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Quality Assurance Project

#M* . >.-..-.. -•. • ' . ^ ' • • • ' . •1*-'"' 1"'i'";:';v.Omiaha Lead Site • • V;-.;:" i;v "; :Omaha, Nebraska

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RECEIVEDPrepared for: FF~? P pU.S. Environmental Protection Agency Lt5 lj 6 2007Region 7901 North 5th StreetKansas City, Kansas 66101

SUPERFUND DIVISION

FinalRemedial Design

Quality Assurance Project Plan

Omaha Lead SiteOmaha, Nebraska

February 1,2007

EPA Contract No.: EP-S7-05-06EPA Task Order No.: 091

BVSPC Project No.: 44701

BLACK & VEATCHbuilding a VVO M d of difference1"

ENERGY WATER INFORMATION GOVERNMENT

Prepared by:Black & Veatch Special Projects Corp.6601 College Blvd.Overland Park, Kansas 66211

Quality Assurance Project PlanOmaha Lead Site

EPA Contract No. EP-S7-05-06AES Task Order No. 094

BVSPC Project No. 044701

Approvals:

Todd Dudley, BVSPC Program Manager Date2///07

Mike Ellis, BVSPC Quality Manager Date

Bob Feild, EPA Task Order Project Manager Date

Diane Harris, Regional QA Manager Date

Contents

Acronymns and Abbreviations i

A. PROJECT MANAGEMENT 1

A3 Distribution List..1. , 1

A4 Project/Task Organization 1

A5 Problem Definition and Background Information 4

A6 Project/Task Description 6A6.1 Background 6A6.2 Work to be Performed 6

A7 Data Quality Objectives and Criteria for Measurement Data 8A7.1 Measurement Objectives 9A7.2 Data Quality Assurance Parameters 10A7.2.1 Off-Site Analytical Laboratory Data Quality 10A7.2.1.1 Precision and Accuracy 10

A7.2.1.2 Representativeness 11A7.2.1.3 Completeness 12A7.2.1.4 Comparability 12

A7.2.2 Data Quality Objectivees - Surface Soil XRF Measurements 10

A8 Training Requirements 13

A9 Documentation and Records 13A9.1 Information Required 13

A9.1.1 Field Logbook for Sampling Activities 13A9.1.2 Photographs 14A9.1.3 Laboratory Records 14A9.1.4 Data Validation Records 14

A9.2 Corrections to Documentation 14A9.3 Document Control 15A9.4 Project Files 15

B. DATA GENERATION AND ACQUISITION 16

Bl Sampling Process Design 16

B2 Sampling Methods Requirements.... 16B2.1 Sampling Procedures 16B2.2 Description of Decontamination Procedures for Sampling Equipment 16B2.3 Sample Methods, Containers, Preservation, and Maximum Holding Times 18B2.4 Investigation-Derived Wastes (IDW) 18

B3 Sample Custody and Handling Requirements 18B3.1 Sample Custody 18

Omaha Lead Site TC-1 044701.01.21RD QAPP 2/1/2007

B3.1.1 Chain-of-Custody Record 18B3.1.2 Custody Seals 19B3.1.3 Sample Receipt Form 19

B3.2 Sample Handling 19

B4 Analytical Methods and Method Detection Limits 20B4.1 Corrective Action : 21

B6 Instrument/Equipment Testing, Inspection, and Maintenance Requirements.. 22B6.1 Field and On-Site Laboratory Equipment Maintenance 22B6.2 Laboratory Preventive Maintenance 23

B7 Instrument Calibration and Frequency -. 23B7.1 Field and On-Site Laboratory Instruments '. 23B7.1.1 Field Instruments - Lead-Based Paint 23B7.1.2 On-Site Laboratory Instruments 24

B8 Inspection/Acceptance Requirements for Supplies and Consumables 24

B9 Data Acquisition Requirements (Non-Direct Measurements) 24

BIO Data Management 25

Cl Assessment and Response Actions 28

C2 Reports to Management 28

D. DATA VALIDATION AND USABILITY 29

Dl Data Review, Validation, and Reduction ; 28

D2 Validation and Verification Methods ; 28

D3 Reconciliation with User Requirements 28

E. BIBLIOGRAPHY ; 30

Illustrations

Figure 1 Project Organization Chart 2Figure 2 Data Management Process 26Figure 3 Lead-Based Paint Assessment Data Management Process 27

Table 1 RD Sampling Summary 17Table 2 Sample Methods, Containers, Preservation, and Maximum Holding Times 19

Omaha Lead Site TC-2 044701.01.21RJDQAPP 2/1/2007

Abbreviations and Acronyms

AES Architect/Engineering ServicesASTM American Society for Testing and MaterialsBgs Below ground surfaceBVID Black & Veatch Identification NumberBVSPC Black & Veatch Special Projects Corp.EPA U.S. Environmental Protection AgencyFSP field sampling planIDW Investigation-derived wasteLEGS Laboratory for Environmental and Geological StudiesMS matrix spikeMSD matrix spike duplicateNIAT National Institute of Standards and TechnologyOSHA Occupational Safety and Health Administrationppm parts per millionQA quality assuranceQAPP quality assurance project planQC quality controlRD remedial designRI/FS remedial investigation/feasibility studyRPD relative percent differenceTOPO Task Order Project ManagerXRF x-ray fluorescence

Omaha Lead SiteRDQAPP

044701.01.212/1/2007

A. PROJECT MANAGEMENT

This quality assurance project plan (QAPP) was prepared for the Omaha LeadNational Priorities List Site in Omaha, Nebraska, and is submitted as documentation ofthe protocols and procedures to be followed during collection of environmental samplesat the Site. The specific requirements for development of an approved QAPP areoutlined in the U.S. Environmental Protection Agency (EPA) statement of work (SOW)for the remedial design (RD) at the Omaha Lead Site. This Site-specific QAPP wasdeveloped in accordance with EPA Requirements for Quality Assurance Project Plans forEnvironmental Data Operations (EPA QA/R-5).

A3 Distribution List

Distribution of this approved QAPP will be as follows:

EPA Region 7: Bob Feild, EPA Region 7, TOPODiane Harris, EPA Region 7 Regional QA Manager (RQAM)

AES Contractor: David Sanders, Architect/Engineer Services (AES) SiteManager, Black & Veatch Special Projects Corp. (BVSPC)

A4 Project/Task Organization

The QAPP organization chart shown on Figure 1, indicates the typical lines ofauthority, reporting, and communications that exist between the key elements of the EPA,BVSPC, and supporting staff (subcontractors). This organization is intended to facilitatethe efficient and independent review of quality work and allow for the resolution of anyquality assurance (QA) problems. Specific responsibilities of the project personnel arediscussed in the following text.

• EPA Contracting Officer and BVSPC Program ManagerThe responsibilities of the BVSPC program manager, Todd Dudley, and EPAcontracting officer, Anthony LaMaster, under this QAPP include ensuring thefollowing:

All work performed under this QAPP is in compliance with EPA Scope ofServices for the project.Program budget proposals include provisions to comply with environmentalprotection requirements.Management includes adequate environmental resources for assignedfunctions in budget proposals.Appropriate environmental requirements are included in program plans.

Omaha Lead Site 1 044701.01.21RDQAPP 2/1/2007

EPA TOPO8. Feild

Site ManagerD. Sanders

Project EngineerC. Rope

Site SupervisorSteve Langum

Technical SupportClerical Support

EPA Contracting OfficerA. LaMaster

EPA Project OfficerJ. Seller

Program ManagerT. Dudley

BVSPC Quality ManagerM. Ellis

BVSPC H&S ManagerS. Pizzi

Subcontractors:Professional EnvironmentalEngineers, Inc. (Team Sub)FD & Associates, Inc.Marc Environmental Services,Inc.ASW Associates, Inc.Laboratory for Geologic andEnvironmental Science (LEGS),Univ. Of Colorado, Boulder

Figure 1Project Organization ChartOmaha Lead Site RD


044701.01.212/1/2007

• EPA Task Order Project OfficerThe responsibilities for the EPA Task Order Project Officer (TOPO), Bob Feild,for monitoring activities under this QAPP include the following:

Ensuring that the project is carried out consistent with establishedenvironmental quality standards, guidelines, and objectives.Ensuring that appropriate environmental requirements are included in theproject plans.Curtailing or suspending any operation that poses a clear and present dangerto members of the public or the environment.Resolving any QA problems identified by the BVSP QA manager or EPAQA Coordinator involving environmental investigation activities.Acting as liaison with the appropriate federal, state, and local environmentalofficials.Establishing and maintaining liaison and cooperative programs withappropriate federal, regional, state, and local environmental officials tofacilitate effective environmental management.

• EPA Regional OA ManagerThe responsibilities of the EPA RQAM, Diane Harris, include the following:

Reviewing this QAPP to ensure its compliance with all applicable EPAstandard operating procedures (SOPs).Reviewing other project plans to ensure their compliance with this QAPP.Initiating QA assessment and auditing activities and ensuring thatout-of-compliance issues are resolved in accordance with this QAPP.Maintaining EPA's QA documents in the manner specified in this QAPP.

• BVSPC Quality ManagerThe responsibilities of the BVSPC Quality Manager, Mike Ellis, include thefollowing:

Reviewing other project plans to ensure their compliance with this QAPP.Initiating QA assessment and auditing activities and ensuring thatout-of-compliance issues are resolved in accordance with this QAPP.Maintaining the QA documents in the manner specified in this QAPP.

• BVSPC AES Site ManagerGeneral environmental responsibilities for the AES Site Manager, David Sanders,assisted by the Project Engineer, include the following:

Abiding by and ensuring the requirements of this QAPP are implemented bypersonnel under their authority.Ensuring that personnel under their authority attend the training requiredunder this QAPP.Implementing environmental investigation activities and QA procedures,such as sampling activities, according to this QAPP, using BVSPC andsubcontractor personnel and resources.

OmahaLeadSite 3 044701.01.21RDQAPP 2/1/2007

Providing QA oversight of environmental investigation activities for BVSPCproject personnel according to this QAPP.Ensuring that appropriate environmental requirements are included in thisQAPP and the other project plans.Curtailing or suspending any operation that poses a clear and present dangerto members of the public or the environment.Resolving any QA problems identified by, the BVSC QA manager involvingenvironmental investigation activities.Developing and implementing programs that direct subcontractors to executeinvestigation activities and providing oversight, confirmation, andindependent verification of those subcontractor programs where deemedappropriate.Implementing the QAPP for all investigation activities described in this plan.Identifying and resolving QA problems and deficiencies that occur during theinvestigation activities described within this plan.Providing QA requirements in this QAPP to the subcontractors andoverseeing the subcontractors performing analysis and data validationactivities to ensure the quality of the investigation activities.

• BVSPC Project TeamThe general responsibilities for the project team include the following:

Reviewing and understanding this QAPP.Following the provisions of the QAPP when implementing environmentalinvestigation activities and QA procedures.Attending the training required by this QAPP and following the guidelinesand procedures presented in the training.

• SubcontractorsAll field subcontractors (i.e., field sampling subcontractors) will report directly tothe BVSPC Site manager. Under this QAPP, all subcontractors' responsibilitiesinclude the following:

Reviewing the requirements and QA procedures specified in this QAPP.Following the provisions of the QAPP when implementing activities and QAprocedures.

AS Problem Definition and Background Information

BVSPC has been tasked by EPA to perform the RD at the Omaha Lead Site. TheOLS Focus Area is defined as the area in the City of Omaha south of Ames Avenue,north of L Street, and east of 45th Street to the state line. During the remedialinvestigation/feasibility study (RI/FS) effort, the Focus Area was expanded to include thearea south of L Street to the Sarpy County line, an area north of Ames Avenue, and asmall western expansion area to the west of 45th Street.


The Site is defined as the individual properties that became contaminated with leadabove health-based levels as a result of historic emissions due to lead processing (EPA,2004). The contamination is from at least two sources: The most important was theASARCO lead refinery, which was located in downtown in Omaha. A second source oflead contamination is from lead paint, which flakes off homes and accumulates in thesoils.

The former ASARCO property consisted of approximately 23 acres adjacent to theMissouri River at 500 Douglas Street in downtown Omaha, Nebraska. The facility beganoperations at this location in the early 180s. Refining activities were discontinued in July199. Union Pacific Railroad is a former owner of the property. Airborne dispersion ofcontaminants due to melting and refining operations at the ASARCO facility affected alarge area, and resulted in elevated lead levels in surface soils within the OLS focus area.EPA is evaluating whether other industrial manufacturers are also responsible for leadcontamination at the Site.

A non-time critical removal action was initiated by EPA in 1999. The removalaction included remediation of soils with lead concentrations exceeding 400 parts permillion (ppm) at childcare facilities and residences occupied by children with elevatedblood-lead (EBL) concentrations of 10 or more micrograms per deciliter (ug/dl). In2002, EPA expanded the removal action to include all properties with surface soil leadconcentrations greater than 800 ppm.

The Omaha Lead Site was placed on the National Priorities List (NPL) onApril 30, 2003. The Rl/FS report (BVSPC 2004) included surface soil sampling (0-2-inches) at over 15,000 properties. Subsurface soil sampling to a depth of 24 inches belowground surface (bgs) was conducted at 500 residential properties, and interior dust wassampled at 59 residential properties.

An Interim Record of Decision was issued in December 2004. The Interim ROD(EPA, 2004). The Selected Remedy involves excavation and replacement of lead-contaminated soils where exposure to lead is of greatest concern, as follows:

• Any residential-type property where at least one non-foundation sample exceeds800 ppm lead;

• Residences with any non-foundation sample exceeding 400 ppm lead where achild identified with an elevated blood lead (EBL) level resides;

• Child-care facilities and other high child-impact areas with any non-foundationsample exceeding 400 ppm.

Omaha Lead Site J 044701.01.2]RDQAPP 2/1/2007

A6 Project/Task Descriptioni i

A6.1 Background

The objective of this work assignment is to provide Remedial Design support. This IQAPP addresses surface and subsurface soil sampling and lead-based paint (LBP)assessments planned as part of the RD field work. The following sampling activities willbe conducted: j

• Surface soil sampling (0-2 inches bgs) at residential properties within the OmahaLead Site focus area established during the RI/FS phase. j

• Drip zone surface soil sampling at 30 residential properties to evaluate theinfluence of exterior lead-based paints upon surrounding soils.

• Surface soil sampling at all public parks within the OLS focus area.• Sampling of subsurface soils (12 to 14 inches in depth) may be conducted at

remediated properties, where soils exceeding 1,200 ppm lead were left in place at |depths exceeding 12 inches below ground surface. The objective would be to iconfirm that Remedial Action Objectives (RAO, EPA,2004), were achieved.

• Lead-based paint assessments at previously remediated properties and properties |scheduled for RA. Approximately 4,500 LBP Assessments will be performed. I

• Surface soil sampling in connection with a Treatability study, described in theInterim ROD. . !

A6.2 Work to be Performed

(1) Measurements

The field work will include the collection of the minimum amount of data necessaryto satisfy the objectives of each type of sampling effort. The different sampling effortsare detailed in the Field Sampling Plan (FSP) (BVSPC, 2006a).

(2) Standards/Criteria

Residential sampling results will be used to determine whether remedial action isrequired at residential properties within the OLS Focus Area. Sampling methods andprocedures, which are described in the FSP, are based on the EPA Superfund Lead-Contaminated Residential Sites Handbook (Handbook, EPA, 2003), which details howresidential properties, should be subdivided for sampling purposes. Surface soil samplelead concentrations will be compared to criteria set in the Interim ROD (EPA 2004).Remediation will be conducted at any properties exhibiting lead levels:

• Greater than 800 ppm lead in at least one non-foundation soil sample;


• Greater than 400 ppm lead in at least one non-foundation soil sample at anyresidential-type property where an EBL child resides;

• Greater than 400 ppm lead in at least one non-foundation soil sample at anychildcare facility.

• Properties will greater than 400 ppm lead in at least one non-foundation soilsample that are not childcare facilities or where an EBL child resides will beaddressed in the Final ROD, based on the results of a Treatability Study.

Drip zone width study soil sample results will be used to study the influence of leadbased paint on the levels of lead contamination in the soils surrounding residentialstructures at the Site.

EPA has directed that all public parks within the OLS Focus Area be sampledconsistent with the Handbook (EPA, 2003), which includes parks in the definition ofresidential properties. The overall objective of this sampling effort is to determinewhether any of the public parks within the OLS Focus area are eligible for cleanup underthe Interim ROD.

BVSPC completed the sampling of public parks smaller than ten acres in June 2006.The results indicated that the screening level of 400 ppm lead was not exceeded in anyhigh-child impact areas.

If performed, subsurface soil sampling will be conducted to confirm the extent oflead contamination at remediated properties. EPA risk assessors will use the data tomake a final determination regarding whether the remaining contamination poses anongoing health risk and the issuance of a "clean letter" for each affected property.

Samples will not be collected during lead-based paint assessments: However, XRFmeasurements will be taken. The objective of the LBP Assessments will be to assess theextent and potential impact of deteriorating exterior lead-based paint on the continuedprotectiveness of the remedy and to determine whether paint stabilization is required.XRF measurements indicating lead content greater than 1 mg/crh2 are consideredconfirmation of the presence of lead-based paint.

Soil samples will be collected in connection with the Treatability Study. The samplecollection methods are explained in the Treatability Study Work Plan (BVPSC, 2006b).Soil samples will be prepared and analyzed using the same methods and procedures usedfor residential soil samples.

Soil samples will be evaluated using electron microprobe to evaluate themineralogical forms of lead present in Site soils. The objective of this work, which willbe performed at the University of Colorado, Boulder Laboratory for Geologic andEnvironmental Studies, is to make a final determination regarding the boundaries of theOLS Focus Area.

Omaha Lead Site / 044701.01.21RDQAPP 2/1/2007

(3) Personnel/Equipment Requirements

All personnel performing activities covered by this QAPP shall comply with theOccupational Safety and Health Act (OSHA) and EPA regulations regarding workerhealth and safety. Personnel requirements are discussed in detail in Part A8.

The equipment required to conduct these activities are discussed in detail in Part B2.

(4) Assessment Techniques

The EPA Region 7 Laboratory will perform data validation and review of laboratoryanalytical data. BVSPC will perform quality control (QC) activities (instrumentmaintenance, QA confirmation sample collection, etc.). BVSPC will followenvironmental sample handling and custody procedures described in the FSP (BVSPC,2006a).

(5) Project Schedule

The RD field work began in July 2005 and is expected to continue for up to48 months, including performance of the Treatability Study, which is anticipated tocommence in spring 2007.

(6) Documentation

. Data collection activities will be documented with the following:

• Field records.• Laboratory records.• Sample analytical records.• Data evaluation memoranda.• Drip zone study report.• Periodic reports of sample results to EPA.

More detailed descriptions of the documentation are provided in Sections A9, BIO, andC2 of this QAPP.

A7 Data Quality Objectives and Criteria for Measurement Data

The main objectives of RD phase field work are the following:

• Identify residential properties requiring remedial action in accordance with theInterim ROD.

• Collect information and data to update the human health risk assessment.


• Determine the extent of lead paint influence on drip zone soils around residentialstructures.

• Determine the condition of exterior lead paint on previously remediatedproperties and on properties subject to remediation.

• Conduct a Treatability Study in accordance with provisions of the Interim ROD.• Assist EPA in finalizing the boundaries of the OLS focus area. This work will

involve electron microprobe analyses on surface soil samples.

The main objective of this QAPP is to provide guidelines for maintaining the qualityof data generated during the RD phase sampling efforts at the, Omaha Lead Site.

Specific objectives include developing field activity procedures, field documentationprocedures, quality control (QC) procedures for laboratory and field activities, and QAreporting procedures that will provide legally and scientifically defensible results. Theseobjectives will also provide data which is comparable to historical data wheneverpossible. These QA and QC procedures are described in this QAPP. The purpose of thissection (A) is to define measurement objectives, method detection limits, and QCparameters.

A7.1 Measurement Objectives

All measurements must be made so that results are representative of the media andconditions being measured. All data must be calculated and reported in units consistentwith other organizations reporting similar data to allow comparison of the data. Themeasurement objectives of this investigation were discussed in Section A. Theseobjectives will be met by collecting and analyzing soil and dust samples and performinglead-based paint assessments.

The soil samples will be analyzed in the Omaha project office with x-rayfluorescence (XRF) spectrometers. The XRF instruments will be calibrated for lead inaccordance with manufacturer instructions. Results for 20 additional metals are recordedwhen XRF measurements are taken on soil samples: However, the instrument iscalibrated only for lead and results for other constituents will not be considered orevaluated. Five percent (1 out of every 20) of the soil samples will be submitted foroffsite analysis to the EPA Region 7 laboratory. These samples will be analyzed for leadalong with other metals.

The lead-based paint assessments will be conducted by analyzing the exterior paintedsurfaces of the structures with XRF spectrometers. No paint samples will be collected foranalysis.


A7.2 Data Quality Assurance Parameters

QA/QC objectives are established to ensure that all data collected during theinvestigation are of acceptable quality to support remedial response decisions. Theimplementation of appropriate QA/QC procedures allows development of meaningfultechnical conclusions.

A 7. 2. 1 Off-Site Analytical Laboratory Data Quality

Components of the QA/QC program include evaluations of the followingcharacteristics of measured data:

• Precision.• Accuracy.• Representativeness.• Completeness.• Comparability.

A7.2. 1. 1 Precision and Accuracy

The precision and accuracy QA parameters measure the reproducibility of analyticalresults and the bias of a measurement method. QC limits for analytical data areestablished under the method requirements for chemical analyses.

Precision of sample collection can be measured by comparing analytical results offield duplicate samples and matrix spike/matrix spike duplicate/matrix duplicate samples(MS/MSD/MD). The variation in the results is a measure of precision. Precision can beexpressed as the relative percent difference (RPD), which is expressed as follows:

= (D,-D2)*100%

D2)/2]

where

RPD = relative percent difference,DI and D2 = reported values for the duplicate sample pair.

Accuracy of chemical test results is assessed by spike recovery. Spike recovery isdetermined by splitting a series of samples into two portions, adding a known quantity ofa constituent of interest (spiking) to one of the portions, and submitting both portions forlaboratory analysis as independent samples. Spike recovery is then calculated as follows:

Omaha Lead Site 10 044701.01.21RD QAPP 2/1/2007

SSR SRSpike Recovery = x 100%,

SA

where

SSR = spiked sample results,SR = unspiked sample results, andS A = amount of spike added.

Average percent spike recovery can then be calculated by averaging the individualpercent recoveries for a given compound. Two types of recoveries are measured: matrixspike recoveries and surrogate spike recoveries. For a matrix spike, known amounts ofstandard compounds that are identical to the compounds of interest present in the sampleare added to the sample. For a surrogate spike, the standards are chemically similar butnot identical to the compounds in the fraction being analyzed. The purpose of thesurrogate spike is to provide QC on every sample by monitoring for unusual matrixeffects and gross sample processing errors during the analysis of organic compounds.

The control limits for precision and accuracy are a RPD of 80 percent and spikerecovery as specified in the analytical method for soil samples analyzed off-Site. TheRPD between XRF results and laboratory results is 80 percent. The control limits will beutilized to identify outliers (data results outside the specified control limits). If outliersoccur, the samples in question may be reanalyzed, if possible, or carefully evaluated on acase-by-case basis. If either the XRF result or the laboratory analytical result is above theaction level, remediation decisions will be based on the higher result regardless of theRPD between the samples.

A7.2.1.2 Representativeness

Representativeness expresses the degree to which sample data accurately andprecisely represent Site conditions. The representativeness of data is evaluatedsubjectively by the following:

• Comparing actual sampling procedures to those delineated in the planningdocuments.

• Meeting extraction and analytical holding time method requirements.• Comparing analytical results of field duplicate results to determine the spread in

the analytical results.• Examining the results of QC blanks for evidence of contamination; contamination

may be cause for invalidation or qualification of the affected samples.

Results classified as questionable or qualitative by any of these criteria will bedocumented as such and possibly invalidated.


A 7.2.1.3 Completeness

Completeness is a measure of the amount of valid data obtained from a measurementsystem or program compared with the amount that was expected to be obtained underideal conditions. Valid data is data that has not been rejected during data validation. Itcan be expressed as a percentage as follows:

Valid Data• x 100 = Percent Completness

Total Projected Data

Completeness will be routinely assessed using this equation. The completeness dataquality objective for this project is 90 percent. If data deficiencies fail to meet thecompleteness data quality objectives, the need for resampling of the deficient data will beevaluated.

A7.2.1.4 Comparability

Comparability expresses the confidence with which one set of analytical data may becompared with another. Data that can be used for comparison are duplicate and matrixspike/matrix spike duplicate results for each sample data group. Comparability ismaintained through the consistent use of standard analytical methods and units. Dataobtained from XKF can be comparable to data obtained from a laboratory using non-XRFmethods if agreement is achieved between the two. When samples were split betweenthe field XRF and the off-Site laboratory, the data indicated an average RPD ofapproximately 26 percent, which is acceptable. The same historical data indicated thatdata comparability for soils with lead concentrations over about 2000 ppm was not asgood. However, soils with lead concentrations in this range are remediated.

A7.2.2 Data Quality Objectives - Surface Soil XRF Measurements

Soil samples collected from residential properties will be sent to the BVSPC on-Sitelaboratory, dried (if necessary), sieved thorough a No. 10 sieve, and analyzed using XRF.The instrument will be calibrated at least twice per day according to manufacturer'sinstructions. Approximately one sample per twenty field samples will be analyzed withthe on-Site XRF and then sent to the off-site EPA QA laboratory for analysis. Becausethis procedure measures the reproducibility of the data, EPA has directed that noadditional duplicate samples will be collected and submitted to the EPA laboratory.

Historical RPD results comparing on-site lab XRF and the EPA QA lab data averageapproximately 26 percent. A RPD goal of 80 percent or less will be consideredacceptable. Corrective action is addressed in Section B4.1.


A8 Training Requirements

All BVSPC personnel who will be on-Site performing field activities associated withthe RD at the Omaha Lead Site must have successfully completed an initial 40-hourhazardous waste operations training course and, thereafter, an annual 8-hour refreshercourse. The training must comply with OSHA regulations found in 29 Code of FederalRegulations (CFR) 1910.120(e).

All personnel must complete a minimum of 3 days on-the-job training under thedirect supervision of a qualified site safety coordinator (SSC) or site supervisor beforethey are qualified to work unsupervised on a hazardous waste site.

Consistent with OSHA 29 CFR 1910.120 paragraph (e) (4), individuals, such as thefield team leader, serving in a supervisory role require an additional 8 hours of sitesupervisor training. BVSPC personnel functioning in an SSC capacity must also have atleast 6 days of experience at the level of protection expected during field activities whichhave been and are expected to be modified Level D (normal work clothes; see Health andSafety Plan).

For the RD work efforts, BVSPC will have from one to four persons at the Site. Atleast one person will be trained and currently certified in first aid and adultcardiopulmonary resuscitation (CPR).

A9 Documentation and Records

The following subsections describe the required sample documentation and theprocedures for completing these documents at the Omaha Lead Site. These documentswill be utilized for each environmental sample collected for chemical analysis. Sampledocumentation will be performed in accordance with EPA's RENSV SOP 2420.5,"Identification, Documentation, and Tracking of Samples."

A9.1 Information Required

All procedures and documentation will be reviewed by the BVSPC Site Manager toconfirm that the following documentation and sampling procedures identified in thisQAPP are followed. The BVSPC Site Manager is responsible for issuing the latestversion of the QAPP. He will verify that all personnel have been issued the latest versionof the QAPP.

A9.1.1 Field Logbook for Sampling Activities

The most important aspect of documentation is thorough, accurate recordkeeping.All information obtained during the sampling activities will be recorded in a boundlogbook with consecutively numbered pages. All entries in logbooks and on sampledocumentation forms will be made in waterproof ink, and corrections will consist of


line-out deletions that are initialed and dated. Directions for completing the field logbookare found in the FSP.

A9.1.2 Photographs

Some sampling locations may be photographed; therefore, an entry will be made inthe field notebook to identify which sampling station is depicted in each photograph.Where possible, the photographs will show the surrounding area and reference objects toidentify the sampling Sites. A digital camera will be used to take photographs.Photographs will be documented as follows:

• Initials of the photographer, month-day-year, and picture number.• Description of what is being photographed.

For example: GLF-05-30-2006-01Omaha Lead Site, Photograph of paint on south wall of house atBVID 1234.

A9.1.3 Laboratory Records

The records to be maintained by the EPA Region 7 laboratory will include sampleturnaround times, sample management records, analytical methods, and data handlingrecords for each sample data group. Specific reporting forms will be provided.

A9.1.4 Data Validation Records

The records to be maintained by the EPA will include the Data Validation SummaryReport and the validated data sheets for all data received.

A9.2 Corrections to Documentation

All original data recorded will be written with waterproof ink. No accountableserialized documents are to be destroyed or thrown away even if they are illegible orcontain inaccuracies that require a replacement document.

-i

If an error is made on an accountable document assigned to one individual, thatindividual must make corrections .by making a line through the error and entering thecorrect information. The erroneous information should not be obliterated. Anysubsequent error discovered on an accountable document should be corrected by theperson who made the entry, if possible. If necessary, changes may be made by the SiteManager or his designee. All corrections must be initialed and dated.


A9.3 Document Control

The goal of document control is to ensure that all documents are accounted for whenthe project is completed. The QA manager may schedule audits of project files. Thedocument control audit consists of checking each document submitted for accountability.Written explanations must be included for any unaccounted documents. Documents willbe maintained in the project files in accordance with the requirements of the AEScontract.

A9.4 Project Files

Once the project has been completed, files will be assembled, organized, and storedas the project file. The BVSPC project team will maintain the project file for 10 years.Upon completion of the AES contract and upon authorization by EPA, all project fileswill be copied and delivered to EPA for archiving.

Omaha Lead Site 15 044701.01.21RD QAPP 2/1/2007

B. DATA GENERATION AND ACQUISITION

B1 Sampling Process Design

The RD field work at the Omaha Lead Site will consist of conducting the followingsampling activities:

• Residential property surface soil sampling.• Public park surface soil sampling.• Drip zone width study surface soil sampling.• Subsurface soil sampling at remediated properties, if requested by EPA.• Exterior lead-based paint assessments• Speciation analyses using electron microprobe.

Because of uncertainties including obtaining property owner access signatures forsampling, the presence of child's play areas and garden areas, the number of structureslocated at a property (residence, detached garage, shed, etc.), the total number of samplesthat will be collected during RD phase sampling efforts is not known. A summary of thetypes of samples that will be collected, along with an estimate of the potential number ofsamples is provided in Table 1.

B2 Sampling Methods Requirements

For each major type of sample collection, quality control procedures are described inthe following subsections. This section is a guide for the collection of environmentalsamples by the BVSPC team. The analytical laboratory will provide sample containersand preservatives. Analytical methods, preservation requirements, bottle requirements,and holding times are listed in Table 2.

B2.1 Sampling Procedures

Sampling methods and procedures are described in the FSP (BVSPC 2006).

B2.2 Description of Decontamination Procedures for SamplingEquipment

Equipment used to collect and prepare samples (spoons, sieves, vacuums, etc.) andany other equipment (hand auger, etc.) that comes in contact with soil or dust shall bedecontaminated prior to sampling by washing with a soap solution (such as Alconox),rinsing the washed equipment with potable water, and rinsing the equipment withdistilled water. Detailed decontamination procedures are provided in the FSP(BVSPC 2006).


Table 1RD Sampling Summary

Omaha Lead Site

SampleLocations/MediaResidentialSurface Soil

Small PublicPark Surface Soil

Large PublicPark Surface Soil

ResidentialSubsurface SoilSampling atpreviouslyremediatedproperties.Surface Soil DripZone

Lead-BasedPaint Assessment

Number ofLocationsApproximately6,000properties.

40 parks

8 parks

Approximately300 properties

30 residentialproperties

Constantlychangingnumber

Analysis Summary

All samples analyzed byXRF at Omaha fieldoffice. 5 percent (1 in 20)of the samples will besent to EPA Region 7Laboratory for QA metalsanalysis.All samples analyzed byXRF at Omaha fieldoffice. 5 percent (1 in 20)of the samples will besent to EPA Region 7Laboratory for analysis.All samples analyzed byXRF at Omaha fieldoffice. 5 percent (1 in 20)of the samples will besent to EPA Region 7Laboratory for analysis.All samples analyzed byXRF at Omaha fieldoffice. 5 percent (1 in 20)of the samples will besent to EPA Region 7Laboratory for analysis.All samples analyzed byXRF at Omaha fieldoffice. 5 percent (1 in 20)of the samples sent toEPA Region 7 Laboratoryfor analysis.All samples analyzed inplace by XRF. Nosamples collected foroffsite analysis.

Comments

5 to 7 samples peryard — numberdependent onpresence of play areasand garden areas.

Number of samplescollected will bedependent of the sizeof the park asspecified in the FSP(BVSPC 2006a).30 samples per parkas specified in theFSP (BVSPC, 2006c).Additional samples inhigh child-impactareas and ball fields.1 to 5 compositesamples per property.

Up to 42 samples perproperty for a total ofapproximately 1200samples.

Approximately 1 1samples per property.


17 044701.01.212/1/2007

B2.3 Sample Methods, Containers, Preservation, and MaximumHolding Times

The sample methods, containers, preservatives, and holding times that will be usedfor the sampling at the Omaha Lead Site are summarized in Table 2. Sample storage bythe laboratory will conform to established procedures. Holding times listed in Table 2begin at the time of sample collection.

B2.4 Investigation-Derived Wastes (IDW)

IDW will include unused portions of the soil samples, XRF-analyzed soil samples,decontamination fluids, and disposable personal protective equipment and samplingequipment. Detailed IDW disposal procedures are provided in Section 4.0 of the FSP(BVSPC2006).

B3 Sample Custody and Handling Requirements

Sample custody procedures are a vital aspect of any environmental sampling event.Each sample or field measurement must be properly documented to facilitate timely,correct, and complete analysis. Additional sample custody procedures are necessary tosupport the use of data in potential enforcement actions at a Site. The sample chain-of-custody procedure provides the means to identify, track, and monitor each sample fromthe point of collection through final data reporting.

B3.1 Sample Custody

B3.1.1 Chain-of-Custody Record

A chain-of-custody record will be completed for each sample shipment to the off-Site laboratory. Standard laboratory chain-of-custody records will be used. Aftercompletion of the chain-of-custody-record, the original and all but one copy will beenclosed in a scalable plastic bag and secured to the inside of the shipping container lid.The last carbon copy of the chain-of-custody record will be kept for the project files. Ifmore than one shipping container is used for a day's shipment, a separate chain-of-custody record will be completed for each shipping container. When returned, theoriginal chain-of-custody record sent to the laboratory will be placed in the final projectfile.

Shipping containers will be secured, and custody seals will be placed across thecontainer openings as described in Subsection B3.2. As long as the chain-of-custodyrecord is sealed inside the shipping container and the custody seals remain intact,commercial carriers will not be required to sign the chain-of-custody record. Samplecustody will be performed in accordance with EPA's RENSV SOP 2420.4B, "FieldChain-of-Custody for Environmental Samples."


Table 2Sampling Methods, Containers, Preservation, and Maximum Holding Times

Omaha Lead Site

Parameter Method ContainerRequirements

Preservative Holding Time

Extraction Analysis

Soil - EPA Region 7 Laboratory AnalysisLead SW8466010 1 - 4 oz. glass jar

containing the XRF-analyzed 2oz. Whirl-Pak®

None 1 80 days 180 days

Soil - Omaha Field Office AnalysisLead EPA Method 6200 1 - 2oz. Whirl-Pak® None 180 days 1 80 days

Dust - Wipe Sample - EPA Region 7 Laboratory AnalysisLead SW8466010 1 x 8 oz glass jar None 1 80 days 1 80 days

Lead Paint - In-Place XRFLead ASTM PS 95-98 Not applicable (NA) NA NA NA

ASTM - American Society for Testing Materials

B3.1.2 Custody Seals

Chain-of-custody seals will be used to ensure the integrity of the samples should theyremain unattended or when they are relinquished to a delivery service, and until they areopened by the laboratory. All samples will be shipped in an insulated shipping container,and each shipping container will be sealed with at least two chain-of-custody seals. Theseals will be affixed to each shipping container so that it is necessary to break the seals toopen the shipping container.

63.7.3 Sample Receipt Form

If samples are provided to another party, a receipt for samples form will becompleted. After completion of this form, the original copy, which is to be signed, willbe retained for the project file, and a copy will be given to the sample recipient.

B3.2 Sample Handling

Sample packaging and shipping procedures are based on EPA guidance and U.S.Department of Transportation (USDOT) regulations (49 CFR). Samples collected at theOmaha Lead Site will be shipped as non-dangerous goods. Soil samples collected forXRF analyses are placed in 2-oz Whirly-pak containers from Nasco. These containersare labeled and delivered to the Site office.


19 044701.01.212/1/2007

The following general steps will be used for the packaging and shipping of samples:

1) Affix a completed sample label to the sample container and protect it bycovering with clear tape.

2) Protect each glass sample container with bubble wrap or foam, taped securely inplace as necessary.

3) Tape the shipping container drain closed.4) Place packing material in bottom of cooler for cushioning as necessary.5) Place the samples (protected by bubble wrap or foam) into the sample container.6) Fill the remaining volume of the cooler with packing material as necessary.7) Fill out and sign the chain-of-custody record and indicate the estimated time the

shipping container will be relinquished to a courier service or when the shippingcontainer will be relinquished directly to the laboratory.

8) Separate the copies of the forms. Seal the original form and all but one copy ina scalable plastic bag and tape it to the inside lid of the shipping container.

9) Secure shipping container by making several revolutions with strapping tape orclear plastic tape on both ends.

10) If shipped by courier, place airbill marked for delivery with laboratory addresson shipping container.

11) Affix custody seals over top front and top back corners of the shippingcontainer. Cover seals with clear plastic tape.

12) Notify the EPA laboratory by telephone and provide the following information:

- Sender's name and firm (BVSPC).~ Project name (Omaha Lead Site).— Number and type of samples to be received.-- Date and estimated time of delivery.~ Anticipated sampling schedule (for establishing sample delivery groups at

laboratory).

The laboratory that will perform the analyses is listed below:EPA Region 7 LaboratoryC/o Nicole Roblez300 Minnesota AvenueKansas City, KS 66101(913)551-5130

13) The site supervisor shall maintain a file containing copies of the documentation.

B4 Analytical Methods and Method Detection Limits

All analyses will be performed in accordance with the methods and protocolsidentified in Table 2 (see above). Standard turnaround time for samples analyzed by theEPA Region 7 Laboratory, including holding time, performing analyses, and reporting


results, is 21 working days. The quantitation limits for each analytical method are listedbelow:

Lead SW8466010 0.3 ppm EPA Region 7 LaboratoryLead EPA Method 6200 5 ppm* Omaha field office XRF

Lead-based-paint assessment XRF measurements are reported as mg/cm2

concentration, negative (lead-based is not present), or inconclusive.

B4.1 Corrective Action

Depending upon the type or severity of the QC problem, (For example, anunacceptable RPD), additional QC documentation may be required, samples may bereanalyzed, or, if directed by EPA, additional samples may be collected for analysis.

If a laboratory QA audit or data review indicates unacceptable data, corrective actionwill be the responsibility of the EPA Region 7 laboratory.

B5 Quality Assurance/Quality Control Samples

One out of every 20 soil samples will be sent to the EPA Region 7 Laboratory forQA metals analysis (Table 2). The actual 2 oz. plastic Whirl-Pale® bag, on which theXRF measurement was taken, is sent to the EPA lab. QA/QC confirmation samples arerecorded on the field sheets. Following receipt of the QA data, BVSPC places the QAsample results on the field sheets. Field duplicates will not be collected unless directedby the EPA TOPO.

Equipment rinsate blanks are used to determine the effectiveness of the equipmentdecontamination: However, no equipment rinsate blanks will be collected during the RDsampling effort. . Rinsate samples were collected during the initial investigation efforts,and the results indicated no cross contamination (BVSPC 2005). Sieves and stainlesssteel spoons used to prepare samples for XRF analysis are thoroughly decontaminatedafter each use. Rinsate sample collection was terminated in 2000 after the collection ofsoil samples from 433 properties.

' The quantitation limit is based on ] 0 times the standard deviation of the low-concentration samples. Thisvalue was calculated in the Data Evaluation Report for the Remedial Investigation (BVSPC 2005). Thedetection limit was calculated as 1.1 ppm.


B5.1 Quality Assurance/Quality Control for Soils

B5.1.1 MS, MSD, or Matrix Duplicate Samples

MS and MSD samples will be analyzed at the EPA Region 7 laboratory at a rate of5 percent of the primary samples. As directed by the EPA Region 7 Laboratory, no extravolume will be collected for the MS/MSD samples. The selection of the MS and MSDsamples will be determined by the EPA Region 7 Laboratory and will generally consist ofevery 20th sample received by the laboratory.

The MS sample will be analyzed at the EPA laboratory for the same analytes as theprimary sample. A MS is a sample to which the laboratory adds known concentrations ofanalytes before analysis. The MS sample is used to evaluate the effect of the samplematrix on the accuracy of the analysis. The MSD sample will also be analyzed for thesample analytes as the primary sample. A matrix spike duplicate sample is a sample thatis divided into two separate aliquots, each of which the laboratory spikes with knownconcentrations of analytes before analysis. The two spiked aliquots are processedseparately, and the results are compared to determine the effects of the matrix on theprecision and accuracy of the analysis. RPDs will be calculated along with spikerecoveries. See Section A.2.1.

The EPA Region 7 laboratory may choose to do a matrix duplicate in place of or inaddition to the matrix spike duplicate. The procedure is to split the soil sample in twoportions and analyze both portions.

65.12 Confirmation (QA) Samples

After an XRF analysis of 19 soil samples, the next sample will be analyzed by theXRF, removed from the instrument, and shipped as is to the EPA QA Region VIIlaboratory for confirmatory, or QA, analysis. An RPD of less than 100 percent betweenthe XRF and QA results is considered acceptable.

B6 Instrument/Equipment Testing. Inspection, and MaintenanceRequirements

B6.1 Field and On-Site Laboratory Equipment Maintenance

Preventive maintenance of equipment is essential if project resources are to be usedin a cost-effective manner. Preventive maintenance will take two forms: regularlyscheduled preventive maintenance activities to minimize downtime and ensure accuracyof measurement systems and activities to ensure availability of critical spare parts,backup systems, and equipment. Any equipment or device determined not to be in goodworking order by field personnel or the Site safety coordinator will be replaced orrepaired. Maintenance records for rental equipment will be maintained by the rentalcompany.

Omaha Lead Site 22 044701.0l.2lRDQAPP 2/1/2007

B6.2 Laboratory Preventive Maintenance

The laboratory is responsible for maintaining the equipment used during analyticalprocedures. Specific instrument calibration and tuning requirements will ensure that theresults obtained are reliable. It is the laboratory's responsibility to ensure that backupsystems and equipment are available as required. Maintenance records for laboratoryequipment will be maintained by the laboratory.

B7 Instrument Calibration and Frequency

B7.1 Field and On-Site Laboratory Instruments

B7.1.1 Field Instruments - Lead-Based Paint

XRF units manufactured by NITON and Scitec Corporation are being used duringthe LBP Assessments. Manufacturer's Instrument calibration requirements differ slightly.

The Niton XRF units will be calibrated at the beginning of each sampling day andrecalibrated every 4 hours. The calibration is performed using a 1.02 mg/cm2 N1STStandard Reference Material 259 paint film. If the calibration average is not within ±0.1mg/cm2, the manufacturer's instructions will be followed to adjust the instrument withintolerance limits before any measurements are taken.

Daily calibration daily checks on the Scitec Map-4 XRF units are performed usingblocks of wood painted with a known lead level or a NIST standard backed by commonbuilding material. Five calibration checks are performed each morning prior to use, priorto and after each LBP Assessment. In addition, on-site validation checks are performedafter two hours of continued usage. If the validation checks result in data out ofcalibration range, then the MAP 4 unit will be sent back to the manufacturer to be fixedor replaced.

If the result of any of the individual checks deviate from the manufacturer's averageby more than ± 0.2 mg/cm2, a confirmation measurement will be taken. If theconfirmation measurement is off by more than ± 0.1 mg/cm2, the manufacturer will becontacted.

Literature .(HUD, 1995, page -10 for references) has shown that multiple locations ona painted surface will result in only a 0.1 percent variation. Therefore, only one locationfor each exterior wall is required for a representative XRF reading.


87.1.2 On-Site Laboratory Instruments

Calibration and maintenance procedures for the Innov-X XRF analyzers used for soilanalyses will be performed in accordance with manufacturer recommendations andrequirements. Pre-field-use calibration will be performed by the rental company. Pre-field-use calibration records will be maintained by the rental company. Calibrationactions will be recorded in the field logbooks as part of the normal field data collectionand documentation process.

Upon turning the instrument on each day, the instrument blank, or standardizationcoupon, will be analyzed first. The silicon dioxide (SiCh) test is to verify that nocontamination is on the analyzer window and is to be conducted once for approximatelyevery 50 samples analyzed. Each morning during bulk soil sampling, a set of threeNational Institute of Standards & Technology (NIST) soil standards (a low, a medium,and a high concentration standard) will be used to check the calibration of the XRF asdescribed in the instruction manual. The results will be recorded in the field logbookassigned to that unit. Should the standards readings be greater than 20 percent in error,the XRF will be returned to the leasing agency for replacement.

B7.2 Laboratory Instruments

Laboratory calibration will conform to the guidelines specified under each analyticalmethod and as specified in the EPA Region 7 Laboratory's Quality Assurance Manual.

B8 Inspection/Acceptance Requirements for Supplies andConsumables

Sample containers, coolers, or other packing materials will generally be obtainedfrom the EPA Region 7 Laboratory* Materials obtained will be checked by the SiteSupervisor or his designee for accuracy and integrity. The Site Supervisor will inspectmaterials to ensure that no containers are broken or cracked and to ensure the Integrity ofthe shipping containers appears intact.

B9 Data Acquisition Requirements (Non-Direct Measurements)

Jacobs Engineering, under a contract with the EPA, collected surface soil samplesfrom approximately 1,615 residential yards during 1999. These samples were collectedunder an EPA-approved field sampling plan (Sverdrup 1999) and were analyzed with aXRF instrument. Confirmation samples were submitted to an off-site laboratory foranalysis. The data has been reviewed and determined to be usable. The data has beenentered into the Omaha Lead Site data base.


B10 Data Management

Data management analytical services will be performed by the EPA Region 7Laboratory. Data transmittal, analysis, and storage will be performed as part of thelaboratory sample management activities. XRF soil analytical data will be handled asshown in Figure 2. Lead-based paint data flow is shown in Figure 3.


C. ASSESSMENT

C1 Assessment and Response Actions

As part of a performance and system audit of field activities, the BVSPC QAManager and Site Manager or Project Engineer may, conduct site visits to review andevaluate the performance of sampling and field measurement procedures, chain-of-custody procedures, and field documentation to ensure conformance with the QAPP.Following the site visit, a memorandum summarizing the results of the evaluation andincluding recommendations for corrective actions, if needed, will be prepared. Thememorandum will be submitted to the AES Program Manager. Random audits will beperformed by the QA Manager, as required, based on review of data as it is generated.Random audits will be conducted in accordance with EPA's REN SV SOP 1350.2A,"Conducting On-Site Review of Field Sampling Activities."

C2 Reports to Management

This task includes preparing the following documents to report the activities tomanagement:

• Monthly status or progress reports.• Corrective action reports, as necessary.• Letter reports and data evaluation memoranda.• Technical Memoranda.• Drip Zone Width Determination Study• Large Park Surface Soil Sampling Data Evaluation Memorandum.• Quality Assurance reports.

All memoranda and reports will be submitted to the EPA TOPO. Lead-based paintdata will be provided to the City of Omaha and is stored in the BVSPC Overland Park,Kansas, office. Project status reports will be submitted to the EPA TOPO with eachmonthly invoice and will document the activities that have occurred on the project thatmonth and the anticipated activities for the next period. Letter reports and TechnicalMemoranda will include analytical results and evaluation of data collected during thefield sampling activities and compared to the criteria described in section A6.2(2). AQuality Assurance report will be generated written at the end of each field samplingseason.

Omaha Lead Site 28 04470l.0l.2lRD QAPP 2/1/2007

D. DATA VALIDATION AND USABILITY

D1 Data Review, Validation, and Reduction

Sample analysis and reporting for the samples will be the responsibility of thelaboratory performing the analyses. The EPA Region 7 laboratory will be responsible forsample analysis, reporting, and data validation of the samples. BVSPC will beresponsible for data reduction efforts to evaluate the reported data.

D2 Validation and Verification Methods

EPA Region 7 laboratory will perform all data review and validation efforts foranalyses performed under the CLP. BVSPC will perform review of that data validationand provide conclusions and comments to the EPA TOPO regarding sample results,including a determination of whether the data are defensible, produced in accordancewith the QAPP and FSP, and useable for their intended purposed.

D3 Reconciliation with User Requirements

Upon compilation of the validated sample analytical results, BVSPC will review thedata in relation to the quality objectives and criteria for measurement. If BVSPCdetermines data quality indicators do not meet the projects requirements, then the datamay have to be discarded and re-sampling may be required.


E. BIBLIOGRAPHY

ASTM, 1995, Standard Provisional Practice for Quality Systems for Conducting In SituMeasurements of Lead Content in Paint or Other Coatings Using Field Portable X-RayFluorescence (XRF) Devices, Annual Book of ASTM Standards, ASTM PS 95-98.

o

ASTM, 2002, Standard Practice for Collection of Floor Dust for Chemical Analysis,2002 Annual Book of ASTM Standards, ASTM D 5438-00.11.03: 499-505.

BVSPC, 2001, Letter to Don Bahnke, EPA, from Todd Dudley, BVSPC, subject:Modifications to FSP for the Omaha Lead Site, May 1, 2001. ,

BVSPC, 2002, Statement of Work for Omaha Lead Site, prepared for EPA Region VII,September 2002.

BVSPC, 2003a, Health & Safety Plan, Omaha Lead Refining Site, Omaha, Nebraska,prepared for EPA Region VII, April 2003.

BVSPC, 2003b, Final Work Plan, Remedial Investigation/ Feasibility Study, OmahaLead Site, Omaha, Nebraska, prepared for EPA Region VII, January 22, 2003.

BVSPC, 2005, Data Evaluation Report for the Remedial Investigation at the OmahaLead Site, Omaha, Nebraska, prepared for EPA Region VII, March 25, 2005.

BVSPC, 2006a, Remedial Design, Field Sampling Plan, Omaha Lead Site, Omaha,Nebraska, prepared for EPA Region 7, December 2006.

BVSPC, 2006b, Draft Treatability Study Work Plan, Omaha Lead Site, Omaha,Nebraska, prepared for EPA Region, December 2006.

BVSPC, 2006c, Draft-Final Field Sampling Plan, Large Park Surface Soil Investigation,Omaha Lead Site, Omaha, Nebraska, November 2006.

CS3, Inc., 1998, High Volume Small Surface Sampler, HVS3, Operation Manual, 1998.

EPA, 2003, Superfund Lead-Contaminated Residential Sites Handbook,OSWER 9285.-50, August 2003.

EPA, 2004, Omaha Lead Site, Operable Unit 01, Interim Record of Decision,December 15,2004.

HUD, 1995, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards inHousing, June 1995.


Sverdrup 1999, Field Sampling Plan (FSP), Omaha Lead Site Investigation, Omaha,Nebraska, Revision 1, U.S. Environmental Protection Agency Contract No. 68-W5-0014,prepared by Sverdrup Environmental, Inc., Overland Park, Kansas, for the U.S.Environmental Protection Agency Region 7, March 22, 1999.
