Associates, Inc. 19,1998 s. - semspub.epa.gov · provided with the BW212 memo dated 5/8/98. ......

O'Reilly, Talbot & Okun Environmental • Safety • Health • Geotechnical Engineering

Associates, Inc.

19,1998 s . i ' File No. 267-02-01 bKt. _

OlhtK: ~~n of Mr. Charles Crocetti Sanborn, Head & Associates 6 Garvins Falls Road, Suite 1 Concord, New Hampshire 03301-5174

Re: SDG BW230 NHDES Laboratory Beede Waste Oil/Cash Energy Site Organic Data Validation

Volatiles: 16 / Groundwater / AE-3, AE-4, AE-5, AE-10, AE-21, AE-22, SH-32I, SH-32S, SH-33S, SH-53S, SH-54S, SH-55S, SH-56S, SH-57S, SH-58S, OW-230 (Field Duplicate Pair / SH-56 & OW-230)

6 / Resamples / AE-10 RS, AE-21 RS, AE-22 RS, SH-32S RS, SH-33S RS, SH-57S RS

5 / Trip Blanks / TB071598, TB072098, TB072198, TB072398, TB072798 3 / Aqueous PES / V02046, PV151, PW143

Dear Mr. Crocetti:

SDG BW230 includes 16 groundwater samples, 6 groundwater resamples, five aqueous trip blanks and three aqueous PE samples collected from the Beede Waste Oil/Cash Energy Site by Sanborn, Head & Associates (SHA). Copies of field sampling notes are attached.

The samples were analyzed by the NHDES laboratory using EPA Methods 8260A and 504.1 consistent with the project Work Plan and QAPP, both dated November 1997. The result pages for 504.1 analysis incorrectly state the method as "504.2". The laboratory was contacted (correspondence attached); they confirmed that the method used was 504.1. SOPs for the two methods were provided in the QAPP and have also been attached to previous validation memos for reference. The Method 8260 SOP (No. 10.57e, Rev. 0, 6/19/97) was provided with the BW219 validation memo dated 4/6/98. The Method 504.1 SOP (No. 10.52a, Revision 4.3) was provided with the BW212 memo dated 5/8/98.

Methylene chloride was detected in trip blanks associated with some of these samples. Because methylene chloride was believed to actually be present in groundwater samples and the initial data was compromised by trip blank results, six of the wells were resampled for confirmation. Results from both analyses are reported in this data package.

293 Bridge Street • Suite 500 • Springfield, Massachusetts 01103 Phone (413) 788-6222 • Fax (413) 788-8830 • [email protected]

mailto:[email protected]

BW230 Data Validation, O'Reilly, Talbot & Okun

Associates, Inc.

A Tier II data validation was performed on this volatile organic using the Region I, EPA-NE Data Validation Functional Guidelines for Evaluating Environmental Analyses, December 1996 and project-specific criteria (attached). A CADRE review was not performed.

These data were evaluated based on the following parameters:

• Overall evaluation of data and potential usability issues; * • Data completeness (CSF audit); * • Preservation and technical holding times; * • GC/MS instrument performance check (tuning);

• Initial and continuing calibration; • Blanks;

* • Surrogate compounds; * • Internal standards; * • Matrix spike/matrix spike duplicate; * • Field duplicates; * • Sensitivity check;

• PE Samples/accuracy check; and * • Compound quantitation and reported quantitation limits.

* Indicates all criteria were met for this parameter.

The following information is provided in attachments to this data validation memorandum:

Table 1: Recommendation Summary Table - summarizes validation recommendations.

Table 2: Overall Evaluation of Data - summarizes site DQOs and potential usability issues.

Table 3: Data Summary Tables summarize accepted, qualified and rejected data, including tentatively identified compounds (TICs).

Overall Evaluation of Data and Potential Usability Issues

This data is intended for use in delineating the nature and extent of contamination and assessing risks and remedial alternatives at the site. Results of QC samples generally indicate good laboratory accuracy and precision.

Methylene chloride was detected in trip blanks and in several samples at similar levels. Affected sample results have been modified to nondetects with elevated quantitation limits.

Several analytes were qualified as a result of continuing calibrations which failed to meet criteria. Results for these analytes were estimated (flagged J or UJ) to indicate uncertainty in the concentration or the quantitation limit. This does not significantly affect data usability.


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Many of the groundwater samples could not be analyzed by the drinking water method 504.1 due to the concentrations of chlorinated compounds present. This resulted in quantitation limits which exceed target limits for ethylene dibromide and dibromo-3-chloropropane. Three other samples were diluted to get target analytes on scale, causing quantitation limits which exceeded criteria in those samples. The end user should determine whether the elevated quantitation limits affect data usability.

Two compounds (chloroethane and trichloroethene) scored action low in one of the PE samples analyzed by Method 8260A. Positive detections of those analytes have been estimated as a result. Nondetects have been rejected, as they may be false negatives.

The following sections provide further information on this sample delivery group.

Initial and Continuing Calibrations

The initial calibrations for both methods and the continuing calibration for Method 504.1 met project criteria. This project has expanded criteria for the relative response factors of four compounds (acetone, 2-butanone, tetrahydrofuran and 4-methyl-2-pentanone) by Method 8260. Project specific criteria are attached.

Continuing calibrations for several compounds failed due to a high % difference (%D) from the initial calibration. Results and quantitation limits for these compounds have been estimated due to the variability in response. Outlying results and validation actions are summarized below.

Calibration Compound 1 %D | Action Affected Samples Date (+/-)

7/20/98 Methyl t-butyl ether 26 J / U J AE-21.AE-22, SH-32I, 2-Butanone 31 J / U J SH-32S, SH-33S, SH-55S, 1 ,2,3-Trichloropropane 26 J / U J TB071598

7/24/98 2-Butanone 36 J /U J AE-3, AE-4, AE-5, SH-53S, 1 ,2,3-Trichloropropane 26 J /U J SH-54S, SH-56S, OW-230,

TB072198 7/29/98 Dichlorodifluororaethane 38 J / U J AE-10RS, AE-21RS, AE-22RS,

2-Butanone 28 J /UJ SH-32SRS, SH-33SRS, 2,2-Dichloropropane 26 J /UJ SH-57SRS, SH-58S, TB072398, Tetrahydrofuran 26 J / U J TB072798

Notes: (+) indicates action on detected values, (-) indicates action on nondetect results.

Blanks

One laboratory method blank contained a tentatively identified compound (N-butylbenzenesulfonamide). This TIC was not identified in samples, therefore no action is taken based on its presence.


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Two trip blanks contained methylene chloride at 3.4 and 12 ug/1 respectively. The laboratory performed a duplicate analysis on one of these and confirmed the presence of methylene chloride in the blanks. Methylene chloride was not being used in the laboratory on that date. The lab contacted SHA to alert them to this condition (phone log attached). The source was believed to be the amber jar which was used to store trip blanks prior to sampling events. The laboratory believes the jar may have been rinsed with methylene chloride, which then contaminated the trip blanks prior to use. If this were the source, only the trip blanks and not actual field samples would be affected. However, because methylene chloride was a particular target of interest in these samples, wells in which methylene chloride had been detected were resampled. Data from the initial analyses is flagged as shown on the table below due to the uncertain source of the methylene chloride.

Compound Max. Blank Action Level Action Affected Samples Detected Cone, (ug/1) (ug/1)

Methylene 12 120 Elevate quantitation AE-10.AE-21, chloride limit to detected level; AE-22, SH-32S,

report as nondetect (U) SH-33S, SH-57S

Results from some of the resampled groundwaters, such as SH-57, show good agreement, suggesting the original methylene chloride analysis was unaffected.

Performance Evaluation Samples

Two performance evaluation samples (PES) were analyzed by Method 8260 in this SDG: one low level (PV151) and one low/medium level (V02046). Because the low and low/medium PES were handled and analyzed in the same manner, both with a 5 ml sample volume and no dilution, both PES are considered applicable to all groundwaters in this SDG. In the low PES, all nine target compounds present were within limits. In the low/medium sample, 8 of 12 targets were within limits. Chloroform scored warning low and 1,1,2-trichloroethane scored warning high. Per Region I guidance, no action is taken based on warning scores. Two targets scored action low: chloroethane and trichloroethylene. Positive detections of these compounds have been estimated due to possible low bias; nondetects have been rejected as unusable due to the possibility of false negatives.

Two additional compounds were reported by the lab as present, but scored as contaminants by EPA. No action was taken on either of these detections. Methylene chloride was reported at 2.8 ug/1, below the trip blank concentration which was used to determine the action level for methylene chloride. The other compound, cis-l,3-dichloropropene, was not detected in samples or blanks, and appears to be PES-specific.


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Compound Quantitation and Reported Quantitation Limits

Sample AE-21 RS contained methylene chloride at a concentration which exceeded calibration limits. The sample was reanalyzed at dilution to get that analyte on scale. Results for the methylene chloride in sample AE-21 RS should be reported from the diluted run, while all other analytes should be reported from the undiluted run which achieved lower quantitation limits. AE-21 RS was also the only resample which showed a significant difference from its original analysis. Methylene chloride and trichloroethylene in AE-21 RS were much higher than in AE-21. No analytical cause was identified for this difference. Interpretation is left to the end user, who should consider factors such as sample collection method (pump vs bailer) or other field conditions.

Target quantitation limits for groundwater were based on USEPA drinking water Maximum Contaminant Levels (MCLs) and on NHDES GW-1 criteria as shown on Table C.I of the 11/97 Work Plan (copy attached with the DQO summary form). Method 8260 analysis was supplemented with Method 504.1 to achieve quantitation limits below MCLs for ethylene dibromide (EDB) and l,2-dibromo-3-chloropropane (DBCP). EDB and DBCP were analyzed by both methods with different quantitation limits. When the 8260 run detected halogenated VOCs at elevated levels (relative to the 504.1 quantitation limit of 0.02 ug/1), the sample was not analyzed by Method 504.1. Only seven of the groundwater samples in this SDG could be analyzed by Method 504.1 for this reason. This is acceptable as an analytical limitation. The end user should determine whether the elevated quantitation limit from 8260 analysis for these two analytes affects data usability.

In addition, target quantitation limits were exceeded for 21 analytes in samples SH-56 and OW-230 due to dilutions required to get analytes on scale. The affected analytes are indicated on Table C.I, attached with the DQO form. In general these exceedences probably do not significantly affect data usability because elevated concentrations of other analytes are present. In some cases, however, such as use of one-half the quantitation limit to represent nondetects in a risk assessment, usability may be affected.

In this and other recent SDGs the laboratory reported sample results on two sets of forms: standard Form I's and signed result reports on NHDES letterhead. Concentrations reported on the two sets sometimes vary slightly, generally due to rounding. Laboratory personnel consider the results on letterhead to be the more accurate version. The software which generates the Form I's was new for this project, and it rounds/truncates differently than the lab's standard software. Letterhead results agree with raw data, while Form I's are sometimes slightly different due to software limitations. The data summarized on Table 3 was therefore taken from the letterhead versions of results.


Associates, Inc.

Please feel free to contact me at (413) 788-6222 if you have any questions regarding this validation.

Very truly yours,

Valerie D. Watanaoe

James D. Okun ) Principal

cc: D. Szaro / EPA QA (with all attachments) W. Ives / NHDES Site Manager (memo + tables only) J. DiLorenzo / EPA Site Manager (memo + tables only) P. Bickford / NHDES Lab (memo + tables only) D. Vorhees / Menzie-Cura (memo + tables only)

Attachments: Table 1: Recommendation Summary Table Table 2: Overall Evaluation of Data Table 3: Data Summary Tables (includes TICs) Data Validation Worksheets PES Score Reports (3) Communication/Phone Logs Field Sampling Notes Project Validation Criteria (QAPP Tables 6b, 8b, 6c and 8c) CSF Audit (DC-2 Form) DQO Summary Form


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TABLE 1: Recommendation Summary Table VOLATILE ORGANIC ANALYSIS (8260A and 504.1)

Beede Waste Oil/Cash Energy Site, SDG BW230

Sample Number

AE-3

AE-4

AE-5

AE-10

AE-10RS

AE-21

AE-21 RS

AE-22

AE-22 RS

SH-32I

SH-32S

SH-32S RS

SH-33S

SH-33S RS

SH-53S

SH-54S

SH-55S

SH-56S

SH-57S

SH-57S RS

SH-58S

OW-230

TB071598

TB072098

TB072198

TB072398

TB072798

Matrix

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Groundwater

Aq./ Trip blank

Aq./ Trip blank

Aq./ Trip blank

Aq./ Trip blank

Aq./ Trip blank

Recommended Qualifiers

PR1

PR1

PR1

R'U'

PR 1

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D1 P-4 R1

P R1 U1

PR1

PR 1

P-4 R1 U1

P." R1

P R1 U1

PR 1

P-4 R1

PR1

PR1

P.4 R1

J4 R1 U1

P.4 R1

PR1

P4 R1

PR1

R1

PR1

PR1

PR 1


' Associates, Inc.

D1 - Use results from diluted run for methylene chloride only. Value from the undiluted run exceeded calibration limits; quantitation is uncertain.

J1 - High percent difference for methyl t-butyl ether, 2-butanone and 1,2,3-trichloropropane in continuing calibration. J detects and UJ nondetects due to analytical variability.

J2 - High percent difference for 2-butanone and 1,2,3-trichloropropane in continuing calibration. J detects and UJ nondetects due to analytical variability

J3 - High percent difference for dichlorodifluoromethane, 2-butanone, 2,2-dichloropropane and tetrahydrofuran in continuing calibration. J detects and UJ nondetects due to analytical variability.

J4 - Estimate positive detection of trichloroethylene due to action low PES score. Results may be biased low.

R1 - Reject nondetects for chloroethane and/or trichloroethylene. PE sample scored action low for these analytes; nondetects may be false negatives.

U1 - Consider methylene chloride to be nondetect due to presence in sample and in trip blank at similar levels. Elevate quantitation limit to reported value.

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ochloromelhane

1 1,2-Dibrom

oethane | C

hlorobenzene

1

|cis-l,3-Dichloropropene

[Toluene

| trans-1 ,3 -Dichloropropene

1 1, 1,2-Trichloroethane Cb

Dichlorobrom

omethane

1 , 2-Dichloroethane CX o

Tetrahydrofuran

1,1,1-Trichloroethane

1,1 -Dichloropropene

2-Butanone

2, 2-Dichloropropane

cis-1 , 2-Dichloroethene

Chloroform

o

Chloroethane

Trichlorofluorom

ethane D

iethyl ether A

cetone 1, 1-D

ichloroethene M

ethylene chloride C

arbon disulfide M

ethyl t-butyl ether trans-1 , 2-D

ichloroethene

Dichlorodiiluorom

ethane C

hloromethane

Vinyl chloride

I

Method 8260 L

ab ID:

Date Sam

pled: D

ate Analyzed:

Dilution F

actor:

13 q -j f rn

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Associates, Inc. 19,1998 s. - semspub.epa.gov · provided with the BW212 memo dated 5/8/98. ......

Documents

Transcript of Associates, Inc. 19,1998 s. - semspub.epa.gov · provided with the BW212 memo dated 5/8/98. ......