REMEDIAL ACTION CONTRACT - United States Environmental ... · REMEDIAL ACTION CONTRACT . United...

REMEDIAL ACTION CONTRACT

United States Environmental Protection Agency Region 6

Contract No. EP-W-06-021

Quality Assurance Project Plan Version 1.1

American Creosote Works Superfund Site Feasibility Study

Winnfield, Louisiana Task Order No. 0051-RIFS-06G3

Document Control No. 0051-02010 February 2012

In Association With: Weston Solutions E2 Consulting Engineers, Inc. Arrowhead Contracting, Inc.

007377

AMERICAN CREOSOTE WORKS SUPERFUND SITE FEASIBILITY STUDY QUALITY ASSURANCE PROJECT PLAN

VERSION 1.1

ACW FS_QAPP_VER 1.1_TEXT.DOC ES021512103510DFW

This page intentionally left blank.

007378


V e r s i o n 1 . 1


Quality Assurance Project Plan

Prepared for U.S. Environmental Protection Agency

Contract No. EP-W-06-021 Task Order No. 0051-RIFS-06G3 CH2M HILL Project No. 411242

Document Control No. 0051-02010

February 2012

12750 Merit Drive, Suite 1100 Dallas, Texas 75251

007379


VERSION 1.1



007380


VERSION 1.1

ACW FS_QAPP_VER 1.1_TEXT.DOC iii ES021512103510DFW

QUALITY ASSURANCE PROJECT PLAN (QAPP) Version 1.1

APPROVAL SHEET


Winnfield, Louisiana

Prepared by: CH2M HILL Date: February 2012 Approved by: _____________________________________________ Michael Hebert Date EPA Region 6 Task Order Manager _____________________________________________ 2/16/2012 John Knott Date CH2M HILL Project Manager __________________________________________ 2/16/2012 Margaret O’Hare Date CH2M HILL RAC 2 Quality Assurance Manager _____________________________________________ 2/16/2012 John Ynfante Date CH2M HILL RAC 2 Program Chemist EPA QTRAK #:

007381


VERSION 1.1

ACW FS_QAPP_VER 1.1_TEXT.DOC iv ES021512103510DFW


007382


VERSION 1.1

ACW FS_QAPP_VER 1.1_TEXT.DOC v ES021512103510DFW

QUALITY ASSURANCE PROJECT PLAN (QAPP) Version 1.1

DISTRIBUTION LIST


Winnfield, Louisiana

Copies of this QAPP have been distributed to the following people:

Michael Hebert – EPA Region 6 Task Order Manager

Christy Warren – EPA Region 6 Houston Laboratory Sample Control Coordinator

Myra Perez – EPA Region 6 Contract Laboratory Program Regional Sample Control Coordinator

John Knott – CH2M HILL Project Manager

Margaret O’Hare – CH2M HILL RAC 2 Quality Assurance Manager

John Ynfante – CH2M HILL RAC 2 Program Chemist

007383


VERSION 1.1

ACW FS_QAPP_VER 1.1_TEXT.DOC vi ES021512103510DFW


007384

ACW FS_QAPP_VER 1.1_TEXT.DOC vii ES021512103510DFW

Contents

Section Page

Abbreviations and Acronyms ...............................................................................................................................ix

1 Project Management ........................................................................................................................... 1-1 1.1 Introduction ..................................................................................................................................... 1-1 1.2 Project and Task Organization ......................................................................................................... 1-1

1.2.1 EPA Region 6 Remedial Project Manager and Task Order Manager .................................. 1-1 1.2.2 CH2M HILL Project Manager .............................................................................................. 1-2 1.2.3 CH2M HILL RAC 2 Quality Assurance Manager .................................................................. 1-2 1.2.4 CH2M HILL Review Team Leader ........................................................................................ 1-2 1.2.5 CH2M HILL Health and Safety Manager ............................................................................. 1-2 1.2.6 CH2M HILL Procurement Specialist .................................................................................... 1-3 1.2.7 Project Data Manager ......................................................................................................... 1-3 1.2.8 CH2M HILL Project Chemist ................................................................................................ 1-3 1.2.9 CH2M HILL Project Quality Control Manager ..................................................................... 1-3 1.2.10 CH2M HILL Field Quality Manager ...................................................................................... 1-3 1.2.11 CH2M HILL Field Team Leader ............................................................................................ 1-4 1.2.12 EPA Region 6 Houston Laboratory Sample Control Coordinator ....................................... 1-4 1.2.13 EPA Region 6 Contract Laboratory Program Regional Sample Control Coordinator ......... 1-4

1.3 Problem Definition and Background ............................................................................................... 1-5 1.4 Project and Task Description ........................................................................................................... 1-5 1.5 Quality Objectives and Criteria ........................................................................................................ 1-5

1.5.1 Data Quality Objectives ...................................................................................................... 1-6 1.5.2 Measurement Performance Criteria .................................................................................. 1-9

1.6 Special Training and Certifications .................................................................................................. 1-9 1.7 Documentation and Records ........................................................................................................... 1-9

1.7.1 Field Sampling Documentation .......................................................................................... 1-9 1.7.2 Sample Identification System ........................................................................................... 1-10 1.7.3 Hard Copy Analytical Records ........................................................................................... 1-10 1.7.4 Electronic Analytical Records............................................................................................ 1-10 1.7.5 Project Record Maintenance and Storage ........................................................................ 1-11

2 Data Generation and Acquisition ......................................................................................................... 2-1 2.1 Sampling Process Design ................................................................................................................. 2-1 2.2 Sampling Methods ........................................................................................................................... 2-1 2.3 Sample Handling and Custody ......................................................................................................... 2-1

2.3.1 Sample Preservation and Holding Time ............................................................................. 2-1 2.3.2 Sample Custody and Shipping Requirements ..................................................................... 2-2

2.4 Analytical Methods .......................................................................................................................... 2-3 2.4.1 Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry ..................... 2-3 2.4.2 Semivolatile Organic Compounds by Gas Chromatography/Mass Spectrometry .............. 2-3 2.4.3 Total Petroleum Hydrocarbons by Gas Chromatography .................................................. 2-3 2.4.4 Total Organic Carbon by Combustion-infrared Spectrometry ........................................... 2-3 2.4.5 Total Suspended Solids by Gravimetry ............................................................................... 2-3 2.4.6 pH by Electrometry ............................................................................................................. 2-3 2.4.7 Field Data Acquisition ......................................................................................................... 2-4 2.4.8 Soil Properties ..................................................................................................................... 2-4

007385

CONTENTS

ACW FS_QAPP_VER 1.1_TEXT.DOC viii ES021512103510DFW

2.5 Quality Control ................................................................................................................................. 2-4 2.5.1 Quality Control Samples ..................................................................................................... 2-4 2.5.2 Field and Laboratory Corrective Action .............................................................................. 2-5

2.6 Instrument and Equipment Testing, Inspection, and Maintenance ................................................ 2-6 2.7 Instrument and Equipment Calibration and Frequency .................................................................. 2-7 2.8 Inspection and Acceptance of Supplies and Consumables .............................................................. 2-7 2.9 Non-Direct Measurements .............................................................................................................. 2-7 2.10 Data Management ........................................................................................................................... 2-7

2.10.1 Data Types .......................................................................................................................... 2-8 2.10.2 Data Tracking and Management ........................................................................................ 2-8 2.10.3 Computer Database ............................................................................................................ 2-8 2.10.4 Documentation ................................................................................................................... 2-9 2.10.5 Evidence File ....................................................................................................................... 2-9 2.10.6 Presentation of Analytical Data .......................................................................................... 2-9

3 Assessment and Oversight ................................................................................................................... 3-1 3.1 Assessments and Response Actions ................................................................................................ 3-1 3.2 Reports to Management .................................................................................................................. 3-1

Data Validation and Usability ............................................................................................................... 4-1 4.1 Data Review, Verification, and Validation ....................................................................................... 4-1

4.1.1 Precision ............................................................................................................................. 4-1 4.1.2 Accuracy .............................................................................................................................. 4-1 4.1.3 Completeness ..................................................................................................................... 4-1 4.1.4 Sensitivity ............................................................................................................................ 4-2

4.2 Data Types ....................................................................................................................................... 4-2 4.2.1 Screening Data .................................................................................................................... 4-2 4.2.2 Definitive Data .................................................................................................................... 4-2

4.3 Verification and Validation Methods ............................................................................................... 4-2 4.4 Reconciliation with User Requirements .......................................................................................... 4-3

4 Works Cited ......................................................................................................................................... 5-1

Tables 1-1 Project Personnel and Telephone Numbers 1-2 Project Data Quality Objectives and Associated Investigation Tasks 1-3 Summary of Deliverables for Laboratory Analytical Reports 2-1 Sample Containers, Preservatives, and Holding Times 2-2 ISS Bench-scale Test Analysis 2-3 VOCs Target Analyte List and Reporting Limits for Groundwater Samples 2-4 SVOCs Target Analyte List and Reporting Limits for Groundwater Samples 2-5 General Chemistry Target Analyte List and Reporting Limits

Figures

1-1 Project Organization Chart 1-2 Site Map 2-1 Proper Labeling of Sample Coolers

Attachment

1 Quality Control Corrective Action Form

007386

ACW FS_QAPP_VER 1.1_TEXT.DOC ix ES021512103510DFW

Abbreviations and Acronyms

%R percent recovery

°C degrees Celsius

.csv comma-separated value (file)

.txt comma-delimited text (file)

ASTM ASTM International

BaP benzo(a)pyrene

BTEX benzene, toluene, ethylbenzene, xylenes

C carbon

CLP Contract Laboratory Program

CoC chain-of-custody

COC contaminant of concern

DNAPL dense nonaqueous phase liquid

DQO data quality objective

EB equipment blank (equipment rinsate blank)

EDD electronic data deliverable

EDMS Environmental Data Management System

EPA U.S. Environmental Protection Agency

ESAT Environmental Services Assistance Team

FD field duplicate

FOP field operations plan

FQM Field Quality Manager

FTL Field Team Leader

GC/MS gas chromatograph/mass spectrometer

H2SO4 sulfuric acid

HCl hydrochloric acid

HDPE high-density polyethylene

HSM health and safety manager

HSP health and safety plan

ID identification number

ISCO in situ chemical oxidation

ISS in situ solidification/stabilization

KA Contract Administrator

007387

ABBREVIATIONS AND ACRONYMS

ACW FS_QAPP_VER 1.1_TEXT.DOC x ES021512103510DFW

LCS laboratory control sample

LDEQ Louisiana Department of Environmental Quality

MCAWW Methods for the Chemical Analysis of Water and Wastes

MCL maximum contaminant level

MDL method detection limit

mg/kg milligrams per kilogram

mg/L milligrams per liter

MS matrix spike

MSD matrix spike duplicate

NAPL nonaqueous phase liquid

PAH polycyclic aromatic hydrocarbon

PC Project Chemist

PCP pentachlorophenol

PDM Project Data Manager

PLTS process liquid treatment system

PM Project Manager

PQCM Project Quality Control Manager

PRG preliminary remediation goal

QA quality assurance

QAM Quality Assurance Manager

QAPP quality assurance project plan

QC quality control

QMP quality management plan

RAC response action contract

RCRA Resource Conservation Recovery Act

RI/FS remedial investigation/feasibility study

RL reporting limit

ROD Record of Decision

RPD relative percent difference

RSCC Regional Sample Control Coordinator

RTL Review Team Leader

SAP sampling and analysis plan

S-EPR surfactant-enhanced product recovery

site American Creosote Works Superfund Site

SOP standard operating procedure

SOW statement of work

007388


ACW FS_QAPP_VER 1.1_TEXT.DOC xi ES021512103510DFW

SPLP synthetic precipitation leaching procedure

SVOC semivolatile organic compound

TMV toxicity, mobility, and volume

TOC total organic carbon

TOM Task Order Manager

TPH total petroleum hydrocarbons

TR traffic report

TSS total suspended solids

TT treatability test

TTP treatability test plan

VOA volatile organic analysis

VOC volatile organic compound

UCS unconfined compressive strength test

µg/kg micrograms per kilogram

µg/L micrograms per liter

007389


ACW FS_QAPP_VER 1.1_TEXT.DOC xii ES021512103510DFW


007390

ACW FS_QAPP_VER 1.1_TEXT.DOC 1-1 ES021512103510DFW

SECTION 1

Project Management Section 1 of this quality assurance project plan (QAPP) presents information regarding the management of the project. The aspects of project management discussed include the following:

• Project organization, roles, and responsibilities • Problem definition and background • Project task description • Project data quality objectives (DQO) • Special training requirements • Documentation and records management

1.1 Introduction The purpose of this QAPP is to present the quality assurance (QA)/quality control (QC) requirements for the collection and analysis of samples in support of the Feasibility Study (FS) at the American Creosote Works Superfund Site (site). The procedures for sampling are described in the Treatability Test Plan (TTP), American Creosote Works Superfund Site, Version 2.1 (CH2M HILL, 2011a). The TTP includes applicable procedures, forms, and guidelines for the performance of the field data acquisition activities. The QAPP and the TTP together make up the required components of a sampling and analysis plan (SAP) for this work. These documents will be used in conjunction with the health and safety plan (HSP) (CH2M HILL, 2010a). Together, these documents describe the procedures to be used during the performance of the field investigation.

This QAPP was written according to guidelines set forth in the U.S. Environmental Protection Agency’s (EPA) EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5) (EPA, 2001), Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA QA/G-4) (EPA, 2006), and EPA Guidance for Quality Assurance Project Plans (EPA QA/G-5) (EPA, 2002). It is also compliant with the information presented in CH2M HILL’s Quality Management Plan (QMP) for Response Action Contract 2, Revision No. 4 (CH2M HILL, 2011b). The QMP and this document describe CH2M HILL’s program quality procedures, which are in place to assess the quality of environmental data collection and evaluation activities related to the response action contract (RAC) and the task order scope of work.

1.2 Project and Task Organization CH2M HILL will serve as the prime contractor during implementation of field activities and will subcontract components of the field activities to various specialty subcontractors. The relationships and lines of communication between key project personnel are presented in the organization chart on Figure 1-1.1 Key project personnel telephone numbers are provided in Table 1-12

The roles and responsibilities of the key project personnel are summarized in the following paragraphs.

.

1.2.1 EPA Region 6 Remedial Project Manager and Task Order Manager Mr. Michael Hebert is the EPA Region 6 Task Order Manager (TOM) for this project. The TOM serves as the EPA liaison for the project with the ultimate responsibility for overall EPA project management. Any significant changes to the planned activities, site access issues, public outreach issues, or significant problems encountered will be reported to the TOM by the Project Manager (PM) or designee. Any changes in the systems defined in the site-specific plans for this project must be approved by the TOM.

1 All figures are located at the end of this report behind the Figures divider.

2 All tables are located at the end of this report behind the Tables divider.

007391

SECTION 1: PROJECT MANAGEMENT


1.2.2 CH2M HILL Project Manager Mr. John Knott is the CH2M HILL PM for this project. The PM functions as the primary interface between the TOM and the project team and is responsible for achieving technical, financial, and scheduling objectives. The PM will be the central point of contact for all matters concerning the project. The PM’s site management responsibilities include the following:

• Define project objectives and develop a detailed work plan and schedule.

• Establish project policies and procedures to address the specific needs of the project as a whole, as well as the objectives of each task.

• Advise the TOM of technical progress, program needs, potential problems, and recommended solutions.

• Arrange, organize, monitor, direct, and control staff and other resources needed to execute the task order within budget and schedule restraints, and establish clear lines of communication within the CH2M HILL organization.

• Familiarize the Field Team Leader (FTL) and support staff with the project’s special considerations.

• Review the work performed and overall task performance for quality, responsiveness, timeliness, and budgetary considerations.

• Oversee subcontractor management.

• Review external reports (deliverables) before submission to EPA.

• Represent the project team at meetings with EPA and other project stakeholders.

1.2.3 CH2M HILL RAC 2 Quality Assurance Manager Ms. Margaret O’Hare is the CH2M HILL RAC 2 Quality Assurance Manager (QAM). The QAM provides quality management support to the PM and reviews and approves the following documentation:

• Program quality management plan • Program-level quality work instructions and procedures • Project-level QAPP

1.2.4 CH2M HILL Review Team Leader Mr. Paul Favara is the CH2M HILL Review Team Leader (RTL) for the project. Mr. Favara is a professional engineer with significant project and program management experience. He has 25 years of consulting experience working on and managing multidisciplinary projects involving remedial construction, remedial design, scientific and engineering studies, and multimedia compliance audits.

The RTL responsibilities include the following:

• Monitor the scope, quality, and completeness of project deliverables before submittal to EPA.

• Guide the QC process by serving as a technical resource and counselor to the PM.

• Monitor the quality and delivery of all project-related work, and assist the PM and the project team in addressing technical requirements.

1.2.5 CH2M HILL Health and Safety Manager Mr. Michael Goldman is the CH2M HILL Health and Safety Manager (HSM). Responsibilities of the HSM include the following:

• Serve as a resource and contact point for all team members regarding issues/concerns related to health and safety.

• Provide review and approval of the HSP and subsequent addenda.

007392



• Conduct field audits, if necessary, in accordance with CH2M HILL policies and procedures.

• Identify the cause and implement necessary corrective action in the event of an accident.

1.2.6 CH2M HILL Procurement Specialist Ms. Heather Smith is the CH2M HILL Procurement Specialist or Contract Administrator (KA). The procurement specialist is responsible for the management of any subcontract documents created in support of this project. Specific responsibilities of the Procurement Specialist are as follows:

• Contract the subcontractors in accordance with program and legal requirements. • Procure necessary equipment and materials from vendors. • Resolve any subcontract disputes.

1.2.7 Project Data Manager Ms. Patricia Twigg is the Project Data Manager (PDM). The PDM is responsible for overall management of the data flow throughout the project. Specific responsibilities of the PDM include:

• Monitor and manage the flow of data throughout the project. • Create and maintain the project database, which will contain project analytical data. • Work with the Project Chemist to ensure the development of a complete and accurate project database. • Oversee the production of data tables or other required output of the project database.

1.2.8 CH2M HILL Project Chemist Mr. John Ynfante is the CH2M HILL Project Chemist. The Project Chemist is responsible for all technical chemistry issues relating to data quality, laboratory performance, and sampling. Specific responsibilities of the Project Chemist include performing or overseeing the following:

• Support the development of project-specific DQOs during the planning phase, and evaluate the analytical needs to satisfy those DQOs.

• Draft and maintain the QAPP.

• Work with the KA to subcontract services for sample analysis.

• Act as project liaison to the analytical laboratories to address any technical chemistry issues or problems encountered by the laboratories or by data reviewers.

• Perform or oversee the validation of all analytical data obtained, and assess its usability in achieving project DQOs and supporting project decisions.

• Work with the PDM to ensure the development of a complete and accurate project database.

1.2.9 CH2M HILL Project Quality Control Manager Mr. John Knott will serve as the Project Quality Control Manager (PQCM). The PQCM has direct responsibility for developing and implementing the quality requirements defined in the RAC 2 Program Quality Management Plan (CH2M HILL, 2011b) and the CH2M HILL Environmental Services Business Group Quality Management Plan (CH2M HILL, 2010b). The quality procedures defined by these plans are intended to assure the quality of environmental data collection and evaluation activities related to all aspects of the RAC 2 scope of work, which includes assessments, studies, designs, construction activities, and postconstruction activities. This role reports on a matrix basis (that is, dotted line) to the Program QAM.

1.2.10 CH2M HILL Field Quality Manager Ms. Carrie Wallestad will serve as the Field Quality Manager (FQM). The FQM is an individual within the onsite work organization who will be responsible for overall management of QC and have the authority to act in all field QC matters for CH2M HILL. The FQM responsibilities include, but are not limited to, the following:

007393



• Performing QC inspections of materials, equipment, and services

• Conducting field tests and overseeing subcontractor performance of field tests

• Implementing document control

• Performing review and administration of submittals

• Preparing and administering site project records

• Overseeing implementation of corrective actions required

• The FQM has the authority to stop work on all or any project work activity that does not comply with the basic contract and task order. Onsite personnel will be encouraged to discuss concerns with the FQM and supporting technical personnel to prevent project nonconformance incidents.

1.2.11 CH2M HILL Field Team Leader Ms. Carrie Wallestad will serve as the CH2M HILL FTL. The FTL is responsible for all onsite activities during the field investigation including sample collection, field analysis, directing the work of other CH2M HILL staff and any field subcontractor activities. Other responsibilities include:

• Coordinate the day-to-day sampling activities of the project team and the subcontractors.

• Maintain close contact with the project manager so that potential schedule, budget, and/or technical problems can be addressed in a timely manner.

• Coordinate with the HSM to ensure compliance with the HSP.

• Ensure compliance with the TTP and this QAPP.

• Coordinate field efforts, and provide and maintain sampling equipment and materials shipping and packing materials.

• Supervise the completion of chain-of-custody (CoC) records, the handling and shipping of samples, and the completion of the field notebooks.

• Implement the required field QA/QC measures, and ensure that the sampling team follows approved policies and field procedures.

1.2.12 EPA Region 6 Houston Laboratory Sample Control Coordinator Ms. Christy Warren is the EPA Region 6 Houston Laboratory (EPA Houston Lab) Sample Control Coordinator. Ms. Warren coordinates and schedules all analytical activities for the EPA Houston Lab and will serve as the lab liaison for any samples that are submitted to the EPA Houston Lab for analysis. Ms. Warren will be responsible for coordinating and scheduling the laboratory analyses, supervising the in-house CoC procedures, ensuring the lab’s adherence to requirements outlined in this QAPP, and overseeing the delivery of analytical data to the TOM and Project Chemist.

1.2.13 EPA Region 6 Contract Laboratory Program Regional Sample Control Coordinator

Ms. Myra Perez is the EPA Region 6 Contract Laboratory Program (CLP) Regional Sample Control Coordinator (RSCC). Ms. Perez coordinates all EPA CLP scheduling and analytical activities with the Sample Management Office and CLP laboratories. Ms. Perez also acts as the liaison between the CH2M HILL project team and the CLP labs. No member of the project team may contact any participating CLP lab directly and must communicate with them only through Ms. Perez.

007394



1.3 Problem Definition and Background The site is a 34-acre former wood treating facility that used creosote and pentachlorophenol (PCP) to treat various wood products between 1901 and 1984. The facility was placed on EPA’s National Priorities List in 1992 and has undergone extensive remediation since the Record of Decision (ROD) was signed in April 1993 (EPA, 1993). CH2M HILL is currently operating a fluids extraction and in situ bioremediation system to treat the subsurface soil and groundwater contamination remaining at the site. This system comprises 28 recovery wells and trench sumps, several injection wells and injection trenches, an onsite process liquid treatment system (PLTS), and an extensive array of underground piping to convey fluids to and from the PLTS (Figure 1-2). The PLTS includes an oil/water separator and lamella clarifier for free-phase and emulsified oil removal, and biological and granular activated carbon for dissolved-phase contaminant treatment.

In addition to installation of the PLTS, remedial actions completed at the site to date include incineration of highly contaminated material present in the former Tar Mat Area with burial of the incinerator ash in an onsite geotextile-lined, clay-covered cell identified as the Tar Mat Ash Disposal Area, and consolidation of 7,000 cubic yards of low-level contaminated soil with material stabilized during pre-ROD removal actions in a waste cell.

The waste cell is covered with 1 to 3 feet of clay and underlain with a visqueen-plastic liner. The soil incineration and consolidation actions were completed in 1995. The deep subsurface soil and groundwater component of the remedy, including the PLTS, was implemented in October 1996. Through September 2010, the deep subsurface soil and groundwater remedy has recovered approximately 196,000 gallons of free-phase and emulsified creosote and treated 80 million gallons of groundwater.

1.4 Project and Task Description The purpose of the treatability study is to test the effectiveness of three different technologies for treatment of creosote-contaminated soil and groundwater at the site. The three technologies include: (1) in situ chemical oxidation (ISCO), (2) surfactant-enhanced product recovery (S-EPR), and (3) in situ solidification/stabilization (ISS). The first two technologies will be tested at the field scale, while the third will use a bench-scale approach. The findings will be used to determine if these technologies should be retained as a component(s) of a sitewide remedial alternative to be evaluated in the FS, and if so, to develop conceptual design and cost estimate information to support the detailed and comparative evaluation of alternatives in the FS.

This QAPP applies to collection and analysis of groundwater and soil samples to support the treatability study.

1.5 Quality Objectives and Criteria The primary goal of remedial activities at the site is to protect human health and the environment by reducing contaminant concentrations in soil and groundwater to levels that protect future site, groundwater, and surface water uses. In support of that goal, the treatability study has the following objectives:

• Assess the effectiveness and potential full-scale application of ISCO for treating contaminated soil and groundwater at the site

• Assess the effectiveness and potential full-scale application of S-EPR for treating contaminated soil and groundwater at the site

• Assess the effectiveness and potential full-scale application of ISS for treating contaminated soil at the site

These objectives were used to develop specific DQOs, which are qualitative and quantitative statements that describe the type and quality of analytical data needed to meet project objectives. The DQO process used for this project follows the EPA QA/G4 guidance and uses the seven-step DQO development process described in EPA’s Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA QA/G-4) (EPA, 2006). The DQOs provide a basis for the investigation activities to be performed, and they ensure that data collected during the investigation will be of sufficient and adequate quality for their intended use.

007395



1.5.1 Data Quality Objectives The objectives for the treatability tests (TT) were developed using the DQO process (EPA, 2006). The DQO process resulted in the test objective of determining if one or more of the technologies included in the TT (ISCO, S-EPR, and ISS) should be retained for further evaluation in the FS. The recommendation to retain the technologies will be based on determination of the following:

• The percent reduction in residual dense nonaqueous phase liquid (DNAPL) mass that can be attained using ISCO via catalyzed hydrogen peroxide

• The percent reduction in DNAPL mass that can be attained using S-EPR

• The reduction in DNAPL mobility and leachability that can be attained through ISS of DNAPL-impacted media

• The cost to complete full-scale implementation of each technology, as estimated by interpretation of pilot study results and the conceptual site model (Note: Considerable uncertainty is expected in this cost estimate, because it is technically very difficult to estimate the total volume of creosote in the subsurface.)

• Overall effectiveness of the technology in reducing risks to human health and the environment

TT objectives associated with reducing the toxicity, mobility, and volume (TMV) of dissolved-phase contaminants were not specifically addressed in the TTP (CH2M HILL, 2011a). Due to the timeframes that may be required for these reductions to become evident, they will be assessed through semiannual groundwater monitoring conducted under the long-term remedial action task order, and the information will be incorporated into the TT or FS report.

The DQO process used for the TT is summarized in the following subsections. Table 1-2 summarizes the data deliverable associated with each objective.

Step 1 – State the Problem Project Objectives The objective of the TT is to evaluate performance of three technologies (ISCO, S-EPR, and ISS) to treat areas of residual (immobile) and/or mobile DNAPL present at the site. By destroying (ISCO), removing (ISCO and S-EPR), or immobilizing (ISS) nonaqueous phase liquid (NAPL) source material, the longevity of the dissolved plume is reduced by minimizing the contribution of contaminants from the DNAPL.

Project Assumptions If one or more of these technologies is selected for full-scale application, it will likely be coupled with one or more additional technologies (that is, combined remedy) to address the current dissolved-phase polycyclic aromatic hydrocarbon (PAH) plume or areas with very low concentrations of residual DNAPL.

Project Issues CH2M HILL will provide the technical and labor resources required to implement the TT, conduct performance monitoring during the TT, and evaluate the TT results. Based on the data evaluation, CH2M HILL will make recommendations on which technologies should be retained for the FS.

Data Quality Objective Planning Team Members and Key Decision Makers The planning team will include CH2M HILL, the Louisiana Department of Environmental Quality (LDEQ), and EPA.

Contaminants of Concern Contaminants of concern (COC) include PAHs, PCP, and benzene with naphthalene selected as a primary PAH indicator contaminant. On average, naphthalene, which is highly mobile in the dissolved phase, accounts for 35 percent of the total PAH concentration in the groundwater sample data set (CH2M HILL, 2011c), and 20 percent of the total PAH concentration in the year 2008 subsurface soil investigation data set (CH2M HILL, 2008).

Dioxins and furans will not be evaluated specifically, because their fate in each of the three TT tests is expected to be comparable to the high molecular weight PAH constituents.

007396



Current and Potential Future Land Use The initial baseline risk assessment assumed a residential land use. Restoration of the site to allow for a future residential use may be impracticable (cost prohibitive). Therefore, the FS will evaluate restoration to allow for future industrial land use or recreational land use with residential land use retained as a baseline for comparison. Future land use options will be explored further with EPA, the City of Winnfield, and LDEQ.

Statement of the Problem Can one or more of these technologies effectively address residual and/or mobile DNAPL such that future concentrations of COCs in site soil and groundwater can be reduced to allow for conditional reuse? The determination of effectiveness includes consideration of the cost of implementation and the cost of waste disposal, in addition to ability to meet remedial goals.

Step 2 – Identify the Goals of the Study Principal Study Questions • What percentage of reduction in DNAPL mass will ISCO achieve during the pilot-scale testing?

• What percentage of reduction in DNAPL mass will S-EPR achieve during the pilot-scale testing?

• How will ISS reduce contaminant leachability during the bench-scale testing?

• What is the cost to complete full-scale implementation of the technology per treatment volume?

Alternative Actions • Evaluation of an alternative technology • Additional pilot-scale testing

Decision Statement If one or more of these technologies is able to perform as specified, they will be retained for consideration during the FS.

Step 3 – Identify Information Input Information Required to Address the Problem • Ability to Implement. Is it possible to inject sufficient amounts of oxidant or surfactant in the ground or attain

adequate subsurface mixing?

• Contaminant Reduction. What percentage of reduction in DNAPL TMV can be reasonably achieved through implementation of these technologies such that the longevity of the dissolved-phase plume is reduced or eliminated?

• Cost Parameters. Were all design criteria determined to the extent required to budget for a full-scale application?

Source of Required Information Sources of the required information will include historical data, data collected during the pilot-scale and bench-scale tests, performance data collection events, and the current conceptual site model.

Action Levels for Contaminants of Concern The action levels for COCs in groundwater specified in the ROD (EPA, 1993) are 0.2 micrograms per liter (µg/L) for PAHs expressed as benzo(a)pyrene (BaP) equivalents and 5 µg/L for benzene. A 1 µg/L action level for PCP corresponding to the federal maximum contaminant level (MCL) is assumed. For COCs in soil, the cleanup levels included 50,000 micrograms per kilogram (µg/kg) for PCP; 3,000 µg/kg for PAHs expressed as BaP equivalents; and less than 10 µg/kg for 2,3,7,8-tetrachlorodibenxop-dioxin. As indicated previously, the TT will not specifically evaluate the performance of these technologies with respect to dioxin. The analytical methods are outlined in Section 4 of the TTP (CH2M HILL, 2011a).

The updated draft risk assessment report (CH2M HILL, 2011d) and Draft Feasibility Study – Remedial Action Technology Screening and Preliminary Remedial Action Alternatives (CH2M HILL, 2011e) proposed a new set of

007397



preliminary remediation goals (PRG) based on an industrial land use and potable groundwater beneficial use. A comparison of the proposed PRGs versus the ROD remedial goals is provided in Table 1-2 of the TTP (CH2M HILL, 2011a).

Step 4 – Define the Boundaries of the Study Target Population of Interest The target population consists of all validated soil and groundwater data collected from the test areas or during bench-scale testing.

Spatial Boundaries of the Test Areas The spatial boundary for the ISCO (Area 1) and S-EPR (Area 2) pilot-scale tests are shown on Figure 1-5 of the TTP (CH2M HILL, 2011a). Soil samples for the ISS bench-scale test will be collected from within the S-EPR test area (Area 2).

Temporal Boundaries of the Test Areas The performance monitoring sampling parameters and frequency are summarized in Section 4 of the TTP (CH2M HILL, 2011a).

Conditions Most Favorable for Collecting Data No specific weather or time conditions are considered more favorable for collecting data. However, because the TT will be conducted within highly contaminated zones, sampling to evaluate the ability of the technology to treat contaminants should be completed quickly after completion of the injection and extraction processes, before contamination from adjacent, untreated areas migrates into the treatment cell. Because the ISS bench-scale test will be conducted in a laboratory setting, there are no special conditions for data collection.

Practical Constraints Affecting Data Collection Constraints include holding times for the analyses. The field sampling procedures, including equipment and monitor well purging requirements, are outlined in Appendix B of the TTP (CH2M HILL, 2011a).

Scale of Decision Making For the field pilot-scale tests, soil and groundwater throughout the thickness of the shallow aquifer will be sampled. The data from the baseline sampling event will be compared to the performance monitoring data to determine if the test objectives and uncertainties were achieved. For the bench-scale test, solidified materials will be tested for strength, permeability, and leachability.

Step 5 – Develop the Analytic Approach Statistical Parameter of Interest for Decision Making The average and maximum contaminant concentrations in groundwater and soil within the test areas (Areas 1 and 2) of the site will be used for decision making. Also, field data describing the ability to inject and extract ISCO and S-EPR materials will be evaluated. The ISS bench-scale test will take the average and highest contaminant concentrations in soil and monolith permeate, as well as strength and permeability, into consideration.

Decision Rules If the physical application of ISCO or S-EPR cannot be achieved, then these technologies will either not be retained in the FS or missing information required to improve or carry the technology forward will be provided.

If DNAPL in either test area is not reduced by a reasonable amount compared to the cost of implementation, then that technology will either not be retained for the FS, or missing information required to improve or carry the technology forward will be provided.

If it is determined that the technology does not reduce risks to human health and the environment, then the technology will not be retained for the FS.

007398



Step 6 – Specify Performance or Acceptance Criteria Acceptance of analytical data will be based on data validation conducted by CH2M HILL. All data will be considered useable unless specified during the data validation process. The results of the data validation will be provided in data validation reports.

Step 7 – Plan for Obtaining Data The sampling plan is summarized in Section 4 of the TTP (CH2M HILL, 2011a).

1.5.2 Measurement Performance Criteria Project DQOs require meeting certain measurement performance criteria, including the following:

• Peer and senior review of data and documents • QC standards • Management controls

The analytical data will undergo three levels of review: an initial review by the analytical chemist, a subsequent review by either a peer chemist or QA manager, and a final data quality review by the CH2M HILL Project Chemist. All documents pertaining to the quality standards of the project are drafted and reviewed internally by CH2M HILL staff with relevant technical experience.

All analytical data must meet the QC standards set forth in the applicable standard operating procedures (SOP), in this QAPP, and in the applicable analytical methods. If these standards are not met, the data will be appropriately qualified during the data review process. In cases where the data are deemed of insufficient quality to satisfy project DQOs, the data will be rejected and will not be used to support project decisions. While performing field activities, the FTL will manage the field activities to ensure that SOPs are being followed.

1.6 Special Training and Certifications Project team members have been chosen with the necessary experience and technical skills to perform required project tasks. The only additional training required is a mandatory review of the project-specific HSP.

Project field staff, including subcontractors, must meet the requirements specified in the work plan, HSP, and the applicable subcontract documents.

1.7 Documentation and Records The following sections describe the documentation and record keeping requirements of the project.

1.7.1 Field Sampling Documentation Field team members will keep a daily record of significant events, observations, and measurements during sampling. The required contents of the field logbook are specified in the TTP. A bound field logbook with numbered pages will be initiated at the start of field activities and will be maintained to record onsite activities during all sampling events. The field logbook will be supplemented by sampling CoC forms and/or notes recorded onto site maps or field forms. All documents generated during the field effort are controlled documents that become part of the project file. All entries in the field logbooks should be signed and dated and should include the following information:

• Name and title of author, field crew, and site visitors present • Weather and environmental conditions during the field activity • Date and time of sample collection and/or logbook entry • Location of sampling activity • Sample media (for example, groundwater) • Sample collection method • Number of samples collected

007399



• Sample identification numbers (ID) • Field observations and measurements (for example, pH, temperature, water levels, core description)

If a logbook entry is recorded in error, personnel should not obliterate the mistake. Personnel should mark a single line through the mistake, initial it, and date the section that is crossed out.

Field documentation requirements specific to other field data collection efforts are specified in the TTP (CH2M HILL, 2011a).

1.7.2 Sample Identification System Unique sample IDs will be assigned to all samples collected according to the protocol presented in the TTP, Field Operations Plan (FOP), and this QAPP to prevent sample ID duplication in the project database. A record of the unique sample ID, time, and date of sampling will be maintained in the field sampling documentation as indicated in the TTP (CH2M HILL, 2011a) and within applicable CoC records as specified in Section 2 of this QAPP.

Sample IDs will be assigned to all non-CLP samples according to the protocol discussed in Section 2 of this QAPP. Sample IDs will be assigned to all CLP samples according to the protocol discussed in EPA’s Contract Laboratory Program Guidance for Field Samplers (EPA, 2010a) and Section 2 of this QAPP. The sample IDs required to be used for the CLP samples will be provided by the RSCC.

Sample labels and CoC forms will list the unique sample ID as well as the appropriate sample location, date, time, samplers, and other relevant information. Samples sent to a CLP lab for analysis must adhere to the guidelines set forth in EPA’s Contract Laboratory Program Guidance for Field Samplers (EPA, 2010a).

1.7.3 Hard Copy Analytical Records Hard copy data will include all applicable items listed in Table 1-3 and should be unbound for the purpose of data evaluation. If the EPA Houston Lab performs the analysis, then a Regional Level II data deliverable will be provided. If a CLP laboratory performs the analysis, then a Level IV data deliverable will be provided. If a Tier IV subcontract laboratory performs the analysis, then a Level III deliverable will be provided.

Any deviations from the analytical method or this QAPP will be fully detailed in the case narrative, along with a description of any corrective actions taken. The case narrative will address the following aspects of the analysis at a minimum:

• Sample receipt conditions and completeness • Holding times • Blank samples • Matrix spikes and matrix spike duplicates • Laboratory control samples (LCS)

1.7.4 Electronic Analytical Records CH2M HILL requires subcontract laboratories to submit an electronic data deliverable (EDD) in a comma-delimited text file (.txt) or comma-separated value file (.csv). If the laboratory is a Tier IV subcontract laboratory, the file format will be consistent with the CH2M HILL Environmental Data Management System (EDMS) LabSpec7 format, which will be communicated to the laboratory within the laboratory statement of work (SOW) or by the PDM. If the EPA Houston Lab or a CLP lab is used, files will be provided in the standard regional format for those laboratories.

Prior to delivering the analytical results to CH2M HILL, the laboratories’ QC officer or appointed deputy will verify that the hard copy and electronic deliverable match. The product of this activity is accurate and complete analytical information ready for data evaluation and database entry.

007400



1.7.5 Project Record Maintenance and Storage Each project team member is responsible for filing all project information or providing it to the administrative assistant familiar with the project filing protocol. Individual team members may maintain separate files or notebooks for individual tasks but must provide such files to the main project file upon completion of each task.

The general project file categories are as follows:

• Correspondence • Non-laboratory project invoices and approvals by vendor • Original unbound reports • Non-laboratory requests for proposal, bids, contracts, and SOWs • Field data • Data evaluation and calculations • Site reports from others • Bound report copies • Photographs • Insurance documentation • Laboratory analytical data and associated documents/memoranda • Regulatory submittals, licensing, and permitting applications • Site and reference material • HSPs • Figures and drawings

A project-specific index of file contents should be kept with the project files at all times.

In addition to including the above hard copies in the physical file system, all logbooks and field forms completed during a field event will be scanned into electronic format and stored with the project files.

007401




007402


SECTION 2

Data Generation and Acquisition Section 2 of this QAPP describes the procedures for the measurement, acquisition, handling, review, and management of data to be performed in support of TTP activities.

This section addresses the following aspects of measurement and data acquisition:

• Sampling process design • Sampling method requirements • Sample handling and custody requirements • Laboratory analytical methods requirements • Laboratory QC requirements • Field and laboratory instrument calibration and frequency • Inspection and acceptance requirements for supplies and consumables • Data acquisition requirements • Data management • Field and laboratory instrument and equipment testing, inspection, and maintenance requirements

2.1 Sampling Process Design The TTP (CH2M HILL, 2011a) provides the analytical requirements and sample collection design for this project. SOPs for soil and groundwater sampling methods are provided in the FOP (CH2M HILL, 2006a). Soil and groundwater samples will be collected from the site for analysis.

The planned sampling locations, rationale for selection, and analytical parameters for each location are detailed in Section 4 of the TTP (CH2M HILL, 2011a). Depending on the conditions encountered in the field, note that the exact sample locations and the total number of samples might change from those described in the TTP (CH2M HILL, 2011a).

2.2 Sampling Methods Specific SOPs or procedures for soil and groundwater field sampling protocol are contained in the TTP (CH2M HILL, 2011a) or FOP (CH2M HILL, 2006a). Untreated soil samples will also be collected and analyzed as described in Section 4.3.4 of the TTP (CH2M HILL, 2011a) prior to the ISS bench-scale study.

2.3 Sample Handling and Custody The following sections describe the sample handling and sample custody requirements.

2.3.1 Sample Preservation and Holding Time Table 2-1 summarizes the project requirements for sample containers, preservatives, and sample holding times for the analytical method and media to be sampled. All analytical methods can be found in one or more of the following sources:

• SW-846 Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods (EPA, 1999)

• Standard Methods for the Examination of Water and Wastewater 21st edition (American Public Health Association, American Water Works Association, and Water Environment Federation, 2005)

• Code of Federal Regulations

• Methods for the Chemical Analysis of Water and Wastes (MCAWW) (EPA, 1983)

• Multi-Media, Multi-Concentration, Organic Analytical Service for Superfund (SOM01.2) (EPA, 2007)

007403

SECTION 2: DATA GENERATION AND ACQUISITION


• Annual Book of ASTM Standards (EPA, 2009)

• Recommended Practice for Field Testing Water-based Drilling Fluids (API, 2009)

Treated and untreated soil will be analyzed as part of the ISS study as described in Section 4 of the TTP (CH2M HILL, 2011a). These tests will be carried out at the curing time specified for each test in the TTP.

2.3.2 Sample Custody and Shipping Requirements Sample Custody Sample custody procedures include the use of field logbooks, sample labels, custody seals, and CoC forms/traffic reports (TR; using FORMS II Lite or Scribe). Each person involved with sample handling should be familiar with CoC procedures prior to the start of field operations. The CoC form must accompany the samples during shipment from the field to the laboratory. A sample is considered to be in a person’s custody under the following circumstances:

• It is in the person’s actual possession • It is in the person’s view, after being in the person’s physical possession • It was in the person’s physical possession and that person locks it up to prevent tampering • It is in a designated and identified secure area

Sample Shipping and Chain-of-Custody Proper sample handling, shipment, and maintenance of CoC documentation are key components of the quality system designed to obtain data that can be used to make project decisions. A very important aspect of these procedures is for all sample handling protocols and CoC requirements to be followed completely, accurately, and consistently. All samples shipped to the laboratory must be accompanied by a properly completed CoC form/TR.

The unique sample IDs and descriptive information (for example, sample location, date, time) will be listed on the appropriate CoC. Individuals relinquishing or receiving possession of samples will sign and note the time on the CoC in the <relinquished by> or <received by> box. The signed CoC documents the transfer of sample custody from the sampler to the laboratory.

Field samples should be sealed in individual resealable plastic bags and positioned within the cooler to prevent damage and maintain sample integrity. Hard plastic coolers or ice chests will be used for shipping samples. A signed CoC will be placed in a plastic bag and taped to the inside of the lid in each cooler. The cooler is then closed and secured with strapping tape and custody seals for shipment to the laboratory. The preferred procedure involves attaching custody seals to two sides of the cooler and then covering the seals with clear plastic tape. The cooler is then strapped shut with strapping tape in at least two locations and shipped by priority overnight delivery service (Federal Express or equivalent) to the laboratory for analysis. If Saturday delivery is required, the receiving laboratory, in order to schedule receipt, must be notified by no later than 2:00 p.m. Central Standard Time on Friday. The EPA Houston Lab does NOT accept Saturday deliveries. Typical labeling requirements are shown on Figure 2-1.

When samples are relinquished to the delivery service for transport, the shipping air bill number will be recorded on the CoC form. Commercial carriers are not required to sign off on the CoC forms as long as the forms are sealed inside the sample cooler and the custody seals remain intact. The CoC record identifying the contents will accompany all shipments. The original record will accompany the shipment, with field copies being retained by the sampler. The FTL will fax a copy of the completed CoCs to the Project Chemist and the PDM on a daily basis to allow for sample tracking and resolution of any questions from the analytical laboratory regarding that day’s sample shipment.

Upon receipt of field samples, the analytical laboratory representative will sign the CoC to accept custody of the samples and will then properly store them to await analysis.

007404



2.4 Analytical Methods Samples collected in support of this project will be analyzed using only EPA-approved methods from the sources presented in the previous section. Methods for ISCO and S-EPR were specified in Table 2-1. Table 2-2 lists the test methods associated with ISS.

The analytical scope and a summary of the QA/QC protocol are provided in this document. Method-specific QC requirements are provided in the referenced analytical methods. Each analytical methodology is discussed below.

2.4.1 Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry Soil and groundwater samples will be collected and sent to an offsite laboratory for volatile organic compound (VOC) analysis by SOM01.2 (or by EPA SW-846 Method 8260B; EPA, 1999). Samples will be introduced into a purge and trap system that will purge the VOCs from the matrix, concentrate them on a sorbent trap, and thermally desorb them onto a gas chromatograph (GC) column for separation and quantitation by gas chromatograph/mass spectrometer (GC/MS). Soil and ISS samples will also be analyzed for synthetic precipitation leaching procedure (SPLP) VOCs. This requires extraction of samples using SW-846 Method 1312. Resulting leachate is then analyzed using the procedure described above. The target analytes will consist of benzene, toluene, ethylbenzene, xylenes (BTEX) as listed in Table 2-3.

2.4.2 Semivolatile Organic Compounds by Gas Chromatography/Mass Spectrometry

Soil and groundwater samples will be collected and sent to an offsite laboratory for semivolatile organic compound (SVOC) analysis by SOM01.2 (or by EPA SW-846 Method 8270C; EPA, 1999). Samples undergo an extraction by methylene chloride followed by a concentration step that produces a small aliquot (1 milliliter [ml]) of concentrated sample that is introduced onto a GC column for separation and quantitation by GC/MS. Soil and ISS samples will also be analyzed for SPLP SVOCs by extraction using SW-846 Method 1312. Resulting leachate is then analyzed using the method described above. The target analytes will consist of the SVOCs listed in Table 2-4.

2.4.3 Total Petroleum Hydrocarbons by Gas Chromatography Groundwater and soil samples will be collected and sent to an offsite laboratory for total petroleum hydrocarbons (TPH) analysis. by Texas Commission on Environmental Quality (TCEQ) 1005. Samples are extracted with n-pentane and analyzed using a gas chromatography with flame ionization detection (GC/FID). This method measures the concentration of hydrocarbons in the carbon (C) range C6 to C35.

2.4.4 Total Organic Carbon by Combustion-infrared Spectrometry Groundwater and soil samples will be collected and sent to an offsite laboratory for total organic carbon (TOC) analysis by EPA MCAWW Method 415.2 and SW-846 Method 9060A, respectively. The organic carbon in the sample is converted by combustion or chemical oxidation into carbon dioxide, and then measured by infrared spectrometry. The required quantitation limits are listed in Table 2-5.

2.4.5 Total Suspended Solids by Gravimetry Groundwater samples will be collected and sent to an offsite laboratory for total suspended solids (TSS) analysis by EPA MCAWW Method 160.2. The water sample is filtered through a glass fiber filter, and the residue retained on the filter is dried to a constant weight at 103 to 105 degrees Celsius (°C) to determine the amount of suspended solids. The required quantitation limits are listed in Table 2-5.

2.4.6 pH by Electrometry Soil samples will be analyzed for pH by SW-846 Method 9045A. Soil is mixed with reagent water in a 1:1 ratio, and the pH of the resulting liquid is measured with an electric pH probe.

007405



2.4.7 Field Data Acquisition During field data acquisition, the field team will conduct activities, such as sample collection and analytical work, by using field SOPs, field instruments, and field-test kits. Field data acquisition for this project will include surveying, water level measurement, and field analytical measurements for temperature, pH, oxidation-reduction potential, specific conductivity, and dissolved oxygen.

2.4.8 Soil Properties Several tests will be performed to quantify properties of both the untreated and ISS treated soil. Untreated, samples for ISS will undergo screen analysis to quantify the percentage of fines within the soil. The plasticity index, which is the difference between the liquid and plastic limit, will also be determined by ASTM International (ASTM) D4318. Liquid and plastic limits are the moisture contents where soil can no longer hold its shape due to free flow or crumbling. Moisture content of the untreated and treated samples will be determined by measuring the difference in mass between a soil sample before and after drying at 110°C plus or minus 5°C as specified in ASTM D2216. The difference in mass is assumed to be the moisture content of the original sample. The following tests will only be performed on treated soils that, when cured, are in the form of 2-inch-diameter cylinders. Density is the recorded mass per unit volume. In ASTM C143, slump is characterized by the vertical displacement of the center of a compacted cone of the soil within a mold. Slake immersion and swell are measured through soaking the sample in water. Slake tests (ASTM D4644) involve intervals of soaking and drying the sample, and swell is based on the change in volume following the soaking period. Penetration resistance (ASTM D1558) is measured with a handheld penetrometer, which indicates resistance to deformation with a spring dynamometer. This test will be performed after 1, 3, and 5 days of curing. The unconfined compressive strength test (UCS) will be performed on days 7 and 28 of curing according to ASTM D1633/D4832 to determine the maximum load the soil can bear. Finally, the hydraulic conductivity of the treated soils will be determined by ASTM D5084. Samples are placed in a flexible-wall permeameter, and the flow rate of water is measured under an applied hydraulic gradient. Hydraulic conductivity is calculated through use of Darcy’s Law.

2.5 Quality Control All project members will adhere to a QA program to ensure the reliability and validity of the activities being performed. The QA program includes a wide variety of QC measures, one of which is the analysis of various QC samples. Applicable QC samples are discussed below, and the field procedures for obtaining them are presented in the TTP. QC samples are collected for those samples submitted for chemical analysis only.

2.5.1 Quality Control Samples The following sections present the various QC samples to be collected during the treatability study field sampling activities.

Field Duplicates Field duplicates (FD) are samples that are collected at the same time and location in an effort to duplicate the collection of a particular sample. FDs are used to monitor the precision of the field sampling process. The identity of the duplicate samples will be recorded in the field sampling logbook. This information is forwarded to the data quality evaluation team to aid in review and evaluation of the data. It is expected that FDs will be collected at a rate of 1 per 10 field samples, or 10 percent, per matrix for all analyses.

Equipment Rinsate Blanks For water and soil sampling, after the sampling equipment is fully decontaminated, it is rinsed with deionized and organic-free water and a sub-sample of this rinsate is collected as the equipment blank (EB). The EB is preserved, handled, and stored in the same manner as the normal field samples. The EB is then sent to the laboratory and typically analyzed for the same analytical parameters as the corresponding normal samples that were collected with that equipment that day. The EB is used to monitor for potential cross-contamination caused by improper

007406



equipment decontamination procedures. EBs will be collected at a rate of 1 per week per matrix for samples that do not involve dedicated or disposable sampling equipment and thus are at risk for possible cross-contamination.

Trip Blanks A trip blank is a clean sample of ASTM Type II water contained in a 40-ml VOC vial that is prepared prior to the sampling event. The vial is transported to the site and stored with the other normal VOC sample containers. The trip blank, which is not opened in the field, is transported back to the laboratory with the normal VOC samples and analyzed for VOCs only. The trip blank is used to monitor the potential for sample contamination with VOCs during sample transport. A trip blank will be included in every cooler that contains a sample for soil or water VOCs analysis.

Temperature Blanks Temperature blanks are sent with each cooler shipped to the offsite laboratory containing soil or groundwater samples that require preservation at 4°C. Temperature blanks consist of a non-preserved VOC vial or similar laboratory container filled with ASTM reagent grade water. Temperature blanks are measured with a thermometer or thermal sensing device at the laboratory upon receipt to verify the temperature of the samples contained in that cooler. One temperature blank will be shipped with each cooler to each offsite lab.

Matrix Spike and Matrix Spike Duplicate A matrix spike (MS) is a normal field soil or water sample that is spiked by the analytical laboratory with a known concentration of target analyte(s) prior to sample preparation and then prepared and analyzed in the same fashion as other normal environmental samples. The matrix spike duplicate (MSD) is an intralaboratory split of the same sample used for the MS, which is also spiked with identical concentrations of target analyte(s) and treated the same as the MS sample. MS/MSDs are used to monitor and document possible bias for a given analytical method in a given sample matrix. MS/MSDs are also used to measure the precision and accuracy of the laboratory analytical procedure. For CLP laboratories, the MS/MSD sample is also referred to as the lab QC sample.

CLP laboratories require an MS/MSD (or MS/lab duplicate) to be analyzed at a frequency of 5 percent, or 1 MS/MSD per 20 samples of similar matrix per week, collected and shipped for analysis with the first set of samples of the week. The EPA Houston Lab requires an MS/MSD for organic analyses to be analyzed at a frequency of 5 percent, or 1 MS/MSD per 20 samples of similar matrix per week. However, the EPA Houston Lab requires an MS/MSD (or MS/lab duplicate) for general chemistry analyses to be analyzed at a frequency of 10 percent, or 1 MS/MSD per 10 samples of similar matrix per week. Water samples for organic analyses that are also to be used for the MS/MSD (that is, laboratory QC) require the provision of triple volume to allow for the sample, the MS, and the MSD. Water samples for inorganic analyses typically require double volume to allow for the normal sample and the MS/MSD. Soil samples for VOCs and TPH analysis for this project will also require triple volume for the sample that will be used as the MS/MSD, because the samples are being provided in closed-system vials or Encore devices. Other soil analyses do not require triple volume to accommodate the MS/MSD.

2.5.2 Field and Laboratory Corrective Action The following sections discuss the field and laboratory corrective action requirements.

Field Corrective Action Any project team member may initiate a field corrective action process. This process consists of identifying a problem, acting to eliminate the problem, monitoring the effectiveness of the corrective action, verifying that the problem has been eliminated, and documenting the corrective action. A copy of a corrective action form is presented in Attachment 1.

Field corrective actions may include such activities as correcting CoC forms, solving problems associated with sample collection, repacking samples to ensure sample integrity, correcting an entry in a field logbook, reprogramming and deployment of a transducer, or providing a team member with additional training in sampling or water level collection procedures. More extensive corrective actions may involve resampling or evaluating and

007407



revising sampling procedures. The FTL will summarize the problem, establish possible causes, and designate the person responsible for a corrective action. The FTL will then verify that the initial action has been taken and that it appears to be effective. Finally, the FTL will follow up at a later time to verify that the problem has been resolved. If a corrective action could affect the quality of the analytical process, the FTL must inform the CH2M HILL Project Chemist of the situation immediately.

Laboratory Corrective Action The analytical laboratories analyze samples according to specific methods with required QC standards. All analytical data are reviewed to ensure that the required QC measures are followed and that all specified QC standards are met. Some examples of situations that may require laboratory corrective action include:

• QC data are outside the control limit ranges for precision and accuracy established for laboratory samples.

• Blanks contain target analytes above acceptable levels.

• Deficiencies are detected by the laboratory QA director during internal or external audits or from the results of performance evaluation samples.

• Undesirable trends are detected in QC data.

• Unusual changes are apparent in detection limits.

• Inquiries concerning data quality are received.

If the bench analyst identifies a QC violation, then corrective action is taken immediately. The analyst immediately notifies his or her supervisor of the problem and the investigation being performed. Some examples of analyst-level corrective action can include:

• Recalculating mathematical expressions • Reanalyzing suspect samples • Recalibrating analytical instruments • Recalibrating with new standards

If the problem persists or cannot be identified, the matter must be referred to the laboratory supervisor and to the QA/QC officer for further investigation. All laboratory QC problems that will affect the quality of the final data must be discussed with the CH2M HILL Project Chemist as part of the corrective action process. Some examples of managerial-level corrective action include the following:

• Evaluating and amending sub-sampling or analytical procedures • Resampling and analyzing new samples • Qualifying or rejecting the data

Once resolved, the corrective action must be fully documented in a corrective action form and must be included with the applicable data package submitted to the CH2M HILL Project Chemist.

2.6 Instrument and Equipment Testing, Inspection, and Maintenance

The CH2M HILL FTL is responsible for overseeing the proper operation of all field equipment. Field equipment testing, inspection, and maintenance will be performed in accordance with the SOPs in the TTP or the manufacturer’s recommendations as described in the equipment manual. Any field equipment malfunction will be reported to the CH2M HILL PM to identify the necessary corrective action. A detailed list of field equipment to be used for this project is available in the TTP.

Laboratory equipment testing, inspection, and maintenance will be in accordance with the laboratory’s QA plan. The laboratory QA plan will discuss the schedule, procedures, criteria, and documentation for verifying that all analytical equipment is operating in an accurate and precise manner. Any laboratory equipment malfunction that

007408



will impact sample analysis will be reported immediately to the CH2M HILL Project Chemist or designee to evaluate the corrective action.

2.7 Instrument and Equipment Calibration and Frequency Any field instruments used will be calibrated in accordance with manufacturers’ specifications before the beginning of sampling activities and at specified intervals thereafter. For field instruments calibrated by the manufacturer, calibration will be verified daily. If a field instrument cannot be properly calibrated, the instrument must not be used and must be replaced with a functioning instrument. All laboratory instruments will be calibrated in accordance with manufacturers’ directions, method requirements, and SOP specifications.

2.8 Inspection and Acceptance of Supplies and Consumables CH2M HILL is responsible for furnishing all required supplies and consumables for the duration of the project. Any purchased supplies or other subcontract service must meet the project scope, specified levels of quality, and the submittal schedule. Project subcontractors should have contractual arrangements with their suppliers for all required materials. Subcontractors will provide the FTL and KA with documentation that the supplied materials meet the requirements of the subcontract documents.

2.9 Non-Direct Measurements This subsection discusses types of data that will be used to make project decisions obtained from non-measurement sources. Project objectives were outlined and summarized in Section 1 of this QAPP. The data needed to achieve the project objectives include site maps, sampling location selection and sample identifiers, laboratory method selection, detection limit verification, analytical parameter lists and critical values, field parameter measurement list, and a project schedule. This information is included in several project documents such as the project work plan, HSP, TTP, FOP, and this QAPP.

As part of the data acquisition planning activity, the team defined the historical and reference information to be used. The historical data were also reviewed and their data quality assessed. A similar QC review will be performed on the new analytical data obtained during this investigation. The product of this activity is a database containing complete and accurate analytical information that can be used for project decision making and report production.

2.10 Data Management Data gathered during the investigation, as well as any gathered during previous site investigations, will be consolidated and compiled into a project environmental database system, which is used to evaluate site conditions and data trends.

Project data management includes the following project-specific objectives:

• Establish a controlled, functional, and efficiently operated data management system and accompanying procedures to manage, analyze, document, and transfer the environmental data that are collected and generated.

• Maintain a usable and accurate database throughout the life of the project.

• Process specific data requests from project team members.

• Transfer the database or specific data components to other parties, as appropriate.

• Archive the database and related documentation upon project closeout.

007409



2.10.1 Data Types Activities performed during site investigations will involve accessing a number of different types of data. Contents of the project database are described below.

Historical Data Historical data for the site include chemical and physical data from previous investigations, historical accounts, and various other types of data collected from the site.

Investigative Data The FOP identifies additional analytical and hydrogeological data that are collected on an ongoing basis to assess remedy effectiveness. These data are incorporated into the project database as they become available. These data include field parameter data collected during sampling and field observations. Other types of data elements may be added as the field investigation needs and activities evolve.

2.10.2 Data Tracking and Management The following sections describe the tracking and management procedures for hard copy data and data input procedures.

Hard Copy Measurements made during field data collection activities will be recorded in field logbooks and on field forms. Field data will be reduced, summarized, and stored along with the field logbooks. Photocopies of this field data will be provided to the PDM for entry into the project database as needed, unless alternate electronic delivery of the data has been provided.

All hard copy analytical laboratory data will be stored. These may include CoC forms, case narratives, analytical bench sheets and reports, instrument printouts and chromatograms, certificates of analyses, and QA/QC report summaries.

Data Input Procedures Sampling information will be entered into the project database electronically by uploading the information from the FORMS II Lite or Scribe exportable files if available. If the exportable files are unavailable, the sampling information will be entered manually into the project database for storage and retrieval during data evaluation and report development.

Any analytical data obtained from the EPA Houston Lab, Tier IV subcontract laboratory, or CLP laboratory will be uploaded electronically to the project database from a .txt or a .csv file.

Data validation qualifiers applied by the Project Chemist or designee during the analytical data validation process will be entered manually into the project database by the PDM or designee.

A percentage of the final electronic results of any data uploaded to the project database will be verified against the original hard copy reports to ensure accuracy of the EDD and of any manual transcription. All data entry evaluation procedures and results will be appropriately documented. The product of this activity is an accurate and complete project database ready to support project data evaluation.

2.10.3 Computer Database The computer database system uses SQL Server 2000 to store the data. Microsoft Access 2003 is used as a front end that contains tools to build menus, online forms, and report formats. The database is based upon a relational model, in which independent tables containing fields of data can be linked through selected fields that are common to two or more tables. This database design allows inclusion of the historical data and allows users to effectively conduct trend analysis, and generate a variety of data reports to aid in data interpretation and report generation. The database should be protected from unauthorized access, tampering, accidental deletions or additions, and data or program loss that can result from power outages or hardware failure.

007410



2.10.4 Documentation Documentation of data management activities is critical because it provides:

• A record of project data management activities • Reference information critical for database users • Evidence of the activities having been properly planned, executed, and verified • Continuity of data management operations when personnel changes occur

Additional documentation will be maintained as a record of specific issues such as database structure definitions, database inventories, database maintenance, user requests, database issues and problems, and client contact.

2.10.5 Evidence File The final evidence file will be the central repository for all documents that constitute evidence relevant to sampling and analysis activities. CH2M HILL is the custodian of the evidence file and maintains the contents of the evidence files for the project, including all relevant records, reports, logs, field notebooks, pictures, contractor reports, and data reviews in a secured, limited access area under the custody of CH2M HILL.

CH2M HILL will retain all records until project completion and closeout. If necessary, records may be transferred to an offsite record storage facility to provide secure, access-controlled storage of records. Subcontract laboratories will retain all records of raw analytical laboratory data, QA data, and reports for a minimum of 5 years. The central repository for electronic files will be located in the project directory of the CH2M HILL Dallas server.

2.10.6 Presentation of Analytical Data Data presentation will vary depending on the data user’s needs. Some examples of data presentation formats are the following:

• Tabulated results of data summaries or raw data • Figures showing concentration isopleths or location-specific concentrations • Tables providing statistical evaluation results or calculation results • Presentation tools such as ArcInfo or other similar analysis/presentation aids

007411




007412


SECTION 3

Assessment and Oversight The following sections describe how assessment and oversight activities, response actions, and reports to management will be performed.

3.1 Assessments and Response Actions Assessment and oversight activities are performed to evaluate whether the QC measures identified in the TTP, FOP, and this QAPP are implemented and documented as required. The PM, Project Chemist, and FTL will undertake assessment and oversight activities to monitor conformance to plans. For example, during a field review, the TTP may be checked to verify that a monitor well has been correctly sampled or that the field QC samples were collected at the appropriate frequency. Additional checks may address the questions:

• Is the TTP being followed? • Is non-conformance being identified, resolved, and documented with a process or system? • Are identified deficiencies being corrected? • Are sampling operations being performed as stated in the TTP? • Are the sample labels being filled out completely and accurately? • Are the CoC records complete and accurate? • Are the field notebooks being filled out completely and accurately? • Are the documents generated during assessment activities being stored as described in the QAPP?

The need for a check can be assessed independently by the PM, or assigned by the PM to another team member. Assessment activities may include surveillance, inspection, peer review, management system review, performance evaluation, and data quality assessment. Results of the assessment and oversight activities will be reported to the PM, who will be responsible for ensuring that the corrective action response is completed, verified, and documented.

3.2 Reports to Management Effective communication among all project team members will be established and maintained throughout the course of the project.

The PM will coordinate monthly status reports to the EPA TOM as necessary. Status reports will present discussions of current activities, problems encountered and their resolution, and planned work.

007413

SECTION 3: ASSESSMENT AND OVERSIGHT



007414


SECTION 4

Data Validation and Usability This section discusses the procedures for evaluating the analytical data for the chemical analyses and assessing its usability.

4.1 Data Review, Verification, and Validation Data review or validation is the process by which data generated in support of a project are reviewed against the data QA/QC requirements. For this project, the QA/QC requirements are those specified by applicable EPA methods, SOPs, EPA Region 6 guidelines, this QAPP, and EPA’s National Functional Guidelines for Superfund Organic Methods Data Review (EPA, 2008) and EPA’s National Functional Guidelines for Inorganic Superfund Data Review (EPA, 2010b).

In instances in which the data are deemed of insufficient quality to satisfy project DQOs, the data will be flagged to identify use limitations or rejected. Data flagged as rejected will not be used to support key project decisions. After the data review is completed, a data quality evaluation memorandum will be prepared to document the findings. Several key statistical QC measurements that may be used in the data review are discussed below.

4.1.1 Precision Precision is a measure of the agreement or reproducibility of a set of replicate results obtained from duplicate analyses made under identical conditions. Precision is estimated from analytical data and cannot be measured directly. The precision of a duplicate determination can be expressed as the relative percent difference (RPD) calculated as follows:

RPD = {(|X1 - X2|)/((X1 + X2)/2)} x 100 = ( ) 100

221

21 xXXXX

+−

where X1 is the result from the native sample, and X2 is the result from the duplicate sample.

4.1.2 Accuracy Accuracy is a measure of the agreement between an experimental determination and the true value of the parameter being measured. Accuracy is estimated through the use of known reference materials or MSs. It is calculated from analytical data and is not measured directly. Spiking of reference materials into a sample matrix is the preferred technique, because it provides an assessment of the matrix effects on analytical accuracy. Accuracy, defined as percent recovery (%R), is calculated as:

( ) 100 x SA

SR-SSR = R

%

where SSR is the spiked sample result, SR is the sample result (native), and SA is the spike concentration added to the spiked sample.

4.1.3 Completeness The completeness of the field and laboratory-generated analytical data will be assessed for compliance with the amount of data required for decision making. The calculation for assessing completeness is as follows:

% Completeness = Valid Data Obtained × 100

Total Data Obtained

007415

SECTION 4: DATA VALIDATION AND USABILITY


The completeness goal for the project data set is 95 percent.

4.1.4 Sensitivity Sensitivity is a measure of the limit of how low a concentration can be for an analysis to maintain its reliable detection and reporting of a particular analyte. Higher sensitivities allow the laboratory to establish method detection limits (MDL) and reporting limit (RL) at sufficiently low levels so that the project DQOs can be achieved.

4.2 Data Types The following sections briefly describe the two different types of data that will be collected during the project.

4.2.1 Screening Data Screening data generally include field measurements that are analyzed with a minimal level of QC to produce approximate numbers for screening purposes. Screening data are generally used on the basis of very limited QA/QC and documentation in contrast to the rigorous review of data quality required for the definitive data sets. Screening data are expected to include field measurements of temperature, pH, dissolved oxygen, oxidation reduction potential, turbidity, specific conductivity, and water level measurements.

The FTL or Project Chemist will normally review the screening data and accept or reject them. Unusual readings are recorded in the field logbook, along with the rationale for accepting or rejecting the data. The following types of field data are generally recorded in the site logbooks for the FTL’s review:

• Instrument identification • Calibration information and/or verification (standards used and results) • Date and time of calibration and sample measurement • Sample results • Supporting information (such as temperature for pH reading)

4.2.2 Definitive Data Definitive data are those of known quality with a substantial level of associated QA/QC. The definitive data results undergo an extensive quality system of data review and data evaluation. Definitive data can be used as follows:

• To investigate the nature and extent of site-related constituents • To support human health and ecological risk assessment tasks • To show that an area has or has not been affected by site-related constituents • To establish RD criteria

Definitive data can be generated by various measurements, ranging from onsite field analyses to laboratory analyses. All data collected for this project will constitute definitive data with the exception of any field analytical and water level measurements.

4.3 Verification and Validation Methods The data validation or data review process is conducted to assess the effect of sampling and analytical processes on the usability of the data. Two corresponding areas of review are laboratory performance evaluation and the effect of matrix interference or sampling error. The evaluation of laboratory performance as a relatively straightforward examination assesses whether or not the laboratory met the QC requirements of the analytical methods and other stated protocol requirements. The assessment of potential matrix effects and sampling error consists of evaluating the analytical results for the samples, as well as a number of QC measures, such as blank samples, duplicates, MS/MSDs, LCSs, and then assessing whether this process could affect the usability of the data.

All analytical data will be supported by a data package that will contain the relevant items listed in Section 1.7 of this QAPP. Before the laboratory will release each data package, the laboratory QA officer (or the analytical

007416



section supervisor) must carefully review the sample and laboratory performance QC data to verify sample identity, the completeness and accuracy of the sample and QC data, and compliance with method specifications.

Analytical data will be evaluated against the analytical QC standards set forth in the applicable SOPs, this QAPP, and applicable methods. If these standards are not met, the data are appropriately qualified during the validation process. In cases where the data are deemed of insufficient quality to satisfy project DQOs, the data will be rejected and will not be used to support project decisions.

Analytical data provided by a CLP laboratory in support of this project will undergo a data validation by the Environmental Services Assistance Team (ESAT), in accordance with EPA’s National Functional Guidelines for Superfund Organic Methods Data Review (EPA, 2008) and EPA’s National Functional Guidelines for Inorganic Superfund Data Review (EPA, 2010b), prior to submittal to CH2M HILL; and therefore will not require further validation by the Project Chemist. Nonetheless, the Project Chemist will review the data validation findings provided by ESAT to support the data evaluation.

All non-CLP analytical data obtained in support of this project will be reviewed by the Project Chemist or designee based on guidance provided in EPA’s National Functional Guidelines for Superfund Organic Methods Data Review (EPA, 2008) and EPA’s National Functional Guidelines for Inorganic Superfund Data Review (EPA, 2010b). Sample results will then be assigned data qualifiers as needed to express the degree of usability based upon overall data quality. After the completion of the data validation effort, a data quality evaluation technical memorandum will be prepared to discuss the findings of the review. The CH2M HILL project team will review the data quality evaluation to assess how the data, as qualified by the data validation, can be used on the project.

4.4 Reconciliation with User Requirements The final data evaluation task is to assess whether the data meet the project DQOs. The final validated analytical results, which may have been modified during the data validation process, will be compared against the DQOs, and an assessment will be made regarding whether or not the data are of sufficient quality to support them.

If the data are deemed sufficient to achieve project objectives, the project database will be updated with the newly validated data and any qualifiers or comments that were applied during the course of the review. The PDM will then produce the data presentations based upon the data user needs of the project team.

007417




007418


SECTION 5

Works Cited American Public Health Association, American Water Works Association, and Water Environment Federation. 2005. Standard Methods for the Examination of Water and Wastewater 21st Edition.

American Petroleum Institute (API). 2009. API RP 13B-1: Recommended Practice for Field Testing Water Based Drilling Fluids. March 1.

CH2M HILL. 2006a. Field Operations Plan, American Creosote Works Superfund Site.

CH2M HILL. 2006b. Site Management Plan, American Creosote Works Superfund Site.

CH2M HILL. 2008. Subsurface Soil Investigation for the American Creosote Works Superfund Site Winnfield, Louisiana. August.

CH2M HILL. 2010a. Health and Safety Plan, American Creosote Works Superfund Site. June.

CH2M HILL. 2010b. Environmental Services Business Group Quality Management Plan, Edition 4. August.

CH2M HILL. 2011a. Treatability Test Plan, American Creosote Works Superfund Site, Version 2.1. November.

CH2M HILL. 2011b. Quality Management Plan for Response Action Contract 2, Revision 4. July.

CH2M HILL. 2011c. Year 2010 Annual Operations Summary American Creosote Works Superfund Site Winnfield, Louisiana, Version 1.0. February.

CH2M HILL. 2011d. Draft Risk Assessment American Creosote Works Superfund Site. October.

CH2M HILL. 2011e. Draft Feasibility Study – Remedial Action Technology Screening and Preliminary Remedial Action Alternatives. October.

U.S. Environmental Protection Agency (EPA). 1983. EPA Methods for Chemical Analysis of Water and Wastes (MCAWW).

U.S. Environmental Protection Agency (EPA). 1993. Record of Decision (ROD), American Creosote Works Superfund Site, Winnfield, Louisiana. April.

U.S. Environmental Protection Agency (EPA). 1999. SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. EPA Office of Solid Waste. SW-846, 3rd Edition. May.

U.S. Environmental Protection Agency (EPA). 2001. EPA Requirements for Quality Assurance Project Plans (QA-R5). EPA Office of Environmental Information. EPA/240/B-01/003. March. Reissued in May 2006.

U.S. Environmental Protection Agency (EPA). 2002. EPA Guidance for Quality Assurance Project Plans (QA-G-5). EPA Office of Environmental Information. EPA/240/R-02/009. December.

U.S. Environmental Protection Agency (EPA). 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process (QA/G4). EPA Office of Environmental Information. EPA/240/B-06/001. February.

U.S. Environmental Protection Agency (EPA). 2007. Multi-Media, Multi-Concentration, Organic Analytical Service for Superfund (SOM01.2). EPA/540-FS-07-001. August.

U.S. Environmental Protection Agency (EPA). 2008. U.S. EPA Contract Laboratory Program National Functional Guidelines for Superfund Organic Methods Data Review. EPA Office of Solid Waste and Emergency Response. EPA/540/R-08-001. June.

U.S. Environmental Protection Agency (EPA). 2009. Annual Book of ASTM Standards.

U.S. Environmental Protection Agency (EPA). 2010a. Contract Laboratory Program Guidance for Field Samplers. EPA Office of Environmental Information. EPA/540/R-09/03. May.

007419

SECTION 5: WORKS CITED


U.S. Environmental Protection Agency (EPA). 2010b. U.S. EPA Contract Laboratory Program National Functional Guidelines for Inorganic Superfund Data Review. EPA Office of Solid Waste and Emergency Response. EPA/540/R-10-011. January.

007420

Tables

007421

TABLES

ACW FS_QAPP_VER 1.1_TABLES ES021512103510DFW


007422

TABLES

ACW FS_QAPP_VER 1.1_TABLE 1-1 1 OF 1 ES021512103510DFW

TABLE 1-1 Project Personnel and Telephone Numbers American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Name Role Telephone Number

Michael Hebert EPA Region 6 TOM 214-665-8315

Christy Warren EPA Houston Lab Sample Control Coordinator 281-983-2137

Myra Perez EPA Region 6 CLP Regional Sample Control Coordinator 281-983-2130

John Knott CH2M HILL Project Manager 409-781-8015

Mike Goldman CH2M HILL Health and Safety Manager 770-604-9182 x54133

Margaret O’Hare CH2M HILL RAC 2 QA Manager 972-663-2238

Heather Smith CH2M HILL Procurement Specialist 972-663-2245

John Ynfante CH2M HILL Project Chemist 281-721-8546

Patricia Twigg Critigena Project Data Manager 720-872-4051

Greg Twigg Critigena Project Geographic Information Systems Manager 281-721-8539

Paul Favara CH2M HILL Review Team Leader 352-384-7067

Scott McKinley CH2M HILL Senior Consultant 541-768-3514

Carrie Wallestad CH2M HILL Field Team Leader 972-663-2257 aCritigen is a team subcontractor to CH2M HILL.

007423

TABLES

ACW FS_QAPP_VER 1.1_TABLE 1-1 ES021512103510DFW


007424

TABLES


TABLE 1-2 Project Data Quality Objectives and Associated Investigation Tasks American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Problem Statement

Decision to be Made

Inputs to the Decision

Decision Rule Investigation Tasks Analyses Data Deliverable

Level Soil and Ground Water Sampling – ISCO Pilot-Scale Test The objective of the TT is to evaluate performance of three technologies (ISCO, S-EPR, and ISS) to treat areas of residual (immobile) and/or mobile DNAPL present at the site. By destroying (ISCO), removing (ISCO and S-EPR), or immobilizing (ISS) NAPL source material, the longevity of the dissolved plume is reduced by minimizing the contribution of contaminants from the DNAPL.

What percentage of reduction in DNAPL mass will ISCO achieve during the pilot-scale testing?

New analytical data obtained from DPT borings, one existing PLTS injection well, and PLTS effluent. Historical analytical data collected during past studies.

The new data will be evaluated to determine the effectiveness of the remedy when compared to performance data.

Soil and groundwater samples will be collected from six boring locations within the pilot testing area. A groundwater sample will also be collected from one existing injection well. Baseline samples will be collected prior to conducting injections, and performance samples will be collected when hydrogen peroxide is no longer present in the subsurface. Soil: Samples will be collected from three vertical zones of each boring and analyzed for SVOCs, BTEX, SPLP, TOC, and TPH. Groundwater: Samples will be collected from two vertical zones of each boring and analyzed for SVOCs, BTEX, TOC, and TPH. Samples will also be collected at one existing injection well.

Temperature Turbidity Specific conductivity Dissolved oxygen Oxidation reduction potential pH

Field Parameters: Level I

SVOCs BTEX TOC TPH

EPA Region 6 Houston Lab: Level II or CLP Lab: Level IV or Tier IV Lab: Level III

SPLP SVOCs SPLP BTEX SPLP TOC SPLP TPH

Tier IV Lab: Level III

007425

TABLES



Problem Statement

Decision to be Made



Level Soil and Ground Water Sampling – S-EPR Pilot-Scale Test

The objective of the TT is to evaluate performance of three technologies (ISCO, S-EPR, and ISS) to treat areas of residual (immobile) and/or mobile DNAPL present at the site. By destroying (ISCO), removing (ISCO and S-EPR), or immobilizing (ISS) NAPL source material, the longevity of the dissolved plume is reduced by minimizing the contribution of contaminants from the DNAPL.

What percentage of reduction in DNAPL mass will S-EPR achieve during the pilot-scale testing?

New analytical data obtained from DPT borings, existing PLTS injection and extraction wells, and PLTS effluent. Historical analytical data collected during past studies.

The new data will be evaluated to determine the effectiveness of the remedy when compared to performance data.

Soil and groundwater samples will be collected from nine boring locations within the pilot testing area. Baseline samples will be collected prior to conducting injections and performance samples will be collected at the injection conclusion. Soil: Samples will be collected from three vertical zones of each boring and analyzed for SVOCs, BTEX, SPLP, TOC, and TPH. Groundwater: Samples will be collected from two vertical zones of each boring and analyzed for SVOCs, BTEX, TOC, and TPH. Samples will also be collected from one existing injection well and seven recovery wells.

Temperature Turbidity Specific conductivity Dissolved oxygen Oxidation reduction potential pH

Field Parameters: Level I

SVOCs BTEX TOC TPH

EPA Region 6 Houston Lab: Level II or CLP Lab: Level IV or Tier IV Lab: Level III

SPLP SVOCs SPLP BTEX SPLP TOC SPLP TPH

Tier IV Lab Level III

007426

TABLES



Problem Statement

Decision to be Made



Level Bench Testing –ISS Bench-Scale Test The objective of the TT is to evaluate performance of three technologies (ISCO, S-EPR, and ISS) to treat areas of residual (immobile) and/or mobile DNAPL present at the site. By destroying (ISCO), removing (ISCO and S-EPR), or immobilizing (ISS) NAPL source material, the longevity of the dissolved plume is reduced by minimizing the contribution of contaminants from the DNAPL.

How will ISS reduce contaminant leachability during the bench-scale testing?

New geotechnical and analytical data collected during bench testing.

The new data will be evaluated to determine the effectiveness of the stabilization.

Develop appropriate grout mix to sufficiently stabilize soils and prevent additional leaching of contaminants to groundwater.

Geotechnical parameters: Moisture content Slump and density Accelerated cure pH Penetration Resistance UCS Hydraulic conductivity Swell

GeoSolutions, Inc: Level I

Analytical Parameters:

SPLP Permeate analyses

Tier IV Lab: Level III

007427

TABLES



Problem Statement

Decision to be Made



Level Full-Scale Cost Estimation The objective of the TT is to evaluate performance of three technologies (ISCO, S-EPR, and ISS) to treat areas of residual (immobile) and/or mobile DNAPL present at the site. By destroying (ISCO), removing (ISCO and S-EPR), or immobilizing (ISS) NAPL source material, the longevity of the dissolved plume is reduced by minimizing the contribution of contaminants from the DNAPL.

What is the cost to complete full-scale implementation of the technology per treatment volume?

Results of pilot-scale and bench-scale testing.

Pilot-scale and bench-scale testing will be evaluated to determine if the technical approach is effective. If it is, the cost to complete a full-scale application of the technology will be determined.

Use pilot-scale and bench-scale results to determine cost for full-scale application.

Review the amount of materials and labor hours required to complete the pilot-scale and/or bench-scale testing and determine the cost to complete a full-scale application.

NA

007428

TABLES



Problem Statement

Decision to be Made



Level Soil Waste Samples

Contaminated soil and water will likely be generated during remedial action activities. Contaminated water will be treated at the PLTS.

How will generated wastes be disposed?

Analytical data from waste soil, using analyses relevant to likely disposal options.

Depending on the results of the waste characterization, soil will be disposed at an appropriate facility.

Collect composite soil sample from each waste container. Samples will be analyzed in the laboratory, and the results will be communicated to the project team.

Soil: TCLP VOCs TCLP SVOCs TCLP pesticides TCLP herbicides TCLP metals Dioxins PCBs Ignitability TPH (GRO, DRO) Corrosivity

Tier IV Lab: Level II

Notes: DPT: dye penetration test DRO: Diesel Range Organics GRO: Gasoline Range Organics NA: not applicable PCB: polychlorinated biphenyl TCLP: toxicity characteristics leaching procedure

007429

TABLES



007430

TABLES


TABLE 1-3 Summary of Deliverables for Laboratory Analytical Reports American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

ALL Analytical Fractions Level I Level II Level III Level IV

Case Narrative – A detailed case narrative per analytical fraction is required to explain any non-compliance and corrective action. Exceptions will be noted for receipt, holding times, methods, preparation, calibration, blanks, spikes, surrogates, etc.

X X X

Sample ID Cross Reference Sheet (Lab IDs and Client IDs) X X X

Completed CoC and any sample receipt information X X X

Applicable MDLs/PQLs – generally at beginning of project or when updated (if not provided in data package) X X X

Copies of non-conformance memos and corrective actions X X X

EDD in specified format by e-mail and/or on CD X X X

GC/MS Organic Fractions (VOCs, SVOCs) Level I Level II Level III Level IV

Sample Results X X X X + raw data

Surrogate Recovery Summary (with applicable control limits) X X X + raw data

MS/MSD Accuracy & Precision Summary (w/ applicable control limits) X X X + raw data

LCS Accuracy Summary (w/ applicable control limits) X X X + raw data

Method Blank Summary X X X + raw data

Instrument Tuning Summary (including tuning summary for applicable initial calibrations) X X + raw data

Initial Calibration Summary (including concentration levels of standards) X X + raw data

Continuing Calibration Summary X X + raw data

Internal Standard Summary (including applicable initial calibrations) X X + raw data

General Chemistry Fractions (TOC, TSS) Level I Level II Level III Level IV

Sample Results X X X X + raw data

Initial and Continuing Calibration Summary X X + raw data

Initial and Continuing Calibration Blanks and Method Blanks Summary X X X + raw data

MS Recoveries Summary X X X + raw data

Native Duplicate or MS/MSD Precision Summary X X X + raw data

LCS Recovery Summary X X X + raw data

007431

TABLES


TABLE 1-3 Summary of Deliverables for Laboratory Analytical Reports American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Method Detection Limit Summary X X X + raw data

Preparation Log Summary X X + raw data

Analytical Run Sequence X X + raw data

Notes: PQL: Practical Quantitation Limit

007432

TABLES


TABLE 2-1 Sample Containers, Preservatives, and Holding Times American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Analysis Method Container Preservation/ Storage Maximum Hold Time

Groundwater Samples

pH Horiba Model U-22* — — —

Conductivity Horiba Model U-22* — — —

Dissolved oxygen Horiba Model U-22* — — —

Temperature Horiba Model U-22* — — —

Oxidation reduction potential

Horiba Model U-22* — — —

BTEX 8260B or SOM01.2 (3) 40-mL VOA vials pH ≤ 2 (HCl), Cool 4°C

14 days

TPH TCEQ 1005 (2) 40-mL VOA vials pH ≤ 2 (HCl), Cool 4°C

14 days

SVOCs, PAHs, PCP 8270C or SOM01.2 (2) 1-liter amber bottles Cool 4°C Extraction: 7 days Analysis: 40 days

TOC EPA 415.2 (1) 1-liter amber bottle pH ≤ 2 (H2SO4), Cool 4°C

14 days

TSS EPA 160.2 (1) 1-liter HDPE bottle Cool 4°C 7 days

Soil Samples

BTEX 5035/8260B or SOM01.2

(3) 40-mL Terracore vials with 5g soil and (1) 4oz jar Cool 4°C

48 hours to analysis, freezing or preservation

If frozen or preserved then 14 days to analysis

TPH TCEQ 1005 (3) 40-mL Terracore vials with 5g soil and (1) 4oz jar Cool 4°C

48 hours to analysis, freezing or preservation

If frozen or preserved then 14 days to analysis

SVOCs, PAHs, PCP 8270C or SOM01.2 (1) 8 oz jar Cool 4°C Extraction: 14 days Analysis: 40 days

TOC 9060 (1) 8 oz jar Cool 4°C 28 days

pH 9045A (1) 8 oz jar Cool 4°C As soon as possible

Percent moisture ASTM D2216 (1) 8 oz jar Cool 4°C 28 days

SPLP BTEX 1312 / 8260B (1) 8 oz jar Cool 4°C SPLP: 14 days

Analysis: 14 days

007433

TABLES


TABLE 2-1 Sample Containers, Preservatives, and Holding Times American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Analysis Method Container Preservation/ Storage Maximum Hold Time

SPLP SVOCs, SPLP PCP 1312 / 8270C (1) 8 oz jar Cool 4°C SPLP: 14 days

Extraction: 7 days Analysis: 40 days

SPLP TOC 1312 / 9060 (1) 8 oz jar Cool 4°C SPLP: 28 days

Analysis: 28 days

≤: less than or equal to —: Not applicable *: Or equivalent °C: degrees Celsius g: gram H2SO4: sulfuric acid HCl: hydrochloric acid HDPE: high-density polyethylene oz: ounce VOA: volatile organic analysis

007434

TABLES


TABLE 2-2 ISS Bench-scale Test Analysis American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana Test Description Test Method

Soil pH SW-846 9045A

Percent fines Sieve analysis

Plasticity index ASTM D4318

Moisture content ASTM D2216

Slump and density ASTM C143 mod.

Slake immersion ASTM D4644 mod

Swell (theoretical and measured) Weight and volume

Penetration resistance (1, 3, and 5 days) ASTM D1558

UCS (7 and 28 days) ASTM D1633/D4832

Hydraulic conductivity ASTM D5084

Permeate analyses -PAHs (including naphthalene) and PCP - Benzene

SW-846 8270C SW-846 8260B

SPLP PAHs (including naphthalene) and PCP SPLP benzene SPLP TOC

SW-846 1312/8270C SW-846 1312/8260B SW-846 1312/9060A

007435

TABLES



007436

TABLES


TABLE 2-3 VOCs Target Analyte List and Reporting Limits for Groundwater Samples American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Compound Water and SPLP RL

(µg/L) Soil RL (µg/kg)

1 Benzene 1.0 2.6

2 Toluene 1.0 5

3 Ethylbenzene 1.0 5

4 o-xylene 1.0 5

5 m&p-xylenes 1.0 5

007437

TABLES



007438

TABLES


TABLE 2-4 SVOCs Target Analyte List and Reporting Limits for Groundwater Samples American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

Compound Water and SPLP RL

(µg/L) Soil RL (µg/kg)

1 Acenaphthene 0.2 187

2 Acenaphthylene 0.2 187

3 Anthracene 0.2 187

4 Fluorene 0.2 187

5 Fluoranthene 0.2 187

6 Naphthalene 0.2 187

7 Phenanthrene 0.2 187

8 Pyrene 0.2 187

9 Benzo(a)anthracene 0.2 187

10 Benzo(b)fluoranthene 0.2 187

11 Benzo(k)fluoranthene 0.2 187

12 Benzo(ghi)perylene 0.2 187

13 BaP 0.2 187

14 Chrysene 0.2 187

15 Dibenzo(a,h)anthracene 0.2 187

16 Indeno(123-cd)pyrene 0.2 187

17 2-Methylnaphthalene 0.2 187

18 Pentachlorophenol 1.0 10

19 Dibenzofuran 1.0 5000

20 Bis(2-ethylhexyl)phthalate 1.0 5000

007439

TABLES



007440

TABLES


TABLE 2-5 General Chemistry Target Analyte List and Reporting Limits American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana Compound Water and SPLP RL Soil RL

1 TOC 2 mg/L 200 mg/kg

2 TSS 4 mg/L -

mg/L =milligrams per liter

007441

TABLES



007442

Figures

007443

FIGURES

ACW FS_QAPP_VER 1.1_FIGURES ES021512103510DFW


007444

FIGURES

ACW FS_QAPP_VER 1.1_FIGURE 1-1 ES021512103510DFW

FIGURE 1-1 Project Organization Chart American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

EPA Task Order Manager

Michael Herbert

EPA Houston Lab Sample Control

Coordinator Christy Warren

EPA Region 6 CLP Regional

Sample Control Coordinator Myra Perez

EPA

Sample Management

Office

CLP Laboratories

EPA Houston Lab

Project Manager

John Knott

RAC 2 QA Manager

Margaret O’Hare

Health and Safety Manager

Michael Goldman

Project Data Manager

Patricia Twigg

Project Chemist John Ynfante

Field Team Leader

Carrie Wallestad

Review Team Leader

Paul Favara

Procurement Specialist

Heather Smith

Contractors

SEPR Contractors VeruTEK &

Evergreen (ERGI)

ISCO Contractor

Geo-Cleanse International (GCI)

ISS Contractor

TBD

007445

FIGURES



007446

Site Location

CH2MHILL

PLTS SupportBldg.

PLTSBldg.

Bioreactor

Pond

I-2

R-191%

R-2010%

R-2130%

I-9

I-8

I-11

I-103

WasteCell

1 2

4Tar Mat

Area

Deep InjectionTrench

Shallow InfiltrationTrench

East RecoveryTrench

North RecoveryTrench

North RecoveryTrench

R-7NM

R-920%

R-1535%

I-5

S-9S-8S-7S-6

I-6

I-3

I-7

I-1

I-4

R-80%

R-615%

R-555%

R-415%

R-31%R-2

NM

R-1NM

S-10

S-1240%

S-1165%

S-050%

S-040%

S-030%

S-020%

S-015% R-18

15%

R-1750%

R-165%

R-1425%

R-130%

R-12100%

R-110%

R-1040%

FIGURE 1-2Current Site MapDecember 2009

American Creosote WorksWinnfield, LA

0 10050

Feet

NOTE: Aerial Photo Taken in 1993

LEGENDRecovery Well Location

Recovery Trench Piping

Injection System PipingUnderground Piping

FenceCreek (Creosote Branch)

PondCurrent Location ofBuildings

Recovery Sump LocationInjection Well Location

Site Utility Roads

R-2 Indicates an InactiveRecoveryWell/Injection Well/Sump Location (2010)

Aboveground Piping

Infiltration/Injection SystemTrench Piping

Approximate Locationof Tar Mat AreaApproximate Location ofWaste CellApproximate Location ofImpoundment Areas

Estimated Boundary of NAPLSource Area - Feb 2008

50% - Estimated Percentage of NAPL in Recovery Well Groundwater Sample on April 17, 2011NM - Not Measured (No Pump)

Date: 9/23/2011 Time: 10:29:20 AM

Path:

T:\IS

\Proj\

Ameri

can_

Creo

sote\

apr-m

xd\ne

w-inf

iltren

ches

_with

histor

ical_2

011.m

xd

007447

FIGURES



007448

FIGURES


FIGURE 2-1 Proper Labeling of Sample Coolers American Creosote Works Superfund Site Feasibility Study, Winnfield, Louisiana

007449

FIGURES



007450

Attachment 1 Quality Control Corrective Action Form

007451

ATTACHMENT 1: QUALITY CONTROL CORRECTIVE ACTION FORM

ACW FS_QAPP_VER 1.1_ATTACHMENT 1 ES021512103510DFW


007452

ACW FS_QAPP_VER 1.1_ATTACHMENT 1 A1-1 ES021512103510DFW

ATTACHMENT 1

Quality Control Corrective Action Form

Quality Control Corrective Action Form Originator: ________________ Date: ______________

Description of Problem:

Corrective Action Taken:

Corrective Action Results:

CA initially approved by: _________________________________ on Date: ________________

Follow-up date:

Final CA approval by: _________________________________ on Date: ______________ ___

SEND COPIES TO:

Responsible Person, Project Chemist, Field Team Leader, Project Manager

007453

ATTACHMENT 1: QUALITY CONTROL CORRECTIVE ACTION FORM

ACW FS_QAPP_VER 1.1_ATTACHMENT 1 A1-2 12103510

ES0215 DFW


007454

REMEDIAL ACTION CONTRACT - United States Environmental ... · REMEDIAL ACTION CONTRACT . United...

Documents

Transcript of REMEDIAL ACTION CONTRACT - United States Environmental ... · REMEDIAL ACTION CONTRACT . United...