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HomeMy WebLinkAboutNCD980729602_19940631_Jadco-Hughes_FRBCERCLA RA_Remediation Goal Verification Plan-OCRI I • I I I I I I I D I m m m ·I ·I I , I RECEKVED MAR 1 5 1994 SUPERFUNO secr,J REMEDIATION GOAL VERIFICATION PLAN Jadco-Hughes Site Gaston County, North Carolina JANUARY 1994 REF. NO. 3669 (19) This report is printed on recycled paper. CONESTOGA-ROVERS & ASSOOATES I I • I {I I a u D H I I I I I I I I I ~ TABLE OF CONTENTS Page 1.0 INTRODUCTION ...................................................................................................... 1 1.1 REPORT ORGANIZATION ........................................................................ 1 2.0 PROJECT DESCRIPTION .......................................................................................... 3 2.1 GENERAL. ....................................................................................................... 3 2.2 REMEDIATION OBJECTIVES ..................................................................... 3 2.2.1 Soil .................................................................................................................... 3 2.2.2 Groundwater ................................................................................................... 4 2.2.3 Performance Monitoring -Hydraulic Containment. ............................. 6 2.3 SHUT-OFF CRITERIA .................................................................................. 7 2.3.1 Groundwater Remediation ......................................................................... 7 2.3.2 Soil Remediation ........................................................................................... 9 3.0 REMEDIATION GOAL VERIFICATION (RGV) SAMPLING AND ANALYSIS PLAN (SAP) ............................................................................... 11 3.1 RGV INVESTIGATIVE ACTIVITIES ........................................................ 11 3.1.1 Groundwater Sampling and Analysis ....................................................... 11 3.1.2 Soil Gas Sampling and Analysis ................................................................. 12 3.1.3 Groundwater Treatment System Sampling and Analysis .................... 13 3.1.4 SVE System Monitoring, Sampling and Analysis .................................. 13 3.2 SAMPLE COLLECTION AND ANALYSIS PROTOCOLS ..................... 13 3.2.1 General Sampling Protocols ........................................................................ 13 3.2.2 Monitoring Well Sampling ......................................................................... 14 3.2.2.1 Well Purging ................................................................................................ 14. 3.2.2.2 Monitoring Well Sampling Procedure .................................................. 15 3.2.3 Groundwater Treatment System Sampling Procedure ......................... 17 3.2.4 Gas Monitoring .............................................................................................. 18 3.2.4.1 SVE Exhaust Gas Monitoring ................................................................... 18 3.2.4.2 SVE Treatment System Gas Monitoring ............................................... 19 3.2.4.3 Soil Gas Monitoring ................................................................................... 19 3.2.5 Sample Labeling and·Control. ..................................................................... 20 3.2.5.1 Initial Labeling of Samples ....................................................................... 21 3.2.5.2 Sample Shipment ................................................... , ................................... 22 3.2.5.3 Chain-of-Custody-Records .......................................... "····························22 3.2.6 Analytical Protocols .................................................. .-........... ; ........................ 22 3.2.6.1 Scope ................................. : ..................................... , ....... : .............................. 22 3.2.6.2 Sample Analysis .......................................................................................... 23 3.2.6.3 Data Quality Assessment. .......................................................................... 23 3.2.6.4 Reporting ...................................................................................................... 24 3.3 WASTE MATERIAL HANDLING ............................................................ 24 3.4 ON-SITE HEALTH AND SAFETY PLAN ................................................ 24 3669 09) CONESTOGA-ROVERS & ASSOOATES I I I m fl I D D I I I • I I I t I I I TABLE OF CONTENTS Page 4.0 RGV QUALITY ASSURANCE PROJECT PLAN (QAPP) .................................. 26 4.1 INTRODUCTION .......................................................................................... 26 4.2 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT DATA ............................................................................. 27 4.2.1 Level of QA Effort .......................................................................................... 29 4.2.2 Accuracy, Sensitivity and Precision of Analysis ..................................... 30 4.2.3 Completeness, Representativeness and Comparability ........................ 31 4.2.4 Field Measurements ...................................................................................... 31 4.3 SAMPLING PROCEDURES ......................................................................... 32 4.4 SAMPLE CUSTODY AND DOCUMENT CONTROL ............................ 32 4.1.1 Field Custody Procedures ............................................................................. 32 4.4.2 Sample Labels ................................................................................................. 32 4.4.3 Chain-of-Custody ........................................................................................... 33 4.4.4 Sample Documentation In The Laboratory ............................................. 33 4.4.5 Storage of Samples ......................................................................................... 34 4.4.6 Sample Documentation -CRA ................................................................... 34 4.5 CALIBRATION PROCEDURES AND FREQUENCY ............................. 35 4.5.1 Laboratory Instrument Performance ......................................................... 35 4.5.1.1 Organic Analyses ......................................................................................... 35 4.5.2 Laboratory Calibration .................................................................................. 36 4.5.2.1 Calibration Check ........................................................................................ 36 4.5.3 Field Instrument Calibration ...................................................................... 36 4.5.3.1 pH Meter ....................................................................................................... 37 4.5.3.2 Conductivity Meter .................................................................................... 37 4.5.3.3 HNu Meter ................................................................................................... 38 4.6 ANALYTICAL PROCEDURES .................................................................... 39 4.6.1 Overview ......................................................................................................... 39 4.6.2 Identification ................................................................................................... 39 4.6.3 Quantification ................................................................................................. 40 4.6.4 Detection Limit and Quantification Limit .............................................. .40 4.7 DATA REDUCTION, VALIDATION ASSESSMENT AND REPORTING ........................................................................................ 40 4.8 INTERNAL QUALITY CONTROL CHECKS AND FREQUENCY ....................................................................................... 42 4.8.1 Field QC ............................................................................................................ 42 4.8.2 Laboratory QC ................................................................................................. 42 4.8.2.1 Method Blank Samples ............................................................................. 43 4.8.2.2 Matrix Spike/Matrix Spike Duplicates (MS/MSD) Analyses ........... .43 4.8.2.3 Surrogate Compounds ............................................................................... 44 4.8.2.4 Laboratory Control Samples ..................................................................... 44 4.9 PERFORMANCE AND SYSTEM AUDITS AND FREQUENCY ........ .45 4.10 PREVENTIVE MAINTENANCE .............................................................. .46 366909) CONESTOGA-ROVERS & ASSOOATES I ' I I 3 a I ti I u - I I I I t I I 11 I TABLE OF CONTENTS Page 4.11 SPECIFIC ROUTINE PROCEDURES USED TO ASSESS DATA PRECISION, ACCURACY AND COMPLETENESS ................. .47 4.11.1 QA Measurement Quality Indicators ....................................................... .47 4.11.1.1 Precision ........................................................................................................ 47 4.11.1.2 Accuracy ........................................................................................................ 47 4.11.1.3 Outliers .......................................................................................................... 47 4.12 CORRECTIVE ACTION ................................................................................ 48 4.13 QUALITY ASSURANCE REPORT TO MANAGEMENT ................... .48 5.0 REPORTING ............................................................................................................... 50 6.0 REFERENCES ............................................................................................................. 51 3669 09) CONESTOGA-ROVERS & ASSOCIATES I ' LIST OF FIGURES I Following Page 0 FIGURE 1.1 SITE LOCATION 1 FIGURE 2.1 GROUNDWATER EXTRACTION SYSTEM 6 a FIGURE 2.2 SOIL VAPOR EXTRACTION SYSTEM 9 u FIGURE 3.1 MONITORING WELL LOCATIONS 11 FIGURE 3.2 TYPICAL CHAIN-OF-CUSTODY FORM 22 It FIGURE 4.1 TYPICAL SAMPLE LABEL 32 I FIGURE 4.2 TYPICAL CHAIN OF CUSTODY FORM 33 FIGURE 4.3 ANALYTICAL DATA FLOW 40 ' I LIST OF TABLES t TABLE 2.1 SOIL CLEANUP GOALS 3 I TABLE 2.2 GROUNDWATER CLEANUP GOALS 4 I TABLE 2.3 EXTRACTION SYSTEM MONITORING WELLS 7 TABLE 3.1 MONITORING PROGRAM 11 t TABLE 3.2 FIELD QUALITY CONTROL PROCEDURES · 17 ' TABLE 3.3 SAMPLE COLLECTIONS, PRESERVATION AND SHIPPING PROTOCOL SUMMARY 22 t TABLE 3.4 TCL VOCs 22 TABLE 3.5 TCL BNAs 22 I TABLE 3.6 PCB ANALYTES 22 t TABLE 3.7 INORGANIC ANALYTES 22 3669 Olll CONESTOGA-ROVERS & AsSOCIATES I I I I I I ' D ti ' ' f; ' ,, I ' t I t I TABLE 4.1 TABLE 4.2 TABLE 4.3 TABLE 4.4 TABLE 4.5 3669 09) LIST OF TABLES Following Page SUMMARY OF SAMPLING AND ANALYSIS PROGRAM 28 TARGETED QUANTITATION LIMITS (ORGANIC ANALYSES/WATER) 30 TARGETED QUANTITATION LIMITS (INORGANIC ANALYSES/WATER) 30 TARGETED QUANTITATION LIMITS (VOC AN AL YSES/ AIR) 30 SURROGATE COMPOUND RECOVERY LIMITS 44 CONEST(X;A-ROVERS &: AsSOOATES I I 8 0 I I ' I t ' ' I I I ' t I I I 1.0 3669 09) INTRODUCTION This Remediation Goal Verification (RGV) Plan has been prepared as part of the Remedial Action (RA) Work Plan for the J_adco-Hughes Site (Site) located in Gaston County, North Carolina. Figure 1. 1 shows the location of the Site. The RA activities consist of: 1) 2) 3) 4) 5) Site spillway construction, gravity drainage line construction and the repair of the Site culvert; groundwater extraction system construction; groundwater treatment system construction; installation of soil vapor extraction (SVE) system; and installation of a soil flushing system. This report presents protocols that will be followed to determine if the Remediation Goals set forth in the Record of Decision (ROD) [United States Environmental Protection Agency (USEPA), September 27, 1990] have been met, or to determine if it is impractical to meet those remediation goals from an engineering perspective. The Scope of Work (SOW) to the Unilateral Administrative Order (UAO) for the Site (USEPA Docket No. 91-31-C) states that the RGV Plan is to "provide a mechanism to ensure that both short-term and long-term performance standards for the Remedial Action are being met.11 Conestoga-Rovers & Associates (CRA) has prepared this RGV Plan on behalf of the Jadco-Hughes Steering Committee (Steering Committee). 1.1 REPORT ORGANIZATION This RGV Plan is organized in the following manner: 1 C0NESTOCA·R0VERS & ASS0OATES I I ti I I I ' I I I I o' 1000' 2000' ·-· '°',,. __ . . .f'.s --. CRA . ::. ·~· ~ ·". ,oo) . -. -. / 4 (W) REV.a 3669 (19.) JAN 10 9 ~--~ ··~ -:- ; •• ,,s ... ' I . " I 1/i l (./ I / /; 't;: ' . ' IT'•;,_, ._. . ,,; ...... ~-Q; ...... I lo' I(.) ' . . ·~ ,• c-'., .J-;.,,, __ , ! I I _; -~j ' \ , '""./ ... --~~. ! ;______;-(: . \ ,\ • ·-' \1. ••'•'r. -.• f, PJP \\_ . :..,: -'=:':~a -~''/;~2::;:~:;: I ·,-...__. ,\; . ?.:=: \ • "-i· ',,,,/ · ... ,/ I I:, \ . ' \._--..;\ ·--:Li ~-••••• .,, ,, ' ·f' I/' \ ·--: !~, ' \~'- F.,.., §. \ ''-"#2 _ · / Rest ~u· .1,..,,< ' u V ' -z· /~ /)( \ -... •.,,,--. ·· .. • ·· ·-•• ""'=· ___ ,, figure 1.1 SITE LOCATION JADCO-HUGHES s1~ Goston County, . ' I ,, I I I I I 8 ' I ,, I I ' ' I ' I 3669 09) • Section 2.0 presents the project description, including remediation objectives and shut off criteria for the soil and groundwater treatment systems; • Section 3.0 presents the RGV Sampling and Analysis Plan; • Section 4.0 presents the RGV Quality Assurance Project Plan; • Section 5.0 presents the RGV Plan reporting requirements; and • Section 6.0 presents a list of references. 2 CONESTOGA-ROVERS&: AsSOClATES ti II I I ' I ' I I ' ,, ' I I 2.0 3669 09) PROTECT DESCRIPTION 2.1 GENERAL In accordance with the SOW, the purpose of the RGV Plan is to provide a mechanism to ensure that both short-term and long-term performance standards and remediation goals for the RA are being met or data are being collected which illustrate the practicality of meeting the remediation goals. This Plan is divided into two parts as required by the SOW: 1) RGV Sampling and Analysis Plan (SAP); and 2) RGV Quality Assurance Project Plan (QAPP). The RGV SAP provides protocols that will be followed for all field work and provides sampling and data gathering methods used for this project. The RGV QAPP describes the policy, organization, functional activities and quality assurance and quality control protocols necessary to evaluate the Site conditions with respect to the remediation goals set forth in the ROD and summarized in the following section. 2.2 REMEDIATION OBJECTIVES 2.2.1 Soil The soil cleanup goals were.developed to predict the level of soil cleanup necessary to protect groundwater. Thirteen specific remediation goals for soil contaminants were identified in the ROD and are presented in Table 2.1. The soil cleanup goals were developed to predict the level of soil cleanup necessary to protect groundwater. The rate of cleanup of the groundwater should be increased by soil vapor extraction and soil flushing. 3 CONESTOGA-ROVERS & AsSOCIATES 0 fl m II I I I I I I I I ' ' I I I TABLE 2.1 SOIL CLEANUP GOALS JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Compound Remediation Goal arsenic 48.0 barium 360.0 cadmium 6.0 carbon tetrachloride 3.689 chloroform 15.865 chromium 140.0 1,2-dichlorobenzene 1.5 lead 1.3 mercury 0.15 PCBs 10.0. selenium 4.6 silver 0.6 vinyl chloride 0.014 Notes: All concentrations are stated in mg/kg. The above identified soil cleanup goals are developed for the protection of the groundwater and are designed to ultimately eliminate the leachability from soil contamination that would exceed the established groundwater remediation goals. CRA3(,6909J I I I I I I I . I I I I I 'I I I I I 3669 09) The soil vapor extraction system will begin operation until it is no longer effective. The soil flushing system will then begin operation as an integral part of the groundwater extraction system until the specific groundwater remediation objectives have been achieved, or technical impracticability has been demonstrated. The soil remediation process described above, coupled with groundwater extraction and monitoring, will provide adequate assurance that the remedy will, as the ROD requires, result in concentrations of contaminants in the soil that do not produce 'leachate' which results in groundwater concentrations which are in exceedance of the groundwater remediation objectives. 2.2.2 Groundwater The groundwater remediation goals contained in the ROD are listed in Table 2.2. These goals are based on State Groundwater Standards, Federal Maximum Contaminant Levels (MCLs) and Proposed MCLs. The groundwater remediation goals for select Target Compound List (TCL) volatile organic compounds (VOCs) and Base, Neutral and Acid Extractable Compounds (BNAs) are below technically achievable detection levels with USEPA approved methods. In addition, the remediation goal for vinyl chloride is below the detection limit with any known method. Consequently, the Steering Committee will utilize USEPA approved methods and will evaluate the remediation process and progress with the detection limits available for these methods. The selected remedy includes operation of the groundwater extraction system for an estimated period of 30 years, during which the system's performance will be carefully monitored on a regular basis and adjusted as warranted by the performance data collected during operation. Typical modifications may include: 1) Alternating pumping at wells to eliminate stagnation points; 4 CONESTOGA-ROVERS &: AsSOCIATFS I • I I I ,1 0 ,g B I I I I t I I I I I TABLE 2.2 GROUNDWATER CLEANUP GOALS JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Page 1 of 2 Compound voes (µg/L! Remediation Goal acetone benzene 2-butanone carbon tetrachloride -chlorobenzene chloroethane chloroform 1, 1-dichloroethane 1,2-dichloroethane 1, 1-dichloroeth ylene 1,2-dichloroethylene (total) 1,2-dichloropropane ethyl benzene 2-hexanone methylene chloride! 4-meth yl-2-pen tanone tetrachloroethylene toluene 1, 1, 1-trichloroethane 1, 1,2-trichloroethane trichloroeth y Jene vinyl chloride xylene BNAs (µg/L! benzoac acid bis(2-chloroethyl)ether bis(2-ethylbenzyl)phthalate 1,2-dichlorobenzene 1,3-dichlorobenzene 1,4-dichlorobenzene di-n-butyl phthalate phenol 1,2,4-trichlorobenzene CRA366909) 700 1 170 0.3 300 10 0.19 0.3 0.3 7 70 0.56 29 10 5 350 0.7 1,000 200 3 2.8 0.015 400 28,000 0.03 4 620 620 1.8 700 4,200 9 I I I I & ff n u I I I I I - I I I I ' TABLE 2.2 GROUNDWATER CLEANUP GOALS JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Page2of 2 Compound Metals (ug/L) Remediation Goal Notes: arsenic cadmium chromium lead nickel VOC:s -volatile organic compounds BNAs -base-neutral and acid extractable compounds CRA3669 09) 50 5 50 15 150 I n I 0 fl I t I I I I I I I I I I I ·a 3669 (19) 2) Pulse pumping to allow aquifer equilibration and to allow adsorbed contaminants to partition into groundwater; 3) Installation of additional extraction wells to facilitate or accelerate groundwater remediation; and 4) Discontinuation of pumping at individual wells where cleanup goals have been attained, and after analytical confirmation. At those wells where the remediation goals have been attained and pumping has ceased following discontinuation of groundwater extraction, the aquifer will be monitored to ensure that the remediation objectives continue to be maintained. This monitoring will be conducted according to the monitoring program established in the Operations and Maintenance Manual. If the Steering Committee demonstrates, in corroboration with hydrogeological and chemical evidence, that it will be technically impracticable to achieve and maintain remediation goals throughout the area of attainment, the Steering Committee will petition EPA to modify the groundwater remediation system. For example, a petition may be filed when it has been demonstrated that contaminant levels have ceased to decline over time, and are remaining constant at some statistically significant level above remediation goals, in a discrete portion of the area of attainment, as verified by multiple monitoring wells. It is possible that technical impracticability may be reached in a portion of the Site. Where such a situation arises, groundwater extraction and treatment would typically continue as necessary to achieve mass reduction and remediation goals throughout the rest of the area of attainment. If it is determined, on the basis of the preceding criteria and the system performance data, that certain portions of the aquifer cannot be restored to their beneficial use, all of the following measures involving long term management may occur, for an indefinite period of time, as a modification of the existing system: 5 CONESTOGA-ROVERS & ASSOCIATES fl I I I B fl ti I I I I I I I I I I I I 1) 2) 3) 4) 5) Engineering controls such as physical barriers or long term gradient control provided by low level pumping, as a containment measure; Chemical-specific ARARs will be waived for the cleanup of those portions of the aquifer based on the technical impracticability of achieving further contaminant reduction; Institutional controls will be.provided/maintained to restrict access to tho~e portions of the aquifer which remain above health-based goals, since this aquifer is classified a potential drinking water source; Continued monitoring of specified wells; and Periodic reevaluation of remedial technologies for groundwater restoration. This decision to invoke any or all of these measures may be made during a periodic review of the remedial action, which will occur at intervals no less frequent than every five years. 2.2.3 Performance Monitoring -Hydraulic Containment Hydraulic containment of the groundwater system will be accomplished using four groundwater extraction wells (PWl through PW4) and a tile collection system. The extraction wells are intended to extract groundwater from deeper portions of the aquifer for treatment. The tile collection system is designed to extract shallow groundwater discharging from the Site. The location of the extraction wells and tile collection system are shown on Figure 2.1. The hydraulic containment system is designed to provide optimum groundwater extraction, while inhibiting the movement of groundwater contamination off Site. Monitoring the performance of both of these systems will be accomplished by hydraulic (water level) monitoring of the extraction wells, monitoring wells, piezometers and the maintenance holes and sumps which 6 CONESTOGA-ROVERS & ASSOCIATES .. - CRA ---- -----PROPERTY LINE ------TIL£ DRAIN (~~ ·-· •""" fORC[MAIN PROPOS(D HOOl<-UP PROPOSED SOIL F1.USHING EXTRACTION TR[NQ-1 CAPTURE ZONE AREA SHALLOW MONITORING WELL DEEP MONITORING 'tt(LL j I J669 (19) JAN 28/94(W) REV.O (P-61) --- - ..... "''" •'"° •'"' I I I I PUMPING \ltUl SURACE WA T[R SAMPLING LOCATION DEEP PIEZOMETER SHAU.OW PIEZOMETER PRE-CAST CONCRETE CHAMBERS UANH()_[ CULVERT - 0 -iiiil 50 1001t figure 2.1 GROUNDWATER EXTRACTION SYSTEM JADCO-HUGHES SITE Gaston County, NC - I I I I I I I I I I I I I I I I I I I 3669 09) are part of the tile collection system. Water level measurements will be collected quarterly in conjunction with the groundwater sampling program (see Section 3.0). After a two-year period, water levels will be collected annually. Water level measurements will be used to develop groundwater contours for the Site. Based on groundwater elevations and hydraulic gradients, hydraulic containment can be verified. In addition, groundwater analytical data from monitoring wells will also verify hydraulic containment by showing constant or reducing contaminant concentrations over time. The monitoring wells associated with each extraction well or trench are shown in Table 2.3. Based on the hydraulic monitoring data, the groundwater extraction systems will be evaluated and recommendations to alter the groundwater pumping rates for achieving optimum groundwater extraction can be determined. 2.3 SHUT-OFF CRITERIA A discussion of the process and criteria for shutting down some or all of the groundwater extraction and s_oil vapor extraction systems is presented below. 2.3.1 Groundwater Remediation At the outset, it is estimated that groundwater extraction will continue for an estimated period of 30 years (see Appendix C of the RD Work Plan). Groundwater extraction will be accomplished by using four extraction wells (PWl through PW4) and a tile drain collection system (see Figure 2.1), with estimated extraction rates of 1 gpm per well and 18 gpm for the tile collection system. Monitoring of the chemical compounds contained in the groundwater from the extraction wells, tile collection system, monitoring wells and groundwater treatment system will occur on a 7 CONESTOGA-ROVERS & AsSOCIATES I I I I I I I I I I I I I I I I I I I Extraction Well PWl PW2 PW3 PW4 CRA366909) TABLE 2.3 EXTRACTION SYSTEM MONITORING WELLS JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Associated Monitoring MW2S, MW2D, MWl0D MWSS, MWSD, MWSDD MW3S, MW3D \.. MWBS I I u I 0 R I I I I I I I I I I I I I 3669(19) scheduled basis, as discussed in Section 3.0. Long-term groundwater monitoring will determine the effectiveness of the groundwater remediation system and ultimately the soil remediation system. Moreover, groundwater analytical results will be utilized to determine when to discontinue groundwater remediation. Generally, contaminant mass removal exhibits a curvilinear reduction over time with the greatest amount of mass removal occurring during the firslfew years of operation of the groundwater extraction system. Due to the limitations of this technology, contaminant concentrations eventually reach an asymptote where continued groundwater pumping results in insignificant mass removal. If the groundwater in the vicinity of one or more extraction wells or in the vicinity of the tile collection system achieves the groundwater remediation goals established in the ROD (Section 2.2), then that specific well or system, or portion of the system can be shut down. Achievement of the groundwater remediation goals will be determined by two consecutive rounds of groundwater samples which exhibit levels of contaminants which are below the remediation goals. Wherever a portion or all of the groundwater extraction . system has been shut down, that portion of the system will become a groundwater monitoring point for long-term sampling. Future sampling will determine if an increase in contaminant concentration is occurring. If future analytical results show an increase contaminant concentration above the remediation goals (a "rebound effect"), then an evaluation and recommendation will be made in the periodic progress reports. "Rebound" effects may be caused by one or more of the following: i) ii) iii) iv) diffusion of contaminants in low-permeability sediments; hydrodynamic isolation within well fields; desorption of chemical compounds from sediments; and/ or partitioning of immiscible fluids into groundwater. 8 CONESTOGA-ROVERS & ASSOOATES I g I I I I I u B u u R I I I I I 3669 09) The extraction system will be brought on line and operated in cycles if appropriate, until rebound effects are minimal. After a minimum of five years of pumping, and once rebound effects have been minimized, if groundwater remediation goals have not been attained, or the chemical compounds in groundwater appear to have reached an asymptote and further contaminant reduction is unlikely, then the existing system may be modified as described in Section 2.2.2, above. The criteria for assessing asymptotic contaminant levels over time will be linear regression using the Student t-test at a 95 percent confidence level. The slope of this fitted regression line will be no greater than zero for each extraction well or trench capture area. Thus, the monitoring data will be grouped with the associated extraction well or trench, as shown in Table 2.3, for this shut-off determination. Alternatively, in accordance with North Carolina Administrative Code (NCAC) T15A:02L.0106 (M)(2)(A), the Steering Committee may prepare its petition for the termination of groundwater remediation based upon a demonstration that "continuation of corrective action would not result in a significant reduction in the concentration of contaminants ... ", based upon an asymptotic slope of less than 2.5 percent over a period of one year. 2.3.2 Soil Remediation The objective of the soil vapor extraction (SVE) system is to accelerate soil as well as groundwater remediation at the Site. The SVE system will consist of a series of soil vapor extraction trenches in the former landfill area (see Figure 2.2), and SVE treatment equipment. During operation of the SVE system, soil gas samples will be collected from the SVE system influent treatment line and from associated soil gas probes in accordance with the long-term monitoring program presented in Section 3.0. Unlike the groundwater extraction system, there are no remediation goals directly associated with the SVE system. The soil 9 CONESTOGA-ROVERS & AsSOCJATES -- FENCE LINE LIMIT OF FORMER LANDFILL AREA !!!!!I l!!l!9 em LIMIT OF NEW CLAY CAP------ OR SYNTHETIC LINER (SLOPED NE FOR DRAINAGE) == [ 3• ISOLATION/VACUUM CONTROL VALVE TOP OF CASON STREET CONCRETE SUPPORT/SEAL 9' DEEP x 100' LONG AIR INFll TRA TION TRENCH. ( TYPICAL OF 4) SOIL CAP=-----~===::::;;/1~=========:::;;1~:::::========~r=== GRADE -2·---•·---6'-- -a·-- -10·-- -12·-- CRA GRAVEL PACKED VAPOR EXTRACTION TRENCH (TYPICAL) sz 3669 (19) JAN 28/94(W) REV.1 (P-6J) GRAVEL PACKED AIR INLET TRENCH (TYPICAL) ~ 1~ 2" PERFORATED PIPE FOR FUTURE SOIL FLUSHING (TYPICAL) iiii -.. a· DIA. PVC SOIL VAPOR EXTRACTION HEADER MW3S 0 SVE EQUIPMENT I ED ED I ~~BON VESSELS 9' DEEP x 80' LONG VAPOR EXTRACTION TRENCH. (TYPICAL OF 5) figure 2.2 SOIL VAPOR EXTRACTION SYSTEM JADCO-HUGHES SITE Goston County, NC - I I I I I I I D u I I I I I I I I I 3(,6909) remediation goals provided in Section 2.2 will not be achievable by the SVE system alone. Hence, the shut off criteria for the SVE system is dependent on its operating effectiveness. As presented in the Preliminary Design Report (CRA, 1993), the SVE pilot study estimated that 5,000 soil pore volume exchanges would be required in order to remove VOCs to a level that would approach non-detect levels in soil gas for most constituents in the soil. The SVE system will operate continuously until approximately 5,000 soil pore volumes are removed. The pore volume removal rate is dependent on the achievable SVE system flow rate and radius of influence. Based on the results of the SVE pilot test, 5,000 pore volumes is estimated to be removed from the former landfill area within a six-month period. After the 5,000 pore volumes are removed, the operation of the SVE system will discontinue. Following a brief shutdown period, the SVE system would be turned on and extracted VOCs monitored with a photoionization detector (PIO). If an increase above those levels measured before the system was shut down in organic vapors is noted, then the SVE system would operate for approximately a one-month period to remove any soil VOCs released by diffusion. This rebound effect is not uncommon, where VOCs from a less permeable soil zone migrates upward via diffusion (reference: Soil Vapor Extraction Technology -Reference Handbook, USEPA, 1991). Cyclic operation of the SVE system would continue until a statistically insignificant VOC rebound occurs. The operation of the SVE system will then be discontinued permanently. After the SVE system is shut down, the operation of the soil flushing system will begin. The soil flushing system will be monitored according to the monitoring program discussed in Section 3.0. The methodology for evaluating the remediation goals of the soil flushing system will be consistent with the procedures for the groundwater remediation system. Thus, if the water collected from soil flushing extraction trench meets the groundwater remediation objectives provided in Section 2.2, the soil flushing system will be shut off. The system may be turned back on if groundwater monitoring of the soil flushing system indicate that contaminant levels exceed the groundwater remediation objectives. 10 CONESTOGA-ROVERS & A~SOCIATFS I I a g u I I I I I I I I I I I I I 3.0 3',l,909) REMEDIATION GOAL VERIFICATION (RGV) SAMPLING AND ANALYSIS PLAN (SAP) 3.1 RGV INVESTIGATIVE ACTIVITIES There are four different types of RGV sampling activities which are described below: • groundwater sampling and analysis; • soil gas sampling and analysis; • groundwater treatment system sampling and analysis; and • SVE treatment system monitoring, sampling and analysis. 3.1.1 Groundwater Sampling and Analysis The groundwater sampling and analysis will be performed to evaluate the level of contaminant reduction in the Site aquifer. As a part of the RGV activities, groundwater from the monitoring wells and the extraction system will be analyzed for Target Compound List VOCs, BNAs, Polychlorinated Biphenyls (PCBs), and a select list of metals at the frequencies presented in Table 3.1. The monitoring well locations are shown on Figure 3.1. The monitoring program is based on the groundwater moni taring pro gr am presented in the USEP A approved Feasibility Study. The basis for the monitoring program is outlined below. i) ii) The groundwater monitoring system involves the collection of groundwater samples within areas of known groundwater contamination. These data are used to monitor the progress of remediation and the redistribution of contamination within the aquifer in response to pumping. The sentry groundwater system is designed to monitor the groundwater zone downgradient and below the contaminant plume. Should groundwater contamination migrate vertically downward or 11 CONESTOGA-ROVERS & AsSOCIATES I I Page 1 of2 TABLE3.l I MONITORING PROGRAM JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN I I Groundwater Remediation voes BNAs PCBs Metals Water Levels A. Groundwater Monitoring Wells I MW2S Q2IA A A Verification Q2/A MW2D Q2IA A A Verification Q2/A MW3S Q2IA A A Verifica lion Q2/A 8 MWSS Q2/A A A Verification Q2/A MWSD Q2/A A A Verification Q2/A MW6S Q2IA A A Verification Q2/A MW7S Q2/A A A Verification Q2/A I MWBS Q2IA A A Verifica lion Q2IA I B. Sentry Groundwater Monitoring System MW3D Q2/A • • Verifica lion Q2/A MWSDD Q2/A • • · Verification Q2/A I MW6D Q2IA • • Verification Q2/A MW9S Q2/A • • Verification Q2IA MWIOD Q2IA • • Verification Q2IA I MW125 Q2IA • • Verification Q2IA MW12D Q2IA • • Verification Q2IA MWI45 Q2IA • • Verification Q2IA MWl4D Q2IA • • Verification Q2IA I MWISS Q2IA • • Verifica lion Q2IA MW15D Q2/A • • Verification Q2IA SS9 Q2/A • • Verification Q2IA I 5514 Q2/A • • V crifica lion Q2IA 5515 Q2/A • • Verification Q2/A I C. Extraction System PW! Q2/A A A Verifica lion NIA I PW2 Q2/A A A Verification NIA PW3 Q2IA A A Verification NIA PW4 Q2/A A A Verification NIA Sump for Soil Flushing Q2IA A A Verification NIA I Extraction Trench (future) Treatment Plant Influent Q2/A A A Verifica lion NIA Treatment Plant Effluent Q2IA A A Verification NIA I I CRA3669 09) I I I I I I g 0 I I Sail Remediation A. Soil Gas Probes TABLE 3.1 MONITORING PROGRAM JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN voes BNAs PCBs B. SVE Exhaust Gas Treatment System Effluent Q (]) Q (]) Q(l) Page2 of 2 Metals Water Levels NIA NIA NIA I Notes: I. I I I I I I NIA Q2/A QS/A • voes BNAs Metals A Q Verification (1) CRA 3669 09) not analyzed not applicable sample quarterly for two years, annually thereafter sample quarterly for five years, annually thereafter sample 7 of 14 stations each year, alternate 7 one year, 7 the next year volatile organic compounds base/neutral and acid extractable compounds lead, cadmium, chromium, nickel and arsenic annually quarterly to be verified after remediation of groundwater complete Monitoring frequency to be increased to monthly toward end of shut-off of SVE system. Sample collection to include measurement of flow, line pressure and temperature for mass balance calculations. Soil gas probe monitoring will be discontinued after SVE system operation is terminated. ---- ------ ..,. LOCATED ON CAROUNA CUSTOM CABtNETS PRa=tERlY CRA ·-· .. .,. ePZ4S •'"° ·~ -- J.W:Mll. PROPERTY LINE SHALLOW MONITORING \l,[LL DEEP MONITORING WEU. SHALLOW PtEZOMETER DEEP PIEZOt.lETER PUMPING Yo(LL I I 3669 (19) JAN 28/94(W) REV.O (P-62) - -- - --II!!!! 1!11111 --iiiil ~ 0 50 IOOlt figure 3.1 MONITORING WELL AND PIEZOMETER LOCATIONS JADCO-HUGHES SITE Gaston County, NC - I I I I g I u 0 0 u I I I 3669 09) iii) northward against the influence of the groundwater extraction system, contamination would be detected in the sentry well system. The extraction system monitoring involves the collection and analysis of samples from the collection drain, the four extraction wells and the combined influent to the treatment system. These data are used to monitor the progress of remediation. Four parameter groups were selected for routine analysis as follows: • voes; • BNAs; • PeBs (Arochlor 1248 and Arochlor 1232 -the only isomers detected on Site); and • Selected Metals (nickel, lead, chromium, cadmium and arsenic). Since voes are the most prevalent and most mobile contaminant group at the Site, these compounds are monitored at all monitoring stations, as shown in Table 3.1. BNAs, PeBs and metals are monitored at all plume and extraction monitoring stations. However, BNAs, PeBs and metals are monitored at 7 of 14 selected sentry locations, to be rotated each sampling round. The frequency of monitoring is annual for long-term monitoring given the slow rate of groundwater movement of 8 to 14 feet/year. The monitoring program involves more frequent sampling in the first two years to assist in optimizing the operation of the groundwater extraction and treatment system. 3.1.2 Soil Gas Sampling and Analysis The soil gas sampling and analysis will be performed to evaluate the level of voe contaminant reduction in Site soils. The sampling frequencies are presented in Table 3.1. 12 CONESTOGA-ROVERS & AsSOClATES I I I I I I I I m I a I D 0 D 0 D u 3669 09) 3.1.3 Groundwater Treatment System Sampling and Analysis The groundwater treatment system influent and effluent water sampling and analysis will be performed to evaluate the effectiveness of the treatment system. The samples will be analyzed for VOC, BNA, PCBs and a select list of metals at the frequencies presented in Table 3.1. 3.1.4 SVE System Monitoring, Sampling and Analysis The SVE monitoring, sampling and analysis will be performed to evaluate the effectiveness of the SVE system. The samples will be monitored for total voe by continuous PIO measurements at the frequencies listed in Table 3.1. The SVE exhaust gases will be continuously monitored and sampled as presented in Table 3.1. 3.2 SAMPLE COLLECTION AND ANALYSIS PROTOCOLS 3.2.1 General Sampling Protocols The following protocols will be employed during all sampling throughout this program: 1) 2) All sampling activities will be conducted in accordance with the RD Health and Safety Plan (Submittal A to the RD Work Plan) which was approved by USEPA on March 1, 1993. Sampling instruments and equipment used in collecting samples for chemical analysis will be cleaned in accordance with the following protocols: a) b) clean water and non-phosphate detergent wash using a brush; rinse thoroughly with potable water; 13 CONESTOGA-ROVERS & AsSOCJATFS I I I m 0 0 I I I I I I I I I I I I 3669 09) 3) 4) c) d) e) f) rinse twice with pesticide-grade isopropyl alcohol; rinse thoroughly with deionized water; allow equipment to air dry on a clean plastic sheet as long as possible; and tag, label, mark with date and wrap in aluminum foil until use. A new pair of disposable latex gloves will be used at each sampling location. Additional glove changes will be undertaken as conditions warrant. Sampling and analysis activities, decontamination activities and the selection, use and calibration of sampling equipment and instruments will follow the protocol and guidelines of the Region IV Standard Operating Procedures (SOPs) USEPA Region IV, February 1, 1991. Additional protocols specific to each sampling method are presented in the following sections. 3.2.2 Monitoring Well Sampling 3.2.2.1 Well Purging Prior to sample collection, all monitoring wells will be purged in accordance with the following protocols: 1) Water levels in all wells will be measured to ±0.01 foot prior to purging. 2) All wells will be purged by one of the following techniques: a) b) bailing with a bottom loading stainless steel/Teflon bailer attached to a nylon rope; a Teflon bladder stainless steel pump fitted with Teflon discharge and polyethylene air supply lines attached to a nylon rope; 14 CONESTOGA-ROVERS & ASSOCIATES I I I I I 0 I I I I I I I I I I I 3669 09) 3) 4) c) d) a peristaltic pump with a Teflon discharge line; or a two-inch submersible pump. Discharge tubing, if used, will be dedicated to each well. The small length of silicon tubing within the peristaltic pump will not be replaced between wells. New nylon rope and polyethylene tubing, where applicable, will be used at each well location. The preferred method for well purging is bailing with a bottom loading stainless steel/Teflon bailer. The other methods will be used as alternates in the event that the preferred method cannot be used. Purging will be conducted until a minimum of three well volumes are evacuated. After each well volume is evacuated, a sample will be collected and analyzed for pH, temperature and conductivity. All purge water will be handled in accordance with the protocols specified in Section 3.3. 3.2.2.2 Monitoring Well Sampling Procedure Sampling frequency will be conducted according to the monitoring program presented in Table 3.1. The monitoring well locations are shown on Figure 3.1. Following well purging, monitoring well sampling will be carried out according to the following protocols: 1) Water samples will be collected for chemical analysis using one of the following techniques: a) a bottom loading stainless steel/Teflon bailer attached to a nylon rope; or 15 CONESTOGA-ROVERS & ASSOCIATES I I I I I I I I I I I I I I I I 2) 3) 4) 3669 09) b) a Teflon bladder stainless steel pump fitted with Teflon discharge tubing and polyethylene air supply lines attached to a nylon rope. Prior to use in any monitoring well, the sampling equipment will be precleaned as described in Section 3.2.1. New nylon rope and polyethylene tubing, where applicable, will be used at each well location. In the event that the groundwater is still turbid following purging, additional purging and/ or alternate sampling techniques (i.e. low pumping rate) may be utilized to collect representative samples which are sediment-free or samples that are as sediment-free as possible. In the event that a well is purged dry, sample collection will commence on the following day and continue for up to four consecutive days to obtain the required sample volume. Sampling may commence on the day of purging if the water level recovers to static water level within four hours after completion of purging. A well shall be deemed dry for sampling purposes if the volume of water collected over four days is not sufficient for the required analysis. The above procedure may require four consecutive days for slow recovering wells. Sufficient groundwater will be collected for chemical analysis of voe, BNA, PeBs and a select list of metals (see Section 3.2.5.2). Groundwater samples collected for voe analysis will be collected in 3 x 40 mL glass septum cap vials each preserved with four drops of He!. BNA and PeBs groundwater samples will be collected in two I liter amber glass bottles for each analysis. The select list metals groundwater samples will be collected in 500 mL polyethylene bottles and preserved with 50% HN03 to pH <2. Sample containers will be IeH-EM 300 series or equivalent to ensure containers are analyte free. Sample containers will be shipped to the site in sealed containers from a single lot of prepared bottles. A trip blank will be included for all aqueous voe sampling events. The trip 16 CONESTOGA-ROVERS & AssoaATES I I I g D I I I I I I I I I I 3669 (19) 5) 6) 7) blank will be prepared, in duplicate, in the laboratory, and will consist of two sets of bottles from the_ same lot of bottles as the sample bottles, filled with distilled/ deionized water. One set will be retained in the lab and the second set will be sent with the sample bottles. Both sets will be analyzed using the same protocols as those used for water sample analysis. Field measurements of pH (using a Fisher Model MDL-107 pH meter or equivalent), conductivity and temperature (using a YSI Model 33 SCT meter or equivalent) will be taken after well purging, prior to sample collection. Calibration of field instruments will be undertaken daily, at the beginning of the day in accordance with manufacturer's specifications. A blind field duplicate sample will be collected per set of samples per matrix (a set of samples is defined as the samples collected in a matrix for a specific sampling event, for example a groundwater sampling round) or at a minimum frequency of one in ten locations per matrix. A rinsate sample will be collected per set of samples or at a minimum frequency of one in ten locations. The rinsate sample will consist of deionized/distilled water poured into, and then sampled out of, a bailer /pump cleaned under the protocol specified for sampling equipment. The rinsate blank collected for metals will be in duplicate (filtered and unfiltered). - Table 3.2 presents a summary of field quality control procedures established for both water and soil gas matrices. Quality control protocols are presented in the RGV QAPP, which is presented in Section 4.0. 3.2.3 Groundwater Treatment System Sampling Procedure The groundwater treatment system sampling procedure will consist of sampling the influent and effluent water. The sampling locations will be sample taps situated in the influent piping to the treatment 17 CONESTOGA-ROVERS & ASSOOATES I g D u I I I I I I -1 I I I I I I m TABLE 3.2 FIELD QUALITY CONTROL PROCEDURES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Matrices Trip Blank Groundwater, one per set of samples Treatment System Water Soil Gas, SVE Exhaust Gas Note: Rinsate Sample one per set of samples or a minimum of 1 in 10 investigatory sampling locations (2) Field Duplicate one per set of samples or a minimum of 1 in 10 investigatory sampling locations one per set of samples or a minimum of 1 in 10 investigatory sampling locations (1) Additional sample (three times the designated value) will be collected for matrix spike/matrix spike duplicate analyses. (2) Where sampling equipment, such as hailers, are used. Matrix Spike/ Matrix Spike Duplicates (1) one per set of samples or a minimum of 1 in 20 investigatory sampling locations one per set of samples or a minimum of 1 in 20 investigatory sampling locations (3) (3) For soil gas and SVE treatment system samples, one matrix spike and one duplicate will be performed by the laboratory per 20 investigative samples. CRA 3669(19) D I ll I I I I I I I I I I I I I I I 'I ,, 3669 (19) system at the aeration tank and effluent will be sampled at the manhole located on Cason Street. Samples will be obtained by opening the sample tap and allowing the water to flow through the sample tap for five minutes. The samples will then be collected directly into the sample container. Sufficient untreated or treated water will be collected for VOC, BNA, PCBs and a select list of metals analyses, as required by the monitoring frequency set out in Table 3.1. Sample container requirements, field measurements and field quality control procedures are the same for wastewater sampling as those presented for groundwater in Section 3.2.2.2, above. 3.2.4 Gas Monitoring 3.2.4.1 SVE Exhaust Gas Monitoring The SVE gas samples will be collected from a sampling port in the exhaust side of the SVE vacuum blower, upstream from the treatment unit. The samples will be collected in accordance with the following protocols for VOCs: 2) 3) The samples will be collected by attaching a pre-evacuated, 6 liter Summa® gas canister to the sampling port using Swageloc® compression tube connectors. The samples will be collected while the vacuum blower is operating at its nominal flow rate and pressure by opening both the sample port valve and the Summa® canister valve. The valves will be left open until the pressure on the canister has equilibrated with that on the SVE exhaust line as indicated by a pressure gauge on the intake of the canister. 18 CONESTOGA-ROVERS & Asso□ATES I I I ' D D ,, ' I I I I I I I I I I I I 3669 09) 4) The valve on the canister will be closed and then the valve on the exhaust port will be closed. 5) The canister will be labeled with the location, time, date, sampler name, initial and exhaust pressure as specified in the RGV QAPP. QA/QC samples (duplicates) will be collected as specified in the RGV QAPP. 6) The samples will be shipped to the laboratory within 24 hours of collection. 3.2.4.2 SVE Treatment System Gas Monitoring The SVE treatment system gas will be monitored for total VOCs by periodic PIO measurements. The measurements will be made according to the following protocols: 1) The PIO (HNu) will be calibrated as described in Section 4.5.3.3 of the RGV QAPP; and 2) The measurements will be taken while the vacuum blower is operating at its nominal flow rate. 3.2.4.3 Soil Gas Monitoring Soil gas samples will be collected from the permanent monitoring probes which were placed in the former landfill during the SVE treatability study conducted in 1993, according to the following protocols: 1) Samples will be collected after the SVE system has been shut off at least 48 hours. 19 CONESTOGA-ROVERS & AssoaATFS " a I I I u I I I I -' ' I· I '; t! I ,,1 I 11 I I &! I ,: I ' fi I I' ·1 2) 3) 4) 5) 6) 7) 8) Samples will be collected by attaching a pre-evacuated, 6 liter Summa® gas canister and portable vacuum pump with a T-connector to the probe with the valves on the probe and canister closed. The probe will be evacuated for a sufficient time to remove three probe volumes of gas at standard temperature and pressure. The probe evacuation volume will be calculated based on the volume of the tubing leading to the sampling interval and the approximate pore volume of the sand pack in the sampling interval. After purging is complete, but prior to shutting off the vacuum pump, the valve between the pump and the T-connector will be closed. The vacuum pump will then be shut off. With the probe valve open and the canister valve shut, the probe will be allowed to equilibrate to ambient pressure. After the vacuum gauge on the probe has read zero vacuum for one minute, the valve on the Summa® canister will be opened to collect the sample. Sampling will be complete after the vacuum gauge on the probe has read zero vacuum for one minute and the valves on the canister and the probe will be closed. The canister will be labeled with the location, time, date and sampler name as specified in the RGV QAPP. QA/QC samples (duplicates) will be collected as specified in Table 3.2. The samples will be shipped to the laboratory within 24 hours of / collection. 3.2.5 Sample Labeling and Control Sample labeling and control will be consistent with USEPA requirements and CRA procedures. These procedures are discussed below. 366909) 20 CONESTOGA-ROVERS & ASSOOATES I I I I I I I ~ 'i I I I -I I\ I ,1 I ti I Ii I 11 I 3669 09) 3.2.5.1 Initial Labeling of Samples A unique numbering system will be used to identify each collected sample. This system will provide a tracking number to allow retrieval and cross-referencing of sample information. A listing of the sample identification numbers with written descriptions of sample location, type, time and date will be maintained by CRA's on-Site personnel. The sample number system to be used is described as follows: Example: where: w YYMMDD AA xxxx W-YYMMDD-AA-XXXX -designates sample type (W -water, G -gas) -date of collection (year, month, day) sampler initials -sequential number starting with 0001 Quality Control samples will also be numbered with a unique location number using this numbering system. CRA's on-Site personnel will be responsible for recording the sampling activities for each day and will record in the log book the following with respect to each sample: 1) 2) 3) 4) Unique sample identification number; Sampling location identification; Date/time of sample collection; and Sampling data/remarks. 21 CONESTOGA-ROVERS & ASSO□ATE.S • 3669 09) 3.2.5.2 Sample Shipment All water and soil samples will be placed in laboratory supplied coolers and iced to 4°C (±2°C) after collection and labeling. Summa® canisters and the filter with adsorbent cartridge will be placed in the original shipping cartons. All samples will be delivered to the laboratory within 48 hours of sample collection by commercial courier. Individual sample bottles will not be sealed; however, each cooler will be sealed with a transportation security seal containing the sampler's initials. The cooler will then be sealed with packing tape. Table 3.3 presents a summary of sample collection, preservation and shipping requirements. 3.2.5.3 Chain-of-Custody-Records CRA chain-of-custody records will be used to track all samples from the time of sampling to the arrival of samples at the laboratory. Three original copies of the chain-of-custody record will accompany the sample shipment to the laboratory and will be signed and retained by the receiving laboratory's sample custodian. A copy of the chain-of-custody record will be retained by the shipper. Two completed copies will be returned to CRA by the laboratory. A typical chain-of-custody form is presented on Figure 3.2. 3.2.6 Analytical Protocols 3.2.6.1 Scope Samples collected for chemical analysis as described in the previous sections will be analyzed for TCL VOCs, TCL BNAs, and a select list of PCBs and metals. Tables 3.4 and 3.5 present the TCL VOCs and TCL BNAs, respectively. Tables 3.6 and 3.7 present the list of select PCBs and metals, 22 CONESTOGA-ROVERS & AssoaATES Matrix Groundwater, Treatment System Water Soil Gas, SVE Exhaust Gas Note: TABLE 3.3 SAMPLE COLLECTION, PRESERVATION AND SHIPPING PROTOCOL SUMMARY JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Parameter Bottles/Jars Preservatives Holding Time (1) Shipping TCLVOCs - 3 x 40-ml glass -iced to 4 °C (±2°C) -14 days -Federal Express septum vials -preserved with Priority 1 four drops of HCI topH<2 TCLBNAs - 2 x I-litre amber glass -iced to 4°C (±2°C) - 7 days until -Federal Express bottle extraction, Priority 1 40 days after extraction TCLPCBs - 2 x I-litre amber glass -iced to 4°C (±2°C) - 7 days until -Federal Express bottle extraction, Priority 1 40 days after extraction Select List -500-ml polyethylene -iced to 4 °C (±2°C) - 6 months -Federal Express Metals bottle -preserved with 50% Priority 1 HNO3topH<2 TCLVOCs -Summa® canister -none -30 days -Federal Express Priority 1 (1) Sample holding time will be calculated from the time of sample collection to sample analysis. CRA 3669(19) Packaging -Cooler, Cushioning (i.e. bubble pack, foam) -Cooler, Cushioning (i.e. bubble pack, foam) -Cooler, Cushioning (i.e. bubble pack, foam) -Cooler, Cushioning (i.e. bubble pack, foam) -packing carton CRA CHAIN OF CUSTODY RECORD CRA SHIPPED TO (Laboratory Name): REFERENCE NUMBER: CONESTOGA-ROVERS & ASSOCIATES 651 Colby Drive Waterloo, Ont. N2V 1 C2 1519188-4-0510 SAMPLER'S PRINTED lslGNATURE: NAME: SEO DAT£ TIME SAMPLE No, No. TOTAL NUMBER OF CONTAINERS RELINQUISHED BY: DATE: (i) TIME: I ~UNOUISHED BY: DATE: TIME: I ~UNOUISHED BY: DATE: TIME: METHOD OF SHIPMENT: White -Fully Executed Copy SAMPLE TEAM: Yellow -Receiving laboratory Copy Pink -Shipper Copy Goldenrod Sampler Copy Vl PA~REMARKS ... f!j Oz -~ SAMPLE Oz TYPE Zo u . HEALTH CHEMICAL HAZARDS T ~CEIVED BY: DATE: TIME: ~CEIVED BY: DATE: TIME: ~CEIVED BY: DATE: TIME: WAY BILL No. RECEIVED FOR LABORATORY BY: DATE: TIME: figure 3.2 CHAIN OF CUSTODY FORM JADCO-HUGHES SITE Gaston County, NC 3669 (19) JAN 13/94(W) REV.O (F-03) I I I I ' I I ' I I I I I I j I' I :I CRA366909) TABLE 3.4 TCLVOCs REMEDIAL ACTION JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN CAS No. 71-55-6 79-34-5 79-00-5 75-34-3 75-35-4 78-87-5 591-78-6 108-10-1 107-06-2 156-60-5 67-64-1 71-43-2 75-27-4 75-25-2 74-83-9 78-93-3 75-15-0 56-23-5 108-90-7 75-00-3 67-66-3 74-87-3 10061-01-5 124-48-1 100-41-4 75-09-2 108-42-5 127-18-4 108-88-3 1330-20-7 10061-02-6 71-01-6 75-01-4 Compound 1, 1, 1-trichloroethane 1, 1,2,2-tetrachloroethane 1,1,2-trichloroethane 1, 1-dichloroethane 1, 1-dichloroethene 1,2-dichloropropane 2-hexanone 4-methyl-2-pentanone 1,2-dichloroethane 1,2-dichloroethene (total) acetone benzene bromodichloromethane bromoform bromomethane butanone carbon disulfide carbon tetrachloride chlorobenzene chloroethane chloroform chloromethane cis-1,3-dichloropropene dibromochloromethane ethyl benzene methylene chloride styrene tetrachloroethene toluene total xylenes trans-1,3-dichloropropene trichloroethene vinyl chloride TCL -Target Compound List VOCs -Volatile Organic Compounds CAS -Chemical Abstract Service I I g I I D 0 I u I I 11 I I I t I' I I CRA3669 09) Page 1 of2 TABLE 3.5 TCL BNAs REMEDIAL ACTION JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN CAS No. 120-82-1 95-50-1 541-73-1 106-46-7 95-95-4 88-06-2 120-83-2 105-67-9 51-28-5 121-14-2 606-20-2 91-58-7 95-57-8 91-57-6 95-48-7 88-74-4 88-75-5 91-94-1 99-09-2 534-52-1 101-55-3 59-50-7 106-47-8 7005-72-3 106-44-5 100-01-6 100-02-7 83-32-9 208-96-8 120-12-7 56-55-3 50-32-8 205-99-2 191-24-2 207-08-9 111-91-1 111-44-4 Compound 1,2,4-trichlorobenzene 1,2-dichlorobenzene 1,3-dichlorobenzene 1,4-dichlorobenzene 2,4,5-trichlorophenol 2,4,6-trichlorophenol 2,4-dichlorophenol 2,4-dimethylphenol 2,4-dini trophenol 2,4-dini trotol uene 2,6-dinitrotoluene 2-chloronaphthalene 2-chlorophenol 2-methylnaphthalene 2-methylphenol 2-nitroaniline 2-nitrophenol 3 ,3' -dichlorobenzidine 3-ni troaniline 4,6-dini tro-2-meth ylphenol 4-bromophenyl phenyl ether 4-chloro-3-meth y 1 phenol 4-chloroaniline 4-chlorophenyl phenyl ether 4-methylphenol 4-nitroaniline 4-ni trophenol acenaphthene acenaphthylene anthracene benzo(a)anthracene benzo(a)pyrene benzo(b )fl uoran thene benzo(g,h,i)perylene benzo(k) fl uor an thene bis(2-chloroethoxy)methane bis(2-chloroethyl)ether 8 B I I I I I I I ' I I I I I I I I I CRA366909) Page2of2 TABLE 3.5 TCL BNAs REMEDIAL ACTION JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN CAS No. 39638-32-9 117-81-7 85-68-7 86-74-8 218-01-9 84-74-2 117-84-0 53-70-3 132-64-9 84-66-2 131-11-3 206-44-0 86-73-7 118-74-1 87-68-3 77-47-4 67-72-1 193-39-5 78-59-1 621-64-7 86-30-6 91-20-3 98-95-3 87-86-5 85-01-8 108-95-2 129-00-0 Compound bis(2-chloroisopropyl)ether bis(2-ethylhexyl)phthalate butylbenzylphthalate carbazole chrysene di-n-bu tylph thalate di-n-octyl phthalate dibenz(a,h)anthracene dibenzofuran diethyl phthalate dimethylphthalate fluoranthene fluorene hexachlorobenzene hexachlorobutadiene hexachlorocyclopentadiene hexachloroethane indeno( 1,2,3-cd)pyrene isophorone N-nitroso-di-n-dipropylamine N-nitrosodiphenylamine naphthalene nitrobenzene pen tachlorophenol phenanthrene phenol pyrene TCL -Target Compound List BNAs -Base, Neutral and Acid Extractable Compounds CAS -Chemical Abstract Service I I I D 0 u I I I I I I I I I I I I I CRA 3fJ69 0 9) TABLE 3.6 PCBs JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN CAS No. 11141-16-5 12672-29-6 Compound Aroclor-1232 Aroclor-1248 I I ff 0 R I I I I I I I I I I I I I I CRA3669 09) TABLE 3.7 INORGANIC ANALITES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN CAS No. 7440-38-2 7440-43-9 7440-47-3 7439-92-1 7440-02-0 Inorganic Compound arsenic cadmium chromium lead nickel I I 0 0 I I I I I I I I I I I I I I 3669 09) respectively. These metals were selected from the list of analytes in the Remedial Investigation and pre-RD database, based upon the frequency of detection in groundwater samples from the on-Site monitoring wells. Analytical work will be completed using approved USEPA methodologies as specified in the following sections. 3.2.6.2 Sample Analysis Samples collected for chemical analysis will be analyzed using approved analytical methods as outlined in the RGV QAPP. Practical Quantification Limits (PQLs) for water and gas matrices are also presented in the RGV QAPP. PQLs are highly matrix dependent, thus, the PQLs are provided for guidance and may not always be achievable. 3.2.6.3 Data Quality Assessment The laboratory data assessment will be conducted by the laboratory quality assurance officer, who will review data and identify results where additional work is required. This additional work may take the form of re-analysis or resampling and analysis. Internal quality control tests will be conducted by the laboratory in accordance with their standard operating procedures and the individual method requirements. · The CRA data assessment is carried out by the CRA Quality Assurance Officer-Analytical Activities to evaluate the quality and utility of the data, as a level of quality assurance beyond that provided by the laboratory. The analytical data will be evaluated based on criteria outlined in the RGV QAPP. The quality and acceptability or unacceptability of the data will be determined following the reporting of the laboratory analysis. The 23 CONESTOGA-ROVERS & ASSOOATFS I I B B u I I I I I I I I I I I I I I 3669 09) data will be examined for the acceptability of trip blanks, rinsate samples, field duplicate samples, percent recoveries of MS/MSD analyses, surrogate compounds and control samples. In the event that data are deemed unacceptable, a decision will be made by CRA regarding the appropriate corrective action. The corrective action may include resampling, re-analysis or data qualification. 3.2.6.4 Reporting CRA will document sampling and analytical activities in the periodic progress report under "Analytical Data". The information will include: • sample code; • analysis requested; • specific samples which were split with USEPA; • the anticipated date of preliminary data; • the expected date of verified data; and • analytical date received. 3.3 WASTE MATERIAL HANDLING Purge water and decontamination fluids will be collected and discharged into the groundwater treatment system for treatment prior to discharge. Other sampling-generated wastes, including personal protective equipment, will be containerized on Site in labeled or marked containers and disposed of periodically. 3.4 ON-SITE HEAL TH AND SAFETY PLAN The sampling plan described in Section 3.0 involves the collection of gas, treated water and groundwater samples at the Jadco-Hughes 24 C0NESTOCA·R0VERS & ASS0OATES I I I u u I I I I I I I I I I I I I I 366909) Site in Gaston County, North Carolina. During the·program personnel may come in contact with materials that contain VOCs, BNAs and PCBs. During the program, provisions for health and safety will be implemented which are designed to ensure: 1) Personnel working on Site are not adversely exposed to Site contaminants; 2) The health and safety of the general public and the environment is not compromised by off-Site migration of contaminated materials; and 3) Compliance with applicable governmental and non-governmental (American Conference of Governmental Industrial Hygienists) regulations and guidelines. The Health and Safety Plan under which work under this RGV Plan will be completed is presented in the EPA-approved document entitled "Health and Safety Plan, Remedial Design Work Plan, Submittal A, Jadco-Hughes Site, Gaston County, North Carolina" (CRA, 1991). 25 CONESTOGA-ROVERS&: ASSOOATFS I a 0 u I I I I I I I I I I I I I I I 4.0 3669 09) RGV QUALITY ASSURANCE PROTECT PLAN (OAPP) 4.1 INTRODUCTION Procedures presented within this document will be used for sample collection and laboratory analyses in support of the RA. This RGV QAPP is consistent with "Environmental Compliance Branch Standard Operating Procedures and Quality Assurance Manual", USEPA Region IV, February 1, 1991 and "Laboratory Operating and Quality Control Manual", USEPA Region IV, September 1990. CRA's project management team and technical resource personnel for this project are described in Section 16.0 of the RA Work Plan. The Steering Committee has contracted analytical services to ENSECO Laboratories, as discussed in the RA Work Plan. ENSECO's key project personnel are listed below: Project Manager -Pat Mclsaac (ENSECO) -Ensures all laboratory resources are available on an as-required basis -Overviews final analytical report -Oversees all laboratory's activities Operations Managers -Steven D. Harris (Air Toxics) and Gary Tort (Rocky Mountain) -Coordinate laboratory analyses -Supervises in-house chain-of-custody -Schedule sample analyses -Oversees data review -Prepares analytical reports -Approves final analytical reports prior to submission to CRA. Quality Assurance Officers -Overview laboratory quality assurance 26 C0NESTOCA·R0VERS & ASS0OATFS I m u B I I I I I I I I I I I I I I I 3669 09) -Overview QA/QC documentation -Conduct detailed data review -Decide laboratory corrective actions, if required -Technical representation of laboratory QA procedures Sample Custodians -Receive and inspect the incoming sample containers -Record the condition of the incoming sample containers -Sign appropriate documents -Verify chain-of-custody and its correctness -Notify laboratory manager and laboratory supervisor of sample receipt and inspection Assign a unique identification number and customer number and enter each into the sample receiving log -Initiate sample transfers to appropriate lab sections with the help of the laboratory manager -Control and monitor access/ storage of samples and extracts 4.2 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT DAT A The overall QA objective is to develop and implement procedures for field sampling, chain-of-custody, laboratory analyses and reporting which provide accurate and precise data. Specific procedures to be used for sampling, chain-of-custody, calibration, laboratory analysis, reporting, quality control, audits, preventive maintenance and corrective actions are presented in other sections of this RGV QAPP. Data quality objectives (DQO) have been established in accordance with the USEPA guidance document entitled "Data Quality Objectives for Remedial Response Activities," EPA/540/G-87 /003, March 1987, dated March 25, 1986, to ensure that the database developed during the Site investigation meets the objectives and quality necessary for its 27 CONESTOGA-ROVERS & ASSOOATES I I I I I I I I I I I I I I I I I I I 3669 09) intended use, namely, evaluation of the success of the RA system in achieving the remediation goals. DQOs can be classified for measurement data by defining the level of analytical support assigned to each type of measurement data. In general, water and soil gas analyses will require level III analytical support. The level III sqpport for the analyses will require that all organics and inorganics are analyzed using SW-846, Third Edition, Final Update, July 1992 (SW-846) methods. Level III analytical results will be used for remedial action purposes. Precision and accuracy data derived from Level III techniques (i.e. SW-846 methods) has historically proven to be acceptable for remediation use. This level of quality adequately served the data needs during the RI/FS process, and would yield results that are comparable to the RI/FS during remediation activities. The data will be used to monitor the effectiveness of the remediation. The deliverables required for Level III analytical data packages are presented in Section 4.7. These deliverables are considered by . CRA to be acceptable for validation of the precision and accuracy of the data. Laboratory quality control procedures for this level of data are presented in Section 4.8. The quality control samples to be collected are presented in Table 4.1. Field screening activities such as determining of pH, specific conductance, temperature and the total VOC concentration in air using a PID will require Level I analytical support. The use of the analytical support levels defined above will ensure that the overall objectives for the RA will be met. 28 CONESTOGA-ROVERS & ASSOOATES I I B I I I I I I I I I I I I I I I I Sample TABLE4.1 SUMMARY OF SAMPLING AND ANALYSIS PROGRAM (1) JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Qua Ii~ Assurance Same_les (2) Field Laboratory Field Trip MS/ Matrix Parameters Parameters Duplicates Rinsate Blanks (3) MSD (4) (5) Groundwater, Treatment System Water Soil Gas (6) SVE Gas (6) Notes: pH, voes Conductivity BNAs Temperature Select Metals Select PCBs Atmospheric voes Pressure, Temperature PID voes 1 1 1 1 1 0 1 1 0 1 1 0 1 1 (1) Table 3.1 of the RGV SAP lists the Monitoring Summary. Table 4.1 lists the necessary QA/QC:. samples per sampling event. 1 1 1 1 (2) Entries reflect number of QA samples per ten samples or number of QA samples per day of sampling events. (3) Trip blank samples are used when aqueous VOC samples arc collected. (4) Matrix spike/matrix spike duplicate sample. (5) Entries reflect number of QA samples per 20 samples. (6) MS/MSD Samples are replaced with duplicate and spiked analyses. Spike compounds will be added using a cryogenic trap by the laboratory. TCL -Target Compound List voe -Volatile Organic Compounds BNA -Base, Neutral and Acid Extractable Compounds PCBs -Polychlorinated biphenyls PIO -Photoionization Detector CRA 3669 09) I I B I I I I I I I I I I I I I I I I 3669 09) 4.2.1 Level of OA Effort To assess the quality of data resulting from the field sampling program, field duplicate samples, rinsate samples (bailer rinse, etc.) trip blank samples, and matrix spike/matrix spike duplicate (MS/MSD) samples will be taken (where appropriate see Table 3.2) and submitted to the analytical laboratory. For field samples which are collected, field duplicate samples will be collected at a frequency of 1 per 10 or at least one per day of sampling activity. One matrix spike/matrix spike duplicate (MS/MSD) sample will be analyzed per 20 investigative samples per matrix, excluding soil gas and SVE exhaust gas. One MS and one duplicate will be performed per 20 investigative samples in the laboratory, for soil gas and SVE exhaust gas samples. Rinsate blank samples will be submitted at a frequency of 1 per 10 well purgings/sampling equipment cleanings or at least once per day of well purging/sampling equipment cleanings (when sampling equipment such as bailers are used). Rinsate blanks will be collected by routing deionized, distilled water through decontaminated sampling equipment. Trip blank samples for voe analyses (prepared by the laboratory and consisting of organic-free water poured into the sample vials) will be shipped with each shipment container of voe sample vials by the laboratory. Trip blanks samples will be handled in a manner consistent with actual field sample handling and will be shipped back to the laboratory each day with the daily field samples. The trip blanks samples will provide a measure of potential cross contamination of samples during shipment and handling. Trip blanks will not be opened in the field. Blank samples will be analyzed to check procedural contamination and/or ambient conditions and/or sample container contamination that may be responsible for sample contamination. 29 CONESTOGA-ROVERS & ASSOCIATES 0 0 I E I I I I I I I I I I I I I I 3669 (19) If blank samples are found to contain any of the target analytes, the following procedure will be followed. First, contamination will be verified by examining the associated investigative samples and laboratory's method blanks. The data will then be examined to determine the extent of contamination and all associated data will be qualified according to the data validation guidelines given in Section 4.7. Field duplicate samples will be analyzed to check for sampling and matrix heterogeneity. Field duplicate samples are to be used as a measure of precision throughout the sampling event. Comparison of field duplicate samples will be based upon the detected target analytes and the relative percent differences (RPD) of each analyte's concentrations. The parameters which do not meet the criteria may only be used as qualitative measurements. Professional judgment shall determine the RPD limits on a sample-to-sample basis. The sampling and analysis program is summarized in Table 4.1, which lists the specific parameters to be measured, the number and frequency of sampling and the level of QA effort required for each matrix. 4.2.2 Accuracy. Sensitivity and Precision of Analysis The fundamental QA objective with respect to the accuracy, sensitivity, and precision of analytical data is to achieve the QC acceptance criteria of each analytical protocol. The sensitivities required for these organic and inorganic analyses will be at least the targeted quantitation limits listed in Tables 4.2 through 4.4. These tables present targeted quantitation limits for all target analytes. Lower method quantitation limits, if achieved by the laboratory, will be substituted for the targeted quantitation limits in the final report. 30 CONESTOGA-ROVERS & ASSOOATES a I B I I I I I I I I I I I I I I I TABLE4.2 TARGETED QUANTIT A TION UMrrs1. ANALYTICAL METHODS OF ANALYSIS AND MATRIX SPIKE/MATRIX SPIKE DUPLICATE ANALYSES RECOVERY CONTROL LIMITS FOR ORGANIC ANALYSES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Targeted Ouantitation Umtts W,:iter . MSIMSD 2Recovery Control Limtts3. Compound Cas No. VOLATILE ORGANIC COMPOUNDS Analytical Method4: 8240 1,1,1-trichloroethane 71-55-6 1,1,2,2-tetrachloroethane 78-34-5 1, 1,2-trichloroethane 79-00-5 1, 1-dichloroethane 75-34-3 1, 1-<lichloroethene 75-35-4 1,2-dichloroethane 107-06-2 1,2-dichloroethene (total) 40-59-0 1,2-<lichloropropane 78-87-5 2-hexanone 591-78-6 4-methyl-2-pentanone 108-10-1 acetone 67-64-1 benzene 71-43-2 bromodichloromethane 75-27-4 bromoform 75-25-2 bromomethane 74-83-9 butanone 78-93-3 carbon disulfide 75-15-0 carbon tetrachloride 56-23-5 chlorobcnzcne 108-90-7 chloroethane 75-00-3 chloroform 67-66-3 chloromethane 74-87-3 ds-1,3-<I ichloropropene 10061-01-5 dibromochloromethane 124-48-1 ethylbenzene 100-41-4 methylene chloride 75-09-2 styrene 100-42-5 tetrachloroethene 127-18-4 toluene 108-88-3 trans-1,3-<I ichloropropene 10061-02-6 trichloroethene 79-01-6 vinyl chloride 75-01-4 xylenes (total) 1330-20-7 CRA 3669 (19) (µg/L) 5 5 5 5 5 5 5 5 10 10 10 5 5 5 10 10 5 5 5 10 5 10 5 5 5 5 5 5 5 5 5 2 5 Water 61-145(14) 76-127(11) 75-130(13) 76-125(13) 71-120(14) Pagel of4 I 0 D I I I I I I I I I I I I I I I Compound TABLE4.2 TARGETED QUANTITATION UMrrs1, ANALYTICAL METHODS OF ANALYSIS AND MA TRIX SPJKFJMA TRIX SPIKE DUPLJCA TE ANALYSES RECOVERY CONTROL LIMITS FOR ORGANIC ANALYSES JADCQ.HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Cas No. Tar.geted Ouantitation Umtt, WRter (µg/L) BASE, NEUTRAL AND ACID EXTRACTABLE COMPOUNDS Analytical Method4: 8270 Extraction Method: 3520 (Water) 1,2,4-trichlorobenzene 120-82-1 10 1,2-dichlorobenzene 95-50-1 10 1,3-dichlorobenzene 541-73-1 10 1,4-dichlorobcnzene 106-46-7 10 2,4,5-trichlorophenol 95-95-4 50 2,4,6-trichlorophenol 88-06-2 10 2,4-dichlorophenol 120-83-2 10 2,4-dimethylphcnol 105-67-9 10 2,4-dinitrophenol 51-28-5 50 2,4.Jinitrotoluene 121-14-2 10 2,6-d.initrotoluene 606-20-2 10 2-chloronaphthalene 91-58-7 10 2-chlorophenol 95-57-8 10 2-methylnaphthalene 91-57-6 10 2-mcthylphenol 95-48-7 10 2-nitroaniline 88-74-4 so 2-nitrophenol 88-75-5 10 3,3'-dichlorobenzidine 91-94-1 20 3-nitroaniline 99-09-2 so 4,6-dinitro-2-methylphcnol 534-52-1 50 4-bromophenylphenylether 101-55-3 10 4-chloro-3-methylphcnol 4-chloroaniline 106-47-8 10 4-chlorophcnylphenylether 7005-72-3 10 4-methyl phenol 106-44-5 10 4-nitroaniline 100-01~ so 4-nitrophenol 100-02-7 so acenaphthene 83-32-9 10 acenaphthylene 208-96-8 10 anthracene 120-12-7 10 benzo(a)anthracene 56-55-3 10 benzo(a)pyrene 50-32-8 10 benzo(b)fluoranthene 205-99-2 10 benzo(g,h,i)perylene 191-24-2 10 benzo(k)fluoranthene 207-08-9 10 bis(2-chloroethoxy)methane 111-91-1 10 bis(2-chloroethyl)ether 111-44-4 10 bis(2-chloroisopropyl)ether 108-60-1 10 bis(2-ethylhexyl)phthalate 117-81-7 10 butylbenzylphthalate 85~8-7 10 carbazole 86-74-8 10 chrysene 218-01-9 10 OlA.366909) MSIMSD 2Recove,y Control Limit.ii Water 39-98(28) 36-97(28) 24-96(38) 24-96(38) 27-123(40) 10-80(50) 46-118(31) Page 2of 4 u I m I I I I I I I I I Compound TABLE4.2 TARGETED QUANTIT A TION UMrrs1, ANALYTICAL METHODS OF ANALYSIS AND MA TRIX SPIKE/MA TRIX SPIKE DUPLICATE ANALYSES RECOVERY CONTROL LIMITS FOR ORGANIC ANALYSES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Cas No. Targeted Ouantitation Limits Water (µg/L) BASE, NEUTRAL AND ACID EXTRACTABLE COMPOUNDS di-n-butyl phthalate di-n-octylphthalate dibenzo(a,h)anthracene dibenzofuran diethylphthalate dimethylphthalate fluoranthene fluorene hexachlorobenzene hexachlorobutadiene hexachlorocyclopentadiene hexachloroethane indeno(l,2,3-cd)pyrene isophorone n-nitroso-di-n-dipropylamine n-nitrosodiphenylamine naphthalene nitrobenzene (pa,a-chloro-meta-cresol) pentachlorophenol phenanthrene phenol pyrcne 84-74-2 117-84-0 53-70-3 132-64-9 84-66-2 131-11-3 206-44-0 86-73-7 118-74-1 87-68-3 77-47-4 67-72-1 193-39-5 78-59-1 621-64-7 86-30-6 92-20-3 98-95-3 59-50-7 87-86-5 85-01-8 108-95-2 129-00-0 JO JO JO JO JO JO JO JO JO JO JO JO 10 JO JO 10 JO JO JO so JO JO JO POLYCHLORINATED BIPHENYLS I Analytical Method4: 8080 I I I I I I Aroclor-1232 Aroclor-1248 CRA 3669 (19) 11141-16-5 12672-29-6 1.0 1.0 MSIMSD 2Recovery P,ntml Umttsl Water 41-116(38) 23-97(42) 9-103(50) 12-110(42) 26-127(31) Page3of 4 u I I I I I I I I I I I I I I I I TABLE 4.2 TARGETED QUANTITATION UMJTS1, ANALYTICAL METHODS OF ANALYSIS AND MA TRIX SPIKF/MA TRIX SPIKE DUPLICATE ANALYSES RECOVERY CONTROL LIMITS FOR ORGANIC ANALYSES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICA TJON PLAN Page 4of 4 1. Quantitation limits are provided for guidance purposes only as they may not always be technically achievable due to such factors as elevated analyte concentrations, which would require sample dilution and matrix interferences. In these cases, the laboratory quantitation limits will be submitted for the quantitation detection limits in accordance with the method(s) protocols. 2. MS/MSD -Matrix Spike/Matrix Spike Duplicate. 3. Values in parenthesis indicate maximum acceptable relative percent differences (RPD) between duplicate spike analyses. 4. 'Test Methods for Evaluating Solid Waste Physical/Chemical Methods", USEPA SW-846, Third Edition, Final Update, July 1992. CRA36611(19) I I I I I I I I I I I I I I I I I Compound TABLE4.3 TARGETED QUANTITATION UMITS1, ANALYTICAL METIIOD OF ANALYSIS AND MA TRIX SPIKE/MA TRIX SPIKE DUPLICATE ANALYSES RECOVERY CONTROL UMITS FOR INORGANIC ANALYSES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Cas No. Targeted Ouantitation Limits Water (µg/1) MSIMSv2 Recovery Control Limits3 Water SELECT LIST METALS Analytical Method 4: 6010/7000 Series arsenic cadmium chromium lead nickel Notes: 7440-38-2 7440-43-9 7440-47-3 7439-92-1 7440-02-0 10 5 10 5 40 75-125 (20) 75-125 (20) 75-125 (20) 75-125 (20) 75-125 (20) 1. Quantitation limits are provided for guidance purposes only as they may not always be technically achievable due to such factors as elevated analyte concentrations, which would require sample dilution and matrix interferences. In these cases, the laboratory quantitation limits will be submitted for the quantitation limits in accordance with the method(s) protocols. 2. MS/MSD -Matrix Spike/Matrix Spike Duplicate. Spike and duplicate analyses may be used in place of MS/MSD analyses. 3. Values in parenthesis indicate maximum acceptable relative percent differences (RPO) between duplicatee analyses. 4. "Test Methods for Evaluating Solid Waste Physical/Chemical Methods", USEPA SW-846, Third Edition, Final Update, July 1992. CRA.366909) 0 H I I I I I I I I I I I I I I I I I Compound TABLE4.4 TARGETED QUANTITATIONLIMITS1 AND ANALYTICAL METHODS FOR GAS SAMPLES JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Cas No. Targeted Quantitation Limits (ppb; v/v) VOLATILE ORGANIC COMPOUNDS Analytical Method2 TO-14 1,1, I-trichloroethane 1, 1,2,2-tetrachloroethane 1, 1,2-trichloroethane 1,1-dichloroethane I, 1-dichloroethene 1,2-dichloroethene (total) 1,2-dichloroethane 1,2-dichloropropane 2-hexanone 4-met hyl-2-pen tanone acetone benzene bromodichloromethane bromoform l:iromomethane butanone carbon disulfide carbon tetrachloride chlorobenzene chloroethane chloroform chloromethane cis-1,3-dichloropropene dibromochloromethane ethyl benzene methylene chloride styrene tetrachloroethene toluene lrans-1,3-dichloropropene trichloroethene vinyl chloride xylenes (total) Notes: 71-55-6 2 78-34-5 4 79-00-5 3 75-34-3 2.5 75-35-4 2 40-59-0 6 107-06-2 2 78-87-5 8 591-78-6 5 108-10-1 3 67-64-1 10 71-43-2 3 75-27-4 2 75-25-2 2 74-83-9 3 78-93-3 3 75-15-0 10 56-23-5 2 108-90-7 2.5 75-00-3 5 67-66-3 2 74-87-3 2.5 10061-01-5 3 124-48-1 2 100-41-4 2.5 75-09-2 4 100-42-5 7 127-18-4 3 108-88-3 3 10061-02-6 3 79-01-6 2.5 75-01-4 2.5 1330-20-7 5 1. Quantitation limits are provided for guidance purposes only as they may not always be technically achievable due to such factors as elevated analyte concentrations, which would require sample dilution and matrix interferences. In these cases, the laboratory quantitation limits will be submitted for the quantitation limits in accordance with the method(s) protocols. 2. "Supplement to EPA/600/4-84/041: Compendum of Methods for the Determination of Toxic Organic Compounds in Ambient Air", EPA/600/487 /006, September 1986. CRA366909) I • I I I I I I I I I I I I I I I 3669 09) 4.2.3 Completeness, Representativeness and Comparability It is expected that analyses conducted in accordance with USEPA methods will provide data meeting QC acceptance criteria for 80 percent of all samples tested. Any reasons for variances from this 80 percent acceptance will be documented. Corrective actions that will be taken if the completeness goals are not met are described in Section 4.12 of this RGV QAPP. The RGV sampling program has been designed to provide data representative of Site conditions. During development of these networks, consideration was given to the limited information regarding past disposal practices, existing data from past studies completed for the Site, remedial activities to date and physical setting. The extent to which existing and planned analytical data will be comparable depends on the similarity of sampling and analytical methods. The procedures used to obtain the planned analytical data are documented in this RGV QAPP. However, it may be necessary to verify similar documentation for previous analytical data to adequately establish comparability. Comparability of laboratory analyses will be ensured by the use of consistent units. Following completion of data collection (during the RA), the existing database will be evaluated for representativeness. 4.2.4 Field Measurements Measurement data will be generated in many field activities. These activities include, but are not limited to, the following: i) documenting time and weather conditions; ii) determining pH, specific conductivity and temperature of water samples; iii) iv) v) determining depths in a well; verifying well development and presampling purge volumes; measuring groundwater elevations in wells; and 31 CONESTOGA-ROVERS & AsSOOATES I I I I I I I I I I I I I I I I I 3(,69 09) vi) measuring total VOC concentrations of SVE system effluent using a PID. The general QA objective for such measurement data is to obtain reproducible and comparable measurements to a degree of accuracy consistent with the use of standardized procedures. 4.3 SAMPLING PROCEDURES The procedures and protocols for collecting samples and for performing all related field activities are described in detail in the RGV SAP (Section 3.0). 4.4 SAMPLE CUSTODY AND DOCUMENT CONTROL This section details the procedures and protocols which must be followed for the transport of samples from the Site. 4.1.1 Field Custody Procedures Once samples are collected and placed in a cooler, limited access will be enforced by keeping coolers in sight or restricting access to the coolers (i.e. locking coolers in field office or vehicle). 4.4.2 Sample Labels Sample labels will include sample number, place of collection and date and time of collection. Corrections will require a single line drawn through the incorrect entry above. Figure 4.1 shows a typical sample jar label. Samples will be placed in the shipping cooler immediately after collection. 32 CONESTOGA-ROVERS & AsSOCIATF.S I I • I I I I I I I ' I I I I I I I I CRA C RA Consulting Engineers CONESTOGA-ROVERS & ASSOCIATES LIMITED JOB NAME: ------------ JOB NO: _____ DATE: _____ _ LOCATION: ------------ REMARKS: ------------ NOTES: 1) SAMPLE LABELS Will BE FIRMLY AFFIXED TO SAMPLE CONTAINERS 2) All SAMPLE LABELS Will BE COMPLETED USING WATER INSOLUBLE INK figure 4.1 TYPICAL SAMPLE LABEL JADCO-HUGHES SITE Goston County, NC 3669 (19) JAN 13/94 (W) REV. 0 I I I I I ·I ·• I I I I I I I I I I I 3669 09) 4.4.3 Chain-of-Custody Each cooler being shipped to ENSECO will contain a chain-of-custody form. Figure 4.2 shows a typical chain-of-custody form consisting of four copies which are distributed to the shipper, the receiving laboratory, the CRA laboratory and the CRA office file. Each sample number of each sample shipped will be recorded on the sheet. The shipper will maintain his copy while the other three copies are enclosed in a waterproof envelope within the cooler with the samples. The container will then be sealed for shipment. The laboratory, upon receiving the samples, will complete the three remaining copies .. The laboratory will maintain one copy for their records. One copy will be returned to CRA upon receipt of the samples by the laboratory. One copy will be returned to CRA with the data deliverables package. Upon receipt of the container at the laboratory, the container will be inspected by the designated sample custodian. The condition of the container will be noted on the chain-of-custody record sheet by the sample custodian. The sample custodian will document the date and time of receipt of.the container and sign the form. If damage or discrepancies are noticed, it will be recorded in the remarks column of the record sheet, dated and signed. Damage or discrepancies will be reported to the laboratory supervisor who will inform the lab manager and QA officer. The laboratory QA officer will then notify the CRA QA Officer -Analytical Activities. 4.4.4 Sample Documentation In The Laboratory The sample custodian will assign a unique number to each incoming sample for use in the laboratory. The unique number and customer number will then be entered into the laboratory information management system and in the project file. The laboratory date of receipt will also be noted. 33 CONESTOGA-ROVERS & ASSOCIATES CRA CHAIN OF CUSTODY RECORD CRA SHIPPED TO (Laboratory Nome): REFERENCE NUMBER: CONESTOGA-ROVERS &: ASSOCIATES 651 Colby Drive Waterloo, Ont. N2V 1C2 /519)88-4-0510 SAMPLER'S PRINTED !SIGNATURE: NAME: SEQ DATE TIME SAMPLE No. No. TOTAL NUMBER or CONTAINERS . AAUNQUISHEO BY: DATE: TIME: · ~UNQUISHED BY: DATE: TIME: ~UNQUISHED BY: DATE: TIME: METHOD or SHIPMENT: Wlille -Fully Executed Copy SAIAPLE TEAM: Yellow -Receiving Laboratory Copy Pink -Shipper Copy Goldenrod Sampler Copy V> PA:w~REMARKS .... "' o\i! SAMPLE -~ Oz TYPE Zo u - HEALTH CHEMICAL HAZARDS I I ~CEIVED BY: iiATE: TIME: ~CEIVED BY: 11ATE: TIME: ~CEIVED BY: nATE: TIME: WAY BILL No. RECEIVED FOR LABORATORY BY: DATE: TIME: figure · 4.2 CHAIN OF CUSTODY FORM JADCO-HUGHES SITE Gaston County, NC 3669 (19) JAN 13/94(W) REV.O (F-04) I I I I ·I I: !I I 11 I I I I I I I I I I 3',69 (19) ENSECO will be responsible for maintaining analytical log books and laboratory data, as well as sample (on hand) inventory for submittal to CRA on an "as required" basis. Samples will be maintained by the laboratory for a period of 30 days following CRA's receipt of the respective sample data under the conditions prescribed by the appropriate USEP A methods for additional analyses, if necessary. Raw laboratory data files will be inventoried and maintained by ENSECO for a period of five years at which time CRA will advise ENSECO regarding the need for additional storage. Laboratory custody procedures are documented in detail in Attachment B-1 of the RD Work Plan. 4.4.5 Storage of Samples After the sample custodian has prepared the log book, the chain-of-custody will be checked to ensure that all samples are stored in the appropriate locations. All water samples will be stored within an access controlled location and will be maintained at 4°C, ±2°C until completion of all analytical work, but in any event for at least 30 days. Gas samples will be stored at 25°C, ±2°C. 4.4.6 Sample Documentation -CRA Evidentiary files for the entire project will be inventoried and maintained by CRA and will consist of the following: -Project Plan; -Project Logbooks; -Field Data Records; -Sample Identification Documents; -Chain-of-Custody Records; -Analytical Data Packages; -Correspondence; 34 C0NESTOCA-R0VERS & ASS0OATES I I I I I I :ti I I I ' I Ir I I I I I I 3669 09) -Report Notes, Calculations, etc.; -References, Literature; -Miscellaneous -photos, maps, drawings, etc.; and -Reports. The evidentiary file materials will be the responsibility of the evidentiary file custodian with respect to maintenance and document removal. Stephen Quigley will be the evidentiary file custodian. 4.5 CALIBRATION PROCEDURES AND FREQUENCY The procedures indicated below will be performed for 1 samples delivered for analysis to ENSECO. Specific instructions relevant to a particular type of analysis are given in the pertinent analytical procedures for this project, and are referenced in Section 4.6 and Tables 4.2 through 4.4. Quality control data and records produced from calibration will be retained by the laboratory and will be made available to CRA on an "as required" basis. The following specific analytical quality control procedures are related to each analytical batch. 4.5.1 Laboratory Instrument Performance Prior to initiating analyses, the laboratory must establish that all instruments will meet required specifications. 4.5.1.1 Organic Analyses The following requirements will be applied to those samples analyzed by gas chromatography (GC) and gas chromatography /mass spectrom~try (GC/MS). The calibration of each of these instruments will be 35 CONESTOGA-ROVERS & ASS0OATES ~ I ,, I I I ., I I I I I I I I ·1 I I 366909) verified at frequencies specified in ENSECO's SOPs, which are provided in the RD Work Plan in Attachment B-2. Where appropriate, a new standard curve may be prepared as specified in the SOPs. 4.5.2 Laboratory Calibration Prior to analysis, instruments will be calibrated using standard procedures for organics and metal analyses. Calibration procedures are detailed in ENSECO's SOPs. 4.5.2.1 Calibration Check Method mandated compounds will be used to check calibration of the instrument being used. A calibration check will be conducted prior to any batch analysis. Calibration check procedures are detailed in ENSECO's SOPs. 4.5.3 Field Instrument Calibration Calibrating field instruments will be done prior to collecting each water sample if well purging data indicate a change (>±10 percent) in pH and/or conductivity from the last location sampled. Calibration will be conducted at least daily during groundwater sampling. The field equipment will be maintained, calibrated and operated in a manner consistent with the manufacturer's guidelines and USEPA standard methods. However, since the majority of field measurements will be limited to pH, conductivity, temperature, depth (water level) and total VOC concen_trations of SVE system effluent, the following procedures will be observed. 36 CONESTOGA-ROVERS & AsSOCIATES I I I I I I I -., I I I I I I I I --1 I ,, I 3669 09) 4.5.3.1 pH Meter The pH meter will be calibrated with commercially obtained pH 4, 7 and 10 buffer solutions. The pH calibration will be temperature compensated and will be performed immediately before initiating a sampling event. Calibration checks will be performed with every sample collected. In the event that the result fails to be within 0.1 pH units, the meter must be recalibrated and all samples after the last calibration must be remeasured. Calibration will be performed in accordance with the following procedure: 1. rinse the probe in deionized water; 2. insert probe in a fresh pH 7 buffer solution; 3. slide battery compartment cover back to the first stop, exposing the adjustment potentiometers; 4. adjust the "CAL" potentiometer such that the display reads 70; 5. remove the probe; rinse in deionized water; 6. insert probe in a fresh pH 4 or pH 10 buffer solution; 7. adjust the slope potentiometer until the correct pH is displayed; and 8. remove probe; rinse in deionized water. 4.5.3.2 Conductivity Meter The specific conductivity meter is factory calibrated, but the calibration should be checked periodically and the probe thoroughly rinsed between samples. Calibrating the specific conductivity meter will be performed as follows: 1. 2. 3. 4. rinse probe in deionized water; wipe probe and allow to dry, the conductivity displayed should be zero in air; adjust the zero potentiometer if necessary; immerse the probe in a solution of known conductivity; 37 CONESTOGA-ROVERS & ASSOOATES I I I I I I I -✓ I I I I I I I I I I I I 3669 09) 5. adjust the "SPAN" potentiometer such that the correct conductivity is displayed; and 6. rinse probes thoroughly with deionized water and allow to dry. 4.5.3.3 HNu Meter Calibration checks will be performed in accordance with the following procedures: 1. Connect the analyzer to the regulator and cylinder with a short piece (butt connection) of tubing. The calibration gas in the cylinder consists of a mixture of isobutylene and zero air. Isobutylene is non-toxic and safe to use in confined areas. There are no listed worker exposure levels. It is important that the tubing be clean since contaminated tubing will affect the calibration reading. Do not use the cylinder below 30 pounds per square inch gauge (psig), as a reading below that level can deviate up to ten percent from the rated value. Safely discard the disposable cylinder when empty. Do no refill this cylinder. 2. Set SPAN and function switches at the same positions as listed in the, Application Data Sheet or Calibration Report. Open the valve on the cylinder until a steady reading is obtained. If the reading is the same as the recorded data, the analyzer calibration for the original species of interest is still correct. 3. If the reading has changed, adjust the SP AN setting until the reading is the same. 4. Shut off the cylinder as soon as the reading is established. 5. Record and maintain this new SP AN setting. 38 CONESTOCA·ROVERS & ASSOCIATES I I I I I I I I I I I I I I I I I I I 3669 (19) 4.6 ANALYTICAL PROCEDURES This section presents the analytical methods which will be employed by ENSECO to complete required analyses. 4.6.1 Overview Groundwater and treatment system water will be analyzed according to SW-846, third edition, Revision I methods presented in Tables 4.2 and 4.3. Soil gas and SVE exhaust gas samples will be analyzed using USEPA Method TO-14. SVE system effluent will be measured for total VOC by continuous PID measurements in the field. 4.6.2 Identification Identification of all targeted analytes will be accomplished with an authentic standard of the analyte. For gas chromatographic determinations of specific analytes, the relative retention time of the unknown will be compared with that of an authentic standard. Since a true identification using GC is not possible, an analytical run for compound confirmation will be performed according to the specifications in the methods. Peaks must elute within daily retention time windows established for each indicator parameter to be declared a tentative or confirmed identification. Retention time windows are determined via a standard 72-hour study defined in each method. Results of the study are to be filed in the laboratory and available for inspection during a QC audit. For GC/MS determinations of specific analytes, the spectrum of the analyte will conform to a literature representation of the spectrum or to a spectrum of the authentic standard obtained after satisfactory 39 CONESTOCA-ROVERS & Asso□ATF.5 I I I I I I I I I I I I I I I I I I I 3669 Oil) tuning of the mass spectrometer. The appropriate analytical methods will be consulted for specific criteria for matching the mass spectra, relative response factors, and relative retention times to those of authentic standards. 4.6.3 Quantification The procedures for quantification of analytes are discussed in the appropriate ENSECO SOPs. 4.6.4 Detection Limit and Quantification Limit The methods used will have quantitation limits or CRQLs/CRDLs that are consistent with the appropriate USEPA methods. The targeted quantitation limits are presented on Tables 4.2 through 4.4. Specific quantitation limits are highly matrix dependent. The quantitation limits are provided for guidance and may not always be technically achievable. 4.7 DATA REDUCTION, VALIDATION ASSESSMENT AND REPORTING ENSECO will perform analytical data reduction and validation in-house under the. direction of the laboratory QA officer. The laboratory QA officer will be responsible for assessing data quality and advising CRA's QA Officer -Analytical Activities of any data which were rated "preliminary" or "unacceptable" or other qualifications. Figure 4.3 illustrates the analytical data flow through the laboratory. Data reduction, validation and reporting by the laboratory will be conducted as detailed in the SOPs provided in the RD Work Plan, Attachment B-3. The analytical data packages will contain a summary of the following: 40 CONESTOGA-ROVERS & ASSOOATES I I I I I I I I I I I I I I I I I I I CRA Samples received by sample custodian, logged in, worksheets generated for each parameter group ond transmitted to lob supervisor Semple preporction Semple onolyses Dato processed and transcribed onto worksheets by onclyst N y Worksheets transferred to independent analyst for review N 3669 (19) JAN 13/94(W) REV.O {C-06) N Loborotory QA/QC officer completes a thorough inspection of one in ten reports. All reports, however, reviewed for completeness N y Final report generation N y Final report to QA/QC officer end lob manager for approval Report figure 4.3 ANALYTICAL DATA FLOW ANALYTICAL SUBCONTRACTOR JADCO-HUGHES SITE Gaston County, NC I I I I I I I I I I I I I I I I \ 3669 09) 1. 2. 3. 4. 5. 6. 7. 8. 9. case narrative that includes summary of analytical methods used and description of any unusual action or conditions; laboratory sample results; dates of sample receipt, preparation and analysis; method blank sample analysis summary; surrogate and matrix spike recovery (if applicable) data and control limits; check sample data and control limits; dilution factors identified (as required); practical quantitation limits (PQL) for each method; and executed chain-of-custody forms. Calibration data, raw chromatograms/spectra and necessary instrument tuning results of required analyses will be retained by the project laboratory until certificate of completion has been issued, and will be available on request for necessary review. CRA QA/QC Officer -Analytical Activities will conduct an evaluation of data reduction and reporting by the laboratory. These evaluations will consider items 1 through 9 listed above as well as field QA/QC results (i.e. rinsate blanks, trip blanks, field duplicate). The data packages will be checked for legibility, completeness, correctness and the presence of requisite dates, initials and signatures. The results of these checks will be assessed and reported to the CRA project manager noting discrepancies and their effect upon the acceptability of the data. Information garnered for QA/QC checks will be discussed in the periodic data report. Validation of the analytical data will be performed by the CRA QA/QC Officer -Analytical Activities based on the QC criteria outlined in "National Functional Guidelines for Organic Data Review," December 1990 (Revised June 1991) and "Laboratory Data Validation Functional Guidelines for Evaluating Inorganics Analyses," July 1988 validation guidance documents. The laboratory data packages (including items 1 through 9 and field QA/QC results) will be assessed in accordance with the criteria outlined in the validation guidance documents .. The results of these data validations 41 CONESTOGA-ROVERS & AsSOCIATES I I I I I I I I I I I I I I I I I I I 3669 09) will be reported to the CRA project managers, noting any field, laboratory or matrix concerns and the effect(s) of the concern(s) on the acceptability of the data. Raw data from field measurements and sample collection activities that are used in the project reports will be appropriately identified and appended to the report. Where data have been reduced or summarized, the method of reduction will be documented in the report. In addition, field data will be audited for anomalously high or low values that may appear to be inconsistent with other data. 4.8 INTERNAL QUALITY CONTROL CHECKS AND FREQUENCY 4.8.1 Field QC Quality control procedures for field measurements will be limited to checking the reproducibility of the measurement in the field by obtaining multiple readings and by calibrating the instruments (where appropriate). Field quality control will involve collecting field duplicate and rinsate samples in accordance with the applicable procedures described in the RGV SAP (Section 3.0). 4.8.2 Laboratory QC Specific procedures related to internal laboratory QC samples (namely, matrix spikes, surrogate spikes, blanks, QC check samples and matrix spike duplicates) are detailed in the following subsections. 42 CONESTOGA-ROVERS & ASSOOATES I I I I I I I I I I I I I I I I I I I 4.8.2.1 Method Blank Samples A method blank sample will be analyzed by the laboratory at a frequency of one per twenty analyses or at least one per batch. The method blank sample, an aliquot of analyte-free water (for aqueous samples) or reagent-grade air (for soil gas or SVE exhaust gas samples), will be carried through the entire analytical procedure. For organic analyses, the concentration of target analytes in the blank must be below the Quantitation Limits listed in Table 4.2. An exception will be made for common laboratory contaminants (methylene chloride, acetone, 2-butanone, and phthalate esters) which may be present in the blank at up to five times the Quantitation Limit and still be considered acceptable. For metals and cyanide analyses, the concentration of the target analytes in the blank must be below two times the Quantitation Limit. If the blank value of a target analyte lies below the Quantitation Limit, the analyte is reported with no flag on the associated sample data. If the blank value lies between the Quantitation Limit and two times the Quantitation Limit, the analyte in the associated samples is flagged to indicate contamination was present in the blank. A blank containing an analyte(s) above two times the Reporting Limit is considered unacceptable unless the lowest concentration of the analyte in the associated samples is at least ten times the blank concentration or the concentration of the analyte in all samples associated with the blank is below the detection limit. 4.8.2.2 Matrix Spike/Matrix Spike Duplicates (MS/MSD) Analyses MS/MSD analyses will be analyzed at a frequency of 1 in 20 for each method per matrix, excluding gas. For metals , spiked and duplicate analyses will be used in place of MS/MSD analyses. Acceptable compounds that will be used for matrix spikes are identified in the methods listed in Tables 4.2 to 4.4. Percent spike recoveries will be used to evaluate analytical accuracy while percent relative standard deviation or percent difference between the spike and matrix spike duplicate recoveries will be used to assess analytical precision. CONESTOGA-ROVERS & ASSOOATES I I I I I I I I I I I I I I I I I ,I I 366909) For soil gas and SVE exhaust gas analyses, one duplicate and one spike analysis will be performed per batch by the laboratory. Table 4.4 presents acceptability criteria for these analyses. 4.8.2.3 Surrogate Compounds Surrogate compounds are used in all organic analyses, excluding gas samples. Every blank, standard and environmental sample, including MS/MSD samples, will be spiked with surrogate compounds prior to purging VOC or extracting BNA and PCB. Surrogate compounds will be spiked into samples according to the appropriate analytical methods. Surrogate compound recoveries will fall within the control limits set by procedures specific in the method for analytes falling within the quantification limits without dilution. Diluting samples to bring the analyte concentration into the linear range of calibration may dilute the surrogates below the quantification limit; assessment of analytical quality in these cases will be based on the quality control embodied in the check and MS/MSD samples. Table 4.5 presents a summary of the surrogate recovery control limits as stated within the analytical methods. 4.8.2.4 Laboratory Control Samples Laboratory control samples are used to assess method accuracy. The analytes contained in control samples will be a representative subset of the target analytes. Percent recoveries shall be within limits specified by the laboratory or corrective actions will be taken as per the project laboratory's SOP provided in Attachment B-2 of the RD Work Plan. 44 CONESTOGA-ROVERS & ASSOOATES I I I I I I I I I I I I I I I I I I I TABLE4.5 SURROGATE COMPOUND PERCENT RECOVERY LIMITS JADCO-HUGHES SITE REMEDIATION GOAL VERIFICATION PLAN Volatile Organic Compounds toluene-d8 bromofluorobenzene 1,2-dichloroethane-d4 Base/Neutral and Acids nitrobenzene-d5 2-fluorobiphenyl terphenyl-d14 pheno!-d5 2-fluorophenol 2,4,6-tribromophenol 2-chlorophenol-d4 (1) 1,2-dichlorobenzene-d4 (1) Polychlorinated Biphenyl Compounds tetrachloro-m-xylene decachlorobiphenyl CRA366909) Percent Recoveries Water 88-110 86-115 76-114 35-114 43-116 33-141 10-110 21-110 10-123 33-110 16-110 60-150 60-150 I I I I I I I I I I I I I I I I I I 3669 09) 4.9 PERFORMANCE AND SYSTEM AUDITS AND FREQUENCY For the purpose of external evaluation, performance evaluation check samples from the USEPA and various state agencies are analyzed periodically by ENSECO. Internally, data evaluation for these samples is done on a continuing basis over the duration of a given project. The CRA QA Officer -Analytical Activities may carry out performance and/or systems audits, which include fieldwork audits, to ensure that data of known and defensible quality are consistently produced during a program. System audits are qualitative evaluations of all components of field and laboratory quality control measurement systems. They determine if the measurement systems are being used appropriately. The audits may be carried out before all systems are operational, during the program, or after the completion of the program. Such audits typically involve a comparison of the activities given in the QA/QC plan described herein, with activities actually scheduled or performed. A special type of system audit is the data management audit. This audit addresses only data collection and management activities. The performance audit is a quantitative evaluation of the measurement system used for a monitoring program. It requires testing the measurement systems with samples of known composition or behavior to evaluate precision and accuracy. A performance/system audit may be carried out by or under the auspices of the USEP A Region IV Environmental Services Division, without the knowledge of the analyst during each sampling event for this program. The scheduling of performance evaluation (PE) audits will be at the discretion of the USEP A. In addition, one external QA audit may be conducted by CRA prior to analysis of any investigatory samples. It should be noted, however, that any additional external QA audits will only be performed if 45 CONESTOGA·ROVERS & ASSOClATES I I I I I I I I I I I I I I I I I I I 3(,69 (19) deemed necessary by either the Steering Committee or CRA project managers or the CRA QA officers. The project laboratory may also undergo PE audit(s) by the USEP A, if so requested. 4.10 PREVENTIVE MAINTENANCE Analytical instruments to be used in this project will be serviced by ENSECO personnel at regularly scheduled intervals in accordance with the manufacturer's recommendations. Instruments may also be serviced at other times due to failure. Requisite servicing beyond the abilities of ENSECO personnel will be performed by the equipment manufacturer or their designated representative. Daily checks of each instrument will be by the analyst responsible for that instrument. These daily checks will include changing GC inlet liners, GC/MS instrument checks, checking operation of data systems, checking for leaks, etc. Manufacturer's recommended procedures will be followed in every case. The HNu, pH and conductivity meters will be calibrated in the field as described in Section 4.5.3. In addition, the following preventive maintenance measures will be taken in the field: HNu -The HNu meter is sent annually to the manufacturer for recalibration and cleaning. pH, Conductivity -Keep probes clean and free of dirt by rinsing with deionized water. -Keep deionized water around probes to prevent dehydration. Water Level Tape -Clean probe and lower three feet of tape with pesticide grade isopropanol and deionized water to prevent hard water and iron build up. 46 CONESTOGA-ROVERS & Asso□ATES I I I I I I I I I I I I I I I I I I I 4.11 SPECIFIC ROUTINE PROCEDURES USED TO ASSESS DATA PRECISION, ACCURACY AND COMPLETENESS 4.11.1 QA Measurement Quality Indicators 4.11.1.1 Precision Precision will be assessed by comparing the analytical results between MS/MSD analyses and/or duplicate sample analyses. Precision will be reported to the USEP A through data validation memos which are attached to the analytical reports. 4.11.1.2 Accuracy Accuracy will be assessed by comparing a set of analytical results to the accepted, or "true", values that would be expected. In general, : surrogate, MS/MSD analyses and check sample recoveries will be used to assess accuracy. Accuracy will be reported to the USEPA through data validation memos which are attached to the analytical reports. 4.11.1.3 Outliers Procedures discussed previously will be followed for documenting deviations from established control limits. In the event a result deviates significantly from established control limits, this deviation will be noted and its effect on the quality of the remaining data assessed and documented. 47 CONESTOCA-ROVERS & ASSOOATF.S I I I I I I I I I I I I I I I I I I I 3l,l,9 (19) 4.12 CORRECTIVE ACTION The need for corrective action may be identified by system or performance audits or by standard QC procedures. The essential steps in the corrective action system will be: checking the predetermined limits for data acceptability beyond which corrective action is required; -identifying and defining problems; -assigning responsibility for investigating the problem; -investigating and determining the cause of the problem; -determining corrective action to eliminate the problem (this may include reanalyses of resampling and analyses); assigning and accepting responsibility for implementing the corrective action; -implementing the corrective action and evaluating the effectiveness; -verifying that the corrective action has eliminated the problem; and documenting the corrective action taken. For each measurement system, the CRA QA Officer -Analytical Activities will be responsible for initiating the corrective action and the laboratory supervisor will be responsible for implementing the corrective action. The corrective action taken will depend upon the QA/QC criteria that did not meet the necessary criteria, and may range form qualifying the data to resampling at the Site. 4.13 QUALITY ASSURANCE REPORT TO MANAGEMENT Management will receive reports on the performance of the measurement system and the data quality, following each sampling round and at the conclusion of the report. Minimally, these reports will include: 48 CONESTOGA-ROVERS & ASSO□ATES I I I I I I I I I I I I I I I I I I I •• 3669 09) -assessment of measurement and quality indicators(Le. data accuracy, precision and completeness); -results of performance audits; -results of system audits; and -QA problems and recommended solutions. The CRA QA Officer -Analytical Activities will be responsible within the organizational structure for preparing these periodic reports. Periodic reports for the project will also include a separate QA section which will summarize data quality information contained in the periodic QA/QC reports to management, and details and overall data assessment and validation in accordance with the data quality objectives outlined in this RGV QAPP. 49 CONESTOGA-ROVERS & ASSOCIATES I I I I I I I I I I I I I I I I I •• , I 5.0 3669 09) REPORTING An annual report is required to be submitted by the UAO (Section XIV) by July 24 of each year. This reporting requirement has, prior to the initiation cif the RA, been met by the content of the monthly progress reports. After the RA construction has been completed, these annual reports will be submitted to USEPA to document activities selected for the RGV Plan implementation, and other activities at the Site. The periodic progress reports required by the UAO will summarize the field activities completed in the previous reporting period. The annual report will present and assess data collected in the previous year. 50 CONESTOGA-ROVERS & AssoaATES I I I I I I I I I I I I I I I I I 6.0 3669 09) REFERENCES 2. 3. 4. 5. 6. 7. "Environmental Compliance Branch Standard Operating Procedures and Quality Assurance Manual", USEPA Region IV, February 1, 1991. "Laboratory Operating and Quality Control Manual", USEPA Region IV, September 1990. "Data Quality Objectives for Remedial Response Activities", USEPA/540/G-87 /003, March 1987. "Test Methods for Evaluating Solid Waste Physical/Chemical Methods", USEPA SW-846, Third Edition, Final Update, July 1992. "Supplement of EPA/600/4-84/041: Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air", USEPA/600/487 /006, September 1986. "Remedial Design Work Plan, Jadco-Hughes Site, Gaston County, North Carolina", CRA, 1992. "Remedial Action Work Plan, Jadco-Hughes Site, Gaston County, North Carolina", CRA, 1994. · 51 CONESTOGA-ROVERS & Asso□ATES