NCD991278953_19951018_National Starch & Chemical Corp._FRBCERCLA RD_Natural Degredation Treatability Study Work Plan OU-4-OCR

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NATURAL DEGRADATION TREATABILITY STUDY
WORK PLAN
FOR THE
FOURTH OPERABLE UNIT
NATIONAL ST ARCH AND CHEMICAL COMPANY SITE
CEDAR SPRINGS ROAD
SALISBURY, NORTH CAROLINA
Prepared by:
National Starch & Chemical Company
10 Finderne Avenue
----.f''y.,-water, New Jersey 08807
Ray Paradowski
Plant Manager & Project Coordinator
Appmved, d 0,(-zi'°~ Date: fa 11/ ~/V--,
Abu Alam
Project Director
•,, • ·1 • ( \ .\ j I i'1 • ,,
Approved: 1\i( '1(1.t\., /:__,._-)'\l-,,k'-'.t·•"
Richard Franklin
Project Health and Safety Officer
Approved: :Jzk/~ .~/
Michael Ford
Project Environmental Engineer
Approved: Date:
Kenneth Kluttz
Field Operations Coordinator
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1.0
2.0
3.0
4.0
TABLE OF CONTENTS
INTRODUCTION . . . . . . . . . . . . . . . . ....................... 1
1. 1 Purpose and Organization of Work Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Site Location and Description . . . . . . ... 1
1.3 Site History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 5
1 .4 Administrative History . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 6
1. 5 Nature and Extent of Soil Contamination . . . . . . . . . . . . ..... 7
1.6 Surface Water Hydrology ........................................ 18
1. 7 Geology and Hydrogeology . . . .................... 22
1.8 Work Plan Contents . . . . . . . . . . . . .......................... 23
REMEDIAL DESIGN/REMEDIAL ACTION (RD/RA) WORK PLAN ........... 25
2.1 Project Objectives . . . . . . . . . . ........... 25
2.1.1 Natural Degradation Treatability Study Objectives ................. 25
2.1.2 Data Quality Objectives . . . . . . . . . . . . . . . . . . . ... 26
2.2 Project Scope of Work .... 26
2.3 Description of Natural Degradation Process . . . . . . . . . . . . . . . . . . . . . . ... 28
2.4 Description of the Treatability Study Experiments and Procedures . . . . . . . 28
2.4.1 Soil Plots and Soil Gas Monitoring Wells . . . . ... 28
2.4.2 Measurements of Performance .. 35
2.4.3 Soil Sampling .. 36
2.4.4 Soil Gas Monitoring . . . . . . . . . . . . . . . . . . ................ 37
2.5 Project Deliverables ............................................. 39
2.5.1 Progress Reports .......................................... 39
2.5.2 Natural Degradation Treatability Study Reports ............... 39
2.6 Residuals Management . . . . ............. 39
PROJECT ORGANIZATION AND RESPONSIBILITY..... . 41
3. I Project Organization And Management Plan . . . . . . . . . . 41
3.1.1 Plant Manager and Project Coordinator .. 43
3 .1.2 Project Director ........................................... 43
3. 1.3 Project Health and Safety Officer .............................. 44
3.1.4 Project Environmental Engineer ............................... 44
3.1.5 Field Operations Coordinator ................................. 45
3.1.6 Quality Assurance Officer .................................... 46
3 .1. 7 Laboratory Directors/Laboratory Coordinators .................... 46
PROJECT SCHEDULE ............................................... 48
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List of Figures
Figure
1-1
1-2
Description
Site Location Map .......................................
Site Map ............................................ .
Page
2
4
1-3 Distribution of 1,2-Dichloroethane in Soil Samples, Area 2 . . . . . . . . . . . . . 9
1-4 Distribution of 1,2-Dichloroethane in Soil at Wastewater Treatment Lagoons . . 10
1-5 Soils Cross Section Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
1-6 Soil Profile A-A' with 1,2-Dichloroethane Concentrations in Soil at Area 2 13
1-7 Soil Profile B-B' with 1,2-Dichloroethane Concentrations in Soil at Area 2 14
1-8 Soil Profile C-C' with 1,2-Dichloroethane Concentrations in Soil at Wastewater
Treatment Lagoons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
1-9 Distribution of Acetone in Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
1-10 Location of Monitoring Wells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
1-11 Groundwater Elevation Contour Map, Bedrock Wells . . . . . . . . . . . . . . . . . 20
1-12 Groundwater Elevation Contour Map, Saprolite Wells . . . . . . . . . . . . . . . . 21
2-1 Location of Soil Plots and Soil Gar Monitoring Wells . . . . . . . . . . . . . . . . . 30
2-2 Metal Box Construction Detail . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
2-3 Soil Plot Detail . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
2-4 Soil Gar Monitoring Well Construction Detail . . . . . . . . . . . . . . . . . . . . . 33
3-1 Project Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
4-1 Project Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
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List of Tables
Table
1-1
2-1
2-2
Description
Range and Frequency of Detection of Organic Compounds Found in Soil
Summary of Treatment and Monitoring Schemes for Different Soil Plots
Summary of Soil Analytical Parameters and Methodologies ............ .
Page
11
35
38
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1.0 fNTRODUCTION
1. 1 Purpose and Organization of Work Plan
This Work Plan is prepared to fulfill requirements of the United States Environmental
Protection Agency's (US EPA 's) Unilateral Administrative Order and the Statement of
Work (SOW) for the Remedial Design/Remedial Action (RD/RA) for Operable Unit 4
(OU4) at the National Starch and Chemical Company's (NSCC) Cedar Springs Road Plant
site in Salisbury, North Carolina. The Work Plan is prepared to provide the-framework for
conducting the RD/RA for OU4 at this site and presents the technical details of studies and
investigations to be conducted as required by the Unilateral Administrative Order. In the
SOW the USEPA has identified the required components of the RD/RA for OU4 at this site
and provided specific work tasks to be included in the Work Plan. A key US EPA
requirement in the specified work tasks for OU4 is preparation and implementation of a
Natural Degradation Treatability Study. This Work Plan provides the details for planning,
organizing and implementing the various work tasks, including the Natural Degradation
Treatability Study, as outlined in the USEPA's SOW.
Thi_s Work Plan is comprised of four sections and three separate appendices. Section one of
the Work Plan presents and discusses (a) Site Background Information, and (b) Work Plan
contents. Site Background Information includes Site Location, Site History, Administrative
History, Nature and Extent of Soil Contamination, Surface Water Hydrology, and Geology and
Hydrogeology. Section two presents the Remedial Design/Remedial Action (RD/RA) \Vork
Plan including details of the Natural Degradation Trcatability Study. Section two also
contains Project Objectives, Project Scope of Work, Description of the Natural Degradation
Process, Description of the Natural Degradation Treatability Study Experiments and Procedures,
Project Deliverables and Residuals Management. Section three presents Project Organization and
Responsibility and Section four presents Project schedule.
Appendix A presents the Field Sampling and Analysis Plan (FSAP). Appendix B presents Quality
Assurance Project Plan (QAPP) and Appendix C contains the Health and Safety Plan (USP).
1.2 Site Location and Description
The NSCC site, also referred to as the Cedar Springs Road Plant site, is located in Rowan
County, North Carolina, approximately 5 miles south of the City of Salisbury. Salisbury is
approximately 40 miles northeast of Charlotte, North Carolina along Interstate 85. Figure 1-1
illustrates the location of the site.
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MILL
BRIDGE
GRANTS
DAVIDSON
COUNTY
--------
l
COUNTY
KANNAPLOIS CABARRUS COUNTY 7
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SCALE:
0 8
FIGURE 1-1
SITE LOCATION MAP
NATIONAL STARCH
AND CHEMICAL COMPANY
SALISBURY. NC
N
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16 MILES
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Land use of the areas immediately adjacent to the site is a mixture of residential and industrial
developments. An industrial park is located on the east and south sides of the site. 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 corner of the site. A housing development, Kings Forest, is adjacent to the north
side of the site. A second development, Stonybrook, lies across Airport Road on the northern
side of the site.
· The NSCC site is approximately 500 acres in size. OU4 at the NSCC site comprises the 1,2-
dichloroethane (1,2-DCA) contaminated soils located in Area 2 of the Plant and wastewater
treatment lagoons located south of the Plant Operations area. The chemical Production Plant
and the wastewater treatment lagoons are located in the southwestern portion of the property.
The portion of the· NSCC facility known as Area 2 is located in the northeast portion of the
Plant Operations area. The wastewater treatment lagoons are located in the south and
southwest portion of Plant Operations area. Figure 1-2 illustrates these facilities at the NSCC
site.
The Northeast Tributary crosses the NSCC property paralleling Cedar Springs Road and
passes within 50 yards of the front of the Plant Operations Area. This tributary receives
runoff from an industrial complex on the east side of Cedar Springs Road, from Cedar Springs
Road itself, and from the Southmark Industrial Park located to the south. Areas on both sides
of the stream contribute runoff throughout its reach. The watershed boundary is shown in
Figure 1-2. From the Area 2 of the Production Plant, the stream flows for approximately
6,000 feet before joining with Grants Creek located to the north. Grants Creek flows
approximately 12 miles beyond NSCC property where it joins with the Yadkin River
approximately 2 miles downstream from the water supply intake for the City of Salisbury.
The Northeast Tributary receives discharge from the W. A. Brown Plant through a National
Pollutant Discharge Elimination System (NPDES) permit. W.A. Brown is an industrial facility
located on the east side of Cedar Springs Road. The discharge point is a pipe located on the
east bank of the Northeast Tributary, downstream of the NSCC Plant Operations area
(Figure 1-2).
Area 2 of the NSCC facility consists of the reactor room, the tank room, raw material bulk
storage facilities, warehouse tanks, diked storage tanks, and roadway. The wastewater from
Area 2 consists of water from washing/rinsing of reactors and line (piping, pumps, etc.)
flushing. These cleaning operations occur between processing of different products. The
waste stream discharge includes reactor and feed line wash and rinse, which contains trace
amounts of organic and inorganic compounds in a water solution.
The wastewater from Area 2 is sent to the Plant's Wastewater Pre-Treatment System before
being discharged to the City of Salisbury's Publicly Owned Treatment Works (POTW). The
existing Wastewater Pre-Treatment System is composed of two Lagoons ( Lagoons No.1 and
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+
+
AIRPORT
ROAD
500 0 500
P"'-! ---250 750
GRAPHIC SCALE: 1'=500'
+ + +
Site Map
FIGURE 1-2
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No.2) for storing untreated wastewater ( Lagoon No. I is aerated), a Primary Treatment
System for solids removal, a Biological Reactor ( Lagoon No.3 ) for stabilizing soluble
organics in the wastewater and a Lagoon ( Lagoon No.4) for storing secondary effluent prior
to discharge into the City of Salisbury sewer system.
The Plant's Wastewater Pre-Treatment System has been upgraded to allow Pre-Treatment and
discharge of combined groundwater from OUl and plant effluent. This system is now treating
both OUl groundwater and plant wastewater and is called the Combined Pre-Treatment
System.
The Combined Pre-Treatment System is designed to treat two OU I groundwater streams
(trench area and plume periphery groundwater) in addition to the Plant's wastewater. Trench
area groundwater will be treated to remove metals and organic compounds before being
discharged to the existing Lagoon No. I where it will combine with the Plant's wastewater.
Lagoon No. I provides equalization and pH adjustment to the wastewater. Flow from Lagoon
No. I is pumped to the Primary Treatment System where solids are removed by chemical
precipitation and settling in a Primary Clarifier. Overflow from the Primary Clarifier flows
into Lagoon No.2 for equalization and is transferred to the Biological Reactor ( Lagoon No.3 )
once a day. Following completion of treatment the treated effluent is decanted and pumped to
Lagoon No.4 for further aeration and storage before being discharged to the City's sewer for
further treatment at the POTW.
1.2 Site History
Construction of the Cedar Springs Road Plant began in 1970. The NSCC facility is primarily
a manufacturing plant for textile-finishing chemicals and custom specialty chemicals. Produc-
tion takes place on a batch basis and varies depending on demand.
Volatile and semi-volatile organic chemicals are used in producing manufactured goods at
NSCC, and acid and alkaline solutions are used in the manufacturing and cleaning processes.
Waste stream discharge includes reactor and feed line wash and rinse, which contains trace
amounts of organic and inorganic compounds in a water solution.
Terra-cotta (fired clay) waste lines were installed underground in Area 2 in 1974. The terra-
cotta lines from Area 2 to the Plant's wastewater pretreatment system were replaced by
overhead stainless steel piping. These were completed on February 15, 1993. All terra-cotta
lines in Area 2 have now been abandoned and replaced by overhead stainless steel lines.
Terra-cotta lines in Area 2 that are no longer in service have been disconnected and abandoned
in place by plugging the pipes with concrete. Based on NSCC's internal waste management
policies, all underground lines have now been replaced with above ground lines.
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Three wastewater lagoons were excavated and built during the period from 1969 to 1970 as a
part of the original Plant. The wastewater lagoons were unlined but were constructed in an
area of natural clay with a permeability in the range of 10-3 square centimeters per second
(cm2/s)_ From 1970 to 1978, wastewaters from the production facilities were pumped into
Lagoon No_2, In 1978, Lagoon No.1 was put into service and Lagoon No.3 was lined with
concrete. The untreated waste stream was directed through these three pretreatment lagoons,
which combined equalization, settling, and surface aeration, prior to controlled discharge to
the City of Salisbury POTW. In 1984, Lagoons No.1 and No.2 were excavated and lined with
concrete.
A fourth lagoon (Lagoon No.4) was installed in 1992 for pretreatment of plant effluent and
contaminated groundwater as part of the Remedial Action (RA) for OUl.
1. 3 Administrative History
Based on the RI/FS, the USEPA issued the Record of Decision (ROD) (USEPA, 1988b) for
the site on September 30, 1988. The ROD divided the site into two operable units. OUl
consists of contaminated groundwater and OU2 consists of trench area soils and surface
water/sediments in surrounding tributaries. The selected remedy in the ROD for OUl
includes a groundwater interception and extraction system installed down gradient of the
trench area that is capable of effectively remediating the contaminated groundwater. The
extracted groundwater will then undergo pre-treatment at the Plant and will then be discharged
to the City of Salisbury's POTW.
The Final Design Report (IT, 1990b) describes the remedial design for OU 1. The Remedial
Design/Remedial Action (RD/RA) for OUl is currently being performed in accordance with
the USEPA's Unilateral Administrative Order effective July 27, 1989.
In accordance with the OUl ROD, IT performed a Supplemental RI/FS report for OU2. IT
completed the Supplemental RI report in May 1990 (IT, 1990a). The OU2 RI/FS concluded
that the surrounding surface water tributaries are not being impacted by contaminants from the
trench area subsurface soils or the groundwater plume; however, volatile organic compounds
(VOC) were detected in the Northeast Tributary from an unknown source. The USEPA issued
the ROD for OU2 on September 30, 1990 (USEPA, 1990). This ROD is currently being
implemented. The selected remedy for OU2 was no further action beyond monitoring because
contaminants from the trench area soils are released into the contaminated groundwater
aquifer, which will undergo remediation in accordance with the OU 1 ROD.
Surface water/sediment (bed material) sampling was conducted during the first and the
Supplemental RI for OU2. However, the source of contaminants detected in the Northeast
Tributary was not determined. The OU2 ROD, therefore, established the Northeast Tributary
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as OU3. On December 4, 1991, the USEPA issued written notification that an "RI/FS must
be conducted to determine the source, nature, and extent of contamination entering the
Northeast Tributary" (USEPA, 1991a). The OU3 RI was completed on June 2, 1993 and the
OU3 FS was completed on June 21, 1993 in accordance with the original Administrative
Consent Order (USEPA, 1986).
USEPA issued the ROD for OU3 on October 7, 1993 (USEPA, 1993a). This ROD is
currently being implemented. The selected remedy in the ROD for OU3 includes groundwater
extraction wells to remove contaminated groundwater; air stripping to remove volatile
contaminants from the extracted groundwater; discharge of treated groundwater to the City of
Salisbury's POTW system·; long-term monitoring of groundwater, surface water, and
sediment; and institutional controls (deed restriction).
The USEPA stated that "the principal flaw of the June 1993 OU3 FS Report is the limited
evaluation presented in the text on the 'active' remedial technologies to address the
contamination in the soil in Area 2 and the wastewater treatment lagoon area" (USEPA,
1993b). Therefore, as part of the selected remedy for OU3, a fourth operable unit (OU4) was
decreed for this site. USEPA declared that the components of OU4 shall be the contaminated
soils associated with Area 2 and the wastewater treatment lagoon area. The April 1992 OU3
RI/FS work plan was deemed applicable as the work plan for OU4 (USEPA, 1993a and c).
The June 2, 1993 OU3 RI Report was also deemed applicable as the OU4 RI report.
However, USEPA directed NSCC to prepare and submit a separate Feasibility Study Report
for OU4. In accordance with USEPA instructions the FS Report for OU4 was prepared and
completed in June 20, 1994.
USEPA issued the OU4 ROD on October 31, 1994 and a Draft Consent Decree and a Draft
Statement of Work for OU3 and OU4 during December 1994. On October 29, 1995 USEPA
issued a Unilateral Administrative Order and Final Statement of Work for OU3 and OU4.
1.4 Nature and Extent of Soil Contamination
This section provides a brief summary of the nature and extent of contamination in the soils
associated with Area 2 and the wastewater treatment lagoons, and the sources of this
contamination. Soil investigations were conducted to establish the levels of contamination in
the vadose zone and determine whether the soils could be contributing contamination to the
groundwater. Soils used as fill in the parking lot area were investigated as a possible
contaminant source during the Phase I OU3 RI. During the Phase II OU3 RI, samples were
collected from areas where the groundwater screening investigation indicated that groundwater
contamination was highest. Additionally, several locations where samples exhibited the
highest levels of contamination were re-sampled for a full chemical characterization under
Level IV Contract Laboratory Program (CLP) protocol. Details of the sample selection, the
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screening results, and results of the 1,2-dichloroethane (DCA) confirmation analyses for the
soil screening and confirmation survey are all provided in the Phase II OU3 RI report (IT,
1993b).
Fill material used for the parking lot area was sampled and analyzed prior to its placement in
1988. The concentration of 1,2-DCA in the sample was 533 parts per billion (ppb) (IT,
1992). Samples collected during the Phase I OU3 RI indicate that 1,2-DCA is still present in
parking lot area soil. Concentrations of 1,2-DCA were 220 ppb and 370 ppb. Six other
VOCs were detected in the parking lot samples, including acetone (250 and 200 ppb),
2-butanone (60 and 120 ppb), and toluene (19 and 23 ppb).
Phase II results for confirmed soil 1,2-DCA concentrations at Area 2 and the wastewater
treatment lagoons are shown in Figures 1-3 and 1-4. The concentrations shown in Figures 1-3
and 1-4 are the highest values from each soil boring in ppb. The concentration ranges and
frequency of detection of organic compounds are provided in Table 1-1.
Soil sampling conducted by IT during the Phase II RI for OU3 was restricted in both the plant
and lagoon areas due to the presence of the plant building and lagoon structures. Sampling of
soil extended up to the edge of these structures. The scope of the OU3 RI did not include
sampling underneath the plant building and lagoons. However, two soil samples were
collected by NSCC from underneath the abandoned process sewer lines (terra-cotta piping) and
floor drain sumps during abandonment/grouting of the lines and replacement with overhead
lines. The depth of the samples was approximately 3 feet below the floor surface. These
samples were analyzed by IT for 1,2-DCA in the IT field laboratory. These samples were
found to contain 332,449 ppb and 4,288 ppb of 1,2-DCA. These data have been incorporated
into Figure 1-3.
From examination of the data presented in Figure 1-3, there are three areas where soil
contamination is concentrated in Area 2:
1.
2.
An elongated area northwest of the main plant exhibits very high concentra-
tions, between 5.5 and 20 feet deep.
A broad area northeast of the loading docks and warehouse area exhibits high
concentrations between 3. 3 and 5. 5 feet deep.
3. The high level of 1,2-DCA from samples collected underneath the abandoned
terra-cotta lines inside the building confirmed contamination in the soil
underlying the lines.
Cross-section lines A-A' and B-B' (Figure 1-5) indicate the locations of vertical contamination
profiles at Area 2. Figures 1-6 and 1-7 show the vertical distribution of 1,2-DCA in soils at
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1----
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----
--
1----0 100
APPROXIlvtATE SCA_LE-'-(1-'-l) __
200 300 400
C:1PROJECTSCDRSPRI:'<G\OU4NDTS·F1Gl-3
---
500
-- -- - - -
NOTE
1-Samples collected by
NSCC from underneath
abandoned terra cotta
process sewer lines
during removal (replaced
with o~rhead lines).
Samples analyized for
1,2-0CA at I1's on-site
laboratory during
PHASE II for OU3
LEGEND
- -
[ill SOIL BORING LOCATION SHOWING MAXIMUM
»:❖ 1,2-DCA CONCENTRATION (ppb) AND
(DEPTH (It)) OF MAXIMUM CONCENTRATION
....__ ·too l,2-DCA CONCENTRATION CONTOUR
,
1 WASTE-WATER LINE, ARROW INDICATES
DIRECTION OF FLOW
NOTE: Confirmation data supplemented by
soil screening data
FIGURE 1-J
DISTRIBUTION OF 1,2-DCA
IN SOIL SAMPLES, AREA 2
PHASE II OU3 RI
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
-
--

-
-

-
-

-
--·--

-

-

-
----

-
I·.
i •.· .. :·. l : . ::•····.••, .. :• .. :.••·••.•···
"_, DRIVEWAY '-• -----_,
--------------------------------'
WASTE-WA'TER: COLLECTION PIT J
.. ------·------PARKING
AREA
TO
LAGOON
3
--w -0 100
APPROXIMATE SCALE(fl) I I ,
200 300 400
SBLA-14 290(3.5)
SBLA-19
ND
SBLA-18
19000(7.!5)
I
l
~
/'
LAGOON2 1 ■ ~LA-03
\. ./ (7.5)
500
SBLA-08
31(1.5) ■
■ SBlA-09
21(3.5)
LEGEND
SOIL BORING S~NO 1,2-0CACX>NCENTRATION
■ (ppb) AND (DEPTH (I)) OF MA>OMUM
CONCENTRATION
j WASTE-WATER LINE. ARRCM'INOtCATES
' DIRECTION OF FLOW
ABANOONEO LINE
...
_/-. 1,2-DCA CONCENTIIA TION CONTOUR
10000
NO'TE: Coafomalion data suppkmutcd by
soil acrccning data.
Figure 1-4
DISTRIBUTION OF 1,2-DCA IN SOIL
AT THE WASTE WATER TREAThlENT
LAGOONS, PHASE II OU3 Al
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
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Compound
I, 1,2-Trichloroethane
1,2-Dichloroethane
2-Butanone
Acetone
Bromodichloromethane
Chloroform
Delta BHC
Dibromochloromethane
Tetrachloroethene
Toluene
Total Xylenes
Trichloroethene
Vinyl Chloride
Table 1-1
Ranges and Frequency of Detection
of Organic Compounds Found in Soil
Phase I and II OU3 RI
National Starch and Chemical Company
Salisbury, North Carolina
Range (ppb) Frequency of Detection
I 1-17 2
2-1600000 42
3-42 30
22-4000 40
1-220 7
2-900 17
22 1
3-31 5
2 2
1-3 100 12
1 1
3 I
32-190 12
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CHAIN LINK FENCE ----. NORlliEAST TRIBUTARY ___ ..,_
A
SBA2-0S SBA2-15
SBA2-10
SBA2-20
I
SBA2-13 l
-19 ~-14 ■ SBA2\-
16
SBA2-08 SBA2-06
BA2-01
SBA2-12
B'
O<'WEWAY __ -~-13
-

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._-_-_-_.. I
S8LA z I PAAONG
SBLA-04 ~-
1
-: N£A : C' · f SSlA-14 1 j
· ~-----· -s~-11
C SSlA-23 ~ •SBLA-10
L a a ii ~•58lA-OS
SBlA-24 ;.....;~--''-■ SBlA-01
SBLA-22 -15
11 .. : I =., ~.. -.J SBI.A-18
LAGOON 1 LAGOON 2
----------
SBI.A-08.
LEGEND Figure 1-5
■ SOL BORJNG LOCATION
A A' LJ CROSS SECTION LOCATION
APPROXJMATE SCALE (f'I)
l,.r->..-
0 l 00 200 300 400 500
SOILS CROSS SECTION
LOCATION MAP
NA T/ONAL STARCH AND
CHEMICAL COMPANY
SALISBURY N.C.
--
775
770
"' 0 0 !c.
C 765 • 0 ~ U)
" 0
0 -,; 0 760 U)
-,; ~ ~
~ E 755 •• e a. a. <(
-
A
-
-
LEGEND
m
(410)
(1393 *)
-
[SBA2-07]
I I I I I
-5 -
c.lprojects\ah;prirg\oo4ruts1Jig 1-6 pre
----
Top of Grade
[SBA2·07J ' /,/
~
/(110)
I
Location of soil sample
1,2-DCA laboratory analytical results in ppb
1,2-DCA field analytical results in ppb
Soil boring ID#
Bedrock/Soil interface
1,2-DCA concentration contour line (ppb)
-
[SBA2-19J
-
- -
I ~ 0 0 0 0 0
i 'l, r p,001
Horilontal Scale (ft.)
' 0 ' "'
- -
[SBA2·20J
r11,6 0,0001
----
A'
[SBA2-12J
0 0 ~
'l, "'
.
r129a·1
(380)
FIGURE 1.S
SOIL PROFILE A-A' WITH
1,2-DCA CONCENTRATIONS
IN SOIL AT AREA 2
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY, NC
--
775
770
765
760
755·
750
745
---- -- -- -- -
B
772 7 (SBA2-11]
(SBA2-20]
770 (SBA2-09]
'fil' g
C • 0 ~
V)
" 0
0
" u V)
" u
'E ~
~ E .,, e a. a. -<
765
760
755
750
745
740
LEGEND
□ (17310 .)
(170)
[SBA2-11)
11rl'>
ir1'>
1,600,0 0)
(290.~)
# 00 '
(53,000)
Bedrock
Location of soil sample
1,2-DCA field analytical results in ppb
1,2-DCA laboratory analytical results in ppb
Soil boring ID#
___ Y . ----Groundwater elevation
1,2-DCA concentration contour line in ppb
c:\projects\cdrspring\ou4ndts\fig1 -7
(SBA2-08]
II V13ao>
0 0 0 0 0 0 :e, ~
(330)
''!,o
(1300)
Horizontal Scale (ft)
0 30
---
2-06) (SBA2-04)
(13.)
Bedrock
60
--
Perched
Water Table
FIGURE 1-7
-
Northeast
Tributary
I
SOIL PROFILE B-B' WITH
1,2-DCA CONCENTRATIONS
IN SOIL AT AREA 2
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY, NC
-
B'
772
770
765
760
755
750
745
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Area 2 along cross-sections A-A' and B-B', respectively. Unsaturated soils at Area 2
exhibited a pattern of 1,2-DCA concentrations decreasing downward. Soils at Area 2 and the
main building are capped by concrete and asphalt surfaces; therefore, recharge or infiltration
through the soil at this location is extremely restricted.
In the area around the wastewater treatment lagoons, 1,2-DCA contamination in soil is much
less widespread. Cross-section line C-C' (Figure 1-8) shows the vertical distribution of 1,2-
DCA in soils at the wastewater treatment lagoons. Where unsaturated soils exhibit 1,2-DCA
concentrations, the levels either increase downward towards the water table or exhibit
nondetectable levels until the water table is reached. The highest levels are found in soils near
the northeast corner of Lagoon 2 (Figure 1-4) just above the water table. The highest level of
1,2-DCA in soil at the lagoon area (19,000 ppb in SBLA-18) was collected where groundwater
exhibited a concentration of more than 660,000 ppb. Because the soils exhibit contaminant
concentrations much lower than the groundwater, contribution of 1,2-DCA from soils to
groundwater around the lagoon area is negligible.
The vertical pattern of soil contamination at the lagoon area is in stark contrast to the pattern
observed in the profiles for Area 2. The soil contamination profiles of Area 2 and the lagoon
area indicate that the vadose zone at the lagoon area is undergoing flushing/contaminant
reduction due to precipitation/infiltration (and thus driving contamination downward);
whereas, at Area 2, the impervious surfaces are effectively preventing flushing.
Acetone is widely distributed in soils around Area 2 and the wastewater treatment lagoons.
The distribution of acetone is shown in Figure 1-9. Around the wastewater treatment lagoons,
acetone distribution in soil appears to be very similar to the pattern of the 1,2-DCA in soil.
The highest concentrations of acetone (3,500 parts per million [ppm]) in the lagoon area soils
are found in the area where the highest concentrations of 1,2-DCA are found in soils. East of
Area 2, higher levels of acetone in soil appear to be similarly distributed as 1,2-DCA is in
soils.
Samples were collected from four soil borings for analyses of inorganic constituents where soil
contamination was found to be greatest during the Phase II soil screening survey. All levels of
metals found in the soil samples were either below the background levels or within one order
A:\OU4WKJ>LN.AA Page 15
-- ------
775
770
750
745
C
LEGEND
R □
(ND*)
(3.0)
(ND)
[SBLA-14]
~10 ~
c:'o.-ciect~nno\oU4rdtsVio 1-8
Location of soil samples
1,2-DCA Field concentration in ppb
1,2-DCA Laboratory concentration in ppb
1,2-DCA analyzed for but not detected
Soil boring ID#
Static groundwater level
1,2-DCA Concentration contour line in ppb
--
(ND)
Honzoc1al Scale (fl.)
' 0 30
- -
(SBLA-05(
(ND)
(ND)
(ND)
60
' '
-
Top of grade
' '
I
' '
--- -
C'
(SBLA-10]
(SBLA-11]
(ND)
FIGURE 1-8
SOIL PROFILE C-C' WITH
1,2-DCA CONCENTRATIONS
775
770
765
760
755
750
745
IN SOIL AT THE WASTEWATER
TREATMENT LAGOONS
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY, NC
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CHAIN LINK FENCE
LEGEND
■ SOIL BORING SHOWING ACETONE
CONCENlRATION (ppb)
... .._ __ / ACE1DNECONCEmRATION
100 .-/ CONTOUR (ppb)
APPROXlMAlE SCALE (fl) ~~""' ;;;;;;~~;;;;;;~~
!00 200 300 400 500
NORTHEAST
TRIBUTARY
FIGURE 1-9
DISTRIBUTION OF ACETONE
IN SOILS, PHASE II OU3 RI
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY N.C.
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of magnitude.
The metals detected are common trace elements in sulphide or oxide minerals common to
crystalline rocks found in the area of the facility. Thus, levels of metals found in soil samples
are considered to be derived from residual soil developing from the crystalline bedrock.
1.5 Surface Water Hydrology
Within the plant area, the Northeast Tributary has an average width of 3 to 4 feet and an
average flowing depth of 4 to 6 inches. The stream has a channel gradient of approximately
0.017 foot per foot (ft/ft). The stream receives runoff during moderate to heavy storm events,
resulting in increased discharge. During the winter, when storms are more frequent, the depth
of water in the stream channel is greater than during the summer months. During most of the
year, water has been observed in the stream channel downstream from the location of the
lagoons. The reach of the tributary upstream of the lagoons does not typically contain water,
but receives runoff after rainstorms from the adjacent grassy/wooded areas.
Water level data were collected during the groundwater screening investigation and from new
monitoring wells that were installed as part of the Phase II OU3 RI (November 1992 to Febru-
ary 1993) (IT, 1993b). All monitoring wells have been surveyed and their locations are
referenced to a plant coordinate system, and horizontal and vertical positions are recorded to
an accuracy of 0.01 foot. Locations of monitoring wells sampled or used for water level data
as part of the OU3 RI are shown in Figure 1-10. Water level data from the Phase II OU3 RI
(tabulated in the OU3 RI report [IT, 1993b]) are contoured in Figures 1-11 and 1-12. Based
on the water level data from the Phase II OU3 RI, groundwater is clearly discharged to the
stream throughout the investigated reach of the stream. Therefore, the Northeast Tributary is
a gaining stream, receiving discharge from groundwater along its entire reach.
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1050
' '-
'
750 :-
450
150
-150 -
-750
-650
• NS-OIA
'
,
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,
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'
, , ,
I ----
, , , ,
_I L-c:..::..'.' -
N~~l"2-.l --,
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-350
JL _J L
' NS-39/40 • ' ' NS-41/42, 'E=]*' : LAG<X>N / , Jt(N
/ 2 / I
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,
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1 ,,*N -14'
,, .... ' NS-33/34 :. ' ' I' ' -50
l---i -_, I I
550
NS-35 •
LEGEND
MONITORING WELL LOCATION
ANO IDENTIFICATION
FENCE
APPROhl~IATE SCALE (!I)
'"" '" '"" '""
IGURE 1-10
LOCATION OF MONITORING
WELLS, PHASE II OU3 RI
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY N.C.
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1050 -
750 -
-150 -
-450 -
----.\--,~---:::-:=..-.::.::: --;----" :::::-= ,,,.,,..,..,,..-,,"
/ ,
r=
I
L -_J •
LAGOON LAGOON U--i-t-----;----t-t----2
I , '\~ --~--7 __ ,, 250
,
'
,
• 768
I I
* 755
550
' '
SCALE(ft)
100 HO )00 ...
LEGEND
• MONllDR!NG WELL LOCATION
767 LOCATION AND GROUNDWAlER
ELEVATION {ft MSL)
---FENCE
FIGURE 1-11
GROUNDWATER ELEVATION
CONTOUR MAP, BEDROCK
WELLS MARCH 1, 1993
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY N.C.
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\
1050 -
750 -
450 -' 11 763 -· 11
150 -II
II
761JI
,1 -
-450 -
-750 I
-650
c: lfoiccts\ ,m,:\ou4mhAfi,o:l-!12 e
I_ II 11
II 11
II 11
-350 -50
--7
' ' '
250
---::..---
~ :;!
~ 0 z o! ~ ~
~ Cl "' u
550
SCALE(ft)
"" '"" '"" '""
LEGEND
• MONI10RING WELL LOCAllON
767 AND GROUNDWAlER
ELEVA110N (ll, MSL)
--FENCE
FIGURE 1-12
GROUNDWATER ELEVATION
CONTOUR MAP, SAPROLITE
WELLS MARCH 1, 1993
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY N.C.
~00
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1.6 Geology and Hydrogeology
At the NSCC site, a thick mantle of residual soil extends from the ground surface to the
bedrock. The soils are saprolites, clay-rich residual soils derived from intense weathering of
the crystalline bedrock that retain the structural fabric of the parent materials below the
oxidation profile. The soil weathering profile generally has its greatest thickness beneath the
ridges (IT, 1990a) and is thinner at the creeks. However, recent drilling along the Southwest
(OU! monitoring wells) and Northeast Tributaries during the Phase II OU3 RI (IT, 1993b)
indicates that weathering of bedrock at some locations near the streams extends to depths
between 80 and 100 feet. During collection of groundwater screening samples along the
eastern bank of the Northeast Tributary, north of the plant entrance during the Phase II OU3
RI, a layer of very stiff clay prevented the sampler from penetrating below about 7 to 15 feet.
During drilling in this area, competent bedrock was located at 49 feet.
Soils at the NSCC facility are silty to sandy clays grading from deep red-brown near the
surface to orange-yellow near the bedrock. Residual soils exhibit increasing amounts of sand-
sized relict mineral grains below the oxidation horizon and closer to the bedrock. Soil fissures
near the water table are filled with goethite, presumably derived from the weathering of the
iron-bearing minerals present in the parent rock. The saprolite is derived from the intense
chemical weathering of the crystalline bedrock, and there appears to be a complete gradation
from saprolite to friable weathered bedrock to fractured bedrock to sparsely fractured bedrock.
No confining layer is apparent between the saprolite and bedrock. Based on these
observations, the contact between saprolite and bedrock appears to be gradational. Therefore,
these two lithologic units are hydraulically interconnected, and there is little or no impedance
between these two hydraulic systems.
Depths to the top of competent bedrock have been determined from drilling logs (IT, 1988a,
1990b; 1993b). Thickness of the soil mantle varies across the site as shown in the Final
Design Report (IT, 1990b) and final Phase II OU3 RI report (IT, 1993b). It appears that the
plant area occupies a structural high and that the bedrock surface slopes steeply away from the
plant to the east and more gently to the north. Rock core records show that the upper 10 to 15
feet of bedrock is deeply weathered and friable. Bedrock begins to appear nonfriable and fresh
15 to 25 feet below the bedrock saprolite interface. However, fractures continue to be
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frequent and fracture surfaces often exhibit oxidation staining to depths of 40 to 100 feet below
the bedrock saprolite interface. Fracture frequency diminishes downward from the bedrock
saprolite boundary (IT, 1990b).
Hydrogeological conditions at the NSCC site have been investigated as part of the OU 1 and
OU2 Ris (IT, 1988a), the supplemental OU2 RI (IT, 1990a), and the remedial design
investigation (IT, 1990b) and are provided in the Phase II OU3 RI report (IT, 1993b).
Additional data provided from the Phase II OU3 RI supplemented the existing soil thickness
data, bedrock fracture intensity and frequency data, and water level data. As shown in the RI
report for OU3 (IT, 1993b), water levels from the OU3 RI monitoring wells indicate that
hydraulic heads decrease from both the east and west toward the stream and toward the north
along the stream; therefore, the Northeast Tributary acts as a groundwater divide and receives
groundwater discharge along its entire reach. As shown in Figures 1-11 and 1-12, the
configuration of the groundwater elevations for the saprolite and bedrock zones are similar in
th is respect.
Hydraulic conductivity of the saprolite materials ranges from 3.35 to 0.72 feet per day
(ft/day), with a geometric mean of 1.75 ft/day (IT, 1990b). Values for hydraulic conductivity
for the bedrock determined during the OU 1 remedial design/remedial action by investigation
packer tests (IT, 1990b) ranged from less than 0.01 ft/day to 1.13 ft/day. Hydraulic
conductivity of the most highly fractured, and intensely weathered portion of the bedrock
(e.g., at well P-02) could not be measured. Adjective transport rates estimated for the
saprolite ranges from about 80 feet per year (ft/yr) in the area of the lagoons, then slow to
about 27 ft/yr as the more shallow gradient is encountered near Area 2. Hydraulic
conductivities for the upper portions of the bedrock overlap the value for the saprolite;
therefore, groundwater should be assumed to be moving at similar rates as in the saprolite.
1. 7 Work Plan Contents
This Work Plan consists of a Natural Degradation Treatability Study along with a Field
Sampling and Analysis Plan, Quality Assurance Project Plan, and Health and Safety
Plan. The Natural Degradation Treatability Study discusses the procedures and methods to
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be used to implement and carry out the treatability study as required by the OU4 ROD, the
Unilateral Administrative Order, the Statement of Work to substantiate that natural
degradation is occurring. The Natural Degradation Treatability Study Work Plan includes
project objectives, project scope of work, and description of the Natural Degradation
Treatability Study. The Project Organization and Responsibility, and Project Schedule are
also included in this Work Plan.
The Field Sampling and Analysis Plan provides the data gathering methods to be used during
the treatability study. It includes sample locations and frequency; sample designation;
sampling procedures including equipment to be used, sample handling and shipping methods;
soil gas monitoring procedures; moisture and nutrient addition procedures; and reporting
procedures.
The Quality Assurance Project Plan (QAPP) provides the project objectives; project
organization and responsibility; QA/QC Procedures; functional activities such as drill rig and
equipment decontamination procedures; and equipment calibration procedures. The QAPP also
provides analytical methods, personnel qualifications, sampling procedures, sample custody,
analytical procedures, and data reduction, validation and reporting procedures.
The Health and Safety Plan provides a health and safety risk analysis, a description of the
personal protective equipment, medical monitoring, and provisions for site control.
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2.0 REMEDIAL DESIGN/REMEDIAL ACTION (RD/RA) WORK
PLAN
2.1 Project Objectives
The objectives of the RD/RA at OU4 are follows:
I. Prevent or mitigate the continued release of hazardous substances, pollutants
and contaminants to the overburden and bedrock aquifers;
2. Prevent or mitigate the continued release of hazardous substances, pollutants
and contaminants at the Site to surface water bodies and sediments;
3. Eliminate or reduce the risks to human health associated with the direct contact
with hazardous substances, pollutants or contaminants within the Site;
4. Eliminate or reduce the risks to human health from inhalation of hazardous
substances, pollutants or contaminants from the Site;
5. Eliminate or minimize the threat posed to human health and the environment
from current and potential migration of hazardous substances in the soils at the
Site;
6. Reduce concentrations of hazardous substances, pollutants and contaminants in
surface water, groundwater, surface and subsurface soil within the Site to levels
specified by the Performance Standards; and
7. Reduce the volume, toxicity and mobility of hazardous substances, pollutants or
contaminants at the Site.
2.1.1 Natural Degradation Treatability Study Objectives
The Natural Degradation Treatability Study has five objectives. These objectives are as
follows:
I. Demonstrate if natural degradation of 1,2 dichloroethane is occurring at the site;
2. Determine if natural degradation can be enhanced through moisture and nutrient
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addition;
3. Determine where in the subsurface soil natural degradation is occurring;
4. Determine at what rate the natural degradation process is proceeding; and
5. Estimate the time frame when the Performance Standards via natural
degradation will be attained with or without moisture and/or nutrient addition.
The performance standards for 1,2 dichloroethane have been established by the USUSEPA for
groundwater at I ppb and for soil at 168 ppb and are described in the Record of Decisions for
Operable Unit 3 and Operable Unit 4, respectively.
2.1.2 Data Quality Objectives
Data quality objectives are qualitative and quantitative statements that specify the quality of
data required to support decisions during remedial response activities (US. USEPA, 1987).
Data Quality Objectives are determined based on the end use of the data to be collected. The
level of detail and data quantity needed vary based on the intended use of the data.
The Data Quality Objectives established for the OU4 Natural Degradation Treatability
Study is to determine the levels of 1,2-DCA in the soil in order to monitor the performance of
the natural degradation process. This will be quantified using CLP Protocol for organics. The
initial sampling event will establish the baseline concentrations of 1,2-DCA. Subsequent,
quarterly samples will be collected to measure the variation (due to degradation) of 1,2-DCA
over time. An evaluation of the soil data collected over time will be used by NSCC to
estimate a natural degradation rate and the time required to reach the USEPA established
performance standards for the site.
2.2 Project Scope of Work
The Natural Degradation Treatability Study consists of performing an intrinsic treatability
study over a 2 year period to demonstrate that 1,2-DCA is degrading naturally or under
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moisture enriched or moisture and nutrient enriched conditions. The Natural Degradation
Treatability Study will consist of the following:
I . Preparation of a Work Plan;
2. Design and construction of Soil Plots;
3. Installation of a Soil Gas Monitoring Well inside each Soil Plot;
4. Drilling and collection of split-spoons from each Soil Plot;
5. Initial soil sampling at the beginning and thereafter quarterly soil sampling
inside each Soil Plot;
6. Weekly soil gas monitoring from the Soil Gas Monitoring Well inside each Soil
Plot;
7. Laboratory analysis of soil and soil gas samples; and
8. Submission of a Natural Degradation Treatability Study findings report.
NSCC will submit this Natural Degradation Treatability Study Work Plan for review and
approval by USEPA Region IV and the NCDEHNR. Upon receiving USEPA Region !V's
and NCDEHNR's approval and notice to proceed with execution of the Work Plan elements,
NSCC will mobilize the drilling sub-contractor to construct the Soil Plots and install all
necessary equipment including Soil Gas Monitoring Wells to initiate the Natural Degradation
Treatability Study.
To establish the baseline conditions, an initial round of soil and soil gas samples will be
collected during the construction of the Soil Plots. Soil samples will be collected during the
installation of the Soil Gas Monitoring Wells. Soil gas samples will be collected following
the completion of Soil Gas Monitoring Wells inside the Soil Plots. Thereafter, NSCC will
collect soil samples and soil gas samples to measure concentrations of 1,2-DCA, other organic
compounds (degradation by-products) and inorganic compounds over a period of two years to
gather information and relevant data to demonstrate that degradation of 1,2-DCA is occurring.
NSCC will keep the USEPA and the NCDEHNR apprised of the treatability study activities by
submitting semi-annual Progress Reports during the 2-year study. Following completion of
all field activities and analyses of all collected samples NSCC will prepare and submit to the
USEPA and the NCDEHNR a Draft Report containing the investigations conducted and
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summarizing the results on the Natural Degradation Treatability Study. NSCC will revise
the Draft Report to incorporate review comments of the USUSEPA and the NCDEHNR and
submit the revised Draft Report for review and approval. Following review and approval of
the revised Draft Report, NSCC will prepare and submit the Final Report on the Natural
Degradation Treatability Study.
2.3 Description of Natural Degradation Process
The focus of the Natural Degradation Treatability Study is to demonstrate that 1,2-DCA is
degrading at the site either under natural conditions or with the addition of moisture and
nutrients. 1,2-DCA is a chlorinated aliphatic hydrocarbon and can be transformed in the
natural environment by both chemical (abiotic) and biological (biotic) processes such as
hydrolysis, dehydrohalogenation, oxidation and reduction. The exact processes under which
1,2-DCA may degrade are complicated and are not the specific focus of the Natural
Degradation Treatability Study. Rather the intent of the study is to confirm that degradation
of 1,2-DCA is occurring. Transformation products of 1,2-DCA ( such as vinyl chloride ) have
been detected at the site during previous Remedial Investigations, indicative of possible
1,2-DCA degradation. This Natural Degradation Trcatability Study will to demonstrate
that natural degradation processes are occurring at the site by collecting soil samples and
measuring the concentrations of 1,2-DCA over a two year period.
2.4 Description of the Treatability Study Experiments and Procedures
2.4.1 Soil Plots and Soil Gas Monitoring Wells
After review and approval of this Work Plan by the USEPA, the Natural Degradation
Treatability Study will be conducted over a two year period to demonstrate that natural
degradation of 1,2-DCA is occurring at the site without or with the addition of moisture and
nutrients. The Natural Degradation Treatability Stndy will be conducted on site using
naturally occurring indigenous microorganisms (mostly facultative bacteria which can stabilize
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organic matter under both anoxic and oxic conditions) in the soil at the selected Soil Plots.
Four Soil Plots, each approximately 3' x 4' in size, will be selected for use in the Natural
Degradation Treatability Study. Three of the four Soil Plots will be located inside Area 2
known to be contaminated with 1,2-DCA. The fourth soil plot will be located north of Area 2
outside the 1,2-DCA contaminated soils in the Plant's Production Facilities. The three Soil
Plots within the contaminated soils area will be used as Reactors for the contaminated soils
and the fourth soil plot located outside the contaminated soils will be used as a Control
Reactor for the uncontaminated soils. The Soil Plots will extend from the ground surface to
groundwater level estimated at a depth of about eight feet below the surface. Figure 2-1
illustrates the locations of the proposed Soil Plots.
The four Soil Plots will be constructed by removing the existing pavement. At each soil plot,
a metal box with a water tight seal will be installed into the cut pavement at existing grade
level. The sealed cover of the metal box will be designed to open up vertically thereby
providing easy access to the soil yet preventing intrusion of water (when the cover is closed),
excessive moisture or other foreign substances to the test area soils. Figure 2-2 illustrates the
construction of the metal box. Figure 2-3 illustrates the layout of each soil plot including the
location of the Soil Gas Monitoring Well, and nine locations for collecting soil samples.
Construction details of the Soil Gas Monitoring Wells inside the Soil Plots are illustrated in
Figure 2-4.
The Soil Plot No. I and the Soil Gas Monitoring Well inside this Soil Plot will be used to
establish 1,2-DCA degradation rate under naturally occurring conditions and will not receive
any moisture or nutrients to enhancement degradation. A pre-measured quantity of moisture
will be added each week to the Soil Plot No.2 to enhance degradation of 1,2-DCA. Thus, Soil
Plot No.2 and the Soil Gas Monitoring Well in this Soil Plot will be used to measure
degradation of 1,2-DCA under moisture enhanced condition. A pre-measured quantity of
moisture containing a certain amount of dibasic ammonium phosphate will be added to the Soil
Plot No.3 to enhance further degradation of 1,2-DCA. Therefore, Soil Plot No.3 and the Soil
Gas Monitoring Well in this Soil Plot will be used to establish the degradation rate of
1,2-DCA enhanced with both moisture and nutrients. Soil Plot No.4, located in an area of
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-------------------
, ro
~ Background Soil Plot
,-----------7
11
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mq\f1q5-1
0
SGMP 1, 2 & 3
Scale (ft)
PARKING LOT
100 200 300 400 500
LEGEND
0 Soil Plot
e Soil Gas Monitoring Point
\
..:... 1,2 OCA CONCENTRATION CONTOUR
'6
NOTE: Confirmation data supplemented by
soil screening data
LOCATION OF SOIL PLOTS
AND SOIL GAS MONITORING WELLS
NATIONAL STARCH ANO
CHEMICAL COMPANY
SALISBURY NC
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FLUSH LIFT HANDLE ____ _
(NOT SHOWN) /
-----!-IH),r
• SLAM LOCK----~
REMOV"-8LE KEY
WRENCH
114"{1U5mm) ~~VA8l.£
~~~c£veR---1-Jl-f-7
11◄"(5 35mm) CHANNEL FRAME
(FORMED STEEL OR EXTRUDED ALUMINUM)
.. ..... ~-LIFTING MECHANISM HOUSING
'1-__ ...:SIZ=E:.:(Wl=O::_T::_Hl:!_ ___ ---1 o
{i[atlonal Slarch and Chomlca/ Company
Figure 2-2
Metal Box
I Construction Detail c___ _________ ___J
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T
2 •
4 •
SP e
SP e
6 •
8 •
• 9
• 7
1 e SP
•-4---------i--Baseline e SP Sampling
SGMW Location
• 5
• 3
PLAN VIEW
Notes:
{iil;atlonal Starch and Chemical Company
1 • = First sompling location, etc.
SP = Spare sampling location
SGMW = Soil Gas Monitoring Well
FIGURE 2-3
Soil Plot Detail
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FINISH GRADE TO WATER TIGHT
DRAIN AWAY FROM BOX WELL BO
GROUT-~-
BENTONITE PELLETS -
1" SCH. 10 SS PIPE
SILICA SANO --+---
VAPOR PROBE
1" DIA. X 2' LONG
1/4" FEMALE QUICK
COUPLE BOX SET IN CONCRETE
FINISHED AT GRADE
Lil
Lil
SS SCREEN, 0.02 SLOT -----6n ____ __.
NOTES: SS = STAINLESS STEEL
Not to scale
/Ji[atlonal Starch and Chemical Company
FIGURE 2-4
Soil Gas Monitoring Well
Construction Detail
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uncontaminated soils, will be used as a Control Plot. No moisture or nutrients will be added
to Soil Plot No.4. Soil quality and gas concentrations in the soil gas measured in this Soil Plot
will be used primarily as a baseline for microbial activities in uncontaminated soil.
Water will be added to two of the four Soil Plots (No.2 and No.3) at a rate of 3.6 liters per
week to assure that there will be sufficient quantity of moisture in the soil column for
microbial activity and growth. Water added to Soil Plot No.3 will be mixed thoroughly with
27 grams of dibasic ammonium phosphate. Since 131 parts of dibasic ammonium phosphate
dissolves in JOO parts of water at 15 degree centigrade, all of the dibasic ammonium phosphate
will go into solution. Water will be evenly distributed over the surface of the soil inside the
Soil Plot No.2 metal box using a stainless steel watering can. Water mixed with dibasic
ammonium phosphate will be evenly distributed on top of the soil inside Soil Plot No.3 metal
box also by using a stainless steel watering can.
Following installation of the Soil Gas Monitoring Well and the metal box at each Soil Plot,
soil samples will be collected from location No. I inside each Soil Plot. Soil Samples will be
collected from several depths at each location for analysis of 1,2-DCA concentrations and
other organic compounds. Soil gas samples will also be collected from the monitoring wells
and analyzed for organic and inorganic compounds. The results from this initial set of samples
will be used as the baseline for the soil characteristics, contaminant levels in the soil, and
concentrations of different gases in the soil gas from each Soil Gas Monitoring Well.
After the initial sampling to establish baseline conditions, the Natural Degradation
Treatability Study will monitor the rate of degradation of 1,2-DCA in the three Soil Plots in
Area 2 under natural, moisture enriched, and moisture and nutrient enriched conditions by
collecting soil samples and analyzing for 1,2-DCA concentrations from different Soil Plots. In
addition, soil gas concentrations will be monitored in the three contaminated zone (Area 2)
Soil Plots and one non-contaminated zone (background area) Soil Plot. Table 2-1 summarizes
the proposed treatment and monitoring schemes in the treatability study for the various Soil
Plots.
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Table 2-1
Summary of Treatment and Monitoring Schemes for Different Soil Plots
Soil Plot No. Moisture Addition Nutrient Addition Soil Gas Monitoring
I No No Yes
(Contaminated Soil)
2 Yes No Yes
(Contaminated Soil)
3 Yes Yes Yes
(Contaminated Soil)
4 No No Yes
(Uncontaminated Soil)
2.4.2 Measurements of Performance
The approach taken in this Work Plan to evaluate the performance of the Natural
Degradation Treatability Study is to collect soil samples and soil gas samples from Soil Plots
located both inside and outside of Area 2. Soil samples will be collected from the four Soil
Plots over a two year period to measure concentrations of the following parameters:
I. 1,2-DCA;
2. By-products of 1,2-DCA degradation such as chloroethane, l ,2-dichloroethene,
ethane, vinyl chloride, and ethene ;
3. Nutrients such as ammonia nitrogen, nitrate nitrogen, TKN, orthophosphate,
and total phosphorous;
4. Soil pH;
5. Chloride, sulphate, and sulfide;
6. Trace metals such as calcium, magnesium and iron; and
7. Total organic carbon.
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As mentioned before, soil samples will be collected initially to establish a baseline
(benchmark) and thereafter on a quarterly basis. The initial, intermediate and final
concentrations of the monitored parameters will be used to determine if degradation of 1,2-
DCA is occurring at the site.
Soil gas in the four Soil Gas Monitoring Wells in the four Soil Plots will also be monitored
and sampled for laboratory analysis. Gas samples will be collected weekly for monitoring
concentrations of the following parameters:
I. Oxygen;
2. Carbon dioxide;
3. Methane; and
4. Hydrogen sulfide.
Concentrations of oxygen, carbon dioxide, methane and hydrogen sulphide will be measured in
the field using real time monitoring instruments. Once a month soil gas samples will also be
collected from the Soil Gas Monitoring Wells and shipped to an off-site laboratory. These soil
gas samples will be analyzed for concentrations of 1,2 dichloroethane, 1,2-dichlorethene,
chloroethane, vinyl chloride, ethene, ethane, carbon dioxide, oxygen, methane and hydrogen
sulfide. Measured concentrations of various gases in the soil gas will be used to support that
natural degradation is occurring.
2.4.3 Soil Sampling
Soil samples will be collected from each Soil Plot initially at the start of the field program and
thereafter every three months for up to 2 years. Soil samples will be collected using a drill rig
and a 2-inch split-spoon in accordance with Field Sampling and Analysis Plan. The Field
Sampling and Analysis Plan is included in Appendix A. The split-spoons will be advanced
continuously at two feet intervals until the water table is encountered. The water table is
estimated to be at about eight feet below grade based on data collected during the Remedial
Investigation at this site. The recovery in the split spoon will be quickly scanned using a
Photo Ionization Detector (PID) or Flame Ionization Detector (FID) instrument. One sample
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of the soil will be collected from each 2-feet spoon interval either from the spot with the
highest headspace reading or based on visual appearance of the soil. All samples will be sent
via Federal Express to Laboratory Resources Inc. During subsequent quarterly sampling
events, soil samples will be collected vertically at a depth below grade as close as possible to
the original sample intervals and horizontally at a minimum distance of six inches from any
previous boring location. Upon completion of sample collection, the bore hole will be grouted
with bentonite slurry from the bottom to the surface as quickly as possible.
Table 2-2 presents the list of parameters and the analytical methodologies to be used in the
analyses of the soil samples. As mentioned before samples will be analyzed by Laboratory
Resources, a member of USEPA's CLP program.
2.4.4 Soil Gas Monitoring
A Soil Gas Monitoring Well will be installed inside and at the center of each of the four Soil
Plots (No. I, No.2, No.3 and No.4) to monitor concentrations of selected organic compounds
and gases in the soil gas. Real time measurements will be made weekly for hydrogen sulfide,
carbon dioxide, oxygen and methane concentrations. Samples of soil gas from the Soil Gas
Monitoring Wells will also be collected monthly and will be analyzed for 1,2-DCA, 1,2-
dichloroethene, chloroethane, vinyl chloride, ethene, ethane carbon dioxide, oxygen, and
methane using USEPA Method T0-14. The screened portion of the Soil Gas Monitoring Wells
will be staged at five to seven feet below the ground surface. A detailed diagram of a typical
Soil Gas Monitoring Well is shown in Figure 2-4. The Soil Gas Monitoring Wells will be
installed in accordance with the Field Sampling and Analysis Plan presented in Appendix A.
Monitoring of the gas samples from each Soil Gas Monitoring Well during each week will be
done two times: (I) before evacuating (purging) any gas from the well; (2) after evacuating
(purging) one well volume of the gases from the well using a calibrated air pump. Real time
instruments will be connected to the quick disconnect located on top of the Soil Gas
Monitoring Well (Figure 2-4) and concentrations of hydrogen sulfide, carbon dioxide, oxygen
and methane gases in the soil gas will be measured and recorded.
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Table 2-2
Summary of Soil
Analytical Parameters and Methodologies
Parameter Method
1,2 Dichloroethane TCL
Vinyl Chloride TCL
1,2 Dichloroethylene TCL
Chloroethane TCL
Chloride EPA 300
Nitrate EPA 300
Sulfate EPA 300
Sulfide EPA 376.2
Alkalinity EPA 310.l
Calcium TAL
Iron TAL
Magnesium TAL
Ammonium EPA 350.2
Phosphate EPA 365.2
pH EPA 150.1
Total Organic Carbon EPA 415.1
Total Khejdal Nitrogen EPA 351.3
Orthophosphate EPA 365.2
Total, phosphorus EPA 365.2
C.\PROJECTS\Cl)]Uil'RNG\OU4NDTS\FSAP\TABLl:2-2.MLI'
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2.5 Project Deliverables
2. 5 .1 Progress Reports
National Starch and Chemical Company will submit semi-annual Progress Reports to the
USEPA Region IV and the NCDEHNR. These reports will be submitted two months after
completion of the second, fourth, and sixth quarterly sampling events to allow adequate time
to receive, review and evaluate the laboratory analytical results. The semi-annual reports will
briefly summarize all activities conducted during the two previous quarters, present monitoring
and analytical results and provide conclusions derived from the studies and experiments
conducted up to that time.
2.5.2 Natural Degradation Treatability Study Reports
NSCC will prepare and submit to the USEPA and the NCDEHNR for review and approval a
Natural Degradation Treatability Study Draft Report to comply with Task II Item 5, of the
OU4 SOW (contained in the Unilateral Administrative Order) within three months of
completion of the two-year treatability study. This Draft Report shall present the findings of
the treatability study objectives 1, 2, 3, 4, and 5. Following review and approval of the Draft
Report by the USEPA and the NCDEHNR, NSCC will incorporate all review comments into
the Draft Report and prepare the Final Report of the Natural Degradation Treatability Study
and submit the required number of copies of the Final Report to the USEPA and the
NCDEHNR.
2.6 Residuals Management
Soil boring materials and auger cuttings will be drummed and temporarily staged on-site. The
criteria for off-site treatment and disposal of soil from soil borings will be determined by the
treatment and disposal facility which will receive the material. Composite samples will be
drawn from the drums and submitted to a USEPA certified CLP laboratory for TCLP organic
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and TCL inorganic analysis, ignitability, corrosivity and reactivity. Upon receipt of the
analytical results, the waste streams will be profiled to determine the material applicability to
RCRA regulations.
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3.0 PROJECT ORGANIZATION AND RESPONSIBILITY
3 .1 Project Organization And Management Plan
The Environmental Projects Group of National Starch and Chemical Company will conduct
and manage the various elements and work tasks required for the Remedial Design/Remedial
Action for OU4 as described in this Work Plan. Staff members of the Environmental
Projects Group will be assisted by several experienced and qualified sub-contractors. A
drilling sub-contractor, registered in North Carolina and certified to work in hazardous waste
sites, will be retained by NSCC to conduct drilling and split-spoon soil sampling operations.
Actual collection of soil samples from the split-spoons will be performed by staff members of
NSCC's Environmental Projects Group who have been trained and are experienced in
conducting such sampling.
A Contract Laboratory Program (CLP) certified laboratory will be retained by NSCC to
carry out the analyses of the soil samples collected for this Work Plan. NSCC will also retain
the services of a certified laboratory, qualified and experienced to conduct analyses of soil gas,
to carry out analyses of soil gas samples collected for the Natural Degradation Trcatability
Study. Figure 3-1 illustrates the proposed Project Organization for the Remedial
Design/Remedial Action for OU4 at the NSCC's Cedar Springs Road Plant site.
The principal NSCC staff members assigned to this project to conduct Remedial
Design/Remedial Action for OU4 are Mr. Ray Paradowski ( Plant Manager and Project
Coordinator), Dr. Abu Alam (Project Director), Mr. Richard Franklin (Health and Safety
Officer), and Mr. Michael Ford (Project Environmental Engineer), Mr. Kenneth Klutz (Field
Operations Coordinator), and Mr. Sreedhar Velicheti (Quality Assurance Officer). In
addition, NSCC will retain the services of Graham and Currie (a North Carolina certified
driller experienced to conduct work in hazardous waste sites) to conduct drilling, and well
installation, and Laboratory Resources Inc. (a CLP Certified laboratory) to conduct analyses of
soil samples and Lancaster Laboratories (a certified laboratory) to conduct analyses of gas
samples. Other personnel will be assigned as deemed necessary. The responsibilities of the
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-------- - -- -- -- - -
Figure 3-1
PROJECT ORGANIZATION
NATURAL DEGRADATION TREATABILITY STUDY
Operable Unit 4
Cedar Springs Road Plant Site, Salisbury, North Carolina
USEPA REGION IV
Plant Manager &
Project Coordinator
Ray Paradowski
Health & Safety Officer Project Director Quality Assurance
Richard Franklin Dr. Abu Alam Officer
Sreedhar Velicheti
Project
Environmental Engineer
Michael Ford
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Field Operations Drilling & Analytical Services (Soil) Analytical Services
Coordinator Well Installation Laboratory (Soil Gas)
Kenneth Kluttz Graham & Currie Resources Inc. Lancaster Lab. Inc.
I
Field Sampling &
Monitoring
Michael Ford
-111!!!!!!1
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individuals selected for this Natural Degradation Treatability Study are described in the
following sections.
3 .1.1 Plant Manager and Project Coordinator
The Plant Manager and Project Coordinator for this Project is Mr. Ray Paradowski.
keep abreast of all project activities and will do the following:
I. Co-ordinate with USEPA Region IV;
2. Co-ordinate with NCDEHNR
3. Co-ordinate with Project Personnel; and
4. Attend all meetings with USEPA and NCDEHNR.
3.1.2 Project Director
He will
The Project Director will be Dr. Abu Alam. He will have the primary responsibility for
planning and executing this project and will have the responsibility for all technical, financial,
and scheduling matters. Project Director's duties will include the following:
I. Assignment of duties, providing guidance to the Project Team Members and
delineating the needs and requirements of the Project;
2. Supervision of performance of various Project Team Members;
3. Planning and scheduling of all Project activities;
4. Keeping the Plant Manager and Project Coordinator informed of all aspects of
the Project;
5. Assure that all Project documents and deliverables are reviewed in a timely
manner for technical accuracy and completeness before their release;
6. Assure that the specific requirements of the QAPP are met; and
7. Attend all meetings with USEPA and NCDEHNR.
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3.1.3 Project Health and Safety Officer
The Project Health and Safety Officer for this Project will be Mr. Richard Franklin. The
Project Health and Safety Officer is responsible for any modifications to this HSP. The Health
and Safety Officer will advise the Plant Manager and the Project Director on health and safety
issues, establish and oversee the Project air monitoring program, and perform at least one
comprehensive health and safety audit during the execution of the Project. The Project Health
and Safety Officer will advise the Project Director on changes and implementation of site
specific health and safety requirements. The Project Health and Safety Officer will give his
site audit report to the Plant Manager and Project Coordinator together with his
recommendations of any site specific needs. Mr. Franklin's work telephone number is (704)
633-1831 Ext.233. Other responsibilities of the Project Health and Safety Officer include:
1. Determining and posting emergency telephone numbers and routes to emergency
medical facilities, including poison control facilities, and arranging emergency
transportation to medical facilities;
2. Notifying local public emergency officers of the nature of the Project Team's
operations, and the posting of their telephone numbers in an appropriate
location;
3. Observing on-site Project personnel for signs of exposure or physical stress; and
4. Ensuring that all site personnel have been given the proper medical clearance,
ensuring that all site personnel have met appropriate training requirements, and
have the appropriate training documentation on-site, and monitoring all team
members to ensure compliance with the HSP.
3.1.4 Project Environmental Engineer
The Project Environmental Engineer for this Project will be Mr. Michael Ford. The Project
Environmental Engineer is in charge of supervising work of all sub-contractors, and
conducting specific Project tasks. This includes adding the moisture and nutrients to the
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selected Soil Plots, collecting soil and soil gas samples in the field, making sure that covers for
all Soil Plots are in place and locked after each sampling activity, and shipping all soil and soil
gas samples to the analytical laboratories with proper chain-of-custody forms.
The Project Environmental Engineer is also responsible for ensuring that all Project work tasks
are carried out in accordance with the Work Plan. He will coordinate all Project tasks with
the Project Director, the Project Health and Safety Officer and the Field Operations
Coordinator. The responsibilities of the Project Environmental Engineer will also include the
following:
I. Making sure that the drilling sub-contractor is using proper equipment suitable
for the Project;
2. Making sure that all drilling equipment and split-spoon samplers are properly
decontaminated and protected from contamination prior to bringing these on site
and actual use;
3. Making sure that all portable field monitors and tools are cleaned, calibrated
and protected from contamination in accordance with the QAPP;
4. Making sure that all soil and soil gas samples are collected, preserved and
shipped according to the QAPP;
5. Review work performed by the sub-contractors and approve their invoices;
6. Establish a record keeping system for the Project; and
7. Conduct Project closeout at the completion.
3.1.5 Field Operations Coordinator
The Field Operations Coordinator for this Project will be Mr. Kenneth Klutz. The Field
Operations Coordinator will be responsible for field implementation of the HSP. This will
include communicating site requirements to all on-site Project personnel (Both NSCC and
subcontractor personnel) and consultation with the Project Health and Safety Officer. As
required by NSCC Policy, the Field Operations Coordinator will be responsible for informing
the Project Health and Safety Officer and the Plant Manager of any changes in the Health and
Safety Plan, so that those changes may be properly addressed. Other responsibilities of the
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Field Operations Coordinator include:
1. Enforcing the requirements of the HSP, including the performance of daily
safety inspections of the work site.
2. Stopping work as required to ensure personal safety and protection of property,
or when life or property threatening non-compliance with safety requirements is·
found.
3.1.6 Quality Assurance Officer
The Quality Assurance Officer for this Project is Mr. Sreedhar Velicheti. The Quality
assurance Officer is in charge of conducting periodic audits and is responsible for monitoring
the Project activities to assure that all tasks are conducted to meet the Project Quality
Objectives. The Quality Assurance Officer reports directly to the Project Director.
The Quality Assurance Officer is responsible for making sure that all Project work undergoes
adequate quality review. Following are the responsibilities of the Quality Assurance Officer:
I. Contacting the analytical laboratories receiving samples to determine if samples
are prepared, packaged, and identified properly;
2. Conducting field audits of sampling events to assure that proper sample
identification, sampling techniques and chain-of-custody procedures are
observed;
3. Reporting to the Project Director on personnel assigned to field supervision and
sample collection tasks are properly trained in sample collection, sample
identification and chain-of custody procedures; and
4. Reviewing work products and Project deliverables.
3 .1. 7 Laboratory Directors/Laboratory Coordinators
Two Laboratory Directors/Laboratory Coordinators will be used in this Natural Degradation
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Treatability Study, one for each laboratory. Each Laboratory Director/Laboratory
Coordinator will be responsible for coordinating laboratory services provided by his laboratory
and will ensure that analytical data from his laboratory meet the objectives discussed in the
applicable sections of the QAPP. Laboratory Directors/Laboratory Coordinators will be
assigned by the two certified laboratories selected for conducting the laboratory analyses of
soil and soil gas samples.
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4.0 PROJECT SCHEDULE
The required elements and activities of the Remedial Design/Remedial Action for OU4 as
described in this Work Plan will be initiated within a month of approval and notification by
the USEPA to proceed with the Work Plan. The project schedule is presented in Figure 4-1
and covers all items identified under Work Plan Contents (Section 1.5).
A:\OU4WKPLN.AA Page 48
-------------------Figure 4-1 :Project Schedule -
OU4 Natural Degradation Treatabilty Study
I 1996 1997 7 1998
Task Name Duration 1 I 2 I 3 I 4 I s I 6 I 1 I s I 9 10111112 I 1314 I 1s 1511111s 119120121122123l2472sl25l217 2s-29l3ol31 I 32 l33l34 l35
Planning and Preparation 30d • •• EPA Review of Submittals 4w []
Submit Final NOTS Work Plan 2w Ill
Submit Final HASP 2w [j]
Submit Final FSAP 2w II
Notice to Proceed 0d ♦ 12/20
Field Activities 30d
•• • Mobilize Contractor 4w g
Baseline Sampling 2w !ID
Install Monitoring Wells 2w Ill
Monitoring Activities 526d .. ~
Soil Gas Monitoring 516d IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII Ill
Treatability Activities 516d 11111111111111111111111111111111111111111111111/IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIUIII
Quarterly Sampling 526d I I I I I I I I
Reports 525d . ~
Progress 260d
Prepare and Submit Draft NOTS 12w Iii i
EPA Review of Draft 4w [ii]
Submit Final NOTS 2w 00
National Starch and Chemical Company Task /Milli I ill 11 Summary • • Salisbury, North Carolina Milestone ♦ Monitoring / I 111111111111111 I II
C:IWINPROJIPROJECT1.MPP
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APPENDIX A
FIELD SAMPLING AND ANALYSIS PLAN
For
Natural Degradation Treatability Study Work Plan
At
Operable Unit 4
National Starch And Chemical Company Site
Cedar Springs Road
Salisbury, North Carolina
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Table of Contents
A.1.0 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1
A.2.0 Sample Locations and Frequency ................................ A-1
A.3.0 Sample Designation ........................................ A-2
A.4.0 Sampling Procedures ....................................... A-2
A.4. I Soil Sampling Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-2
A.4.2 Soil Gas Sampling and Monitoring Procedure .................. A-3
A.4.3 Summa Canister Cleaning Procedure ........................ A-5
A.4.4 Protective Clothing and Screening Equipment . . . . . . . . . . . . . . . . . . A-6
A.4.5 Location of Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6
A.4.6 Samples to be Split for Analysis by US EPA ................... A-7
A.4.7 Sampling Documentation ............................... A-7
A.4.8 Sampling Equipment, Materials and Decontamination Procedures ..... A-8
A.4.9 Sample Handling and Documentation for Samples Shipped to Off-Site
Laboratories ...................................... A-10
A.5.0 Soil Gas Monitoring Well Installation Procedures . . . . . . . . . . . . . . . . . . . . A-10
A.5.0 Moisture and Nutrient Addition Procedures . . . . . . . . . . . . . . . . . . . . . . . . A-11
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List of Figures
Figure Title Follows Page
A-1 Soil Plots and Soil Gas Monitoring Well Locations ..................... A-1
A-2 Soil Plot Detail ............................................ A-1
A-3 Summa Canister Sampling Diagram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-4
A-4 Summa Canister Cleaning Manifold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6
A-5 Soil Gas Monitoring Well Construction Diagram ..................... A-10
List of Tables
Table Title Follows Page
A-1 Soil Sample Locations, Depths and Frequency ························ ~,
A-2 Summary of Soil Analytical Parameters and Methodologies ............... A-3
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A. 1.0 Introduction
This document presents the Field Sampling and Analysis Plan for the Natural Degradation
Treatability Study at Operable Unit 4 of the National Starch and Chemical Company's Cedar
Spring Road Site in Salisbury, North Carolina. The Data Quality Objectives for this investiga-
tion are discussed in Section 2 of the Natural Degradation Treatability Study Work Plan.
This Field Sampling and Analysis Plan, along with the Quality Assurance Project Plan
(QAPP), constitute the sampling and analytical protocols that will be followed for conducting
the Natural Degradation Treatability Study. The methods and procedures described herein
comply with the U.S. EPA Region IV Environmental Compliance Branch Standard Operating
Procedures and Quality Assurance Manual (February 1991).
Sampling for this investigation will include collection of soil samples from four Soil Plots, and
collection and monitoring of different gases from four Soil Gas Monitoring Wells. Three of
the four Soil Plots will be located in 1,2-DCA contaminated soils in Area 2 of the Plant's
Production Facilities while the fourth Soil Plot will be located in uncontaminated soil outside
of Area 2. Each Soil Plot will have a Soil Gas Monitoring Well located at the center. Results
of analysis of soil and soil gas samples from the Soil Plot 4 (located in the uncontaminated
soil) will be used as controls and background levels for determining 1,2-DCA degradation
rates.
A.2.0 Sample Locations and Sampling Frequency
Soil borings will be conducted in three selected Soil Plots located in Area 2 known to be
contaminated with 1,2-DCA and at one Soil Plot located adjacent to Area 2 but outside the
area known to be contaminated with 1,2-DCA. Figure A-1 presents the locations of the Soil
Plots and Figure A-2 illustrates details of the proposed Soil Plots and Soil Gas Monitoring
Wells located inside each Soil Plot. Soil samples will be collected from these four selected
Soil Plots initially at the start of the Natural Degradation Trcatability Study and every three
months thereafter over a 2-year period It is anticipated that three soil samples from each soil
plot will be collected from three different depths above the ground water table during each
sampling event as presented in Table A-1.
A-1
-- -
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- -
,.•---=-0 100
c·lprojects\cdrspmg\ndtsou41fsplfiga-1. pre
--
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Scale (ft)
200 300
- - -- -- -- - -- -
l•J Soil Plot 4
(Background Location)
\ 100
/ ,'
,' I
/ ,'
I ,' / ,, , ; ·,-----
, I ·, ,1: I ,
,' ~ / ,
/
PARKING LOT
400
I
500
LEGEND
0 Soil Plot
• Soil Gas Monitoring Well
\
'__;. 1.2 DCA CONCENTRATION CONTOUR
't,
NOTE: Confirmation data supplemented by
soil screening data
FIGURE A-1
Soil Plots and Soil Gas Monitoring
Well Locations
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
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2 •
4 •
SP e
SP e
6 •
8 •
• 9
• 7
1 e SP
-~-----t--Baseline e SP Sampling
SGMW Location
• 5
• 3
PLAN VIEW
Notes:
c: \projs,;t1\cdrspn11\ndtS01J4\li92-J,d•CJ
{iif:atlonal Sfarch and Chemical Company
1 • = First sampling location, etc.
SP = Spare sampling location
SGMW = Soil Gas Monitoring Well
FIGURE A-2
Soil Plot Detail
l!!!!!!B -111!!!!1 l!!!l!!!!!I 1!111 Bl -1111 ---11111 a; 1111 &ii iiiii aii -aii
I Location I
SP-1
SP-2
SP-3
SP-4
Notes:
Sample
Depth
Interval 0 3
2-4 X X
4-6 X X
6-8 X X
2-4 X X
4-6 X X
6-8 X X
2-4 X X
4-6 X X
6-8 X X
2-4 X --
4-6 X --
6-8 X --
Table A-1
Soil Sample Locations, Depths and Frequency
Cedar Springs, North Carolina
Sample Frequency (months)
6 9 12 15
X X X X
X X X X
X X X X
X X X X
X X X X
X X X X
X X X X
X X X X
X X X X
--

-
-

-
-
--
--------
--------
18
X
X
X
X
X
X
X
X
X
--
----
X = Sample to be collected during the sample event from the specified sample depth interval.
--= No sample collection.
21 24
X X
X X
X X
X X
X X
X X
X X
X X
X X
----
----
----
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As illustrated in Figure A-2 four Soil Gas Monitoring Wells will also be installed, one at the
center of each Soil Plot inside Area 2 (a total of three wells) and one at the center of the Soil
Plot located in the background area outside the 1,2-DCA contaminated zone. These Soil Gas
Monitoring Wells will be used to collect Soil Gas samples and monitor concentrations of
different gases in the Soil Gas on a weekly and monthly basis.
A.3.0 Sample Designation
Collected soil samples will be identified by a unique labeling system indicating the sample
location, sampling event, and sample depth. Soil Plots and Soil Gas Monitoring \Velis will
be designated SP and SGMW, respectively. An example of soil sample designation is as
follows: SPl-1-4. This designation indicates that the sample is collected from Soil Plot No.I
during the first sampling event and the sample is from a depth of four feet from the surface.
An example of Soil Gas Monitoring Well is as Follows: SGMW4-III. This designation
indicates that the Soil Gas sample is collected from Soil Gas Monitoring Well No.4 during
the third sampling event.
A.4.0 San1pling Procedures
Selection and handling of sampling equipment shall follow the procedures described herein and
will comply with the Quality Assurance Project Plan (QAPP), and the Health and Safety
Plan (I-ISP) included as Appendices B and C of this \Vork Plan, respectively.
A.4.1 Soil Sampling Procedures
Split-spoon soil samplers will be advanced using a truck-mounted drill rig for collection of soil
samples. The method used to collect split-spoon samples will be the Standard Penetration
Test (ASTM D-1586), which consists of a 2-inch diameter, 24-inch long sampler being driven
into the soil by dropping a 140-pound weight a distance of 30 inches.
NSCC personnel will supervise the soil penetration and sample collection activities and
maintain boring logs for each borehole. Information such as the boring location, boring
number, sampling depth, sample description, and any other pertinent information will be
recorded in a daily field log during the soil boring and sample collection program. Soils will
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be sampled continuously down to groundwater, estimated to be at about eight feet below
ground surface, using a 24-inch long by 2-inch diameter split barrel sampler. Soil samples
will be logged on a visual classification log as the boring is advanced.
Unsaturated soils will be screened using either an !-!Nu equipped with an 11.7 eV detector
probe or an OVA for the presence of organic vapors in the soil gases. Records to be kept
include (I) blow counts per six inches of drive and the percent of recovery, (2) a visual
description of the soil including stiffness or density, moisture content, and color, (3) USCS
symbol for the soil, (4) results of the screening process and (5) the iime of sample collection_
The most representative and least disturbed portion of the split-spoon sample shall be bisected
with a decontaminated stainless steel knife. The required volume of the split spoon sample will
be collected in 4-oz wide-mouth bottles. Samples for volatile organics analysis will be
collected first, then samples for analyzing the other parameters will be collected. A daily
equipment blank will be collected to confirm proper equipment decontamination procedures.
Soil samples will be collected by a staff member from NSCC's Environmental Projects
Group qualified, trained and experienced in sampling hazardous material. Collected samples
will be shipped off-site for analyses by Laboratory Resources using level IV protocol. These
samples will be analyzed for the parameters shown in Table A-2 in accordance with TCL for
volatile organics and the applicable methods for the remaining constituents.
A.4.2 Soil Gas Sa1npling and Monitoring Procedures
Soil Gas concentrations will be measured weekly using real time instruments. A GEM-500
will be used to detect and measure carbon dioxide, oxygen, and methane concentrations and a
hydrogen sulfide meter will be used to detect and measure hydrogen sulfide concentrations.
Soil Gas concentrations will be measured twice: once before purging the well and once after
purging the well.
Prior to conducting real time monitoring of Soil Gas concentrations, the instruments will be
calibrated against standard gases to manufacture's specifications. The real time instruments
will then be connected, one at a time, by a flexible Tygon or polypropylene tubing to the 1/4
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Table A-2
Summary of Soil
Analytical Parameters and Methodologies
Parameter Method
1,2 Dichloroethane TCL
Vinyl Chloride TCL
1,2 Dichloroethylene TCL
Chloroethane TCL
Chloride EPA 300
Nitrate EPA 300
Sulfate EPA 300
Sulfide EPA 376.2
Alkalinity EPA 310.1
Calcium TAL
Iron TAL
Magnesium TAL
Ammonium EPA 350.2
Phosphate EPA 365.2
pH EPA 150.1
Total Organic Carbon EPA 415.1
Total Khejdal Nitrogen EPA 351.3
Orthophosphate EPA 365.2
Total, phosphorus EPA 365.2
C.\J'ROJECTS\CDRSPRNG\OU4NDTS\FSAP\TABLEA-2.MLF
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inch female quick disconnect installed on the cap located at the top of the Soil Gas Monitoring
Well. The internal pump on the monitoring instrument GEM-500 will be turned on and a
reading for carbon dioxide, oxygen and methane will be recorded and entered into the daily
log book. The GEM-500 will then be disconnected from the Soil Gas Monitoring Well and its
pump and monitoring equipment will be cleaned and purged using an inert gas (helium). The
Hydrogen Sulfide Meter will be connected next to the Soil Gas Monitoring Well and its
internal pump will be turned on to monitor and record the hydrogen sulfide concentration in
the Soil Gas. The measured concentration of hydrogen sulfide will also be recorded in the
daily log book.
After taking the real time measurements of the initial concentrations of carbon dioxide,
oxygen, methane and hydrogen sulfide in the Soil Gas two air volumes will be purged from
inside the Soil Gas Monitoring Well using an air pump. Prior to pumping, the air pump will
be calibrated using a soap bubble flow meter. Concentrations of carbon dioxide, oxygen, and
methane in the Soil Gas of the purged well will then be measured again using the GEM-500
' and the concentration of hydrogen sulfide in the Soil Gas of the purged well will then be
measured by using the hydrogen sulfide meter (make and model no). All measurements and
recording will be carried as previously described above.
Concentrations for oxygen, carbon dioxide, methane, and hydrogen sulfide in the Soil Gas will
be measured in place every week using the portable real time instruments identified above.
Additionally, concentrations of 1,2-dichloroethane, vinyl chloride, 1,2-dichloroethene,
chloroethane, ethane and ethene will be monitored once a month by collecting an air sample
from the Soil Gas Monitoring Well in a stainless steel canister and shipping the canister to an
off-site certified laboratory.
Initially, the Summa Canister will be removed from the shipping box. The canister will be
checked for an identification tag. The canisters will be precleaned at the laboratory in accor-
dance with the laboratories standard operating procedures. The canisters will also be
preevacuatcd by the laboratory to a pressure of approximately -30 inches of mercury. The
canisters will be delivered to the site with a 1/4 inch stainless steel male Swagelock quick
disconnect, pressure gauge and passive flow controller assembly as shown in Figure A-3.
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1/4' FEMALE SWAc:.1:LOCK
FITTING • TO SUMMA CANISTER ----..
1/4' MALE SWAOE1.0CK FITTING
I 0 --:-1/4' SWAGELOCK CAP
INLET .
VAC PRESSURE GUAGE
CANISTER VALVE
,,...
~;
~~ ~ ~.~·-
:Mt~t\i·}•-:~ '.;~1-{~t~.,}}/·· c...t-<>,n
't.1!12. ,_. ,,...,
{jJj:,tlonal Storch and Ch•mlcor Company
"1:-_~.,;-~
UMMA CANISTER
.· ... .;...:.-.. '·-· .
FIGURE A-3
SUMMA CANISTER
SAMPLING DIAGRAM
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To start the sampling, the 1/4 inch male fitting will be connected to the female quick disconnect
located at the top of the soil gas monitoring well. Once connected, the valve on the canister will
be opened at least one turn. An audible sound of rushing air should be heard entering the
canister. If not, the canister should be discarded and another canister used. The passive flow
controller will be calibrated in the laboratory to deliver an air flowrate of approximately 600
ml/min. The 6 liter canister will be filled with air for IO minutes.
At the end of the sampling period, the sampler will close the valve to the Summa canister. The
canister identification tag will be completed with the sample location. The sampling time will be
recorded in the field log book and on the chain-of-custody. The canisters will be packaged using
bubble wrap and shipped via Federal Express to Lancaster Laboratories for overnight delivery.
The soil gas samples will be analyzed for methane, oxygen, carbon dioxide, 1,2-dichloroethane,
1,2-dichlorocthene, chloroethanc, vinyl chloride, ethane and ethene by EPA method TO-14.
A.4.3 Su1nma Canister Cleaning Procedures
These cleaning procedures arc Standard Operating Procedure used by Lancaster Laboratories
Inc. This SOP describes the labeling, cleaning, preparation, tracking, and documentation of
Summa canisters that will be used during the analysis of volatile organics compounds in air by
EPA Method TO-14.
Each new Summa canister that is purchased is assigned a four digit number that is scribed
permanently onto the top of the canister using a metal scribing tool. The four-digit numbers arc
assigned sequentially as canisters arc purchased and arc to identify the canister over its lifetime.
Each canister has a tag attached to it by wire or string stating the condition of the canister or
identifying the sample which it contains. This tag also includes the date the cleaning
certification was completed with he initials or employee number of the person who certified the
canister clean.
Canisters arc cleaned according to the procedure outlined in EPA Method TO-I 4. The canisters
are placed on the manifold shown in Figure A-4 and evacuated for a period of about I hour. The
canister is then pressurized to 30 psi with zero humid air. The cycle is repeated at least two more
time and on the final time the humid air is analyzed by GC/MS, GC/FID or TO-12 (nonmethane
A-5
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hydrocarbon) to certify it clean. To be clean the canister will not contain any volatile organic
compounds at or above the Limit of Quantitation. Only one canister per batch that is cleaned on
the manifold must be analyzed to certify the entire batch. More frequent analysis may be
necessary if previous samples contained in the canisters were found to have high levels of
organic contaminants. This cleaning method will remove volatile organic compounds. How-
ever, inorganic salts and higher molecular weight organics may reach the walls of the Summa
canister. These contaminants can create active sites on the wall of the Summa or may break
down over time to form volatile compounds. Therefore, it may be necessary to use special
cleaning methods such as heating or steaming to clean exceptionally dirty canisters.
After cleaning, each canister is checked for leaks by pressurizing it to 30 psi with humid air and
allowing it to stand for 24 hours. The pressure is not allowed to drop more than 2 psi. This
check can be performed on the manifold shown in Figure A-4. The canister is then evacuated
(<0.05111111 Hg), capped, a tag attached stating the condition, and ready for next use.
Accurate records are kept on each canister. Sample receipt, cleaning, and sample shipment will
be recorded in a database which maintains an historical record of all activity for each canister.
A.4.4 Protective Clothing and Screening Equip1nent
Personnel will wear Level D or modified Level D personal protective clothing while conduct-
ing sampling procedures. Level D protective clothing and equipment includes hard hat, steel
toe boots, eye protection, and latex gloves. Modified Level D protective clothing will consist
of Tyvek coveralls, latex inner gloves, nitrile outer gloves, splash protection, polyvinyl
chloride (PVC) steel toe boots, and hard hat.
During all sampling operations, air quality will be monitored using either an HNu with a 11. 7
eV probe or an OVA. If an HNu is used, it must be equipped with an 11.7 eV probe.
Calibration of air monitoring equipment will be completed and noted daily before its use.
A.4.5 Location of Utilities
Existing utilities that serve plant operations in the vicinity of the proposed Soil and Soil Gas
sampling locations in Area 2 will be identified in the field including known underground pipes,
A-6
1!!!!!9 11!!1!1 1!!!B !!11111 1111 11111 =m 11i11 iiii liiiil _. --------
0------'--------
VACUUM
CRYOGENIC TRAP
-
{N;ational Starch and Chemical Company
VACUUM/PRESSURE
Summa canisters
CRYOGENIC TRAP
HUMIDIFIER
SUMMA CANISTER CLEANING MANIFOLD
FIGURE A-4
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conduits, etc. Location of utilities must be determined to ensure the safety of the sampling
personnel and equipment.
A.4.6 Samples to be Split for Analysis by USEPA
During the 2-year sampling program, if required, some soil and soil gas samples will be split
with the USEPA for analysis by the USEPA. These split samples will be analyzed to provide
QA/QC documentation for the analytical procedures, and for analysis by an U.S. Environmen-
tal Protection Agency chosen laboratory for oversight. All sample splits will be identified as
such on the Sample Logs, the Chain of Custody Record Forms, and in the Daily Field Activity
Log Book. Samples split for analysis will have separate sample numbers referenced on the
Chain of Custody Record Forms and a sample log for cross reference.
A.4. 7 Sa1npling Documentation
All pertinent sample information will be recorded on a field sampling log book including the
following:
• Site name and sample location, and project number
• Date and time of sampling
• Weather conditions
• Sampling team members
• Sample number
• Sample depth (if applicable)
• Type of container used to collect sample
• Volume of sample
• Field Screening results (if any)
• Chemical preservatives used (if applicable).
Data particular to soil sampling will also include:
• Depth of sample
• Classification of soil type.
The sampling log book will include a map showing the relative locations of the Soil Plots and
sampling points inside each Soil Plot. The field log book will also serve as a Chain-of-
Custody document for samples analyzed on site. Any samples split with the EPA will be
indicated on the sample log book and Chain-of-Custody Record Form.
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A.4.8 Sampling Equipment, Materials and Decontamination
Procedures
Following sampling equipment and materials will be used during the conduct of the Natural
Degradation Treatability Study for the OU4 at the Cedar Springs Road Plant site in Salisbury,
North Carolina:
1. Battery operated sampling pumps (5)
2. Soap Bubble Flow Meter (2)
3. Thermometer (-20 to + 120 deg. Centigrade)
4. HNu (PI-101) with 11.7 eV probe
5. OVA (128 GC)
6. Tygon or Polypropylene tubing (20 feet of 1/4 inch)
7. Stainless steel gas canisters (5)
8. Stainless Steel Trowels (10)
9. Wide mouth glass sample bottles, 4-0z size (10)
10. CO2, 0 2, CH, gas monitoring instrument (GEM-500)
11. H2S gas monitoring insturment
12. Dibasic ammonium phosphate (10 lbs)
13. Distilled water (5 gallons)
14. Detergent (Alconox)
15. Cotton gloves
16. Personnel protective gear
17. Coolers and Ice
18. VOC Trip Blanks (2)
19. Polyethylene drop clothes
20. Field Log Book
21. Helium gas canisters
22. Vermiculite
23. Bubble wrap
24. Chain-of-Custody Forms
All equipment will be decontaminated at appropriate intervals (e.g., prior to initial use, prior
to moving to a new sampling site). Different decontamination procedures are used for
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different types of equipment that are used for conducting various field activities.
Decontamination procedures for different equipment are as follows:
I. Decontamination procedures for Teflon and stainless steel equipment.
a. Tap water and detergent (Alconox) rinse
b. Distilled water rinse (three times)
c. 10% nitric acid rinse
d. Distilled water rinse
e. Hexane rinse
f. Distilled water rinse
g. Air dry
h. Wrap in clean aluminum foil with dull side against the equipment.
2. Decontamination Procedures for Drilling Rig
a. Steam cleaning (off-site)
3. Decontamination Procedures for Personnel Protection Equipment
a. Detergent (Alconox) rinse
b. Tap water rinse
c. Air dry
All samples will be collected by using only dedicated and decontaminated equipment (one for
each sample). All sampling equipment will be decontaminated prior to use following the
decontamination procedures described above.
Soil samples will be collected from the split-spoons using a clean and decontaminated stainless
steel trowel. Soil Samples will be collected in cleaned and decontaminated wide mouth glass
jars. All samples will be placed in cooler chest and preserved with ice. All samples will be
shipped to the selected certified laboratories for analysis. Field and trip blanks will be
shipped to the selected laboratories together with the samples.
Field monitoring of different gas concentrations will be conducted using cleaned and purged
real time monitoring equipment. After each use all gas monitoring and sampling equipment
will be purged and cleaned with helium gas prior to the next use. Soil gas samples for
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analyses in the certified laboratory will be collected in clean and decontaminated stainless steel
canisters.
A.4.9 Sample Handling and Documentation for Samples Shipped to
Off-Site Laboratories
Once collected, each sample will be labeled with the collection locality, date, time, and sample
team identifier and then packed in ice in a cooler for temporary storage. Each sample will be
recorded on the Chain-of-Custody Form as soon as possible after collection. Samples will be
packed with bubble wrap, ice, and vermiculite. Samples will be shipped for next-day delivery
at the end of each sampling day.
A.5 .0 Soil Gas Monitoring Well Installation Procedures
Four Soil Gas Monitoring Wells will be installed. one at the center of each Soil Plot, and will
be protected by the 3' x 4' protective metal box. Three of the four Soil Gas Monitoring
Wells will be installed in the three Soil Plots located in the contaminated soil in Area 2 and the
fourth Soil Gas Monitoring \Veil will be installed inside the fourth Soil Plot located in
uncontaminated soil outside Area 2 (in a background location). Hollow-stem augers will act as
a casing as the boring is advanced and will prevent cross-contamination between distinct depth
intervals. The augers will be advanced by a combination of downward pressure and rotation.
Figures A-5 is a schematic well construction diagram for Soil Gas Monitoring Wells. The
proposed location of the Soil Gas Monitoring Wells (labeled SGMW-1 to SGMW-4) are
shown in Figures A-1.
The Soil Gas Monitoring Wells will be completed as shown in Figures A-2. A locking 3' x 4'
BILCO type protective metal box with a cover will be installed at grade level. A protective
concrete curve will be placed around the metal box.
All well casing and screen to be used in the construction of the Soil Gas Monitoring Wells
will be of flush threaded I" Schedule 10 stainless steel. Well screen for Soil Gas Monitoring
Wells will be 0.020 inch slot size. Screen lengths will be 2.0 feet. Prior to installation all
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FINISH GRADE TO WATER TIGHT
DRAIN AWAY FROM BOX WELL BO
GROUT _ __.._
BENTONITE PELLETS --
•
1" SCH. 10 SS PIPE
SILICA SANO --+---
VAPOR PROBE
1" DIA. X 2' LONG
1/4" FEMALE QUICK
COUPLE BOX SET IN CONCRETE
FINISHED AT GRADE
l[)
l[)
SS SCREEN, 0.02 SLOT -~---6'-------
NOTES: SS STAINLESS STEEL
Not to scale
[if atlonal Slarch and Ch•mlcal Company
FIGURE A-5
Soil Gos Monitoring Point
Construction Detail
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well casings and screens will be washed, cleaned and decontaminated using a steam cleaner
and will be transported to the well location wrapped in clean polyethylene sheeting.
Filter pack materials shall be of washed silica sand. The filter pack will extend to 0.5 feet
below the bottom of the screen, and to 0.5 feet above the top of the screen. A bentonite seal,
minimum two feet thick, will be placed above the filter pack and will be allowed to hydrate for
eight hours prior to installation of the bentonite neat cement grout seal.
Grouting and sealing will be completed as a continuous process, using Type I or V Portland
cement using no more than 7 gallons of water and no less than 6.5 gallons of water to a 94
pound bag of cement. Bentonite will be added to the grout during mixing at a rate of 10
percent to prevent formation of shrinkage cracks and to insure the integrity of the grout.
Grout will be tremied into the annular space, until undiluted grout is flowing from the
borehole. Immediately after grouting a sealed cap with an 1/4" size female type quick
connection will be installed on the well.
A.6.0 Moisture and Nutrient Addition Procedures
Once a week water will be added to two of the four Soil Plots (No.2 and No.3) at the rate of
3.6 liters per week using a clean and decontaminated watering can. Water added to Soil Plot
No.3 will be mixed throughly with 27 grams of dibasic ammonium phosphate. The solution
will be vigorously stirred for five m_inutes prior to applying the solution. The dibasic ammo-
nium phosphate will completely dissolve in the water. The water in Soil Plot No.2, and the
water and dibasic ammonium phosphate solution in Soil Plot No.3 will be evenly distributed
over the entire surface area of the Soil Plots.
A-11
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APPENDIXB
QUALITY ASSURANCE PROJECT PLAN
For
Remedial Design And Remedial Action (RD/RA) Work Plan
At
Operable Unit 4
National Starch and Chemical Company Site
Cedar Springs Road Plant
Salisbury, North Carolina
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Table of Contents
List of Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-4
List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-4
B.1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-5
B .1.1 Project Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-5
B.1.2 Project Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-5
Project Organization and Responsibility . . . . . . . . . . . . . . . . . . . . . . . . . . . B-6
B.2.1 Plant Manager and Project Coordinator . . . . . . . . . . . . . . . . . . . . . . . B-7
B.2.0
B.3.0
B.4.0
B.5.0
B.6.0
B.7.0
B.8.0
B.9.0
B.10.0
B.11.0
B.2.2 Project Director ...................................... B-7
B.2.3 Project Health and Safety Officer ........................... B-7
B.2.4 Project Environmental Engineer ............................ B-8
B.2.5 Field Operations Coordinator .............................. B-9
B.2.6 Quality Assurance Officer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-10
B. 2. 7 Laboratory Directors/Laboratory Coordinators . . . . . . . . . . . . . . . . . B-10
B.2.8 QA Reports to Management ............................. B-10
Project-Specific QA and QC Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . B-12
B. 3 .1 Detection Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-13
B.3.2 Data Precision and Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-13
B. 3. 3 Data Accuracy and Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-13
B. 3 .4 Completeness of Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-13
B.3.5 Comparability .................................... , . B-14
Drill Rig and Equipment Decontamination Procedures . . . . . . . . . . . . . . . . . B-15
Sample Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-17
B. 5 .1 Chain-of-Custody Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-17
B.5.2 Sample Labeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-18
Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-19
B.6.1 General Calibration Procedures ........................... B-19
B.6.2 Calibration Failures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-19
Analytical Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-20
B. 7 .1 Overview of Standard Laboratory Operating Procedures . . . . . . . . . . . B-20
B.7.2 Organic Compounds .................................. B-20
B.7.3 Metals ........................................... B-21
Data Reduction, Validation, and Reporting ....................... .
Quality Control Procedures ................................. .
B.9.1 Field Quality Control Procedures ......................... .
B.9.2 Laboratory Quality Control Procedures ..................... .
B.9.3 Metals and Miscellaneous .............................. .
Performance and Systems Audits and Frequency ................... .
Preventive Maintenance ................................... .
B.11.1 Routine Maintenance Activities .......................... .
B.11.2 Preventive Maintenance Documentation
B-22
B-23
B-23
B-23
B-24
B-25
B-26
B-26
B-26
A:\OU4QAPP.AA B-2
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B.11.3 Contingency Plans ................................... B-27
B.12.0 Specific Routine Procedures Used to Assess Data
Precision, Accuracy, and Completeness . . . . . . . . . . . . . . . . . . . . . . . . . . B-28
B.12.1 Laboratory Quality Control Checks . . . . . . . . . . . . . . . . . . . . . . . . B-28
B.12.2 Trip (Travel) Blank Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-28
B.12.3 Method Blank Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-28
B.12.4 Reagent Blank Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-29
B.12.5 Duplicate Sample Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-29
B.12.6 Check Standard Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-29
B.12.7 Surrogate Standard Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-29
B.12.8 Matrix Spike Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-30
B.12.9 Matrix Spike Duplicate Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . B-30
B.12.10 Verification/Reference Standard Analyses . . . . . . . . . . . . . . . . . . . B-30
B.12.11 Blank Spike Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-30
B.12.12 Laboratory Control Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-31
B.12.13 Standard Addition Spike Analyses . . . . . . . . . . . . . . . . . . . . . . . . B-31
B.12.14 Internal Standard Spike Analyses . . . . . . . . . . . . . . . . . . . . . . . . . B-31
B.13.0 Routine Methods to Assess Precision and Accuracy . . . . . . . . . . . . . . . . . . B-32
B.14.0 Nonconformance/Corrective Action Procedures . . . . . . . . . . . . . . . . . . . . . B-35
B.15.0 Quality Assurance Audits and Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . B-37
A:\OU4QAPP.AA B-3
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List of Tables __________________ _
Table Title Follows Page
B-3-1 Target Compound List (TCL) and Contract Required B-13
Quantitation Limits (CRQL) -Volatiles
B-3-2 Target Compound List (TCL) and Contract Required . B-13
Quantitation Limits (CRQL) -Semivolatiles
B-3-3 Target Compound List (TCL) and Contract Required B-13
Quantitation Limits (CRQL) -Pesticides and PCBs
B-3-4 Target Analyte List (T AL) and Contract Required B-13
Quantitation Limits (CRQL) - Metals
B-6-1 Summary of Operational Calibration Requirements B-19
B-11-1 Summary of Periodic Calibration Requirements B-26
B-13-1 QC Samples Used to Generate Precision and Accuracy B-32
List of Figures __________________ _
Figure Title
B-2-1 Natural Degradation Treatability Study Project Organization Chart
B-5-1 Analysis Request and Chain-of Custody Form
A:IDU4QAPP.AA B-4
Follows Page
B-6
B-17
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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 to be
gathered during the Natural Degradation Treatability Study for the Operable Unit 4 (OU4)
at the National Starch and Chemical Company's (NSCC's) site at the Cedar Springs Road
Plant in Salisbury, North Carolina.
This QAPP documents the measures that will be undertaken by National Starch and Chemical
Company and its subcontractors to ensure that the work performed will be of proper quality
for accomplishing project objectives and for responding to requirements of the U.S.
Environmental Protection Agency (USEPA) Region IV. The plan addresses the following:
1. The Quality Assurance (QA) objectives of the Project;
2. Project Organization and Responsibility; and
3. Specific Quality Assurance and Quality Control (QA/QC) procedures that will
be implemented to achieve these objectives.
The EPA' s requirements with regard to QA focus on the acquisition of environmental data of
known and acceptable quality. The methods and procedures described herein comply with
EPA Environmental Compliance Branch Standard Operating Procedures and Quality
Assurance Manual (February 1991).
B.1.1 Project Description
This QAPP supplements the Natural Degradation Treatability Study Work Plan for the
Operable Unit 4 at the NSCC's Cedar Springs Road Plant site. A description of the Project
can be found in the Work Plan.
B.1.2 Project Objectives
The objective of the Natural Degradation Treatability Study for the OU4 is to collect and
evaluate the data needed to achieve the objectives outlined in the Work Plan.
A:\OU4QAPP.AA B-5
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B.2.0 Project Organization and Responsibility
The Environmental Projects Group of National Starch and Chemical Company will conduct
and manage the various work tasks required for the Natural Degradation Treatability Study
as described in this Work Plan. Staff members of the Environmental Projects Group will
be assisted by several experienced and qualified sub-contractors. A drilling sub-contractor,
registered in North Carolina and certified to work in hazardous waste sites, will be retained by
NSCC to conduct drilling and split-spoon soil sampling operations. Actual collection of soil
samples from the split-spoons will be performed by staff members of NSCC's Environmental
Projects Group who have been trained and are experienced in conducting such sampling. A
Contract Laboratory Program (CLP) certified laboratory will be retained by NSCC to carry
out the analyses of the soil samples collected for this Work Plan. NSCC will also retain the
services of a certified laboratory qualified and experienced to conduct analyses of soil gas
samples. Since there is no CLP certification program for analysis of soil gas samples a state
certified laboratory will be used for soil gas analysis. Figure B-2-1 illutrate the proposed
Project Organization and Responsibilities of various members of the Project Team selected
for conducting the Natural Degradation Treatability Study.
The principal NSCC staff members assigned to this project are Mr. Ray Paradowski (Plant
Manager and Project Co-ordinator), Dr. Abu Alam (Project Director), Mr. Richard Franklin
(Project Health and Safety Officer), Mr. Michael Ford (Project Environmental Engineer), Mr.
Sreedhar Velicheti (Quality Assurance Officer), and Mr. Kenneth Klutz (Field Operations
Coordinator. In addition, NSCC will retain the services of Graham & Currie (a North
Carolina Certified Driller experienced to conduct work in hazardous waste sites) to conduct
drilling operations, Laboratory Resources Inc. ( a CLP Certified laboratory) to conduct
analyses of soil samples, and Lancaster Laboratories (a certified laboratory qualified to
conduct analyses of gas samples). Other personnel will be assigned as deemed necessary. The
responsibilities of these individuals are described in the following sections.
A:\OU4QAPP.AA B-6
- ------- - - -- --- - - -
Figure B-2-1
PROJECT ORGANIZATION
NATURAL DEGRADATION TREATABILITY STUDY
Operable Unit 4
Cedar Springs Road Plant Site, Salisbury, North Carolina
USEPA REGION IV
Plant Manager &
Project Coordinator
Ray Paradowski
Health & Safety Officer Project Director Quality Assurance
Officer Richard Franklin Dr. Abu Alam Sreedhar Velicheti
Project
Environmental Engineer
Michael Ford
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Field Operations Drilling & Analytical Services (Soil) Analytical Services
Coordinator Well Installation Laboratory (Soil Gas)
Kenneth Kluttz Graham & Currie Resources Inc. Lancaster Lab. Inc.
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Field Sampling &
Monitoring
Michael Ford
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B.2.1 Plant Manager and Project Co-ordinator
The Plant Manager and Project Co-ordinator for this Project is Mr. Ray Paradowski. He will
keep abreast of all project activities and will do the following:
1. Co-ordinate with USEPA Region IV;
2. Co-ordinate with NCDEHNR
3. Co-ordinate with Project Personnel; and
4. Attend all meetings with USEPA and NCDEHNR.
B.2.2 Project Director
The Project Director will be Dr. Abu Alam. He Will have the primary responsibility for
planning and executing this project and will have the responsibility for all technical,
financial, and scheduling matters. Project Director's duties will include the following:
1. Assignment of duties, providing guidance to the Project Team Members and
delineating the needs and requirements of the Project;
2. Supervision of performance of various Project Team Members;
3. Planning and scheduling of all Project activities;
4. Keeping the Plant Manager and Project Co-ordinator informed of all aspects of the
Project;
5. Assure that all Project documents and deliverables are reviewed in a timely manner
for technical accuracy and completeness before their release;
6. Assure that the specific requirements of the QAPP are met; and
7. Attend all meetings with USEPA and NCDEHNR.
B.2.3 Project Health and Safety Officer
The Project Health and Safety Officer for this Project will be Mr. Richard Franklin. The
Project Health and Safety Officer is responsible for any modifications to this HSP. TheHealth
and Safety Officer will advise the Plant Manager and the Project Director on health and safety
A:\OU4QAPP.AA 8-7
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issues, e·stablish and oversee the Project air monitoring program, and perform at least one
comprehensive health and safety audit during the execution of the Project. The Project Health
and Safety Officer will advise the Project Director on changes and implementation of site
specific health and safety requirements. The Project Health and Safety Officer will give his
site audit report to the Plant Manager together with his recommendations of any site specific
needs. Mr. Franklin's work telephone number is [phone] Ext.233. Other
responsibilities of the Project Health and Safety Officer include:
1. Determining and posting emergency telephone numbers and routes to emergency
medical facilities, including poison control facilities, and arranging emergency
transportation to medical facilities;
2. Notifying local public emergency officers of the nature of the Project Team's
operations, and the posting of their telephone numbers in an appropriate location;
3.
4.
B.2.4
Observing on-site Project personnel for signs of exposure or physical stress; and
Ensuring that all site personnel have been given the proper medical clearance,
ensuring that all site personnel have met appropriate training requirements, and
have the appropriate training documentation on-site, and monitoring all team
members to ensure compliance with the HSP.
Project Environmental Engineer
The Project Environmental Engineer for this Project will be Mr. Michael Ford. The Project
Environmental Engineer is in charge of supervising work of all sub-contractors, and
conducting specific Project tasks. This includes adding the moisture and nutrients to the
selected Soil Plots, collecting soil and soil gas samples in the field, making sure that covers for
all Soil Plots are in place and locked after each sampling activity, and shipping all soil and soil
gas samples to the analytical laboratories with proper chain-of-custody forms.
The Project Environmental Engineer is also responsible for ensuring that all Project work
tasks are carried out in accordance with the Work Plan. He will coordinate all Project tasks
A:\OU40APP .AA B-8
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with the Project Director, the Project Health and Safety Officer and the Field Operations
Coordinator. The responsibilities of the Project Environmental Engineer will also include the
following:
1. The drilling sub-contractor is using proper equipment suitable for the Project;
2. All drilling equipment and split-spoon samplers are properly decontaminated and
protected from contamination prior to bringing these on site and actual use;
3. All portable field monitors and tools are cleaned, calibrated and protected from
contamination in accordance with the QAPP;
4. All soil and soil gas samples are collected, preserved and shipped according to the
QAPP;
5. Review work performed by the sub-contractors and approve their invoices;
6. Establish a record keeping system for the Project; and
7. Conduct Project closeout at the completion.
B.2.5 Field Operations Coordinator
The Field Operations Coordinator for this Project will be Mr. Kenneth Klutz. The Field
Operations Coordinator will be responsible for field implementation of the HSP. This will
include communicating site requirements to all on-site Project personnel (Both NSCC and
subcontractor personnel) and corisultation with the Project Health and Safety Officer. As
required by NSCC Policy, the Field Operations Coordinator will be responsible for informing
the Project Health and Safety Officer and the Plant Manager of any changes in the Health and
Safety Plan, so that those changes may be properly addressed. Other responsibilities of the
Field Operations Coordinator include:
1. Enforcing the requirements of the HSP, including the performance of daily safety
inspections of the work site.
2. Stopping work as required to ensure personal safety and protection of property, or
when life or property threatening non-compliance with safety requirements is
found.
A:IOU4QAPP.AA B-9
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B.2.6 Quality Assurance Officer
The Quality Assurance Officer for this. Project is Mr. Sreedhar Velicheti. The Quality
assurance Officer is in charge of conducting periodic audits and is responsible for monitoring
the Project activities to assure that all tasks are conducted to meet the Project Quality
Objectives. The Quality Assurance Officer reports directly to the Project Director.
The Quality Assurance Officer is responsible for making sure that all Project work undergoes
adequate quality review. Following are the responsibilities of the Quality Assurance Officer:
l. Contacting the analytical laboratories receiving samples to determine if samples are
prepared, packaged, and identified properly;
2. Conducting field audits of sampling events to assure that proper sample
identification, sampling techniques and chain-of-custody procedures are observed;
3. Reporting to the Project Director on personnel assigned to field supervision and
sample collection tasks are properly trained in sample collection, sample
identification and chain-of custody procedures; and
4. Reviewing work products and Project deliverables.
B. 2. 7 Laboratory Directors/Laboratory Coordinators
Two Laboratory Directors/Laboratory Coordinators will be used in this Natural Degradation
Treatability Study, one for each laboratory. Each Laboratory Director/Laboratory
Coordinatorand will ensure that analytical data from his laboratory meet the objectives dis-
cussed in the applicable sections of the QAPP. Laboratory Directors/Laboratory Coordinators
will be assigned by the two certified laboratories selected for conducting the laboratory
analyses of soil ans soil gas samples.
B.2.8 QA Reports to Management
Fundamental to the success of any QAPP is the active participation of the Project Organization
A:\OU4QAPP.M B-10
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and Management Team selected for the Project. The Organization and Management Team will
be aware of all Project activities at all times and will participate in development, review, and
operations of the Project.
Organization and Management Team will be kept informed of all QA activities throughout the
receipt, review, and/or approval of:
1. Task-specific QAPPs
2. Corporate and Project-specific QA/QC Plans and Procedures
3. Post-audit reports and audit closures
4. Corrective action overdue notices
5 N onconformance reports.
A:\OU4QAPP.AA B-11
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B.3.0 Project-Specific QA and QC Procedures
Project QA objectives are as follows:
1.
2.
3.
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 and will be
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 objectives. This plan describes the
QA Program to be implemented and the QC procedures to be followed by NSCC and its
subcontractors during the course of the Project. These procedures will:
1
2.
3.
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, which will include
information on the limitations of the analytical results.
In this regard, the QAPP will provide for the definition and evaluation of the following
parameters:
1.
2.
3.
4.
Detection limits
Data precision
Data accuracy
Completeness of data.
A:\OU4QAPP.AA 8-12
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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. Tables B-3-1
through B-3-4 provide listings of the estimated quantitation limits for Target Compound List
(TCL) and Target Analyte List (T AL) pollutants.
B.3.2 Data Precision and Evaluation
Precision is a measure of the mutual agreement among individual measurements of the
the same property, usually under prescribed similar conditions. Relative percent difference
(RPO) will be used to define the precision between replicate analyses. RPO is defined in
Chapter B.13.0. The precision objectives for the TCL and TAL analyses will be the same as
those estimated by the methodology. Nonhomogeneous constituents in the soil samples may
produce poor precision in the results. QA objectives for precision are less than 15 percent
(average RPO).
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 and T AL analyses will be the same as those established by the EPA for
its Contract Laboratory Program (CLP). QA objectives for accuracy will be in accordance
with EPA OLMO3.0 and ILMO4.0 Statement of Work (SOW).
I B.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.
A:IOU40APP.AA B-13
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Table B-3-1
Target Compound List (TCL) and Contract Required
Quantitation Limits (CRQL)•
Volatiles
(Page 1 of 2)
Quantitation Limits'
Parameter CAS Number Water /ua/L) Soil' /11n/kn\
Chloromethane 74-87-3 10 10
Bromomethane 74-83-9 10 10
Vinvl chloride 75-01-4 10 10
Chloroethane 75-00-3 10 10
Methvlene chloride 75-09-2 10 10
Acetone 67-64-1 10 10
Carbon disulfide 75-15-0 10 10
1, 1-Dichloroethene 75-35-4 10 10
1, 1-Dichloroethane 75-35-3 10 10
1,2-Dichloroethene /total\ 540-59-0 10 10
Chloroform 67-66-3 10 10
1,2-Dichloroethane 107-06-2 10 10
2-Butanone 78-93-3 10 10
1, 1, 1-Trichloroethane 71-55-6 10 10
Carbon tetrachloride 106-23-5 10 10
Bromodichloromethane 710-27-4 10 10
1,2-Dichloronronane 78-87-5 10 10
cis-1,3-Dichloronronene 10061-01-5 10 10
Trichloroethene 79-01-6 10 10
Dibromochloromethane 124-48-1 10 10
C:\PROJECTS\CDRSPRNG\OU4NDTS\QAPP\OAPP.831
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Table 8-3-1
(Page 2 of 2)
Quantitation Limits'
Parameter CAS Number Water l11n/L) Soil' t11n/kn\
1, 1,2-Trichloroethane 79-00-5 10 10
Benzene 71-43-2 10 10
trans-1,3-Dichloroorooene 10061-02-6 10 10
Bromoform 75-25-2 10 10
4-Methvl-2-nentanone 108-10-1 10 10
2-Hexanone 591-78-6 10 10
Tetrachloroethene 127-18-4 10 10
Toluene 108-88-3 10 10
1, 1,2,2-Tetrachloroethane 79-34-5 10 10
Chlorobenzene 108-90-7 10 10
Ethvl Benzene 100-41-4 10 10
Stvrene 100-42-5 10 10
Total wlenes 1330-20-7 10 10
' Specific quantitation limits are highly matrix dependent. The quantitation limits listed herein are provided for
guidance and may not always be achievable.
' Quantitation limits listed for soil are based on wet weight. The quantitation limits calculated by the laboratory
for soil, calculated on dry weight basis, as required by the contract, will be higher.
' Medium soil CRQLs for volatile TCL compounds are 120 times the individual low soil CRQL.
C:\PROJECTS\CDRSPRNG\OU4NDTS\QAPP\QAPP.B31
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Table 8-3-2
Target Compound List (TCL) and Contract Required
Quantitation Limits (CRQL)•
Semivolatiles
(Page 1 of 4)
Quantitation Limits'
Parameter CAS Number Water' '"n/L) Soil' /11n/kn)
Phenol 108-95-2 10 330
bis/2-Chloroethvllether 111-44-4 10 330
2-Chloroohenol 95-57-8 10 330
1,3-Dichlorobenzene 541-73-1 10 330
1,4-Dichlorobenzene 106-46-7 10 330
1,2-Dichlorobenzene 95-50-1 10 330
2-Methvlohenol 95-48-7 10 330
2,2'-oxvbis (1-chlorooropane)' 108-60-1 10 330
4-Methvlohenol 106-44-5 10 330
N-nitroso-di-n-oronvlamine 621-64-7 10 330
Hexachloroethane 67-72-1 10 330
Nitrobenzene 98-95-3 10 330
lsoohorone 78-59-1 10 330
2-Nitrophenol 88-75-5 10 330
2,4-Dimethvlphenol 105-67-9 10 330
bis/2-Chloroethoxv)methane 111-91-1 10 330
2,4-Dichloroohenol 120-83-2 10 330
1,2,4-Trichlorobenzene 120-82-1 10 330
Naohthalene 91-20-3 10 330
4-Chloroaniline 106-47-8 10 330
C:\PROJECTS\CDRSPRNG\OU4NOTS\QAPP\QAPP.B32
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Parameter
Hexachlorobutadiene
' 4-Chloro-3-methvlnhenol
2-Methvlnaohthalene
Hexachlorocvclooentadiene
2,4,6-Trichloronhenol
2,4,5-Trichloroohenol
2-Chloronaohthalene
2-Nitroaniline
Dimethvl nhthalate
Acenaohthvlene
2,6-Dinitrotoluene
3-Nitroaniline
Acenaohthene
2,4-Dinitronhenol
4-Nitroohenol
Dibenzofuran
2,4-Dinitrotoluene
Diethvlnhthalate
4-Chloroohenvl-ohenvlether
Fluorene
4-Nitroaniline
4,6-Dinitro-2-methvlohenol
C:\PROJECTS\CDRSPRNG\OU4NDTS\QAPP\OAPP.B32
Table 8-3-2
(Page 2 of 4)
Quantitation Limits'
GAS Number Water r11n/L) Soil' (11n/kn\
87-68-3 10 330
59-50-7 10 330
91-57-6 10 330
77-47-4 10 330
88-06-2 10 330
95-95-4 25 800
91-58-7 10 330
88-74-4 25 800
131-11-3 10 330
208-96-8 10 330
606-20-2 10 330
99-09-2 25 800
83-32-9 10 330
51-28-5 25 800
100-02-7 25 800
132-64-9 10 330
121-14-2 10 330
84-66-2 10 330
7005-72-3 10 330
86-73-7 10 330
100-01-6 25 800
534-52-1 25 800
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Parameter
N-nitrosodinhenvlamine
4-Bromonhenvl-nhenvlether
Hexachlorobenzene
Pentachloroohenol
Phenanthrene
Anthracene
Carbazole
Di-n-butvlnhthalate
Fluoranthene
Pvrene
Butvlbenzvlohthalate
3,3'-Dichlorobenzidine
Benzo(a \anthracene
Chrvsene
bis/2-Ethvlhe=•l'nhthalate
Di-n-octvl ohthalate
Benzolb\f\uoranthene
Be nzo I k\f\ uora nth ene
Benzo(a\nvrene
lndeno/1,2,3-cd'n"rene
Dibenzla,h \anthracene
Benzol n, h ,i\ ne rvlene
C:\PROJECTS\CDRSPRNG\OU4NDTS\OAPP\QAPP .832
Table B-3-2
(Page 3 of 4)
Quantitation Limits'
GAS Number Water l11n/Ll Soil' l,on/k□\
86-30-6 10 330
101-55-3 10 330
118-74-1 10 330
87-86-5 25 800
85-01-8 10 330
120-12-7 10 330
86-74-8 10 330
84-74-2 10 330
206-44-0 10 330
129-00-0 10 330
85-68-7 10 330
91-94-1 20 660
56-55-3 10 330
218-01-9 10 330
117-81-7 10 330
117-84-0 10 330
205-99-2 10 330
207-08-9 10 330
50-32-8 10 330
193-39-5 10 330
53-70-3 10 330
191-24-2 10 330
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Table B-3-2
(Page 4 of 4)
' Specific quanlitafion limijs are highly matrix dependent. The quantitation limits listed herein are provided for
guidance and may not always be achievable.
' Detection limits for soil are based on wet weight. The detection limits calculated by the laboratory for soil,
calculated on dry weight basis, as required by the contract, will be higher.
' Medium Water CRQLs for Semivolatile TCL Compounds are 100 times the individual Low Water CRQL.
' Medium Soil CRQLs for Semivolatile TCL Compounds are 30 times the individual Low Soil CRQL.
• Previously known by the name bis (2-chloroisopropyl) ether.
C:\PROJECTS\CDRSPRNG\OU4NDTS\QAPP\OAPP.B32
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Table 8-3-3
Target Compound List (TCL) and Contract Required
Quantitation Limits (CRQL)"
Pesticides and PCBs
(Page 1 of 2)
Quantitation Limits'
Parameter CAS Number Water /ua/L) Soil' /11n/kn\
alpha-BHC 319-84-6 0.05 1.7
beta-BHC 319-85-7 0.05 1.7
delta-BHC 319-86-8. 0.05 1.7
gamma-BHC (Lindane) 58-89-9 0.05 1.7
Heotachlor 76-44-8 0.05 1.7
Aldrin 309-00-2 0.05 1.7
Heptachlor epoxide 1024-57-3 0.05 1.7
Endosulfan I 959-98-8 0.05 1.7
Dieldrin 60-57-1 0.10 3.3
4,4'-DDE 72-55-9 0.10 3.3
Endrin 72-20-8 0.10 3.3
Endosulfan II 33213-65-9 0.10 3.3
4,4'-DDD 72-54-8 0.10 3.3
Endosulfan sulfate 1031-07-8 0.10 3.3
4,4'-DDT 50-29-3 0.10 3.3
Methowchlor 72-43-5 0.5 17.0
Endrin ketone 53494-70-5 0.10 3.3
Endrin aldehyde 7421-36-3 0.10 3.3
aloha-Chlordane 5103-71-9 0.5 1.7
gamma-Chlordane 5103-74-2 0.5 1.7
Toxaohene 8001-35-2 1.0 170
C:\PROJECTS\CDRSPRNG\OU4NDTS\QAPP\OAPP.B33
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Table B-3-3
(Page 2 of 2)
Quantitation Limits'
Parameter CAS Number Water lua/L) Soil' /11n/ka)
Aroclor-1016 12674-11-2 1.0 33
Aroclor-1221 11104-28-2 2.0 67
Aroclor-1232 11141-16-5 1.0 33
Aroclor-1242 53469-21-9 1.0 33
Aroclor-1248 12672-29-6 1.0 33
Aroclor-1254 11097-69-1 1.0 33
Aroclor-1260 11096-82-5 1.0 33
' Specific detection limits are highly matrix dependent. The detection limits listed herein are provided for
guidance and may not always be achievable.
' Detection limits listed for soil are based on wet weight. The detection limits calculated by the laboratory for
soil, calculated on dry weight basis, as required by the contract, will be higher.
' Medium Water CRQLs for Pesticide TCL and PCB Compounds are 100 times the individual Low Water
CRQL.
' Medium Soil CRQLs for Pesticide TCL and PCB Compounds are 15 times the individual Low Soil CRQL.
C:\PROJECTS\CDRSPRNG\OU4NDTS\OAPP\OAPP.B33
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Aluminum
Antimonv
Arsenic
Barium
Bervllium
Cadmium
Calcium
Chromium
Cobalt
Conner
Iron
Lead
Mannesium
Mannanese
Mercurv
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cvanide
Table 8-3-4
Target Analyte List (TAL) and Contract Required
Quantitation Limits (CRQL)"
lnorganics
Quantitation Limits
Parameter CAS Number Water l11n/L\ Soil Ima/kn\
7429-90-5 200 40
7440-36-0 60 12
7440-38-2 10 2
7440-39-3 200 40
7440-41-7 5 1
7440-43-9 5 1
7440-70-2 5000 1000
7440-47-3 10 2
7440-48-4 50 10
7440-50-8 25 5
7439-89-6 100 20
7439-92-1 3 0.6
7439-95-4 5000 1000
7439-96-5 15 3
7439-97-6 0.2 0.04
7440-02-0 40 8
7440-09-7 5000 1000
7782-49-2 5 1
7440-22-4 10 2
7440-23-5 5000 1000
7440-28-0 10 2
7440-62-2 50 10
7440-66-6 20 4
N/A 10 2
'Specific detection limits are highly matrix dependent. The detection limits listed herein are provided for
guidance and may not always be achievable.
C:\PROJECTS\CDRSPRNG\OU4NOTS\QAPP\QAPP.B34
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More than 90 percent of all data obtained on this Project should be valid based upon evaluation
of the QC data.
B.3.5 Comparability
To provide the comparability of the data to similar data sets, EPA-approved analytical methods
will be used. For TCL and TAL parameters, these methods will be from current EPA CLP
protocols. For miscellaneous parameters, these methods will be from current EPA 600-series
methods.
A:\OU4QAPP.AA B-14
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B.4.0 Drill Rig and Equipment Decontamination Procedures
Before being brought on site, any portion of equipment (drill rig, backhoe, etc.) that is over
the borehole (Kelly bar, mast, backhoe buckets, drilling platform, mudtub, hoist, or chain
pulldowns and/or cathead, etc.) will be steam-cleaned and wire-brushed to remove rust, soil,
and other material that may have come from other sites. The drill rig will then be inspected to
determine that oil, grease, hydraulic fluid, etc., have been removed, that seals and gaskets are
intact, and that no fluids are leaking. Steam cleaning of the drill rig will then occur before
drilling each borehole. In addition, downhole drilling, sampling, and associated equipment
that will come into contact with the downhole equipment and sample medium will be
decontaminated by the following procedure:
1.
2.
3.
4.
The mud tub and downhole augering, drilling, and sampling equipment will be
sandblasted if there is a buildup of rust, hard or caked matter, and/or painted equip-
ment. Sandblasting will be performed before arrival on site,
Cleaned with tap water and laboratory-grade detergent, using a brush, if necessary,
to remove particulate matter and surface films. Steam cleaning may be necessary to
remove matter that is difficult to remove with the brush.
Rinsed thoroughly with tap water.
Rinsed thoroughly with deionized water.
5. Rinsed twice with solvent (pesticide-grade isopropanol).
6. Rinsed thoroughly with organic-free water and allowed to air dry as long as possi-
ble. If organic-free water is not available, the equipment will be allowed to air dry
as long as possible. The equipment will not be rinsed with deionized or distilled
water.
NOTE: Organic-free water can be processed on site by purchasing or leasing a
mobile deionization-organic filtration system.
NOTE: Tap water may be applied with a pump sprayer. Other decontamination
liquids (deionized water, organic-free water, and solvents), however, must be
applied using noninterfering containers. These containers will be made of glass,
Teflon•, or stainless steel. No plastic containers or pump sprayers will be
A:\OU40APP .AA B-15
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7.
allowed.
Wrapped with aluminum foil, if appropriate, to prevent contamination if equipment
is going to be stored or transported. Clean plastic can be used to wrap augers, drill
stems, casings, etc. if they have been air-dried.
NOTE: Well casing and screen will be cleaned according to these procedures.
Before cleaning, however, it may be necessary to sand off printing inks, if present,
on these materials. If any of these materials are of polyvinyl chloride <PVC}
construction. the solvent rinse step should be omitted. No glued joints are
allowed.
Decontamination rinse waters will be discharged into NSCC's wastewater treatment system at
the decontamination facility located on site.
A:IOU4QAPP.AA B-16
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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 the 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:
1. In one's actual possession
2. In view, after being in physical possession
3. Locked so that no one can tamper with it, after having been in physical custody
4. In a secured area, restricted to authorized personnel.
The following procedures will be implemented for samples subject to chemical analysis for this
Project:
1. 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. In
the event that 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 Director will then be notified. The decision will be
made by the Project Director 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.
2.
3.
4.
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 Project
Director or to his designated representative for record keeping.
5. The custody of individual sample containers will be documented by recording each
container's identification on a Chain-of-Custody Record form.
A:\OU4QAPP.AA B-17
-- --- --- -- -
M Laboratory Resources~
LRIOUOTE t CHAIN OF CUSTODY
CUSTOMER INFORMATION • -~ PROJECTINFORMATION ·•.
cusroMER ___________ _ """'-""'·~· ------------
AOORESS:
PAOJECTLOCATlON: ______ STATE: __
........ _____________ _
TELE~: ___________ _ ~~PHON<E·c_ __________ _
FAX:
"""'""' "" C ""' _, ........ """ <M.TE llilE s
<XWCTED c::o..LECTE0 ~ !
- - --
PAGE OF
BILLING ltffORMATIOH ,.,., ,, '• •
SILL TO:
ADORESS:
ATTENTION: __________ _
TELEPHONE: ___________ _
PO•:
ANALYSIS
TUFINAAOUNO (N:>ICATE IN CAl£N0,t.R DAYS): --"" --HARO co,,, --oeuv. PKO O RETIJRN TO CUE NT FOR DISPOSAL O LAB OISPOSA,L
"IAME OF LA8 PERSC>f,HE\. CONARMING,,_ -------------------j KNOWN HAZARD (FLAMMABl..E, E.XPLOSIVE, TOJUCJ
DELIVERA8l.ESl(CIACL..E ONE): 0,.TA OATNOC AEO,OELN IIL..VCLP I NJ,O..P II a YES a NO (IF YES EXPL>JN UNDER COMMENTS)
l<U'REOl t(V/ASP 0.P OTHER [!J]!'.I!J COHDIT\CIN.SOl'BOTTLESANOCOOLEAATRECEIPT:
S-UIP\.ER / AFFlUA TlCIN: DATE: Q COMPLIANT O NOT COMPU.vfl" (IF NOT EXPLAIN UNOER COMMENTS)
RECEIVED I AFFIUATlON TIME: COMMENTS, _________________ _
RElltO.llSHED I AFFllJATl()fll•
!'IECEIVE01 AFFIUATION:
RELIHOUlStfEO / AFFLL.\TION:
RECEIVED/ AF'FUATlON:
DATE:
TIME:
DATE:
TIME:
--
/H:_atlonal Starch and Cht1mical Company
ANALYSIS REQUEST AND
CHAIN-OF-CUSTODY FORM
-
Figure B-5-1 ~-----------------------
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6. Analyses for each sample will also be recorded on a Chain-of-Custody Record
form.
7. The following documentation will supplement the chain-of-custody records:
a.
b.
C.
B.5.2
Sample label on each sample
Sample seal on each sample
Field Daily Activity Log.
Sample Labeling
Sample labels must contain sufficient information to uniquely identify the sample in the
absence of other documentation. Labels will include as minimum:
1.
2.
3.
4.
5.
6.
7
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.
In addition, a 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.
A:\OU4QAPP.AA B-18
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B.6.0 Equipment Calibration
B.6.1 General Calibration Procedures
Laboratory and field testing equipment used for analytical determinations will be inspected and
calibrated periodically.
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, and
experience. A summary of calibration requirements for certain laboratory instruments is
included in Table B-6-1.
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
inadvertently used, and notify the Project Director 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 inadvertent 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 Project Director. If the activity results are adversely affected, the results of the
evaluation will be documented and the appropriate personnel notified.
A:\OU40APP .AA B-19
--- ------ -- ---- -- --
Table B-6-1
Summary of Operational Calibration Requirements
(Page 1 of 3)
Calibration Standards Used Initially
Instrument and Dailv Acceptance Limits Corrective Actions Documentation
Atomic absorption Initial: 5 levels and blank Correlation coefficient :':_0.995 Make new standards and/or Instrument data file
spectrophotometer establish new calibration curve
Daily: 1 check standard (mid-range) Daily check standard 90-110%
per 10 samcles recoverv
Inductively coupled plasma Initial: high standard and blank NIA Establish new curve. Repeat twice Instrument data file
emission spectrophotometer (daily check); if outside control limit,
Daily: Check standard (mid-range) Check standard :!:. 10% then recalibrate making new
and calibration blank every 10 standards if necessary
samoles
GC/MS Mass scale calibration every 12 U.S. EPA CLP criteria Retune: system maintenance Instrument calibration file
hours: BFB/OFTPP and/or GC/MS project file
Initial: 5 levels and blank meets all SPCC and CCC criteria Make new standards; recalibrate
Dailv: 1 level /low-ranael Make new standards; recalibrate
Gas chromatograph Initial: 3-5 levels and blank Response factor ¾RSD <20% or Make new standards or establish Calibration chart file or GC
use curve new calibration curve project file
Daily: 1 level of check standards Check standard :!:.15% of predicted Make new standards or establish
(mid-range) response new calibration curve
Standard check every 10 samples RF <:t15% of daily calibration Reanalyze samples that were GC project file
(mid-range) (<:!:,20% for confirmation column). analyzed after standard that failed
Retention times within retention time criteria and before the next standard
windows (for methods using that passes criteria
retention time windows)
KN/\NP901 B.6A(149)/11 •23•92/F1
----------- ----
Table 8-6-1
(Page 2 of 3)
Calibration Standards Used Initially
Instrument and Dailv Acceotance Limits Corrective Actions Documentation
UV-visible Initial: 3-5 levels and blank Graph curve Recalibrate, making new standards Calibration fileAogbook
spectra photometer if necessary
Daily: 1 check standard (mid-range) Daily check standard 90-110% Recalibrate
recovery
Quarterly: Wavelength accuracy and Manufacturer specifications Service
photometric linearitv
pH meter Daily: 2 levels (4.0-7.0) :t0.05 pH unit (1) Clean or replace electrode Logbook
(2) Recalibrate
Dailv: Check calibration (1 0.0l +10% of true value (31 Service
Specific conductance Dailv: KCI check standard + 10% of exoected resoonse Reoeat test Pro;ect file
Total organic carbon Daily: 3 levels and blank %RSD of RFs < 20% Make new standards and recalibrate Project file
Reanalyz~ affected samples
Dailv: check standard /mid-ranael RF +15%0 from calibration curve
Total organic halogens Daily: 2 levels; check standard every 15% of true value and recalibrate Make new standards Project file
20. Blank everv 10.
HPLC Initial: 3-4 levels and blank Graph curve or RF %RSD <20% Make new standards and/or Project file
establish a new calibration curve
Daily: Check standard every 10 15% of original curve Reanalyze affected samples
samoles (mid-ranae)
Ian Chromatograph Initial: 3 levels and blank Graph curve Make new standards and recalibrate Project file
Reanalyze affected samples
Daily: 1 level of check standards Daily: !,10% of original curve
everv 10 samoles /mid-ranael
KN/WP901B.6A(149)/11-23-92/F1
--- --- - - -- -- --- ----
Table B-6-1
(Page 3 of 3)
Calibration Standards Used Initially
Instrument and Dailv Acce□tance Limits Corrective Actions Documentation
GC/MS -Dioxins and furans Mass scale calibration: PFTBA Method 8280 criteria System maintenance GC/MS project file
Initial: 5 levels and blank RSD <15% Recalibration
Daily: 1 level (low level) :!:,30% of predicted response Repeat daily check and recalibrate if
necessarv
KNNvP9018.6A(149)/11-23-92/F1
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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:
1. Holding times and the amount of sample available will be reviewed and the analyses
prioritized.
2. Analyses will be performed within holding times according to accepted procedures.
3.
4.
5.
6.
A calibration curve consisting of at least three standards and a reagent blank will be
prepared as specified in the methodology.
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 percentage recovery 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 Laboratory Resources Teterboro Laboratory.
The instrumental techniques employed will be gas chromatography/mass spectrometry
(GC/MS) and gas chromatography with electron capture detector (GC/ECD). The Teterboro
laboratory is certified under CLP for organic analyses. Procedures instituted by CLP will be
adhered to during appropriate organic analyses pertaining to the Natural Degradation
Treatability Study at the Cedar Springs Road site. The analyses for organic compounds will
be based on the EPA OLMO3.0 SOW.
The address for the Laboratory Resources Laboratory in Teterboro is as follows:
Laboratory Resources
A:IOU4QAPP.AA B-20
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100 Hollister Road
Teterboro, NJ 07608-1111
B.7.3 Metals
The analyses for TAL metals will follow the EPA ILMO4.0. The Teterboro Laboratory has
produced acceptable results on CLP performance evaluation samples and is qualified to
perform CLP inorganic analysis. These analyses will be performed by Laboratory Resources.
A:\OU4QAPP.AA B-21
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B.8.0 Data Reduction, Validation, and Reporting
The final report will include, but not be limited to the following:
1.
2.
3.
4.
5.
6.
7.
8.
Completed Analysis Request and Chain-of-Custody Record form
Report data
Method detection limits
Method blank results
Matrix spike 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.13.0. When data
are reduced, the method of reduction will be identified and described.
Calculations included in the final report will be checked by a person of appropriate technical
expertise 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.
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B.9.0 Quality Control Procedures
B.9.1 Field Quality Control Procedures
To confirm the integrity of data from field sampling efforts, equipment blanks and duplicate
samples (QA samples) will be submitted to the Laboratory Resources laboratory. These QA
samples will be analyzed for the same parameters as the media samples (TCL and T AL
parameters). The confidence limits and percent level of uncertainty will be calculated and
reported in the Natural Degradation Treatability Study Report. Duplicate systems will
constitute 10 percent of the samples collected. One equipment blank will be prepared for
every 20 samples (including duplicates) submitted for analysis.
Standard sampling equipment and procedures will be used for blank sampling as described in
the Sampling and Analysis Plan (SAP). All blank 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
EPA OLMO3.0 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 EPA criteria. The continuous calibration is also verified
prior to sample analysis by re-analysis of the midrange standard.
Standards, method blanks, and samples will be spiked before analysis with surrogate standards
as specified in CLP 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 twenty samples will be purged and analyzed for volatile
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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 twenty 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 percent recovery
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.9.3 Metals and Miscellaneous
As for the organics, at least one method blank consisting of reagent water and all reagents
used in the method will be analyzed for every 20 samples. Duplicate and matrix spike
analyses will also be conducted at the same frequency as for the organics, although not
necessarily on the same samples, due to potential sample volume limitations.
Evaluations of the QC data and any corrective action necessary will be the same as for the
organics.
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B.10.0 Performance and Systems Audits and Frequency
Audits may be conducted periodically to verify compliance with specific Project QA/QC
program requirements. Audits consist of evaluations of QA/QC procedures and the
effectiveness of their implementation, an 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 personnel.
In an audit, records of field operations may be reviewed to verify that field-related activities
have been performed in accordance with appropriate Project procedures. Items reviewed may
include, but not be limited to: calibration records of field equipment; daily field activity logs;
photographs; and data, logs, and check prints resulting from the field operations.
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 Project requirements; and maintenance and filing of
Project records.
Audit results are transmitted to the Project Director for information and corrective action as
appropriate.
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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 in the event of equipment failure.
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 spurious environmental measurements that could
endanger site personnel or lead to inappropriate remedial responses. Table B-11-1 summarizes
a preventive maintenance program for laboratory instrumentation and equipment.
B.11.2 Preventive Maintenance Documentation
Laboratory instrument logs are used to record maintenance and service procedures and to
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Table B-11-1
Summary of Periodic Calibration Requirements
Instrument Calibration Standards/Frequency Acceotance Limits Corrective Actions
Analytical balance Daily: Sensitivity (with a Class "S" Acceptance criteria based on Adjust sensitivity
weight) ±_1% of Certified Weight Value
Quarterly: Reproducibility All balances are checked and
Quarterly: Consistency serviced quarterly by an outside
Quarterly: Class "S" weights service contractor
check
Thermometers Annually: Calibrate in constant ±_o.s•c Discard thermometer
temperature baths at two
temperatures against precision
thermometers certified bv NBS
,
Pipettors Quarterly: Gravimetric check High volume (>100 µL}: ::1.0% Service or replace
relative error and RSD
Low volume (<100 µL): ::2.0%
relative error and RSD
Refrigerators Daily: Temperature checked and 4±_2°C Notify quality control coordinator;
recorded service
KNIWP901 B.111 (149)/11-2J-92fF 1
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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
Laboratory Resources maintains an inventory of spare parts and equipment to be used in the
case of equipment failure. In addition, backup instrumentation is available to minimize the
effects of instrument downtime. Manufacturer service contracts have been purchased for some
equipment to ensure prompt response for needed repairs. And finally, a network of
Laboratory Resources 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.
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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
quality control checks performed by Laboratory Resources, (2) the procedures Laboratory
Resources 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 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 B .13. 0.
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 soil/sediment 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
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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 Surrogate 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
spik\ng compounds before purging or extraction to monitor preparation and analysis of
samples.
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B.12.8 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. Matrix spikes are prepared and
analyzed at a frequency of one per twenty samples.
B.12.9 Matrix Spike Duplicate Analyses
Similar in concept to the matrix spike sample above, it is a separate aliquot of sample that is
spiked with the analyte(s) of interest and analyzed with the associated sample and matrix spike.
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. Matrix spike 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.14.0.)
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 soil/sediment 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
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strong evidence that the method has been performed correctly by the laboratory for these
samples, but matrix interferences have affected the results.
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 EPA, Environmental
Regulatory Agency (ERA), or National Institute for Standards and Technology (NIST), 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.
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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:
%R = (A-B) x 100
T
A = Concentration determined in unspiked aliquot
B = Concentration determined in spiked aliquot
T =Known value of the spike
%R =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 RPO in
the concentration level of each constituent; where A, and B, are the concentrations of
constituents A and B.
IA; -B,1
(A; + B;)/2
X 100
Control Charts. The control chart program currently in use at the Laboratory Resources
Teterboro laboratory calculates upper and lower control and warning limits as follows:
A:\OU4QAPP.AA
Upper Control Limit= p+3s
Lower Control Limit = p-3s
Upper Warning Limit = p+2s
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Table 8-13-1
QC Samples Used to Generate Precision and Accuracy
QC Samole Purpose Concentration Level
Matrix spike/matrix spike Precision and accuracy Low-level'
duplicate
Mid-level'
Hiah-level'
Matrix spike Accuracy Low-level
Mid-level
Duplicate Precision NIA
TCLP matrix spike Accuracy Low-to high-level'
Surrogate spike Accuracy Low-level
Mid-level
High-level
Laboratorv control sample Accuracy Mid-level
'Low-level is defined as concentrations from the method detection limit to 10 times the MDL.
'Mid-level is defined as the mean level between the method detection limit and the upper end of the linear range.
'High-level is defined as concentrations at the upper end of the linear range.
Method References
8240,8270,608, 8080,
8010/8020, CLP SOW 2/88, 504,
8090
415.1, 9060
610, 8310
7470, 7471, CLP ILM01.0 for Hg
and cyanide
General chemistry methods', all
methods for graphtte furnace
atomic absorotion and ICP
All inorganic methods and
oeneral chemistrv methods
1311,8240,8270,8080,8150,
6010, 7470, 7471
8240, CLP SOW 2/88 for VOA
8270, CLP SOW 2/88 for BNA
8080, CLP SOW 2/88 for Pest.,
8010/8020, 8090
CLP ILM01.0
'Matrix spike/matrix spike duplicates may be analyzed for general chemistry parameters in lieu of matrix spikes and duplicates.
'Spike level depends on the concentration of the original sample. The level ranges from five times the method detection limtt to the TCLP regulatory
limit.
KN,WP901 B.131 ( 1~9)111-23-92/F 1
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Lower Warning Limit = p-2s
where:
p = average percent recovery
s = standard deviation of percent recovery
Detection Limits. All analytical methodologies have an associated method detection limit
below which an analyte present in the sample cannot be accurately measured.
PQLs and MD Ls. The practical quantitation limit (PQL) is defined by 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 EPA SW-846 and
CLP methodology.
Results for organics analyses are reported using 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 EPA CLP GC/MS methods, values that are below required PQLs, but can still be
quantified, are flagged with a "J" as "estimated concentrations." The laboratory verifies the
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 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 matrix spike containing the
analyte of interest at a concentration three to five times the estimated MDL. The t-statistic is
obtained from the following table:
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No. of samples:
3
4
5
6
7
8
9
10
I-statistic
6.96
4.54
3.75
3.36
3.14
3.00
2.90
2.82
The MDL shall be estimated as follows:
1. 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).
2. The variance (S2) for each analyte shall be determined as follows:
where X; = the ith measurement of the variable x and x = the average value of x;
- 1 n
X = -L X;
n i=1
3. The standard deviation (s) for each analyte shall be determined as follows:
s = (S2)'h
4. The MDL for each analyte shall be determined as follows:
A:\OU4QAPP.AA
where t<o-t,. -_99J is the one-sided t-statistic appropriate for the number of
samples used to determine (s), at the 99 percent level.
8-34
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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:
1. Project staff -During the performance of field investigation and testing,
supervision of subcontractors, and performance of audits and verification of
numerical analyses
2. Laboratory staff -During the preparation for and performance of laboratory
testing, calibration of equipment, and QC activities
3. Oua!ity 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:
1. Name of the individual identifying or originating the nonconformance
2. Description of the nonconformance
3. Any required approval signatures
4. Method for correcting the nonconformance
5. 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 Project Director or the Laboratory Director. In addition, the
Laboratory Director will notify NSCC of significant nonconformances that could impact the
results of the work and will indicate the corrective action taken or planned.
The Project Director will be responsible for approving corrective actions. Completion of
corrective actions for significant nonconformances will be verified by the Project Director.
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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.
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B.15.0 Quality Assurance Audits and Reports
To verify compliance with specific Project QA/QC program requirements. audits may be
conducted. Audits consist of: evaluations of QA/QC procedures and 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:
1. Field operations records
2. Laboratory testing and records
3. Equipment calibration and records
4. Identification and control of samples
5. Numerical analyses
6. Computer program documentation and verification
7. Transmittal of information
8. Record control and retention.
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APPENDIXC
HEALTH AND SAFETY PLAN
For
Natural Degradation Treatability Study Work Plan
At
Operable Unit 4
National Starch And Chemical Company Site
Cedar Springs Road Plant
Salisbury, North Carolina
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Table of Contents
List of Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-4
List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-4
C.1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-5
C.1.1 Scope of Work ...................................... C-5
C.1.2 Health and Safety Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-5
C. I. 3 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-6
C.2.0 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-6
C.2.1 Project Manager and Project Coordinator . . . . . . . . . . . . . . . . . . . . . C-6
C.2.2 Project Director ....................................... C-7
C.2.3 Project Health and Safety Officer .......................... C-7
C. 2.4 Project Environmental Engineer . . . . . . . . . . . . . . . . . . . . . . . . . . C-8
C.2.3 Field Operations Coordinator ............................. C-8
C.2.4 All Other Project Personnel .............................. C-8
C.3.0 Hazard Assessment ........................................ C-9
C.3.1 Chemical Hazards .................................... C-9
C.3.2 Exposure Standards ................................... C-9
C.3.3 Physical Hazards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-10
C.4.0 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-11
C .4. I General Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-11
C.4.2 Drilling Equipment Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . C-13
C.4.2.1 General Drilling Practices . . . . . . . . . . . . . . . . . . . . . . . . C-13
C.4.2.2 Catline Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-13
C.4.2.3 Pipe Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-14
C.4.3 Heat and Cold Illness Prevention . . . . . . . . . . . . . . . . . . . . . . . . . C-14
C.4.3.1 Heat Stress ................................. C-14
C.4.3.2 Cold Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-16
C.4.4 Hearing Conservation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-17
C.4.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-18
C.4.6 Sanitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-18
C.5.0 Personal Protective Equipment ................................ C-18
C.5.1 Respirator Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-19
C.5.2 Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-20
C.5.2.1 Level D Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-20
C.5.2.2 Level C Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-20
C.6.0 Site Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-21
i C.6.1 Authorization to Enter . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . C-21
C.6.2 Hazard Briefing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-22
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Table of Contents (Continued)
C.6.3 Documentation of Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . C-22
C.6.4 Entry Log . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-22
C.6.5 Contamination Control Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-22
C.6.6 Entry Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-23
C.6.7 Emergency Entry and Exit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-23
C.7.0 Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-24
C.7.1 Personnel Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-24
C.7.2 Equipment Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-24
C.8.0 Site Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-25
C.8.1 Air Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-25
C.8.2 Noise Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-25
C.8.3 Monitoring Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-26
C. 8.4 Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-26
C.9.0 Employee Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-26
C.10.0 Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-27
C.11.0 Emergency Response Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-28
C.11.1 Employee Injury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-28
C. l l.1.1 Chemical Inhalation . . . . . . . . . . . . . . . . . . . . . . C-29
C.11.1.2 Eye Irritation . . . . . . . . . . . . . . . . . . . . . . . . . . C-29
C.11.1.3 Skin Contact. . . . . . . . . . . . . . . . . . . . . . . . . . . C-29
C.11.1.4 Personal Injury Accident . . . . . . . . . . . . . . . . . . . C-29
C.11.2 Emergency Medical Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-30
C.11.3 Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-30
C.11.4 Emergency Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-31
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List of Tables __________________ _
Table
3-1
3-2
Title
Ranges and Frequency of Detection or Organic Compounds
Found in Soil Phase I and II OU3 RI
Permissible Exposure Limits and STELs
Quantitation Limits (CRQL) -Semivolatiles
Follows Page
C-9
C-10
List of Figures __________________ _
Figure Title Follows Page
C-1 Hospital Route Map C-30
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C .1. 0 Introduction
This Health and Safety Plan (HSP) establishes the work practices necessary to help ensure
protection of National Starch and Chemical Company (NSCC) personnel and personnel of sub-
contractors during field investigations and sampling activities for Operable Unit 4 (OU4) at
the National Starch and Chemical Company's (NSCC's) Cedar Springs Road Plant site.
The objective of this Health and Safety Plan is to provide a mechanism for the establishment
of safe working conditions at the site. The safety procedures have been established following
an analysis of potential hazards at the site, and procedures have been developed to minimize
the potential of accident or injury.
All site operations will be performed in accordance with the Work Plan, this HSP, applicable
state, local and NSCC regulations and procedures, Occupational Safety and Health
Administration (OSHA), and National Institute for Occupational Safety and Health (NIOSH)
requirements. All NSCC employees and subcontractors shall comply with the requirements of
this HSP.
C.1.1 Scope of Work
Work for OU4 at this site will involve installation of four Soil Plots and four Soil Gas
Monitoring Wells installed inside the Soil Plots (one Soil Gas Monitoring Well in each Soil
Plot). Trained and experienced NSCC employees will be collecting soil samples from the Soil
Plots and soil gas samples from the Soil Gas Monitoring Wells installed inside the Soil Plots
located in the NSCC Plant Operations area (Area 2) of the Cedar Springs Road Plant. Soil
samples will be collected from soil borings and split-spoon samplers. Soil gas samples will be
collected from Soil Gas Monitoring Wells installed inside the Soil Plots in the Plant Operations
area (Area 2).
C.1.2 Health and Safety Policy
It is the policy of NSCC to provide a safe and healthy work environment for all NSCCs
employees. NSCC considers no phase of operations or administration to be of greater
importance than injury or illness prevention. Safety takes precedence over expediency or
shortcuts. At NSCC, we believe every accident and every injury is preventable. NSCC will
take every reasonable step to reduce the possibility of injury, illness, or accident.
This HSP prescribes the procedures that must be followed during the field activities at OU4 at
the NSCC's Cedar Springs Road Plant site. Operational changes which could affect the health
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and/or safety of personnel, the community, or the environment will not be made without the
prior approval of NSCC's Plant Manager and Project Coordinator, the Project Director and
the Health and Safety Officer. The provisions of this HSP are mandatory for all NSCC
personnel and subcontractors assigned to the project. NSCC requires all visitors to the work
site to abide by the requirements of the HSP.
C .1. 3 References
This HSP complies with applicable OSHA and U.S. Environmental Protection Agency (U.S.
EPA) regulations. This follows the guidelines established in the following:
• Standard Operating Safety Guidelines, U.S. EPA, November 1984
• Occupational Safety and Health Guidance Manual for Hazardous Waste Site
Activities, National Institute for Occupational Safety and Health (NIOSH), pg. 86-
116
• Title 29 of the Code of Federal Regulations, (CFR) Part 1910.120, U.S. Depart-
ment of Labor/OSHA.
• Title 29 of the Code of Federal Regulations, (CFR) Part 1910.134, U.S. Depart-
ment of Labor/OSHA -Respiratory Protection Devices: Wearer FIT Policy
NSC Engineering Practice Manual Item No.14 -Employee and Contractor Training
Requirements
NSC Medical Manual Section Ill -Maintenance of Employee Monitoring and Medical Records
NSC Medical Manual Section IV -Periodic/Update Medical Examinations
NSC Medical Manual Section VI -Access to Employee Exposure and Medical Records
NSC SOP Manual Item No. Wl -Confined Spaces, Industrial
NSC SOP Manual Item No. W6 -Emergency Response Operations
NSC SOP Manual Item No. Wl 1 -Work-Related Illnesses and Injuries
These policies and their implementation are central to NSCC's accident prevention program.
C.2.0 Responsibilities
C.2.1 Plant Manager and Project Coordinator
The Plant Manager and Project Coordinator for this project is Mr. Ray Paradowski. As Plant
Manager, Mr. Paradowski has overall responsibility for the health and safety of all personnel
working at the Cedar Springs Road Plant site. He will ensure that any accidents or incidents
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are properly investigated. He will review on-site investigation of any accidents involving lost
time, hospitalization, or fatalities. Mr. Paradowski's work telephone number is (704) 633-
183 I Ext.231. As Project Coordinator, Mr. Paradowski will coordinate with the USEPA
Region IV and the NCDEHNR all Health and Safety related issues .
C.2.2 Project Director
The Project Director for this Project will be Dr. Abu Alam. Dr. Alam will direct and manage
all Project tasks and activities. Dr. Alam, together with the Health and Safety Officer, will
conduct the initial site health and safety audit for this Project. The Project Director will
receive health and safety advise from the Health and Safety Officer and will make sure that the
Project Team carries out all health and safety recommendations of the Health and Safety
Officer. Dr. Alam 's work telephone is [phone].
C.2.3 Project Health and Safety Officer
The Project Health and Safety Officer for this Project will be Mr. Richard Franklin. The
Project Health and Safety Officer is responsible for any modifications to this HSP. The
health and Safety Officer will advise the Plant Manager and the Project Director on health and
safety issues, establish and oversee the Project air monitoring program, and perform at least
one comprehensive health and safety audit during the execution of the Project. The Project
Health and Safety Officer will advise the Project Director on changes and implementation of
site specific health and safety requirements. The Project Health and Safety Officer will give
his site audit report to the Plant Manager together with his recommendations of any site
specific needs. Mr. Franklin's work telephone number is [phone] Ext.233. Other
responsibilities of the Project Health and Safety Officer include:
• Determining and posting emergency telephone numbers and routes to emergency
medical facilities, including poison control facilities, and arranging emergency
transportation to medical facilities.
• Notifying local public emergency officers of the nature of the Project Team's
operations, and the posting of their telephone numbers in an appropriate location.
• Observing on-site Project personnel for signs of exposure or physical stress.
• Ensuring that all site personnel have been given the proper medical clearance,
ensuring that all site personnel have met appropriate training requirements, and
have the appropriate training documentation on-site, and monitoring all team
members to ensure compliance with the HSP.
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C.2.4 Project Environmental Engineer
The Project Environmental Engineer for this Project will be Mr. Michael Ford. The Project
Environmental Engineer is in charge of supervising work of all sub-contractors, and
conducting specific Project tasks. This includes adding the moisture and nutrients to the
selected Soil Plots, collecting soil and soil gas samples in the field, making sure that covers for
all Soil Plots are in place and locked after each sampling activity, and shipping all soil and soil
gas samples to the analytical laboratories with proper chain-of-custody forms. The Project
Environmental Engineer is also responsible for ensuring that all Project work tasks are carried
out in accordance with the Work Plan. He will coordinate all Project tasks with the Project
Director, the Project Health and Safety Officer and the Field Operations Coordinator.
C.2.4 Field Operations Coordinator
The Field Operations Coordinator will be responsible for field implementation of the HSP.
This will include communicating site requirements to all on-site Project personnel (Both
NSCC and subcontractor personnel) and consultation with the Project Health and Safety
Officer. As required by NSCC Policy, the Field Operations Coordinator will be responsible
for informing the Project Health and Safety Officer and the Plant Manager of any changes in
the Health and Safety Plan, so that those changes may be properly addressed. Other
responsibilities of the Field Operations Coordinator include:
• Enforcing the requirements of the HSP, including the performance of daily safety
inspections of the work site.
• Stopping work as required to ensure personal safety and protection of property, or
when life or property threatening non-compliance with safety requirements is
found.
C.2.4 All Other Project Personnel
All NSCC and subcontractor personnel are required to read and acknowledge their
understanding of this HSP. All site Project personnel are expected to abide by the
requirements of this Health and Safety Plan and cooperate with site supervision in ensuring a
safe ,and healthy work site. Site personnel are required to immediately report to the Field
Operations Coordinator any of the following:
• Accidents or injuries, no matter how minor
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• Unexpected or uncontrolled release of chemical substances
• Any symptoms of chemical exposure
• Any unsafe or malfunctioning equipment
• Any changes in site conditions which may affect the health and safety of project
personnel.
C.3.0 Hazard Assessment
All NSCC personnel shall be familiar with the chemical, physical, and biological hazards at
the site, and strictly adhere to the appropriate safety procedures. The potential hazards and the
appropriate controls shall be presented to Project personnel during daily on-site Safety
Meetings.
C. 3 .1 Chemical Hazards
The potential chemical hazards involved at the NSCC site are listed in Table 3-1.
C.3.2 Exposure Standards
Currently, exposure guidelines to chemical substances are regulated by the OSHA. These
exposures are based upon the time-weighted average (TWA) concentration for a normal 8-hour
workday work week. Several chemical substances have short-term exposure limits or ceiling
values which allow a maximum concentration to which workers can be exposed continuously
for a short period of time without suffering from (I) irritation, (2) chronic or irreversible
tissue damage, (3) narcosis of a sufficient degree to result in accidental injury, impair self
rescuer, or substantially reduce work efficiency.
Threshold Limit Values (TLVs) refer to airborne concentration of substances which represent
conditions that nearly all employees may be repeatedly exposed to day after day without
adverse effect. These threshold limits are prescribed by the American Conference of
Governmental Industrial Hygienists (ACGIH). They are based upon the best available
information from industrial experience and animal or human studies. Because of the wide
variation in individual susceptibility, a small percentage of workers may experience discomfort
from some substances at concentrations below the recommended values. It has been NSCC
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Table 3-1
Ranges and Frequency of Detection
of Organic Compounds Found in Soil
Phase I and U OU3 RI
Compound Range (ppb) Frequency of Detection
1, 1,2-Trichloroethane 11-17 2
1,2-Dichloroethane 2-1600000 42
2-Butanone 3-42 30
Acetone 22-4000 40
Bromodichloromethane 1-220 7
Chloroform 2-900 17
Delta BHC 22 I
Dibromochloromethane 3-31 5
Tetrachloroethene 2 2
Toluene 1-3100 12
Total Xylenes 1 1
Trichloroethene 3 1
Vinyl Chloride 32-190 12
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policy to use these guidelines for good hygienic practices; however, whenever applicable,
stricter guidelines may be utilized.
The short-term exposure limit (STEL) is defined by the ACGIH and federal OSHA as a 15-
minute time-weighted-average exposure which should not be exceeded during a workday even
the 8-hour time weighted average is within applicable limits. Federal OSHA required that a
15 minute "Ceiling" concentration never be exceeded for that chemical constituent. This
notation appears as the letter "C" after the chemical name.
Under certain chemical substance listings, there may appear a "skin" notation. This refers to
the potential contribution to the overall exposure by the cutaneous route, including mucous
membranes and eye, either airborne or direct contact. Little quantitative data are available
describing absorption as a function of the concentration to which the skin is exposed.
Biological monitoring may be considered to determine the relative contribution of dermal
exposure to the total dose.
The ACGIH and federal OSHA have recognized that certain chemical substances may have the
potential to be carcinogenic in humans from epidemiological studies, toxicology studies and, to
a lesser extent, case histories.
Because of the long latency period for many carcinogens, it is often impossible to base timely
risk management decisions on the results of such information. Two categories of carcinogens
are designated based upon the most current literature and information. These include
confirmed human carcinogens and suspected human carcinogens. These chemical categories
are based on either (I) limited epidemiologic evidence, experience of clinical reports of single
assays, or (2) demonstration of carcinogens in one or more animal species by appropriate
methods. The worker potentially exposed to a known human carcinogen must be properly
equipped to insure virtually no contact with the chemical constituents. In the case of a
suspected human carcinogen, worker exposure by all routes must be carefully controlled by the
use of personal and respiratory protection, and administrative or engineering controls.
Table 3-2 represents the strictest set of guidelines currently established by either the ACGIH or
federal OSHA for the site contaminants.
C.3.3 Physical Hazards
The potential physical hazards involved at the NSCC site may include:
• Noise
• Heat Stress
• Vehicle Traffic
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Table 3-2
Permissible Exposure Limits and STELs
Compound
1, 1,2-Trichloroethane
1,2-Dichloroethane
2-Butanone
Acetone
Bromodichloromethane
Chloroform
Delta BHC
Dibromochloromethane
Tetrachloroethene
Toluene
Total Xylenes
Trichloroethene
Vinyl Chloride ( +)
* 1995 TLVs from ACGIH
+ OSHA regulated limits
C:IPROJECTSICDRSPRNG\OU4NDTSIHSAPIOU4HSP.AA
*PEL (ppm)
350
10
200
750
NIA
10
NIA
NIA
25
50
100
50
1
STEL (ppm)
450
--
300
1000
--
--
--
--
100
--
150
100
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• Lifting hazards
• Slip/Trip/Fall
• Soil Plot and Soil Gas Monitoring Well construction activities.
All NSCC employees shall be aware of these hazards, and utilize protective equipment and
proper work procedures.
C.4.0 Safety Program
C.4.1 General Practices
The following work practices will be observed during all site activities.
• At least one copy of this HSP shall be available at the project site in a location
readily available to all personnel.
• Contaminated protective equipment such as respirators, hoses, boots, etc., shall
not be removed from the regulated area until it has been cleaned or properly
packaged and labeled.
• Legible and understandable precautionary labels which comply with Hazard
Communication Standard shall be affixed prominently to containers of contami-
nated scrap, waste, debris, and clothing.
• Removal of contaminated soil from protective clothing or equipment by blowing,
shaking or any other means that disperses contaminants in the air is prohibited.
• No food or beverages shall be present or consumed in the regulated area.
• No tobacco products shall be present or used in the regulated area.
• Cosmetics shall not be applied within the regulated area.
• Contaminated materials shall be stored in tightly closed containers in well
ventilated areas.
• Containers shall be moved only with the proper equipment, and shall be secured
to prevent dropping or loss of control during transport.
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• Emergency equipment shall be located outside storage areas in readily accessible
locations that will remain minimally contaminated in an emergency.
• All areas that have been determined to be uncontaminated inside the regulated
area will be clearly marked as such. No personnel, equipment etc., shall be in
these areas until they have been decontaminated.
• All crew personnel on-site shall use the buddy system (working in pairs or teams).
If protective equipment or noise levels impair communications, pre-arranged hand
signals shall be used for communications. Visual contact shall be maintained
between crew members at all times and crew members must observe each other
for signs of toxic exposure. Indication of adverse effects include, but are not
limited to:
• Changes in complexion and skin coloration
• Changes in coordination
• Changes in demeanor
• Excessive salivation and pupillary response
• Changes in speech pattern.
Employees shall inform their partners or fellow team members of nonvisible effects of
overexposure to toxic materials. The symptoms of such overexposure include headaches,
dizziness, nausea, blurred vision, cramps, and irritation of the eyes, skin or respiratory tract.
Visitors to the site shall abide by the following:
• All visitors shall be instructed to stay outside the exclusion zone and remain
within the support zone during the extent of their stay. Visitors shall be cautioned
to avoid skin contact with contaminated or suspected contaminated surfaces.
• Visitors requesting to observe work conducted in the exclusion zone must wear all
appropriate PPE prior to entry into that zone. If respiratory protection devices are
necessary, visitors who wish to enter the exclusion zone must produce evidence
that they have had a complete physical examination, respirator training, and have
been fit tested for a respirator within the past 12 months.
• Visitor inspection of the contaminated area shall be at the discretion of the Field
Operations Coordinator.
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C.4.2 Drilling Equipment Operations
Before the start of the site work, the drilling subcontractor shall inspect all drilling equipment
in the presence of the Project Environmental Engineer and the Field Operations Coordinator.
The inspection shall be documented in the field records. If field operations last longer than I
week, the drilling equipment inspection must be repeated weekly.
The location of all underground utilities must be ascertained and confirmed before the start of
drilling operations.
Documentation that all nearby utilities have been marked on the ground, and that the drill site
has been cleared, shall be in the possession of the Field Operations Coordinator (or his
designee) before commencement of the intrusive investigation at that point of the site.
C.4.2.1 General Drilling Practices
• The off going driller shall inform the oncoming driller of any special hazards or
ongoing work that may affect the safety of the crew.
• Firefighting equipment shall not be tampered with and shall not be removed for
any reason otht;r than the intended firefighting purpose or for servicing.
• If lubrication fittings are not accessible with guards in place, machinery shall be
stopped for oil and greasing.
• Rigging material equipment for material handling shall be checked before use on
each shift and as often as necessary to ensure it is safe. Defective rigging shall
be removed from service.
• Work areas shall not be obstructed.
C.4.2.2 Catline Operations
• Only experienced workers shall be allowed to operate the cathead controls. The
kill switch must be clearly labeled and operational before operation of the catline.
• The cathead area must be kept free of obstructions and entanglements.
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• The operator shal I not use more wraps than necessary to pick up the load. More
than one layer of wrapping is not permitted.
• Personnel shall not stand near, step over, or go under a cable or catline that is
under tension.
• Employees rigging loads on catlines shall:
Keep out from under the load
Keep fingers and feet where they will not be crushed
Be sure to signal clearly when the load is being picked up
Make sure the load is properly rigged, because a sudden jerk in the catline
will shift or drop the load.
C.4.2.3 Pipe Handling
• Pipe should be loaded and unloaded, layer by layer, with the bottom layer pinned
or blocked securely on all four corners. Each successive layer shall be effectively
blocked or chocked.
• Workers shall not be permitted on top of the load during loading, unloading, or
transferring of pipe or rolling stock.
• Slip handles shall be used to lift and move slips. Employees shall not be
permitted to kick slips into position.
C.4.3 Heat and Cold Illness Prevention
C .4. 3 .1 Heat Stress
One or more of the following control measures can be used to help control heat stress. These
measures are mandatory if any site worker has a heart rate in excess of 115 beats per minute.
Heart rates shall be measured immediately prior to each rest period.
• Site workers shall be encouraged to drink plenty of water throughout the day.
They shall be advised to slightly increase their salt intake by lightly salting their
food.
• On-site drinking water will be kept cool (50 to 60 °F) to encourage personnel to
drink frequently.
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• A work regimen that will provide adequate rest periods for cooling down shall be
established, as required.
• All personnel shall be advised of the dangers and symptoms of heat stroke, heat
exhaustion and heat cramps.
• Cooling devices such as vortex tubes or cooling vests shall be used when
personnel must wear impermeable clothing in conditions of extreme heat.
• Employees shall be instructed to monitor themselves and co-workers for signs of
heat stress and to take additional breaks as necessary.
• A shaded rest area shall be provided. All breaks shall take place in the shaded
rest area.
• Employees shall not be assigned to other tasks during breaks.
• Employees shall remove impermeable garments during rest periods. This
includes white Tyvek-type garments.
• All employees shall be informed of the importance of adequate rest, acclimation,
and proper diet in the prevention of heat stress disorders.
The sign of heat stress disorders are given below:
Heat Rash
Heat Cramps
Heat Exhaustion
Heat Stroke
This is caused by continuous exposure to heat and humid air, and
is aggravated by chaffing clothes. Heat rash decreases a
person's ability to tolerate heat.
Heat cramps are caused by heavy sweating and inadequate
electrolyte replacement. Signs and symptoms include muscle
spasms and pain in the hands, feet and abdomen.
Heat exhaustion occurs from increased stress on various body
organs, including inadequate blood circulation due to cardio-
vascular insufficiency or dehydration. Signs and symptoms
include: pale, cool, moist skin; heavy sweating; dizziness and
nausea; and fainting.
Heat stroke is the most serious form of heat stress. Temperature
regulation fails and the body temperature rises to critical levels.
Immediate action must be taken to cool the body before serious
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C.4.3.2 Cold Stress
injury or death occurs. Competent medical help must be
obtained immediately. This is a true medical emergency. Signs
and symptoms include: red, hot, usually dry skin; lack of or
reduced perspiration; nausea, dizziness and confusion; an initial
strong, rapid pulse; and coma.
Most cold-related worker fatalities have resulted from a failure to escape low environmental air
temperatures or from immersion in low temperature water. The single most important aspect
of life-threatening hypothermia is a fall in the deep core temperature of the body.
Site workers shall be protected from exposure to cold so that the deep core temperature does
not fall below 36 oC. Lower body temperatures will very likely result in reduced mental
alertness, reduction in rational decision making or loss of consciousness with the threat of fatal
consequences. To prevent such occurrences, the following measures shall be implemented.
• Site workers shall be provided with warm clothing such as mittens, heavy socks,
etc., when the air temperature is below 45°F. Protective clothing, such as Tyvek
or other disposable coveralls shall be used to shield employees from the wind.
• When the air temperature is below 35°F, clothing for warmth in addition to
chemical protective clothing shall be provided to employees. This shall include:
• Insulated suits such as whole-body thermal underwear
• Wool socks or polypropylene socks to keep moisture off the feet
• Insulated gloves
• Insulated boots
• Insulated head cover such as hard hat, winter liner, or knit cap
• Insulated jacket with wind and water-resistant outer layer.
At air temperature below 35°F, the following work practices shall be implemented:
• If the clothing of a site worker might become wet on the job site, the outer layer
of clothing must be water-permeable.
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• If a site worker's underclothing beconies wet in any way, the employee shall
change into dry clothing immediately. If the clothing becomes wet from sweat-
ing, and the employee is not comfortable, he may finish the task at hand prior to
changing into dry clothing.
• Site workers shall be provided with a warm (65°F or above) break area.
• Hot liquids such as soups and warm, sweet drinks shall be provided in the break
area. The intake of coffee and tea shall be limited due to their circulatory and
diuretic effects.
• The buddy system shall be practiced at all times on-site. Any site-worker
observed with severe shivering shall leave the work area immediately.
• Site workers shall dress in layers, with thinner, lighter clothing worn next to the
body.
• Site workers shall avoid overdressing when going into warm areas or when
performing strenuous activities.
• Employees handling liquids with a high vapor pressure such as gasoline, methanol
or hexane shall take precautions to avoid soaking of gloves and clothing with
those materials.
C.4.4 Hearing Conservation
All on-site personnel shall wear hearing protection with a U.S. EPA Noise Reduction Rating
(NRR) of at least 20 dBA when noise levels exceed 85 dBA. All personnel required to wear
hearing protection shall receive baseline and annual audiograms and training as to the cause
and prevention of noise-induced hearing loss.
Noise monitoring shall be conducted if deeded necessary by the Project Health and Safety
Officer. Monitoring will be conducted using an ANSI Type I or Type 2 sound level meter.
Dosimetry may be conducted at the discretion of the Project Health and Safety Officer.
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C.4.5 Confined Space Entry
No confined space entries are anticipated for this project.
C.4.6 Sanitation
Toilet and personal hygiene facilities shall be provided and maintained. As a minimum, the
following practices shall be followed:
• Toilet and personal hygiene facilities shall be provided and maintained in
sufficient numbers for the use of all on-site personnel. Such facilities shall be
properly screened from public observation. All such facilities will comply with
state and local requirements.
• Portable toilets and personal hygiene facilities shall be emptied periodically.
• When no longer required, portable toilets and personal hygiene facilities shall be
removed from the site and the contents disposed of in a legal manner.
• Local sanitary regulations shall be enforced. Precautions shall be taken to prevent
the spread of infectious diseases.
• Trash collection shall be provided.
C.5.0 Personal Protective Equipment
Based upon the Job Hazard Analysis, it is expected that Project personnel will not need
extensive protective clothing, and that the on-site work can be completed in Level D protective
clotliing.
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C. 5 .1 Respirator Program
Based on data collected at this site during past field investigations there is no need for use of
respirators during the execution of this Project. However, in case unforeseen conditions are
encountered during the execution of this Project a Respirator Program is included here.
During the conduct of field investigations air monitoring will be carried regularly to make sure
that concentrations of air borne contaminants are always below action levels for respirator use.
In the event concentrations of air borne contaminants exceed action levels the site respiratory
protection program as described below will be implemented.
The site respiratory protection program will consist of the following:
• All site personnel shall have an assigned respirator.
• All site personnel shall have been fit tested and qualified in the use of a half-
mask-air-purifying respirator within the past 12 months. Fit test and respirator
qualifications cards must be provided
• All site personnel shall have been medically certified within the past year as being
capable of wearing a respirator. Documentation of the medical certification must
be provided to the Field Operations Coordinator prior to commencement of site
work.
• Only properly cleaned, maintained, NIOSH-approved respirators are to be used on
this site.
• If respirators are used, the respirator cartridge is to be disposed of at the end of
each work shift or when load up or breakthrough occurs.
• Contact lenses are not to be worn.
• All site personnel shall be clean shaven. Mustaches and sideburns are permitted,
but they must not tough the sealing surface of the respirator.
• Respirators will be inspected and a positive-negative pressure test shall be
performed prior to each use.
• After each use, the respirator shall be wiped with a disinfecting, cleansing wipe
and stored in a clean plastic bag.
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C.5.2 Levels of Protection
C. 5. 2 .1 Level D Protection
The minimum level of protective equipment to be worn on-site during this project is:
• Hard hat
• Safety glasses
• Steel-toed boots or shoes
• Long pants and a long-sleeved shirt.
Within the decontamination zone, the following protective equipment is required:
• Hard hat
• Safety glasses
• Steel-toed neoprene boots
• Nitrile gloves
• Uncoated Tyvek coveralls
• Long pants and a long-sleeved shirt.
If noise levels exceed 85 dBA, hearing protection with an NRR of at least 20 dBA shall be
used.
C.5.2.2 Level C Protection
Based on data collected at this site during past field investigations Level C Protection is not
required. However, Level C Protection is included here in the event unforeseen conditions
require use of Level C Protection at this site. The Level C Protection for this Project will
consist of the following:
• Hard hat
• Safety glasses
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• NIOSH-approved half-mask or full face air-purifying respirator with NIOSH-
approved cartridges for dust, mist, fume and organic vapors
• Steel-toed neoprene boots
• Nitrile gloves
• Uncoated Tyvek coveralls
• Long pants and a long-sleeved shirt.
Action Limits
Level D --------> Level C Required when the airborne concentration of suspected contami-
nants in the breathing zone are known to exceed the lowest PEL
shown in Table 3-2.
Level C --------> Level B Required if airborne concentrations of suspected contaminants
exceed 10 ppm in the breathing zone.
No one is pennitted to downgrade levels of PPE without authorization of the Health and
Safety Officer.
C.6.0 Site Control
Site control requires the establishment of specific measures to prevent unauthorized entry onto
the site and to protect all personnel entering the site from recognized safety and health hazards.
C.6.1 Authorization to Enter
Only personnel authorized by the Plant Manager, the Project Health and Safety Officer, or the
Field Operations Coordinator shall be permitted to enter the NSCC work area. Regulatory
personnel will be permitted to enter the work area at any time during business hours for the
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purpose of conducting a site inspection. News media and other personnel shall not be allowed
within the NSCC work area without the written permission of NSCC Plant Manager.
C.6.2 Hazard Briefing
All personnel entering the NSCC work area shall be informed of potential site health and
safety hazards. This briefing shall be documented on daily Site Meeting records. The site
visitor must sign the Site Safety Meeting record.
C.6.3 Documentation of Certification
Personnel entering the site for the purpose of work shall have completed training in accordance
with 29 CFR 1910.120 and this HSP. All personnel entering the NSCC work area shall have
had a medical examination meeting the requirements of 29 CFR 1910.120 within the last 12
months. Certificates of training and medical examinations for on-site personnel (including
subcontractors) shall be maintained on-site. At the completion of the project, these records
shall be placed in the Project file. Personnel not meeting these requirements may observe the
work from outside of the delineated work area.
C.6.4 Entry Log
Access to contaminated work areas shall be restricted to authorized personnel. The NSCC
Field Operations Coordinator shall be responsible for maintaining a daily log of all on-site
personnel. The log should include the length of time each person was in the contaminated
area. This log shall be placed in the project file at the completion of the project.
C.6.5 Contamination Control Zones
The Project Area will be divided into three work zones: an exclusion zone, a decontamination
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zone, and a support zone. The Field Operations Coordinator will be responsible for designa-
tion of the work zones.
The exclusion zone will exist only during sampling operations and include the area around the
four Soil Plots. Only NSCC personnel and authorized visitors who have completed 40-hour
hazardous waste training and are wearing the required PPE shall be allowed within this zone.
A decontamination zone for personnel and equipment decontamination will be established
immediately adjacent to the exclusion zone. This area will be delineated with traffic cones
and/or barrier tape.
The remainder of the NSCC Project Area will be designated as the support zone. No special
markings or warning labels are required for this area.
C.6.6 Entry Requirements
All personnel entering the support, decontamination or exclusion zones shall wear the required
PPE. All personnel entering the exclusion zone will enter and depart through the decontami-
nation zone. Decontamination procedures are mandatory.
C.6.7 Emergency Entry and Exit
During emergencies, decontamination will be conducted to the extent that it is possible without
endangering personnel.
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C. 7. 0 Decontamination
C. 7 .1 Personnel Decontamination
All personnel working in the exclusion zone must undergo personal decontamination prior to
entering the support zone. The personnel decontamination area shall consist of the following
stations:
Station 1
Station 2
Station 3
Personnel leaving the exclusion zone shall
remove the gross contamination from their
outer clothing and boots at Station 1.
Station 2 will contain a plastic-lined waste
receptacle, chairs, plastic bags, and clean,
damp cloths or paper towels. Personnel shall
remove their Tyvek coveralls and gloves and
deposit them in the lined waste receptacles.
Personnel shall wipe their respirators (if used),
hard hats, and boots with clean, damp cloths
and then remove those items, which are then
hand carried to Station 3.
Station 3 will contain a wash basin with soap
and water and a respirator sanitation area. At
this station, personnel will thoroughly wash
their hands and face before leaving the decon-
tamination zone. Respirators shall be sanitized
and placed in a clean plastic Ziploc• bag.
C. 7. 2 Equipment Decontamination
Any "equipment used in the exclusion zone shall be decontaminated prior to leaving the
decontamination zone. Since the level of contamination anticipated is low, decontamination
for vehicles will be limited to rinsing the tires with water. The sampling equipment will be
decontaminated in accordance with procedures in the Work Plan and the Quality Assurance
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Project Plan. All decontamination of equipment and vehicles used in the exclusion zone shall
be conducted at the NSCC site decontamination facility.
C.8.0 Site Monitoring
C. 8 .1 Air Monitoring
During all sampling operations, regular air monitoring shall be carried out using real time
instrumentation. Prior to the start of sampling operations, and continuously thereafter as the
sampling progresses, the air in the breathing zone of the sampler(s) shall be monitored with a
organic vapor analyzer (OVA) for the presence of volatile organics.
The OVA shall be calibrated on a daily basis and the calibration data recorded in the project
calibration log book. OVA readings shall be recorded at least every ½-hour and logged on the
Field Activity Daily Log.
At the discretion of the Project Health and Safety Officer, integrated samples may be collected
for volatile organics. Such sampling shall be carried out in accordance with NIOSH or OSHA
methods by a health and safety professional.
C.8.2 Noise Monitoring
During the initial phase of sampling operations, the noise exposure of all site personnel shall
be determined through the use of noise dosimeters and a sound level meter. All noise monitor-
ing equipment shall be calibrated against a known sound source, both before and after use.
The noise monitoring shall be carried out by a health and safety professional.
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C.8.3 Monitoring Records
The NSCC field Operations Coordinator is responsible for recording all OVA monitoring
records in their Field Activity Daily Log, along with daily calibration records. At the
conclusion of the project, these records shall be placed in the permanent Project file.
Record keeping for any integrated sampling is the responsibility of the Field Operations
Coordinator, who will ensure that the monitoring records include:
• Worker name and social security number
• Sample data, time, task information and exposure information
• Description of the analytical methods, equipment used and calibration data
• Type of personal protective equipment used
• Engineering controls used to reduce exposure.
The Project Health and Safety Officer shall ensure that complete sampling records are placed
in the Project file and in the health and safety files at the completion of the Project.
C.8.4 Notification
The Project Health and Safety Officer shall ensure that any employee whose exposure was
assessed using industrial hygiene sampling techniques is advised in writing of their exposure
within five working days of receipt of the sample results. Any employees working in the
immediate vicinity of the sampled employee are also entitled to notice of exposure.
If any worker has been overexposed to monitored substances, their written notification shall
include an explanation from their manager of measures which will be taken to prevent further
overexposure.
C.9.0 Employee Training
All on-site project personnel shall have completed at least 40 hours of hazardous waste
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operations-related training as required by 29 CFR 1910.120. Those personnel who completed
the 40-hour training more than 12 months prior to the start of the project shall have completed
an 8-hour refresher course within the past 12 months. The Field Operations Coordinator shall
have completed an additional eight hours of relevant health and safety training and shall have a
current first aid/cardiopulmonary resuscitation (CPR) certificate.
Prior to the start of the project, all personnel shall participate in a daily Site Safety Meeting.
During the Site Safety Meeting, the HSP will be discussed. The Field Operations Coordinator
shall ensure that the anticipated site hazards are summarized and explained to all personnel,
and that those personnel are aware of the precautions they must take to minimize their
exposure to these hazards. Site Safety Meetings shall be held at the start of each work shift.
All personnel shall acknowledge having read and understood this HSP by signing the
Acknowledgment Form.
C.10.0 Medical Surveillance
All on-site Project personnel shall have completed within the last 12 months a comprehensive
medical examination which meets the requirements of 29 CFR 1910.120. The annual medical
exam includes the following elements:
• Medical and occupational history questionnaire
• Physical examination
• Complete blood count with differential
• Liver enzyme profile
• Chest x-ray, once every three years for non-asbestos workers
• Pulmonary function test
• Audiogram
• Electrocardiogram for persons older than 35 years of age, or if indicated during
C:IPROJECTS\CDRSPRNG\OU4NDTSIHSAP\OU4HSP.AA C-27
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the physical examination
• Illegal drug screening
• Visual acuity
• Follow-up exams, at the discretion of the examining physician or the corporate
medical director.
All employee medical records are maintained by the Health and Safety Group within the
worker's home profit center or, for subcontractors, at the subcontractor's office. The
examining physician provides the employee with a letter summarizing his findings and
recommendations. Each employee has the right to inspect and obtain a copy of their medical
records.
The examining physician provides the employer with a letter confirming the worker's fitness
for work, and his ability to wear a respirator. A copy of this letter for all project workers
shall be kept on-site during all project site work.
C.11.0 Emergency Response Plan
C .11.1 Employee Injury
All employee injuries must be promptly reported to the Field Operations Coordinator, who in
turn shall:
• Ensure that the injured employee receives prompt first aid and medical attention
• Ensure that the Plant Manager and the Project Health and Safety Officer are
promptly notified of the incident
• Initiate an investigation of the accident.
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C. 11.1.1 Chemical Inhalation
Any employee complaining of symptoms of chemical overexposure as described in Section 3
of this HSP shall be removed from the work area and transported to the designated medical
facility for examination and treatment. It is highly unlikely that the chemicals anticipated as
being on-site in the concentrations anticipated will cause situations which are immediately
dangerous to life and health.
C.11.1.2 Eye Irritation
Project personnel who have contaminants splashed in their eyes or who experience eye
irritation while in the exclusion zone shall immediately proceed to the eyewash station set up
on the decontamination zone. Do not decontaminate prior to using the eyewash. Remove any
and all protective clothing necessary to use the eyewash. Flush the eye with clean running
water for at least 15 minutes. Arrange to promptly transport the employee to the designated
medical facility.
C.11.1.3 Skin Contact
Project personnel who have skin contact with contaminants shall, unless the contact is severe,
proceed through the decontamination zone to the support zone. Personnel shall remove any
contaminated clothing and wash the effected area with water for at least 15 minutes. The
worker shall be transported to the designated medical facility if they show any sign of skin
reddening or irritation, or if they request a medical examination.
C.11.1.4 Personal Injury Accident
In the event of a personal injury accident, the Field Operations Coordinator shall assess the
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nature and seriousness of the injury. In the case of serious or life-threatening injuries, normal
decontamination procedures may be ·ignored. · Less serious injuries such as strains, sprains, and
minor cuts may be treated only after the employee has been decontaminated.
Following decontamination, an NSCC Project Team member qualified in first aid and CPR
shall administer appropriate first aid. The Field Operations Coordinator shall then arrange
transport to the designated medical facility, if necessary.
C.11.2 Emergency Medical Facility
The designated emergency medical facilities (Figure C-1) for this project are:
Rowan Memorial Hospital
Salisbury, N.C.
[phone]
C.11.3 Fire
In the case of a fire on-site, the Field Operations Coordinator shall assess the situation and
direct firefighting activities. The Field Operations Coordinator shall ensure that the Plant
Manager and the Project Health and Safety Officer are immediately notified of any fire.
NSCC personnel shall attempt to extinguish the fire with available extinguishers if safe to do
so. NSCC shall call the local fire department (911) to extinguish fires which NSCC is unable
to safely extinguish.
C:\PROJECTS\CORSPRNG\OU4NDTS\HSAP\OU4HSP.AA C-30
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· ..
'-, ;; j . I l
...
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. ·. . .Ao•= ·/:/(/\'':-\·.
/( \\ ·1"· • ' \ '. •1' l ~r~~c-'-i · ~ ~ :r //.· " ;, ';' ,-. ',:r,-·
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1\, !~~ -~ •,-ct~ '.-•:... . .::::,~~ _ • •"-': • ~••• I• •.
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,,' ( '·:. ~--. •/' '\{~~;~R. ,' .(;:iVJ,. . ~:-~ ,N '• t~ ' '(ir -.· lj~ ~ • ~'t?,j, • , \ ' ~--,1\• . ~t..--,,, I r .. · ~--. --) .· .:-, ~----~-• '" , ,, ··• . I .,,_, ,._,\ ,. , +-v-~ .,__ ~-==-.. , .,
i
LEGEND•
... EMERGENCY ROUTE
~---PROPERTY LINE (APPROX.)
·SCALE
F 9
0 1/2 MILE
Figure C-1
HOSPITAL ROUTE MAP
NATIONAL STARCH 8 CHEMICAL CORP CEDAR SPRINGS RO PLANT
SALISBURY, NORTH CAROLINA
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C.11.4 En1ergency Information
Key Personnel
Plant Manager -
Project Director -
Project Health and Safety Officer -
Project Environmental Engineer -
Field Operations Coordinator -
C:\PROJECTS\CDRSPRNG\OU4NDTS\HSAP\OU4HSP.AA I
Mr. Ray Paradowski [phone] Ext. 231
Dr. Abu Alam [phone]
Mr. Richard Franklin [phone] Ext. 233
Mr. Michael Ford [phone]
Mr. Kenneth Klutz [phone] Ext. 203
C-31