NCD991278953_19920211_National Starch & Chemical Corp._FRBCERCLA RD_Performance Monitoring Work Plan OU-2-OCR

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I rn INTERNATIONAL TECHNOLOGY I CORPORATION
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NATIONAL STARCH AND CHEMICAL COMPANY
SECOND OPERABLE UNIT
REMEDIAL DESIGN/PERFORMANCE
MONITORING WORK PLAN
February 11, 1992
RESPONSIVE TO THE NEEDS OF ENVIRONMENTAL MANAGEMENT
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rn INTERNATIONAL TECHNOLOGY CORPORATION
February 11, 1991
Ms. Barbara Benoy
Remedial Project Manager
Environmental Protection Agency Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Dear Barbara:
SUBJECT: Submittal of Revised Operable Unit 2 Remedial Design/Performance Monitoring
Work Plan; National Starch and Chemical Company, Salisbury, NC; IT Project
Number 408668. 70
On behalf of National Starch and Chemical Company, enclosed are fourteen bound copies and
one unbound copy of the revised Operable Unit 2 (OU2) Remedial Design/Performance
Monitoring Work Plan. This work plan was revised to incorporate review comments from EPA
and NCDEHNR. Formal written responses to the comments are also enclosed. In addition, five
copies of the Health and Safety Plan (HSP) for OU2 are enclosed for your review. The HSP
was prepared as a separate deliverable document as requested by your comments.
If you have any questions, please do not hesitate to call me.
~~
Michael N. Sturdevant, P.E.
Project Manager
cc: Hank Graulich, NSCC
Ray Paradowski, NSCC
Alex Samson, NSCC
Regional O!fice
312 Directors Drive• Knoxville, Tennessee 37923. 615-690-321 l
IT Corporation Is a wholly owned subsidiary of Internat1onal Technology Corporation
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NATIONAL STARCH AND CHEMICAL COMPANY
SECOND OPERABLE UNIT
REMEDIAL DESIGN/PERFORMANCE
MONITORING WORK PLAN
February 11, 1992
IT PROJECT MANAGER:
I IT QUALITY ASSURANCE OFFICER:
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I KN/WP645COV .OU2/02-11-92JDO
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Responses to U.S. EPA Comments (1/17/92) on the
Remedial Design/Performance Monitoring Work Plan,
National Starch and Chemical Company
Operable Unit 2
(12/10/91)
General Comments
Comment G-1: The overall organization of this document is extremely difficult to
follow. I suggest utilizing the format that is implied in the SOW. A simplified outline is
enclosed to assist you. Please reorganize if at all possible. This will greatly enhance the
clarity of this work plan. For example, Section 4.0 of the work plan is titled Health and
Safety Plan, Soil Sampling. However, I acknowledge and approve some of the changes
you have made. The combination of the documents identified in Task IV of the SOW
(Remediation Goal Verification Plan and the Remediation Goal Verification QA/QC
Plan) into the Sampling and Analysis Plan and Quality Assurance Project Plan is
acceptable. The tasks better addressed with this combination. Please note, however,
that in reorganizing or reformatting it is expected that you will not delete existing
information in the work plan to accommodate this outline/format.
Simplified Work Plan Outline1
Work Plan
Introduction
Statement of Problem
Background and History
Data Summary
Detailed description of tasks to be performed with brief list (table), data
gaps, and deliverables.
Schedule for project and submittals with specific dates.
Project Management Plan.
Sampling Plan and Quality Assurance Project Plan2
DQOs
QA/QC
Methodology
Detection Limits (relate to existing contaminant levels onsite)
U.S. EPA assurance of access to all data and information (see page 7 SOW)
Laboratory requirements
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Health and Safety Plan
This will be a separate volume. Format appears adequate. Please refer to the specific
U.S. EPA comments.
1This is a suggestion.
2-r hese plans may be maintained within the work plan as you have done in the first
draft, but will be definite sections. The above listed items do relate more to Q APP
requirements. It would be appreciated if the Sampling Plan could contain specific field
information, drilling, split spoons, etc., keeping the two better segregated.
Response G-1: The document has been reorganized to closely reflect the suggested outline.
The Health and Safety Plan now is contained under separate cover and supplements the Work
Plan.
Comment G-2: In the November 22, 1992 letter from M. Sturdevant, it was requested
that EPA consider the work for Task I be considered complete. This was a follow-up to
a phone conversation. Any disagreement was to be identified by EPA by December 1,
1991. There were no concerns identified until review of the RD!Performance Monitoring
Work Plan (RD Work Plan). Based on the review of the RD Work Plan, it would
appear that the data objectives have not been clearly defined or agreed upon. The
trench area monitoring should consist of the collection of subsurface soil samples. The
samples should be analyzed for contamination concentrations in the soil. Leachate
analysis of those samples is not applicable to monitoring the performance of the natural
soil flushing/natural attenuation, though may be conducted in addition to soil analysis.
The ROD calls for quarterly monitoring to be conducted. Quarterly monitoring should
be done for one year. This will create a baseline database for comparison purposes.
After the initial year, annual monitoring will be conducted as the work plan suggests.
Background sampling should be conducted to establish natural conditions. Periodic
background sampling should also be included, for example, once every three to four
years to establish current data.
Response G-2: The performance monitoring approach and data objectives are now included
in the revised Work Plan (Chapter 3.0). The approach includes monitoring only the ground-
water underlying the trench area soils. Specific groundwater monitoring points have been
established based upon input from U.S. EPA (IT telecon, 1/30/92). Details of the approach
are in the revised Work Plan.
Leachate analysis may be implied in the repon but is not intended (Section 1.2). Reference
to leachate analysis has been deleted.
Background (soil) sampling will not provide useful data for performance monitoring of OU2.
The revised Work Plan includes monitoring the groundwater underlying the trench area soils.
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Comment G-3: The surface soil sampling that was conducted and reported to EPA in August 1991 should be better identified and discussed in the work plan. This is
considered within the scope of the remedy, though the objective of the work has been completed. Likewise, work conducted on deed restriction, as required in the ROD should be identified and discussed in the work plan.
Response G-3: The August 1991 report is now included in Appendix D of the Work Plan
and summarized in Chapter 2.0.
Comment G-4: Several terms for lists of contaminants are used throughout the work
plan which need to be adequately defined and the appropriate term used. The Priority
Pollutants list is the term of the first list of analytes that was developed for CERCLA
site. The Hazard Substance List (HSL) followed, then the Target Compound List
(TCL), supplemented with the Target Analyte List (TAL). It is probably most appro-priate to use TCL, T AL for purposes of this project unless a site specific list is also used.
Response G-4: Text has been revised to reflect TCL volatile organic compounds
(groundwater) only.
Comment G-5: The Health and Safety Plan must be split off into a separate document. Review of the Health and Safety Plan is different from the review and approval of the RD Work Plan. Also, the Health and Safety Plan needs to be a concise, easy to use
document for all field personnel.
Response G-5: The Health and Safety Plan is now under separate cover.
Comment G-6: The Final Action Report, as required by the SOW, should be addressed in the work plan.
Response G-6: See Section 4.2.2.
SPECIFIC COMMENTS
Comment S-1: Page 1-1, Section 1.0, First Paragraph, Last Sentence -This sentence should read 11 ... is anticipated [or expected] to ...... by 2010. 11
Response S-1: This sentence has been deleted.
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Comment S-2: Page 1-1, Section 1.0, Last Paragraph -This paragraph should read "As
of the signature date of the ROD, no designated North Carolina State Significant,
....... have been identified." Just because the ROD states that none has been identified,
does not mean that one could not be designated in the future.
Response S-2: This paragraph has been corrected and now appears in Chapter 2.0, Section
1.0, Site Location and Description (last paragraph).
Comment S-3: Figure 1-1 -This figure is of very poor quality. It appears to be a
recopy of a copy, etc. Report requires better quality figure; an original would be nice.
Response S-3: This figure has been revised. See new Figures 2-1, Site Location Map, and
2-2, Site Map.
Comment S-4: Page 1-3, Section 1.1, First Sentence, Top of Page -Sentence should read
" •.. pumped into an active trench .•. "
Response S-4: The sentence and paragraph have been revised and now appear in Chapter
2.0, Section 2.0, Site Background (second paragraph).
Comment S-5: Page 1-3, Section I.I, Fourth Paragraph, Fourth Sentence -Please
explain what "the final section: of the samples means. Should this be something akin to
" •.. in the final selection ... "?
Response S-5: "Section" has been changed to "Selection" (see Chapter 2.0, Section 3.0,
Summary of Supplemental ... [first paragraph]).
Comment S-6: Figure 1-2 • This figure is of very poor quality. It appears to be a
recopy of a copy, etc. Report requires a better quality figure. Wording on this map is
illegible; site features cannot be deciphered.
Response S-6: This figure has been revised. See new Figures 2-1, Site Location Map, and
2-2, Site Map.
Comment S-7: Page 1-5, Section 1-1, First Paragraph -This paragraph is entirely too
deficient of technical and specific information concerning the information known
concerning the geology, hydrogeology, and the aquifer at the site. Much information has
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been developed in a regional as well as a site-specific nature. Information should be provided so that readers will not be required to reference other documents such as the
RI report in order to understand the nature of Operable Unit 2, as well as the overall
site.
Response S-7: This paragraph has been revised. See Chapter 2.0, Section 1.1 (Topography
and Geology) and Section 1.2 (Hydrology and Hydrogeology).
Comment S-8: Page 1-5, Section 1-1, Second Paragraph -The supplemental FS was the
document that would have measured the effectiveness of the soil flushing, not the RL
Response S-8: The Supplemental PS evaluated the no-action alternative and only provided a discussion on effectiveness of (natural) soil flushing as a technical merit of no action. The
Supplemental RI provided a measurement of effectiveness of natural soil flushing by utilizing
a contaminant fate and transport ( vadose zone) model. (See Chapter 2.0, Section 3.0, second
paragraph).
Comment S-9: Page 1-5, Section 1-1, Second Paragraph -Do not use the acronym
ARAR if it is not accurately defined in text.
Response S-9: The ARAR definition has been added. (See Chapter 2.0, Section 3.0, third paragraph.)
Comment S-10: Page 1-5, Section 1-1, Second Paragraph -Provide the definition of
DCA prior to the use of the acronym.
Response S-10: The definition has been added. (See Chapter 2.0, Section 3.0, third para-graph).
Comment S-11: Page 1-5, Section 1-1, Last Sentence on Page -The last sentence makes
no sense; something is obviously missing.
Response S-11: This sentence has been deleted.
Comment S-12: Page 1-6, Section 1.2, First Sentence -This sentence makes no sense.
No time limit will be identified at this time for the monitoring program, i.e. " ... for the
time period predicted to leach all of the contaminants."
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Response S-12: This sentence has been deleted.
Comment S-13: Page 1-6, Section 1.2 -Additional information must be provided
concerning the personnel which have been assigned to this project.
Response S-13: Descriptions of personnel are included in the revised Quality Assurance and
Project Plan contained in Appendix B of this Work Plan.
Comment S-14: Page 1-6. Section 1.2 -First sentence states that the SAP will be utilized
to monitor on an annual basis the leaching of the contaminants for the time period
predicted to leach all of the contaminants from the trench area. This sentence needs to
be qualified by giving the predicted time and allowing for additional monitoring if the
contaminant reduction has not been observed at the end of that period of time.
Response S-14: This sentence has been deleted. Both the Supplemental RI and the ROD for
OU2 state that most compounds in the trench soils will leach into the groundwater within 5
years; 1,2-dichloroethane is predicted to take approximately 22 years. This is within the
estimated time frame for groundwater remediation (QUI) at 20 to 30 years. The revised
Work Plan approach (Chapter 3.0) utilizes groundwater monitoring as a means of measuring
the impact from the trench soils. An evaluation of groundwater data will be made in
estimating the time required to reach minimal impact from the trench soils (see Chapter 3.0,
Section 3.0).
Comment S-15: Page 1-7, Section 1.2 -The term "Medical Monitoring" is the usual
term used in the industry and incorporates all the requirements identified by OSHA to
conduct work on hazardous waste sites. The term used in Section 1.2 is Medical
Surveillance. Is there any deviation from the requirements or is this simply a different
term used for this document/project only?
Response S-15: "Medical Surveillance" appears in 29 CFR 1910.120(t)(l). The require-
ments are presented in the revised Health and Safety Plan, now under separate cover.
Comment S-16: Page 1-7. Section 1.2 -The information provided on the annual report
is insufficient. Provide a format or outline which identifies the minimum information
that this report will include.
Response S-16: See Section 4.2.1 of the revised Work Plan.
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Comment S-17: Page 1-8, Section 1.3 -Define "significant" with respect to contamina-
tion in soils, solids, etc. Give specific concentrations in a table. Also provide the cleanup numbers with respect to OUl and how the two remedies are integrated.
Response S-17: "Significant" in this context was generally intended to describe concentration
levels above the range of I to I 00 µg/kg. The concentrations appear in Tables C-1 through
C-4 (Appendix C) of the revised Work Plan. The cleanup numbers and the integration of the two remedies are also described in the revised Work Plan, Chapter 3.0.
Comment S-18: Page 1-8, Section 1.3 -Provide the specific information on the surface
soil analysis from the Risk Characterization Report. This surface sampling investigation
is an important part of the overall remedy selection for O U2 and should be included in the Work Plan as a specific task that was conducted. It met a specific objective that was necessary and specified in the ROD.
Response S-18: The report has been added to the Work Plan under Appendix D. A summary of the report is presented in Chapter 2.0, Section 4.0.
Comment S-19: Table 1-1 -Provide a table which identifies the range of concentrations
found in soils (over time) with locations identified.
Response S-19: The approach of the revised Work Plan focuses on monitoring groundwater
rather than soil as a means of measuring the impact (over time) of the trench soil contamina-
tion on groundwater (see Chapter 3.0). Therefore, funher refinement of the soil data will not
be included. The Supplemental RI data tables now appear in Appendix C for reference.
Comment S-20: Page 1-13, Section 1.4, First Paragraph, First Sentence -Delete "work
plans". Also, it is not the SAP that will be conducted.
Response S-20: This sentence has been deleted. The project schedule now appears in
Chapter 4.0 of the revised Work Plan.
Comment S-21: Page 1-13, Section 1.4 -

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reiterate that more information should be
provided on what the annual report will contain. More specifically, all this information
on the schedule must be presented in tabular form also. This is extremely hard to follow when presented only in text.
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Response S-21: Information on the annual (progress) report is presented in Section 4.2. l of
the revised Work Plan. A schedule is presented in Table 4-1.
Comment S-22: Page 1-14. Section 1.4. Top of Page -Add the word "report" as the
third word in the first sentence.
Response S-22: Corrected.
Comment S-23: Page 1-14. Section 1.5. First Sentence -Delete "when deemed neces-
sary". A Project Management Plan is required by the SOW and is not limited to just
the sampling of the soils. The Project Management Plan should include data manage-
ment, monthly reports (formats), document control, etc. for the overall remedial action.
Please refer to page 6, item e. of the SOW.
Response S-23: The data generated during OU2 performance monitoring will be stored and
maintained in a computerized database (LOTUS software). Progress reports and sampling
reports will be submitted in a combined format that will follow the sampling schedule as
shown in Table 4-1. The required elements of the Project Management Plan are incorporated
in the Work Plan and Quality Assurance Project Plan (Appendix B).
Comment S-24: Page 2-1. Section 2.0. First Paragraph, Second Sentence -Correct
"maybe" to "may be".
Response S-24: This paragraph has been deleted. Revised sampling procedures are
presented in the Field Sampling Plan (Appendix A).
Comment S-25: Page 2-1, Section 2.0, First Paragraph -This paragraph should
acknowledge that EPA can initiate modifications any time during the project if a
problem is identified.
Response S-25: Corrected. See Field Sampling Plan, Appendix A, Section A.l (last
paragraph).
Comment S-26: Page 2-1, Section 2.1 -Entirely too little information is provided on the
drilling aspect of this project. The drilling information should be contained in one
section of the work plan and not split up.
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Response S-26: All drilling procedures have been deleted for the revised Work Plan.
Comment S-27: Page 2-1, Section 2.2 -Parentheses are missing in first sentence. There
should be variation in the depth of the samples collected.
Response S-27: Sampling procedures have been revised to reflect groundwater monitoring
only. See Appendix A, Field Sampling Plan.
Comment S-28: Page 2-1, Section 2.2 -Flame ionization is two words.
Response S-28: See Response S-27.
Comment S-29: Figure 2-1 -This figure needs a more comprehensive legend and should
be an original figure. Superimposing new locations over old locations is confusing.
Historical locations may be shown on a separate figure if necessary.
Response S-29: Corrected. See revised Figure A-1 of the Field Sampling Plan (Appendix
A) and Figure 2-3 of the revised Work Plan.
Comment S-30: Page 2-3 -Split spoons are composite samples by definition and should
not be referred to as "grab type" samples.
Response S-30: See Response S-27.
Comment S-31: Page 2-3, First Sentence After Bullet Items -This sentence is ambig-
uous. Sample documentation should be conducted at the time of collection. As written,
an "activity" is not adequately defined.
Response S-31: See Response S-27.
Comment S-32: Tables 2-1, 2-2 -All of the sample containers must have Teflon-lined
septa/caps. The holding time for semivolatile organics is 7 days until extraction and 40
days after extraction. Trip blank is not a parameter. Water samples to be analyzed for
volatile organics must be analyzed within 7 days if not preserved or within 14 days if
preserved with concentrated HCI to pH, 2.
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Response S-32: These comments have been incorporated in the Field Sampling Plan,
Appendix A, Sections A.3 and A.4.
Comment S-33: Page 3-1, Section 3.1, First Sentence After Bullet Items • This sentence
should also contain reference to EPA-SOP. A copy of the most current version is
forwarded with these comments.
Response S-33: Reference has been added. (See Section B.1.1, Appendix B.)
Comment S-34: Page 3-16 -The decontamination detergent must be phosphate free.
Response S-34: This paragraph has been deleted (see Section B.4.0, Appendix B). Decon-tamination procedures are described in the Field Sampling Plan (Appendix A), which reflects
the use of phosphate free detergent.
Comment S-35: Page 3-28, Section 3.7.1.1 -The CLP is not a certification program.
This sentence must be corrected to delete any reference to certification.
Response S-35: The sentence has been rewritten to avoid indication of a certification
program. (See Section B.7.2, Appendix B.)
Comment S-36: Page 3-3, Section 3.2 -This section is entirely insufficient. Sample resumes are needed on individual personnel identifying their function and role in the project. This is necessary on field personnel as well as management personnel. Though sub-contractor individuals do not need to be identified, the companies and general
qualifications should be included.
Response S-36: Resumes of personnel listed on the organization chart (Figure B-7-1) are
included as an attachment to the QAPP (Appendix B).
Comment S-37: Table 3a, 3b, 3c, and 3d -Information should be provided that relates
these detection limits to the known concentrations of the contaminants in the soils and whether these detection limits are sufficiently low to meet the needs of the performance
monitoring.
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Response S-37: With the exception of Table 3a (now Table B-3-1, Appendix B), all tables
have been deleted because the revised Work Plan (and FSP) only addresses TCL volatile
organic compounds in groundwater.
The CRQL for vinyl chloride (10 ppb) is the only detection limit that exceeds the groundwa-
ter cleanup criteria (Table B-3.1 ). The CLP 2/88 protocol will be modified by increasing the
volume of sample purged for the VOA analysis from 5 ml to 25 ml in order to achieve the
required detection limit for vinyl chloride.
Comment S-38: Page 3.8 -I reiterate that CLP packages will be submitted to the
Agency.
Response S-38: CLP packages will be submitted to U.S. EPA for split samples only, or upon
request.
Comment S-39: Page 3.14, Section 3.3.3, Fourth Sentence -Delete the word "also".
Response S-39: This sentence has been deleted (see Section B.3.3, Appendix B).
Comment S-40: Page 3.14, Sections 3.3.4 and 3.3.5 -More specific information is needed
on the validation procedures. The sentence that states that "over 90 % of all data
obtained on this project should be valid based upon evaluation of the QC data" is
erroneous. This may be an objective. Please clarify. A "CLP Package" is required for
sampling events. This is identified in the SOW and has been routinely required on
RI/FS work. Please include in the work plan.
Response S-40: Sentence has been reworded to indicate an objective (see Section B.3.4,
Appendix B). A CLP package will be provided upon U.S. EPA's request.
Comment S-41: Page 3-16, Section 3.4, Third Paragraph -This is improper use of semi-
colons.
Response S-41: Corrected.
Comment S-42: Page 3-16, Section 3.4 -Logbooks should be bound notebooks.
Sampling should be conducted from least contaminated to most contaminated. Back-
ground core samples should be collected from a representative location on site to
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establish background conditions. Background conditions will have to be updated
periodically, (every three to four years).
Response S-42: IT standards require.Field Activity Daily Logs that contain unique and
sufficient documentation of field events. The revised Work Plan addresses only groundwater
sampling. Sampling will be achieved by use of dedicated hailers; therefore, a standard
sequence is unnecessary. Sampling procedures are addressed in the Field Sampling Plan
(Appendix A). Background (soil) sampling is unnecessary for performance monitoring of
OU2. (See Response G-2.)
Comment S-43: Page 3-19, Section 3.4.1, First Sentence -Third word should be "or•.
Response S-43: Decontamination procedures have been moved to the Field Sampling Plan
(Appendix A).
Comment S-44: Page 3.28, Section 3.7.1 -Text should state that the holding times will
be adhered to and what procedure will take place when holding times are exceeded.
The second bullet item is unclear; please clarify. Fourth bullet item, substitute the word
"will" for "should".
Response S-44: Text has been corrected (see Section B.7.1, Appendix B).
Comment S-45: Page 3-29, Section 3.8 -Insufficient information is provided on the
metals analysis.
Response S-45: The revised Work Plan includes TCL volatile organics only. Reference to
metals analysis has been deleted.
Comment S-46: Page 3-30, Section 3.9.2.1 -and %Rand DFTPP should be defined
with or prior to their use.
Response S-46: "%R" (percent recovery) is defined in Section B.3.3 (Appendix B).
"DFrPP" has been deleted.
Comment S-47: Page 3-30, Section 3.9.2.1, Third Paragraph -This may be done only if
it is within EPA accepted procedures and only if properly qualified when reported.
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Response S-47: This paragraph has been deleted (see Section B.9.2, Appendix B).
Comment S-48: Page 3-32, Section 3.9.2.2 -This needs additional information.
Response S-48: This section has been deleted (see Response S-45).
Comment S-49: Page 3-33. Section 3.10 -EPA guidance on QA should be cited in this section concerning audits. Text should also reflect that EPA should have access to all of the information, data, laboratories, etc. identified in, but not limited to, the fourth
paragraph.
Response S-49: EPA guidance and EPA access has been added (see Section B.10, Appendix
B).
Comment S-50: Page 4-7, Section 4.3.2, First Full Paragraph • This section presents
notations that explain some characteristics of concentrations. Where are the notations to be found and are the notations pertinent information for this work plan?
Response S-50: Reference to ceiling notation has been deleted. (Note: The revised Health and Safety Plan is now under separate cover).
Comment S-51: Page 4-11, Section 4.4.2 -Terminology that is not common to the
readers should not be used unless adequately defined. Cathead, catline, and wraps are examples of words that may be known by someone familiar with drill rigs. These terms are not familiar to many of the various disciplines.
Response S-51: All procedures penaining to drilling have been deleted.
Comment S-52: Page 4-12, Section 4.4.2.3 -First word in the last sentence in the first bullet item should be capitalized.
Response S-52: See Response S-51.
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Comment S-53: Page 4-17. Section 4.5.1. Second Bullet Item -Since the site personnel
shall have an assigned respirator, the personnel should be FIT tested for their assigned
respirator. Please indicate so.
Response S-53: Corrected.
Comment S-54: Page 4-17. Section 4.5.1 -Air purifying respirators have several
limitations that must be identified in the Health and Safety Plan, i.e., limits of car-
tridges, atmospheric conditions that must be met, warning properties of contaminants,
etc.
Response S-54: Limitations have been added.
Comment S-55: Page 4-17. Section 4.5.1. Seventh Bullet Item -"Touch" is misspelled.
Response S-55: Corrected.
Comment S-56: Page 4-19, Section 4.6.1 -Regulatory personnel would include EPA
personnel. Delete this limitation of only allowing regulatory personnel site access during
business hours.
Response S-56: Corrected.
Comment S-57: Page 4-19. Section 4.6.4, Second Sentence -"Onsite" is misspelled.
Response S-57: Corrected.
Comment S-58: Page 4-22, Section 4.8.1 -Last sentence of first paragraph should say
"an organic vapor analyzer". Third paragraph identifies "integrated" samples. Please
define integrated samples.
Response S-58: Last sentence has been corrected. "Integrated Samples" has been replaced
with "full shift personal air monitoring samples."
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Comment S-59: Page 4-26, Section 4.10, Eighth Bullet Item -Why the differentiation
for electrocardiogram for persons older than 45 years of age? Please define a "home
profit center".
Response S-59: The age provision is established by the medical consultant that pexfonns the
medical exams (for IT). "45" has been corrected to "35". Reference to "home profit center"
has been deleted.
Comment S-60: Page 4-27, Section 4.11 -The Health and Safety Plan should include
injury for persons other than employees, for example, visitors from state or county or
press.
Response S-60: Corrected.
Comment G-7: The RD/Performance Monitoring Work Plan had numerous typographi-
cal and grammatical errors, and some of the figures were of poor quality. In addition,
there is some concern about the technical adequacy of the proposed sampling design to
provide a sufficient statistical evaluation of the effectiveness of natural soil flushing.
Based on the size of OU2, it seems that five borings with three soil samples each is not
adequate enough to characterize the effectiveness of the natural soil flushing. In the
previous RI, ten soil borings with three soil samples each were collected. The Record of
Decision for OU2 (ROD) specifies monitoring of soils on a quarterly basis rather than
the annual basis proposed in the Work Plan.
Response G-7: The errors have been corrected and figures revised. The revised Work Plan
reflects groundwater monitoring only (see Response R-14, and Chapter 3.0, and the Field
Sampling Plan, Appendix A).
Comment S-61: Section 1.4, Page 1-14, Second Paragraph -Where is Table 1-5?
Response S-61: This sentence has been deleted.
Comment S-62: Section 2.2, Page 2-1, First Paragraph -The sampling procedure
proposed does not appear to provide a statistically reproducible evaluation for compar-
ing the year to year data. It would seem more reasonable to perform the first year's
borings in locations where the data can be reasonably compared to the original RI data.
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It would seem more reproducible to collect the soil sample from the full length of the
split spoon or at least from an interval within the spoon which can be reproduced in the
next sampling event in ·the same area.
Response S-62: The revised Work Plan reflects groundwater monitoring only (see Response
R-14 and Chapter 3.0).
Comment S-63: Table 2-1. Page 2-6 -Water samples for volatile organic analysis
require preservation with hydrochloric acid.
Response S-63: Information from Table 2-1 has been incorporated into the Field Sampling
Plan, Appendix A. Sample preservation is addressed in Section A.3.2.
Comment S-64: Table 3a, Page 3-9 -The Contract Required Quantitation Limit for
bromoform for multimedia and low or medium concentration is 10 µg/L for aqueous and
10 µg/Kg for soils.
Response S-64: Table 3a has been replaced with Table B-3-1, which lists TCL Contract
Required Quantitation Limits for volatiles only. Bromoform is not included.
Comment S-65: Table 3d, Page 3-14 -In the heading of this table it should specify that
the Contract Required Detection Limits are for aqueous media and low or medium
concentration samples.
Response S-65: The revised Work Plan only addresses TCL volatile organics; therefore, this
table has been deleted.
Comment S-66: Section 3.4. Page 3-16, Four Paragraph -The description of the
decontamination procedures provided on page 3-19 is adequate and more appropriate.
Response S-66: All decontamination procedures have been moved to the Field Sampling
Plan, Appendix A. Groundwater samples will be collected with dedicated bailers.
Comment S-67: Figure 3-2. Page 3-17 -Included in the Field Logbook or in the Field
Activity Daily Log should be a clear description of the sample location and the interval
where it was collected from as described in Comment 2 (IT Comment S-62) above.
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Response S-67: Text has been revised to include sample description (Section B.4, Appendix
B).
Comment S-68: Figure 3-5 -The Sample Label shown does not have a place for
entering the sampling time.
Response S-68: Figure 3-5 has been replaced with Figure B-5-2 (Section B.5.2, Appendix
B), which contains the sampling time.
Comment S-69: Section 3.8, Page 3-29 -Who is responsible for performing the data
validation and does the ITAS QA Manual reference the CLP SOW? Will the Data
Report be submitted with appropriate data qualifiers.
Response S-69: IT' s Field Analytical Services, an organization independent of the IT
Analytical Services (laboratory), will perform the data validation. The data repon will
include appropriate data qualifiers.
Comment S-70: Section 3.9.2.1, Page 3-31, First Sentence -Please clarify this sentence.
Does this mean that there may be an additional sampling event?
Response S-70: Sentence has been deleted.
Comment S-71: Section 4.3.1, Page 4-6, First Paragraph -Correct spelling on 1,2-dichloroethane (and) 2-butanone.
Response S-71: Corrected.
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Responses to State of North Carolina Comments (1/14/92)
on the Remedial Design/Performance Monitoring Work Plan
National Starch and Chemical Company
Operable Unit 2
General Comments
Comment NC-1: Page 1-13, Section 1.4 -Editorially, the first sentence in the section is
not clear. We suggest it be changed to read, "The activities described in the SAP will be
conducted annually. Field sampling will take place in the first two weeks of June each
year."
Response NC-1: Text has been revised (see Chapter 4.0).
Comment NC-2: Page 2-1, Section 2.2 -How were the number and locations of the
proposed 1992 borings chosen. How will future boring locations be chosen? Rationale
for the answers to both of these questions should be presented in the Work Plan. Also,
from the procedure described in the SAP, a total of 15 subsurface soil samples will be
taken and analyzed each year. This fact should be explicitly stated somewhere in the
SAP.
Response NC-2: The revised Work Plan reflects groundwater monitoring only. Sampling
rationale is presented in Chapter 3.0 and the Field Sampling Plan, Appendix A.
Comment NC-3: Page 2-4, Table 2-2; and Page 2-7, Table 2-1 -These tables appear to
be mislabeled in that Table 2-2 appears before 2-1. Also, the last column of both tables
would be more properly titled, "Maximum Allowable Holding Time".
Response NC-3: This section has been revised. See Field Sampling Plan, Appendix A.
Comment NC-4: Sections 2 and 3 -Throughout these sections the word "aliquot" is
used to describe the samples taken from the split spoon or sample material in the
sample container. This seems to us to be a confusing misnomer in that "aliquot" implies
an exact or measured amount of material. Unless we are misunderstanding the SAP, the
sample material described is not a measured amount. We suggest this be changed to
avoid confusion.
Response NC-4: See Response S-27.
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Table of Contents'-----------------
List of Tables
List of Figures
List of Acronyms
1.0 Introduction
1. 1 Administrative History
1.2 Work Plan Organization
2.0 Site Location and Background
2.1 Site Location and Description
2.1.1 Topography
2.1.2 Hydrology and Hydrogeology
2.2 Site Background
2.3 Summary of Supplemental Remedial Investigation of the Second
Operable Unit
2.4 Summary of Risk Characterization for the Trench Area
3.0 Performance Monitoring Approach/Data Quality Objectives
3.1 General
3.2 Performance Monitoring Approach
3.3 Data Quality Objectives
4.0 Project Schedule and Submittals
4.1 Project Schedule
4.2 Submittals
4.2.1 Progress Reports
4.2.2 Final Actin Report
4.2.3 U.S. EPA Review
4.3 Deed Restriction
5.0 References
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Table of Contents, ________________ _
List of Tables
List of Figures
List of Acronyms
1.0 Introduction
I. 1 Administrative History
1.2 Work Plan Organization
2.0 Site Location and Background
2.1 Site Location and Description
2.1.1 Topography
2.1.2 Hydrology and Hydrogeology
2.2 Site Background
2.3 Summary of Supplemental Remedial Investigation of the Second
Operable Unit
2.4 Summary of Risk Characterization for the Trench Area
3.0 Performance Monitoring Approach/Data Quality Objectives
3.1 General
3.2 Performance Monitoring Approach
3.3 Data Quality Objectives
4.0 Project Schedule and Submittals
4.1 Project Schedule
4.2 Submittals
4.2.1 Progress Reports
4.2.2 Final Actin Report
4.2.3 U.S. EPA Review
4.3 Deed Restriction
5.0 References
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Table of Contents (Continued) ______________ _
Appendix A -Field Sampling Plan
Appendix B -Quality Assurance Project Plan
Appendix C -Analytical Data from the Supplemental RI Report
Appendix D -Risk Characterization Report
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List of Tables, _________________ _
Table Title Follows Page
3-1 Groundwater Cleanup Criteria 3-3
4-1 Project Schedule 4-1
List of Figures, _________________ _
Figure
2-1
2-2
2-3
Title
Site Location Map
Site Map
Soil Sample Locations, Supplemental RI, 1989
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List of Acronyms, ________________ _
ARAR
CERCLA
CLP
DCA
DHS
DQO
FSP
HSP
IT
ms!
NCP
NPDES
NPL
NSCC
OU!
OU2
OU3
POTW
ppb
PRE
PRG
QAPP
RD/RA
RVFS
ROD
sow
TAL
TCL
TCLP
U.S. EPA
UAO
voe
applicable or relevant and appropriate requirement
Comprehensive Environmental Response, Compensation, and Liability Act
Contract Laboratory Program
dichloroethane
Division of Health Services
data quality objectives
Field Sampling Plan
Health and Safety Plan
IT Corporation
mean sea level
National Oil and Hazardous Substance Pollution Contingency Plan
National Pollutant Discharge Elimination System
National Priority List
National Starch and Chemical Company
Operable Unit 1
Operable Unit 2
Operable Unit 3
Publicly Owned Treatment Works
pans per billion
preliminary risk evaluation
Preliminary Remediation Goals
Quality Assurance Project Plan
Remedial Design/Remedial Action
Remedial Investigation/Feasibility Study
Record of Decision
Scope of Work
Target Analyte List
Target Compound List
Toxicity Characteristic Leaching Procedure
U.S. Environmental Protection Agency
Unilateral Administrative Order
volatile organic compound
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1.0 Introduction
This Work Plan was prepared as a requirement of the Consent Decree (U.S.A., 1991) and the
Scope of Work (SOW) (U.S. Environmental Protection Agency [U.S. EPA], 1991) for the
Remedial Design/Remedial Action (RD/RA) at the National Starch and Chemical Company
· (NSCC) site, Operable Unit 2 (OU2). The SOW is designed to provide a framework for
conducting the RD/RA at this site and is the technical portion of the Consent Decree. Task II
of the SOW specifies that a work plan be prepared and implemented and provide the
technical details for implementation of the response actions. Task IV of the SOW specifies
that performance monitoring be conducted to ensure that the site objectives for the remedy are
met. This Work Plan addresses the planning requirements for both Tasks II and IV.
The purpose of the RD/RA is to carry out the necessary response actions to complete the
selected remedy and, therefore, ensure protection of human health and the environment. The
U.S. EPA has selected no (further) action as the remedy for the OU2.
1. 1 Administrative History
The U.S. EPA proposed the NSCC site for inclusion on the National Priority List (NPL) in
April 1985, under the authority of the Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA), better known as Superfund. The site was officially placed
on the NPL on October 4, 1989 and ranked 257.
NSCC retained IT Corporation (IT) as their environmental consultant in 1984 and directed IT
to perform the Remedial Investigation/Feasibility Study (RI/FS) in accordance with an
Administrative Order of Consent (U.S. EPA, 1986). IT completed the RI on June 21, 1988
(IT, 1988a) and the FS on September 8, 1988 (IT, 1988b).
Based on the RI/FS, the U.S. EPA issued the Record of Decision (ROD) (U.S. EPA, 1988)
for the site on September 30, 1988. The ROD divided the site into two operable units. The
first operable unit (OU!) consists of contaminated groundwater and OU2 consists of trench
area soils. The selected remedy in the ROD for OUl includes a groundwater interception and
extraction system installed downgradient of the disposal area that will effectively contain and
remediate the contaminated groundwater. The extracted groundwater will then undergo
pretreatment and discharge to the City of Salisbury Publicly Owned Treatment Works
(POTW). The ROD specified that soil contamination in the trench area be further
K.N/WP645.l/02-1 l-91.JD6 1-1
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investigated to determine whether the area continued to be a major source of groundwater
contamination.
In accordance with the OUl ROD, IT performed a Supplemental RI/FS for OU2 and
completed it in May 1990 (IT, 1990a). The U.S. EPA issued the ROD for OU2 on
September 30, 1990 (U.S. EPA, 1990). For the trench area soils, no further action is the
selected remedy because contaminants from these soils are released into the contaminated
groundwater aquifer, which will then undergo remediation in accordance with the OUl ROD.
1.2 Work Plan Organization
Chapter 1.0 provides an introduction and administrative history of how OU2 was created.
Chapter 2.0 of this Work Plan presents the site background. Chapter 3.0 presents the
performance monitoring approach and data quality objectives (DQOs). Chapter 4.0 presents
the project schedule and submittals. Chapter 5.0 contains the references.
The appendices provide the supporting documents required to complete the field activities.
Appendix A (Field Sampling Plan [FSP]) presents the specific activities planned to conduct
performance monitoring. Appendix B (Quality Assurance Project Plan [QAPP]) provides the
procedures that will be undertaken to ensure the precision, accuracy, and completeness of the
data gathered. The FSP and QAPP make up the sampling and analysis plan for the field
operations. Appendix C contains analytical data from the Supplemental RI Report. Appendix
D contains a Risk Characterization Report for the trench area surface soils.
A Health and Safety Plan (HSP) prepared by IT (IT, 1992) is contained under separate cover
and supplements this Work Plan. The HSP describes the procedures to be followed to
provide a safe and healthy work enviomment.
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2.0 Site Location and Background
2. 1 Site Location and Description
The NSCC site is located in Rowan County, North Carolina, approximately 5 miles south of
the City of Salisbury (Figure 2-1). Salisbury is located approximately 40 miles northeast of
Charlotte, North Carolina.
The NSCC site, also referred to as the Cedar Springs Road Plant, is approximately 500 acres
in size. The chemical plant is located in the southeastern portion of the property. The
disposal area, known as the trench area, is located southwest of the plant operations and is
surrounded by heavily wooded acreage to the north, west, and south (Figure 2-2).
Presently, land use of the areas immediately adjacent to the site is a mixture of residential and
industrial developments. As shown in the RI Report (IT, 1988a), on the east and south sides
of the site, opposite of Cedar Springs Road, is an industrial park consisting primarily of light
industrial operations. Grants Creek forms the western boundary of the site. The Southmark
Industrial Park is located along the southern property line. The Little Acres Mobile Home
Subdivision adjoins the extreme southwestern comer of the site. A housing development,
Kings Forest, is adjacent to the north side of the site. The site actually forms the east, west,
and south boundaries of the development, and although the site is adjacent to the backyards of
a number of homes in the development, the nearest home is approximately 1,700 feet from
the trench area. A second development, Stonybrook, lies across Airport Road on the northern
side of the site.
As of the signature date of the ROD for OU2, there was no designated North Carolina State
Significant Habitat, agricultural land, or historic landmark site potentially or directly affected
by the NSCC site. There were no endangered species or critical habitats near the NSCC site.
There were no identified coastal or freshwater wetlands within an area of influence of the
NSCC site.
2.1.1 Topography and Geology
Rowan County is located within the Piedmont Physiographic Province of North America.
The NSCC property is located in the center of Rowan County. The terrain follows the
general trend exhibited in the Piedmont, sloping from the mountains in the west, eastward
toward the coastal plain. Elevations in the county range from nearly 800 feet above mean
seal level (ms!) in the west to 650 feet above ms! in the east.
KN,WP645.2'02-l l-91.JD7 2-1
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FIGURE 2-1
SITE LOCATION MAP
NAnONAL STARCH
AND CHEMICAL COMPANY
SALISBURY, NC
[i] IIIT!:RNATIONAL TECHNOLOGY CORPORA'IION
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FIGURE 2-2
SITE MAP __,,_--
..... [i] INTERNATIONAL
TECHNOLOGY
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400 FEET
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The topography of the area surrounding the site consists of gently sloping uplands, intercut by
several small tributaries of Grants Creek. In the immediate vicinity of the NSCC plant,
elevations range from approximately 790 feet above ms! at the trench area and fall away to
roughly 700 feet above msl to the north and west. The trench area is located to the west and
just over a ridge from the manufacturing plant. Dense woods border the trench area on the
northern, western, and southwestern sides.
The geologic structure of Rowan County comprises two major geologic units. The first unit
is igneous rocks that consist principally of granite and diorite. The second unit consists of
metavolcanic rocks, which are a part of the so-called Carolina Slate Belt. The metavolcanic
rocks occupy approximately 15 percent of the county and are located within the southeastern
quadrant. The remaining portion of the county, including the NSCC site, consists of igneous
rocks.
The soil above the crystalline bedrock consists of a sandy clay to clayey saprolite, which
varies from a few feet to tens of feet in thickness over the bedrock. Saprolite is a clay-rich
material that has undergone in situ chemical weathering without any erosional transport.
Bedrock borings obtained during the RI/FS field investigation for OUJ were described as
being grano-diorite. Depths to bedrock across the NSCC facility range from 37 to 66 feet.
As is typical of crystalline bedrock, the fracture concentrations significantly decrease with
depth.
2. 1.2 Hydrology and Hydrogeology
The climate for the Piedmont area of North Carolina is characterized by mild winters and
humid summers. The average annual precipitation of 45.28 inches is fairly evenly distributed
throughout the year with the summer months of June, July and August being the period of
greatest rainfall.
Grants Creek delineates the westernmost property line and flows in a northeasterly direction.
Grants Creek flows approximately 12 miles beyond the NSCC property before reaching the
Yadkin River. Three unnamed tributaries of Grants Creek traverse the NSCC site. The first
stream passes within 200 yards of the front of the plant (the northeast tributary), paralleling
Cedar Springs Road, and leaves the property to the north. The second stream, known as the
southwest tributary, follows the property boundary from the Southmark Industrial Park to
Grants Creek. The third small stream is positioned in the northwest quadrant of the property.
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The hydrogeologic framework at the site consists of two aquifers with distinctly different flow
characteristics. The uppermost aquifer lies within the clay rich saprolite and the deeper
aquifer within the crystalline bedrock. These two aquifers are interconnected, but because of
the hydrogeologic characteristics of the bedrock, the deeper aquifer produces a higher yield,
averaging 40 to 50 gallons per minute, whereas wells in the saprolite yield 3 to 5 gallons per
minute.
2.2 Site Background
Beginning in September 1968, Proctor Chemical Company purchased 465 acres along Cedar
Springs Road. Within the next year, Proctor Chemical was acquired by NSCC. Construction
of the Cedar Springs Road plant began in 1970. The NSCC facility is primarily a manufac-
turing plant for textile-finishing chemicals and custom specialty chemicals. Production takes
place on a batch basis and varies depending upon demand.
From 1971 to 1978, NSCC pumped reaction vessel wash waters from holding lagoons into
trenches within a 5-acre tract of land located behind the plant known as the "trench area"
(Figure 2-2). The wash waters were disposed of in several trenches approximately 200 to
300 feet long and 10 feet deep. Some trenches ran east to west, and others north to south.
Approximately 350,000 gallons of the reaction vessel wash waters (consisting predominantly
of salt brine and sulfuric acid solutions) were disposed of in accordance with the standard
operating procedure for this time period. The wash waters also included trace amounts, based
on water solubilities, of sulfonating fats, oils, and solvents. Each trench was used until liquid
no longer readily percolated into the ground. The trench was then backfilled and seeded
followed by construction of a new trench. In 1976, NSCC installed eight monitoring wells
around the site to determine if the trenching operations had impacted groundwater quality.
Four of these monitoring wells were installed adjacent to or within the trench area. Analyti-
cal results from the sampling revealed that shallow groundwater immediately within and
adjacent to the trench area was contaminated.
In June 1977, sampling and analysis conducted by the State of North Carolina verified
NSCC's data. The state subsequently requested that NSCC stop disposing of waste in the
trench area, and in I 978, the City of Salisbury and NSCC mutually agreed to connect
NSCC's wastewater lagoons to a sewer interceptor line that was under construction along
NSCC's southwestern boundary; therefore, since 1978 the production plant process waters
have been directed to a pretreatment facility located adjacent to and south of the production
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area. The waste stream is directed through equalization and settling lagoons with surface
aeration prior to controlled discharge to the City of Salisbury P01W.
Numerous studies and reports were generated prior to the RI. These reports are summarized
in the RI Report (IT, 1988a). Currently the OUI groundwater RD/RA is being performed in
accordance with the U.S. EPA Unilateral Administrative Order (UAO) effective July 27,
1989.
2.3 Summary of Supplemental Remedial Investigation of the Second Operable Unit
The Supplemental RI consisted of collecting samples from ten soil borings drilled from the
surface to 30 feet or to the saturated zone, whichever was encountered first in the trench area
(Figure 2-3). Field screening was conducted in the final selection of the samples submitted
for laboratory analysis. Toxicity Characteristic Leaching Procedure (TCLP) analyses were
also conducted on several borehole samples using a standard and a rainwater solution
(collection on site) to determine certain site-specific leachability characteristics of the soils.
The Supplemental RI was designed to measure the effectiveness of the natural soil flushing
by percolating rainfall through the soil contaminants as well as determining the actual
contaminant concentrations remaining in the trench area subsurface soils. Results of the
Supplemental RI indicate that the natural leaching process has resulted in reducing the levels
of the soils contamination. This is based on the magnitude of the contamination currently in
the groundwater compared to the residual levels of contamination left in the soil. Several of
the contaminants of concern identified in the first ROD in 1988 were not detected within the
trench area soils during the supplemental field work in 1990.
The Supplemental RI presented contamination transport modeling to evaluate the effectiveness
of the natural soil flushing during the groundwater remediation effort. Contaminants in the
trench area subsurface soil were predicted to leach over time by infiltrating rainwater. The
leachate will then become captured by the groundwater extraction system and treated in the
on-site pretreatment system, so that the applicable or relevant and appropriate requirements
(ARAR) will be satisfied. Most of the organic contaminants were predicted to take 5 years to
leach into the groundwater before a safe level is reached in the soil that would not result in
future impacts on groundwater. Predictions are that 1,2-dichloroethane (DCA) will take 22
years to leach into the groundwater before a safe level is reached in the soil.
KN/WP64S.7,<l2-ll-92/D7 2-4
I I .., 0 N "' I 0 < " I .; "' <O <O <O <O "' "' 0 0 ... ... 0 0 z z ~ -; 0 0: 0 Q_ ;: z < > w >-0 0: _, F' < w ;I :i: U1 vi '" 0 ::, ,-< -; ,= 0 ~ 0: Q_ 0 " w >-:i: " _, < < w Q_ :i: c,; U> :i' vi CD :i' :,: CD " "' :i: " " :i: " >-' e; I,. < 0: z 0 w ;;,; w 0: ,-:i' !i1 CD _, i I!! < < 0: 0 0 N "' ' "' ~ ~ _, 5 l:l •• CD I!! < 0 " z ,= ~ U1 3i :i' CD i < 25 ,-'; E Jr ... .;; N .g:_ "' ~ N 0 .., N "' <O <O ~ 0 0 0 ,,,. "' I 0 /:: \ \) LTR1ELINE \ I 8H-07Cil LEGEND: Ciil 1989 SOIL BORING SITE SCALE: -----N H ~ ?so ,,/' 0 ~ ./ 0 __,--./ ------CC! ,,,-----------i I GAIN PLANT l,J \ OPERATIONS \ AREA ,...l FIGURE 2-3 \\ \\ \\ TANKS 1 \--+,' __ _ ./ SOIL SAMPLE LOCATIONS, SUPPLEMENTAL RI, 1989 NA noNAL STARCH AND CHEMICAL COMPANY SALISBURY, NC ID INTERNATIONAL TECHNOLOGY CORPORATION ~ I O 200 400 FEET I
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Results from the supplemental RI Target Compound List (TCL) organic analysis showed the
trench area solids to be contaminated with organics, especially 1,2-DCA. The TCLP analysis
(organics) also showed DCA, while there was virtually no difference between TCLP standard
and rainwater tests. Other compounds detected included 2-butanone, 1,2-dichloropropane, 4-
methyl-2-pentanone, toluene, ethyl benzene, and total xylenes. Common laboratory contami-
nants methylene chloride, acetone, and bis(2-ethylhexyl)phthalate were detected in the
laboratory and field blanks. Results for TCL and TCLP organics are shown in Appendix C.
The supplemental RI Target Analyte List (T AL) inorganic analysis results showed that the
soil within the trench area is representative of background conditions. This also included
extractable concentrations of inorganics from the TCLP tests. When TCLP analytical data
tests are compared to water cleanup criteria, the inorganic concentrations are much lower than
the cleanup criteria. Results for T AL and TCLP inorganics are shown in Appendix C. Based
on these two comparisons, the inorganics in the trench area soils are not considered contami-
nants and will not be addressed under the OU2 performance monitoring task.
Groundwater contamination from the leaching chemicals in the soils will be remediated
through extraction wells placed in the area to contain and remove the contaminated plume by
the first operable unit RD/RA. The subsurface soil contamination has been observed from 5
feet below land surface down to the water table. Maximum concentrations of organic
contaminants were encountered 18 feet below the surface of the trench area.
2.4 Summary of Risk Characterization for the Trench Area
A risk characterization of the trench area surface soils was prompted by U.S. EPA's review of
the OU2 ROD. U.S. EPA determined that additional characterization of the soil exposure
pathway was required.
Upon U.S. EPA's approval of a surface soil sampling plan in May 1991, IT collected six
surface soil samples from the trench area in June 1991. The locations of the samples are
contained in the Risk Characterization Report (Appendix D). The samples were analyzed for
the TCL volatile and semivolatile compounds. The results of this investigation also satisfy
the SOW Task I requirements for further investigation of the trench area soils.
The risk assessment determined the current risks associated with potential direct human
exposure to the trench area surface soils. The risk assessment established a list of chemicals
KN/WP645.2.tU2-l 1·92/1)7 2-5
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of concern, evaluated human exposures to chemicals and toxic characteristics of the chemi-
cals, and provided a quantified human health risk associated with current site conditions.
After performing appropriate screening of the TCL organics found in the soil samples, the
chemicals of concern were acetone, 2-butanone, benzoic acid, and bis(2-ethylhexyl)phthalate.
The semivolatile bis(2-ethylhexyl)phthalate, which is considered a common laboratory
contaminant, was present with the highest concentrations reaching 6,900 µg/kg (parts per
billion [ppbl).
Based on the exposure pathways analyzed, the risk characterization indicated that the
concentrations of the organics found in the surface soils do not pose a substantial health risk
to workers in the trench area.
KN/WP645.2J02-l I •tn/07 2-6
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3.0 Performance Monitoring Approach/Data Quality
Objectives
3.1 General
Results of past investigations of the trench area have confirmed soil contamination; therefore,
this area was designated as the second operable unit in the first operable unit ROD (U.S.
EPA, 1988). The OU2 ROD specifies that no (further) action is the selected remedy for the
soils in the trench area.
The no-action remedy is protective of human health and the environment based upon the
following (U.S. EPA, 1988):
• The OU! ROD presents the groundwater remedy (pump and treat) that mitigates the
principle threat posed by the contaminated groundwater at the site. The only route of
migration for the trench area soils would be into the contaminated groundwater.
• The natural precipitation and infiltration will work with the selected groundwater
remedy to effectively flush residual soil contamination into the groundwater action
zone.
• No public health threats exist directly from the trench area soils. The remedy for the
potential exposure from groundwater has been addressed in the OUl ROD.
The OU2 ROD specifies that monitoring of the trench area soils must be conducted to verify
that no unacceptable exposures to risks posed by conditions at the site occur in the future.
Therefore, the primary objective of this Work Plan is to implement a performance monitoring
program that will verify that the trench area soils do not pose (future) unacceptable exposures
to risks.
3.2 Performance Monitoring Approach
Performance monitoring will consist of periodic sampling of the groundwater. This will be
achieved by collecting groundwater samples from eight wells located within and adjacent to
the trench area. Four of these wells will be existing groundwater monitoring wells NS09,
NSI0, NSll, and NS!S. The remaining four wells will be the new groundwater extraction
wells EX-6, EX-7, EX-8, and EX-9. The extraction wells are an integral part of the OUl
remedial action. They will be installed under Phase II of OU I RA, scheduled 9 months after
startup of Phase I (plume periphery extraction wells). All eight wells were chosen for OU2
KN/WP651.3,m..J t-92JD4 3-1
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performance monitoring based upon U.S. EPA's request (IT telecon, 1992). The locations of
the eight wells as well as sampling procedures and methods are provided in the FSP,
Appendix A.
The trench area soils will not be monitored. The approach of exclusive groundwater
monitoring is based on the following:
• There is presently no technologically implementable soil sampling method that can
accurately characterize the effectiveness of natural soil flushing/degradation.
Placement of conventional soil borings would not provide a reproducible evaluation
for comparing data from one sampling event to the next. Also, even though monitor-
ing soil gas is a possible monitoring alternative, concentrations of contaminants
found in soil gas cannot be directly compared to concentrations in soil.
• Monitoring the groundwater will achieve the primary objective of verifying that the
trench area soils will not pose future unacceptable exposures to risks because the
only exposure route of contamination to the trench soils is via the underlying
groundwater.
The locations of the eight wells, as well as the sampling procedures, and the methods are
described in the FSP, Appendix A. Essentially, a groundwater sample will be collected
quarterly from each of the eight wells for the first 2 years and then on a 5-year frequency
starting on the fifth year from Work Plan approval. Water quality data generated during the
OU I RA may be used for the OU2 performance monitoring task to maintain efficiency in the
overall performance monitoring tasks for both OU I and OU2.
3.3 Data Quality Objectives
DQOs are qualitative and quantitative statements that specify the quality of the data required
to support decisions during remedial response activities (U.S. EPA, 1987). DQOs are
determined based on the end uses of the data to be collected. The level of detail and data
quality needed vary based on the intended use of the data.
The DQO established for the OU2 RD/RA performance monitoring task is to determine the
levels of TCL volatile organic compounds in the groundwater underlying and adjacent to the
trench area soils in order to monitor the performance of the no-action remedy. The data will
be compared from one sampling event to the next. Periodic sampling will continue until
there is sufficient and acceptable evidence that groundwater is no longer being impacted by
KN/WP651.3,U2-l 1·92./D4 3-2
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contamination in the trench area soils. This may be quantified by one or both of the
following methods:
1) The TCL concentration levels found in the groundwater will be compared to the
cleanup criteria established for OU!, as shown in Table 3-1. When the levels
found in the prescribed monitoring points do not exceed (consistently) the cleanup
levels in Table 3-1, this will indicate that the trench area soils are no longer
impacting groundwater.
2) The TCL concentration levels found in the groundwater will be evaluated by
statistical procedures that are appropriate for comparing groundwater monitoring
data to a fixed (cleanup) standard.
An evaluation of groundwater data obtained over time will be made to aid in estimating the
time required to reach a point of minimal impact from the trench soils.
KN/WP65t.3,m..tt-92/D4 3-3
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Table 3-1
Groundwater Cleanup Criteria
I Compound I
Volatile organics
Acetone
Benzene
Bromodichloromethane
Chloroform
1,2-dichloroethane
1, 1-dichloroethylene
1,2-dichloropropane
Ethyl benzene
Methylene chloride
Toluene
1, 1,2-trichloroethane
Trichloroethylene
Vinyl chloride
Xylenes
Semlvolatlle organics'
Bis(2-ch loroethyl)ether
4-Nttrophenol
lnorganlcs"
Arsenic
Barium
Beryllium
Cadmium
Chromium
Manganese
Nickel
Selenium
Zinc
'ppb = parts per billion.
'Included only for completeness. Not applicable for this Work Plan.
Reference source: U.S. EPA, 1988, p.19.
KN/WP651.3A/02· 10-92/02
Cleanup Concentration (ppb)"
3,500
5
5
5
5
7
6
3,500
5
2,000
5
5
2
350
5
350
10
1,000
17.5
10
50
7,700
350
10
7,350
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4.0 Project Schedule and Submitta/s. ________ _
4. 1 Project Schedule
Upon receiving U.S. EPA's final approval of this Work Plan and final review of the HSP (under
separate cover), the performance monitoring activities as prescribed in this Work Plan will begin
in July 1992. Sampling of the selected groundwater monitoring wells and extraction wells will
begin in July 1992 and continue on a quarterly basis for 2 years (to July 1994). Subsequent
sampling will continue on 5-year intervals, starting on the fifth year from Work Plan approval.
The project schedule is presented in Table 4-1.
4.2 Submittals
4.2. 1 Progress Reports
NSCC will submit periodic progress reports to U.S. EPA that document the progress of the OU2
response action. A combined progress and sampling report will be submitted quarterly for the
first two years of performance monitoring. Monitoring/reporting will then continue on 5-year
intervals. The monthly reporting requirements specified in the OU2 Consent Decree will be
incorporated into the OU2 progress/sampling reports. Reporting of the progress of RA for OU2
will be combined with performance monitoring reporting for the OUl RA. This submittal
schedule follows the sampling/analysis approach presented in Chapter 3.0 and the FSP, Appendix
A.
In general, the progress/sampling reports will contain a synopsis of the sampling event, the
groundwater analytical data (certificates of analysis), an evaluation of the data, and a discussion
of any problems encountered during the period. A general outline of the report will be as
follows:
• Introduction
• Description of Sampling Event
• Data Summary
• Conclusions and /or Recommendation
• Certificates of Analysis.
4.2.2 Final Action Report
NSCC will submit to U.S. EPA a Final Action Report to comply with Task III of the OU2 SOW.
The report will be submitted before the completion of the RA for OU2. The report provides
certification that all items contained in the Consent Decree, the ROD, and the SOW and all
KN/WP65l.4/02-11·91.JD2 4-1
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I Activity
Quarterly Groundwater Sampling/Analysis
First Quarter, July -September, 1992
Second Quarter, October -December, 1992
Third Quarter, January -March, 1993
Fourth Quarter, April -June, 1993
Fifth Quarter -July -September, 1993
Sixth Quarter -October -December, 1993
Seventh Quarter -January -March, 1994
Eighth Quarter -April -June, 1994
Five-Year Sampling/Analysis
July 1997
July 2002
July 2007
July 2012
Prepare Final Action Report
Table 4-1
Project Schedule
I Submittal/Date
Progress/Quarterly Sampling Report, September 1992
Progress/Quarterly Sampling Report, December 1992
Progress/Quarterly Sampling Report, March 1993
Progress/Quarterly Sampling Report, June 1993
Progress/Quarterly Sampling Report, September 1993
Progress/Quarterly Sampling Report, December 1993
Progress/Quarterly Sampling Report, March 1994
Progress/Quarterly Sampling Report, June 1994
Progress/Quarterly Sampling Report, July 1997
Progress/Quarterly Sampling Report, July 2002
Progress/Quarterly Sampling Report, July 2007
Progress/Quarterly Sampling Report, July 2012
Final Action Report"
"Submittal date to be determined based upon progress of OU2 RA.
KN/WP541 .4A/02· 11-92/00
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incorporated documents (Work Plan, HSP, etc.) have been completed. The Final Action Report
will include:
• A synopsis of the work defined in the SOW
• An explanation of modifications, if any, made to the original Work Plan during the
response actions.
After a review of the Final Action Report submitted by NSCC to U.S. EPA, NSCC shall address
any comments and submit a revised report. The response action for OU2 will be completed upon
U.S. EPA approval of the Final Action Report.
4.2.3 U.S. EPA Review
A 5-year review will be conducted by U.S. EPA to ensure that contaminant residual levels are
being reduced by the leaching remedy and will meet the goals to protect human health and the
environment. The 5-year review shall start on the day that the Work Plan is approved. U.S.
EPA conclusions from this review shall be submitted in a report by the first of December of the I fifth calendar year. Changes in the Work Plan or SAP to address current data or achievable goals
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may be addressed at this time. Any changes to the Work Plan must be submitted to U.S. EPA
for approval by the first of March of the next or sixth calendar year. Any U.S. EPA comment
changes to the Work Plan shall be submitted within 30 days of receipt. A Work Plan
encompassing the U.S. EPA comments shall be resubmitted to the U.S. EPA within 30 days of
receipt. U.S. EPA approval of changes to the Work Plan shall be granted or disapproved by May
15 of that calendar year.
4.3 Deed Restriction
NSCC will prepare a deed restriction that will identify the trench disposal area as an area of
contamination. This is a requirement of the OU2 ROD. The deed restriction will prevent
property transfers to uninformed purchasers and will limit further utilization of the property. The
deed restriction will be implemented by processing the restriction through an attorney selected
by NSCC. The restriction will be filed through the Rowan County Register of Deeds, Salisbury,
North Carolina.
The deed restriction is not a required submittal but will be made available to U.S. EPA upon
request. The restriction is scheduled to be completed by December 1992.
KN/WP6Sl.4i02-l I-91.JD2 4-2
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5.0 References
IT Corporation, 1992, National Starch and Chemical Company, Second Operable Unit,
Remedial Design/Performance Monitoring Health and Safety Plan.
IT Corporation, 1990a, "Final Supplemental Remedial Investigation Report for the Second
Operable Unit, National Starch and Chemical Company Site."
IT Corporation, 1988a, "Remedial Investigation Report, National Starch and Chemical
Corporation Site," Revision No. 2.
IT Corporation, 1988b, "Feasibility Study Report, National Starch and Chemical Corporation
Site."
U.S. Environmental Protection Agency, 1991, Scope of Work for the Remedial Design and
Remedial Action at the National Starch and Chemical Corporation Site, Operable Unit 2.
U.S. Environmental Protection Agency, 1990, Enforcement, Record of Decision, Remedial
Alternative Selection for National Starch and Chemical Corporation Site, Operable Unit 2.
Prepared by U.S. EPA Region IV, Atlanta, Georgia.
U.S. Environmental Protection Agency, 1988, Enforcement, Record of Decision, Remedial
Alternative Selection for National Starch and Chemical Corporation Site. Prepared by U.S.
EPA Region IV, Atlanta, Georgia.
U.S. Environmental Protection Agency, 1987, "Data Quality Objectives for Remedial
Response Activities." Prepared by the U.S. EPA, Office of Emergency and Remedial
Response and Office of Waste Programs Enforcement, Washington, D.C., EPA 540/G-8/003,
OSWER Directive 9355.0-7B.
U.S. Environmental Protection Agency, 1986, Administrative Consent Order No. 87-01-C for
National Starch and Chemical Corporation Site, U.S. District Court.
U.S.A, 1991, Consent Decree, United States District Court for the Western District of North
Carolina, Charlotte Division.
KN/WP651.5,U2-11·92/Dl 5-1
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APPENDIX A I FIELD SAMPLING PLAN
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A.1.0 lntroductio ._ ______________ _
As a result of the findings of a Remedial Investigation (RD conducted in 1987 (IT, 1988), and
a Supplemental RI conducted in 1989 (IT, 1990), the Record of Decision (U.S. EPA, 1988)
has established natural soil flushing (no action) as the preferred remedial action for the second
operable unit (OU2). This Field Sampling Plan (FSP) combined with the Quality Assurance
Project Plan (QAPP) (Appendix B) comprise the Sampling and Analysis Plan for the OU2
Remedial Action (RA). OU2 was established to address the contamination in soils at the
trench area.
Based on the Supplemental RI leachability studies, natural soil flushing will remove contami-
nants from the soil in approximately 22 years. This RA involves the continual generation of
leachate from the contaminated soil and subsequent recharge to the water table. Concurrent to
the no action alternative for OU2, a groundwater extraction and treatment remedial effort will
be in operation for the first operable unit (OU! RA) and will mitigate any impact of leachate
in groundwater. Performance of the remedial action for both operable units will be monitored
to ensure that contaminant levels found in groundwater are declining. Performance monitor-
ing for the OU! RA will be part of the operational monitoring of the groundwater treatment
system and will not be discussed in detail in this document. Performance monitoring of the
no action alternative will consist of monitoring groundwater from selected monitoring wells in
the trench area and from the trench area extraction wells.
This FSP has been organized to provide guidance for obtaining data from groundwater
monitoring points and the periodic collection of samples. The FSP will address two phases of
monitoring:
• Short-term monitoring (less than 2 years)
• Long-term monitoring (greater than 2 years)
Short-term monitoring will occur quarterly for 2 years and will be reported in progress reports
issued to the U.S. EPA. Long-term monitoring will take place every 5 years in conjunction
with performance monitoring of the OUl RA.
This FSP is intended to serve as a standard operational procedure for the projected 22-year
remediation schedule. Upon approval of the FSP by the U.S. EPA, no changes may be made
to the FSP without prior approval by U.S. EPA and IT Project Managers. U.S. EPA may
initiate modifications to the FSP to resolve issues it has identified. Field sampling activities
KN/'WP65I .FSP.m-11 ·92/DO A-1
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and changes to the planned approaches shall be completely documented as directed by the
QAPP (Appendix B).
A.2.0 Selection of Monitoring Point Locations _____ _
Groundwater under the trench area soils has been investigated as part of the initial RI in
1987, and during the Remedial Design (IT, 1990). As a result of the RI conducted in 1987
(IT, 1988), a ROD was issued in 1988 and established contaminants of concern and cleanup
levels for those contaminants in groundwater (U.S. EPA, 1988). The remedial action selected
for the trench area soils involves the continuous release of leachate by natural soil flushing
into the groundwater. Based on past studies of the trench area soils, volatile organic com-
poundJ (VOe) (1,2-dichloroethane [1,2-DeA], toluene, acetone, etc.) are the most prevalent
contaminants detected; therefore, progress of the RA will be performed by monitoring
concentrations of voes in groundwater at the trench area.
Based on the soil sampling results presented in the Supplemental RI for OU2, it appears that
the area that exhibits the greatest impact by voes is around the central portion of the former
disposal area. For purposes of monitoring the impact of soil contaminants on groundwater in
the trench area, groundwater will be collected from monitoring and extracticn wells listed in
Table A-1. The location of the wells to be sampled is indicated in Figure A-1. In addition to
the samples collected from monitoring wells, samples will be collected from the effluent
stream of each of the extraction wells installed in the trench area as part of the remedial
action for QUI. The location of the trench area extraction wells are also shown in Figure
A-1.
A.3.0 Collection of Groundwater Samples ______ _
Sample collection from monitoring wells will follow the following four step procedure:
• Location preparation and air monitoring
• Well purging
• Groundwater sample collection
• Sample documentation.
Groundwater samples will be collected from the monitoring wells within 24 hours of well
purging. The number of samples to be collected and container types required are shown in
Table A-2. Dedicated bailers are provided at each monitoring well location and will be used
to purge the well as well as to collect the sample. Purge water will be collected and disposed
KN/WP6Sl.FSPm-11-92JDQ A-2
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N N I < I .,
"' "' .,
0 ..
d z
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>-...,
< w :,:
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0 0 w 0 < Q.
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>= w °' ... V, < ...,
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'-' z I=
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"' "' .,
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0 z
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0 °' Q. ...
~ w 0 "' F "' ::;_
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l:l CD
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(iEX-5
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LEGEND:
■ • 0
EX-6(i
(iEX-7
■NS-11
EXISTING SAPROUTE MONITORING WELLS
EXISTING BEDROCK MONITORING WELLS
NEW TRENCH AREA EXTRACTION WELLS
--- -
\...---7so
■NS-02
■NS-04
FIGURE A-1
PROPOSED GROUNDWATER MONITORING
POINTS
NATIONAL STARCH
AND CHEMICAL COMPANY
SALISBURY, NC
[D INTERNATIONAL TECHNOIDGY CORPORATION ..._ _______________________ ... SCALE:
0 200 400 FEET
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of at the on-site groundwater treatment facility. Extraction wells will be sampled by filling
sample bottles directly from the sampling port at each well.
A.3. 1 Preparation and Air Monitoring
Prior to well purging, the sampling location will be prepared by placing a clean sheet of ·
polyethylene plastic around the well. All sampling materials will be placed on the plastic
sheet and will not contact the ground.
Personal protective equipment will be worn by sampling team members, as specified in the
Health and Safety Plan. The level of protection required will depend on the level of
groundwater contamination expected to be encountered, but will consist of Level D as a
minimum. Initially, groundwater contamination levels in some of the wells are expected to be
high enough to require modification of the Level D personal protective clothing. The
sampling team members will wear latex gloves during all sampling events. Upon opening of a
monitoring well, the headspace of the well will be monitored using an Hnu, and if voe
levels are above 1 part per million (ppm), the sample team members shall don modified Level
D protective clothing. Where modification of Level D personal protective clothing is
indicated, sampling team members shall be clothed in polycoated Tyvek™, wear latex inner
gloves, and nitrile outer gloves. Table A-2 lists the wells from which samples are to be
collected and the level of personal protection expected to be required for purging and
sampling.
Air monitoring will be conducted throughout the purging of the monitoring wells. If voe
levels in the breathing zone exceed S ppm, purging must be halted and air purifying respira-
tors must be donned. The cartridges used will conform to the requirements outlined in the
Health and Safety Plan.
A.3.2 Purging
Each well shall be purged prior to collecting samples. Purging clears the well of water that is
not representative of water quality in the aquifer. The purge volume for monitoring wells, or
extraction wells that are not in operation at the time of sampling, will be three to five well
volumes. The water column length will calculated from the measured depth to water and well
depths given in Table A-1 . Depth to water will be measured using a decontaminated elec-
tronic water level indicator.
Water level meters will be decontaminated using a general procedure as follows:
KN/WP6Sl .FSP.K>2• l I ·92/DO A-3
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•
•
•
•
Wash with nonphosphatic detergent and tap water
Rinse twice with organic-free deionized water
Rinse with pesticide grade isopropyl alcohol
Air dry .
The monitoring wells that will be sampled as part of the no action performance monitoring
program will be purged by the method indicated in Table A-1. Dedicated bailers and new
nylon rope will be used when purging and sampling by bailer. Purge water will be collected
and disposed of through the water treatment facil:ty.
Monitoring Wells. Purge volume will lie calculated in the field. The depth to water will
be measured using a decontaminated water level meter, and the purge volume computed using
the following equation. Monitoring well NS-15 has a dedicated bladder pump and inflatable
packer above the screened interval, thus the purge volume for that well will be 27 gallons.
[(Well Depth -Depth to Water) x 0.95 (gaVft)] x 5.0 = Purge Volume (gal)
Extraction Wells. Any extraction well that is operating when the sampling event is started
will not require purging; however, the sampling team shall allow a minimum of 3 gallons of
groundwater to flow through the sampling port before sample collection to en~ure that
stagnate groundwater has been removed from the sampling access port and piping. If any
extraction well is not operating at the time of sampling, the depth to water level will be
measured and the purge volume calculated using the following equation. The pump will then
be started and the discharge will be monitored until the required volume has been purged and
a sample drawn.
[Well Depth -Depth to Water) x 2.73 (gal/ft)] x 5 = Purge Volume (gal)
A.3.2 Sampling
Groundwater will be sampled using either a dedicated Teflon® bailer, or new teflon tubing
attached to the sampling port. If, for any reason, nondedicated bailers are used, the bailer
will be decontaminated before and after each use as outlined in Section A.3.1. If sampling
equipment used is nondedicated, one rinsate sample will be collected per sampling day from
the decontaminated sampler. The rinsate sample will be collected by pouring a sufficient
volume of organic-free deionized water into the decontaminated bailer and filling sample
bottles directly from the bailer as would be done to collect a groundwater sample.
KN/WP651.FSPi{l2-J 1-92/00 A-4
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Table A-1
Performance Monitoring Wells,
Level of Personal Protection, Well Depth,
and Purge Methods to be Used During Sampling
DEPTH TO
PERSONAL BASE PURGE
WELL PROTECTION OF WELL METHOD
NS-09 MODIFIED 45 BAIL
LEVEL D
NS-10 MODIFIED 48 BAIL
LEVEL D
NS-11 MODIFIED 18 BAIL
LEVEL D
NS-15 LEVEL D 75 PUMP
EX-6 LEVEL D 80 PUMP
EX-7 LEVEL D 80 PUMP
EX-8 LEVEL D 80 PUMP
EX-9 LEVEL D 80 PUMP
KNIWP651 A 1.FSP/02-11-92/DO
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Where samples will be collected using a bailer, the bailer will be lowered into the water
slowly to minimize surface disturbance. Samples collected from wells that have a dedicated
pump will be filled from the sampling port using new Teflon tubing. Groundwater will be
transferred into the sample container slowly to prevent turbulence, and no headspace will be
trapped in the sample containers. Samples will be collected in 40 mL clear glass vials and
closed using Teflon septa caps Groundwater samples will be preserved with 2 mL of
concentrated hydrochloric acid (HCl), to a pH of 2. Sample containers will be labeled
immediately after the sample is collected and the following information will be included on
the label:
•
•
•
•
•
•
•
•
Unique sample number
Project narr.e and number
Type of sample
Analytical program to be followed
Preservative type
Sample location
Time and date of collection
Names of sample team members .
Two vials will be collected per sample. One sampling location will be chosen at random as a
field duplicate, and one sample location will have two sample volumes collected for use as a
matrix spike/spike duplicate. The number of samples, container types, and analytical program
to be followed are summarized in Table A-2.
Sample Documentation. The following sample documentation will be completed for these
items in accordance with the QAPP.
• Field Activity Daily Log (FADL)
• Request for Analysis and Chain of Custody Record (RNCOC).
The time that each sample is collected will be recorded on the FADL as it is being collected.
The RA/COC form is initialized during sampling; the sample number, number of bottles and
volume of sample collected, and the analysis program is recorded for each sample as soon as
the sample labeling is complete. At the end of each sampling day, the RNCOC is signed and
packaged with the samples and shipped to the laboratory. This sample documentation will be
completed by the IT representative in compliance with the QAPP.
Once the sample has been placed into the appropriate sample bottle, custody tape will be
placed over the sample bottle lid and sample bottle. The sample bottle will then be placed
KN/WP651.FSPJ02•11-92JDO A-5
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Sample type
Field Samples
Matrix Spike/
Spike Duplicate
Rinsateb
Trip Blank
Table A-2
Samples to be Collected
During Performance
Monitoring Sampling Events
Number of Bottles Per
Samples Sample
ga 2 • 40 ml
1 2 • 40 ml
1 2 • 40 ml
1 2 -40 ml
Anaylitical
Program
VOA
VOA
VOA
VOA
8 lncludes field duplicate
bRinsate sample is required only if nondedicated sampling equipment is used
KNIWP651 A2..FSP/02· 11 ·92JDO
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into a ziplock style plastic bag and placed into a cooler with inert absorbent packing such as
vermiculite, packed with ice packs or frozen blue ice packs surrounding the sample bottles to
keep the sample at 4°C. A copy of the RNCOC form also shall accompany the sample
shipment. The cooler lid will be secured with strapping tape or duct tape and Tamper ~r
Custody Tape shall be placed over the seal of the cooler in at least two places.
A.4.0 Chemical Analysis _____________ _
Samples will be submitted to the IT Analytical Services (ITAS), Knoxville laboratory for
analysis of Target Compound List (TCL) VOCs. Samples will be shipped overnight express
to the IT AS laboratory either on the day of collection or within 24 hours. If samples must be
stored on site, they will be kept at 4°C in a dedicated refrigerator and shipped for delivery
within 48 hours of the collection time. Samples will be analyzed within 14 days so that
holding times will not be exceeded for preserved samples. Samples will be analyzed using
U.S. EPA Contract Laboratory Program (CLP) data quality assurance protocols, and CLP
specified detection limits.
Ms. Kim Laisy will be the ITAS Middlebrook project contact (telephone numbe;-615-588-
6401).
A.5.0 Sampling Schedule ____________ _
The short-term monitoring schedule allows initial, frequent sample collection for developing a
data base and establishing the baseline initial conditions, followed by less frequent perfor-
mance monitoring sampling (long-term monitoring). During the first 2 years, samples will be
collected quarterly. After the development of baseline conditions is complete_d, sampling will
occur in conjunction with performance monitoring of the OU! RA. Quarterly reports will be
prepared for the short-term monitoring schedule. After the initial phase of sampling has been
completed, reporting of the progress of the no action of OU2 will be once every 5 years.
KN/\VP651.FSPi02-1 l-9'2/DO A-6
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APPENDIX B
QUALITY ASSURANCE PROJECT PLAN
KN/WP645COV.OU2/02· 1 1-92/00
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B.1.0 Introduction _______________ _
The purpose of this Quality Assurance Project Plan (QAPP) is to document the procedures
that will be undertaken to provide the precision, accuracy, and completeness of the data
gathered during the remedial action (RA) process for the second operable unit (OU2) of the
National Starch and Chemical Corporation (NSCC) Cedar Springs Road site in Salisbury,
North Carolina by IT Corporation (IT).
This QAPP documents the measures that will be undertaken by IT and its subcontractors to
ensure that the work performed will be of proper quality to accomplish project objectives and
to be responsive to requirements of the U.S. Environmental Protection Agency (U.S. EPA).
The p:an addresses:
• Quality assurance (QA) objectives of the project
• Staff organization and responsibility
• Specific QA and quality control (QC) procedures that will be implemented to
achieve these objectives.
The requirements of the U.S. EPA with regard to the QA focus on the acquisition of
environmental data of known and acceptable quality. Other aspects of the project, such as
engineering analysis and report preparation, will be controlled by the internal requirements of
IT's QA Program.
The program is documented in the IT Engineering Operations Quality Assurance Manual,
Revision No. 1, (ITEO QAM). The policies and procedures specified in the manual define
acceptable practices to be employed by personnel engaged in any particular project.
The ITEO QAM is a controlled document that is considered proprietary information; however,
it may be supplied to regulatory agencies upon request.
Project Objectives. The objective of the OU2 RA is to collect and evaluate the data
needed to ensure that the projected remedial process is being maintained. The tasks that will
be undertaken include:
• Establishing sampling schedules to support the objectives
KN/WP651.APB(B4)/2-11·92 B-1
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• Establishing sampling methods and locations that will provide proper representa-
tion of the process
• Conducting analyses of samples for previously identified contaminants
• Recording and analyzing results to determine if the remediation goal can be
verified.
IT Analytical Services (IT AS) will conduct all required analysis in accordance with estab-
lished industry standards and IT AS protocols as well as the applicable portions of the U.S.
EPA Standard Operating Procedures and QA Manual (Environmental Compliance Branch
Standard Operating Procedures and Quality Assurance Manual. U.S. EPA Region IV. ESD.
Athens. Georgia, February 1, 1991 and subsequent revisions).
B.2.0 Project Organization and Responsibility ____ _
The principal IT personnel assigned to this project are Mike Sturdevant (Project Manager
[PM]), Steve Alvanas (Quality Assurance Officer [QAO]), Melissa Smith, Health and Safety
Officer [HSO]) and Kim Laisy, Laboratory Project Coordinator), as shown in Figure B-2-1.
Resumes of these personnel are provided as Attachment I to this appendix. Their responsi-
bilities are described in the following sections. Other personnel will be assigned as deemed
necessary.
B.2. 1 Project Manager
The PM will be the prime point of contact with NSCC and will have primary responsibility
for technical, financial, and scheduling matters. His duties will include:
• Assignment of duties to the project staff and orientation of the staff to the needs
and requirements of the project
• Supervision of the performance of project team members
• Budget and schedule control
• Review of subcontractor work and approval of subcontract invoices
• Establishment of a project record keeping system
• The provision that all major project deliverables are reviewed for technical
accuracy and completeness before their release
KN/WP651.APB(84)/2-I 1-92 B-2
Project Coordinator, NSCC
Hank Greulich
(Alex Samson)
IT Project Management NSCC Regional
Director Operations Manager
Cliff Vaughan
Ray Paradowski
Contract Administrator/ Project Manager Quality Assurance Officer
Purchasing Manager Steve Alvanas
Lynda Gregg Mike Sturdevant
Health & Safety Officer
Melissa Smith
Project Engineer Principal Investigator Analytical Services Risk Assessment Manager
Kevin Pack Jonathan Shireman Kim Liasy Samantha Pack
-
FIGURE B-2-1 PROJECT ORGANIZATION CHART
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• The provision that the specific requirements of the QAPP are satisfied
• Project closeout.
B.2.2 Quality Assurance Officer
The QAO is in charge of audits and monitors adherence to the project QA objectives. The
QAO reports directly to the PM.
The QAO is responsible for determining that project work undergoes adequate quality review.
The QAO's responsibilities will include:
• Contacting the analytical laboratories receiving samples to determine if san1ples
are properly prepared, packaged, and identified
• Conducting audits of sampling episcxks to provide that sample identification and
chain-of-custody procedures are being followed
• Contacting the PM to determine that personnel assigned to field sampling
episodes are properly trained in sample identification and chain-of-custody
procedures
• Reviewing work products.
B.2.3 Health and Safety Officer
The HSO will be responsible for seeing that all team members adhere to the site safety
requirements. Additional responsibilities are as follows:
• Updating the equipment or procedures based upon new information gathered
during the site inspection
• Modifying the levels of protection based upon site observations
• Determining and posting locations and routes to medical facilities, including
poison control centers, and arranging for emergency transportation to medical
facilities
• Notifying local public emergency officers, i.e., police and fire departments, of the
nature of the team's operations and posting their telephone numbers
• Examining work party members for symptoms of exposure or stress
KN/Wl'651 .APB(84)/2-l 1·92 B-3
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• Providing emergency medical care and first aid as necessary on site; the HSO has
the ultimate responsibility to stop any operation that threatens the health or safety
of the team or surrounding populace.
B.2.4 Laboratory Project Coordinator
The Laboratory Project Coordinator will be responsible for coordinating laboratory services
and will determine that analytical data meet the objectives discussed in the applicable sections
of the QAPP.
B.2.5 QA Reports to Management
Fundamental to the success of any QAPP is the active participation of management in the
project. Management will be aware of project activities and will participate in development,
review, and operation of the project.
Management will be informed of QA activities through the receipt, review, and/or approval
of:
• Project-specific QA project plans
• Corporate and project-specific QNQC plans and procedures
• Post-audit repons and audit closures
• Corrective action overdue notices
• Nonconformance repons.
B.3.0 Project-Specific QA and QC Procedures~----
This project will be performed in conformance with IT's QA Program requirements and
applicable federal, state, and contract requirements. Project QA objectives are as follows:
• The scientific data generated will be of sufficient or greater quality to stand up to
scientific and legal scrutiny
• The data will be gathered or developed in accordance with procedures appropriate
for the intended use of the data
• The data will be of known and acceptable precision, accuracy, and completeness.
This QAPP has been prepared in direct response to these goals. This plan describes the QA
Program to be implemented and the QC procedures to be followed by IT and its subcontrac-
tors during the course of the project. These procedures will:
KN/WP651.APB(84)/1,-l 1·92 B-4
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• Maintain the necessary level of quality of each aspect of the analytical program
by providing the appropriate level of verification testing, checking, and statistical
analysis of laboratory program procedures
• Assist in the early recognition of factors that may adversely affect the quality of
data, and provide for the implementation of procedures to correct these adverse
effects
• Enhance the utility of data produced by the laboratory for decision-making
purposes by requiring sufficient documentation of the testing process. This
provides information on the limitations of the analytical results.
In this regard, the QAPP will provide for the definition and evaluation of the following
parameters:
• Detection limits
• Data precision and evaluation
• Data accuracy and evaluation
• Completeness of data
• Comparability.
B.3. 1 Detection Limits
The detection limit for a given parameter is defined as the minimum concentration that can be
determined from an instrument signal that is three times the background noise. Table B-3-1
provides a listing of the estimated detection limits for pollutants.
B.3.2 Data Precision and Evaluation
Precision is a measure of the mutual agreement among individual measurements of the
the same propeny, usually under prescribed similar conditions. Relative percent difference
(RPD) will be used to define the precision between replicate analyses. RPD is defined in
Chapter B.13.0. The precision objectives for the Target Compound List (TCL) analyses will
be the same as those estimated by the methodology. QA objectives for precision are less than
15 percent (average RPD).
B.3.3 Data Accuracy and Evaluation
Accuracy is defined as the degree of agreement of a measurement with an accepted reference
or true value. The percent recovery (%R), determined by sample spiking, is typically used to
determine the accuracy of the instrumentation and is defined in Chapter B.13.0. The accuracy
objectives for the TCL analyses will be the same as those established by the U.S. EPA for its
KN/Wl'6Sl APB(84 )/2-11 ·92 B-5
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Contract Laboratory Program (CLP). QA objectives for accuracy will be in accordance with
U.S. EPA CLP 2/88 Statement of Work (SOW) .
8.3.4 Completeness of Data
Completeness is a measure of the amount of valid data obtained from a measurement system
compared to the amount that was expected to be obtained under correct normal conditions. It
is anticipated that more than 90 percent of all data obtained on this project should be valid
based upon evaluation of the QC data.
8.3.5 Comparability
To provide the comparability of the data to similar data sets, only U.S. EPA-approved
analytical methods will be used. For TCL compounds, these methods will be from current
U.S. EPA CLP protocols. For miscellaneous parameters, these methods will be from current
U.S. EPA 600-series methods.
B.4.0 Sampling Procedures. ____________ _
Any sample obtained during the course of a field investigation should be representative of the
site and free of contaminants from sources other than the immediate environment being
sampled.
Information obtained from site exploration activities will be recorded and documented.
Required documentation of field investigation and testing includes a daily log of project
activities, appropriate subsurface logs, and test data forms. It is IT's standard procedure to use
unbound Field Activity Daily Logs (FADLs) to document field events. These documents
identify the specific activity and are completed in sufficient detail to provide a clear descrip-
tion of events. The descriptions typically include sample locations and intervals. Details of the
sampling sequence and methods are provided in the Field Sampling Plan (Appendix A). An
example of this documentation is shown in Figure B-4-1.
The Field Sampling Plan (Appendix A) describes the numbers and types of samples to be
collected, sampling equipment, procedures, and locations, sample containers, methods of
sample preservation, shipping and packaging methods, analytical tests to be performed,
sampling personnel, and sampling schedule.
KN/WP651 .APB(84)/2-11·92 B-6
I rn INTERNATIONAL
TECHNOLOGY
CORPORATION
I
PROJECT NAME
" FIGURE B-4-1 0 ...
► ...
FIELD ACTIVITY DAILY LOG < 0
I PROJECT NO.
DATE
NO.
SHEET OF
.1: FIELD ACTIVITY SUBJECT: t---------------------,--,---,----------------1
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DESCRIPTION OF DAILY ACTIVITIES AND EVENTS:
•. -..1..
. -'
VISITORS ON SITE:
WEATHER CONDITIONS:
IT PERSONNEL ON SITE·
SIGNATURE
------,---•---.
·-· ... J
CHANGES FROM PLANS AND SPECIFICATIONS, AND
OTHER SPECIAL ORDERS AND IMPORTANT DECISIONS.
IMPORTANT TELEPHONE CALLS:
DATE:
327A-7-86
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B.5.0 Sample Custody ____________ _
B.5. 1 Chain-of-Custody Procedures
Chain-of-custody procedures are intended to document sample possession from the time of
collection to disposal in accordance with federal guidelines. A copy of IT' s Analysis Request
and Chain-of-Custody Record form is included in Figure B-5-1. For the purpose of these
procedures, a sample is considered in custody if it is:
• In one's actual possession
• In view, after being in physical possession
• Locked so tha•. no one can tamper with it, after having been in physical custody
• In a secured area, restricted to authorized personnel.
These procedures will be followed for samples subject to chemical analysis for this project:
• Sample containers will be sealed in the field. Any samples that do not arrive at
the laboratory with seals intact will not be considered to have been in valid
custody. If the laboratory sample custodian judges the sample custody to be
invalid (i.e., samples arrive with seals broken), nonconformance documentation
will be initiated. The project manager will then be notified. The decision will be
made by the project manager as to the fate of the sample(s) in question. The
sample(s) will either be processed "as is" with custody failure noted along with
the analytical data, or rejected with the resampling scheduled if necessary.
• A chain-of-custody record will be initiated in the field for each sample. A copy
of this record will accompany each sample.
• Each time responsibility for custody of the sample changes, the new custodian
will sign the record and note the date.
• Upon sample destruction or disposal, the custodian responsible for the disposal
will complete the chain-of-custody record, file a copy, and send a copy to the PM
or to his designated representative for record keeping.
• The custody of individual sample containers will be documented by recording
each container's identification on an appropriate Analysis Request and Chain-of-
Custody form.
• Analyses for each sample will also be recorded on an IT Analysis Request and
Chain-of-Custody Record form.
KN/WP651.APB(84)/2-l 1-92 B-7
--(--[E. INTERNATIONAL
TECHNOLOGY
CORPORATION
Project Name/No. ~
Sample Team Members 2_
Profit Center No. ~
Project Manager4 _ ·-_ ---·
Purchase Order No. 6 ·------·-_____ _
Required Report Date 11 ________ _
Sample 14 Sample 15
Number Descriptian/Tvoe
..
Special Instructions: 23
Possible Hazard Identification: 24
., .. •-F-E --1--ANALYSIS REQUEST AND
CHAIN OF CUSTODY RECORD* ..... ----Reference Document No_ .'.>Z 3 5TI
Samples Shipment Date 7 ____ . __ _
Lab Destination e _______ _
Lab Contact.~--
Project Contact/Phone -~2__ __
carrier/Waybill No. 13 ___ _
ONE CONTAINER PER
Page 1 of __
Bill to:5 ---· ... -------
--··----Reportto:1_0 __
LINE
Date/Time 16 Conteiner1; Sample 1' Pre-19 Requested Testing 20 Condition an 21
Collected Tvna Volume servative Program Receipt
--·---ll" t ll 'i,,\ I) .,;, t1 . ~ ....
12 A,rs.a. mes L.,;"'!I,,.
l.\.ll ~ It:.: (\:,}J
lf"'li!'~tPn l'i
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"" ,;·;;-':r-
ro "" Disposal 22
Record Na.
-< g,_
5 " fl\lt! ,,
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MP~ 1 0
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11'1'1-
ff'7'\it.~
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·. ; i;-'1'; i] n n
C 0 C ,
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Sample Disposal: 25
Non-hazard '_J Flammable 'JI Skin Irritant I.JI . Poison B ljJ Unknown 1..J Return to Client l]I Disposal by Lab I..J Archive_ (mos.]
Turnaround Time Required: 26 I QC Level: 21
Normal 1...1 Rushl_j 1.1.:a 11.l_j 111.i_J Proiect Soecific (soecifv]· ·-· ---· --. --
1 . Relinquished by 28 Date: 1 . Received by 28 Date: ·----------------
(Signature/ Affiliation) Time: [Signature/ Affiliation} Time:
2. Relinquished by Date: ··---2. Received by Date: ---------------
(Signature/ Affiliation) Time: (Signature/ Affiliation) Time:
3. Relinquished by Date: ·-3. Received by Date:
(Signature/ Affiliation) Time: {Signature/ Affiliation) Time: -~----
Comments: 29
MCA 3115/91
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• The following documentation will supplement the chain-of-custody records:
-Sample label on each sample
-Sample seal on each sample
-Field collection report
-Photographic records (wherever practical will have received copies of
the chain-of-custody procedure),
B.5.2 Sample Labeling
Sample labels must contain sufficient information to uniquely identify the sample in the
absence of other documentation. Labels will include as minimum:
• Project number
• Unique sample number
• Sample location
• Sampling date and time
• Individual collecting the sample
• Preservation method employed
• Analysis Required.
The sample label will always be directly affixed to the sample container and will always be
completed using indelible ink. An example of the sample label to be used on this project is
presented in Figure B-5-2.
In addition, IT custody seal tape will be used on each sample container to prevent the
unauthorized tampering or removal of each aliquot. This tape will be affixed across the
container lid so as to show visible evidence of tearing when the lid is ultimately removed.
B.6.0 Equipment Calibration, ____________ _
B.6.1 General Calibration Procedures
Laboratory and field testing equipment used for analytical determinations will be subject to
periodic inspection and calibration. Equipment calibration will be conducted in accordance
with Section 5.5 of the ITEO QAM.
Measuring and test equipment and reference standards will be calibrated at prescribed
intervals and/or before use. Frequency will be based on the type of equipment, inherent
stability, manufacturer's recommendations, values given in national standards, intended use,
KN/WP65! APB(S4)/2-I 1-92 B-8
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FIGURE B-5-2 SAMPLE LABEL
rn INTERNATIONAL F
TECHNOLOGY H<S>R CORPORATION
Project Name -
I Project No.
Sample No.
Collection Date/Time I Collector's Name
I Sample Location
Sample Type/Depth/Description
,-,
I Analyze For Preservative
Bottle of __ Filtered __ Nonfiltered
23-8•85
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and experience. A summary of calibration requirements for certain laboratory instruments is
inc!uded in Table B-6-1. n
Calibrated equipment shall be uniquely identified by using either the manufacturer's serial
number or other means. A label with the identification number and the date when the next
calibration is due will be attached to the equipment. If this is not possible, records traceable
to the equipment will be readily available for reference.
Scheduled periodic calibration of testing equipment does not relieve field or laboratory
personnel of the responsibility of employing properly functioning equipment. If an individual
suspects an equipment malfunction, he shall remove the device from service, tag it so it is not
inadvenently used, and notify the PM so that recalibration can be performed or substitute
equipment can be obtained.
B.6.2 Calibration Failures
Equipment that fails calibration or becomes inoperable during use will be removed from
service and either segregated to prevent inadvenent use, or tagged to indicate it is out of
calibration. Such equipment will be repaired and recalibrated or replaced as appropriate.
Results of activities performed using equipment that has failed recalibration will be evaluated
by the PM. If the activity results are adversely affected, the results of the evaluation will be
documented and the appropriate personnel notified.
B.7.0 Analytical Procedures ___________ _
B. 7. 1 Overview of Standard Laboratory Operating Procedures
Procedures that are to be routinely followed when analyzing samples include the following:
• Holding times and the amount of sample available will be reviewed and the
analyses prioritized. If the holding time is exceeded, the IT AS Coordinator will
contact the IT project manager, who will determine whether the sample will be
analyzed.
• Analyses will be performed within the CLP holding times.
• A calibration curve consisting of at least three standards and a reagent blank will
be prepared as specified in the methodology.
KN/W~I.APB~)/2-11·92 B-9
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• Preparation and analysis of at least one procedural blank will be completed for
each group of samples analyzed.
• At least one spiked sample will be analyzed for every 20 samples processed to
monitor the %R and accuracy of the analytical procedure.
• One sample in duplicate will be analyzed for every 20 samples processed .
B.7.2 Organic Compounds
The analyses for volatiles will be performed by the IT AS laboratory in Knoxville, Tennessee.
The instrumental techniques employed will be gas chromatography/mass spectrometry
(GC/MS) and gas chromatography with electron capture detector (GC/ECD). The Knoxville
laboratory is contracted under CLP for organic analyses methods. Procedures instituted by
CLP will be adhered to during appropriate organic analyses pertaining to the OU2 RA at the
NSCC Cedar Springs Road facility. The analyses for organic compounds will be based on
the U.S. EPA CLP 2/88 SOW.
The address for the IT AS Knoxville laboratory is as follows:
IT Analytical Services, Inc.
5815 Middlebrook Pike
Knoxville, Tennessee 37921
B.8.0 Data Reduction, Validation, and Reporting~-----
The final report will include, but not be limited to the following:
• Completed Analysis Request and Chain-of-Custody Record forms
• Report data
• Method detection limits
• Method blank results
• Matrix spike (MS) results
• Duplicate results
• A presentation of the accuracy and precision data.
• Trend analysis .
Procedures for assessing these aspects of the data are described in Chapter B.12.0. When
data are reduced, the method of reduction will be identified and described. Laboratory data
validation will follow the procedures as described in the IT AS QAM. IT's Field Analytical
Services (FAS), an organization within IT AS but independent of the laboratory analysis, will
conduct the data validation.
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Calculations included in the final report will be checked by a person of appropriate technical
expenise who will verify a minimum of 20 percent of the data. Errors will be identified with
a red pen. The originator will then review the changes recommended by the checker, If the
originator disagrees with the checker, the two will confer until their differences are resolved.
If errors are identified, the associated data will be checked.
8.9.0 Quality Control Procedures'-----------
B.9.1 Field Quality Control Procedures
To check the quality of data from field sampling efforts, blank (water) and duplicate samples
will be submitted to IT's Analytical Laboratory. Blank samples will be analyzed to check for
container contamination. Duplicate samples will be analyzed to check for sampling and
analytical error causing data scatter. The confidence limits and percent level of uncertainty
will be calculated and reported in the OU2 RA progress/sampling reports. One duplicate will
be prepared for every JO borings made and one blank will be prepared for every 20 samples
(including duplicates) submitted for analysis.
Water used for the analysis of trace metals will be purified by reverse osmosis/deionization to
no less than JO MO/cm. Water for organics determinations will be deionized and then further
purified with activated carbon.
Standard ITAS sampling equipment and procedures will be used for blank sampling as
described in the Sampling and Analysis Plan. All blank (water) and duplicate samples will be
treated as separate samples for identification, logging, and shipping.
B.9.2 Laboratory Quality Control Procedures
Volatile Organics. Samples for volatile organics analysis will be analyzed according to the
U.S. EPA CLP 2/88 SOW. An initial calibration curve will be prepared using a mixture of
standards at five different concentrations and a mixture of three internal standards. Each
GC/MS tune will be verified every 12 hours to provide that its performance on bromofluoro-
benzene (BFB) meets the applicable U.S. EPA criteria. The continuous calibration is also
verified prior to sample analysis by re-analysis of the midrange standard.
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Standards, method blanks, and samples will be spiked before analysis with surrogate standards
as specified in OJ> procedures. Surrogate standards are defined as non-TCL compounds used
to monitor the %R efficiencies of the analytical procedures on a sample-by-sample basis.
Samples exhibiting surrogate standard responses outside the contract required control limits
will be re-analyzed.
At least one method blank for every 20 samples will be purged and analyzed for volatile
organic compounds (VOC). Volatile organics analysis requires a method blank consisting of
5 milliliters (mL) of organic-free water spiked with the appropriate surrogate standards.
Results of the method blank analysis will be maintained with the corresponding sample
analyses.
Matrix spike and matrix spike duplicate (MS/MSD) analyses will be performed on one of
every 20 samples per matrix analyzed. A separate aliquot of the sample will be spiked with
the appropriate TCL compounds and will then be calculated. Should the %R values fall
outside the appropriate QC limits, the other QC parameters will be evaluated to determine
whether an error in spiking occurred or whether the entire set of samples requires re-analysis.
The relative percent error for each parameter will then be calculated from these MS/MSD
analyses. Should the average relative percent error fall outside the appropriate QC limits, the
other QC parameters will be evaluated to determine whether the duplicate sample should be
re-analyzed or whether the entire set of samples must be re-purged and analyzed.
B.10.0 Performance and Systems Audits and Frequency __
Audits may be conducted periodically to verify compliance with IT and specific project
QNQC program requirements. Audits consist of evaluations of QNQC procedures and the
effectiveness of their implementation, and evaluation of work areas and activities, and a
review of project documentation as appropriate .
Audits may cover both field activities and report preparation and will be conducted by trained
and qualified IT personnel. Audits will follow the applicable guidelines of the U.S. EPA SOP
and QA Manual (U.S. EPA, 1991).
The records of field operations may be reviewed to verify that field-related activities were
performed in accordance with appropriate project procedures. Items reviewed may include,
but not be limited to: calibration records of field equipment; field activity daily logs;
KN/W1'651.APB(84)/l-11·92 B-12
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photographs; and data, Jogs, and checkprints resulting from the field operations. The U.S.
EPA may have access to these documents as necessary.
Audits may also examine, as appropriate, the documentation and verification of field and
laboratory data and results; performance, documentation, and verification of analyses;
preparation and verification of drawings, logs, and tables; content, consistency, and conclu-
sions of the final report; compliance with IT and project requirements; and maintenance and
filing of project records .
Audit results are transmitted to the PM for information and corrective action as appropriate.
B.11.0 Preventive Maintenance. ___________ _
Periodic preventive maintenance is required for equipment whose performance can affect
results. Instrument manuals are kept on file for reference if equipment needs repair.
Troubleshooting sections of manuals are often useful in assisting personnel in performing
maintenance tasks.
Any equipment that requires routine maintenance will be included in the laboratory preventive
maintenance program. Information pertaining to life histories of equipment maintenance will
be kept in individual equipment logs with each instrument. Appropriate and sufficient
replacement parts or backup equipment will be available so that sampling and monitoring
tasks are not substantially impeded or delayed.
B.11.1 Routine Maintenance Activities
Depending on the parameters to be analyzed and the intended purpose of the data, a wide
variety of instrumentation and equipment is available for analytical activities. Because of the
reliance placed on such equipment to assist in evaluating the appropriate level of protection
for field personnel and because of the use of environmental measurements to support
enforcement cases, all analytical equipment will be maintained at its proper functional status.
Analytical instrumentation and equipment used to prepare and analyze groundwater and
surface water samples will be maintained to manufacturers' specifications and in operational
condition. Routine preventive maintenance will be conducted to verify proper operation of
the various pieces of equipment. The objective of the preventive maintenance program for
analytical equipment is to avoid generating false environmental measurements that could
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endanger site personnel or lead to inappropriate remedial responses. Table B-11-1 summariz-
es ITAS's preventive maintenance program for laboratory instrumentation and equipment.
B.11.2 Preventative Maintenance Documentation
Laboratory instrument logs are used to record maintenance and service procedures and to
document instrument problems and steps taken to resolve problems. It is the responsibility of
the person performing the maintenance activity or repair to provide documentation in the
instrument log. These records are kept with the instrument or filed in the respective instru-
ment laboratory according to laboratory standard operating procedures. Instrument logs are
subject to QC audit.
B.11.3 Contingency Plans
ITAS maintains an inventory of spare parts and equipment to be used in the case of equip-
ment failure. In addition, backup instrumentation is available to minimize the effects of
instrument downtime. Manufacmrer service contracts have been purchased for some
equipment to ensure prompt response for needed repairs. And finally, the ITAS network of
11 laboratories provides a means for completing analyses within holding times and with a
standard QA program when the other contingency plans for equipment failure do not succeed.
(The other IT AS laboratories will only be used with a client's permission.)
B.12.0 Specific Routine Procedures Used to Assess Data
Precision, Accuracy, and Completeness'-------
QC checks are needed to demonstrate that the laboratory is operating within prescribed
requirements for accuracy and precision. This section describes (1) the type and frequency of
QC checks performed by IT AS, (2) the procedures ITAS will use to determine the precision
and accuracy targets listed in Chapter B.3.0, and (3) the procedures used to calculate method
detection limits.
B.12.1 Laboratory Quality Control Checks
The IT AS QA program was designed to meet or exceed the requirements of the analytical
methods employed. The type and frequency of QC checks is discussed in the following
sections. Specific acceptance criteria for these checks are provided in Chapters B.3.0 and this
section.
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B.12.2 Trip (Travel) Blank Analyses
Volatile organics samples are susceptible to contamination by diffusion of organic contami-
nants through the Teflon-faced silicone rubber septum of the sample vial; therefore, trip
blanks are analyzed to monitor for possible sample contamination during shipment. Trip
blanks are prepared in the laboratory by filling two volatile organic analysis vials (40 mL)
with organic-free water and shipping the blanks with the field kit. Trip blanks accompany
each set of sample bottles through collection and shipment to the laboratory and are stored
with the samples.
B.12.3 Method Blank Analyses
A method blank is a volume of deionized, distilled laboratory water for water samples, or a
purified solid matrix for soiVsediment samples carried through the entire analytical procedure.
The volume or weight of the blank is approximately equal to the sample volume or sample
weight processed. A method blank is performed with each batch of samples. Analysis of the
blank verifies that method interferences caused by contaminants in solvents, reagents,
glassware, and other sample processing hardware are known and minimized .
B.12.4 Reagent Blank Analyses
A reagent blank is composed of the materials that will be added to samples during preparation
(e.g., solvents, acids, adsorptive materials). It is run prior to the use of the materials on "real"
samples to verify that no contaminants are present at levels that would affect sample results.
B.12.5 Duplicate Sample Analyses
Duplicate analyses are performed to evaluate the precision of an analysis. Results of the
duplicate analyses are used to determine the RPD between replicate samples. Duplicate
samples are analyzed at a frequency of 10 percent for inorganic and general chemistry tests.
B.12.6 Check Standard Analyses
Because standards and calibration curves are subject to change and can vary from day to day,
a midpoint standard or check standard is analyzed at the beginning of each run, after every 10
or 20 samples, depending on the method, and at the end of each run. Analysis of this
standard is necessary to verify the calibration curve.
B.12.7 3urrogate Standard Analyses
Surrogate standard determinations are performed on all samples and blanks for GC/MS
analyses and for most GC analyses. All samples and blanks are fortified with surrogate
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spiking compounds before purging or extraction to monitor preparation and analysis of
samples.
B.12.B Matrix Spike Analyses
To evaluate the effect of the sample matrix upon analytical methodology, a separate aliquot of
sample is spiked with the analyte of interest and analyzed with the sample. The %R for the
respective compound is then calculated and results evaluated. MSs are prepared and analyzed
at a frequency of one per twenty samples.
B.12.9 Matrix Spike Duplicate Analyses
Similar in concept to the MS sample previously described is a separate aliquot of sample that
is spiked with the analyte(s) of interest and analyzed with the associated sample and MS. A
comparison of the recoveries of the spiked compounds in the MS/MSD samples is made to
determine the RPD between the MS/MSD samples. MS duplicates are prepared and analyzed
with each group of 20 samples for all organic tests .
B.12.10 Verification/Reference Standard Analyses
On a quarterly basis, the Quality Control Coordinator introduces a group of prepared
verification samples, or standard reference materials, into the analytical testing regime. The
concentrations are unknown to laboratory personnel. Results of these data are summarized,
evaluated, and presented to laboratory management for review and corrective actions, if
appropriate. (Refer to Chapter B.13.0.)
B. 12. 11 Blank Spike Analyses
A blank spike is a volume of deionized, distilled laboratory water for aqueous samples, or a
purified solid matrix for soiVsediment samples that is spiked with parameters of interest and
carried through the entire analytical procedure. Analysis of this sample with acceptable
recoveries of spike materials demonstrates that the laboratory techniques for this method are
in control. This sample is generally analyzed with MS/MSDs on those sample matrices that
are anticipated to cause analytical difficulties due to matrix interferences. If the MS/MSD
pair shows poor recoveries due to interferences, yet the blank spike sample is acceptable, this
is strong evidence that the method has been performed correctly by the laboratory for these
samples, but matrix interferences have affected the results.
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B.12.12 Laboratory Control Samples
A laboratory control sample (LCS) is a blank spike analyzed for inorganic or general chemis-
try parameters. The LCS spiking solution is a certified material from U.S. EPA, Environmen-
tal Regulatory Agency (ERA}, or National Institute for Standards and Technology (NISn,
and represents a source of material independent from that used for calibration. The LCS is
carried through the entire sample preparation/analysis procedure with each batch of 20
samples and is used to determine whether the laboratory techniques are in control for the
method employed.
B.12.13 Standard Addition Spike Analyses
This is a sample created by spiking target analytes into a prepared portion of a sample just
prior to analysis. It only provides information on matrix effects encountered during analysis,
i.e., suppression or enhancement of instrument signal levels. It is most often encountered
with elemental analyses, and is analyzed with each sample digestate during graphite furnace
and cold vapor atomic absorption analyses.
B.12.14 Internal Standard Spike Analyses
This is an analyte that has the same characteristics as the surrogate, but is added to a sample
just prior to analysis. It provides a short-term indication of instrument performance, but it
may also be an integral part of the analytical method in a non-QC sense, e.g., to normalize
data for quantitation purposes. Internal standards are spiked into all GC/MS standards,
blanks, and samples.
B.13.0 Routine Methods to Assess Precision and Accuracy_
When the analysis of a sample set is completed, the QC data generated will be reviewed, and
calculated accuracy and precision will be evaluated against the goals identified in Chapter
B.3.0 to validate the sample set. The specific methods used to generate precision and
accuracy data are described in Table B-13-1.
Accuracy. Accuracy is the nearness of a result or the mean of a set of results to the true
value, and is calculated as follows:
Percent Recovery (%R)
where:
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Concentration determined in unspiked aliquot
Concentration determined in spiked aliquot
Known value of the spike
=Percent recovery.
Precision. Precision is the measurement of agreement of a set of replicate results among
themselves without assumption of any prior information as to the true results. A measure of
the agreement in the reported values for the two portions is obtained by calculating the RPD
in the concentration level of each constituent, where ~ and B; are the concentrations of
constituents A and B.
IA; -B) RPO; = -'-------'-x 100 (A; + B;)/2
Control Charts. The control chart program currently in use at the Knoxville laboratory
calculates upper and lower control and warning limits as follows:
Upper Control Limit = ji+3s
Lower Control Limit = ji-3s
Upper Warning Limit= ji+2s
Lower Warning Limit= ji-2s
where:
ji = average percent recovery
s = standard deviation of percent recovery
Generation of these in-house limits requires re-entry of data points into a computer system
separate from that used to collect and process raw data. Thus, the list of parameters and
analyses for which control charts are generated is limited to those that would provide the
most needed information.
Detection Limits. All analytical methodologies have an associated method detection limit
below which an analyte present in the sample cannot be accurately measured.
Organic Analyses. The practical quantitation limit (PQL) is defined by U.S. EPA as the
lowest level that can be reliably achieved within specified limits of precision and accuracy
during routine laboratory operating conditions. PQLs are specified by the U.S. EPA SW-846
and CLP methodology.
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Results for organics analyses are reported using U.S. EPA PQLs, i.e., a detection limit
quantity is reported as a value flagged with "U ." This less than value does not indicate that
an analyte is not present in a sample, but instead, that it is not present at levels above the
PQL. For results produced by U.S. EPA CLP GC/MS methods, values that are below
required PQLs, but can still be quantified, are flagged with a "J" as "estimated concentra-
tions." The laboratory verifies the U.S. EPA PQLs by analysis of a low calibration standard
at or near the detection limit, with each calibration range.
The method detection limit (MDL) is defined by U.S. EPA as the minimum concentration of
a substance that can be measured and reported with 99 percent confidence that the analyte
concentration is greater than zero. The MDL is determined from analysis of a sample in a
given matrix type containing the analyte.
For operational purposes, when it is necessary to determine the MDL in the matrix, the MDL
shall be determined by multiplying the appropriate one-sided 99 percent t-statistic by the
standard deviation obtained from a minimum of three analyses of a MS containing the analyte
of interest at a concentration three to five times the estimated MDL. The t-statistic is
obtained from the following table:
No. of samples:
3
4
5
6
7
8
9
10
The MDL shall be estimated1ias follows:
t-statistic
6.96
4.54
3.75
3.36
3.14
3.00
2.90
2.82
• The concentration value that corresponds to one of the following shall be deter-
mined:
a. an instrument signal/noise ratio within the range of 2.5 to 5.0, or
b. the region of the standard curve where there is a significant change in sensi-
tivity (i.e., a break in the slope of the standard curve).
• The variance (S2) for each analyte shall be determined as follows:
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where '¼ = the ith measurement of the ,yariable x and i1. = the average value of x;
- 1 't"' X = -L..J X;
n i=1
• The standard deviation (s) for each analyte shall be determined as follows:
• The MDL for each analyte shall be determined as follows:
MDL = t(n-1, a= _99i(s)
where \n-I, a= _99) is the one-sided t-statistic appropriate for the number of
samples used to determine (s), at the 99 percent level.
B.14.0 Nonconformance/Corrective Action Procedures'----
Nonconforming items and activities are those that do not meet the project requirements,
procurement document criteria, or approved work procedures. Nonconformances may be
detected and identified by:
• Project staff -During the performance of field investigation and testing, supervi-
sion of subcontractors, and performance of audits and verification of numerical
analyses
• Laboratory staff -During the preparation for and performance of laboratory
testing, calibration of equipment, and QC activities
• Quality Assurance Staff -During the performance of audits.
Each nonconformance will be documented by the person identifying or originating it. For this
purpose, a Nonconformance Report, Testing Procedure Record, Notice of Equipment
Calibration Failure, results of laboratory analysis control tests, post-audit report, internal
memorandum, or letter will be used as appropriate. Documentation shall, when necessary,
include:
• Name of the individual identifying or originating the nonconformance
• Description of the nonconformance
KN/WP<iSI .APB(84)12-11·92 B-20
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• Any required approval signatures
• Method for correcting the nonconformance
• Schedule for completing corrective action.
Documentation will be made available to project, laboratory, and/or QA management.
Appropriate personnel will be notified by the management of any significant nonconformance
detected by the project, laboratory, or QA staff. Implementation of corrective actions will be
the responsibility of the PM, or the laboratory director. In addition, the PM will notify NSCC
of significant nonconformances which could impact the results of the work and will indicate
the corrective action taken or planned. The PM will be responsibl) for approving corrective
actions. Completion of corrective actions for significant nonconfo~ances will be verified by
the PM.
Any significant recurring nonconformance will be evaluated by the project or laboratory
personnel to determine its cause. Appropriate changes will then be instituted in project
requirements and procedures to prevent future recurrence. When such an evaluation is
performed, the results will be documented.
B.15.0 Quality Assurance Audits and Reports _____ _
To verify compliance with IT and specific project QA/QC program requirements, audits are
conducted in accordance with the applicable requirements of Section 11.0 of the ITEO QAM,
Rev. 1. Audits consist of: evaluations of QNQC procedures ancf the effectiveness of their
implementation; evaluations of work areas and activities; and reviews of project documenta-
tion. Audits are performed in accordance with written check lists by trained personnel. Audit
results are formally documented and sent to project management
Audits may include, but not be limited to, the following areas:
• Field operations records
• Laboratory testing and records
• Equipment calibration and records
• Identification and control of samples
• Numerical analyses
• Computer program documentation and verification
• Transmittal of information
• Record control and retention.
KN/WP651APB(84)/2,l 1·92 B-21
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CLIFFORD E. VAUGHAN
Professional Qualifications
Mr. Vaughan is a professional engineer with more than 21 years of experience in the
environmental assessment and remediation field. He is experienced in problem assessment and
implementation of construction and mining projects, including developing permit applications and
managing regulatory affairs for industry. His background in the development and administration
of environmental regulations from both a government and industry perspective is extensive. Mr.
Vaughan bas negotiated out-of-court settlements (including site mitigation measures) for both
industry and the federal government regarding violations of environmental regulations. His
experience includes major project administration as well as management of day-to-day operations.
He has a strong background in problem solving and management of multidisciplined staff with
both physical and biological science members, and has directed remedial investigation/feasibility
studies (RI/FSs) on large National Priority List (NPL) sites. He serves as a senior site
investigation and remediation expert and consutant on other major environmental issues. He
holds current DOD secret and DOE "O" clearance.
Education
B.S., Civil Engineering, Virginia Polytechnic Institute, Blacksburg, Virginia; 1969
Experience and Background
1990 -Director, Project Management, Environmental Engineering and Services, IT
Present Corporation, Knoxville, Tennessee. Directs senior project managers responsible for
managing projects that exceed $1.0 million in revenues. Directs efforts to win and
execute work with clients of significant strategic value to the company. Develops major
project support systems necessary for execution of major projects such as cost and
schedule control and project management administrative support. Other responsibilities
include:
• Serves as the Functional Work Group team leader for project management and
accounting to develop the requirements for a new company wide project cost tracking
system
• Directs the start-up of new offices in the southeast
• Conducts major project reviews to ensure that all client and company requirements
are being met
• Initiate activities to improve the image of IT Corporation as a• project management
organization
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Clifford E. Vaughan page 2
1983 -General Manager, Environmental Assessment and Remedial Design, IT
1990 Corporation, Knoxville, Tennessee. Responsibilities included profit center
1984 -
1988
management, including technical, operating, and business considerations. Administered
company policies and procedures relative to the quality assurance (Q/,) program,
performed administrative functions, and oversaw overall project performance. Works
with clients to identify appropriate project/program functions and client preferences for
services to be provided. Provided direction to the managers of the various operating
groups within Environmental Assessment Remedial Design (EARD) for completion of
projects. Other responsibilities included:
• Directed RI/FS on major NPL sites at Air Force Bases in the western United States
through the Hazardous Waste Remedial Actions Program (HAZWRAP) in Oak
Ridge, Tennessee
• Directed development of an underground storage tank program to provide client
services in investigation and remediation from IT-Knoxville
• Directed a program of complete environmental services for a large national defense
contractor for nationwide services provided by IT
• Directed completion of RI/FSs for multiple commercial clients in the southeastern
United States
• Served as a senior staff consultant to IT staff and to clients to provide guidance for
management of major environmental issues
Manager, Civil and Environmental Engineering, IT Corporation, Knoxville,
Tennessee. Managed the civil and environmental engineering group that included
,engineers, geologists, and hydrogeologists. Was the manager-in-charge of multiple
major projects done simultaneously by IT Corporation in the Southeast, such as
Resource Conservation Recovery Act (RCRA) Part B permits and RI/FSs at NPL sites.
Assigned project managers to coordinate the assignment of personnel working on
multiple projects. Served as a senior consultant to provide staff and industry with
guidance and consultation on the necessary activities for waste site assessment and
remediation. Experience includes:
• Managed RI/FS oversight project for the Environmental Quality Board (EQB) of
Puerto Rico
• Directed RI/FS for a state Superfund site in Florida
• Managed a geochemical evaluation and study of the environmental impacts of ash
disposal at a large coal-fired power plant in the southeastern United States
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Clifford E. Vaughan page 3
1983 -
1984
1982 -
1983
• Directed preparation of a RCRA Part B permit for a large Department of Energy
(DOE) facility at Oak Ridge, Tennessee
• Directed multiple underground storage tank leak investigations and remediation
projects
• Directed RI/FSs on several large NPL sites in the southeastern United States
• Program manager for developing Remedial Action Plant (RAPs) or RI/FSs on
mu!tiple sites at Air Force Bases in the western United States.
Project Manager/Senior Civil Engineer, IT Corporation, Knoxville, Tennessee.
Directed the design of hazardous waste landfills, site mitigation, and complex
environmental studies. Ensured that hazardous waste facility designs conformed to
requirements of RCRA regulations for permitting. Provided service to the mining
industry on special problems, such as complex groundwater contamination, "lands
unsuitable for mining" petitions, and reclamation. Managed complex environmental
assessments for the coal mining industry relative to petitions filed under P.L. 95-97 to
have areas determined as unsuitable for coal mining. Experience includes:
• Designed a state-of-the-art landfill to store dioxin-contaminated soil
• Completed an environmental study on a large stream and watershed to determine the
validity of a petition to have the watershed declared unsuitable for coal mining under
P.L. 95-87
• Investigated sites in British Columbia to select a site suitable for a commercial
hazardous waste landfill
• Performed extent-of-contamination surveys involving organics, solvents, dioxins,
heavy metals, PCBs, and wood treatment chemicals
• Investigated leaking underground storage tanks and designed remediation procedures.
Senior Environmental Engineer, Sierra Coal Company. Prestonburg. Kentucky.
Kentucky. Directed the company's environmental regulation compliance efforts.
Coordinated technical support supplied by corporate environmental staff. Directed
engineering consultants in developing mining permit applications. Directed company
technical staff in the preparation of permit application. Evaluated capabilities of
engineering consulting firms and selected consultants for projects. Inspected mining and
construction projects and determined appropriate action to be taken. Served as liaison
between the company and various state and federal regulatory agencies. Recommended
company policies to ensure cost-effective compliance with federal and state regulations.
D
U Clifford E. Vaughan page 4
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1982
1977 -
1979
1972
1977
1970 -
1972
1969 -
1970
Civil Engineer, Office of Surface Mining. Department of the Interior, Knoxville,
Tennessee. Had regional authority on civil and environmental engineering problems.
Reviewed and evaluated experimental mining practices. Served as national expert on
excess spoil disposal for a rewrite of the excess spoil regulations. Investigated
abandoned mine<! land emergency projects and developed specifications for construction.
Conducted training seminars and workshops on federal regulations requirements.
Civil Engineer, Department of Agriculture, Soil Conservation Service, Richmond,
Virginia. Served as chairman of a Citizens Advisory and Technical Committee to
develop a Best Management Practice Handbook for Virginia. Handbook identified cost-
effective land treatment methods for control of diverse sources of water pollution.
Developed a procedure to assess diverse-source water pollution problems in Virginia and
set priorities, by watershed, where diverse-source control would be most critical.
Civil Engineer, Soil Conservation Service, Soil Conservation Service, Department
of Agriculture, Chase City, Virginia. Was the assistant engineer responsible for
construction work in south central Virginia, which included design and layout for
construction. Served as the project engineer on earth-fill flood control structures.
Construction Engineer, U.S. Army. Platoon Leader for an earth-moving construction
platoon. Was in charge of design and construction of roads, dams, culverts, and other
assorted earth-moving projects.
Civil Engineer, Soil Conservation Service, Department of Agriculture, Richmond,
Virginia. Designed earth-fill flood control structures and reinforced concrete
appurtenances. Coordinated with regional design group on methods of design and
changes in designs. Developed stage stor~ge and other hydrologic data for reservoirs.
Registrations/Certifications
Registered Professional Engineer: Virginia, Kentucky, West Virginia, Tennessee,
Missouri, Florida, New Jersey, Alabama, South Carolina, and the Commonwealth of
Puerto Rico.
Publications
Vaughan, Clifford, E., 1979, "Best Management Practice Handbook," report prepared
for the Virginia State Water Control Board, Richmond, Virginia.
Vaughan, Clifford, E., James L. Chisholm, and Thomas N. Crebbs, 1984, "An
Evaluation of Expected Impacts on the Environemnt of Frozen Head State Natural Area
if Mining is Conducted in Flat Fork Watershed," IT Corporation, Knoxville, Tennessee.
03/26/90
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MICHAEL N. STURDEVANT
Professional Qualifications
Mr. Sturdevant is a professional engineer with 11 years of civil/environmental engineering
experience. As a project manager, he is responsible for managing the technical and budgetary
aspects of projects. Project management experience includes directing multi-disciplinary teams
in preliminary assessment/site investigation (P NSI) projects, remedial investigation/feasibility
study (RI/FS), and remedial design/remedial action (RD/RA). He interprets rules and regulations
to define project approach and evaluate data. Directs the preparation of technical reports, plans,
specifications, and cost estimates for Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA) sites. He has
coordinated his work activity with various disciplines, clients, and regulatory agencies. He has
assisted clients with regulatory negotiations and litigation support. Mr. Sturdevant also has a
U.S. Department of Defense (DOD) secret clearance. /
Education
B.S., Civil Engineering, Michigan Technological University, Houghton, Michigan; 1980
Experience and Background
1984 -Senior Project Manager, IT Corporation, Knoxville, Tennessee. Responsible for
Present defining scope of work, organizing, coordinating, tracking, and delivering the final
product on schedule and under budget. As a project manager he manages
multidisciplinary personnel on complex environmental projects that have included the
following:
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Project manager of a major RD/RA project at a National Priority List (NPL) site
in North Carolina. Project involves pumping and treating a groundwater
contaminant plume in fractured bedrock. Regulatory interface with U.S.
Environmental Protection Agency (EPA) Region IV.
Project manager for the preparation of SI work plans and performance of Sis at
Navy Installation Restoration Program (IRP) sites in San Diego, California.
Completed hazardous ranking system scoring for 17 sites in 1 month. Completed
a preliminary assessment (PA) of two sites.
Project manager of a RI/FS at Tidewater Community College (Nansemond
Ordnance Depot) for the USACE under delivery order # DACW45-88-D0008.
Contaminants of concern that were evaluated from soil and groundwater sampling
include inorganics and explosive compounds (i.e., TNT, ONT, 2 amino -4.6-DNT,
etc.) FS will evaluate capping, incineration, composting, and stabilization remedial
action alternatives.
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Michael N. Sturdevant page 2
1983 -
1984
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Project engineer involved in the preparation of an FS for an NPL site in North
Carolina. Remedial alternatives evaluated were no action, off-site disposal,
capping, pumping/treating groundwater, excavation/incineration, and pumping/off-
site disposal to Public Owned Treatment Works (POTW).
Senior project engineer involved in technical evaluations, Rl/FS work plans, and
reports for DOD, U.S. Department of Energy (DOE), EPA and numerous
commercial clients. Some of these projects include Mare Island Naval Shipyard
Rl/FS, Mather Air Force Base (AFB) Rl/FS, Williams AFB Rl/FS, Concord Naval
V/eapons Station Rl/FS, Olin Chemical Rl/FS, Lewisburg Dump Rl/FS, Fernald
Rl/FS, Chemtronics FS, Fresno Air National Guard Base (ANGB) SI, Roane Alloys
FS.
• Project engineer for the preparation of work plans and technical reports for site
investigations under the Air Force Remedial Action Program.
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Deputy program manager of immediate responses and environmental assessments
of Superfund sites in Tennessee. Site investigations to determine sources of
imminent or potential hazards to public and environment. Sampling and analysis
to determine extent of contamination. Evaluation of remedial alternatives to clean
up hazardous sites.
Prepared RCRA Part B permits and closure plans for storage facilities, surface
impoundments, an incinerator, a sludge fixation plant, and treatment facilities in
Oak Ridge, Tennessee.
Supervised drilling operations for subsurface soil sampling investigations and
installing groundwater monitoring wells for underground storage tank (UST) and
Superfund sites in Tennessee. Work was performed under the Tennessee
Emergency Response contract.
Set up a data base for environmental monitoring results for future and past surface
and subsurface investigations at a Superfund site in Florida. Plotted concentration
contours from data base to establish hot spot zones.
• Assisted in groundwater sampling at Superfund sites using EPA-approved sampling
and decontamination procedures.
Civil Engineer, Bechtel National, Inc., Advanced Technology Division, Oak Ridge,
Tennessee. Worked on the Formerly Utilized Sites Remedial Action Program
(FUSRAP). Designed and prepared subcontract packages for radiological
characterization, monitoring well installation, site preparation, contaminated soil
excavation, building demolition, land surveying, and material testing at various sites in
New Jersey and New York. This work included developing conceptual and final design
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Michael N. Sturdevant page 3
1982 -
1983
1980 -
1982
drawings, cost estimates, and technical specifications. Also prepared permits for point
discharges to groundwater and soil and erosion control. Coordinated work with federal,
state, and local regulatory agencies.
Civil Engineer, Bechtel National, Inc. Nuclear Fuels Operation Division, Oak
Ridge, Tennessee. Worked on site preparation for the Defense Waste Processing
Facility at the DOE Savannah River Plant. Was responsible for design and layout of
access roads, storm and sanitary sewers, underground piping, drainage facilities, and
general utilities. Used models and corr,puter programs as design aids. Coordinated
work with various disciplines and the client.
Junior Civil Engineer, California Department of Transportation, San Francisco,
California. Worked in project development, construction, environmental planning, and
hydraulics departments. Experience included design and coordination, estimating,
inspecting, surveying, computer-sided design, and report writing.
Registrations/Certifications
Registered Civil Engineer; California, Tennessee, North Carolina, and South Carolina.
Active DOD Secret "Q" Clearance
10/09/91
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STEPHENF.ALVANAS
Professional Qualifications
Mr. Alvanas has more than 15 years of progressive, diversified experience in the nuclear utility
and defense industry. His utility experience includes quality assurance (QA) auditing,
procurement engineering and information officer. He is a certified lead auditor in accordance
with American National Standards Institute (ANSI) N45.2.23 requirements. He is also certified
to NQA-1 requirements. His procurement experience includes development of technical
specifications as well as evaluation of bids and administration of resulting contracts through
completion. He has administered and developed an automated data processing program including
budgeting, procurement disbursement and utilization.
Mr. Alvanas has been responsible for the development of procedures and administration of
training for the procurement of spare parts in the defense industry. He has been employed as a
nuclear sales engineer responsible for the development of utility and manufacturing accounts for
utilization of nuclear related steel products.
Education
B.S., Business Administration/Management, Tusculum College, Greeneville,
Tennessee; 1987
A.M.E., Mechanical Engineering, Wentworth Institute, Boston, Massachusetts; 1975
Experience and Background
1991 -
Present
1990 -
1991
1989 -
1990
1986 -
1989
Quality Assurance Officer, Environmental Engineering Services, IT Corporation,
Knoxville, Tennessee. Responsible for implementing QA programs including
preparation of customer specific QA plans, internal and external auditing, and overall
program enhancements.
Procurement Engineer, Westinghouse Savannah River, Aiken, South Carolina.
Developed procedures and training courses for activities related to procurement of
spare parts including product specifications, standardization of data entry, evaluation
of part interchangeability and standardization of administrative and technical activities.
Sales Engineer, DuBose Steel Inc., Roseboro, North Carolina. Developed utility
and manufacturing accounts for nuclear steel products.
Certified Lead Auditor, Tennessee Valley Authority, Knoxville, Tennessee.
Conducted supplier QA evaluations and audits to assure conformance to established
nuclear guidelines. Participated in commercial grade dedication program.
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Stephen F. Alvanas page 2
1984 -
1986
1975 -
1984
Information Officer, Tennessee Valley Authority, Knoxville, Tennessee.
Administered and developed automated data processing programs for engineering
division including review of requests, processing of orders and disbursement of
systems.
Procurement Engineer, Tennessee Valley Authority, Knoxville, Tennessee.
Coordinated all phases of the procurement cycle including writing of technical
specifications, evaluating bids, and administering contracts.
Registrations/Certifications
Active DOE "L" Clearance
Certified Engim:ering Technician
05/21/91
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MELIBSAGUILLOTSMITH,CHMM
Professional Qualifications
Ms. Smith is a professional industrial hygienist and a Certified Hazardous Materials Manager in
with 5 years of experience in the comprehensive practice of industrial hygiene, loss control, and
occupational health and safety.
Education
B.S., Environmental Health, Louisiana State University, Baton Rouge, Louisiana, 1987
Completed Industrial Ventilation Fundamentals Course, Institute of Safety and Systems
Management, University of Southern California, Los Angeles, 1990
Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120
Experience and Background
1990-Industrial Hygienist, IT Corporation, Knoxville, Tennessee. Performs health and
Present safety surveys to recognize, evaluate, and control various occupational hazards. Provides
consultation and technical assistance to ensure compliance with applicable federal and
state regulations.
• Cocrdinates health and safety issues, writes health and safety plans, coordinates
training courses, conducts safety audits, accident investigations, writes monthly loss
reports, provides employee health and safety training, and is secretary for the safety
council.
• Developed Corporate health and safety procedures for a major construction contractor
to Department of Energy.
• Conducted a comprehensive Environmental, Health, and Safety (EH&S) audit for two
major petroleum refining facilities.
• Delivered 40-hour Hazardous Operations Emergency Response training courses to
Department of Defense clients.
• Developed MSDS to provide chemical hazard and toxicity information in compliance
with the Occupational Safety and Health Administration (OSHA) Hazard
Communication Standard.
• Provided on-site health and safety coordination for the closing of two major
radioactive disposal sites for the Department of Energy.
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1988-
1990
1988
1987-
1988
Industrial Hygienist, IT Corporation, Cerritos, California. Performed health and
safety surveys of various operation operations associated with hazardous waste
remediation and oil, chemical and manufacturing industries. Provided consultation and
technical assistance to ensure compliance with applicable federal and state regulations.
• Conducted employee task evaluations for various operations involved in the research
and production of petroleum products.
• Developed Material Safety Data Sheets (MSDS) to provide chemical hazard and
toxicity information in compliance with the Occupational Safety Health
Administration (OSHA) Hazard Communication Standard.
• Conducted two comprehensive Environmental, Health, and Safety (EH&S) audits for
two heavy machinery manufacturers.
• Provided health and safety assistance and was the liaison with OSHA officials during
the Huntington Beach oil spill cleanup activities.
• Provided worker health and safety training instruction to ensure compliance with
applicable federal and state regulations.
• Developed and implemented industrial hygiene principles in the asbestos management
area. Conducted asbestos-in-buildings surveys in accordance with the Asbestos
Hazards Emergency Response Act (AHERA).
Industrial Hygienist, Clayton Environmental Consultants, Inc., Cypress. California.
Developed and implemented industrial hygiene principles in the asbestos management
area. Conducted comprehensive workplace surveys using bulk sampling and air
sampling protocol in accordance with AHERA.
• Provided technical assistance on chemical hazard information to ensure compliance
with Proposition 65 and Hazard Communication.
Health and Safety Coordinator, IT Corporation, Port Allen, Louisiana. Managed
health and safety activities for IT field services and engineering projects in the Gulf
Coast region. Provided technical assistance and guidance in support of health and safety
evaluations and surveys. Conducted asbestos surveys involving air monitoring and bulk
sampling protocol. Evaluated occupational hazards associated with industrial operations
including chemical handling, facility cleanups and waste management. Duties also
included writing and implementing contingency plans, internal/external loss control, and
worker health and safety training development and instruction.
• Working knowledge of Department of Transportation (DOT), Resource Conservation
and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation,
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Melissa Guillot Smith page 3
and Liability Act of 1980 (CERCLA), and Federal OSHA regulations. Performed
audits of field operations to ensure compliance with federal and state, as well as IT
policies and procedures, in the areas of occupational and environmental health and
safety. Provided technical assistance for comprehensive risk analyses to address
environmental regulatory requirements in compliance with U.S. Environmental
Protection Agency (EPA), Superfund Amendments and Reauthorization Act of 1986
(SARA) Title III.
Certifications/Registrations
Certified Rad Worker, DOE Order 5480.11 and 5480.20, MK-Ferguson; 1992
Certified in First Aid/CPR Practices, Red Cross; 1992
Certified Hazardous Materials Manager, Institute for Hazardous Materials; 1991
AHERA Accreditation, Asbestos Worker and Asbestos Supervisor Course,
MK-Ferguson; 1991
AHERA Accreditation, Asbestos Building Inspector and Management Planner, Clayton
Environmental Consultants, Inc.; 1988
National Institute for Occupational Safety and Health (NIOSH) 582 Certification,
Sampling and Evaluating Airborne Asbestos Dust, Clayton Environmental
Consultants, Inc.; 1988
Certifications in Mine Safety Appliances (MSA) Ultra Twin, MSA Duo Flow Supplied
Air, and MSA Powered Air Purifying Respirator Maintenance and Use, Martinez,
California; 1987
Professional AtTtliations
American Industrial Hygiene Association
American Society of Safety Engineers
Tennessee Valley Section of American Industrial Hygiene Association
Additional Training
RCRA Training, IT Corporation; 1990
Rad Worker Training, Department of Energy; 1989
IT Corporation training courses in Asbestos Abatement and Control, Confined Spaces,
Site Remediation, Emergency Response, Hazard Categorization, Hazard Chemical
Handling, Air Monitoring, and Training Development; 1987 and Safe Driver Training;
1991
02/06/92
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KEVIN W. PACK
Professional Qualifications
Mr. Pack is an Engineer-in-Training with more than 9 years of experience including
environmental assessments for both private and military operations, groundwater remediation,
regulatory compliance, site development/planning, and construction management.
Education
M.S., Environmental Engineering, University of Tennessee, Knoxville,
Tennessee; 1990
B.S., Civil Engineering, West Virginia University, Morgantown, West
Virginia; 1981
Experience and Background
1989 -Project Engineer/Scientist, Environmental Assessment/Remedial Design, IT
Present Corporation, Knoxville, Tennessee. Provides technical support on a Superfund project
including remedial investigation/feasibility study (RI/FS) reports, preparation, waste
management of investigation derived wastes, and Comprehensive Environmental
Response, and Liability Act (CERCLA), Resource Conservation and Recovery Act
(RCRA), and Clean Water Act (CW A) regulatory compliance. Provides project
management support for three Star Enterprise (Texaco) sites including groundwater
monitoring, and remediation.
1989 Civil/Project Engineer, Dennis Weeter Associates, Louisville, Tennessee. Prepared
environmental assessments for three Chevron, USA, operations including field and
report preparation; supervision for groundwater monitoring; well installation; directed
installation and monitoring of a groundwater remediation system.
1987 -
1989
1984 -
1987
Project Engineer/Scientist, PEER Consultants, Oak Ridge, Tennessee. Performed
as task manager, environmental assessments for several military installations including
identification and records search of past disposal practices, report preparation, and
project management.
Civil Engineer, Barge Waggoner Sumner and Cannon Consulting Engineers,
Knoxville, Tennessee. Involved in planning, design, and construction phases of
commercial site development, including interface with developers, contractors, and
government personnel.
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Kevin W. Pack page 2
1982 -
1984
1982
1974 -
1982
Field Supervisor, Tompkins Beckwith, Inc., Mechanical Contractors, Waterford
III S~eam Electric Station, Taft, Louisiana. Resolved construction restraints for
installation of structural steel and pipe support systems; acting as liaison between
construction contractors, design engineers, and quality control personnel on a fast-paced
production schedule.
Field Supervisor, Daniel Construction Company, Calloway Nuclear Power Plant,
Fulton, Missouri. Inspected pipe support systems, maintained productions schedules,
and acting as liaison between contractors an_d design engineers.
Prior Positions
Lab and Field Technician, H.C. Nutting Geotechnical Engineers, Charleston, West
Virginia; Engineering Aide, West Virginia Department of Natural Resources,
Charleston, West Virginia; Laborer, E. E. Moore Construction Company, South
Charleston, West Virginia.
Registrations/Certifications
Engineer-in-Training; Tennessee
04/23/91
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JONATHANSHIREMAN,RPG
Professional Qualifications
Mr. Shireman is a hydrogeologist with more than four years of experience in modeling solute
transport in complex geological terrains. He is a Registered Professional Geologist in Tennessee,
and his education is concentrated in structural geology, geochemistry, and mineralogy. He has
been responsible for writing portions of work and engineering plans, remedial
investigation/feasibility study (RI/FS) reports, remedial design reports and for coordinating field
investigations involving numerous subcontractors and IT personnel. Acted as technical advisor,
designed, completed groundwater flow, contaminant fate and transport modeling investigations
supporting baseline risk assessments, monitoring well placement and remedial alternatives. His
technical expertise includes evaluation of proposed remedial action plans, modeling of aquifer
restoration strategies, and evaluation of the impact of hazardous waste disposal sites on human
health.
Education
Ph.D., Candidate, Geology, University of Tennessee, Knoxville, Tennessee
M.S., Geology, University of South Carolina, Columbia, South Carolina; 1983
B.S., Geology, Humboldt State University, Arcata, California; 1981
Additional Post Graduate Study, Geochemistry, University of Tennessee, Knoxville,
Tennessee; 1987
Experience and Background
1989 -Project Hydrogeologist. Environmental Assessment and Remedial Design, IT
Present Corporation, Knoxville, Tennessee. Resi:onsible for supervising a wide range of tasks
in support of remedial investigations for both industrial and governmental clients. Has
performed the following duties:
• Support hydrogeologist, groundwater transport modeling at Air Force Bases, under the
Hazardous Waste Remedial Actions Program (HAZWRAP) program. Compiled,
evaluated and interpreted geophysical logs and aquifer test data to synthesize
conceptual models of aquifers. Developed a finite difference, 2-D contaminate
transport model. Analysis of multilayered aquifer system, evaluated vertical and
horizontal dispersion of TCE through four aquifers. Analysis of complex alluvial
aquifer, predictive transport of dissolved aromatic hydrocarbons. Results of modeling
incorporated base line risk assessment and used site monitoring wells. Results
presented to base and HAZWRAP representatives.
• Project hydrogeologist, aquifer restoration evaluation, petroleum refinery. Conducted
aquifer tests and evaluated subsurface conditions at petroleum refinery. Evaluated
product recovery systems during field pilot tests and established pumping strategies
to optimize capture of dissolved phase and free product plumes in stratified sand
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1989
aquifer.
• Project hydrogeologist and site coordinator, National Starch Phase I Remedial Design
installation in Salisbury, North Carolina. Managed site activitie3 during the
installation of a groundwater extraction system. Major project tasks included drilling
large diameter deep boreholes into crystalline bedrock, well bore hydrofacturing,
aquifer tests, and extraction well installation. Project required work under Air
Purifying Respirators and Supplied Air Respirators. Responsible for supervising
drilling and hydrofacturing subcontractors and six subordinate personnel.
• Project hydrogeologist and field activities manager for a geotechnical investigation for
the Costain Coal fly ash land fill design. Developed and conducted a geotechnical
investigation to determine the hydrogeological setting of a small water shed chosen
to site a residual landfill. Geotechnical investigation involved soil boring, coring
stratified rocks and conducting in situ pressure testing of selected intervals. Also
was responsible for interfacing with the Kentucky state regulatory agency. Supervised
subcontractor activities and IT field personnel.
Project Geologist, Environmental Assessment/Remedial Design. IT Corporation,
Knoxville, Tennessee. Supervised subcontractors and coordinated drilling activities
during site investigations. Developed cost proposals and evaluates subcontractors for
geotechnical and environmental investigation for commercial and government clients.
• Lead geologist, National Starch Remedial Action/Remedial Design (RA/RD)
investigation. Managed drilling activities during a remedial design investigation at
a chemical waste disposal site. Installation of soil borings, installation of bedrock
monitoring wells, performance of segregated hydraulic conductivity tests. Synthesis
of the hydrogeological framework of the site, and preparation and support for the
engineering reports.
• Lead geologist for site investigations (SI) at former U.S. Department of Defense
(DOD) sites under the Defense Environmental Restoration Program. Field supervisor
during installation and development of monitoring wells, soil sampling, groundwater
sampling, and field permeability tests at inactive defense sites. Site ranking according
to the Hazard Ranking system.
• Assistant hydrogeologist, remedial investigation (RI) for Yellow Freight Inc. Long-
term aquifer test, numerical transport modeling of migration path and residence time
of soil contaminants. Geotechnical and analytical investigation established
contamination plume and fracture systems in the bedrock. Installation of groundwater
monitoring wells and injection tests determine immediate aquifer response to proposed
remediation designs.
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1987 -
1988
1983 -
1987
• Geologist, RI at a Superfund hazardous waste site in Columbia, South Carolina.
Installation of groundwater monitoring wells.
• Developed quality assurance (QA) procedures for the Knoxville Engineering
operations office (KEQAP) for a wide spectrum of technical tasks. These procedures
were designed to ensure that hydrogeological investigations are in compliance with
requirements of HAZWRAP project quality plans.
Hydrogeologist, Oak Ridge National Laboratory, Oak Ridge, Tennessee. Consultant
to the Office of Risk Analysis, acting in the capacity of senior scientist. Experience
included:
• Principal investigator for groundwater solute transport modeling and risk evaluation
at the S-3 disposal ponds under the Y-12 Closure and Postclosure Analysis project.
• Developed methodology and guidance for identifying and evaluating possible health
hazards because of water transport of contaminants from waste management units, and
presented methods to government agency personnel at regularly scheduled seminars.
• Provided risk assessment of hazardous waste management units.
Laboratory Instructor and Lecture Assistant, University of Tennessee, Knoxville,
Tennessee. Developed laboratory exercises in geochemistry and petrology, prepared
lectures for physical geochemistry optical mineralogy, and metamorphic petrology.
• Developed a geochemical software code to solve for thermodynamic equilibrium
conditions in terms of pressure, temperature, and/or fluid composition from mineral
composition data for a variety of calibrated mineral assemblages
• Assistant instructor to geologic field methods course.
1981 -Laboratory Instructor for Petrology and Mineralogy, University of South Carolina,
1983 Columbia, South Carolina. Developed laboratory exercises in petrology and
mineralogy.
1982 Petrographic Consultant to Amselco Mineral Exploration, Camden, South Carolina.
Private consultant managing the manufacture of petrographic thin sections and making
petrographic examinations of the specimens. Provided ore mineralogy of each specimen
and an analysis of the paragenetic sequence. Documented a report for each specimen,
and a final report for each borehole that summarized the findings for the study.
1981 Assistant Instructor, Los Angeles State College, Los Angeles, California. Geologic
field methods course, six-week field study in crystalline basement. Instructed groups of
up to six students during daily field exercises.
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1981
Petrographic Assistant, Humboldt State University, Arcata, California. Manufactured
petrographic thin sections for mineral exploration and faculty research. Assisted in
teaching laboratories in geologic field methods, petrology, petrography, and optical
mineralogy.
Registrations/Certifications
Professional Geologist; Tennessee
Professional Affiliations
National Water Well Association
Publications
Shireman, J. and V. J. Brumback, 1988, Health Assessment. Midway Landfill NPL Site.
1-87-158. Seattle. Washington, Agency for Toxic Substances and Disease Registry
(ATSDR) Health Assessment, Atlanta, Georgia.
Travis, C. C., R. K. White, J. Shireman, F. R. O'Donald, and G. R. Southworth, 1988,
Analysis of Proposed Post Closure Alternatives at the S-3 Ponds, Oak Ridge National
Laboratory (ORNL), Oak Ridge, Tennessee.
Brumback, V. J. and J. Shireman, 1988 Draft Health Assessment for the Vineland
Chemical Company Site. Vineland. New Jersey, Agency for Toxic Substances and
Disease Registry (ATSDR) Health Assessment, Atlanta, Georgia.
Shireman, J., T. Labotka, and S. Knapp, 1985, "Metamorphic History of a Portion of the
North Carolina Blue Ridge," Geological Society of America, abstracts with programs,
Vol. 17, No. 2, p. 134.
Shireman, J., 1983, Petrology and Deformational History of the Clouds Creek Igneous
Complex. Central South Carolina Piedmont, Thesis (Manuscript), University of South
Carolina, Columbia, South Carolina.
Shireman, J., 1983, "Petrographic Variations of Peraluminous Granitic Rocks and
Associated Quartz Gabbros of the Clouds Creek Igneous Complex, South Carolina
Piedmont," Geological Society of America, abstracts with programs, V. 15, No. 2, p. 64.
Shireman, J., 1981, Igneous and Metamorphic Petrology of Phaneritic Melange Blocks
Near Trinidad, North Wester. California, Senior Thesis (Manuscript), Humboldt State
University, Arcata, California.
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SAMANTHA R. PACK
Professional Qualifications
Ms. Pack has more than 6 years of experience in risk analysis/risk management. She has
performed research on cancer risk management, analytical decision-making models, and cancer
modeling. She is perhaps best known for her work in extrapolating acceptable risk levels from
waste management cleanup decisions made by regulatory agencies. Ms. Pack acts as a project
manager in the Risk Management Services Group.
Education
Undergraduate/Graduate Studies in Environmental Toxicology, University of Tennessee,
Knoxville, Tennessee
M.S., Communications, University of Tennessee, Knoxville, Tennessee; 1986
B.A, English/Economics, Centre College of Kentucky, Danville, Kentucky; 1983
Occupational Safety and Health Administration (OSHA) 29 Code of Federal Regulation
(CFR) 1910.120; 1990
Experience and Background
1989 -
Present
1986 -
1989
Project Scientist. Risk Evaluation, Environmental Projects Group, IT Corporation,
Knoxville, Tennessee. Project experience includes a health and environmental risk
assessments involving mixed wastes.
• Managed a health and environmental risk assessment subtask involving mixed waste
(chemical and radionuclide) U.S. Department of Energy (DOE) facility in Ohio. The
Remedial Investigation/Feasibility Study (RI/FS) for this site involves quanitification
of the risks associated with six separate waste management units, as well as an
integrated assessment of the total risk from all units.
• Implemented a decision-making methodology for the selection of remedial
alternatives at a DOE facility using the Analytical Hierarchy Process.
• Performed an RI/FS risk assessment for a municipal landfill Superfund site m
Tennessee.
• Performed an assessment of a volatile organic compound (VOC) spill in
Massachusetts.
President. Richter Pack. Inc., Knoxville, Tennessee. Performed contract work for the
Office of Risk Analysis, Oak Ridge National Laboratory (ORNL), Oak Ridge,
Tennessee. Tasks included:
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Samantha Richter Pack page 2
1985 -
1986
• Project Manager for development and demonstration of the Remedial Alternative
Prioritization Method for ORNL Remedial Action Program. Developed and used a
decision-making model to prioritize remedial alternatives at inactive hazardous waste
sites.
• Project Manager for the application of the Analytical Hierarchy Process decision
model to prioritize waste streams for technology demonstration projects at the Martin
Marietta Center for Waste Management Technology at the K-25 facility in Oak
Ridge, Tennessee.
• Data Analyst for various cancer modeling projects including pharrnacokinetic,
pharmacodynamic, and relative potency models. Produced a guidance document on
Composite Relative Potency Method for the Agency for Toxic Substance and
Disease Registry, Atlanta, Georgia.
Researche:-1 University of Tennessee, Knoxville, Tennessee. Performed contract work
for tlie Office of Risk Analysis, ORNL, Oak Ridge, Tennessee. Performed a
retrospective review of the use of cancer risk assessment and cost-effectiveness in
regulatory decisions made by the U.S. Environmental Protection Agency, the Food and
Drug Administration, and the Occupational Safety and Health Administration to
determine acceptable risk levels for environmental cleanup.
Professional Aff"tliations
Society for Risk Analysis
Publications/Presentations
Travis, C. C., S. Richter Pack, M. A Hattemer-Frey, 1989, "Is Ionizing Radiation
Regulated More Stringently than Chemical Carcinogens?" Health Physics. Vol. 56,No.
4, pp. 527-531.
Pack, S. Richter, November 1, 1988, "The Use of Short-Term Toxicological
Oata to Predict Carcinogenic Potency", Annual Meeting of the Society for Risk
Analysis, Washington, D.C.
Pack, S. Richter, "A Remedial Action Prioritization Method," Presented to American
Institute of Chemical Engineers Annual Meeting, Houston, Texas, March 29, 1987.
Pack, S. Richter, C. C. Travis, J. P. Witherspoon, D. B. Hunsaker, J. W. Webb, 1987,
"Ranking Remedial Action Technologies," Hazardous Waste and Hazardous Materials.
Vol. 4, No. 4, pp. 363-376.
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Samantha Richter Pack page 3
Travis, C. C., S. A. Richter, E. A. C. Crouch, R. Wilson, E. Klema, 1987, "Risk and
Regulation," Chemtech, Vol. 17, No. 8, pp. 478-483.
Travis, C.C., S. A. Richter, E. A. C. Crouch, R. Wilson, E. Klema, 1987, "Cancer Risk
Management: A Review of 132 Federal Regulatory Decisions," Environmental Science
and Technology, Vol. 21, No. 5, pp. 415-520.
Travis, C. C, S. A. Richter, 1987, "Or. Defining a De Minimis Level for Carcinogens,"
in De Minimis Risk, edited by C. Whipple, Pergamon Press, New York, New York, pp.
61-73.
Travis, C. C., S. A. Richter Pack, A. Fisher, 1987, "Cost-effectiveness as a Factor in
Cancer Risk Management," Environment International, Vol. 13, pp. 469-474.
11/20/90
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APPENDIX C
ANALYTICAL DATA FROM THE
SUPPLEMENTAL REMEDIAL INVESTIGATION,
OPERABLE UNIT 2
--------------TABLE -c-1: BORING
1990) ORGANIC ANALYSIS
COLLECTED NOVEMBER
RESULTS FROM SOIL
1989 (SOURCE: IT,
SAMPLES
l 15' SLeShNCfS
\IOL"Illf OIGANIC5
aelhylene chloride
ACelOM
c.&rbon DI IUI I Ide
cti1ora1or■
I. 2-dlchlulot:ll\ane
2-bulal'IOflt
tro.>dl chlaroaethane
1. J-dlchlorop1op1ne
11oaotor■
,i-••hr I-J-pen11none
Toluene
llhYlbenJene
Taul xylenu
st• I YPU• II U OIIGAN I CS
4-aelhylphenol
1en101c acid
n-NI I fOI0dlphenylUI neh
QUANT IT All ON • Ll•IU
' 1
, .. " 7cc12
I ..
<di ' ...
' I '700
1700
' ' 11.000
·-
• • SOil IOIIIHG llC> SUl'lf ,...US 1concentnllon1 are In ug/U (ppll)I
SuPUO INlUVAL nm LAN> SlAfACf OTI
• I I ,., I
71 .. " " " • •
I I J1.ooo'" ' , .. 200 270 160 " 100
' II 1
HO· ,,. 100.000 " --... oo• s,oo! .... a,oo"
' " " '
uo 110
' " uo 160 IJO
' ' ... l7 .000 ' " ' JO -
1100 • .... 1700
"' :uoc
"°'
II IC J-ett,ylbHYI lphlhalale ...... ,
CdJIO cd:110 dJM cd210 dJ.O cdJIO Cd:170 cdJ70 Cd:110 cd:190 cdJM cd270
JtO HO 760 470 ,,o uo no 110 "o JM oo no no
tteHChlorolM.ltadl ene
J-aelhylphenol
leruyl alcohol
111( 2-cllloroelhYI )elhf:r JJ.0009
' ...
' 040
' ..
' ...
• QUi,ntllHlon 11 ■111 are not fepGrted 10, 1011 H■PIU dUe IO U'lelf v■rl•l>lllty, ,t,pplluble 11 ■111 lfl! •v•ll•l>le on lhe Crrllllule1 of ANIYIII.
I> --ln41Ulet org,nlc co.pc>undl lrYI .e,e nol dUeCled.
lrPortrd concen11u1on Is below 1hr quan111allon 11■11.
d (oaipound II •ho prurnl In the laboruo,.,. l>l•nl. the 1upe11c,1p11:11 nwm1:1 II IIM l•b bl•nl concrnlr•llon.
r CUIIOOOOd eacudrd ulll>nllon nnoe of lnllflal!nl but within lnnru■rnl llnur range.
ARllylr NI lound In thr bl•nl U well U 1hr Hasilr.
g (otllll)OUl'ld an,,ly1ed U I ,econCS.n di lut Ion hCIOf,
• oe1ec11:d 11 dlpflen.,.,,. .. ,ne.
NA NOi •oollc.able.
1 INS.UI U INl'ATU
ll1100l7 DU04
,.,
I
<dJ
" •
"
•
' I
-
uo•uu
n120111
.. .. .. .. .. .. .. .. .. .. .. .. ..
--
-------------------
TABLE c-2: INORGANIC ANALYSIS RESULTS FROM SOIL BORING SAMPLES
COLLECTED NOVEMBER 1989 (SOURCE: IT, 1990)
'°" toa I~ AN> S.u.Pl I N.UIIS (concen11111on1 ••• In 119/kg IPPIII J
s, ... uD INTll\lAl flQI, lAtrCI SlaUCl (JT)
..... IH-12
fAIGfT AN,t.l vn DfTlCTl<H
DU' DU'
l 1ST StaSTA~U l1a1fS • ..... -..... ..... ,.._ ... ,.,_,, ..,_., ..... ,, ..... ...... ....... IIN-111 IIIH-171 llNSUf .,.,,.nu ■.u,.•n■
o-,· , ... 11· n.,,· 10-n· 1-10· u-n· 11-20' 2◄-21. 11-10· 2-•. 11-32' 10-JJ' :14-21. HOOlt DUO◄ ••mn
Ahalnua ,,.100 :H.000 JJ. 100 JI. zoo 51,400 H.toO J1.SOO l0, 700 ' 21.toO 71.700 ~.700 H ... 25.200 " • ' ' ARllmf!Y .. • • •
Aflenlc 4, I " ,. ,
I.uh• 21, J '" 70.t .. lJ.2 '" ,., ,., , .. 0.1 "' "' ... I ' ' • '
IU)'llha ' ' ' ' ' ••• ••• • •• • •• .. ' ,., .. , .. , ••• ,., ,., ,.,
um1ua . ' , .. ' .. J I , ..
Cllclua ' ' u,' ' ' ' '
"' 1110 "' ,.. m 60)0 ,. .. :IIJ0 "' "' JJJO J270 7150 ... ,.,
chroalua " " " " " ' • " • " '
Col>AII " " .. • " .. " " " ,. .. " "
COOPU " .. •• " .. .. ., " .. .. .. . " ,., " " .... t].000 27. IOO 14.400 ... , .. "· ... 41.000 .. ... 40. 600 JJ.SOO "· , .. .. ,.. u.,oo H.100 , .. " ' .,,
' ' , ... .. , ,., ••• , .. 5. I ' ' .. ,. , ,., , .. ,., •
... , .. 11.-u,c JtSO .... "' ' "' 2050 n•o .... ,, .. m JUG 2570 J510 ' ' IJIO ,,.
.. noanese m '" ... 211.0 .. , '" "' .,, ... '" "' "' ,.. • ' ' " '
ae,curr o.o, 0.0l o.o, 0.0] D.01 ....
NIO.al • ID ID " 1 1 " " " •
Potauh• , .. "' ' '" , ..
' ' ' ' ' ' ' ,., ' ' ' ... , .. " , .. "' .. ,., m "' 1540 "' " "' IHO 10.900 mo
v•nadh• '" .. ,., '" "' "' "' "' IH "' ., ,., II
""' • ,.2 O.J SI.I >•-• .,_. , ... .. ' 50.2 12.J .,_, lt.J .... , .. , .. " ' "
• oe1ec11on ll■lt• no1 reporled to, 1011 1...-111 ... to their \IHl•blllly. oetecllon 11 ■111 an anllable on the cu11t1u1es 01 Anah·•11 .
• --1nc11u1e1 lnoro,nlc cOllll)OUnd1 1r,.u .en not deleCUd In thlJ ••aple.
' value QfHIU thin ln11r..-en1 cktecllon 11■11. IMII IHI '"'" conuact UQUIUd QUUI ltU Ion 11■11.
HA NDI Appl IU,ble.
----TA:, C:-~ OR=C ~p ~YSIS REsftlfs -sm BAG -L·
COLLECTED NOVEMBER 1989 (SOURCE: IT, 1990)
SOIL BORING MID SAMPLE IIUIIIERS (Concentratt ... are In ue/1 (ppb))
SAMPLED INTERVAL FRON LAIII> SURFACE (FT)
BH·D8 BH·D8
TARGET CIN'QIIID
LI ST SIIISTANCES
QUANT IT A TIIII DUI' DUI'
LINITS8 BN·D8 BH·D8 BN·D8·RE BH·09B BH·09B BN·09B·RE BH•10 BN·10 (BH·18) (BH-18) EX-01 EX·01·RE
TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP
RAIN. STAND. STAIID. RAIN. STANO. STAND RAIN. STAND. RAIN. STAIII>. STANO. STAND.
14·16' 14·16• 14·16' 12·13' 12·13' 12-13' 14· 16' 14·16' 16-1a• 16-18' PBLKE PBLKE
ll!!bAUL, Q!!GA!(CS
Methylene chloride .. b 2cc11 NA 1«t2 1 cc:12 NA 2cd1 1cd1
Acetone 53 NA 150 120 NA a< 51 a< 34 58 41
carbon Disulfide NA NA
Chlorofora NA NA 2<
1,2·dlchloroothane 50 43 NA 12 15 NA 3208 590• a10• no•
2-butanone NA NA
Bromodlchlor-thane NA NA
1,2-dichloropropane NA 12 19 NA
Bromofora NA NA
4•a,ethyl·2·pentonone NA 45 NA
Toluene NA 50 62 NA
Ethylbenlene NA 30 33 NA
Styrene NA NA
Total Xylene• NA 78 95 NA
1,Sl!l!ILAIIL, !l!!GA!l'I
4·•thylp,enol
2<
Benzolc acid 5<
n·Nitroaodtp,enyl•lne1 -rd2 5Cd6 8cd3
Bl1(2·othylhexyl)p,thalato
Phenol
Hexachlorobutadlene
3< 3C
2-.,.thylp,enol zC
Benlyl alcohol
zC
Bls(2·chloroothyl)•ther
-
EX-02
TCLP
RAIN.
PBLICI
6c
• Quantltatlon li ■ita are not reported for aoll l811f>le1 CkJe to their variability. Applicable lt ■ita are available on the Certificates of Anelyaia.
b •· Indicates organic c~ that .,.re not detected.
c Reported concentration ia below the quantlt ■tlon lt ■tt.
d c~ ii also present in the laboratory blank. The •~rscripted 1'1Ud)er is the lab blank concentration.
e C~ analyzed at a secondary dilution· factor.
Detected as diphenyle11ine.
EX Extraction Blank
RE Reextraction
--
EX·OJ E~-~
TCLP ra.,
STAIID. RAI~ .•
C1109 ;1197
-r
5cd6 4""2
-------------

-
-----
TABLE C-4: TCLP INORGANIC ANALYSIS RESULTS FROM SOIL BORING
SAMPLES COLLECTED NOVEMBER 1989 (SOURCE: IT, 1990)
SOIL BORING ANO SAMPLE IIUIIBERS (Concentrations are in 1119/l (pp>))
SAMPLED INTERVAL FROM LANO SURFACE (FT)
BH-08 BH-08
TARGET ANAL YTE DETECTION
DUP DUP
LIST SUBSTANCES LINITS8 BN-08 IH-08 IN-08-RE BH-098 BN-098 BH-098-RE BH-10 BH-10 (BN-18) (BH-18) EX-01 EX-02 EX-03 ~•-04
TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP TCLP
'
RAIN. STAND. STANO. RAIN. STANO. STAND. RAIN STAND. RAIN. STANO. STAND. RAIN. STAii>. IIAIN.
12-18' 12-11' IZ-18' 10-16' 10-16' 10·16' 14-22' 14-22• 14-22' . 14-22• PBC1087 PBCI095 PBCIIOO ~1196
Alunlrua 130 350 NA NA 60 980 5]
Antimony --b NA NA
Arsenic NA NA
Barl&.a 11 760· NA 158 32 NA 4 6 247 425 4 I 4
Beryll lun NA NA
C-IUI NA NA
Colet .. 100 2050 NA 210 61 NA 930 1130 7900 1180 239 ZJ 218 2111
Chrcnl .. NA NA
Cobalt 220 NA NA 20 20 140 120
c_, 40 55 NA 12 NA JO JO 40 40 Z9 16
Iron 360 16,300 NA 50 14 NA 50 JO JO 1550 44 151 32 54
Lead 2 NA NA 4
Na_.1 .. 50 2450 NA 45 NA 140 160 azo 630 40
Manganeae 53 5900 NA 67 14 NA 484 622 ]530 3240 ] 21 J
Mercury NA NA NR NR NR ..
Nickel JO NA NA
Potaaaha zooo NA 1000 1000 NA 1000 1000
soc11 .. 14,000 1,330,000 NA 18,000 3890 NA 6700 19,100 1,170,000 1,140,000 325 1,200,000 1J,JOO
Vanodha NA NA
Zinc 59 71 NA 58 14 NA 28 23 48 43 17 7 17 11
• Detection lt ■its not reported for ■oil amapln 0.18 to their variability. Detection lf ■ltl are available on the Certificates of Analysla .
b •· Indicates inorganic c~ that were not detected in this saq,le.
NA Not applicable.
RE Reextract ion.
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APPENDIX D
RISK CHARACTERIZATION REPORT
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@ INTERNATIONAL
TECHNOLOGY CORPORATION
August 21, 1991
Ms. Darcy Duin
Remedial Project Manager
Environmental Protection Agency Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
SUBJECT: Risk Characterization for the Trench Area; Second Operable Unit; National
Starch & Chemical Co. Site Salisbury, North Carolina; IT Project Number
408668.70
Dear Darcy:
Enclosed for your review and approval is the Risk Characterization Report for the trench
area surface soils. This report represents an expanded version of the preliminary risk
calculation provided in the July 1991 Monthly Progress Report.
In order to tie together the work that has been performed in the past and the work required
for the future, a summary chronology of events that lead up to the additional investigation
of the trench area surface soils is provided below.
• The trench area soils are considered the Second Operable Unit for the National Starch
Site. The Second Operable Unit Remedial Investigation and Feasibility Study was
completed and approved by EPA in June 1990.
An additional risk characterization of the trench area surface soils was prompted by
Elmer W. Akin's (Health Assessment Officer, EPA) review of the Second Operable
Unit Record of Decision.· He determined that additional characterization of the direct
soil exposure pathway was required.
• At a meeting between EPA and National Starch on October 5, 1990, Ms. Barbara
Benoy, EPA requested the additional characterization of the trench area surface soils.
National Starch submitted a surface soil sampling plan to EPA by transmittal letter
dated November 12, 1990. National Starch received EPA's verbal approval of the
san1pling plan in May 1991.
Regional Otlice
SOU2SS.DOC 312 Directors Drive • Knoxville. Tennessee 37923 • 6 I 5-690-3211
TT Corporation iS a wholly owned subsidiary of Internat1ona1 1echnology Corporation
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Ms. Darcy Duin
August 20, 1991
Page Two
INTERNATIONAL TECHNOLOGY CORPORATION
In accordance with the approved plan, IT collected six surface soil samples from the
trench area on June 6-7, 1991. The samples were analyzed for the Target Compound
List volatile and semivolatile compounds by IT Analytical Services laboratory. The
analytical results were provided in the July Monthly Progress Report.
The results of the enclosed Risk Characterization Report indicate that the chemicals
measured in the trench surface soils do not pose a significant health risk to workers based
on routine maintenance activities (ie. mowing) within the trench area.
The completion of this work should be considered as a completion of Task I and Task II
of the Scope of Work for the Remedial Design and Remedial Action for Operable Unit 2.
The only exception is the filing of a deed restriction, as required under Task I objective
number 3. The remaining tasks (Task III Final Action Report and Task IV Performance
Monitoring) and the filing of a deed restriction will be completed after EPA and National
Starch approve the Consent Decree.
Please provide your comments or acceptance of the report and our understanding of the
SOW requirements by September 13, 1991.
Sincerely,
~~
Michael N. Sturdevant, P.E.
Project Manager
cc: H. Graulich
R. Paradowski
A Samson
SOU2SS.DOC
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RISK CHARACTERIZATION FOR TRENCH AREA,
NATIONAL STARCH AND CHEMICAL COMPANY
A risk assessment was performed to determine the current risks associated with potential
direct human exposure to surface soils at the National Starch and Chemical Company
(NSCC) site. This risk assessment follows EPA guidance for performing risk
assessments (EPA 1989a). Aside from the determination of chemicals of concern, the
risk assessment evaluates human exposures to chemicals, summarizes the toxic
characteristics of the chemicals, and provides a quantified human health risk associated
with current site conditions.
1.0 CONTAMINANTS OF CONCERN
Table 1 lists the analytical results for the trench area surface soil sampling. Sample
results were compared to applicable field and laboratory blanks to determine if any
compounds detected may be contaminants introduced during sampling or analysis. The
"five and ten times rule" was applied to the sample results. (EPA, 1989a) Fer common
laboratory contaminants (methylene chloride, acetone, 2-butanone, toluene and phthalate
esters), data within ten times an associated blank concentration were disregarded. For
all other compounds, data within 5 times the blank concentration was eliminated from
consideration. Methylene chloride was screened out due to its presence in both field and
laboratory blanks. Background levels for the detected organic compounds in site soils
were considered to be zero. Frequency of detection was not considered due to the small
size of the data set. If a compound was detected at least once, it was included. The
sample results that remained after this screening process are presented in Table 2. The
contaminants in the trench surface soils are acetone, 2-butanone, benzoic acid, and bis(2-
ethylhexyl)phthalate.
-1-
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2.0 EXPOSURE ASSESSMENT
An exposure assessment was performed to detennine the potential for human receptors,
primarily on-site workers, to be exposed to the above-background concentrations of
chemicals of concern identified in surface soils of the trench area. The exposure
assessment involves identification of potential human receptors, identification of
exposure pathways, and quantification of intakes.
2.1 Site Description
The National Starch and Chemical Company (NSCC) site is located in Rowan County,
North Carolina, approximately five miles south of the City of Salisbury. Salisbury is
located about 40 miles northeast of Charlotte, North Carolina.
The NSCC site, also referred to as the Cedar Springs Road Plant, is approximately 485
acres in size. The disposal area, known as the trench area, is surrounded by heavily
wooded acreage to the north, west, and south. Residential areas are located no less than
1500 feet from the trench area in the northwest and southwest directions. Public access
to the trench area is controlled by posting, fencing, and plant personnel. Figure 1 shows
the Trench Area and locations of the surface soil samples.
2.2 Identification of Exposure Pathways
Table 3 provides a summary of pathways by which a human receptor may come into
contact with the chemicals found in the surface soils of the trench area. General
exposure assumptions include:
Entry by public is restricted by posting and/or fencing around the
site; and
workers enter the trench area infrequently, primarily for weed
control activities.
The frequency and duration of worker activities in the trench area is based on
information from R.E. Paradowski (1991) of NSCC.
-2-
-------------------·
Figure 1. Trench Area and Surface Soil Sampling Locations. (Source: RI Report, June 1988, IT Corporation, Figure 2-I)
-3
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2.3 Quantification of Exposure
The quantitiative estimate of intake by human receptors involves:
Determining the concentration of each chemical in the
environmental media at the point of assumed human
contact;
identifying applicable exposure models and input parameters; and
quantifying human intake.
Exposure models. were identified to address each potential exposure pathway. The
model used to estimate incidental ingestion of soils (EPA, 1989a) is:
where:
I.oil
Cs
IR
CF
FI
EF
ED
BW
AT
=
=
=
=
=
=
=
=
=
I..u = (Cs)(IR)(CF)(Fl)(EF)(ED)/(BW)(Al)
intake of sediment/soil (mg/kg-day)
chemical concentration in sediment/soil (rrig/kg)
ingestion rate (mg soil/day)
conversion factor (lo·• kg/mg)
fraction ingested from contaminated source (unitless)
exposure frequency (days/year)
exposure duration (years)
body weight (kg)
averaging time (days)
The model for dermal contact with chemicals in soil is also presented in EPA (1989a):
where:
AD = (Cs)(CF)(FI)(SA)(AF)(ABS)(EF)(ED)/(BW)(AT)
AD =
SA =
AF =
ABS =
absorbed dose from sediments/soil (mg/kg-day)
skin surface area available for contact ( cm2)
soil to skin adherence factor (mg/cm2)
skin absorption factor
Skin absorption factors were determined using the method of McKone (1990).
The model used to determine intake by inhalation of airborne chemicals (EPA 1989a)
is:
I ,ir = (Ca)(IR)(ET)(EF)(ED)/(BW)(A 1)
-4-
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where:
I. ..
Ca
IR
ET
=
=
=
=
intake from air (mg/kg-day)
air concentration of chemical (mg/m3)
inhalation rate (m3/hour)
exposure time (hours)
Air concentrations were determined for the volatile organic compounds (VOCs) by
modeling vapor flux from the surface soils and subsequent dispersion. Air
concentrations due to fugitive dust releases were estimated for all contaminants using
a dust-loading model. These models are described below.
The specific parameters and assumptions used to model site-specific conditions at the
NSCC site are listed in Table 4.
Volatilization Model
Workers in the trench area could potentially be exposed to vapor-phase chemicals due
to volatilization of organic compounds present in the surface soils. Volatilization and
dispersion models were used to estimate air concentrations of VOCs based on their
concentrations in surface soil. First a VOC flux from soil is calculated, then air
dispersion is modeled for on-site workers. Model assumptions and parameters are
presented in Table 5.
The emission rate for waste at the saturated soil surface was calculated by (ORI, 1988):
where:
Q
Ac
Ka
u
Dp
Sc
p
pinf
R
T•
=
=
= =
=
=
=
=
=
=
mass flux (moles/hr)
contaminated area (m2)
air mass-transfer coefficient = 0.0292 (U0·78)(Dp·0·11)(Sc·0·67)
Windspeed (m/hr)
Diameter of waste boundary (m)
Schmidt gas number (unitless)
Vapor pressure of the volatile at the soil surface (atm)
Vapor pressure of the volatile in the atmosphere (atm)
Gas constant (atm • m2/mol • "K)
Temperature of waste surface CK)
The equation was modified to account for a mixture of volatiles present at less than
saturation amounts by the factor:
(Ci)/(Cs)
-5-
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where:
Ci
Cs
=
=
Measured concentration of a given volatile in soil (mg/kg)
Concentration if soil were saturated with a given volatile (~
Cs was calculated by: volatile liquid density {d) • soil porosity (E)
soil density (D)
Dispersion of volatiles into air was estimated using the Nearfield Box Model (GRI,
1988):
where:
Ca
Q
Hb
Wb
Um
=
=
=
=
=
(Ca) = (Q)/(Hb)(Wb)(Um)
Concentration of contaminant in ambient air on site (mg/m3)
Emission rate of contaminant (µg/sec)
Downwind exposure height (m)
Width of contaminated area perpendicular to wind direction (m)
Average wind speed= 0.22 (U10) In (2.5 Hb) (m/sec)
U10 = Windspeed at 10 m above ground surface (m/sec)
The following assumptions were included in the model:
The area of contaminated soil is 5 acres
VOCs are present in a mixture of compounds. The maximum soil
concentration for each compound was used for Ci
The flux from subsurface contaminants is negligible.
Fugitive Dust Model
Concentrations of contaminants on fugitive dust were estimated using an average dust
loading of 100 µg/m3 (NCRP, 1984). Concentrations in air were calculated by:
where:
Ca =
Cs =
DL =
CF =
Ca = (Cs)(DL)(CF)
air concentration (mg/m 3)
soil concentration (mg chemical/kg soil)
dust loading factor (µg soil/m 3)
unit conversion factor (1 x 10·9 kg/µg)
The results of the exposure modeling effort are presented in Table 6. the highest intake
encountered was for acetone through inhalation of vapor-phase chemicals, at 2.5 x 104
mg/kg-day. All other intakes were two or more orders of magnitude below this level.
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In summary, modeling results show that intake levels for all chemicals, all pathways are
low.
3.0 TOXICITY ASSESSMENT
3.1 Carcinogenic Effects
Bis(2-ethylhexyl)phthalate (BEHP) is not known to be carcinogenic in humans; however,
BEHP was found to be carcinogenic in rats and mice (NTP, 1982). Benign and
malignant liver tumors were seen at increased incidence in male and female animals of
both species in the absence of other toxicity. EPA classifies it as Group B2, probable
human carcinogen on the basis of animal studies. EPA has calculated a carcinogenic
slope factor of 1.4 X 10 ·2 (mg/kg-day) ·1 via the oral route (EPA, 1991a).
3.2 Noncarcinogenic Effects
BEHP, acetone, 2-butanone, and benzoic acid also show noncarcinogenic effects.
Reference doses (RfDs), uncertainty factors and critical effects or target organs are listed
for these chemicals in Table 7.
4.0 RISK CHARACTERIZATION
Using modeled human intakes and dose-response information, it is possible to estimate
the potential risks associated with the chemicals of concern. Risks are estimated
differently for carcinogens and noncarcinogens. For carcinogenic chemicals, risk is
expressed in terms of the probability of contracting cancer over a lifetime in excess of
the background probability, called the incremental lifetime cancer risk (ILCR). This risk
is estimated using the following formula:
where:
I
SF
=
=
ILCR = (I)(SF)
chemical intake (mg/kg-day)
chemical-specific slope factor (mg/kg-day) ·1
Noncarcinogenic risks are characterized by comparing estimated intakes to allowable
intakes or RfDs. The Hazard Quotient (HQ) is defined:
HQ= I/RID
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where:
I =
RID =
chemical intake (mg/kg-day)
reference dose (mg/kg-day)
As the HQ approaches unity, concern increases regarding adverse health effects.
HQs were added together for all contaminants for each pathway to arrive at a
cumulative Hazard Index (HI). This approach is conservative because noncarcinogenic
risks are not necessarily additive. Because all pathways involve the same receptor in
the same period of time, risks were also added together for all pathways to determine
overall risks for the trench area.
Risk characterization results for estimated intakes in the trench area are listed in Tables
8 and 9. All of these intake are either below the acceptable risk-range for a carcinogen
of 1 x 10-< to 1 x 10 .. (EPA, 1990), or have hazard indices much less than one.
5.0 UNCERTAINTIES AND CONCLUSIONS
Uncertainties are introduced at several steps in the risk assessment process, including:
sampling and sample analysis;
selecting chemicals of concern
quantifying exposure-point concentrations, including contaminant fate and
transport modeling
development of toxicity factors
quantification of exposure intakes.
To minimize the effect of uncertainties in the evaluation, each step is biased toward
health-protective (conservative) estimations. The results of the risk assessment are
estimates of potential risk only if all of the conservative assumptions are realized .
Based on the exposure pathways analyzed, it appears that concentrations detected in the
surface soils do not pose a substantial health risk to workers in the trench area.
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Table I. Surface Soil Sampling Resulu
Tronch Aiu. Natiooal S1an:b and Qicmical Company
Compound (µg/lcg) Trip Rinsat, DI Water VBLK 2'
Blank Blank Blank VB0611
Methylene chloride 4' 2' 1•
acetone
2-butanonc
toluCDc 2' 2•
total xylene,
benzoic acid NA NA
bi,(2-cthylhcJtyl) NA NA
phthalatc
Compound TSS-1 TSS-2 TSS-3 TSS-4
Methylene chloride 11 s• 17 9
acetone 28 69
2-butanonc 2'
toluene
total xy lcnes
bcnzoic acid 43' 210d
bis{2-cthylhcJtyl) 1SO 6900 3700 1000
phthalatc
' VBLK 2 applies IO sample TSS-1; VBLK 3 applies IO samples TS~-2 through TSS-4;
VBLK 5 applies IO samples TSS-5 through TSS-7; SVBLK applies to TSS-1 through TSS-7.
b Field duplicate of TSS-5
c Indicates compound was not detected
d Compound was detected but below quantification limit
• compound not included in this analytical fraction
EPA blank and spike samples, TSS-8 and TSS-9, arc not included in this table.
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VBLK3' VBLKS' SVBLK'
VB06112 VB0612 BLA3374
NA'
NA
NA
NA
2' NA
NA NA
NA NA
TSS-5 TSS-6 TSS-7"'
11 18 s•
11' 4' 2'
110d ss•
3400 1400 1400
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Table 2. Significant Sample Reauhs for Trench Surface Soil
TIOnch Al.a, National Slarch and au,nucal Company
Compound (µg/kg) TSS-1 TSS-2 TSS-3 TSS-4 TSS-5 TSS-6
acetone 28 69 11 4
2-butanone 2
benzoic acid 43 210 110
bis(2-ethylhcxyl)-750 6900 3700 1000 3400 1400
phthala1e
• Field duplicate of TSS--5
b Indicates oompound was not detected; or detected concentration was within 10 X the associated blank
concentration for acetone, 2-butanonc, or bis(2-ethylhcxyl)phthalatc, or within 5x the associated blank
concentration for bcnzoic acid.
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TSS-7"
2
88
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Receptor
On-site Worker
On-site Worker
On-site Worker
On-site Worker
Off-site Resident
Table 3. Potential Exposure Pathways
Trench Area, National Starch and Chemical Company
Evaluated in
Exposure Pathway Risk Assessment Reason for Inclusion/Exclusion
Incidental Ingestion of Soil Yes Direct contact with surface soils
may occur
Dermal contact With Soil Yes Direct contact with surface soils
may occur
Inhalation of Fugitive Dust Yes Workers may encounter fugitive
dust from surface soils
Inhalation of Vapor Phase Yes Workers may encounter volatile
Chemicals organics from surface soils
All Pathways No Access to area is restricted;
transport offsite would be
negligible.
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Table 4. Parameters Used to Describe Exposure to Site-Related Chemicals of Potential Concern
Trench Area, National Starch and Chemical Company
Concentration of
Exposure Pathway Chemical in
Medium
Incidental Ingestion Maximum
of Soils Concentration
Dermal Contact Maximum
With Soils Concentration
Inhalation of Modeled From
Airborne or Vapor-Maximum
Phase Chemicals Concentration
Exposure Assumptions
Ingestion rate
(IR) = 50 mg/ day
Fraction ingested from
source
(FI)= 0.5
Exposure frequency
(EF) = 5 days/year
Exposure duration
(ED) = 25 years
Body weight (BW) = 70 kg
Averaging time
(AT) = 9,125 days
Averaging time, carcinogens
(ATc) = 25,550 days
Skin surface area
(SA) = 1,980 cm2
Soil adherence factor
(AF)= 2.77 mg/cm2
EF = 5 days/year
ED= 25 years
FI= 0.5
BW=70kg
AT= 9,125 days
ATc= 25,550 days
Inhalation rate
(IR) = 2.5 m3 / hr
Exposure time
(ET)= 4 hr/day
EF = 5 days/year
ED= 25 years
BW = 70 kg
AT= 9,125 days
ATc= 25,550 days
Source
EPA, 1991b
assumed'
based on Paradowski (1991)
EPA, 1991b
EPA, 1991b
EPA, 1989a
EPA, 1989a
EPA, 1989b
EPA, 1989a
based on Paradowski (1991)
EPA, 1991b
assumed'
EPA, 1991b
EPA, 1989a
EPA, 1989a
EPA, 1989b
based on Paradowski (1991)
based on Paradowski (1991)
EPA, 1991b
EPA, 1991b
EPA, 1989a
EPA, 1989a
• assumed that one-half of total soil contact would be from the site, because only 4 hours per day are spent the
trench arta.
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Parameter
Mean wind speed
(Um)
Diameter of site
boundary (Dp)
Surface area (Ac)
Temperature at
surface (Tp)
Soil porosity (E)
Soil density (D)
Height of box (Hb)
Width of box (Wb)
Universal gas
constant (R)
Schmidt number (Sc)
Molecular weight
(MW)
Vapor pressure (P)
Vapor pressure at
infinite distance (P wl
Liquid density (d)
Measured
concentration (Ci)
Saturated
concentration (Cs)
Table 5. Volatilization Model Parameters and Assumptions
Trench Area, National Starch and Chemical Company
Units Value Reference
m/hr 12,200 for Charlotte, NC;
GRI, 1988
m 141 calculated from Ac,
assuming square
dimensions
m2 20,000 five acres
OK 293 assumed 20 °C
unitless 0.05 average for clay;
GRI, 1988
g/cm3 1.49 average for clay;
GRI, 1988
m 1.83 assuming a worker
height of 6 feet
m 141 same as Dp
atm·m 8.21 X 10 -S
2/mol•°K
Acetone 2-Butanone
unitless 1.7 1.7 GRI, 1988
g/mol 58 72 EPA, 1986
atm 270 77.5 EPA, 1986
atm 0 0 assumed
g/cm3 0.788 0.805 Merck Index, 1989
mg/kg 0.069 0.002 analytical results
mg/kg 123,000 126,000 calculated from Ci,
d, E, and D
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Exposed
Population
Workers
Workers
Workers
Workers
Table 6. Results of Exposure Estimates
Trench Area, National Starch and Chemical Company
Concentration at
Receptor Location Estimate Chronic
(mg/kg-soil) Daily Intake
Exposure Pathway Chemical (mg/m3-air) (mg/kg/day)
Noncarcinogens
Ingestion of Soil acetone 0.069 3.4 X 10'10
2-butanone 0.002 9.8 X 10'12
benzoic acid 0.210 1.0 X 10'9
bis(2-ethylhexyl)-phthalate 6.9 3.4 X 10-8
Carcinogens
bis(2-ethylhexyl)-phthalate 6.9 1.2 X 10 '8
Noncarcinogens
Dermal Contact acetone 0.069 7.4x10·'
With Soil 2-butanone 0.002 2.2 X 10'9
benzoic acid 0.210 2.2 X 11) •7
bis(2-ethylhexyl)-phthalate 6.9 4.4 X 10-6
Carcinogens
bis(2-ethylhexyl)-phthalate 6.9 1.6 X 10-6
Noncarcinogens
Inhalation of Vapor-acetone 0.129 2.5 X 10-1
Phase Chemicals 2-butanone 0.0013 2.5 X 10-6
Noncarcinogens
Inhalation of acetone 6.9x10·9 1.4 X 10'11
Fugitive Dust 2-butanone 2.0 X 10-10 3.9 X 10'13
benzoic acid 2.1 X 10-8 4.1 X 10'11
bis(2-ethylhexyl)-phthalate 6.9 X 10'7 1.4 X 10'9
Carcinogens
bis(2-ethylhexyl)-phthalate 6.9x10·7 4.8 X 10'10
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Table 7. Summary of Noncarcinogenic Health Effects
Trench Area, National Starch and Chemical Company
Chronic RID
Chemical (mg/kg/ day)' Critical Effect or Target Organ• Uncertainty Factor'
Oral
Acetone
2-butanone
benzoic acid
bis(2-ethylhexyl)-phthalate
Inhalation
2-butanone
'EPA, 1991a
0.1
0.05
4
0.02
0.09
Kidney toxicity
Fetotoxicity
Irritation, Malaise
Liver
Central nervous system
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1000
1000
1
1000
1000
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Table 8. Cancer Risks Associated with Potential Exposures
Trench Area, National Starch and Chemical Company
Chronic Daily Slope factor
Exposure Pathway Chemical Intake (mg/kg-day) (mg/kg-day) ·1
Incidental Ingestion
of Soil
Dermal Contact
with Soil
Inhalation of
Fugitive Dust
Overall Cancer Risk,
all pathways
bis(2-ethy lhexy 1)-
phthalate
bis(2-ethylhexyl)-
phthalate
bis(2-ethylhexyl)-
phthalate
• Incremental Lifetime Cancer Risk
b used oral slope factor for inhalation pathway
1.2x10"" 0.014
1.6 X 10-6 0.014
4.8 X 1()"10 0.014b
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ILCR'
1.7 X 10-10
2.2 X 10-8
6.8 X 10-12
2.2 X 10"8
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Exposure Pathway
Incidental
Ingestion of Soil
Dermal Contact
with Soil
Inhalation of
Vapor-Phase
Chemicals
Inhalation of
Fugitive Dust
Table 9. Hazard Indices Associated with Potential Exposures
Trench Area, National Starch and Chemical Company
Chronic Daily
Intake Reference Dose
Chemical (mg/kg/day) (mg/kg/day)
acetone 3.4 X 10-10 0.1
2-butanone 9.8 X 10-12 0.05
benzoic acid 1.0 X 10"9 4
bis(2-ethylhexyl)phthalate 3.4 X 10-8 0.02
Total Hazard Index
acetone 7.4x10.,. 0.1
2-butanone 2.2x 10·• 0.05
benzoic acid 2.2 X 10"7 4
bis(2-ethylhexyl)phthalate 4.4 X 10-6 0.02
Total Hazard Index
acetone 2.5 X 10-4 0.1·
2-butanone 2.5 X 10-6 0.09
acetone 1.4 X 10-11 0.1'
2-butanone 3.9 X 10-13 0.09
benzoic acid 4.1 X 10-11 4•
bis(2-ethylhexyl)phthalate 1.4 X 10"' 0.02'
Total Hazard Index,
Inhalation
Overall Hazard Index, all
pathways
'used oral RID for inhalation pathway
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Hazard Quotient
3.4 X 10"9
2.0 X 10-10
2.6 X 10-10
1.7 X 10-6
1.7 X 10-6
7.4 X 10'7
4.3 X 10-8
5.6 X 10-8
2.2 X 10-4
2.2 X 10-4
2.5 X 10·3
2.8 X 10"5
1.4 X 10-10
4.4 X 10-12
1.0 X 10-11
6.8 X 10-8
2.6 X 10·3
2.8 X 10"3
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References
Gas Research Institute (GRI), 1988. Management of Manufactured Gas Plant Sites, Volume ID, Risk Assessment.
GRI-87 /0260.3.
McKone, T.E., 1990. Dermal Uptake of Organic Chemical From a Soil Matrix. Risk Analysis, Vol. 10, 407-419.
The Merck Index, 1989. S. Budavari, M.J. O'Neil, A. Smith, P.E. Heckelman, eds. Merck & Co., Inc. Rawway,
NJ.
National Council on Radiation Protection and Measurements (NCRP), 1984. Radiological Assessment: Predicting
the Transport, Bioaccumulation, and Uptake by Man of Radionuclides Released to the Environment. NCRP
Report No. 76.
National Toxicology Program (NTP), 1982. Carcinogenesis bioassay of di-(2-ethylhexyl)phthalate (CAS No. 117-
81-7) in F344 rats and B6C3F, mice (feed study). NTP Tech. Rep. Ser. TR No. 217, NTP, Research Triangle Park,
NC.
Paradowski, RE., 1991. "Worker Exposure at Trench Area, Cedar Springs Road Plant, National Starch and
Chemical Company". Letter to M. Sturdevant, 25 July 1991.
United States Environmental Protection Agency (EPA) 1986. Superfund Public Health Evaluation Manual. EPA
540/1-86/060.
United States Environmental Protection Agency (EPA) 1989a. Risk Assessment Guidance for Superfund, Volume
1: Human Health Evaluation Manual (Part A). EPA/540/1-89/002.
United States Environmental Protection Agency (EPA), 1989b. Exposure Factors Handbook. EPA/ 600 /8-89 /043.
United States Environmental Protection Agency (EPA) 1990. National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). 40 CFR, July 1, 1990, U.S. Government Printing Office, Washington, D.C.
United States Environmental Protection Agency (EPA), 1991a. Health Effects Assessment Summary Tables,
Annual FY-1991. OERR 9200.6-303(91-1).
United States Environmental Protection Agency (EPA), 1991b. Risk Assessment Guidance for Superfund,
Volume 1: Human Health Evaluation Manual, Supplemental Guidance, "Standard Default Exposure Factors."
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