QUALITY ASSURANCE PROJECT PLANt117.com/documents/2014-10/Appendix E_QAPP_30Nov2012.pdf · 2020. 5....

APPENDIX E QUALITY ASSURANCE PROJECT

PLAN

QUALITY ASSURANCE PROJECT PLAN ADJACENT STREETS AND RESIDENTIAL YARDS

LDW Superfund Site Terminal 117 Early Action Area

November 30, 2012

QUALITY ASSURANCE PROJECT PLAN

May 1, 2012, Pre-design Sampling and Addendum for May through July 2012 Additional Sampling Scope

Adjacent Streets and Residential Yards Study Area Lower Duwamish Waterway Superfund Site

Terminal 117 Early Action Area

Prepared for City of Seattle

700 Fifth Avenue Seattle, WA 98104

Prepared by

411 1st Avenue S.

Suite 550 Seattle, WA 98104

November 30, 2012

Revision History

Rev. Description Date By Reviewed

0 Draft Pre-design QAPP 2/13/2012 N. Varnum/K. Carlton L. Baker

1 Draft Final Pre-design QAPP 3/21/2012 K. Carlton L. Baker

2 Revised Draft Final Pre-design QAPP 9/26/2012 N. Varnum/K. Carlton L. Baker

3 Final Pre-design QAPP 10/26/2012 K. Carlton L. Baker

T-117Adjacent Streets and Residential Yards Pre-design Sampling Quality Assurance Project Plan November 30, 2012

SECTION A: PROJECT MANAGEMENT

A1 TITLE AND APPROVAL PAGE

QUALITY ASSURANCE PROJECT PLAN

PRE-DESIGN SAMPLING ADJACENT STREETS AND RESIDENTIAL YARDS STUDY AREA

SEATTLE, WASHINGTON

Integral Principal in Charge

Reid Carscadden, P.E. Date

Integral Project Manager Linda Baker, L.H.G. Date

Integral Technical Support Nick Varnum, L.G. Date

Integral QA Manager

Kimberly Magruder Carlton Date

EPA Project Manager Piper Peterson Date

EPA QA Manager Ginna Grepo-Grove Date

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A2 TABLE OF CONTENTS

LDW Superfund Site .............................................................................................................. A-i

SECTION A: PROJECT MANAGEMENT ................................................................. A-iv

A1 TITLE AND APPROVAL PAGE ........................................................................ A-iv A2 TABLE OF CONTENTS ....................................................................................... A-v

LIST OF FIGURES ............................................................................................................... A-vii

LIST OF TABLES .................................................................................................................. A-vii

ACRONYMS AND ABBREVIATIONS .......................................................................... A-viii

A3 DISTRIBUTION LIST ........................................................................................... A-x A4 BACKGROUND, PROBLEM DEFINITION, AND COMPLIANCE

DETERMINATION............................................................................................... A-1 A.4.1 Background ............................................................................................... A-4 A.4.2 Problem Definition .................................................................................. A-4 A.4.3 Compliance Determination .................................................................... A-6

A5 PROJECT TASK DESCRIPTION ........................................................................ A-6 A6 ORGANIZATION AND SCHEDULE................................................................ A-7

A.6.1 Task Organization .................................................................................... A-7 A.6.2 Schedule .................................................................................................. A-11

A7 QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA .................................................................................................................... A-12 A.7.1 Data Quality Objectives ........................................................................ A-12 A.7.2 Data Quality Indicators ......................................................................... A-13

A8 SPECIAL TRAINING/CERTIFICATION ........................................................ A-13 A9 DOCUMENTS AND RECORDS ....................................................................... A-13

SECTION B: DATA GENERATION AND ACQUISITION ................................... B-1

B1 SAMPLING DESIGN............................................................................................. B-1 B.1.1 Pre-design Supplemental Sampling ....................................................... B-1 B.1.2 Pre-removal Confirmation Sampling ..................................................... B-3 B.1.3 Field Screening and Post-excavation Sampling .................................... B-6 B.1.4 Geotechnical Testing ................................................................................ B-8

B2 SAMPLING METHODS ........................................................................................ B-8 B3 SAMPLE HANDLING AND CUSTODY ......................................................... B-10 B4 ANALYTICAL METHODS ................................................................................ B-10 B5 QUALITY CONTROL ......................................................................................... B-11

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B6 INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE ................................................................................................. B-11

B7 INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY .......... B-11 B8 INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES ....... B-12 B9 NON-DIRECT MEASUREMENTS .................................................................... B-12 B10 DATA MANAGEMENT ..................................................................................... B-13

B.10.1 Field Data ................................................................................................. B-13 B.10.2 Laboratory Data ...................................................................................... B-13

SECTION C: ASSESSMENT AND OVERSIGHT .................................................... C-1

SECTION D: DATA VALIDATION AND USABILITY .......................................... D-1

SECTION E: REFERENCES ........................................................................................... E-1

ATTACHMENTS Attachment F1. Response to March 30, 2012, USACE Comments on the March 21,

2012, Final Draft QAPP and Subsequent E-mail Correspondence on the QAPP

Attachment F2. May through July 2012 QAPP Addendum – Additional Scope Items

Attachment F3. Maps 2-7, 2-29, 2-30, and 2-36 from the EE/CA (Windward et al. 2010)

Attachment F4. Equations and Rules for Applying Upper Confidence Limit and Stratified Sampling

Attachment F5. CAS SOP – Subsampling and Compositing of Samples (Multi-increment)

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LIST OF FIGURES Figure A1. Pre-Removal Confirmation Sampling Design

Figure A2. Project Organization Chart

Figure B1. Process for Decision and Analysis of Archived Excavation Unit (EU) Confirmation Samples

LIST OF TABLES Table A1. Laboratory Methods for Soil Samples

Table A2. Analytes, Target Detection Limits, Method Detection Limits, and Method Reporting Limits for Soil Samples

Table A3. Laboratory Control Limits for Surrogate Recoveries in Soil Samples

Table A4. Laboratory Control Limits for Matrix Spike and Laboratory Control Samples in Soil Samples

Table A5. Measurement Quality Objectives

Table B1. Soil Sample Identification and Analysis Scheme for Adjacent Streets and ROW EUs—Point Samples and Composites

Table B2. Soil Sample Identification and Analysis Scheme for Residential Yards and Adjacent Street ROW DUs—MIS

Table B3. Sample Containers, Preservation, Holding Times, and Sample Volume

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ACRONYMS AND ABBREVIATIONS ARI Analytical Resources, Inc. ASAOC Administrative Settlement Agreement and Order on

Consent ASTM American Society for Testing and Materials bgs below ground surface CAS Columbia Analytical Services, Inc. CERCLA Comprehensive Environmental Response, Compensation

and Liability Act City City of Seattle DQI data quality indicator DQO data quality objective DU decision unit EAA early action area Ecology Washington State Department of Ecology EDD electronic data deliverable EE/CA engineering evaluation/cost analysis EPA U.S. Environmental Protection Agency EU excavation unit HSA hollow-stem auger HSP health and safety plan HSPA Harris & Smith Public Affairs Integral Integral Consulting Inc. LIMS laboratory information management system MIS multi-increment sampling MTCA Model Toxics Control Act NTCRA non-time-critical removal action PARCC precision, accuracy or bias, representativeness,

completeness, and comparability PCB polychlorinated biphenyl PCDD polychlorinated dibenzo-p-dioxin PCDF polychlorinated dibenzofuran Port Port of Seattle QAPP quality assurance project plan QA/QC quality assurance and quality control

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ROW right-of-way RvAL removal action level SOP standard operating procedure T-117 Terminal 117 TOC total organic carbon UCL upper confidence limit on the mean USACE U.S. Army Corps of Engineers X1 EU sample location X2 EU paired sample location

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A3 DISTRIBUTION LIST

EPA Project Manager: Piper Peterson EPA QA Manager Ginna Grepo-Grove

City of Seattle Project Coordinator: Mary Mitchener/Brett Richardson

Port of Seattle Project Manager: Ticson Mach Port of Seattle Project Coordinator: Roy Kuroiwa

Crete Technical Consultant Lead Grant Hainsworth Integral Technical Consultant Lead: Reid Carscadden

Integral Project Manager Linda Baker Integral Technical Support Nick Varnum

Integral Task Manager/QA Coordinator: Kim Magruder Carlton Integral Field Coordinator: Stefan Wodzicki

CAS Project Manager: Greg Salata CAS QA Manager: Lee Wolf

ARI Geotechnical Division Manager: Guenna Smith ARI QA Manager: Dave Mitchell

EcoChem Data Validation and Verification Specialist: Christine Ransom

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A4 BACKGROUND, PROBLEM DEFINITION, AND COMPLIANCE DETERMINATION

The City of Seattle (City) and the Port of Seattle (Port) are currently performing a non-time-critical removal action (NTCRA) at the Terminal 117 (T-117) early action area (EAA) under the authority of the Administrative Settlement Agreement and Order on Consent (ASAOC) for the T-117 EAA removal action implementation pursuant to the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA; USEPA 2011). The City is the lead in performing tasks that address the Adjacent Streets and Residential Yards portion of the NTCRA EAA.

This quality assurance project plan (QAPP) describes site investigation activities required for final design and implementation of the cleanup. These investigation activities include sampling and analysis for polychlorinated biphenyls (PCBs) and total solids at decisions units (DUs) and excavation units (EUs). DUs are areas that were characterized by multi-increment sampling (MIS) techniques and include most residential yards and some street rights-of-way (ROWs). EUs are in the streets and the ROW planting strips (previously referred to as parking strips) along S. Cloverdale Street; they include removal areas that were characterized by point samples. EUs and DUs are shown on Figure A1.

This QAPP is a revised version of the March 21, 2012, draft final QAPP. Revisions are based on comments from the U.S. Army Corps of Engineers (USACE) dated March 30, 2012, and subsequent related e-mails on responses to these comments through May 1, 2012. The comments and the responses to the comments are provided in Attachment F1. Sampling was completed in April and early May 2012, in accordance with the draft final QAPP as modified based on agreements documented in the correspondence in Attachment F1. Finalizing the QAPP was deferred to allow for focus on the sampling effort and subsequent additional scope items. This final, revised QAPP incorporates the agreements in correspondence through May 1, 2012.

An addendum to this QAPP has been prepared that addresses additional scope items completed in late May, June, and July 2012. These additional scope items were added based upon results from the April and early May 2012 sampling, and include sampling of alleyways. The May through July 2012 additional scope addendum is provided as Attachment F2. Appendix G of the RADR reports the results of analyses through the additional scope of sampling for residential yards, alleyways, and planting strips along South Cloverdale Street. A data report for the results of street EU and ROW DU sampling described in this QAPP is in preparation and will be submitted separately from the data report in RADR Appendix G, as part of the design for remediation of the street EUs and ROWs DUs. Another QAPP addendum has also been prepared that describes supplemental pre-excavation confirmation analyses for dioxins/furans. Considered together, these documents support the remediation design for the streets

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and yards adjacent to T117. It should be noted that the primary QAPP text does not address all of the elements that are described in subsequent documents listed above.

The investigation activities described in this QAPP build upon previous QAPPs for the investigation of PCBs and polychlorinated dibenzo-p-dioxin and polychlorinated dibenzofuran (PCDD/PCDF) contamination in soil (Integral 2008) and boundary refinement of PCB contamination in adjacent streets and residential yards (Integral 2009a,b). The basis for this sampling program is presented in the revised engineering evaluation/cost analysis (EE/CA; Windward et al. 2010) and the U.S. Environmental Protection Agency’s (EPA’s) subsequent action memorandum (USEPA 2010). This QAPP includes the following elements (for supplemental investigations completed in May through July 2012 and not listed here, see Attachment F2):

• Supplemental MIS approach for the backyards of 1418 S. Donovan Street and 1425 S. Cloverdale Street, where soils adjacent to a DU designated for removal (DU25 and DU35) have not been characterized (see Figure A1), as described in the EE/CA (Windward et al. 2010, Section 7.1.2)

• Pre-removal confirmation sampling approach in residential yard DUs designated for removal to minimize delays and associated disturbance to the local residents during construction (EE/CA; Windward et al. 2010, Section 7.1.2)

• Pre-removal confirmation sampling approach for adjacent street EUs to minimize community disruption during construction

• Rationale for postponing the development of confirmation sampling of the S. Donovan Street ROW hill slope until the design phase for the adjacent streets

• Geotechnical sampling and testing approach to support design for grade separation and stabilization of the slope along the S. Donovan Street ROW

• The approach for sampling in the event that area(s) of contamination are identified during the removal action based on field observations at the removal area boundary (post-removal sampling).

Total PCB concentrations will determine the extent of the excavation prisms in the Adjacent Streets and Residential Yards study area. Removal actions will be completed in the Adjacent Streets and Residential Yards study area where total PCB concentrations exceed the removal action level (RvAL) as discussed below.

Samples will be analyzed for PCB concentrations sequentially with depth. The first sample that passes the PCB criteria outlined in this QAPP will delineate the excavation depth and a portion of this sample will be held for PCDD/PCDF analysis should EPA and the Washington State Department of Ecology (Ecology) decide analysis is necessary. For each DU, an aliquot of the MIS sample will be held for PCDD/PCDF and total solids analysis; for street EUs, a sufficient portion of the two applicable composite samples will



be retained for PCDD/PCDF and total solids analysis. For the planting strip EUs, equal amounts from the three to five discrete samples at the passing depth will be composited into one sample that will be held for potential PCDD/PCDF and total solids analysis. Samples will be held until EPA directs that they either be analyzed or discarded.

Areas within the Adjacent Streets and Residential Yards are subdivided into three groups based on land use characteristics and historical sampling strategies. The areas and associated sampling and data evaluation approaches are as follows:

• Decision Units (DUs): Residential yards and ROW DUs have similar residential-like exposure scenarios, have been previously characterized by MIS, and will be sampled with MIS techniques during the 2012 field event. Removals will occur where total PCB concentrations in DUs exceed the RvAL of 1.0 mg/kg. A remediation level for total PCBs of 0.50 mg/kg is used to define portions of the yards to be removed, based on the confirmation sampling design using single MIS samples per unit. The 0.50 mg/kg remediation level for total PCBs was developed from an evaluation of variability in triplicate MIS samples previously collected from DUs and discussed in Appendix L of the EE/CA (Windward et al. 2010).1 Excavation is planned for the whole DU to the specified depth.2

• Street Excavation Units (street EUs): Street EUs are largely paved, have a typical street exposure, and have been previously sampled with point or composite sampling techniques. Street EUs will be sampled with composite sampling techniques during the 2012 field event as described in Section B2. The total depth of excavation will be determined by the depth where street EU results as a whole meet the Model Toxics Control Act (MTCA) three-part rule in compliance with the RvAL of 1.0 mg/kg as described in Section B.1.2. Depths of removal may vary between street EUs, but will be consistent within each street EU as indicated in Section B.1.2.

• Planting Strip Excavation Units (planting strip EUs): Planting strip EUs are narrow grassy areas between the sidewalk and street on either side of S. Cloverdale Street with the potential for residential exposures. Planting strip EUs have been previously characterized by point sampling and will be evaluated with point samples during the 2012 field event. The depth of excavation will be the depth where total PCB concentrations in all point samples in a given planting strip EU are less than 1.0 mg/kg.

1 Note that where triplicate MIS samples were initially collected, allowing a direct calculation of a UCL on the mean, some DUs with reported PCBs above the 0.50 mg/kg remediation level are not identified for cleanup because the UCL is still less than the PCBs RvAL of 1.0 mg/kg (see EE/CA, Appendix L). 2 For three DUs (DU25a, DU25b and DU35a), excavation will not be completed if the upper two sampling intervals (0.2 and 0.5 ft) do not exceed the RvAL as defined by the upper confidence limit on the mean (UCL) (see Section B.1.1). With single MIS samples, a remediation level of 0.50 mg/kg will be applied for these decisions.



As outlined in the EE/CA (Section 4.4.3), cleanup in the Adjacent Streets and Residential Yards study area will be guided by the following decision rules:

• Total PCB concentrations are the driver for streets and yards cleanup

• Cleanup will occur where total PCB concentrations exceed the RvAL of 1.0 mg/kg as outlined above and as discussed in detail in Section B.1.2

• Wherever PCB cleanup occurs, co-located PCDD/PCDFs will also be removed.

The results of this investigation will be detailed in two separate field data reports: One for the Residential Yards study area, which includes residential yards and planting strips; and one for the Adjacent Streets and Right-of-ways study area, which includes streets and ROWs. Pre-design and supplemental sampling results will be incorporated into the design of the excavation prisms for the adjacent streets and yards.

The following documents are referenced for details that remain unchanged from previous investigations:

• T-117 QAPP (Windward et al. 2003)

• Investigation of Potential PCDD/PCDF Contamination in Soil, City Street Rights-of-Way and Residential Yards, QAPP (Streets and Yards QAPP; Integral 2008)

• April 2009 T-117 QAPP Addendum for Adjacent Streets Boundary Refinement (Integral 2009a)

• July 2009 T-117 QAPP Addendum Phase 2 for Adjacent Streets Boundary Refinement (Integral 2009b).

The referenced information in these previous documents is still relevant and applicable to the work presented in this QAPP.

A.4.1 Background

Background information for the site can be found in the EE/CA (Windward et al. 2010) and the Streets and Yards QAPP (Integral 2008). Selected maps from the EE/CA showing previous sampling locations and total PCB concentrations are included in Attachment F3.

A.4.2 Problem Definition

This QAPP is intended to guide three activities: 1) supplemental MIS where soils adjacent to a DU designated for removal have not been characterized, 2) pre-removal confirmation sampling within the Adjacent Streets and Residential Yards excavation areas, and 3) geotechnical testing of the hill slope along the S. Donovan Street ROW to support remedial design for road grade separation. In addition, the QAPP outlines



general sampling procedures should areas of contamination be identified during the removal action based on field observations at the removal area boundary (post-removal sampling).

Areas identified in the EE/CA for supplemental MIS include the backyards of 1418 S. Donovan Street and 1425 S. Cloverdale Street (adjacent to DU25 and DU35, respectively) and the uncharacterized portion of the hill slope along the S. Donovan Street ROW (surrounded by DUs designated for removal). This QAPP describes supplemental MIS for the areas adjacent to DU25 and DU35 (designated DU25a, DU25b, and DU35a). Supplemental MIS for the uncharacterized portion of the hill slope along the S. Donovan Street ROW is being deferred. This supplemental sampling, along with sampling to confirm the removal depth in the surrounding DUs (DU18, DU19, DU27, DU28, and DU29) will be defined in the design phase for the adjacent streets removal. The final sampling design will allow for incorporation of geotechnical data and consideration of the excavation requirements for the selected road improvements in this area (to be determined).

The pre-confirmation sampling outlined in this QAPP for the residential yards and adjacent streets will minimize disruption to local residents and businesses. Having the excavation depths fixed prior to construction precludes the need for and the delays associated with post-construction sampling (e.g., sample collection, laboratory testing, and decision making) and expedites the removal action by having known areas and volumes. A defined process for sampling unexpected contamination during removal, as outlined in this plan, will also minimize disruption.

The sampling objectives of this investigation are as follows:

• Verify that total PCB concentrations directly below the DUs identified for removal in residential yards are below the DU remediation level by conducting MIS at the currently planned excavation depth.

• Provide supplemental characterization of total PCB concentrations in soil samples from DU25a, DU25b, and DU35a for the following purposes:

– To determine if removal is necessary: MIS will be completed at depths of 0 to 0.2 ft and 0.2 to 0.5 ft, and the MIS samples will be analyzed. If the sample concentration of either depth exceeds the 0.50 mg/kg DU remediation level, then a removal will be completed in the DU. If concentrations of both depths are below 0.50 mg/kg, then a removal will not be completed in the DU.

– To determine the depth of removal in DUs where a removal is necessary: Pre-excavation confirmation samples will be collected at the planned depth of excavation in the supplemental DUs. Where sample concentrations in the planned excavation depth interval indicate a removal action is necessary, the subsurface samples will be analyzed sequentially with depth to determine



the depth of removal. Samples will continue to be analyzed with increasing depth until the resulting concentration is below the 0.50 mg/kg DU remediation level.

• Verify that total PCB concentrations directly below planned EUs in adjacent streets are below the RvAL by collecting multipoint sample composites at incremental depths below the currently planned excavation depth.

• Collect and archive samples from additional depth intervals down to a depth of 3 ft below the current planned excavation depth at all locations to be analyzed in the event the total PCB concentrations at the planned excavation depth exceeds the RvAL. This precludes the need to resample if exceedances are found at the planned excavation depths.

• Address geotechnical sampling and analyses to support design of the grade separation between upper and lower S. Donovan Street (sampling to be deferred until design phase).

In addition, the QAPP outlines contingency sampling procedures in the event that field observations identify contaminated soil during excavation. Details of the sampling program are presented in Section B.1.

A.4.3 Compliance Determination

Compliance with the total PCB RvALs will be determined for the adjacent street EUs, planting strip EUs, and residential yard DUs using a tiered approach for analyzing samples collected at intervals below the proposed excavation prisms. Details of this approach are provided in Section B.1.

A5 PROJECT TASK DESCRIPTION

The tasks to be completed for this investigation include fieldwork, laboratory chemical and geotechnical analyses, data quality evaluation, data management, data analysis, and reporting. Tasks that will be completed in the field, including related documentation and quality assurance and quality control (QA/QC) activities, as well as sample handling, laboratory analyses, and data management are described in Section B of this QAPP. Project assessment and oversight procedures are referenced in Section C, and procedures relating to data validation and determination of usability are referenced in Section D of this QAPP. Where procedures have not changed from previous QAPPs for the adjacent streets and residential yards, text from previous QAPPs is either reiterated in this document or incorporated by reference.



A6 ORGANIZATION AND SCHEDULE

This section presents the organizational structure and schedule for activities associated with this investigation.

A.6.1 Task Organization

Integral Consulting Inc. (Integral) is performing this investigation on behalf of the City, in coordination with the Port and EPA. The organizational structure and associated contact information for this investigation are presented in Figure A2.

Regulatory Agency Management

EPA Project Manager—Piper Peterson from EPA is the remedial project manager with responsibility for overseeing the implementation of the T-117 NTCRA. All submittals associated with this investigation will be delivered to the EPA remedial project manager.

EPA QA Manager—Ginna Grepo-Grove is the EPA QA Manager.

EPA Community Outreach Lead—Kendra Tyler is EPA’s community outreach coordinator for the investigation work. Ms. Tyler will implement EPA-related tasks associated with contacting affected property residents and owners regarding property access and the implications of sampling activities on the use of their properties.

USACE Technical Consultants—Leanna Woods Pan and Jayson Osborne from USACE will support EPA with implementation of technical aspects of this investigation.

City and Port Management

City Project Manager—Brett Richardson was the City’s project coordinator during spring and summer 2012 sampling activities; Mary Mitchener is the City’s current project coordinator and primary City point of contact for the T-117 NTCRA ongoing investigation activities. Mr. Richardson/Ms. Mitchener will coordinate with Mr. Roy Kuroiwa, who is the program manager on behalf of the Port of Seattle and the designated lead project coordinator for the T-117 NTCRA.

Integral Project Personnel

Principal in Charge—Reid Carscadden, P.E., is Integral’s principal in charge. Mr. Carscadden will provide project oversight and direction, and ensure the investigation work is consistent with the T-117 NTCRA project as a whole.

Project Manager—Linda Baker, L.H.G., is Integral’s project manager and main point of contact for the Streets and Yards portion of the T-117 NTCRA. Ms. Baker will have responsibility for the overall implementation of the investigation. Her duties include



planning and coordination of the investigation, and overseeing and reviewing all project deliverables for completeness, accuracy, and quality. In the event that changes in the QAPP are needed, Ms. Baker will ensure that proposed changes are coordinated with the City’s project coordinator.

Integral Technical Support—Nick Varnum, L.G., will provide technical guidance in support of the sampling design, data analysis, and data reporting tasks of this investigation. Mr. Varnum will ensure consistency with previous work in the Streets and Yards.

Project QA Coordinator/Task Manager—Kimberly Magruder Carlton is the QA coordinator and field task manager. She is responsible for planning and supporting the field investigation, and providing overall QA oversight for field collection, sample analysis, and data reporting activities. Ms. Magruder Carlton will provide overall direction to the testing laboratory and data validation specialist.

Field Coordinator/MIS Specialist—Stefan Wodzicki is the field coordinator and MIS specialist for the investigation. Mr. Wodzicki will be responsible for all aspects of field sampling activities including field sampling preparation and contracting and overseeing the drilling subcontractor. He is also responsible for ensuring that appropriate sampling, QA, and documentation procedures are used throughout sample collection.

Project Data Manager—Gerald Palushock is the project data manager. Mr. Palushock will have primary responsibility for data management and database maintenance. Mr. Palushock will work with the field crew to ensure field data entries are correct and complete, and he will work with the QA coordinator to ensure that the data are delivered in the correct format for entry into the Integral project database and ensure correct and efficient entry of data qualifiers. Mr. Palushock will also be responsible for developing and maintaining the integrity and completeness of the database and for providing various data summaries to data users for interpretation.

Integral Project Subcontractors

Harris & Smith Public Affairs

Harris & Smith Public Affairs (HSPA) is the City’s community outreach coordinator for the investigation work. HSPA will implement City-related tasks associated with contacting affected property residents and owners regarding property access and the implications of sampling activities on the use of their properties. Barbara Harris is the lead for HSPA.



Columbia Analytical Services, Inc.

The following responsibilities apply to the project manager and QA manager at Columbia Analytical Service, Inc. (CAS), the analytical laboratory that will be used for this investigation.

Laboratory Project Manager—Greg Salata, Ph.D., is the laboratory project manager. He is responsible for the successful and timely completion of sample analyses, as well as the following actions:

• Ensuring that samples are received and logged in correctly, that the correct methods and modifications are used, and that data are reported within specified turnaround times

• Reviewing analytical data to ensure that procedures were followed as required in this QAPP, the cited methods, and laboratory standard operating procedures (SOPs)

• Keeping the Integral QA coordinator apprised of the schedule and status of sample analyses and data package preparation

• Notifying the Integral QA coordinator if problems occur in sample receiving, analysis, or scheduling, or if control limits cannot be met

• Taking appropriate corrective action as necessary

• Reporting data and supporting QA information as specified in this QAPP.

Laboratory QA Manager—Lee Wolf is the laboratory QA manager. He is responsible for overseeing the QA activities in the laboratory and ensuring the quality of the data for this task. Specific responsibilities include the following:

• Overseeing and implementing the laboratory’s QA program

• Maintaining QA records for each laboratory production unit

• Ensuring that QA/QC procedures are implemented as required for each method and providing oversight of QA/QC practices and procedures

• Reviewing and addressing or approving nonconformity and corrective action reports.

Analytical Resources, Inc.

The following responsibilities apply to the project manager and QA manager at Analytical Resources, Inc. (ARI), the geotechnical laboratory that will be used for this investigation.



Laboratory Project Manager—Guenna Smith is the manager of ARI’s Geotechnical Division. She is responsible for the successful and timely completion of sample geotechnical analyses, as well as the following actions:

• Ensuring that samples are received and logged in correctly, that the correct methods and modifications are used, and that data are reported within specified turnaround times

• Reviewing analytical data to ensure that procedures were followed as required in this QAPP, the cited methods, and laboratory SOPs

• Keeping the Integral QA coordinator apprised of the schedule and status of sample analyses and data package preparation

• Notifying the Integral QA coordinator if problems occur in sample receiving, analysis, or scheduling, or if control limits cannot be met

• Taking appropriate corrective action as necessary

• Reporting data and supporting QA information as specified in this QAPP.

Laboratory QA Manager—Dave Mitchell is the laboratory QA manager. He is responsible for overseeing the QA activities in the laboratory and ensuring the quality of the data for this task. Specific responsibilities include the following:

• Overseeing and implementing the laboratory’s QA program

• Maintaining QA records for each laboratory production unit

• Ensuring that QA/QC procedures are implemented as required for each method and providing oversight of QA/QC practices and procedures

• Reviewing and addressing or approving nonconformity and corrective action reports.

EcoChem, Inc.

Christine Ransom of EcoChem, Inc., will be performing data validation and verification. Ms. Ransom is responsible for verifying the accuracy of the laboratory electronic data deliverables (EDDs) (i.e., verifying that analytical procedures and calculations were completed correctly and checking transcriptions of the laboratory data), validating the laboratory data, communicating any data quality issues to the Integral QA coordinator, and working with the QA coordinator to address any data limitations. The data validation and verification specialist will work closely with the Integral QA coordinator to ensure that the objectives of this QAPP are met.

Cascade Drilling, Inc.

Cascade Drilling, Inc., of Woodinville, Washington, will be contracted to work with the Integral field crew to accomplish the aspects of this investigation that call for subsurface



push-probe soil sampling. Cascade personnel will work closely with the Integral task manager/field coordinator to ensure that the objectives of this QAPP are met.

A.6.2 Schedule

A preliminary schedule for this investigation, beginning with the submittal of this QAPP through submittal of the draft field data reports, is outlined in the following table.

Milestone Completion Date

Draft Final QAPP to EPA March 21, 2012

Obtain Access Agreements April 6, 2012

Begin Field Sampling April 16, 2012

Sample Analysis—Yards April 20–June 7, 2012

Final Data Package from Laboratory June 25, 2012

Data Validation Complete July 23, 2012

Sample Analysis—Streets May 9–June 15, 2012

Final Data Package from Laboratory July 5, 2012

Data Validation Complete August 2, 2012

Draft Field Data Report to EPA (Residential Yards study area)

August 14, 2012

Draft Field Data Report to EPA (Adjacent Streets and Right-of-ways study area)

60 days after approval of final data report for Residential Yards study area

All samples proposed in this QAPP are scheduled to be collected during one field event. Additional supplemental sampling events were completed based on the results of the sampling scope outlined in this QAPP. These additional investigations completed in May through July 2012 are described in Attachment F2. Field sampling will include sample collection from test holes in streets, ROWs, and residential yards where owners and tenants have submitted signed access agreements. The schedule is dependent upon the following:

• EPA meeting the document review schedule in support of the agreed upon expedited schedule to accomplish yards removal in 2012

• The City being able to obtain property access agreements by the date specified in the table

• The laboratory meeting expedited turnaround times (10 calendar days) for PCB analyses assumes the samples will be relatively low in percent fines and free of matrix interferences



• The base of the excavation being defined by analysis of three or fewer depth intervals analyzed in succession

• The duration of the field sampling activities is anticipated to be 25 working days, or 5 weeks. If any of the above tasks/conditions are not met or DUs/EUs require analyses of a fourth depth interval, the schedule will need to be extended accordingly.

A7 QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA

Data quality objectives (DQOs) and quality control criteria related to PCBs are described in this section. DQOs related to PCDD/PCDF are discussed in Appendix H to the Removal Action Design Report. Data quality indicators (DQIs) such as the PARCC parameters (precision, accuracy or bias, representativeness, completeness, and comparability) (USEPA 2002) and analytical sensitivity will be used to assess conformance of data with quality control criteria and are described later in this section.

A.7.1 Data Quality Objectives

The goal of this QAPP is to ensure that data collected for this investigation are technically defensible. Establishing DQOs assures that data generation and sampling will be focused on the goals of the remedial action and will be sufficient to address those goals. Collected data will be evaluated relative to the DQOs and quality assurance objectives described below. These DQOs have been prepared in accordance with USEPA (2006) and Ecology (1995) guidance.

Statement of Problem

The problem definition is presented in Section A4.

Goal of Study

The objectives of this investigation are presented in Section A4.2.

Information Inputs

The information inputs associated with this investigation are presented in Section A5.

Study Boundaries

This investigation will occur within the removal action area boundary for the T-117 adjacent streets and residential yards defined in the EE/CA (Windward et al. 2010) and action memorandum (USEPA 2010).



Sample Collection Design

The sample collection design is presented in Section B.

Analytical Approach and Performance/Acceptance Criteria

Laboratory analysis will be conducted using EPA-approved analytical methods (Table A1). Method reporting limits for this investigation are provided in Table A2. Laboratory QA/QC will meet method requirements specified in this QAPP or as referenced by this QAPP (Tables A3 and A4).

The site-specific RvAL per the EE/CA (Windward et al. 2010) is 1.0 mg/kg for total PCBs, with a remediation level of 0.50 mg/kg total PCBs for DUs where single MIS sample designs are used. Laboratory detection and reporting limits are identified in Table A1 and are well below these concentrations.

Geotechnical samples will be analyzed for moisture content, grain size, Atterberg limits, bulk density, and triaxial shear strength. Geotechnical laboratory testing procedures will be conducted in accordance with methods of the American Society for Testing and Materials (ASTM).

A.7.2 Data Quality Indicators

The overall DQO for this project is to develop and implement procedures that will ensure the collection of representative data of known and acceptable quality. The QA procedures and measurements that will be used for this investigation are based on EPA guidance (USEPA 2001, 2002) and are described in detail in Section A7.2 of the Streets and Yards QAPP (Integral 2008). Measurement quality objectives that will be used in evaluating the quality of the data are provided in Table A5.

A8 SPECIAL TRAINING/CERTIFICATION

Training requirements for personnel participating in sample collection can be found in the T-117 QAPP (Windward et al. 2003). Integral’s 2009 site health and safety plan (HSP; Integral 2009c) will be used for this sampling effort. The Integral project manager will ensure that the field team receives the final approved version of this QAPP, supporting information from all QAPPs referenced in this document (Windward et al. 2003; Integral 2008, 2009a,b), and the site HSP prior to the initiation of field activities.

A9 DOCUMENTS AND RECORDS

Records will be maintained documenting all activities and data related to field sampling and chemical analyses. Results of data verification and validation activities will also be



documented. Procedures for documenting field observations, laboratory records, and data reduction can be found in the T-117 QAPP (Windward et al. 2003). Copies of field sampling forms to be used during this investigation are included in Attachment 1 of the Streets and Yards QAPP (Integral 2008) and Attachment 1 to the April 2009 QAPP addendum (Integral 2009a).



SECTION B: DATA GENERATION AND ACQUISITION

This section presents the sampling design and sampling methods. Details regarding decontamination procedures, field-generated waste disposal, sample handling and custody, inspection/acceptance requirements for supplies and consumables, and data management can be found in the T-117 QAPP (Windward et al. 2003). SOPs are provided in Attachment 1 of previous QAPPs (Integral 2008, 2009a,b).

B1 SAMPLING DESIGN

This sampling design describes approaches and methods for 1) collecting supplemental site characterization samples in the residential areas adjacent to DU25 (DU25a and DU25b) and DU35 (DU35a), 2) pre-removal confirmation sampling within the Adjacent Streets and Residential Yards excavation areas, and 3) geotechnical testing of the hill slope between upper and lower S. Donovan Street to support design for grade separation.

The following sections present a summary of the sampling design, collection areas, and analytical approach for the above-described investigation activities. Sample locations are shown in Figure A1.

B.1.1 Pre-design Supplemental Sampling

The EE/CA (Windward et al. 2010, Section 7.1.2) identified two residential yards and one ROW area adjacent to DUs designated for removal for supplemental sampling in order to investigate soil conditions within those areas.

Protocols for sampling DUs will comply with protocols used in previous site investigations (Integral 2009a,b). Exclusion criteria include driveways, parking areas, areas under buildings, decks or any other structure, unusual uses of a parcel or portion of the parcel, and limited access areas between structures (case-by-case as determined in consultation with EPA). If locations cannot be sampled “in the vicinity” of an initial 30-location MIS sample in a residential DU (due to tree roots or buried debris, etc.), additional “makeup” locations within the initial grid layout will be selected as needed to ensure at least a 28-location MIS composite sample. In addition, the surface soil intervals (e.g., 0- to 0.2-ft and 0.2- to 0.5-ft) of supplemental MIS samples will be analyzed for total organic carbon (TOC), in accordance with previous MIS surface soil investigations at the site.

The supplemental sampling areas DU25a, DU25b, and DU35a (adjacent to DU25 and DU35) will vary slightly from those identified in the EE/CA as discussed below. The

Integral Consulting Inc. B-1


supplemental sampling in the S. Donovan Street ROW will be deferred as discussed below.

DU35a—1425 S. Cloverdale Street

Concentrations in the front yard of 1425 S. Cloverdale Street (DU35) exceeded the RvAL and thus the EE/CA called for sampling of the backyard (DU35a). However, a building was erected on DU35a sometime between November 2007 and May 2009 that covers approximately 90 percent of the area identified in the EE/CA for sampling. The only remaining portion of the yard accessible for sampling is a small area in the southeast corner of the yard that extends south of the shed adjacent to the alley, and wraps around to the west of the shed (see Figure A1).

Supplemental sampling at DU35a will include collection of soil from the 0- to 0.2-ft and 0.2- to 0.5-ft depth intervals using MIS methodology per the 2009 QAPP addenda (Integral 2009a,b). These samples will be analyzed for PCBs, TOC, and total solids per the Streets and Yards QAPP (Integral 2008). In addition, pre-removal confirmation samples will be collected from this DU as discussed in Section B.1.2.

DU25a and DU25b—1418 S. Donovan Street

Concentrations in the front yard of 1418 S. Donovan Street (DU25) exceeded the RvAL and thus the EE/CA called for sampling of the backyard (DU25a and DU25b). The area adjacent to DU25 has been subdivided into two portions (DU25a and DU25b) as shown on Figure A1. Backyards in the study area have not previously been subdivided into two DUs because the backyards are assumed to be consistent throughout the yard. However, per EPA’s request since publication of the EE/CA, the backyard at DU25 has been subdivided to include a small DU adjacent to the alley. The side yards and the main backyard closer to the house is DU25b, and the back portion of the yard alongside the shed and adjacent to the alley is DU25a.

Supplemental sampling at DU25a and DU25b will include collection of soil from the 0- to 0.2-ft and 0.2- to 0.5-ft depth intervals using MIS methodology per the 2009 QAPP addenda (Integral 2009a,b). These samples will be analyzed for PCBs, TOC, and total solids per the Streets and Yards QAPP (Integral 2008). In addition, pre-removal confirmation samples will be collected from these DUs as discussed in Section B.1.2.

ROW—S. Donovan Street

The uncharacterized area on the hillside separating upper and lower S. Donovan Street ROW is adjacent to DU18, DU19, DU27, DU28, and DU29 (refer to EE/CA Map 2-30, Windward et al. 2010), which are all designated for removal. Given that all surrounding DUs in the S. Donovan Street ROW exceed the total PCB RvAL and require excavation, the hillside slope will likely need to be excavated to approximately the same depth due



to its high angle. Geotechnical testing described in Section B.1.4 and input from the Seattle Department of Transportation is needed to develop a final configuration for this area. As such, it is recommended that an approach for supplemental and confirmation sampling for the hill slope be developed following these necessary inputs.

B.1.2 Pre-removal Confirmation Sampling

As identified in the EE/CA, pre-removal confirmation sampling will be performed in the residential yards to minimize both the removal action construction timeframe and any impact to residents that would otherwise occur during post excavation sampling (e.g., time to collect and process samples, time period associated with laboratory analytical turnaround time, potential tiered analysis, and subsequent redesign of the excavation prism). For the same reasons, pre-excavation confirmation sampling will also be conducted in the adjacent streets. Post-removal soil sampling will be completed only where unanticipated contaminated soil is encountered during excavation at the boundary of an excavation unit (based on field screening; see Section B.1.3).

In the event that data evaluations described below show non-compliance at the depth defined for removal areas in the EE/CA, specific actions to extend the depth of planned soil excavations will be taken. In the case of street EUs and planting strips, the depth of the excavation will be extended on a unit-by-unit basis until compliance is achieved. For residential yard and ROW DUs, extended depths, if necessary, include the entire DU and not subareas of a DU.

Figure A1 shows excavation depths for residential and ROW DUs and EUs in the Adjacent Streets, ROWs, and planting strips. Maps summarizing the EE/CA data for PCBs in adjacent streets and residential yards are provided in Attachment F3.

The following sections describe the pre-excavation confirmation sampling approach for EUs and DUs.

Excavation Units in Adjacent Streets

The nature and extent characterization of the adjacent streets includes more than 350 point samples at 90 locations (Figure A1). For EE/CA purposes, excavation prisms were conservatively designed and extend, on average, 1.5 ft below the known vertical extent of total PCB RvAL exceedances.

The removal area boundary was delineated by identifying samples with total PCB concentrations greater than 1.0 mg/kg. To accommodate the reconstruction of the streets, all areas within the removal boundary will be excavated to a depth of at least 1 ft and extend across the street to the edges of the ROWs. This area was further defined by dividing the area within the removal boundary into manageable EUs based on areas



with similar depths of impact. The EU removal depths were then established one to two feet below the deepest observed impacts as discussed in the EE/CA. For example:

• 1.0 ft impact depth = assumed 2.0 ft excavation depth

• 2.0 ft impact depth = assumed 4.0 ft excavation depth

• 4.0 ft impact depth = assumed 6.0 ft excavation depth.

As part of the ongoing design work, it was found that final excavation depths for the EUs did not get incorporated into the final draft for Maps 7-1 and 7-2 of the EE/CA (Windward et al. 2010). As a result, the excavation depths shown in Figure A1 differ from the EE/CA maps for EU2, EU5, EU6, and EU9. A final adjustment was made to incorporate non-EU areas between EU9 and EU10 and between EU8 and EU9. The non-EU areas are now included with the adjacent EUs such that the boundaries of EU9 and EU10 extend to the midpoint of the non-EU area. A similar adjustment was made for the non-EU area between EU8 and EU9. While the EE/CA maps differ somewhat from Figure A1, the areas, volumes, and associated costs presented in the EE/CA utilized the proposed excavation depths that are now presented in Figure A1. Figure A1 is the accurate version of the EE/CA proposed excavation depths for all areas. Borehole data analyzed late in the EE/CA process resulted in the adjustment of the excavation depth for DU19, and thus was not reflected in the EE/CA area, volumes, and costs. Because DU19 is part of the S. Donovan Street hill slope area, it is not addressed in this QAPP.

The proposed sampling strategy for the EUs draws on previous confirmation sampling conducted at the site during the T-117 time-critical removal action (RETEC 2006) with respect to sample density and compositing; as such, samples will be collected on a 2,500 ft2 grid and composited within each EU. In the six EUs with an area less than 2,500 ft2, a minimum of two sample locations were selected. This design results in two to six sample locations per EU, depending on the EU size. In order to evaluate compliance with the PCBs RvAL of 1.0 mg/kg for the street EUs as a whole, a UCL on the mean will be calculated. Two independent composite samples for each street EU will be collected and used to give estimates of variability for each street EU, which are part of the UCL calculation based on a stratified sampling design with unequal strata sizes. The method for selection of the sampling locations within street EUs is described in Section B2. The resulting sample locations are shown in Figure A1. Discrete samples, sample composites, and field QA samples (when applicable) to be collected from each EU are provided in Table B1. The presence of underground utilities may necessitate moving sample locations a few feet from the determined locations. Sampling location changes will be documented in the field data report.

A tiered analytical approach has been developed to provide sufficient data for the evaluation of compliance using the criteria prescribed by the MTCA three-part rule (Ecology 1995):



• (i) The 95 percent UCL of the true population mean (average) of all adjacent street confirmation samples must be less than the RvAL3

• (ii) No sample concentration (based on the average of two composite samples per street EU) can be more than two times the RvAL

• (iii) Less than 10 percent of the total street EU area can exceed the RvAL.

The analytical approach is as follows:

• Composites will be prepared for each 0.5 ft depth interval collected within each EU (in the field by combining equal volumes of soil from each point sample collected at a given depth interval across the EU). Two composites representing independent sample location layouts will be prepared for each EU (Figure A1).

• The topmost depth interval (0 to 0.5 ft below the planned excavation depth) composites for each EU will be analyzed for PCBs.

• Results from the analysis of PCBs in the topmost composites will be evaluated using the criteria prescribed by the MTCA three-part rule (Ecology 1995). If these are determined to meet the compliance requirements prescribed by the MTCA guidance (Ecology 1995), the planned design depth will be considered the final design basis for the removal and in compliance with the RvAL and no further analyses of archived confirmation samples will be conducted. If the topmost interval fails to meet the MTCA compliance requirements, PCB analysis of successive underlying increments will be performed until the conditions meet the compliance requirements.

• Figure B1 provides a flow diagram of how the MTCA requirements will be applied to the adjacent street EUs. Attachment F4 provides the equations that will be used to calculate the 95 percent UCL and describes how rules (ii) and (iii) above will be applied.

Planting Strips

The planting strips on the north and south sides of S. Cloverdale Street have been identified for removal. These areas have different exposure scenarios than streets and are therefore treated separately. Three to five individual samples will be collected based on the planting strip size (Figure A1 and Table B1). The total removal depth for each planting strip EU will be the depth where all sample results are below the 1.0 mg/kg RvAL.

3 The data being used for the UCL calculation at 13 street EUs represent the post-excavation surface, at different depths below ground surface in different EUs.



Decision Units in Residential Yards and ROWs

As previously noted, pre-confirmation samples for the residential yards and certain ROW areas will be collected and analyzed using the MIS methodology established during the EE/CA. Current planned excavation depths of the DUs range from 1 to 3 ft below ground surface (bgs). Soil samples will be collected in 0.5-ft intervals starting at and down to a depth of 3 ft below the elevation of the planned excavation prism floor. Therefore, sample depths will range from 4 to 6 ft bgs. To achieve these depths, a small GeoprobeTM (Model M420), or comparable rig, will be used. Sample collection and processing is the same as with direct push sampling described in the April 2009 QAPP addendum (Integral 2009a) except that the machine that powers the direct push probe weighs less than 400 lb and is configured similar to that of a hand truck. Therefore, vehicular access to the yards is not necessary and site disturbance and noise is minimized.4 As per the 2009 MIS, 30–35 sample locations will be identified for each DU. Samples will be composited in the field per sample interval (e.g., from 0.5 to 1.0 ft below the excavation level identified in the QAPP) per MIS methodology (Integral 2009a).

DU20 and DU21 located in the ROW of 16th Avenue S. are adjacent DUs identified for removal. The original premise for the two DUs was that the DU nearer the street may be more contaminated. Because the data indicate that this area is fairly homogenous, the two DUs will be combined for the purposes of confirmation sampling. This confirmation DU is identified as DU20/21.

Pre-removal confirmation sampling will be conducted at a total of 12 DUs as shown in Figure A1. The depth intervals and sample identifiers for each of the 12 DUs are provided in Table B2 and include samples designated for laboratory QA samples.

The tiered approach for analysis of the depth increments will be similar to that described above for EUs. If the topmost MIS result exceeds the total PCB remediation level, the next lower sample(s) will be analyzed until the concentration is below the remediation level, and this depth will be established as the removal depth.

The remediation level for total PCBs of 0.5 mg/kg will apply to DU20/21 based on the analysis of variance in Appendix L of the EE/CA and the RvAL for total PCBs of 1.0 mg/kg.

B.1.3 Field Screening and Post-excavation Sampling

If contamination is identified based on field observations during the removal action at the removal area boundary, then sampling will be completed to document conditions,

4 Details on the Geoprobe Model M420 can be found at the following web site: http://geoprobe.com/products/machines/42_series/420mdesc.htm



and if feasible extend the removal. During removal action excavation activities, exposed soils will be visually monitored for evidence of contamination, and as appropriate supplemented with field screening techniques including, but not limited to visual observation, sheen testing, and olfactory evidence of hydrocarbons (utilizing the association between PCBs and oil at this site). SOPs for these techniques are included in Attachment 1 of previous QAPPs (Integral 2008, 2009a,b). If these methods identify areas of potential soil contamination at the planned removal boundary, additional evaluation will be completed to address contaminated soil if feasible. If screening indicates contamination exists at the boundary of the excavation, soil will be removed during the excavation process until field evidence is absent, if feasible. If any additional potential contamination is identified in the excavation areas during soil removal (e.g., buried drums, discoloration of soils, unusual odors, etc.), and extends to the boundary of the planned removal area, cleanup work within the immediate vicinity of the potential contamination will be suspended and EPA will be notified.

Further excavation will not be considered feasible if the area of impact is extensive, extending beyond the study area, significantly into adjacent properties within the study area, into properties where contamination is being addressed through other administrative orders (e.g., South Park Marina and Basin Oil), to the water table, or to depths that would compromise surrounding structures. In these cases, EPA will be contacted prior to backfilling to confirm the decision process, samples will be collected to document remaining conditions and analyzed for PCBs, and any precautions necessary to prevent recontamination of clean fill will be implemented as outlined in design documents (e.g., demarcation layer, plastic sheeting).

Additional excavation beyond the lateral boundaries of the EU or DU will be evaluated on a case-by-case basis. Where further excavation of contaminated soil based on field evidence is completed, post-removal confirmation sampling will be conducted, whereby the bottom extent of the additional excavation will be sampled for PCBs on a 5-ft grid with a minimum of two samples and these samples will be composited for laboratory analysis and compared to the total PCB RvAL (i.e., 1.0 mg/kg). Similarly, where additional horizontal excavation is completed, sidewalls of the additional excavation will be sampled on a 5-ft grid.

In the event that areas of potential soil contamination are found below the current excavation prisms and additional excavation is required, the goal will be to minimize the amount of time the excavation remains open; however, the actual time will depend on the nature of the potential contamination and the size and location of the excavation. The soil confirmation sample composites described above will be analyzed on a rush turnaround time of 24 hours using ultrasonic extraction. The current PCB Soxhlet extraction procedure used for the T-117 investigations would result in a minimum of 48 hours for data results. In order to obtain laboratory results within 24 hours, the laboratory will extract the soil samples using an ultrasonic extraction procedure (EPA



Method 3550C) rather than the Soxhlet extraction procedure. This method entails sonicating 30 g of soil in a three serial extraction process. Method reporting limits for this extraction process are the same as the Soxhlet extraction procedure (EPA Method 3541), which are two orders of magnitude below the PCB RvAL (i.e., 1.0 mg/kg). The advantage in using the ultrasonic extraction over Soxhlet extraction for excavation related sampling is that it minimizes delays and associated disturbance to the local residents during construction. This soil extraction method would be used only for samples requiring PCB analysis during the removal action; it will not be used for the pre-confirmation sampling.

B.1.4 Geotechnical Testing

Geotechnical sampling for laboratory testing will be conducted to obtain engineering properties of the soils below the hill slope between upper and lower South Donovan Street.

Four borings located at the base of the slope will be advanced to a depth of up to 20 ft bgs by hollow stem auger (HSA). Two borings located at the top of the slope will be advanced up to 30 ft bgs. Proposed geotechnical sample locations are shown in Figure A1.

Geotechnical laboratory testing will be conducted on selected split spoon samples collected at 5-ft intervals (5, 10, 15, and 20 ft bgs for borings located at the bottom of the slope, and 25 and 30 ft bgs for borings located at the top of the slope) to obtain geotechnical index properties (e.g., specific gravity, water content, Atterberg limits, grain size distribution, and bulk density).

Triaxial shear strength testing will be conducted on up to four samples to evaluate the range of shear strength in soil. Shear strength samples will be collected with thin-walled Shelby tubes.

B2 SAMPLING METHODS

All sampling methods will follow procedures presented in the Streets and Yards QAPP (Integral 2008) and April 2009 QAPP Addendum (Integral 2009a), with the following exceptions:

• EU soil borings will be collected from locations associated with the removal prism with the first interval beginning at the elevation of the excavation floor. These borings will have sample depth intervals of 0.5 ft and extend as deep as 3 ft below the designed excavation floor. The methodology for push-probe sampling is described in the Streets and Yards QAPP (Integral 2008). If the sampler does not recover enough material for analysis, then an additional probe



hole will be advanced to collect missing intervals within 1 to 2 ft of the original location. Sampling location changes will be documented in the field data report.

• Individual EU sample locations will be established in a random fashion as follows:

– Measure along the roadside edge of an EU (parallel to traffic flow).

– Divide by the number of samples per composite (varies by EU, approximately uniform sampling density), getting “segment length.”

– Using a random number between 0 and 1, locate the first transect in first segment of the EU from an end-point of the measured length.

– Identify additional transect locations at distances equal to the segment length (this provides for “spatial coverage” over the EU and still preserves equal probability sampling given a random first transect location).

– Using random numbers between 0 and 1, identify the sampling locations on each transect based on the fraction of the full cross-road distance—all distances starting from the same measured side line.

– The second composite would follow the same procedures but with a new randomly defined initial transect location, and new randomly determined cross-road distances along each transect. Tables of random 0 to 1 interval values can be generated in the office and taken to the field.

The above describes the approach for rectangular EUs. L-shaped EUs (e.g., EU9 in Figure A1) will be divided into approximately rectangular areas, and one part will be “rotated” to show how to get a single edge measurement that will cover the entire EU, with no missing or duplicated portions. The net result is that transect lines will occur across the EU in multiple directions, with a goal of having them maximally drawn across the street width (conceptually preferred, given possible crowning of street surfaces and traffic lanes for truck trackout of PCBs). Additional details of the sample location procedure are provided in Attachment F1.

• A similar approach will be used to identify discrete sampling locations for the S. Cloverdale Street ROW (planting strip) areas. Randomly selecting locations across (short) transects will result in samples at different distances in from the street, rather than all at the same distance.

• DU samples will be collected using MIS techniques as described in the April 2009 QAPP addendum Integral (2009a) and a Geoprobe™ Model M420, or comparable rig, will be used as described above in Section B.1.2.

• Sample recovery will be based on the volume recovered in the Geoprobe sample tube—as measured by the length of the entire sample recovered. If the sampler is advanced 3 ft (six intervals), then at least 75 percent or 2.25 ft must be recovered, and that recovered length would be split into six equal intervals for



collecting the six-sample intervals. In addition, if fewer than 28 of the MIS samples have at least 75 percent recovery, additional random locations will be selected for sampling so that there is a minimum of 28 sample locations with greater than 75 percent recovery in the MIS composite sample.

• Samples for geotechnical testing will be collected by HSA as described in Section B.1.4. Details for HSA sampling are provided in SOP SL-07 (provided in Attachment 1 of previous QAPPs [Integral 2008, 2009a,b]).

• Boreholes located in paved areas (streets) will be backfilled with bentonite chips to within 1 ft of the surface and hydrated. For residential yards, planting strips, and ROWs, the boreholes will be backfilled with clean sand. For boreholes in planters or other garden areas, the top 6 inches of the borehole will be filled with topsoil.

B3 SAMPLE HANDLING AND CUSTODY

All sample handling and custody will follow procedures presented in the Streets and Yards QAPP (Integral 2008) and April 2009 QAPP addendum (Integral 2009a), except for sample homogenization procedures for street and planting strip EU samples. Street and planting strip samples will undergo homogenization at the laboratory per the MIS compositing and subsampling procedures.

The laboratory’s SOP for subsampling and compositing of MIS samples from the April 2009 QAPP is provided as Attachment F5. Per previous sampling events, all unused sampling material will be archived for each sample collected and laboratory MIS subsampling will be employed for all samples analyzed. Sample containers, preservation, and holding times are presented in Table B3.

B4 ANALYTICAL METHODS

Samples collected for this investigation will be analyzed for chemical constituents, conventional parameters, and geotechnical properties as described in Section B1. Analytical methods for PCBs, TOC, and total solids will be in accordance with analytical methods referenced in the Streets and Yards QAPP (Integral 2008) and April 2009 QAPP addendum (Integral 2009a). PCDD/PCDF analysis, if needed, will be completed using Soxhlet extraction, sulfuric acid cleanup, silica/carbon column cleanup, and analysis by EPA 1613B (HRGC/HRMS). PCDD/PDCF analytical protocol information is provided in Appendix H to the Removal Action Design Report. Samples designated for archival (Tables B1 and B2) will be held frozen at (–20°C) in glass jars at the analytical laboratory until EPA directs that they either be analyzed or discarded.



Geotechnical laboratory testing for specific gravity, water content, Atterberg limits, grain size distribution, bulk density, and triaxial shear strength will follow ASTM methods as follows:

• Specific gravity—ASTM D854-10 for samples consisting of particles less than 4,750 micron diameter; ASTM C127 for samples consisting of particles greater than 4,750 micron diameter.

• Water content—ASTM D2216-10

• Atterberg limits—ASTM D4318-10

• Grain size distribution—ASTM D422-63(2007)

• Bulk density—ASTM D7263-09

• Triaxial shear strength—ASTM D4767-11 (consolidated, undrained) and ASTM D2850-07 (unconsolidated, undrained).

B5 QUALITY CONTROL

QC procedures, field QA/QC sampling, and sample identification will follow the Streets and Yards QAPP (Integral 2008) and April 2009 QAPP Addendum (Integral 2009a). QA/QC samples are identified in Tables B1 and B2. For this QAPP, field splits of samples collected in EUs and planting strip ROWs will not be included in the data evaluation (e.g., will not be included in the averages calculated for the EU) and will be used only as field QA samples.

B6 INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE

Analytical instrument testing, inspection, maintenance, setup, and calibration will be conducted by the laboratory in accordance with the requirements identified in the laboratory’s SOPs and manufacturer instructions. In addition, each of the specified analytical methods provides protocols for proper instrument setup and tuning, and critical operating parameters. Instrument maintenance and repair will be documented in maintenance log or record books.

B7 INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY

Laboratory instruments will be properly calibrated, and the calibration will be verified with appropriate check standards and calibration blanks for each parameter before beginning each analysis. Instrument calibration procedures and schedules will conform



to analytical protocol requirements and descriptions provided in the laboratory’s QA plans.

All calibration standards will be obtained from either the EPA repository or a commercial vendor, and the laboratory will maintain traceability back to the National Institute of Standards and Technology. Stock standards will be used to make intermediate standards and calibration standards. Special attention will be given to expiration dating, proper labeling, proper refrigeration, and prevention of contamination. Documentation relating to the receipt, mixing, and use of standards will be recorded in a laboratory logbook. All calibration and spiking standards will be checked against standards from another source.

B8 INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES

The quality of supplies and consumables used during sample collection and laboratory analysis can affect the quality of the project data. All equipment that comes into contact with the samples and extracts must be sufficiently clean to prevent detectable contamination, and the analyte concentrations must be accurate in all standards used for calibration and QC purposes.

During sample collection, solvents of appropriate, documented purity will be used for decontamination. Solvent containers will be dated and initialed when they are opened. The quality of laboratory water used for decontamination will be documented at the laboratory. Certified pre-cleaned sample containers will be provided by the laboratory. All containers will be visually inspected prior to use, and any suspect containers will be discarded.

Reagents of appropriate purity and suitably cleaned laboratory equipment will also be used for all stages of laboratory analyses. Details for acceptance requirements for supplies and consumables at the laboratory are provided in the laboratory SOPs and QA plan (Streets and Yards QAPP, Attachments 2 and 3; Integral 2008). All supplies will be obtained from reputable suppliers with appropriate documentation or certification. Supplies will be inspected to confirm that they meet use requirements, and certification records will be retained by Integral (i.e., for supplies used in the field) or the laboratory.

B9 NON-DIRECT MEASUREMENTS

Existing chemical data from previous site characterization efforts have been reviewed to assist in identifying pre-design sampling locations, as referenced herein. All data reviewed were evaluated for data quality.



B10 DATA MANAGEMENT

Data for this project will be generated in the field and at the laboratory. The final repository for sample information for the sample collection efforts described will be an Integral project database and the T-117 EE/CA project database. Procedures used to transfer data from the point of generation to the Integral project database are described in this section. Final data will be presented and summarized in tables in the field data reports.

B.10.1 Field Data

Data that are generated during field activities will be manually entered into the field log books, sampling forms, tables, or chain-of-custody forms. Data from these sources will be entered into the Integral project database directly from the field inspection report form or chain-of-custody forms, as needed. These data include station location coordinates, station names, sampling dates, sample identification codes, and additional station and sample information (e.g., sample type, field replicate number). All entries will be reviewed for accuracy and completeness by a second individual, and any errors will be corrected before the data are approved for release to data users.

B.10.2 Laboratory Data

A variety of manually entered and electronic instrument data will be generated at CAS and ARI. Data are manually entered into:

• Storage temperature logs

• Balance calibration logs

• Instrument logs

• Sample preparation and analysis worksheets

• Maintenance logs

• Individual laboratory notebooks

• Results tables for conventional analyses (e.g., total solids).

All manual data entry into CAS’s and ARI’s laboratory information management system (LIMS) is proofed at the laboratory. All data collected from each laboratory instrument, either manually or electronically, are reviewed and confirmed by analysts before reporting. At CAS and ARI, the sample information is electronically loaded to temporary files in LIMS and submitted for further review. Forms IV to X for validated data packages are generated in the laboratory and reviewed for correctness in interpretation, conformance with QA requirements, and completeness. Once the data have been accepted, the final results are released to the LIMS for reporting. The LIMS is



used to generate the EDD as well as Forms I to III for the data package, providing a single source for reporting of chemical data. The EDD is further spot-checked against the hard copy to ensure that the correct data set is reported for both. Detailed descriptions of procedures for laboratory data management and data review and verification are provided in each laboratory’s QA plans (CAS—Attachment 3 of Integral, 2008; ARI—http://www.arilabs.com/portal/downloads/lqap.pdf).



SECTION C: ASSESSMENT AND OVERSIGHT

Procedures for assessment and oversight are defined in the original T-117 QAPP (Windward et al. 2003), are applicable to the work outlined in this QAPP, and will be followed.

Integral Consulting Inc. C-1


SECTION D: DATA VALIDATION AND USABILITY

The validation of results is discussed in the Streets and Yards QAPP (Integral 2008). This procedure is fully applicable to the work specified in this QAPP, and EcoChem will perform a full validation of all results as described in the Streets and Yards QAPP (Integral 2008).

Integral Consulting Inc. D-1


SECTION E: REFERENCES

Ecology. 1995. Guidance on Sampling and Data Analysis Methods. Publication No. 94-49. Washington State Department of Ecology Toxics Cleanup Program. January 1995.

Integral. 2008. City of Seattle streets and residential yards T-117 Early Action Area, investigation of potential PCDD/PCDF contamination in soil – quality assurance project plan. Prepared for City of Seattle. Integral Consulting Inc., Mercer Island, WA. August 14, 2008.

Integral. 2009a. Lower Duwamish Waterway Superfund Site, Terminal 117 Early Action Area. Quality Assurance Project Plan Addendum – Adjacent Streets PCB Boundary Refinement. Prepared for the City of Seattle and Port of Seattle. Integral Consulting Inc., Seattle, WA. April 17, 2009.

Integral. 2009b. Lower Duwamish Waterway Superfund Site, Terminal 117 Early Action Area. Quality Assurance Project Plan Addendum – Adjacent Streets PCB Boundary Refinement, Phase 2. Prepared for the City of Seattle and Port of Seattle. Integral Consulting Inc., Seattle, WA. July 10, 2009.

Integral. 2009c. Lower Duwamish Waterway Superfund Site, Terminal 117 Early Action Area. Site Health and Safety Plan – Adjacent Streets PCB Boundary Refinement. Prepared for the City of Seattle and Port of Seattle. Integral Consulting Inc., Seattle, WA. April 15, 2009.

RETEC. 2006. Time-Critical Removal Action Work Plan, Terminal 117 Seattle, Washington. Prepared by The RETEC Group, Inc., Seattle, Washington for the Port of Seattle, Seattle, WA. September 11, 2006.

USEPA. 2001. EPA requirements for quality assurance project plans. EPA QA/R-5. EPA/240/B-02/003. U.S. Environmental Protection Agency, Office of Environmental Information, Washington, DC.

USEPA. 2002. Guidance for quality assurance project plans. EPA QA/G-5. EPA/240/R-02/009. U.S. Environmental Protection Agency, Office of Environmental Information, Washington, DC.

USEPA, 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process. EPA QA/G-4. EPA/240/B-06/001. U.S. Environmental Protection Agency, Office of Environmental Information, Washington, DC.

USEPA. 2010. Action Memorandum for a Non-Time-Critical Removal Action at the Terminal 117 Early Action Area of Lower Duwamish Waterway Superfund Site, Seattle,

Integral Consulting Inc. E-1


Washington. Addressed to Daniel D. Opalski, Director, Office of Environmental Cleanup from Piper Peterson Lee, Superfund Project Manager. September 30, 2010.

USEPA. 2011. Administrative settlement agreement and order on consent for removal action, Lower Duwamish Waterway Superfund Site Terminal 117 Early Action Area, Seattle, Washington. U.S. EPA CERCLA Docket No. 10-2011-0089. June 9, 2011. U.S. Environmental Protection Agency, Region 10, Seattle, WA.

Windward, DOF, and Onsite. 2003. Lower Duwamish Waterway Superfund Site, Terminal 117 Early Action Area. Quality assurance project plan. Prepared for the Port of Seattle. Windward Environmental LLC, Dalton, Olmsted & Fuglevand, Inc., and Onsite Enterprises, Inc., Seattle, WA.

Windward, AECOM, Crete, Integral, and DOF. 2010. Lower Duwamish Waterway Superfund Site, Terminal 117 Early Action Area. Revised engineering evaluation/cost analysis. Final. Prepared for the Port of Seattle and the City of Seattle. Windward Environmental LLC, Seattle, WA; AECOM, Seattle, WA; Crete Consulting, Inc., Seattle, WA; Integral Consulting Inc., Seattle, WA; and Dalton, Olmsted & Fuglevand, Inc., Seattle, WA.

Integral Consulting Inc. E-2

FIGURES

T-117 Upland

Boeing South Park

Basin Oil

South Park MarinaDU011

DU032

DU141

DU162

DU173

DU20/212

DU252

DU25a

DU322

DU352

B

B

B

B

B

B

Confirmation sampling of hillslope areadeferred to 60% design phase

1425

D

C

DU25b

DU35a

B

A

C

D

C

B

A

B

A

CC

B

AA

EB

AD

C

AB

B

A

A

B AB

F

E

D

C

BA

B

A

BCBEDA

B

A

B

PS South B2

EU22

EU54

EU84

EU105

EU13

EU92

EU71

EU124

EU46

EU112

EU34

EU66

EU132

PS North A1

PS North B2

PS North C1

PS South A1 A

A

A

B

A

A

B CAB

B

A

A

E

D

C

B

A

AA

F

E

D

CBA

BA

CAACB

GT-5

GT-1 GT-2 GT-4

GT-6

GT-3

1415 1417 1421 1429 1445

1412 14181426 1430 1438 1442 1446 1450

1433

8620

86178602

8609

8601

8603

1410 1412 1420 1424 1440

8529

85258523

85198500

Figure A1Pre-Removal Confirmation Sampling Design

0 50 10025

Feet

Note: Street and planting strip excavation unit point samples are shownfor illustration purposes. Actual locations will be determined in the fieldper Section B2.

Background imagery is for reference purposes only, courtesy of theCity of Seattle and dated 2009.

Dallas Ave S

17th

Ave

S

16th

Ave

S

S Cloverdale St

S Donovan St

14th

Ave

S

Excavation Unit Confirmation Point for Composite Sample (X1)


Planting Strip Discrete Sample Location

Geotechnical Boreholes

T-117 EAA Boundary

Residential Yard Decision Units (MIS Confirmation)

Right-of-way Decision Units (MIS Confirmation)

Decision Units Identified for Supplemental Sampling

Adjacent Street Excavation Units

Planting Strip Excavation Units

Tax parcels

Buildings with addresses2574

S:\s

e\A

0006

_Low

er-D

uwam

ish_

Vario

us\A

0006

_15H

_T11

7\P

rodu

ctio

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60pc

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ign\

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Sam

p_10

1120

12.m

xd 1

0/19

/201

2 1

2:10

:34

PM

EU/DU 993

Location IdentificationExcavation Depth (ft bgs)

XX

Confirmation Point Sample

Figure A2. Project Organzation Chart

Brett Richardson

Project CoordinatorCity of Seattle

206-233-7224

Piper PetersonProject Manager

EPA206-553-4951

Ginna Grepo-GroveQA Manager

EPA206-553-1632

Technical ConsultantsUSACE

Leanna Woods Pan206-764-3322

Jayson Osborne206-764-3521

Reid CarscaddenPrincipal in Charge

Integral Consulting Inc.206-957-0350

Linda BakerProject Manager


Nick VarnumTechnical Support

Northwest Envrionmental Solutions503-349-0841

Kim Magruder-CarltonTask Manager/

Project QA CoordinatorIntegral Consulting Inc.

360-756-9296

Gerald PalushockProject Data ManagerIntegral Consulting Inc.

206-957-0331

Jaymen LauerDrilling SubcontractorCascade Drilling Inc.

425-485-8908

Stefan WodzickiField Coordinator


Christine RansomData Validator

Eco Chem, Inc.206-233-9332, ext. 109

Greg SalataLaboratory Project Manager

Columbia Analytical Services, Inc.713-266-1599 or 800-695-7222

Guenna SmithGeotechnical Lab Division Manager

Analytical Resources, Inc.206-695-6246

Field Crew(to be determined)

Lee WolfLaboratory QA Manager

Columbia Analytical Services, Inc.800-695-7222

Dave MitchellLaboratory QA Manager

Analytical Resources, Inc.206-695-6205

Kendra TylerCommunity Outreach

EPA206-553-0041

Barbara SmithCommunity Outreach

Coordinator Harris & Smith Public Affairs

206-343-0250

Mary Mitchener206-324-9530

Figure B1. Process for Decision and Analysis of Archived

Excavation Unit (EU) Confirmation Samples

EU Composite analysis (2 composites per EU)

Does the composite

average exceed x2 the RvAL?

Analyze next depth interval of EUs with

average concentrations >2x RvAL


average concentrations > RvAL


higher average

Complete

Do composite averages exceed RvAL over more

than 10 percent of the total street EU

Is calculated Adjacent Street

UCL>RvAL?

Yes

Yes

Yes

No

No

No

TABLES

T-117 Quality Assurance Project PlanPre-design Sampling November 30, 2012

Integral Consulting Inc. Page 1 of 1

Table A1. Laboratory Methods for Soil Samples

Sample PreparationQuantitative

AnalysisProtocol Procedure Protocol Procedure

Conventional Analyses CAS KelsoTotal solids -- -- EPA 160.3M BalanceTotal organic carbon EPA 9060A Acid pretreatment EPA 9060A Combustion; colorimetric titration

PCB Aroclors CAS Kelso EPA 3541/EPA 3550a Soxhlet extraction/sonicationa EPA 8082A GC/ECD (dual column)EPA 3665A Sulfuric acid cleanupEPA 3630C Silica gel cleanup (optional)EPA 3660B Sulfur cleanup

Notes:CAS = Columbia Analytical Services EPA = U.S. Environmental Protection AgencyPCB = polychlorinated biphenyl

a Sample extraction Method 3550 (sonication) will only be used for samples requiring PCB analysis during construction activities.

Analysis Laboratory



Analyte Target Detectin Limit MDL MRLa

Total solids (percent of whole weight) * 0.01 0.01Total organic carbon (percent) * 0.02 0.05

Aroclor 1016 0.01 0.0017 0.01Aroclor 1221 0.02 0.0017 0.02Aroclor 1232 0.01 0.0017 0.01Aroclor 1242 0.01 0.0017 0.01Aroclor 1248 0.01 0.0017 0.01Aroclor 1254 0.01 0.0017 0.01Aroclor 1260 0.01 0.0017 0.01

Notes:MDL = method detection limitMRL = method reporting limitPCB = polychlorinated biphenyl

* Target detection limit has not been established.a The MRL is provided on a dry-weight basis and assumes 50 percent moisture in the samples. The MRL for project samples will vary with moisture content in the samples. The MRL generally represents the level of lowest calibration standard (i.e., the practical quantitation limit).

Table A2. Analytes, Target Detection Limits, Method Detection Limits, and Method Reporting Limits for Soil Samples

Conventional Analyses

PCB Aroclors, mg/kg dry wtb,c

b Expected MDLs are shown. c Target detection limits are based on the laboratory's reporting limits. The laboratory will report any detections below the MRL with a "J" estimated qualifier.



Control Limits forPercent Recovery

PCB AroclorsDecachlorobiphenyl 33-153Tetrachloro-m -xylene 21-142

Notes:

PCB = polychlorinated biphenyl

Table A3. Laboratory Control Limits for Surrogate Recoveries in Soil Samples

Surrogate Compound

Control limits are updated periodically by the laboratories. Control limits that are in effect at the laboratory at the time of analysis will be used for sample analysis and data validation. These may differ slightly from the control limits shown in this table.



Accuracy PrecisionMatrix Spike LCS Control Limit

Recovery (percent) Recovery (percent) Type of Duplicate RPD

Conventional AnalysesTotal organic carbon 75-125 85-115 LD 20Total solids NA NA LD 20

PCB AroclorsAroclor 1016 39-145 26-163 LD 40Aroclor 1260 51-146 24-171 LD 40

Notes:

LCS = laboratory control sampleLD = laboratory duplicateNA = not applicableRPD = relative percent difference

Table A4. Laboratory Control Limits for Matrix Spike and Laboratory Control Samples in Soil Samples

Analysis

Control limits are updated periodically by the laboratories. Control limits that are in effect at the laboratory at the time of analysis will be used for sample analysis and data validation. These may differ slightly from the control limits shown in this table.



Table A5. Measurement Quality Objectives

Pre-excavation Sampling

Post-excavation Sampling

Bias Precision Completeness Completenessa

(percent) (RPD) (percent) (percent)

Conventional parameters 75–125 ±35 100 95PCB Aroclors 50-150 ±50 100 95

Notes:a Where compositing produces a single sample result, the completeness objective is 100 percent.

PCB = polychlorinated biphenylRPD = relative percent difference

Analysis




Excavation Unita Boring ID

Sample Interval from Each

Boring (ft bgs) Sample IDPCB

Aroclorsb Archive Notes

Street Samplesc

NA CS-EU-EB XFilter wipe (drilling

equipment wipe prior to sample collection)

EU1 A1, B1 3.0-3.5 CS-EU1-X1-3.5 X XExcavation depth 3 ft bgs A1, B1 3.5-4.0 CS-EU1-X1-4.0 X

A1, B1 4.0-4.5 CS-EU1-X1-4.5 XA1, B1 4.5-5.0 CS-EU1-X1-5.0 XA1, B1 5.0-5.5 CS-EU1-X1-5.5 XA1, B1 5.5-6.0 CS-EU1-X1-6.0 XA2, B2 3.0-3.5 CS-EU1-X2-3.5 X XA2, B2 3.5-4.0 CS-EU1-X2-4.0 XA2, B2 4.0-4.5 CS-EU1-X2-4.5 XA2, B2 4.5-5.0 CS-EU1-X2-5.0 XA2, B2 5.0-5.5 CS-EU1-X2-5.5 XA2, B2 5.5-6.0 CS-EU1-X2-6.0 X

EU2 A1, B1, C1, D1, E1, F1 2.0-2.5 CS-EU2-X1-2.5 X XExcavation depth 2 ft bgs

A1, B1, C1, D1, E1, F1 2.0-2.5 CS-EU2-X1-2.5-FW XFilter wipe (processing

equipment cross contamination check)

A1, B1, C1, D1, E1, F1 2.5-3.0 CS-EU2-X1-3.0 XA1, B1, C1, D1, E1, F1 3.0-3.5 CS-EU2-X1-3.5 XA1, B1, C1, D1, E1, F1 3.5-4.0 CS-EU2-X1-4.0 XA1, B1, C1, D1, E1, F1 4.0-4.5 CS-EU2-X1-4.5 XA1, B1, C1, D1, E1, F1 4.5-5.0 CS-EU2-X1-5.0 XA2, B2, C2, D2, E2, F2 2.0-2.5 CS-EU2-X2-2.5 X XA2, B2, C2, D2, E2, F2 2.5-3.0 CS-EU2-X2-3.0 XA2, B2, C2, D2, E2, F2 3.0-3.5 CS-EU2-X2-3.5 XA2, B2, C2, D2, E2, F2 3.5-4.0 CS-EU2-X2-4.0 XA2, B2, C2, D2, E2, F2 4.0-4.5 CS-EU2-X2-4.5 XA2, B2, C2, D2, E2, F2 4.5-5.0 CS-EU2-X2-5.0 X



A2, B2 NA CS-EU3-X2-FW XFilter wipe (drilling equipment cross

contamination check)EU4 A1, B1 6.0-6.5 CS-EU4-X1-6.5 X XExcavation depth 6 ft bgs A1, B1 6.5-7.0 CS-EU4-X1-7.0 X








Aroclorsb Archive NotesEU5 A1, B1, C1, D1, E1 4.0-4.5 CS-EU5-X1-4.5 X XExcavation depth 4 ft bgs A1, B1, C1, D1, E1 4.0-4.5 CS-EU55-X1-4.5 X Field homogenization split

A1, B1, C1, D1, E1 4.5-5.0 CS-EU5-X1-5.0 XA1, B1, C1, D1, E1 5.0-5.5 CS-EU5-X1-5.5 XA1, B1, C1, D1, E1 5.5-6.0 CS-EU5-X1-6.0 XA1, B1, C1, D1, E1 6.0-6.5 CS-EU5-X1-6.5 XA1, B1, C1, D1, E1 6.5-7.0 CS-EU5-X1-7.0 XA2, B2, C2, D2, E2 4.0-4.5 CS-EU5-X2-4.5 X XA2, B2, C2, D2, E2 4.5-5.0 CS-EU5-X2-5.0 XA2, B2, C2, D2, E2 5.0-5.5 CS-EU5-X2-5.5 XA2, B2, C2, D2, E2 5.5-6.0 CS-EU5-X2-6.0 XA2, B2, C2, D2, E2 6.0-6.5 CS-EU5-X2-6.5 XA2, B2, C2, D2, E2 6.5-7.0 CS-EU5-X2-7.0 X

EU6 A1, B1 6.0-6.5 CS-EU6-X1-6.5 X XExcavation depth 6 ft bgs

A1, B1 6.0-6.5 CS-EU6-X1-6.5-FW XFilter wipe (processing


A1, B1 6.5-7.0 CS-EU6-X1-7.0 XA1, B1 7.0-7.5 CS-EU6-X1-7.5 XA1, B1 7.5-8.0 CS-EU6-X1-8.0 XA1, B1 8.0-8.5 CS-EU6-X1-8.5 XA1, B1 8.5-9.0 CS-EU6-X1-9.0 XA2, B2 6.0-6.5 CS-EU6-X2-6.5 X XA2, B2 6.5-7.0 CS-EU6-X2-7.0 XA2, B2 7.0-7.5 CS-EU6-X2-7.5 XA2, B2 7.5-8.0 CS-EU6-X2-8.0 XA2, B2 8.0-8.5 CS-EU6-X2-8.5 XA2, B2 8.5-9.0 CS-EU6-X2-9.0 X



EU8 A1, B1, C1, D1 4.0-4.5 CS-EU8-X1-4.5 X XExcavation depth 4 ft bgs A1, B1, C1, D1 4.5-5.0 CS-EU8-X1-5.0 X

A1, B1, C1, D1 5.0-5.5 CS-EU8-X1-5.5 XA1, B1, C1, D1 5.5-6.0 CS-EU8-X1-6.0 XA1, B1, C1, D1 6.0-6.5 CS-EU8-X1-6.5 XA1, B1, C1, D1 6.5-7.0 CS-EU8-X1-7.0 XA2, B2, C2, D2 4.0-4.5 CS-EU8-X2-4.5 X XA2, B2, C2, D2 4.5-5.0 CS-EU8-X2-5.0 XA2, B2, C2, D2 5.0-5.5 CS-EU8-X2-5.5 XA2, B2, C2, D2 5.5-6.0 CS-EU8-X2-6.0 XA2, B2, C2, D2 6.0-6.5 CS-EU8-X2-6.5 XA2, B2, C2, D2 6.5-7.0 CS-EU8-X2-7.0 X







Aroclorsb Archive NotesEU9 A1, B1, C1 2.0-2.5 CS-EU9-X1-2.5 X XExcavation depth 2 ft bgs A1, B1, C1 2.5-3.0 CS-EU9-X1-3.0 X

A1, B1, C1 3.0-3.5 CS-EU9-X1-3.5 XA1, B1, C1 3.5-4.0 CS-EU9-X1-4.0 XA1, B1, C1 4.0-4.5 CS-EU9-X1-4.5 XA1, B1, C1 4.5-5.0 CS-EU9-X1-5.0 X

A2, B2, C2 NA CS-EU9-X1-EB XFilter wipe (drilling equipment cross

contamination check)A2, B2, C2 2.0-2.5 CS-EU9-X2-2.5 X XA2, B2, C2 2.5-3.0 CS-EU9-X2-3.0 X

A2, B2, C22.5-3.0

CS-EU9-X2-3.0-FW XFilter wipe (processing



EU10 A1, B1, C1 5.0-5.5 CS-EU10-X1-5.5 X XExcavation depth 5 ft bgs A1, B1, C1 5.5-6.0 CS-EU10-X1-6.0 X

A1, B1, C1 6.0-6.5 CS-EU10-X1-6.5 XA1, B1, C1 6.5-7.0 CS-EU10-X1-7.0 XA1, B1, C1 7.0-7.5 CS-EU10-X1-7.5 XA1, B1, C1 7.5-8.0 CS-EU10-X1-8.0 XA2, B2, C2 5.0-5.5 CS-EU10-X2-5.5 X XA2, B2, C2 5.5-6.0 CS-EU10-X2-6.0 XA2, B2, C2 6.0-6.5 CS-EU10-X2-6.5 XA2, B2, C2 6.5-7.0 CS-EU10-X2-7.0 XA2, B2, C2 7.0-7.5 CS-EU10-X2-7.5 XA2, B2, C2 7.5-8.0 CS-EU10-X2-8.0 X



EU12 A1, B1 4.0-4.5 CS-EU12-X1-4.5 X XExcavation depth 4 ft bgs 4.0-4.5 CS-EU62-X1-4.5 X X Field homogenization split

A1, B1 4.5-5.0 CS-EU12-X1-5.0 XA1, B1 5.0-5.5 CS-EU12-X1-5.5 X



A1, B1 5.5-6.0 CS-EU12-X1-6.0 XA1, B1 6.0-6.5 CS-EU12-X1-6.5 XA1, B1 6.5-7.0 CS-EU12-X1-7.0 XA2, B2 4.0-4.5 CS-EU12-X2-4.5 X XA2, B2 4.5-5.0 CS-EU12-X2-5.0 XA2, B2 5.0-5.5 CS-EU12-X2-5.5 XA2, B2 5.5-6.0 CS-EU12-X2-6.0 XA2, B2 6.0-6.5 CS-EU12-X2-6.5 XA2, B2 6.5-7.0 CS-EU12-X2-7.0 X







Aroclorsb Archive NotesEU13 A1, B1 2.0-2.5 CS-EU13-X1-2.5 X XExcavation depth 2 ft bgs A1, B1 2.5-3.0 CS-EU13-X1-3.0 X


ROW Samplesc

PS North A A1 1.0-1.5 CS-PSNA-A1-1.5 X XExcavation depth 1 ft bgs A1 1.5-2.0 CS-PSNA-A1-2.0 X

A1 2.0-2.5 CS-PSNA-A1-2.5 XA1 2.5-3.0 CS-PSNA-A1-3.0 XA1 3.0-3.5 CS-PSNA-A1-3.5 XA1 3.5-4.0 CS-PSNA-A1-4.0 XB1 1.0-1.5 CS-PSNA-B1-1.5 X XB1 1.5-2.0 CS-PSNA-B1-2.0 XB1 2.0-2.5 CS-PSNA-B1-2.5 XB1 2.5-3.0 CS-PSNA-B1-3.0 XB1 3.0-3.5 CS-PSNA-B1-3.5 XB1 3.5-4.0 CS-PSNA-B1-4.0 XC1 1.0-1.5 CS-PSNA-C1-1.5 X XC1 1.5-2.0 CS-PSNA-C1-2.0 XC1 2.0-2.5 CS-PSNA-C1-2.5 XC1 2.5-3.0 CS-PSNA-C1-3.0 XC1 3.0-3.5 CS-PSNA-C1-3.5 XC1 3.5-4.0 CS-PSNA-C1-4.0 XD1 1.0-1.5 CS-PSNA-D1-1.5 X XD1 1.0-1.5 CS-PSND-D1-1.5 X X Field homogenization splitD1 1.5-2.0 CS-PSNA-D1-2.0 XD1 2.0-2.5 CS-PSNA-D1-2.5 XD1 2.5-3.0 CS-PSNA-D1-3.0 XD1 3.0-3.5 CS-PSNA-D1-3.5 XD1 3.5-4.0 CS-PSNA-D1-4.0 XE1 1.0-1.5 CS-PSNA-E1-1.5 X XE1 1.5-2.0 CS-PSNA-E1-2.0 XE1 2.0-2.5 CS-PSNA-E1-2.5 XE1 2.5-3.0 CS-PSNA-E1-3.0 XE1 3.0-3.5 CS-PSNA-E1-3.5 XE1 3.5-4.0 CS-PSNA-E1-4.0 X

PS North B A1 2.0-2.5 CS-PSNB-A1-2.5 X XExcavation depth 2 ft bgs A1 2.5-3.0 CS-PSNB-A1-3.0 X

A12.5-3.0 CS-PSNB-A1-3.0-FW X

Filter wipe (processing equipment cross

contamination check)A1 3.0-3.5 CS-PSNB-A1-3.5 XA1 3.5-4.0 CS-PSNB-A1-4.0 XA1 4.0-4.5 CS-PSNB-A1-4.5 XA1 4.5-5.0 CS-PSNB-A1-5.0 XB1 2.0-2.5 CS-PSNB-B1-2.5 X XB1 2.5-3.0 CS-PSNB-B1-3.0 XB1 3.0-3.5 CS-PSNB-B1-3.5 XB1 3.5-4.0 CS-PSNB-B1-4.0 XB1 4.0-4.5 CS-PSNB-B1-4.5 XB1 4.5-5.0 CS-PSNB-B1-5.0 XC1 2.0-2.5 CS-PSNB-C1-2.5 X XC1 2.5-3.0 CS-PSNB-C1-3.0 XC1 3.0-3.5 CS-PSNB-C1-3.5 XC1 3.5-4.0 CS-PSNB-C1-4.0 XC1 4.0-4.5 CS-PSNB-C1-4.5 XC1 4.5-5.0 CS-PSNB-C1-5.0 X







Aroclorsb Archive NotesPS North C A1 1.0-1.5 CS-PSNC-A1-1.5 X XExcavation depth 1 ft bgs A1 1.5-2.0 CS-PSNC-A1-2.0 X

A1 2.0-2.5 CS-PSNC-A1-2.5 XA1 2.5-3.0 CS-PSNC-A1-3.0 XA1 3.0-3.5 CS-PSNC-A1-3.5 XA1 3.5-4.0 CS-PSNC-A1-4.0 XB1 1.0-1.5 CS-PSNC-B1-1.5 X XB1 1.5-2.0 CS-PSNC-B1-2.0 XB1 2.0-2.5 CS-PSNC-B1-2.5 XB1 2.5-3.0 CS-PSNC-B1-3.0 XB1 3.0-3.5 CS-PSNC-B1-3.5 XB1 3.5-4.0 CS-PSNC-B1-4.0 XC1 1.0-1.5 CS-PSNC-C1-1.5 X XC1 1.5-2.0 CS-PSNC-C1-2.0 XC1 2.0-2.5 CS-PSNC-C1-2.5 XC1 2.5-3.0 CS-PSNC-C1-3.0 XC1 3.0-3.5 CS-PSNC-C1-3.5 XC1 3.5-4.0 CS-PSNC-C1-4.0 X

PS South A A1 1.0-1.5 CS-PSSA-A1-1.5 X XExcavation depth 1 ft bgs A1 1.5-2.0 CS-PSSA-A1-2.0 X

A1 2.0-2.5 CS-PSSA-A1-2.5 XA1 2.5-3.0 CS-PSSA-A1-3.0 XA1 3.0-3.5 CS-PSSA-A1-3.5 XA1 3.5-4.0 CS-PSSA-A1-4.0 XB1 1.0-1.5 CS-PSSA-B1-1.5 X XB1 1.5-2.0 CS-PSSA-B1-2.0 XB1 2.0-2.5 CS-PSSA-B1-2.5 XB1 2.5-3.0 CS-PSSA-B1-3.0 XB1 3.0-3.5 CS-PSSA-B1-3.5 XB1 3.5-4.0 CS-PSSA-B1-4.0 XC1 1.0-1.5 CS-PSSA-C1-1.5 X XC1 1.5-2.0 CS-PSSA-C1-2.0 XC1 2.0-2.5 CS-PSSA-C1-2.5 XC1 2.5-3.0 CS-PSSA-C1-3.0 XC1 3.0-3.5 CS-PSSA-C1-3.5 XC1 3.5-4.0 CS-PSSA-C1-4.0 X

PS South B A1 2.0-2.5 CS-PSSB-A1-2.5 X XExcavation depth 2 ft bgs A1 2.5-3.0 CS-PSSB-A1-3.0 X

A1 3.0-3.5 CS-PSSB-A1-3.5 XA1

3.0-3.5 CS-PSSB-A1-3.5-FW XFilter wipe (processing


A1 3.5-4.0 CS-PSSB-A1-4.0 XA1 4.0-4.5 CS-PSSB-A1-4.5 XA1 4.5-5.0 CS-PSSB-A1-5.0 XB1 2.0-2.5 CS-PSSB-B1-2.5 X XB1 2.5-3.0 CS-PSSB-B1-3.0 XB1 3.0-3.5 CS-PSSB-B1-3.5 XB1 3.5-4.0 CS-PSSB-B1-4.0 XB1 4.0-4.5 CS-PSSB-B1-4.5 XB1 4.5-5.0 CS-PSSB-B1-5.0 XC1 2.0-2.5 CS-PSSB-C1-2.5 X XC1 2.5-3.0 CS-PSSB-C1-3.0 XC1 3.0-3.5 CS-PSSB-C1-3.5 XC1 3.5-4.0 CS-PSSB-C1-4.0 XC1 4.0-4.5 CS-PSSB-C1-4.5 XC1 4.5-5.0 CS-PSSB-C1-5.0 X








S Donovan St - Geotechnical Boringsc

GT-1 0.0-5.0 GT-1-5.0 Geotech analysisd5.0-10.0 GT-1-10.0 Geotech analysis10.0-15.0 GT-1-15.0 Geotech analysis15.0-20.0 GT-1-20.0 Geotech analysis

GT-2 0.0-5.0 GT-2-5.0 Geotech analysis5.0-10.0 GT-2-10.0 Geotech analysis10.0-15.0 GT-2-15.0 Geotech analysis15.0-20.0 GT-2-20.0 Geotech analysis



GT-5 0.0-5.0 GT-5-5.0 Geotech analysis5.0-10.0 GT-5-10.0 Geotech analysis10.0-15.0 GT-5-15.0 Geotech analysis15.0-20.0 GT-5-20.0 Geotech analysis20.0-25.0 GT-5-25.0 Geotech analysis25.0-30.0 GT-5-30.0 Geotech analysis

GT-6 0.0-5.0 GT-6-5.0 Geotech analysis5.0-10.0 GT-6-10.0 Geotech analysis10.0-15.0 GT-6-15.0 Geotech analysis15.0-20.0 GT-6-20.0 Geotech analysis20.0-25.0 GT-6-25.0 Geotech analysis25.0-30.0 GT-6-30.0 Geotech analysis

Notes:

bgs = below ground surfaceEU = excavation unitPS = planting stripX = Sample to be analyzed.X = Sample to be archived.

a Excavation depths as presented in the EE/CA (Windward et al. 2010).

d Geotech analysis includes specific gravity (ASTM D854-10 and ASTM C127), water content (ASTM D2216-10), Atterberg limits (ASTM D4318-10), grain size (ASTM D422-63), bulk density (ASTM D7263-09), and triaxial shear strength (ASTM D4767-11 and D2850-07).

Yellow shaded cells correspond to composite sample X1.Green shaded cells correspond to composite sample X2.Archive = The sample will be collected and submitted to the analytical laboratory for archival storage, pending the results of analyzed samples.

b Additional PCB analysis will be conducted on deeper intervals if the total PCB concentration in the preceding interval exceeds the removal action limit. c See Figure A1 for sample locations.



Table B2. Soil Sample Identification and Analysis Scheme for Yards and Adjacent Street ROW DUs—MIS

Decision UnitEE/CA Excavation

Depth (bgs) Sample ID

Approximate Sample Interval

(ft bgs)

PCB Aroclors and Total Solidsa

Total Organic Carbon Archive QA

CS-DU-EB NA X Filter wipe (drilling equipment wipe prior to sample collection)

Dallas Avenue S. - Yardsb

DU01 1.0 CS-DU01-1.0-1.5 1.0-1.5 XCS-DU01-1.5-2.0 1.5-2.0 XCS-DU01-2.0-2.5 2.0-2.5 XCS-DU01-2.5-3.0 2.5-3.0 XCS-DU01-3.0-3.5 3.0-3.5 XCS-DU01-3.5-4.0 3.5-4.0 X

S. Cloverdale St - Yardsb



DU32 2.0 CS-DU32-2.0-2.5 2.0-2.5 X

CS-DU32-2.0-2.5-FW 2.0-2.5 XFilter wipe (processing


CS-DU32-2.5-3.0 2.5-3.0 XCS-DU32-3.0-3.5 3.0-3.5 XCS-DU32-3.5-4.0 3.5-4.0 XCS-DU32-4.0-4.5 4.0-4.5 XCS-DU32-4.5-5.0 4.5-5.0 X

DU35 2.0 CS-DU35-2.0-2.5 2.0-2.5 X MS/MSDCS-DU35-2.5-3.0 2.5-3.0 XCS-DU35-3.0-3.5 3.0-3.5 XCS-DU35-3.5-4.0 3.5-4.0 XCS-DU35-4.0-4.5 4.0-4.5 XCS-DU35-4.5-5.0 4.5-5.0 X

DU35a Unknown DU35a-0.0-0.2 0.0-0.2 X XDU35a-0.2-0.5 0.2-0.5 X X

CS-DU35a-1.0-1.5 1.0-1.5 XCS-DU35a-1.5-2.0 1.5-2.0 XCS-DU35a-2.0-2.5 2.0-2.5 XCS-DU35a-2.5-3.0 2.5-3.0 XCS-DU35a-3.0-3.5 3.0-3.5 XCS-DU35a-3.5-4.0 3.5-4.0 XCS-DU35a-4.0-4.5 4.0-4.5 XCS-DU35a-4.5-5.0 4.5-5.0 X

16th Avenue S. - ROWsb


DU17 3.0 CS-DU17-3.0-3.5 3.0-3.5 X MS/MSDCS-DU17-3.5-4.0 3.5-4.0 XCS-DU17-4.0-4.5 4.0-4.5 XCS-DU17-4.5-5.0 4.5-5.0 XCS-DU17-5.0-5.5 5.0-5.5 XCS-DU17-5.5-6.0 5.5-6.0 X

DU20/21 2.0 CS-DU20/21-2.0-2.5 2.0-2.5 XCS-DU20/21-2.5-3.0 2.5-3.0 XCS-DU20/21-3.0-3.5 3.0-3.5 XCS-DU20/21-3.5-4.0 3.5-4.0 XCS-DU20/21-4.0-4.5 4.0-4.5 XCS-DU20/21-4.5-5.0 4.5-5.0 X



Table B2. Soil Sample Identification and Analysis Scheme for Yards and Adjacent Street ROW DUs—MIS

Decision UnitEE/CA Excavation

Depth (bgs) Sample ID

Approximate Sample Interval

(ft bgs)

PCB Aroclors and Total Solidsa

Total Organic Carbon Archive QA

S. Donovan St - Yardsb


DU25a Unknown DU25a-0.0-0.2 0.0-0.2 X X LDUP; MS/MSD

DU25a-0.0-0.2-FW 0.0-0.2 XFilter wipe (processing


DU25a-0.2-0.5 0.2-0.5 X XCS-DU25a-1.0-1.5 1.0-1.5 XCS-DU25a-1.5-2.0 1.5-2.0 XCS-DU25a-2.0-2.5 2.0-2.5 XCS-DU25a-2.5-3.0 2.5-3.0 XCS-DU25a-3.0-3.5 3.0-3.5 XCS-DU25a-3.5-4.0 3.5-4.0 XCS-DU25a-4.0-4.5 4.0-4.5 XCS-DU25a-4.5-5.0 4.5-5.0 X

DU25b Unknown DU25b-0.0-0.2 0.0-0.2 X XDU25b-0.2-0.5 0.2-0.5 X X

CS-DU25b-1.0-1.5 1.0-1.5 XCS-DU25b-1.5-2.0 1.5-2.0 XCS-DU25b-2.0-2.5 2.0-2.5 XCS-DU25b-2.5-3.0 2.5-3.0 XCS-DU25b-3.0-3.5 3.0-3.5 XCS-DU25b-3.5-4.0 3.5-4.0 XCS-DU25b-4.0-4.5 4.0-4.5 XCS-DU25b-4.5-5.0 4.5-5.0 X

S Donovan St - ROWsGeotechnical sampling deferred to 60% design

Notes:

bgs = below ground surfaceLDUP = laboratory MIS processing duplicate sampleMIS = multi-incremental sampling

X = Sample to be analyzed.X = Sample to be archived.

a Additional PCB analysis will be conducted on deeper intervals if the total PCB concentration in the preceding interval exceeds the removal action level.

Archive = The sample will be collected and submitted to the analytical laboratory for archival storage, pending the results of analyzed samples.

MS/MSD = laboratory matrix spike and matrix spike duplicate for MIS samples, actual samples will be selected by the laboratory during MIS subsample preparation.

b See Figure A1 for DU Locations.



Type Size Quantity

Soil SamplesPCB Aroclors Deep frozen

(-20ºC)1 year 30 g

Total solids 4±2ºC 6 months 10 gTotal organic carbon Deep frozen

(-20ºC)1 year 1 g

WMG 1 literb 1 CAS Archival Deep frozen (-20ºC)

1 year NA

Equipment Wipe BlanksWMG 4 oz 1 CAS PCB Aroclors Deep frozen

(-20ºC)1 year 1 filter

Notes:NA = not applicableWMG = wide mouth glass

a Size and number of containers may be modified by analytical laboratory.b Archival volume shown is an estimate.

WMG 1 liter 1 CAS

Table B3. Sample Containers, Preservation, Holding Times, and Sample Volume

Containera

Laboratory Analysis Preservation Holding Time Sample Size

ATTACHMENT E1 RESPONSE TO MARCH 30, 2012,USACE COMMENTS ON THE

MARCH 21, 2012, FINAL DRAFT

QAPP AND SUBSEQUENT E-MAIL

CORRESPONDENCE ON THE QAPP

The draft Final QAPP was submitted to EPA on March 21, 2012. EPA provided comments on March 30 and April 5, 2012 and Integral, on behalf of the City of Seattle, prepared a response to the comments dated April 10, 2012. The EPA and City of Seattle worked out final details regarding the sampling program via email in the subsequent weeks between the submittal of the response to comments and initiation of the sampling. This Attachment includes copies of the April 10 response to comments and the subsequent emails. The reader should note that the April 10 response to comments was initially intended to be an Addendum to the March 21 QAPP. However, based on EPA request, these responses and the revisions based on subsequent emails were incorporated into the revised draft Final QAPP, the main body of this document.

Integral Consulting Inc. 411 1st Avenue S. Suite 550 Seattle, WA 98104 telephone: 206.230.9600 facsimile: 206.230.9601 www.integral-corp.com

MEMORANDUM

To: Piper Peterson

Cc: Leanna Woods Poon, Jayson Osborne, Greg Glass, Brett Richardson, Reid Carscadden, Ticson Mach, Roy Kuroiwa, Grant Hainsworth

Date: April 10, 2012

Subject: Addendum to the Quality Assurance Project Plan, Pre-Design Sampling, Adjacent Streets and Residential Yards Study Area, March 2012 (Responses to EPA Comments)

This memorandum is a response to EPA comments1 on the draft final QAPP, Pre-Design Sampling, March 21, 2012, and serves as an Addendum to the QAPP. The draft final version of the QAPP, with this attached Addendum is considered the final QAPP.

EPA comments are presented in standard text and responses are in blue italics.

GENERAL

Comment #1: sampling design for ROW parking strips on S. Cloverdale St.

The revised QAPP does not discuss data evaluations for the 5 narrow street ROW strips along the north and south sides of S. Cloverdale St. These narrow ROW areas, unlike the 13 street EUs, are located adjacent to occupied residences and are likely maintained as part of general yard maintenance at those residences. They should be evaluated individually and not combined with the other street EUs. A sampling design and rationale, and data evaluation approaches, should be added to the QAPP (e.g., see section B.1.1). A sampling design based on a number of discrete samples in each ROW area, with application of the MTCA 3-part rule, is suggested. With a small number of 1 Comments provided by the USACE on 4/4/12 from Greg Glass on the Draft Final Quality Assurance Project Plan Pre-Design Sampling Adjacent Streets and Residential Yards Study Area dated 30 March 2012 and a subsequent comment provided by the USACE via email on 4/5/12.

Responses to EPA Comments, Draft QAPP, Pre-Design Sampling, March 2012 April 10, 2012 Page 2 of 11

Integral Consulting Inc.

samples per ROW the exceedance of any one sample would fail the 10% rule under MTCA; rather than try to isolate small remediation areas based on this sampling approach, any failures should lead to further remediation of the entire small ROW unit.

The term EUs has been applied to the 13 areas of the connected street network remediation area (see Figure A1). The 5 narrow areas along S. Cloverdale St. are not included as EUs and appear to be missing in some parts of the text. For example, the bullets in section A4 do not appear to cover these areas; see also section A.4.2, among others. Are they properly designated as street ROWs (or, instead, parking strips?) to distinguish them from streets where traffic has access (e.g., EUs)? Make sure the areas along S. Cloverdale St. are appropriately referenced in the QAPP text and consider clarifying the distinction between adjacent streets (EUs) and street ROWs (parking strips) being addressed in this field program.

As discussed in this comment, the narrow right-of-way (Parking Strip) excavation units (EUs) have different exposure scenarios than streets and, based on this comment will be treated separately. The attached Revised Figure A1 delineates the Parking Strip EUs along S. Cloverdale Street. The paired sampling scheme outlined in the draft final QAPP for the Parking Strip EUs will be replaced with individual sampling locations. The number of samples per Parking Strip is based on the Parking Strip size and will range from three to five samples per unit as illustrated on Revised Figure A1 and discussed on Revised Table B1. The total removal depth for each Parking Strip EU will be the depth where all sample results are below the 1 mg/kg removal action level (RvAL). The Revised Figure A1 and Revised Table B1 are attached.

Comment #2: Please include an introduction to various sampling designs and corresponding data evaluation procedures to be performed under this QAPP

In section A4, page A-2, the 6th bullet in middle of page states, “Clean up will occur where PCBs exceed the RvAL of 1 mg/kg as determined by the upper confidence limit (UCL).” This bullet cites only the UCL on the mean as a criterion for data evaluations, while the MTCA 3-part rule is identified and proposed for data evaluations later in the QAPP. This introductory section is a good place to note that different sampling designs and different data evaluation procedures will be used for different portions of the investigation, and to the extent possible provide a concise rationale for why this is being done.

The following paragraph provides additional clarification on the sampling designs, data evaluation procedures and general remedial plans for areas discussed in this QAPP. The areas are subdivided into three groups based on land use characteristics and historical sampling



strategies. Removal actions will be completed in the Adjacent Streets and Residential Yards study area where total PCB concentrations exceed the RvAL of 1 mg/kg.

The areas and associated sampling and data evaluation approaches are as follows:

• Decision Units (DUs): Residential yards and right-of-way DUs have similar residential-like exposure, have been previously characterized by MIS sampling, and will be sampled with MIS techniques during the 2012 field event. The total depth of excavation will be determined by the depth with an MIS sample result below the removal action level (RvAL) upper confidence limit (UCL) for MIS sampling of 0.5 mg/kg. Excavation is planned for the whole DU to the specified depth.2

• Street Excavation Units (Street EUs): Street EUs are largely paved, have a typical street exposure and have been previously sampled with point or composite sampling techniques. Street EUs will be sampled with composite sampling technique during the 2012 field event as outlined in Comment 21. The total depth of excavation will be determined by the depth where Street EU results as a whole meet the MTCA 3 part rule in compliance with the RvAL of 1 mg/kg as described in Section B.1.2 of the draft final QAPP. Depths of removal may vary between Street EUs, but will be consistent within each Street EU as indicated in Comment 18.

• Parking strip Excavation Units (Parking Strip EUs): Parking strip EUs are narrow grassy areas between the sidewalk and street on either side of S. Cloverdale St. with the potential for residential exposures. Parking Strip EUs have been previously characterized by point sampling and will be evaluated with point samples during the 2012 field event. The depth of excavation will be the depth where all point samples in a given Parking Strip EU are less than 1 mg/kg total PCB.

Comment #3: testing for dioxins/furans

Section 4.4.3 of the EE/CA states, "...in areas where removal actions are required for PCBs, dioxins and furans will remain a COC and will be included as part of pre-removal confirmation sampling for the [Streets and Yards]." However, the current QAPP does not include analysis for dioxins and furans. Please clarify.

Analysis of dioxins and furans is not planned for the pre-design confirmation sampling and this sentence will be disregarded. Dioxins and furans will be addressed as part of the removal action where total PCB concentrations exceed 1 mg/kg. Therefore, the pre-design sampling addresses

2 For 3 DUs (DU25a, DU25b and DU35a) excavation will not be completed if the upper two sampling intervals (0.2 and 0.5 ft) do not exceed the RvAL as defined by the UCL (see Comment 12).



PCB analyses only. After the total depth of removal is defined, sufficient sample for dioxin and furan analysis will be retained on hold at the laboratory for a period of 4 months.

SPECIFIC

Comment #4: Attachment B: Equations and Rules for Applying Upper Confidence Limit and Stratified Sampling:

Satterthwaite (1946) has a formula for the approximate effective degrees of freedom (df) to be used to calculate the UCL. In the limiting case of equal strata sizes and variances, the upper bound for df is [total number of independent sample results, minus the number of strata]; in the case of T117 design, with 2 composite results per stratum, this gives [26-13 = 13 df]. (See also Cochran 1977, Thompson 1992, plus online references for stratified sampling design.)

Note that we can use the actual sample analysis results in Satterthwaite’s equation to estimate an alternate df for use in UCL calculation. (See also comment in Cochran that Satterthwaite’s approximate formula may give an overestimate of the df, and Thompson who cites further literature on estimating df). Please state in Attachment B that after analytical results are obtained, you will evaluate the most appropriate method to determine degrees of freedom using Satterthwaite’s equations.

References for Comment #4:

Cochran, William G., 1977. Sampling Techniques, third edition. John Wiley& Sons, New York.

Satterthwaite, F. E., 1946, An Approximate Distribution of Estimates of Variance Components., Biometrics Bulletin 2: 110–114.

Thompson, Steven K., 1992. Sampling. John Wiley & Sons, New York.

When evaluating the Streets EU data per Attachment B to the QAPP, the City will evaluate degrees of freedom using Satterthwaite’s equations.

Comment #5: A.7.1 Data Quality Objectives, Analytical Approach and Performance/Acceptance Criteria, 2nd paragraph (pg. A-11):

The text citing “…concentrations as low as 0.65 mg/kg…” for previous PCB values that had a calculated UCL (indirect) above the RvAL of 1 mg/kg (from EE/CA; Windward et al. 2010, Appendix L) is not relevant and should be removed.



As discussed below in Comment 6, the correct UCL is 0.50 mg/kg and is discussed in Section A.7.1 of the draft final QAPP to demonstrate that detection limits are sufficiently low to achieve project goals.

Comment #6: B.1.2 Pre-Removal Confirmation Sampling, last paragraph (pg. B-6):

The statement in B.1.2, page B-6 that “The effective PCB concentration that will determine the depth of excavation will be the UCL developed in Appendix L of the EE/CA, 0.65 mg/kg” cites an incorrect value. As stated in Appendix L, the critical value for UCL exceedance of the RvAL of 1 mg/kg based on an “indirect” UCL calculation based on a single MIS result is 0.50 mg/kg.

The comment correctly cites the UCL as 0.50 mg/kg and this value will be used to assess compliance with an RvAL of 1 mg/kg for DUs.

Comment #7: Table B1, Soil Sample Identification and Analysis Scheme for Adjacent Streets and ROW EUs – Point Samples and Composites

At EU5 there is a field homogenization split for the first sampled depth interval. How will the two resulting analytical values be used in data evaluations? Is one a QA result that will not be used? Will the two results be averaged? Please add a statement to clarify. Same comment for EU12 field homogenization split sample.

Field splits will not be averaged, and will only be used as field QA samples.

Comment #8: Table B2, Soil Sample Identification and Analysis Scheme for Yards and Adjacent Street ROW DUs - MIS

No archiving of remaining sample materials is indicated for all sampled intervals proposed for initial PCB testing. Assuming that lab subsampling for analyses will leave additional materials for these samples, the remaining sample materials should be archived.

Previous MIS sampling for residential yards and streets used a specific incremental procedure for subsampling at the lab. This same subsampling procedure should be used for all MIS and non-MIS (discrete or composite) samples collected under this QAPP. Please add a statement to this effect within the QAPP.



Per previous sampling events, unused material will be archived for each sample collected and MIS laboratory subsampling will be employed for all DUs. Street EU composite samples will be prepared in the field by taking an equal volume of representative material from each subsample, homogenized using decontaminated stainless steel bowls and spoons, and placed into certified, clean sample jars for shipment to the analytical laboratory. Discrete samples collected from the Parking Strip EUs will be homogenized in the field using decontaminated stainless steel bowls and spoons, and placed into certified, clean sample jars for shipment to the analytical laboratory.

Comment #9: Figure A1, Pre-Removal Confirmation Sampling Design

Since confirmation sampling of the ROW areas along S. Donovan St. has been deferred, the color coding for these combined areas shown as DU39 in Figure A1 should be omitted to avoid confusion – under this QAPP there is no pre-removal confirmation sampling occurring there as part of this field program.

The color coding of this area has been removed in the attached Revised Figure A1 to be clear regarding the sampling of this QAPP.

Comment #10: Figure B1, Process for Decision and Analysis of Archived Adjacent Street Confirmation Samples, and B.1.2 Pre-removal Confirmation Sampling, bullets on MTCA 3-part rule (pgs. B-4 and B-5)

Please include a second figure to summarize data evaluation procedures for the narrow ROW areas along S. Cloverdale St. The existing figure should be updated to reflect the Attachment B rules (e.g., based on average of two composite samples per EU, not single composite sample results, and 10% rule evaluation based on area and not EU or sample count). The text in bullets in section B.1.2 regarding the MTCA rule should be similarly revised for consistency.

See attached Revised Figure B1. Per Comment 1, the Parking Strip EUs will be excavated to a depth where all sample concentrations are less than 1 mg/kg; as such, a figure is not needed.

Comment #11: Attachment B, Equations and Rules for applying Upper Confidence Limit and Stratified Sampling

The current version applies to the 13 street EUs. Either in Attachment B or in the main QAPP text there should be a similar discussion of data evaluation rules for the narrow ROW areas along S. Cloverdale St. In the 4th bullet under Decision Rules, note that if more than one EU has an EU average above the RvAL of 1 mg/kg PCB, it is the cumulative area of such EUs that will be evaluated under the MTCA 10% rule.



The data evaluation rules for the Parking Strip EUs described in Comment #1 will be adopted. The cumulative area of the EU average above the RvAL of 1 mg/kg PCB will also be adopted.

Comment #12: A.4.2 Problem Definition, page A-4, 2nd bullet

The 2nd bullet states: “Verify that total PCB concentrations directly below the planned DUs in residential yards and ROWs (including supplemental DU25a, DU25b, and DU35a) are below the RvAL by conducting MIS at the currently planned excavation depth.” Note that with no prior soil data there are as yet no planned excavation depths at the 3 supplemental residential yard DUs. Reword for clarity. Note also that non-compliance in either of the first two sampled depth intervals would result in soil removal, as with earlier characterization studies. A “first complying interval” at 0-2 inches would not mean overall compliance if the second depth interval failed.

The 2nd bullet applies to DUs where excavation has been determined to be necessary based on previous sampling. For the supplemental DUs (DU25a, DU25b and DU35a) sampling has two objectives as follows:

• To determine if removal is necessary: Sampling will be completed at depths of 0.2 and 0.5 ft and the MIS sample analyzed. If the sample concentration of either depth exceeds the 0.5 mg/kg UCL criteria, then a removal will be completed in the DU. If concentrations of both depths are below 0.5 mg/kg, then then a removal will not be completed in the DU.

• To determine the depth of removal in DUs where a removal is necessary: Pre-excavation confirmation samples will be collected at depth in the supplemental DUs. Where surface sample concentrations indicate a removal action is necessary, the subsurface samples will be analyzed sequentially with depth to determine the depth of removal. Samples will continue to be analyzed with increasing depth until the resulting concentration is below the 0.5 mg/kg UCL criteria.

Comment #13: A5 Project Task Description

Sections C and D simply cross reference earlier documents. The language in section A5 would better reflect this rather than state that those later sections “describe in detail” investigation procedures. Please state the information from Sections C and D directly in section A5 Project Task Description and then delete Sections C and D.

This paragraph is restated as follows:

The tasks to be completed for this investigation include fieldwork, laboratory chemical and geotechnical analyses, data quality evaluation, data management, data analysis, and reporting.



Tasks that will be completed in the field, including related documentation and quality assurance and quality control (QA/QC) activities, as well as sample handling, laboratory analyses, and data management are described in Section B of this QAPP. Where procedures have not changed from previous QAPPs for the adjacent streets and residential yards, text from previous QAPPs are either reiterated in this document or incorporated by reference. Project assessment and oversight procedures are described in detail in Section C, and procedures relating to data validation and determination of usability are described in Section D of previous QAPPs and are not restated in this QAPP.

Comment #14: B2 Sampling Methods

Do previous documents address how less than 100% recoveries in geoprobe sampling will be handled with respect to obtaining sample materials (as indicated in section B2)? Please state (or restate) the criterion for minimal acceptable recovery here.

The minimum acceptable sample recovery is 75 percent of the targeted volume. If that volume is not achieved, additional attempts will be made in the immediate vicinity (e.g., within 1 ft of the original location). Any deviations from the original location or volumes will be documented in the field report.

Comment #15: A.6.2 Schedule

What is the anticipated duration of field sampling activities, assuming 100% access agreements are obtained? Please state.

The duration of the field sampling activities is anticipated to be 25 working days, or 5 weeks.

Comment #16: B.1.1 Pre-Design Supplemental Sampling

At DU35a, if there are access restrictions for using geoprobe techniques, why was hand-sampling not considered? In general, is there a need for additional discussion of exclusion criteria for collecting yard samples because a new sampling method (geoprobes) is being used? If tree roots, for example, make it difficult to obtain MIS sample materials, could hand sampling at a few yard locations be used as an alternate method, or would sampling have to omit such areas?

For the narrow area between the new building and the fence on the west side of DU35a, access is not sufficient for geoprobe equipment, which would be necessary to characterize the depth of excavation. Hand sampling is sufficient for surface soil, but not for characterization with depth. Therefore, this area will not be sampled. Exclusion criteria include driveways, parking areas, areas under buildings, decks or any other structure, unusual uses of a parcel or portion of the



parcel, and limited access areas between structures (case-by-case as determined in consultation with EPA).

Comment #17: B.1.2 Pre-removal Confirmation Sampling, 2nd paragraph

This paragraph discussed point sampling for streets, when actually composite samples (at compositing ratios much less than for MIS samples) are proposed. Since point (discrete) samples are not in fact being submitted to the lab, please edit this text for clarity and consistency.

The City agrees that this paragraph is no longer relevant.

Comment #18: B.1.2 Pre-removal Confirmation Sampling, page B-4, bullet at bottom of the page (re: UCL)

It should be noted (footnote is suggested) that the data being used for the UCL calculation at 13 street EUs represent the post-excavation surface, at different depths below ground surface in different EUs. [This is notable because it differs from the common “layer-cake”, constant-depth approach for many exposure/risk evaluations. The UCL calculation here is focused on whether excavations have resulted in low-enough residual PCBs at the variable excavation depths]

This comment is accurate and noted.

Comment #19: B.1.2 Pre-removal Confirmation Sampling, page B-5, last bullet

This is the best place to add text stating that in the event of data evaluations showing non-compliance, specific actions to extend planned soil excavations would be taken. In the case of street EUs, this would be on an EU by EU basis until compliance is achieved. For the narrow street ROWs (parking strips), it is suggested this be the entire ROW unit. For residential yard DUs (page B-6), this would be entire DUs and not subareas of a DU. Design documents will be prepared later, but this QAPP should briefly note how extended soil removal designs would be evaluated for compliance – that is, to relate remediation decisions to compliance evaluations.

The City agrees and will implement these actions as included in the response to Comment 2.



Comment #20: B2 Sampling Methods, last paragraph (pg. B-9)

Is backfilling with bentonite chips what we want here? Pre-sampling materials will be porous soils, so why end up with 30 or more impervious columns in the yard, which could affect future plantings, etc.? Why not backfill with similar porous materials, including all excess materials from boreholes (e.g., surficial depth intervals not collected for analysis)?

Backfilling will be completed in accordance with the Washington State drilling rules, which include bentonite backfill. Bentonite with a 2-ft clean sand cap will be used to backfill the holes in yards and topsoil in garden areas. The sand cover allows for grass regrowth and was reportedly the same surface backfill used in the Ruston site work.

Comment #21: B2 Sampling Methods

A slightly modified process for selecting street sampling locations is proposed, to better approximate equal probability sampling. The general approach is as follows:

• Measure along the roadside edge of an EU (parallel to traffic flow)

• Divide by the number of samples per composite (varies by EU, approximately uniform sampling density), getting “segment length”

• Using a random number between 0 and 1, locate the first transect in first segment of the EU from an end-point of the measured length

• Identify additional transect locations at distances equal to the segment length (this provides for “spatial coverage” over the EU and still preserves equal probability sampling given a random first transect location)

• Using random numbers between 0 and 1, identify the sampling locations on each transect based on the fraction of the full cross-road distance – all distances starting from the same measured side line

The second composite would follow the same procedures but with a new randomly defined initial transect location, and new randomly determined cross-road distances along each transect. Tables of random 0 to 1 interval values can be generated in the office and taken to the field.

For rectangular EUs this approach is straightforward. For L-shaped EUs (e.g., EU9 in Figure A1) it is necessary to conceptually divide them into approximately rectangular areas, and “rotate” one part to show how to get a single edge measurement that will cover the entire EU, with no missing or duplicated portions (this is easier to demonstrate



with a drawing, not included here). The net result is that transect lines will occur across the EU in multiple directions, with a goal of having them maximally drawn across the street width (conceptually preferred, given possible crowning of street surfaces and traffic lanes for truck trackout of PCBs).

For the S. Cloverdale St ROW (parking strip) areas, a similar approach can be used to identify discrete sampling locations. Randomly selecting locations across (short) transects would result in samples at different distances in from the street, rather than all at the same distance.

This sample location scheme will be adopted per this comment and as clarified in the attached emails.

Additional Comment provided by the USACE on 4/5/12

If more than one composite result from one street EU is ND, a conservative, bounding approach should be utilized to maximize the estimate of the EU variance. For example, if two composite samples from one street EU are ND, calculate the variance by assuming one ND is zero and the other is the detection limit (or the higher of the DLs if they differ, sample specific).

This approach will be adopted in analyzing data from Street EUs.

T-117 Upland

Boeing South Park

Basin Oil

South Park MarinaDU011

DU032

DU141

DU162

DU173

DU20/212

DU252

DU25a

DU322

DU352

BB

B

B

B

B

C

Confirmation sampling of hillslope areadeferred to 60% design phase

1425

DC

DU25b *

DU35a *

B

A

CDC

B

A

B

A

C C

B

AA

E

B

A D

C

AB

B

A

A

B AB

F

E

D

C

BA

B

A

BCBED

A B B

A

B

A B

EU22

EU54

EU84

EU105

EU13

EU92

EU71

EU124

EU46

EU112

EU34

EU66

EU132

PS North A1 PS North B

2

PS South B2

PS North C1

PS South A1 A

A

A

B

A

A

BC

A

B

B

A

A

E

D

C

BA

AA

F

E

D

CB

AB

A

CA

CAACB

GT-5

GT-1 GT-2 GT-4

GT-6

GT-3

1415 1417 1421 1429 1445

1412 14181426 1430 1438 1442 1446 1450

1433

8620

86178602

8609

8601

8603

1410 1412 1420 1424 1440

8529

85258523

85198500

Revised Figure A1Pre-Removal Confirmation Sampling Design

0 50 10025

Feet

Note: Excavation unit point samples are shown for illustration purposes. Actuallocations will be determined in the field per Section B2.

* - The boundaries of this DU will be determined in the field.

Background imagery is for reference purposes only, courtesy of theCity of Seattle and dated 2009.

Dallas Ave S

17th

Ave

S

16th

Ave

S

S Cloverdale St

S Donovan St

14th

Ave

S



Parking Strip Discrete Sample Location

Geotechnical Boreholes

Historic Sample Locations

T-117 EAA Boundary

Residential Yard Decision Units (MIS Confirmation)

Decision Units Identified for Supplemental Sampling

Adjacent Street Excavation Units

Parking Strip Excavation Units

Tax parcels

Buildings with addresses2574

EU/DU 993

Location IdentificationExcavation Depth (ft bgs)

XX

Confirmation Point Sample

Revised Figure B1. Process for Decision and Analysis of Archived

Excavation Unit (EU) Confirmation Samples

EU Composite analysis (2 composites per EU)

Does the composite

average exceed the RvAL?


average concentrations >2x RvAL


average concentrations > RvAL


higher average

Complete

Do more than 10% of

composite averages exceed

Is calculated Adjacent Street

UCL>RvAL?

Yes

Yes

Yes

No

No

No

T-117 Quality Assurance Project PlanPre-design Sampling

DRAFT FINALApril 10, 2012

Integral Consulting Inc. 1 of 6

Revised Table B1. Soil Sample Identification and Analysis Scheme for Adjacent Streets and ROW EUs—Point Samples and Composites




Aroclorsb Archive NotesStreet Samplesc

NA CS-EU-EB XFilter wipe (drilling

equipment wipe prior to sample collection)



EU2 A1, B1, C1, D1, E1, F1 2.0-2.5 CS-EU2-X1-2.5 X XExcavation depth 2 ft bgs

A1, B1, C1, D1, E1, F1 2.0-2.5 CS-EU2-X1-2.5-FW XFilter wipe (processing


A1, B1, C1, D1, E1, F1 2.5-3.0 CS-EU2-X1-3.0 XA1, B1, C1, D1, E1, F1 3.0-3.5 CS-EU2-X1-3.5 XA1, B1, C1, D1, E1, F1 3.5-4.0 CS-EU2-X1-4.0 XA1, B1, C1, D1, E1, F1 4.0-4.5 CS-EU2-X1-4.5 XA1, B1, C1, D1, E1, F1 4.5-5.0 CS-EU2-X1-5.0 XA2, B2, C2, D2, E2, F2 2.0-2.5 CS-EU2-X2-2.5 X XA2, B2, C2, D2, E2, F2 2.5-3.0 CS-EU2-X2-3.0 XA2, B2, C2, D2, E2, F2 3.0-3.5 CS-EU2-X2-3.5 XA2, B2, C2, D2, E2, F2 3.5-4.0 CS-EU2-X2-4.0 XA2, B2, C2, D2, E2, F2 4.0-4.5 CS-EU2-X2-4.5 XA2, B2, C2, D2, E2, F2 4.5-5.0 CS-EU2-X2-5.0 X



A2, B2 NA CS-EU3-X2-FW XFilter wipe (drilling equipment cross

contamination check)EU4 A1, B1 6.0-6.5 CS-EU4-X1-6.5 X XExcavation depth 6 ft bgs A1, B1 6.5-7.0 CS-EU4-X1-7.0 X









Aroclorsb Archive NotesEU5 A1, B1, C1, D1, E1 4.0-4.5 CS-EU5-X1-4.5 X XExcavation depth 4 ft bgs A1, B1, C1, D1, E1 4.0-4.5 CS-EU55-X1-4.5 X Field homogenization split

A1, B1, C1, D1, E1 4.5-5.0 CS-EU5-X1-5.0 XA1, B1, C1, D1, E1 5.0-5.5 CS-EU5-X1-5.5 XA1, B1, C1, D1, E1 5.5-6.0 CS-EU5-X1-6.0 XA1, B1, C1, D1, E1 6.0-6.5 CS-EU5-X1-6.5 XA1, B1, C1, D1, E1 6.5-7.0 CS-EU5-X1-7.0 XA2, B2, C2, D2, E2 4.0-4.5 CS-EU5-X2-4.5 X XA2, B2, C2, D2, E2 4.5-5.0 CS-EU5-X2-5.0 XA2, B2, C2, D2, E2 5.0-5.5 CS-EU5-X2-5.5 XA2, B2, C2, D2, E2 5.5-6.0 CS-EU5-X2-6.0 XA2, B2, C2, D2, E2 6.0-6.5 CS-EU5-X2-6.5 XA2, B2, C2, D2, E2 6.5-7.0 CS-EU5-X2-7.0 X

EU6 A1, B1 6.0-6.5 CS-EU6-X1-6.5 X XExcavation depth 6 ft bgs



A1, B1 6.5-7.0 CS-EU6-X1-7.0 XA1, B1 7.0-7.5 CS-EU6-X1-7.5 XA1, B1 7.5-8.0 CS-EU6-X1-8.0 XA1, B1 8.0-8.5 CS-EU6-X1-8.5 XA1, B1 8.5-9.0 CS-EU6-X1-9.0 XA2, B2 6.0-6.5 CS-EU6-X2-6.5 X XA2, B2 6.5-7.0 CS-EU6-X2-7.0 XA2, B2 7.0-7.5 CS-EU6-X2-7.5 XA2, B2 7.5-8.0 CS-EU6-X2-8.0 XA2, B2 8.0-8.5 CS-EU6-X2-8.5 XA2, B2 8.5-9.0 CS-EU6-X2-9.0 X



EU8 A1, B1, C1, D1 4.0-4.5 CS-EU8-X1-4.5 X XExcavation depth 4 ft bgs A1, B1, C1, D1 4.5-5.0 CS-EU8-X1-5.0 X

A1, B1, C1, D1 5.0-5.5 CS-EU8-X1-5.5 XA1, B1, C1, D1 5.5-6.0 CS-EU8-X1-6.0 XA1, B1, C1, D1 6.0-6.5 CS-EU8-X1-6.5 XA1, B1, C1, D1 6.5-7.0 CS-EU8-X1-7.0 XA2, B2, C2, D2 4.0-4.5 CS-EU8-X2-4.5 X XA2, B2, C2, D2 4.5-5.0 CS-EU8-X2-5.0 XA2, B2, C2, D2 5.0-5.5 CS-EU8-X2-5.5 XA2, B2, C2, D2 5.5-6.0 CS-EU8-X2-6.0 XA2, B2, C2, D2 6.0-6.5 CS-EU8-X2-6.5 XA2, B2, C2, D2 6.5-7.0 CS-EU8-X2-7.0 X








Aroclorsb Archive NotesEU9 A1, B1, C1 2.0-2.5 CS-EU9-X1-2.5 X XExcavation depth 2 ft bgs A1, B1, C1 2.5-3.0 CS-EU9-X1-3.0 X


A2, B2, C2 NA CS-EU9-X1-EB XFilter wipe (drilling equipment cross

contamination check)A2, B2, C2 2.0-2.5 CS-EU9-X2-2.5 X XA2, B2, C2 2.5-3.0 CS-EU9-X2-3.0 X

A2, B2, C22.5-3.0

CS-EU9-X2-3.0-FW XFilter wipe (processing



EU10 A1, B1, C1 5.0-5.5 CS-EU10-X1-5.5 X XExcavation depth 5 ft bgs A1, B1, C1 5.5-6.0 CS-EU10-X1-6.0 X

A1, B1, C1 6.0-6.5 CS-EU10-X1-6.5 XA1, B1, C1 6.5-7.0 CS-EU10-X1-7.0 XA1, B1, C1 7.0-7.5 CS-EU10-X1-7.5 XA1, B1, C1 7.5-8.0 CS-EU10-X1-8.0 XA2, B2, C2 5.0-5.5 CS-EU10-X2-5.5 X XA2, B2, C2 5.5-6.0 CS-EU10-X2-6.0 XA2, B2, C2 6.0-6.5 CS-EU10-X2-6.5 XA2, B2, C2 6.5-7.0 CS-EU10-X2-7.0 XA2, B2, C2 7.0-7.5 CS-EU10-X2-7.5 XA2, B2, C2 7.5-8.0 CS-EU10-X2-8.0 X



EU12 A1, B1 4.0-4.5 CS-EU12-X1-4.5 X XExcavation depth 4 ft bgs 4.0-4.5 CS-EU62-X1-4.5 X X Field homogenization split

A1, B1 4.5-5.0 CS-EU12-X1-5.0 XA1, B1 5.0-5.5 CS-EU12-X1-5.5 X



A1, B1 5.5-6.0 CS-EU12-X1-6.0 XA1, B1 6.0-6.5 CS-EU12-X1-6.5 XA1, B1 6.5-7.0 CS-EU12-X1-7.0 XA2, B2 4.0-4.5 CS-EU12-X2-4.5 X XA2, B2 4.5-5.0 CS-EU12-X2-5.0 XA2, B2 5.0-5.5 CS-EU12-X2-5.5 XA2, B2 5.5-6.0 CS-EU12-X2-6.0 XA2, B2 6.0-6.5 CS-EU12-X2-6.5 XA2, B2 6.5-7.0 CS-EU12-X2-7.0 X








Aroclorsb Archive NotesEU13 A1, B1 2.0-2.5 CS-EU13-X1-2.5 X XExcavation depth 2 ft bgs A1, B1 2.5-3.0 CS-EU13-X1-3.0 X

A1, B1 3.0-3.5 CS-EU13X1-3.5 XA1, B1 3.5-4.0 CS-EU13-X1-4.0 XA1, B1 4.0-4.5 CS-EU13-X1-4.5 XA1, B1 4.5-5.0 CS-EU13-X1-5.0 XA2, B2 2.0-2.5 CS-EU13-X2-2.5 X XA2, B2 2.5-3.0 CS-EU13-X2-3.0 XA2, B2 3.0-3.5 CS-EU13-X2-3.5 XA2, B2 3.5-4.0 CS-EU13-X2-4.0 XA2, B2 4.0-4.5 CS-EU13-X2-4.5 XA2, B2 4.5-5.0 CS-EU13-X2-5.0 X

ROW Samplesc

PS North A A1 1.0-1.5 CS-PSNA-A1-1.5 X XExcavation depth 1 ft bgs A1 1.5-2.0 CS-PSNA-A1-2.0 X

A1 2.0-2.5 CS-PSNA-A1-2.5 XA1 2.5-3.0 CS-PSNA-A1-3.0 XA1 3.0-3.5 CS-PSNA-A1-3.5 XA1 3.5-4.0 CS-PSNA-A1-4.0 XB1 1.0-1.5 CS-PSNA-B1-1.5 X XB1 1.5-2.0 CS-PSNA-B1-2.0 XB1 2.0-2.5 CS-PSNA-B1-2.5 XB1 2.5-3.0 CS-PSNA-B1-3.0 XB1 3.0-3.5 CS-PSNA-B1-3.5 XB1 3.5-4.0 CS-PSNA-B1-4.0 XC1 1.0-1.5 CS-PSNA-C1-1.5 X XC1 1.5-2.0 CS-PSNA-C1-2.0 XC1 2.0-2.5 CS-PSNA-C1-2.5 XC1 2.5-3.0 CS-PSNA-C1-3.0 XC1 3.0-3.5 CS-PSNA-C1-3.5 XC1 3.5-4.0 CS-PSNA-C1-4.0 XD1 1.0-1.5 CS-PSNA-D1-1.5 X XD1 1.0-1.5 CS-PSND-D1-1.5 X X Field homogenization splitD1 1.5-2.0 CS-PSNA-D1-2.0 XD1 2.0-2.5 CS-PSNA-D1-2.5 XD1 2.5-3.0 CS-PSNA-D1-3.0 XD1 3.0-3.5 CS-PSNA-D1-3.5 XD1 3.5-4.0 CS-PSNA-D1-4.0 XE1 1.0-1.5 CS-PSNA-E1-1.5 X XE1 1.5-2.0 CS-PSNA-E1-2.0 XE1 2.0-2.5 CS-PSNA-E1-2.5 XE1 2.5-3.0 CS-PSNA-E1-3.0 XE1 3.0-3.5 CS-PSNA-E1-3.5 XE1 3.5-4.0 CS-PSNA-E1-4.0 X

PS North B A1 2.0-2.5 CS-PSNB-A1-2.5 X XExcavation depth 2 ft bgs A1 2.5-3.0 CS-PSNB-A1-3.0 X

A12.5-3.0 CS-PSNB-A1-3.0-FW X

Filter wipe (processing equipment cross

contamination check)A1 3.0-3.5 CS-PSNB-A1-3.5 XA1 3.5-4.0 CS-PSNB-A1-4.0 XA1 4.0-4.5 CS-PSNB-A1-4.5 XA1 4.5-5.0 CS-PSNB-A1-5.0 XB1 2.0-2.5 CS-PSNB-B1-2.5 X XB1 2.5-3.0 CS-PSNB-B1-3.0 XB1 3.0-3.5 CS-PSNB-B1-3.5 XB1 3.5-4.0 CS-PSNB-B1-4.0 XB1 4.0-4.5 CS-PSNB-B1-4.5 XB1 4.5-5.0 CS-PSNB-B1-5.0 XC1 2.0-2.5 CS-PSNB-C1-2.5 X XC1 2.5-3.0 CS-PSNB-C1-3.0 XC1 3.0-3.5 CS-PSNB-C1-3.5 XC1 3.5-4.0 CS-PSNB-C1-4.0 XC1 4.0-4.5 CS-PSNB-C1-4.5 XC1 4.5-5.0 CS-PSNB-C1-5.0 X








Aroclorsb Archive NotesPS North C A1 1.0-1.5 CS-PSNC-A1-1.5 X XExcavation depth 1 ft bgs A1 1.5-2.0 CS-PSNC-A1-2.0 X

A1 2.0-2.5 CS-PSNC-A1-2.5 XA1 2.5-3.0 CS-PSNC-A1-3.0 XA1 3.0-3.5 CS-PSNC-A1-3.5 XA1 3.5-4.0 CS-PSNC-A1-4.0 XB1 1.0-1.5 CS-PSNC-B1-1.5 X XB1 1.5-2.0 CS-PSNC-B1-2.0 XB1 2.0-2.5 CS-PSNC-B1-2.5 XB1 2.5-3.0 CS-PSNC-B1-3.0 XB1 3.0-3.5 CS-PSNC-B1-3.5 XB1 3.5-4.0 CS-PSNC-B1-4.0 XC1 1.0-1.5 CS-PSNC-C1-1.5 X XC1 1.5-2.0 CS-PSNC-C1-2.0 XC1 2.0-2.5 CS-PSNC-C1-2.5 XC1 2.5-3.0 CS-PSNC-C1-3.0 XC1 3.0-3.5 CS-PSNC-C1-3.5 XC1 3.5-4.0 CS-PSNC-C1-4.0 X

PS South A A1 1.0-1.5 CS-PSSA-A1-1.5 X XExcavation depth 1 ft bgs A1 1.5-2.0 CS-PSSA-A1-2.0 X

A1 2.0-2.5 CS-PSSA-A1-2.5 XA1 2.5-3.0 CS-PSSA-A1-3.0 XA1 3.0-3.5 CS-PSSA-A1-3.5 XA1 3.5-4.0 CS-PSSA-A1-4.0 XB1 1.0-1.5 CS-PSSA-B1-1.5 X XB1 1.5-2.0 CS-PSSA-B1-2.0 XB1 2.0-2.5 CS-PSSA-B1-2.5 XB1 2.5-3.0 CS-PSSA-B1-3.0 XB1 3.0-3.5 CS-PSSA-B1-3.5 XB1 3.5-4.0 CS-PSSA-B1-4.0 XC1 1.0-1.5 CS-PSSA-C1-1.5 X XC1 1.5-2.0 CS-PSSA-C1-2.0 XC1 2.0-2.5 CS-PSSA-C1-2.5 XC1 2.5-3.0 CS-PSSA-C1-3.0 XC1 3.0-3.5 CS-PSSA-C1-3.5 XC1 3.5-4.0 CS-PSSA-C1-4.0 X

PS South B A1 2.0-2.5 CS-PSSB-A1-2.5 X XExcavation depth 2 ft bgs A1 2.5-3.0 CS-PSSB-A1-3.0 X

A1 3.0-3.5 CS-PSSB-A1-3.5 XA1

3.0-3.5 CS-PSSB-A1-3.5-FW XFilter wipe (processing


A1 3.5-4.0 CS-PSSB-A1-4.0 XA1 4.0-4.5 CS-PSSB-A1-4.5 XA1 4.5-5.0 CS-PSSB-A1-5.0 XB1 2.0-2.5 CS-PSSB-B1-2.5 X XB1 2.5-3.0 CS-PSSB-B1-3.0 XB1 3.0-3.5 CS-PSSB-B1-3.5 XB1 3.5-4.0 CS-PSSB-B1-4.0 XB1 4.0-4.5 CS-PSSB-B1-4.5 XB1 4.5-5.0 CS-PSSB-B1-5.0 XC1 2.0-2.5 CS-PSSB-C1-2.5 X XC1 2.5-3.0 CS-PSSB-C1-3.0 XC1 3.0-3.5 CS-PSSB-C1-3.5 XC1 3.5-4.0 CS-PSSB-C1-4.0 XC1 4.0-4.5 CS-PSSB-C1-4.5 XC1 4.5-5.0 CS-PSSB-C1-5.0 XC1 4.5-5.0 CS-PSSB-C1-5.0 X









S Donovan St - Geotechnical Boringsc

GT-1 0.0-5.0 GT-1-5.0 Geotech analysisd

5.0-10.0 GT-1-10.0 Geotech analysis10.0-15.0 GT-1-15.0 Geotech analysis15.0-20.0 GT-1-20.0 Geotech analysis

GT-2 0.0-5.0 GT-2-5.0 Geotech analysis5.0-10.0 GT-2-10.0 Geotech analysis

10.0-15.0 GT-2-15.0 Geotech analysis15.0-20.0 GT-2-20.0 Geotech analysis






10.0-15.0 GT-5-15.0 Geotech analysis15.0-20.0 GT-5-20.0 Geotech analysis20.0-25.0 GT-5-25.0 Geotech analysis25.0-30.0 GT-5-30.0 Geotech analysis


10.0-15.0 GT-6-15.0 Geotech analysis15.0-20.0 GT-6-20.0 Geotech analysis20.0-25.0 GT-6-25.0 Geotech analysis25.0-30.0 GT-6-30.0 Geotech analysis

Notes:

bgs = below ground surfaceft = feet X = Sample to be analyzed.X = Sample to be archived.

a Excavation depths as presented in the EE/CA (Windward et al. 2010).

d Geotech analysis includes specific gravity (ASTM D854-10 and ASTM C127), water content (ASTM D2216-10), Atterberg limits (ASTM D4318-10), grain size (ASTM D422-63), bulk density (ASTM D7263-09), and triaxial shear strength (ASTM D4767-11 and D2850-07).

Yellow shaded cells correspond to composite sample X1.Green shaded cells correspond to composite sample X2.Archive = The sample will be collected and submitted to the analytical laboratory for archival storage, pending the results of analyzed samples.

b Additional PCB analysis will be conducted on deeper intervals if the total PCB concentration in the preceding interval exceeds the RvAL. c See Figure B1 for sample locations.

-----Original Message-----From: Woods Poon, Leanna M NWS [mailto:[email protected]]Sent: Monday, April 30, 2012 2:20 PMTo: Linda Baker; Greg Glass ([email protected])Cc: Osborne, Jayson B NWS; Piper Peterson ([email protected]); Richardson, Brett([email protected]); Reid Carscadden; Kimberly Magruder CarltonSubject: RE: Proposal for sampling subsurface at DU32 (UNCLASSIFIED)

Classification: UNCLASSIFIEDCaveats: NONE

Hi Linda,

Piper, Greg, and I have discussed the proposed approach at DU 32. Like I mentioned in my discussion

with you earlier, we are agreeable to a reduced number of MIS samples within the area that can besampled (and possibly excavated) at depths below 6 inches. 14:1 or 15:1 (however the area is splitbest) MIS samples would allow us to continue to use the same decision framework for all the residentialyards. Please let us know if you have any questions.

Thanks,Leanna

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Leanna Woods Poon, M.S.Environmental EngineerUSACE Seattle District4735 E Marginal Way SouthSeattle, WA 98134Phone: [email protected]~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

-----Original Message-----From: Linda Baker [mailto:[email protected]]Sent: Monday, April 30, 2012 11:46 AMTo: Woods Poon, Leanna M NWS; Greg Glass ([email protected])Cc: Osborne, Jayson B NWS; Piper Peterson ([email protected]); Richardson, Brett([email protected]); Reid Carscadden; Kimberly Magruder CarltonSubject: Proposal for sampling subsurface at DU32

Leanna/Greg -

Regarding DU32 - The landscapers have gotten back to me regarding areas where excavations couldextend deeper in DU32 and have indicated that - in an effort to maintain the juniper hedge and thecorner tree - we should not dig deeper than 6 inches within 8 feet of the Juniper trunk or within thecanopy line of the tree. This leaves an area of roughly 28ft by 6 ft for sampling where excavationscould extend below 6-inches. The sidewalk is located in the center of this area, leaving more like a 25ft x 6 ft accessible area to sample and assess the need to dig deeper.

This is smaller than any previous DU's handled by MIS sampling (almost half the size) and is more akinto the parking strip areas. We are proposing handling the area similar to the parking strips - dividingthe area into 4 cells (approx. 14 ft x 3 ft ) and randomly locating samples within each of the 4 cells.Depth of excavation would be based on the first depth interval where all concentrations are below 1mg/kg total PCB for the DU as a whole.

I understand it is short notice, but if possible, we would like to get concurrence by 2 PM (or maybe 3PM) we were hoping to sample the subsurface portion this DU today (we will be sampling the surface).

We will get you the project status/5-day look ahead schedule email shortly.

Thanks

Linda Baker | Principal Hydrogeologist

Integral Consulting Inc. | www.integral-corp.com <http://www.integral-corp.com/>

411 1st Avenue S., Suite 550 | Seattle, WA 98104

Tel: 206-230-9600, ext. 314 | Direct: 206.957.0314 | Cell: 206.719.3421 | Fax: 206.230.9601

HEALTH ENVIRONMENT TECHNOLOGY SUSTAINABILITY


-----Original Message-----From: Woods Poon, Leanna M NWS [mailto:[email protected]]Sent: Thursday, April 26, 2012 4:48 PMTo: Linda Baker; Reid Carscadden; Kimberly Magruder Carlton; Richardson, Brett([email protected])Cc: Piper Peterson ([email protected]); Greg Glass ([email protected]); Osborne,Jayson B NWS; [email protected]: RE: T117 QAPP Response to Comments Follow-up (UNCLASSIFIED)


Hello Linda,

Thank you for spending some time talking to Greg and I about these comments. Due to timeconstraints on the phone (and for the benefit of the group), here is a summary of our conversation andresponse other topics:

We plan to discuss the laboratory protocol for parking strip composites tomorrow. I should be availablemost of the day.

1) DU 16 and DU 20/21

Due to the gas line running north-south along the entire length of the narrow DU 16, it is agreed thatpre-confirmational sampling will not be possible. Therefore MIS sampling will be completed at DU 16upon excavation to 2 feet depth. Lab turnaround time may be up to a week, so (as we discussed) theopen excavation will need to be covered and barricaded. Also, no work at DU 17 should be done whileDU 16 remains open to allow for continued access on 16th Ave S.

At DU 20/21, the gas line runs north-south through the middle of the DU. Since DU 20/21 is wider thanDU 16 and there is room on either side of the gas line for MIS sampling, pre-confirmational samplingoutside of the 6 ft buffer zone is possible. A random number generator should be used to identifysampling locations along transects. It is recommended that if a random number falls within the 6 ftbuffer zone, than another random number should be generated until outside of the buffer zone. Thereshould be no bias as to how many samples are taken east or west of the gas line.

2) DU 32, PS South A, and PS South B

The question at DU 32 has yet to be resolved. Greg plans to discuss the EE/CA field notes with the Cityfield team to help determine what exactly was sampled during that time. Linda is checking on EE/CAactivities at DU 12. Will discuss tomorrow?

Similar to DU 16, the gas line runs directly through the length of PS South A and PS South B. Thereforediscrete sampling will be completed at PS South A and PS South B upon excavation to 1 and 2 feetdepth, respectively. Lab turnaround time may be less than a week (depending on our laboratoryprotocol discussion tomorrow). The open excavation will be covered and barricaded. Linda plans tocheck with the owner and tenant at 1425 regarding the tenant's access to their home/(possibledriveway?) while the excavation at PS South A is open.

3) Generation of sampling coordinates along the EUs

The figure and table sent to Greg and I seem acceptable. We clarified on the phone that the field teamwill locate sampling locations via x,y coordinates from a surveyed and marked location (Linda willconfirm this). Also, exclusion zones for sampling include the sidewalks, area along Basin Oil, and theboats on EU 1. Linda will determine if other sampling exclusion zones are needed. Also, the reservedcomposite sampling locations will be utilized (when necessary) on a point by point basis, meaning that if2A and 2B are good but 2C meets refusal, than the location of 3C could be utilized to take an alternatesample along the 2C transect.

We would like to see an example of sampling coordinate generation on a EU that is L-shaped, such asEU 9.

4) Processing field samples

We agreed that tubes from the entire sampling depth will be evaluated for recovery before compositingthe sample.

I think that's it for now.

Regards,Leanna

-----Original Message-----From: Woods Poon, Leanna M NWSSent: Tuesday, April 24, 2012 5:12 PMTo: 'Linda Baker'; Reid Carscadden; Kimberly Magruder Carlton; Richardson, Brett([email protected])Cc: Piper Peterson ([email protected]); Greg Glass ([email protected]); Osborne,Jayson B NWS; [email protected]: RE: T117 QAPP Response to Comments Follow-up (UNCLASSIFIED)


Hello Linda,

Thank you for the RTC. Could you please clarify the last sentence in the response to Comment #8: "Thelaboratory will further homogenize the sample in the laboratory before removing the aliquot foranalysis." Please verify that the same protocol that was attached to your email will be utilized for allparticulate samples in the laboratory.

Also, Greg has informed me of a few field issues that require our quick feedback:

1) DU 16 (and likely to apply to DU 20 and DU 21).The utility survey located a gas line that runs north-south through DU16. Field personnel indicated toGreg that a 3ft setback would be required on either side of the pipe during geoprobe sampling, whichwould reduce the immediately accessible area of DU16 by about half. As I understand it, your optionsare to 1) complete MIS sampling in the accessible area now and then complete another round of MISsampling throughout the entire DU upon excavation around the pipe, or 2) take half of your MISsamples now in the accessible area, run analysis, determine approximate excavation depth, and archivethe remaining sample to be potentially combined with the other half of the MIS samples after the areaaround the pipe has been excavated. Greg and I think the latter option is the better, but I'd be willingto discuss this tomorrow.

2) DU 32 (near bldg 1445)Sampling has occurred behind the fence and in a parking area on the outside of the fence, leaving agrassy area in between without samples (to be verified?). Both sampled locations have come backcontaminated. A few samples could be collected in the grassy area with the geoprobe or hand auger tohelp determine the depth of excavation between these areas, which would be beneficial because we donot know if the homeowner will accept us removing the mature hedge that is growing along the fenceline.

3) Generation of sampling coordinates along the EUsPlease provide a quick explanation as to the methods that will be utilized to generate street samplingcoordinates. I believe the current thinking is to utilize City geo-data to identify the boundaries of theright of way areas and then generate random sampling locations. We want to ensure that samples arenot biased to the edge of the street.

4) Processing field samplesEvery effort should be made to consider the recovery of each sample location as a whole. I understandthat the shallow sample from each hole gets to the processing station first, followed by the deepersample ~3 minutes later. Instead of just looking at the recovery of each sample tube individually, all ofthe tubes for each hole should be evaluated for recovery together before processing... to avoidcompositing the shallow material from a 95% recovery tube before seeing that the deeper material onlyhad 75% recovery.

Please let me know if you have any questions. I will try to be as responsive as possible tomorrow,though I have back to back meetings from 10:30am to 2:30pm. My Thursday and Friday are clear (fornow!)

Cheers,

Leanna


-----Original Message-----From: Linda Baker [mailto:[email protected]]Sent: Monday, April 23, 2012 10:50 PMTo: Woods Poon, Leanna M NWS; Reid Carscadden; Kimberly Magruder Carlton; Richardson, Brett([email protected])Cc: Piper Peterson ([email protected]); Greg Glass ([email protected]); Osborne,Jayson B NWS; [email protected]; Linda BakerSubject: RE: T117 QAPP Response to Comments Follow-up (UNCLASSIFIED)

We have responded to the follow-up questions on the QAPP response to comments below in blue italicfont. Please let us know if additional clarification is needed.

Thanks

Linda Baker


Direct: 206.957.0314 | Cell: 206.719.3421

-----Original Message-----From: Woods Poon, Leanna M NWS [mailto:[email protected]]Sent: Wednesday, April 18, 2012 12:24 PMTo: Linda Baker; Reid Carscadden; Kimberly Magruder Carlton; Richardson, Brett([email protected])Cc: Piper Peterson ([email protected]); Greg Glass ([email protected]); Osborne,Jayson B NWSSubject: T117 QAPP Response to Comments Follow-up (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats: NONE

Hello Team,

EPA, USACE, and Greg have some follow-up on the City QAPP RTC.

Regarding the response to Comment #2: The approach to be utilized in the Parking Strip EUs along S.Cloverdale Street is acceptable. Instead of calculating UCLs, discrete sampling will be conducted inthese small areas and there will be no allowable exceedances of the RvAL of 1 mg/kg PCBs. Any singlepoint sample above the RvAL will result in additional soil excavation over the entire EU.

Regarding the response to Comment #3: We request some clarification regarding this response. Doesthis response say that d/f analyses will be done at a single depth just below the PCB-determinedexcavation depths, once determined? Or is the response suggesting that samples will be archived toallow such d/f analyses, without a deterministic assurance that analysis will be completed? The responseindicates that the City will hold samples for 4 months before discarding. Note, that archived samplesshould not be discarded without clear acceptance from EPA and that samples many need to be frozen inorder to be viable for later analysis. Holding times and preservation techniques should be clearly statedfor the archived samples.

Samples will be analyzed for PCB concentrations sequentially with depth. The first sample that passesthe PCB criteria outlined in the QAPP will delineate the excavation depth and a portion of this samplewill be held for dioxin/furan analysis should EPA and Ecology decide analysis is necessary. For each DU,an aliquot of the MIS sample will be held for dioxin/furan and total solids analysis; for Street EUs asufficient portion of the two applicable composite samples will be retained for dioxin/furan and totalsolids analysis. For the parking strip EUs, equal amounts from the three to five discrete samples at thepassing depth will be composited into one sample that will be held for potential dioxin/furan and totalsolids analysis. Samples will be held until directed by EPA to either analyze or discard the sample.Dioxin/furan analysis, if needed, will be completed using Soxhlet extraction, sulfuric acid cleanup,silica/carbon column cleanup, and analysis by EPA 1613B (HRGC/HRMS). Samples will be preserved byfreezing (-20C) in glass jars.

Regarding the response to Comment #8. The response does not appear to apply to the comment. Thesecond paragraph of the comment refers to lab subsampling procedures, not the field methods forcollecting composite samples. We would like concurrence on the method at the lab for getting asubsample for instrumental analyses from the jars as submitted, and that this incremental methodshould be used for all soil (particulate) samples.

MIS subsampling procedures will apply to samples collected from DUs and will follow the laboratorycompositing procedures in Attachment 3 to the April 2009 QAPP. The protocol is attached for referenceand will be attached to the final QAPP for completeness. We have confirmed with Columbia AnalyticalServices that the attached Revision 3 is the current protocol used for MIS sampling. Consistent withnon-MIS sampling protocols, compositing/homogenization of EU samples will occur in the field. Thelaboratory will further homogenize the sample in the laboratory before removing the aliquot foranalysis.

Regarding the response to Comment #11, Figure B1 as revised. The middle blue diamond box stillappears to refer to sample count rather than area when referencing the MTCA 10% rule. The textshould be revised for clarity. We need to have concurrence that 2 of 13 street EUs accounting for 9%of total street EU area is not a failure, but 1 of 13 street EUs accounting for 12% of total street area is a

failure.

The wording in the middle blue diamond box will be revised to "Do composite averages exceed RvALover more than 10 percent of the street EU area".

Regarding the response to Comments #14 and 16. It is assumed that linear interpolation will always beused to pro-rate depth intervals for less than 100% recoveries, even if soil color or other featuressuggest non-linearity in recovery. Please confirm this to be the case. Also, if 2 or 3 locations can't besampled "in the vicinity" of an initial 30-location MIS sample in a residential DU (due to tree roots orburied debris, etc), additional "makeup" locations within the initial grid layout should be selected asneeded to assure at least a 28-location MIS composite sample.

Sample recovery will be based on the volume recovered in the Geoprobe sample tube - as measured bythe length of sample recovered. If the sampler is advanced three feet (6 intervals), then at least 2.25 ftmust be recovered and that recovered length would be split into 6 equal intervals for collecting the 6sample intervals. With regard to third sentence, should recover be below 75% on more than 28 of theMIS locations, additional random locations will be selected for sampling so that there is a minimum of28 sample locations with greater than 75% recovery in the MIS composite sample.

Please let us know if you have any questions.

Thanks,

Leanna

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Leanna Woods Poon, M.S.

Environmental Engineer

USACE Seattle District

4735 E Marginal Way South

Seattle, WA 98134

Phone: 206.764.3322

[email protected] <mailto:[email protected]>

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

-----Original Message-----From: Woods Poon, Leanna M NWS [mailto:[email protected]]Sent: Tuesday, April 17, 2012 7:27 PMTo: Linda Baker; Piper Peterson ([email protected]); Osborne, Jayson B NWS; Greg Glass([email protected])Cc: Richardson, Brett ([email protected]); Reid Carscadden; Kimberly Magruder CarltonSubject: RE: Request for expedited review - Revised DU35a and borehole backfill (UNCLASSIFIED)


Hi Linda,

I was in a Port meeting all afternoon and my "out of office" wasn't functioning. Piper, Greg, and Idiscussed plan the proposed by Kim on Monday (attached email). We have not had time to discuss allthe detail that was included in your most recent email.

If you are able to access the area west of DU35a with a portable drill rig, that should be attempted andthe area should be included in DU35a. Otherwise, 5 discrete contingency samples should be taken from0-2 ft, to be analyzed if warranted following DU25a and DU35a results.

Regarding soil backfill, we agree that clean sand should be utilized to minimize soil settling issues.However, we suggest adding that the holes are filled with clean material to at least 3 or 2 feet bgs tohelp avoid potential dioxin/furan complications at depth in the future.

I hope this helps answer your questions. I will be in the office on conference calls in the morningtomorrow. Piper, Greg, and Jayson will be at the site (I believe ~10am).

Regards,Leanna


-----Original Message-----From: Linda Baker [mailto:[email protected]]Sent: Tuesday, April 17, 2012 2:58 PMTo: Piper Peterson ([email protected]); Woods Poon, Leanna M NWS; Osborne, Jayson BNWS; Greg Glass ([email protected])Cc: Richardson, Brett ([email protected]); Reid Carscadden; Kimberly Magruder CarltonSubject: Request for expedited review - Revised DU35a and borehole backfill

I am catching up from a few days off and hoping to iron out the last few sampling details for the T-117Streets & Yards. I tried to touch base with Leanna via phone, but she seems busy so I am sending anemail to all.

The following is the City's proposal for dealing with the back yard at 1425 S Cloverdale St (DU35a) andborehole backfilling. I believe the proposed approaches are consistent with comments/requests madeby the USACE and EPA. We hope it is acceptable as we are planning to start surface soil sampling inDU35a tomorrow AM and subsurface sampling in late morning. Sorry for the short review time - pleaselet us know as soon as possible if you have concerns with the proposed approaches.

The back yard at 1425 S Cloverdale St (DU35a):

We are proposing to expand DU35a to include other portions of the back yard of 1425 S Cloverdale Stas shown on the attached figure (west side of Figure A1 from the QAPP). DU35a will be expanded toinclude the parking area south of the new building (just west of the originally proposed DU35a) and thestrip between the new building and the fence on the far west side of the property. During the driller'ssite visit, the driller indicated that he expects they can get their smallest drilling equipment between thenew building and the fence, so this area will be included (as well as the hard-packed parking area onthe west side of the back lot - provided the drill can penetrate). Should access be problematic when the

drillers equipment is actually onsite, we will default to the original DU35a and confer with EPA on othermeans of addressing soil conditions in the strip between the new building and the fence.

Borehole backfilling

The boreholes will be backfilled with clean sand. For boreholes in planters or other garden areas, thetop six inches of the borehole will be filled with topsoil.

Linda Baker | Principal Hydrogeologist

Integral Consulting Inc. | www.integral-corp.com <http://www.integral-corp.com/>

411 1st Avenue S., Suite 550 | Seattle, WA 98104

Tel: 206-230-9600, ext. 314 | Direct: 206.957.0314 | Cell: 206.719.3421 | Fax: 206.230.9601

HEALTH ENVIRONMENT TECHNOLOGY SUSTAINABILITY


Hello Leanna, After our site visit and discussions with the driller last Thursday, we might be able to access the area west of the shed at DU35a with the M420 portable drill rig. If we can reasonably do this, shall we go ahead and include this area in DU35a? If we are unable to successfully access this area, we will proceed with collecting 5 discrete samples along the west side of the shed from 0-2 ft bgs, and archive them (pending DU25a and DU35a surface interval PCB results). Regarding soil backfill - We can use soil to backfill the 6" deep holes left from surface MIS DUs (DU25a, DU25b, and DU35a), because we can easily pack it down to minimize any settling that would occur over time. However, in order to avoid issues with the soil settling into the 4 to 6 ft depth holes from the push-probe sampling (essentially creating miniature sinkholes throughout the yards over time), we would like to propose backfilling the holes created by the push-probes with clean sand, rather than clean soil. From the driller's experience - this would be the best option and leave the least impact. Let me know if you concur. Thanks, Kim 360.756.9296 -----Original Message----- From: Woods Poon, Leanna M NWS [mailto:[email protected]] Sent: Friday, April 13, 2012 2:18 PM To: Linda Baker; Reid Carscadden; 'Richardson, Brett'; Kimberly Magruder Carlton Cc: Piper Peterson; Greg Glass; Osborne, Jayson B NWS Subject: T-117 Streets and Yards QAPP (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE Hello Team, As we discussed during the monthly meeting regarding response to Comment #16, USACE/Greg agree that full MIS sampling in the area west of DU35a is not practical due to the access limitations. However, we would suggest that contingency surface samples could be taken at five locations (0-2 ft) by hand auger (or some other method) in this area. These samples could be analyzed if the DU35a and DU25a results do not provide sufficient information to make a clear decision regarding the status of the alley. Regarding the response to Comment #20, Jayson has looked at the WAC (below) and we are in agreement that these regulations do not seem to apply to our situation. We are not collecting information regarding the structural properties of the subsurface (which would be a "Geotechnical soil boring") and we are not installing a cased boring to collect subsurface information (which would be a "Resource protection well"). Therefore, we suggest that bentonite is not used to fill the sampling holes; soil should be utilized instead. Clean material would be preferable in order to avoid any potential future complications regarding dioxin/furan contaminated soil mixing into the subsurface.

Discussion on borehole closure requirements under WA state law: WAC 173-160-460 references "resource protection wells and geotechnical soil borings." The section further states "Direct push wells shall be decommissioned in accordance with this section." [WAC 173-160-460, (2)(d)] The section also defines definition of terms: - WAC 173-160-410, (3) "Geotechnical soil boring" or "boring" means a well drilled for the purpose of obtaining soil samples or information to ascertain structural properties of the subsurface. - WAC 173-160-410, (13) "Resource protection well" means a cased boring intended or used to collect subsurface information or to determine the existence or migration of pollutants within an underground formation. Resource protection wells include monitoring wells, observation wells, piezometers, spill response wells, remediation wells, environmental investigation wells, vapor extraction wells, ground source heat pump boring, grounding wells, and instrumentation wells. Please let us know if you have any questions. Thank you, Leanna ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Leanna Woods Poon, M.S. Environmental Engineer USACE Seattle District 4735 E Marginal Way South Seattle, WA 98134 Phone: 206.764.3322 [email protected] ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Classification: UNCLASSIFIED Caveats: NONE

From: Linda BakerTo: Linda BakerSubject: Greg-Nick emails 4/4 and 4/5 regarding comment 21Date: Friday, April 06, 2012 6:21:45 PMAttachments: EU Sample Locations.xls

-----Original Message-----From: Greg Glass [mailto:[email protected]]Sent: Thursday, April 05, 2012 6:02 PMTo: 'Nick Varnum'Subject: RE: T-117 revised QAPP comments (UNCLASSIFIED)

Hi Nick,

OK, let me try to describe the procedure I have in mind. Call me to get any remaining questionsanswered - evenings are fine, even late, but I'll be out tonight until about 9 though. The following textwill be redundant for you in places, I know.

For a "regular rectangular" EU, one way to get equal probability sampling done, and still providereasonable "spatial coverage" of the EU, is to use a grid sampling approach with a random grid startingpoint. Simple random sampling, especially with a small number of locations sampled, also is equalprobability but is often found to provide "clustering" of sampling locations and poor overall spatialcoverage. So the grid approach better satisfies both equal probability and spatial coverage goals.

The simple "grid" idea for a "thin ribbon" like a street has been modified to locating "transects" alongone dimension and then selecting sampling locations along each transect by a random process. (Amongother things, this avoids having all "grid" locations on a single alignment). I think this follows prettymuch the ideas we used to sample the narrow DUs along 16th Avenue S a while back.

The total length along one side of the EU, divided by the number of locations per composite sample,defines a "segment length" - just as you have it. So for the first figure, X = 125 feet, a 3:1 compositeis to be collected, and thus X/3 = 41.7 feet. The key to laying out the 3 transect locations is torandomly locate the first one in the first segment, measuring from one end point. So with a randomnumber between 0 and 1 to establish the fraction of segment length to the first transect we fix thatlocation. Using a random value of 0.30 would give 0.3 x 41.7 ft = 12.5 feet, so the first transect wouldbe 12.5 feet from the end point. The second transect would be at 12.5 + 41.7 ft = 54.2 feet, and thethird at54.2 + 41.7 ft = 95.9 ft. If the second composite sample has a random value of 0.74 to fix the startingtransect location, the transects would be at30.8 ft, 30.8 + 41.7 = 72.5 ft, and 72.5 + 41.7 ft = 114.2 ft. [Note: the random numbers between 0and 1 should be carried to at least 2 decimal places for calculations, which would locate spots to withinless than a foot or so, as opposed to one decimal place which would be 10 feet on a 100 ft Xdimension]. So unlike your drawing, the random value is applied only to find the first transect location,not all three. Random selection within each "segment" could produce clustering of sampling locations,to a greater degree than the "grid = transect + distance along transect" approach.

Then the distance along each transect, generally across the traffic lanes, would be determined byrandom values between 0 and 1 applied to the Y distance. This is what you have, I think, in thesecond part of the top figure (sample locations)- but use at least 2 decimal places for the randomvalues and calculations, as before. Actually it is best to just generate random values in the 0,1 intervaland round to the nearest tenth of a foot or so after calculations for laying out transect and samplinglocations.Note that with random values close to 0 or 1 the sampling locations could be very close to the streetedges - and that is fine. One could posit a CSM with variable probability of residual contaminationacross a transect - lower at the centerline, for example, which could be crowned for runoff and whichisn't a traffic lane, maybe higher at the edges where runoff could have pooled. But we are using astraight equal probability model, so an equal probability (equal frequency, in the limit of many samples)of sampling anywhere across the street width is invoked by the random selection process. This just

requires care and good judgment for defining where the edges of the streets are, especially if selecteddistances along transects give sampling locations very near the edge (i.e., random values close to 0 or1).

The places where an EU bends around a corner or is otherwise not a rectangle are illustrated in yourbottom figure. The only real difference is in how the total X length is determined, to start laying out thetransect locations- and you have that, I think. Essentially if one breaks up the EU into(approximately) rectangular, non-overlapping blocks, the total X length is the sum of the pieces requiredto provide possible transect that cover the whole area. In your bottom figure, exactly right: X (total) =X1 + X2, without duplicating the length to the left of X2 that is already covered for possible transects bylength X1. The transect directions will change, as you show in your Y1 and Y2 vectors.

So just as in the simpler case above, use a single random value between 0 and 1 to determine the firsttransect location. Then add the segment length successively to find the next transect locations. In thiscase, however, you may need to "bend the measurement" from the end of X1 onto X2. Example:if X1 = 100 ft and X2 = 50 feet, with a 4:1 composite design, the segment length would be 150/4 ft or37.5 ft. If the first transect is located at 30 ft, the second would be at 30 + 37.5 = 67.5 feet (fine sofar) and the third would be at 67.5 + 37.5 = 105 ft. This third transect would be located by moving all100 feet along X1, then an additional 5 feet along X2 - i.e., "bent around the corner". Once transectsare located, random values between0 and 1 are used as before to find sampling locations on each transect. If the street width varies, thespecific widths at each transect would be used with the random value between 0 and 1 to find samplinglocations for that transect. The street "width" near the corner, where blocks are adjacent, is alwaysdetermined just within one block - so in your bottom figure in the blue block, only up to the Y1 length,as you show. Exactly right.

Clear as mud? Call me as needed...

Cheers,

Greg206 523 [email protected]

-----Original Message-----From: Greg Glass [mailto:[email protected]]Sent: Thursday, April 05, 2012 11:12 AMTo: 'Nick Varnum'Subject: RE: T-117 revised QAPP comments (UNCLASSIFIED)

Hi Nick,

Thanks for this well-drawn example.

On closer reading, I think the first part - finding the transect locations - isn't quite what I had in mind.I am overdue at another meeting for mid-day- hope it is OK that I'll send you revision when I return this afternoon.

In brief, what I wanted was a grid approach with equal spacing between transects, and with a randomstarting point in the first "segment" (total X distance divided by number of locations in a compositesample equals segment length). So the second and third transect locations are fully determined bysegment length and first transect random starting point. For the L-shaped EUs, a "segment" couldactually bend around the point of the L.

More later...


-----Original Message-----From: Nick Varnum [mailto:[email protected]]Sent: Thursday, April 05, 2012 9:07 AMTo: 'Greg Glass'Cc: 'Linda Baker'; 'Reid Carscadden'Subject: RE: T-117 revised QAPP comments (UNCLASSIFIED)

Greg, attached is the picture(s) I get from your description. Does this look right?

_____________________________Nick Varnum503.349.084186.01.52.94

-----Original Message-----From: Greg Glass [mailto:[email protected]]Sent: Wednesday, April 04, 2012 11:39 AMTo: [email protected]: FW: T-117 revised QAPP comments (UNCLASSIFIED)

Hi Nick,

When you get to comment 21 on the selection of sampling locations, feel free to call me to get clarityon the details. (A case of a picture being worth a thousand words, but you don't have a picture in thecomments).

Regards,


-----Original Message-----From: Osborne, Jayson B NWS [mailto:[email protected]]Sent: Friday, March 30, 2012 3:13 PMTo: [email protected]; Linda BakerCc: Piper Peterson; Woods Poon, Leanna M NWS; Greg GlassSubject: T-117 revised QAPP comments (UNCLASSIFIED)


Reid and Linda,

Please find attached Greg's comments on the revised QAPP for the T-117 streets and yards.

Thanks,

Jayson

[email protected] Seattle District

Environmental Engineering and Technologyoffice: 206-764-3521 BB: 206-369-2615


ATTACHMENT E2 MAY THROUGH JULY 2012 QAPP

ADDENDUM – ADDITIONAL

SCOPE ITEMS

October 26, 2012

ATTACHMENT E2

ADDENDUM TO THE QUALITY ASSURANCE PROJECT PLAN, PRE-DESIGN SAMPLING, ADJACENT STREETS AND RESIDENTIAL YARDS STUDY AREA, SEPTEMBER 2012—SUMMARY OF ADDITIONAL SCOPE

The City of Seattle (City) and the U.S. Environmental Protection Agency (EPA) expanded the original scope of work outlined in the March 21, 2012, draft final pre-design quality assurance project plan (QAPP) (Integral 2012) to collect additional data needed to complete the expanded fall 2012 Residential Yards cleanup. The original scope of the remedial design sampling program was completed in early May 2012. Additional sampling was conducted based on results from this original scope; the scope of additional sampling was determined in cooperation with EPA and documented in e-mail prior to implementation of work. The additional sampling was completed in four separate field events from mid-May through mid-August 2012, as presented in Figure 1. Minimum excavation depths for each removal area are included in Figure 1, and are based on the first sample depth interval with total polychlorinated biphenyl (PCB) concentrations below the remediation level of 0.50 mg/kg.

The additional sampling was completed in accordance with the March 2012 QAPP (Integral 2012) and subsequent EPA and City communications during late March and April 2012. The revised QAPP incorporates these late March and early April comments and responses and this addendum describes the additional pre-removal sampling approach, scope and locations. References to e-mails or other communications documenting the decisions for the additional scope items are provided in this addendum.

Overview of Additional Sampling

Additional sampling was completed at residential decision units (DUs) and alleyways based on preliminary results from sampling described in the QAPP and EPA directives. The April and early May 2012 sampling described in the Pre-design QAPP (Integral 2012) included sampling in two backyards that were not previously investigated during the Engineering Evaluation and Cost Analysis (EE/CA; Windward et al. 2010), to determine whether the removal area identified should be expanded to include the backyard of those properties.

The April and early May 2012 results indicated that PCB concentrations in soils from the backyard of 1425 S. Cloverdale Street (DU35a) exceeded the remediation level and thus would need to be added to the removal action. Per the decision rules developed during the engineering evaluation/cost analysis (EE/CA), yards adjacent to yards exceeding the remediation level (identified for removal) were to be sampled. Following this approach, the PCB results for DU35a triggered sampling of adjacent accessible properties and along

T-117Adjacent Streets and Residential Yards QAPP Attachment B – Additional Scope October 26, 2012 the S. Cloverdale Street–South Donovan Street alleyway (commonly referred to as the Southern Alleyway) in late May 2012. This late May 2012 sampling included the following:

• The backyards of 1421 S. Cloverdale Street, subdivided into DU36a and DU36b

• The backyard of 1445 S. Cloverdale Street, referred to as DU33a

• Portions of the Southern Alleyway referred to as Areas 14, 15, 16, and 17.

The late May 2012 sample results in turn, triggered additional sampling as follows:

• June 2012—1445 S. Cloverdale Street adjacent to DU33a, referred to as DU33b

• July 2012—Portions of the Southern Alleyway including further depth intervals from Area 14 and samples from the east end of the Southern Alleyway, referred to as Area 21

• August 2012—Collection of samples from the unpaved portions of the Northern Alleyway located between S. Cloverdale Street and Dallas Avenue S.

This work was completed between May and August, 2012 and is summarized in Figure 1. Additional details are provided in the following sections.

Figure 2 provides the results of all 2012 pre-removal confirmation PCB sampling for the yards and the adjacent alleyways (including the original scope and additional sampling). This information is included to aid in the understanding of the additional scope items. The data will be formally provided in the Pre-excavation Confirmation Sampling Report for the Residential Yards Study Area (Residential Yards Data Report; Appendix G of the Remedial Action Design Report; Integral 2012).

Per the Pre-design QAPP (Appendix F of the Remedial Design Action Report; Integral 2012), the removal action level (RvAL) for total PCBs for this project is 1.0 mg/kg for discrete sampling locations in planting strips, and the remediation level is 0.50 mg/kg for DUs (established based on an evaluation of multi-increment sample variability in the EE/CA, Appendix L). EPA also directed the City to apply the remediation level of 0.50 mg/kg for total PCBs for composite samples collected in the southern and northern alleyways (e-mail from Leanna Woods Pan dated June 16, 2012).

1445 S. Cloverdale Street (DU33a and DU33b)

Preliminary laboratory results indicated that PCB concentrations in the backyard at 1425 S. Cloverdale Street (DU35a) exceeded the remediation level. Per the decision rules developed during the EE/CA, yards adjacent to yards identified for removal (i.e., those that exceeded the remediation level) were to be sampled. The backyard of 1445 S. Cloverdale Street (DU33a) is the first accessible property east of DU35a and was added to the sampling

Integral Consulting Inc. 2

T-117Adjacent Streets and Residential Yards QAPP Attachment B – Additional Scope October 26, 2012 scope. Surface soils were collected from 0 to 0.2 ft below ground surface (bgs) and 0.2 to 0.5 ft bgs; and subsurface soils were collected in 0.5-ft intervals from 1.0 to 5.0 ft bgs. The sampling scope was outlined and approved in May 14, 2012, e-mails from Linda Baker of Integral Consulting Inc. (Integral) and Leanna Woods Pan of the U.S. Army Corps of Engineers (USACE), respectively.

Preliminary laboratory results for DU33a indicated that PCB concentrations in the area exceeded the remediation level; and triggered sampling of the uncharacterized area of the yard (DU33b) between DU33 (the front and side yards of the property; sampled in 2009) and DU33a (Figure 2). Surface soils were collected from 0 to 0.2 ft bgs and 0.2 to 0.5 ft bgs. The sampling approach was approved by EPA in an e-mail from Leanna Woods Pan on Friday June 15, 2012. Preliminary laboratory results for DU33b indicated that total PCBs in this area are below the PCB remediation level and no additional sampling was necessary.

1421 S. Cloverdale Street (DU36a and DU36b)

Preliminary laboratory results indicated that PCB concentrations in the backyard at 1425 S. Cloverdale Street (DU35a) exceeded the remediation level. Per the decision rules developed during the EE/CA, the backyard of 1421 S. Cloverdale Street (adjacent to and west of DU35a) was added to the sampling scope. Using the approach described in the pre-design QAPP for 1418 S. Donovan Street (DU25a and DU25b), the backyard of 1421 S. Cloverdale Street was divided into two areas for sampling to isolate the area adjacent to the Southern Alley from the rest of the backyard. DU36a was located in the back portion of the yard between the fence and the alley. DU36b was located in the side yard (to the west of the house) and the northern portion of the backyard (essentially from the front of the house to the back fence). Surface soils were collected from 0 to 0.2 ft bgs and 0.2 to 0.5 ft bgs; and subsurface soils were collected in 0.5-ft intervals from 1.0 to 5.0 ft bgs. The sampling scope was outlined and approved in May 14, 2012, e-mails from Linda Baker (Integral) and Leanna Woods Pan (USACE), respectively.

Preliminary laboratory results indicated that the backyard at 1421 S. Cloverdale Street behind the fence (DU36a) exceeded the remediation level. However, the backyard adjacent and along the side of the house was below the remediation level.

1417 S. Cloverdale Street DU37a

Per the decision rules developed during the EE/CA, the backyard of 1417 S. Cloverdale Street (DU37a) is adjacent to DU36a and was considered for sampling.

Field observations revealed that the entire backyard of 1417 S. Cloverdale Street is under asphalt paving and is used for parking, except a small area covered with blackberry bushes at the southeast corner (adjacent to DU36a). Paved areas and other areas that preclude


T-117Adjacent Streets and Residential Yards QAPP Attachment B – Additional Scope October 26, 2012 access to surface soils are exempt from samples per decision rules developed for the EE/CA. Sampling was initially considered for the small blackberry-covered area as an extension of the removal at DU36a (Comments on Proposed Additional June 2012 T117- Yards and Alley Scope, June 11, 2012). However, when the blackberry bushes were removed in early July 2012, the entire surface of DU37a was found to be covered with uneven asphalt with 1 to 2 inches of soil and overlying leaf litter.

As there are no exposed surface soils at this location, no sampling will take place. In addition, the excavation boundary for DU36a will not extend into DU37a. The City agreed to remove the accumulated soil and leaf litter layer from the asphalt immediately adjacent and west of DU36a during the Residential Yards cleanup.

Southern Alleyway

Preliminary laboratory results indicated that DU35a soils exceed the remediation level along the north side of the Southern Alleyway. EPA directed the City to sample throughout the unpaved portion of the Southern Alleyway including the area adjacent to the backyard of 1425 S. Cloverdale Street (DU35a). The sampling scope was outlined and approved in field conversations and follow-up e-mails dated May 14, 2012, from Linda Baker (Integral) and Leanna Woods Pan (USACE), respectively.

The alley was divided into four discontinuous areas (Areas 14, 15, 16, and 17) with Areas 15 and 16 immediately adjacent to DU35a and Areas 14 and 16 characterizing the western and eastern portions of the alleyway, respectively.1 Each area was subdivided into northern, middle, and southern subareas Xa, Xb, and Xc, respectively. The subareas Xa and Xc are 2 ft-wide strips along the north and south alley borders, with Xb subareas representing the remaining widths through the middle of each area as follows: 14b (8.0 ft), 15b (3.8 ft), 16b (5.0 ft), and 17b (8.0 ft). The sampling approach for the Southern Alleyway consisted of the collection of a 4:1 multipoint composite in each Xa and Xc subarea and collection of an 8:1 multipoint composite in each Xb subarea. When sample points within subareas Xa and Xc were adjacent to a physical structure (e.g., fence or building), the sample point locations were offset by 6 inches to accommodate the drill rig. Positioning of the point samples within each subarea followed the same procedures as random point sample positioning for the excavation unit areas for streets as described in the pre-design QAPP.

The alley was initially sampled from 0 to 1.0 ft bgs and from 1.0 to 2.0 ft bgs. All boring locations were positioned where the surface soils included fine material. If the random sampling design placed a boring in an area consisting primarily of large rocks/gravel, an alternate location was selected. Field notes and photos were taken to describe sampling

1 In the original EPA sampling scope approval email, the central areas (Area 15 and 16) were to be sampled as one area. This central area was subdivided into two areas based on field discussion.


T-117Adjacent Streets and Residential Yards QAPP Attachment B – Additional Scope October 26, 2012 locations, noting presence of potholes or other surface features and are presented in the Residential Yards Data Report. Elevations at each sampling location were determined to judge excavation depths more accurately.

The northern and southern subareas (subareas Xa and Xc) generally included private property, which required access agreements from the property owners prior to sampling. All access agreements were obtained except for a portion of Subarea 14c and Subarea 17c. Property owners from 1446 S. Donovan Street in Subarea 14c were not available and the property owner from 1412 S. Donovan Street denied access. Therefore, Subarea 14c did not include any point samples from the 1446 S. Donovan Street property, and Subarea 17c was not sampled.

Total PCB concentrations were below the remediation level for from the 0 to 1.0 ft and 1.0 to 2.0 ft bgs sampling intervals in Subareas 14c and 17a; and the 1.0 to 2.0 ft bgs sampling intervals in Areas 15 (Subareas 15a, b, and c), 16 (Subareas 16a, b, and c), and Subarea 17b. No further sampling analysis was necessary for these subareas. Results are discussed in more detail in the Residential Yards Data Report.

Due to exceedances of the remediation level in the lower interval (1.0 to 2.0 ft bgs) at Subareas 14a and 14b, additional samples were collected in July 2012 from these subareas at 0.5 ft intervals from 2.5 to 6.0 ft bgs, as well as the area east of Area 14 and west of 16th Avenue S. (Subareas 21a and 21b). The sample from Subarea 21a consists of a 4:1 multipoint composite, and the sample from Subarea 21b consists of an 8:1 multipoint composite from an area 13 ft wide. These samples were collected to determine the extent of soil removal depth required along the eastern portion of the Southern Alleyway. This sampling approach for the additional depths and Area 21 were discussed with EPA and outlined in July 4 and July 11, 2012, e-mails from Linda Baker of Integral.

Total PCB concentrations were below the remediation level at 2.5 ft bgs for Subareas 14a, 14b, and 21a; and 3.0 ft bgs for Subarea 21b. Final sample results are discussed in the Residential Yards Data Report.

Northern Alleyway

Based on the results from the Southern Alleyway, EPA directed that the unpaved portion of the Northern Alleyway be sampled. This alleyway was divided into three areas (Area 18, 19, and 20; two along the longer east-west portion of the alleyway and one perpendicular to Dallas Avenue S.). To expedite the work, sampling was restricted to the main City-owned portion of the Northern Alleyway and these areas were referred to as 18b, 19b, and 20b (Figure 2). Surface soils were collected from 0 to 1.0 ft bgs and 1.0 to 2.0 ft bgs, and subsurface soils were collected in 0.5-ft intervals from 2.5 to 6.0 ft bgs. Each area sample from the Northern Alleyway consists of an 8:1 multipoint sample composite.


T-117Adjacent Streets and Residential Yards QAPP Attachment B – Additional Scope October 26, 2012 Analysis of the all depth intervals for each of the Northern Alleyway subareas resulted in detections below the remediation level, thus no further sampling or analysis was necessary.


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17th

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S Cloverdale St

S Donovan St

Boeing South Park

Lower Duwamish Waterway

FormerBasin OilStorage

MW-13

MW-12

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MW-11

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MW-5R

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MW-06

MW-05

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Marina MW-2

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MW-09

MW-08

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SW-2

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Map 2-7. Sampling locations in the T-117 EAA and vicinity

Sampling locations

!(Adjacent streets andresidential yards study area

!(Adjacent streets and residential yardsstudy area - superseded or removed

!( T-117 sediment study area

!( T-117 upland study area

!( Basin Oil

!( South Park Marina

## Archived 2008 samples

Decision Units for MultipleIncrement Sampling

hg Seep sample locations*

�/ Catch basin

A Existing monitoring well

T-117 EAA boundary

Unpaved area

Paved terminal area

Building

Basin Oil recontaminationassessment areas

South Park Marinarecontamination assessment area

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Intertidal mudflat habitat (-4 ft to +5 ft)

Navigation channel

* Marked seeps do not represent all seeps present at the site.Other seep locations are present that have not been sampled

±

0 150 30075

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0 30 6015

Meters

Map 2-29. Adjacent Streets total PCB concentrations in soil, 2004-2006

0 0 .0 2 04 - 6 1.8 *

6 7.08 - 9 2 510 55

TP8 5

2 - 4 0 .0 2 0 U4 - 6 0 .0 19 U

P6 0

1- 2 0 .172 - 4 0 .0 12 J4 - 6 0 .0 2 0 U

P6 2

1- 2 0 .0 19 U2 - 4 0 .8 3 *4 - 6 0 .586 - 8 0 .0 2 0 U

P6 5

1- 2 0 .6 82 - 4 1.44 - 6 0 .0 54

P6 6

2 - 4 0 .2 84 - 6 0 .11

P6 7

1- 2 2 .42 - 4 0 .0 504 - 6 0 .4 1

P6 8

1- 2 0 .0 2 0 U2 - 4 0 .0 2 0 U4 - 6 0 .0 19 U

P6 9

2 - 4 0 .0 19 U *4 - 6 0 .0 19 U

P70

1- 2 0 .3 72 - 4 0 .144 - 6 0 .0 2 0 U

P71

2 - 4 0 .0 3 64 - 6 0 .0 2 0 U6 - 8 0 .0 2 0 U

P72

1- 2 0 .0 2 52 - 4 0 .0 2 0 U4 - 6 0 .0 2 0 U6 - 8 0 .0 2 0 U

P73

1- 2 1.72 - 4 0 .0 2 04 - 6 0 .0 19 U

P74

1- 2 0 .0 4 22 - 4 0 .0 2 0 U *4 - 6 0 .0 19 U

P75

1- 2 0 .9 02 - 4 0 .0 19 U4 - 6 0 .0 14 J

P76

1- 2 0 .0 2 0 U2 - 4 0 .0 19 U4 - 6 0 .0 2 0 U

P77

2 - 4 0 .0 2 0 U4 - 6 0 .14

P78

2 - 4 0 .0 4 54 - 6 0 .11

P79

2 - 4 0 .0 2 0 U *4 - 6 0 .0 16 J

P8 0

1- 2 3 9 02 - 4 0 .144 - 6 0 .0 4 16 - 8 0 .0 2 0 U

P8 1

1- 2 0 .0 2 22 - 4 0 .0 4 64 - 6 0 .0 3 0

P8 2

1- 2 7.72 - 4 0 .0 4 94 - 6 0 .0 2 0 U

P8 3

1- 2 0 .0 15 J2 - 4 0 .0 2 0 U4 - 6 0 .0 2 0 U

P8 4

1- 2 8 .32 - 4 0 .6 14 - 6 0 .0 2 0 U6 - 8 0 .0 2 0 U8 - 10 0 .0 19 U

P8 5

1- 2 6 12 - 4 0 .0 19 U4 - 6 0 .0 2 0 U6 - 8 0 .0 2 0 U *8 - 10 0 .0 2 0 U

P8 6

1- 2 0 .2 02 - 4 0 .0 2 74 - 6 0 .2 26 - 8 0 .0 4 98 - 10 0 .0 19 U

P8 7

0 0 .3 20 .5 0 .0 6 6

TP50

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0 .5 0 .0 2 0 UT P3 6 ( 1 )

0 .5 0 .4 4TP3 9 ( 1 )

0 .5 0 .6 61 0 .10

T P2 7

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TP3 0

0 .5 0 .0 19 UTP3 2 ( 1 )

0 .5 0 .0 2 0 U *T P3 3 ( 1 )

0 .5 181 3 .6

TP2 9

1 0 .4 6TP3 5

0 6 .20 .5 2 .8

TP4 7

0 .5 0 .0 8 9TP52

0 .5 0 .6 8TP51

0 .5 14 01 122 5.9

TP4 1 ( 1 )

0 .5 5.8TP3 7 ( 1 )

0 .5 10 01 0 .572 0 .2 8

TP4 2 ( 1 )

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TP2 8

0 .5 4 8 01 0 .6 82 0 .3 4

T P4 0 ( 1 )

0 .5 9 .81 1.1

T P1

0 .5 7.01 0 .3 6

TP2

0 .5 4 .71 1.7

T P3

0 .5 6 61 13

T P2 6

1 122 0 .3 43 0 .10

TP60 .5 14

1 112 12

TP19

1 7.52 0 .593 0 .15 J

T P7

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TP2 5

0 .5 4 .91 1.7

T P2 3

1 112 0 .2 43 0 .0 4 5

TP8

1 2 .62 0 .173 0 .0 4 64 0 .0 3 1 J5 0 .0 3 1 J

T P100 .5 7.0

1 1.9

TP2 4

1 182 2 13 0 .0 4 2 U

T P9

1 1.92 0 .153 0 .0 8 2

TP11

0 .5 3 .31 5.5

TP15

1 4 62 7.63 0 .3 6

TP12

1 182 0 .8 13 0 .2 0

TP13

0 .5 0 .0 141 0 .0 16

T P17

0 .5 0 .0 9 21 0 .13

TP55

0 .5 0 .101 0 .15

TP54

0 .5 0 .2 41 0 .14

T P531 0 .4 12 0 .123 0 .0 59

T P14

0 .5 1.51 0 .9 4

T P18

0 .5 0 .121 0 .0 9 0

T P2 2

0 .5 0 .9 41 0 .16

T P16

1 0 .4 72 0 .0 3 8 J3 0 .0 554 0 .0 4 0 U5 0 .0 3 9 U

T P5

0 .5 6 .31 4 .52 1.6

TP2 0

0 .5 3 81 0 .2 8

TP4

1 0 .0 19 U2 0 .0 2 0 U

T P4 3 ( 1 )

0 2 10 .5 9 3

T P4 6

1 0 .0 2 0 U2 .5 0 .0 2 0 U

TP4 4 ( 1 )

0 4 .90 .5 3 .6

TP4 50 .5 8 .61 0 .8 82 1.2

TP2 1

U

J

0 0 .0 4 60 0 .2 0 J

R S- A 5

0 0 .0 3 80 0 .0 8 9 J

R S- A 4

0 0 .100 0 .2 1 J

R S- A 6

0 0 .0 9 80 0 .18

R S- A 3

0 1.80 2 .2

R S- A 7 0 0 .3 2 J *0 3 .6 *

R S- A 1

0 2 .40 0 .8 9

R S- A 2

0 .1 0 .6 2R W - 0 3

0 .1 0 .3 3R W - 0 4

0 .1 0 .3 2R W - 0 60 .5- 2 1.4

2 .5- 4 0 .0 3 3 U5- 6 .5 0 .0 557.5- 9 0 .0 3 2 U

10 - 11.5 0 .0 3 3 U12 .5- 14 0 .0 3 3 U

M W - 9

0 .5- 2 0 .4 02 .5- 4 1.55- 6 .5 0 .547.5- 9 0 .12

10 - 11.5 0 .0 5312 .5- 14 0 .0 3 2 U

M W - 10

TP480.5 0.99

Map 2-30. Adjacent Streets total PCB concentrations in soil, 2008-2009

0 0 .0 2 04 - 6 1.8 *

6 7.08 - 9 2 510 55

P55

J

U

0 .4 - 1 2 11- 2 4 9 *

P10 0

0 .1- 1 57P9 5

0 .4 - 1 0 .0 2 7P9 6

0 .3 - 1 0 .14P9 9

0 .3 - 1 2 .6 *1- 2 0 .0 2 0 U2 - 4 0 .0 2 0 U

P10 1

0 - 1 0 .9 21- 2 0 .0 2 0 U2 - 4 0 .0 0 2 6 J

P10 2

0 .1- 1 7.4P9 4

0 .2 - 0 .5 0 .6 4Y C 12 c

0 .2 - 0 .5 0 .58Y C 12 b

0 .2 - 0 .5 0 .6 7Y C 13 c

0 .1- 0 .5 1.20 .5- 1 0 .3 5

Y C 14 c

0 - 0 .5 1.7 *0 .5- 1 0 .3 3

Y S10 0

0 .1- 0 .5 0 .4 2Y C15b

0 .1- 0 .5 1.60 .5- 1 0 .53

Y C 0 9 c0 .2 - 0 .5 1.7

0 .5- 1 0 .77

Y C 10 c

0 .1- 0 .5 4 .70 .5- 1 1.9

Y C 0 8 c

0 .1- 0 .5 1.30 .5- 1 0 .6 2

Y C 0 7c

0 .2 - 0 .5 2 .40 .5- 1 0 .77

Y C 0 6 b

0 .2 - 1 0 .2 0 JP9 2

0 .4 - 1 1.61- 2 0 .0 15

P9 0

0 .2 - 1 2 .01- 2 0 .0 0 6 7 J

P8 8

0 .3 - 1 0 .73P8 9

0 .2 - 1 1.61- 2 0 .0 0 2 7 J

P9 1

0 .2 - 1 1.51- 2 0 .0 2 0 U

P9 3

0 - 0 .5 0 .1502 .5 0 .0 13 U

M W - 13

0 - 0 .5 0 .2 72 .5 0 .0 3 2 U

M W - 12

0 - 0 .5 0 .11Y C 16 a

0 .5- 1 0 .2 1P119

0 .5- 1 0 .2 5P116

0 .3 - 1 0 .0 17 UP9 8

0 .1- 1 0 .0 57P9 7

0 - 0 .2 1.0 *0 .2 - 0 .5 0 .72 *

D U 17

0 - 0 .2 0 .4 60 .2 - 0 .5 0 .3 7

D U 15

0 - 0 .2 0 .4 50 .2 - 0 .5 1.4

D U 16

0 - 0 .2 1.20 .2 - 0 .5 1.4

D U 18

0 - 0 .2 0 .6 5 J *0 .2 - 0 .5 0 .14 J *

D U 2 0

0 - 0 .2 0 .54 *0 .2 - 0 .5 0 .9 7 *

D U 2 1

0 - 0 .2 0 .8 00 .2 - 0 .5 0 .6 8

D U 2 9

0 - 0 .2 0 .0 6 10 .2 - 0 .5 0 .0 55

D U 3 0

0 - 0 .2 1.0 *0 .2 - 0 .5 0 .70 *

D U 2 8

0 .2 - 0 .5 0 .54Y C 11c

0 - 0 .2 0 .2 10 .2 - 0 .5 0 .2 3

D U 3 8

0 - 1 0 .0 131- 2 0 .0 12 U

P10 5

0 - 1 0 .0 0 2 5 J1- 2 0 .0 15 U2 - 4 0 .0 15 U

P10 6

0 - 0 .2 5.70 .2 - 0 .5 8 .1

D U 19 0 .5- 1 0 .0 3 01- 2 0 .0 15 U

P10 7

0 .5- 1 9 .21- 2 0 .2 72 - 4 0 .0 13 U

P10 8

0 - 1 0 .50 *1- 2 0 .0 15 U *

P10 4

0 - 1 0 .6 11- 2 0 .0 2 9

P10 9

0 - 0 .2 1.4 *0 .2 - 0 .5 1.6 *

DU2 7

1- 2 0 .0 13 UP110

0 .5- 1 0 .4 71- 2 0 .0 17

P12 2

0 .5- 1 0 .0 14 U1- 2 0 .0 14 U

P117

0 - 1 0 .0 0 4 9 J1- 2 0 .0 15 U

P112

0 .5- 1 0 .0 2 0 U1- 2 0 .0 15 U

P115

0 .5- 1 0 .72 *1- 2 0 .0 102 - 4 0 .0 0 3 3 J

P118

0 .5- 1 0 .0 141- 2 0 .0 15

P12 1

0 .5- 1 0 .0 14 UP111

Map 2-36. Residential Yards total PCB concentrations in soil

0 0 .0 2 04 - 6 1.8 *

6 7.08 - 9 2 510 55

T P55

J

U

0 - 0 .2 0 .130 .2 - 0 .5 0 .11 *

D U 0 4

0 - 0 .2 0 .2 1 *0 .2 - 0 .5 0 .9 4 *

D U 0 3

0 - 0 .2 0 .0 540 .2 - 0 .5 0 .0 78

D U 0 6

0 - 0 .2 0 .0 530 .2 - 0 .5 0 .0 4 8

D U 0 8

0 - 0 .2 0 .14 *0 .2 - 0 .5 0 .15 *

D U 11

0 - 0 .2 0 .3 80 .2 - 0 .5 0 .2 2

D U 10

0 - 0 .2 0 .3 90 .2 - 0 .5 0 .3 0

D U 13

0 - 0 .2 0 .180 .2 - 0 .5 0 .14

D U 3 7

0 - 0 .2 0 .180 .2 - 0 .5 0 .17

D U 3 6

0 - 0 .2 0 .8 40 .2 - 0 .5 1.7

D U 3 5

0 - 0 .2 0 .9 8 *0 .2 - 0 .5 0 .4 7 *

D U 0 1

0 - 0 .2 0 .140 .2 - 0 .5 0 .16

D U 0 9

0 - 0 .2 0 .9 5 *0 .2 - 0 .5 0 .18 *

D U 14

0 - 0 .2 0 .3 70 .2 - 0 .5 0 .3 6

D U 120 - 0 .2 0 .16

0 .2 - 0 .5 0 .18

D U 0 70 - 0 .2 0 .2 0

0 .2 - 0 .5 0 .16

D U 0 5

0 - 0 .2 0 .2 5 *0 .2 - 0 .5 0 .3 6 *

D U 3 4

0 - 0 .2 0 .8 10 .2 - 0 .5 0 .8 0

D U 2 5

0 - 0 .2 0 .0 6 00 .2 - 0 .5 0 .0 79

D U 2 40 - 0 .2 0 .76 *

0 .2 - 0 .5 0 .2 4 *

D U 2 30 - 0 .2 0 .0 4 4 *

0 .2 - 0 .5 0 .0 74 *

DU2 2

0 - 0 .2 2 .10 .2 - 0 .5 1.4

D U 3 2

0 - 0 .2 0 .4 80 .2 - 0 .5 0 .3 4

D U 0 2

0 - 0 .2 0 .52 *0 .2 - 0 .5 0 .14 *

D U 3 3

0 .2 5 0 .3 11 0 .16

Y S54

0 .2 5 0 .0 8 21 0 .11

Y S55

0 .2 5 0 .0 4 0Y S56

0 .2 5 0 .2 7Y S3 9 0 .2 5 0 .4 4

1 0 .8 8

Y S52

0 .2 5 0 .12Y S53

0 .5 0 .11Y S3 3

0 .2 5 0 .4 1Y S4 9

0 .5 0 .12Y S3 4

0 .5 0 .3 41 0 .0 18 J

Y S2 8

0 .5 0 .2 91 0 .0 2 1 J

Y S2 5

0 .2 5 0 .3 4Y S51

0 .16 0 .0 58 UY S14

0 - 0 .5 0 .12Y C17a

0 - 0 .5 0 .17Y C 17b

0 - 0 .5 0 .15Y C17c

0 - 0 .5 0 .2 6Y C 18 a

0 - 0 .5 0 .14Y C18 b

0 - 0 .5 0 .12Y C18 c

0 - 0 .2 0 .130 .2 - 0 .5 0 .14

D U 2 6

0 .16 0 .0 9 70 .3 3 0 .0 8 7

Y S1

0 .16 0 .0 9 10 .3 3 0 .0 8 6

Y S2

3 0 .3 8Y S2 3

0 .2 5 0 .3 31 0 .2 7 *

Y S3 7

ATTACHMENT E4 EQUATIONS AND RULES FOR

APPLYING UPPER CONFIDENCE

LIMIT AND STRATIFIED SAMPLING

October 26, 2012

ATTACHMENT E4

EQUATIONS AND RULES FOR APPLYING UPPER CONFIDENCE LIMIT AND STRATIFIED SAMPLING

Definition Formula

Equation Reference

(Gilbert 1987)

Upper confidence limit on the mean for the entire area of all adjacent street confirmation samples

𝑈𝐶𝐿0.95 = 𝑥 + 𝑡0.95,𝑛−1 ∙𝑠√𝑛

11.6

Unbiased estimator for the mean of the entire area of all adjacent street confirmation samples

𝑥 = � 𝑊ℎ 𝐿

ℎ=1𝑥ℎ 5.3

Unbiased estimator for the variance of the mean of the entire area of all adjacent street confirmation samples

𝑠2(𝑥) = �𝑊ℎ

2𝑠ℎ2

𝑛ℎ

𝐿

ℎ=1 5.5

The design for T-117 pre-removal confirmation sampling has the following fixed elements:

L = 13; total number of strata (EUs).

𝑛ℎ = 2, for all ℎ = 1, … , 𝐿; sample size within each stratum, 2 composite samples.

Wh = weight of each EU in the calculation of the weighted mean for the entire excavation area (A) will be determined based on relative area of each of the EUs (Ah) as 𝑊ℎ = 𝐴ℎ/𝐴; therefore, ∑𝑊ℎ = 1.

𝑥ℎ = calculated arithmetic mean of the two composite samples within stratum EUh, for all ℎ = 1, … , 𝐿. If two composite samples from one street EU are non-detect, the variance will be calculated by assuming one non-detect is zero and the other is the detection limit (or the higher of the detection limits if they differ, sample specific).

𝑠ℎ2 = calculated unbiased sample variance (i.e., with Bessel’s correction; Gilbert 1987, Eqn. 4.4) of the two composite samples within stratum EUh, for all ℎ = 1, … , 𝐿.

s = �𝑠2(𝑥); positive square root of the sample variance; i.e., the standard deviation of the mean of the entire area of all adjacent street confirmation samples (𝑥).

T-117Adjancent Streets and Residential Yards QAPP Attachment B – Additional Scope October 26, 2012

n; following receipt of analytical data, the value of n (degrees of freedom) will be evaluated

per Satterthwaite’s (1946) equations.

Decision Rules

• Decisions will be based on the arithmetic average of the two replicate composite samples in each EU (𝑥ℎ) or Xh, and not the individual values (x1, x2).

• Estimates of individual EU variance based on the two replicates will be used to calculate a site-wide variance only; they will not be used to calculate individual UCLs for each EU.

• The site-wide variance estimate will solely be used to calculate a site-wide UCL, per Gilbert formulas; it will not be used to adjust the clean-up level.

• The MTCA 10 percent rule will be applied to the area of the EUs; that is, if Xh is > 1 ppm, and the area of the EU is less than 10 percent of the total area, the rule will have been met and no additional testing is necessary.

References

Gilbert, R.O. 1987. Statistical methods for environmental pollution monitoring. John Wiley and Sons. 336 pp. (Chapter 5 – Stratified Sampling; Chapter 11 – Confidence Intervals)

Satterthwaite, F.E. 1946. An Approximate Distribution of Estimates of Variance Components. Biometrics Bulletin 2:110–114.

2

ATTACHMENT E5 CAS SOP – SUBSAMPLING AND

COMPOSITING OF SAMPLES

(MULTI-INCREMENT)

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