:

☐ Asbestos

☐ Lead-based Paint

☐ PCBs

☐ Hazardous Wastes

☐ Universal Wastes

☐ Petroleum Hydrocarbons

☐ Other:

A4. Scope of Work The scope of work will includes bulk testing and quantification of asbestos containing building materials, identification and quantification of other hazardous materials (including mercury containing bulbs and devices), PCB-containing equipment, lead-based paint (if applicable), refrigerated equipment, and potential hazardous wastes.

A5. Project Objectives The objectives of an asbestos/hazardous materials assessment are to conduct sampling and complete a report of the sites contaminates of concern in order to identify materials that may need to be removed before site building demolition or renovations occur.

B. QUALITY ASSURANCE/CONTROL

Contractor will conduct all sampling and reporting activities, as determined by the NDDEQ Request for Proposal and assessment contract. Contractor will comply with sample handling, quality control, and custody procedures required by the receiving laboratory.

B1. Sampling Methods EPA approved bulk sampling methods for asbestos can be found in 40 CFR § 763.86.

EPA approved methods for lead paint chip, dust, and soil sampling can be found in 40 CFR §

745.227. HUD approved methods for X-ray Fluorescence (XRF) sampling can be found EPA publication 747-R-95-0008 (1997).

B2. Instrumentation If instruments are needed for sampling the instrument(s) must be calibrated, deployed, operated, and maintained to avoid cross-contamination and to ensure reliable information is collected.

C. REGULATORY CRITERIA

Transporters of solid waste materials must have a valid North Dakota Solid Waste Transporter Permit issued by the NDDEQ. All methods used by laboratories for analytical testing must be EPA approved.

C1. Asbestos Laboratories that analyze asbestos samples must be certified by the National Institute of Standards and Technology (NIST) National Voluntary Laboratory Accreditation Program. All asbestos analysis must be conducted pursuant to the methods listed in NDAC 33.1-15-24; 40 CFR § 745.227; and 40 CFR § 763.87.

C2. Lead-Based Paint Laboratories that analyze paint chips, dust, or soil samples for lead must be certified by the National Lead Laboratory Accreditation Program (NLLAP). All lead-paint related analysis must be conducted pursuant to the methods listed in 40 CFR § 763.31 and TSCA § 405(b).

C2. Hazardous Materials/Wastes Laboratories that analyze hazardous wastes in North Dakota must be certified by the NDDEQ, Division of Chemistry. All hazardous waste analysis must be conducted pursuant to the methods listed in NDAC 33.1-24-02.

D. REPORTING

All assessments must be summarized in a final report. The final report will include the following sections:

1. Introduction.

2. Site History and purpose of the assessment.

3. Summary of work completed and relevant findings of the assessment.

4. Sampling and analytical procedures used.

5. Pictures and location descriptions of all samples taken.

6. Description of all asbestos/hazardous material containing material sampled including approximate quantities identified.

7. Conclusions and Discussion.

8. Pictures and detailed map of site.

9. Laboratory analysis results and chain of custody paperwork.

10. Copies of contractor and laboratory asbestos/hazardous material certifications and accreditations.

This final report will be prepared by the contractor and approved by Program staff.

Attachment A

Attachment B

Attachment C

Attachment D

Attachment E

Attachment B

Hazardous Waste Program Document Storage Standard Operating Procedure (SOP)

North Dakota Department of Environmental Quality 918 E. Divide Avenue

Bismarck, North Dakota 58501

Phone: (701)328 -5150

Fax: (701) 328-5200

AUTHORIZATIONS

DateTitle Signatur^eName

Derek KannenbergAuthor

Derek KannenbergProgram Manager

Ted PoppkeQA Manager

Quality Assurance / Quality Control Documentation

HAZARDOUS WASTE PROGRAM DOCUMENT STORAGE

STANDARD OPERATING PROCEDURE

HAZARDOUS WASTE PROGRAM

TITLE:

TYPE:

PROGRAM:

VERSION:

VERSION DATE:

AUTHOR(S):

1.0

4/29/2019

DEREK KANNENBERG

REVISION HISTORY

AuthorizationDateChange DescriptionRevision

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4/29/2019

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HazWaste Document Storage -vl.O

Standard Operating Procedure

HAZARDOUS WASTE PROGRAM DOCUMENT STORAGE

Table of Contents

Purpose & Use Constraints 41.0

42.0 Scope

Summary of Method

Required Equipment List

Procedure

43.0

54.0

55.0

Document Finalization 55.1

55.2 Temporary Storage

Archive Storage 65.3

7Document Storage5.4

7Document Retrieval5.5

75.6 Corrections, Errors, & Bugs

6.0 Quality Assurance/Quality Control

Appendix A Hazardous Waste Archive Fields Quick Reference Guide

Appendix B Document Types & Examples

Appendix C Monthly Document Storage Audits

,9

1.0 Purpose & Use Constraints

The purpose of this document is to describe the permanent storage practices of the Hazardous

Waste Program (the Program). It wil l discuss the types of documents that should be stored, the length of time they are stored, and the appropriate electronic formats.

The procedures were drafted in accordance with North Dakota Department of Environmental

Quality (the Department) guidance.

This document is specific to the Hazardous Waste Storage Archive (the Archive). Updates to the

Archive may necessitate changes to this procedure.

2.0 Scope

This document applies to the Hazardous Waste Program within the Division of Waste

Management at the North Dakota Department of Environmental Quality. This document will serve as the official process until a Department-wide electronic document storage procedure is implemented.

3.0 Summary of Method

All documents generated or received by the Program must be stored in an electronic format. E-mails should be stored if they contain important information. Storing documents in electronic format allows for easy retrieval and saves on physical storage space. Only final versions of documents are stored, and the primary formats are PDF, DOCX, XLSX, and image files (JPG, TIFF, PNG).

The documents will be loaded into a Microsoft Access database, where they will be copied to a secure location. There are ten (10) attributes assigned to each document. These attributes are:

Program*;

Facility/Business Name;

Site/Project Name*;

Document Type*;

Corrective Action;

Document Name;

Document Date*;

EPA ID Number;

Author or Signee; and

Comments

Items marked with an * are required fields.

Required Equipment List

• Computer with access to the Department network drives;

• Scanner (optical character recognition [OCR] capabilities preferred); and

• Internet access

4.0

5.0 Procedure

The procedure begins once a finalized version of a document is generated or received. Draft document should not be permanently stored, unless they are being utilized in day to day operations. All Draft documents must be watermarked with the word DRAFT.

Document Finalization

A document is finalized when;

5.1

1. It has received approval from all stakeholders; and

2. The appropriate individuals have signed (ink or electronic) a final version.

Once a document has been finalized, it is then converted to a permanent electronic format - if it is not already in an electronic format. The most common method is to scan a signed hard copy into a PDF. When scanning, use optical character recognition (OCR) settings to ensure the document is searchable.

Approved documents already in electronic formats, such as pictures or spreadsheets, may be considered finalized by verbal or e-mail communication. These documents are considered less formal, and record of the finalization is not necessary.

Once an e-mail has been determined to contain important information, it should be finalized in a PDF format. Attachments may be added to the database separately.

5.2 Temporary Storage

After finalizing, the document is moved into a temporary storage location. This temporary storage location must be located on the user's C: drive. This location should be a file folder labeled Temporary_Storage.

Documents can be moved into Temporary Storage after the initial scan, or one a document is received. Documents can be named to the user's preference. These file names will not be carried into the archive and are for personal use only.

5.3 Archive Storage

Once the document is staged in Temporary_Storage, it can be moved into the Archive. The

Archive storage and retrieval interface is pictured below/;

ail w m

• Rexjufredfield. | Search fof Dofuments Program

Add New Documents

Sne/Piofect NameFocddy/Businets Name ’Program

Document Name:Document type’Faeiirty/Business Nome CorrectiveAction T

I Author or Signatory Oolff Range Slte/Project Nome to

I EPA ID Number Comments ‘Document Type

;<Sel“rtOne>

CorrectiveAction T a

^ ftrdSeeofd^l Click twice to dearfAers.

Document Name

. ' radiit/

Clifford Neircn

Bismarck Public ScJiools

CalftacWpIlSerriffi?

CaifracWeil5ervt«?.s

Sherwi>iWii!umi 3421

Sharw-'in ‘Mliisma 3421

«uiTii?er ' iitViiicciWi HaiWasie

HWOCCC38 HaiWajte

H'.VOOOC33 8?0¥/ft<(eid3

HWOOOWC HaH'j'aste

‘i\V0C<!M3 nsivVaite

!AV«CC0<12 HazWflSte

/0CCC43 HazVv'ascE!

HW0CCC44 HaiWaste

H\VUCC04V f*C nwocoMS pccs

HW0C0050 PCB5

►fvVOCCC'Sl PCBi H^vococsz pce$

HW)OGC53 PC85

H'AWCf'M PCB<

KWtK)CC!55 f*C8$

HW00CCS6 PCBS

HWOnOTA? OCR'S

>:-MiC<'C-59 nanvaste

HWOCOCVH HaaWastf?

Hwocoosi narw;ast6

KVVOCCC-82 Harvvaste

‘•vvocccas KacvVaste

H\V00CCS4 HarvVaste

Program Si7t_?JAM£ Gsnsratof Plsrit 2

SPA iD

N'DDOOOGOe999 !

NDROC-COOS9.W

General | fteneratcrNot? i Geoerai Corrsr > tOAN : i ifijfjettion fi fe f.';

LOAN

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Monitoring Rer innp»cnc!'! Kep inipsctton Rep inipiicticn Rop :

ether

‘Document Date

I

EPA roMum6erf99-> No Number Assigned) Ole Town Gas

Wiliiston rariiity Willtitoofacilisy Vy’itiiston

Wiliistc'O Facilily Dakota Gasification Compary Great Plains Synfoels Riant {■t'-eanP’T^’er'jpsMitieRoijfsh f.oteau ProppftiH-Miof-Beulah 33

Coyote Station Coyote Station Bfrnbaum Scrap Yarn Prliiminar, 99 fi inbjvm Scran Va.'^Pnlirrinary 33

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Coyote Station

Coyoli? StaUem

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Author or Signee iv!

m)Comments (25S Ctn

Tartie MoonUir fAmufaLlgrlng TontB Meuntair MaruUeUiilng 39 tiirtie iVasie Retevory Services Waste Recovery Services Wistfi Recevorv-Sarvirrs loost iiripierr.ent Oavm Refinery Davis RtHner/ Oneok RwJciBS Midstream

Oneok Rockies Midstream

Orecs RocMes Midstre-a.m untair HaosingAi/tho TyrtiftMcuntalnHoiiSingAulho 99 V7?ste Recovery Services W.'ajte fi eco\

Waste RprmvotY Services Loder implement

'Services 33

ND

Alamo Station

Grasslanos Plant

Gr»s$fann<: Plant inspecllon Rep inspection Rep ;

inspection Rep inspection Rep Other lOA-vn«vmtt fieneralnr No-i

Generator fioti ^

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Generator hioii

Generator Nott

Document Source ftfrop and drop from file enplorer) D3il?.59I7M

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fV»R0l!00i4.3nS

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NDfi0000142?4

NOR<v-OC>1429C'

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I iNOTE: If the incorrect dowment is dragged in, do not delete the contertts of the Document Source bon. Simply drag In the conect documenL This will overwrite the irtoirrect document.

Add Record

I ^ Rc'cta 5»«<b’Exit Document Manager

Documents are added in the Add New Document portion of the interface. The Archive utilizes a drag-and-drop mechanism for file storage. Follow these steps to archive a document:

Open the Archive and Temporary_Storage file explorer;

Dock the Archive and Temporary_Storage to the left and right sides of the screen (or left/right screens) respectively;

Click and drag the desired document from Temporary_Storage into the Document

Source field in the Archive;

a. NOTE: Do not click in the Document Source field. This will deactivate the drop feature.

Open the document from Temporary_Storage) Use the 10 attribute fields to enter as much information as possible about the document;

a. NOTE: The comments field may be used as a tag field, or to add comments,

b. NOTE: Refer to Appendix A for a description of the document fields,

c. NOTE; When adding an e-mail and attachments, add the e-mail first. Then, note the document number and place this number in the comments field of each attachment.

1.

2.

3.

4.

5.

HazWaste Document Storage -vl.O

6. Once the fields are complete, review for accuracy;

7. Click Add Record.

A list and brief description of the available fields is available in Appendix A: Hazardous Waste

Archive Fields Quick Reference Guide. Examples of document types can be found in Appendix

B: Document Types & Examples.

5.4 Document Storage

Once the document has been added to the Archive, it is stored in a secure location on the

Department network drive. The document location and attributes are stored within the Archive data tables.

Documents must be moved into the Archive no more than one week after finalizing.

Document Retrieval

Documents are retrieved by utilizing the Search for Documents portion of the interface. The fields available for searching correspond to the information entered when storing a document.

Search fields will act as filters to the data table located beneath the search criteria. More information will decrease the number entries.

5.5

Once the appropriate document has been located, double click the gray square next to the

Document Number field. This will load a copy of the record. This record can then be saved to an appropriate work folder.

If the document loaded is in an editable format (DOCX, XLS, etc) do NOT save any changes to the document. Use the Save As... function to save a working copy to a work drive.

Corrections, Errors, & Bugs Errors and bugs can only be fixed by the Archive technician. When submitting a correction, or reporting an error or bug, include this information in an e-mail:

5.6

1. The Document Number upon which the correction/error is concerned;

2. The nature of the error; and

3. A description of the desired fix.

Corrections, errors, and bug reports can be made out to:

Derek Kannenberg

Hazardous Waste Program dkannenberg@nd.gov

701-328-5160

Quality Assurance/Quality Control The Program Manager is responsible for performing monthly reviews of entries for accuracy.

The assessment process involves reviewing stored documents for accuracy with assigned attributes. Ten (10) documents should be reviewed on a monthly basis, two from each staff member. Appendix C: Monthly Document Storage Audits contains the form that will be used to audit the records in the archive.

6.0

Any documents found to be inaccurately represented must be corrected immediately. Staff members who have accuracy rates of less than 100% will receive notification that their records are being inaccurately stored. Consistent failure to accurately store documents wil l result in re training and wil l require supervision until a 100% accuracy rate is maintained for at least 3 (3) months.

<Remainder of page left intentionally blank.>

Hazardous Waste Archive Fields Quick Reference GuideAppendix A

*Program - The program the document is associated with. HazWaste is the general category.

*Facility/Business Name-The name of the facility at the time of the document. New facilities can be added. Spelling is important.

TIP: Include store numbers for chain or franchise stores. Example; Sherwin Williams

Site/Project Name - If the facility has multiple sites, or if there are different projects associated with the site, specify here. Added project names are not tied to the facility/business.

TIP: When specifying a city, only include the facility name. Example; Williston.

*Document Type - The type of document.

Corrective Action - If the document is related to corrective action.

Document Name - The title of the report, subject of the letter, or form title.

*Document Date-The date of the document. For letters, this is usually the sent/receipt date listed in the letter. Reports would be the date of publication. The exception to this is the

Inspection Report & Letter and the LOAN. Those will be tracked by the Date of Inspection.

EPA ID Number-Jhe EPA ID number for a facility. "99" indicates no EPA ID number.

Author or Signee -\Nho signed the document. If the document has an external origin, the signee may be entered. If no author or signee can be determined, use "External".

Comments - Field used for brief descriptions or key word tags.

Document Source - Where you drag and drop your file into the archive.

TIP: Do not click inside the text box. This will interfere with the drag and drop code.

*Required Field

Document Types & ExamplesAppendix B

Biennial Report" - SQG & LQG biennial reports.

Brownfield Assessment Report" - Final assessment reports from the brownfield program

Brownfield Assistance Request" - A request for brownfields assistance

Brownfield Bid " - A bid from a contractor for a brownfield project

Brownfield Bid Request" - DEQ-generated brownfield project bid request

Brownfield Contract"- Signed contract for Brownfield projects

Brownfield Contract Documents" - Supporting Brownfield contract documents

Brownfield Funding Request" - Request for brownfield funding

End of Year Report" - Our EOY that goes to the EPA

"Financial Assurance Documentation" - Supporting documentation for Financial Assurance. FA decision documents.

"General Correspondence" - General communication between the public and the program. NOT related to enforcement or return to compliance from LOAN or NOVs.

"Generator Notification" - Notification of hazardous waste activity. EPA form 8700-12, 8700-13, 8700-23

"Inspection Report and Letter" - Inspection summary package containing the inspection report, the letter communicating the results of the inspection, and the Notice of Inspection. Used for

COMPLIANT facilities ONLY. Stored by date of inspection.

"Letter of No Further Action" - Letter confirming that a site has been remediated or has no need of remediation issued through the regulatory assurance process.

"LOAN" - Inspection summary package containing the inspection report, the letter communicating the results of the inspection, and the Notice of Inspection. Used for NON-

COMPLIANT facilities ONLY. Stored by date of inspection.

"LOAN Correspondence" - Communication between the regulated entity and the department regarding issues of non-compliance. This includes responses to LOANs, and negotiations.

"LOAN Return to Compliance" -The letter from the department that confirms the actions taken by the facility/entity are enough to return the site to compliance.

Manifest" - Manifests from generators, transporter, disposal facility, etc.

"Monitoring Report" - Report that summarizes monitoring activity. Additional detail regarding the contents of the report should be given in the comments, or by the title.

Mid Year Report" - The Mid year report given to EPA.

Phase I ESA" - Phase I environmental site assessment.

Phase I I ESA" - Phase II environmental site assessment.

Proof of Disposal" - Documentation proving that disposal of wastes has occurred.

"Request for No Further Action" - A request for approval of remediation/monitoring activities at a site have been completed.

"Request for Responsibility Exemption" - A request for release of liability from effects stemming from environmental contamination.

"Responsibility Exemption" - A department generated document that releases liability of a property owner/financier.

"Waste Characterization" - Lab analytics describing the physical and chemical properties of a waste stream.

"Waste Profile" - A pre-generated or industry standard document describing a waste or product stream.

Other" - Catch all category. Provide able description in the comments or document title.

Monthly Document Storage AuditsAppendix C

Hazardous Waste Program E-File QA Audit Document Number Deficient? Deficient FieldsStaff

Comments

Attachment C

ASTM Standards for Phase I/II ESAs

Designation: E1527 − 13

Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process1

This standard is issued under the fixed designation E1527; the number immediately following the designation indicates the year of original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A superscript epsilon (´) indicates an editorial change since the last revision or reapproval.

1. Scope

1.1 Purpose—The purpose of this practice is to define good

commercial and customary practice in the United States of America for conducting an environmental site assessment2 of a parcel of commercial real estate with respect to the range of contaminants within the scope of the Comprehensive Environ-mental Response, Compensation and Liability Act (CERCLA) (42 U.S.C. §9601) and petroleum products. As such, this practice is intended to permit a user to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations on CERCLA liability (hereinafter, the “landowner liability protections,” or “LLPs”): that is, the practice that constitutes all appropriate inquiries into the previous ownership and uses of the property consistent with good commercial and custom-ary practice as defined at 42 U.S.C. §9601(35)(B). (See Appendix X1 for an outline of CERCLA’s liability and defense provisions.) Controlled substances are not included within the scope of this standard. Persons conducting an environmental site assessment as part of an EPA Brownfields Assessment and Characterization Grant awarded under CERCLA 42 U.S.C.

§9604(k)(2)(B) must include controlled substances as defined in the Controlled Substances Act (21 U.S.C. §802) within the scope of the assessment investigations to the extent directed in the terms and conditions of the specific grant or cooperative agreement. Additionally, an evaluation of business environ-mental risk associated with a parcel of commercial real estate may necessitate investigation beyond that identified in this practice (see Sections 1.3 and 13).

1.1.1 Recognized Environmental Conditions—In defining a

standard of good commercial and customary practice for conducting an environmental site assessment of a parcel of property, the goal of the processes established by this practice is to identify recognized environmental conditions.