NCD991278953_19960708_National Starch & Chemical Corp._FRBCERCLA RA_Remedial Design Remedial Action Work Plan OU-4-OCR

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REMEDIAL DESIGN/REMEDIAL ACTION
WORK PLAN
FOR
FOURTH OPERABLE UNIT
NATIONAL STARCH AND CHEMICAL COMPANY
CEDAR SPRINGS ROAD• PLANT SITE
SALISBURY, NORTH CAROLINA
RECEI\/EO
Prepared by:
National Starch & Chemical Company JUL 1 0 1996
10 Finderne Avenue
New Jersey 08807 SUPERFUND SECTION
Ray Paradowski
Plant Manager & Project Coordinator
Appro.,d, t2h,,, m;f l/lL..__
Abu Alam
Project Dire r ·
Approved: 'R KJMl LJ .J l\l1;1JJ,;'-'
Richard Franklin
Project Health & Safety Officer
Approved: yJ~
Michael ForJ
Project Environmental Engineer
Approved: ,£--v><d.~2
-
Kenneth Kluttz
Approved:
~ti&ordinator
Bill Algiere ~
Construction Manager
Date: 7/8/96
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Date: 7/8/96 -----
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Date: 7/8/96 -----
Date: 7/8/96
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.,,anal Stan:h and Chem/ca/ Company
10 Finderne Avenue
P. 0. Box 6500
Bridgewater, New Jersey 08807-0500
908-685-5000
Cabla Address: NASPAOD,BAIOGEWATERNEWJEASEY
Writer's Direct Dial Number:
Fax Number:
July 8, 1996
Mr. Jon Bornholm
Remedial Project Manager
United States Environmental Protection Agency
Region IV
345 Courtland Street, N .E.
Atlanta, Georgia 30365
RECE=l\n=n
JUL 1 0 1996
SUPt:HrUNlJ ot:CTION
Subject: Submittal of Final Remedial Design/Remedial Action Work Plan
for Operable Unit 4 at National Starch and Chemical Company's
Cedar Springs Road Plant Site, Salisbury, North Carolina
Dear Mr. Bornholm:
In accordance with the USEPA's September 29, 1995 Unilateral Administrative Order (effective
date October 6, 1995) for Remedial Design/Remedial Action for Operable Units #3 and #4 at the
subject site we are transmitting herewith four (4) bound copies and one unbound copy of the
Natural Degradation Treatability Study Final Work Plan for OU4 as per your instructions of
November 8, 1995. Please note that we have revised our October 18, 1995 Natural Degradation
Treatability Study Work Plan for OU4 to incorporate the November 11, 1995 comments and
suggestions ofUSEPA, the December 4, 1995 comments and suggestions ofNCDEHNR, the
March 18, 1996 comments and suggestions of USEP A and the telephone discussions of March
26, 1996 with the USEPA and the NCDEHNR. Also included in this Final Work Plan are:
I. Field Sampling and Analysis Plan;
2. Quality Assurance Project Plan;
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Health and Safety Plan; and 3.
4. BioReport Proposal by Blue Planet Technologies.
Please note that as per your instructions we are also transmitting two (2) copies of this Natural
Degradation Treatability Study Final Work Plan for OU4 to Mr. David Lown of the Superfund
Section of the North Carolina Department of Environment, Health, and Natural Resources
(NCDEHNR). Please feel free to call me if there are any questions.
Very Truly Yours,
~m.~-~ Abu M. Z. Al SC.D. P.E.
Corporate Dire or of Environmental Projects
CC: D. Lown, NCDEHNR
D. Cregar, NSCC w/o Work Plan
R. Paradowski, NSCC
S. Rogers, NCDEHNR w/o Work Plan
A. Samson, NSCC
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TABLE OF CONTENTS
LIST OF FIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
LIST OFT ABLES ............................................................ iii
1.0 INTRODUCTION ....................................................... I
I. I Purpose and Organization of Work Plan ................................ I
1.2 Site Location and Description ........................................ I
1.3 Site History ...................................................... 6
1.4 Administrative History .............................................. 6
1.5 Nature and Extent of Soil Contamination ............................... 8
1.6 Surface Water Hydrology .......................... : ............... 17
1.7 Geology and Hydrogeology ......................................... 19
1.8 Work Plan Contents ............................................... 24
2.0 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 ............................................ 27
2.3 Description of Natural Degradation Process ............................ 30
2.4 Description of the Treatability Study Experiments and Procedures .......... 30
2.4.1 Laboratory Biotreatability Study ................................ 31
2.4.2 Soil Plots and Soil Gas Monitoring Wells ......................... 31
2.4.3 Measurements of Performance .................................. 39
2.4.4 Soil Sampling .............................................. 40
2.4.5 Soil Gas Monitoring .......................................... 41
2.5 Project Deliverables ............................................... 43
2.5.1 Progress Reports ............................................ 43
2.5.2 Natural Degradation Treatability Study Reports .................... 43
2.6 Residuals Management ............................................ 44
3.0 PROJECT ORGANIZATION AND RESPONSIBILITY ........................ 45
3.1 Project Organization And Management Plan ........................... 45
3.1.1 Plant Manager and Project Coordinator .......................... 47
3.1.2 Project Director ............................................. 47
3.1.3 Project Health and Safety Officer ............................... 48
3.1.4 Project Environmental Engineer ................................ 48
3.1.5 Field Operations Coordinator .................................. 49
3. l.6 Quality Assurance Officer ..................................... 50
3.1.7 Laboratory Directors/Laboratory Coordinators ..................... 50
4.0 PROJECT SCHEDULE ................................................. 51
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List of Figures
Figure
1-1
1-2
1-3
1-4
1-5
1-6
1-7
1-8
1-9
1-10
1-11
1-12
2-1
2-2
2-3
2-4
2-5
3-1
4-1
Description
Site Location Map ....................................... .
Site Map ............................................. .
Distribution of 1,2-Dichloroethane in Soil Samples, Area 2 ............ .
Page
2
4
9
Distribution of 1,2-Dichloroethane in Soil at Wastewater Treatment Lagoons ..
Soils Cross Section Location Map ............................. .
Soil Profile A-A' with 1,2-Dichloroethane Concentrations in Soil at Area 2
Soil Profile B-B' with 1,2-Dichloroethane Concentrations in Soil at Area 2
Soil Profile C-C' with 1,2-Dichloroethane Concentrations in Soil at Wastewater
Treatment Lagoons ...................................... .
Distribution of Acetone in Soils .............................. .
Location of Monitoring Wells ............................... .
Groundwater Elevation Contour Map, Bedrock Wells ................ .
Groundwater Elevation Contour Map, Saprolite Wells ................ .
Location of Soil Plots and Soil Gar Monitoring Wells in Area 2 ......... .
Location of Soil Plots and Soil Gar Monitoring Wells in Lagoon Area ..... .
Metal Box Construction Detail . . . . . . . . . . . . . . . . . . . . . . . . . ...... .
Soil Plot Detail ......................................... .
Soil Gar Monitoring Well Construction Detail ..................... .
Project Organization ..................................... .
Project Schedule ........................................ .
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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 ............ .
iii
Page
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35
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1.0 INTRODUCTION
1.1 Purpose and Organization of Work Plan
This Work Plan is prepared to fulfill requirements of the United States Environmental
Protection Agency's (USEPA's) Unilateral Administrative Order and the Statement of
\Vork (SO\V) 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 USEPA
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 .
This 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
1-lydrogeology. Section two presents the Remedial Design/Remedial Action (RD/RA) Work
Plan including details of the Natural Degradation Treatability 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
(HSP).
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
NATIONAL --~•A,/
STARCH SITE
DAVIDSON
COUNTY
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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.
NSCC has made efforts to reduce and control surface runoff from the production area. NSCC
has paved the area around the production area and has installed curbs to control storm surface
water. All stormwater in this area is collected now in a sump and is directed to the lagoons
for treatment before ultimately being discharged and treated at the local POTW.
During the time for conduct of the Phase I RI for OUl activities (June 1988) and the
Supplemental RI for OU2 activities (1990), NSC abandoned and plugged all storm water
discharge lines that collected storm water from the asphalt area between the main building and
the Northeast Tributary. These lines used to discharge surface water runoff from the asphalt
area to the steep-sloped bank between the Northeast Tributary and the Plant Operations Area.
In addition, concrete dikes, catch basins, sumps, new discharge lines, and sump pumps were
installed in the asphalt area (immediately east of the Plant operations Area) to collect and
discharge the storm water to the existing Pretreatment Lagoons. All surface runoff from this
area is now pretreated with the Plant's wastewater prior to discharge to the City of Salisbury
sewer for further treatment.
The Northeast Tributary receives discharge from the W. A. Brown Plant through a National
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Page 4
500 ,...._.-0 500
TRENCH
AREA
250 750
J
--1.t.
+
[Hp Ilona, Slorclt ond Clt•mkol c-eo•r
CEDAR SPRINGS, NC PLANT
+
SITE MAP
N0Y£MB(R 199$ ri9ure 1-2
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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. l and
No.2 ) for storing untreated wastewater ( Lagoon No.1 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 OU 1 groundwater and plant wastewater and is called the Combined Pre-Treatment
System.
The Combined Pre-Treatment System is designed to treat two OUl 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.1 where it will combine with the Plant's wastewater.
Lagoon No. 1 provides equalization and pH adjustment to the wastewater. Flow from Lagoon
No.1 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.
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1.3 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.
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. I 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.land 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.
1.4 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.
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The Final Design Report (IT, 1990b) describes the remedial design for OU!. The Remedial
Design/Remedial Action (RD/RA) for OU! is currently being performed in accordance with
the USEPA's Unilateral Administrative Order effective July 27, 1989.
In accordance with the OU! 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! 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
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, I 993 OU3 RI Report was also deemed applicable as the OU4 RI report.
However, US EPA 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
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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.
1.5 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
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.
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APPROXIMA IT SCALE (11) L--·· ■---JL:-.a.JL: ____ -~~---
0 JOO 200 300
C \l'R0JECTIICORSPIUNG\OU4NOTS\FIGl•l P'f
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-
NOTE
1 Samptea oollcled by
NSCC from~ --oona ---C).l"Y'IQ J'lfflOY .. (~
wrttl~---)
SaT1ple1 IIN,/y!Zed for
1,2-0CA MIT• on-au __ ..,....
PHASE U for OU3
LEGEND
--
•
SOIL BORING LOCATION SHOWING MAXll,,IJM
1,2-0CA CONCENTRATK>H (ppt,) N¥J
(DEPTH (ft)) OF MAXIMUM CONCENTRATION
-Joo l.l•OCACONCENTitATIONCONTOUR.
,
1 WASTE-WATER LINE. AAROY-J INOtCATES
DIRECTION OF FLOW .
NOTE ConlirmMion daa:: pp! ••Aid by
IOII taWD'lin.a 4aa
FIGURE 1-3
DISTRJBUTION OF 1,2-DCA
IN SOIL SAMPLES, AREA 2
PHASE 11 OU3 RI
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
-
--

-
---

-
I I --·-··-·
I I
I I
I I I
I I
-0 I I
"' I I <.Q n, ... I I 0
I
I
APPROXIMATE SCALE (ll) _..r.
0 100 200 300 400 ,oo
C \J'R.OIECTS\CDR5PM-IG\OU4NDTS\FIO 1-4. Pll
-

-
-

-
LOT
--

-
NOTE
1. Sarn?'ff coUoded by
NSCC fr0m ~
~ ..,.. 00Cla
procua....,..-
o.n,g,-nowal(rep&lced
wllh~ln<U)
S.-np6N ~ ICf
,.2-0CA • rr, ~ ,_.....,......,.
PHASE II for OU3
LEGEND
-

-
■ SOIL BORING LOCATION StiC1MNG ~
1,2-0CA CONCENTRA TK>H (.Ppb) AHO
(DEPTH (fl')) Of MAXIMUM COHCENTRATlON
.._ .J 0o 1.l-DCA CONCENTRATION CONTOUk
• WASTE-WATER LINE, AA.ROW INDtCATES
' DIRECTION OF FLOW
NOTE Confiffl\llUOf'I d,...., ,uwlcmailed by
toil IU'DCI\UII daa
FIGURE 1-4
DISTRJBUTION OF 1,2-DCA
IN SOIL SAMPLES, AREA 2
PHASE II OUJ RJ
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
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Compound
1, 1,2-Trichloroethane
1,2-Dichloroethane
2-Butanone
Acetone
Bromodichloromethane
Chloroform
Delta BHC
Dibromochloromethane
Tetrachloroethene
Toluene
Total Xylenes
Trichloroethene
Vinyl Chloride
Table l-l
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
11-17 2
2-1600000 42
3-42 30
22-4000 40
1-220 7
2-900 17
22 I
3-31 5
2 2
1-3100 12
I 1
3 I
32-190 12
Page 11
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From examination of the data presented in Figure 1-3, there are three areas where soil
contamination is concentrated in Area 2:
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
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 comer 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.
A:\OU4NDTS\OU-IWKPLN.RVI Page 12
-

-

-
,_.
w
--
0 100
DRIVEWAY
1
Scale {ft)
200 300
--

-

-
2
400 500
PARKING
AREA
/. · ..
(. 23(7.5)
\ / ND ' . .
1111(1.5)
-

-
-

-

-
LEGEND 3/
SOIL BORING SHOV't'\NO I .2 OCA
CONCENTRATION (pptl) ANO DEPTH (fl)
OF MAXIMUM CONCENTRATK)N
WASTE-WATER LINE, AAROW'INOtCATES
OtRECTION OF FLOW'
', / t,20CACONCV<TIIIATIONCCWTOIJfl
10000 ..
NOTE: ~csa-,;; ••adbr ,.. __
FIGURE 1-5
DISTRIBUTION OF 1,2 DCA IN SOIL
AT THE WASTE WATER TREAlMENT
LAGOONS
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
-

-
-
"' "' "" rt> ,_.
~
-----------

-

-
-

-

-
A
A'
775
775
770 (SBA2-20(
-770
ii ~
~ 765 --
765
"' • • .!l ~ 760 -· .. 7tl0
i > • • 755 -··
755
E •• 0 a. i
750
/ (3700)
/' (1393') \ .
750
.. (410) --i l 11 I \"I I I I Ir 1·0-1
--rr1 i --rn n 745
745 ·--
LEGEND
I
(410)
(1393 •)
[SBA2-07]
I I 11·n
-5 -
f Bedrock
Location of soil sample
1,2-DCA laboratory analytical resulls in ppb
1,2-DCA field analytical results in ppb
Soil boring ID#
Bedrock/Soil interface
1,2-DCA concentration contour line (ppb)
HrwRorul Scaa Cft-1 l _-_ C • ·;),
FIGURE 1-6
SOIL PROFILE A-A' WITH
1,2-DCA CONCENTRATIONS
IN SOIL AT AREA 2
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY, NC
-

-
--------------
"'0 "' IQ
"' ....
"'
I
I u,
~ ~ ,,
J
i > !! m
E I
772
770
B
765 -
160 -
755
750
745
740
LEGEND
I
(17310 °)
(170)
(53,000) .
Bedrock ,~ .
·111,310';---
Location of aoll aemple
1,2-DCA field enelytical results in ppb
1,2-DCA laboratory analytical results in ppb
[SBA2-11] Soil boring ID#
""" . _ . Groundwater elevation
~5~ 1,2-DCA concentration contour line in ppb
c:\pfojec1s\cdrspring\Ou-4ndta\tig 1-7
(170)
,,,,-(120)
(1300)
Bedrock
i-tortzonlal Scale (fl.)
0 30 00
-

-

-
Perched
water Table
FIGURE 1-7
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
745
740
"0 "' "" Cl) ...
"'
--------------
!
I Cl) a
JI ~
i > ~ E J
--
C
C'
775
770 .
(SBLA-04)
(SBLA-24) (SBLA-23) I (SBLA-15) ------i--___ l:~-~2~_JSB:>-·~I )SBLA-06) . I (~BLA-14)
(NO) ·--· • ---. __ 1 J Topofgrade
----------_ (SBLA-05)
: , ' •.••• •• ~ /"(5) ~(NO) ~-~ /
775
-710
765 -
v(~OY ·-. • r<ND) ~
, r (NO) ~-<~~>,._ . r (ND) ;-(NO) (SBLA-10)
• ' ';. (36) -.----. . •
-765
~ -4".--· too,. (ND )-" IF (NO) ------!SBLA-11)
\ '\ \ \. -·rr-------L
760 -
755 --
750
745
LEG::.:Ec~N.:.::D:.._ _______________________________ _
I Location of soil samples
(ND) 1,2-DCA Field concentration in ppb
(3.0) 1,2-DCA Laboratory concentration in ppb
(ND) 1,2-DCA analyzed for but not detected
[SBLA-14J Soil boring ID#
T Static groundwater level
-10 -1,2-DCA Concentration contour line in ppb
(186) • _\ \ (NO I
\
(ND)
Ho.uonlal Sc.ai. tn I
J ,b
760
-755
~ 750
-,(3)
,_ 7-45
FIGURE 1-8
SOIL PROFILE C-C' WITH
1,2-DCA CONCENTRATIONS
IN SOIL AT THE WASTEWATER
TREATMENT LAGOONS
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY, NC
c: ~~~'o1g1-8
--
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Acetone is widely distributed in soils around Area 2 and the wastewater treatment lagoons.
The distribution of acetone is shown in Fig~re 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
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.
1.6 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
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CHAIN LINK FENCE
3/
!
l •
k
j
I
LEGEND
■ SOIL BORING SHO'vVING ACETONE
CONCENTRATION (ppb)
..._ -ACETONE CONCENTAATION
100___,/ CONTOtm. (ppb)
APPROXIMATE SCALE (I\)
200 ]00 "' "'
Page 18
NORTHEAST
TRIBUTARY
FIGURE 1-9
DISTRIBUTION OF ACETONE
IN SOILS, PHASE II OU3 RI
NA TTONAL STARCH AND
CHEMICAL COMPANY
SAUSBURY N.C.
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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.
1.7 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
(OUl 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.
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1050 _ .,.,
t-r--
~
,_
750 :-
-750 ,
-050
• NS--OIA
' '
------
' '
Page 20
' ' ' ' ' ' '' ' '' '
'' ' '' '
· NS43t«;
550
"' JI I I
LEGEND
NS-JS • MONITORINGWFll.LOCATION
AND IDENTIFICATION
FENCE
Al'PROXIMA TE SCALE (f\)
i' ,,
Ii I
= ,.
i' FIGURE 1-10
---
r LOCATIONOFMONITORING
I WELLS, PHASE n ouJ RI
I
f i NATIONAL STARCH AND
I CHEMICAL COMPANY
' \ SALISBURY N.C.
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718
7Jo ~
· · · -----730 --------\-----
1050 _
~------735
750 -
•750 I -
Page 21
550
3/
SCALE(ft) ,. ----
LEGEND
MOl'llTORING WELL LOCATION
LOCATION AND GROL"NDW.ti.tD.
ELEVATION (ft MSL)
FENCE
FIGURE 1-11
GROUNDWATER ELEVATION
CONTOUR MAP, BEDROCK
WELLS MARCH 1, 1993
NA noNAL STARCH AND
CHEMICAL COMPANY
SALISBURY N.C.
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740
t
~
l::,
\ \
\
1050 _ -',r,-
"' " ~
750 -
, ~--450 -~ .---
i 763 ,
\ -• \
\ -,
:150 -
I 761 \_ ~-=-
-150 -
!
i
-750 , j 1 = -350
i
-50
\
,, ,, ,, ,,
'
250
Page 22
70 •
550
SCALE(ft)
,. -.. -
LEGEND * MONITORING WEl.1. LOCATION
767 ANDGllot.Jt"DWATER.
ELEVATION (ft. MSL)
ru<CE
FIGURE 1-12
GROUNDWATER ELEVATION
CONTOUR MAP, SAPROUTE
WELLS MARCH 1, 1993
NA TTONAL STARCH AND
CHEMICAL COMPANY
SAUSBURYN.C.
,.
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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
frequent and fracture surfaces often exhibit oxidation staining to depths of 40 to l 00 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 OUl 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
this 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! 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.
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1.8 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
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:
1. 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:
l. Demonstrate if natural degradation of 1,2 dichloroethane is occurring at the site
in the saprolite;
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2.
3.
4.
5.
Determine if natural degradation can be enhanced through the addition of
moisture and nutrients to the soil;
Determine where in the subsurface degradation is occurring;
Determine at what rate the natural degradation process is proceeding; and
Estimate the time frame when the Performance Standards via natural
degradation will be attained.
The performance standards for 1,2 dichloroethane have been established by the USUSEPA for
groundwater at 1 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.
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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
moisture enriched or moisture and nutrient enriched conditions. The Natural Degradation
Treatability Study will consist of a laboratory biotreatability study as well as a two-phase
field study. The laboratory study will be conducted concurrently with the initial phase of the
field study. The laboratory studies will answer the following questions:
a. Are bacteria capable of biodegrading 1,2-DCA in soil at the site?
b. Which conditions most favor biodegradation of 1,2-DCA at the site?
c. What additions (moisture, nutrients, pH control agent, etc.) will enhance the
biodegradation rate?
d. What are the specific biodegradation rates under controlled conditions in the
laboratory.
The answer to these questions will assist in the completion of the field biodegradation study,
and collection and interpretation of data.
While conducting the laboratory biotreatability study, NSCC will initiate the first phase of the
field study. Initially NSCC will conduct the Natural Degradation Treatability Study using four
Soil Plots. The purpose of Phase I is to determine:
a. If natural degradation of 1,2-DCA is occurring in the saprolite;
b. Whether natural degradation of 1,2-DCA can be enhanced by addition of
moisture or addition of moisture and nutrients; and
c. Which of the three treatment methods provides the maximum degradation of
1,2-DCA
Phase I of the Natural Degradation Treatability Study will consist of the following:
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I.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Preparation of a Work Plan;
Design and construction of Soil Plots;
Installation of a Soil Gas Monitoring Well inside each Soil Plot and at four
random locations;
Drilling and collection of split-spoons from each Soil Plot and Soil Gas
Monitoring Well;
Initial soil sampling at the beginning and thereafter quarterly soil sampling
inside each Soil Plot and initial soil sampling only at each random Soil Gas
Monitoring Well;
Weekly on-site soil gas monitoring from the Soil Gas Monitoring Well inside
each Soil Plot and at each random Soil Gas Monitoring Well;
Monthly soil gas sampling from the Soil Gas Monitoring Wells inside of the soil
plots for off-site analyses
Quarterly soil gas sampling from the ran·dom Soil Gas Monitoring Wells for off-
site analyses.
Laboratory analysis of soil and soil gas samples; and
Submission of a Phase I Natural Degradation Treatability Study findings
report.
The Phase I Natural Degradation Treatability Study Report will be completed approximately 1
year after commencement of the field study and will be submitted with the semi-annual
Progress Report together with the fourth quarterly sampling data. This report will identify the
treatment method that gives the best degradation rate for 1,2-DCA during Phase I which will
be replicated under Phase II.
Phase II of the Natural Degradation Treatability Study will consist of the following:
I.
2.
Replication of the treatment method at three randomly selected Soil Plots with
the best degradation rate of 1,2-DCA established under Phase I.
Continue to operate the Soil Plot that gave the best degradation rate of 1,2 DCA
under Phase I. Relocate the other three Soil Plots at the three randomly selected
Soil Plots mentioned above.
3. Submission of a Draft and a Final Natural Degradation Treatability Study
Report.
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The purpose of Phase II is to determine:
1. Determine statistically at what rate the natural degradation process is proceeding
The treatment plot established under Phase I which gives the best degradation rate of 1,2 DCA
will be replicated at three other randomly selected locations. The replication of the treatment
plots will provide a reliable and statistically valid degradation rate of 1,2-DCA and will be
used to estimate the time required to cleanup the site to the prescribed performance standards.
NSCC will submit this Natural Degradation Treatability Study \Vork Plan for review and
approval by USEPA Region IV and the NCDEHNR. Upon receiving USEPA Region IV's
and NCDEHNR's approval and notice-to-proceed with execution of the Work Plan elements,
NSCC will then commence with the laboratory biotreatability study and 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.
An initial round of soil and soil gas samples will be collected during the construction of the
Soil Plots to establish baseline conditions. Soil samples will be collected during the
installation of the Soil Gas Monitoring Wells. Soil gas samples will be collected following
completion of the 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. NSCC will also submit a
Phase I Natural Degradation Treatability Study Report with the 2nd progress report.
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 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.
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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 Treatability 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
After review and approval of this \York 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 Study will be conducted on site using
naturally occurring indigenous microorganisms (mostly facultative bacteria which can stabilize
organic matter under both anoxic and oxic conditions) in the soil at the selected Soil Plots.
The treatability study and procedures described in the following sections will be the same
under phase I and phase II except under phase II one the treatment methods will be replicated
at three random locations. The exact treatment method will be determined during the first
year under Phase I.
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2.4.1 Laboratory Biotreatability Study
Two soil samples will be collected during the initial phase of the field study and will be sent to
Blue Planet Technologies of Madison Heights, Michigan. These soil samples will be collected
from the contaminated area and will be used for conducting the laboratory studies and
screening for biodegradation. In addition, these soil samples will be used to establish
partitioning of 1,2-DCA between the soil water and solid phases, and between soil vapor and
solid phas~s. Results of 1,2-DCA partitioning will assist in the interpretation of the soil gas
monitoring data including the mass balance of the degradation products of 1,2-DCA such as
chloroethane, ethane, ethene, and vinyl chloride.
2.4.2 Soil Plots and Soil Gas Monitoring Wells
Under Phase I, four Soil Plots and eight soil gas monitoring wells will be installed for use in
the Natural Degradation Trcatability Study. Under Phase II, the Soil Plot demonstrating the
best degradation rate of 1,2 DCA will be replicated at three random locations. Figure 2-1
illustrates the locations of the proposed Soil Plots and Figures 2-1 and 2-2 presents the location
of the eight soil gas monitoring wells and three replication plots. Figure 2-1 shows that 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. Each Soil
Plot will be approximately 4 feet by 6 feet in size and will extend from the ground surface to
groundwater level estimated at a depth of about eight feet below the surface. Figure 2-1 also
shows that four of the SGMW will be installed in the center of the Soil Plots. The other four
SGMW will be installed randomly with two in Area 2 and two near the lagoon.
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. To prevent corrosion and associated interferences, the frame and cover of the metal
box will be constructed of epoxy primed and epoxy painted formed steel. The metal box will
be sandblasted to near white metal to meet SSPC SPlO requirements, primed with a polyamide
A:\OU4NDTS\OU4 WKPLN.R VI Page 31
-------------------
"C "' IQ 11)
w N
1--
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.L
c:~'cdrlpmg\ou4ndtl\ftg2-1
SGMW 4 ------1 ... ► [ e] Soil Plot 4 (Background)
-----
\.'· I :.~ ---·-
-•. \--: ·-1
,_·_-f--100-----
Scale (ft) 1 ..... s.----
... -. "
I
6',
\
ooo I --. -L~ -)
' .,
' I·
'
·1 I, I '
I· ,' I
I .
/ ,
·I
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I
LEGEND
l] Soil Plot
• Soil Gas Monitoring Well
■ RP-1 = Replication Plot 1
\
'.> 1,2 DCACONCENTRATION CONTOUR
'6
/ , ' NOTE: Coofirmation data supplemented by
' / soil saeenlng data
C ,f ~ i-_F1_G_U_R_E_2_-1 ________ ...,1
__,, ,' / ,i} LOCATION OF SOIL PLOTS / I# / REPLICATION PLOTS
~1;;~-~-'iil.•.._;;;;;.~~~-.;;;; .. ~111 __ 111 __ •_~_1 I
f /;; AND SOIL GAS MONITORING WELLS
Ii PARKING LOT
0 100 200 300 400 500
I'° NATIONAL STARCH AND
fs CHEMICAL COMPANY
:z: SALISBURY NC
-
"C DI
(,Q ro
w w
----
--~-__J
----0 100
C.~'c:drlpmg\ou4ndtl\11;2-2
--- ---- ----- -
j
I /
I /
DRIVEWAY
WASTE-W,TER COLLECTION PIT I I l
.\ I [_AMMONIA BURNING SHED,;") . CJ ,, • 3 7 Soil Boling Showing 1,2 DCA
c / ■ J 1 ( .5) • Concentration (ppb) and Oepttl(n.J
, .. ·. __ ./C~\. U------~~GAL~o;iPif'.-'. ) • al Maximum Concentrallon
Soil Gas Monitoring Well
3 , : ·. /·_"·'~-,-.. ___ SGMW7 /
LEGEND
6 (9 5)_• j ru~Pj. ·--_ ~~•ft··'.~\· , !
·-. ---. . .. .. . ··sGMWB ~:)cc;' b<i~,000 /4UJ0
.. .. ,;""-)000 ~
LAGOON LAGO,ON "'ci!)O 'iE
II RP-3 " Replication P1o1 •J
WASTE-WATER LINE, ARROW INDICATES
' DIRECTION OF FLOW
: ABANDONED LINE
1
Scale (ft)
200 300 400
( • \ 23 (7.5)
\ '
2 /---l/~
---------·--·· \.
j
500
\
\
.
·, _/ 1.2 OCA CONCENTRATION CONTOUR
10000
NOTE: Conllrm■bOn d■LI tU1)91emenlad by
SOIi ,crn111ng a.ta
FIGURE 2-2
LOCATION OF REPLICATION PLOTS
AMO SOIL GAS MONITORING WELLS
IN THE LAGOON AREA
NATIONAL STARCH AND
sHfld~PANY
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epoxy coat (4 to 5 mils Dry Film Thickness(DFT)) and then painted with a compatible
polyamide epoxy paint (6 mils DFT). This epoxy priming and painting normally prevents
corrosion in carbon steel for a minimum of 10 to 15 years and, therefore, will prevent
corrosion for the duration of the Treatability Study and potential interferences of iron filings.
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 2-3 illustrates the
construction of the metal box. Figure 2-4 illustrates the layout of each soil plot including the
location of the Soil Gas Monitoring Well, and thirty-nine locations for collecting soil samples.
Construction details of the Soil Gas Monitoring Wells inside the Soil Plots are illustrated in
Figure 2-5.
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
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.
The water to be used in the study will be supplied by the City of Salisbury Water Treatment
Plant. The water will be drawn from an on-site spigot directly into the container to be used to
distribute the water. First, the water will be aerated with ambient air for approximately five
minutes to remove any residual chlorine. 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. During the initial weeks of
the Treatability Study, it might be necessary to add more moisture than the 3.6 liters per week
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'b
,LUSH un HAHCX..I' ___ _
(NOT SH0WN) /
ll.AMLOC•-----RU y·
~~A8U KEY __ ~il.i..Ao.tov.J A8tA
1H"ll~I P1.UQ O<AMONO
Pl.ATEC0v£ ..
AUTOMA TlC HOlD•OPEH AAM Al-40 COVER ~E
,,.-11 ~I ~l 'AAME rf"ORMEO STEE1. OIi
omwm. ~
{ilgtlo,,af Slan:h and Ch•mlcal Campany
Figure 2-3
Metal Box
Construction Detail Page 35
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6'
I I <TYPICAL) -t-s·-j-
' rs·t-s· -• • ., • • • •
l . • • • • • • • -' s• <TYP!CAU
@ • J • • • • -I
4' T SGMW • • • • • • • • 2' -I-. • • • --ts· • • • --s·
0--3'~
PLAN VIEW
{Hj,tlonal Storch and Chomlco/ Company
Page 36
Notes: • = Sample Location
SGMW = Soil Gos Monitoring Well
FIGURE 2-4
Soil Plot Detail
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WATER TIGHT 1 /4" FEMALE QUICK FINISH GRADE TO
DR 0 E BOX SET IN CONCRETE
GRADE
AIN AWAY FROM BOX WELL BO~ re UPL
FINISHED AT
-
BEN TONITE PELLETS
SCH. 10 SS PIPE
SILICA SAND
OR PROBE
" DIA. X 1' LONG -
VAP
1/4
ss SCREEN, 0.02 SLOT
BEN TONI TE PELLETS
1/ 4" SCH. 10 SS PIPE
SILICA SAND
VA POR PROBE
I
~--------------------------------
\
,
I/
-(\J
-
. -(\J
-------------------------(\J ----------------------
-J . 1/4 DIA. X 1 LONG
SS SCREEN, 0.02 SLOT
• -----6-------
NOTES: SS ~ STAINLESS STEEL
Not to scole
fHi,tlonal Starch and Chemical Company
Page 37
FIGURE 2-5
Soil Gas Monitoring Well
Construction Detail
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to bring the moisture content in the soil to about 50 percent saturation level. Once this
moisture level is attained, the soil moisture content will be monitored during collection of the
subsequent quarterly soil samples. If the moisture content should decrease below the desired
50 percent level, additional moisture will be added to raise the soil moisture content up to the
desired level. 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
100 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 inside each Soil Plot. Three bores during each sampling event
will be advanced to a depth of approximately eight feet. Two soil samples will be collected
from each boring or a total of six samples per event. The samples will be collected from the
soil interval with highest headspace reading recorded in the field. Soil Samples will be
analyzed for 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
1 No No Yes
(Contaminated Soil)
2 Yes No Yes
(Contaminated Soil)
3 Yes Yes Yes
(Contaminated Soil)
4 No No Yes
(Uncontaminated Soil)
2.4.3 Measurements of Performance
The approach taken in this \Vork 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:
1.
2.
3.
4.
5.
6.
7.
1,2-DCA;
By-products of 1,2-DCA degradation such as chloroethane, 1,2-dichloroethene,
ethane, vinyl chloride, and ethene ;
Nutrients such as ammonia nitrogen, nitrate nitrogen, TKN, orthophosphate,
and total phosphorous;
Soil pH;
Chloride, sulfate, and sulfide;
Trace metals. such as calcium, magnesium and iron; and
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-
dichloroethane 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 using real time
instruments for monitoring concentrations of the following parameters:
1. Oxygen;
2. Carbon dioxide;
3. Methane; and
4. Hydrogen sulfide.
In addition, once a month soil gas samples will also be collected in stainless steel canisters
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-dichloroethene,
chloroethane, vinyl chloride, ethene, ethane, carbon dioxide, oxygen, and methane.
Measured concentrations of various gases in the soil gas will be used to support that natural
degradation is occurring.
As per USEPA request, depth to groundwater and quality of groundwater at the monitoring
wells NS-35/36, NS-39/40 will be monitored during the conduct of the Natural Degradation
Treatability Study.
2.4.4 Soil Sampling
Under Phase I, 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 I year. Under Phase II, soil
samples will be collected initially from the new replicated plots and thereafter every three
months until the end of the study. 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
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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 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, detection limits 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.
2.4.5 Soil Gas Monitoring
Under Phase I, 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) and to monitor concentrations of selected
organic compounds and gases in the soil gas. Additionally, during the initial phase of the
Natural Degradation Study, four isolated soil gas monitoring wells will be installed in the
saprolite zone. Two of these four Soil Gas Monitoring Wells will be located in the
contaminated soils near the Lagoon Area and the other two Soil Gas Monitoring Wells will be
located in the contaminated soil under the pavement in Area 2. Soil gas concentrations will be
measured using real time instruments and through off-site laboratory analyses. Real time
measurements will be made weekly for hydrogen sulfide, carbon dioxide, oxygen and methane
concentrations. Samples of soil gas will also be collected monthly from the Soil Gas
Monitoring Wells inside the soil plots and quarterly from the random Soil Gas Monitoring
Wells in stainless steel canisters and shipped off site to be analyzed for 1,2-dichloroethane,
1,2-dichlroethene, chloroethane, and vinyl chloride using USEPA Method T0-14 and
analyzed for ethene, ethane, carbon dioxide, oxygen, and methane using ASTM Dl496. The
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Table 2-2
Summary of Soil
Analytical Parameters and Methodologies
Parameter MDL (mg/kg)
1,2 Dichloroethane 0.01
Vinyl Chloride 0.01
1,2 Dichloroethylene, total 0.01
Chloroethane 0.01
Calcium 1000
Iron, Total 20
Magnesium 1000
Chloride 200
Nitrate 10
Sulfate 500
Sulfide 100
Alkalinity 200
Ammonium 500
Phosphate 2.5
pH --
Total Organic Carbon 100
Total Khejdal Nitrogen 50
Orthophosphate I
Total, phosphorus 2.5
EPA 325.3 M -The "M" stands for Modified.
--= Not applicable. PH result will be reported in Standard Units.
C:\PROJECTS\CDRSPRNG\OU4NDTS\WORKl'LAN\FIG&TA0L\TABLE2-2.REV
Page 42
Method
EPAOLM03.0
EPAOLM03.0
EPA OLM03.0
EPAOLM03.0
EPAILMO4.0
EPAILMO4.0
EPAILMO4.0
EPA325.3 M
EPA 353.1 & 354.1 M
EPA 375.4 M
EPA376.I M
EPA3l0.IM
EPA350.2 M
EPA 365.2 M
EPA 9045
EPA 9060
EPA 353.1 M
EPA365.2 M
EPA365.2 M
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screened portion of the Soil Gas Monitoring Wells will be staged at two to four and five to
seven feet below the ground surface. A detailed diagram of a typical Soil Gas Monitoring
Well is shown in Figure 2-5. 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: (1)
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 2-5)
to be used to record soil gas concentrations.
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, sixth, and eighth 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
Phase I Natural Degradation Treatability Study Report and 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.
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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 laboratory in the CLP program for TCLP organic
and TCL inorganic analysis, ignitability, corrosivity and reactivity. Upon receipt of the
analytical results, the waste streams will be profiled for 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) 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 Treatability
Study. In addition, NSCC will retain the services of a laboratory, qualified and experienced
to conduct biotreatability studies, to complete the biotreatability study for the Natural
Degradation Treatability 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 Kluttz (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
A:\OU4NDTS\OU4WKPLN.RVI Page 45
---- ---- -- - -- ---
"C '" IQ "' ... c:n
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 &
I Project Coordinator
Ray Paradowski
Health & Safety Officer
Richard Franklin
Project Director Quality Assurance
Dr.Abu Alam Officer
Sreedhar Velicheti
Field Operations
Coordinator Project
Kenneth Kluttz Environmental Engineer
Michael Ford
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Analytical Services Drilling & Analytical Services (Soil) Analytical Services (Biotreatability Study) Well Installation Laboratory (Soil Gas) Blue Planet Graham & Currie Resources Inc. Lancaster Lab. Inc.
-- -
I
Field Sampling &
Monitoring
Michael Ford
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installation, and Laboratory Resources Inc. (a laboratory in the CLP program) 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 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. He will
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
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 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:
I. 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
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.
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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:
1.
2.
3.
4.
5.
Making sure that the drilling sub-contractor is using proper equipment suitable
for the Project;
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;
Making sure that all portable field monitors and tools are cleaned, calibrated
and protected from contamination in accordance with the QAPP;
Making sure that all soil and soil gas samples are collected, preserved and
shipped according to the QAPP;
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
Field Operations Coordinator include:
1.
2.
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,
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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:
1. 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
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 \Vork Plan. The project schedule is presented in Figure 4-1
and covers all items identified under Work Plan Contents (Section 1.5).
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Figure 4-1 : Project Schedule -
OU4 Natural Degradation Treatabilty Study
I 1996 1997 1998 1999 2000
Task Name AISIOINIDIJIFIMIAIMIJIJ IA SIOINID J I F IM I A I M·I J I J I A I S I O I N I D JI FI MI A 1M I JI JI A Is IO IN ID J IF IM I A IM.I J I J I A IS IO IN ID JIFIMIAIMIJIJIAISIOINID
PlaMlng and Pntparation • • '
Submtt Draft Work Plan ♦ 10/26
EPA & NCOEHNR 1st Commen -NSCC Submits 1st Responses -EPA & NCDEHNR 2nd Comme -NSCC Submits 2nd Responses I
EPA Approves Approach ~ 6/11
Submtt Final NOTS Work Plan !• 7/9
Notice to Proceed ♦ 7/23
Field Activities • • Mobilize Contractor ■
Biotreatability Study -Baseline Sampling I
Install Monitoring Wells I
Monitoring Activities -~ . .
Soil Gas Monitoring I 111111111111111 ii I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 111111111111111111111111111111111111111111111111
Treatability Activities I I I I I I I I I I I II II I II I I I I I I I I I I I I II I I I I II I I II 1111111111111111111111111111111 lllll 11111111111111111111111111
Quarterty Sampling I I I I I I I I I
Reports --
Progress I I I I
Phase I NOTS Letter Report ♦ 7/23 .
Prepare and Submtt Draft NOTS -EPA Review of Draft • Submtt Final NOTS I
National Starch and Chemical Company Task Milestone ♦ Summary • • Monitoring I 11 I I I I I I llll I I I I I I I
Salisbury, North Carolina
C:\WINPROJIOU4-REV2.MPP Fri 6/21/96
Page 52 Page 1
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JIFIMIAIMIJ
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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
List of Figures .................................................. 11
List of Tables ................................................... ii
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.4.1 Soil Sampling Procedures ............................... A-3
A.4.2
A.4.3
A.4.4
A.4.5
A.4.6
A.4.7
A.4.8
A.4.9
Soil Gas Sampling and Monitoring Procedure .................. A-4
A.4.2.1 Real Time Instrument Sampling Procedure ............. A-4
A.4.2.2 Summa Canister Sampling Procedure ................. A-5
Summa Canister Cleaning Procedure . . . . . . . . . . . . . . . . . . . . . . . . A-6
Protective Clothing and Screening Equipment .................. A-7
Location of Utilities ................................... A-7
Samples to be Split for Analysis by USEPA ................... A-7
Sampling Documentation ................................ A-8
Sampling Equipment, Materials and Decontamination Procedures . . . . . A-8
Sample Handling and Documentation for Samples Shipped to Off-Site
Laboratories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-10
A.5.0 Soil Gas Monitoring Well Installation Procedures ..................... A-11
A.5.0 Moisture and Nutrient Addition Procedures ........................ A-12
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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 Plots and Soil Gas Monitoring Well Locations ..................... A-1
A-3 Soil Plot Detail ............................................ A-1
A-4 Summa Canister Sampling Diagram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-5
A-5 Summa Canister Cleaning Method ............................... A-6
A-6 Soil Gas Monitoring Well Construction Diagram ..................... A-11
List of Tables
Table
A-1
A-2
Title Follows Page
Soil Sample Locations, Depths and Frequency ........................ A-2
Summary of Soil Analytical Parameters and Methodologies ............... A-3
II
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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).
The Natural Degradation Study will consist of a laboratory study as well as a two-phase field
study. The sampling procedures described in the following sections will be the same under
Phase I and Phase II except under phase II one of the treatment methods will be replicated at
three random locations. Sampling for this investigation will include collection of soil samples
from four Soil Plots and three replication plots, and collection and monitoring of different
gases from eleven Soil Gas Monitoring Wells. 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 back-
ground levels for determining 1,2-DCA degradation rates.
A.2.0 Sample Locations and Sampling Frequency
Under phase I, 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. Under phase II soil samples will be
collected from the three replication plots. Figures A-1 and A-2 presents the locations of the
Soil Plots and Figure A-3 illustrates details of the proposed Soil Plots and Soil Gas Monitor-
ing Wells located inside each Soil Plot.
Under phase I, soil samples will be collected from these four selected Soil Plots initially at the
start of the Natural Degradation Treatability Study and every three months thereafter up to
I year. Under Phase II, soil samples will be collected initially from the new replicated plots
and thereafter every three months until the end of the study. Soil samples will be collected
A-1
-------------------
SGMW 4 -----1 ... ►~ Soil Plot 4 (Background)
1-----------1
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L
c:~rojects\c.drspmglou4ndts\fig2-1
---
1----~-0 100
Scale (ft)
200 300
' ----' \
-------' I ',
_______ .. I
1011----------------, • I '. i :
lot 2 ' : /
I
LOADING
DOCK I
PARKING LOT
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'1 I,'
'·/
400 500
LEGEND
0 Soil Plot
• Soil Gas Monitoring Well
■ RP-1 = Replication Plot 1
\
'_.... 1.2 DCACONCENTRATION CONTOUR
'6
NOTE: Confirmation data supplemented by
soil screening data
FIGURE A-1
LOCATION OF SOIL PLOTS
REPLICATION PLOTS
AND SOIL GAS MONITORING WELLS
NATIONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC
-----
lliiil ---0 100
c.l;Jrojecls\cOOpmglou4ndl5\flg2-2
----
DRIVEWAY
LAGOON
1
Scale (ft)
200 300
2
---~' 500 400
---
PARKING
AREA
/--.. ,
( \ 23 (7.5)
\ . /
' /
-
I-
~ lJ.J iE
0:: 0 ;z
-- ---
7
• ■
LEGEND
Soil Boring Showing 1,2 DCA
Concentration (ppb) and Depth (ft.)
of Maximum Concentration
Soil Gas Monitoring wen
RP-3::: ReplicaUon Plol #3
WASTE-WATER LINE, ARROW INDICATES
DIRECTION OF FLOW
ABANDONED LINE
• '-_/--_ 1 ,2 DCA CONCENTRATION CONTOUR
10000
NOTE: Confirmallon data supplemented by
soil screening data
FIGURE A-2
LOCATION OF REPLICATION PLOTS
AMO SOIL GAS MONITORING WELLS
IN THE LAGOON AREA
NATIONAL STARCH AND
CHEMICAL COMPANY SALISBURY NC
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4' T
2'
c: \p,o ject1\cdrspnQ \ndtao.,4 \flQ2-J.d~
f---------6'-------11 <TYPICAL;
-1-s·-j-I
I s· . ~ ....... :----~', • • • •
8' <TYPICAU
• • • @ • •-:---+--r'
SGMW t • • • • • • • • -I--• • • . . . ' -t-s·--s·
'
PLAN VIEW
Notes: • = Sample Locotion
SGMW = Soil Gas Monitoring Well
[i,[atlonal Starch and Chemical Company FIGURE A-3
Soil Plot Detail
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using a drill rig and a 2-inch split-spoon. During each sampling event, three bores within each
Soil Plot will be advanced to a depth of approximately eight feet. Two soil samples will be
collected from each boring or a total of six samples per event as presented in Table A-1.
As illustrated in Figures A-1, A-2, and A-3, four Soil Gas Monitoring Wells (SGMW-1 to
SGMW-4) will also be installed, one at the center of each Soil Plot inside Area 2 (a total of
three wells), one at the center of the Soil Plot located in the background area outside the 1,2-
DCA contaminated zone. Additionally, four Soil Gas Monitoring Wells (SGMW-5 to
SGMW-8) will be installed at random locations in Area 2 and near the Lagoon in areas known
to be contaminated with 1,2-DCA. 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, Soil Gas Monitoring Wells and
Replication Plots will be designated SP, SGMW and RP, 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-
Ill. 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 Sampling 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 (HSP) included as Appendices B and C of this Work Plan, respectively.
A-2
-------- -,_ -- -- -Table A-1
Soil Sample Locations, Depths and Frequency
Cedar Springs, North Carolina
ii Sample ~-3~~~-~~-.. Sample-Frequency"(monthsr -· -· --.
ii Depth l=le ------------Ii Locati_o_n _ ....JD~e~al g _6_ 9 -~12 --·-~-15_~~ _ 18 21 ,1-·-
11 SP-1 2-8' 1 X X X X X
ii 2-8' 2 X X X X X
11 2-8' 3 X X X X X
I SP-2 2-8' 1 X X X X X
2-8' 2 X X X X X
Ii 2-8' 3 X X X X X
I SP-3 11 2-8' 1 X X X X X
I 11 2-8' 2 X X X X X
I 11 2-8' 3 X X X X X
I I
SP-4 I . 2-8' 1 X
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2-8' 2 X I' 2-8' 3 X
RP-1 2-8' 1 X X X X
2-8' 2 X X X X
2-8' 3 X X X X
RP-2 2-8' 1 X X X X
2-8' 2 X X X X
I
2-8' 3 X X X X
RP-3 2-8' 1 X X X X
2 X X X X 1 2-8' l I 2-8' 3 X X X X
~~~-t ..
Notes:
. . -· ··--------~----·---
X = Two soil sampls will be collected from each boring based on the highest headspace readings recorded in the field.
--= No sample collection.
SP = Soil Plot under Phase I
RP= Replication Plot under Phase II
Soil samples will be collected from the Soil Plot (SP) with the best degradation rate during months 12 to 24.
C:\123r4\table-a1 .wk4
----
24
-1
X
X
X
X
X
X
X ~
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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 activiti~s 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
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 HNu 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 (1) 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 time 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-3
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Table A-2
Summary of Soil
Analytical Parameters and Methodologies
Parameter MDL (mg/kg)
1,2 Dichloroethane 0.01
Vinyl Chloride 0.01
1,2 Dichloroethylene, total 0.01
Chloroethane 0.01
Calcium 1000
Iron, Total 20
Magnesium 1000
Chloride 200
Nitrate 10
Sulfate 500
Sulfide JOO
Alkalinity 200
Ammonium 500
Phosphate 2.5
pH --
Total Organic Carbon JOO
Total Khejdal Nitrogen 50
Orthophosphate 1
Total, phosphorus 2.5
EPA 325.3 M -The "M" stands for Modified.
--= Not applicable. PH result will be reported in Standard Units.
C:\PROJECTS\CDRSPRNG\OU4NDTS\WORKPLAN\TADLEA-2.R.Vl
Method
EPA OLM03.0
EPA OLM03.0
EPA OLM03.0
EPAOLM03.0
EPA ILMO4.0
EPA ILMO4.0
EPA ILMO4.0
EPA 325.3 M
EPA 353.J & 354.1 M
EPA 375.4 M
EPA 376.1 M
EPA 310.J M
EPA 350.2 M
EPA 365.2 M
EPA 9045
EPA 9060
EPA 353.1 M
EPA 365.2 M
EPA 365.2 M
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A.4.2 Soil Gas Sampling and Monitoring Procedures
Soil Gas concentrations will be measured on-site using real time instruments and off-site using
Summa Canisters. Soil Gas concentrations will be measured weekly using real time instru-
ments. A GEM-500 will be used to detect and measure carbon dioxide, oxygen, methane and
hydrogen sulfide concentrations. Soil Gas concentrations will be measured twice: once before
purging the well and once after purging the well. Soil Gas concentrations will be measured
first from the 6 to 8 feet interval and then the from the 2 to 4 feet interval.
A.4.2.1 Real Time Instruments Sampling Procedures
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 Teflon tubing to the 1/4 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, methane and hydrogen sulfide 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
measured concentration of hydrogen sulfide will also be recorded in the daily log book.
After recording 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,
methane and hydrogen sulfide in the Soil Gas of the purged well will then be measured again
using the GEM-500. All measurements and recording will be carried as previously described
above.
Concentrations of oxygen, carbon dioxide, methane, and hydrogen sulfide in the Soil Gas will
be measured weekly in the field using portable real time instruments identified above.
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A.4.2.2 Summa Canisters Sampling Procedures
Soil gas samples will be collected monthly in stainless steel canisters from the Soil Gas
Monitoring Wells located in the center of the Soil Plots and quarterly from the four isolated
Soil Gas Monitoring Wells located in Area 2 and near the Lagoon. These soil gas samples
will be shipped to an off-site laboratory for analyses of 1,2-dichloroethane, 1,2-
dichloroethene, chloroethane and vinyl chloride by USEPA Method TO-14 and for analyses of
ethane, ethene, oxygen, carbon dioxide, and methane by ASTM D1496.
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
preevacuated 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-4.
First, the 6 to 8 feet interval will be sampled followed by the 2 to 4 feet interval. 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 for the 6 to 8 feet interval. Once connected, the valve on
the canister will be opened at least one tum. 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 approxi-
mately 500 ml/min. The canister will fill with the required 4 liters of air in 8 minutes. At the
end of the sampling period, the sampler will close the valve to the Summa canister, will complete
the canister identification tag with the sample location and will enter the sampling time in the
field log book. Next, the 2 to 4 feet interval will be sampled following the same procedures
described above.
When finished sampling both intervals, the sampler will complete the chain-of-custody and will
package the canisters in bubble wrap for shipment to Lancaster Laboratories via Federal Express
or United Parcel System for overnight delivery.
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1/4" FEMALE SWAG1:LOCK
FITTING • TO SUMMA CANISTER ---
{Nj:,tlonal Storch and Chemical Company
1/4" MALE SWAoaocK FITTING
IA. b:;I'" -1/4" SWAGELOCK CAP
VAC PRESSURE GUAGE
CANISTER VALVE
FIGURE A-4
SUMMA CANISTER
SAMPLING DIAGRAM
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A.4.3 Summa Canister Cleaning Procedures
These cleaning procedures are 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 and ASTM D1496.
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 are
assigned sequentially as canisters are purchased and are 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 certifica-
tion was completed with he initials or employee number of the person who certified the canister
clean.
Canisters are cleaned according to the procedure outlined in EPA Method TO-14. The canisters
are placed on the manifold shown in Figure A-5 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
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-5. The canister is then evacuated
(<0.0Smm Hg), capped, a tag attached stating the condition, and ready for next use.
A-6
-------------------
VACUUM
CRYOGENIC TRAP
---
National Starch and Chemical Company
VACUUM/PRESSURE
Summa canisters
CRYOGENIC TRAP
HUMIDIFIER
SUMMA CANISTER CLEANING MANIFOLD
FIGURE A-5
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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 Equipment
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. !fan 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,
conduits, etc. Location of utilities must be determined to ensure the safety of the sampling
personnel and equipment.
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.4.6 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
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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 Sampling 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.
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)
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3. Thermometer (-20 to + 120 deg. Centigrade)
4. HNu (PI-IOI) with 11.7 eV probe
5. OVA (128 GC)
6. Teflon 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, CH4 gas monitoring instrument (GEM-500)
I I. H2S gas monitoring instrument (GEM-500)
12. Dibasic ammonium phosphate (10 lbs)
13. Distilled water (5 gallons)
14. Detergent (Alconox)
15. Cotton gloves
16. Personnel protective gear
I 7. Coolers and Ice
18. VOC Trip Blanks (2)
I 9. 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
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. Rinse thoroughly with tap water (three times)
c. Rinse thoroughly with deionized water
d. Rinse twice with isopropanol
e. Rinse thoroughly with organic free. water.
f. Air dry
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g. Wrap in clean aluminum foil with dull side against the equipment.
Note: Do not rinse with deionized or distilled water during Step E.
If organic free water is not available, allow equipment to air dry as long as
possible
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 2 ounce jars with
Teflon lined septum lid. 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
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
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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
A total of eleven Soil Gas Monitoring Wells will be installed during the Natural Degradation
Study. Eight wells will be installed under Phase I and three wells under Phase II. Under
phase I, 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 Well will be
installed inside the fourth Soil Plot located in uncontaminated soil outside Area 2 (in a
background location). These Soil Plots will be protected by a 4' by 6' protective metal box.
The fifth, sixth, seventh and eighth Soil Gas Monitoring Wells will be installed at random
locations in Area 2 and near the Lagoon. Under phase II, a Soil Gas Monitoring Well will be
installed in the center of the three replication plots used to replicate the Soil Plot which
demonstrated the best degradation rate of 1,2-dichloroethane under Phase I.
Soil Gas Monitoring Wells will be installed using hollow-stem augers which 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-6 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-8) and
three replication plots (RP-1 to RP-3) are shown in Figures A-1 and A-2.
The Soil Plots will be completed as shown in Figures A-3. A locking 4' x 6' BILCO type
protective metal box with a cover will be installed at grade level. The frame and cover of the
metal box will be constructed of epoxy primed and epoxy painted formed steel. The formed
steel will be sandblasted to near white metal, immediately primed with a coat (4 to 5 mils
DFT) of polyamide epoxy and then painted with a coat ( 6 mils DFT) of compatible epoxy
paint. This will prevent corrosion and related interferences with the soil. A protective
concrete curve will be placed around the metal box.
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FINISH GRADE TO WATER TIGHT 1 /4" FEMALE QUICK
DRAIN AWAY FROM BOX WELL BO~ (COUPLE
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BENTONITE PELLETS ____
1" SCH. 10 SS PIPE
-
SILICA SAND --+---( .
VAPOR PROBE ~
1 /4" DIA. X 1' LONG ___. · .
SS SCREEN, 0.02 SLOT
BENTONITE PELLETS
1 /4" SCH. 10 SS PIPE
-(\J
-(\J
-(\J
SILICA SAND --+---'
l,,.,)\...::___-.:.___:..-:----'----J ] VAPOR PROBE
1 /4" DIA. X 1' LONG
SS SCREEN, 0.02 SLOT -----6" ----------
NOTES: SS = STAINLESS STEEL
Not to scale
BOX SET IN CONCRETE
FINISHED AT GRADE
FIGURE A-6
[if ational Storch and Chemical Company Soil Gas Monitoring Well
Construction Detail
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Soil Gas Monitoring Wells will be completed as shown in Figure A-6. All well casing and
screen to be used in the construction of the Soil Gas Monitoring Wells will be of flush
threaded 1/4" 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 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 aI111ular 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. The source of water will
be the City of Salisbury Water Treatment Plant. The water will be drawn directly from an on-
site spigot into the container to be used to distribute the water. Prior to distribution, the water
will be aerated for approximately thirty minutes to remove any residual chlorine, and if
necessary, the aerated water will be stored over-night to remove all traces of chlorine prior to
use in the Soil Plots. 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 minutes prior to
applying the solution. The dibasic ammonium 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-12
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APPENDIX B
QUALITY ASSURANCE PROJECT PLAN
For
Remedial Design/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 Figures ........................................................... - . - --
List of Tables ................................................................ .
B.1.0 Introduction ....................................... : ................... B-1
B.1.1 Project Description ............................................... B-1
B.1.2 Project Objectives ................................................ B-1
B.2.0 Project Organization and Responsibility ..................................... B-2
B.2.1 Plant Manager ................................................... B-2
B.2.2 Project Director .................................................. B-3
B.2.3 Project Health and Safety Officer .................................... B-3
B.2.4 Project Environmental Engineer ..................................... B-4
B.2.5 Field Operations Coordinator ....................................... B-5
B.2.6 Quality Assurance Officer .......................................... B-5
B.2.7 Laboratory Directors/Project Coordinators ............................. B-6
B.2.8 QA Reports to Management ........................................ B-6
B.3.0 Project-Specific QA and QC Procedures .................................... 8-7
BJ. I Detection Limits ................................................. B-8
B.3.1.1 Soil .................................................... B-8
B.3.1.2 Soil Gas ................................................ B-8
B.3.2 Data Precision and Evaluation ...................................... 8-9
B.3.2.1 Soil .................................................... B-9
B.3.2.2 Soil Gas ................................................ B-9
B.3.3 Data Accuracy and Evaluation ...................................... B-9
B.3.3.1 Soil .................................................... B-9
B.3.3.2 Soil Gas ................................................ B-10
B.3.4 Completeness of Data ............................................ B-10
B.3.5 Comparability .................................................. B-10
B.3.5.1 Soil ................................................... B-10
B.3.5.2 Soil Gas ............................................... B-10
B.4.0 Drill Rig and Equipment Decontamination Procedures ........................ B-11
B.5.0 Sample Custody ...................................................... B-13
B.5.1 Chain-of-Custody Procedures ...................................... B-13
B.5.2 Sample Labeling ................................................ B-14
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Table of Contents ___________________ _
8.6.0 Equipment Calibration ................................................. B-15
8.6.1 General Calibration Procedures ..................................... B-15
8.6.2 Soil Gas ....................................................... B-15
8.6.3 Field Calibration Procedures for GEM-500 ........................... B-16
8.6.3.1 Equipment ............................................. B-17
8.6.3.2 Setting Up the Equipment ................................. B-17
8.6.3.3 Calibration Gases ........................................ B-18
B.6.3 .4 Calibration Method ...................................... B-18
8.6.4 Calibration Failures .............................................. B-18
B. 7.0 Analytical Procedures .................................................. B-20
8.7.1 Overview of Standard Laboratory Operating Procedures ................. B-20
8.7.2 Organic Compounds ............................................. B-20
B.7.2.1 Soil ................................................... B-20
8.7.2.2 Soil Gas ............................................... B-21
B.7.3 Metals ........................................................ B-21
8.8.0 Data Reduction, Validation, and Reporting ................................. B-22
8.9.0 Quality Control Procedures .............................................. B-23
8.9.1 Field Quality Control Procedures ................................... B-23
8.9.2 Laboratory Quality Control Procedures .............................. B-23
8.9.2.1 Volatile Organics in Soil .................................. B-23
8.9.2.2 Metals and Miscellaneous ................................. B-24
8.9.2.3 Soil Gas Parameters ...................................... B-24
8.10.0 Performance and Systems Audits and Frequency ............................ B-26
8.11.0 Preventive Maintenance ............................................... B-27
8.1 I. I Routine Maintenance Activities ................................... B-27
8.11.2 Preventative Maintenance Documentation ............................ B-27
B.11.3 Contingency Plans .............................................. B-28
B.12.0 Specific Routine Procedures Used to Assess Data Precision, Accuracy, and
Completeness ........................................................ B-29
B.12.1 Laboratory Quality Control Checks ................................ B-29
B.12.2 Trip (Travel) Blank Analyses ..................................... B-29
B.12.2.1 Soil .................................................. B-29
B.12.2.2 Soil Gas .............................................. B-29
B.12.3 Method Blank Analyses ......................................... B-30
B.12.3.1 Soil .................................................. 8-30
B.12.3.2 Soil Gas .............................................. B-30
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Table of Contents ____________________ _
B.12.4 Reagent Blank Analyses ......................................... B-30
B.12.4.1 Soil .................................................. B-30
B.12.4.2 Soil Gas .............................................. B-31
B.12.5 Duplicate Sample Analyses ....................................... B-31
B.12.5.1 Soil .................................................. B-31
B.12.5.2 Soil Gas .............................................. B-3 I
8.12.6 Check Standard Analyses ........................................ B-32
B.12.6.1 Soil .................................................. B-32
B.12.6.2 Soil Gas .............................................. B-32
B.12.7 Surrogate S!andard Analyses ..................................... B-32
B.12.7.1 Soil .................................................. B-32
B.12.7.2 Soil Gas .............................................. B-32
B.12.8 Matrix Spike Analyses .......................................... B-33
B.12.9 Matrix Spike Duplicate Analyses .................................. B-33
B.12.10 Verification/Reference Standard Analyses .......................... B-33
B.12.11 Blank Spike Analyses .......................................... B-33
B.12.12 Laboratory Control Samples ..................................... B-34
B.12.12.1 Soil ................................................. B-34
B.12.12.2 Soil Gas ............................................. B-34
B.12.13 Standard Addition Spike Analysis ................................. B-35
B.12.13.1 Soil ................................................. B-35
B.12.13.2 Soil Gas ............................................. B-35
B.12.14 Internal Standard Spike Analyses ................................. B-35
B.12.14.1 Soil ................................................. B-35
B.12.14.2 Soil Gas ............................................. B-35
B.13.0 Routine Methods to Assess Precision and Accuracy ......................... B-36
B.13.1 Soil ......................................................... B-36
B.13.2 Soil Gas ...................................................... B-39
B.14.0 Nonconfonnance/Corrective Action Procedures ............................. B-40
B.15.0 Quality Assurance Audits and Reports .................................... B-42
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List of Tables __________________ _
Table Title Follows Page
B-3-1 Target Compound List (TCL) and Contract Required B-8
Quantitation Limits (CRQL) -Volatiles
B-3-2 Target Analyte List (T AL) and Contract Required B-8
Quantitation Limits (CRQL) -Metals
B-3-3 EPA TO-14 -Volatile Organics Quantitation Limits B-8
B-3-4 ASTM-D 1496 -Fixed Gases Quantitation Limits On Page B-7
B-6-1 Summary of Operational Calibration Requirements B-15
B-11-1 Summary of Periodic Calibration Requirements B-27
B-13-1 QC Samples Used to Generate Precision and Accuracy B-36
I List of Figures __________________ _
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Figure
B-2-1
B-5-1
B-6-1
Title Follows Page
Remedial Design/Remedial Action Work Plan Project Organization Chart B-2
Analysis Request and Chain-of Custody Form B-13
Field Calibration Shematic 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 Remedial Action/Remedial Design \Vork Plan for the Operable Unit 3 (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:
I. 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 Remedial Action/Remedial Design \Vork Plan for the Operable
Unit 3 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 Remedial Action/Remedial Design \Vork Plan for the OU3 is to collect and
evaluate the data needed to achieve the objectives outlined in the \Vork Plan.
B-1
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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 Remedial Design/Remedial Action \Vork Plan as
described in the \Vork 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 sampling operations. Actual collection of groundwater samples from the extraction and
monitoring wells as well as the collection of sediment and surface water samples from along the
Northeast Tributary will be perfom1ed 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) laboratory will be retained by NSCC to carry out the analyses of the
sediment, surface water and groundwater samples collected for this \Vork Plan. NSCC Figure B-2-
1 illustrate the proposed Project Organization and Responsibilities of various members of the
Project Team selected for conducting the Remedial Design/Remedial Action \Vork Plan.
The principal NSCC staff members assigned to this project are Mr. Ray Paradowski (Plant Manager
and Project Coordinator), 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, and Laboratory Resources
Inc. ( a CLP laboratorv) to conduct analyses of soil samples. Other personnel will be assigned as
deemed necessary. The responsibilities of these individuals are described in the following sections.
B.2.1 Plant Manager
The Plant Manager and Project Coordinator for this Project is Mr. Ray Paradowski. He will 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.
B-2
- -·--- - - --,_ -- --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
Richard Franklin
Project Director Quality Assurance
Dr. Abu Alam Officer
Sreedhar Velicheti
Field Operations Project
Coordinator Environmental Engineer
Kenneth Kluttz Michael Ford
I
Analytical Services Drilling & Analytical Services (Soil) Analytical Services
(Biotreatability Study) Well Installation Laboratory (Soil Gas)
Blue Planet Graham & Currie Resources Inc. Lancaster Lab. Inc.
I
Field Sampling &
Monitoring
Michael Ford
--
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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.
3.
4.
5.
6.
7.
Supervision of performance of various Project Team Members;
Planning and scheduling of all Project activities;
Keeping the Plant Manager and Project Coordinator informed of all aspects of the
Project;
Assure that all Project documents and deliverables are reviewed in a timely manner for
technical accuracy and completeness before their release;·
Assure that the specific requirements of the QAPP are met; and
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 I-ISP. 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 perfom1 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 (704)
633-1831 Ext.233. Other responsibilities of the Project Health and Safety Officer include:
1. Detem1ining and posting emergency telephone numbers and routes to emergency medical
facilities, including poison control facilities, and arranging emergency transportation to
medical facilities;
B-3
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2.
3.
4.
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; 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.
B.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 collecting groundwater, surface water and sediment samples
in the field, making sure that covers for all extraction and monitoring wells are in place and locked
after each sampling activity, and shipping all groundwater, surface water and sediment samples to
the analytical laboratory with proper chain-of-custody fonns.
The Project Environmental Engineer is also responsible for ensuring that all Project work tasks are
carried out in accordance with the \York 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. The drilling sub-contractor is using proper equipment suitable for the Project;
2. All drilling equipment and split-spoon samplers arc properly decontaminated and
protected from contamination prior to bringing these on site and actual use;
3.
4.
5.
6.
7.
All portable field monitors and tools arc cleaned, calibrated and protected from
contamination in accordance with the QAPP;
All groundwater, surface water, and sediment samples are collected, preserved and
shipped according to the QAPP;
Review work performed by the sub-contractors and approve their invoices;
Establish a record keeping system for the Project; and
Conduct Project closeout at the completion.
B-4
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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 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:
I. 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.
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:
I.
2.
3.
4.
Contacting the analytical laboratories receiving samples to detem1ine if samples are
prepared, packaged, and identified properly;
Conducting field audits of sampling events to assure that proper sample identification,
sampling techniques and chain-of-custody procedures are observed;
Reporting to the Project Director on personnel assigned to field supervision and sample
collection tasks arc properly trained in sample collection, sample identification and
chain-of custody procedures; and
Reviewing work products and Project deliverables.
B-5
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B.2. 7 Laboratory Directors/Project Coordinators
A Laboratory Director/Project Coordinator will be used in this Remedial Design/Remedial Action
\Vork Plan. The Laboratory Director/Project Coordinator will be responsible for coordinating
laboratory services provided by Laboratory Resources and will ensure that analytical data from his
laboratory meet the objectives discussed in the applicable sections of the QAPP. Laboratory
Director/Project Coordinator will be assigned by the certified laboratory selected for conducting the
laboratory analyses of groundwater, surface water and sediment samples.
B.2.8 QA Reports to Management
Fundamental to the success of any QAPP is the active participation of the Project Organization and
Management Team selected for the Project. The Organi7.ation 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:
I.
2.
3.
4.
5.
Task-specific QAPPs
Corporate and Project-specific QA/QC Plans and Procedures
Post-audit reports and audit closures
Corrective action overdue notices
Nonconformance reports.
B-6
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B.3.0 Project-Specific QA and QC Procedures
Project QA objectives are as follows:
I.
2.
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:
I 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
2. 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
3. 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:
I. Detection limits
2. Data precision
3. Data accuracy
4. Completeness of data.
B-7
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B.3.1 Detection Limits
B.3.1.1 Soil
The detection limit for a given parameter is defined as the minimum concentration that can be
detem1ined from an instrument signal that is three times the background noise. Tables B-3-1 through
B-3-2 provide listings of the estimated quantitation limits for Target Compound List (TCL) and
Target Analyte List (TAL) pollutants.
B.3.1.2 Soil Gas
Detection limits for volatile organics compounds by TO-14 have been evaluated on the basis of
MDL studies. The MDL coupled with an evaluation of the typical method blanks have been used
to develop the detection limits listed in Table 13-3-3. The quantitation limit for the target compounds
is I ppbv. This is based on both the detectability fthe analyte and the ability to have contaminant
free blank analyses at the quantiation limit.
Detection limits for fixed gases by GC/FID and GC/TCD are based on calibration range as well as
the sample volume injected. The detection limits arc set as one firth of the quantitation limits listed
below in Table B-3-4
Compound
Methane
Ethane
Ethene
Oxygen
Carbon Dioxide
Table B-3-4
Quantitation Limits for
Fixed Gases
Quantitation Limit
20 ppmv
10 ppmv
10 ppmv
0.1 % (v/v) = 1000 ppmv
0.1 % (v/v) = 1000 ppmv
These represent the lowest concentration of the standards used for calibration. For the detennination
of oxygen and carbon dioxide, the detection limits are below the typical concentration in air.
8-8
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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 (µg/L) Saile (µg/kg)
Chloromethane 74-87-3 10 10
Bromomethane 74-83-9 10 10
Vinyl chloride 75-01-4 10 10
Chloroethane 75-00-3 10 10
Methylene 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-Dichloropropane 78-87-5 10 10
cis-1,3-Dichloropropene 10061-01-5 10 10
Trichloroethene 79-01-6 10 10
Dibromochloromethane 124-48-1 10 10
C:\PROJECTS\CDRSPRNG\OU4NOTS\OAPP\FIG&TB\OAPP.B31
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Table B-3-1
(Page 2 of 2)
Quantitation Limits•
Parameter GAS Number Water (µgll) Soil' (µglkg)
1, 1,2-Trichloroethane 79-00-5 10 10
Benzene 71-43-2 10 10
trans-1,3-Dichloropropene 10061-02-6 10 10
Bromoform 75-25-2 10 10
4-Methyl-2-pentanone 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
Ethyl Benzene 100-41-4 10 10
Styrene 100-42-5 10 10
Total xylenes 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\FIG&TB\QAPP.B31
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Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
Table 8-3-2
Target Analyte List (TAL) and Contract Required
Quantitation Limits (CRQL)"
lnorganics
Quantitation Limits
Parameter CAS Number Water (µg/L) Soil (mg/kg)
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\OAPP\FIG&TB\OAPP.834
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Table B-3-3
EPA Method T0-14
Quantitation Limits
(page lof 2)
Compound LOQ (ppbv) LOD (ppbv)
Ally! Chloride 1.0
Benzene 1.0
Benzyl Chloride 1.0
Bromomethane 1.0
Carbon Tetrachloride 1.0
Chlorobenzene 1.0
Chloroethane 1.0
Chloroform 1.0
Chloromethane 1.0
1,2-Dibromomethane 1.0
1,2-Dichlorobenzene 1.0
1,3-Dichlorobenzene 1.0
1,4-Dichlorbenzene 1.0
1, 1-Dichloroethane 1.0
1,2-Dichloroethane 1.0
1, 1-Dichloroethylene 1.0
cis-1,2-Dichloroethylene 1.0
1,2-Dichloropropane 1.0
cis-1,3-Dichloropropylene 1.0
Notes: LOQ = Limit of Quantitation
LOD = Limit of Detection
MDL = Method Detection Limit
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.5
0.5
0.5
0.2
0.2
0.2
0.2
0.2
0.2
MDL (ppbv)
0.05
0.03
0.04
0.08
0.03
0.03
0.07
0.04
0.03
0.02
0.02
0.04
0.02
0.03
0.02
0.04
0.05
0.03
0.02
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Compound
trans-1,3-Dichloropropylene
1,2-
Dichlorotetrafluoroethane
Ethyl benzene
4-Ethyl toluene
Freon 11
Freon 12
Freon 113
Hexachlorobutadiene
Methylene Chloride
Styrene
Tetrachloroethylene
1, 1,2,2-Tetrachloroethane
Toluene
1,2,4-Trichlorobenzene
1, 1, I-Trichloroethane
1, 1,2-Trichloroethane
Trichloroethy Jene
1,2,4-Trimethylbenzene
1,3,5-Trimethylbenzene
Vinyl Chloride
Xylene (s)
Table B-3-3
Page (2 of 2)
LOQ
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Notes: LOQ = Limit of Quantitation
LOD = Limit of Detection
MDL = Method Detection Limit
LOD MDL
0.2 0.01
0.2 0.08
0.2 0.03
0.2 0.02
0.2 0.04
0.2 0.02
0.2 0.05
0.5 0.04
0.2 0.04
0.2 0.02
0.2 0.03
0.2 0.03
0.2 0.03
1.0 0.02
0.2 0.03
0.2 0.04
0.2 0.02
1.0 0.01
0.2 0.03
0.2 0.04
0.2 0.05
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B.3.2 Data Precision and Evaluation
B.3.2.1 Soil
Precision is a measure of the mutual agreement among individual m~asurements 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 T AL 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 arc less than 15 percent (average RPO).
B.3.2.2 Soil Gas
The analysis of a second aliquot from the SUMMA canister will be used to evaluate the precision
of the analysis. Acceptance criteria arc set for the VOCs and fixed gases analyses at 25% relative
percent difference for any analyte present at concentrations at least five times the limit of
quantitation.
B.3.3 Data Accuracy and Evaluation
B.3.3.1 Soil
Accuracy is defined as the degree of agreement of a measurement with an accepted reference or true
value. The percent recovery (¾R), detem1ined 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 TAL 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).
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B.3.3.2 Soil Gas
The determination of the accuracy of the analytical system will be based on the analysis of a
Laboratory Control Standard (LCS). The concentration of the LCS must be within+/-25% of the
known level for the volatile organics compounds and+/-20% of the known level for the fixed gases.
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. 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
B.3.5.1 Soil
To provide the comparability of the data to similar sets, EPA-approved analytical methods will be
used. For TCL and T AL parameters, these methods will be from the current EPA CLP protocols.
B.3.5.2 Soil Gas
To provide the comparability of the data to similar sets, EPA method TO-14 for volatile ogranics
will be used. Fixed gases: methane, ethane, cthene, carbon dioxide, and oxygen, will be determined
by GC using flame ionization and thermal conductivity detectors following the procedures in
ASTM-D 1496 with modification of the specific columns used for the analysis and the use of a flame
ionization detector for the hydrocarbon fixed gases.
B-10
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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:
I. The mud tub and downhole augering, drilling, and sampling equipment will be
sandblasted ifthere is a buildup of rust, hard or caked matter, and/or painted equipment.
Sandblasting will be perfom1cd before arrival on site.
2.
4.
5.
6.
7.
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.
Rinsed twice with solvent (pesticide-grade isopropanol).
Rinsed thoroughly with organic-free water and allowed to air dry as long as possible. 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
noninterferring containers. These containers will be made of glass, Teflon®, or stainless
steel. No plastic containers or pump sprayers will be 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.
B-11
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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.
B-12
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B.5.0 Sample Custody
B.5.1 Chain-of-Custody Procedures
Chain-of-custody procedures arc 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:
I.
2.
4.
In one's actual possession
In view, after being in physical possession
Locked so that no one can tamper with it, after having been in physical custody
In a secured area, restricted to authorized personnel.
The following procedures will be implemented for samples subject to chemical analysis for this
Project:
I.
2.
3.
4.
5.
6.
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.
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 san1plc 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.
The custody of individual sample containers will be documented by recording each
container's identification on a Chain-of-Custody Record form.
Analyses for each sample will also be recorded on a Chain-of-Custody Record form.
B-13
- - ---

-
----

-
---
LRIOUOTE •
M Laboratory Resources~
CKA!N OF CUSTODY PAGE OF
CUS TOUEA INFOAMA TION PROJECT CNfOAM.lTION • BIUJNGPCFORIIATION .,, •• ·•
CUSTOM EA; ____________ _ ""'-'EC"<,_--------------
AOOA<SS, Pfl0JECT lOCATIOH-, ______ STATE: __
PROJECTWAHAGEA, ___________ _
.. ~ ....... -.llUllfl'IQOa_.....,_U_Ml>O.ADC,1,U: ..... ,._ ---------------
TtLEP'10HE: ____________ _ TELEPHONE'' _____________ _
'""----------------
SAMPU: TYPE
"' • ""' ,_, """""""' (l,lT( nit: ~
CCUECTED CXlilCTEO a I
SIU TO: ..,,.,... ...
ATTENTON _________ _
TELEPHONE: ____________ _
ANALYSIS
TURNAROUNO (WOICATE IN CALENOAA OAYS)· __ ,,.,, __ HARO COPY __ OELI\I. PKO ll RETURN TO CLIENT FOR DISPOSAL Q LAB D1SPOSAL
NAME OF I.AB PEASONNELCONFIRMINQ, --------------------~ KNOWN HAU.AD (FlAMMA8l.E, EXPLOSIVE, TOXIC)
DELIVERA8L.ES/(CIRCLE ONE)· OATA DATA/QC AEO,OELN "-"CU' I "'-'!Ct.P JI a YES a NO (IF YES EXPVIN UNOER COI.CMENTSI
to'RE04.. NYIJ,,SP ClP OTHER l!lJ!ID CONDITIONS OF 80TTlES ANO COOLER AT RECEIPT;
S,UIPI.ER I AFFIUATION. DATE: QCQf,IPI.IAHT O NOT COMPUAHT (1F NOT f)(Pl,.AIIII UNDER COMMENT SJ
•~e~c~•~••~•~o~'~"~'~•~••='~'°""'c~---------------t-o'~••~•~·---------j COMMENTS, ______________ _
AetltOJl~OfAFFI..IATIOJ,,i DATE:
~ECEIVEO/AFl'IJATlON Tll.lE:
R.El-«'.ll.llSH'EOI AFF1..IATIQft; DATE:
Recerv£O I AF1UATlON TIME:
--
{H;__atlonal Starch and Chemical Company
ANALYSIS REQUEST AND
CHAIN-OF-CUSTODY. FORM
-
Figure B-5-1
~----------------------
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7. The following documentation will supplement the chain-of-custody records:
a.
b.
C.
Sample label on each sample
Sample seal on each sample
Field Daily Activity Log.
B.5.2 Sample Labeling
Sample labels must contain sufficient information to uniquely identify the sample in the absence of
other documentation. Labels will include as minimum:
I. Project number
2. Unique sample number
3. Sample location
4. Sampling date and time
5. Individual collecting the sample
6. Preservation method employed
7 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.
B-14
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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-l.
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 perfom1ed or substitute equipment can
be obtained.
B.6.2 Soil Gas
For volatile organics compounds by TO-14, three levels of standards are used for the initial
calibration. The calibration is checked daily using the mid level standard. The response factor for
the mid level calibration is used to quantify the samples. The relative standard deviation (RSD) of
the response factors must be less than 30% (up to three of the VOCs may have RSDs up to 40%).
The response factor for the continuing calibration check must be within+/-25% of the average.
At least four levels of standards prepared by injecting various volumes of a standard prepared by a
commercial supplier of gas phase standards will be used to calibrate for the methane, ethane, and
B-15
--- - ---- - -- --- ----
Table B-6-1
Summary of Operational Calibration Requirements
(Page 1 of 3)
Calibration Standards Used Initially
Instrument and Daily 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 1 0 samples recovery
Inductively coupled plasma Initial: high standard and blank N/A Establish new curve. Repeat twice Instrument data file
emission spectrophotometer (daily check); if outside control
Daily: Check standard (mid-range) Check standard ± 10% limit, then recalibrate making new
and calibration blank every 10 standards if necessary
samples
GC/MS Mass scale calibration every 12 U.S. EPA CLP criteria Retune: system maintenance Instrument calibration file
hours: BFB/DFTPP and/or GC/MS project file
Initial: 5 levels and blank meets all SPCC and CCC criteria Make new standards; recalibrate
Daily: 1 level (low-range) Make new standards; recalibrate
Gas chromatograph Initial: 3-5 levels and blank Response factor %RS□ <20% or Make new standards or establish Calibration chart file or
use curve new calibration cwve GC 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 1 D samples RF <±15% 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 criteria and before the next
time windows (for methods using standard that passes criteria
retention time windows)
KNN.'?9018.6A(149)/11-23-92/F1
------ --
Calibration Standards Used Initially
Instrument and Daily
UV-visible Initial: 3-5 levels and blank
spectrophotometer
Daily: 1 check standard (mid-range}
Quarterly: Wavelength accuracy
and photometric linearity
pH meter Daily: 2 levels (4.0-7.0)
Daily: Check calibration (10.0)
Specific conductance Daily: KCI check standard
Total organic carbon Daily: 3 levels and blank
Daily: check standard (mid-range)
Total organic halogens Daily: 2 levels; check standard
every 20. Blank every 10.
HPLC Initial: 3-4 levels and blank
Daily: Check standard every 10
samples (mid-range)
Ion Chromatograph Initial: 3 levels and blank
Daily: 1 level of check standards
eve"' 10 samnles /mid-ranae)
KNJ\\'P901 8.6A(149)/11-23-92/F1
- -
Table 8-6-1
(Page 2 of 3)
-
Acceptance Limits
Graph curve
Daily check standard 90-110%
recovery
Manufacturer specifications
±0.05 pH unit
+10% of true value
+10% of expected response
%RSD of RFs < 20%
RF +15%0 from calibration curve
15% of true value and recalibrate
Graph curve or RF %RSD <20%
15% of original curve
Graph curve
Daily: ±10% of original curve
------ --
Corrective Actions Documentation
Recalibrate, making new standards Calibration fileflogbook
if necessary
Recalibrate
Service
(1) Clean or replace electrode Logbook
(2) Recalibrate
(3) Service
Repeat test Project file
Make new standards and Project file
recalibrate
Reanalyze affected samples
Make new standards Project file
Make new standards and/or Project file
establish a new calibration curve
Reanalyze affected samples
Make new standards and Project file
recalibrate
Reanalyze affected samples
----- --
Calibration Standards Used Initially
Instrument and Daily
GC/MS -Dioxins and furans Mass scale calibration: PFTBA
Initial: 5 levels and blank
Daily: 1 level (low level)
KN!WP901 B.6A(149)/11-23-92/F1
--
Table B-6-1
(Page 3 of 3)
-
Acceptance Limits
Method 8280 criteria
RSD <15%
±_30% of predicted response
- - ------
Corrective Actions Documentation
System maintenance GC/MS project file
Recalibration
Repeat daily check and recalibrate
if necessary
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ethene by GC/FID. An initial calibration will be prepared for each day's analysis. The linear least
squares fit of the standard injections with equal weighting of the data must have a correlation
coefficient of greater than or equal to 0.99. A check standard consisting of the mid level standard
will be analyzed with every 10th sample. This check must be within 20% of the expected level
based on the calibration curve.
The GC/MS will be tuned using bromofluorobenzene (13Fl3) following the standard EPA criteria
listed in Method TO-14.
At least four levels of standards prepared by injecting various volumes of a standard prepared by a
commercial supplier of gas phase standards will be used to calibrate for carbon dioxide and oxygen
by GC/TCD. If high levels of methane are found in the sample, the analysis for methane may be
perfom1ed on the TCD. An initial calibration will be prepared for each day's analysis. The linear
least squares fit of the standard injections with equal weighting for all data must have a correlation
coefficient of greater than or equal to 0.99. A check standard consisting of the mid level standard
will be analyzed with every 10th sample. This check standard must be within +/-20% of the
expected level based on the calibration curve. Detennination of fixed gases by GC/FID or GC/TCD
does not use a mass spectrometer , thus there is no need for tuning.
B.6.3 Field Calibration Procedures for GEM-500
Field Calibration is menu-guided and can be completed in about ten minutes. The pump does not
have to be running to pass calibration gas through instrument. Using the pump will consume more
gas than necessary. The GEM-500 contains a calibration map which is accessed by its
microprocessor for baseline reference data. This reference data was programmed into the GEM-500
during the factory calibration using various gas mixtures in an environmental chamber. At any time,
the GEM-500 can be reset by returning to the "factory settings". This clears the GEM-500 of any
user calibration settings and restores the GEM-500 to its original factory calibration.
Factory calibration has been designed to give the best possible results over a wide range of
conditions. However, the instrument's accuracy can be improved in specific operating ranges by
performing a "field calibration". Most field instruments are calibrated or adjusted prior to taking a
series of gas or pressure readings. They may also be checked for calibration during the reading and
after readings are taken in order to verify the accuracy of the data collected.
B-16
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It is important to field calibrate the GEM-500 on-site after the instrument has stabilized at working
temperature. For this reason, a GEM-500 that was calibrated in the cool of the morning may not
read as accurately at the hottest part of the day. Field calibration procedures for methane, oxygen
and carbon dioxide arc described below.
Hydrogen sulfide will recorded using a electrochemical gas pod. The pods are connected directly
to the GEM-500 for direct reading. Factory calibrations for the GEM-500 will be used for hydrogen
sulfide during this study.
B.6.3.1 Equipment
To perform a field calibration, the following items are required.
I. Cylinder of methane and carbon dioxide span gas
2. Cylinder of 4/96 (4% 02 and 96% N2) calibration gas
3. Pressure regulators for the above cylinders capable of regulating in the range of 0-5 psig fitted
with connectors suitable for 1/4" Tygon tubing.
4. Regulator, which is set to deliver the required flow, or a regulator and flowmeter capable of
delivering 300-500 cc per minute at 2-5 psig. (See Figure B-6-1)
5. Interconnecting lengths of 1/4" Tygon tubing.
The connections must be gas tight and secure. The calibration equipment set up is shown in Figure
B-6-1.
B.6.3.2 Setting Up the Equipment
As described and shown in the Equipment Section, begin assembly of the GEM-500 .
I. Connect calibration gas cylinder to the pressure regulator.
2. Connect sample input line.
3. Connect second 24" of 1/4" Tygon tubing to the exhaust nozzle of the GEM-500. Direct exhaust
away from you and out of the immediate area.
4. Turn the calibration gas cylinder valve two turns.
B-17
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Pressure/
Flow Regulator
Sample Line
..k.--....... Tygon Tubing
Calibration Gas
Canister
Gas Flow
Pressure Regulator
Sample Line
.Jl!II-....... Tygon Tubing
Calibration Gas Flow Meter
Canister
fRi,tlonal Storch and Ch•mlco/ Company
►
Exhaust
Tygon Tubing
Gas Flow ►
FIGURE B-6-1
Exhaust
Tygon Tubing
Field Calibration Schematic
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5. I fusing a LANDTEC regulator, no flow meter is required. Turn off cylinder valve.
6. If not using the LANDTEC regulator, adjust the regulator discharge pressure to 2 psig and the
flow meter to 300 cc per minute. Pinch the gas supply hose that will attach to the GEM-500. The
regulator discharge pressure should not climb to over 5 psig. Turn off the cylinder valve.
Note: This procedure will be duplicated for the second span gas when Oxygen is
calibrated. The Oxygen/Carbon Dioxide calibration gas cylinder will be substituted for
the Methane/Carbon Dioxide calibration gas.
B.6.3.3 Calibration Gases
Zero Gases: Air to zero methane (in non-methane environment)
4.5% oxygen balance nitrogen to zero methane in methane environment
Span Gases: 15% methane, 15% carbon dioxide, balance nitrogen (span gas)
4.5% oxygen, balance nitrogen (span gas)
B.6.3.4 Calibration Method
I. Zero methane
2. Connect methane/carbon dioxide mixture
3. Span methane and carbon dioxide
4. Zero oxygen using methane/carbon dioxide mixture
5. Disconnect methane/carbon dioxide mixture
6. Connect 4.5% oxygen mixture
7. Span oxygen
8. Disconnect oxygen mixture
B.6.4 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
B-18
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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 arc adversely affected, the results of the evaluation will be documented and the
appropriate personnel notified.
B-19
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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.
2.
4.
5.
6.
Holding times and the amount of sample available will be reviewed and the analyses
prioritized.
Analyses will be performed within holding times according to accepted procedures.
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
B.7.2.1 Soil
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 part of the
CLP for organic analyses. Procedures instituted by CLP will be adhered to during appropriate
organic analyses pertaining to the Natural Degradation Trcatability Study at the Cedar Springs
Road site. The analyses for organic compounds will be based on the EPA OLMO3.0 SOW.
B-20
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Laboratory Resources
l 00 Hollister Road
Teterboro, NJ 07608-111 l
B.7.2.2 Soil Gas
The analyses for volatile organic compounds and fixed gases in soil gas will be performed by
Lancaster Laboratories. The instrumental techniques employed will be gas chromatograph with
mass spectrometer (GC/MS) for volatile ogranics, gas chromatograph with flame ionization detector
GC/FID for methane, ethane and cthenc, and gas chromatograph with thennal conductivity detector
(GC/TCD) for oxygen and carbon dioxide. Volatile organic compounds will be analyzed following
the procedures in EPA Method TO-14. Fixed gases: methane, ethane, ethene, oxygen and carbon
dioxide will be determined following the procedures in ASTM-O1496 with modification of the
specific columns used for the analysis and the use of flame ionization detector for the hydrocarbon
fixed gases.
The address for Lancaster Laboratories is as follows:
Lancaster Laboratories
2425 New Holland Pike
PO Box 12425
Lancaster, Pennsylvania 17605-2425
B.7.3 Metals
The analyses for T AL 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.
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:
I.
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 arc described in Chapter B. l 3.0. 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.
B-22
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B.9.0 Quality Control Procedures
B.9.1 Field Quality Control Procedures
To confinn 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 TAL 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 IO percent of the samples collected.
One equipment blank will be prepared for every 20 samples (including duplicates) to characterize
both field and laboratory cleaning procedures.
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
B.9.2.1 Volatile Organics in Soil
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 perfonnance on bromofluorobenzene (13Fl3) 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 ¾R 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 organic
B-23
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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.9.2.2 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 san1ples. 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.
B.9.2.3 Soil Gas Parameters
Samples of soil gas collected in SUMMA canisters will be analyzed for volatile ogranics compounds
(VOCs) according to the procedures listed in EPA method TO-14 for the analysis using GS/MS. An
initial calibration curve is prepared using commercially prepared mixtures of VOCs which are
diluted to three different levels. Three internal standards are added to each calibration as well as the
sample analysis. The GC/MS tune will be verified daily using·bromof1uorobenzene (BFB) using the
criteria listed in the method.
B-24
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At least one method blank will be analyzed for each analytical batch of samples (twenty samples).
The method blank must not contain the target compounds at a level above the limit of quantiation.
A laboratory control sample (LCS) consisting of a set of six target compounds will be analyzed for
each analytical batch. Percent recovery will be determined for these compounds. Should the LCS
fall outside the control limits, the calibration of the instrument will be checked. If the calibration
is still within acceptable limits, the LCS may be reanalyzed or prepared again. If the LCS still is not
within control limits the analytical system will be checked and the calibration prepared again.
Samples of soil gas will also be analyzed for fixed gases according to procedures in ASTM-D1496.
Carbon dioxide and oxygen will be determined using a thermal conductivity detector (TCD), and
methane, ethane and ethenc will be detem1ined using a flame ionization detector (FID). The TCD
is selected for carbon dioxide and oxygen because it can detect both. The FID is selected for
methane, ethane and ethcne because it is more sensitive to the hydrocarbon fixed gases. In the event
that high levels of methane arc detected, the TCD may be used for the analysis of methane.
At least four levels of standards of the fixed gases prepared by commercial suppliers will be used
to calibrate the gas chromatograph. The data from the calibration will be used to prepare linear least
squares fit of the data using equal weighting for all data. The linear calibration will be used to
calculate sample concentration. The calibration will be checked periodically during the analysis of
samples using a mid level standard. This standard must agree with the expected concentration. Due
to the nature of the analysis, neither surrogate nor internal standards will be used in the analysis.
A method blank consisting of nitrogen gas will be analyzed with each set of twenty samples. The
method blank must not contain the target compounds at a level above the limit of quantitation
A laboratory control sample (LCS) will also be analyzed for each analytical batch. Percent recovery
will be determined for these compounds. Should the LCS fall outside the control limits, the
calibration of the instrument will be checked. If the calibration is still within acceptable limits, the
LCS may be reanalyzed or prepared again. If the LCS still is not within control limits the analytical
system will be checked and the calibration prepared again along with reanalysis of the samples.
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B. l 0.0 Perfonnance 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 conclusions 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 arc kept on file for reference if equipment needs repair. Troubleshooting
sections of manuals arc 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 document
instrument problems and steps taken to resolve problems. It is the responsibility of the person
perfonning the maintenance activity or repair to provide documentation in the instrument log. These
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- - -- - -- - - -- - -- - -- - -
Table B-11-1
Summary of Periodic Calibration Requirements
Instrument Calibration Standards/Frequency Acceptance Limits Corrective Actions
Analytical balance Daily: Sensitivity (with a Class Acceptance criteria based on Adjust sensitivity
"S" 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 ±0.5'C Discard thermometer
temperature baths at two
temperatures against precision
thermometers certified by 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
KN/vVP9018.111 (149)/11-23-92/F1
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records are kept with the instrument or filed in the respective instrument 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 (l) the type and frequency of quality control
checks performed by Laboratory Resources and Lancaster Laboratories, (2) the procedures
Laboratory Resources and Lancaster Laboratories will use to determine the precision and accuracy
targets listed in Chapter B.3.0.
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 8.3.0 and 8.13.0.
B.12.2 Trip (Travel) Blank Analyses
B.12.2.1 Soil
Volatile organics samples arc susceptible to contamination by diffusion of organic contaminants
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.12.2.2 Soil Gas
Trip blanks will be prepared by the laboratory consisting of an evacuated SUMMA canister. This
canister will be sent to the field, stored with the other canisters used for sampling and returned to the I laboratory. Upon return, the canister is filled with humidified nitrogen air and analyzed as a sample.
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B.12.3 Method Blank Analyses
B.12.3.1 Soil
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 blank verifies that method
interferences caused by contaminants in solvents, reagents, glassware, and other sample processing
hardware are known and minimized.
B.12.3.2 Soil Gas
A method blank is a volume of gas which is carried through the complete procedure. Zero grade
nitrogen will be used for the fixed gases and humidified zero grade air will be used for the VOCs
by TO-14.
For determination ofVOCs by TO-14, a typical volume of air will be cryogenically concentrated,
the internal standards added, and the method blank analyzed as a normal sample. For the fixed gases
analysis,.a standard volume of nitrogen will be analyzed.
A method blank is pcrfom1ed with each batch of samples, or daily, which ever comes first. Analysis
of the blank must indicate that all analytes are not present above the limit of quantiation listed in
Section B.3.0.
B.12.4 Reagent Blank Analyses
B.12.4.1 Soil
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 arc present at levels that would affect sample results.
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B.12.4.2 Soil Gas
Since no specific reagents arc used in the analysis, this analysis is equivalent to the method blank
described above.
B.12.5 Duplicate Sample Analyses
B.12.5.1 Soil
Duplicate analyses are performed to evaluate the precision of an analysis. Results of the duplicate
analyses are used to detem1ine the RPO between replicate samples. Duplicate samples are analyzed
at a frequency of l O percent for inorganic and general chemistry tests. Obtaining duplicate sample
in soil typically requires homogenization of the sample aliquot prior to filling the sample container.
In order to prevent loss of volatile organics constituents to preserve the integrity of the sample, VOA
samples are always taken from discrete locations or intervals without composting or mixing.
Inherently due to soil heterogeneity, there will always be uncertainty to the validity of a soil sample
duplicate which is subsequently analyzed for VOA, especially when the soil samples are collected
from separate discrete intervals. With this understanding, the duplicate for this project will comprise
of opening the split spoon, bisecting the soil in half along the longitudinal direction of the split
spoon, and placing each half of the soil sample in a sample jar for analyses.
B.12.5.2 Soil Gas
Duplicate samples are analyzed at a frequency of one per analytical batch of samples (at minimum
one per twenty). The duplicate samples are two aliquots taken from the same SUMMA canister.
This analysis will be used to evaluate the precision of the analysis. The duplicate analyses must
agree within 25% relative percent difference (RPO) for any target compounds present at greater than
five times the quantiation limit.
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B.12.6 Check Standard Analyses
B.12.6.1 Soil
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 IO 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.12.6.2 Soil Gas
A midpoint calibration standard is analyzed at least daily to evaluate the instrument calibration.
For the T0-14 analysis, the response factor calculated for this check standard must be within+/-
25% of the average response factor calculated for the initial calibration standards. This response
factor is used to calculate sample concentrations.
For fixed gas analysis, the response for the check standard must be within+/-20% of the value
predicted by the calibration curve. The calibration check standard will be injected with every tenth
sample.
B.12. 7 Surrogate Standard Analyses
B.12.7.1 Soil
Surrogate standard determinations are performed on all san1ples and blanks for GC/MS analyses and
for most GC analyses. All samples and blanks arc fortified with surrogate spiking compounds before
purging or extraction to monitor preparation and analysis of samples.
B.12.7.2 Soil Gas
Surrogate standard are not used in the analysis of air samples because of the problems associated to
adding these standards to each sample independent of the internal standards for the analysis of VOCs
by T0-14. The use of surrogate standards is not appropriate for the analysis of fixed gases as
described in ASTM-1946.
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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 ¾R 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 RPO between the MS/MSD samples. Matrix spike duplicates arc prepared and
analyzed with each group of20 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 arc 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 san1ples, o?a·purified
solid matrix for soil/sediment samples that is spiked with paran1etcrs of interest and carried through
the entire analytical procedure. Analysis of this san1ple with acceptable recoveries of spike materials
demonstrates that the laboratory techniques for this method are in control. This sample is generally
analyzed with MS/MSDs on those sample matrices that are anticipated to cause analytical difficulties
due to matrix interferences. If the MS/MSD pair shows poor recoveries due to interferences, yet the
blank spike sample is acceptable, this is strong evidence that the method has been performed
correctly by the laboratory for these samples, but matrix interferences have affected the results.
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B.12.12 Laboratory Control Samples
B.12.12.1 Soil
A laboratory control sample (LCS) is a blank spike analyzed for inorganic or general chemistry
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.12.12.2 Soil Gas
A laboratory control samples (LCS) is a spike of the blank medium carried through the entire
analytical procedure.
For the VOC determination by TO-14 a LCS is analyzed daily or with each analytical batch of
samples. This consists of the blank zero air blended with a 2 ppm standard containing the following
compounds: benzene, 1,4-dichlorobenzene, ethyl benzene, I, I, I-trichloroethane, trichloroethene, and
vinyl chloride. These compounds are blended to a final concentration of approximately IO ppb. The
recovery of the LCS must be within 75 and 125% of the expected value. This standard is carried
through the analytical procedure from the concentration of the volume of air to the determination
by gas chromatography with a mass selective detector.
For the fixed gases, a LCS is prepared from a standard of the fixed gases. This standard is injected
in the GC system and analyzed as a regular sample. The recovery of this LCS must be between 80
and 120% of the expected concentration of the LCS.
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B.12.13 Standard Addition Spike Analyses
B.12.13.1 Soil
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 san1plc digestate during graphite furnace and cold vapor atomic
absorption analyses.
B.12.13.2 SoilGas
Standard Addition analysis will not be performed for the analysis of air samples.
B.12.14 Internal Standard Spike Analyses
B.12.14.1 Soil
This is an analyse 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 perforniance, but it may also be
an integral part of the analytical method in a non-QC sense, e.g., to nornrnlize data for quantitation
purposes. Internal standards arc spiked into all GC/MS standards, blanks, and samples.
B.12.14.2 Soil Gas
An internal standard is added to the cryogenic concentrator immediately before an air sample
analyzed for VOCs by EPA method TO-I 4. This standard consists of chlorobromomethane, 1,4-
difluorobenzene, and chlorobenzene d5. The peak area for the internal standard must be within+/-
50% of the area for the internal standard analyzed with the initial or continuing calibration standard.
For the analysis of fixed gases an internal standard will not be used.
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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.
B.13.1 Soil
The specific methods used to generate precision and accuracy data arc 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 (¾R)
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
¾R = 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 13; arc the concentrations of constituents A and
B.
IA; -B)
(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:
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-------------------
Table B-13-1
QC Samples Used to Generate Precision and Accuracy
QC Sample Purpose Concentration Level Method References
Matrix spike/matrix spike Precision and accuracy Low-level' 8240, 8270, 608, 8080,
duplicate 8010/8020, CLP SOW 2/88, 504,
8090
Mid-level' 415.1, 9060
High-level' 610, 8310
Matrix spike Accuracy Low-level 7470, 7471, CLP ILM01.0 for Hg
and cyanide
Mid-level General chemistry methods', all
methods for graphite furnace
atomic absorption and ICP
Duplicate Precision N/A All inorganic methods and
general chemistry methods
TCLP matrix spike Accuracy Low-to high-level' 1311,8240,8270,8080,8150,
6010, 7470, 7471
Surrogate spike Accuracy Low-level 8240, CLP SOW 2/88 for VOA
Mid-level 8270, CLP SOW 2/88 for BNA
High-level 8080, CLP SOW 2/88 for Pest.,
8010/8020, 8090
Laboratory control sample Accuracy Mid-level CLP ILM01.0
'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.
'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 limit to the TCLP
regulatory limit.
KNN'IP9018.131(149)111-23-92/F1
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Upper Control Limit= p+ 3s
Lower Control Limit= p-3s
Upper Warning Limit= p+2s
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 analytc present in the sample cannot be accurately measured.
PQLs and MDLs. 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 arc reported using EPA PQLs, i.e., a detection limit quantity is reported
as a value flagged with "U." This less than value docs 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 arc below required PQLs, but can still be quantified, are flagged
with a "J" as "estimated concentrations." The laboratory verifies the EPA PQLs by analysis ofa 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 analytc 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 detem1ined by multiplying the appropriate one-sided 99 percent I-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 I-statistic is obtained from
the following table:
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No. of samples: I-statistic
3 6.96
4 4.54
5 3.75
6 3.36
7 3.14
8 3.00
9 2.90
10 2.82
The MDL shall be estimated as follows:
1. The concentration value that corresponds to one of the following shall be determined:
a. an instrument signal/noise ratio within the range of2.5 to 5.0, or
b. the region of the standard curve where there is a significant change in sensitivity
(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 ;.,
3. The standard deviation (s) for each analyte shall be determined as follows:
4. The MDL for each analyte shall be determined as follows:
where t(,-l .•• _991 is the one-sided I-statistic appropriate for the number of samples
used to determine (s), at the 99 percent level.
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B.13.2 SoilGas
The method blank will be evaluated to ensure the analytical system is free of the target compounds.
The laboratory control sample will be evaluated to ensure that the analytical system is operating
within control limits listed in section B.12.12.
The laboratory duplicate analysis is used to evaluate the precision of the analysis. If the analysis of
a laboratory duplicates are not within the control limits, the analysis will be repeated. Control limits
are listed in section B.12.5. If the analysis is still outside these limits, the LCS will be analyzed in
duplicate to ensure the sampling system is performing with acceptable precision.
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B.14.0 Nonconformance/Corrective Action Procedures
Nonconforming items and activities arc those that do not meet the Project requirements, procurement
document criteria, or approved work procedures. Nonconfom1ances may be detected and identified
by:
I. Project staff -During the perfomiance of field investigation and testing, supervision
of subcontractors, and perfom1ance of audits and verification of numerical analyses
2. Laboratorv staff -During the preparation for and performance of laboratory testing,
calibration of equipment, and QC activities
3. Quality Assurance Staff -During the performance of audits.
Each nonconformance will be documented by the person identifying or originating it. For this
purpose, a Nonconfomiance 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.
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
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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 ·documentation. 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:
I. 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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APPENDIX C
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . m
List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . m
C .1. 0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1
C.1.1 Scope of Work ....................................... C-1
C.1.2 Health and Safety Policy ................................ C-1
C.1.3 References ......................................... C-2
C.2.0 Respons1b1ht1es ............................................ C-2
C.2.1 Project Manager and Project Coordinator ..................... C-2
C.2.2 Project Director ....................................... C-3
C.2.3 Project Health and Safety Officer ........................... C-3
C.2.4 Project Environmental Engineer . . . . . ..................... C-4
C. 2. 5 Field Operations Coordinator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-4
C.2.6 All Other Project Personnel .............................. C-4
C.3.0 Hazard Assessment ......................................... C-5
C.3.1 Chemical Hazards ..................................... C-5
C.3.2 Exposure Standards .................................... C-5
C.3.3 Physical Hazards ..................................... C-6
C.4.0 Safety Program ............................................ C-7
C .4.1 General Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-7
C.4.2 Drilling Equipment Operations ............................ C-9
C.4.2.1 General Drilling Practices ......................... C-9
C.4.2.2 Catline Operations .............................. C-9
C.4.2.3 Pipe Handling ................................ C-10
C.4.3 Heat and Cold Illness Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . C-10
C.4.3.1 Heat Stress .................................. C-10
C.4.3.2 Cold Stress .................................. C-12
C.4.4 Hearing Conservation ................................. C-13
C .4. 5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-14
C.4.6 Sanitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-14
C.5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-15
C.5.1 Respirator Program ................................... C-15
C.5.2 Levels of Protection .................................. C-16
C.5.2.1 Level D Protection ............................. C-16
C.5.2.2 Level C Protection .. : .......................... C-17
C.6.0 Site Control ............................................. C-18
C.6.1 Authorization to Enter ................................. C-18
C.6.2 Hazard Briefing ..................................... C-18
C:\PROJECTS\CDRSPRNG\OU4NDTS\HSAP\HASP.TOC
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Table of Contents (Continued)
C.6.3 Pocumentation of Certification ........................... C-18
C.6.4 Entry Log . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-19
C.6.5 Contamination Control Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-19
C.6.6 Entry Requirements .................................. C-19
C.6.7 Emergency Entry and Exit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-20
C.7.0 Decontamination .......................................... C-20
C.7.1 Personnel Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-20
C.7.2 Equipment Decontamination ............................. C-21
C.8.0 Site Monitoring ........................................... C-21
C.8.1 Air Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-21
C.8.2 Noise Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-21
C.8.3 Monitoring Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-22
C.8.4 Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-22
C.9.0 Employee Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-23
C.10.0 Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-23
C.11.0 Emergency Response Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-24
C.11.1 Employee Injury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-24
C.11.1.1 Chemical Inhalation . . . . . . . . . . . . . . . . . . . . . . C-25
C.11.1.2 Eye Irritation ........................... C-25
C.11.1.3 Skin Contact . . . . . . . . . . . . . . . . . . . . . . . . . . . C-25
C.11.1.4 Personal Injury Accident . . . . . . . . . . . . . . . . . . . C-26
C.11.2 Emergency Medical Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-26
C.11.3 Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-26
C.11.4 Emergency Information ................................ C-27
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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-5
C-6
List of Figures __________________ _
Figure
C-1 Hospital Route Map
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Title
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Follows Page
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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 ofNSCC 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 ofNSCC'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. Department
of Labor/OSHA.
• Title 29 of the Code of Federal Regulations, (CFR) Part 1910.134, U.S. Department
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 III -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. WI -Confined Spaces, Industrial
NSC SOP Manual Item No. W6 -Emergency Response Operations
NSC SOP Manual Item No. WI I -Work-Related IIJnesses 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 are
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properly investigated. He will review on-site investigation of any accidents involving lost time,
hospitalization, or fatalities. Mr. Paradowski's work telephone number is [phone]
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.2.5 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.2.6 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
• Unexpected or uncontrolled release of chemical substances
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• 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 ofa sufficient degree to result in accidental injury, impair self rescuer, or
substantially reduce work efficiency.
Threshold Limit Values (TL Vs) 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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Compound
1, 1,2-T richloroethane
1,2-Dichloroethane
2-Butanone
Acetone
Bromodichloromethane
Chloroform
Delta BHC
Dibromochloromethane
Tetrachloroethene
Toluene
Total Xylenes
Trichloroethene
Vinyl Chloride
Table 3-1
Ranges and Frequency of Detection
of Organic Compounds Found in Soil
Phase I and II OU3 RI
Range (ppb) Frequency of Detection
11-17 2
2-1600000 42
3-42 30
22-4000 40
1-220 7
2-900 17
22 I
3-31 5
2 2
1-3100 12
I I
3 1
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 ACGJH and federal OSHA as a I 5-
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
I, 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
*PEL (ppm)
350
10
200
750
NIA
IO
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 1
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 other 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.
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• The cathead area must be kept free of obstructions and entanglements.
• The operator shall 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 I· measures are mandatory if any site worker has a heart rate in excess of 115 beats per minute.
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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.
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• On-site drinking water will be kept cool (50 to 60 °F) to encourage personnel to
drink frequently.
• 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
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.
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Heat Stroke
C.4.3.2 Cold Stress
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
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
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• 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.
• If a site worker's underclothing becomes 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.
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Noise monitoring shall be conducted if deeded necessary by the Project Health and Safety
Officer. Monitoring will be conducted using an ANSI Type 1 or Type 2 sound level meter.
Dosimetry may be conducted at the discretion of the Project Health and Safety Officer.
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 ..
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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
clothing.
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.
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• 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.
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.
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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
• 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 permitted to downgrade levels of PPE without authorization of the Health and
Safety Officer.
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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
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.
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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
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.
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C.6.7 Emergency Entry and Exit
During emergencies, decontamination will be conducted to the extent that it is possible without
endangering personnel.
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 I
Station 2
Station 3
Personnel leaving the exclusion zone shall
remove the gross contamination from their
outer clothing and boots at Station I.
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.
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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
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
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monitoring 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.
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.
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C.9.0 Employee Training
All on-site project personnel shall have completed at least 40 hours of hazardous waste
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
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• Audiogram
• Electrocardiogram for persons older than 35 years of age, or if indicated during
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.
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C .11.1.4 Personal Injury Accident
In the event of a personal injury accident, the Field Operations Coordinator shall assess the
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\CDRSPRNG\OU4NDTS\HSAP\OU4HSP.AA C-26
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;
--•----•-w --•
··-.• ~ ;-::..,J
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-/-:, .:c' C)~ .-...... • ----, . ,,-:---· ·-.
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LEGEND• .. EMERGENCY ROUTE
:_ __ -PROPERTY LINE (APPROX.)
SCALE p-
--

I

0 1/2 MILE
Figure C-1
HOSPITAL ROUTE MAP
NATIONAL STARCH a CHEMICAL CORP
CEDAR SPRINGS RD PLANT
SALISBURY, NORTH CAROUNA
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C.11.4 Emergency Information
Key Personnel
Plant Manager -
Project Director -
Project Health and Safety Officer -
Project Environmental Engineer -
Field Operations Coordinator -
C:IPROJECTSICDRSPRNGIOU4NDTSIHSAPIOU4HSP.AA
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-27
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Blue Planet Technologies
BIOreport™ Proposal
1,2 Dichloroethane Contaminated Site
Proposal #1060-B
Prepared for:
Abu Alam
National Starch & Chemical Company
10 Findeme Ave.
Bridgewater, NJ 08807
Blue Planet Tecbnologie5
32384 Edward Street
Madison Heights, Michigan 48071
[phone]
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810 589 2b52 TO 19083551741 P . .JJ
National Starch & Chemical, Company Blue Planet Techoologic., Proposal# 1060-B
March 27. 1996
Introduction
Based on a phone conversation between Abu Alam of National Starch & Chemical
Company and Jody Albertson on January 16, 1996, Blue Planet Technologies submitted a
proposal for performing a B!Oreport™ of soil samples taken from a site contaminated with
1,2 Dichloroethane (I ,2-DCA). Per a fax from Abu Alam on March 27, I 996,
adjustments to the original proposal have been made.
Anaerobic degradation of higher-chlorinated compounds may produce 1,2-DCA.
Generally, 1,2-DCA is slightly soluble in water, adsorbs poorly to soils, is stable in water,
and resistant to oxidation. Consequently, these contaminants migrate through the vadose
zone and contaminate the aquifer. Many chlorinated solvents can be transformed by
chemical and biological processes in soils to form a variety of other chlorinated aliphatic
hydrocarbons such as methylene chloride, vinyl chloride, 1, 1-dichloroethane and
chloroethane. Generally microorganisms cannot obtain energy from the transformation of
these solvents. Transformation is brought about by cometabolism, a process in which
another compound must serve as the primary source of metabolic energy.
Objective/Scope of Work
Blue Planet Technologies' objective in this project is to provide National Starch &
Chemical Company with a BIOreport™ that will be useful in predicting and/or confirming
successful application of bioremediation as a remedial technology to the site under
consideration. The basis for making this assessment will involve a study of the indigenous
microflora's ability to biodegrade the site contaminants in the laboratory, under conditions
similar to those found at the site. Additionally, we may determine the effects of pH
modifications, added oxygen, nutrients, and co-metabolites on the rate of biodegradation.
In order to accomplish these objectives, the following studies will be conducted for each
soil sample submitted:
2
Th.i, information was developed •xclu.ivoly for National Starch 1k. Chemical Coml""'Y and is the property of mue
Plnn•t T echnologics. Reproduction or di•trihution i:, by pcnnission of Blue Plnnct T c,;hnologics only.
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P.0--l
National Starch & Chemical, Company Blue Planet Technologi .. Propo,al # 1060-B
M~rch 27, 1996
Analytical Testing. The chemical and physical properties of the site samples such as pH
and the concentrations of all chlorinated compounds of concern will be determined. All
analytical measurements will be performed using USEPA approved methods or other
conventional methods, observing all associated QA/QC. EPA Method 8260 will be used
for 1,2-DCA and all other VOC's of concern. Throughout the course of this
investigation, samples will be handled and stored in accordance with EPA approved
methodologies. If the contaminant is found to be below state regulatory requirements
Blue Planet Technologies will contact National Starch & Chemical Company immediately.
1,2 DCA Degrading Bacterial Enumerations. The method used is a modification of the
most probable number method (MPN) described in Soil Sampling and Methods of
Analysis, Canadian Society of Soil Science, 1993. This protocol employs the concept of
dilution to extinction in order to estimate the number of microorganisms in .the sample.
This method is utilized to determine the numbers of contaminant degrading bacteria by
using a minimal salt media with the contaminant as the sole carbon source. Thus, only
microorganisms capable of utilizing the 1,2-DCA as a food source will proliferate. This
study may be run for each co-metabolite (including lactate, acetate, formate, toluene,
methanol, methane, and phenol) at the customer's request.
Nutrient Panel. An analysis may be performed to determine if the levels of nutrients
essential for bacterial proliferation fall within published ratios. Specifically, nutrients
determined will include Kjedahl nitrogen, ammonium nitrogen, orthophosphate, and total
organic carbon (TOC).
Confirmation of Biodegradation. Microcosm studies will be conducted at site
determined temperatures under aerobic and anaerobic conditions in order to, as closely as
possible, represent prevailing site conditions. DO2 levels at 1-2 ppm can be obtained if
necessary, during this study. The disappearance of 1,2-DCA as compared to an abiotic
control will be monitored in order to positively confirm that the indigenous bacteria are
capable of facilitating biodegradation of these contaminants under site representative
conditions.
3
This infonnation was developed exclusively foi Notional Swch & Chemical Comp1111y and is lhc property of Blue
Planet Tc'Chnologics. Reproduction or distribution is by pennis,inn ofl:llue Planet Technologie, only.
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810 589 2to52 TO 1 ·3063551 7 ~ l P.05
N•tional Starch & Chemi<•h Comuany
March 27. I 996 Blue Planet Technolo~~•• Propos•I # 1060-B
EITect of Methane on 1,2 DCA Biodegradation. It has been reported in the literature
and other cases that indigenous methanotrophic bacteria are capable of facilitating the
cometabolic transformation of I ,2 DCA upon stimulation with the addition of methane as
a cometabolite. We propose to perfonn the above microcosm study in the presence of
methane. This is a means to accelerate 1.2 DCA biodegradation in a microcosm study
using a possible in situ treatment method.
I Kinetics of Contaminant Biodegradation. Experiments utilizing microcosms will be
performed to determine the biodegradation rate of the contaminant under site
representative conditions. Studies will be conducted under aerobic and anaerobic
conditions. Data will be presented in graphical form, plotting concentration of
contaminant (corrected for abiotic losses) versus time. This data will then be fitted to a
mono-exponential decay function in order to determine the first-order rate constant for the
biodegradation of contaminant. The residual concentration of each contaminant will be
estimated from these plots where the curve becomes asymptotic to the time axis. If the
rates are too slow such that they do not become asymptotic within the duration of the
experiment, a biochemical assay of microcultures will be used to estimate the residual
concentrations.
Range of Conditions. This study will determine the effects of added oxygen;
supplemental nutrients, various co-metabolites, moisture addition, and pH modification on
the biodegradation rate of the contaminant. Data will be presented in graphical fonn,
similar to data presented in the Biodegradation Kinetics Study. This information may have
a significant impact on engineering design of the remedial system, overall project cost, and
closure requirements. Inherent in this study is the determination of the optimal pH,
moisture, oxygen concentrations for bioremediation.
1,2 DCA Partitioning. This study involves analyses of the contaminant in the liquid,
insoluble. and vapor phases using EPA Method 8260. All analytical measurements will be
perfonned using USEPA approved methods or other conventional methods, observing all
associated QA/QC. From the data generated, DCA partitioning can be determined.
4
11,is i11foII1UJtion was developed ciwlusively for Nutiolllll Starch & Ch~""1 C'.ompany and ii, the property ofllluc
Planet Technologic:,. Reproduction or di>lribution is by pomw,.;on of Blue PllilU:1 Ts-chnologies only.
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National St-rch & Chemical~ Company
March 27, 1996
810 509 2552 TO 1·::053551741 P.86
Blue Planet Technolo!!in Proposal# 1060-B
Cost and Delivery
The times to complete the various studies described in this proposal are listed in the
following schedule. These times assume receipt of sample(s) and a signed copy of the
em;losed Laboratory Services Agreement. The cost of this effort is quoted using the
following schedule:
Study Time of Cort per Sample
Delivery
Analytical Testi112 l wc,:k $95
1,2-DCA and Co-Mct.lbolitc Dcgr~ding Bacterial 2 weeks $75 + $50/co-mctabolitc
Enumerations
Nulricm Panel 2 weeks $120
Confim,alion ofBiodegradation (aerobic & 2-12 weeks $1,600
anaerobic)
Effect of Methane on 1 2 DCA Biodeirradation $975
Kinetics of Biode.,,.adation (aerobic & anaerobic) 2-12 weeks $2,400
Ranee of Conditions 2-12 weeks $3,000
1.2-DCA Partitionin2 l week $350
Above charges include sample containers and non-expre,s delivery (ground). for you,·
convenience, complete sampling kits may be provided, and shipped eKpress via an
overnight carrier. An additional charge of $40 will be applied if this service is desired.
Upon completion of the investigation. a final report will be submitted. Frequent verbal
progress reports will also be made during the course of the investigation.
ff additional studies beyond the scope of this work is required later, the cost can be
negotiated at such time. Cost and Delivery quoted in this proposal are firm for 90 days.
after which Blue Planet Technologies reserves the right to revise them_
If you would require any additional information on any aspect of this proposal, please do
not hesitate to contact Jody Albertson, Technical Support Representative, at (810) 597-
1428.
Very truly yours,
Timothy J. Geddes
Staff Scientist
Cheryl Franks-Denman
Director of Business Development
5
Thi, infumu,tiun-, developed excb1.,ively for Nationol ~'torch II< Chemical Company and is the proJ><r1.Y of Blue
l'lnuet Technologies. Reproduction or cli,1ribution is by pc:mu:,oiun of Dlue Planet Technologies only.
1·
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i•l~'r' 82 . 3b .Jg; .?8 FR BLUE PLHl'JET TECH 810 569 2b52 TO l~C53551?~1 P.J,
National Starch & Chemicals Campany Blue Planet Technnlngi .. Propo~al # 1060-B
March 27, 1996
References
I. Most Probable Number Enumeration, Standard Methods for the Examination of Water
and Waste Water, APHA. AWWA. WEF, 18 ed., 1992.
6
This infonnalion Wllll developed exclu.•ively for National Staidl & Chemical Compony 11ml ii, the property of l;llue
Pbmt::t Technologies. Reproduction or distribo.tion is by ~s..-ri.on of Blue !'lanet Technologies only.
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P.88
National Starch & Chemical• Company
March 27. 1996 Blue Pla11et Tccb11olngiea Prono,al # 1060-B
LABORATORY SERVICES AGREEMENT
TI-ITS AGREEMENT by and between National Starch & Chemical Company, hereafter
referred to as the "Client", and Blue Planet Technologies, hereafter referred.to as "BPT."
SCOPE OF SERVICES. The client hereby contracts with BPT to pcrfonn the following
described laboratory services, hereafter collectively referred as Scope of Services.
As stated in proposal.
BPT' s Proposal Number I 060-B is hereby incorporated into this agreement.
BPT's COMJ>ENSATlON. BPT will be paid for all services rendered on the following
basis:
As stated in proposal and #4 of Terms and Conditions.
TERMS AND CONDITIONS. BPT's Terms and Conditions of contract, as printed on
the following page hereof, shall apply to all work performed by BPT pursuant. to this
Agreement unless otherwise specifically agreed in writing.
ENTIRE AGREEMENT. The Client and BPT mutually agree that this Laboratory
Services Agreement constitutes the entire agreement of the parties, and that the Terms and
Conditions of the Agreement cannot be changed except in writing, executed by both
parties.
IN WITNESS WHEREOF, the parties hereto have made and executed this Agreement.
CLIENT: BLUE PLANET TECHNOLOGIES:
By:------------By: ___________ _
Title: -------------Title: ____________ _
Date:-------------Date:, _____________ _
7
nu• information wa., developed exclusively for Natio11al Slllrch & Chemical Cot11jllllly and ii, the property of 1:ilue
l'lt,nct Tc-chnologies. Reproduction or w.tribution;. by penni,,:,ion of Blue Planet lechnologico only.
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Nation.al Starch & Chemicals Comp;iny Blue PIAncl Technnlngi•• Pruoo,al # 1060-B
March 27, 1996
TERMS AND CONDITIONS
The fol1<1wing tenn.11 and conditions shall be i1 part of Ulue Plunet Tc.i;hnologic:~. (hc:n::.uilcr referred to as "BPT'')
contractual undertaking to perform lKboratory services, and BPT' s 3greement to pertOnn such aavices is l!Xprcssly
conditioilc:lt up011 dient'l:I 11s~ent to such Tenn:1 aml Conditions, notwitluhm<ling any additional or conflicting Tenns
and Conditions of t:lient which 31·e hereby ex:pr~ly objected to nn.d nrjci;lcd by BPT. Whac a cli~nt issues a
pwcha..<ie order to author17.e BPT's w1dertaking to perfonn labon1tory services. thAt undl!:11.uking will be governed by
the Tenns and Conditions of lb.is Agreement.
l. PERFQR.J,,,1A."J"CE BY BPT. BPI shall exercise due care in performing prnfe.,c:ional ~ice.q, but DPT mukc:t no
WtUTwity. exprt$8 or implied, with re~t to tffl.Y ~~ paformcd hereunder. BPT sh.111 not b~ liable for a11y
claim. damage. cost or expense (including attorney fees) or other 11ahility or lo.q::i not djrei;tly und ~lt:J.y cti~t.l
t,y the negligent ucl>, erruN ur umissiun:1 uf DPT. IN NO EVENT SHALL BPT BE LIABLE FOR ANY
INClDCNlAL OR CONSEQUENTIAL LOSS OR DAMAGE TO CLIENT IN CONNECTION WITH
PERFORMANCE OF SERVJCES HEREUNDER.
2. ADOmONAL SERVICES. bt the event Uuit Client reque,t:1 ndditionAl servic .. be pcrlimw.-d by BPT, "11 ,uch
additional services shall bi:: performed subject to these Tenns and Conditions.
3. SUBCONTRACTORS. BPT muy cnguge .uhc<,ntructuN un oclwl[ of Cli,:nt to P<,7fonn • portion of the sc,:viccs
to he provided by HPT herewider.
4. P/\ YMENT. BPT w..11 bill for Scr\lices rc:nd"-"T<.-tl tmd rcimbur:ut.blc costs incurred when the laboratory work is
completed, or on a monthly basis if the scope of services extends beyond one mooth. Ench invoice Rholl he: du~
fl.Ild payttbk with.in 15 UUy::i: of the pre::1cntuli.on of the invoice. Invoices OV(,,."'f 30 days past due will be charged
monthly interest .1t a rate of 15% per aruiwn on the W1pa.id balance or the hjghest lawful rate, whichever i:. le.-.."'.
DPT mt1y, utter 7 daya wtitte11 notice to Client, mI..Clfk"ld perfonno.nce: of ~iecii until ttll ~l Jue M([lounls :trc
paid.
S. TERMlNATlON. This Agreement may be terminated by either party hy giving 7 day• written notice. ln the
event of termination, BPT shall be pnid up to the effective date oftennination for a.ll services l"endered by it, and
,tll rcpurts un<l rrwtcriula pr"f'ored by nPT •hull =in tho prvpcrty uf BPT llllU no! bo dcliv,,:cd lo client until
all monies owed to BM' by Client (whether or not such monie.,i; have then h«ome due and paynble) have heen
paid.
6. ARBITRATION. Any dispute arising pursuant to any contact to which these Terms and Conditions apply shall
be submiUcd to u.rbitrt1tion in Oaklund County, Michigtm, in »ceord.Kncc wilh the rules of .American Arbilr.1lion
Association, and tl1e award of the arbi'ttator shall be final and binding on the parties. Judgment upon any award
rendered may be cnlcn;U in uny court lul:vingjl.lrulW.ction.
7. l'NIJfo:MN.fTV. Client agrees to indemnify, protect and l1old harmles.,i; BPT from and asain:tt ttlt lio.hility c.Jo.im . .;;,
demands, losses, dtmtagc!I, cxpcruu:tt und ~ (including 11.Uomcy fct •. --s) related in any W8Y to BPT's performance
ur ~vice.i un~ thi~ Agreement, provided, however, that Client :ihall n0t be ohlig1itcd tu indemnify DPT for 1my
injury or damage caused directly and solely by the negligent acts, errors or omissions of BPT.
8. SITE ACCESS AND SI!-CliRffY. ln the event the Scope of Service~ requires DPT to enter onto tJi~ property or
others, Client shall be solely responsible for all aspects of site security and for obtaining any and all necessary
penni~ion from wiy u.ffected third party o"WTier for \L~ of their land. If nec~~'wl!Y, Client shall ohtdfo .,, sig11ed
authoriuition of entry oDto t.hc:: lund to cnublc DPT Lo perform iL:J :services. Client ~ll be: solely responsible: for
11ny .;Juim~ arising from tl1e distw-ba.nce of sw-face or subsurface lands or waters caused by the performance of
any BPT's services, cxcc:pl for t1uc,;h dumuge Uj w\.Used b)' th~ :sok nc:gligcncc of BPT.
9. WAIVER. No waiver, discharge of renwiciation of any claim or right of BPT arising out of breach of this
Agreement by Cliait ,shall be <lkctivo uni= in writing sil!Il«l by BPT.
JO. GOVERNTNO T.AW. This Agreement shall be governed by and construed in accordance with the laws of the
State; uf Michigon.
l'EDERAl.lLOCAL RIGHT-TO-KNOW COMPLIANCE. In compliance with the Federal Ha,.ard Communicotion
Standards and applicable laws or ordUUI.Ilccs>. Cli,;nt sluul provid,; BPT with a lisL of hazardous sub3WlG4.'S in lhc
Work ploe<: lo which BPT employ••• or ,mhcontractors may be expo,ed while pcrfonnini: ,ervice, under thi•
Agreement. In addition, the Client shall provide a listing of protective measw-es in case e>..l)Osure occ:urs.
8
This inlurmation W1l!I developed exclusively for National Starch Ill. Chemical Company and is the propaty of Blue
Planet Technologies. Reproduction or di.:,tribulion i.8 by pmnjstriun ofB!uo Plon•t Technologies only.
** TOTAL PAGE.09 **
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4WD-NSRil
l lJ: 4U4-.)4 (-:,U',4
UNITED STATES ENVIRONMENT AL PROTECTION AGENCY
REGION ◄
J◄S COURTLAND STaEET. l'I.E.
A Tl.ANT A. G[OAGIA )OJ65
Jun.c 7, 1996
(lPT10HAI FORM ~ fl ~l
Dr. Abu M. Z. Alam
National Starch&: Ch~mica.l Company
10 Finderne Avenue
P.O. Box 6500
Bridgewater, NJ 08807-0500
SUBJ: Approval of Approach to be Incorporated in the Remedial
Deaign/Remedial Act.ion Work Plan for Opetable Unit #3 and Natural
Degradation Treatabilit.y Study Work Plan for Operable Unit #4 at the
National Sta~·ch & Chemical Company Superfund Site
Dear Dr. Alam:
A draft version of the N~tural Pegradatjon Traatability Study Work Plan
for Operable Unit (OU) #4 waa received by the Agency on October 26, 1995 and
the draft. vor:;,ion of the Remodia.l Design/Remedial Action Work Plan for OU #3
waa submitted by National Storch&: Chemica1·compo.ny (NSCC) on December S,
1995. These documents were disseminated ro:r review.
The following is a chronology on events with regard to the Natural
Degraclation Treatability St.Udy Work Plan tor OU #4. The Agency transmitted
its original comments to NSCC on November 11, 1995 and North Carolina
Department of Environment, Health & Natural Reaources (NCDEHNR) comments were
forwarded to NSCC on D"cernber 4, 1995. NSCC responded to these conunent.s in a
January 16, 1996 correapondence. In reply to NSCC's respo11se, the Agency sent
additional comments/concerns on March 18, 1996. A conference call was held on
March 26, 1996 to rsview and resolve the remaining differences. In response
to this conference call, NSCC sent their reply on March 28, 1996.
The following is~ chronology on events with regarcl to the Remedial
Design/Remedial Action Work Plan for.OU i3. The Agency transmitted its
original conunent& along wit.h comments from NCDEIINR to NSCC on January 19,
1996. NSCC responded to these comments in a February i7., 1996 correspondence.
Additional comments from NCDEHNR, dated March 13, 1996, wBre transmitted to
NSCC which NSCC responded to on March 28, 1996.
Based on the e.l:>ove draft Work Plo.ns and the resolutions atte.ined through
the numerous communications between EPA, NCDEHNR, and NSCC, the approe.ches
dQscribed in these communications are e.cceptable to EPA. Based on these
referenced communications, NSCC shall prepare the final Work Plans for OU #3
and OU #4. The Agency would like to receive the fin<>l versiona of these
documents by Friday, June 21, 1996, it feasible, Please <1dvise.
The following oomrnent"/concerns need t.o be e.ddressed in the final Work
Plans.
Comments/concerns with regard to NSCC March 2B, 1996 Response to NCDEHNR
Comments 011 NSCC R,H1po111.1e to J.t.inua..ry 18 Comments on Remodiol Des1gn/Remedial
Action Work Plan for Operable Unit '113 at the: Nation.:JJ Sta.rcl1 & Chemic41
Comp4~Y Sup~rfund Sito,
STATE PROG. StCI lUN JU I'~ IJ I ::, 0
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2
Tha December 1995 draft Work ~l.an states t.hat t.he bedrock extraction
wells will be drilled to a depth of 200 fee\: below eurface. As discu~aed and
agreed upon during our March 26 conference call, two of these wells will be
cored to depth. Groundwater samples will be collected from these two wells
via packers (every 10 feet or so) to define the vQrt.ical depth of groundwat.er
contamination in the bedrock zonQ. If the cores at 200 !eet depth show
fractures, the coring is to continue until competent bed1·~ck is encountered.
Thie information wil 1 be used to determine if the existing bedrock wells
are at sufficient depth to determine the aerial extent of gt·oundwater
contaminAtion in the bedrock zone and whether or not the existing bedrock
rnonit.oring wells are at sufficient. depth t.o monitor th .. bedrock oxtt·Action
systems in the lagoon araa a.nd Area 2. This appl.Ao~ch needs to delinat1.ted in
the ravised Work Plan.
Commenta/conoerns with regard to NSCC March 28, 1996 Re.spo111:1e eo USEPA
Comments (3/18/96) on Rem,.dial D"sign/Remedial Action Work Pla11 for Natural
Degradation Treo,t .. bility Study to1· Operabl,. Unit #4 at th" National Stare!, &
Chem.ical COJl1P'lllY Supe,·tund Si. te.
1.
2.
3.
t>a.ge 3, It.em 2., third pZ1.ragraph, second sentence: Chonge thia t't'ntence
\:o read, • ... on a quarterly baais for l,2-DCA ~jj,gi;,'t§i'i{J}itfPCI\ degradtLl:ion
by-products such aa ... '.
!>age 3, Item 2., fourth paragr<1ph: 1'he installation and sampling
procedures for the soil gag ~onitoring WQlls need ~o be incorporAted in
the revised docurnenta.
Page 3, Item J: Are eoil gaa sarnplea to be collected from two septLrate
dept.hs at every loca.t.ion (the four Soil !'lots and the four Soil Gas
Monitoring locations as discussed .in Item J at the t.op of Pa.ge 3) 7 This
component needs to be clarified.
Please Advise if it. will take NSCC a longer timeframe to prepare these
final document.s for approvtLl than June 21, 1996. lf you have any questions,
please call me at. (404) 34?-7791, x-2053.
Sincorely yours,
Remediol Projec::t Manager
cc: David Lown, NCOEHNR
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10 Finderne Avenue
P.O. Box 6500
Bridgewater, New Jer.iey 08807-0500
908-685-5000
Cable Addrou, NASPROO.BRIOGEWATER-RSEY
Writer's Direct Oial Number:
Ft.I: Numbtr.
Mr. Jon Bornholrn
Remedial Project Manager
United States Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
March 28, 1995
Subject: Response to USEPA comments (3/18/96) on
Remedial Design/Remedial Action Work Plan for
Natural Degradation Treatability Study for Operable Unit 4
at National Starch and Chemical Company's Cedar Springs
Road Plant Site, Salisbury, North Carolina
Dear Mr. Bornholrn:
Attached please find NSCC's response to USEPA's March 18 comments. USEPA provided
these comments after review of NSCC's January 16 response to USEPA's November 22
comments an the Natural Degradation Treatability Study Work Plan for the fourth Operable Unit
(OU4) at the National Starch and Chemical Company's Cedar Springs Road Plant site in North
Carolina. Altogether there are five pages of comments and responses. As in the case of
responses to OU3 comments NSCC assumes that USEP A will transmit these responses to the
NCDEHNR. We will wait until we hear from you and the NCDEHNR before we revise and
finalize the Natural Degradation Treatability Study Work Plan. Please feel free to call me if
there are any questions.
Very Truly Yours,
{24 t'Jrl-~ae,._
Abu M. Z. Alam, . P.E.
Director, Environrn ntal Projects
CC: D. Cregar, NSCC w/o Response
M. Ford, NSCC
C 'PROIECTS\SALSBR'\'\OU4TI. TIU.AA
A. Samson, NSCC
R. Parado"",ki, NSCC
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Responses to USEPA's Comments (03/18/96) on the
Remedial Design/Remedial Action Work Plan
for the Fourth Operable Unit (OU4)
National Starch & Chemical Company
Cedar Springs Road Plant, North Carolina
A. Work Plan Comments
The Agency continues to question NSCC's approach with regard to constructing single plots for
each of the parameters to be evaluated and the location selection of the plots. The Agency
believes that it is necessary to duplicate (at a minimum) each plot as well as have randomiz.ed
location of the plots. The Agency's rationale for taking these positions is provided in the
following comments:
Comment No. 1
NSCC argues that their original approach of using a single plot to evaluate the effectiveness of
each treatment is adequate to meet the objectives of the study. The four plots proposed are: no
treatment, treatment with moisture, treatment with moisture and nutrients, and no treatment in
an uncontaminated area. If the objectives of this study are (I) to measure the rate of natural
degradation of 1,2-dichloroethane (DCA) with known confidence, and (2) to detennine with
known level of confidence that the treatments provide (or do not provide) a greater rate of
degradation, then the approach proposed by NSCC is insufficient
For a specific treatment, in order to know the rate of degradation and the associated error of it's
value (i.e., error bars), replicate plots must be operated. In other words, replicate plots allow the
calculation of the rate+/-error where the magnitude of the error indicates the confidence of the
computed rate. Thus, if a measured degradation rate implies that the site would be clean in 20
years due to natural degradation, insufficient data would be collected to specify if the rate is 20
+/-5 years or 20 +/-19 years. In this example, the error will assist the Agency in determining
the feasibility of the proposed treatment.
The error in the rate is also required to compare the effectiveness of the treatments. By
operating replicate plots, sufficient data will be generated to state with known confidence that a
particular treatment approach provides a higher rate relative to others, or that it does not (e.g.,
Treatment1 is superior to Treatment2 with 80% confidence). Without replicate plots, this will
not be attainable.
C:1PROJECTS\SALSBRY\OU4RESP2.AA I
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Response to Comment No. t
The Natural Degradation Treatability Study is required by the Record of Decision (ROD) for
Operable Unit 4 (OU4). The Statement of Work accompanying the Unilateral Administrative
Order for Remedial Design/Remedial Action at OU3 and OU4 stated the following five
objectives for the Natural Degradation Treatability Study:
1. Determine if the natural degradation of site contaminants is occurring in the
saprolite;
2.
3.
Determine whether natural degradation can be enhanced through the
addition of nutrients to the soil;
Determine where in the subsurface degradation is occurring;
4. Determine at what rate the natural degradation is proceeding; and
5. Estimate a time frame when the Performance Standards via natural
degradation will be attained.
As discussed during the March 26 telephone conference with the USEP A and the NCDEHNR,
NSCC and its consultant Dr. David Kosson of the Rutgers University has reviewed USEPA's
comments in the light of the five objectives of the Natural Degradation Treatability Study listed
above. To achieve the above five objectives in an efficient and cost-effective manner, NSCC
proposes the following modifications to the Remedial Design/Remedial Action Work Plan for
OU4 submitted during October 1995.
1. Initially NSCC will conduct the Natural Degradation Treatability Study
using the four Soil Plots as originally proposed. The purpose of this initial
phase is to determine:
(a) If natural degradation of 1,2-DCA is occurring in the saprolite;
(b) Whether natural degradation of 1,2-DCA can be enhanced by
addition of moisture or addition of moisture and nutrients; and
(c) Which of the three treatment methods provides the maximum
degradation of 1,2-DCA.
NSCC believes that the results of this initial phase of the study will identify the
treatment method that produces the best degradation rate and will also give initial
estimates of the degradation rates for the three treatment methods.
C:\J>ROJECTS',SALSBRY\OU4RESP2.AA 2
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2.
3.
4.
During the initial phase of the Natural Degradation Treatability Study
NSCC will also install four Soil Gas Monitoring Wells in the unsaturated
saprolite zone. Two of these four Soil Gas Monitoring Wells will be located
in the contaminated soils near the Lagoon Area and the other two Soil Gas
Monitoring Wells will be located in the contaminated soils under the
pavement in Area 2.
During installation of each Soil Gas Monitoring Well soil samples will be
collected and analyzed to establish initial concentrations of 1,2-DCA and
other organic contaminants.
The proposed Soil Gas Monitoring Wells will be located at random. Soil gas
from these wells will be monitored on a quarterly basis for 1,2-DCA
degradation by-products such as Chloroethane, ethane, ethene and vinyl
chloride. Data from these four Soil Gas Monitoring Wells will then be used
to determine whether 1,2-DCA is naturally degrading at othc,r contaminated
locations at this site.
Results of soil gas monitoring in these four Soil Gas Monitoring Wells will
also be compared and correlated with the results of soil gas monitoring in the
four proposed Soil Plots in Area 2.
In the initial phase NSCC will collect and analyze soil gas samples from two
separate depths (one screened at 2-4 ft. and the other screened at 5-7 ft.)
using nested vapor sampling wells and 0.25 inch diameter stainless steel
tubing. These measurements will provide answer to where in the soil
1, 2-DCA degradation is taking place and \'\ill also provide concentration
gradients in the soil gas.
Upon establishment of the treatment method that gave the best degradation
rate for 1,2-DCA during the initial phase (estimated to be about one year),
NSCC will select this treatment method for replication at other locations
during the second phase. Replication will be conducted at three other
randomly selected Soil Plots to establish a reliable and statistically valid
degradation rate for 1,2-DCA.
NSCC believes that the proposed Soil Plot with addition of moisture and
nutrients will give the highest degradation rate. Whichever treatment
method (Soil Plot) gives the best degradation rate during the initial phase,
NSCC will continue to operate that Soil Plot during the second phase. The
other three Soil Plots will be relocated during the second phase at three
randomly selected locations within the contaminated soil
C:1PROJECTS\SALSBRY\OU4RESP2.AA 3
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5.
6.
Monitoring results from all four Soil Plots duplicating the same treatment
method will then be used to determine statistically valid 1,2-DCA
degradation rate(s) and to estimate the time required to clean up the site.
Before starting the initial phase of the field study NSCC will collect two soil
samples from the contaminated area. These soil samples will be used for
conducting laboratory studies and screening for biodegradation. These
laboratory studies will answer the following questions:
a. Are bacteria capable of biodegrading 1,2-DCA in soil at the site?
b.
c.
Which conditions most favor biodegradation of 1,2-DCA at the site?
What additions (moisture, nutrients, pH control agent, etc.) will
enhance the biodegradation rate most?
d. What are the specific biodegradation rates under controlled
conditions in the laboratory?
The answer to these questions will assist in conducting the field
biodegradation study, and collection and interpretation of data.
Before starting the initial phase of the field study NSCC will also collect soil
samples from the contaminated area to establish partitioning of 1,2-DCA
between the soil water and solid phases, and between soil vapor and solid
phases. Results of 1,2-DCA partitioning will assist in the interpretation of
the soil gas monitoring data including the mass balance of the degradation
products of 1,2-DCA such as Chloroethane, ethane, ethene, and vinyl
chloride.
Comment No. 2
NSCC argues that because values of environmental parameters are often correlated to distance,
randomization of the location plots is a poor approach. The Agency believes the opposite to be
true. Because these values may be correlated with distance , i.e., the values. may be a function
of space, not randomly distributed, the location of the plots must be randomized to eliminate the
spatial bias.
Response to Comment No. 2
NSCC respectfully disagrees with the Agency. NSCC bad provided enough information
indicating that randomization brings in far more uncertainties in the determination of
C:\PROJECTS\SALSBRY\OU4RESP2.AA 4
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degradation rates. However, rather than continue to argue the merits of specific versus
random selection of Soil Plots and delay the implementation of this project, NSCC
proposes to install three Soil Plots at random locations during the second phase (about
1 year after the initial phase) of the Natural Degradation Treatability Study after
establishment of the best treatment method and determination of preliminary estimates of
the 1,2-DCA degradation rates from the four Soil Plots installed during the initial phase.
C: PROJECTS' SALSBR'f\OU4RESP2.AA 5
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filJ:?.tional Starch and Chemical Company
1 0 Findeme Avenue
P.O. Box 6500
]irulitiml o+E✓, n 1 j .\Ce ence
Bridgewater, New Jersey 08807-0500
908-685-5000
Cable Address: NASPAOO,BRIOGEWATEANEWJERSEY
Wrtter's Direct Dial Number:
Fax Number.
Mr. Jon Bomholm
Remedial Project Manager
United States Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
January 23, I 996
Subject: Bacterial Enumerations Prior to Conducting
Natural Degradation Treatability Study for Operable Unit 4
at National Starch and Chemical Company's Cedar Springs
Road Plant Site, Salisbury, North Carolina
Dear Mr. Bomholm:
1895/1995
Thank you for sending the information on Blue Planet Technologies. Upon review of the
material you sent to us I talked to Ms. Judy Albertson of Blue Palnet Technologies to determine
their experience and capabilities. Based on my discussions with Ms. Jody Albertson and
Timothy Geddes of Blue Planet Technologies I have asked them to submit a proposal for
conducting analytical tests and bacterial enumerations. Attached please find Blue Planet
Technologies proposal for conducting this work. We believe that the proposal submitted by Blue
Planet Technologies is a good one and, if incorporated, will assist the Natural Degradation
Treatability Study for Operable Unit 4. We are sending this proposal for obtaining review
comments from the USEPA and the NCDEHNR. Upon receipt of your approval we would like
to carry out this work prior to initiating the Natural Degradation Treatability Study work tasks.
Please feel free to call me if there are any questions.
Very Truly Yours,
~/?l'-
AbuM. Z. Al
Director, Envir
CC: D. Cregar, NSCC w/o Proposal
R. Paradowski, NSCC
C:\PROJECTSISALSBR Y\OU4L llll .AA
A. Samson, NSCC
M. Ford, NSCC
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. ·, J .... , •
. .:. ' -.. --· -··-·-·••--·-·----
Blue Planet Technologies
B10report111 Proposal
1,2 Dichloroethane Contaminated Site
Proposal #1060-A
Prepared for:
Abu Alam
National Starch & Chemical Company
10 Findeme Ave.
Bridgewater, NJ 08807
Blue Planet Technologies
31384 Edward Street
Madison Heights, Michigan 48071
[phone]
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r-. , ... L.:
Nation•! St•rch & Chemicals Company Blue Pia.net Tttbnologies Proposal# 1060-A
January 17, 1996
Introduction
Based on a phone conversation betWeen Abu Alam of National Starch & Chemical
Company and Jody Albertson on January 19, 1996, Blue Planc:t Technologies is
submitting this proposal for performing a BIOreport"' of samples taken from a site
contaminated with 1,2 Dichloroethane (1,2-DCA).
Anaerobic degradation of higher-chlorinated compounds may produce 1,2-DCA.
Generally, 1,2-DCA is slightly soluble in water, adsorb poorly to soils, stable to water, and
resistant to oxidation. Consequently, these contaminants migrate through the vadose zone
and contaminate the aquifer. Many chlorinated solvents can be transformed by chemical
and biological processes in soils to form a variety of other chlorinated aliphatic
hydrocarbons such as methylene chloride, vinyl chloride, l, 1-dichloroethane and
chloroethane. Generally microorganisms cannot obtain energy from the transformation of
these solvents. Transformation is brought about by cometabolism, a process in which
another compound must serve as the primary source of metabolic energy.
Objective/Scope of Work
Blue Planet Technologies' objective in this project is to provide National Starch &
Chemical Company with a BlOreport"' that will be useful in predicting and/or confirming
successful application of bioremediation as a remedial technology to the site under
consideration. In order to accomplish these objectives, the following studies will be
conducted for each soil sample submitted:
Analytical Testing. The chemical and physical properties of the site samples including
pH, and concentrations of all chlorinated compounds of concern will be determined. All
analytical measurements will be performed using USEP A approved methods or other
conventional methods, observing all associated QA/QC. EPA Method 8260 will be used
for 1,2-DCA. Throughout the course of this investigation, samples will be handled and
stored in accordance with EPA approved methodologies. If the contaminant is found to
2
This information was dcvclopc:d s-xclusivcly for National Stan;h &. ~I Company 1111d is 1hc property of DI~
PIMet Technologies. Reproduction or distribution is by permission of Blue Planet Tc<hooloa;ic,o only.
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-. =-·-: ·-. ---,.. .... --
Nation•I Starch & O,ernical, Cnrnnany Blue Planet Technologies Propoul II 1060-A
January 17, 1996
be below state regulatory requirements, Blue Planet T eclmologies will contact National
Starch & Chemical CompllI\Y immediately.
Bacterial Enumerations. Total heterotrophic organisms will be enumerated using a
standard spread plate assay according to Method 92 l SC, modified (Standard Methods for
the Examination of Water and Wastewater) under aerobic and anaerobic conditions. This
study is important in establishing the presence of significant numbers of viable bacteria
prior to implementing in situ bioremcdiation.
1,2 DCA Degrading Bacterial Enumerations. The method used is a modification of the
Most Probable Number Method (MPN) described in Soil Sampling and Methods of
Analysis, Canadian Society of Soil Science, 1993. This protocol employs the concept of
dilution to extinction in order to estimate the number of microorganisms in the sample.
This method is utilized to determine the numbers of contaminant degrading bacteria by
using a minimal salt media with the contaminant as the sole carbon source. Thus, only
microorganisms capable of utilizing the 1,2-DCA as a food source will proliferate.
Nutrient Panel. An analysis may be performed to detennine if the levels of nutrients
essential for bacterial proliferation fall within published ratios. Specifically, nutrients
determined will include Kjedahl nitrogen, ammonium nitrogen, orthophosphate, and total
organic carbon (TOC).
Cost and Delivery
The times to complete the various studies descn'bed in this proposal are listed in the
following schedule. These times assume receipt of sample(s) and a signed copy of the
enclosed Laboratory Services Agreement. The cost of this effort is quoted using the
following schedule:
Study T"dlll! In J>dh,uy C<>rt per
Samnle
Analvtical Tcstin2 l week $205
Bacterial Enumerations 2 weeks $170
1,2-DCA Oegradine BaclCrial Enumerations 2 weeks $110
Nutrient Panel 2 weeks $95
3
Thi9 information was developed exclusively for National Starch & Chc:nical Company and is lhe property ofBlue
Planet Te<:hnologies. lu:ptoduction or dis1nllU1ion is by pennissico of Blue Planet Technol()jies only.
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.. . .-,,
-. . -. -' -.. ·--
National StarO. & Cbemlcall Company Blue Planet Tccboologic:i Proponl # 1060-A
January 17, 1996
Above charges include sample containers and non-express delivery (ground). For your ·
convenience, complete sampling kits may be provided, and shipped express via an
overnight carrier. An additional charge of$40 will be applied if this service is desired.
Upon completion of the investigation, a final report will be submitted. Frequent progress
reports will also be made during the course of the investigation.
If additional studies beyond the scope of this work is required later, the cost can be
negotiated at such time. Cost and Delivery quoted in this proposal are firm for 9.0 days,
after which Blue Planet Technologies reserves the right to revise them.
If you would require any additional infonnation on any aspect of this proposal, please do
not hesitate to contact Jody Albertson at [phone].
Very truly yours,
J11~d.y ~/,ti.-
Cheryl Franks-Denman Timothy J. Geddes
Staff Scientist Director of Business Development
4
This infonnation was d,vetoped exclusively tbr National Starch&. Chemical Company a:id i., the property of Blue
Plaru!t Technologie•. R.eprodw:tion or di<tribution i• by penni•sion ofBlue Planet Technologies only.
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National Starch & Chemical~ Company
January 17, 1996
References
·-. --··· . --·--__ ._,_,,._..,, __
Blue PIAnct Tcchaologies Prnngw # 1060-A
I . Most Probable Number Enumeration, Standard Methods for the Examination of Water
and Waste Water. APHA. AWWA, WEF, 18 ed., 1992.
5
This infonnation w:as developed exclusivoly for Natiol\lll Swch & Chffl\lcal Company ond is the property of Blue
Planet Technologies. Reproduction or distribution is by pcrmis:rion of Blue Planet Technologies only.
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..
11:!.ti.onal Starch and Chem/cs/ Company ']i-aditim1 0fE✓, .n
1 0 Findeme Avenue
P.O. Box 6500
Bridgewater, New Jersey 08807-0500
908-685-5000
Cable Address: NASPR00,BA1DG8NATEANEWJEASEY
Writer's Otrect Dial Number:
Fu Number:
Mr. Jon Bomholm
Remedial Project Manager
United States Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
] j ,.\Ceuence
J,W5,/J'J'J5
January 16, I 996
Subject: Response to Questions on Remedial Design/Remedial Action Work Plan
Natural Degradation Treatability Study for Operable Unit 4
at National Starch and Chemical Company's Cedar Springs
Road Plant Site, Salisbury, North Carolina
Dear Mr. Bomholm:
Attached please find the responses to USEP A and NCDEHNR comments on the Natural
Degradation Treatability Study Work Plan for the Fourth Operable Unit (OU4) at the National
Starch and Chemical Company's Cedar Springs Road Plant site in North Carolina. Altogether
there are twenty two pages. After you have had a chance to review the responses please give us
call and advise us as to how we should transmit the responses to the NCDEHNR. As we have
discussed and agreed earlier, we will wait until we hear from you and the NCDEHNR before we
finalize the responses and revise the Natural Degradation Treatability Study Work Plan. Please
feel free to call me if there are any questions.
aru;;.o~urs: ~
Abu M. Z. Al SC.D. P.E.
Director, Env nmental Projects
CC: D. Cregar, NSCC w/o Work Plan
R. Paradowski, NSCC
A. Samson, NSCC
C: PROJECT'S SALSBR Y',OU4L TIU .AA
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Responses to U.S. EPA Comments (11/24/1995) on the
Natural Degradation Treatability Study Work Plan
for the Fourth Operable Unit (OU4)
National Starch & Chemical Company
Cedar Springs Road Plant, North Carolina
1. Work Plan Comments
Comment No.I;
Page 3, third paragraph: I suggest incorporating language into this paragraph or elsewhere in this
Section about the efforts NSCC has made to reduce/control/eliminate surface run-off from the
production area. The description should include the time frames the work was started and
completed.
Response No. 1
NSCC has made efforts to reduce/control/eliminate surface run-off from the Production Area.
NSCC has paved the area surrounding the Production Area and has installed curbs to contain
and collect storm run-off. All stormwater from this area is now collected in a sump and directed
to the lagoons for treatment before ultimately being discharged and treated at the local POTW.
During the time for conduct of the Phase I RI for OU I activities (June 1988) and the
Supplemental RI for OU2 activities (1990) National Starch and Chemical Company (NSCC)
abandoned and plugged all storm water discharge lines that collected storm water from the
asphalt area between the main building and the Northeast Tributary. These lines used to
discharge surface water runoff from the asphalt area to the steep-sloped bank between the
Northeast Tributary and the Plant Operations Area. In addition, concrete dikes, catch basins,
sumps, new discharge lines, and sump pumps were installed in the asphalt area ( immediately
east of the Plant operations Area) to collect and discharge the storm waterto the existing
Pretreatment Lagoons. All surface runoff from this area is now pretreated with the Plant's
wastewater prior to discharge to the City of Salisbury sewer for further treatment.
Comment No. 2:
Page 29, second paragraph, second sentence, "Metal Box": There is ongoing research in the area
of chlorinated compounds in soils and water involving the use of iron filings to enhance the
redox potential thereby liberating the chlorine. The drawing in Figure 2-2 (page 31) alludes to
the use of extruded aluminum or formed steel. There is no reference in the test as to what metal
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will be used to form the box. Due to potential interferences that may come from the steel
(ferrous) and the possible reaction of dibasic ammonium phosphate with the aluminum, it is
recommended that stainless steel be used to form the box (es).
Response No. 2
This is an excellent observation. To prevent corrosion and the associated interference the frame
and cover of the metal box will be constructed of epoxy primed and epoxy painted formed steel.
The metal box will be sandblasted to near white metal to meet SSPC SPl0 requirements, primed
with a polyamide epoxy coat ( 4 to 5 mils Dry Film Thickness (OFT)) and then painted with a
compatible polyamide epoxy paint (6 mils OFT). This epoxy priming and painting normally
prevents corrosion in carbon steel for a minimum of 10 to 15 years and, therefore, will prevent
corrosion for the duration of the Treatability Study and potential interference of iron filings.
Comment No.3
Page 29, third paragraph, second sentence: This sentence states that water will be added to Soil
Plot# 2, however, the source of water was not specified. Will the source of the moisture be
distilled water, collected rain water, tap water, aged tap water to allow the chlorine to evaporate,
etc.? Will electrolytes be added? These details should be clarified?
Response No. 3
The water for addition of moisture to the Soil Plots will be obtained from the supply provided by
the City of Salisbury Water Treatment Plant and will be drawn directly from an on-site spigot
into a container to be used to store and distribute the water. Prior to distribution, the water will
be aerated for approximately thirty minutes to remove any residual chlorine and, if necessary, the
aerated water will be stored over-night to remove all traces of chlorine prior to use in the Soil
Plots.
Comment No. 4
Page 35, Section 2.4.2 Measurements of Performance: What is the possibility of conducting
some viable bacterial counts or even determine the species of bacteria present? Is there a local
college that can be contacted to see if the Biology Department may be interested in helping?
Response No. 4
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Determination of bacterial species is very time consuming and requires a lot of effort because
there are thousands of types of bacteria that might be present in a soil matrix. So far NSCC has
been unsuccessful in locating a company capable of determining the species of bacteria present
in the soil. NSSC believes that the confirmation of the presence of 1,2-DCA by-products and
the detection of certain off-gases associated with the breakdown of 1,2 dichloroethane are
sufficient to support the degradation of 1,2 dichloroethane during the Treatability Study.
Comment No. 5
Page 3 7, Section 2.4.4: Methane, ethane, carbon dioxide, and oxygen are listed in the section as
being analyzed using EPA Method TO-! 4. However, the method itself does not list these
compounds as target analytes. Please indicate whether these analytes will be analyzed with
method T0-14 and any modifications necessary to adapt the method for these analytes.
Response No. 5
The statement made on page 37, section 2.4.4 was incorrect. Methane, ethane, ethene, carbon
dioxide, and oxygen will be analyzed by ASTM Method D1496. Chloroethane, 1,2-
dichloroethane, 1,2-dichloroethene, and vinyl chloride will be analyzed by USEP A Method
T0-14. The Work Plan has been modified to reflect this revision.
Comment No. 6
Page 38, Table 2-2: This table needs to specify an exact version of the CLP Statement of Work
(SOW) for parameters which "TCL" and "T AL" are listed. The EPA methods listed for the
remaining parameters are designed for water analyses, not soils. Methods designed for soil
analyses must be listed in this table.
Response No. 6
Table 2-2 of the Work Plan has been revised and now shows the exact version of the CLP
Statement of Work. The laboratory NSCC has selected for conducting the analyses ( Laboratory
Resources Inc.) has informed us that they will modify EPA methods for water analysis for
conducting analysis of certain parameters (such as chloride, nitrate, sulphate, sulfide, ammonia,
phosphate, TKN, orthophosphate and total phosphorous) in the soil matrices. Please note that
based on Laboratory Resources Inc. Supplied information we have revised Table 2-2 to include
soils analyses methods.
Comment No. 7
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Page 39, Section 2.6: Reference to CLP "certified" laboratories should be removed. EPA's
Contract Laboratory Program is not a laboratory certification program. Laboratories may be
referred to <IS CLP laboratories, but not as CLP "certified".
Response No. 7
As suggested this change has been incorporated in the revised Work Plan.
Comment No. 8
Page 4 I, Section 3. I : Refer to comment # 7.
Response No. 8
As suggested this change has been incorporated in the revised Work Plan.
2. Field Sampling and Analysis Plan Comments (Appendix A)
Comment No. 9
Page A-3, Section A.4.2, second paragraph, second sentence: This sentence discusses the use of
"flexible Tygon or polypropylene tubing". In order to avoid interferences (false positives or false
negatives), it is recommended that all connections to collection devices or sampler pumps be
made using either stainless steel or Teflon tubing.
Response No. 9
As suggested flexible teflon tubing will be used for connections to collection devices and this
change has been incorporated in the revised Work Plan.
Comment No, 10
Page A-4, Section A.4.2: There appears to be a discrepancy between this section and section
2.4.4. This section does not list oxygen and carbon dioxide as analytes to be sampled using the
stainless steel canister (TO-14), but as real-time analyses to be performed with the GEM-500
instrument. Please clarify which compounds will be analyzed with Method TO-14 and which
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will be analyzed on-site.
Response No. 10
Carbon dioxide, methane, oxygen and hydrogen sulfide will be analyzed weekly in the field
using real time instruments such as the GEM-500. Additionally, soil gas samples will be
collected monthly in stainless steel canisters and shipped to an off-site laboratory for analyses of
1,2 dichloroethane, 1,2-dichloroethene, chloroethane, vinyl chloride using USEPA Method TO-
14 and carbon dioxide, methane, oxygen, ethane and ethene using A TSM D 1496.
Comment No. 11
Table A-2: Refer to comment No. 6 above.
Response No. 1 J
This change has been incorporated in the revised Work Plan.
Comment No. J 2
Page A-5, Section A.4.2: Same comment as #5 above. Also, ethene is added to the list ofTO-14
analytes. This appears to be the first time ethene is mentioned as a target analyte. It is not a
listed TO-14 target analyte in the method. Please clarify whether ethene is a target analyte for
the study.
Response No. 12
Ethene is a target analyte and will be analyzed using ASTM D1496 as indicated in Response
No. 5 ..
Comment No. 13
Page A-6, Section A.4.4, second paragraph: This paragraph discusses safety monitoring using
either the Hnu or OVA. It is recommended that both instruments be used. Each has a specific
range of organic compounds it can detect; therefore, using both will give a better evaluation of
the air that is being breathed.
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Response No. 13
Both instruments are easily operated, reliable, and durable as well as both have very rapid
response time (3 to 5 seco.nds) and are easily calibrated. The HNU maintenance consists of
cleaning the lamp and recharging the battery whereas the OVA requires periodic preventative
maintenance, refilling of hydrogen gas and recharging of the battery.
The HNU is a photoionizatoin detector capable of responding to organics and inorganics
depending on the ionization potential of the analyte and choice of lamp bulb. In this case,
NSCC has proposed to use an 11. 7 e V lamp capable of detecting the compounds of interest. In
addition, HNU does not respond to methane which often can create a source of interference.
However, the lamp window of the HNU must be cleaned periodically to ensure ionization of the
air contaminants and to minimize the effect of relative humidity. Relative humidity can cause
interference and inaccuracies in organic response interpretation. On the other hand, OVA is not
readily affected by the relative humidity but the OVA responds to methane which is often a
source of interference. Either instrument can be used to help determine the proper health and
safety protocols and to use both can become quite cumbersome. As a result, NSSC proposes to
use only one of the two instruments to perform air monitoring unless the EPA requires,
otherwise.
Comment No. 14
Page A-9, Section A.4.8, Procedure I: This procedure is for Field Cleaning/decontamination of
sampling equipment and can be found in Appendix 8.8.3, USEPA, Region IV, Environmental
Compliance Branch Standard Operating Procedures and Quality Assurance Manual, February I,
1991 (S©P)
The decontamination procedures for Teflon and stainless steel are slightly different.
Teflon and glass are cleaned the same way (Appendix 8.3, SOP), but using nitric acid on
steel deteriorates the steel. This should be omitted for use on any steel (Appendix 8.4,
SOP)
Additionally, the use of hexane as the pesticide grade solvent is discouraged. Hexane is
miscible with water; therefore, this solvent is not an effective rinsing agent unless the
equipment is already dry. Pesticide grade isopropanol is standardly used by ESD
personnel (Appendix B.1.2, SOP)
Response No. 14
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These suggested changes have been incorporated in the revised Work Plan.
Comment No. 1s
Page A-9, Section A.4.8, third paragraph, Soil samples: Due to the volatility of the compounds
being analyzed, the use of (standard) wide mouth jars is discouraged. The samples should be
collected into a glass jar with a Teflon lined septum lid. ESD typically uses a 2 ounce jar of this
configuration.
Response No. 1s
The suggested change has been incorporated into the revised Work Plan.
Comment No, 16
Page A-10, Section A.5.0, second paragraph, BILCO type protective metal box with a cover will
be installed at grade level: Any portion of the box that interfaces with the soil should be
constructed of stainless steel (See comment# 1)
Response No. 16
The frame of the metal box will be constructed of epoxy primed and epoxy painted formed steel.
The formed steel will be sandblasted to near white metal, immediately primed with a coat ( 4 to 5
mils DFT) of polyamide epoxy and then painted with a coat (6 mils DFT) of compatible epoxy
paint. This will prevent corrosion and related interference.
Comment No. J7
Page A-11, Section A.6.0 Moisture and Nutrient Addition Procedures:
Refer to comment #3 above.
Response No, 17
Please see Response No 3 for details of water source and use for moisture addition.
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3. Quality Assurance Project Plan (Appendix B)
Comment No. 18
Appendix B, Quality Assurance Project Plan (QAPP): The QAPP appears to address only the
quality control requirements for soil analyses performed during the RD/RA. No quality control
criteria are specified for the on-site and TO-14 air analyses. Since these measurements are a
very important part of the study, this oversight should be corrected. Some of the items which
must be addressed are the calibration of the field instruments used for air analyses, detection
limits for TO-14 analyses as applied to the target compounds, calibration of the laboratory
instrumentation used for TO-14 analyses, analysis of stainless steel canister for field and
laboratory blanks, and precision, accuracy, completeness, comparability, and representativeness
of air measurements.
Response No. 18
NSCC has incorporated quality control requirements for air methods TO-I 4 and ASTM D 1496
as well as field calibration procedures for the GEM-500 in the revised Quality Assurance Project
Plan (QAPP).
Comment No. 19
Section B.2.0: Refer to comment No. 7.
Response No. 12
Please see Response No. 7.
. Comment No. 20
Tables B-3-1, B-3-2, B-3-3, and B-3-4: No quantiation limits are specified for the non-T AL,
non-TCL analytes such as chloride, nitrate, sulfate, etc., listed in Tables 2-2 and A-2. Please
specify quantitation limits for these analytes.
Response No. 20
These suggestions have been incorporated in the revised Work Plan. Table 2-2 and A-2 now
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show detection limits for non-TCL and non-T AL parameters.
Comment No, 21
Table B-3-2 & B-3-3: It is not clear why these tables are included in the QAPP since none of the
compounds listed are target analytes for this study.
Response No, 21
As suggested Tables B-3-2 and B-3-3 have been deleted from the QAPP in the revised Work
Plan.
Comment No, 22
Page B-14, Section B.3.5: The reference to EPA 600 methods for miscellaneous parameters is
erroneous. None of the miscellaneous parameters, i.e. non-CLP analytes, for this study are
analyzable by EPA 600 series Methods
Response No. 22
Reference to EPA 600 methods have been deleted in the Revised Work Plan ..
Comment No. 23
Section B.7.2: Refer to comment No. 7.
Response No, 23
See Response No. 7.
Comment No, 24
Page B-23, Section B.9.1, Equipment Blanks should be prepared based on cleaning events. If
equipment is cleaned in a "clean room", lot sampling by date would be adequate. The same
applies to field cleaning. An equipment blank should be prepared at a frequency of one per
cleaning event or weekly.
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Response No. 24
NSSC will collect equipment blanks at a rate of 5 percent to characterize both field and
laboratory cleaning procedures.
Comment No. 25
Page B-29, Section B.12.5, Duplicate Sample Analysis: There are a total of 4 sample plots
(boxes). Approximately four samples will be collected from each point (based on location of
ground water). Each point is spaced 6 inches apart. Each sample will be analyzed for volatile
organic compounds (VOCs or VOA). How will a duplicate be collected if there is limited
spacing? What portion of the split spoon will the VOA sample be collected? How does one
duplicate a VOA sample? This needs further explanation.
Response No. 25
Obtaining duplicate samples in soil typically requires homogenization of the sample aliquot prior
to filling the sample container. In order to prevent loss of volatile constituents to preserve the
integrity of the sample, VOA samples are always taken from discrete locations or intervals
without compositing or mixing. Inherently due to soil heterogeneity, there will always be
uncertainty to the validity of a soil sample duplicate which is subsequently analyzed for VOA
especially when the soil samples are collected from separate discrete intervals. With this
understanding and to minimize the variability, the duplicate for this project will comprise of
opening the split spoon, bisecting the selected portion of the soil in half along longitudinal
direction of the split spoon and placing each half of the selected portion of the soil sample in a
sample jar for analyses.
4. Health and Safety Plan (Appendix C)
Comment No. 26
The plan adequately addresses site concerns.
Response No. 26
NSCC will use the Health and Safety Plan without any revisions.
OU4WKPLN.REVI 10
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s. Comments by EPA's National Risk Management Research Laboratory Located in
Cincinnati, Ohio
Comment No, 27
Mass balance is needed to prove degradation. To determine the natural rate of degradation,
NSCC must be able to show that all ( or most) of the decrease in DCA concentration with time is
due to degradation, and not due to nondegradative mechanisms such as transport to the aquifer or
to soils outside of the plot by movement of soil water or vapor. A strict mass balance of an in-
situ process can be best attempted by isolating the plots with vertical walls such as sheet piling.
However, such walls are expensive to purchase and install. Without isolation of the plots, that
are to be measured, then the test would fail. The test would fail because the loss ofDCA with
time would not be attributable to degradation.
Response No. 27
Developing a strict 'Mass Balance' of contaminants in a Soil Plot by building vertical walls with
sheet piles is impractical, infeasible and unreliable. Installation of sheet piling around a Soil Plot
(a) will disturb the structure of the soil mass, (b) will create cracks and fissures in the soil mass,
and © will allow penetration of air and water into the soil mass through the cracks and fissures
created by the sheet piling. This will allow both volatilization and leaching of the VOCs in the
disturbed soil mass. As a result, the soil samples collected from the disturbed Soil Plot to obtain
an initial estimate of the contaminant mass and its subsequent degradation with time will be far
less reliable as compared with estimates of the contaminant mass and its subsequent degradation
determined from samples collected from an undisturbed Soil Plot. Because of these reasons
sheet piling will not be used for isolating the Soil Plots. Instead, prefabricated, epoxy-primed
and epoxy-painted carbon steel boxes will be used to delineate the soil within each Soil Plot.
This will prevent corrosion and associated iron filings problems.
Comment No. 28
No-treatment plot must be replicated: The rate of natural degradation should be measured such
that the variability of the rate (i.e., the standard deviation or the 95% confidence interval) can be
calculated. The variability of the rate is needed to tell us how confident we are in the value of the
rate. To determine the variability, the contaminated/no-treatment plot must be replicated. _.Thus,
NSCC should construct at least 2 (perhaps more) replicate plots and located them at random
locations in the contaminated area
Response No. 28
In determining estimates of contaminant concentrations and mass in soils it is customary to use
Geostatistics rather than Classical Statistics because geostatistics provide a better measure and
OU4WKPLN.REVI 11
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correlation between data obtained from field investigations and estimate of contaminant
concentrations in the contaminated media. As stated in the US EPA publication on Data Quality
Objectives for Remedial Response Activities, 'geostatistical techniques utilize the location of the
data and the size of the site in all calculations, whereas Classical techniques ignore both of these
important parameters' .1 The USEPA also states in the same publication that 'Geostatistics
recognizes that observed concentrations are goverened by physical processes; thus, one particular
point in space yields information concerning the expected contaminant level at a location 5 or 10
feet away from the sampled point. In statistical terms, these data are correlated in space.• 2
Flatman and Yfantis3 have stated that 'In pollution monitoring, because of the physical laws
governing the source, transport, and fate of the pollutant, one observes that samples taken closely
together have more agreement in magnitude than samples taken further apart. Therefore,
regional variables rather than random variables mathematically describe this type of sample.•
Using two or more Soil Plots located at random within the contaminated zone for Replication as
suggested by USEPA's National Risk Management Research Laboratory located in Cincinnati,
Ohio contradicts the basis and findings of geostatistical techniques as clearly stated above.
Experience from field investigations in the management of hazardous material and contaminated
soils confirm that to obtain a better estimate of contaminant concentrations and mass it is
necessary to collect samples from a 'small area' (smaller sampling areas generally provide better
estimates) surrounding the point of interest. To obtain a better estimate of the mean and reduce
variance it is necessary to collect more samples from the same location. Barth and Mason'
developed soil sampling guides for different confidence levels and analytical precision. Relevant
data from Barth and Mason is presented in Table 1 and contains required number of samples for
90, 95 and 99 percent confidence levels and 1, 5 and 10 percent analytical precision.
Table 1
Number of Samples Required to Achieve Different
Levels of Analytical Precision at Different Confidence Levels
--------------------------
Confidence Level
(Percent)
-------------90
95
99
Analytical Precision
(Percent)
1 5 10
5 2 1
6 2 2
10 3 2
Because contamination concentrations in soil are highly variable and sampling and analysis of
OU4WKPLN.REVI 12
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soil for detennination of contamination levels is expensive a reasonable balance is usually
achieved by selecting confidence level in the 90 to 95 percent range with analytical precision set
at I to 5 percent. Thus, to assure a 90 percent confidence limit the minimum number of samples
required for I percent analytical precision is 5 and to assure a 95 percent confidence level the
minimum number of samples required for I percent analytical precision is 6.
The definition 'small area' is somewhat relative and depends to a large extent on the size and
extent of the contaminated area. For example, if the contaminated area is very large (thousands
of acres) such as the Dallas Lead Monitoring Study5 site, the size of the 'small area'6 used for
sample collection was 61 m x 61 m. In the case of soil contamination by 1,2-DCA in Area 2 of
the Cedar Springs Road Plant Site the area of contamination varies from about 3.90 acres (for the
1,000 ppb contour) to 7.1 acres (for the 100 ppb contour). As a result, the size of'small area' for
collection of soil samples to obtain reliable estimates of the mean concentrations should very
small.
Data collected by IT' during OU3 Remedial Investigations in Area 2 indicated that the
concentrations of 1,2-DCA in the soil is highly variable, both locally and spatially. Attached
Figure 1-12 reproduced from the Final Feasibility Study Report for Operable Unit 3 illustrate this
variation of 1,2-DCA concentrations. As seen from the data presented on this figure the
concentrations of 1,2-DCA varies up to four orders of magnitude (from I to I 0,000 times) in
samples collected. Due to this large variation of measured concentrations of 1,2-DCA in the
soil, samples collected from widely separated areas will provide far less reliable estimate of the
mean concentration and variance while samples collected from within a 'small area' should
provide a more reasonable estimate of the mean concentration of 1,2-DCA with less variance.
Using the results of the Dallas Lead Monitoring Study site and extrapolating that to the smaller
site at the Cedar Springs Road Plant site for obtaining reliable estimates of the mean
concentration of 1,2-DCA in the soil, the size of the Soil Plots in Area 2 should be about 10 feet.
During the Phase II Remedial Investigations at OU3, a total of thirty one (31) soil samples from
fifteen ( 15) boring locations detected concentrations of 1,2-DCA and these samples were used to
define the areal extent of soil contamination in Area 2 of the Production Area at the Cedar
. Springs Road Plant site. Soil samples and boring locations found to be contaminated with 1,2-
DCA (analysis was done at an off-site laboratory) are summarized in Table 2. We have used
this data to calculate means, standard deviations and variances ( at locations where sufficient data
was collected) for individual boring locations as well as for multiple locations to demonstrate
that geostatistics from localized areas provide better estimate of means with lesser variance as
compared to estimate of means obtained from a number of areas. Table 3 presents the results of
this statistical analysis using data from boring locations SBA2-6, SBA2-9, and SBA2-20. As
seen from this data the concentration means calculated from data for a single location are more
. realistic of the site conditions as compared with the means calculated from data for the three
locations. Also, the variances calculated for a single location are much smaller as compared to
OU4WKPLN.REVI 13
-------
APPROXIMATE SCALE (ft) -----0 100
1'-----:c::I
200 300 400 500
-----
,-,. \
. ·· SBA2-i6 SBA213 6J(5.57 .. ···· · ..
1-11)_■ SBA2-14 . . ·_..,; 540(3.5) '· ...
.... . .• ND ... · ,· , .
'; \ : \
: I ' ' ' :
-----
LEGEND·
SOIL B0R1NO LOCATION SHOWINO M:t.x»ee N ■ 1 2-DCA CONCENTRATION (ppb) N'10
(DEPTH (ft)) Of MAXM at-cc>NCENTftATION
. · · -1~ 1.2-DCA CONCENTRATION CONTOUR
N«J CONCENTRATION-)
I WASTE-WATER UNE. NftOW NllCATEll t DIRECTION OF fl.ON
NOTE: Coullm•lkJ.1 dala ••SI ••"80 br'
aoll ecreenlng data
FIGURE 1-12
DISTRIBUTION OF 1,2-DCA
IN SOIL SAMPLES, AREA 2
PHASE II OU3 RI
NATTONAL STARCH AND
CHEMICAL COMPANY
SALISBURY NC m INTERNATIONAL
TECHNO<.OOY
OORPOAATION
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Boring
SBA2-l
SBA2-2
SBA2-3
SBA2-4
SBA2-6
SBA2-7
SBA2-8
SBA2-9
SBA2-10
SBA2-l l
SBA2-15
SBA2-16
SBA2-18
SBA2-19
SBA2-20
Mean
Variance
Standard Deviation
Table 2
Analytical Results for 1,2 Dichloroethane
in Area 2 of the Plant Production Area
Cedar Springs Road Plant
Distance from SBA2-20 (ft.)
380
416
361
296
247
211
146
63
167
158
314
360
454
75
0
-
--
--
Average Result (ppb)
34000
26& 8300
240
17000
95,29000,4100,
9100, & I 1000
410 & 740
380, 1300, & 330
53000, 170, 120,
23000 & 32000
2
2&3
6
540
4
3700
I 690000, 290000,
27000 & 3100
3.94E+04
l.65E+IO
l.28E+o5
Notes: Table 2 only includes only the borings and analytical results which detected 1,2
dichloroethane for samples analyzed by an off-site laboratory and collected in Area 2 of
the production area.
Soil samples were collected during Remedial Investigation of Operable Unit 3.
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Table 3
Mean, Variance, and Standrard Deviations for
Individual Soil Borings versus
Multiple Sampling Locations
Individual Borings Multiple Locations
(SBA2,-6, -9 and-20)
Standard
SBA2-6 SBA2-9 SBA2-20 Mean Variance Deviation
29000 53000 1690000 5.91E+o5 9.07E+I I 9.52E+o5
4100 170 290000 9.81E+o4 2.76E+IO l.66E+o5
9100 23000 27000 1.97E+o4 8.83E+07 9.40E+o3
11000 32000 3100 1.54+04 2.23E+08 1.49E+o4
Mean l.33E+04 2.70E+o4 5.03E+o5
Variance l. l 8E+08 4.79E+o8 6.44E+l l
Standard 1.09E+04 2.19E+o4 8.02E+o5
Deviation
Note: All concentrations shown are for 1,2 dichloroethane in parts per billion (ppb).
Sample results collected during Phase II Remedial Investigation.ofOU3.
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variances calculated from data for the three locations. Thus, samples collected from a single
location at the Cedar Springs Road Plant site for calculating mean are far more reliable with less
variance and are consistent with geostatistics. Therefore, use of soil sampling data from two or
three sites for replication should not be used because it is less reliable and will give higher
variance and standard deviation. Based on the above mentioned reasons, NSCC respectfu!Jy
requests elimination of replication of the Soil Plots.
In Environmental Engineering it is customary to conduct Pilot Tests and Treatability Studies in
the field to establish reliability of the process as well as to determine process kinetics and related
coefficients such as decay rates, growth constants, etc. The normal practice is to collect a
sufficient number samples to calculate the mean, standard deviation and variance of the desired
parameter (such as growth coefficients, decay rates, etc.). If the decay rates are small
measurements are conducted over a longer period oftime to establish the variation of the sample
concentrations with time. Following completion of the Pilot Tests and/or Treatability Studies,
the time variation of the mean concentrations are estimated and plotted together with estimated
high and low concentrations within the desired confidence limits such as 90 percentile or 95
percentile. The mean, high and low estimates of the growth coefficients and decay rates are also
determined from the collected data. The estimated mean, high and low decay rates are then used
to project the time required to remediate the contamination at the site. The low decay rate
provides the longest remediation time while the high decay rate gives the shortest remediation
time. As long as the longest time frame for remediation based on the lowest decay rate is
acceptable and consistent with other activities at the site then the approach is considered
acceptable.
At the Cedar Springs Road Plant site a conservative estimate of enhanced Natural Degradation of
1,2-DCA with moisture addition might take 15 to 25 years while the accelerated Natural
Degradation of 1,2-DCA with addition of moisture and nutrients might take 10 to 15 years.
NSCC's experience of accelerated Natural Degradation of organic contaminants at Zutphen,
Holland leads NSCC to believe that actual time for accelerated Natural Degradation of 1,2-DCA
at the Cedar Springs Road Plant site might be significantly lower than 10 to 15 years. Even the
IO to 15 years for accelerated Natural Degradation is quite favorable when this time frame is
compared with the estimated 100 to 200 years required for remediation qfthe 1,2-DCA
contaminated groundwater at this site to below 1 ppb.
Comment No. 29
All treatment plots must be replicated: To evaluate the effect of the addition of moisture or
nutrients on the degradation rate, the rates measured in the treatment pilots must be compared.
The determination of significant differences in rates requires replication of the treatment plots.
Thus, all treatments should be replicated. The location of the treatment plots should also be
OU4WKPLN.REVI 17
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randomized and given sufficient spatial separation so that each plot can ben considered
independent of its nearest neighbor.
Response No. 29
Please refer to Response No. 2 above which provides reasons for not replicating Soil Plots.
Comment No. 30
Moisture addition rate too low: Given that each plot measures 3' x 4' x 8", an estimated soil
porosity of0.35, and the proposed moisture addition rate of3.6 L/week, the fraction of the soil
pore volume that is water will increase only 0.4% per week or 20% per year. To maximize the
effect of the moisture addition treatment, the moisture content should be greatly increased early
in the test and held roughly constant during the test by periodically adding small amounts of
water. Moisture content could be monitored via the quarterly soil sampling. I realize that NSCC
may be attempting to avoid washing the DCA out of the soil by using a low water addition rate
as this issue is important. The moisture content could be raised significantly over a period of
several days without washing DCA into the aquifer.
Response No. 30
The moisture addition rate was calculated for a 3' x 4' x 8' Soil Plot having 30 percent voids. For
optimum microbial activity in the soil maximum moisture content should be about 50 percent.
Half of this 50·percent moisture content was assumed to be tied in the double layer surrounding
the soil particles and cannot be released or drained. The other half of the 50 percent moisture
content is available for use by the microbes for growth and stabilization of the organic carbon.
Because the Soil Plots are covered, confined and enclosed and the microbes stay within this
below ground confined space only a small portion of this available moisture content ( estimated
to be about 2 to 3 percent per week) is used during the microbial stabilization of the organic
carbon. This leads to the estimate of 3.6 liters/week. It is possible that during the initial weeks
of the Treatability Study it might be necessary to add more moisture than the calculated value to
. bring the moisture content in the soil to about 50 percent saturation level. Once this level of
moisture content is attained the soil moisture contents will be monitored during collection of the
subsequent quarterly soil samples. Monitoring of the moisture contents in the soil will be
continued during the Treatability Study period and if the moisture content falls below the desired
50 percent level additional moisture v.ill be added to bring the soil moisture content up to the
desired level. It would be unwise to add excessive amounts of moisture because it will be
OU4WKPLN.REVI 18
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counter productive to the Treatability Study objectives and will have the following undesirable
effects:
a. Excessive moisture in the soil will cause downward seepage and percolation of moisture
containing contaminants to groundwater;
b.
C.
Excessive moisture in the soil will inhibit microbial activity and growth; and
Excessive moisture in the soil will reduce degradation rate of 1,2-DCA in the soil.
Comment No. 31
Groundwater must be monitored: To help close the mass balance, the quantities listed in Section
2.4.2 (page 35) should be measured in the groundwater, both upgradient and downgradient of
each plot.
Response No. 31
Depth to groundwater and quality of groundwater at the Monitoring Wells NS-35/36, NS-39/40
will be monitored during the Treatability Study. These Monitoring Wells were installed by IT
Corporation during the conduct of the Phase II RI at OU3. However, it is not expected that
moisture will percolate and seep down through the soil to the groundwater because the soil
moisture content will always be at or below the 50 percent saturation level which will prevent
downward flow of the moisture.
Comment No. 32
NSCC refers to no treatment and treatment with moisture or nutrient as "natural degradation". It
is commonly accepted in the environmental remediation field that the term, "natural
degradation", should only be applied to remediation where there is no intervention by man.
Thus, it is misleading to call the cases where moisture or nutrients are added as natural
degradation.
Response No. 32
By Natural Degradation we mean degradation of the organic contaminants by naturally occurring
facultative bacteria in the soil without introducing commercially available microbes. In this
study we have proposed investigation of (a) Natural Degradation of 1,2-DCA, (b) enhanced
OU4WKPLN.REVI 19
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Natural Degradation of 1,2-DCA through addition of moisture and © accelerated Natural
Degradation of 1,2-DCA through addition of both moisture and nutrients by the facultative
bacteria naturally present in the soil. Remediation of soil and groundwater contamination by
NSCC at a plant in Zutphen, Holland demonstrated that the rate of Natural Degradation is
increased many times through addition of moisture and nutrients, and greatly reduced the actual
remediation period. Because of this finding of greatly accelerated degradation and reduced
remediation time we have included addition of moisture and nutrients in the Natural Degradation
Treatability Study.
6.0
I.
2.
3.
4.
5.
6.
7.
References
USEPA, Washington D.C., Mar. 87 -"Data Quality Objectives for Remedial Response
Activities (Development Process), Appendix A -Statistical Considerations pp. A-1,
EP A/540/G-87/003.
USEPA, Washington D.C., Mar. 87 -"Data Quality Objectives for Remedial Response
Activities (Development Process), Appendix A· Statistical Considerations" pp. A-11,
EP A/540/G-87/003.
Flatman, George T. And Yfantis, Angelo A.-"Geostatiscal Strategy for Soil Sampling:
The Survey and the Census" pp 336, Environmental Monitoring and Assessment 4, 1984.
Barth, Delbert S. and Mason, J. Benjamin, May 84 • "Soil Sampling Quality Assurance
User's Guide" pp. 60, EPA-600/4-84-043.
Brown, K. W., Beckert, W.F., Black, S.C., et. al., 1983," The Dallas Lead Monitoring
Study", EPA 600/X-83-007
Flatrnan, George T. And Yfantis, Angelo A.-"Geostatiscal Strategy for Soil Sampling:
The Survey and the Census" pp. 341, Environmental Monitoring and Assessment 4,
1984.
IT Corporation, 1993 -Final remedial Investigation Report for Operable Unit Three ,
Cedar Springs Road, Salisbury, North Carolina.
OU4WKPLN.REV1 20
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Comment No. 1
Responses to NCDEHNR Comments (12/4/1995) on the
Natural Degradation Treatahility Study Work Plan
for the Fourth Operable Unit
National Starch & Chemical Company
Cedar Springs, North Carolina Site
Where has the soil box approach been used before and what were the results? Are there any
references for this methodology?
Response No.I
This approach is current state-of-the-art and no such references are known.
Comment No. 2
The soil boxes are located in the same general area. One objective of the investigation is to
determine where natural degradation is occurring at the site. · A statistically meaningful number
of samples from random locations throughout the site may provide more information on natural
degradation and where it is occurring.
Response No.2
Please refer to Response No.2 under Comments by EPA's National Risk Management Research
Laboratory Located In Cincinnati, Ohio contained under Responses to EPA Comments.
Comment No. 3
Because the contaminants are not homogenous in soils, there will be variations in levels even 6
inches apart as proposed in the Plan for quarterly sampling. No statistics are given to show that
the samples taken from the box are representative of the soil in that column. Variations from
quarter to quarter could results from areal (i.e., non-homogeneities), sampling, and analytical
variations. For this reason, multiple boxes ( the number to be determined statistically but at least
three) of each treatment type would seem necessary to get a statistically valid result.
Ot:•WKPLN.REVI . 21
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Response No. 3
Based on the results of soil sampling conducted by the IT Corporation concentrations of
contaminants in soil samples are expected to vary even when the sampling stations are closely
spaced Replication of Soil Plots does not help in resolving the problems associated with local
and spatial variation of contaminant concentrations. Please refer to Response No. 2 under
Comments by EPA 's National Risk Management Research Laboratory Located in Cincinnati,
Ohio for the approach taken to address this problem and the justifications for the approach.
Comment No. 4
In any investigations conducted, the State would prefer that NSCC retain a qualified contractor to
do the sampling. The QAPP contains no specifics regarding experience of the personnel listed to
conduct such an investigation. Furthermore, there is less potential for the appearance of conflict
of interest regarding the study.
Response No, 4
The Team Members assigned by NSSC to lead this Treatability Study Project have considerable
experience in conducting all phases of Hazardous Waste Management ( e.g., Field Investigations,
Remedial Investigations, Pilot Testing, Feasibility Studies, Conceptual Design, Remedial
Design/Remedial Action, Equipment Testing, Start-Up and Plant Operations). For further
assurance EPA has indicated that EPA will assign an Oversight Contractor for this Treatability
Study Project. Also, in the Field Sampling Plan NSCC has proposed that EPA and NCDEHNR
split samples collected during the conduct of this study and analyze these split samples to check
on the quality of the work. In addition, representatives of EPA and NCDEHNR can visit the site
to assure that the quality of work performed meets current standards.
OU4WKPLN.REVI 22