HomeMy WebLinkAbout14024 Edward Removal Work Plan& Approval 201206041601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: 919-707-8600 \ Internet: www.ncdenr.gov
An Equal Opportunity \ Affirmative Action Employer – 50% Recycled \ 10% Post Consumer Paper
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Dee Freeman
Secretary
August 9, 2012
Sent Via E-mail (Ed.Hollifield@erm.com)
Ed Hollifield, P.G.
ERM NC Inc.
8000 Corporate Center Drive
Suite 200
Charlotte, NC 28226
Subject: Approval Voluntary Removal Action Work Plan
Anne Edwards Property
10211-10311 Rozzelle’s Ferry Road
Charlotte, Mecklenburg County
Brownfields Project Number 14024-10-60
Dear Mr. Hollifield:
The North Carolina Department of Environmental and Natural Resources (DENR) received a
DRAFT Voluntary Removal Action Work Plan dated June 4, 2012 and a revised final work plan
dated August 8, 2012. The final August 2012 work plan is approved.
Be advised that this approval from the Brownfields Program does not waive any applicable
requirement to obtain any necessary permits, licenses or certifications for the above listed
activities nor does it waive any requirement to comply with applicable law for such activities. If
you have any questions, please feel free to contact me at 704/661-0330, or via e-mail at
carolyn.minnich@ncdenr.gov.
Sincerely,
Carolyn Minnich
Carolyn F. Minnich
Brownfields Project Manager
Division of Waste Management
cc: Central Files
ec: Bruce Nicholson, DENR
DRAFT Voluntary Removal Action Work Plan
Anne Edwards Property
Rozzelles Ferry and Mt. Holly / Huntersville Road
Charlotte, North Carolina
June 4, 2012
Delivering sustainable solutions in a more competitive world
DRAFT Voluntary Removal Action Work Plan
Anne Edwards Property
Rozzelles Ferry and Mt. Holly / Huntersville Road
Charlotte, North Carolina
June 4, 2012
Richard Tarravechia, P.G.
Partner In Charge & IHSB Registered Site Manager
Edward Hollifield, P.G.
Project Manager
ERM NC, Inc.
8000 Corporate Center Drive, Suite 200
Charlotte, NC, USA 28226
T: 704-541-8345
F: 704-541-8416
ERM i
TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 SITE DESCRIPTION AND BACKGROUND 1
1.2 PREVIOUS ENVIRONMENTAL ASSESSMENT 2
1.3 OBJECTIVES 5
2.0 SITE AND DATA MANAGEMENT 6
2.1 PROJECT TEAM 6
2.2 RECORDKEEPING 6
2.3 SITE WORK HOURS 6
2.4 SITE SECURITY 6
2.5 PROJECT HEALTH AND SAFETY REQUIREMENTS 7
2.6 QUALITY ASSURANCE/QUALITY CONTROL 8
2.7 SURVEYING 9
3.0 SCOPE OF WORK 11
3.1 MOBILIZATION AND SITE PREPARATION 12
3.2 IMPACTED MATERIAL EXCAVATION 13
3.3 STOCKPILE MANAGEMENT 14
3.4 MATERIAL STABILIZATION 15
3.5 SOIL LOAD-OUT, TRANSPORTATION, AND DISPOSAL 16
3.6 BACKFILL DELIVERY AND PLACEMENT 16
3.7 REVEGETATION 17
3.8 SITE CLEANUP AND DEMOBILIZATION 17
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3.9 REPORTING 17
FIGURES
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Boring and Sample Location Map
Figure 4 Excavation, Treatment and Load Out Plan
TABLES
Table 1. Summary of Foundry Sand Fill and Native Soil Total Metals Analytical
Results
Table 2. Summary of Foundry Sand Fill and Native Soil TCLP Lead Analytical
Results
Table 3. Monitor Well Construction Details
Table 4. Summary of Groundwater Analytical Results
ATTACHMENTS
A. Quality Assurance Project Plan
B. Project Health & Safety Plan
ERM 1
1.0 INTRODUCTION
ERM NC, Inc. (ERM) has prepared this workplan on behalf of Charlotte Pipe and
Foundry (CPF) to document the technical approach and management of a voluntary
removal action at the currently undeveloped property located at the northwest corner
of Rozzelles Ferry Road and Mt. Holly-Huntersville Road, Charlotte, Mecklenburg
County, North Carolina (“property”, “site”). The proposed work is being performed by
CPF in coordination with Ms. Anne Edwards, the property owner. A site location map
is provided as Figure 1 and a site layout map is provided as Figure 2. Proposed
voluntary removal activities and methods have been developed to comply with the North
Carolina Department of Environment and Natural Resources (NCDENR) Registered
Environmental Consultant Guidance (August 2010) and the Field Branches Quality System
and Technical Procedures, which supersedes the Environmental Investigations Standard
Operating Procedures and Quality Assurance Manual (EISOPQAM), dated November 2001.
1.1 SITE DESCRIPTION AND BACKGROUND
The Site is comprised of five contiguous parcels owned by Ms. Edwards, located on the
northwest corner of the intersection of Rozzelle’s Ferry Road and Mt. Holly-
Huntersville Road in Charlotte (Mecklenburg County), North Carolina. A brief history
of the site and surrounding properties is summarized below.
Summary of Site Ownership
Year Owner Use
Unknown to
1935
W.O. and Mary Rozzelle Unknown.
1935 – 1990
E.L. and Alma B. Rozzelle
(100% ownership interest
until 1960; 50% interest
until 1990)
Convenience Store / Bait Shop and
Minnow Ponds (1945- approx. 1988).
1960 - 1996 James E. and Julia C.
Rozzelle (50% ownership
interest from E.L and Alma
Rozzelle)
Convenience Store (operated by E.L.
Rozzelle and later by Lessee Melody
Hatfield under the name of Shuffletown
Grocery, Inc.).
1990 to Present
1996 to Present
Ms. Anne Edwards
(50% ownership interest
from E.L. and Alma
Rozzelle in 1990)
(50% ownership interest
from Julia Rozelle in 1996)
Lots used for residential housing until
2006 when houses were razed for
potential development.
The currently undeveloped parcels were once part of a convenience store / bait shop
and minnow pond operation owned and operated by Ms. Edward’s parents, Edward
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Lawson (“E.L”) and Alma B. Rozzelle, from 1945 until approximately 1988. The
convenience store also sold gasoline and groceries.
Eight shallow minnow ponds were operated at the subject site property until being
abandoned by filling with backfill materials from 1987 to 1988. Ms. Edwards indicated
that the three southernmost ponds were previously abandoned with clean soil material
with the remainder of the ponds being filled with foundry sands and soil. Once filled,
the ponds were capped with soil generated during the construction of nearby Highway
16.
Upon closure of the ponds, the property was subdivided into lots and between 1998
and 2002, several small frame houses were placed in the vicinity of former ponds B, C,
and D. The houses were maintained by Ms. Edwards until 2006, when they were razed
for potential redevelopment of the property. During due diligence and prior to
demolition of the referenced houses, foundry sands were found to have been used as
backfill at some of the former minnow ponds. To assess the extent of the foundry sands
assessment activities were continued at the site. The following is a summary of
assessment activities conducted to date at the site, including the initial effort in 2004
through present.
1.2 PREVIOUS ENVIRONMENTAL ASSESSMENT
Between 2004 and 2006, assessment was completed at the Edwards property to define
the extent of the foundry sand and to evaluate the concentrations of metals at the site. In
preparation of this removal action workplan, ERM relied upon the following reports
previously submitted to NCDENR:
• Potential Environmental Concerns – Teleconference on November 3, 2004, Proposed
Shuffletown Development - S&ME letter Report, November 4, 2004
• Corrective Action Plan, Anne R Edwards Property – Aware Environmental, February
2006
• Supplemental Site Investigation Report Anne R. Edwards Property – Aware
Environmental, August 2006
A summary of the significant findings of previous assessment efforts are provided
below. Soil and groundwater sample locations are shown on Figure 3. Soil sample
results are summarized on Tables 1 and 2. A monitor well construction detail summary
is provided as Table 3 and groundwater sample results are summarized on Table 4.
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S&ME, Inc. Assessment
The foundry sands used to fill the minnow ponds were initially sampled by S&ME, Inc.
in 2004 as part of the environmental due diligence for a potential real estate transaction
Ten soil samples were collected from test pits advanced at the site and analyzed for
total RCRA metals. Additionally, four of the samples were analyzed for leachable
metals via the toxicity characteristic leaching procedure (TCLP) via EPA Method 1311.
Based on laboratory results, elevated total metals (primarily lead) were identified in
samples of the foundry sands. TCLP analysis identified one sample that contained lead
with a concentration of 8.6 milligram per liter (mg/l), slightly above the Regulatory
Action Level of 5.0 mg/l. This data was included Attachment A of the referenced
Corrective Action Plan (Aware 2006).
AWARE Environmental Inc. Assessment
From September to November 2005, eighty shallow soil/sand borings were advanced in
and around the former minnow ponds to collect additional material characterization
samples, and to visually identify the depth and lateral extent of the foundry sand. Nine
soil/sand material samples including 2 background soil samples were retained for
analysis for the 8 RCRA metals. Forty soil samples were retained for TCLP lead
analysis. Elevated total lead concentrations ranging from 360 milligrams per kilogram
(mg/kg) to 1,500 mg/kg were detected in the soil waste material samples as a result of
the sampling event. Elevated TCLP lead levels ranging from 5.6 to 16.0 mg/l were
reported in nine foundry sand samples that were obtained from two localized backfill
areas at the site. Based on the results of the 2005 assessment, an estimated volume of
buried foundry sand that could potentially contain elevated TCLP lead determined to
be 430.6 cubic yards.
As part of the 2005 assessment effort, three soil borings were advanced to below the
water table and three grab shallow groundwater samples were collected from the
borings for analysis of dissolved and total RCRA metals. Total lead concentrations of
0.023 mg/l and 0.019 mg/l were detected in two groundwater samples, which are
slightly above the 15A NCAC 2L groundwater quality standard for lead of 0.015 mg/l.
Lead was not detected in these samples for the corresponding dissolved metals analyses
above the method detection limit. Also, chromium was detected at 0.06 mg/l in the
total metals analysis of a groundwater sample, which is slightly above its 2L standard of
0.05 mg/l. Chromium was not detected in this sample for the corresponding dissolved
metals analysis above the method detection limit. In summary, dissolved metals were
not detected above their respective laboratory reporting limits in the grab groundwater
samples. These wells remain on site.
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Supplemental Assessment (2011)
ERM advanced 15 additional soil borings at the Site in September 2011 to further refine
the areas of the site reportedly filled with foundry sand. Soil borings were advance
using a hand auger and a soil sample from each boring was collected and visually
screened for the presence of readily identifiable foundry sands. Based on the screening
process, ten additional soil borings were retained for laboratory analysis of lead. Total
lead concentrations ranging from 4.4 mg/kg to 1,670 mg/kg were detected in the soil
material samples during the supplemental sampling event. Based on the visual
identification of the foundry sand, the extent of found sand distribution at the site was
refined as shown on Figure 2.
Conclusions of Assessment
Based on the assessment activities conducted from 2004 until 2011, the following
conclusions are provided:
• Backfilled foundry sands are present in the central portion of Pond A and fill
Pond C and E. Foundry sands are located in the southern half of pond F.
• The total volume of identified foundry sands at the site is estimated to be
approximately 2,000 cubic yards and the estimated total volume of potentially
leachable foundry sands occurring in these two areas is approximately 431 cubic
yards
• Foundry sands with concentrations of lead in excess of the TCLP limit are located
in two locations at the site. One area is located between ponds E and F with
approximately 65 cubic yards and one area in the north central portion of pond A
with a volume of 366 cubic yards.
• Dissolved lead has not been detected above the laboratory reporting limit in grab
groundwater collected beneath the fill areas or from groundwater samples
collected from permanent site monitor wells.
The site layout, with estimated extent of the suspect material based on visual
observations, soil boring and sample locations is provided on Figure 3. A soil sample
analytical summary for each referenced phase of assessment is provided as Table 1 and
Table 2. Maximum metals concentrations detected in soil at the site above applicable
cleanup levels are summarized in the following table:
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Summary of Soil Analytical Results
IHSB SOIL REMEDIATION GOALS
Compound
Maximum
Concentration
Average
Background
Concentration
Preliminary
Health
Protection of Ground
Water
IHSB Priority Metals (mg/kg)
Antimony 14 <0.55 6.3 0.9
Arsenic 7.8 1.17 4.4 5.8
Cadmium 6.1 <0.11 14 3
Cobalt 10 17 4.6 0.9
Iron 41,000 17,160 11,000 150
Lead 1,500 6.1 400 270
Manganese 1,100 616 360 65
Silver 5.1 0.3 to 0.7 78 3.4
Vanadium 23 42 7.8 6
TCLP Metals (mg/L) TCLP Limit
Lead 16 NA 5.0
Notes:
mg/Kg = milligrams per kilogram
NE = Not Established
Only metals detected above regulatory threshold shown
NR= No data reported
1.3 OBJECTIVES
This Voluntary Removal Action Workplan has been prepared to provide guidance for
excavation treatment and removal, health and safety monitoring, field mitigation
measures, transportation and disposition of the lead-affected material above TCLP
limits.
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2.0 SITE AND DATA MANAGEMENT
2.1 PROJECT TEAM
The Project Team has a proven track record for executing projects similar in scope to the
subject property. The Project Team consists of personnel each with over 20 years of
remediation experience including engineers, geologist, scientist, construction managers,
equipment operators, and environmental technicians. A summary of key members of
the project team is provided below. Other team members will be used as necessary.
Team Member Project Role
Rick Tarravechia, P.G. Partner-in-Charge and IHSB Registered Site Manager
Edward Hollifield, P.G. Project Manager
Scott Robinson, P.E. Project Engineer and Construction Quality Manager
Don Hall, CSP Health & Safety Manager / Field Safety Officer (FSO)
Sub-Contractors To be determined
2.2 RECORDKEEPING
Data management for the removal action will consist of documenting site activities by
use of a field log book, daily work logs, site photographs and sample chain of custody
records. Additional guidance is provided in the Quality Assurance Project Plan (QAPP)
provided in Appendix A.
2.3 SITE WORK HOURS
The projected start date for site activities is August 1, assuming receipt of necessary
approvals. The project duration is anticipated to be approximately 5 weeks. Project site
activities will be conducted during daylight hours. Because there are some residences in
the area, work will be scheduled to minimize disturbances to surrounding properties.
Anticipated site work hours are 7 AM to 6 PM or 10 hour work days Monday through
Friday, or modified to comply with local regulations. A police detail may be needed to
manage truck traffic during off-site transportation activities.
2.4 SITE SECURITY
The treatment area will be secured from in locking [NEED TO FIX] security fencing to
prevent accidental entry during and after working hours. The fencing will be placarded
with “No Trespassing” signs. The security fencing will be inspected daily at the start
and finish of work. Repairs will be made as necessary. During site activities, dedicated
entrance and exit locations will be used and metal construction fencing will be moved
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into place each night to secure the entrance and exit. A sign-in log will be maintained by
the onsite H&S officer.
2.5 PROJECT HEALTH AND SAFETY REQUIREMENTS
The Project Team will be prepared through training and experience to conduct their
work safely. A comprehensive Health and Safety Plan (HASP), has been prepared for
the protection of workers and bystanders at the site, compliant with EPA, OSHA, and
North Carolina regulations. ERM’s loss prevention system which consists of behavior
based health and safety practices will be implemented at the site. A copy of the
comprehensive HASP is included in Appendix B. A summary of the critical elements of
the H&S program is provided below.
Subsurface Utility Clearance
Subsurface utilities and overhead power lines will be marked and/or identified in the
field prior to initiation of excavation activities.
Stop Work Authority
All site personnel have the authority to immediately stop any work activity that
presents a danger to the site team or the public and can get involved, question and
rectify any situation or work activity that is identified as not being in compliance with
the HASP or with broader ERM health & safety policies.
Ambient Air Monitoring
Ambient air monitoring will be conducted by the FSO when there is a question of
employee or the vicinity’s potential exposure to dust generated from site operations to
assure the proper selection of engineering controls, work practices, and personal
protective equipment (PPE).
Ambient air monitoring will be conducted using field calibrated direct-reading real-
time instruments as follows:
• TSI AM-510 Aerosol/Particulate Monitor, or equivalent, will be used for
personal monitoring in the breathing zone for excavation activities.
• A TSI Dust Trak, or equivalent, will be utilized to monitor the perimeter of the
property.
Under stable site conditions, ambient air monitoring will be conducted at least once
every half-hour in the workers’ breathing zone and along the down-wind property
boundary location. If site conditions become unstable or change dramatically ambient
air monitoring will be conducted more frequently based on the professional judgment
of the FSO. Engineering controls and PPE will be selected by the FSO to mitigate
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potentially unsafe conditions. The following table outlines the steps to be taken by the
FSO if the action levels are exceeded.
Action Levels and Response Actions Requirements
Chemical Action Level Response Actions
Dust from
metals
impacted soil
All Excavation Areas:
Greater than 2.0
mg/m3 sustained in
the breathing zone for
1 minute
• Stop work and leave the immediate area.
• Contact PM and FSO.
• Evaluate work practices and assess engineering
controls to reduce airborne concentrations.
• Increase dust suppression (i.e., water spray).
• If readings are less than or equal to 2.0 mg/m3,
resume work.
• FSO will evaluate need for Tyvek coveralls, don
half-face respirator with high efficiency particular
air (HEPA) cartridges and monitor again after
allowing dust to dissipate.
mg/m3 = milligrams pre cubic meter
2.6 QUALITY ASSURANCE/QUALITY CONTROL
Quality Assurance (QA) is defined as an integrative program designed to assure
reliability of monitoring and measurement data. Quality Control (QC) is defined as the
routine application of procedures for obtaining prescribed performance standards for
monitoring, measuring, and assessment data. The QA Project Plan for the removal
action described herein is included as Appendix A.
Data Quality Objectives
The QA objectives for project sampling are in place to ensure that the data collected
during all phases of work are of sufficient quality to support decisions regarding
confirmation that metals impacted waste and native soils are removed from the site.
For this project, the data quality will be comparable to Level III (moderate level of
detail), as defined in the EPA Contract Laboratory Program.
Quality Control Samples
Quality control samples including equipment rinse blanks and duplicate samples will
be collected and field equipment will be calibrated during the field activities.
Equipment blanks will be collected as a check for cross-contamination between samples
due to incomplete decontamination procedures. Equipment blanks shall be prepared
by rinsing field-cleaned equipment with laboratory supplied deionized water and
collecting the rinse water in a sample container. An equipment blank shall be prepared
to verify the adequacy of decontamination procedures during the sampling events. One
equipment blank sample will be prepared per every sampling tool, per each 10 samples
collected.
Duplicate samples will be collected as a check on the laboratory’s accuracy and
precision and will be prepared by placing sample material collected simultaneously
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from the same source under identical conditions into two separate sample containers.
For quality control purposes, 10% duplicate samples will be collected and submitted for
laboratory analysis.
Sampling and laboratory analytical methods and procedures will conform to ERM
direction, approval and guidance regarding sampling quality assurance/quality
control, data validation and chain of custody procedures. The selected analytical
laboratory will be accredited under the National Environmental Laboratory
Accreditation Program (NELAP) and will comply with appropriate EPA and State of
North Carolina guidance.
2.7 SURVEYING
Excavation extents and confirmation sampling locations will be staked in the field and
then surveyed by a professional surveyor, registered in North Carolina, for
incorporation into site figures.
2.8 DECONTAMINATION PROCEDURES
Decontamination involves the orderly controlled removal of contaminants from both
personnel and equipment. The purpose of decontamination procedures is to prevent
the spreading of metals impacted materials into unaffected areas. Site personnel should
limit contact with impacted material or equipment to reduce the need for extensive
decontamination. Equipment and materials used in the decontamination process may
include the following:
• High pressure/hot water cleaning using only potable water/fire water;
• Phosphate-free detergent;
• Five-gallon bucket;
• Potable water;
• Isopropanol
• Distilled water;
• Paper towels; and
• Brushes.
Personnel Decontamination
The following procedures will be utilized for personnel decontamination:
1. Decontaminate rubber boots with water and/or remove Tyvek® boot covers
2. Remove all PPE and dispose of the PPE in designated receptacles; and
3. Wash hands and any skin that may have come in contact with affected material
with moistened disposable towels, such as baby wipes, or soap and water.
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Equipment Decontamination
The following will be required for equipment and tool decontamination:
• Before leaving the work area, excess contamination will be removed from the
equipment and tools and placed in approved, properly labeled containers.
• A decontamination area will be designated for cleaning all non vehicular
equipment that has been in contact with the site waste materials before leaving
the site. All decontamination will be conducted on a pad with an impermeable
synthetic liner and fluid-containment boom. Equipment will be placed on the
pad and rinsed, brushed and/or steam cleaned to remove any contamination.
• If necessary, decontamination liquids will be managed with a either vacuum
truck or portable pump and transferred to 55-gallon steel drums. Collected
liquids will be sampled for metals and ultimately disposed offsite in an
appropriate manner as determined by the laboratory analysis.
• Disposal of solids collected within the decontamination pad and the pad liner
will be collected and placed on the stockpiles of excavated materials for disposal.
• For major equipment, minimum decontamination will consist of using a soap
and/or water rinse followed by steam cleaning.
• All PPE worn within the work area and during decontamination activities,
including Tyvek®, gloves and rubber boots will be containerized in a 55-gallon
drum (or bag) to be labeled PPE Waste. This will be included with contaminated
material for offsite disposal.
• A truck dry decontamination station will be established to minimize visible soil
on wheels and truck bodies.
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3.0 SCOPE OF WORK
Based upon assessment activities summarized in Section 1.0 above, foundry sands with
concentrations of metals above the NC IHSB Protection of Groundwater and Health
Based Soil Remediation Goals (SRGs) are located at the site as shown in Figure 3. Two
areas of the site have been identified that contain foundry sands with concentrations of
lead in excess of the TCLP limit for hazardous waste of 5.0 mg/kg. The selected
remedial approach presented in this workplan is to excavate, stabilize and remove for
off-site disposal the impacted material in excess of the TCLP limit for lead. It is
understood that a land use restriction will be used to manage the waste material present
on site with lead concentrations less than the TCLP limit but in excess of the IHSB RGs.
The land use restriction will be provided under separate cover upon completion and
regulatory acceptance of the removal action.
The estimated volume of foundry sands that failed to pass TCLP for lead is
approximately 431 cubic yards (~650 tons) of material located in two areas of the Site as
shown in Figures 3 and 4 . The removal action will consist of excavation of the material
from the two areas, placing the excavated material in temporary containment, mixing
the foundry sand with triple superphosphate (TSP) to stabilize (bind) the lead which
renders it not-leachable and thus non hazardous. Once treated, the material will be
temporarily stockpiled on-site. Confirmatory soil sampling will then be conducted in
the excavated area to confirm stabilization of the lead and to confirm that soil
containing lead above TCLP threshold has been excavated from the Site. Confirmation
soil samples will also be collected from the stabilized excavation material to confirm
stabilization of the lead. Upon confirmation of lead stabilization, the treated material
will be transported from the site and disposed as non-hazardous waste in an approved
landfill.
The following summary of activities are proposed to meet the project objectives:
• Site preparation including securing the property, emplacement of erosion
control devices, clearing vegetation; including small trees and shrubs from
the excavation and treatment areas;
• Surveying and marking the proposed excavation extents based on previous
assessment results;
• Excavation of metals impacted soils and post excavation sampling;
• Air monitoring for particulates;
• Dust suppression, if warranted based on air monitoring;
• Soil stockpiling, treatment/stabilization and analytical testing;
• Soil stockpile management, and load-out;
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• Separate decontamination station for onsite personnel and for transportation
and construction vehicles that will leave the Site;
• Offsite transportation and disposal of impacted soil;
• Backfill delivery and placement; and
• Site restoration.
Details of the scope of work are provided below and Figure 4 presents the general
locations of planned site activities.
3.1 MOBILIZATION AND SITE PREPARATION
Once planning and preparation activities are complete, manpower, equipment, and
supplies will be mobilized to the site. The on-site project personnel will include at a
minimum the following:
• Environmental Management
o Construction Quality Manager
o Site Field Safety Officer (FSO)
• Earth Work Subcontractor
o Construction Site Superintendent
o Excavation Foreman/Excavator Operator
o Rubber Tire Loader Operator (stockpile consolidation)
o Technician (Tarp Management and Decontamination)
The necessary equipment will at a minimum include:
• Excavator;
• Dump truck;
• Rubber tire loader;
• Water truck for dust suppression;
• Decontamination equipment;
• Temporary sanitary facilities; and
• Miscellaneous tools and support vehicles.
Prior to initiating excavation, the targeted excavation extents will be defined and
marked. A private utility contractor will be used to locate potential underground
utilities within and adjacent to the planned excavation areas. Additionally and as
required by Law, the North Carolina One-Call Center will be notified 72 hours prior to
initiation of excavation. Relevant previous soil samples used to define the excavation
area will be located and their position will be surveyed.
Security fencing will be installed to control access around the work areas. Removable
locking sections of chain link construction fencing will be installed to allow access on
and off site (Figure 4). One main entrance from Mt. Holly-Huntersville Road will serve
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as the primary entrance and exit locations to the work area. A decontamination area
will be located near the site entrance (Figure 4). The decontamination area will include
personal protective equipment (PPE) and small equipment storage area, boot wash, eye
wash station, and expended PPE disposal container. The truck dry decontamination
pad consisting of crushed stone will also be established near this area of the site.
Because the excavation is less than 1 acre in size, a formal erosion and sediment control
(E&SC) plan is not required. However because of the nature of the excavation and
removal activities, E&SC control measures will be installed at the site prior to initiation
of site excavation In general, the E&SC measures include silt fence installed along the
downgradient portions of the property as well as straw bales in areas of potential
stormwater runoff. If at any point during the excavation, the E&SCs are not adequately
managing stormwater runoff or if the controls appear worn or damaged, additional
control devices will be installed or repaired. The site E&SC controls will be inspected
daily and prior to and after rain events. Should the scope require such duration,
monthly inspections will be conducted on areas that have undergone final E&SC
measures. Inspection records will be maintained by the Construction Quality Manager
until project completion.
After the E&SCs have been installed and underground utilities cleared, necessary site
grading will be completed to allow truck access to the site from Mt. Holly-Huntersville
Road. The layout of the access areas has been planned to accommodate dump trailer
traffic. A truck dry decontamination station will be established to minimize visible soil
on wheels and truck bodies. The existing soils and grade will be used to the extent
possible and compacted as needed to allow truck traffic. Where necessary, the access
point areas will be amended with gravel to stabilize the surface.
3.2 IMPACTED MATERIAL EXCAVATION
The areas scheduled for initial excavation are shown on Figure 4. Prior to excavation, a
North Carolina Registered Land Surveyor (RLS) will locate the previous sample
locations and other relevant site features. A treatment area will then be constructed and
secured within security fencing.
The excavation activities will begin in the smaller of the two impacted areas. As soils
are removed, the excavation will continue initially to the predetermined excavation
extents. The excavation will proceed from the starting location and will be guided by
the presence of visually impacted soil (dark staining). The vertical extent of the
excavation will be determined based on historical sampling results and/or visual
inspection. The material from the smaller of the two locations, will be moved to the
central staging / treatment area which will be constructed adjacent to the larger of the
two impacted areas in former Pond A.
Excavation activities will continue in the larger of the two impacted areas and proceed
as above, guided by the presence of visually impacted soil (dark staining). The vertical
extent of the excavation will be determined based on historical sampling results and/or
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visual inspection. Based on data from prior borings, groundwater is not anticipated in
the excavation.
Upon completion of the removal activities, it is anticipated that up to 20 soil samples
will be collected from the sidewalls and base of the two excavation areas to confirm
material removal. Samples will be analyzed for lead via the TCLP process. The
required sample containers will be filled using decontaminated collection tools (trowels,
stainless-steel hand auger, etc.). Samples will be immediately placed on ice and
shipped/delivered under Chain of Custody control to a certified North Carolina
laboratory. For quality control purposes, 10% duplicate samples will be collected and
submitted for laboratory analysis.
Excavation of the impacted materials will primarily be achieved using a tracked
excavator and the soil will be relocated to the designated stockpile area. The stockpile
will be positioned on the southern end of Pond A as shown on Figure 4. A rubber tire
loader will be used to consolidate the material into one stockpile. A water truck or
water tanker will be maintained on-site at all times to moisten the excavated area and
stockpiles to limit dust production. The stockpile will be watered at the end of a work
day and covered in poly sheeting to prevent transport/migration of lead impacted
material via wind.
After post-excavation samples are received that indicate that underlying native soils do
not contain concentrations of metals above the TCLP concentrations for lead, a post-
excavation survey will be conducted by an RLS to document the horizontal and vertical
location of the excavation area and the confirmation sample locations.
3.3 STOCKPILE MANAGEMENT
A water tanker truck and or a water tank will be used prior to and throughout the
removal process to wet the grounds and structural materials in an effort to suppress
dust and particulates. The planned stockpile area has been strategically placed between
the excavation/treatment area and the truck access locations to minimize traffic across
the site and prevent migration of impacted materials via truck traffic.
Plastic 10 mil sheeting will be placed on the existing ground surface prior to the start of
the soil stockpile. A soil berm will be constructed around the perimeter of the stockpile
area to form a slight bowl over which the plastic sheeting will be placed. This will help
to capture potential liquids draining from the soils or generated due to soil wetting or
rain events. If necessary, liquids accumulating within the base of the stockpile area will
be managed with a vacuum truck or transfer pump and transferred to 55-gallon steel
drums. These liquids will be sampled for metals and ultimately disposed offsite in an
appropriate manner as determined by the laboratory analysis.
The soil stockpile will be wetted and covered at the end of each work day using poly
sheeting or tarps to limit dust generation and transport. The soil stockpile will be
ERM 15
covered prior to rain events. The soil stockpile covers will be anchored by gravel, or
sand bags.
3.4 MATERIAL STABILIZATION
TSP Dosing Pilot Test
The referenced CAP (Aware 2006) recommended an application of 5.5% (36 tons) triple
super phosphate (TSP) to treat the approximately 650 tons of lead impacted foundry
sands detailed in this workplan for excavation. Based on the assessment results and
documented lead concentrations, an application of approximately 1% to 2% is generally
adequate to effectively bind (stabilize) the lead sufficiently for disposal as a non-
hazardous material. To refine the TSP application rate sufficient to treat the excavated
material, ERM will conduct a bench scale pilot test to determine the appropriate volume
of TSP necessary to effectively stabilize the lead impacted soil.
To conduct the pilot test, two soil borings will be advanced at the Site prior to
excavation, one in each of the two areas of the targeted foundry sands. Based on TCLP
data, borings will be installed in the areas and at the depths where soil sampling
previously indicated the highest lead concentrations. Borings will be manually
advanced using a stainless steel hand auger. The soil sample from each boring will be
homogenized, and then quartered into four separate aliquots. Three of the soil sample
aliquots will be mixed with 1%, 3% and 5% TSP, respectively and analyzed for lead via
TCLP. The remaining soil sample aliquot will be analyzed for total lead and TCLP lead
to confirm the initial lead concentration. Using the data from the pilot test, a TSP
application volume will be selected to achieve stabilization.
Full Scale Stabilization
Upon selection of the TSP application volume, the stabilization agent will be mobilized
to the site, applied to the stockpile and be thoroughly mixed into the stockpiled material
using a backhoe or equivalent method.
Post Stabilization Stockpile Sampling
Once the material and TSP are thoroughly mixed, to test effectiveness of the
stabilization process, soil samples will be collected from the stabilized material. Based
on the estimated total volume of 431 cubic yards of foundry sands requiring
stabilization, approximately 6 samples will be collected from the stockpile material for
TCLP extraction testing. The TCLP limit for lead is 5 mg/l. If based on the post
treatment sample results, the lead in the treated material is not stabilized, additional
TSP will be applied and the sampling process repeated until post treatment samples
pass the TCLP limit for lead.
ERM 16
In accordance with the disposal facility waste characterization requirements, at a
minimum, three post treatment composite samples from the stabilized material will be
collected for laboratory analysis. Each sample will consist of a 3-point composite
sample and will be submitted to a certified North Carolina laboratory for analysis of
total and TCLP lead. After receipt and review of the analytical data, an appropriate
disposal method will be identified. It is anticipated that the treated material can be
disposed in a subtitle D landfill.
3.5 SOIL LOAD-OUT, TRANSPORTATION, AND DISPOSAL
A waste profile will be generated based on the stockpile analytical results. The
stockpiled soils will then be transported offsite for disposal under the approved waste
profile. The treated material will be loaded into dump trailers using an excavator.
Transportation dump trucks, dump trailers or roll-off boxes, as appropriate will be
dedicated to handling of the impacted material. The trucks or containers will not be
used to transport backfill during the same day. Soil from outside the trucks and on the
tires will be removed prior to the trucks leaving the site by dry brushing while on a
decontamination pad. Soil or waste materials cleaned from the trucks will be returned
to the stockpile area for proper disposal.
It is currently planned that the impacted soil will be transported and disposed at a
subtitle D landfill pending approval. Transportation manifests for each truck / roll off
box will be generated and signed by CPF or designated representative, and a soil
disposal log including the load date, load number, manifest number, truck number,
time in, time out, and stockpile description will be completed.
3.6 BACKFILL DELIVERY AND PLACEMENT
The backfill material including up to 3 inches of topsoil will be obtained locally. To
ensure that backfill materials are free of contaminants, one sample each from the
backfill and topsoil material will be obtained and submitted to the laboratory for
chemical analysis of VOCs (EPA 8260B), SVOCs (EPA 8270C), and IHSB priority metals.
If the excavation contains standing rain water at the time of backfill operations, the
water will be removed and the area allowed sufficient drying time. A 3-inch pump and
filtration system that filters the water from the excavation using bag filtration units with
10 micron filters prior to discharge will be used. Water will be containerized, sampled
and disposed as hazardous or non-hazardous waste depending on characterization
results.
Once clean fill materials have been identified, backfill activities will be initiated after
the following:
• Receipt of post-excavation soil sample laboratory results indicating soil
remediation goals have been satisfied;
• Completion of the post excavation survey.
ERM 17
To restore the property, the clean backfill will be placed directly into the excavation in
lifts (and wetted if necessary) and compacted with a backhoe. The excavation area will
be finished with 3-4 inches of top soil, terminating at the pre-excavation grade level.
The area will be graded to avoid standing water and achieve the pre-excavation
drainage conditions.
3.7 REVEGETATION
Upon final backfill and grading, disturbed areas will be prepared for restoration with a
vegetative cover consisting of native grass as necessary to stabilize the site. Before grass
seed is emplaced, the area will be cleared of stones larger than 2-inches, roots, and other
debris and the new topsoil will be loosened to a minimum depth of three (3) inches.
The excavation area and other disturbed areas of the property will then be seeded with
a native grass blend and covered with straw. The seed will be watered periodically, as
needed, to establish a vegetative cover. The cover conditions will be inspected at a
minimum directly after germination, and two months post germination. Additional
seed will be applied in the amend the cover as needed.
3.8 SITE CLEANUP AND DEMOBILIZATION
At the conclusion of site activities, demobilization will occur. The temporary
improvements installed at the site as part of construction activities, including but not
limited to unneeded erosion control devices, soil stockpile areas, and construction
fencing, will be removed from the site. All general construction trash and associated
containers will be removed and disposed of properly.
Construction equipment scheduled for demobilization will be decontaminated on the
dry decontamination pad. The decontamination materials will be collected and
disposed of at the selected landfill. The Project Team will walk the site and confirm that
all disturbed areas have been restored. Once revegetation has occurred, the remaining
erosion control devices will be removed from the site.
3.9 REPORTING
At the completion of the project, a Voluntary Removal Action Report will be prepared
and submitted to the NCDENR. The report will include, at a minimum, the following:
• Detailed discussion of the excavation activities completed;
• Confirmation soil sampling summary and results including summary tables,
figures, and laboratory reports;
• Excavation and disposal totals (tons, cubic yards);
• Survey map illustrating extents of excavation;
ERM 18
• Soil disposition including records of transportation and disposal weight
tickets/manifests, and
• Field activity documentation including a photographic log, excavation
records and site restoration.
FIGURES
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Site Location MapRemoval Action Work PlanAnne R. Edwards PropertyCharlotte, North Carolina
LEGEND
Project Site
0 500 1,000 Feet
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ERM NC, INC.FIGURE1
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Present Road Boundary
Old Road Boundary
Former Minnow Pond
Project Site Boundary
Parcel Boundary
ERM NC, INC.Site MapRemoval Action Work PlanAnne R. Edwards PropertyCharlotte, North Carolina 2
FIGURE
Notes: Source of 2009 Aerial Photography:Mecklenburg County, North CarolinaSource of Pond Locations: Aware Figure 2: Boring andSample Location Map and 1966 Aerial Photograph
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Piedmont Companies Inc. Property
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Piedmont Companies Inc. Property
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TABLES
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TP-1 12/21/2004 Unknown <0.025 0.58 NA <0.01 8.6 <0.0002 <0.025 <0.01
TP-2 12/21/2004 Unknown NA 0.6 0.07 <0.01
2.9 <0.0002 <0.025 <0.01
TP-7 12/21/2004 Unknown <0.025 0.37 0.047 <0.01 0.82 <0.0002 <0.025 <0.01
TP-9 12/21/2004 Unknown <0.025 0.34 0.082 <0.017 2.2 <0.0002 <0.025 <0.01
B-1 10/31/2005 4.-6.5 NA NA NA NA 1.2 NA NA NA
B-2 10/31/2005 3.5-6 NA NA NA NA 2 NA NA NA
B-11 10/31/2005 3.5-6 NA NA NA NA 3 NA NA NA
B-15 10/31/2005 4-6.5 NA NA NA NA 10 NA NA NA
B-20 10/31/2005 5-8.5 NA NA NA NA 7.2 NA NA NA
B-21 10/31/2005 0.5-3.5 NA NA NA NA 0.7 NA NA NA
B-31 10/31/2005 6.5-8 NA NA NA NA 6 NA NA NA
B-37 10/31/2005 3-4 NA NA NA NA 0.62 NA NA NA
B-38 10/31/2005 1.5-3.5 NA NA NA NA 0.64 NA NA NAB-39 10/31/2005 3.5-4.5 NA NA NA NA 0.92 NA NA NA
B-41 10/31/2005 2.5-4 NA NA NA NA 1.4 NA NA NA
B-42 10/31/2005 3-5 NA NA NA NA 2.8 NA NA NA
B-43 10/31/2005 2.5-3.5 NA NA NA NA 0.68 NA NA NAB-45 10/31/2005 3-4 NA NA NA NA 1.3 NA NA NA
B-48 10/31/2005 4-5 NA NA NA NA 4.3 NA NA NA
B-49 10/31/2005 3.5-4 NA NA NA NA 1.3 NA NA NA
B-50 10/31/2005 3.5-4 NA NA NA NA 1 NA NA NA
B-51 10/31/2005 5-6 NA NA NA NA 4.7 NA NA NA
B-53 10/31/2005 1-3 NA NA NA NA 0.24 NA NA NA
B-56 10/31/2005 5-7 NA NA NA NA 15 NA NA NA
B-58 10/31/2005 4.5-6 NA NA NA NA 16 NA NA NA
B-59 10/31/2005 2.5-3 NA NA NA NA 0.5 NA NA NA
B-61 10/31/2005 4-6 NA NA NA NA 13 NA NA NA
B-62 11/28/2005 3-4 NA NA NA NA 1.8 NA NA NA
B-63 11/28/2005 4-5 NA NA NA NA 5.6 NA NA NA
B-64 11/28/2005 3-4 NA NA NA NA 0.84 NA NA NA
B-65 11/28/2005 4-5 NA NA NA NA 3.9 NA NA NA
B-66 11/28/2005 4.5-5.5 NA NA NA NA 2.8 NA NA NA
B-67 11/28/2005 3.5-6 NA NA NA NA 0.42 NA NA NA
B-68 11/28/2005 1-7 NA NA NA NA 0.6 NA NA NA
B-69 11/28/2005 4-5 NA NA NA NA 8.8 NA NA NA
B-70 11/28/2005 2-3 NA NA NA NA 4 NA NA NA
B-71 11/28/2005 3-4 NA NA NA NA 2.4 NA NA NA
B-72 11/28/2005 4-5 NA NA NA NA 3.4 NA NA NAB-73 11/28/2005 4-5 NA NA NA NA 1.9 NA NA NA
B-74 11/28/2005 4-5 NA NA NA NA 1.7 NA NA NA
B-75 11/28/2005 3-4 NA NA NA NA 1.4 NA NA NA
B-78 11/28/2005 4-5 NA NA NA NA 0.094 NA NA NAB-79 11/28/2005 4-5 NA NA NA NA 1.6 NA NA NA
B-80 11/28/2005 4-5 NA NA NA NA 11 NA NA NA
5 100 1 5 5 0.2 1 5
Notes:
mg/L= milligrams per liter
Bold values Exceed TCLP Limit Version 1.0 EH
NA = Sample Not Analyzed
"<" = compound not detected above method detection limit
TCLP = Toxicity Characteristic Leaching Procedure
TCLP Standard
Test Pit Data (S&ME 2004)
Soil Borings (AWARE Environmental 2005)
TABLE 2. SUMMARY OF FOUNDRY SAND FILL AND NATIVE SOIL TCLP ANALYTICAL RESULTS
ANNE EDWARDS PROPERTY
TCLP METALS (mg/L)
File AE Worlplan Tables (1-12).xls
AEI Project No. N432-03
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ATTACHMENT A
QUALITY ASSURANCE PROJECT PLAN
QUALITY ASSURANCE PROJECT PLAN
Anne R. Edwards Property
Charlotte, North Carolina
Quality Assurance (QA) is defined as an integrative program designed to assure
reliability of monitoring and measurement data. Quality Control (QC) is defined
as the routine application of procedures for obtaining prescribed performance
standards for monitoring, measuring, and assessment data.
Data Quality Objectives
The quality assurance objectives associated with the project sampling are in place
to ensure that the data collected during all phases of work are of sufficient
quality to support decisions regarding confirmation that metals impact waste
and native soils are removed from the site. QA is established to assure
appropriate equipment and methods are used. Data Quality Objectives (DQOs)
are used to set parameters and guidelines to evaluate data with respect to
precision, accuracy, representativeness, completeness and comparability.
Specific QC measures are developed for both field and laboratory procedures to
help assure data quality falls within these parameters and guidelines to meet the
DQOs. For this project, the data quality will be comparable to Level III as
defined in the EPA Contract Laboratory Program. Level III data provides an
intermediate level of data quality and is typically used for site characterization.
Quality Control Samples
Quality control samples will be collected and field equipment will be calibrated
throughout the field activities. Quality control samples will include equipment
blanks, and duplicate samples collected during the sampling events.
Equipment blanks shall be prepared by rinsing field-cleaned equipment with
laboratory supplied de-ionized water and collecting the rinse water in a sample
container. An equipment blank shall be prepared to verify the adequacy of
decontamination procedures during the sampling events. One equipment blank
sample will be prepared per every sampling tool, per each 10 samples.
Field duplicate samples will be collected as a check on the laboratory’s accuracy
and precision. Duplicate samples shall be prepared by placing sample material
collected simultaneously from the same source under identical conditions into
two separate sample containers. Duplicate samples will be collected during the
sampling event. For quality control purposes, 10% duplicate samples will be
collected and submitted for laboratory analysis. Equipment and duplicate
Appendix A Page 1 of 6
samples sample will be analyzed for IHSB priority metals via EPA 6000 -7000
series.
Excavation Confirmation Samples
To confirm suspect material has been removed from the Edwards property, up to
20 soil samples will initially be collected from the sidewalls and base of the
excavation following soil/waste removal. Duplicate samples for soil will be
homogenized prior to placement in laboratory containers. Homogenization will
be performed by mixing the soil sample in a stainless steel bowl and then
distributing samples into their respective laboratory-provided containers.
Confirmation samples will be collected for analysis of TCLP Lead. The required
sample containers will be filled using decontaminated collection tools (trowels,
stainless-steel hand auger, etc.). Samples will be immediately placed on ice and
shipped under Chain of Custody control to North Carolina certified laboratory
Pace Labs of Huntersville, North Carolina for analysis.
Field Cleaning Procedures for Sample Contacting Equipment
Sample contacting equipment such as scoops, trowels, etc. shall be
decontaminated in the field using the following procedure.
1. Clean with tap water and laboratory detergent using a brush if
necessary to remove particulate matter and surface film;
2. Rinse thoroughly with tap water;
3. Rinse thoroughly with de-ionized/distilled water;
4. Rinse twice with solvent (isopropanol unless otherwise noted);
5. Rinse thoroughly with organic-free water and allow to air dry as
long as possible.
If organic-free water is not available, allow equipment to air dry as long as
possible.
Sample Identification
In instances where samples must be collected for laboratory analysis or
evaluation, documentation of the sampling event will be included in the field
notebook and on the appropriate laboratory paperwork. Sample labels will be
attached to or affixed to each sample container. Labeling shall be performed
Appendix A Page 2 of 6
with waterproof ink. The following information must be included on the sample
container:
Project Number or other identifying reference;
Field Identification or Sample Station Number;
Date and time of sample collection;
Depth of sample location;
Initials of sampler;
Preservatives added;
Analyses to be performed; and
Relevant comments, if applicable (highly toxic, odor, reactive, etc.)
Chain-of-Custody
Chain-of-Custody forms shall be prepared to document the transfer of
possession of samples. Standard Chain-of-Custody forms will be used for all
sample shipments. The following information is required to complete the Chain-
of-Custody:
Project number and site location;
Name and telephone number of individual completing the Chain-of-
Custody;
Identification, date, time, grab or composite, type (water, liquid, solid),
number of containers, analysis to be performed and relevant remarks for
each sample;
Comments such as packing and shipping information; and
Signature, date and time of personnel relinquishing samples.
Sample Custody
Labels and sample containers of adequate number and size containing required
preservatives shall be provided by the contract laboratory in addition to ice
chests for storage and transport of samples. Sample containers shall generally be
filled leaving a small amount of headspace. Care should be taken to keep soil or
other materials away from container threads so that an airtight seal can be
achieved.
After collection, sample handling shall be minimized. Immediately after filling
the sample container, the sample container shall be securely capped and labeled.
Containers shall be placed inside plastic Zip-lock® bags and wrapped with
packaging material if appropriate to reduce the potential for container damage
during shipping. Containers shall be stored on ice immediately after collection
and labeling, and shall be shipped in ice chests to the receiving laboratory with
Appendix A Page 3 of 6
adequate ice to maintain appropriate temperature. Ice chests shall be secured
with packaging tape and include custody seals. The receiving laboratory should
be consulted about sample shipping and delivery arrangements so that sample
holding times will not be exceeded.
Sample containers filled with heavily contaminated material should be placed
immediately into a Zip-lock® bag after collection, preservation and identification.
Samples with suspected heavy contamination shall be shipped separately from
trace and ambient samples when practicable.
Samples must be maintained in a secure manner to maintain control over
management of the sample conditions and to avoid tampering, vandalism and
other negative effects. Samples are considered secure if one of the following
applies:
They are in the hands of the project team or transferee, such as
FedEx;
They are in clear view of the project team or the transferee;
The project team or transferee secured them in a manner to
prevent obvious tampering (i.e., locked truck, car, storage cabinet);
or
They are placed in a designated secure area.
Calibration of Equipment
Field equipment requiring calibration includes TSI AM-510 Aerosol / Particulate
Monitor and TSI Dust Trak. Calibration procedures are generally specific to each
model and are not included in this document. Calibration shall be performed
per the manufacturer's instructions and recommended schedule.
Data Management, Validation, and Reporting
Data Management
Raw data from field measurements and sample collection activities will be
appropriately recorded in the field logbook. If the data are to be used in the
project reports, they will be reduced or summarized, and the method of
reduction will be documented in the report.
Appendix A Page 4 of 6
The subcontractor laboratory will perform in-house analytical data reduction
under the direction of the Laboratory QA Officer. The Laboratory QA Officer is
responsible for assessing data quality and advising of data which were rated
“preliminary” or “unacceptable” or other notations which would caution the
data user of possible unreliability. Data reduction, by the laboratory, will be
conducted as follows:
• Raw data produced by the analyst is submitted to the respective area
supervisor;
• The supervisor reviews the data for attainment of quality control
criteria as outlined in the QA/QC program and/or established US EPA
methods and for overall reasonableness;
• Upon acceptance of the raw data by the supervisor, a computerized
report is generated and sent to the Laboratory QA Officer;
• The Laboratory QA Officer is responsible for auditing reports generated
within the laboratory;
• The Laboratory QA Officer and supervisor will decide whether any
sample re-analysis is required; and
• Upon acceptance of the preliminary reports by the Laboratory QA
Officer, final reports will be generated and signed by the Laboratory
Section Supervisor.
Data reduction procedures will be those specified in the SW-846 for inorganic
analyses.
Data Validation
The Data Reviewer will review field notes and field Chain-of-Custody forms to
determine that procedures have been followed. Data validation will be
accomplished under the direction of the QA/QC Coordinator. The Data
Reviewer will conduct a systematic review of the data for compliance with the
established QC criteria based on the spike, duplicate, and blank results provided
by the laboratory. An evaluation of data accuracy, precision, sensitivity, and
completeness will be performed using the following guidance documents for
data validation:
• Laboratory Data Validation Functional Guidelines for Evaluating
Inorganic Analyses - US EPA, December, 1996.
The Data Reviewer will identify out-of-control data points and data omissions
and will interact with the laboratory to correct data deficiencies. Decisions to
repeat sample collection and analyses may be made by the ERM Project Manager
Appendix A Page 5 of 6
based on the extent of the deficiencies and their importance in the overall context
of the project.
Data generated for the site during this removal action will be computerized in a
format organized to facilitate data review and evaluation. The computerized
data set will include the data flags provided by the contractor laboratory, as well
as additional flags and comments of the Data Reviewer. The Data Reviewer will
assess the usability of results against the data quality objectives (DQOs).
Data Reporting
Field data reporting will consist of field logs documenting site activities and the
field copy of Chain-of-Custody forms.
The laboratory will prepare and retain full analytical and QC documentation as
required by SW-846. Such retained documentation need not be hard (paper)
copy, but may be in other storage media (digital medial). As needed, the
laboratory will supply a hard copy of the retained information. The laboratory
will report the data in the same chronological order in which it is analyzed along
with the QC data. The subcontract laboratory will provide the following
information in each analytical data package submitted:
• Cover sheets listing the samples included in the report and narrative
comments describing problems or issues encountered during analysis,
• Tabulated results of compounds identified and quantified,
• Surrogate recovery date,
• Matrix spike/matrix spike duplicate (MS/MSD) recovery date,
• Procedural/method blank summary,
• Results of laboratory duplicate analyses and laboratory control sample
(LCS) analyses,
• Instrument performance check, and
• Copies of laboratory Chain-of-Custody forms.
Raw data system printouts (or legible photocopies) identifying date of analysis;
analyst’s name; parameters determined; laboratory initial and continuing
calibration data; calibration verification summary; computer printouts; internal
standard area and retention time summary; and clean-up information will be
retained by the contractor laboratory.
Standard Laboratory Information Management system (LIMS) reports with
Estimated Quantitation Limits (EQLs) for the target analytes will be provided for
the screening data.
Appendix A Page 6 of 6
ATTACHMENT B
HEALTH AND SAFETY PLAN