boeing renton factory source investigation study sampling plan

Prepared for

The Boeing Company

N 6th St

Renton, WA 98057

Boeing Renton Factory

Source Investigation Study

Sampling Plan

Renton, WA

Prepared by

920 SW Sixth, Suite 600

Portland, OR 97204

Project Number: PNW0434B

September 2020

Boeing Renton Source Investigation Sampling Plan ii September 2020

TABLE OF CONTENTS

1 INTRODUCTION .................................................................................................... 1

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

1.2 Background and Regulatory Context ......................................................... 2

1.3 Study Area ................................................................................................ 2

2 NEED FOR SOURCE INVESTIGATION ............................................................... 3

2.1 Source Investigation Sampling Locations .................................................. 4

2.2 Parameters to be Sampled ......................................................................... 6

3 SAMPLING PROTOCOL ........................................................................................ 6

3.1 Health and Safety ...................................................................................... 7

3.1.1 Field Safety ................................................................................... 7

3.2 Event Criteria and Goals ........................................................................... 8

3.2.1 Storm Event Criteria ...................................................................... 8

3.2.2 Dry Event Criteria ......................................................................... 8

3.3 Sampling Methods .................................................................................... 8

3.3.1 Determining Flow in Dry Events ................................................... 8

3.3.2 Grab Samples ................................................................................ 9

3.3.3 Field Measurements .................................................................... 10

3.3.4 Field Duplicates .......................................................................... 10

3.4 De-mobilization ...................................................................................... 11

4 ANALYTICAL SUITE .......................................................................................... 11

5 REPORTING ......................................................................................................... 12

6 REFERENCES ....................................................................................................... 13

Boeing Renton Source Investigation Sampling Plan iii September 2020

LIST OF FIGURES

Figure 1: Site Overview .............................................................................................. 16

Figure 2: Current Storm Drain Network Overview ...................................................... 17

Figure 3: Proposed Treatment Areas ............................................................................ 18

Figure 4: Proposed Sampling Locations Overview ...................................................... 19

Figure 5: Proposed Sampling Locations, Northern Side ............................................... 20

Figure 6: Proposed Sampling Locations, Southern Side ............................................... 21

LIST OF ATTACHMENTS

Attachment A: Field Note Forms

Attachment B: Data Quality Assurance and Control

Boeing Renton Source Investigation Sampling Plan 1 September 2020

1 INTRODUCTION

The Boeing Company’s (Boeing’s) Renton Factory (Site) is responding to a 2019

Industrial Stormwater General Permit (ISGP) Level 2 corrective action trigger related to

elevated turbidity measurements at the Site’s Outfall 004. Due to a previously planned

construction project which will reconfigure the drainage areas to several outfalls at the

Site, including Outfall 004 (Apron R Project), Boeing is choosing to implement a Level 3

corrective action rather than the required Level 2 corrective action. As part of the

requirements for a Level 3 corrective action, Boeing is required to submit an Engineering

Report for approval by the Washington State Department of Ecology (Ecology).

In addition, Boeing is proposing two additional studies to inform the design and

maintenance requirements of the proposed corrective action. This document, which

presents a sampling plan for a source investigation at the Site, represents one of those

proposed studies.

This sampling plan is meant to inform and verify Boeing’s understanding of the sources

of turbidity in discharges to Outfall 004, the substantially similar Outfall 003, and other

nearby drainage basins. As such, this plan includes details on sampling protocols,

parameters to be measured, and documentation of field activities.

1.1 Objectives

Data collected as part of this project will include both wet and dry weather samples, which

will be used to characterize and determine the origin of turbidity and total suspended

solids (TSS) in stormwater discharges from the Site.

Specific objectives of the investigation are to:

• Inform and confirm Boeing’s understanding of the hydrological process in this

area of the Site;

• Identify turbidity source areas and further assess the relationship between iron,

TSS, and turbidity;

• Locate hot spots for groundwater intrusion, which, if identified, Boeing may

choose to mitigate with future capital improvement projects;

• Verify that the treatment BMPs identified in this Engineering Report are in areas

that would be effective at reducing turbidity at the outfall;


• Inform Boeing’s understanding of turbidity loading to the proposed treatment

BMPs, thereby informing necessary maintenance intervals.

1.2 Background and Regulatory Context

The Site’s stormwater discharges are covered under the ISGP (WAR000232), which, at

the time the corrective action was triggered, contained benchmarks for turbidity, pH, oil

sheen, total copper, and total zinc. The Site’s stormwater outfalls must be sampled and

analyzed for the stated parameters at the specified sampling locations on a quarterly basis.

Permittees are required to institute corrective actions in response to any quarterly average

sample concentration above a permit benchmark. If two quarterly average concentrations

are above the same benchmark parameter in the same drainage basin, a Level 2 Corrective

Action is required.

In 2019, sampling at Outfall 004 resulted in two quarterly averages with turbidity

concentrations above the ISGP turbidity benchmark, triggering a Level 2 Corrective

Action. Because Outfall 004 is sampled as representative of Outfall 003, the corrective

action must apply to both Outfalls 003 and 004.

The proposed corrective action in response to the 2019 turbidity exceedances includes

the installation of manufactured Modular Wetlands System (MWS) Linear units which

will passively treat stormwater flows in drainage areas to Outfalls 003 and 004. MWS

Linear units are a treatment best management practice (BMP), as required for a Level 3

corrective action, rather than a structural source control BMP as required for a Level 2

corrective action. As such, Boeing has met and exceeded the corrective action

requirements established in the ISGP. Detailed descriptions of the proposed corrective

action as well as justification for selection are provided in the Engineering Report.

1.3 Study Area

The study area is approximately 38 acres in size and is nearly 100% impervious (Figure

1). It includes the entire drainage area to Outfall 004 at the time the corrective action was

triggered (2019). The study area also includes the entire drainage area to Outfall 003 at

the time the corrective action was triggered. Figure 2 shows the drainage area pertaining

to each Outfall at the time the corrective action was triggered.

Stormwater from the study area generally drains north toward Lake Washington and

discharges at Outfalls 004 and 003. The invert elevation of both outfalls is at the

spring/fall lake surface elevation, and it is submerged nearly 100 percent of the time. The


ISGP outfall for compliance purposes is Outfall 004, which is sampled from the last

manhole upstream of the outfall on Boeing property (SDMH-458).

The study area consists of the subbasins listed in Table 1, which also describes the general

use of the areas.

Table 1: Study Area Subbasins

Current

Outfall Subbasin1 Description of Area Activities

004 27A Roof of building 4-81

004 27B Material staging, vehicle traffic

004 27C Employee parking, vehicle traffic

004 27E Employee parking, vehicle traffic, roof of building 4-90

004 27F Roof of building 4-04, vehicle traffic, material staging and

forklift operation

004 27H Aircraft parking, vehicle traffic

004 27I Roof of maintenance building, aircraft parking, material

staging and forklift operation

003 26A (28A) Vehicle traffic, aircraft traffic

003 26B (26) Roof of buildings 4-81 and 4-82 1The names of some subbasins will change with the Apron R Project. In these cases, the current name is

listed with the future name listed in parentheses next to the current name.

2 NEED FOR SOURCE INVESTIGATION

The Site’s storm drain network is impacted by inflows of both groundwater and lake

water. Groundwater levels are typically within 5 feet of ground surface elevations, and

much of the storm drain network is below the groundwater table. Soils typical of the area

characteristically contain deposits of iron and manganese at relatively shallow depths.

When submerged under a high groundwater table, reducing environments can mobilize

iron in the groundwater. When re-exposed to oxygen, for example, as groundwater enters

a storm sewer system, the iron can precipitate, causing higher turbidity in the mixed


water. A 2020 technical memo submitted to Ecology on behalf of Boeing as part of a

Request for Permit Modification (Geosyntec, 2020) details this further. This study is

designed to determine the extent to which elevated turbidity at Outfalls 003 and 004 can

be contributed to groundwater inflows.

As described in the Engineering Report, the proposed corrective action will not treat four

subbasins which are not thought to contribute to elevated turbidity in stormwater

discharges Outfalls 003 and 004 (27A, 27E, 27F, and 26B; Figure 3). These basins consist

mostly of rooftop (see Section 1.3) and upland area where the storm drains lie above the

groundwater table. This source investigation study will confirm that the proposed

treatment BMPs are located in areas that will effectively reduce the turbidity at the

outfalls.

2.1 Source Investigation Sampling Locations

To assess contributing sources of turbidity in the study area, nine sampling locations

within the storm system were identified through a desktop analysis of drainage maps,

CAD files, and previous reports. Locations were selected for dry and wet weather sample

collection to provide information on 1) areas believed to be most likely to contribute to

elevated turbidity at Outfalls 003 and 004, 2) areas tributary to proposed treatment BMPs,

and 3) the influence of groundwater intrusion in the Site’s storm sewer network. Special

consideration was given to areas that will not receive treatment from the proposed

corrective action (see the Engineering Report and Figure 4) to verify that these areas are

not significant sources of turbidity. Sampling locations are presented in Table 2. Maps of

the locations can be found in Figure 4 through Figure 6.


Table 2: Sample Locations

Sampling

Basin1

Boeing

Structure ID2

Wet or Dry

Sample

Location?

Reason for Selection

27C SDMH-527 dry Represent potential baseflow from

upland areas

27E SDMH-515C wet

Represents vehicle parking and

transportation, roof of building 4-90

(not to be treated)

27F SDMH-506 wet Represents roof of building 4-04 (not

to be treated)

27H SDMH-466 both Represents area tributary to future

RTU 17/18

27I SDMH-490G-

14 dry

Represents area tributary to future

RTU 17/18

27F SDMH-464 dry

Represents dry weather flow from

majority of Outfall 004 drainage

network

27A (or

26B)

SDMH-459 (or

SDMH-455) wet

Represents roof of building 4-82/4-82

(not to be treated)

26A CB-454 wet Represents area tributary to future

RTU 15

27I CB-490 wet Represents area tributary to future

RTU 13/14 1Sampling basin refers to current stormwater drainage delineations (pre-Apron R project)

2The designated names of some storm drain features is not clear at this time. This information will be

clarified prior to the start of sampling. If existing names cannot be determined, names will be assigned

to ensure consistency and clarity of sample labels and results.

Sampling locations are subject to change based on an initial site walk at the start of the

source investigation study. The Site is currently under phased construction of a major

infrastructure maintenance and repair project known as the Apron R Project

(BergerABAM, 2018), which may impact the storm sewer network layout and/or

accessibility of sampling locations. However, the general areas represented by the

sampling points in Table 2 will be maintained to the extent possible.


2.2 Parameters to be Sampled

Turbidity, TSS, and volatile suspended solids (VSS) are the primary constituents of

concern for this sampling plan. Additional parameters, including iron (Fe), manganese

(Mn), redox potential, and dissolved oxygen (DO) have been identified to assist in flow

source identification (i.e., groundwater versus stormwater). The following parameters are

to be sampled:

• Total Suspended Solids (TSS) by SM 2540D (American Public Health

Association, 2018)

• Total Volatile Suspended Solids (TVSS) by SM 2540 E-97 (American Public

Health Association, 2018)

• Total and dissolved manganese by EPA Method 6010C (EPA, 2007)

• Total and dissolved iron by EPA Method 6010C (EPA, 2007)

• Turbidity by field meter

• Oxidation-reduction potential (ORP) by field meter

• Dissolved oxygen (DO) by field meter

3 SAMPLING PROTOCOL

Identification of a potential sampling event, and then preparing for and collecting samples

during an event should follow these general steps:

1. Check the forecast to identify a potential qualifying event (see Section 3.2) within

the next 72 hours. If an event (dry or wet) is identified, identify available sampling

team members.

2. Continue to check forecasts to confirm that the event is still predicted to occur. If

not, notify crews; if the event is still predicted, move to step 3 at least 24 hours in

advance.

3. Gather and check necessary supplies, including the appropriate number of Field

Note Forms, and secure vehicles and equipment.

4. Randomly determine from which location to collect a field duplicate (see

Section 3.3.4; the field duplicate should not come from the same location for

every event). Label and distribute sample bottles, coolers, and Field Note Forms.

5. Perform sampling following the recommended standards and methods.


a. If sampling a wet weather event, ensure that the site is clearly experiencing

runoff (sites are in stormwater runoff conditions as compared to dry-

weather flows).

b. If sampling a dry weather event, check for flows in the drainage network

at the sampling points. Determine if there is flow following Section 3.3.1.

Note that many of the sampling locations would not be expected to have

flow during dry weather.

6. Ensure samples are in cooler(s) on ice, and chain of custody forms are completed

and placed with appropriate samples.

7. Submit the samples to the laboratory for testing (or schedule for courier pick-up).

8. Clean all equipment and order any supplies/equipment necessary for the next

sampling event (e.g., distilled water, gloves, bottles, etc.).

9. Send a copy of all field notes and forms to the Project Manager.

10. All sampling results should be sent directly from the laboratory to the Project

Manager; designated Boeing staff will be copied on lab results.

3.1 Health and Safety

All sampling teams should follow company health and safety policies/procedures.

3.1.1 Field Safety

Sampling team members should wear gloves, high-visibility clothing, and safety-toed

boots. Note that it may be necessary to barricade some parking spaces the day prior to a

forecasted qualifying event to ensure accessibility of stormwater structures (manholes,

inlets, etc.) for sampling during the storm.

Work will occur around manholes and inlets, which have limited means of entry and

egress and may contain hazardous gases. Boeing company safety policies should govern

safety procedures and training requirements for work near these locations.

To assist with safety, sampling, and documentation, the sampling crew shall include a

minimum of 2 staff members.


3.2 Event Criteria and Goals

3.2.1 Storm Event Criteria

Six locations will be sampled for each wet weather event. Three to four storm events are

targeted for sampling at each location.

Potential storm sampling events should be identified as events when rainfall is forecast

to be at least 0.2 inches over a 6-hour period. Ideally, sampling events should be separated

by 48-hours of dry weather (defined as less than 0.1 inches of rainfall over 48 hours).

Samples must be taken while it is actively raining and runoff is being produced. Ideally,

sampling should occur within the first 3 hours of the storm event; however, it is important

that each location is clearly showing runoff conditions when sampled.

3.2.2 Dry Event Criteria

To assess the extent of groundwater intrusion in the drainage system, four locations

within the storm sewer network will be inspected and sampled during dry weather events.

A minimum of two dry weather events is targeted. The dry sampling events should be

temporally spaced; one in the late fall or winter and one in the spring.

The outcome of dry events will be recorded observations of the presence or absence of

water in the storm drain network and estimated water depth. In addition, samples will be

analyzed for all the parameters described in Section 4 for each location at which water is

present in the storm sewer.

Potential dry weather sampling events should be identified as periods following at least

3 days of no recorded precipitation.

3.3 Sampling Methods

The same sampling methods described apply to wet weather flows and any dry weather

flows observed during dry event sampling.

3.3.1 Determining Flow in Dry Events

Because Outfall 004 and some of the storm sewer network are below normal lake

elevations, it is possible that water found in the storm sewer network during dry events

could be attributed to backwatering from Lake Washington. For dry events, field


personnel should record how any water present in the system is moving; if it is difficult

to determine visually, one end of a string or other object may be held in the water to

determine the presence or absence of flow, as well as flow direction.

In addition, the time at which observations are taken will be noted. If possible, the lake

surface elevation at the time of sampling will be compared to the invert elevation of the

sampling point. Hourly lake elevation data can be found through the US Army Corps of

Engineers Reservoir Control Center (Water Management, 2013). Finally, the dry weather

sampling data will provide valuable clues as to the presence of lake water versus

groundwater.

3.3.2 Grab Samples

Sampling should follow Ecology guidance for stormwater grab samples (Ecology, 2015).

This guidance includes:

1. Samples should be taken from a well-mixed area of flow near the center of the

flow stream, and with the flow directed into the bottle opening;

2. Bottles should not touch the sides or bottom of the manhole or catch basin;

3. Bottle caps should not touch the ground; and

4. Clean gloves and equipment should be used at each sample location.

Should any of the aforementioned sampling methods be violated, the sample bottle should

be discarded, and a new sample bottle should be used. A detailed list of equipment and

more detailed methods will be provided to the sampling team.

When possible, grab samples should be collected directly into laboratory-provided

bottles. If not possible, samples should be collected using a clean container and

transferred directly into laboratory bottles by careful pouring. Containers will be

considered clean when they have been rinsed a minimum of two times with deionized

(DI) water and once with stormwater from the next sampling location.

Sample bottles should be appropriately labeled with the Structure ID (Table 2), date, and

time. Two, 1-liter laboratory bottles and two, 500-milliliter laboratory bottles will be

collected from each site (Table 3). Samples will be field filtered as appropriate.

At each sampling location, for both wet and dry weather events, appropriate Field Note

Forms (Appendix A) should be completed. Pictures may be taken to support any special


notes listed on the field forms. If pictures are taken, this should be documented on the

field form.

Samples should be stored in a cooler with ice or ice packs no higher than 2 inches from

the top of the bottles before being submitted to the laboratory. Samples will be preserved

and filtered as needed by the laboratory; holding time before submission to the laboratory

should be no more than 48 hours. A completed chain of custody (COC) form should be

submitted to the laboratory with each cooler.

3.3.3 Field Measurements

Wet and dry weather samples will be analyzed in the field for turbidity, dissolved,

oxygen, and oxidation-reduction potential (ORP) using field instruments. The general

process for taking field measurements is as follows; a more detailed procedure will be

provided to the sampling team.

• Gather and prepare necessary equipment.

o Prepare the meter according to the manufacturer’s directions.

o Calibrate the meter according to the manufacturer’s directions.

• Collect the sample in a glass or plastic bottle that has been thoroughly rinsed with

DI water. The volume should be sufficient to ensure a representative sample.

• Analyze the sample according to the manufacturer’s directions.

o If the sampling apparatus contains a probe, insert the probe into the sample

and allow it to reach equilibrium.

• Record the result on the field sheet and repeat for each sampling location.

3.3.4 Field Duplicates

One field duplicate should be obtained for each event. A field duplicate is obtained by

collecting two field measurements and two laboratory samples for each parameter from

a randomly selected sampling point. The duplicate sample should be collected as close to

the same time as the regular sample as possible and should include the same number and

type of bottles as the sample itself. The duplicate sample will have a different label than

the normal sample and should not include the sample time.

The sampling team should note from which sampling point the duplicate was taken on

the corresponding Field Note Form.


3.4 De-mobilization

After samples have been collected, return to sampling de-mobilization area to:

• sort bottles for transfer to laboratory,

• dispose of consumable sampling supplies, and

• finalize COC forms.

Note the number of bottles remaining for the next event and order the appropriate number

of bottles needed from the laboratory.

4 ANALYTICAL SUITE

Table 3 provides laboratory methods and requirements. Two, 1-liter sample and two, 500-

milliliter samples will be collected from each sampling point at each wet weather

sampling event and at one dry weather sampling event. Dissolved samples will be filtered

in the field. Further detail is provided in the Data Quality Assurance and Control Plan

(Appendix B).


Table 3: Stormwater Collection Techniques and Constituent Analytical Methods

Total Suspended Solids by Method SM2540D – Water Samples

Collection Technique

Grab sample. Collect sample directly into sample container

for lab analysis. Do not freeze, do not preserve. Refrigerate

at ≤6°C.

Volume Required 1 liter

Maximum Sample Holding

Time 7 days

Total Volatile Suspended Solids by Method SM2540-E-97 – Water Samples

Collection Technique

Grab sample. Collect sample directly into sample container

for lab analysis. Do not freeze, do not preserve. Refrigerate at

≤6°C.

Volume required 1 liter


Time 7 days

Total and Dissolved Iron and Manganese by EPA Method 6010C– Water Samples

Collection Technique Grab sample. Preserve with nitric acid – any filtering should

be done prior to acid preservation. Refrigerate at ≤6°C.

Volume required 500 mL for each of total and dissolved analyses


Time 6 months preserved

5 REPORTING

After completing field activities, copies of Field Note Forms and relevant photos should

be sent to the Project Manager. Geosyntec and designated Boeing staff should be copied

on all laboratory communications.


6 REFERENCES

American Public Health Association (2018). 2540 SOLIDS (2017) In Standard Methods

for the Examination of Water and Wastewater. Standard Methods for the

Examination of Water and Wastewater.

https://doi.org/10.2105/SMWW.2882.030

American Public Health Association (2017). 2580 OXIDATION-REDUCTION

POTENTIAL (ORP) (2017). In Standard Methods for the Examination of

Water and Wastewater. Standard Methods for the Examination of Water and

Wastewater. https://doi.org/10.2105/SMWW.2882.034

American Public Health Association (2017). 3500 -Fe IRON (2017) In Standard Methods

for the Examination of Water and Wastewater. Standard Methods for the

Examination of Water and Wastewater.


American Public Health Association (1992). EPA Method 180.1. Standard Methods for

the Examination of Water and Wastewater. 18th ed. Washington, D.C.

https://archive.epa.gov/water/archive/web/html/vms55.html

BergerABAM, 2018. Technical Information Report: Boeing Commercial Airplanes

Apron R Infrastructure Maintenance and Repair, Renton, WA. October.

Creed, J.T., C.A. Brockhoff, and T.D. Martin (1994). Method 200.8: Determination of

Trace Elements in Waters and Wastes by Inductively Coupled Plasma – Mass

Spectrometry. Environmental Monitoring Systems Laboratory Office of

Research and Development, U.S. Environmental Protection Agency. Revision

5.4, EMMC Version. https://www.epa.gov/sites/production/files/2015-

06/documents/epa-200.8.pdf

Ecology (2015). Stormwater Sampling Manual: A Guide for the Industrial Stormwater

General Permit. Publication No. 15-03-044. December.

https://fortress.wa.gov/ecy/publications/documents/1503044.pdf

EPA (1993). Method 180.1: Determination of Turbidity by Nephelometry. Revision 2.0

August. https://www.epa.gov/sites/production/files/2015-

08/documents/method_180-1_1993.pdf




https://archive.epa.gov/water/archive/web/html/vms55.html

https://www.epa.gov/sites/production/files/2015-06/documents/epa-200.8.pdf

https://www.epa.gov/sites/production/files/2015-06/documents/epa-200.8.pdf

https://fortress.wa.gov/ecy/publications/documents/1503044.pdf

https://www.epa.gov/sites/production/files/2015-08/documents/method_180-1_1993.pdf

https://www.epa.gov/sites/production/files/2015-08/documents/method_180-1_1993.pdf


EPA (2007). Method 6010C (SW-846): Inductively Coupled Plasma-Atomic Emission

Spectrometry. Revision 3.

Washington State Department of Health, 2018. DOH-337-160 Standard Operating

Procedures for Measuring Dissolved Oxygen: A Guide to Field Measurements

Using an Optical Dissolved Oxygen Meter and other Handheld Meters.

Wastewater Management Program.

https://www.doh.wa.gov/Portals/1/Documents/Pubs/337-160.pdf

Water Management, USACE-Seattle District, 2013. Reservoir Control Center-Lake

Washington Elevation. https://www.nwd-

wc.usace.army.mil/nws/hh/www/index.html#

WSP, 2020. Draft Technical Information Report: Boeing Commercial Airplanes Apron

R – Central, Renton, WA. March.

https://www.doh.wa.gov/Portals/1/Documents/Pubs/337-160.pdf

https://www.nwd-wc.usace.army.mil/nws/hh/www/index.html

https://www.nwd-wc.usace.army.mil/nws/hh/www/index.html


FIGURES


Figure 1: Site Overview


Figure 2: Current Storm Drain Network Overview


Figure 3: Proposed Treatment Areas


Figure 4: Proposed Sampling Locations Overview


Figure 5: Proposed Sampling Locations, Northern Side


Figure 6: Proposed Sampling Locations, Southern Side


ATTACHMENT A

Field Note Forms

Storm Sewer Sampling Field Form Sampling Event Form

UPON ARRIVAL

Sample Team Number: Date:

Location ID: Time:

Team Member Initials:

PRIOR TO SAMPLING

Is it currently raining on site? How heavy is the flow at time of sampling? Yes No

Is there flow to and from all pipes in the structure? (if no, describe in notes)

Trickle Moderate

Yes No Steady/Low Turbulent/Heavy

FIELD SAMPLING RESULTS Dissolved Oxygen Turbidity Oxidation-Reduction Potential

Type/Model of Meter: Type/Model of Meter: Type/Model of Meter:

Measured Value: Measured Value: Measured Value:

AFTER SAMPLING

Sample vessel (e.g. direct to field bottle, pole with dipper): Were any bottles discarded?

Yes No

Iron staining on structure? If yes, describe.

Yes No

Note any deviation from methods advised in sampling plan:

Clarity of sample:

Clear (low solids) Moderate Dirty (high solids)

ADDITIONAL NOTES

Was a duplicate taken here? Were any photographs taken?

Storm Sewer Observation Field Form Dry Weather Observation Form

UPON ARRIVAL

Sample Team Number: Date:

Location ID: Time:

Team Member Initials:

FIELD OBSERVATIONS

Is it currently raining on site? Yes No

Is there water present in the storm sewer system at this location? Yes No

If yes, describe (i.e. which pipes have water) and estimate water depth in pipes.

If water is present, is it moving? Yes No

If yes, how fast? Trickle Moderate

Steady/ Low Turbulent/ Heavy

If yes, which direction? Upstream Downstream

How can you tell? (ripples, string test, etc.)

If yes, describe (i.e. which pipes have flow and which do not)

Is there iron staining on the structure? Yes No

If yes, describe (i.e. where, how much)

ADDITIONAL NOTES

Were any photographs taken? Were samples taken here? (also complete sampling event form)


ATTACHMENT B

Data Quality Assurance and Control


Quality Assurance Objectives for Data Management

The general quality assurance (QA) objectives for this project are to develop and

implement procedures for obtaining and evaluating data of a specified quality that can be

used to assess the concentrations of total and dissolved iron, total manganese, and TSS in

collected samples. To collect such information, analytical data must have an appropriate

degree of accuracy and reproducibility; samples collected must be representative of actual

field conditions and must be collected and analyzed using unbroken chain-of-custody

procedures.

The target method reporting limit (MRL) for each analyte is listed in Table E-1. Actual

MRLs will depend on what the laboratory can achieve given laboratory quality

assurance/quality control (QA/QC) and potential matrix interferences.

Table E-1: Data Quality Objectives for Proposed Analytes

Analyte Units MRL1

Total and Dissolved Fe and Mn by EPA Method 6010C – Water Samples

Iron mg/L 0.050

Manganese mg/L 0.001

Total Suspended Solids (TSS) by EPA Method SM2540 D – Water Samples

TSS mg/L 1.00

Total Suspended Solids (TSS) by EPA Method SM2540 E – Water Samples

VSS mg/L 1.00 1MRL = Method Reporting Limit

Specific QA objectives are as follows:

• Establish sampling techniques that will produce analytical data representative

of the media (e.g., stormwater) being measured.

• Analyze a sufficient number of analytical duplicate samples to assess the

performance of the analytical laboratory.

• Collect and analyze a sufficient number of blank samples to evaluate the

potential for contamination from sampling equipment and techniques, and/or

transportation.


• Analyze a sufficient number of blank, standard, duplicate, spiked, and check

samples within the laboratory to evaluate results against numerical QA goals

established for precision and accuracy.

Precision, accuracy, representativeness, completeness, and comparability parameters

used to indicate data quality are defined below.

Precision

Precision is a measure of the reproducibility of data under a given set of conditions.

Specifically, it is a quantitative measure of the variability of a group of measurements

compared to their average value. For duplicate measurements, precision can be expressed

as the relative percent difference (RPD). Five to ten percent field duplicates will be

collected. A five to ten percent duplicate frequency will be carried out for laboratory

samples.

Accuracy

Accuracy is the measure of error between the reported test results and the true sample

concentration. True sample concentration is never known due to analytical limitations

and error. Consequently, accuracy is inferred from the recovery data from spiked samples.

Because of difficulties with spiking samples in the field, the laboratory will spike

samples. The laboratory shall perform sufficient spike samples of a similar matrix to

allow for computation of accuracy. For analyses of less than five samples, matrix spikes

may be performed on a batch basis. Perfect accuracy is 100 percent recovery.

Representativeness

Representativeness is a measure of how closely the results reflect the actual concentration

of the chemical parameters in the medium sampled. Sampling procedures—as well as

sample-handling protocols for storage, preservation, and transportation—are designed to

preserve the representativeness of the samples collected. Proper documentation will

confirm that protocols are followed. This helps to assure sample identification and

integrity.

Laboratory method blanks will be run in accordance with established laboratory protocols

to ensure samples are not contaminated during sample preparation in the laboratory.

Completeness


Completeness is defined as the percentage of measurements made which are judged to be

valid. It is calculated as the number of valid data points achieved divided by the total

number of data points requested by virtue of the study design. For this project,

completeness objectives have been established at 95 percent.

Comparability

Comparability is a qualitative parameter expressing the confidence with which one data

set can be compared with another. The objective of this QA program is to assure that all

data developed during the investigation are comparable. Comparability of the data will

be assured by using EPA-defined procedures which specify sample collection, handling,

and analytical methods. The comparability of past data will be evaluated during the

investigation (if possible) by assessing the techniques used for sample collection and

analysis.

Documentation

Essentially, EPA Level II documentation will be generated during this investigation. This

level of documentation is generally considered legally defensible and consists of the

following:

• Holding times

• Laboratory method blank data

• Sample data

• Matrix/surrogate spike data

• Duplicate sample data

Sampling Procedures

Sampling procedures are designed to ensure:

• Samples collected at the site are consistent with project objectives; and

• Samples are identified, handled, and transported in a manner that does not alter

the representativeness of the data from the actual site conditions.

QA objectives for sample collection will be accomplished through a combination of the

following items:


• Trip Blank. No trip blanks are planned for the stormwater sampling program as

there are no planned analyses for volatile organic compounds (VOCs).

• Rinse Blank Sample. No rinse blanks are planned for the sampling program as

the parameters analyzed are not sensitive to minor impurities from sampling

containers.

• Filter Blank Sample. No filter blanks are planned for the sampling program as

the parameters analyzed are not sensitive to minor impurities from filter

materials.

• Duplicate Samples. One field duplicate is planned for each sampling event.

This will consist of a duplicate measurement of all field measurements and a

duplicate sample of all laboratory parameters at a single sampling location per

event.

• Laboratory QA. Laboratory duplicate measurements will be carried out on at

least 5 percent of laboratory samples. Analytical procedures will be evaluated

using the protocols of the analytical laboratory. These protocols can be

submitted upon request.

Sample and Document Custody Procedures

The various methods used to document field sample collection and laboratory operation

are presented below.

Field Chain-of-Custody Procedures

Sample chain-of-custody refers to the process of tracking the possession of a sample from

the time it is collected in the field through the laboratory analysis. A sample is considered

to be under a person's custody if it is:

• In a person's physical possession;

• In view of the person after possession has been taken; or

• Secured by that person so no one can tamper with the sample, or secured by that

person in an area restricted to authorized personnel.

A chain-of-custody form is used to record possession of a sample and to document

analyses requested. Each time the sample bottles or samples are transferred between


individuals, both the sender and receiver sign and date the chain-of-custody form. When

a sample shipment is transported to the laboratory, a copy of the chain-of-custody form

is included in the transport container (e.g., ice chest).

The chain-of-custody forms are used to record the following information:

• Sample identification number

• Sample collector's signature

• Date and time of collection

• Description of sample

• Analyses requested

• Shipper's name and address

• Receiver's name and address

• Signatures of persons involved in chain of custody

Laboratory Operations

The analytical laboratory has a system in place for documenting the following laboratory

information:

• Calibration procedures

• Analytical procedures

• Computational procedures

• Quality control procedures

• Bench data

• Operating procedures or any changes to these procedures

• Laboratory notebook policy

Laboratory chain-of-custody procedures provide the following:

• Identification of the responsible party (sample custodian) authorized to sign for

incoming field samples and a log consisting of sequential lab tracking numbers.


• Specification of laboratory sample custody procedures for sample handling,

storage, and internal distribution for analysis.

Corrections to Documentation

Original data will be recorded in field notes and on chain-of-custody forms using indelible

ink. Documents will be retained even if they are illegible or contain inaccuracies that

require correction.

If an error is made on a document, the individual making the entry will correct the

document by crossing a line through the error, entering the correct information, and

initialing and dating the correction. Any subsequent error discovered on a document is

corrected, initialed, and dated by the person who made the entry.

Equipment Calibration Procedures and Frequency

Instruments and equipment used during this project will be operated, calibrated, and

maintained according to the manufacturer's guidelines and recommendations. Operation,

calibration, and maintenance will be performed by laboratory personnel fully trained in

these procedures.

Analytical Procedures

Samples will be analyzed using protocols for the parameters identified above. Table E-1

lists the data quality objectives for the proposed analytes including the target method

reporting limits (MRLs). Table 2 of the Sampling Plan summarizes the sample collection

requirements.

Data Reduction, Validation, and Reporting

Reports generated in the field and laboratory will be included as an appendix to the draft

and final versions of the Source Investigation Technical Memorandum.

The task manager will assure validation of the analytical data. The laboratory generating

analytical data for this project will be required to submit results that are supported by

sufficient backup and QA/QC data to enable the reviewer to determine the quality of the

data. Validity of the laboratory data will be determined based on the objectives outlined

in the Quality Assurance Objectives for Data Management section above. Data validity

will also be determined based upon the sampling procedures and documentation outlined

in this Sampling Plan. Upon completion of the review, the task manager will be


responsible for assuring development of a QA/QC report on the analytical data. Data will

be stored and maintained according to the standard procedures of the laboratory. The

method of data reduction will be described in the final report.

Performance Audits

Performance audits are an integral part of an analytical laboratory's SOPs and are

available upon request.

Corrective Actions

If the QC audit detects unacceptable conditions or data, the project manager will be

responsible for developing and initiating corrective action. The task manager will be

notified if the nonconformance is significant or requires special expertise. Corrective

action may include the following:

• Reanalyzing the samples, if holding time criteria permit;

• Resampling and analyzing;

• Evaluating and amending sampling and analytical procedures; or

• Accepting data and acknowledging level of uncertainty or inaccuracy by

flagging the data.