2. Sampling Analysis Plan-General Property Investigation - April 2010.pdf

Remedial Action Contract for Remedial Response, Enforcement Oversight, and Non-Time

Critical Removal Activities at Sites of Release or Threatened Release of Hazardous Substances in EPA Region VIII

U.S. EPA Contract No. EP-W-05-049

Sampling and Analysis Plan, General Property Investigation

Libby Asbestos Site, Operable Unit 4

Work Assignment No.: 229-RICO-08BC Libby Asbestos Superfund Project, OU4 Remedial Investigation/Feasibility Study EPA Work Assignment Manager: Victor Ketellapper

CDM Project Manager: Dee Warren

April 23, 2010

Prepared for:

U.S. Environmental Protection Agency

Region VIII 1595 Wynkoop Street

Denver, Colorado 80202

Prepared by:

CDM Federal Programs Corporation

555 17th Street, Suite 1100

Distribution List Victor Ketellapper (2 copies) U.S. Environmental Protection Agency, Region 8 1595 Wynkoop Street; 8EPR-SR Denver, Colorado 80202-1129

Mike Cirian (1 copy) EPA Information Center 108 East 9th Street Libby, Montana 59923

EPA Information Center (5 copies) 108 East 9th Street Libby, Montana 59923

EPA Technical Assistance Unit (2 copies) U.S. Environmental Protection Agency, Region 8 1595 Wynkoop Street; 8EPR-PS Denver, Colorado 80202-1129

Catherine LeCours (2 copies) Montana Department of Environmental Quality 1100 North Last Chance Gulch Helena, Montana 59601

John Hartley (1 electronic SAP) USACE Omaha District Castle Hall, Building 525, 3rd Floor Offut Airforce Base, Nebraska 68113

Rob Burton (1 electronic SAP) Project Resources, Inc.

60 Port Boulevard, T4 Libby, Montana 59923

Mike Noble (1 copy) Libby Area Technical Advisory Group 6669 Farm to Market Road Libby, Montana 59923

Robert DeMalo (1 electronic SAP) EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, New Jersey 08077

Ron Mahoney (1 electronic SAP) EMSL Analytical, Inc.

107 West 4th Street Libby, Montana 59923

Kyeong Corbin (1 electronic SAP) Hygeia Laboratories Inc.

82 West Sierra Madre Boulevard Sierra Madre, California 91024

Jeanne Orr (1 electronic SAP) Reservoirs Environmental Services Inc.

5801 Logan Street, Suite 100 Denver, Colorado 80216

Nick Raines (7 copies, 1 electronic SAP)

CDM

60 Port Boulevard, Suite 201 Libby, Montana 59923

Project Files (1 copy)

CDM

555 17th Street, Suite 1100 i

General Property Investigation SAP.docx

Contents Section 1 Introduction

1.1 Objectives ................................................................................................................ 1-1

1.2 Project Schedule and Deliverables ....................................................................... 1-2

Section 2 Site Background

2.1 Site Location ............................................................................................................ 2-1

2.2 Site History .............................................................................................................. 2-2

2.3 Occurrence of LA ................................................................................................... 2-3

2.4 Summary of Previous Investigations .................................................................. 2-4

Section 3 Data Quality Objectives

3.1 Step 1 – State the Problem ..................................................................................... 3-1

3.2 Step 2 – Identify the Decision ............................................................................... 3-2

3.3 Step 3 – Identify the Inputs to the Decision ........................................................ 3-3

3.4 Step 4 – Define the Boundaries of the Study ...................................................... 3-3

3.4.1 Spatial Bounds .............................................................................................. 3-3

3.4.2 Temporal Bounds ......................................................................................... 3-3

3.5 Step 5 – Develop Decision Rules .......................................................................... 3-3

3.6 Step 6 – Specify Tolerable Limits on Decision Errors........................................ 3-9

3.7 Step 7 – Optimize the Design for Obtaining Data ............................................. 3-9

Section 4 Sampling Program

4.1 Pre-Sampling Activities ......................................................................................... 4-2

4.1.1 Field Planning ............................................................................................... 4-2

4.1.2 Field Team Training Requirements ........................................................... 4-3

4.1.3 Inventory and Procurement of Equipment and Supplies ....................... 4-4

4.2 Screening Investigation (SI) .................................................................................. 4-5

4.2.1 Property Selection and Initial Communication ........................................ 4-6

4.2.2 Land Survey .................................................................................................. 4-6

4.2.3 Scheduling Screening Investigations ......................................................... 4-6

4.2.4 Verbal Interview ........................................................................................... 4-6

4.2.5 Interior Screening Inspection ...................................................................... 4-7

4.2.6 Exterior Screening Inspection ..................................................................... 4-7

4.2.6.1 Visual Inspection .............................................................................. 4-7

4.2.6.2 Soil Samples ....................................................................................... 4-9

4.2.7 Screening Documentation ........................................................................... 4-9

4.3 Detailed Investigation (DI).................................................................................. 4-10

4.3.1 Property Selection and Communication ................................................. 4-10

4.3.2 Land Survey ................................................................................................ 4-11

4.3.3 Scheduling Detailed Investigations ......................................................... 4-11

4.3.4 Previously Collected Data ......................................................................... 4-11

4.3.5 Interior Design Inspection ......................................................................... 4-12

Contents ii

General Property Investigation SAP.docx

4.3.5.1 Attic Inspection ............................................................................... 4-12

4.3.5.2 Living Space Assessment and Wall Inspection .......................... 4-13

4.3.5.3 Understructure Inspection ............................................................ 4-13

4.3.5.4 Bulk Material Samples ................................................................... 4-14

4.3.5.5 Interior Soil Samples ...................................................................... 4-14

4.3.5.6 Interior Inspection Documentation .............................................. 4-14

4.3.6 Exterior Design Inspection ........................................................................ 4-16

4.3.6.1 Visual Inspection ............................................................................ 4-16

4.3.6.2 Soil Sampling .................................................................................. 4-16

4.3.6.2.1 Sample Collection .................................................... 4-17

4.3.6.3 Exterior Inspection Documentation ............................................. 4-17

4.4 Field QC Samples ................................................................................................. 4-18

4.5 General Processes ................................................................................................. 4-18

4.5.1 Equipment Decontamination .................................................................... 4-18

4.5.2 Investigation-Derived Waste .................................................................... 4-19

4.5.3 Field Sample Data Sheets .......................................................................... 4-19

4.5.4 Field Logbooks ............................................................................................ 4-19

4.5.5 Sample Labeling and Identification ......................................................... 4-20

4.5.6 Photo Documentation ................................................................................ 4-20

4.5.7 Change Control ........................................................................................... 4-21

4.5.8 GPS Point Collection .................................................................................. 4-21

4.5.9 Field Sample Custody ................................................................................ 4-21

4.5.10 Chain-of-Custody Records ....................................................................... 4-22

4.5.11 Sample Packaging and Shipping ............................................................. 4-22

4.5.12 Field Equipment Maintenance ................................................................ 4-23

Section 5 Laboratory Operations

5.1 Analytical Methods and Turnaround Times ...................................................... 5-1

5.1.1 PLM-VE/PLM-Grav – Soil Samples ........................................................... 5-1

5.1.2 PLM-9002 – Bulk Material Samples ............................................................ 5-2

5.1.3 TEM – Dust Samples ..................................................................................... 5-2

5.2 Holding Times ........................................................................................................ 5-2

5.3 Laboratory Custody Procedures .......................................................................... 5-2

5.4 Laboratory QA/QC ............................................................................................... 5-3

5.5 Laboratory Documentation and Reporting ........................................................ 5-3

5.6 Laboratory Nonconformance ............................................................................... 5-3

Section 6 Assessments and Oversight

6.1 Assessments ............................................................................................................ 6-1

6.2 Corrective Actions .................................................................................................. 6-1

6.3 Reports to Management ........................................................................................ 6-2

Contents iii

General Property Investigation SAP.docx

Section 7 Data Review and Verification

7.1 Data Review and Verification Requirements ..................................................... 7-1

7.2 DQO Reconciliation ............................................................................................... 7-1

Section 8 References .......................................................................................................... 8-1

Appendices Appendix A Standard Operating Procedures

Appendix B Field Planning Meeting Form Appendix C Inspection Forms Appendix D Example Field Sample Data Sheets Appendix E Chain-of-Custody Record Appendix F Libby Asbestos Project Record of Modification Forms (Field and

Laboratory)

Figures Figure 2-1 Site Location Map, Libby Asbestos Site Figure 2-2 Area of Response Action, Libby, Montana Figure 2-3 Operable Unit Boundaries, Libby Asbestos Site

Figure 4-1 Property Investigation Process Figure 4-2 Interior Inspection Example Sketch Figure 4-3 Exterior Sampling Example Sketch Figure 4-4 Exterior Inspection Example Sketch

Tables

Table 3-1 Summary of Inputs to Resolve Study Questions and Use of Information Acquired from Inputs

Table 3-2 Decision Rules Table 3-3 Limits on Decision Errors

Table 4-1 Standard Operating Procedures Table 4-2 Visual Inspection and Soil Sampling Protocol

Table 4-3 Investigation Sketch Details Table 4-4 Summary of Field QC Samples iv

Acronyms A&E architecture and engineering contractor AHERA Asbestos Hazard Emergency Response Act ASTM American Society for Testing and Materials BNSF Burlington Northern Santa Fe CAR corrective action request CDM CDM Federal Programs Corporation COC chain-of-custody CFR Code of Federal Regulations CSHASP comprehensive site health and safety plan CSS Contaminant Screening Study CUA common-use area DI detailed investigation DQOs data quality objectives EDD electronic data deliverable EPIF exterior property inspection form EPA U.S. Environmental Protection Agency ERS Environmental Resource Specialist FPM field planning meeting eFSDS electronic field sample data sheet FTL field team leader GPI General Property Investigation GPS global positioning system HASP health and safety plan HVAC heating, ventilation, and air conditioning ID identifier IDW investigation-derived waste IFF information field form IPIF interior property inspection form ISA interior surface area LA Libby Amphibole asbestos LC laboratory coordinator LUA limited-use area NIOSH National Institute for Occupational Safety and Health NUA non-use area OIF occupant information form OSHA Occupational Safety and Health Administration OU operable unit PLM polarized light microscopy PLM-VE polarized light microscopy – visual estimation PPE personal protective equipment QA quality assurance QC quality control RAWP Response Action Work Plan RI remedial investigation SI screening investigation Site OU4 of Libby Asbestos Superfund Site

Acronyms v

General Property Investigation SAP.docx

SAP sampling and analysis plan SOP standard operating procedure SRC Syracuse Research Corporation SUA specific-use area TEM transmission electron microscopy TL task leader VVEF visual vermiculite estimation form W.R. Grace W.R. Grace Company Zonolite Universal Zonolite Insulation Company

1-1

Section 1 Introduction This document serves as the General Property Investigation (GPI) sampling and analysis plan (SAP) for operable unit (OU) 4 (Site) of the Libby Asbestos Superfund Site. This SAP outlines activities that will be implemented to screen properties for Libby Amphibole asbestos (LA) or LA source materials and to determine the extent of any required removal action at each property selected for investigation. These activities include verbal interviews, interior and exterior visual inspections, and soil and bulk material sampling.

This SAP contains all the elements required for both a field sampling plan and quality assurance (QA) project plan. This SAP was developed in accordance with the Environmental Protection Agency 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).

The purpose of this SAP is to describe the sampling objectives, locations, measurement methods, and data quality objectives (DQOs) to support residential, commercial, and industrial response actions. The SAP is organized as follows:

Section 1 – Introduction Section 2 – Site Background Section 3 – Data Quality Objectives Section 4 – Sampling Program Section 5 – Laboratory Operations Section 6 – Assessment and Oversight Section 7 – Data Review and Verification Section 8 – References

The process detailed within this SAP will be independent of the EPA contractor completing the activities, herein referred to as the architectural and engineering contractor (A&E).

1.1 Objectives

This section defines the objectives of the GPI program and the intended use of data.

There are two main objectives to the sampling program described in this SAP:

1. Collect data to confirm the presence/absence of LA and/or LA source materials at residential, commercial, industrial, and public properties within

OU4.

2. Collect data to determine the extent of removal activities required at properties within OU4 where previous investigations indicate the presence of LA and/or LA source materials.

Section 1 Introduction

1-2

General Property Investigation SAP.docx

1.2 Project Schedule and Deliverables

Sampling activities are planned to begin in April 2010. It is estimated that over 700 properties in OU4 have had no previous investigation completed. In addition, more than 400 properties in OU4 have been identified as requiring further investigation and removal activities. The overall schedule for implementing the sampling program described in this SAP will be determined by the annual clean-up goals.

2-1

Section 2 Site Background

2.1 Site Location

The Site is located within Sections 3 and 10, T30N, R31W of the Libby Quadrangle in Lincoln County, Montana (Figure 2-1). The Site includes homes and other businesses that may have become contaminated with LA as a result of the vermiculite mining and processing conducted in and around the City of Libby (Figure 2-2).

The Site has been subdivided into eight OUs (Figure 2-3) to facilitate a phased approach to cleanup:

OU1. The former export plant is defined geographically by the property boundary of the parcel of land that included the former export plant and nearby impacted areas.

OU2. OU2 includes areas impacted by contamination released from the former screening plant. These areas include the former screening plant, the adjacent Flyway property, the Highway 37 right-of-way adjacent to the former screening plant and Rainy Creek Road, and privately-owned property. The Kootenai Bluff Subdivision area (former railroad loading station area), located directly across the Kootenai River from the former screening plant, has been removed from OU2 and is now part of OU4.

OU3. The mine OU includes the former vermiculite mine and the geographic area (including ponds) surrounding the former vermiculite mine that has been impacted by releases from the mine, including Rainy Creek and the Kootenai River. Rainy Creek Road is also included in OU3. The geographic area of OU3 is primarily based upon the extent of contamination associated with release from the former vermiculite mine.

OU4. OU4 is defined as residential, commercial, industrial (not associated with former W.R. Grace Company [W.R. Grace] operations), and public properties, including schools and parks in and around the City of Libby, or those that have received material from the mine not associated with W.R. Grace operations.

OU5. OU5 is defined geographically by the parcel of land that included the former Stimson Lumber Company. OU5 is bounded by the high bank of Libby Creek to the east, the Kootenai River to the north, and residential/commercial/industrial property within OU4 to the south and west. This OU is approximately 400 acres in size and is currently occupied by various vacant structures/buildings as well as multiple operating businesses (lumber processing, log storage, excavation contractor, etc.). Within the OU5 boundary is the Libby Groundwater Superfund Site, which is not associated with the Libby Asbestos Superfund Site.

Section 2 Site Background

2-2

General Property Investigation SAP.docx

OU6. Owned and operated by the Burlington Northern and Santa Fe Railroad (BNSF), OU6 is defined geographically by the BNSF property boundaries from the eastern boundary of OU4 to the western boundary of OU7 and extent of contamination associated with the rail yard.

OU7. Approximately 20 miles west of downtown Libby, the Troy OU includes all residential, commercial, and public properties in and around the town of Troy, Montana.

OU8. OU8 is comprised of the United States and Montana State Highway right-of-ways within the OU4 and OU7 boundaries.

2.2 Site History

Vermiculite was discovered 7 miles northeast of Libby, Montana in 1881 by gold miners. In the early 1920s, Edward Alley began initial mining operations on the vermiculite ore body located approximately 7 miles northeast of Libby. Full-scale operations began later that decade under the name of the Universal Zonolite Insulation Company (Zonolite). This ore body contains a solid solution series of amphibole asbestos fibers with compositions including tremolite, richterite, and winchite (herein referred to as LA) as defined by Meeker et al. (2003). Unlike chrysotile asbestos, LA has never been used commercially on a wide scale. During the mine's operating life, while vermiculite was used in a variety of products (including insulation and construction materials, as a carrier for fertilizer and other agricultural chemicals, and as a soil conditioner), LA was considered a byproduct of little or no value.

The vermiculite ore was mined using standard strip mining techniques and conventional mining equipment. The ore was then processed in an onsite dry mill to remove waste rock and overburden material. Once processed, the ore was transported from the mine to the former screening plant, where the ore was sorted into five size ranges. After the sorting process, the material was shipped to various locations across the United States, for either direct inclusion in products or for "expansion" prior to use in products. Expansion (also known as "exfoliation" or "popping") was accomplished by heating the ore, usually in a dry kiln, to approximately 2,000 degrees Fahrenheit.

This process explosively vaporizes the water contained within the phyllosilicate structure causing the vermiculite to expand by a factor of 10 to 15. This produces the vermiculite material most commonly sold as a soil amendment for gardens and greenhouses.

In Libby, operations handling this material occurred at four main locations: the mine and mill located on Rainy Creek Road on top of Zonolite Mountain; the former screening plant and railroad loading station located at the intersection of Highway 37 and Rainy Creek Road and directly across the Kootenai River, respectively; the former expansion/export plant (the former export plant) located immediately west of Highway 37 where it crosses the Kootenai River; and at the former expansion plant located at the end of Lincoln Road, near 5th Street. The Lincoln Road Expansion Plant

2-3

General Property Investigation SAP.docx went offline sometime in the early 1950s. In 1963, W.R. Grace purchased Zonolite and continued vermiculite mining operations in a similar fashion. In 1975, a wet milling process was added that operated in tandem with the dry mill until the dry mill was taken offline in 1985. The wet milling process was added to reduce dust generation of the milling process. Expansion operations at the former export plant ceased in Libby sometime prior to 1981, although this area was still used to bag and export milled ore until mining operations concluded in 1990. Before the mine closed in 1990, Libby produced about 80 percent of the world's supply of vermiculite.

Since 1999, Environmental Protection Agency (EPA) Region 8 has been conducting sampling and cleanup activities to address highly contaminated areas in the Libby valley. The EPA inspection was initiated in response to media articles, which detailed extensive asbestos-related health problems in the Libby population. While at first the situation was thought limited to those with direct or indirect occupational exposures, it soon became clear that there were multiple exposure pathways and many persons with no link to mining-related activities were affected.

2.3 Occurrence of LA

Typically, the LA contamination found in the Libby valley comes from one or some combination of "primary" sources: vermiculite mining wastes, vermiculite ores, vermiculite processing wastes, bulk residuals from vermiculite processing, LA-containing rocks, or vermiculite insulation. Asbestos from these primary sources has been found in interior building dust samples and local soils, which in turn act as secondary sources. To date, EPA’s goal has been to find and identify areas with elevated levels of LA (the primary sources) and to remove them. EPA has conducted removal of contaminated soil at the former export plant location, the former screening plant and adjacent properties, and residential, commercial, and public properties with LA source materials present. Removal actions have also been performed at three schools in Libby.

Cleanup work in Libby is ongoing and includes the removal of LA-containing media that include: vermiculite-containing materials (including vermiculite insulation and building materials with vermiculite additives), soil, and dust from residential, commercial, and industrial properties. The vermiculite encountered within structures/buildings is typically found in attics and exterior walls where it is used for insulation. In some cases, vermiculite insulation is found in interior and exterior walls due to sifting from the attic. In rare cases, vermiculite is found as an additive in building materials such as plaster, mortar, and concrete. The LA-contaminated soil encountered is generally due to vermiculite used as a soil amendment in flowerbeds and gardens, for leveling of low spots, and for backfilling of utilities. LA-contaminated dust occurs inside structures due to vermiculite insulation leaking into the living spaces from the attic or walls, and/or LA being tracked inside from the outdoor source locations discussed above.

2-4

General Property Investigation SAP.docx

2.4 Summary of Previous Investigations

Historical inspections at the Site include the Phase 1 and Phase 2 investigations, contaminant screening study (CSS), and the ongoing remedial investigation (RI).

The Phase 1 sampling program, initiated in early 2000, was designed as a rapid pilot-scale inspection to:

Determine whether or not airborne asbestos levels in Libby required time-critical action to protect public health

Obtain data on asbestos levels in potential source materials

Identify the most appropriate analytical methods to screen and quantify asbestos in source materials

The Phase 2 sampling program began in March 2001 and was designed to refine human exposure and health risk estimates through collection of systematic data on asbestos levels in air and other media and identification of sources of airborne asbestos. A summary of the findings of the Phase 1 and 2 studies is presented below:

Asbestos occurs in ore and processed vermiculite obtained from the mine site located outside the City of Libby.

Asbestos fibers of the type that occur in vermiculite ore from the mine site are hazardous to humans when inhaled.

Asbestos fibers that are characteristic of those that occur in materials from the Libby mine are present in a variety of different source materials at residential and commercial locations in and around Libby.

Disturbance of asbestos-contaminated source materials can result in exposure to respirable asbestos fibers in air.

The concentrations of fibers in air generated by disturbance of source materials may exceed Occupational Safety and Health Administration (OSHA) standards for acceptable occupational exposures, and estimated excess cancer risks can exceed EPA’s typical risk range by an order of magnitude or more.

The CSS inspection, which was part of OU4 RI activities, was initiated in early 2002 and employed a combination of visual inspections, verbal property owner interviews, and outdoor soil sampling to screen each property in the study area for the presence of potential sources of LA in areas where exposure is most likely to occur.

2-5

General Property Investigation SAP.docx

The primary objective of the CSS was to determine the presence or absence of potential LA sources at each property within the study area. Additional objectives included:

Identification of properties that require remediation (i.e., contain primary sources)

Identification of properties that require further inspection (i.e., contain or have indicators of secondary sources)

Quantification of relative LA abundance in soils

Identification of characteristics of properties that may increase chances of exposure to LA

Identification of characteristics of properties that may aid in development of remedial decisions

Determination of spatial trends

Results of the Phase 1 and CSS inspections are currently used to determine which properties would require additional investigation and subsequent cleanup activities.

The status for each property, as of 2006, was summarized in the 2006 CSS Final Technical Memorandum (CDM 2006a). It is estimated that over 700 properties within OU4 were not inspected during the Phase 1 and CSS sampling programs.

3-1

Section 3 Data Quality Objectives The DQO process, based on scientific methods, is a series of planning steps that are designed to ensure that the type, quantity, and quality of environmental data used in decision-making are appropriate for the intended purpose. The DQOs presented in this section were developed in accordance with EPA guidance (EPA 2006).

The DQO process specifies project decisions, the data quality required to support those decisions, specific data types needed, data collection requirements, and analytical techniques necessary to generate the specified data quality. The process also ensures that the resources required to generate the data are justified. The DQO process consists of seven steps; output from each step influences the choices that will be made later in the process. These steps include:

1. State the problem

2. Identify the decision

3. Identify the inputs to the decision

4. Define the study boundaries

5. Develop a decision rule

6. Specify tolerable limits on decision errors

7. Optimize the design

3.1 Step 1 – State the Problem

The purpose of this step is to describe the problem to be studied so that the focus of the investigation will be unambiguous.

Several property investigation field efforts have been completed for the Site, including the Phase 1 and Phase 2 investigations and the CSS. A number of properties were not inspected during these investigations due to various circumstances including refusal of access, inability to contact property owners, and incomplete county parcel information. Consequently, there are a number of properties where it is unknown whether LA contamination exists. In addition, some historical investigations were performed using techniques that differ from current site investigation protocols (e.g., 5-point composite sampling, high-traffic area visual inspections, semi-quantitative estimation of vermiculite, etc.).

Section 3 Data Quality Objectives

3-2

General Property Investigation SAP.docx

This GPI SAP was developed to reflect current investigation and sampling methods.

The GPI process is divided into two distinct phases; screening investigation (SI) and detailed investigation (DI). SIs are intended to screen properties that have not undergone previous investigation, while DIs are performed at properties where a removal trigger has been identified. The SI and DI phases will be combined into a single property visit when possible. Therefore, the overall GPI sampling program described in this SAP is designed to:

Determine if LA and/or LA source materials are present at residential, commercial, industrial, or public properties within OU4.

Determine the extent of LA contamination on each property if LA or LA source materials are present.

This SAP describes the sampling and inspection procedures that will be used to collect data of sufficient quality and representativeness to evaluate each of these items.

3.2 Step 2 – Identify the Decision

This step identifies what questions the investigation will attempt to resolve and what actions may result. The principal study questions and possible alternative actions are as follows:

Response Item Evaluated Principal Study Question Alternative Actions Screening Investigation

Determine if LA or LA source materials are present on individual properties.

Is vermiculite-containing material present in buildings?

Terminate SI phase and transition to DI phase

Take no action Is vermiculite visible in surface soils?

Terminate SI phase and transition to DI phase if vermiculite is found in SUAs

For CUAs and LUAs, document location of surface soils that contain vermiculite and isolate these areas for discrete sampling

Take no action Is LA detected at levels ≥1% in any surface soil samples collected from individual properties?

Document location of LA-contaminated surface soils and transition to DI phase

Take no action

Detailed Investigation

Determine the extent of LA contamination on individual properties if LA or LA source materials are present.

Is vermiculite insulation present in property buildings?

Sketch and document location and extent of vermiculite for removal action

Take no action Is LA detected in friable building materials (e.g., plaster) that contain vermiculite additives?

Collect samples, sketch and document location and extent of LA-contaminated building materials for removal action

Take no action

3-3

General Property Investigation SAP.docx

Response Item Evaluated Principal Study Question Alternative Actions Is LA detected at concentrations ≥5,000 s/cm2 in indoor dust from any one previously collected dust sample from individual properties?

Sketch and document location of living space with LA-contaminated indoor dust for removal action

Take no action

Is vermiculite visible in surface soils?

Sketch and document location and extent of vermiculite-containing soil for removal action

Take no action What is the extent of LA contamination in surface soils?

Collect samples, sketch and document location and extent of LA-contaminated soil for removal action

Take no action CUA – common-use area DI – detailed investigation LA – Libby Amphibole asbestos LUA – limited-use area s/cm2 – structures per square centimeter SI – screening investigation SUA – specific-use area ≥ – greater than or equal to

3.3 Step 3 – Identify the Inputs to the Decision

The purpose of this step is to identify the information and measurements that need to be obtained to resolve the decision statements. The information needed to resolve the principal study questions are summarized in Table 3-1.

3.4 Step 4 – Define the Boundaries of the Study

This step specifies the spatial and temporal boundaries of this investigation.

3.4.1 Spatial Bounds

The information gathered to answer the objectives will be collected from properties within the boundaries of OU4 and outside existing OUs as directed by EPA (Figure 2- 3). The vertical spatial boundaries extend from the highest point at a property, approximately two stories, to the depth of soil samples collected, approximately 6 inches below ground surface.

3.4.2 Temporal Bounds

For each property, the temporal boundaries of this investigation include the time from when an SI begins to the time it is determined LA or LA source materials do not exist on the property or when a DI is complete.

3.5 Step 5 – Develop Decision Rules

The purpose of this step is to describe the method that EPA will use to determine if the data collected indicate acceptance and the resulting decision applied when acceptance is not obtained. The principal study question, inputs to resolve study questions, action levels, and decision rules are summarized in Table 3-2.

3-4

General Property Investigation SAP.docx

Table 3-1 Summary of Inputs to Resolve Study Questions and Use of Information Acquired from Inputs

Principal Study Question Input to Resolve

Question Use of Input to Resolve Question Screening Investigation Is vermiculite-containing material present in buildings?

Visual Inspection For each property undergoing an SI, attics, living spaces, walls, and understructures will be inspected for vermiculite-containing material to the extent possible.

The results of the inspection will be used to determine if an LA source material is present within buildings at individual properties and result in removal action.

Is vermiculite visible in surface soils?

Visual Inspection For each property undergoing a screening investigation, a semi-quantitative visual estimation inspection of vermiculite will be performed on surface soils throughout the entire property. The results of the visual inspection will be used to determine if LA source materials are present at individual properties and to determine if DI activities are required.

Is LA detected at levels greater than or equal to 1% in any surface soil samples collected from individual properties?

Soil Samples For each property undergoing an SI, surface soil samples will be collected from use areas (e.g., SUAs, CUAs, LUAs, etc.). The results of the surface soil samples will be used to determine if LA contamination is present at individual properties and to determine if DI activities are required.

Detailed Investigation Is vermiculite insulation present in property buildings?

Visual Inspection For each property undergoing a detailed investigation, a visual inspection will be performed within each building on the property. The results of the visual inspection will be used to determine the extent of LA source materials for removal planning.

Is LA detected in friable building materials (e.g., plaster) that contain vermiculite additives?

Bulk Material Samples

For each property undergoing a detailed investigation, bulk material samples will be collected from friable building materials that contain vermiculite. The results of the bulk material samples will be used to determine if LA contamination is present in the building materials at individual properties for removal planning.

Is LA detected at concentrations greater than or equal to 5,000 s/cm2 in indoor dust from any one previously collected dust sample from individual properties?

Dust Samples For each property where dust samples were collected during previous investigations, analytical results will be reviewed to determine if LA contamination is present in indoor dust at individual properties for removal planning.

Dust samples will not be collected as part of this investigation.

Is vermiculite visible in surface soils?

Visual Inspection For each property undergoing a DI, semi-quantitative visual estimation inspections for vermiculite will be performed on surface soils to determine the extent of LA source materials for removal planning.

What is the extent of LA contamination in surface soils?

Soil Samples For each property undergoing a DI, additional surface soil samples may be collected from use areas (e.g., SUAs, CUAs, LUAs, etc.) to further determine the extent of LA contamination for removal planning.

CUA – common-use area LUA – limited-use area DI – detailed investigation SI – screening investigation LA – Libby Amphibole asbestos SUA – specific-use area

3-5

General Property Investigation SAP.docx

Table 3-2 Decision Rules

Principal Study Question Input to Resolve

Question Input Requirements Action Level Decision Rule Screening Investigation Is vermiculite-containing material present in buildings?

Visual Inspection Presence or absence of vermiculite via visual inspection

Presence of vermiculite

If open, non-contained, or migrating vermiculite is observed, the location will be documented and an interior DI will be performed.

If contained vermiculite is observed, the location will be documented.

If vermiculite is not observed, take no action.

Is vermiculite visible in surface soils?

Visual Inspection CDM-LIBBY-06 Detectable quantities of visible vermiculite as defined in CDM-

LIBBY-06

If vermiculite is observed in surface soils within SUAs, the investigation activities will transition to the DI phase.

If vermiculite is observed in surface soils only within non-SUAs, isolate these areas for discrete sampling.

If vermiculite is not observed, take no action.

Is LA detected in individual surface soil samples collected from individual properties?

Soil Samples Analysis: PLM-VE and PLM-Grav with project-specific modifications Reported Result: % LA

AS: 0.2%

Greater than or equal to1% LA

If levels of LA greater than or equal to 1% are detected in surface soil samples, the investigation activities will transition to the DI phase.

If levels of LA less than or 1% (≤1% LA, Trace, or non-detect) are detected in surface soil samples, take no action.

Detailed Investigation Is vermiculite insulation present in property buildings?

Visual Inspection Presence or absence of vermiculite insulation via visual inspection

Presence of vermiculite

If vermiculite insulation is observed, the location will be documented for subsequent removal action.

If vermiculite insulation is not observed, take no action.

Is LA detected in friable building materials (e.g., plaster) that contain vermiculite additives?

Bulk Material Samples

Analysis: PLM by NIOSH 9002 Reported Result: % LA AS: Method defined as 1%, but qualitative estimates of LA present below 1% reported as less than 1% or ND

Any detectable LA

If LA is detected in any bulk material samples, the building material(s) that the bulk sample represents will be sketched/documented for subsequent removal action.

If LA is not detected in any bulk material sample, take no action.

3-6

General Property Investigation SAP.docx

AS – analytical sensitivity ASTM – American Society for Testing and Materials DI – detailed investigation LA – Libby Amphibole asbestos NA – not applicable ND – nondetect PLM – polarized light microscopy s/cm2 – structures per square centimeter SI – screening investigation SUA – specific-use area TEM – transmission electron microscopy % – percent

Table 3-2 Decision Rules (continued)

Principal Study Question Input to Resolve

Question Input Requirements Action Level Decision Rule Detailed Investigation Is LA detected in indoor dust from previously collected individual dust samples from individual properties?

Dust Samples Analysis: TEM by ASTM D5755 with project-specific modifications Reported Result: s/cm2 AS: 1,000 per cm2

5,000 s/cm2 If LA is detected greater than or equal to 5,000 s/cm2 in any dust sample, the living space that the dust sample represents will be sketched/documented for subsequent removal action.

If LA is detected at levels less than 5,000 s/cm2 in any dust sample, take no action.

Is vermiculite visible in surface soils?

Visual Inspection CDM-LIBBY-06 Detectable quantities of visible vermiculite as defined in CDM-

LIBBY-06

If vermiculite is observed in surface soils, the location will be sketched/documented for subsequent removal action.

If vermiculite is not observed in surface soils, take no action.

What is the extent of LA contamination in surface soils?

Soil Samples Analysis: PLM-VE and PLM-Grav with project-specific modifications Reported Result: % LA

AS: 0.2% LA

Any detectable LA If any detectable levels of LA are found in surface soil samples, the location will be sketched/documented for subsequent removal action.

If LA is not detected in surface soil samples, take no action.

3-7

General Property Investigation SAP.docx

Table 3-3 Limits on Decision Errors

Principal Study Question Null Hypothesis Type I Error

Will Result in:

Type II Error

Will Result in:

Screening Investigation Is open, non-contained, or migrating vermiculite containing material present in buildings?

Vermiculite is present in property buildings.

Determining that property buildings do not contain vermiculite when they actually do. This would result in no subsequent removal action and in turn, an increased risk to human health.

Determining that property buildings contain vermiculite when actually they do not. This would result in unnecessarily performing removal action planning and adds to investigation costs.

Is vermiculite visible in surface soils? Vermiculite is present in surface soils.

Determining that surface soils do not contain vermiculite when they actually do. This may result in no subsequent exterior DI and in turn, an increased risk to human health.

Determining that surface soils contain vermiculite when they actually do not. This may result in unnecessarily performing an exterior DI and adds to investigation costs.

Is LA detected in surface soil samples collected from individual properties?

Surface soils are contaminated with

LA.

Determining that surface soils are not contaminated with LA when they actually are. This may result in no subsequent exterior DI and in turn, an increased risk to human health.

Determining that surface soils are contaminated with LA when they actually are not. This would result in unnecessarily performing an exterior DI and adds to investigation costs.

Detailed Investigation Is vermiculite insulation present in property buildings?

Vermiculite insulation is present in property buildings.

Determining that property buildings do not contain vermiculite insulation when they actually do. This would result in no subsequent removal action and in turn, an increased risk to human health.

Determining that property buildings contain vermiculite insulation when they actually do not. This would result in unnecessarily performing removal action planning and adds to investigation costs.

Is LA detected in friable building materials (e.g., plaster) that contain vermiculite additives?

Friable building materials that contain vermiculite are contaminated with LA.

Determining that friable building materials that contain vermiculite are not contaminated with LA when they actually are. The LA-contaminated building material(s) would not be included in the removal action and in turn, an increased risk to human health.

Determining that friable building materials that contain vermiculite are contaminated with LA when they actually do not. This would result in unnecessarily including the building materials in the removal action and adds unnecessary costs to the investigation and removal.

3-8

General Property Investigation SAP.docx

Principal Study Question Null Hypothesis Type I Error

Will Result in:

Type II Error

Will Result in:

Is LA detected in indoor dust from previously collected dust samples?

Indoor dust is contaminated with

LA.

Determining that indoor dust is not contaminated with LA when it actually

is. The LA-contaminated living space would not be included in the removal action and in turn, an increased risk to human health.

Determining that indoor dust that contains is contaminated with LA when it actually is not. This would result in unnecessarily including an interior cleaning to the removal action and adds unnecessary costs to the investigation and removal.

Is vermiculite visible in surface soils? Vermiculite is present in surface soils.

Determining that surface soils do not contain vermiculite when they actually do. The LA-contaminated soils would not be included in the removal action and in turn, an increased risk to human health.

Determining that surface soils contain vermiculite when they actually do not. This would result in unnecessarily including exterior excavation to the removal action and adds unnecessary costs to the investigation and removal.

What is the extent of LA contamination in surface soils?

Surface soils are contaminated with

LA.

Determining that surface soils are not contaminated with LA when they actually are. The LA-contaminated soils would not be included in the removal action and in turn, an increased risk to human health.

Determining that surface soils contain are contaminated with LA when they actually are not. This would result in unnecessarily including exterior excavation to the removal action and adds unnecessary costs to the investigation and removal.

DI – detailed investigation LA – Libby Amphibole asbestos

3-9

General Property Investigation SAP.docx

3.6 Step 6 – Specify Tolerable Limits on Decision Errors

The tolerable limits on decision errors, used to establish performance goals for the data collection design, are specified in this step.

Specific to performing SIs and DIs, two types of decision errors are possible:

A Type I (false negative) decision error would occur if a risk manager decides that an inspection/sample does not contain vermiculite/LA above a level of concern, when in fact it is of concern.

A Type II (false positive) decision error would occur if a risk manager decides that an inspection/sample does contain vermiculite/levels of LA above a level of concern, when in fact it does not.

EPA is most concerned about guarding against the occurrence of Type I errors, since an error of this type may leave humans exposed to unacceptable levels of LA.

EPA is also concerned with the probability of making Type II (false positive) decision errors. Although this type of decision error does not result in unacceptable human exposure, it may result in unnecessary expenditure of resources. Generally, EPA allows for a 20 percent false positive rate.

For the purposes of completing all seven steps of the DQO process, the null hypotheses and consequences of making an incorrect decision are summarized in Table 3-3. However, the gray region and tolerable limits on decision errors are not proposed because they are not applicable in this case.

Typically, Step 6 of the DQO process is useful to encourage careful design of decision rules by defining and integrating the errors that are acceptable based upon a myriad of integrated project management decisions such as reduction in risk to human health, implementability/practicability, and cost. As stated in the guidance document for development of DQOs: QA/G-4 (EPA 2006a), solely statistically generated tolerable limits on decisions errors are not necessary in certain cases provided that a line of reasoning (scientific justification) is presented that adequately defines acceptable limits or decision errors. This particular effort was put forth in the Action Level/Clearance Criteria Technical Memorandum (EPA 2003) for DQOs for the following sampling and inspection: (1) vermiculite in surface soils and property structures/buildings; (2) surface soil samples; and (3) indoor dust samples.

3.7 Step 7 – Optimize the Design for Obtaining Data

This step identifies a resource-effective data collection design for generating data that are expected to satisfy the DQOs. The data collection design is described in detail in the remaining sections of this SAP and other site documents referenced in Section 4.

3-10

General Property Investigation SAP.docx

Referencing the Action Level/Clearance Criteria Technical Memorandum (EPA 2003) and data previously generated for the site, the DQOs have been designed to support the proposed SI and DI activities and represent the best possible project planning effort.

However, in implementing the requirements contained in this SAP, unforeseen situations may arise or team members may find more efficient means to carry out some of the day-to-day activities.