Quality Assurance Services Projects

TCEQ State Superfund QA Management

• Client: Various including Geo Strata-INTERA, APTIM Environmental & Infrastructure, and Tetra Tech
• Program: Texas State Superfund 
• Guidelines: TCEQ Quality Assurance Project Plan (QAPP) for the Superfund Programs (Document Control No. 200919.4 through Q-TRAK #: 14-453)
• Tests: Volatiles, BTEX/MTBE, Semivolatiles, PAH, TPH, Metals, Pesticides, PCBs, Herbicides, Methanol
• Samples: Over 1,500 soil, sediment, groundwater, surface water, NAPL, concrete, and sludge samples
• Function: QAA provided oversight and analytical expertise, assisted in preparation of Field Sampling Plans (FSPs), performed data review/ validation, and prepared Data Usability Summaries (DUS). QAA also submitted a detailed review of PCB chromatograms to the TCEQ for one particularly complicated project, which the agency deemed clear and helpful in establishing site conditions.

TCEQ TRRP-13 Data Review

• Client: Various including Trinity Environmental, ENTACT Services, Pastor, Behling, & Wheeler (now Golder), W.E.S.T., and Michael Pisani & Associates (an ERM Group company)
• Program: TCEQ TRRP (Texas Risk Reduction Program) 
• Guidelines: TCEQ Review and Reporting of COC Concentration Data (RG-366/ TRRP-13  December 2002)
• Tests: Volatiles, Semivolatiles, TPH, Metals, Pesticides, PCBs, Herbicides, Glycols, Organotin, Wet Chemistry (Nitrate, Sulfate, etc.)
• Samples: Over 1,000 soil, sediment, groundwater, and fish tissue samples
• Function: QAA completed the data review checklists per TRRP13 requirements and prepared a Data Usability Summary (DUS).

TCEQ PST Data Review

• Client: Geo Strata Environmental Consultants and Daniel B Stephens & Associates (State Lead Contractors)
• Program: TCEQ PST (Petroleum Storage Tank) 
• Guidelines: TCEQ PST Program Quality Assurance Project Plan (FY2009 to FY2019)
• Tests: BTEX/MTBE, TPH, Polycyclic Aromatic Hydrocarbons (PAH)
• Samples: Over 5,000 soil and groundwater samples
  
• Function: QAA completed a data review and prepared a Quality Assurance (QA) Summary.

LDEQ RECAP Environmental Data Validation and EDD Verification

• Site: Metals Production Facility; Lake Charles, LA
• Client: Tetra Tech
• Program: LDEQ RECAP (Louisiana's Risk Evaluation Corrective Action Program) 
• Guidelines: USEPA CLP National Functional Guidelines (NFG); USEPA Risk Assessment Guidance for Superfund (RAGS); and USEPA Guidance for Data Useability in Risk Assessment
• Tests: PAHs, PCBs, RCRA Metals, Volatiles, Semivolatiles, Toxicity Characteristics
• Samples: Over 1,100 soil, groundwater, sediment, and surface water samples
• Function: QAA completed the data validation and usability determination per RECAP requirements for the investigation of the site as directed in the Administrative Order. Due to the complex nature of the samples, which contain weathered mixtures of PCBs, numerous QC issues arose for this project. Through extensive communications with the laboratory, QAA was able to thoroughly document and investigate the analytical difficulties encountered and qualify the data accordingly. QAA's detailed reports allowed the user to understand and account for the data qualifications and as a result, the project  was able to proceed without re-sampling.

NYSDEC Data Usability Summary Reports (DUSR)

• Site: Heavy Industrial Manufacturing in New York State
• Client: ENTACT LLC
• Guidelines: New York State Department of Environmental Conservation (NYSDEC) DER-10 Technical Guidance for Site Investigation and Remediation (May 2010)
• Tests: Total Metals, Toxicity Characteristic Leaching Procedure (TCLP) Metals, Hexavalent Chromium, Volatiles, Semivolatiles, Pesticides, PCBs, Herbicides, Cyanide
• Samples: Over 1,000 soil samples
• Function: QAA completed a third party QA/QC data validation of chemical analysis data for backfill materials and remediation confirmation samples using NYSDEC Category B laboratory data deliverables. The validation procedures were derived from the U.S. EPA Contract Laboratory Program National Functional Guidelines for Inorganic Superfund Data Review (August 2014) and National Functional Guidelines for Superfund Organic Methods Data Review (August 2014) and the DUSR were prepared per the requirements of Appendix 2B of DER-10.

Quality Assurance Services for a Federal Superfund Site

• Site: Gulfco Marine Maintenance Federal Superfund Site (Freeport, Texas)
• Client: Pastor, Behling, & Wheeler (now Golder Associates)
• Program: CERCLA Superfund
• Tests: Volatiles, Semivolatiles, Metals, Pesticides, PCBs
• Samples: Over 500 soil, sediment, groundwater, surface water, and fish tissue samples
• Function: QAA prepared the Quality Assurance Project Plan (QAPP), provided analytical expertise to the environmental firm, coordinated with the laboratory, and completed the Level III or Level IV data validation (primarily electronic) of all samples. During the validation, QAA uncovered an error in the laboratory GC data system that resulted in the reporting of over 130 false positives for pesticides (i.e., the analyte was reported as present when actually not detected). This error was found and the laboratory submitted revised results before decisions were made using the erroneous results, which resulted in significant cost savings.

NPDES Permit Compliance Audit and Data Review

• Site: Offshore Drilling Platforms, Louisiana
• Client: Major oil company
• Program: NPDES Permit Compliance (Permit GMG290000 for Discharges of Synthetic Drilling Fluids)
• Guidelines: USEPA CLP National Functional Guidelines (NFG); USEPA Guidance on Evaluation, Resolution, and Documentation of Analytical Problems Associated with Compliance Monitoring (the "pumpkin" book)
• Function: QAA assisted the client in complying with the modification to permit GMG29000. QAA developed procedures and performed the first-ever audits of mobile laboratories on eight offshore drilling platforms. QAA also developed procedures and performed data validation of the mud certification laboratory results.

USEPA Region 4 Data Validation

• Site: Confidential Superfund Site in West Tennessee
• Client: Environmental Resources Management (ERM)
• Guidelines: USEPA CLP National Functional Guidelines for Organic Data Review (October 1999) and National Functional Guidelines for Inorganic Data Review (October 2004); USEPA Risk Assessment Guidance for Superfund (RAGS); and USEPA Guidance for Data Useability in Risk Assessment
• Tests: Volatiles, Semivolatiles (Appendix 9), Metals, Cyanide, Pesticides, PCBs, Herbicides, Formaldehyde, Carbaryl
• Samples: Approximately 220 soil, sediment, and groundwater samples
  
• ​Function: QAA performed a data validation and review of all data for this extensive analytical protocol, which included several analytes that are typically poor performers. The review included the upward adjustment of the reporting limits for several of these analytes, which accounted for low instrument response while allowing use of the data. Additionally, QAA worked with the laboratory in developing a method for GC/MS confirmation of suspect results for pesticides, which showed that several of the results initially confirmed by GC were actually false positives.

USEPA Region 2 Quick-Turnaround Data Validation

• Site: Pedricktown Superfund Site; Pedricktown, NJ
  
• Client: Entact Inc.
  
• Program: CERCLA
  
• Guidelines:  USEPA Region II SOP HW-6 for organics data; USEPA Region II SOP HW-2 for metals data; and USEPA Region II SOP No. HW-7 for TCLP data
  
• Tests: Total and TCLP Metals (Lead), Semivolatile Organics (SVOC), Volatile Organics (VOC)
  
• Samples: over 1000 soils and 40 waters
  
• Function: After developing procedures approved by the agency, QAA performed the data validation, review, and suitability determination for all samples at this site. Due to limited space at the site, most of the work required a 24-hour turnaround so that the stabilized material could be immediately disposed of off-site. QAA met this schedule for over 2 years.

Total Quality Assurance Services for a Superfund Site

• Site: French Limited Superfund Site; Crosby, TX
• Client: French Limited Task Group
• Program: CERCLA
• Function: QAA contracted to provide all QA services for this site, which resulted in cost savings, increased data reliability and enhanced project image. Services performed include:
  • Preparation of the Quality Assurance Project Plan (QAPjP), which was reviewed by the EPA and rated exemplary in nearly all respects
  • Selection of the subcontractor laboratories and preparation of the laboratory contract, which allowed for the recovery of $350,000 in late delivery penalties
  • Centralized management of all sample, analytical, and QA data using an electronic database designed and implemented by QAA
  • Electronic data validation of approximately 8,000 samples (air, water, sludge, and soil), which reduced labor costs compared to manual validation by 75%
  • Evaluation and interpretation of analytical data, which resulted in a refinement notice that reduced the air-monitoring costs by 70% while still meeting project goals to protect the public health
  • Quality assurance oversight and auditing of subcontractor laboratories

USEPA Region 5 Data Validation

• Site: Former Industrial Facility in the State of Illinois
• Client: ENTACT LLC
• Guidelines: U.S. EPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review (October 2004) and National Functional Guidelines for Superfund Organic Methods Data Review (June 2008)
• Tests: Total Metals, Synthetic Precipitation Leaching Procedure (SPLP) Metals, TCLP Metals, Fine-Fraction Lead, Hexavalent Chromium, Volatiles, Semivolatiles
• Samples: Over 1,400 soil, sediment, groundwater, surface water, air, and fish tissue samples
• Function: QAA performed an independent data validation of sample results for use in site characterization and delineation, risk assessment, and evaluation of remedial options. QAA then prepared a comprehensive data validation summary report for five large sets of data that presented a summary of the overall laboratory performance, an evaluation of the precision, accuracy, representativeness, completeness and comparability (PARCC), and a discussion of data usability.

USEPA Region 7 Data Validation

• Client: Risk Assessment & Management (RAM) Group of Gannett Fleming, Inc.
• Program: Missouri Risk-Based Corrective Action (MRBCA)
• Guidelines: USEPA CLP National Functional Guidelines for Organic Data Review (October 1999) and National Functional Guidelines for Inorganic Data Review (October 2004); USEPA Risk Assessment Guidance for Superfund (RAGS); and USEPA Guidance for Data Useability in Risk Assessment
• Tests: Volatiles, Semivolatiles, Alcohols, TPH (Extractables and Gasoline), Arsenic, Chlorinated Pesticides, Organophosphorus Pesticides, Herbicides
• Samples: 65 groundwater samples
• Function: QAA performed a data validation and review of all data from periodic groundwater monitoring, which will be used for risk assessment, for this complex analytical protocol and difficult sample matrix (due to presence of multi-component pesticide).

USEPA Region 1 Tier I and Tier III Data Review

• Site: Haverhill Landfill; Haverhill, MA
• Client: Camp Dresser & McKee Inc.
• Program: EPA Region I Remedial Investigation
• Guidelines: USEPA Region I Data Validation Functional Guidelines for Organic Analysis; USEPA Region I Data Validation Functional Guidelines for Inorganic Analysis
• Tests: VOC, SVOC, Pesticides, PCB, TPH, Metals, Miscellaneous Wet Chemistry
• Samples: approximately 130 groundwater and 30 sediment samples
• Function: QAA performed a data validation and review of all data from one year of quarterly monitoring in support of a Comprehensive Site Assessment, which included extent of contamination studies and risk assessment. The QAPjP called for a Tier I review on 80% of the data with a Tier III review on 20%. The client stated that the agency representative considered QAA's reports to be excellent.

Resolution of Data Quality Problems for a High Profile Site

• Site: Carver Elementary School; Baytown, TX
• Client: ERM-Southwest, Inc.
• Program: RCRA
• Guidelines: USEPA CLP National Functional Guidelines (NFG) and USEPA Guidance for Data Useability in Risk Assessment
• Parameters: VOC, SVOC, PAH, Pesticides, PCB, Metals
• Samples: approximately 350 groundwater and soil samples
• Function: QAA performed a Level IV data validation, review and usability determination in two weeks for 250 samples, which had been collected and analyzed prior to QAA's involvement in the project. Low internal standard areas were reported for several of the samples, which indicated reduced instrument sensitivity and thus indefensible reporting limits. After communication with the laboratory, QAA obtained the data necessary to calculate defensible reporting limits for each specific sample using a technique similar to that used for dioxin analysis, thereby eliminating the need for resampling. For the second phase of the project, QAA coordinated with the laboratory and instituted corrective actions that raised the completeness for QC tests from approximately 65% before QAA involvement to over 90% after QAA involvement.  

Litigation Support Projects

Automobile Cooling System Failure Analysis

• Client: Duncan, Green, Brown, Langeness, and Eckley, P.C.; Des Moines, IA
• Contact: Matt Duncan
• Case: Confidential
• Representing: Plaintiff
• Function: QAA completed a literature search then sampled automobile coolants, identified analyses to be performed, selected the analytical laboratory, and coordinated the analytical effort. QAA is currently in the process of interpreting the results to determine the cause of corrosion in 900 vehicles and identify the source of contamination.
• Disposition: Pending

Medical Equipment Personal Injury Claim

• Client: Holtkamp, Leise, Beckemeier, and Childress; St. Louis, MO
• Contact: Gil Beckemeier, Jr.
• Case: Abtox vs. various plaintiffs
• Representing: Defendant
• Function: Plaintiffs alleged that a surgical instrument sterilizer sold by Abtox formed deposits on ophthalmic instruments, which caused eye injuries upon use. QAA managed a team of experts and gathered, catalogued, evaluated, and summarized scores of documents in a searchable database for easy reference. Extensive knowledge was gained on FDA procedures for approval of medical devices and hospital sterilization procedures. QAA developed and performed an experimental testing protocol to study deposit formation and determine origin and composition. 
• Disposition: Settled

Pesticide Exposure Personal Injury Claim

• Client: Holtzman, Urqhuart, & Moore, P.C.; Houston, TX
  
• Contact: John Ghezzi and Laura Santos
  
• Case: Confidential
  
• Representing: Defendant
  
• Function: QAA completed a data validation, review, and suitability determination of pesticide data serving as the basis for a personal injury claim by the plaintiff. Data discredited for lack of quality control and mis-interpretation. 
  
• Disposition: Settled in favor of defendant

Fate and Effects of Chemical Contamination

• Client: Campbell and Associates; Houston, TX  for  Bickle & Brewer, Attorneys; Dallas TX
• Contact: Michael D. Campbell
• Case: IMC Global vs. Angus Chemical Company
• Representing: Defendant
• Function: QAA completed a data validation, review, and suitability determination of site chemical characterization data. Evaluated depositions and literature citations pertaining to fate and effects of 2-nitropropane contamination. Prepared written report on fate and effects of 2-nitropropane, acetone, and chlorinated hydrocarbons.
• Disposition: Pending