Environmental Monitoring Plan - Brown's Island Landfill (Exhibit B)

Environmental Monitoring Plan - Brown's Island Landfill (Exhibit B)
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Prepared for
Marion County Department of Public Works
Environmental Services
5155 Silverton Road NE
Salem, Oregon 97305
Prepared by
Parametrix
700 NE Multnomah, Suite 1000
Portland, OR 97232-4110
T. 503.233.2400 T. 360.694.5020 F. 503.233.4825
www.parametrix.com
March 18, 2013 │ 275-2063-007
CITATION
Parametrix. 2013. Environmental Monitoring Plan
Browns Island Landfill
Marion County. Prepared by Parametrix, Portland,
Oregon. March 18, 2013.
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
TABLE OF CONTENTS
1. INTRODUCTION ................................................................................................ 1-1
1.1
EMP HISTORY ..................................................................................................... 1-1
1.2
PLAN ORGANIZATION ...................................................................................... 1-2
1.3
SITE LOCATION AND OPERATING BACKGROUND .................................... 1-2
1.3.1 Site Location ................................................................................................. 1-3
1.3.2 Site Description ............................................................................................ 1-3
1.3.3 Site Developments ........................................................................................ 1-3
1.3.4 Composting Facility ..................................................................................... 1-3
1.3.5 On-Site Water Supply................................................................................... 1-4
1.3.6 Adjacent Properties ...................................................................................... 1-4
1.3.7 Site Monitoring ............................................................................................. 1-5
1.4
GEOLOGIC AND HYDROGEOLOGIC CONDITIONS ..................................... 1-5
1.4.1 Geologic Conditions ..................................................................................... 1-6
1.4.2 Hydrogeologic Conditions............................................................................ 1-6
2. SITE MONITORING BACKGROUND ................................................................ 2-1
2.1
MONITORING WELL NETWORK ..................................................................... 2-1
2.1.1 Network Development.................................................................................. 2-1
2.1.2 Completion Depths ....................................................................................... 2-2
2.1.3 Background Monitoring ............................................................................... 2-2
2.1.4 Network Adjustments ................................................................................... 2-2
2.1.5 Well Survey .................................................................................................. 2-3
2.2
GROUNDWATER QUALITY .............................................................................. 2-3
2.2.1 GQAR Findings ............................................................................................ 2-4
2.2.2 GQAR Update Findings ............................................................................... 2-4
2.2.3 Annual Monitoring Report Findings ............................................................ 2-5
2.2.4 Organic Constituent Detections .................................................................... 2-5
2.2.5 River Water Quality ..................................................................................... 2-7
3. GROUNDWATER MONITORING PLAN ........................................................... 3-1
3.1
GROUNDWATER QUALITY MONITORING POINTS .................................... 3-1
3.2
MONITORING SCHEDULE ................................................................................ 3-2
3.3
COMPLIANCE BOUNDARY AND CONCENTRATION LIMITS .................... 3-2
3.4
REVIEW OF GROUNDWATER QUALITY RESULTS ..................................... 3-2
3.4.1 Routine Event Data Review Action Criteria ................................................ 3-3
3.4.2 Resampling Event Data Review Action Criteria .......................................... 3-3
3.5
DATA ANALYSIS AND EVALUATION ............................................................ 3-4
3.5.1 Data QA/QC ................................................................................................. 3-4
3.5.2 Data Presentation and Analysis .................................................................... 3-4
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Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
TABLE OF CONTENTS (CONTINUED)
3.6
REPORTING.......................................................................................................... 3-5
3.6.1 Annual Water Quality Monitoring Report .................................................... 3-5
3.6.2 DEQ Laboratory Split Sampling Report ...................................................... 3-6
3.7
REDUCTION IN MONITORING ......................................................................... 3-7
4. REFERENCES ................................................................................................... 4-1
APPENDICES
A
Solid Waste Disposal Site Closure Permit Number 255
B
Monitoring Well Logs, 1997 Well Evaluation & Upgrade Report
C
Well Logs on Record - Sections 29 thru 32
D
Property Owners and Zoning within ½-mile of the Site
E
Nitrate Investigation – 2007/2008
ATTACHMENT
A
Sampling and Analysis Plan
LIST OF FIGURES
1
Site Location
2
Facility Map
3
Aerial Site Map
4
North/South Cross-Section
5
Well Cross-Section A-A’
LIST OF TABLES
ii
1
Monitoring Well Summary Data
2
Sample Location Summary – 1974 through 2000
3
Water Quality Sample Locations, Frequency, and Schedule
4
Water Quality Monitoring Parameters
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Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
1.
INTRODUCTION
This March 18, 2013 Environmental Monitoring Plan (EMP) for the Browns Island Landfill
(BI) is an update completed to reflect changes to the site’s groundwater monitoring program
that have occurred since development of the April 26, 2001 EMP. Select elements of the
April 26, 2001 EMP were updated on September 22, 2005. This EMP for BI address
environmental monitoring requirements set forth in Section 14 of Solid Waste Disposal Site
Closure Permit Number 255, issued on May 4, 2006, for BI. A copy of the BI Solid Waste
Disposal Site Closure Permit (the closure permit) is presented in Appendix A for reference
purposes.
Environmental monitoring is required at solid waste disposal facilities to evaluate the
performance of engineered control and containment systems and the magnitude and
significance of any leachate or gas release impacts from the landfill on human health, welfare
and safety, and the environment (DEQ 1996). Environmental monitoring at the BI consists of
groundwater quality monitoring. This EMP update considers site-specific conditions to
provide a monitoring program that address closure permit requirements while being
protective of human health, welfare and safety, and the environment.
The Browns Island Landfill operated as a municipal solid waste disposal facility for the City
of Salem and surrounding Marion County area from April 1967 until September 1986 with
final closure approval granted in September 1987. The total area of the landfill complex is
approximately 87 acres. An unfilled approximately 8 acre area located near the north central
portion of the landfill is currently being filled with construction and demolition debris under
Solid Waste Disposal Site Permit Number 399. A 4.5-acre composting facility located on the
east central portion of the landfill was constructed in September 1999.
1.1 EMP HISTORY
Groundwater quality conditions at the site have been monitored through a network of
monitoring wells since 1974. The wells were originally sampled by the DEQ Laboratory on a
semi-annual frequency until March 1995 when Marion County assumed site monitoring.
Following county assumption of site monitoring in 1995, the April 19, 1996 EMP was
completed as required by the closure permit issued on October 11, 1995.
The EMP was updated on April 26, 2001 to reflect monitoring modifications and adjustments
that had occurred since completion of the April 19, 1996 EMP. These modification and
adjustments were based on additional site characterization and data analysis that resulted in
the recommendation and approval for several adjustments and modifications to the facility’s
groundwater monitoring program. Site activities completed between the April 19, 1996 and
the April 26, 2001 EMPs included:
•
Monitoring Well Evaluation – An evaluation of the monitoring well network was
completed in 1997 to assess the characteristics and integrity of the existing
monitoring wells at the site. This evaluation effort and findings are presented in the
Monitoring Well Evaluation Plan (Parametrix 1997a) and the Monitoring Well
Upgrade Report (Parametrix 1997b). Appendix B includes the 1997 monitoring well
evaluation plan and upgrade report along with associated correspondence.
•
Groundwater Quality Assessment – A Groundwater Quality Assessment Update
Report (GQAR) (Parametrix 1998) was completed to further evaluate groundwater
quality conditions at the site, evaluate facility impacts to the Willamette River, and to
modify the monitoring well network based on the report findings. The 1996 BI
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Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
Groundwater Quality Assessment Report (Parametrix 1996) compiled and evaluated
available groundwater quality data collected at the site since April 1985.
Select portions of the April 26, 2001 EMP were updated on September 22, 2005 to reflect
modifications and adjustments that had occurred to the site’s groundwater monitoring
program. Specifically, the September 22, 2005 EMP update incorpoarated permit-specific
concentration limits approved by the DEQ in a letter dated May 5, 2005.
This March 18, 2013 EMP update incorporates modification and adjustments that had
occurred to the site’s groundwater monitoring program since the September 22, 2005 EMP
update. Monitoring modifications and adjustments since 2005 include use of dedicated
sampling pumps, low-flow sampling methodology, and adjustments to the site’s sample
analysis schedule. This 2013 EMP update also identifies changes that have occurred in land
use of properties adjacent to the landfill complex and results of a nitrate investigation
completed in 2007 and 2008.
1.2 PLAN ORGANIZATION
The DEQ’s Solid Waste Permit Guidance (DEQ 1996) was referenced in the development of
this plan. This EMP update maintains the structure originally presented in the April 26, 2011
and is organized in the following manner:
•
Section 1 - Introduction. This section presents site location and operations
background, site characterization activities, geologic and hydrogeologic conditions,
and area climate. Current and proposed uses of properties adjacent to the site are also
described.
•
Section 2 – Site Monitoring. This section presents background information on the
site’s monitoring history. The groundwater monitoring network established at the site
is described. Historical groundwater quality conditions are presented.
•
Section 3 – Groundwater Quality Monitoring Plan. This section describes
groundwater quality monitoring program for the site and monitoring elements such as
schedule, analysis, data review, evaluation, and reporting.
•
Attachment A contains a site-specific Sampling and Analysis Plan (SAP). The BI
SAP describes the procedures recommended for obtaining and documenting water
quality samples collected at the site.
EMP appendices contain the following supporting information:
1-2
•
On-site well logs with installation details and recorded upgrades (Appendix B).
Documentation associated with a well evaluation and upgrades completed during
1997 are also presented.
•
Well logs on recorded at the Oregon Water Resource Department for Township 7
south, Range 3 west, Sections 29 through 32 (Appendix C). As indicated on a map
contained in Appendix C, portions of BI are situated in four sections. The Marion/
Polk County line is located in the middle of the Willamette River
•
Landowners and property zoning within a half-mile radius of the site (Appendix D).
This listing includes landowners located in both Marion and Polk Counties.
•
Activities and findings associated with a nitrate investigation completed during 2007
and 2008 (Appendix E). The material was presented in the 2007 and 2008 BI Annual
Water Quality Monitoring Reports.
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Browns Island Landfill
Marion County
Marion County Department of Public Works
References cited are presented in Section 4.
Attachment A to the EMP contains the SAP. There are two attachments associated with the
SAP. Attachment 1 presents sampling field data sheets. Attachment 2 contains an electronic
file of the current designated laboratories quality assurance program (QAP). This QAP is
contained on a compact disc.
It is expected that elements of this EMP will continue to be revised from time to time as site
conditions and monitoring objectives change. Consequently, this EMP is presented in threering binder format to allow for portions of the document to be updated or amended without
full plan revision.
1.3 SITE LOCATION AND OPERATING BACKGROUND
Background information regarding the site’s location, setting, and operation is presented
along with an overview of geologic and hydrogeologic conditions based on findings
presented in the GQAR Update.
1.3.1 Site Location
The Browns Island Landfill is located in Marion County approximately 1.5 miles west of
Salem, Oregon (Figure 1). The site is located in the northeast ¼ of the northeast ¼ of Section
31 and the northwest ¼ of Section 32, Township 7 South, Range 3 West and situated on
Browns Island, a Quaternary (Holocene) river alluvium deposit. Browns Island is bordered
by the Willamette River on its north and west sides, and by unnamed interconnecting sloughs
on its south and east sides.
The landfill complex (total area of approximately 87 acres) is enclosed within a flood
protection berm that is elevated approximately two feet higher than the 100-year flood level.
The site is located in and bounded by an area zoned as urban transition. The area around the
site was historically used for agricultural purposes but has more recently transitioned over to
conservation reserve enhancement use in an effort to protect environmentally sensitive land,
decrease erosion, restore wildlife habitat, and enhance water quality in the floodplain area
adjacent to the Willamette River. Figure 2 presents a facility site map based on a May 8,
2012, aerial photograph of the site.
1.3.2 Site Description
BI operated as a municipal solid waste disposal facility for the City of Salem and the
surrounding Marion County area from April 1967 until September 1986. The Department of
Environmental Quality (DEQ) granted final closure approval in a letter dated September 8,
1987. Landfilling began in the central portion of the site in 1967 and expanded onto City and
County land in the mid to late 1970s. From 1979 through 1986, landfill expansion was
toward the west onto adjacent private (former Trussell) property. The approximate fill
thickness is 35 feet in the older eastern portion of the site and 40 feet in the western area of
the landfill. The County secured water rights appurtenant to the former Trussell property and
a major portion of the adjoining City of Salem property and purchased the Trussell property
in 1997. In 2003, surface water irrigation rights were leased back to the State of Oregon as
part of the Conservation Reserved Enhancement Project completed at the site.
When the use of the site as a municipal landfill was terminated, there remained an unfilled
area (a former gravel pit) of approximately eight acres located near the north central portion
of the landfill (Figure 2). This unfilled area, originally bordered on the north by the protection
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Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
berm and by completed areas on all other sides, is currently being filled with construction and
demolition debris under Solid Waste Disposal Site Permit Number 399.
1.3.3 Site Developments
Several site developments have occurred since completion of the 1996 EMP. These
developments include construction of a composting facility over a portion of the eastern fill
area; conversion of the former Trussell domestic water well to an operations water supply
well; and conversion of land north and east/southeast of the landfill from cropland through
conservation reserved enhancement program to become part of the Minto-Browns Island Park
complex. Aggregate mining is occurring east of the site with a plan to ultimately create a lake
that would be integrated into the park complex.
1.3.4 Composting Facility
Construction of the BI composting facility was completed in September 1999. The facility
consists of an approximately four-acre asphalt composting pad. A stormwater collection and
management system and a water supply system were developed for the facility. The location
of the composting pad is shown on Figure 2.
The BI composting facility (BICF) is scheduled to receive and process up to 5,000 tons of
Type 1 feedstocks (primarily source-separated yard and garden wastes) material per year.
Yard debris is received from various County and City sponsored yard cleanup events held
within Marion County. Yard debris is delivered to the BICF by county, city, public, and
franchise waste haulers during specific collection events.
The volume of incoming yard debris is recorded and unloaded on a portion of the asphalt pad
and shredded using an on-site tub grinder. The shredded yard debris is formed into windrows,
watered and turned as required for the composting process. All composting activities occur
on the asphalt pad. The BICF Operations Plan further describes composting operations.
1.3.5 On-Site Water Supply
In 1998 the former Trussell domestic water supply well was upgraded and converted to an
on-site nonpotable limited use water supply source primarily for dust control on landfill
access roads, routine equipment wash down and cleaning, watering of compost to maintain
optimal moisture content, and fire suppression. As part of the BICF development, an
underground pipe was constructed from the well pump house to the compost facility. The
pipeline is designed to provide water to hydrants at the BICF. Water from the hydrants is
used to wet and cool the compost.
This well draws from the marine sediments bedrock unit that underlies the site as described in
Section 1.4. Water in this deeper rock unit is commonly high in dissolved solids and iron
(Sweet 1987). A flow meter and totalizer is installed on the well. The water supply well is
sampled on the same frequency for the same parameters as the BI monitoring wells. Samples
from the on-site water supply well are designated MW-5, consistent with the historic DEQ
site groundwater sample location designation.
1.3.6 Adjacent Properties
In 1997, the County purchased 58.3 acres of cropland adjacent to the Willamette River, which
was part of the Brown’s Island Demolition Landfill Property acquired from Robert Trussell.
The eastern portion of this area is shown on Figure 2 as the area with topographic contours
between the landfill and the river. The land had been farmed for many years without cause for
concern. Seasonal flooding of the Willamette River resulted in severe erosion of the
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Browns Island Landfill
Marion County
Marion County Department of Public Works
riverbank and farmland that raised several concerns including the loss of topsoil, sediment
and nutrient pollution from agricultural operations adjacent to the river, stability of the river
bank, and potential impact to the closed municipal solid waste landfill. Investigation into
these concerns led the Marion County to the Conservation Reserve Enhancement Program
(CREP).
The U.S. Department of Agriculture’s Farm Service Agency Commodity Credit Corporation
(CCC) and the State of Oregon agreed to implement a voluntary CREP at the site to improve
water quality of streams providing habitat for nine salmon and two trout species listed under
the Federal Endangered Species Act. CREP is designed to encourage and assist landowners to
voluntarily plant long lasting areas of ground cover (trees and shrubs – riparian buffer) on
environmentally sensitive cropland. In return for participation in the program, landowners
receive annual rental payments and cost-share assistance for the planting. Under CREP,
Marion County entered into a 15-year contract with the CCC and the State of Oregon.
The CREP project initiated by Marion County in 2000 occurred on county land located
between the western portion of BI and the Willamette River. This area has become part of the
county park system known as Eola Bend Park. This approximately 60 acre area was planted
with over 45,000 native plants that serve to control erosion, reduce flood damage, and
provide wildlife habitat along the river. On City of Salem property adjacent to the eastern
portion of BI is the western portion of the Minto-Brown Island Park. In recent years the City
through CREP planted over 5,000 native trees to create a 200-foot buffer along the sloughs
and river banks within the Minto-Brown Island Park. Year around footpaths have been
established in both parks. The locations of both parks are shown on Figure 3.
The Minto-Browns Island Park includes approximately 286 acres of cropland; approximately
107 acres borders the eastern portion of BI (Figure 3). In 2010, the City entered into a
floodplain easement agreement with the U.S. Department of Agriculture Resources
Conservation Services to remove approximately 166 acres of cropland. The easement areas
are to be restored to a more natural native condition. Initial restoration work began in 2010
with planting of various types of native trees and shrubs.
The cropland (farm field) located southwest of the western portion of BI is located outside the
park complex and is still used an active agriculture field. In 2012, a backflow channel or
initial expansion cell associated with the aggregate operation located west of BI facility was
excavated along the south side of the farm field that is adjacent to the western corner of BI.
Commercial Redimix Aggregate, Inc. operates an aggregate quarry west of BI in the area
shown on Figure 3. High quality sand and gravel deposits are extracted by surface mining to
produce material for various aggregate-related construction needs. Present operation consists
of extracting gravel, sizing the crushed rock, and cleaning sand and gravel for concrete. The
facility is permitted by the Department of Geology and Mineral Industries under operating
permit aggregate identification number 24-0010. The current disturbed area of the facility is
identified to be 115 acres with a total permitted area of 287 acres. As described in a 1997
aggregate expansion plan for the facility, the proposed long term plan for the facility is to
continue extraction, processing, and distribution of aggregate products ultimately creating a
lake which will be up to 150 surface acres in size. According to the facility’s 1997 Eola Point
Project description, the lake and a portion of the surrounding property will be incrementally
dedicated to the public as an undeveloped regional park and recreation site.
1.3.7 Site Monitoring
Groundwater quality conditions at the BI site have been monitored through a network of
monitoring wells since 1974. The location of these wells is shown on Figures 2 and 3. The
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Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
wells are sampled on a semi-annual basis. Site monitoring activities and findings are
discussed in Section 2.
1.4 GEOLOGIC AND HYDROGEOLOGIC CONDITIONS
Geologic and hydrogeologic conditions at the site are described in the BI GQAR Update
(Parametrix 1998). The geology at the site can be characterized as young river terrace
deposits consisting of stratified sands with well-rounded pebbles, gravels, and cobbles.
Underlying the young alluvium deposits is an older marine sedimentary rock unit consisting
of tuffaceous siltstone and sandstone. Groundwater flow at the site is primarily toward the
northeast with the Willamette River functioning as a discharge or a recharge boundary
dependent upon river stage. The base of the uppermost aquifer at the site is at the top of the
older marine sedimentary rock unit.
1.4.1 Geologic Conditions
There are two distinct geologic units that underlie the site. These units are the recent river
alluvium deposits and Eocene-Oligocene sedimentary rock.
The recent river alluvium consists of Quaternary (Holocene) age deposits from the
Willamette River. The unit consists of stratified sands with well-rounded pebbles, gravel, and
cobbles. The upper 15 feet of the unit generally consists of light brown sand and silt
overburden material. The lower terrace deposits, which may be present in the lower portion
of the alluvium unit, consist of unconsolidated to semi-consolidated cobbles and gravel with
sand, silt, and clay.
Underlying the river alluvium deposit is an Eocene-Oligocene sedimentary rock unit
consisting of tuffaceous siltstone and sandstone of marine depositional origin. On-site well
logs describe the unit as consisting of sandstone, silty sand, sandy clay, or blue clayey silt and
clay. At the site, the unit has been encountered at depths ranging from 27 to 55 feet below
ground surface (bgs). The Columbia River Basalt Group (CRBG) flows that are present
northwest and southeast of the site overlie this sedimentary rock unit. However, at the site,
the CRBG flows have been eroded away by the Willamette River. No known CRBG flow
remnants are present at the site.
Based on well logs, the elevation of the top of the sedimentary rock unit appears to be highest
in the central area of the landfill and slopes downward toward the Willamette River. Since the
surface elevation is fairly consistent in the unfilled area of the site, the thickness of the recent
alluvium appears to increase from the landfill to the river.
1.4.2 Hydrogeologic Conditions
There are two hydrogeologic units present at the site corresponding with the two geologic
units. The uppermost aquifer is present in the river alluvium deposit. Water-bearing zones
are also present in the deeper marine sedimentary rock unit. The hydrogeologic conditions of
these two units are described below. Figure 4 presents a north/south oriented cross-section of
the site showing the two hydrogeologic units at the site.
1.4.2.1 Alluvium
The uppermost aquifer is present in the river alluvium with groundwater depths generally
ranging from 8 to 18 feet bgs with an average depth of approximately 14 feet bgs. The
uppermost aquifer is bounded on all sides by hydraulic boundaries in the form of surface
water bodies. The Willamette River forms a boundary on the north and west sides of the site
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Marion County
Marion County Department of Public Works
and the slough system forms boundaries on the south and east sides of the site (Figure 1). The
water elevation of slough system has been observed to be predominantly higher than the
Willamette River (Parametrix 1998). A small spill dam located at the east slough’s
confluence with the Willamette River helps to maintain a higher slough stage.
The direction of groundwater flow in the uppermost aquifer is predominantly toward the
Willamette River. Groundwater flow direction reversals (i.e., flow away from the river) have
been observed to occur during periods of high river stage conditions (Parametrix 1998). The
Willamette River functions as a losing or gaining stream in the site area dependent upon river
stage conditions. In general, changes in river stage level correlate with changes in
groundwater elevations measured at the site. Changes in river stage influence the gradient of
the alluvial groundwater system (i.e., a rising river stage will decrease the groundwater flux
to the river causing a flatter groundwater gradient).
Slug tests were performed on wells MW-8b/c, MW-12a/b, MW-16, and MW-17 on June 16,
1999. Both falling and rising head tests were completed on each well. Well response was
recorded using a pressure transducer and data logger. In general, well response to the
inclusion or removal of the slug was quick. The average horizontal hydraulic conductivity for
rising head was 3.3E-02 cm/sec (93.4 ft/day). The average horizontal hydraulic conductivity
for falling head was 3.9E-02 cm/sec (110.4 ft/day). Slug test activities and analysis were
presented in an August 23, 1999, memorandum to the DEQ.
As depicted in Figure 4, the saturated thickness of the alluvium aquifer generally increases
from the landfill toward the river. As mentioned in Section 1.4.1, this is due to the apparent
decreasing elevation of the top of the sedimentary bedrock unit. The area of greatest saturated
thickness appears to be in the area of wells MW-12a/b. An increase in saturated thickness
represents an increase in the transmissivity of the aquifer. Given the understood
hydrogeologic conditions of the site, it appears that the greatest volume of groundwater
flowing away from the landfill is moving in the area between wells MW-12a/b and
MW-8a/b/c (Parametrix 1998).
1.4.2.2 Marine Bedrock
There are water-bearing zones present in the underlying Tertiary marine sedimentary bedrock
unit. Regionally, water-bearing zones present in this bedrock unit have been observed to be
confined with vertical upward gradients (Woodward 1998). Tertiary sedimentary units in the
Willamette Valley commonly produce saline waters (Woodward 1998) that yield only small
quantities of water that may be highly mineralized (Foxworthy 1970). The direction of
groundwater flow in this unit is not known but the Willamette River in the site area would
appear to function as a local area discharge point.
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Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
2.
SITE MONITORING BACKGROUND
This section presents background information on the environmental monitoring network
established at the site. The network consists of groundwater quality monitoring wells and
groundwater level measurement points. Groundwater quality monitoring at the site has been
conducted on a semi-annual basis since May 1974. This section describes the existing site
groundwater quality monitoring well network and water quality conditions.
2.1 MONITORING WELL NETWORK
Figure 2 shows the locations of active, nonactive, and decomissioned wells at the site.
Summary data for both active and nonactive wells are presented in Table 1. Table 1 also
identifies abandoned wells. Appendix B contains copies of the monitoring well logs.
Based on the current understanding of site hydrogeologic conditions, the functionality and
integrity of the BI monitoring well network is considered good for monitoring groundwater
quality conditions at the site. An evaluation of the monitoring well network was completed in
1997 (Parametrix 1997a). The evaluation led to an upgrade effort on several of the older
wells (Parametrix 1997b). Documents and correspondence associated with the 1997
monitoring well evaluation and upgrades can be found in Appendix B. All wells at the site are
secure, protected, and surveyed.
The SAP (Attachment A) describes the procedure that will be used to routinely evaluate and
maintain the integrity of all monitoring points at the site. Section 3 describes in further detail
how groundwater quality conditions at the BI will be monitored using the existing monitoring
well network.
2.1.1 Network Development
The first monitoring wells at the site were installed in 1973 and additional wells have been
installed over time as the site’s groundwater monitoring program has been modified and
adjusted. There have been five phases of well installations at the site. These well installation
phases are:
•
Phase I (May 1973) wells: MW-1a/b/c, MW-2a/b, MW-4a/b/c, and MW-6a/b/c.
Wells MW-3 and MW-5 were existing water supply wells. Wells MW-2a/b and
MW-6a/b/c were installed in existing supply wells.
•
Phase II (October 1975) wells: MW-7a/b and MW-8a/b/c.
•
Phase III (May/June 1979) wells: MW-9a/b, MW-10a/b/c, MW-11a/b, and
MW-12a/b.
•
Phase IV (October 1986) wells: MW-13, MW-14, and MW-15.
•
Phase V (November 1998) wells MW-16 and MW-17.
Wells installed prior to 1980 were completed as single, double, or triple installations. The
1997 Monitoring Well Evaluation Plan (Parametrix 1997a) presents additional monitoring
well network information in association with a plan that was used to address well suitability
issues. The 1997 Monitoring Well Upgrade Report (Parametrix 1997b) describes the
upgrades completed to the site monitoring well network.
2-
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Browns Island Landfill
Marion County
Marion County Department of Public Works
2.1.2 Completion Depths
Monitoring wells at the site have generally been completed at three different depths or zones
in the uppermost aquifer as identified below:
•
Shallow wells: MW-9b, MW-10a*, MW-6a*, MW-2a*, MW-8a, and MW-7a*. The
screen intervals for these wells are above elevation 110 feet.
•
Intermediate wells: MW-10c, MW-15, MW-6b*, MW-12a, MW-1a*, MW-8b,
MW-7b*, MW-13*, and MW-14*. The screen intervals for these wells are generally
located between elevations 100 feet and 110 feet.
•
Deep wells: MW-9a, MW-10b, MW-6c*, MW-12b, MW-1b*, MW-1c*, MW-2b*,
MW-8c, MW-16, and MW-17. The screen intervals for these wells are generally
below elevation 100 feet.
Several monitoring wells have also been completed in the underlying marine sedimentary
rock unit. Wells included in this group are:
•
Sedimentary rock wells: MW-6c*, MW-5, MW-1b*, and MW-1c*.
Wells with an asterisk indicate that the well is an inactive water quality monitoring point. All
inactive wells are used as piezometers to provide additional information on groundwater flow
characteristics at the site.
Figure 5 presents a cross-section showing well depths across the site with respect to
elevation.
Well MW-5 is the on-site water supply well and formerly known as the Trussell well and
briefly identified as well W-1. The DEQ Laboratory identified this well as MW-5 in their site
monitoring program.
2.1.3 Background Monitoring
Well MW-15 functions as the up-gradient background well for the site. However, during
temporary groundwater flow reversals that can occur during high river stage events, MW-15
become a down-gradient well. Wells MW-9a/b are located cross-gradient (with respect to
groundwater flow) of the landfill and historically have similar water quality concentrations as
well MW-15. The 1998 GQAR Update included a limited parameter statistical comparison of
wells MW-15 and MW-9a/b. This analysis found that use of wells MW-9a/b as supplemental
background water quality monitoring locations was not statistically supported. Given the
occurrence of groundwater flow reversals at the site, use of wells MW-9a/b as supplemental
background monitoring points may still be justified. However, recent aggregate mining
activities occurring just south of MW-9a/b, as discussed in Section 1.3.6, will likely cause
geochemical changes to occur at this well pair.
2.1.4 Network Adjustments
Since completion of the 1996 BI EMP, inactive monitoring wells MW-11a/b were abandoned
during September 1997 due to erosion of the river bank where they were located. Well group
MW-4a/b/c was discovered during construction of the new compost facility during 1999. The
MW-4 well nest was abandoned shortly afterward in August 1999.
As recommended in the 1998 GQAR Update, cross-gradient monitoring wells MW-13 and
MW-14 became inactive monitoring points following the spring 1998 event and two new
deep replacement monitoring wells MW-16 and MW-17 were installed in November 1998.
Inactive wells MW-13 and MW-14 are used as piezometers.
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The 1999 AWQMR presented a request to switch shallow well MW-10a with adjacent
inactive intermediate well MW-10c. The switch was requested due to shallow well MW-10a
not being able to provide water samples year around and yielding turbid samples when water
was available. The DEQ approved this request in a letter dated April 27, 2000.
2.1.5 Well Survey
All wells at the site were surveyed during February 2008 by the county. This survey updated
the 1998 completed by David Evans and Associates. The 2008 survey included determining
the vertical elevations of the water level measurement point (i.e., top of the well PVC) and
the top of the aluminum monument caps. Aluminum cap survey monuments were installed
next to each well location as part of the 1998 well survey. Elevations are in NAVD88 units
and northing/easting coordinates are NAD83 units. The 2008 survey top of the PVC water
level measurement point elevations are presented on Table 1.
2.2 GROUNDWATER QUALITY
This section presents a review of historic and recent groundwater quality data from the site.
Review of historical water quality data has indicated that groundwater quality conditions at
the site are seasonally variable. The concentrations of water quality parameters are typically
higher during the fall event and lower during the spring event. This seasonal variation of
groundwater quality is understood to be caused by Willamette River interaction with the
uppermost aquifer at the site. During the spring, the river stage is typically high as a result of
the wet winter season and spring runoff events, which effectively recharge the aquifer to
some extent. During the fall a low river stage has been established for several months in
response to dry summer conditions and as a result discharge to the river from the uppermost
aquifer has been established. Due to these conditions, groundwater quality conditions at the
site can vary substantially between spring and fall events, especially in wells located closest
to the river.
Groundwater quality samples at the site have been collected and analyzed on a semi-annual
basis since 1974. Table 2 identifies which wells at the site have been sampled 1974 to 2000.
Wells indicated as sampled in 2000 are the same wells sampled from 2001 thru 2012.
The following water quality standards are typically exceeded in groundwater samples
collected from the site monitoring well network:
•
OAR 340-80 Table 3 Guidance Levels or the EPA secondary drinking water
standards associated with manganese, iron, and total dissolved solids (TDS). These
aesthetic based standards have been exceeded at the site the past four years (2009
through 2013) typically occurring at the following locations: TDS (wells MW-8a/b/c
and MW-12a/b), manganese (all wells except MW-9b and MW-15), and iron (all
wells except MW-8a/c, MW-9a/b, and MW-15).
•
Nitrate has been detected several times in shallow well MW-9b and almost
consistently in fall event samples from MW-8s above the OAR 340-80 Table 1
Reference Level, EPA primary drinking water standard associated with nitrate. The
PSCL for nitrate, equal to the Primary Drinking Water Standard for nitrate, is also
exceeded.
The exceedance of manganese, iron, and TDS Guidance Levels has been reported in past
annual environmental monitoring reports.
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The exceedance of nitrate Reference Level and PSCL at well MW-8a has been previously
reported. The source of nitrate being detected at MW-8a was investigated as reported in the
2007 and 2008 BI AWQMR. Appendix E contains activities and findings presented in these
two reports. As noted in the 2012 AWQMR, nitrate is regularly detected above its primary
standard at well MW-8a in fall event samples (14 times in the past 16 years). Elevated nitrate
concentrations have also been observed in up-gradient well MW-15 and in cross-gradient
wells MW-9a/b. In a July 17, 2009 letter, the DEQ concluded that nitrogen compounds do not
appear to be adversely affecting the beneficial uses of groundwater.
2.2.1 GQAR Findings
The March 28, 1996, GQAR presented an analysis of groundwater quality data collected from
the monitoring well network for the period of April 1985 to March 1995. This time period
was selected to evaluate the change in groundwater quality characteristics at the site since
closure occurred in 1986.
The 1996 GQAR noted that some landfill indicator parameters are higher in wells downgradient (north and northeast) of the landfill than in background well MW-15, including:
specific conductance, alkalinity, hardness, dissolved iron, dissolved manganese, sulfate,
chemical oxygen demand (COD), and total organic carbon (TOC). Wells that were identified
as having elevated indicator parameters were MW-8a/b/c, MW-10a/b/c, and MW-12a/b. The
GQAR noted that some downward trends are apparent on the time-series plots for some of the
parameters in these down-gradient wells, suggesting that closure activities are beginning to
reduce leachate generation and subsequent groundwater quality impacts. In the DEQ's letter
review of the GQAR, the current and/or past exceedances of water quality standards were
identified as; TDS, iron, manganese, sulfate, total coliform, total cadmium, and total lead at
the compliance boundary.
2.2.2 GQAR Update Findings
The GQAR Update presented a non-parametric trend analysis (Sen’s slope estimator) used to
determine whether the concentrations of six indicator parameters (alkalinity, specific
conductance, COD, manganese, chloride, and sulfate) were increasing, decreasing, or
remaining the same at both active and inactive well locations. Analysis completed on the
active wells found that:
1. Upward trends were occurring primarily at down-gradient well MW-12b, to a lesser
extent at shallow well MW-12a; and at background well MW-15 with the exception of
chemical oxygen demand (COD) (no change) and manganese (down-ward).
2. Downward trends were occurring primarily in down-gradient wells MW-8a/b/c with the
exception of sulfate and at well MW-5 (former Trussell supply well) also with the
exception of sulfate.
An explanation for the observed upward trends at wells MW-12a/b and downward trends at
wells MW-8a/b/c was that:
1. The more westerly wells MW-12a/b are detecting impacts from the more recent use of
the western landfill area;
2. The more easterly wells MW-8a/b/c are detecting impacts from the older eastern landfill
area.
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2.2.3 Annual Monitoring Report Findings
Recent annual water quality monitoring reports for BI have noted the following groundwater
quality conditions at the site.
•
Examination of recent trends generally indicates site-wide stable or declining
concentrations. Wells MW-12b, and to a lesser extent MW-10c, appear to be showing
an overall upward trend while wells MW-8b, MW-12a, MW-16, and MW-17 appear
to be showing an overall downward trend. The remaining wells are showing either an
overall stable trend or no clear overall upward or downward trend.
•
Wells MW-8c, MW-10b/c, MW-12a/b, and MW-17 show the greatest indications of
water quality impact. These wells are located between the landfill and the river.
Some of the highest parameter concentrations are being detected at wells MW-12a/b
followed by wells MW-17 and MW-8c. A sustained decreasing concentration trend is
occurring at well MW-8c. In general, the greatest impacts are observed in wells
completed near the base of the uppermost aquifer down-gradient of the landfill.
•
Observed groundwater quality impacts at the site are primary in the form of ions;
specifically calcium, magnesium, bicarbonate, and to a lesser extent chloride, sulfate,
iron, and manganese. The highest trace metal concentrations are generally observed
at locations where high ion concentrations are also observed (wells MW-8a/b/c,
MW-10c, and MW-12a/b).
•
Recent trace metals results indicate that four (barium, cobalt, nickel, and arsenic) of
the nine metals analyzed were detected above the reporting limit in more than 50
percent of the monitoring wells sampled. Selenium and silver were not detected and
cadmium was detected in one sample at the reporting limit. The detection frequency
of chromium and lead was less than 40 percent. Trace metals were most commonly
detected in well MW-9a and MW-10b followed by wells MW-8c, MW-12a/b, and
MW-17. The highest concentrations were detected at wells MW-12a/b followed by
wells MW-8b and MW-10b. Examination of trends for the four higher frequency
detected trace metals found an overall declining concentration trend. Notable
concentration increases recently observed in well MW-9a may be related to the
recent excavation associated with aggregate mining occurring up-gradient of the well.
•
The deep wells (MW-8c, MW-10b, MW-12b, and MW-17) are showing the greatest
water quality impacts. The shallower portion of the uppermost aquifer has the
greatest water quality changes due to apparent river recharge/discharge interaction.
Groundwater quality impacts at the BI site are being observed primarily at down-gradient
well groups MW-12, MW-10, and MW-8. More limited data is available for newer wells
MW-16 and MW-17. Concentrations at well MW-16 are generally lower than at well
MW-17. These two newer wells were installed to further delineate and characterize the
groundwater quality impacts occurring north of the landfill.
2.2.4 Organic Constituent Detections
A review of historical data indicates that volatile organic constituents (VOCs) have been
detected at several wells at the site.
VOCs have historically been detected at the following well locations:
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Location
Historic Volatile Organic Compound Detections
MW-8a
Toluene 0.0018 mg/l (10/20/93), 0.00561 mg/l (9/2/98).
MW-8b
Toluene 0.0010 mg/l (10/20/93), xylenes 0.0015 mg/l (10/20/93).
MW-10a
Chlorobenzene 0.0026 mg/l (10/20/93)
MW-12a
Chlorobenzene 0.001 mg/l (10/4/89), 0.0015 mg/l (10/20/93), 0.008 mg/l
(10/13/96); 1,4-dichlorobenzene 0.001 mg/l (10/4/89), 0.0025 mg/l
(10/20/93), 0.00138 mg/l (9/2/98); 1,3-dichlorobenzene 0.008 mg/l (9/6/90);
metyhlene methylene chloride 0.011 (10/13/96)
MW-12b
Chlorobenzene 0.001 mg/l (10/4/89), 0.0009 (10/20/93), 0.0009 mg/l
(10/13/96), 0.00211 mg/l (9/13/00); 1,4-dichlorobenzene 0.001 mg/l
(10/4/89), 0.0007 mg/l (10/20/93), 0.0006 mg/l (10/13/96), 0.00149; 1,3dichlorobenzene 0.001 mg/l (9/6/90)
MW-13
Methylene Chloride 0.017 mg/l (10/13/96)
MW-17
1,4-dichlorobenzene 0.00073 mg/l (9/13/00)
Methylene chloride detected in the fall 1996 samples from wells MW-12a and MW-13 was
noted in the laboratory analytical report as a possible laboratory contaminant. The tentatively
identified compound (TIC) tetrahydrofuran has been detected in well MW-12b in samples
collected on 9/2/98 (0.00388 mg/l) and on 9/6/00 (0.0024 mg/l). VOCs have historically
been detected in wells MW-12a/b and MW-8a/b. More recent sampling found that the
1,4-dichlorobenzene detected in wells MW-12a/b is also present in well MW-17.
More recent analysis for VOCs was completed during the fall 2010 and fall 2012 monitoring
events. The results of these analyses are presented in the BI 2010 and 2012 Annual Water
Quality Monitoring Reports. Chlorobenzene is typically detected at low concentrations at
wells MW-8b and MW-12a/b. Toluene is typically detected at a low concentration at well
MW-8a. The compound 1,4-dichlorobenze, which historically was being detected at a
decreasing number of locations over time, was not detected in during the fall 2012 event. The
greatest number of VOCs (including tentatively identified compounds [TICs]) tends to be
detected in the samples from wells MW-12a/b.
Analysis of semi-volatile organic compounds (semi-vols), by EPA Method 8270, was
completed on a bi-annual basis from 1996 to 2004. During this period, semi-vols had
historically been detected at the following well locations.
Location
Historic Semi-Volatile Organic Compound Detections
MW-8a
Di-n-octylphthalate 0.006 mg/l (10/13/96); bis(2-ethylhexyl)phthalate
0.0152 mg/l (9/2/98)
MW-8b
Di-n-octylphthalate 0.006 mg/l (10/13/96)
MW-8c
Di-n-octylphthalate 0.0091 mg/l (10/13/96)
MW-9a
Di-n-octylphthalate 0.007 mg/l (10/13/96)
MW-9b
Bis(2-ethylhexyl)phthalate 0.0162 mg/l (9/6/00)
MW-12a
Chlorobenzene 0.008 mg/l (10/13/96); di-n-octylphthalate 0.007 mg/l
(10/13/96)
MW-12b
Bis(2-ethylhexyl)phthalate 0.0257 mg/l (9/2/98)
MW-14
Bis(2-ethylhexyl)adipate 0.011 mg/l (10/13/96), di-n-octylphthalate 0.012
mg/l (10/13/96),
MW-15
bis(2-ethylhexyl)adipate 0.003 mg/l (10/13/96), di-n-octylphthalate 0.006
mg/l (10/13/96)
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During the fall 1998 sampling event, bis(2-ethylhexyl)phthalate was detected at wells MW-8a
and MW-12b. Bis(2-ethylhexyl)phthalate is a synonym for dioctyl phthalate (and chemically
similar to di-n-octylphthalate), which is used as a plasticizer and may represent possible
laboratory contamination (i.e., tubing) or degradation of the PVC well casing. Bis(2ethylhexyl)phthalate was also detected by the DEQ Laboratory in every sample that they
collected from the site during the fall 1998 split sampling event including their transfer and
transport blanks. The DEQ did not collect a sample from well MW-9b during that event.
During the fall 2000 sampling event, several unknown compounds were detected primarily in
well MW-12a. The laboratory reported the TICs as unknown compounds because poor
correlation existed with associating them to any specific compound names. Further
examination of the above unknown TICs by the laboratory identified them as long-chain
hydrocarbons from a non-petroleum source. There were also several more peaks present but
at levels below the mrl. In essence the semi-vol TIC detections may represent breakdown
products of potentially naturally occurring long-chain hydrocarbon compounds.
None of the VOCs or semi-vols detected at the site has exceeded a DEQ Numerical
Groundwater Standard or an EPA Primary Drinking Water Quality Standard.
2.2.5 River Water Quality
The 1998 GQAR Update included an analysis of groundwater discharge into the Willamette
River. Groundwater discharge rates into the river were found to be negligible (less than one
gallon per day) due to equilibrium conditions that exist between the surface water and the
river alluvium deposit groundwater system. The results of the June 1999 slug test further
supported the 1998 analysis conclusions.
An estimate of chemical loading to the river was also examined in the GQAR Update using
the principle of mass balance. This analysis indicated that when considering worst-case
conditions (low river stage, high groundwater discharge rate), no measurable increase in the
water quality parameters is observed down river of the landfill. This is due to the high river
flow volume compared with the rate of groundwater discharged from the site.
In an attempt to confirm the chemical loading analysis findings, samples of the river up and
down-stream of the site were collected during the fall 2000 event river when river stage
conditions are lowest and groundwater discharge to the river is greatest. Examination of the
results of fall 2000 river samples indicate that the concentration of the various parameters
analyzed are similar at the two locations sampled. The most notable difference were bacteria
results where the up-stream river sample location had higher reported enterococcus and total
coliform concentrations. Fecal coliform concentrations were similar. The detected
concentrations of site-specific parameters such a bicarbonate, chloride, iron, magnesium, and
sulfate at the two river sample locations were either the same or very similar. The calcium
concentration at the up-stream location was slightly higher than the down-stream sample
location. However, the up-stream sample concentration was qualified as an estimated value.
The detected total alkalinity concentration was slightly higher in the down-river sample
compared with the up-river sample. The field conductivity readings were slightly higher at
the down river location whereas the laboratory conductivity reading was slightly higher in the
up-stream sample.
The results of the fall event sampling of the Willamette River are consistent with the results
of the groundwater discharge analysis presented in the BI GQAR Update. In a letter dated
March 30, 2001, the DEQ indicated that while the up-stream and down-stream concentrations
of inorganic parameter tends to support the no notable difference observation, the estimated
values for the bacteria results (their hold times were exceeded) cannot be used as conclusive
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evidence that groundwater discharge from the site has resulted in no notable impact to the
river.
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3.
GROUNDWATER MONITORING PLAN
The existing groundwater quality monitoring network at the site consists of 13 groundwater
monitoring wells as described in Section 2.1. Historic and recent groundwater conditions at
the site were presented in Section 2.2. Based on the information presented in Section 2, a plan
for the continued use of these monitoring wells for groundwater quality compliance sampling
is presented in this section. The existing site groundwater quality database is described along
with procedures that will be used to analyze, review, and report water quality results.
Attachment A presents a Sampling and Analysis Plan (SAP) which provides information to
guide the collection and analysis of groundwater quality samples at the BI site. The SAP
describes the procedures recommended for preparing, obtaining, documenting, preserving,
and shipping water quality samples collected at the BI. The SAP establishes Quality
Assurance/Quality Control (QA/QC) requirements for sample acquisition and handling at the
site.
3.1 GROUNDWATER QUALITY MONITORING POINTS
Table 1 identifies the 13 active monitoring wells that will serve as the groundwater quality
monitoring network for the site. As shown on Figure 2, wells MW-8a/b/c, MW-12a/b, MW16, and MW-17 are down-gradient compliance boundary wells. Wells MW-9a/b and inactive
wells MW-13 and MW-14 are also located on the compliance boundary shown on Figure 2.
Potentiometric maps and water quality data indicate that wells MW-9a/b are cross-gradient
wells. Potentiometric maps have indicated that wells MW-13 and MW-14 appear to be
recharged from the adjacent east slough. The 13 inactive wells will be used as piezometers.
Water levels are collected from all 26 wells and used to develop potentiometric maps for the
site.
All 13 active wells are capable of yielding representative groundwater quality samples from
the uppermost aquifer beneath the site. The wells were evaluated for suitability and upgraded
in 1997 (see Appendix E). The security casing of each well consists of steel casing with a
lock protected access cap. Each well is equipped with a dedicated bladder sampling pump
that has been in uses since the fall 2008 event. Dedicated sampling pumps were installed in
the 12 active monitoring wells to limit the potential for cross-contamination while increasing
sample collection efficiency and representativeness. Prior to the fall 2008 event, the
monitoring wells were purged and sampled using a dedicated PVC bailer stored (suspended)
in each active well. An exception is sample point MW-5, which is a supply well that is
sampled from a tap. All well locations are currently accessible by vehicles using gravel and
dirt roads or trails.
Section 13.2 of the closure permit indicates that the County shall protect and maintain each
groundwater or surface water monitoring well or device so that sample representative of
actual conditions can be collected. Any damage discovered shall be reported to the DEQ in
writing within 14 days of the discovery, along with a description of the proposed repair or
replacement measures and time schedule for completion of repair work. All monitoring well
repairs, abandonments, replacements and installations must be documented in a report
prepared by an Oregon registered geologist and must be submitted to the DEQ within 30 days
of the action and included in the next annual environmental monitoring report.
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3.2 MONITORING SCHEDULE
Section 10.4 of the BI closure permit identifies a semi-annual sampling schedule for
environmental monitoring at the site in accordance with the approved EMP. The following
compliance sample event periods are identified in the closure permit:
•
Spring – March 1st through May 31st.
•
Fall – September 1st through October 31st.
During the spring and fall compliance periods, groundwater quality sampling will be
completed on the 13 active monitoring wells as identified on Table 3. Table 3 identifies the
analytes to be sampled, the sampling frequency and schedule. Table 4 identifies the analytes
or parameter included in each parameter group listed in Table 3.
As indicated on Table 3, analysis of BI Permit Parameters is completed every two years on
even years during fall events (i.e., fall 2014, fall 2016). With the exception of the even year
fall events, analysis of BI Indicator Parameters is completed. Table 4 identifies the analytes
and parameters associated BI Permit Parameters and BI Indicator Parameters. BI Indicator
Parameters were applied beginning with the fall 2011 event.
Water level measurement events from all monitoring wells at the site will also be completed
during a semi-annual monitoring.
3.3 COMPLIANCE BOUNDARY AND CONCENTRATION LIMITS
Permit-specific concentration limits (PSCLs) proposed on October 24, 2003 were approved
by the DEQ in a letter dated May 5, 2005. The following PSCLs have been established for the
BI site.
Contaminant
Concentration Limit
Arsenic
0.05 mg/l
Barium
1.0 mg/l
Cadmium
0.0163 mg/l
Chromium
0.0469 mg/l
Lead
0.05 mg/l
Nitrate-N
10.0 mg/l
Selenium
0.01 mg/l
Silver
0.0140 mg/l
The above PSCLs are based on Groundwater Quality Protection Reference Levels (OAR 34040 Table 1) or a site-specific derived concentration. The 1996 BI EMP identified compliance
boundary for the site is shown on Figure 2. The GQAR Update indicated that trend analysis
using time series plots and Sen’s slope estimator (Gilbert 1987) would be used to periodically
to assess the trends in compliance well concentrations.
3.4 REVIEW OF GROUNDWATER QUALITY RESULTS
The existing BI groundwater quality database is in Microsoft Access format and includes
groundwater quality data, dating back to April 1985. As new site water quality data is
obtained, electronic data deliverables (EDDs) from the laboratory are directly uploaded into
the database. This database update methodology increases data transfer efficiency and
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reduces data entry errors. Templates and queries have been developed that can provide
various types of data reports and formats.
The analysis and evaluation of water quality data collected from BI is completed in the
following manner. A review of field and laboratory data is initially completed, upon receipt
of the data from the laboratory, to identify and address data that: 1) did not meet QA/QC
control objectives, 2) represents a significant change in water quality, or 3) exceeds a primary
groundwater, drinking water quality standard, or a PSCL.
3.4.1 Routine Event Data Review Action Criteria
Section 11.4 of the closure permit indicates that if there is a significant change in water
quality, then the County shall notify the DEQ within 10 days of the receipt of the laboratory
data. Dependent upon the data review findings, a resampling event may be required as
described in this section.
The following actions shall be taken based on this data review:
•
Data indicates there is no significant change (below primary numerical groundwater
reference levels, primary drinking water quality standards, or PSCLs: → continue
groundwater monitoring with next scheduled event.
•
Data indicates a significant change in water quality at any monitoring point: → notify
the DEQ within 10 days of receipt of laboratory results and perform resampling
within 15 days.
•
Data is above a PSCL: → notify the DEQ within 10 days of receipt of laboratory
results and perform resampling within 15 days.
Note if this is a known release previously confirmed to the DEQ in writing, then resampling
is not required.
Examples of a significant change in water quality include:
•
Detection of a volatile organic constituent (VOC) or other hazardous constituent not
detected in the background monitoring point (well MW-15) and previously not
reported.
•
Exceedance of a Table 1 value listed in OAR 340-40-020 unless the background
monitoring point (well MW-15) is above these numerical limits and the exceedance
has previously been reported.
•
Exceedance of a primary EPA Primary Drinking Water Standard that has previously
not been reported.
Note that established permit specific concentration limits and compliance points are listed in
Section 3.3.
3.4.2 Resampling Event Data Review Action Criteria
As indicated in Section 11.5 of the closure permit, in the case where a routine data review
indicates that a resampling event needs to be completed, the data from the resampling event
shall be reviewed upon receipt and responded to in the following manner:
•
If the resampling results do not confirm the routine results, then:
1. Continue with routine monitoring.
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2. Discuss the data from the routine sampling event and the resampling event in the
next Annual Water Quality Monitoring Report.
•
If the resampling results confirm that a significant change in water quality has
occurred, as noted in the routine results:
1. Notify the DEQ within 10 days of receipt of the laboratory data or within 60 days
of the sample date (whichever occurs first).
2. Submit a plan within 30 days (unless another time period is authorized) for
developing an assessment program with the DEQ.
3.5 DATA ANALYSIS AND EVALUATION
This section describes procedures that will be used to evaluate data quality (data QA/QC) and
data analysis using statistical methods.
3.5.1 Data QA/QC
A QA/QC review will be completed for each sampling event and will be summarized in a
QA/QC summary report that will accompany all data presentation reports. The QA/QC
summary report will present the following information: project and sample information; a
quality assurance summary; a review of analytical methods and holding times; and a review
of laboratory and field quality control samples. Data exclusions from statistical consideration
and/or analysis will be identified based on the QA/QC review. Data presentation reports (i.e.,
Annual Water Quality Monitoring Reports) will also include a review of field activities or
observations that may have had an influence on the representativeness of water quality data
collected from the site.
3.5.2 Data Presentation and Analysis
Water quality data from the site will be tabulated by sample location and parameter. The
summary data tables will be organized in a manner consistent with the parameter groups
listed on Table 4. Each table will present chemical data for that parameter for each
monitoring point in chronological order (i.e., for each sample point the most recent data is
presented on the bottom row). Tables organized in this manner facilitate the review and
statistical analysis of data.
The following formats will be used to present data collected from the BI site, including:
potentiometric contour maps, time series plots, trilinear plots, and Stiff diagrams. Note that
analysis of BI Indicator Parameters does not allow for development of trilinear plots or Stiff
diagrams.
The Sen’s slope estimator has been used in the past to evaluate trends in the compliance well
data as noted in Section 2.2.2 and represents an accepted DEQ statistics method. EPA’s
March 2009 Statistical analysis of Groundwater Monitoring Data at RCRA Facilities Unified
Guidance is now considered to provide current recommended and approved statistical
analysis methodologies. For trend tests, the Unified Guidance identifies three primary
methods: (1) linear regression be used to identify a linear trend and estimate its maganitude;
(2) Mann-Kendall test provides a method for identifying trends; and (3) the Theil-Sen trend
line method can be used to gauge trend of magnitude.
As noted in Section 2.2, groundwater concentrations at BI vary notably over time due
seasonal variability and in response to other geochemical changes. As a consequence, time
series plots for BI show a lot of variability in groundwater quality data over time. Some of
March 18, 2013 │ 275-2063-007
3-
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
this variability is seasonal while some variability does not appear to be seasonally related.
The variability at a given well is not necessarily consistent for all parameters or locations or
at similar locations but different depths. For example, a well could show a notable
concentration increase of ammonia and total dissolved solids while showing, at the same
time, a notable decrease in sodium and potassium. An adjacent well screened slightly deeper
may show different conditions. The extent of data variability at the site can make it difficult
to characterize whether a given parameter is actually increasing or decreasing over time.
In response to the presence of notably variable groundwater concentration conditions, review
of BI time series plots has consisted of examining short-term plots, consisting of 5 years of
most recent data [10 sample data sets], along with review of long-term plots (consisting up to
more than 25 years of data) to provide context for the short-term plots. A best fit line using
linear regression is applied to the 10 sample data set and used to assist in examining the
overall recent linear trend of the data.
As needed, summary statistics can also be completed including: sample size, average,
median, standard deviation, interquartile range, standardized skewness, standardized kurtosis,
and interquartile range of parameter detections. All nondetects will be replaced with a value
that is 1/2 of the reported method detection limit (MDL). The summary statistics will be
computed using either Microsoft Excel, an Excel statistics add-on package such as Analyzsit, Statgraphics, or a comparable statistical software package.
Data evaluation will also include a comprehensive comparison of groundwater quality sample
results to the following applicable water quality standard and site-specific concentration
limits:
•
State of Oregon Numerical Groundwater Quality Reference and Guidance Levels
(OAR 340-40-020 Tables 1 through 3).
•
EPA National Primary Drinking Water Regulations.
•
Permit Specific Concentration Limits listed in Section 3.3.
These water quality standards are presented on Table 4.
3.6 REPORTING
Reporting of environmental data includes the submittal of Annual Water Quality Monitoring
Reports and the results of split-sampling events. These reporting requirements are addressed
in this section.
3.6.1 Annual Water Quality Monitoring Report
As indicated in Section 12.2 of the closure permit, an Annual Water Quality Monitoring
Report (AWQMR) is to be submitted prior to March 15th of each calendar year for the
duration of the closure permit. The AWQMR will address environmental monitoring
activities, results, and findings from the previous year. Whenever possible, the report needs
to be completed as a two-sided document. To reduce physical size of the report and reduce
paper usage, report appendices can be presented as electronic files contained on a compact
disc attached to the report’s back inside cover page. Two copies of the report, stamped by an
Oregon registered geologist or engineering geologist, are to be submitted to the DEQ.
The AWQMR is to include a statement of compliance, a one-page cover letter that presents a
concise comparison of the analytical results with the monitoring standards identified above in
Section 3.5.2. Specifically, the statement of compliance letter will:
3-
March 18, 2013 │ 275-2063-007
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
•
Compare the analytical results with the relevant monitoring standards (PSCLs).
•
State whether or not federal or state standards were exceeded for the relevant media.
•
State whether or not a significant change in water quality has occurred.
Examples of significant change in water quality are provided in Section 3.4.1.
As indicated in Section 12.4 of the closure permit, the AWQMR needs to include the
following information:
•
An executive summary.
•
Site background and recent site activity information.
•
A summary presentation of all environmental monitoring performed during the past
year.
•
A summary presentation of data validity (i.e., review of holding times, comparison of
blanks and duplicates, major cation/anion balance for each groundwater sample
collected, identification of data problems or discrepancies, field QA/QC issues, and
laboratory compliance with QA/QC standards) and identification of data problems.
•
Summary tables of all analytical results by sampling location organized by the
parameter groups as described in Section 3.5.2.
•
Itemization of any activities resulting from the exceedance of a relevant standard or
significant change in water quality. Examples include resampling events, submittal
of a Preliminary Assessment or an Assessment Monitoring Report.
•
Presentation of water level data and groundwater flow direction using contour maps,
tables, and graphs.
•
Updated time-series plots and other completed statistical analysis as described in
Section 3.5.2.
•
Copies of all field data sheets, laboratory analytical reports, and chain-of-custody
documents completed for the year being reported.
•
Copies of all monitoring well repairs, abandonments, replacements, and installations
that occurred at the site during the reported year.
•
A summary of new or proposed activities at the site.
Note that application of the BI Indicator Parameters does not allow for completion of
cation/anion balances or the generation of Stiff and Piper diagrams.
Copies of the AWQMR are to be submitted to the following address:
Oregon Department of Environmental Quality
Manager – Western Region Solid Waste Program
750 Front Street NE, Suite 120
Salem, Oregon 97301-1039
3.6.2 DEQ Laboratory Split Sampling Report
The BI closure permit does not contain specifies split sampling event dates but indicates in
Section 10.3 that spit sampling with DEQ shall occur when requested. If requested,
scheduling the event with the DEQ Lab must occur at least 45 days prior to the sampling
event.
March 18, 2013 │ 275-2063-007
3-
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
In the event of a DEQ split sampling event, the following information will be submitted to the
DEQ laboratory, located in Portland, Oregon, within 90 days of the split-sampling event:
•
Copy of all information pertinent to the sample collection, handling, transport and
storage, including field notes.
•
Site map showing groundwater flow directions and contours.
•
Copies of all laboratory analytical data, QA/QC reports, and any additional data
specifically requested by the DEQ laboratory.
The address for the DEQ laboratory is:
Oregon Department of Environmental Quality
Laboratory Division, Groundwater Monitoring Section
3150 NE 229th Avenue, Suite 150
Hillsboro, Oregon 97124
(503) 693-5700
3.7 REDUCTION IN MONITORING
The County may petition for a reduction in the sampling frequency, a reduction in the number
of locations to be sampled, or the elimination of selected monitoring parameters for the site
environment monitoring program. A demonstration would need to be presented to the DEQ’s
satisfaction that, for each monitoring point or parameter in consideration, sufficient samples
have been analyzed to allow for adequate assessment of the data. Adequate justification for
all proposed reductions in sampling frequency and parameters will need to be provided to the
DEQ.
3-
March 18, 2013 │ 275-2063-007
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
4.
REFERENCES
American Society for Testing and Materials (ASTM) 1996, Provisional Standard Guide for
Developing Appropriate Statistical Approaches for Ground-Water Detection Monitoring
Programs. ASTM PS 64-96.
Bela, James L. 1981. Geology of the Rickreall, Salem West, Monmouth, and Sidney 7½’
Quadrangles, Marion, Polk, and Linn Counties, Oregon. Issue by State of Oregon
Department of Geology and Mineral Industries, Geological Map Series GMS-18.
Foxworthy, B.L. 1970. Hydrologic Conditions and Artificial Recharge through a well in the
Salem Heights Area of Salem, Oregon: U.S. Geological Survey Water-Supply Paper
1594-F.
Oregon Department of Environmental Quality (DEQ). 1996. Solid Waste Guidance
Municipal
Solid
Waste
Landfills;
September
1,
1996.
Updated versions of the guidance document is presented on the DEQ’s homepage
(www.deq.state.or.us/wmc/solwaste/swguide/) can also be referenced.
Parametrix, Inc. 1996. Environmental Monitoring Plan, Brown’s Island Landfill; prepared for
Marion County Department of Solid Waste Management, April 19, 1996.
Parametrix, Inc. 1996. Groundwater Quality Assessment Report, Brown’s Island Landfill;
prepared for Marion County Department of Solid Waste Management, March 28, 1996.
Parametrix, Inc. 1997a. Monitoring Well Evaluation Plan, Brown’s Island Landfill; prepared
for Marion County Department of Solid Waste Management, June 16, 1997.
Parametrix, Inc. 1997b. Monitoring Well Upgrade Report, Brown’s Island Landfill; prepared
for Marion County Department of Solid Waste Management, December 8, 1997.
Parametrix, Inc. 1998. Groundwater Quality Assessment Report Update, Brown’s Island
Landfill; prepared for Marion County Department of Solid Waste Management, April 13,
1998.
Parametrix, Inc. 2001. Environmental Monitoring Plan, Brown’s Island Landfill; prepared for
Marion County Department of Solid Waste Management, April 26, 2001 update.
Sweet, Edwards & Associates, Inc. 1987. Brown’s Island Landfill, Proposed Waste Boundary
Adjustment and Post-Closure Monitoring. Unpublished report prepared for Marion
County.
U.S Environmental Protection Agency (EPA). 2009. Statistical Analysis of Groundwater
Monitoring Data at RCRA Facilities, Unified Guidance, Office of Resource Conservation
and Recovery. EPA 530-R-09-007. March 2009. U.S. Environmental Protection Agency,
Washington D.C.
March 18, 2013 │ 275-2063-007
4-
Environmental Monitoring Plan
Browns Island Landfill
Marion County
Marion County Department of Public Works
U.S Environmental Protection Agency (EPA). 1993. Solid Waste Disposal Facility Criteria,
Technical Manual. EPA 530-R-93-017. U.S. Environmental Protection Agency,
Washington D.C.
U.S. Environmental Protection Agency (EPA). 1992. Statistical Analysis of Ground-Water
Monitoring Data at RCRA Facilities. Addendum to Interim Final Guidance. Office of
Solid Waste, Permits and State Programs Division, U.S. EPA, Washington, D.C.
U.S Environmental Protection Agency (EPA). 1989. Statistical Analysis of Ground-Water
Monitoring Data at RCRA Facilities. Interim Final Guidance. Office of Solid Waste,
Waste Management Division, U.S. EPA, Washington, D.C. EPA/530-SW-89-026.
U.S Environmental Protection Agency (EPA). 1986. Test methods for evaluating solid waste,
3rd edition, update III. U.S. Environmental Protection Agency. Washington, D.C.
Woodward, D.G, Gannett, M. W., and Vaccaro, J.J. 1998. Hydrogeologic Framework of the
Willamette Lowland Aquifer System, Oregon and Washington. Regional Aquifer-System
Analysis – Puget-Willamette Lowland. U.S. Geological Survey Professional Paper
1424-B.
4-2
March 18, 2013 │ 275-2063-007
Site Location
DATE: March 1, 2011 FILE: BrownIsland_SiteLocation.mxd
0
´
0.5
Miles
Figure 1
Site Location
1
Annual Water Quality
Monitoring Report
Brown's Island Landfill
DATE: Oct 19, 2012
0
400'
SCALE IN FEET
FILE: PO2063007F-91
Figure 2
Facility Map
Annual Water Quality Monitoring Report
BROWN'S ISLAND LANFILL
MARION COUNTY, OREGON
Fa rm Fi eld
MW-16
W
IL
.
!
E
E oo ll aa B
B ee nn dd
C
C oo uu nn tt yy P
P aa rr kk
. MW-9a/b
!
.
MW-12a/b !
L
A
M
E T
T E
! MW-10a/b/c
.
. MW-17
!
Ag gre g at e Q u arry
Future
Aggregate
Extraction
Area
RI
VE
R
!
. MW-8a/b/c
. MW-13
!
MW-6a/b/c !
.
Fa rm Fi eld
Fa rm Fi eld
.
!
Fa rm Fi eld
MW-5
!
. MW-7a/b
Fa rm Fi eld
. MW-2a/b
!
. MW-1a/b/c
!
MW-14
. MW-15
!
.
!
.
!
East Slough
Fa rm Fi eld
M
M ii nn tt oo -- B
B rr oo w
w nn II ss ll aa nn dd
C
C ii tt yy P
P aa rr kk
Fa rm Fi eld
.
!
South Slough
(Entrance Slough)
Sale m Go l f Clu b
Fa rm Fi eld
Ho me st ead R o ad
Br o w n' s Is lan d
R .D . 5
Fa rm Fi eld
Go lf C o urs e
DATE: March 3, 2011 FILE: BrownIsland_AerialSiteMap.mxd
0
´
0.25
Miles
0.5
Site Location
.
!
Monitoring Well
Future Aggregate Extraction Area
.
!
Surface Water Elevation Monitoring Point
Recent Excavated Area
Park Boundary
Figure 3
Aerial Site Map
Annual Water Quality
Monitoring Report
Browns Island Landfill
SOUTH
NORTH
Figure 4
North/South Cross-Section
A
A'
Figure 5
Well Cross-Section A-A'
Environmental Monitoring Plan Update
Table 1: Monitoring Well Summary Data
Sampling and Analysis Plan
Browns Island Landfill
Active Monitoring Wells
Well ID
MW-5
MW-8a
MW-8b/c
MW-9a/b
MW-10b/c
MW-12a/b
MW-15
MW-16
MW-17
Date Installed Well Log
1/5/1969
10/16/1975
10/15/1975
3/76-7/79
3/76-7/79
3/76-7/79
10/31/1986
11/11/1998
11/10/1998
yes
yes
yes
no
no
no
yes
yes
yes
Construction Well Depth (from top
Type
of PVC - ft)
Top of PVC Casing
Elevation (ft)
Screen
Length (ft)
Screen interval (ft below top of
PVC)
supply
single
double
double
double
double
single
single
single
105
20.47
23.90/37.72
37.08/23.78
33.42/24.70
26.90/43.51
44.36
48.77
42.38
153.84
136.72
136.88/136.62
136.98/137.02
134.78/134.94
136.17/135.83
140.24
141.92
137.81
none
5
3/3
4.0/4.9
1.1/4.8
4.6/4.4
20
10
10
61-105
15.3 - 20.3
23-26/32-35
32.9-36.9/18.8-23.9
32.2-33.3/19.8-24.6
22.2-26.8/39.0-43.4
20-40
36/46
30/40
Construction
Type
Well Depth (ft)
Top of PVC Casing
Elevation (ft)
Screen
Length (ft)
Screen interval (ft below top of
PVC
triple
double
triple
single
single
single
single
single
40.67/47.17/51.33
41.75/57.5
33.3/43.33/54.3
22.0
34.3
14.32
43.55
28.25
151.75/152.01/152.16
158.63/158.68
151.89/151.89/151.90
141.36
141.90
134.78
135.31
128.85
2.5/2.5/2.5
2.5/2.5
5/5/4
5
5
4.8
20
5
38.2-40.6/44.7-47.1/48.8-51.3
39.2-41.7/55.0-57.5
28.3-33.3/38.3-43.3/50.3-54.3
15-20
30-35
9.4-14.2
21/41
21/26
Construction
Type
Well Depth (ft)
Date Abandoned
triple
double
40/48/62
15.08/21.31
7/29/99-8/2/99
9/8/1997
Inactive Monitoring Wells
Well ID
MW-1a/b/c
MW-2a/b
MW-6a/b/c
MW-7a
MW-7b
MW-10a
MW-13
MW-14
Date Installed Well Log
5/8-5/21/73
5/22-23/73
5/23-5/31/73
10/13/1973
10/8/1973
3/76-7/79
10/29/1986
10/30/1986
yes
yes
yes
yes
yes
no
yes
yes
Abandoned Monitoring Wells
Well ID
MW-4a/b/c
MW-11a/b
3/20/2013
Date Installed Well Log
4/16-5/7/73
3/76-7/79
yes
no
Table01_well data sum_2013.xlsx
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4/13/1976
X
X
X
5/24/1976
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6/23/1976
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
7/27/1976
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
9/23/1976
X
X
X
X
X
X
X
X
X
7/11/1977
X
X
3/6/1978
X
X
X
9/18/1978
X
X
X
X
5/21/1979
X
X
X
X
9/10/1979
X
X
X
X
10/7/1980
X
X
X
5/27/1981
X
X
X
7/7/1982
X
X
X
9/22/1982
X
X
5/11/1983
X
X
9/8/1983
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5/2/1984
X X X X X
10/31/1984 X X
X
4/17/1985 X X X X X
11/7/1985 X X X X X
6/3/1986
X X X X X
10/29/1986
12/30/1986
4/22/1987 X X X X X
11/12/1987 X X X
X
4/6/1988
9/7/1988
5/2/1989
10/4/1989
X
4/11/1990
4/12/1990
X
9/5/1990
X
9/6/1990
4/18/1991
X
10/8/1991
X
10/9/1991
5/13/1992
5/14/1992
X
6/4/1992
10/5/1992
10/6/1992
X
4/7/1993
4/8/1993
X
10/20/1993
X
4/11/1994
4/12/1994
X
9/13/1994
X
3/7/1995
X
3/27/1996
10/3/1996
X
5/22/1997
X
X
9/3/1997
5/28/1998
X
9/2/1998
X
5/26/1999
X
9/21/1999
X
5/31/2000
X
9/13/2000
X
NOTES: 9/13/94 data indentified as 9/12/94 data in Storet.
Former Trussel water supply well and Well 5 are the same well.
- Indicates related events
3/20/2013
X
X
X
X
X
X
X
X
X
X
X
X
X
X
QA Sample
X
X
X
River Down
X
X
X
X
Well 17
X
X
X
X
River Up
X
X
X
X
Well 16
X
X
X
X
Well 15
Well 12B
X
X
X
X
Well 14
Well 12A
X
X
X
X
Well 13
Well 11B
X
X
X
X
Well 11A
Well 10B
Well 10C
X
X
X
X
Well 9B
X
X
Well 10A
X
X
X
Well 9A
X
X
Well 8B
X
X
Well 8C
X
X
Well 8A
X
X
X
Well 7B
X
7/9/1975
9/9/1975
X
Well 7A
3/10/1975
X
Well 6B
X
X
Well 6C
X
X
Well 5
X
X
Well 6A
12/30/1974
X
Well 4B
X
X
Well 4C
X
X
X
Well 3
X
X
X
Well 4A
X
3/9/1976
Well 2B
Well 1B
Well 1C
5/2/1974
9/11/1974
WELL ID
Well 2A
Well 1A
TABLE 2: SAMPLE LOCATION SUMMARY - 1994 thru 2000
ENVIRONMENTAL MONITORING PLAN UPDATE
BROWNS ISLAND LANDFILL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Well 12A
Well 12B
Well 9B
Well 10C
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
SEA Data/No Dup.
Well 13A
Well 13A
Well 15A
Well 8B
Well 8A
Well 5
Well 15C
Well 5
Well 5
X
X
Well 5 & 15
Well 5
Well10B
Well 8B
Well 5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Well 9B
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Well 14B
Well 10B
Well 8A
Well 5
Well 5
Well 8C
Well 5
Well 15
Well 13A
Well 10B
Well 12A
Well 8C &10B
Well 9A &12A
Well 5 & 8C
Well 12A
Well 16
Well 5
X Well 10C
X Well 15
Table02_Well Sampling Location Summary.xlsx
TABLE 3: WATER QUALITY SAMPLE LOCATIONS, FREQUENCY, AND SCHEDULE
ENVIRONMENTAL MONITORING PLAN
BROWNS ISLAND LANDFILL
Locations
Analytes *
Alluvium wells:
Group 1a
Group 1b
Group 2a
Shallow: MW-8a.
Frequency
Schedule
Semi-annual
Spring and Fall
Bi-annual
Every two years in Fall
beginning in 2006
Semi-annual
Spring and Fall
Bi-annual
Every two years in Fall
beginning in 2006
Intermediate: MW-8b, MW-9b,
MW-10c, MW-12a, and MW-15.
Deep: MW-8c, MW-9a, MW-10b,
MW-12b, MW-16, and MW-17.
Group 2b
Group 3
Marine Sedimentary Rock
wells:
Group 1a
Group 1b
Group 2a
MW-5 (on-site supply well)
Group 2b
Group 3
Piezometers:
Water levels
MW-1a/b/c, MW-2a/b,
MW-6a/b/c, MW-7a/b, MW-10a,
MW-13, and MW-14.
Semi-annual: all
monitoring wells
Spring and Fall
NOTES:
* See Table 2, Water Quality Monitoring Parameters, for analytes/parameters included in each parameter
group. BI Indicator Parameter list is applied except during even year Fall events (i.e., Fall 2012, Fall
2014, etc.) when the BI Permit Parameter list is applied.
The semi-annual compliance monitoring periods are:
Spring:
March 1st through May 31st.
Fall:
September 1st through October 31st.
TABLE 4: WATER QUALITY MONITORING PARAMETERS
ENVIRONMENTAL MONITORING PLAN
BROWNS ISLAND LANDFILL
BI INDICATOR PARAMETERS
BI PERMIT PARAMETERS
GROUP 1a: FIELD INDICATOR PARAMETERS
ELEVATION OF WATER LEVEL
ELEVATION OF WATER LEVEL
pH
pH
TEMPERATURE
TEMPERATURE
SPECIFIC CONDUCTANCE
SPECIFIC CONDUCTANCE
DISSOLVED OXYGEN
DISSOLVED OXYGEN
REDOX POTENTIAL (Eh)
REDOX POTENTIAL (Eh)
GROUP 1b: LABORATORY INDICATOR PARAMETERS
HARDNESS (as CaCO3)
TOTAL ALKALINITY (as CaCO3)
TOTAL ALKALINITY (as CaCO3)
TOTAL DISSOLVED SOLIDS (TDS)
TOTAL SUSPENDED SOLIDS (TSS)
TOTAL DISSOLVED SOLIDS (TDS)
TOTAL SUSPENDED SOLIDS (TSS)
CHEMICAL OXYGEN DEMAND (COD)
TOTAL ORGANIC CARBON (TOC)
GROUP 2a: COMMON ANIONS AND CATIONS#
CALCIUM (Ca)
CALCIUM (Ca)
MAGNESIUM (Mg)
SODIUM (Na)
POTASSIUM (K)
IRON (Fe)
IRON (Fe)
MANGANESE (Mn)
MANGANESE (Mn)
AMMONIA-NITROGEN (NH3-N)
AMMONIA-NITROGEN (NH3-N)
BICARBONATE ALKALINITY (HCO3)
SULFATE (SO4)
SULFATE (SO4)
CHLORIDE (Cl)
NITRATE (NO3-N)
CHLORIDE (Cl)
NITRATE (NO3-N)
SILICA (Si)
GROUP 2b: TRACE METALS
ARSENIC (As)
BARIUM (Ba)
CADMIUM (Cd)
CHROMIUM (Cr)
COBALT (Co)
LEAD (Pb)
NICKEL (Ni)
SELENIUM (Se)
SILVER (Ag)
GROUP 3: VOLATILE ORGANIC CONSTITUENTS
VOLATILE ORGANIC CONSTITUENTS
METHOD REPORTING DEQ REFERENCE
LEVEL
LEVELSd
(mg/L)
(mg/L)
METHOD
METHOD
DESCRIPTION
FIELD
FIELD
FIELD
FIELD
FIELD
FIELD
Electric Probe
Reference Electrode Probe
Temperature Probe
Conductivity Probe
Metal Cathode Probe
Platinum Band Sensor Probe
6020a
ICP-MS
Titrimetric
Gravimetric
Gravimetric
Spectrophotometric
UV, Persulfate Oxidation-IR
2.00
10.0
10.0
10.0
5.00
1.00
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
Electrode
Titrimetric
Ion Chromotography
0.050
0.002
1.00
1.00
0.0250
0.00200
0.100
10.0
1.00
b
310.1
b
160.1
160.1b
410.4b
b
415.1
200.7b
200.7b
200.7b
200.7b
200.7b
200.7b
b
350.3
310.1b
b
Ion Chromotography
Ion Chromotography
0.500
0.100
Spectrophotometric Reduction
0.250
6020a
6020a
6020a
6020a
6020a
6020a
6020a
6020a
6020a
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
ICP-MS
0.00100
0.00100
0.00100
0.00200
0.00100
0.00100
0.00200
0.00100
0.00100
8260a
Gas Chromotography/Mass Spect
0.50-1.0 ug/L
DISSOLVED CONCENTRATIONS. SAMPLES MUST BE FIELD-FILTERED.
a
TEST METHODS FOR EVALUATING SOLID WASTE - PHYSICAL/CHEMICAL METHODS. 3rd edition. EPA SW-846 (November 1990).
b
METHODS FOR CHEMICAL ANALYSIS OF WATER AND WASTES. EPA-600/4-79-020 (revised March 1983).
d
DEQ NUMERICAL GROUNDWATER QUALITY REFERENCE LEVELS (HEALTH BASED). OAR 340-040-080 (January 1990).
e
DEQ NUMERICAL GROUNDWATER QUALITY GUIDANCE LEVELS (NONHEALTH BASED). OAR 340-040-080 (January 1990).
f
EPA NATIONAL PRIMARY DRINKING WATER STANDARDS. EPA 816-F-02-013 July 2002.
EPA DRINKING WATER
f
STD
(mg/L)
6.5 to 8.5 su
300.0
325.3b
b
353.3
370.1b
#
DEQ GUIDANCE
LEVELSe
(mg/L)
500
0.3
0.05
250
250
10.0
10
0.05
1.0
0.01
0.05
0.05
2
0.005
0.1
0.05
0.015***
0.01
0.05
0.05
0.1
*** EPA ACTION LEVELS.
ICP-MS: Inductively Coupled Plasma-Mass Spectrometry
TRACE METALS - TOTAL CONCENTRATIONS IF TSS <100 mg/L; BOTH TOTAL AND DISSOLVED CONCENTRATIONS IF TSS >100 mg/L.
3/20/2013
Table04_WQ Parameters_indicators.xlsx
ATTACHMENT 2
Designated Analytical Laboratory Quality Assurance Program
(Please see attached CD)
Clarifications & Definitions
This document is footnoted to reference applicable sections of the 2003 National Environmental Laboratory
Accreditation Conference (NELAC) Standard and the corresponding items on the NELAC 2003 Quality
Systems checklist.
Element: refers to Apex's laboratory information management system. Element is the brand name of the
software marketed by Prōmium.
This is an uncontrolled copy of a controlled document. Please check with Apex Labs to ensure that this is the
most recent revision of this document.
Page 2 of 55
Table of Contents
Title
Section
Page
Quality Assurance Policy Statement
1.0
6
2.0
7
3.0
8
4.0
9
5.0
11
6.0
12
7.0
12
8.0
13
Objectives
Protocols
Responsibilities
Laboratory Ethics and Data Integrity
Ethics Training
Documentation and Tracking
Client Services
Acceptance of Work
Statement of Qualifications
Client Communication
Complaints
Organization & Responsibility
Conflict of interest & Employee Roles
Organizational Structure
Job Descriptions of Key Positions
Sample storage, tracking and handling
Training
Training Protocol
New Employee Orientation
Ongoing Training
Training Files
Laboratory Responsibilities
Lines of Authority
Approved Signatories
Independence of QA
Facilities, Equipment & Supplies
Facilities
Equipment
Procurement of Supplies
Sample Management
Page 3 of 55
Analysis Requests
Sample Receipt
Cooler Receipt Form
COC Inconsistencies / Sample Problems
Subcontracting of Samples
8.3
14
8.4
15
Environmental Test Method Selection, Validation & Documentation 9.0
15
Policy
Reporting
Sample Handling
Storage
Tracking
Disposal
Method Sources
Standard Operating Procedures
Method Detection Limits
Method Reporting Limits
Calibration & Maintenance
10.0
16
11.0
19
Calculations
12.0
24
Data Reduction, Validation, & Reporting
13.0
25
Naming conventions used by Element
14.0
27
Control of Nonconformances and Corrective Action
15.0
27
Instrument Calibration
Instrument Maintenance
Reference Standards
Support Equipment
Data Quality Objectives
Definitions
Criteria
Instrument QC
Extraction Batch QC
Data Reduction & Primary analytical review
Secondary data review
Tertiary data review and reporting
Definitions and Explanation
Laboratory & Sample Quality Control Nonconformance
Procedural Nonconformance
Expected Nonconformance
Page 4 of 55
Technical Operations or Quality System Nonconformance
Responsibilities & Authority for Nonconforming Work
Response Time
Assessment of Impact
Corrective Actions, Preventative Measures and Follow up
Documentation
16.0
32
17.0
35
18.0
36
19.0
37
Analytical Data
Analytical Data Storage
Supporting Data Storage
Quality System Documentation
Accessibility
Document Control
Definitions and Explanation
Authorization and Revision
Laboratory Policy Process
Computer Hardware and Software Validation
Backup
Performance and System Audits
Performance Audits
Proficiency Testing
Quality System Audits
Figures
Organizational Chart
Floor Plan
Chain of Custody
Cooler Receipt Form
Sample Report
Nonconformance Report Form
Page 5 of 55
Apex Laboratories, LLC
Quality Assurance Manual
Rev No 3, 06/30/11
1. Quality Assurance Policy Statement
This Quality Assurance (QA) Manual summarizes the overall quality system in place at Apex Laboratories,
LLC. The signatures on the front cover serve to document laboratory management's commitment to
upholding the tenets of this QA Manual and the related documents that support the quality system.1 The
objectives and policies laid out in this manual are issued under the authority of the Laboratory Director, and
Apex assumes legal responsibility for compliance with them.2
1.1. The objectives of Apex's quality system are summarized as follows:3
a)
Produce data that are scientifically valid, defensible, reproducible, accurate and timely.
b)
Report data of known quality, representative of the submitted sample and most appropriate to the
end-use of the data.
c)
Provide a framework for effective communication of, and adherence to, all applicable method and
regulatory guidelines and client requirements. 4
d)
Provide a mechanism for continuous improvement and minimize departures from the quality
system.
e)
Document the means by which the laboratory's quality objectives (items a-d above) are achieved.
f)
Ensure that personnel uphold the laboratory's quality objectives and are fully empowered to do so.5
1.2. 6The protocols of the laboratory's quality system fall into two categories: (1) those specific to the
analytical method sources referenced in section 9.1, and (2) those applicable to the laboratory's
operations in general as regulated by the standards of accrediting bodies, including Washington
Department of Ecology (WA DOE) and Oregon Environmental Laboratory Accreditation Program
(ORLAP). Whichever format presents the most stringent QA/Quality Control (QC) requirements takes
precedence, unless specifically excluded.7
a)
Analytical procedure and QA/QC requirements specific to an analytical method are included in the
laboratory's standard operating procedure (SOP) for the method. An SOP may cover more than one
analytical method.
b)
QA protocols applicable to the laboratory's operations in general are documented as one or more of
the following:
i The QA Manual - references further detailed documentation when applicable and copies may
be footnoted to reference the 2003 National Environmental Laboratory Accreditation Conference
(NELAC) Standard.
ii Apex SOPs - categorized by department, including QA administrative SOPs.
iii Laboratory Policies – address issues applicable to multiple SOPs, usually short enough to not
warrant being a full SOP.
1.3. 8It is the QA Department's duty, with the support of the rest of the management team, to integrate the
quality system into the daily operations of the laboratory. Requirements of the quality systems are
informally communicated through the normal day-to-day interactions of laboratory status and department
meetings, data review, training, addressing analytical problems, etc. For Apex, it is imperative that the
quality system is the framework of the laboratory's function, not a separate aspect of it. Formal periodic
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documentation of each employee's knowledge of the aspects of the quality system relevant to their job
and their agreement to implement them is achieved by the following:
a)
Each employee reads the QA Manual as part of their initial orientation, and each new revision of it
thereafter.
b)
A training session on the QA Manual and relevant QA SOPs and policies is given by a member of
the QA department at least once a year.
c)
New policies are communicated via email and are made available electronically.
d)
Analysts review their method SOPs against current published methods annually.
2. Laboratory Ethics and Data Integrity9
Apex Laboratories, LLC, has an internal program in place to create an ethically sound culture and ensure
data integrity. Apex’s ethics program is described in detail in Apex SOP Q-101 Code of Ethics.
2.1. Ethics Training
Apex's ethics program is supported by many components of the quality system and includes annual
ethics training for all employees that covers:
a)
Detection, evaluation and remediation of any improper, unethical or illegal actions.
b)
Management's responsibility to provide personnel with the resources and authority to carry out their
work in accordance with the quality system and ethics program.
c)
Prevention of any undue pressures or influences (internal or external) that may adversely affect the
quality of work. 10
d)
The agreement of personnel, and the laboratory as a whole, to not participate in any business or
activity that could:11
i Pose a conflict of interest,
ii Compromise the integrity of the data generated by the laboratory or client confidentiality, or
iii Undermine the laboratory's compliance with safety and/or hazardous waste disposal
regulations.
e)
Each new employee receives ethics training as part of their orientation. A signed ethics agreement
is kept in each employees training file. Lab-wide refresher training for the ethics program is given
annually by the QA department. This training is documented by dated signatures of those attending
the training session. Training signature sheets are kept on file in the QA department.
2.2. Documentation and Tracking
Data integrity issues are documented in order to track any further investigation or follow-up that may be
required and to provide a historical record in case of further incidents.
a)
Documentation may include:
i Data review or internal audit findings and subsequent corrective action,
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ii A non-conformance report with subsequent corrective action, or
iii In cases where confidentiality is an issue, and/or the ethical concern is not directly associated
with any specific data, documentation as a Code of Ethics Non-Conformance Report may be
kept by human resources in the appropriate personnel file.
b)
In order to track the occurrence of data integrity and/or ethical concern issues for periodic
assessment of the Quality System, (the annual QA Report to Management, etc), the QA department
keeps a record of all Code of Ethics Non-Conformance Reports kept in personnel files.
c)
Apex maintains that the greatest deterrent for inappropriate action is a corporate climate of personal
accountability and commitment to the highest degree of integrity in all actions of the laboratory and
its staff members.
3. Client Services
3.1. Acceptance of Work12 - The Project Manager is responsible for reviewing the technical and service
requirements of any request to provide analytical testing prior to accepting the work. This includes a
review of the capacity and capability of each department involved, taking into consideration factors such
as laboratory accreditation, instrumentation, methodology, staffing, turn around times, reporting levels and
specialized project requirements. The laboratory will not accept samples for in-house analysis where
capability or capacity is exceeded.
a)
A client's request for work is documented, at a minimum, by a submitted chain of custody (COC)
and may be include further documentation such as a Quality Assurance Project Plan (QAPP) or
Sampling and Analysis Plan (SAP) from the client.
b)
Apex makes every effort to clarify and document project requirements and provide the most
appropriate analytical support:
i If impropriety of sample handling or sample containers is significant enough to potentially
compromise data integrity, the client is notified for the option of re-sampling or qualification of
the data.
ii If samples are of an atypical matrix, Apex has a protocol in place to ensure appropriate sample
preparation and analytical methods are applied and thoroughly documented.
iii Any incongruities between a client's request for work and the laboratory's ability to perform the
analyses are resolved prior to commencing work.
c)
Review of any request for work is documented in the project file, at a minimum as review of the
COC and sample receipt confirmation sent to the client. More extensive requests that include a
contact or QAPP, etc., entail further documentation and approval signatures.
3.2. Apex's Statement of Qualifications includes a list all test methods the laboratory is able to perform and
the extent of accreditation for each test method and applicable matrix.13 The laboratory's protocol for
development and validation of alternative methodologies is documented as Apex SOP Q-108.
3.3. Amendments, Deviations & Complaints – Pertinent client communications during routine samples
analyses may be documented as notes in the project file or retained electronically as emails or entries in
Element.14
a)
Amendments to a client's request for work (whether a COC or QAPP, etc.) are reviewed as above
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b)
and are communicated to the appropriate personnel and documented accordingly.15
If there are changes in Apex's accreditation status relevant to a client's work or the laboratory
deviates from the agreed upon protocols during performance of the work, such changes are
communicated to the client for timely resolution and are documented accordingly.16
3.4. Apex is amenable to client's request to monitor laboratory performance through project specific QC,
split samples, performance test samples, and/or client audits.17
3.5. Any complaint a client has against the laboratory's service or reported data will be handled by the
appropriate management or QA personnel. The extent of corrective action and documentation warranted
will be determined by the nature of the compliant and may include an amended Analytical Report, a nonconformance report and/or inclusion in the annual QA report to management.18
4. Organization & Responsibility
4.1. Apex is an independently owned and operated laboratory and is not part of a larger organization. The
laboratory does not perform business activities other than those associated with environmental testing,
therefore the potential for conflict of interest in the roles of key personnel is minimal.19 The laboratory's
management team consists of the Laboratory Director, the Technical Manager, the Business Director and
the QA Manager. The laboratory management and quality systems cover all work conducted by Apex
personnel at the laboratory facility or on behalf of the laboratory at a client location.20
Employees may fill multiple roles in the laboratory in order to provide coverage in all areas at all times.
Each employee is fully trained in any new tasks they are assigned, and must demonstrate proficiency
before being allowed to work independently on client samples. Where applicable, the organizational chart
(Figure 1.) shows an employee's secondary responsibilities in parentheses under the appropriate
department.
4.2. Organizational Structure
The organizational chart (Figure 1.) depicts the structure of the laboratory organized per department and
the independent relationship of quality assurance, technical operations and business development.21
Personnel responsible for supervising the work of a department are bolded on the organizational chart.
No name bolded for a department indicates that all personnel are at an equivalent experience level
sufficient that supervision other than by the Technical Manager is not required.22
The organizational chart and position descriptions below, in conjunction with the Code of Ethics (Apex
SOP Q-101), define the responsibility, authority and interrelationship of personnel responsible for data
integrity.23
4.3. Job descriptions of key positions24
A brief job description for key positions within the laboratory are given below. The names of personnel
filling these positions are given in the organizational chart (Figure 1.) and Apex’s Statement of
Qualifications (SOQ) contains detailed descriptions of their relevant experience. Deputies assigned in the
absence of the key positions (Laboratory Director, Technical Manager, Business Development Manager
and QA Manager) are indicated on the organizational chart (Figure 1.)25
a)
Laboratory Director - Responsible for the overall laboratory functions, including daily laboratory
operations and adherence to technical standards. The Laboratory Director works in conjunction with
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the Technical Manager and Quality Assurance Manager to ensure that adequate technical and
staffing resources are available for the work being performed. Responsibilities also include project
management and reporting, as well as purchasing, facilities management and supervision of
laboratory employees.
b)
Quality Assurance (QA) Manager - The Quality Assurance Manager role will be filled by someone
who meets the minimum requirements of the 2003 NELAC standard Section 5.4.1.5.i, including
general knowledge of analytical methods performed by the laboratory and documented quality
assurance training.
Responsible for developing, implementing and maintaining the laboratory's Quality System.
Ensures that the Quality System is relevant to laboratory operations and complies with analytical
methods and applicable standards.26
Duties: 27
i Oversees the auditing of laboratory and system operations, and any necessary corrective
actions.
ii Oversight of QA/QC data review & assessment of compliance with laboratory quality objectives,
independent of any outside influences.
iii Works in conjunction with the Technical Manager to determine the minimum qualifications for all
technical positions.
iv Ensures that personnel are appropriately trained and that training is documented. Maintains
training records.
v Maintains laboratory accreditations, including proficiency testing22, 32and communicates with
state and federal agencies regarding all accreditation matters.
vi Communicates the ongoing status of Quality System compliance to management, including the
Annual Quality Report to Management referenced in Section 19.3 of this manual.
vii Maintains current revisions of controlled documents including the Quality Assurance Manual and
SOPs.28
viii Maintains method development and validation documentation, including MDL studies.
c)
Technical Manager - The Technical Manager role will be filled by someone who meets the
minimum requirements of the 2003 NELAC standard Section 4.1.1.129
Responsible for managing the technical functions of laboratory operations, including monitoring
analytical capabilities, ensuring adequate resources, performing technical project assessments and
monitoring the validity of analyses performed and data generated to assure reliable data. The
Technical Manager oversees method development and manages laboratory data systems, including
the LIMS system and electronic infrastructure, along with report and deliverable design. The
Technical Manager works in conjunction with the Quality Assurance Manger to determine the
minimum qualifications for all technical positions and ensure adequate training.30 The Technical
Manager also works closely with the Quality Assurance team to implement and maintain the quality
system, and ensure adherence to it.31
d)
Business Development Manager - Responsible for business development and client relations,
including determination of the laboratory’s ability to meet project specifications. In conjunction with
the Laboratory Director, the Business Development Manager performs client project management
and reporting activities. Other responsibilities include overseeing sample receipt and courier
operations.
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e)
Project Manager (PM) – Responsible for primary contact with the client. The PM is responsible for
clarifying client requests and monitoring the laboratory's performance in relation to the work
performed. The PM advises clients of any subcontracting of work whether because of unforeseen
reasons or on a continuing basis and gain approval from the client for such work, preferably in
writing. Produces and reviews final reports for completeness and accuracy. The PM must also
ensure client confidentiality.
f)
Sample Receiving Supervisor - Reports to the Business Development Manager. Supervises
sample control technicians who are responsible for sample receipt and login, including the
completeness of all sample receipt documentation for incoming samples and projects. Sample
Control Technicians also prepare sample bottles, fill client bottle requests and coordinate delivery of
sample containers for client sampling and subsequent sample pick-up.
g)
Laboratory Analyst - Responsible for preparation and/or analysis of samples in accordance with
the relevant SOP and published method(s). Depending on their documented level of experience,
analysts may also be responsible for training other analysts, data entry and review, instrument
maintenance, preparation of analytical standards, and initiation of non-confromance reports.
Analysts may be assigned additional secondary roles, such as serving on the safety committee,
coordinating waste disposal activities, or working in a different department in the laboratory. In all
aspects of work conducted, analysts are responsible for compliance with Apex's quality system,
including the Code of Ethics' right of refusal and full disclosure (SOP Q-101 4.2.4 and 4.2.7)
Personnel in key positions and lines of authority are depicted on the organizational chart in Figure 1 at the
end of this document.
5. Training32
The selection of well-qualified personnel, based upon education and experience, is critical to the success
and quality of the laboratory. In order to maintain a qualified staff and provide for personnel advancement
within the laboratory, Apex follows a thorough program of orientation and training as detailed in Apex SOP
Q-103.
5.1. Apex's training protocol is designed to provide a mechanism to document the competence of personnel
and set appropriate goals for individual training.
5.2. Each new employee receives an orientation that includes familiarization with the Apex Orientation &
Training SOP Q-103 and Training Record, the Quality Assurance Manual, the Safety Manual & Chemical
Hygiene Plan (SOP SMO-001) and the Code of Ethics (SOP Q-101).
5.3. The level of experience upon hire, and the continuous training of each employee, is documented in an
individual's Training Record by both the trainer and trainee initialing and dating the appropriate methods
and level of training.
a)
Training is conducted as one-on one instruction by an experienced analyst on the specific analytical
procedure to be performed. Employees are provided with the appropriate SOPs and reference
methods, and are fully trained in all aspects appropriate to the training level of the procedure,
including quality control and safety.
b)
Prior to preparing or analyzing any client samples without direct supervision, an analyst must
demonstrate proficiency in the task through successful completion of a Demonstration of Capability
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(DOC) (Refer to Apex SOP Q-107).
c)
Original Training Records are retained in each department for ease of access.
5.4. An individual training file is kept for each employee in the QA department. Each employee training file
contains:
a)
A completed Initial Training Signature Sheet to document initial orientation and certify understanding
and agreement to comply with Apex's QA Manual.
b)
A completed Training Record Documentation Agreement to certify understanding and agreement to
comply with Apex's training protocol.
c)
A completed Apex Laboratories Safety & Environmental Orientation form to document initial safety
training.
d)
A completed Ethics Agreement and Training Form to document initial ethics training and agreement
to comply with Apex's Code of Ethics.
e)
A copy of the individual's Training Record.
f)
A signed hard copy of the individual's annual Demonstration of Capability of Certification Statement.
g)
Certificates of any training obtained from external sources.
6. Laboratory Responsibilities
6.1. Lines of Authority - The Laboratory Director is responsible for nominating deputies in the case of the
absence of personnel in management or supervisory positions. The Business Development Manager
assumes this responsibility in the absence of the Laboratory Director.
6.2. Approved Signatories - Apex Laboratories, LLC, provides environmental data for a variety of clientele.
Management level positions are approved signatories for all reported data and controlled laboratory
documents. Alternate signatories may be assigned in the case of an extended absence or leave to ensure
normal work flow.
6.3. Independence of QA - The QA Department has a high degree of independence and authority in the
laboratory’s organization. The QA Department reports directly to the Laboratory Director to review the
work of groups and individuals, and is independent of production pressures that associated with
generating or compiling data.
7. Facilities, Equipment & Supplies33
7.1. Facility
Apex Laboratories, LLC is a 7800 square foot main facility, with a 6000 square foot secondary facility
dedicated to environmental analytical services and divided into separate areas for sample receipt and
laboratory departments. The floor plan is organized in such a manner as to minimize cross contamination
between analytical procedures and maximize work flow efficiency. The laboratory’s floor plan is depicted
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in Figure 2 at the end of this document.
Apex does not have mobile laboratory facilities. 34
7.2. Equipment35
Apex analysts operate and maintain a wide variety of state-of-the-art analytical instrumentation and
equipment for the performance of a variety of chemical analysis. All instruments and analytical equipment
are subject to service and preventative maintenance procedures per manufacturer instruction to minimize
the occurrence of failure or malfunction. Each instrument used for testing is uniquely identified and has it's
own instrument logbook which is kept near the instrument. All maintenance is documented in the
appropriate instrument logbooks. A detailed list of instrumentation is maintained in Apex’s Statement of
Qualifications for accurate assessment of the laboratory’s capabilities.
7.3. Procurement of supplies
Apex purchases all supplies associated with samples analyses, such as gases, chemicals and sample
containers, from reputable suppliers and maintains records of lot numbers when applicable. Chemicals,
bottles and standards are tested prior to use in the laboratory. Volumetric dispensing devices, such as
glass microliter syringes, must be procured from vendors with ISO 9001 certification, or otherwise be
certified to meet the requirements for Class A glassware.
8. Sample Management
Most samples submitted to Apex Laboratories are sampled by our clients, either directly or through the use
of third party sampling services. Apex provides limited sampling services for storm water monitoring and
other projects. Prior to sampling, clients receive appropriate sampling containers with preservatives from
the laboratory. This service is extended to our clients to ensure that the proper containers are used for the
requested analyses, and that the containers used are clean and contain the appropriate preservative. At
login, sample container information is recorded and Apex may qualify results from samples received in
containers that were not provided by the lab or were sampled in improper containers.
8.1. Analysis Requests
Analytical methods used by Apex are those specified by regulatory agencies such as the U.S.
Environmental Protection Agency (USEPA), including SW-846 methodologies and the Code of Federal
Register Guidelines, ASTM, Standard Methods or state agencies. Any deviations from these methods are
documented in the related Standard Operating Procedures.
Ideally, clients coordinate with the Laboratory Director, Business Development Manager and/or
designated Project Manager prior to sampling to ensure that correct sampling procedures, containers and
preservatives are employed for the analytical method best suited to the matrix and end use of the
analytical data. Chain of Custody (COC) forms accompany all bottle orders to be completed at the time of
sampling, and are provided to clients in bulk for unscheduled projects. If prior planning is not possible,
analysis requests may be made by the client and documented at the time of sample receipt.
Figure 3 at the end of this document is an example of an Apex COC.
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8.2. Sample receipt 36
a)
The Sample Control department is responsible for receiving samples from the clients or their
designees. Samples are routinely delivered to the laboratory by the client or sampler, commercial
courier or delivery service (UPS/Fed Ex/DHL), or may be picked up by Apex courier. The COC is
signed by both the client and the sample control personnel or Apex courier upon receipt,
documenting transfer of custody to the laboratory. Commercial delivery services are not required to
sign COCs as long as the cooler has remained sealed while in custody.
b)
When samples arrive at the laboratory, the COC accompanying the samples is reviewed to confirm
that all pertinent information is filled out, including client name and address, project name and
number, sample name and matrix, number of containers, required turnaround time and date /time
sampled. Sample control personnel verify the following parameters:
i Sample containers received correspond to those on the COC, and containers are intact.
ii Sample volume, container, preservation and temperature are correct for requested analyses.
iii Adequate time is allowed to meet holding time requirements for the requested analyses.
iv Samples are not visibly damaged or compromised.
c)
Sample conditions as received are documented using the Apex Cooler Receipt Form form during
cooler receipt and inspection. Once custody is taken, cooler and sample conditions are recorded on
the Cooler Receipt Form, the COC information is checked and entered into Element, Apex sample
labels are printed. Samples are labeled with their unique container identifiers (labels) and placed
into the appropriate storage location prior to analysis. When sample control personnel enter all
pertinent sample information into Element, a work order number is assigned to the sample delivery
group, unique individual sample and container identifiers are created, and the samples are placed
into extraction and analysis queues. Project specific information pertaining to the samples and
requested analyses is also entered into Element when applicable.
d)
If there are any inconsistencies in the chain of custody or problems with sample receipt or login,
they are noted on the Cooler Receipt Form and the Apex project manager is notified immediately
and the client contacted. Detailed descriptions of protocols for all aspects of sample control,
including handling, tracking, acceptance, and storage are contained in Apex SOP L-001 R0 Sample Receipt, Login, Subsampling, and Subcontracting, and L-003 – Sample Management
Tracking and Storage.
Figure 4 at the end of this document is an example of an Apex Cooler Receipt Form.
8.3. Subcontracting of samples37
a)
When clients request an analysis not performed in-house by Apex employees or exceeds laboratory
capacity, sample control personnel will arrange for the samples to be delivered to and analyzed by a
laboratory with the appropriate certification.
b)
Client notification and approval is required prior to subcontracting of any samples. The certifications
and Quality Assurance Manuals of all subcontract laboratories utilized by Apex should be
maintained by the QA Department. A subcontract COC is prepared to accompany the samples and
document transfer of custody to the subcontract laboratory. Subcontract custody documentation is
retained with the project folder. Apex assumes responsibility for coordinating all reporting and QC
requirements between the client and subcontracting laboratory, along with the release of final data.
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c)
Subcontracted data is received either electronically or in hardcopy form. The full subcontractor's
report is included with our Apex report to the client. When possible, the subcontracted data is
included in the text of the Apex report and identified as subcontracted data.
See also Apex SOP L-001 - Sample Receipt, Login, Subsampling and Subcontracting, Section 6.1.
8.4. Sample Handling
a)
Storage
Samples are stored in accordance with conditions listed in the individual methods. All soil samples
and all water samples, except acid preserved samples for metals analysis only, are refrigerated and
maintained at less than 6°C, but not frozen. Acid preserved polyethylene bottles for metals
analyses only are stored at ambient temperature in a designated storage location. Samples stored
away from all standards, reagents, food and other potentially contaminating sources. Client sample
storage location is documented in Element.
b)
Tracking
Prior to commencing work on a set of samples, the extractionist or analyst will create a bench sheet
in Element and add the desired samples to the batch by selecting the bottle to be used. The bench
sheet is used to track information relating to all aspects of extraction including sample amount, date
and time of extraction, person performing the work, spike standard IDs and amounts, along with any
comments relevant to the sample or samples in the batch. Sample analysis may be tracked by
creating an analytical sequence in Element for organics analyses including GC and GC/MS
techniques. Analytical batches and sequences are assigned unique identification numbers by
Element.
c)
Disposal
Refrigerated samples are kept at 6oC for the remainder of the month in which they are received and
the following month. Samples are retained for at least two full months after receipt. Samples are
then disposed of according to laboratory determined disposal procedures which meet DEQ
guidelines. Samples deemed hazardous may be returned to the client.
9. Environmental Test Method Selection, Validation & Documentation
Apex Selects methods for environmental testing which meet the needs of the client and which are
appropriate for the environmental tests it undertakes.
9.1. Method Sources
Most of the analytical methods used by Apex are those specified by regulatory agencies such as the U.S.
Environmental Protection Agency (USEPA), or the Code of Federal Register (CFR) Guidelines. The
following is a partial list of method references used by Apex:
a)
Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, U.S. Environmental
Protection Agency, SW-846, 3rd Edition, September 1986, Update l, July 1992 and Update ll,
September 1994.
b)
Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020, Revised 1983.
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c)
Standard Methods for the Examination of Water and Wastewater, American Public Health
Association, American Water Works Association, and Water Pollution Control Federation, 20th
Edition (1999).
d)
Guidelines Establishing Procedures for the Analysis of Pollutants Under the Clean Water Act , 40
CFR, Part 136.
e)
Oregon Department Of Environmental Quality, test methods as contained in OAR 340-122.
f)
Washington Department of Ecology, test methods as defined in WAC 173-300 – 173-340
g)
ASTM Standards
9.2. Standard Operating Procedures38
Apex Laboratory maintains SOPs that accurately reflect all phases of current laboratory activities
including Quality Assurance, General Laboratory Procedures, and Test Methods. All SOPs are internally
written documents with adequate detail to allow someone (with similar qualifications to the analyst), other
than the analyst, to reproduce the procedures used to generate the test result.
9.3. Method detection limits (MDL)
Method Detection Limit studies are performed in accordance with 40CFR part 136 Appendix B, MDL
Study specifications, upon introduction of any new analyte, matrix type, instrument, technique or following
significant changes to any one of these. The MDL is verified annually for each matrix, method and
analyte. MDL studies are not performed for some methods where spiking standards are not available or
the reporting scale is not determined by low-level sensitivity or precision, such as pH, Solids,
Temperature, or Turbidity.
9.4. Method reporting limits
Method reporting limits are usually set at two to five times the method detection limit (MDL) above.
Documentation of an acceptable MDL study and demonstrated method reporting limit capability for each
analytical instrument must be in place prior to analysis of client samples. When applicable, MRL values
are adjusted for sample dilution and percent dry weight of solid samples.
10. Calibration & Maintenance
10.1. Instrument calibration39
a)
Apex calibrates all instrumentation using certified traceable reference materials. Calibration
procedures for routine analyses are performed in accordance with approved appropriate analytical
methods and documented in the relevant analytical SOPs. No points may be deleted between the
high and low points of an initial calibration curve in order to meet QC criteria, however points at the
high or low ranges of the curve may be deleted to improve the curve fit as long as the minimum
number of points is retained and the limitation in analytical range and/or reporting limit are not
detrimental to the data quality objectives. Method specific guidelines for calibrations are followed
when available, and Apex specifies preferred calibration criteria when they are not. At a minimum,
Apex analysts prepare calibration curves in accordance with the following criteria:
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i
ii
iii
iv
Calibration is comprised of at least three points.
Calibration is verified by a second source, if available.
Lowest point of the calibration curve must be at or below the MRL.
Internal calibration point or level cannot be deleted.
b)
All calibration standard preparations are entered in to the Element data system. Information such as
concentration of the standard used, dilution volumes, solvent, date prepared, manufacturer's lot
number, and the name of the analyst is recorded to ensure the calibration may be reconstructed if
necessary. To assure that calibration standards are prepared correctly, an external quality control
standard from a secondary source is analyzed each time a new calibration is prepared.
c)
Initial calibration curves are verified by continuing calibration standards every twelve hours for
organic methods or every ten samples for inorganic methods. Sample analysis is not performed
until the calibration has been verified. If the continuing instrument calibration verification results
obtained are outside established acceptance criteria, corrective actions are performed. If routine
corrective action procedures fail to produce a second consecutive calibration verification within
acceptable limits, then the analyst must demonstrate acceptable performance after corrective action
with two consecutive calibration verifications or a new initial instrument calibration must be
performed.
d)
If samples are analyzed with an unacceptable calibration, all associated samples will be
reanalyzed. If reanalysis is not possible, data associated with an unacceptable initial instrument
calibration shall be reported with appropriate data qualifiers.40 Data associated with an
unacceptable continuing calibration verification (CCV) may be fully useable under the following
special conditions:
i When the acceptance criteria for the CCV are exceeded high, and there are associated samples
that are non-detects, then those non-detects may be reported.
ii When the acceptance criteria for the CCV are exceeded low, those sample results may be
reported if they exceed the applicable maximum regulatory limit level.
e)
Sample data is traceable to the calibration source through unique method (calibration) names
recorded on all hard copy data. Instrument calibration curves can be entered into Element for most
analyses utilizing analytical sequences.
10.2. Instrument Maintenance41,42
a)
Apex’s instrument preventive maintenance program complies with instrument manufacturer
recommendations and is designed to maximize instrument performance and minimize downtime.
Maintenance schedules for instrumentation are included in the related analytical SOPs. All
maintenance carried out on an instrument is documented in the instrument logbook kept with the
instrument, and is followed by the appropriate calibration and/or calibration verification procedures.
b)
Instrument logbooks must include the following information:
i The identity of the item of equipment and it's software.
ii The manufacturer's name, type identification, and and serial number or other unique
identification.
iii Current location.
iv The manufacturer's instructions, or reference to their location.
v All maintenance carried out to date (documentation on all routine and non-routine maintenance
activities).
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vi Any damage, malfunction, modification or repair to the equipment.
vii Date received and date placed in service (if available).
viii Condition when received if available (used, new, reconditioned).
c)
In the event a problem arises which cannot be corrected in-house, manufacturer trained service
technicians are contracted and brought on-site (service calls are also documented in the
instrument logbooks.
10.3. Reference standards43
In general, unless a higher grade is required per method or instrument sensitivity, all chemicals used are
reagent grade or higher, and all standards traceable to ACS or NIST reference standards. Whenever
possible, Apex maintains independent source standards for each analysis to allow for verification of
calibration standards. All reference materials are assigned a unique identification number upon receipt
that is retained with the traceability certification and entered into Element. Records of all stock and
intermediate standard solutions prepared, including information on reagent and solvent purity, lot
numbers, analyst’s initials and preparation dates are maintained in Element. All standard solutions are
validated prior to use. The validation procedure is typically verification of concentration using a standard
prepared at a different time or obtained from a second source. All standards are labeled with an
expiration date.
10.4. Support equipment44
Support equipment includes any devices for weighing, measuring, heating or cooling standards or
samples. Support equipment includes, but is not limited to the following: analytical balances, ovens,
refrigerators, freezers, water baths, thermometers, rotary extractors, water purifying systems, and
volumetric dispensing devices.
a)
Quantitative results of analyses are highly dependent on the accuracy and reliability of support
equipment, therefore, all support equipment is maintained in proper working order and calibration
verified on a regular basis. The results of such calibration or verification shall be within the
specifications required of the application for which this equipment is used or it shall be removed
from service until repaired. Equipment which has been removed from service must be clearly
labeled as such, or physically removed from the laboratory.
b)
Apex maintains ASTM class I certified reference weights for all analytical balances bracketing their
range of use for analysis. Partial immersion and total immersion NIST traceable thermometers are
maintained for thermometer calibration. Prior to use on a daily basis the calibration of each balance,
oven, refrigerator, freezer and water bath is verified and documented. On a quarterly basis the
calibrations of rotary extractors, and volumetric dispensing devices are verified. All other support
equipment either has the calibration verified or is recalibrated at least on an annual basis. If
operational conditions change or the instrument is moved, calibration verification must be
performed before use.
c)
Glass microliter syringes are purchased from an ISO 9001-2000 certified vendor, such as Hamilton
Company. Such syringes are manufactured to be accurate withing +/- 1% of nominal volume, with
precision within 1% when measured at 80% of total scale volume.
d)
The Laboratory uses type 1 Deionized (ASTM (D1193-91)) water for all extractions and solutions.
The system is checked weekly and preventative maintenance is performed bi-monthly.
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11. Data Quality Objectives
11.1. Definitions
The quality of data generated is always the top priority at Apex. The quality of the data generated is
confirmed by assuring the data is accurate, precise, representative, complete, comparable and defensible
as defined below.
a)
Accurate- The degree of accuracy is determined by the agreement between an observed value
and an accepted reference or true value. Accuracy is ensured by adherence to analytical quality
protocols and use of dual source certified reference materials for all possible methodologies.
Accuracy is monitored through the performance of quality control check samples, matrix spikes,
laboratory quality control spikes, and surrogate/internal standard spikes
b)
Precise - The degree of precision is determined by the difference in resultant value of two
identically prepared items. Precision is ensured by adherence to protocols for replicate analyses.
Precision is monitored by the performance of sample and/or field duplicates, matrix spike and
control spike duplicates, and the subsequent calculation of relative standard deviation (RSD) or
relative percent difference (RPD).
c)
Representative - The degree of representation is expressed by how accurately and precisely a
point defines the mean characteristics of a population, parameter variations at a specific sampling
point, or an environmental condition within a defined boundary. Proper representation is ensured by
adherence to proper sample treatment protocol including appropriate analytical approved
methodologies, adherence to holding times and analysis of field duplicate samples.
d)
Complete - The degree of completion is determined by the amount of valid data returned from any
sampling set compared to the expected amount under normal conditions. Completeness is ensured
by adherence to all quality protocols for every sample received. Apex makes a concerted effort to
provide the most complete resultant data possible for every sampling set by minimizing laboratory
error and instrument or electronic failure.
e)
Comparable - The degree of comparability is determined by the precision of one data set to
another. Comparability is ensured by adherence to appropriate analytical methods and SOPs and
consistent detection levels for each method routinely performed by Apex. Detection levels are
evaluated annually to provide documented proof of limit appropriateness. External comparability is
ensured by the use of common reporting units and general reporting protocols.
f)
Defensible - The degree of defensibility of a specific data set is measured by the completeness of
documentation and traceability to certified standards for comparison. Apex will provide expert
witness testimony regarding environmental analyses performed at Apex, if required. In order to
provide the best quality for our clients, Apex maintains laboratory operating conditions such that all
data associated with sample analysis can withstand scrutiny for legal purposes.
The following definitions are found in the TNI Standard, Volume 1, Management and Technical
Requirements for Laboratories Performing Environmental Analysis. They are included here for easy
reference. Changes or additions to the TNI definition are included in italics. For further definitions, see the
appropriate TNI section.
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g)
Analyst: The designated individual who performs the “hands-on” analytical methods and
associated techniques and who is the one responsible for applying required laboratory practices
and other pertinent quality controls to meet the required level of quality.
h)
Audit: A systematic and independent examination of facilities, equipment, personnel, training,
procedures, record-keeping, data validation, data management, and reporting aspects of a system
to determine whether QA/QC and technical activities are being conducted as planned and whether
these activities will effectively achieve quality objectives.
i)
Batch: Environmental samples that are prepared and/or analyzed together with the same process
and personnel, using the same lot(s) of reagents. A preparation batch is composed of one (1) to
twenty (20) environmental samples of the same quality systems matrix, meeting the above
mentioned criteria and with a maximum time between the start of processing of the first and last
sample in the batch to be twenty-four (24) hours. An analytical batch is composed of prepared
environmental samples (extracts, digestates or concentrates) which are analyzed together as a
group. An analytical batch can include prepared samples originating from various quality system
matrices and can exceed twenty (20) samples.
j)
Bias: The systematic or persistent distortion of a measurement process, which causes errors in one
direction (i.e., the expected sample measurement is different from the sample’s true value).
k)
Blank: A sample that has not been exposed to the analyzed sample stream in order to monitor
contamination during sampling, transport, storage or analysis. The blank is subjected to the usual
analytical and measurement process to establish a zero baseline or background value and is
sometimes used to adjust or correct routine analytical results. Blanks include:
Method Blank: A sample of a matrix similar to the batch of associated samples (when available) that
is free from the analytes of interest and is processed simultaneously with and under the same
conditions as samples through all steps of the analytical procedures, and in which no target
analytes or interferences are present at concentrations that impact the analytical results for sample
analyses.
l)
Certified Reference Material (CRM): Reference material, accompanied by a certificate, having a
value, measurement uncertainty, and stated metrological traceability chain to a national metrology
institute. Also includes Standard Reference Material (SRM)
m) Chain of Custody Form: Record that documents the possession of the samples from the time of
collection to receipt in the laboratory. This record generally includes: the number and types of
containers; the mode of collection; the collector; time of collection; preservation; and requested
analyses.
n)
Holding Times: The maximum time that can elapse between two (2) specified activities.
o)
Internal Standard: A known amount of standard added to a test portion of a sample as a reference
for evaluating and controlling the precision and bias of the applied analytical method.
p)
Limit(s) of Detection (LOD): A laboratory's estimate of the minimum amount of an analyte in a
given matrix that an analytical process can reliably detect in their facility.
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q)
Limit(s) of Quantitation (LOQ): The minimum levels, concentrations, or quantities of a target
variable (e.g., target analyte) that can be reported with a specified degree of confidence.
r)
Matrix: The substrate of a test sample.
s)
Matrix Duplicate: A replicate matrix prepared in the laboratory and analyzed to obtain a measure of
precision.
t)
Matrix Spike (spiked sample or fortified sample): A sample prepared, taken through all sample
preparation and analytical steps of the procedure unless otherwise noted in a referenced method,
by adding a known amount of target analyte to a specified amount of sample for which an
independent test result of target analyte concentration is available. Matrix spikes are used, for
example, to determine the effect of the matrix on a method's recovery efficiency.
u)
Matrix Spike Duplicate (spiked sample or fortified sample duplicate): A replicate matrix spike
prepared in the laboratory and analyzed to obtain a measure of the precision of the recovery for
each analyte.
v)
Quality System: A structured and documented management system describing the policies,
objectives, principles, organizational authority, responsibilities, accountability, and implementation
plan of an organization for ensuring quality in its work processes, products (items), and services.
The quality system provides the framework for planning, implementing, and assessing work
performed by the organization and for carrying out required quality assurance (QA) and quality
control (QC) activities.
w) Quality System Matrix: These matrix definitions are to be used for purposes of batch and quality
control requirements:
Aqueous: Any aqueous sample excluded from the definition of Drinking Water or Saline/Estuarine.
Includes surface water, ground water effluents, and TCLP or other extracts.
Chemical Waste: A product or by-product of an industrial process that results in a matrix not
previously defined.
Drinking Water: Any aqueous sample that has been designated a potable or potential potable water
source.
Non-Aqueous Liquid: Any organic liquid with <15% settleable solids.
Solids: Includes soils, sediments, sludges and other matrices with >15% settleable solids.
The options available in the Element LIMS for matrix types tested at Apex are: Cartridge, Digest,
Liquid, Oil, Paint Chip, Pore Water, Sediment, Soil, Solid, Transformer Oil, Water, and Wipe. Liquid
may refer to aqueous or non-aqueous liquid that does not meet the definition of Water. Some of
these Apex matrices may be combined for the purposes of an extraction batch. The above TNI
definitions are generally used to establish extraction batches.
x)
Reference Standard: Standard used for the calibration of working measurement standards in a
given organization or at a given location.
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11.2. Criteria45
Data Quality Objectives (DQOs) are defined as the goals of accuracy and precision established for a data
set to demonstrate freedom from bias. Apex’s data quality objectives are assigned from one of three
sources: 1) EPA method specified criteria or published guidance such as Contract Laboratory Program
(CLP), Functional Guidelines or the Department of Defense QSM; 2) internally derived criteria from
control charts of analytical data; and 3) client mandated project specific criteria. EPA method specified
criteria are included in Apex’s analytical SOPs when available and serve as the minimum requirements.
All data quality objectives are maintained in Element and included in analytical reports. Client specific
DQOs are coordinated between Apex and the client prior to commencement of work and are
documented as a Quality Assurance Project Plan (QAPP) provided by the client. Data quality objectives
are comprised of the internal and reportable quality control checks described below.
11.3. Instrument QC
a)
Calibration Verification Standards - At the start of each analytical sequence, a Calibration
Verification Standard (CCV) is run to verify the continued applicability of the initial calibration. The
standard or set of standards contains all of the analytes to be measured along with any internal
standards or surrogates used. In most cases the calibration verification standard is from the same
source as the initial calibration standard. Calibration verification standard acceptance criteria are
established by the related analytical methods, or determined by Apex based on instrument and
method limitations. These criteria are stated in the relevant analytical SOP. In general, if a
calibration check standard does not pass the acceptance criteria, reanalysis of the standard is
permitted if there is a reasonable cause for the initial failure. Potential reasons for failure of a CCV
include: need for instrument maintenance, tuning, or conditioning; incorrect or degraded standard
analyzed; sample introduction error; or instrument performance drift requiring recalibration.
Corrections can be made for any of these conditions (except instrument drift) and a second CCV
analyzed if the instrument operating parameters are not modified. For example, if a dirty GC
injection liner causes a CCV failure, the liner can be replaced with an identical liner, conditioned as
necessary, and a second CCV analyzed. If standards analyzed after corrections are made fail to
match the current calibration, a new calibration curve must be run.
i Conditioning runs and response checks are standard solutions analyzed to condition and test
the system during and after maintenance. Conditioning runs/response checks and CCVs cannot
be used interchangeably, and the intended use of any standards analyzed should be clear from
the information contained in the analytical data.
ii It is not acceptable to analyze repeated CCVs with the intention of accepting data based on a
passing CCV without a reasonable cause for the initial failure. Repeated runs of any standard
are only acceptable if instrument conditions have been corrected to match those of the current
calibration curve.
iii Calibration must be re-verified again every 20 samples for organic methods (except GC/MS)
and every 10 samples for inorganic methods. Samples should be run using the same conditions
as CCVs. For example, if a sequence of dirty samples requires repeated instrument blanks to
be run prior to the CCV, then instrument blanks should be run between each sample as well. If
sequences with multiple CCVs are used to analyze samples, failing CCVs will mean that data
not bracketed by acceptable QC is not reportable. However, the failure of subsequent CCVs in a
sequence (e.g. when a sequence runs overnight) will not automatically force recalibration, and
the rules stated above for determining and correcting CCV failure still apply.
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b)
Instrument Performance Standards - Instrument performance criteria must be demonstrated
when running GC/MS, GC/ECD, ICP or ICP/MS methods, and may include mass spectral tunes,
analyte breakdown and tailing check standards, and interference check standards. At the beginning
of every twelve-hour period, the instrument must pass the performance criteria defined in the
respective analytical method and related Apex analytical SOP.
c)
Instrument Blanks - Prior to sample analysis, an instrument or extraction blank must be analyzed
to assure that the analytical system is free of contamination. Analytes should not be detected above
one-half the Method Reporting Limit (MRL) in the instrument or extraction blank for some analyses.
See Apex Laboratory Policy #091016A, “Data assessment and qualification for blank detections” for
further clarification. If it is determined that the blank is not free of contamination, corrective action
must be taken to eliminate the source of contamination. Affected samples may be either reextracted
and reanalyzed or the data appropriately qualified as specified below for method blanks, depending
on the end use of the data.
d)
Internal Standards - A known concentration of Internal Standard is added to every standard, blank
and sample being analyzed for organic parameters by GC/MS or metals by ICP/MS. Internal
Standard calibrations compensate for minor fluctuations in instrument response by adjusting target
analyte results based on Internal Standard responses. If fluctuations in the Internal Standard are
more than the acceptance criteria, corrective action must be taken to solve the problem. Effected
samples must be reanalyzed or the data reported as Estimated.
11.4. Extraction Batch QC
a)
Batch QC Source Selection – Matrix Spikes and Sample Duplicates that are performed on client
samples should be analyzed on a systematic random basis, such as selecting the first and tenth
sample assigned to the batch. Alternately, client samples that are known from historical analysis to
be likely to provide useful information may be selected as the QC source. (e.g. Selecting a sample
as the duplicate source that is suspected to have detections above the reporting level, or
deliberately not selecting a sample that is suspected to have such severe matrix effects or high
native analyte concentration as to preclude calculation of spike recovery.)
b)
Laboratory Control and Matrix Spikes - Laboratory Control Samples (LCS) and Matrix Spikes
and Spike Duplicates (MS/MSD) are performed by spiking laboratory blanks or client samples,
respectively, with a spiking solution containing some or all of the analytes of interest for the
analysis. Laboratory control spikes are performed on matrix specific, analyte free media, while
matrix spikes are performed on sample media. These analyses are a measure of method
performance and accuracy and are done at a frequency of one out of every twenty samples, or one
per extraction batch for all applicable methods. Accuracy data are expressed as percent recovery
and acceptance criteria for laboratory spike recovery are derived from the appropriate analytical
methods or listed sources, from internal control charts, or from client specified DQOs. If recoveries
for the Laboratory Control Sample fall outside of acceptance limits, corrective action and reanalysis
must be performed if possible. If reextraction and reanalysis are not possible, data will be qualified
appropriately, or not reported at all. Out of control matrix spike recoveries, from batches with incontrol LCSs, are usually indicative of some form of matrix interference. Apex will qualify the
reported data accordingly and inform the client of the sample matrix interference.
c)
Sample Duplicate Analyses – A percentage of all samples are analyzed in duplicate as a measure
of analytical precision, expressed as relative percent difference (RPD). Sample Matrix Duplicates
are performed on replicate (separately extracted) aliquots of actual samples. Sample Matrix
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Duplicates are run at minimum rate of one per batch of twenty samples or less for all methods.
Duplicate Matrix and/or Laboratory Control Spikes may also be run to demonstrate method
precision. If RPD values for an LCS/LCS Duplicate pair do not fall within acceptance limits,
corrective action and reanalysis must be performed, if possible. If reextraction and reanalysis are
not possible, data will be qualified appropriately, or not reported at all. The rules for allowing
marginal exceedences of LCS compounds is not used and all results are qualified when LCS
componds are outside of control limits. Out- of- control Sample Duplicate or Matrix Spike RPD
values, associated with in-control LCS RPDs, are usually indicative of interference with the specific
sample matrix. Apex will qualify the reported data accordingly and inform the client of the suspected
sample matrix interference.
d)
Method Blanks – One method blank is processed with each batch of samples to assure that the
equipment and reagents being used are free of contamination. Analytes should not be detected
above one half the Method Reporting Limit (MRL) in the method blank. If it is determined that the
blank is not free of contamination, corrective action must be taken to determine the source of
contamination. The affected samples must either be reanalyzed, or the data appropriately qualified.
If an analyte is detected in a method blank at a concentration greater than one half of the MRL, the
associated data is flagged in Element. Final qualification of the data is determined by analyst review
and end use of the data; non-detected sample results are not qualified, sample concentrations less
than five to 10 times the concentration detected in the method blank are qualified based on the
client's end use of the data. See Apex Laboratory Policy #091016A - “Data assessment and
qualification for blank detections” for further clarification.
e)
Surrogate Standards - Surrogates are compounds closely related to the compounds of interest,
but not expected to be found in real world samples. All samples and QC are spiked with a known
concentration of the surrogates before extraction for all GC and GC/MS methods. Surrogate
recovery limits for each matrix are established in the same way as Lab Control Sample limits. For
methods with multiple surrogates, only a certain number of surrogate recoveries may need to meet
QC criteria, as reflected in the SOP. Samples should be reanalyzed if surrogate recoveries do not
meet acceptance criteria and no interferences or matrix effects are suspected. Data with failing
surrogates will be qualified based on the client's end use of the data.
12. Calculations
Accuracy Measurements
(Percent Recovery = P)
Method Standards:
P =
100 x observed recovery
true concentration
Matrix Spikes:
P =
100 x ( observed - background )
spike concentration
Average Recovery (P):
P=
Standard Deviation of Recovery:
∑ P
n
SD =
∑
2
(P - P )
(n - 1)
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Upper and Lower Control Limits (Recovery):
UCL p = P + 3SD
LCL p = P - 3SD
Precision Measurements
Relative Percent Difference:
RPD = 100 x
Mean RPD:
R =
UCL for Mean RPD:
X1- X2
( X 1 + X 2 )/2
∑ RPD
n
R c = 3.27xR
13. Data Reduction, Validation and Reporting
13.1. Data reduction and primary analytical review
a)
An extractionist or analyst initiates the sample preparation process by querying Element for
samples requiring the analysis to be performed. A bench sheet is created with a unique batch
identification number for the samples to be extracted or digested. The bench sheet is printed out
and used to document the sample preparation procedure, including the extractionist, date and time,
sample amounts used, standards IDs and amounts and any comments relevant to the samples.
Bench sheets are considered raw data and are retained in each department.
b)
Following analysis, instrument raw data is reviewed using the instrument software and all relevant
reports are generated. Each analyst is responsible for the primary data review, including checking
instrument performance criteria such as mass spectral tunes, blank evaluation and initial/continuing
calibration checks prior to sample analysis.
c)
Whenever possible, instrument data is automatically acquired by commercially available software
designed by the instrument manufacturers specifically for this purpose. Hard copy printouts of all
instrument QC and sample data are generated at the time of acquisition or prior to any manual
integrations or edits. For GC and GC/MS methods, each data file of an analytical sequence is
reviewed electronically by the analyst for correct analyte identification and integrations and
acceptable QC results. During this process, chromatograms for any necessary manual integrations
are printed and added to the raw data packet for that sample. Following review, edited quantitation
reports are reprinted, if necessary, and the sample raw data packet is initialed and dated by the
analyst. The analyst then uploads the electronic data for the samples into Element using the
companion DataTool instrument interface software, which allows for direct data uploads without the
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need for manual entry.
d)
Metals data generated by ICP or ICP/MS and Wet Chem data generated by IC is also captured by
manufacturer designed software specific direct acquisition software and printed out at the time of
acquisition. Following the primary analyst's electronic review, the raw data for the sequence is
similarly uploaded into Element.
e)
Wet chemistry data that is not electronically captured is manually entered into Element following
primary review.
f)
Sample data is then queried from Element and undergoes the first level of review in Element. The
analyst adds appropriate qualifiers, initiates reextraction or reanalysis if necessary, and updates the
sample analysis status to “needs review”.
13.2. Secondary data review
a)
All hard copy sequence data is secondarily reviewed by a person qualified to perform the analysis,
or who is trained in the specifics of data review of the particular analysis. Instrument data is
reviewed against the electronic data in Element, and the package is evaluated against stated Data
Quality Objectives. The appropriate corrective action is implemented and documented if a problem
is found at any stage in the review process.
b)
The analyst and secondary reviewer similarly review GC and GC/MS calibration sequence data.
Metals and wet chemistry calibrations are reviewed with the associated sample data.
13.3. Tertiary data review and reporting
a)
Tertiary review of all data for a given project is performed when the report is generated through the
Element data system by project management. The report format includes sample and batch QC
results (blanks, blank spikes, duplicates and matrix spikes) and analysis information such as
analysis date and batch identification. Project narration, calibration data, instrument QC data, or
client-specified component data packages are also available upon request. Once the project
manager approves the data, a final report is generated electronically in Adobe .pdf format with the
project manager’s electronic signature attached. Safeguards against unauthorized use of the
electronic signature include password authentication and user specific privileges. The original Chain
of Custody, Cooler Receipt Form, documentation of vital client correspondence and/or nonconformance issues are retained in the project file. Electronic Final Report and a snapshot of the
table data used in the report is archived at the time of reporting so subsequent requests for EDDs
or other report variations will come from the same subset of data, and include any modifications
done in the original report.
Figure 5 at the end of this document is an example of an Apex Analytical Report.
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14. Naming conventions used by Element
Element Naming Schemes (auto-assigned):
Work Orders:
LYYMNNN
A10A001
Samples:
AN
-01
Container:
A-Z
A
Standards:
LYYMNNN
A10H001
Batch Numbers:
YYMNNNN 10H0001
Sequence Numbers: YMDDNNN 0H01001
Calibration IDs:
LYMDDNN A0H0101
Batch QC/Instrument QC/Sample Naming:
L
Y
YY
MM
M
Lab Code
Year
Year
Month (Num)
Month (Alpha)
N
Sequential
Number
Day
DD
A
0
10
08 (Aug)
A– L (JanDec)
0-9
01-31
Batch QC: (Batch Number - QC Type - Number)
10A80001-BLK1
Batch QC Blank
10A80001-BS1
Batch QC Lab Control Sample
10A80001-Dup1
Batch Duplicate
10A80001-MS1
Batch QC Matrix Spike
10A80001-MSD1
Batch QC Matrix Spike Dup
10A80001-PS1
Batch QC Post Spike (ICPMS)
Instrument QC:
0H01001-TUN1
0H01001-CCV1
0H01001-CCB1
0H01001-ICV1
0H01001-CAL1
0H01001-IBL1
0H01001- etc…
Samples:
A10A001-01
(Sequence Number - QC Type - Number)
MS Tune Sample
Continuing Cal Std
Continuing Cal Blank
Initial Cal Verification
Calibration Standard
Instrument Blank
Work Order A10A001, Sample -01
15. Control of Nonconformance and Corrective Action 46
15.1. Any aspect of the environmental testing work conducted by the laboratory that fails to comply with the
standards of the laboratory's quality system, agreed upon client requirements, and/or accepted regulatory
guidelines constitutes a nonconformance event. Appropriate documentation and corrective action steps
must be taken in a timely manner for all noncomformances as detailed below. Documentation and
corrective action steps, as well as the level of responsibility at which they are dealt with, are dependent
upon the type of noncomformance, the extent of deviation and its impact on data.
a)
Types of nonconformance documentation and guidelines for timely resolution in ascending order of
severity are listed below and explained in detail in Section 15.8. More than one type of
documentation may be applied to a nonconformance event.
i Documentation in the data and qualification of results – immediately upon data entry.
ii Case Narrative on the Analytical Report – before final report issued.
iii Nonconformance Form retained by the QA department – completed/finalized within 2 weeks of
nonconformance event.
iv Amended Analytical Report – issued within 1 week after the nonconformance form finalized.
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v
Client notification/data recall – completed within 2 weeks after the nonconformance form
finalized.
b)
Apex's system to accurately and consistently assess the impact of any nonconformance event on
data quality and useability is based on potential known bias and the type of nonconformance. Types
of deviations and the corresponding appropriate documentation and corrective action are
characterized in Sections 15.2 through 15.5 below.47 Criteria for assessment of impact on data is
covered in Section 15.8
c)
Lines of authority and responsibilities for implementing corrective action, tracking nonconformance
events, follow-up, and preventative measures are outlined in Section 15.6. and 15.8.
15.2. Laboratory & Sample Quality Control Nonconformance
Problems related to QC data commonly identified by an analyst at the time of analysis, or during data
review, are categorized below as pertaining to either laboratory QC issues or sample QC issues. Such
issues are usually recognized prior to reporting results and are dealt with at the analyst level by either
reanalysis or qualification of the data. Apex analytical SOPs and QC policies address specific QA for each
noncoformance.
a)
Laboratory QC Nonconformance
i Initial Calibration - Corrective action is initiated if the initial calibration criteria specified in the
analytical method and related Apex SOP are not met. Identification of the cause of failure is
essential. Routine corrective actions are to verify standard concentrations, perform instrument
maintenance, and reanalyze the calibration curve. The cause of failure is identified and
corrected prior to proceeding with curve reanalysis.
ii Continuing Calibration - Corrective action is initiated if continuing calibration criteria are not
met. Routine corrective actions are to reanalyze the continuing calibration standard, perform
instrument maintenance, or run a new calibration curve if necessary. All samples analyzed with
a continuing calibration standard outside acceptance limits are reanalyzed or adequately
qualified.
iii Laboratory Control Sample (LCS) Recoveries – Laboratory policy Spike Policy 091112A
describes in detail the protocol followed when an LCS recovery falls outside acceptance limits.
Corrective action is initiated if LCS recoveries are found to be outside acceptance limits. Poor
recoveries could be due to extraction inefficiency, analyst error or instrument problems. The
LCS may be reanalyzed to verify an out-of control situation. Corrective action requires reextraction and re-analysis of the associated samples, or appropriate qualification of the sample
data if reanalysis is not possible.
iv Method or Instrument Blanks - Laboratory policy Blank Policy 091016A describes in detail the
protocol followed when analyte is detected in a blank. Method and instrument blanks should
have analyte concentrations less than one-half of the Method Reporting Limit in order to avoid
bias of sample results near the MRL. The source of any significant blank contamination is
determined and eliminated. If the contamination is related to instrument contamination or
carryover, maintenance can be performed and the blank and any samples reanalyzed. If the
source is determined to be from the sample preparation steps or from the reagents, the samples
should be reextracted or the data qualified appropriately.
v Instrument Performance Standards - Corrective action is initiated when a GC/ECD, GC/MS,
ICP or ICP/MS does not pass the method instrument performance criteria such as tune,
breakdown and response factors. Normal corrective actions include cleaning or retuning the
mass spectrometer, cleaning the GC inlet, or changing the cones on the ICP/MS.
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b)
Sample QC nonconformance
When laboratory QC data are within acceptance limits, sample QC exceedances such as Sample
Duplicate RPD, Matrix Spike recovery, Internal Standard response, Surrogate recovery and Postdigestion Spike recoveries are usually indicative of some form of sample matrix interference with
the chosen methodology.
i Corrective action for a sample QC exceedance may include reextraction and/or reanalysis of the
sample to eliminate the possibility of analytical or preparation error. If the results of reanalysis
are consistent with the initial results, the data is qualified accordingly.
ii Significant sample QC deviations may warrant a Case Narrative on the Analytical Report written
by the Technical Manager or QA Department.
c)
Issuance of a Nonconformance Form for laboratory and sample QC nonconfromances is not usually
warranted, unless a laboratory QC deviation begins to occur frequently or the QC deviation is
discovered after the data has been issued without qualification.
i If a QC deviation is discovered after the data has been issued as a final report without
qualification, documentation should include an amended Analytical Report and a
Nonconformance Form noting the root cause and corrective action for the QC deviation and for
reporting the data unqualified.
ii Continued occurrence of a laboratory QC nonconformance requires documentation on a
Nonconformance Form so that the root cause of the deviation can be investigated and resolved
with the appropriate corrective action.
15.3. Procedural Nonconformance
Unexpected occurrences of procedural errors during sample preparation or analysis, such as a sample
going to dryness during concentration, should be documented in the raw data and the results qualified
accordingly by the analyst. Qualification of results may also extend to a Case Narrative on the Analytical
Report written by the Technical Manager or QA Department. Frequently occurring procedural errors
warrant the use of a nonconformance form and a corrective action plan as described in section 15.2.
15.4. Expected Nonconformance48
The laboratory has protocols in place for accepting and performing work that does not fall within the usual
scope of normal sample preparation and analytical methods. Apex's Weird Sample Plan and New Method
Development and Validation SOP Q-108, provide the frame work to ensure that permitted deviations from
and/or modifications of standard policies and procedures are thoroughly documented and data are
accurately qualified and reported.
15.5. Technical Operations or Quality System Nonconformance49
Noncompliance issues that are not directly associated with analytical QC data may also arise; such
deviations are considered operational noncompliances. When it is discovered that an aspect of the
laboratory's normal operation deviates from laboratory policy and/or regulatory requirements, the QA
department assumes responsibility for initiating corrective action. Examples of such a deviation might be:
a refrigerator temperature exceedance during sample storage, or a balance used past its certification
date.
a)
Operational deviations, including root cause and corrective action, are documented initially on a
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Nonconformance Form and followed through to a level commensurate with the seriousness of the
nonconformance. Technical and QA management assess the potential impact of a noncompliance
on all associated reported results.
b)
Response to operational nonconformance issues that are recognized as a result of a client or
regulatory agency audit are the responsibility of the QA department. Corrective action in such cases
is documented as a formal audit response.
15.6. Responsibilities & Authority for Nonconforming Work50
The level of authority required to resolve a nonconformance issue is dependent upon the extent of the
nonconformance as noted in the descriptions in Sections 15.2 through 15.5.
a)
Procedural, laboratory QC, and sample QC nonconformances are generally addressed at the
analyst level by data qualification during data entry or data review.
b)
Extenuating procedural nonconformances, expected nonconformances for atypical samples,
technical operations and quality system nonconformances need to be addressed at the
management level (by the Technical Manager, QA Department and/or Laboratory Director) and
require more extensive documentation than qualification of affected results. This usually involves a
case narrative added at the beginning of the analytical report.
c)
Apex's nonconformance policy is to empower analysts to be directly responsible for any
noncompliance of data they generate. In accordance with Apex's Code of Ethics SOP Q-101- “All
analysts have the right to, and are expected to, initiate a stop work investigation in the event that
work fails to comply with the standards of the laboratory's quality system and/or accepted regulatory
guidelines. Each analyst is responsible for collaborating with QA and the Technical Manager to
investigate any situation that could potentially compromise data integrity and take the corrective
actions necessary to resolve the nonconformance.”
d)
Resolution of extenuating nonconformances is considered a collaborative effort between the
analyst, Technical Manager, QA, project management and the Laboratory Director. However,
because the Laboratory Director is ultimately responsible for all reported test results, corrective
action steps that involve stopping and/or resuming production or withholding or amending results
are enacted under the final authority of the Laboratory Director.51 If the analyst, Technical Manager
and/or QA Manager disagree with the Laboratory Director's corrective action decision, dissent is
documented.
15.7. Response Time
a)
Corrective action is initiated as soon as possible after a nonconformance is discovered. If the
corrective action involves more than documentation in the data and qualification of results, the
entire corrective action process, including root cause analysis and data assessment, may take
several weeks to complete. In such cases:
i An electronic Nonconformance Form is initiated and management notified immediately to begin
the corrective action and assessment of impact on data process.52 The QA department controls
the amount of time a nonconformance case is open by monitoring each electronic
Nonconformance Form on the X:\ drive to closure, as indicated by the signed Nonconformance
Form in pdf format in the same location.
ii If data submitted to a client could potentially be significantly affected by the nonconformance,
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the client is promptly notified via email that their data is under review and that further information
will be forthcoming.53 The QA department is responsible for ensuring that resolution of the
nonconformance is completed with the client.
15.8. Assessment of Impact
a)
For laboratory and sample QC nonconformances, assessment of the impact of the nonconformance
on data is done at the analyst level. The assessment, and corresponding data qualification, is then
incorporated into the data review process.
b)
Impact is usually limited to an analytical batch or sequence.
c)
For nonconformance events that are deviations from the quality system or technical operations
policies (section 15.5), the impact on data is initially assessed by the analyst in conjunction with the
Technical Manager to determine the amount of data affected and to what extent data integrity has
been compromised. After the initial assessment by the analyst and Technical Manager, QA and the
Laboratory Director are consulted to discuss possible courses of corrective action and compliance
requirements.54 Element is used to determine all data potentially effected by a non conformance
event. The following points outline criteria for assessment of impact on data quality for potential
data recall.
d)
if the nonconformance event is a correctable error, such as a quantitation, transposition or
transcription error, the data are corrected and reissued as an amended report with appropriate
documentation.
e)
If the nonconformance event causes results to change from nondetect to detected, or vice versa, an
amended Analytical Report with Case Narrative is issued.
f)
If the nonconformance event causes a specific known bias in the data and the amount of error
introduced to the final results is significant in comparison to the level of the reported result and/or
the error inherent in the analysis, results may be reissued as estimated and qualified for the
potential bias.
g)
If there is no known bias associated with the nonconformance event, and/or the amount of error
introduced to the final results is not significant in comparison to the level of the reported result or
error inherent in the analysis, corrective action will entail internal documentation rather than
reissuing data.
15.9. Corrective Actions, Preventative Measures and Follow up55
a)
Corrective actions applicable to various types of nonconformances are given in Section 15.2. In
general, the criteria for an acceptable corrective action are as follows: 56
i The investigation must start with a determination of the root cause of the nonconformance and
identification of potential corrective actions.
ii The corrective action chosen must be the most likely to eliminate the noncompliance and
prevent recurrence.
iii The extent of the corrective action must be appropriate to the magnitude and associated risk of
the nonconformance.
iv If the nonconformance casts doubt on the lab's compliance with it's own policies, the lab must
ensure that the appropriate areas of activity are audited as soon as possible.
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v
b)
Changes implemented as a result of corrective action should be documented and measurable
for appropriate follow up.
Documentation of corrective action is critical to ensuring that the changes implemented as a result
of corrective actions are maintained and that nonconformance events are able to be tracked to
assess laboratory performance.57
i Corrective actions for nonconformances that have minimal data impact, and are able to be
executed to completion immediately, do not need to be documented further. For example, a
blank spike recovery outside control limits may be resolved with re-extraction/reanalysis of the
samples, documentation in the raw data and\or qualification of results, and does not require a
nonconformance Form.
ii A Nonconformance Form is used to document any nonconformance event that cannot be
remedied immediately and fully documented as such in the data.
iii Nonconformance forms should include:
• The responsible analyst and an explanation of the nonconformance and root cause
• data effected.
• Initial and subsequent corrective actions, target completion dates and date of reissued
reports.
• QA, Technical Manager and Laboratory Director comments and approval.
iv Documentation of changes implemented as a result of corrective action may include a
laboratory policy or an SOP revision.
v Nonconformance events and subsequent corrective actions are summarized and documented
annually in the QA Report to Management for overall assessment of laboratory performance.
Figure 6 at the end of this document is an example of an Apex Nonconformance form.
c)
The laboratory has the following measures in place in order to prevent the occurrence of
nonconformances and to be able to readily identify them when they do occur:58
i The Apex Code of Ethics sets a standard for continuous improvement.
ii There is an established policy for review of SOPs and most current methods.
iii Regularly scheduled laboratory-wide and department specific status meetings provide a forum
for identifying potential problems and preventing nonconformance.
d)
The effectiveness of corrective actions taken for nonconformance issues pertaining to the Quality
System, technical operations and/or regulatory compliance is assessed by incorporating the issues
into the next scheduled internal audit for the appropriate department(s).59
16. Documentation60
The laboratory maintains record keeping systems applicable to the scope of work conducted and sufficient
to meet the regulatory requirements under which the work is conducted.61 Records are organized and
stored to ensure easy retrieval and prevent loss or damage during retention.62 After the allotted retention
time, hard copy records and data are disposed of in such a way that maintains client confidentiality.63
Types of records retained fall into two main categories; analytical data, and documentation supporting the
quality system (including health & safety and hazardous waste disposal).
16.1. Analytical Data64
All laboratory activities that contribute to generating analytical results are documented promptly, legibly,
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and in ink, in the appropriate place to indicate the task with the person's initials and the date the task was
performed.65 Any corrections to raw data are made in such a manner that the original data are still legible.
The correction is initialed and dated by the person making the correction.66 A note must be added if
necessary to clarify the reason for the correction. Electronic documentation, including an audit trail of
changes, is maintained in Element as the initials/date of the analyst responsible for the data.67
All analytical data necessary to reconstruct sample results and ensure traceability of all measurements
are retained by the laboratory for a minimum of two years in hard copy and five years in electronic
format68. Such data include, but are not limited to69:
a)
Chain of custody forms and sample receipt and tracking documentation.70
b)
Standard preparation records, including reference material certificates of purity.
c)
Handwritten bench sheets completed with relevant information pertaining to sample preparation/
analysis, including standard/reagent IDs and any analyst notes.
d)
Support equipment data such as balance checks and refrigerator temperature logs.
e)
Instrument calibration data.
f)
Instrument data from the analysis of all samples, and instrument and batch QC samples, including:
i Sample ID.
ii Instrument & calibration ID.
iii Any manual manipulations such as calculations or integrations.
iv Documentation of data review.
g)
Analysis sequence logs.
h)
Instrument maintenance logs.
i)
Analytical reports (including sample results, sample preparation and analysis methods, QC results
and acceptance criteria) & project specific client correspondence.
16.2. Analytical Data Storage
Sample analyses are organized by preparation batch and analytical sequence. Each batch and analytical
sequence is assigned a unique identification number in Element. (Please refer to Section 14 of this
manual for Element naming conventions.71) Data are organized for storage by sequence number, except
conventional chemistry parameter tests that do not involve an analytical sequence run on an instrument.
Data for such tests are organized per batch.
a)
Data Storage by Sequence - For each successful analytical sequence run on an instrument, the
laboratory prints out a hard copy packet of data and the electronic data is uploaded from the
instrument software into Element. Upon completion and review, the sequence data packet,
including the Element sequence log, is scanned into the data warehouse on the laboratory's
network. Hard copy sequence data packets are stored chronologically in each department and
periodically boxed and placed in the laboratory's main storage area.
b)
Data Storage by Batch - Benchsheets for batches are scanned into the data warehouse on the
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laboratory's network. Analytical data organized by batch only are retained as hard copies per
department.
16.3. Supporting Data Storage72
Data that is not stored by either sequence or batch is organized for retention and retrieval as outlined
below.
a)
Traceability records for standards and reagents are kept in a binder by the department using the
material. Standard preparation records are maintained in Element.
b)
Instrument maintenance logs are assigned a unique identification number entered into the log book
of log books for tracking purposes. Completed log books are stored chronologically with other
support data in the laboratory's main storage area.
c)
Loose leaf data such as balance checks and temperature logs are kept in a binder by the
equipment. A full binder is transferred to a labeled folder and archived chronologically with other
support data in the laboratory's main storage area.
d)
Infrequent support data, such as pipet and thermometer calibration records are kept in the QA
department or in the department responsible for maintaining the calibration.
16.4. Quality System Documentation73
All records and data important in documenting the Quality System are retained by the laboratory in either
electronic or hard copy format for a minimum of five years. The QA department maintains the following
records including all previous and current versions:
a)
Analyst training records, including qualifications, education and experience including Demonstration
of Capability (DOC) records for each analyst.
b)
Log of names and initials of all personnel who make logbook entries.
c)
Proficiency Testing results.
d)
Audit findings and corrective actions reports.
e)
Information & correspondence pertaining to accreditations.
f)
Method Detection Limit (MDL) studies.
g)
Annual Reports to Management.
h)
Nonconformance Reports, and all other documentation of data integrity.
i)
Standard operating procedures.
j)
Lab policies.
k)
Quality assurance manual and Statement of Qualifications.
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16.5. Accessibility74
a)
Access to active and archived data and records is controlled for hard copy data by limited access to
the laboratory facility, and through computer log-in restrictions for electronic records. Retrieval of
archived information is documented as the end product of the reason for the retrieval, for example
as a data package or nonconformance report, etc.75
b)
All data and records are made available for audits by regulatory agencies. To maintain client
confidentiality76, audits by clients are limited to data and reports for the client's samples, and
general data and records pertaining to Apex's QA system, such as SOPs and MDL, DOC and PT
sample data.
c)
If ownership of the laboratory is transferred, all data and records, and the obligation to retain them,
would be included in the transfer. In the event of business closure or bankruptcy, the applicable
regulatory and state legal requirements will be met.77
17. Document Control78
17.1. Description and Explanation
Documents that are fundamental to the laboratory’s quality system are issued as either controlled or
regulated documents, according to Apex Policy 100928A Document Control79. Documents considered
fundamental to the quality system include: the Quality Assurance Manual, standard operating procedures,
laboratory policies, non-conformance reports, Analytical Reports, audit finding reports, audit response
reports, Apex Change Memos, QA Reports to Management, etc.
a)
For a controlled document, the generation, distribution and period of use is controlled. This process
is applicable to documents where periodic revision is mandated to ensure continuing suitability and
compliance with applicable requirements.80
i Controlled documents are assigned a unique controlled document number, revision number,
and effective date to clearly identify the time period a document is in force. Each page of a
controlled document contains the document number, page number and total number of pages.81
ii The QA department maintains distribution records of all controlled documents and current
revision status to ensure that a document is retracted at the end of the enforcement period.82
iii The original of each non-current revision is marked as obsolete and archived to document
changes per revision.83
iv Apex's QA Manual and SOPs are maintained as controlled documents. Binders of hard copies
of the current QA Manual and relevant SOPs are maintained in the QA department only; the
most recent revisions of all SOPs are accessible to the laboratory electronically in read-only
format.84
b)
The generation of regulated documents is controlled, but distribution is not controlled to the extent
that the number copies distributed is known. With the exception of laboratory policies (see Section
17.3 below), regulated documents are not expected to be revised.
c)
Controlled and regulated documents are assigned unique identification numbers for tracking.
Page 35 of 55
Apex Laboratories, LLC
Quality Assurance Manual
Rev No 3, 06/30/11
17.2. Approval and Revision
Controlled and regulated documents require the dated signature(s) of authorized personnel necessary to
review and approve the document prior to use.85 A regulated document such as an Analytical Report only
requires the signature of the project manager, where as a technical standard operating procedure
requires the approval of the Technical Manager, QA Management and/or an appropriate representative
from the analytical department.
a)
Review for an approval signature on a controlled document includes pertinent background
information such as the applicable analytical method and/or changes made to the previous revision
of the document being reviewed.86
b)
Revisions of a controlled document require the same level of approval signatures as the original
version and are re-issued as soon as practicable to incorporate necessary changes.87
17.3. Laboratory Policy Process
The laboratory policy process was created as a means to document aspects of laboratory operation that
are applicable to multiple SOPs or brief enough to not warrant an entire SOP.
a)
In order to keep the policy process efficient and flexible, policies are issued and maintained
electronically.
b)
A hard copy of approval signatures for each policy is kept separately from the electronic format to
allow for flexibility. Modifications that do not alter the intent of the policy do not require further
approval signatures. Modifications that do alter the intent of the policy require the signature of one
of the original signatories. Policy modifications are tracked by the date noted in the document
footer.88
18. Computer Hardware, Software, Validation and Back-up
Apex uses only commercially available computer hardware from reputable sources and software designed
specially for analytical instrumentation such as Agilent Technologies ChemStation Software. The
Laboratory Information Management System, Element, is developed by Promium, LLC and maintained
internally by the Technical Manager and externally by a service contract with the manufacturer. The
integrity of Element and instrumentation software is tracked in the related audit trails which document
changes made in the system; and is verified by review of the raw data against the uploaded data, and
review of the final report.
18.1. Back-up89
The laboratory's electronic data and documents are organized to facilitate easy retrieval by authorized
personnel. To guard against potential loss, electronic records are stored in multiple locations, including an
external hard drive kept off site. The Technical Manager assumes responsibility for ensuring that
electronic records are kept in a format supported by the hardware/software necessary for retrieval. 90
Page 36 of 55
Apex Laboratories, LLC
Quality Assurance Manual
Rev No 3, 06/30/11
The diagram below illustrates the extensive electronic backup systems in place.91
automatic
nightly
back-up
raw data on
Instruments
manually
moved to
active raw data folders
folders on Server
archived instrument
folders on Server
manually
uploaded
via Data Tool
Backup
Server
auto back-up
M/W/F
Second
hard drive
on backup
server
manual
back-up
weekly
External
hard drive
off-site
Element
SQL server data base
+
Data warehouse
automatic
storage of scanned data
nightly back-up
19. Performance and System Audits92
In order to maintain accreditation and meet contractual qualifications Apex is subject to audits conducted
by regulatory agencies and private clients. In addition to these external audits, Apex performs internal
audits to support the Quality System and continuous improvement. The three types of audits outlined below
are conducted according to a predetermined schedule by the QA department.93 The QA Manager may also
delegate auditing tasks to qualified personnel independent of the activity to be audited.94
19.1. Performance audits are qualitative evaluations to assure that the Quality System requirements are
being followed in the day-to-day analytical operations of the laboratory.
a)
Performance audits may include:
Determining whether the current SOP meets the most up to date regulatory requirements and
whether the SOP is being followed in the laboratory.
ii Assessing analyst training and documentation of training.
iii Evaluation of record keeping systems.
iv Ensuring that adequate equipment, supplies and personnel are available for the audited
analysis.
v Auditing data as instrument data, in Element and as the final analytical report.
vi Ensuring that corrective actions implemented for previous audit findings are in place.95
i
b)
Performance audit reports include the department, method(s) and analyst(s) audited, any findings
and subsequent corrective actions and date of implementation. Performance audit reports are
retained by the QA department.96
c)
Corrective action for audit findings should be implemented as soon as possible. The time frame for
completion of such corrective action will be determined by the QA Manager and included in the
Page 37 of 55
Apex Laboratories, LLC
Quality Assurance Manual
Rev No 3, 06/30/11
audit report (usually 30 days).97 In the event that audit findings warrant data recall, effected clients
will be notified in writing within 45 days of the audit report.98
d)
Internal performance audits should be performed at least annually per department, or more often as
needed at the discretion of the Laboratory Director or QA Manager.45
19.2. Proficiency Testing99
Proficiency tests (PT) are quantitative evaluations of laboratory performance to assure the accuracy of
data being generated. PT samples are an integral part of maintaining the laboratory's accreditations.100 PT
samples are purchased and analyzed by the laboratory for all analytes and matrices for which the
laboratory reports results, except in cases where a PT is not available for a particular analysis. PT
samples are prepared according to the manufacturers instructions and analyzed using the same
procedures and QC requirements as normal samples including the following:101
a)
PT samples are logged in to Element and assigned a work order number. The project manager role
is assigned to a QA department representative.
b)
PT samples are prepared (extracted/ digested) and analyzed by the same analyst that usually
performs the analysis, using the same methodology.
c)
The organization (per batch /sequence) and extent of analysis of the PT sample and associated
batch QC and instrument QC are the same as for routine environmental samples. The PT sample
should not be singled out as the source for batch QC. Batch QC for PT batches should be selected
using the same criteria as non-PT batches. 102
d)
PT sample results are entered into Element and the analytical data are retained the same as for
routine environmental samples103. An Analytical Report is generated and retained with the electronic
report sent from the PT provider.
e)
PT results are reported according to the PT provider's instructions, by either transcribing the results
from Apex's Analytical Report onto the PT provider's reporting sheets and manually submitting them
via fax or mail, or entering the results on the PT provider's web site.104
f)
PT sample results submitted to maintain Apex's accreditation status will be generated from
analyses performed only by the laboratory; the analyses cannot be subcontracted. Apex may send
specifically designated PT samples to subcontract laboratories in order to assess their analytical
capability. Such results may be submitted to the PT provider for assessment criteria, but not to
maintain Apex's accreditation status.105
g)
Apex may receive PT samples from a client as part of the client's QA protocol, but Apex will not
knowingly analyze PT samples to support a client's own accreditation for an analysis.106
h)
Prior to submission of PT results, Apex will not make any attempt to obtain PT result information
from the PT provider or other laboratories participating in the PT study. If circumstances arise that
compromise the integrity of Apex's participation in a PT study, Apex will withdraw from the study. 107
i)
Once PT results are submitted by the laboratory, the PT provider reports results and acceptance or
failure to the laboratory and any listed accrediting agencies.22 If a parameter does not pass,
corrective action is taken to find the source of the problem. Analysis of a remedial PT may be part of
Page 38 of 55
Apex Laboratories, LLC
Quality Assurance Manual
Rev No 3, 06/30/11
the corrective action. Generally, accreditation is based on successful completion of two out of three
PT studies for each matrix and analyte. Certification is generally downgraded to “Provisional” for an
analyte/matrix upon failure of that analyte in a single PT sample. Subsequent failure will likely result
in suspension of certification until corrective action has been sufficiently completed and two
successful PT sample analyses are completed. PTs are analyzed at least 2 times per year for each
method and matrix analyzed in the laboratory. PT sample results and supporting data are readily
available for review by any client or regulatory agency upon request.
19.3. Quality System Audits108
At least once per year the QA department conducts a review of the Quality System as a whole to
determine any necessary revisions or additions to ensure the maintenance of a properly functioning and
adapting system.
a)
The Quality System review should incorporate:
i An assessment of the Quality Assurance Manual and any necessary revisions.
ii New policies implemented.
iii Examination of non-conformance issues and corrective actions, including any issues pertaining
to non-compliance with Apex Code of Ethics SOP Q-101.
iv Results of PT studies for the year and any remedial action.
v Findings of performance audits and corrective actions.
vi Client feedback and/or complaints.
vii Changes in workload volume, instrumentation and analyses.
viii Any external assessments/ audits, findings and responses.
b)
Quality System audit findings and proposed corrective actions are formally documented and
submitted to the Laboratory Director and management team as an annual QA Report to
Management.
i The report is initiated as an open document and is finalized with documentation of the corrective
action, usually within 90 days. (Substantial actions that require system changes may take
longer, in which case the QA Report to Management is finalized with a proposed completion
date for the corrective action.)
ii The QA Report to Management is dated with the initiation date and is finalized by the
management team signing and dating the final hard copy report.
iii Signed final QA management reports are retained in hard copy or electronic format by the QA
department for a minimum of 5 years.
Page 39 of 55
Figure 1 – Organization Chart
Page 40 of 55
Figure 2 – Floor Plan
Apex Labs - Fire/Safety Hazards
.
Semivolatile
GC-MS
Semi-vol
ECD
Analysis
Waste
Room
Metals
Analysis
Break
Room
Metals
Prep
DI
Room
Safety
Fuels
Extra
ctions
Shower/
eye wash
Non-Flam
Haz Waste
Area
Ext.
Annex
Ext.
Restrooms
Dishes
office
Walk in
fridge
office
Sample
Receiving
KEY
Confe
rence
room
Fire Extinguisher
office
Chemical Spill Kits
Page 41 of 55
Figure 3 – Chain of Custody
The next page is an example of an Apex
Laboratories Chain of Custody.
Page 42 of 55
Page 43 of 55
Figure 4 – Cooler Receipt Form
APEX LABS COOLER RECEIPT FORM
Client: _______________________________________Element WO#: A11_________
Project/Project #: ________________________________________________________
Delivery info:
Date/Time Received: [email protected]____________ By: _________________________
Delivered by: Apex Courier___Client___FedEx___UPS___Senvoy ___SDS___Other
Cooler Inspection
Inspected by: [email protected]
Chain of Custody:
Included? Yes ___ No ___
Signed/Dated by Client? Yes ___ No ___
Signed/Dated by Apex Personnel? Yes ___ No ___
Coolers:
No. of Coolers: ________
Cooler #1
Cooler #2
Cooler #3
Cooler #4
Temperature (deg. C)
________
________
________
________
Received on Ice? (Y/N)
________
________
________
________
Temp. Blanks? (Y/N)
________
________
________
________
Ice Type: (Gel/Real/Other) ________
________
________
________
Condition:
________
________
________
________
Cooler out of temp? (Y/N) Possible reason why:
Samples Inspection:
Inspected by: [email protected]
All Samples Intact? Yes ___ No ___ Comments:______________________________
_______________________________________________________________________
Bottle Labels/COCs agree? Yes ___ No ___ Comments: _______________________
_______________________________________________________________________Containers
Appropriate for Analysis? Yes ___ No ___ Comments: _______________
_______________________________________________________________________
Do VOA Vials have Visible Headspace?
Yes ___ No ___ NA ____
Comments_______________________________________________________________ Water Samples:
pH Checked and Appropriate (except VOAs): Yes___No___NA______
Comments:
Additional Information:
Labeled by:
See Client Contact Form: Y
Page 44 of 55
Figure 5 – Sample Report
The next six pages are an example of a report
generated out of Element by Apex Laboratories.
Page 45 of 55
12232 S.W. Garden Place
Tigard, OR 97223
503-718-2323 Phone
503-718-0333 Fax
Apex Labs
Wednesday, August 4, 2010
Philip Nerenberg
Apex Labs
12232 S.W. Garden Place
Tigard, OR 97223
RE: Performance Evaluation / Spring 2010 Water Remedial PT
Enclosed are the results of analyses for work order A10F200, which was received by the laboratory on
6/17/2010 at 3:51:00PM.
Thank you for using Apex Labs. We appreciate your business and strive to provide the highest quality
services to the environmental industry.
If you have any questions concerning this report or the services we offer, please feel free to contact me by
email at: [email protected], or by phone at 503-718-2323.
Apex Laboratories
The results in this report apply to the samples analyzed in accordance with the chain of
custody document. This analytical report must be reproduced in its entirety.
Page 1 of 6
Evan Holloway, Quality Assurance Manager
Page 46 of 55
12232 S.W. Garden Place
Tigard, OR 97223
503-718-2323 Phone
503-718-0333 Fax
Apex Labs
Apex Labs
12232 S.W. Garden Place
Tigard, OR 97223
Project: Performance Evaluation
Project Number: Spring 2010 Water Remedial PT
Project Manager: Philip Nerenberg
Reported:
08/04/10 16:16
ANALYTICAL REPORT FOR SAMPLES
SAMPLE INFORMATION
Sample ID
Laboratory ID
Matrix
Date Sampled
Date Received
Trace Metals 1
A10F200-01
Water
06/17/10 00:00
06/17/10 15:51
Apex Laboratories
The results in this report apply to the samples analyzed in accordance with the chain of
custody document. This analytical report must be reproduced in its entirety.
Page 2 of 6
Evan Holloway, Quality Assurance Manager
Page 47 of 55
12232 S.W. Garden Place
Tigard, OR 97223
503-718-2323 Phone
503-718-0333 Fax
Apex Labs
Apex Labs
Project: Performance Evaluation
12232 S.W. Garden Place
Project Number: Spring 2010 Water Remedial PT
Project Manager: Philip Nerenberg
Tigard, OR 97223
Reported:
08/04/10 16:16
ANALYTICAL SAMPLE RESULTS
Total Metals by EPA 6010C (ICP-AES)
Analyte
Result
MDL
Trace Metals 1 (A10F200-01)
Copper
Reporting
Limit
Units
Matrix: Water
0.363
Apex Laboratories
---
0.0100
Dilution
Date Analyzed
Method
06/23/10 17:24
EPA 6010C
Notes
Batch: 1006383
mg/L
1
The results in this report apply to the samples analyzed in accordance with the chain of
custody document. This analytical report must be reproduced in its entirety.
Page 3 of 6
Evan Holloway, Quality Assurance Manager
Page 48 of 55
12232 S.W. Garden Place
Tigard, OR 97223
503-718-2323 Phone
503-718-0333 Fax
Apex Labs
Apex Labs
Project: Performance Evaluation
12232 S.W. Garden Place
Project Number: Spring 2010 Water Remedial PT
Project Manager: Philip Nerenberg
Tigard, OR 97223
Reported:
08/04/10 16:16
QUALITY CONTROL (QC) SAMPLE RESULTS
Total Metals by EPA 6010C (ICP-AES)
Analyte
Result
MDL
Reporting
Limit
Units
Dil.
Spike
Amount
Source
Result
%REC
%REC
Limits RPD
RPD
Limit
Notes
Water
Batch 1006383 - EPA 3015A
Blank (1006383-BLK2)
Prepared: 06/23/10 14:07 Analyzed: 06/23/10 17:18
EPA 6010C
Copper
ND
---
0.0100
mg/L
LCS (1006383-BS2)
1
---
---
---
---
---
---
---
---
Prepared: 06/23/10 14:07 Analyzed: 06/23/10 17:21
EPA 6010C
Copper
0.0543
---
Apex Laboratories
0.0100
mg/L
1
0.0556
---
98
80-120%
The results in this report apply to the samples analyzed in accordance with the chain of
custody document. This analytical report must be reproduced in its entirety.
Page 4 of 6
Evan Holloway, Quality Assurance Manager
Page 49 of 55
12232 S.W. Garden Place
Tigard, OR 97223
503-718-2323 Phone
503-718-0333 Fax
Apex Labs
Apex Labs
Project: Performance Evaluation
12232 S.W. Garden Place
Project Number: Spring 2010 Water Remedial PT
Project Manager: Philip Nerenberg
Tigard, OR 97223
Reported:
08/04/10 16:16
SAMPLE PREPARATION INFORMATION
Total Metals by EPA 6010C (ICP-AES)
Prep: EPA 3015A
Lab Number
Matrix
Method
Sampled
Prepared
06/17/10 00:00
06/23/10 14:07
Sample
Default
RL Prep
Initial/Final
Initial/Final
Factor
45mL/50mL
45mL/50mL
1.00
Batch: 1006383
A10F200-01
Water
EPA 6010C
Apex Laboratories
The results in this report apply to the samples analyzed in accordance with the chain of
custody document. This analytical report must be reproduced in its entirety.
Page 5 of 6
Evan Holloway, Quality Assurance Manager
Page 50 of 55
12232 S.W. Garden Place
Tigard, OR 97223
503-718-2323 Phone
503-718-0333 Fax
Apex Labs
Apex Labs
Project: Performance Evaluation
12232 S.W. Garden Place
Tigard, OR 97223
Project Number: Spring 2010 Water Remedial PT
Project Manager: Philip Nerenberg
Reported:
08/04/10 16:16
Notes and Definitions
Qualifiers:
Notes and Conventions:
DET
Analyte DETECTED
ND
Analyte NOT DETECTED at or above the reporting limit
NR
Not Reported
dry
Sample results reported on a dry weight basis. Results listed as 'wet' or without 'dry'designation are not dry weight corrected.
RPD
Relative Percent Difference
MDL
If MDL is not listed, data has been evaluated to the Method Reporting Limit only.
WMSC
Water Miscible Solvent Correction has been applied to Results and MRLs for volatiles soil samples per EPA 8000C.
Batch
QC
Unless specifically requested, this report contains only results for Batch QC derived from client samples included in this report. All
analyses were performed with the appropriate Batch QC (including Sample Duplicates, Matrix Spikes and/or Matrix Spike Duplicates) in
order to meet or exceed method and regulatory requirements. Any exceptions to this will be qualified in this report. Complete Batch QC
results are available upon request. In cases where there is insufficient sample provided for Sample Duplicates and/or Matrix Spikes, a
Lab Control Sample Duplicate (LCS Dup) is analyzed to demonstrate accuracy and precision of the extraction and analysis.
Blank
Policy
Apex assesses blank data for potential high bias down to a level equal to ½ the method reporting limit (MRL), except for conventional
chemistry and HCID analyses which are assessed only to the MRL. Sample results flagged with a B or B-02 qualifier are potentially
biased high if they are less than ten times the level found in the blank for inorganic analyses or less than five times the level found in the
blank for organic analyses.
For accurate comparison of volatile results to the level found in the blank; water sample results should be divided by the dilution factor,
and soil sample results should be divided by 1/50 of the sample dilution to account for the sample prep factor.
Results qualified as reported below the MRL may include a potential high bias if associated with a B or B-02 qualified blank. B and B-02
qualifications are not applied to J qualified results reported below the MRL.
Apex Laboratories
The results in this report apply to the samples analyzed in accordance with the chain of
custody document. This analytical report must be reproduced in its entirety.
Page 6 of 6
Evan Holloway, Quality Assurance Manager
Page 51 of 55
Figure 6 – Nonconformance Report Form
APEX LABORATORIES NONCONFORMANCE FORM
Severity (circle one):
1 2 3 -
1
2
3
Needs signatures of analyst and one QA/QC/TD person w/ documentation of decision.
Needs QA/QC review (discussion among QA/QC/TD) w/ initials of all involved,
documentation of decision and possible system modifications.
Needs actions indicated in level 2 with signature of laboratory manager and follow-up
to verify that system changes have been implemented.
Levels 1 & 2 need only 1st page, level 3 needs 2 pages.
Notification of Nonconformance:
Date:
Analyst/Department:
Nonconformance:
Root Cause:
Initial Corrective Action:
Samples Affected:
QC Affected:
Reviewed By / Date:
Comments:
(List Client(s), Work Order(s) and Sample(s) Affected)
(List Batch and Instrument QC Affected)
(Quality Assurance Department or Technical Manager / Date of review)
(Comments from QA Department or Technical Manager)
Page 52 of 55
Figure 6 – Nonconformance Report Form
Follow-up to Corrective (List further steps to be completed to remedy Nonconformance, only if a
Action:
level 3 nonconformance)
Target Completion Date:
Project Management Notification:
Project Manager
Comments:
(Comments from Project Manager, including documentation of client
notification, if applicable)
Subsequent Actions to be
(if applicable)
Taken:
Date of Reissued Report
(Date Amended Report sent to Client, if applicable)
Quality Assurance Approval:
QA Comments:
(Comments from Quality Assurance Department)
Subsequent Actions to be (if applicable)
Taken:
Corrective Action
Completed?
QA Approval:
Date:
Laboratory Manager Approval:
Laboratory Manager:
Date:
Additional Comments:
Page 53 of 55
Footnote#: 2003 NELAC Standard Section # : NELAC Checklist #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
5.4.2.2.a, .b & .e
5.4.1.1 & 5.4.2.2
5.4.2.2 & 5.4.2.2c
5.1.1, 5.4.1.2
5.4.1.5.a
5.4.2.1 & 5.4.2.3
5.1.1
5.4.2.1 & 5.4.2.2d
5.4.2.6, 5.4.2.6.1-2
5.4.1.4.b
5.4.1.4.b, 5.4.1.5.c & d
5.4.2.3.i, 5.4.4.1 & 5.4.4.2
5.4.2.3.h
5.4.4.2
5.4.4.5
5.4.4.4 & 5.4.4.5
5.4.7
5.4.2.3.q & 5.4.8
5.4.1.4
5.4.1.3
5.4.1.5.e, .i.2
5.4.1.5.f. & g
5.4.1.5.f.
5.4.2.3.e.
5.4.1.5.j
5.4.1.5.i., 5.4.2.4
5.4.1.5.i.1-.6
5.4.2.5
5.4.1.5.h
5.4.1.5.h
5.4.1.5.h, 5.4.2.4
5.4.2.3.t
5.4.2.3.l
5.4.1.3
5.4.2.3.m
5.4.2.3.k
5.5.10.5
5.5.4.1.1a
5.4.2.3.j
5.5.5.2.2.1.i
5.4.2.3.m
5.5.5.2.1.a
5.4.2.3.l
5.5.5.2.1.a
5.4.2.3.n
5.4.2.3.o,p, 5.4.9.1
5.4.9.1.b
5.4.2.3.p
5.4.10.1
5.4.9.1. & 5.4.9.1.a
5.4.9.1.e
5.4.9.1.c
5.4.9.1.d
5.4.10.3
5.4.9.1., 5.4.9.1.a, 5.4.9.2, 5.4.10.2 & 5.4.10.6.a 1-3
5.4.10.3
5.4.10.4
51, 52, 55
17, 50
49, 53
2, 18
23
46, 47, 56, 57, 59
2
48, 54
82-88
22, 25
24, 26, 27
66, 105-112
65
113
116 & 117
115 & 119
134
74, 135 & 136
20, 21
19
28, 38, 60
30, 31
30
62
44
36, 80
37-42
81
35
33
32, 80
77, 234-250
69
19
70
68
521-523
288
67, 70
380
70
356
69, 71
356
71
72, 73, 137-139
140
73
145
138, 139
143
141
142
147
138, 139, 144, 146, 154
148-150
151
Page 54 of 55
Footnote#: 2003 NELAC Standard Section # : NELAC Checklist #
58
59
60
61
62
63
64
65
66
67
68
5.4.10.6.a
5.4.10.5
5.4.12.2.5.2.a-h
5.4.12
5.4.12.1.1, 5.4.12.1.2, 5.4.12.2.4.e
5.4.12.1.1
5.4.12.2.5.3.a-n
5.4.12.1.2, 5.4.12.1.5.a, d & e, 5.4.12.2.1, 5.4.12.2.2
5.4.12.1.5.d & f, 5.4.12.2.3
5.4.12.1.5.f, 5.4.12.2.3
5.4.2.3.g, 5.4.12, 5.4.12.1.2, 5.4.12.1.5,
5.4.12.2.4.b & 5.4.12.2.1
69 5.4.12.1.5.b & 5.4.12.2.1
70 5.4.12.1.5
71 5.4.12.1.5.c
72 5.4.12.2.4.d
73 5.4.12.1.1 & 5.4.12.2.5.4.a-c
74 5.4.12.3
75 5.4.12.2.4.e
76 5.4.12.2.4.a
77 5.4.12.2.4.f
78 5.4.2.3.d
79 5.4.3.1
80 5.4.3.2.2.b
81 5.4.3.2.3
82 5.4.3.2.1, 5.4.3.2.2.c
83 5.4.3.2.2.d
84 5.4.3.2.1
85 5.4.3.2.1
86 5.4.3.3.1
87 5.4.3.3.1
88 5.4.3.3.4
89 5.4.12.1.4
90 5.4.12.2.4.b
91 5.4.12.2.4.c
92 5.4.13.1, 5.4.2.3.s
93 5.4.13.1
94 5.4.13.1
95 5.4.13.4
96 5.4.13.3
97 5.4.13.3
98 5.4.13.2
99 5.4.2.3.n
71
1005.4.1.5.k
1012.5
1022.5
1032.5.2
1042.5
1052.5.1a
1062.5.1b
1072.5.1c
1085.4.1.5.i.7, 5.4.14.1, a-j, 5.4.14.2
153
152
208
161
164, 167, 168, 202
164
209
166, 174, 178, 179, 187-189
177, 180, 181, 183, 190, 192, 193
182, 184, 191
64, 160, 162, 169, 172, 185-188, 196-197
175, 185, 187
173
176
200
165, 210
170, 171
201
194
203
61
89
94
97
91, 95
96
92-93
90
98, 100
99, 103
104
171
198
199
76, 211, 212
217
215, 216
221
219
220
213, 214, 218
45
3, 4, 5, 7
8, 9, 10
16
11
12
13
14, 15
43, 222 - 231
Page 55 of 55
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