RAP3709j - LM Sites - Department of Energy

200.1e Shpack_Landfill_03.04_0021_a

VOLUME

TABLE OF CONTENTS

SECFION PHASE 1A INITIAL SITE CHARACTERIZATION WORK PLAN

SECTION QUALITY ASSURANCE PROJECT PLAN QAPP

APPENDIX LABORATORY QAPPs

EPA 04466

EPA 04467

PHASE 1A INITIAL SITE

CHARACTERIZATION WORK PLAN

EPA Q4468

TABLE OF CONTENTS

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1.0 INFRODUCHON1-1

1.1 PURPOSE OF RJJFS 1-1

1.2 PURPOSE OF PHASE 1A INITIAL SITE CHARACTERIZATION

WORKPLAN 1-1

2.0 SITE BACKGROUND AND SlT1iNG 2-1

2.1 SITE LOCATION 2-1

2.2 S1TELAYOUT 2-1

2.3 PHYSICALSETflNG 2-1

2.3.1 Current Land Use 2-1

2.3.2 Physiography 2-5

2.3.3 Geology 2-5

2.3.4 Hydrogeology 2-6

2.3.5 Surface Hydrology 2-7

2.3.6 Ecology 2-7

2.3.7 Site Contaminants 2-7

3.0 INITIAL SITE EVALUATION3-1

3.1 SITEFIISTORY3-1

3.1.1 Operating History 3-1

3.1.2 Previous Investigations 3-1

4.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ARAR 4-1

4.1 INTRODUCTION4.1

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TABLE OF CONTENTS Contd

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4.2 CHEMICAL SPECIFIC ARARs 4-66

4.2.1 Safe Drinking Water Act SDWA 4-66

4.2.2 Clean Water Act CWA 4-66

4.2.3 Toxic Substance Control Act TSCA 4-67

4.3.4 Radiological Hazards 4-67

4.3 LOCATION SPECIFIC ARARs 4-67

4.4 ACFION SPECIFIC ARARs 4-67

4.4.1 Clean Water Act CWA 4-67

4.4.2 Resource Conservation and Recovery Act RCRA 4-67

4.4.3 Other 4-71

4.5 STATE OF MASSACHUSETFS ARARs 4-71

5.0 DATA REQUIREMENTS FOR POTENTIAL REMEDIAL ALTERNATIVES ANDTECHNOLOGIES 5-1

5.1 IDENTIFICATION OF POTENTIAL REMEDIES 5-1

5.2 DATA REQUIREMENTS FOR POTENTIAL REMED 5-8

6.0 DATA NEEDS AND DATA QUALITY OBJECHVES 6-1

6.1 GENERALDESCRIPTION OF DATA QUALITY OBJECFIVESDQO PROCESS 6-1

6.2 DESCRIPTION OF DATA QUALITY CATEGORIES 6-I

6.3 DATANEEDS 6-9

6.4 DATA QUALITY NEEDS 6-10

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7.0 RI/FS TASKS 7-1

7.1 PROJECT PLANNING ERM TASKS 1-3 7-2

7.1.1 ERM TASK Review Existing Data 7-2

7.1.2 ERMTASK2 Develop Site Plans 7-2

7.1.3 ERM TASK Develop Work Plans 7-4

7.1.3.1 Develop Project Operations Plan POP 7-4

7.1.3.2 Develop Additional Work Plans 7-5

7.2 COMMUNiTY RELATIONS 7-5

7.3 REMEDIAL INVESTIGATION ERM TASKS 4-14 7-5

7.3.1 ERM TASK Mobilize Personnel and Equipment 7-7

7.3.2 ERM TASK Collect Ecological Data 7-7

7.3.3 ERM TASK Complete Health and Safety Testing andAir Monitoring 7-8

7.3.4 ERM TASK Sample Existing On-Site Wells 7-8

7.3.5 ERM TASK Perform Geophysical Investigations 7-9

7.3.5.1 General Considerations 7-9

7.3.5.2 Seismic Refraction Survey 7-10

7.3.5.3 Electromagnetic EM Induction Survey 7-10

7.3.5.4 Ground Penetrating Radar GPR Survey 7-10

7.3.6 ERM TASK Complete Soil Gas Survey 7-11

7.3.7 ERM TASK 10 Excavate Test Pit 7-12

7.3.8 ERM TASK 11 Install Micro-Wells 7-12

7.3.9 ERM TASK 12 Install Ground-Water Monitoring Wells 7-13

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7.3.9.1 General 7-13

7.3.9.2 Number and Location 7-14

7.3.9.3 Frequency of Soil Sampling and Analysis 7-15

7.3.10 ERM TASK 13 Sample Ground Surface Water StreamWetlands Sediment 7-17

7.3.10.1 Ground-Water Sampling 7-17

7.3.10.2 Aquifer Testing 7-18

7.3.10.3 Surface Water Sediment and Tar Material

Sampling 7-18

7.3.11 ERM TASK 14 Update Site Survey 7-20

7.4 ERM TASK 15 ECOLOGICAL RISK ASSESSMENT 7-20

7.5 ERM TASK 16 PREPARE INITIAL SITECHARACTERIZATION REPORT 7-22

7.5.1 Sample Analysis/Validation 7-22

7.5.1.1 Sample Management 7-22

7.5.1.2 Data Validation 7-22

7.5.2 Data Evaluation and Tabulation 7-22

7.6 ERM TASKS 17-23 PREPARE PHASE WORK PLAN 7-22

7.6.1 Treatability Study/Pilot Testing 7-23

7.6.2 ERM TASK 23 Prepare RI Report 7-23

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7.7 FEASIBILITY STUDY TASKS 7-24

7.7.1 ERM TASKS 24-25 Develop Remedial Action

Objectives and Identify and Evaluate Technologies 7-24

7.7.1.1 Develop Remedial Action Objectives andIdentify and Evaluate Technologies 7-24

7.7.1.2 Develop General Response Actions 7-24

7.7.1.3 Identify and Evaluate Suitable Technologies 7-25

7.7.1.4 Technology Screening 7-25

7.7.2 ERM TASK 26 Assemble Alternatives and Initial Screening 7-25

7.7.2.1 Assemble Alternatives 7-25

7.7.2.2 Initial Alternative Screening 7-26

7.7.3 ERM TASK 27 Detailed Analysis of Remedial Alternatives .. 7-27

7.7.4 ERM TASKS 28-29 Feasibility Study Report 7-27

8.0 BASELINE PUBLIC HEALTH RISK ASSESSMENT8-1

9.0 SCHEDULE9-1

10.0 PROJECF MANAGEMENT10-1

10.1 STAFFING10-1

10.1.1 Coordinating Project Manager/PrincipalinCharge 10-2

10.1.2 Project Manager Remedial Investigation 10-2

10.1.3 Project Manager Ecological Risk Assessment 10-2

10.1.4 Project Manager Feasibility Study 10-2

10.1.5 Field Team Leader10-2

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10.1.6 Treatability Studies if needed 10-3

10.1.7 Community Relations Support 10-3

10.1.8 Radioactive Materials Specialists 10-3

10.1.9 Quality Assurance Manager 10-3

10.1.10 Health and Safety 10-3

10.1.11 Department of Energy DOE Contacts 10-3

10.2 MONTHLY STATUS REPORTS 10-4

10.3 SCOPE OF WORK MODIFICATIONS 10-4

11.0 REFERENCES 11-1

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Work Plan

LIST OF FIGURES

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Figure 2-1 Site Location Map 2-2

Figure 2-2 Site Map 2-3

Figure 2-3 Shpack Landfill Site Location 2-4

Figure 3-1 Plan View of Grid System for the Site Showing Numbered Locationsof Surface Soil Water and Silt Samples 3-10

Figure 3-2 Location of Drill Holes Monitoring Wells AOW and Shpack PotableWater Well SNOW 3-11

Figure 3-3 Location of Off-Site Soil Water and Silt Samples and BackgroundExternal Gamma Radiation Measurements 3-13

Figure 3-4 Interpretation of Ground Penetrating Radar Survey at Norton/Attlboro MA Dumpsite 3-15

Figure 3-5 Plot of Detected Levels of 12-Trans-Dichloroethylene 3-21

Figure 3-6 Plot of Detected Levels of Trichloroethylene 3-22

Figure 3-7 Areas of Contamination in Excess of Guidelines 3-27

Figure 4-1 Procedure for Identifying ARARs 4-2

Figure 4-2 General Procedure for Determining if Requirement is Applicable 4-4

Figure 4-3 General Procedures for Determining if Requirement is Relevant andAppropriate 45

Figure 6-1 DQO Three-State Process 6-2

Figure 6-2 Phased RI/FS Approach and the DQO Process 6-3

Figure 6-3 DQO Stage Elements 6-4

Figure 6-4 DQO Stage Elements6-5

Figure 6-5 Stage Elements Design Data Collection Program 6-6

Figure 7-1 Site Plan 73

Figure 7-2 Location of Surface Water and Sediment Samples 7-19

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LIST OF FIGURES Contd

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Figure 9-1 Flow Diagram of RI/FS Process 9-3

Figure 9-2 Shpack Landfill Overall RIIFS Project Schedule 9-4

Figure 9-3 Shpack Landfill Overall RIIFS Project Schedule 9-5

Figure 9-4 Scoping the RI/FS 9-6

Figure 9-5 Scoping the RIIFS 9-7

Figure 9-6 Initial Site Characterization Phase 1A Scope of Work 9-8

Figure 9-7 Initial Site Characterization Phase 1A Scope of Work 9-9

Figure 9-8 Phase lB Field Work Scope of Work 9-10

Figure 9-9 Phase lB Field Work Scope of Work 9-11

Figure 9-10 Post-Screening Field Investigation and FS Development Phase 9-13

Figure 9-11 Post-Screening Field Investigation and FS Development Phase 9-14

Figure 9-12 Additional RIIFS Drafts Reviews and Revisions 9-15

Figure 9-13 Additional RIIFS Drafts Reviews and Revisions 9-16

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LIST OF TABLES

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Table 3-1 All Results in pC/L 3-5

Table 3-2 Results of Ground-Water Sampling 1982 3-17

Table 3-3 Priority Pollutant Analyses of On-site Borehole Samples NonPriority and Tentatively Identified Organics 3-18

Table 3-4 Priority Pollutant Analyses of On-site Borehole Samples Metals. 3-19

Table 3-5 Priority Pollutant Analyses of On-site Borehole Samples Organics 3-20

Table 3-6 Results of Sampling Wehran Engineering Corp 1987 3-30

Table 3-7 Results of March 30 and April 1987 Residential Water SupplySampling 3-31

Table 3-8 Results of July 16 1987 Residential Water Supply Sampling 3-33

Table 3-9 Results of October 15 1987 Residential Water Supply Sampling 3-34

Table 4-1 Selected Location-Specific Potential Applicable or Relevant and

Appropriate Requirements 4-7

Table 4-2 Selected Chemical-Specific Potential Applicable or Relevant andAppropriate Requirements 4-1

Table 4-3 Selected Action-Specific Potential Applicable or Relevant and

Appropriate Requirements 4-23

Table 4-4 Other Federal and State Criteria Advisories and Guidance to be

Considered 4-61

Table 4-5 Additional Potential ARARs for Radiological Wastes 4-68

Table 5-1 Remedial Action Objectives Response Actions and Technologies 5-2

Table 6-1 Summary of Analytical Levels Appropriate to Data Uses 6-7

Table 6-2 Appropriate Analytical Levels By Data Use 6-8

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SECflON 1.0

JNflODUC11ON

1.1 PURPOSE OF RIIFS

The overall purpose of the remedial investigation is to develop comprehensive data

base to interpret the new data sufficiently to determine potential ecological and

public health risks associated with or resulting from the contamination and to

facilitate selection of an appropriate remedial program if necessary All field

activities are designed to be implemented in accordance with the National

Contingency Plan NCP The data to be collected include air soil sediment and

water quality analyses hydrogeological parameters and information regarding

geological conditions These data will be analyzed to develop conceptual models for

the

hydrogeological setting and ground-water flow conditions

exposure pathways

distribution of chemical contaminants in soil and ground water and

migration dynamics associated with the distribution of contaminants

1.2 PURPOSE OF PHASE 1A INITIAL SITE CHARACrERIZArION WORK PLAN

The intent of the Phase la Initial Site Characterization Work Plan the work planis to define the RIIFS program and its rationale by task as designed by ERM to

address the data needs at the Shpack site This manual attempts to

summarize existing data collected at the site

define the likely past site activities

identify ARARs on preliminary basis

identify data requirements for potential remedial actions

define data needs

define data quality objectives

discuss the rationale for the Phase la field investigation

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discuss the conceptual rationale for conducting the FS

define the project schedule and

define the project staff and respective responsibilities

ERMs tasks parallel the RI/FS structure suggested in the EPAs guidance manual for

conducting RIIFS investigations ERMs anticipated tasks are listed below

Task Task Title

Review existing data

Develop site plans

Develop work plansMobilize personnel and equipment to site

Collect ecological data

Complete health and safety testing and air monitoringSample existing on-site wells

Perform geophysical investigations

Complete soil gas survey10 Excavate test pits

11 Install micro-wells12 Install ground-water monitoring wells13 Sample ground and surface water and stream and wetlands sediment14 Update site survey15 Perform ecological risk assessment16 Prepare initial site characterization report

17 Prepare Phase lb work plan18 Mobilize to site

19 Install monitoring wells

20 Sample ground and surface water21 Survey site

22 Collect additional risk assessment samples23 Prepare RI report

24 Complete early focused FS25 Develop cleanup activities and technologies26 Assemble alternatives and initial screening27 Perform detailed analysis of remedial alternatives28 Prepare FS report

29 Revise RIIFS report

Based on data collected during the Phase la investigation remaining data gaps will

be identified and addressed as part of Phase lb This may required tasks in addition to

the ones listed

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SECTION 2.0

SITE BACKGROUND AND SETFING

2.1 SITE LOCATION

The Shpack site is located in southeastern Massachusetts in the Towns of Norton and

Attleboro Figure 2-1 The site covers an area of approximately 3.2 hectares

acres Of this area 2.2 hectares 5.5 acres lie within the Town of Norton The

Shpack family formerly owned and operated this site and sold it to the Town of Norton

in 1981 The remaining hectare 2.5 acres lies within the Attleboro corporate

limits and Attleboro Landfill Inc AL is the current owner Figure 2-2 is site

map for the Shpack landfill

2.2 SiTE LAYOUT

As shown in Figure 2-3 Union Road Norton side and Peckham Street Attleboro

side form the northwest boundary of the Shpack site The AL landfill abuts the site

and forms the southwest boundary Chartley swamp forms the southeast border

Wooded undeveloped land forms the northeast border beyond which lays Chartley

swamp Finally the former Shpack residence now the McGinn residence lies

beyond the northern corner of the site adjacent to Union Road Additional residences

lay north and east of the site The Site Management Plan SMP contains figure

indicating the owners of each adjacent and nearby property

2.3 PHYSICAL SE1TING

The Shpack site is now closed and the area is undeveloped Three sets of high-voltage

power transmission lines owned by the New England Power Company traverse the

site The surface presently contains metal scrap brick concrete blocks metal drums

plastics and other miscellaneous debris ORNL 1981

2.3.1 Current Land Use

The areas to the northwest across Union Road and Peckham Street southeast and

northeast are undeveloped except for the power lines mentioned above The McGinn

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Figure 2-3 Shpack Landfill Site Location

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SCALE MILE

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family currently occupies the former Shpack residence to the north of the site The

AL landfill to the southwest is currently operating as private sanitary landfill

2.3.2 Phvsiography

The Shpack site is essentially flat with only minor depressions and knolls An

elongated landlocked wetland area lies immediately within the northeastern fenced

border At least two other depressions also contain standing water Other lower lying

areas support wetland vegetation seasonally The area to the east and north of the

site are low lying wetland areas Waste materials deposited in former wetland areas

entirely compose the ALL landfill to the south that rises approximately 200 feet above

the surrounding ground surface The land west of the site is generally flat beyond

which lays Chartley brook The wetland east of the site drains generally north then

west into Chartley pond

2.3.3 Geology

The following description has been extracted from ORNL 1981 and NUS 1985

The Shpack landfill site is located in the northwestern portion of the Narragansett

Basin This 2500 km2 960 mi2 topographic and structural depression contains

terrigenous clastic sediments of Late Pennsylvanian Age 200 to 275 million years

old Directly underlying the Shpack site the bedrock unit is the Rhode Island

Formation It Consists of feldspathic sandstone shale siltstone pebble to boulder

conglomerate and locally coal Deposition of the Rhode Island Formation was

predominantly in fluvial environment possibly associated with active alluvial fans

from ORNL 1981 after Skehan et al 1979

Six structural domains divide the Narragansett Basin The Shpack site is located in

the Taunton Domain which is characterized by series of large scale east-northeast

striking folds The bedrock structures have had some influence on the present

topography however Pleistocene glacial deposits overlying the bedrock have had

the dominant surficial influence from ORNL 1981 after Skehan et al 1979

Glacial units include unstratified deposits of till consisting of poorly sorted silt sand

angular to rounded pebbles cobbles and boulders These units form mantle on the

bedrock surface Stratified glacial units include beds and lenses of outwash or other

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glaciofluvial deposits which grade into glaciolacustrine deposits These deposits

consist of sandy gravel sand and fine sand silt and clay from ORNL 1981 after

Skehan et al 1979

At the Shpack property till deposits form the slightly raised ground at the Shpack

residence Till extends northwestward across Union Road to Chartley Pond and forms

finger of high ground extending southward into the large swamp south of Union

Road These unstratified deposits grade into stratified deposits along the margins of

the high ground and give way to glaciolacustrine deposits that underlie the swampareas west and south of the Shpack residence Unconsolidated deposits overlying

bedrock at the Shpack landfill are approximately 6.1 to 7.6 20 to 25 feet thick

from ORNL 1981 after Williams et al 1973

Many tills are considered to be relatively impermeable hOwever those underlying

the Shpack site have low blow counts and higher granular material content

suggesting less compact till with more moderate permeability NUS 1985

Organic deposits peat overlie unconsolidated glacial deposits in the swamp areas of

the region Depth of the peat ranges from 1.5 to 9.1 to 30 feet depending on the

age and depth of the swamp from ORNL 1981 after Stone 1980

Well logs from on-site monitoring well installations indicate that bedrock depthbeneath the site varies from approximately 4.5 15 feet in the northwest to about

9.1 30 feet in the southwest Approximately 6.1 to 10.7 20 to 35 feet of

stratified glaciofluvial sand and gravel were also identified beneath the Shpack

landfill Above this unit lies an approximately 60 cm feet thick layer of peat The

peat layer apparently thins to the northeast towards DOE-i and thickens to the south

It is not clear based on current data whether this peat layer is continuous NUS1985

2.3.4 Hdrogeology

The observed geology of the site indicates that the overburden and bedrock units are

hydrologically connected therefore they comprise one aquifer unit of differing

properties

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The water table at the site is very shallow and is generally within five feet of ground

level The hydraulic gradient at the site is extremely flat with no discernible

preferential flow direction ORNL 1981 suggested that flow may be radially out

from the center of the site

2.3.5 Surface Hydrology

The ground-water and surface water systems are connected at this site since the

wetlands and surface water bodies at and adjacent to the site are surface expressions

of the water table

Surface drainage at the site does not have preferential flow direction since the

surface of the landfill is uneven This likely results in infiltration through the

landfill into the shallow ground-water table

In the adjacent stream to the east of the site surface water flow is towards the north

in the direction of Chartley Pond

2.3.6 Ecology

The wetland areas directly adjacent to the Shpack site are the environments which

may be mostly directly impacted by site contamination NUS 1985 The site is

covered with early successional vegetation and contains variety of resident and

migratory birds small mammals and insects No endangered species are known to

exist at the site NUS 1985

2.3.7 Site Contaminants

The contaminants of primary concern at the site include radionuclide.s volatile

organic compounds VOCs and heavy metals The key radionuclide constituents are

235j 238U and 226Ra The VOCs most often detected are trans-12-dichloroethene

tDCE and trichloroethene TCE Some of the heavy metals that have been found at

the site include zinc copper chromium lead nickel iron and manganese

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SECFION 3.0

INITIAL SITE EVALUATION

3.1 SITE HISTORY

3.1.1 Ooerating History

The Shpack landfill was private landfill which began operations in 1946 The

landfill received both industrial and domestic wastes with the major use of the

landfill occurring between 1951 and 1965 after which the landfill was closed by

court order Bechtel 1984 The landfill was developed on what was originally

swamp by the progressive filling of portion of the swamp with wastes starting

along Union Road and Peckham Street and proceeding southeast to the landfills

present terminus at Chartley Swamp ORNL 1981 NCC 1980 reported that waste

materials were burned at the site

3.1.2 Previous Investigations

This section summarizes the information presented in various reports known to date

to be completed at the site In all cases the conclusions presented are those

contained in the respective reports or correspondence and are not necessarily those

of ERM

U.S.N.R.C 1979 Norton and Attleboro Surveys Radioactive Material inUncontrolled Locations February 12 1979

As result of phone call from citizen of the Town of Attleboro on September 221978 the Nuclear Regulatory Commission USNRC conducted preliminary and more

comprehensive radiological surveys of the Shpack site in October and November 1978

USNRC 1979 Three types of equipment were used during the surveys including

Eberline Ratemeter Geiger-Muller SN-5515 Model E-120 Probe Endwindow G-M tube Background level to 0.03 mR/hr

Eberline Pulse Ratemeter SN-2662 Model PRM-5-3 Probe 2x2 SodiumIodide Detector Background level 450 cpm and

Ludlum Scintillation Analyzer SN-4440 Model 16 Probe 1xl Sodium IodideDetector Background level 2000 cpm

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The initial survey was conducted by the USNRC Town of Norton Conservation

Commission NCC and the Massachusetts Department of Public Health Bureau of

Radiation Control Programs Three areas of soil contamination of undefined size

were detected at between 4.0 and 5.0 milliRems/hour mR/hr up to four inches deepand more comprehensive survey was performed by the same parties

The latter study indicated that extensive areas up to 50000 square feet contained

radioactively contaminated soils including 235U 238U and 226Ra Radiation

readings of between 0.5 and 1.0 mR/hr at three feet below ground level and isolated

areas of up to 20 mR/hr at contact were detected USNRC 1979 During soil sampling

the USNRC reported encountering containers possibly drums at up to two feet below

ground level Ground water from the Shpack residence and surface water from

small pond bordering the Shpack and Attleboro landfills were also sampled howeverthese results were not available to ERM

EGG 1979 Radiological Survey of the Shpack Site October 1979

As follow-up to the initial ground site surveys the U.S Department of Energy DOEauthorized the completion of an aerial radiological survey of the Shpack site The

survey was completed in August 1979 by measuring gamma rays with an array of 12.7

cm by 5.1 cm sodium iodide Na crystals The survey was performed by airplane at

an altitude of 45 meters 41 yards along grid lines 60 meters 55 yards apart

DOEs contractor concluded that the gamma ray levels detected during the aerial

survey were consistent with natural background levels for that area No evidence of

any man-made anomalies were detectable EGG 1979

Norton Conservation Commission 1980 Shpack Site March 17 1980

The Norton Conservation Commission NCC compiled local data including

property deed and easement information

zoning classifications

aerial photograph analyses

geology soil and ground-water information and

information from local citizens

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Filling at the Shpack site apparently began in 1951 This date was later suggested as

1946 in ORNL 1981 in the deeper portion of the former swamp adjacent to Union

Street The report suggests that liquids and powders such as alkalines weak acids

chemicals oils or slurries may have been deposited initially in the former swamp on

the Shpack site NCC 1980 Later fill material potentially included ordinary fills

debris building debris junk and tins and lot of cleaning slurries fine

grinding/polishing materials sweepings sludges of both tanks and lagoons The byproduct was dumped mostly via barrels NCC 1980

The NCC also stated that materials from nearby chemical facility were deposited in

200 foot by 150 foot area on the Norton side of the dump along the New England Power

Company Transmission line service road These wastes may have included

warehouse debris warehouse chemicals heated and unheated PVC liquids and

powder in containers and other unknowns NCC 1980 These wastes were thought

to be separate from the radioactive materials in the middle of the landfill Finally

the report stated that slurry and sludge-like materials were deposited behind the

Shpack house at the edge of the swamp NCC 1980

Shearer D.R 1980 Report on Results of Analyses of Test Well Water atAttleboro Landfill Site March 10 1980

In addition to the studies being completed at the Shpack site investigations were also

ongoing at the adjacent Attleboro Landfill site Shearer 1980 evaluated the results

of radiological testing gross alpha and beta analysis and gamma spectrographic

analysis of 10 ground-water samples from the Attleboro landfill collected on

January 24 1980 This report was submitted as part of the GHR 1980 report The

methodology for sampling was not documented

Shearer discovered that the results varied significantly for unfiltered and filtered

samples indicating that the radioactivity in the samples originated predominantly in

the sediment The analytical results indicated the presence of Potassium-40 Radon-

222 and Thorium-228 with maximum readings of 16400 pCi/I 900 pCi/I and 520

pCi/l respectively All of the detected constituents are purportedly naturally

occurring radionuclides in this area The maximum gross beta concentrations were

360 pCi/l for unfiltered samples and 72 pCifl for filtered samples The maximum gross

alpha concentrations were 250 pCi/I for unfiltered samples and 52 pCi/i for filtered

samples Shearer concluded that

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these radionuclides were not likely due to the disposal of radioactive wastesbut rather from naturally occurring sources and

though the gross alpha and beta activity exceeded the EPA investigatoryguidelines for potable water supplies there was no immediate threat sincethis water was not being consumed and local wells including the Shpackwell were within appropriate guidelines

Shearer based his conclusions on the data from Interex Corporation presented in

Table 3-1

GHR Engineering Corporation 1980 Report Evaluation of AttleboroLandfill Monitoring March 25 1980

Split samples from the ten wells described above were delivered to the Massachusetts

DEQE now the DEP Lawrence Experiment Station LES for radiological analysis

Table 3-1 The results of the LES were generally higher than those reported by

Interex Corporation This variation was not explained however it may be due to the

relative sediment content of the samples as described by Shearer 1980

These 10 monitoring wells were also tested for volatile and semi-volatile organic

compounds pesticides polychiorinated biphenyls trace metals minerals nutrients

and oxygen demand as part of the same investigatory effort The methodology for

sample acquisition was not documented Soil samples were also collected from an

older portion of the Attleboro landfill Finally surface and well water samples were

collected and analyzed

GHR 1980 concluded that there is no evidence that water supply or stream is

affected or endangered by the contaminated water that is confined to the AL landfill

and therefore there is no imminent health hazard Highlights of this sampling

effort are as follows

no pesticides or semi-volatiles were detected in any of the monitoringwells

dichiorodifluoromethane was detected at 36 ig/l in well ALl-b at theShpack site as well as trace levels of methylene chloride

trace levels of methylene chloride trans-12-dichloroethene tDCE andtrichioroethene TCE were detected in well ALI-9 at the Shpack site

trace levels of methylene chloride were detected in well ALI-8 at the

Shpack site


215-02-02EPA 04490

Gross GrossBeta Alpha Potassium Radon Thorium

Location Particle Particle -40 -222 -228

ALl-i 614 539 30030

ALI-2 36020 25050 16400600 90070 52050

729 5214

ALI-3 423 225 33030

ALI-4 844 326 34040

14001

ALI-5 346 30j10 14030

ALI-6 1579 17020 600200 24040 4030385 226

ALl-i 554 226 270140 10030 3020

1220

ALI-8 464 579 1600200 58050 13030

ALI-9 162 102 21040

ALI-lO 584 266 230200 13050 4020

234 73

Original Interex Corporation alpha and beta results are from unfiltered turbidsamples Alpha and beta results reported in parentheses are from clearer samples wherethe sediment was allowed to settle Alpha and beta results reported in brackets are fromthe DEPs Lawrence Experiment Station All gamma results Potassium Radon Thoriumare for filtered samples as reported by Interex Corporation

Work Plan

revised 1/21/9

215-02-02

3-5

EPA 04491

Thq

Table 3-1

All results in pCi/l

Note

total volatiles ranged from trace levels up to 863 ugh in the seven wells at

the AL landfill

copper was detected at maximum of 18 pg/i in ALI-9 and -10 and zinc wasdetected at maximum of 820 pg/i in ALI-9

PCB-1260 was detected at 0.11 0.06 2.13 0.37 and 0.49 ugh in wells ALI-6-8 -9 and -10 respectively and

metal plating wastes were detected on the northeast corner of the AL site

southeast of Shpack

In addition to the monitoring well samples samples were collected for radiological

analysis from the dug well at the Shpack residence several times as listed below

Results of Sampling of the Shpack Residence Dug Well

Date Gross Alpha pCi/fl Gross Beta DCiID Samole type

11/9/78 0.80.2 ground water

6/1/79 3.80.3 filtered ground water

6/1/79 0.040.01 sediment from filtered

ground water

6/14/79 1.20.2 93 ground water

3/25/80 ground water

reported in White 1980

The well construction diagrams for the ALl wells indicate that five foot section of

0.060 inch slot PVC screen was used in wells ALI-8 -9 and -10 at the Shpack site All

three wells are screened in unconsolidated deposits labelled brown hardpan to

depths of between 16 and 26 feet which places the top of the screens at 10 to 20 feet

below the water table

White R.A 1980 Memo re Shpack Site Visit from DEP Solid WasteDivision to Jeffrey Gould Southeast Region Water PollutionControl Engineer March 31 1980

This memo outlined the activities of March 25 1980 when the DEP collected eight

sediment samples from across the site and three surface water samples The sampling

methodology was not documented The DEP observed that the area under the power

Work Plan 3-6revised 1/21/91 Th

215-02-02

EPA 04492

lines and areas in close proximity to this area contained scrap rubber hoses burnt

material few 55 gallon drums and various areas of soil having colors and

consistencies of black adhesive tar substance oil soaked soil white powdery

substances bright orange paint-like substance and bright yellow-orange

stratified soil The area directly behind the Shpack house contained approximately

300 to 400 55-gallon drums in various states of decay 99% of the drums were emptybroken ceramic pieces under which the soil appeared oil contaminated several areas

of hard tar cover material and an area of soil having dull green color and having

sludge consistency White 1980 White 1980 did not specify the locations for

these observations

The results of sediment analysis from the DEPs LES laboratory indicated heavy metals

concentrations with maximum readings as follows

zinc at 56497 mg/kg

copper at 36170 mg/kg

chromium at 3060 mg/kg

lead at 3055 mg/kg and

nickel at 301318 mg/kg

One grease-like sample was determined to be ignitable

Zinc was detected in the surface water samples collected from the fire pond at ALlthe inlet to Chartley pond at Union Street and at the south culvert at the rear of the

site near the access road to ALl at up to 0.8 mg/l Lead was also detected at the fire

pond at 0.05 mg/I All other metals were non-detectable The only volatile organic

detected was 4.6 ug/l of LDCE at the fire pond on the AL site

DEP 1980 Letter re Monitoring at ALl and Shpack from DEP SoutheastRegion to Mayor G..J Keane of Attleboro December 1980

This correspondence summarized the monitoring activities at the AL and Shpack

landfills during 1980 In summary the DEP concluded that review of the results

indicate that private or public water supplies that could be directly or even remotely

affected presently meet drinking water standards Analyses of downstream surface

waters show no sign of significant deterioration and expectantly the sediment

samples collected from excavations on the Shpack site where chemical wastes .. were

Work Plan 3-7revised 1/21/91 Th215-02-02

EPA 04493

said to be disposed of were high in heavy metals and volatile organics Even

knowing this it is significant to note that all of the monitoring wells including ALl-

and ALI-8 which are nearest the Shpack site did not have high concentrations of

metals possibly as result of attenuation by soil adsorption DEP 1980

Oak Ridge National Laboratory ORNL 1981 Radiological Survey of the

Shpack Landfill Norton Massachusetts December 1981

This report documents the activities of ORNL in 1981 which were designed as follow-

up to previous USNRC activities The ORNL investigation included ORNL 1981

measurement of beta-gamma dose rates cm 0.4 in above ground surface

at grid centers on 50 by 50 grid and at off-site points using Geiger-Muller G-M survey meter

measurement of external gamma radiation levels ft and cm inabove ground surface at grid centers on 50 by 50 grid and at off-site

points using portable gamma-ray scintillation Sodium iodide Na crystal

survey meters

collection of surface soil samples between ground surface and cm in at

alternate grid centers 100 foot centers and some in-between samples andanalysis by GeLi detector mass spectrometry and neutron activation

methods

advancement of soil borings based on ground penetrating radar results toavoid intersecting buried objects to the water table and borehole analysisby Na scintillation probe

collection of split spoon soil samples at the interval of highest radioactivityas identified in the previous step and analysis by GeLi detector massspectrometry and neutron activation methods and

collection of ground-water and surface water samples from the boreholesexisting AL monitoring wells Shpack residence well swamp and various

drainageways and analysis by radiochemical techniques isotope dilution-

mass spectrometry fluorometry and neutron activation methods

ORNL 1981 did not perform any chemical analyses other than those for

radionuclides

Surface Scanning

ORNL personnel determined that background external gamma radiation levels ranged

between 4.0 and 9.0 pR/hr with an average of 7.0 pR/hr Soil samples collected at the

same location showed an average of 0.64 pCi of 226Ra and 0.66 pCi of 238U per gram of

Work Plan 3-8

revised 1/21/91 mq215-02-02 O44

soil Background beta-gamma dose rates typically averaged 0.02 mrad/hr ORNL1981 The average readings at grid centers fell generally within the range of

natural background readings however the maximum observed external gammaradiation level at 1.0 ft from the ground was 365 iiR/hr and the corresponding

gamma radiation level at the surface was 1450 iiR/hr The maximum observed beta-

gamma dose rate at 1.0 cm 0.4 in was 30 mrad/hr ORNL 1981 Figure 3-1 shows the

location of surface scanning sampling points

Surface Soil Sampling

Concentrations of 226Ra in systematic surface soil samples ranged from to 11 pCi/g

and only eight of 72 samples exceeded background levels pCilg Concentrations

up to 47000 pCi of 226Ra per gram of soil were observed in biased samples ORNL1981

Concentrations of 238U in systematic surface soil samples ranged from to 140 pCi/g

and the highest biased sample had 96300 pCi/g Concentrations of 235U in systematic

soil samples ranged from 0.03 to 51 pCi/g and the highest sample collected between

the standard grid had 7080 pCi/g ORNL 1981

Dilution mass spectrometry on 63 of 91 surface soil samples showed that five were

depleted 21 were natural and 37 were enriched up to 76% 235U Isotopic abundance

determinations were performed on sixteen samples all of which showed 236U

implying that the source is reprocessed reactor fuel ORNL 1981 Figure 3-1 shows

the location of surface soil sampling points

Subsurface Soil Sampling

In split spoon samples the maximum observed concentrations of 226Ra 238U and

were 4650 pCi/g 106000 pCi/g and 5640 pCi/g respectively Of the 70% of

subsurface samples analyzed by isotopic abundance methods 64% showed some

degree of enrichment and enrichments up to 69% 235U were observed ORNL 1981

Figure 3-2 shows the locations of borehole sampling points

During borehole logging any sample which had greater than 1000 counts per

minute cpm on the shielded scintillator or containing more than pCi/g of either

226Ra and/or was considered contaminated Because of the difficulty of detecting

Work Plan 3-9revised 1/21/91 mq215-02-02

EPA 04495Qro

ORNL-DWG 81-20502

NW6

SNWS

__

WS/

SNW2

I\ ASNWSZ

//

NASNW1\SNW$I

/49/.59N/

SNW

$2

SNWSI2NN/ A$4

55/

B351

/\ Aspjw3TWII

/N

.6 .0197N/38/l7/

.66/

N/

5Nw8 tN

.7

// X27/

.13

4/ //o27i.B3Ô

7N/ SNW9

SNW5942.//// 75

SNWy

SWAMP

20

.18///

//.69.56/

.54/N

--

-J/1.0 ./

SNWIOstwsio

tTLfl L.OLLOIASED SAMPLES

SYSTEMATIC SURFACE SAMPLES

CHARTItY

WATER

AND SEDIMENT SAMPLES

SWAMP

Figure

3-1 Plan view

of grid system

for

the site showing numbered locations

of surface soil

water

and silt samples

CD

.0

ORNL-DWG 81-20501

tJ3

-S

LII

Location

of drill holes monitiring wells

AOW

and Shpack potable water well SNOWFigure

3-2

uranium with the shielded scintillator any in sample may have gone undetected

if Ra was not also present ORNL 1981

Ground-Water Sampling

Ground-water samples collected from the soil boreholes all showed concentrations of

radionuclides below the respective concentration guidelines for 230Th 210Pb The

maximum concentrations of 238U and 235U were 4400 and 2400 pCi/I respectively

Three samples exceeded the concentration guidelines for 226Ra with maximum

concentration detected at 1400 pCi/I Samples collected from the Shpack residence

dug well and monitoring wells ALI-8 -9 and -10 were below the concentration

guidelines for all radioactive constituents ORNL 1981 Figure 3-2 shows the

location of boreholes monitoring wells and the Shpack residence well

Surface Water Sampling

Surface water samples collected from the on-site swamp along the northeast side of

the site and from the adjacent Chartley swamp to the east Figure 3-1 showed levels

below the applicable concentration guidelines

Likewise surface water samples collected at the outlet of Chartley swamp into

Chartley pond at the inlet to Chartley pond from the Barrowsville Pond tributary

and at the outlet from Chartley pond into Chartley brook Figure 3-3 showed levels

below applicable concentration guidelines ORNL 1981

Swamp and Stream Sediment Sampling

All of the sediment samples collected from the on-site swamp and from the adjacent

Chartley swamp showed concentrations of 238U and 235U above natural background

levels In addition several samples were in excess of the background concentration

for 226Ra Isotopic abundance analyses indicated up to 6% enrichment of 235U

These data indicate that the radioactive contamination in the dump site has migrated

into and spread across the landlocked portion of the swamp and into the edge of

Chartley swamp Figure 3-1 shows the location of on-site swamp and stream sediment

sampling points ORNL 1981

Work Plan 3-12revised 1/21/91 Th215-02-02 EPA 04498

ORNL-DWG 81-11201

SOIL SAMPLES

WATER AND SEOtMENT SAMPI..ES

Figure 3-3 Locations of off-site soil water and silt samples andbackground external gamma radiation measurements

Work Plan

revised 1/21/91

215 -02-02

3-13ThQ

SN7.sse

0.5

SCALE MILE

EPA 04499

Stream sediment samples collected at the off-site surface water sampling points

described above Figure 3-3 all showed concentrations at or near background levels

ORNL 1981

Ground Penetrating Radar GPR Investigation

Included in the ORNL 1981 investigation report was report by Geo-Centers Inc

which discussed the results of the GPR study at the site preceding the soil boring

program 300 MHz antenna was used which can penetrate 10 to 15 feet below

ground surface and resolve objects as small as one foot ORNL 1981 As shown on

Figure 3-4 buried metallic and other reflective objects were detected below the

surface of the landfill The following ORNL borehole program was specifically

designed to avoid intersecting these objects No subsurface intrusive

characterization was performed on the areas where buried objects were suspected

Ecology and Environment 1982 Preliminary Assessment Form April1982

The preliminary assessment PA was completed April 1982 by the EPAs Region

FIT contractor EE listed the site as having low apparent seriousness relative to

the volatiles and metals and an unknown seriousness relative to the radioactive

constituents The PA concluded that off-site migration was unlikely due to the

underlying peats and clays

Bechtel National Inc 1982 Project Report on Fence Construction atthe Former Shpack Landfill Norton Massachusetts June 1982

This report summarized the fence construction activities at Shpack An eight-foot

high barbed wire fence was erected between October 13 1981 and November 1981

During the fence construction three hot particles it is unclear what these

particles were were identified along the fence line at the western corner of the site

These particles measured between 13000 and 23000 counts per minute cpm using

by Na detector These were removed from the post holes placed in tin cans and

buried at the site In addition another area of radioactivity at the western corner

had detections of between 20000 and 90000 cpm versus background of 4500 cpmThis material was left in place Bechtel 1982

Work Plan 3-14revised 1/21/91 Thq

215-02-02EPA 04500

Figure 3-4

to. to .o.s.oi% S00_ Ttofl 1. ..o oo

Pt..o o..r ..t .o.. So...

ho Po.oo..Ato.o.o0qCT$

re Sio

Work Plan

revised 1/21/9

215-02-02

3-15

EPA 04501 TM

Ecology and Environment 1982 Chemical Contamination at the ShpackLandfill Norton/A ttleboro Massachusetts December 1982

This report was commissioned by the EPA to document chemical quality at the site to

parallel DOEs radiological investigations at the site In the site history section EEdocuments the results of sampling by the DEP on November 1980 when three

ground-water samples were collected from very shallow boreholes The results

indicated the presence of tDCE at 32000 pg/I TCE at 13000 pg/i and tetrachloroethene

PCE at 19000 pg/i The locations of these samples are unknown other than that

they were collected at the Shpack site

EE collected ground-water samples from the DOE wells at the Shpack site using

stainless steel bailer These samples were delivered for priority pollutant analysis

The results are summarized in Table 3-2 As shown LDCE was detected at maximum of

665 g/l and vinyl chloride was detected at maximum of 26 g/l Iron and

manganese concentrations had maximum readings of 60400 and 12400 pg/i

respectively

In addition EE collected ground-water samples from DOEs interior boreholes for

priority pollutant analysis using stainless steel bailer The results are summarized

in Tables 3-3 through 3-5 As shown tDCE and TCE appear to be the predominant

volatile organics at the site with up to 65000 pg/I of tDCE and up to 72000 pg/I of TCEFigures 3-5 and 3-6 show site maps with tDCE and TCE concentrations respectively

Camp Dresser McKee Inc 1983 Preliminary Draft Remedial Action

Master Plan Shpack Landfill Site Norton/A ttleboro MA February1983

This report included general summary of the site history and of sampling results

which have already been discussed above No new sampling results were presented

in this report The generation of preliminary remedial designs was halted by the

EPA in December 1982 when the Shpack site was not listed as one of the top 418

Superfund sites in the country

Massachusetts Department of En vironmental Quality Engineering 1984Hazardous Waste Site Fact Sheet Shpack Landfill Norton/A ttleboroMA February 1984

This summary did not present any new data


215-02-02 EPA 04502

Table 3-2

Results of Ground-Water Sampling EE 1982

Well Designation all concentrations__in jg/1

Contaminant DOE-i DOE-2 DOE-3 DOE-4 DOE-5 DOE-6 DOE-i packwell

Aluminum 3950 570 380 180 4120

Chromium 15 15

Barium 1290 140 44 125 79 324 97 130

Copper nd nd nd nd nd nd nd 185

Iron 610 23600 1960 29800 3640 60400 2250 6400

Nickel nd 40 39 50 32 31 146 48

Manganese 760 1920 4300 3450 610 12400 729 460

Zinc 128 63 134 128 75 28 104 524

Boron nd nd nd nd nd 140 nd nd

Arsenic nd

Antimony nd nd nd 21 nd 11 nd nd

Mercury nd nd nd nd nd nd 0.3

Tin nd nd nd 25 11 62 15 13

Cadmium nd nd 15 nd nd nd nd nd

Lead 132 12 51 63 12 194

bis2-ethylhexyl 12 nd nd nd nd nd 136 ndphthalate

trans-12- nd nd nd 665 nd nd nd nddichioroethene

methylene nd nd nd nd nd 13 nd ndchloride

vinyl chloride nd nd nd 26 nd nd nd nd

Work Plan

revised 1/21/9

215-02-02

3-17ThQ

EPA 04503

iLyzed

September

1982

by

Head

Compuchem

Not

detected

pç

TABLE

3-3

PriorityPollutant

Analyses

of

Onsite

Borehole

Samples

Concentrations

in

ppb

Nonpriority

and

Tentatively

Identified

Organics

NUMBER

17E

2E

49R

49R

38E

27E

22E

63R

lIE

Dupi

24E

19E

40R

43E

35R

droxylMethyl

Pentanone

120

170

130

NA

51

ND

ND

thylIleptanol

ND

ND

25

NA

ND

ND

ND

ND

ND

37

ND

ND

13

42

ND

heptatriene

ND

49

ND

NA

ND

ND

ND

ND

ND

ND

MD

46

ND

ND

ND

methyl

Octane

Ml

ND

NA

Ni

MD

ND

ND

ND

ND

ND

ND

ND

ND

ND

clohexane

ND

ND

ND

NA

ND

ND

ND

ND

MD

ND

NI

ND

opene

ND

ND

11

NA

NI

ND ND

ND

2400

ND

ND

ND

2800

ND

ND

ND

etone

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

thyl

Benzene

ND

ND

ND

NA

ND

ND

ND

MD

ND

ND

100

ND

100

chlorotrjflUoroethane

ND

ND

86

NA

ND

ND

ND

ND

ND

16

ND

ND

ND

ND

ichlorotrjfluoroethane

ND

ND

790

NA

1300

MD

ND ND

ND ND

ND

ND

ND

ND

MD

ND

ND

trahydrofuran

71

ND

ND

NA

ND

ND

ND

ND

ND

ND

MD

ND

ND

NI

xanone

ND

NI

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

clohexanone

ND

ND

NA

ND

ND

ND

ND

160

ND

9000

140

ichloroethylene

1100

MD

3200

NA

140

ND 64

ND ND

ND160

ND

ND

ND

ND

ND

ND

ND

thylDichiorobutane

ND

22

MD

NA

ND

ND

NI

ND

MD

ND

22

ND

1500

NI

oxane

ND

59

ND

NA

29

ND

18

12

ND

ND

ND

ND

ND

ND

ND

hyl

Ilexanol

MD

18

ND

NA

ND

ND

ND

ND

ND

ND

Ni

ND

trachioroethylene

ND

ND

ND

NA

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

meThyl

Benzene

ND

ND

ND

NA

ND

ND

ND

ND ND

ND

ND

ND

ND

NE

110

ND

xanoic

Acid

ND

ND

ND

ND

MD

ND

ND

ND

ND

thyl

Pentanone

methyl

Benzenibutanoic

Acid

imethyllieptadecane

loromethyl

Butene

tramethyl

Ileptadecane

ND ND ND ND ND

ND ND ND 24 ND

ND ND ND ND ND

NA ND NA NA NA NA

ND ND Ni ND ND

ND ND ND ND ND230

ND ND ND 34 ND ND

ND ND ND ND ND ND

ND ND ND ND ND

ND ND ND ND ND

ND ND ND ND ND

ND 14 ND ND ND

ND ND ND ND ND

58 ND ND NI ND

ND

100

ND ND ND

methyl

Formamide

ND

ND

280

NA

ND

ND

ND

ND

ND

ND

ND

ND

tat

Tentative

80%

Purity

580

38

220

NA

3185

19780

437

ND ND

ND 56

ND116

ND 10

ND ND

ND 12

ND206

NJ 18

EPA

04504

TABLE

3-4

PriorityPollutant

Analyses

of

Onsite

Borehole

Samples

Concentrations

in

ppb

Metals

TAL

BOREHOLE

NUMBER

22E

63R

63R

lIE

24E

19E

40R

43E

35R

DupI

Dupi

ninum

10

.7100

14000

4200

1600

9800

760

rnium

45

61

94

47

81

51

ium

20

710

520

3200

3400

960

1700

yllium1

ND

17

.1

42

22

11

47

55

per

1350

1900

4000

700

4000

200

25900

10900

47700

24200

160000

36500

el

15

410

560

5590

780

2260

730

960

3460

20700

7950

4150

4990

10

3060

4180

2360

1520

6700

3750

on

100

ND

ND

ND

ND

ND

ND

.i

urn

50

ND

ND

ND

ND

NI

ND

ver

ND

14

13

tnic

48

69

39

27

93

55

imony

ND

ND

ND

ND

ND

ND

niurn2

ND

ND

ND

ND

NI

ND

11

iurn

ND

Ni

ND

ND

NT

ND

cury

0.2

ND

ND

ND

ND

NT

10

29

37

40

24

80

60

niurn

14

74

24

820

530

260

89

1040

57

lyzed

October

1982

by

Environmental

Consultants

Not

Detected

-S

nit

liE

2E

49R

49R

38E

27E

Blank

37900

1160

1200

16500

23000

11900

16200

23600

13300

ND

260

43

40

88

220

92

31

89

210

33

2500

660

570

2000

3500

1200

1300

3800

2300

85

ND

ND

10

15

10

ND

37

204

56

12

17

16

49

ND

1500

500

550

5650

650

2650

200

350

1050

ND

103500

2600

2300

22700

326000

28900

7800

51800

147000

ND

5170

180

170

4570

19700

430

130

2050

2590

ND

3990

1510

1510

11090

10560

1290

1910

3910

5370

ND

25600

800

830

13100

10200

1280

1470

3680

6350

ND

ND

ND

ND

100

200

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

NI

ND

ND

10

10

17

200

49

48

120

240

55

48

210

110

ND

ND

ND

ND

20

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

NI

ND

ND

ND

NI

ND

ND

ND

ND

ND

NI

ND

ND

ND

NI

ND

ND

ND

ND

ND

140

15

19

70

114

28

30

85

81

ND

63

197

72

134

22

34

ND

7400

49

67

1020

2560

820

65

400

1090

ND

EPA

04505

TABLE

3-5

PriorityPollutant

Analyses

of

Onsite

Borehole

Samples

Concentrations

in

ppb

Organics

ND

ND

NDND

ND

ND

NOND

ND

ND

ND

ND

ND

ND

ND

ND

ND ND ND ND ND ND ND ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

58

ND

ND

ND

ND

ND

5200

ND

ND

ND

ND

10

13

ND

73

ND

ND

1200

ND

ND

ND

ND

ND

ND

ND

ND

Ni

NI

ND

ND

.ND

NJ

28000

ND

ND740

ND

ND

ND

72000

ND

3800

ND

Volatile

Organics

10776

215

88861

75400

68400

164

17

1974

61

230

6549

21

104540

o-

RGANIC

COIPOtIND

17E

2E

49R

49R

38E

27E

22E

Dupi

BOREHOLE

NUMBER

63R

lIE

24E

19E

40R

43E

ND

ND

ND

ND

ND

ND

20

93

NI

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ranthene

2EthylilexylPhthalate

ButI

Phthalate

acnthracene

ob

luoranthene

sene

anthrene

1Trichioroethane

Dichioroethane

roethane

ro

form

Dichloroethylene

transDichloroethylene

ylcnc

Chloride

nch

loroe

thy

lene

hioroethylene

Chloride

ND

ND

ND

ND

ND

ND

ND

20

ND

ND

ND

ND

ND

NI

ND

ND

ND

ND

Nt

ND

ND

ND

ND

ND

35R

EE

Blank

58

NI

20

NI

ND

ND

40

ND

40

ND

22

ND

24

ND

54

ND

ene

NI

ND

ND

ND

ND

ND

ND

NI

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND ND

ND

ND

51

ND

10

ND

1100

29 ND

ND

ND

ND

ND

760

10

45

22

ND

ND

ND

NI

ND

ND

ND

40

ND

NI

ND

ND

54

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

18

ND

43

ND

ND

10000

15

65000

46000

39000

360

560

ND

ND

ND

170

ND

2400

12

ND

ND

ND

600

180

23000

30000

27000

150

190

ND

NI

ND ND20

ND ND ND ND ND ND ND ND ND ND ND150

ND 65

ND

Ni

ND

ND ND

10

ND

ND

ND

ND

MD

100ND

ND ND

14 28

yzcd

September

1982

by

Head

Compuchem

imple

diluted

prior

to

analysis

detection

limits

100

to

200

times

reater

than

those

for

undiluted

sample

detected

EPA

04506

..o

4JO

FIGURE 3-5 Plot of the Dececce Levels of

2TransDichloroethy1.er ppbPriority Pollutant Analyses of isiteBorthole SanplesBase Map fran Ref 81205X

EP

Work Plan 3-21

revised 1/21/91

215-02-02

FIGURE 3-6 Plot of the Detected Levels of

Trichioroethylene ppb Priority

Pollutant Analyses of Onsite r.ioleSanples

Base Map fran Ref LUX 8120500

EPA 04508

Work Plan

revised 1/21/9.1

215-02-02

3-22Thq

U.S EPA 1984 Site Analysis Shpack Dump Norton MassachusettsInterim April 1984

EPAs air photo analysis included not only the Shpack site as stated but also the ALl

landfill to the south statement that the Shpack Dump has grown from

approximately hectares acres in 1951 to approximately 48 hectares 120 acres

in 1982 is inaccurate in that this area also includes the ALl landfill The area of the

Shpack site has been reported as 3.2 hectares acres in previous MA DEP and DOE

reports

This report referenced 1941 photograph which indicated that no filling had

occurred at that time and this photo was not included in the report The 1951 photo

showed initial filling primarily at the AL site with only minor filling around the

perimeter of the Shpack residence The remaining portion of the current Shpack

site is wetlands

The 1959 photo shows more expansion of the Shpack and AL landfills Expansion on

the Shpack side was directly into former wetlands areas on the south and

southeastern sides of the Shpack residence Three areas reported as standing liquid

are evident on the photo at the Shpack site Drums were also identified but only on

the southern portion of the AL site

The 1961 photo shows continued expansion in southeasterly direction from the

Shpack residence This photo shows initial clearing for the power line right of wayover the filled area which was formerly wetlands Two areas reported as standing

liquid are identified in the same areas as in the 1959 photo

The 1970 photo shows that the expansion of the Shpack landfill is nearly at present

day limits Since 1961 expansion has occurred in northeasterly direction to the

edge of the current landlocked portion of the wetlands Though not indicated this is

the area where densely stockpiled drums currently exist It is unclear whether the

drums were present in 1970 This photo also shows an area immediately north of the

AL firepond and overlapping onto the power line right of way which is indicated as

fill area and an area of ground staining This area at the Shpack Site is coincident

with an area identified in NCC 1980 as having received wastes from nearbychemical facility after an explosion at that site This area extends beyond the current

security fence beneath the power lines

EPA 04509Work Plan 3.23revised 1/21/91

215-02-02

The 1980 photo of the Shpack and AL landfills presents little detail of the Shpack

site however the Shpack boundaries do not appear to have changed since the 1970

photo The 1982 photo shows the fence around the Shpack site Leachate is

apparently emanating from the alleged chemical company fill area mentioned above

Debris most likely drums standing liquid and ground staining are also indicated

Bechtel National Inc 1984 Radiological Survey of the Former ShpackLandfill Norton Massachusetts May 1984

This report documents the activities of DOEs subcontractor during August and

September 1982

Surface Scanning

Beta-gamma dose rate measurements were made at the ground surface using thin-

window probe Gamma measurements were made 30 cm foot and feet above

the ground surface using cm by cm 2x2 Na detector designed for downward

directional response Initial beta-gamma and gamma measurements were made at

20 foot intervals within the 30 100 foot grid which superimposed the original

ORNL 1981 grid except for the 30 cm foot gamma measurements which were

only taken at 30 100 foot intervals Additional measurements were taken at 1.5

foot intervals to define more precisely the boundaries of contaminated soil

The average background beta-gamma dose rate in the landfill area was 30 cpm 0.02

mradlhr The maximum beta-gamma dose rate at the surface was approximately 0.8

mrad/hr The average background gamma measurement was 5000 cpm at 30 cm

foot and 10 pR/hr at feet The maximum external gamma measured at

feet above ground surface was 29.5 pR/hr

Surface Soil Sampling

The surface soil sampling locations were selected based on the results of near-surface

gamma measurements In addition at least four samples were collected in the area of

ground-level gamma exposure rates greater than 50 pR/hr as defined in the ORNL1981 investigation Samples were analyzed for

EPA 04510


215-02-02

226Ra and 238U using high-resolution gamma spectrometry

234U and 238U by radiochemical analysis and

235U by neutron absorption techniques

Concentrations of 226Ra 234U 235U and 238U were found in surface soils with

maximum detections at 166.8 4200 1500 and 7200 pCilg respectively

Subsurface Soil Sampling

Boreholes were advanced as in the ORNL 1981 investigation to depths of between

eight and 15 feet Borehole testing was completed using cm by cm 2x2 Nadetector to profile the borehole at 15 cm inch intervals subsurface sample was

then collected below 15 cm inch depth and analyzed as described for surface

soils

Concentrations of 226Ra 234U 235U and 238U were found in subsurface soils with

maximum detections at 1571 1020 200 and 16460 pCi/g respectively


Ground-water samples were collected from the seven DOE wells the three ALl wells

on the Shpack site and the Shpack residence well The DOE wells were analyzed for

226Ra 234j 235U and 238U by radiochemical techniques The AL and Shpack wells

were analyzed for 226Ra and total

Though some of the on-site ground-water samples had above background

concentrations of radionuclides none of the off-site wells were above background

Concentrations of 238U ranged from 0.1 to 6300 pCi/I which is below the 10 CFR 20

release limit of 40000 pCi/I but above the DOE Order 5480.1A release limit of 600 pCi/l

None of the perimeter wells or off-site wells had elevated levels of radionuclides


Surface water samples were collected from the landlocked portion of the swampwithin the Shpack fenced border and also from the wetlands east of the site These

samples were analyzed for 234U 35U and 238U by radiochemical techniques All

surface water samples were within DOE limits

EPA 04511Work Plan 3-25revised 1/21/91 Tb215-02-02

Swamp and Stream Sediment Sampling

Swamp and stream sediment samples were collected from the landlocked portion of

the swamp within the Shpack fenced border and also from the wetlands east of the

site These samples were analyzed by the same methods as for surface soil samples

All sediment samples were within DOE limits

Air Monitoring

Finally Bechtel established two air monitoring stations at the site The filters were

changed every 48 hours and analyzed for 226Ra 234U 235U and 238U by

radiochemical techniques All air samples were within DOE limits

Extent of Hot Spots

Figure 3-7 shows the radiological hot spots at the Shpack site The lateral extent of

the hot spots were determined based on gamma readings The vertical extent of

contamination was determined based on the general correlation of subsurface

radium and uranium concentrations and the borehole gamma Count rate data The

report concluded that while surface contamination has been accurately defined the

spotty nature of the subsurfaáe contamination does not allow for as precise

delineation of vertical contamination

EPA 1984 Hazard Ranking Score Worksheet May 24 1984

The HRS for the site of 29.45 appears to have been driven predominantly by thefollowing factors

the presence of 238U as well as other radionuclides

the close proximity to residences with drinking water wells whichcurrently have no alternative source of potable water and

the close proximity to wetlands and surface water bodies

The HRS relied on existing data for the site presented above

EPA Q4512


Ths

215-02-02

CD

tli

I-i

Figure

3-7 Areas

of contamination

in

excess

of guidlines

NUS Corporation 1985 Final Site Response Assessment SRA ReportShpack/A Itleboro Landfill Incorporated Norton/A ttleboroMassachusetts November 21 1985

This report is primarily summary of previous investigations Some additional

sampling was performed however as described below

Air Monitoring

NUS performed air quality screening using Foxboro OVA 128 in both survey and GCmode Screening of grab air syringe samples did not detect volatiles other than

methane


NUS collected ground-water samples in May 1984 from the DOE and AL wells and four

adjacent residential wells using stainless steel bailer after evacuating three well

volumes All samples were filtered for metals and radionuclide analysis Someunfiltered samples were also delivered for analysis Volatile organic samples were

preserved with HgCI2 and filtered metals samples were preserved with HNO3

The nearby residential wells were free of volatile inorganic and radiochemical

contamination Analysis of the site perimeter wells indicated little migration of

inorganic and radionuclide constituents NUS 1985 DOE-4 had detections of tDCE at

1200 igfl and vinyl chloride at 73 i.g/l while the other wells had significantly lower

or non-detectable readings


Surface water samples were collected in 16 oz glass jar one foot above the stream

bottom and split into 44 ml vials for VOC analysis oz glass jars for metals analysis

and liter polyethylene bottles for radionuclide analysis The VOC samples from the

landlocked swamp within the fenced perimeter were analyzed using Foxboro OVA128 in GC mode Surface water samples from the adjacent swamp to the east outside

the fence were analyzed with Photovac 1OA1O GC

No VOCs other than methane were detected in the interior swamp samples Likewise

no VOCs were detected in the exterior surface water samples Manganese and zinc

were detected in the interior swamp samples but not in the exterior swamp samples

Work Plan 3-28revised 1/21/91 Tb215-02 -0

EPA 04514

Gross alpha Counts for the surface water samples were below the limits of detection

NUS 1985

Bechtel National Inc 1986 Site Plan for Shpack Landfill NortonMassachusetts November 1986

This report contains summary of previous DOE activities at the site and describes

DOEs future plans for remediation soil removal

Wehran Engineering Corporation 1987 Shpack Residential WellSampling Program Revised March 1987

This report documents the results of sampling at 16 nearby residences by Wehran

for the DEP on September and 1986 The report does not specify how the

samples were acquired All samples were analyzed for the following

VOCs by EPA Method 624

Trace Metals by EPA Method 200

Pesticides by EPA Method 608 and

Gross Alpha gross beta and radon gas

Table 3-6 summarizes the results of sampling None of the samples exceeded drinking

water standards for VOCs or radionuclides Samples from two residences exceeded

appropriate standards for lead

ERT Analytical Laboratory 1987a Analysis of Water Samples fromShpack Landfill Attleboro Massachusetts April 28 1987

This analytical report documents the results of residential sampling on March 30 and

April 1987 by Wehran for the DEP The report does not specify how the samples

were acquired Table 3-7 summarizes the results of sampling No VOCs or pesticides

were detected in any of the residential wells Only copper and zinc were detected at

up to 540 and 1200 i.ig/I respectively

ERT Analytical Laboratory 1987b Analysis of Water Samples fromShpack Landfill Attleboro Massachusetts May 1987

This analytical report documents the results of residential sampling on April 10 1721 and 28 1987 by Wehran for the DEP The report does not specify how the

Work Plan 3-29revised 1/21/91 Th215-02-02

EPA 04515

-o

Volatile

Organic

Compounds

ugh

Metals

ugIL

CD -S

Collection

Date

Location

Sample

Numher

Sample

CollectionPoint

Radio-NuclearCompounds

pCifL

Methylene

l1.1

trkhchloro

Gross

Gross

Radon

Chloride

ethane

Alpha

Beta

Gas

Arsenic

Copper

Lead

Zinc

ij9/2J86

106

Peckham

St

SHP-RW-01-001

Frontoutside

water

tap

0.2

0.2

1.4

2450

80

100

/2/86

100

Peckham

St

SHP-RW-02-002

Frontoutside

water

tap

0.9

4270

100

10

12

/2/86

179

Peckham

St

SHP-RW-03-003

Kitchen

tap

450

50

130

23C

9/2/86

68

Union

Rd

SHP-RW-04-004

Sideoutsidewater

tap

--

2.01

180

50

340

--

19

9/2186

59

Union

Rd

Duplicate

SHP-RW-05-005

SHP-RW-06-006

Kitchen

Tap

--

0.3

0.5

10

1920

801

850

80

-- --

130 130

120

65160

9/2/86

14

North

Worcester

Rd

SHP-RW-07-007

Kitchen

Tap

--

1.5

1.4

2040

110

71

9/3/86

80

Maple

Si

SHP-RW-08-008

Backoutsidewater

tap

1.3

2880

110

19

130

9/2/86

79

Maple

Rd

SHP-RW-09-009

Kitchen

tap

--

0.2

1.4

1910

110

--

100

9/2/86

82

Maple

St

SHP-RW-10-010

Frontoutside

water

tap

--

0.5

5500

200

58

9/3/86

83

Maple

St

SHP-RW-1

1-011

Frontoutside

water

tap

--

2440

120

--

51

9/3/86

90

Maple

St

SHP-RW-

12-012

Frontoutside

water

tap

11

--

0.5

1580

110

200

951

9/3/86

97

Maple

St

SHP-RW-13-013

Frontoutside

water

tap

5.4

12

1.3

660

110

--

95

461

9/3/86

95

Maple

St

SHP-RW-

14-014

Frontoutside

water

tap

--

1.5

7100

200

9/3/86

94

Maple

Si

SHP-RW-1

5-015

Frontoutside

water

tap

0.8

4200

200

23

9/3/86

111

Maple

St

Duplicate

SHP-RW-

16-016

SHP-RW-18-018

Frontoutside

water

tap

-- --

0.9 0.6

1.1

220

2003

800

200

63

9/3/86

113

Maple

St

SHP.RW-17-017

Frontoutside

water

tap

0.1

1.5

640

130

340

70

9/3/86

Field

Blank

SHP-RW-19-019

Frontoutside

water

tap

0.1

0.7

230

120

--

12

flegtlaoy/Staridard

i50

1000

15

507

100061

507

5000

background

concentration

of______should

be

subtracted

to

the

gross

alpha

concentrations

to

compare

to

appropriate

standards

background

concenuation

of_

should

be

subtuacted

to

the

grass

beta

concentrations

to

compare

to

appropriate

standards

background

concentration

ol_

should

be

subtracted

to

the

radon

gas

concentration

to

compare

to

appropriate

standards

NOTI

pCi/I

error

Standard

Deviation

Draft

suggested

no

adverse

response

levels

SNARLS

NationalInterim

Primary

Drinking

WaterRegulationsMaximum

ContaminantLevelsMCLs

NationalSv.ndary

Dunking

WaterRegulations

Secondary

Maximum

ContaminantLevelsSMCLS

EPA

04516

Massachi

DrinkingWater

Regulations

Maximum

ContaminantLevels

for

Inorganic

Cher

t-

Table

3-7 Results

of March

30

and April 1987 residential water supply sampling

VOCs Metals Radionuclides

Location Methylene Pesticides Gross Gross

Chloride Copper Zinc Alpha Beta Radon-222

95

Maple 1.3/-0.6 1.31-0.5 7580/-100

113 Maple

430 0.71-0.5 1.5/-0.5 18601-SO1

13 Maple

dup

540 0.4/-0.4 1/-0.4 1940/-505

9 Union 110 1200 0/-0.2 0.6/-0.3 2170/-605

9 Union

dup

110 1200 0.2/-0.4 0.9/-0.4 2260/-601

79 Pcckham

72

200 3.1/-1.4 6.8/-1.1 15701-501

06 Peckham

190 0.61-0.5 1.81-0.4 4070/-801

00 Peckham

42 360 2/-0.7 2/-0.4 6320/-100

field blank

90

0.41-0.4 3/-0.5 1110/-40trip blank N

A NA 901-506

8 Union

NA NA

NA NA 0.6/-0.4 0.81-1.3 240/-50

field blank

NA

NA NA

NA 01-0.2 0.2/-1.3 801-50

Notes

All units

in

p.g/l except radionuclides which are

in

pCi/I Only parameters with detections are listedA

ll other parameters were non-detect

samples were acquired Likewise the report does not specify the sampling locations

Therefore these data are of limited value

ERT Analytical Laboratory 1987c Analysis of Water Samples fromShpack Landfill Attleboro Massachusetts August 12 1987

This analytical report documents the results of residential sampling on July 16 1987

by Wehran for the DEP The report does not specify how the samples were

acquired Table 3-8 summarizes the results of sampling No VOCs or pesticides were

detected in any of the residential wells that were not also detected in the blank

samples Only copper and zinc were detected at up to 590 and 1300 g/l respectively

ERT Analytical Laboratory 1987d Analysis of Water Samples fromShpack Landfill Attleboro Massachusetts November 13 1987

This analytical report documents the results of residential sampling on October 151987 by Wehran for the DEP The report does not specify how the samples were

acquired Table 3-9 summarizes the results of sampling No VOCs or pesticides were

detected in any of the residential wells Only copper and zinc were detected at up to

390 and 1100 lAg/I respectively

Bechtel National Inc 1988 Record of Telephone Conversation withEberline February 18 1988

This record indicated that 800 to 900 pounds of metal fragments enriched in 235U

were removed from the site under armed guard immediately following the ORNL1980 investigation This material was transported to ORNL for retention

Agency for Toxic Substances and Disease Registry 1989 PreliminaryHealth Assessment for Shpack Landfill Attleboro/NortonMassachusetts March 1989

This report relied on existing data to define the following exposure pathways

dermal absorption or ingestion of contaminants in soil sediments groundwater and surface water

exposure to gamma radioactivity in the ambient air at Shpack landfill and

dermal exposure to beta-gamma emissions near ground surface level


215-02-02EPA 04518

-a

Table

3-8 Results

of July

16 1987 residential water supply sampling

VOCs Metals Radionuci ides

Location Pesticides Gross GrossAcetone Copper Zinc Alpha Beta Radon-222

100 Peckham 220 1.8/-0.6 1.6/-0.4 4000/-70

106 Peckham 0.31-0.3 2.41-0.5 2770/-601

79 Peckham

12

70

1.51-1.3 8.3/-1.4 480/-3068 Union

10 240 0.8/-0.5 2.31-0.5 3601-305

9 Union 66 1300 0.51-0.4 1.6/-0.4 2000/-606

8 Union

dup

290

230 1.1/-0.3 2/-0.4 3501-40

Field Blank

11

-0.11-0.12 -0.11-0.3 90/-50113 Maple

590 0.1/-0.4 3.3/-0.7 810/-609

5

Maple 1.51-0.7 1.6/-0.5 7140/-120Trip Blank

52

NA NA NA 1.5/-0.7 1.61-0.5 7140/-120

Notes

All units

in

jtg/l except radionuclides which are

in

pCI/I Only parameters with detections

are listedA

ll other parameters were non-detect

Fr

Jl

pç

-a

Table

3-9 Results

of October

15 1987 residential water supply sampling

Notes

AU units

In

p.g/I except radioriuclides which

are

inpCi/I Only parameters with detections are listedAll other parameters were non-detect

90

59 Union

100 Peckham

106 Peckham

179 Peckham

68 Union

113 Maple

95

Maple

95 Maple

Field Blank

1100

100

54

130

390

70

Ui

0.31-0.4

6/-20.1/-0.2

3.51-1.2

1.1/-0.4

0.2/-0.4

0.7/-0.4

0.7/-0.4

-0.08/-0.06

1.2/-0.4

4.6/-0.7

1.3/-0.4

2/-0.8

2.31-0.5

1/-0.4

0.9/-0.4

0.9/-0.4

-0.2/-0.2

1790/-906380/-2002770/-1

10

410/-80350/-80970/-1007000/-2006700/-200-40/-100

U.S DOE 1990 Environmental Compliance Assessment for the ShpackLandfill Site Norton Massachusetts July 1990

This report contains preliminary discussion of ARARs that may be applied to the

Shpack site specifically related to radioactive and mixed wastes at the site


Thq

215-02-02 EPA 04521

SEC1ON 4.0

APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS ARARs

4.1 INTRODUCflON

This section identifies Federal and State applicable or relevant and appropriate

requirements ARARs that may provide cleanup standards at the Shpack Site This

section also provides the procedures that ERM follows to identify and evaluate ARARsProvided in Figures 4-1 4-2 and 4-3 are the procedures ERM uses to identify ARARs

and to determine if they are applicable relevant or appropriate

Applicable requirements are those cleanup standards standards of control and other

substantive environmental protection requirements promulgated under Federal or

State law that specifically address hazardous substance pollutant contaminant

remedial action location or other circumstances at CERCLA site

Relevant and appropriate requirements are those cleanup standards standards of

control and other substantive environmental protection requirements criteria or

limitations promulgated under Federal and State law that while not applicable to

hazardous substance pollutant contaminant remedial action location or other

circumstances at CERCLA site address problems or situations sufficiently similar to

those encountered at the CERCLA Site that their use is well suited

Throughout the RIIFS process ARARs and other criteria advisories and guidances

will be

considered in terms of their chemical-specific location-specific andaction-specific attributes

evaluated for each medium surface water ground water sediment soilair biota and facilities particularly for action-specific ARARs but

including other ARARs as appropriate

distinguished for each technology considered particularly for action-

specific ARARs but including other ARARs as appropriate and

considered at each major step of the RIJFS where they are indicated

Work Plan 4-1

revised 1/21/91

215-02-02EP 04522

Figure 4-1

Procedure for Identifying ARARs

List All

Chemicals

Present

Jr

Remedial Investigation RIScoping and Site Characterization

List All

Location

Characteristics

LocationSpecific

Matrix

For Potential

Requirements

Work Plan

revised 1/21/91

215-02-02

4-2

Th_____1_

Consult Scoping and Site

Characterization Data

ChemicalSpecific

Matrix

For Potential

Requirements

Determine ActualChemical Specific

ARARsGo to General

Procedures For Determining Applicabilityand Relevance andAppropriateness

Determine ActualLocation Specific

ARARsGo to General

Procedures For Determining Applicabilityand Relevance andAppropriateness

EPP 04523

Work Plan 4-3

revised 1/21/91

215-02-02

Figure 4-1 Continued

Procedure for Identifying ARARs

Feasibility Study FS Development of

Alternatives Initial Screening Stage

Develop Alternatives and Conduct Initial

Screening

Identify Probable Action Specific ARARsfor Alternatives Passing Thru Initial Screen

List Remedial Actions and Likely

ActionSpecific ARARs

Go To General Procedures For

Determining Applicability and

Relevance and Appropriateness

Detailed Analysis of Alternatives

List All Alternatives and All of Their

Identified ARARs ActionSpecific

Document Alternatives and

Their ARARs in PS

Selection of RemedyDocument Reason For Selecting

Remedial Alternative and How Its

ARARs Were Identified and Complied

With or Waived in the ROD

Note that chemicalspecific ARARs will generally be the same for all alternatives and need not be repeated for

each alternative single list of chemicalspecific ARARs should be developed during the site characterization

phase of the Remedial Investigation and modified during the remedy selection process

EPA 04524

Figure 4-2

General Procedure for DeterminingIf Requirement is Applicable

Stan

Identify Pertinent Facts ConcerningSttuation at Site or Operable Unit

Type of Substances

When Substances Placed at Location

Type of Site or Special LocationPersons Affected

Identify Types of Response Action or

Technology Under Consideration for

Site or Operable UnitOther Characteristics

Review and List the Provisions

of Each Potential Applicable Requirement

Substances CoveredTime Period CoveredTypes of Facilities CoveredPersons CoveredActions CoveredOther Prerequisites

Compare Pertinent Facts About the Chemicals Present the Location ofand the Types of Action/Technology under Consideration at the Site

to Prerequisites for Requirements

Ar AU Go to Procedure

Pertinent Nofor Determining if

Provisions ReSuirement is

for RequirementsReievant and

Met Appropnate

Yes

Requirementis Applicable

Work Plan 44revised 1/21/91

215-02-02 EPA 04525

Figure 4-3

General Procedure for Determiningif Requirement is Relevant and Appropriate

Factors Relating to Problem Present at CERCLASite or Operable Unit that Must be Addressed by

Remedial Action

Specific Goals and Objectives of CERCLARemedial Action at Site

Use of Requirement at Site Consistent with

Purpose

Media ContaminatedlAffected by Cleanup

Substances Involved at Site

Entities Affected

Remedial Action Contemplated at the Site

and Duration of Activity

Circumstances at SiteDo they Fit

Requirements for Variances

Waivers or Exceptions

Type of Physical Location Involved

Type of St.ructure or Facility Involved

Use or Potential Use of Resource

Involved

Refine the Comparison Considering Nature/Character

of the Substances Characteristics of the Site

Circumstances of the Release Proposed Response Action

Use Best

Professional

Judgment Based on Con No______________________

siderauori of Above Factors Is________________________

Requirement Both Relevant

n.cJ Appropriate

Work Plan 45Yes

revised 1/21/91

215-02-02 Requirement is ----Relevant and Appropriaj

During the Identification Stage

For Each Requirement Not Found to be

Applicable Review Factors Below to

Determine if CERCLA Problem Situation

is Sufficiently Similar to the Problem

that the Requirement in Question is

Designed to Remedy or Address

Factors Relating to Origin and Objective

of the Requirement in Question

Specific Goals and Objective of Requirement

Purpose of Requirement in Program of Origin

Media RegulatedlAffected by Requirement

Substances Covered by Requirement

Entities Regulated/Affected

Action or Activity Regulated by Requirement

Variances Waivers or Exemptions of

Requirement

Type of Physical Location Regulated or

Affected

Type of Structure or Facility Regulated or

Affected

Requirements Consideration of Use or

Potential Use of Affected Resource

Try to Subdivide

Requirement into Smaller

Parts that may be

Sufficiently Similar

then Analyze and Compare

Requirement is Not

Relevant and Appropriate

EPA 04526

Identification of chemical- and location-specific ARARs is more important in the

beginning steps of the RI/FS whereas the identification of action-specific ARARs

gain importance later during the more FS-oriented activities

If requirement is determined to be not applicable ERM will subsequently consider

whether it is relevant or appropriate When any new site-specific information

becomes available ARARs will be re-examined

Chemical-specific ARARs are usually health or risk-based numerical limits The

Maximum Contaminant Levels MCLs of the Safe Drinking Water Act SDWA 1986and the Federal Ambient Waste Quality Criteria of the Clean Water Act are examples

of chemical-specific ARARs

Location-specific ARARs are general restrictions placed upon the concentration of

hazardous substances or activities because of locations Some examples of special

location include floodplains and wetlands

Action-specific ARARs are usually technology-based or activity-based directions or

limitations which control actions taken at CERCLA Sites Action-specific ARARs as

the name implies govern the remedial actions The RCRA 40 CFR Part 264 Standards

for Hazardous Waste are an example of possible action-specific ARAR

Provided in Tables 4-1 4-2 4-3 and 4-4 is chart of ARARs and EPA criteria

advisories and guidances and limitations The descriptions briefly describe the

requirement and will include numerical requirements and basis of the ARARs and

media The tables indicate the prerequisites for applicability chemical-specific

location-specific or action-specific pertinent to surface water ground water soil

air or biota Also specific levels and goals set by the ARAR are provided or

referenced Throughout the Work Plan ERM has considered data requirements in

terms of physical chemical and radiological characteristics needed to evaluate

ARARs

The following EPA guidance documents were consulted and will continue to be used

during the ongoing ARAR identification process

CERCLA Compliance with Other Laws Manual Draft Guidance August 1988EPA/540/G-89/006


215-02-02

EPA 04527

Within 100-year floodplain Facility must desirned

conzt.ruct..d opsrat.d

and

maintained

to avoid washout

hazazdus waste treatmentstore o

r disposal

40 FR 264.18b

Within floodplain Action

to avoid adverse affectsminimize potuctial harm rsstore

and prss..rv natural and

b.n.ficial valuss

Action that will occur

in

floodplain

i.e lLsnds and

rslativ.ly flat areas adjoinina

4i1

and coastal waters

sod

other flood pron areas

Protection

of floodpiains40 CFR Appendix

Fish

and Wildlife Coordination

Act

16

USC

661

jt 40

CFR

6.302

Within salt

don formation

uodar8iound mine

or

cay

Placanant

of non-ccmtainsrjz.d or

bulk liquid hazardous waiti

probthit.d

hazardous waste placament

40

FR 264.18c

Within arac wbsr action may

cause irreparable harm loss or

destruction

of significant

artifact

Historic project aimed or

controlled

by Federal asncy

Action

to recover

and preserve

s.rti facts

Action

to

preserv historic

properties pliu of action

minimize harm

to National

Historic Lancaxks

Action to conserve andan.r.dspecies o

r threatened speciesincluding consultation with th

e

Department

of Interior

Alt.ration of terrain that

threatens sijnificsnt

sciscUfic prehistoricalhistorical o

r archaeo1oicaldata

Prop.rty inclnded

in or li5ibleto

for

tb

National Raister

of

Historic Places

D.t.rnination of presance

of

sndaner.d or threatened species

National Historical Preservation

Act

16

USC S.ction 469

36

CFR Part

65

National Historic Preservation

Act Section

106

16

USC

470

et

ia 36

CYR Part

800

Endan5ered Species

Act

of 1973

16

USC 1531 50

CFR

Part

200

50 CYR Part

402

Fish

and WildLife Coordination

Act

16

USC

661

33

CYR Parts 320330

Location

TABLE 4.1

SELECTED LOCA11ON-SpECIRC POTENWIL APPLKABIF

OR EVANT

AND APPROPRTATE REOUIREMFNTS a/

Riquiranent

Within

61 meters

200 feat

of

fault displaced

in Bonoc.n time

Prerequisite

New

treatment stora8e or

dlsposs.l

of hazardous waste

prohibited

Citation

hazardous waste treatmentstors4e o

r disposal

40 FR 264.18a

Lxi

01tj

Critical habitat upon which

endangered species or threat.ned

species depends

41 Confinued

SECTRD LOCATON-SPECIFC POTRJT1AL APPUCARLE

OR RELEVArrr

AND APPROPRATF REOUIRlENTS

Requir.nsnt

Action

to

prohibit discharge

of

dredged or fill material into

wetlands without permit

Action to avoid sdv.rse effectsminimize pottia1 harm

and

pres.rvs

and enhance wetlands

to

the extant possible

see

discussion

in section 3.4.4.1

Prerequisite Citation

Wetlands as defined in

U.S Army

Corp

of Fngineers regulations

Action involving construction

of

facilities or wanagent

of

property

in

wetlands as defined

by

40

CYR Part Appendix

section

Wilderness area Area most

hi ainistered

in such

ner

as

wiU leave

it

tmiwpair.d as wilderness

end

to

pressrve

its wilderness

YederaLly-oied area designated

as wilderness area

Wilderness

Act

16

USC 1131

50

CYR 35.1

0o

Wildlife refuge

Area affecting strean or river

c1y actions allowed mder

the

provisions

of

16

USC Section

668

ddc

nay

undertaken in areas

that are part

of

the $ational

Wildlife Refuge Syatum

Action to protect fish or

wildlife

Area designated as part

of

National Wildlife Refuge System

Diversion channeling

or other

activity that modifies streem

or river

and effects fish or

wildlife

16

USC 668dd

50

CFR Pert

27

Fish


Act

16

USC

661

40

CYR 6.302

Within area affecting national

wild scenic

or recreational

river

Avoid taking

or assisting

in

action that will

hay direct

adverse effect on scenic river

Conduct activities

in

maimer

consistent with approved State

management progrems

Prohibits any

new Federal

expenditure withinthe Coastal

Barrier Resource System

Activities that affect or

may

affect any

of

the rivers

specified

in section 1276a

Activities affecting

the coastal

zone including lands therein

and

thereunder

and adjacent

shorelinds

Activity within

the Coastal

Barrier Resource System

Wild

and Scenic Rivers

Act

16

USC 1271 section

40

CFR 6.302e

Coastal Zone Hana8ement

Act

16

USC Section 1451

Additional locationspeclfic requirements will

be added after analysis

of additional sources

and wilt

be included

in sbsequentdraft

of this maraL

40 CFR Part StApart sets forth

EPA

policy

for carrying

out

the provisions

of Executive Orders 11988 Floodplain Management

and

11990 ProtectIon

of Wetlands Executive orders

are binding

on

the level

e.g Federal1 State

of goverrnent

for which they

are

issued

Location

WetLands

2./ Clean Water

Act section

404

40

CFR Parts

230

33

FR Parts 320-330

40

CFR Faxt Appendix

LII

Within coastal zone

Within designated coastal barrier Coastal Barrier Resources

Act

16

USC 3501

TABLE

41

Continued

New

major stationary sources shall apply bestavailable control technology

for each pollutant

subject

to

regulation under the

Act that

the

source would have potential

to emit in

significantamounts

Owner or operator

of proposed source or

modification shall demonstrate that allowableemissions increases o

r reductions includingsecondary emissions will not cause or contributeto

violation of

the NAAQS or epplicable maximwsallowable increase over baseline concentrations

Source must obtain emission offsets in Air QualityControl Region

of greater than one-to-one

Source subject

to lowest achievable emission rateLAIR as defined in 40

CFR section

Sl.18jxijj

All major stationary sources owned o

r operated

bythe

person

in the State are

in

compliance or

on

schedule for compliance with

all applicable

emission standards

CHAPrER OTHER RESOURCE PROTECTION STATUES

Major Stationary Sources as identified in 40

CFR section 52.21b1j5 that emits o

rhas

the

potential

to emit

100 tons per yearor more of

any regulated pollutant any

other stationary source that emits or

hasthe potential to emit

250

tons per year or

more of any regulated pollutant

Any stationary facility or source of

air

pollutants that directly emits or

hae

the

potential

to emit

100 tons per year or moreof any

air pollutant including any major

emitting facility or source

of fugitive

emissionsof any such pollutant CAA

$302jJ

Historic districtsite buildingstructure o

r

object

Critical habitatof/or a

n endangered

or threatened

species

Avoid impacts on cultural resources Where

impacts are unavoidable mitigate through designa

nd data recovery

Identify activities that may affect listed

species

Actions must

not threaten

the continued existenceof listed species

Properties Hated in the National Registerof Bistoric Places or eligible

for such

listing

Species or habitat listed as endangered or

threatened

National HistoricPreservation A

ct NHPA1

6

CFR Part 470

.L

Endangered Species

Act

ESA

50

CFR section 402.04

50

CFR section 402.01

SELECTED LOCATION-SpECIFIC POTBl11AL APPLICABLE

OR RELEVANrAND APPROPflL4JE REOUlREME is

LocationReirements

Prereisites

for Applicability Citation

CLEAN AIR

ACT

NAAQS AttainmentAreas

NAAQS NonAttajnmentAreas

40

CFR section 52.21JC

AA

CA.A Part S1731

CAA Part 1732

CAA Part 51733

Ui

Actions must not destroy critical habitat

50 CFR section 40201

TABLE

4-1

ConInued

SFLECT LOCATON-SPECIFC POTENflAL APPLAR1F

OR RELEVANT

AND APPROPRLbTE REQUIREMENTS

Location Requirements Prerequisites


CnArFJ

OTH RESOURCE PROTECTION STATUES

Wild and ScenicRivers

Determine

if

project will affect

the freeflowing

characterietics scenic or natural values

of

designated river

Any river

and

the bordering

or adjacent

land designated

as wild

and scenic or

recreational

Wildand Scenic Rivers

Act WS.A

36

CFR section 297.4

Not authorize any water resources project

or

any

other project that would directly or indirectly

impact any designated river without notifying

DOE

or Forest Service

Coaatal zone or

an

area that willaffect t

he coastal

zone

Federal activities must be consistent with

to

the

maximum extent practicable State coastal zonemanagement programs

Wetland flood plain estuary beach dunebarrier island coral reef

and fieh

and

wildlife

and their habitat within

the

coastal zone

Coastal Zone Management

Act CZMA

15

CFR section 93030

Federal agencies must supply

the State with

consistency determination

The following are

not allowed

in Wildernessarea

15

CFR section 930.34

CZ1IA

Wilderness Act

WA

50

CFR section 35.5

comercial enterprisespermanent roads except

as neceasary

to administer

the area

motor vehiclesmotorized quientmotorboata

aircraftmechanized transportstructures o

r buildings

Minimize disturbance

of

the hydrologic balance

within

the permitted

and adjacent areas

Implement sediment control measures

to minimizeerosion

and prevent additional contributions

of

sediment

to streamfiow or runoff Measures

instituted must attain State

and Federal effluent

limits

Applies

to

all surface coal mining

operations except

for non-coasnercial use

extraction

of

250 tons or less extraction

as

an incidental part

of government-financedconstruction o

r

of mining

of other minerals

or extraction

of coal that affects loss than

acres

30

CFR section 700.11

30

CFR section 816.41

S4RA

Backfill

and grade disturbed areas

to

approximateoriginal contour minimize erosion

and achiev

stable slope

30

CFR soction 616.102

S4RA

30

CFR section 816.11

SlCRA

-4 Wilderness Area

Any unit

of

the National Wildlife Refuge

System

LII

CflAP1TR MINItG PffLLTNG ELTTfiO SITE$

Surface liming Sites Remove

and segregate topsoil from site before

remedial action After cleanup redistributeoriginal soil o

n site

Surface Mining Control

and Reclamation Act

S14RA

30

CFR section 816.22

30 CFR section 616.41

S14RA

Revegetate disturbed area with species native

to

the area

IABLE 4-2

SELECTED CHEMCAL-SPECIFIC ImAL APPliCABLE

OR RELEVANT

AND APPROPRIATE RECIJIREMENTS

MD PCLS

Pot..tit1 ARAB

b/

Kax1n St1A 4Thwft

CctinaxtL1it. L.vLa

Q.Q1csl /j iJI

Ara.nio s.o

io2 5.0

io2

1.0 10

Bsnz.n 5.0

B.ta Partial Phot Radioactivity jj1_j

cai 1.0

io

1.0

io2

Carbon Tstrachl.orids 5.0

10

5.0

io2 5.0

io2

Colifor Bact.ria p.r

100

p-Dichlorob.nz.ne 7.5

10

12-Dicbloro.than 5.0

10

lDicbloro.thyl.n 7.0

10

2-4-Dichloroph.noxyac.tic Acid 24-D 1.0 10_i 1.0 10_i

dxi

2.0

10 2.0

10

Pluorid 4.0

L.ad 5.0

io2 5.0

io2

Liod 4.0

10 4.0

10

Tot.al M.roury

2.0

2.0

10

M.thoxychlor 10

iol 1.0

io

Nitrat 10Lii

Rad.ionuclid.s roas alpha particl activity 15 Ci/l

Radju-226 RId1LXD-228

S.l.niz 1.0

io2

i.o

io

Ui Silvr so

io2 5.0

io2

Toxaen 5.0

s.o

245-7 Silv.x 1.0

io2 1.0

io2

11 1-Trich1oro.th 2.0 10_i

Trichloro.thyl.n 5.0

10

Total TrihaJthan. 1.0 10_i

Turbidity Tu

Vinyl C1orid 2.0

TABLE

4.2

ContInued

SELECTED CHEMICAL-SPECIFC POTBmAL APPLABLE

OR AREVANTAND APPROPRIATE REOUIRENTS

For

Use

In

SpecialPotantlel AJARs

bI

Circ.znstangs

CA Water Quality Criteria

CWA ALisnt Wetsr QuaUty Criteria

for

for Protection

of

an Health Prot.cti of Aquatic Life

c/Water

and Fish Cccstrtjon Yrs.hat.r Maxine

i.h Inssti 1y Acuts/Chrcxijc Acute/Chronic SEWA/CL Goal

Chnjca1 r/l

r/1 ngJt cn8Jl

a/l

Acenapthms 1.710.5 0.910.7Acenaphthyl.ne

3.0xl0_01Acrolein 3.2x1001 7.8x1001 6.8x10.02/2.lxjO_02 5.3x10-02

Acrylonitrjle 5.8x1005 6.SxlO04 7.512.6A.ldrjn 7.4x1008 7.9x1008 3.OxlO03 1.3x1003Anthxacsn

AntIny

and Cccpoda l.SxlO-01

45

9.0/1.6

Arsenic

and Ccc7pounds 2.2x10-06 1.8x1003

Arsenic

CV

and Cccpounda 0.8/4.8x10_02 2.3/1.3x10_02

Arsenic

III

and Caopounds 0.3/0.1 6.9x10-02/3.6x1002

As

be tos

Barjtzn

and Ccpotoida

Benraanthracsne

Benzcacridjn

B.nzane 6.6x10-04 4.OxlO02 5.1/0.7Senxidjn 1.2x10-0 5.3x1004 2

.5

8.nioapyr.n

Banzob fluoranthsns

Benxoship.ryl.n

B.nzok fluoranth.ne

Berylliun

and

Ccxipounda 6.8x1006 1.2x1004 01/5.3x10_03

flis2-chloroethy.ther

Bis2-chloroiaopropyleth.r

EL schlorocn.thylether

TABLE

4-2 Continued

SELECTED CHEMICAL-SPECIFIC POTENTiAl APPLICABLE

OR RELEVANT

AND APPROPRIATE REQUIREMENTS

For

Uis

In

Spsciat

Font-lal ABAP.s

bI Ctrctioat-enes

CI4A Wtsr Quality Crit.ris 01AArbi.ut Wttsr Quality Crit.ria

for

for Frot..ction

of U.sJth Prot.ctic

of Aquatic

Lif

c/Wat-

i4 Yisi Csizçti Yrsitst.r Harms

Fish

IuU

iy Acat/ric Acut./ric SE-LA/CL Goal

Qi.cnical

J1 ijJ1

Jl

/1

Cai Ccxrpomds 1.OxlO02 3.9x1003/1.IX1003 4.3x1002/9.3X1002

Carb T.trscblorids 4.0x1004 6.9x1003 35x1001 5.OxtO01

Qlords 6x10-07 8x10-07 4x1003/4 3x1006 .0x1005/4 .0x1006

Qilorinatsd B.nz.s2.5x10_01/5.OlO_OZ 1.6x10_01/1.2X10_01

QLormnatsd Nat.ba1si

1.6 7.SzlO_03

aLoroaikyt Eth.rs2.3X1002

QiLorob.n2s

Hio

cl1rodibr.t11tnS

QLrofor 1.8x1002 2.SxlO01/1.2

2-QLorobo343/20

Qriit III

and Ccziipounda

170 3433 1.7/0.2 1.OxlO01

Qirit VI

and Cccipounda

5.0x1002 1.6x10-02/1.1X1O02 1.1/5.0x1002

Copp.r

and Cpoda

1.8x1002/1.ZX1OOZ 2.9x1003/2.9x1OO3

Cyanidsa2x1001 2.2X1002/.2X1003 1.OxlO03/1.0x1003

DDT

2.4x1008 2.4x1006 1.lxlO03/l.OX1OO6 1.3x10-04/1.OxlO06

Dibutyl Ibthalats

14

DlchloroblDzan$AxlO01

2.6 1.1/7.6x10_01

1.9

2-Dicblorobsnzqnl

3-DicbLorobnZS1S

14-Dicorobsorans

7.SxlO-01

33-DicblOrObSnidlns1x1004 2x10-O5

2-DichLorostbInI4x1004 4x10-01 1x1O02/Z OxlO01 1x1002

Dicbioroit.hylSflsI3.3x1005 1.9x1003 1.lxlO01 2.202

TABLE

4.2

ContInued

SECTH CHEMICAL-SPECIFiC POTEN11AL APPLiCABLE

OR RRIANT AND APPROPRLZTE RFCXJIREMENTS

For

Us

Ia

Sp.ciaPtt4.t MARi

b/

W.t. ality CrLt.rj C34 Mthi W.t.r Quality Crit..ria

to

tar Protaoti

of

Bu EsaIth Prot.ctic

of Aquatic

Lit

Cl

Wat.r Fish Cisitjcm Yr.slavat.r MariaFish Inj.ati 1

y Acut./Qarcic Acut./Chrcsijc SCAJCL GoalQnics1 J1 i.J1 asJ1 aaJ1 r/1

4/

1lDichl.aro.thylu

3.1

1.111001k 2.2x1002 7.OxlO-0324-Dich1croo1 2.0/0.326-Dich1orobo1

4-Dichro3o1

3-Djch3.oroEo1

Dichl.orogao1

DichLorosaoxy-ac.tjc Acid

40

7.OxlO-0313DicbLoroprop 8.7x1002 14.1 6.01/0.2 0

.7

Dl .id.rth lxlO08 6x1008 SxlO03/1 9x10-06 7x10-03/1 9x1006

Dietbylpbtha.st 350 1800

Bls2-.thy1h.yLphthaat

Dl.thyLnitrosjn

12Djm.t1b.agatacDixx.thy1n.ttros.jn

24Di.thyi.aoL 2.1k

Dia.thy1ths.1at 313 2900

6-Din.lt.ro-o-cr.so3

4-Dlr4traph.aol

2Dièsay1.hydrazin

Fdo.uUsn 4x1002 6x1001 2x1004/5 6z10-05 4x10-05/8 7x10-06Endrin lxlO03 1.8.xlO04/2.3x1006 3.7x1005/2.3x10-06

Ethy1.b.ns.n

1.4

13.3 3.2x10O1 4.3x10-01

Fiuoranth.u 2x1002 4x1002

39 0x1002/1 6x10_02_

_ Fiuorid.s 4.0

TABLE

4.2 ContInued

SELECTED CHEMICAL-SPEC

lFC POTENTIAL APPLABLE

OR RELEVANT

AND APPROPRtATE REQUIREMENTS

pteit4at ARAR

b/ CtrcutazCii

\0

CWA Water QuaLity Crit.ria

CWA Acbient Wat.r Quality Criteria

for

for Protection

of

Uen Bulth Prot.ction

of Aquatic Life

Cl

Water

end FLs1 Cavption Fr.ibwat.r Marine

Yi Ii4..tic QI.y Acut./CIXCXiC Acute/ChroniC SCA/CL Goal

Chice1 Ne ri/i ri/i ri/i

ru ri/i

Beptachior8x1007 9x1007 2x1004/3 8xi006 3x1005/3 6x1006

aexachlorob.n.zens 7.2x1007 7.4x1007

H.xacaloroka.itadienI5x1004 5x1002 9.010/9 3xlOO3 .2zl002

alpha-liaxahiOrOCyCl0h1

fl 9.2x1006 3.1x1005

Linden

T.chnical i.2xi005 4.ix1005

Uoxacb.orocycloPentIdienS1x1001 0xl003/S 2x10O3 Oxl0O3

B.xachlorosthi.ne9x1003 74x1003 8x1001/S 4x100l 4z1O0l

Iodcnsthin

Isophorons1.17x1002 l.Zx1001

Lead

and Conpotmdi InOrganiC 5x10028.0x1002/3.2xi003f O.l/56x1003

Mercury Cccoundi Alkyl2.4xi003/1.21iOOS 2.lx10O3/2.SxlOO5

Mercury

end Cccoda Inorenic 1.4x1004 1.5x1004 2.4x1003/l.2X1005 2.1x1003/2.5X1005

ttj MethoxychiOr1x1001 0.3x1004 0.3xi0_04

Methyl Chloride

2-M.thyl-4-chlorobOl

St 3-M.thyl-4-ohlorOphei

3H.thyl6ChLOrO.St0t

3-othI.orophOi

4-ttinoCbLOrOphenOl

Nickel

aDd Caxipoiadi

1.3x1010 1x1001 1.4/1.6x1001 7.5x1002/8.3X1OO3

Nitrat

as

10

Hit.rthenzsne

20 2.7x1001

6.6

flitrophenol.i

2.3x1001/l 5x1001

4.8

TABLE

4.2

Continued

CD

SaECTED CHEMJCA1-SpEClF POTENTLAL APPLICABLE OR

PEI EVANTAND APPROpRi REOUIRES

-.

For

LI.

In

SpecialPotsntjel

AMR

b/ _cutimc

Wst.r Quality Crit.ria CWA Ajsn Water Quality Criteria

for

for Prot.ctjon

of Rize.an E.alth Prot.ction of Aquatic

Lit

c/

Water and Fi$h Constiptjon Yr.sbtatr Marine

Pia In..stion il.y Acute/Chrjc Acute/Chronic SrMAJcL GoalChsica1 r

/L /L Jj /L

n/l

Nitosanjn3.3x1003

n-flitroaodtph.ny.aaijn 4.9x10-03 1.6z1002N-Nitrosopyrroj.jdjn 16x10-05 9.2x10-02

Par Dictob.i.

Pentachjorthat.d Ethanea7.2/i 9x10-0l/2 8x1001P.ntach.orthg.n 4x1002 5x10-02

Pentachloroph.noOxlO-02/1 3x10-02 3x10-02/7 9x1003Ptien a

n thren

Pnanol 3.5

1.OxlO01/2.5 5.8

Itithalat Zat.rs9.4x10-Ol/3.OxlO-03 Z.9/3.4x10_03

Polychthrjnsted Bir.ny.g

PC8 7.9x10-08 7.9x1008 2Ox1O-03/1.4x10-O5 iOx1O02/3.OxlO-O5

Radlceiuctid. Gross alpha activity 15 Ci/1

RadltE

226

and

228

ICi/1Sel.niun a

nd Cacimd 1.OxlO-02 1.OxlO-02 2.6x10-Q1/3.5x10-02 41X1O-O1/5.4x10-O2Silver a

nd Conpoda 5.OxlO-02 5.OxiO-02 4.1x10-03/1.2x10-04 2.3z10-03

Strontjt.9OpCi/i

23.78Tcrv Dioxinl.0x10_05/1.lO_08

Tatrachlorjnat.4 Ethans 93

124 5-Tetrach1.orobzan 8x10-02 8x10-02

l22T.trach.oro.than 7x1004 I.xlOO2

2.4 9.0

T.tracbj.oro.than. 93

Tstrichl.oro.thylans 8x10-04 9x10-03 5.2/e 4x1001 i.OxlOOle/4234 6Tstrschloroph.no

4x10-01ThalUui

and Conzpotmd 1.3x10-02 4.8x10-02 i.4/4.OxlO_02 2.1z10-03

TABLE

4-2 ContInued

SELECTED CHEMICAl-SPECIFIC POTR-1TIAL APPI CABLE

OR RELEVANT

AND APPROPRLTE REOUIREMRIFS

For

the

In

Special

Pott-1I ARABs

b/ _c1rcLI18tericea

CWt Water Quality Criteria

CW Aient Water QuaLity Criteria

for

for Protection

of

Bun Eealth hotcUcri

of Aquatic Life

c/

Wat.r

and Fish Ccmatiou Fr.abatsr Maxine

Fish Injestiou

1.y Acut.iThrouic Acute/Chronic SEIdAJHL Goal

Chica1

Nan

r/L Irs/i ms/i mB/i mB/i

Toluan

14

420 l.7z1001 6.315.0

Toxaiien 1.xiO07 3x10-07 .3x1004/2.OxlO-07 lxlO-04/2x1007

Trthrsthaxi BrformTrichlorinat.d Ethanea 1.8x1001

1.11-Trichloro.thane

18 1000 3.1x1001 2.0x1001

112Trichloro.than 6z1004 4.2x1002

9.4

Trichloro.thyian 2.7x10-03 8.1x1002 4.5x10Ole/Z.1.Z10t0l

2.0

Tricb1orofluor.thsna

245Tricbl.nrophanol

2.8

2.4.6Tricblcropbsnoi 1.2x1003 3.6x1003 9.7x1001

25Tricbloroanoxypropiomio Acid

Triha.tonsthanss Total

Tritit

LII

Vil Chloride 2x10-03 5.3z1001

Zinc

and Ccxpotd.s 1.3x1001/1.1x1001 9.6x1002/8.6x1002

pJ Additional chw.ioal-ip.cific r.quiranants

wLU added

s.j National iant Aix Quality Criteria after analysis

of additional statutes

.n two

or

re vsl.u.a conflict

th lower value .neral1y should used

p./ Federal water quality critria

YC are

not lejaU.y .nforc..bla .taz4.rda

but

axe potentially relevant

and appropriate

to

LA actions CtCLA

$121dC2BL requires considerationof four factors iian d.t.4g isbetbsr

ax xeisvsnt

and appropriate

the deaioatied

or potential

use

of

the

surface ox xomater

tb snvirsntal media aff.ct.d

th

purp..s

for diich such criteria were d.velop.d

and

the latest information availthle

Fr

Not more than 2300 g/day

Not more than 3200 6/day

Not more than

2.5 Mg/yr or achieve

85X emission

reduction

Not more than

0.4 Mg/yr or achieve

85X emission

reçtuction

Not more than 11.6 mg/rn3 particulate matter

design

and operating requirements

Inspection maintenance

and housekeeping

No visible emissions

No surfacing with asbestos

No visibl emissions

Notification

wet

and remove friable asbestos

Limitations on concentration

of asbestos no

visible emissions


No asbestos



No visible emissions design/work practice

standards

No visible emissions design/work practice

standards

Not more than

10 g/day

or 0.01 5/rn3 ambient

concentration with years

of monitoring data

Not more than g/hr maximum

10 5/day

Not more than

10 equipnent standards work

practice standards

TABLE

4-2 Continued

SEECTED CHEMCAL-SPECIFIC POTRlT1AL APPLICABLE

OR RREVANTPNDAPPROPRLATE REOUlRR4flITS

Requirements Prerequisites

for Applicability CitationChemical Name

CHAPTER CLEAN

AIR

ACT

NESHAPS

Her

Cu

ry

Arsenic

-4

00

Asbestos

Beryllium

Vinyl chloride

Mercury smelters chioroaLkali plants

Sewage sludge incinerators/dryers

Existing glass manufacturing plants

New glass manufacturing plants

Primary copper smelters

Arsenic trioxideand metallic arsenic

production facilities

Asbestos mills

RoadwaysManufactuting plantsDemolition activities

Spraying operations

Fabricating shopsInsulation operationsMill waste disposal sites

Waste disposal--manufacturing demolition/

renovation spraying fabricatingInactive waste disposal sites

for mills

manufacturing fabricatingActive waste disposal sites

Extraction plants ceramic plants

foundries incinerators rocket propellantplants machin shopsRocket motor teat sites collection

of

combustion products

Ethylene dichloride vinyl chloride

and

vinyl chloride polymer plants

Clean

Air

Act

CAA

40

CFR Part

61

40

CFR Part 61 CA/i

10

CFR Part 61

CAA

40

CFR Part

61 C/iA

40

CFR Part

61 C/iA

40

CFR Part

61 CA/i

40

CFR Part

61 C/iA

40

CFR Part

61 C/iA

40

CFR Part

61 CA/i

40

CFR Part 61 C/iA

40

CFR Part

61 C/iA

40

CFR Part

61 C/iA

40

CFR Part

61 CA/i

40

CFR Part 61 CA/i

40

CFR Part

61

CAA

40

CFR Part

61 CA/i

40

CFR Part

61 CA/i

40

CFR Part 61 CA/i

40

CFR Part

61 CA/i

40

CFR Part 61 C/iA

Design

and operation

Design

and operation

No visible emissions operation

and maintenanc

standards

Not

to xo..d ppa over 6-hour period

and

not

to

exceed

35 ppo over 1-hour period primary no

secondary standards

Not

to exceed 1.5 p3/rn3 based on

quarterlyaverage

Not

to exceed 0.053 pc annually

Not

to exceed 50 pg/rn3 annuallyN

ot

to

exceed

150 pg/rn3/24-hour period

Not

to exesed 0.12 pxn/hr

Not

to

exceed 0.03 ppa annuallyNot

to

exceed 0.14 ppu/24-hour period

Not

to

exceed

0.5

pxn/3-hour period

The NESHAP for arsenic benrene

and radionuclides are being reexamined

and

may

be revised as result

of July 1987 court ruling on

vinylchloride NESEAPs

The court required

EPA

to first consider only human health

in

determining sate level of risk

and only then consider costs end

technical feasibility

in

establishing an ample margin

of safety

NAAQS are translated into source-specific requirements

in State Implementation Plans SIPs

Chemical Name

TAI3LE

4-2

ContInued

SELECTED CHEMICAL-5pECtF POTENTIAL APPLABLE

OR RELEVANT

AND APPPrPnIr Dt fTOI

Requirements

cFrER 1- CLLkN AIR

ACT

SflAPS

Benzene

j/

-S

Prerequisites

for Applicability

No detectable emissions approximately

500

ppD

25 mrem/year whole body7

5 mrem/year

any critical organ

Citaion

Radionuc1ide

1/

Radon 222

Coke ovenemissions

Carbon monoxide

Lu

ad

Nitrogen dioxide

Particulatematter

Ft1

Ozone

Sulfur oxides

40

CFR Pert

61 CM

40

CFR Pert

61 CAA

40

CFR Part

40

CFR Part

40

FR Part

40 CFR Part

40

CFR Part

Fugitive leaks from equixnent containing

ioz

benrene

DOE facilities

NRC licensees

and non-DOE

Federal facilities except from doses fromradon220 rsdon222

and their decayproducts facilities re8ulated under 4

0

CFR

190192

and low-energy accelerators

and

users

of sealed sources

Elemental phosphorus

Uranium winesUranium mill tailings

Coke ovens

Major stationary

and mobile sources

Major stationary sources

Major atationary

end mobile sources


Major stationary

and mobile sources


61

CAA

61 CA.A

61

CM

61

CM

61 CM

40

CER Part

50

CM

40

CFR Part

50 CM

40

CFR Part

50 CM

40 CFR Part

50 CM

40

CFR Fart 50

CM

40

CFR Part 50

CM

TABLE

4-2 Continued

Protection

of

Drinking Water

Supplies fromRadioactivePollutants

Maximum Contaminant levels

for radioactivity

in

corimmity water system are

set

as follows

pCi/I

of combined radium-226 and radium-228

or

15 pCi/I

of gross alpha particle activity

including radium-226

but excluding radon

and

uranium

Applicable

to comwiity water systems which

are defined as public water systems that

serve at least

15 service connection usedb

y year-round residents or regularly serveat least

25 yearround residents

llu-i

Discharge

of

Radioactive

Pollutants to

Surface Waters

The average annual Concentration of beta particleand photon

i.e gama radioactivity from man

made radionuclides in

drinking water shall not

produce an annual dose quivalent

to

the total

body or

any internal organ greater then mrsm

Beet Available TechnoloAy

The concentration of pollutants discharged

in

drainage from mines that produce uranium ore shall

not exceed

10 pCi/I

of dissolved radium-226 in any

one

day

or pCi/I

of dissolved radium-226

averaged over 30 consecutive days

30 pCi/I

of total radium-226 in any

one

day

or10 pCi/I

of total radium-226 averaged over

30

consecutive days

nd

mg/I

of uranium in any

one

day

or mg/I

of

uranium averaged over

30 consecutive days

Applicable

to comunity water systems which

are defined as public water systems that

cccv

at least

15 service connections usedb

y year-round residents or regularly servea

t least

25 year-round reaident

Applicableto discharges

of radium-226

and

uranium from open-pit or underground mines

from which uranium radium

and vanadium

ores are produced including mines that use

in-situ leach methods

40

CFR section 141.16

SDWA

Clean Water Act

CWA

40

CFR section 440.33

CD

SEIECTED CHEMICAL-SPECIFIC POTENTIAL APPLICABLE

OR RELEVANT AND APPROPRWFE REQUIREMENTS

Chemical Name Requirements Prerequisites


CHAPTER Mk1AGfl4ENT

OP RADIQACIrVE

Safe Drinking Water Act

SDWA

40

CFR section 141.15

Protection of

Individuals in

Restricted Areas

i.e Workers from

Radiation Exposure

Protection

of

Individuals

in

Unrestricted Areasfrom Radiation

Exposure

variety

of different radiation exposure units

are

set

for individuals in restricted areas

including dose limit

of 1.25 rem/ quarter whichis

equivalent

to

rein/year

to the whole body

and

radioactivity concentration limits

for

air

and

water

in restricted areas designed

to limitworker exposures

to 1.25 rem/quarter

Radiation exposure

to members of

the public

is

limited to

whole body dose

of

0.5 rem/year

0.002 rem/hour

0.1

rem

in any consecutive days

and

The dose limits in 40

CFR Part

190

for

operations within

the uranium fuel

cycle

see Section 4.1.1.3

of Chapter

of Part

Applicable

to

all categories

of

NRC

licensees also applicable

to AgreementState licensees

Applicable

to exposures

to

sourcebyproduct

and special nuclear material as

well as

to NAR1 released from facilitieslicensed

to

possess source byproduct arid

special nuclear material

Applicable

to

all categories

of

NRC


to AgreementState licensees

Applicable

to

exposures

to

sourcebyproduct

and special nuclear material as

well as

to WARM released from facilitieslicensed

to

possess source byproduct

and

special nuclear material

Discharge

of

Rsdionuclides to

Unrestricted Areas

Air

and Water

Airborne

and liquid discharges

to unrestrictedareas shall meet radipnucljdpepecjfjcconcentration limits

in 10

CFR Part

20 Appendix

Table

II Thes concentrations are designedto

limit radiation exposure

to members

of

the publicto 0

.5 rein/year

to

the whole body bloodforming

organs

and gonads reins/year

to the bone

thyroid

and

1.5 reins/year

to other organs

Applicable

to

all categories

of

NRC


to

AgreementStat licensees

Applicable

to releases

of scurce byproduct

and special nuclear material as well as

to

NMUI rel.aeed from facilities lioens.d to

possess source byproduct

and special

nuclear material

10

CFR section 20106

AEA

TABLE 4.2 ContInued

SEIECTED CHEMICAL.SPECIFIC POTENTIAl APPUCABI

OR REEVANTAND APPROPRIATE REOUIREMENTS

-a



CHAPTER HANAZDIENT

OF RADIOACTTVE WASTE

Atomic Energy

Act

AEA

10

CFR sections 20.101

through 20.104

1OCFR section 20.105

AEA

TABLE

42 Continued

SELECTED CHEMTCAI-SPECIFC POrBfl1AL APPtJCABLE

OR RELEVANT

AND APPROPRLTE REQUIREMENTS



CflAPrER HARA IERT

OP RADIQACTVE WASTE

Radioactive Waste variety

of waste disposal requirements are

set Applicable

to

all categories

of

NRC

10

CFR sections 20.301

Treatment

and including those specifying

how licensees may licensees also applicable

to Agreement through 20.311

AEA

Dispoaal dispose

of licensed materiel

see Section 4.2.1.1

of Chapter

is of Pert II well as concentration

limits for diepoasl

of redioective waatp into

sanitary sewerage systems requirements

for

treatment

and disposal

by Incineration

and

apecific requirements

for

the disposal

of

radioactively contaminated animal tissue

and

State licensees Applicable

to releases

of

source byproduct

and special nuclearmaterial

Certain requirements also apply

to otherradioactive materials

i.e HARM released

from facilities licensed to possess source

10

CFR sections

20.302a

and 20.302b

AZA

liquid scintillation media byproduct

end special nuclear material

Control of Uranium Control measures shall be designed

to ensure that Applicable

to certain inactive uranium Uranium Hill Tailings

or Thorium Hill releases

of radon222 from residual radioactiv processing sites designated

for remedial Radiation Control

Act

Tailings material

to the atmosphere will

not exceed an

average applied over

the entire surface

of

the

disposal site

and over least oneyear periodrelease rate

of

20 pCi/mh/aec or increase

the

averag annual concentration

of radon222

in the

action under Title

of UMTRCA

see Chapter

for more detail

UMTRCA

40

CFR section

192.02b

atmospher

at or above any location outside

th

disposal sits

by more than

0.5 pCi/I

are considered high relative to recent

EPA standards

see discusaion in Section 4.21.1

of this chapter

JJi These dose limits

tnpj

TABLE 4-3

SEIECTED ACT1ON-SECIFIC POTNTIAI APPLICABLE

OR REEVANTAND APPROPRLkTE REQUIREMENTS

Action. Rquirements Fr.r.quisit.a

for AppLtcsbility

2g Citation

LI.x 8trdi CA.A requirements

to

hi provided

Cq

See also Closur with Wait

in Placs

for edditional

associat.d requirement.

P.acemsnt

of cap ov.r waits

e.g

closing landfill or closing surfac

icçouthnsnt

or waste

pil

as landfill

or similar action rsquirss cover

d.sign.d

end canatruct.d

to

Provid long-term minimization

of

migration

of liquid. throug1

the

capped .r.a

RA hazardous waite placed

at

ut after

the

.ff.ctiv

dat

of

the r.qu.irem.nts or placement

of hazardous waits into anoth.r tm.tt

wiU make

requirements applicehi wb.nthe waste

ii

beingcovered with c

ap

for

the parposs

of leaving

it

behind after

the remedyii

completed Cappingwithout such p.ac.ment wifl

not make

requirements spplic.bl.

40

CYR 264.228e

Surface Impoundznents

40

CFR 264.258b Waite

Piles

40

CF 264.310a

Landiill.s

Function with minimx maintenance

Prt drainage

and minimis sros

ion

or abrasion

of

the cover

Accodats settling

end aubsidsnc so

that

the covers integrity

is

maintained

end

Bay permeability less than or equal

to the p.xmeability

of any

botton

liner system or natural sub-soils

present

j/ Currently only

RA

CWA

and SDWA requirements

are included Additional action-specific requirements will

be added as additional statutes are

analyzed

k/ Action alternatives from

RCI keyword index FY1986 Record

of Decision Annual Retort January 1987 Razardou. Site Control Division

EPA

Requirements have been proposid

but

cot prcaonl.gated

for

air strippin hybrid closure gaa

collection

and miscellaneous unit treatuent Whttn

this regulation.s

axe pron.zlgated they will included

in th matrix

gi Sons action-specific requirements listsd m

ay

be relevant

and appropriate even

if RQA definitions

of storag disposal

or haze.rdous waste are

not

met

or

if the waste

at

hi

sit

is similar

to but

not identifiable as hazs.rdou.s waste

S. Chapter

for information on relevant

and

appropriate

RA requirement..

CD

tn

TABLE

43 Connued

Action. R.equirememt.s Prerequisites

for Applicability

JW Citation

Eliminate

tr. liquids stabiLize wait.

40

CYR 264.228a

bfors c.ppth5 surface inpotimdusnts

Restrict post-cLosure

use

of prOperty

as

necessary

to prevent d.ema8s

to the cover

40

CFR 264.117c

Prevent rim-on

end run-off frcc dema5in5

cover

40

CYP 264.228b

40

CFR 264.310b

Protect ms.ints.tn surveyed benchrksui.d to Locate waste cells landfillswaste piles

40

CFR 264.310b

C.asir with Po.t-CI.o.ure

Car

e.j Clean Closure

Genera performance standard requireselimination

of need

for further

maintenance

and control elimination

of

post-closure escap

of hazsxdons waste

hs.zardou.s constituents leachatecontaminated run-off

or hazardou waste

dsccmposition products

Applicab3.e

to

le4basedunit contanin6

hazardous waste Applicabl

to RA hazardous

wsst listed or characteristic placed

at site

after

the effective date

of

the requirements

or

placed into another unit

Not applicable

to

material treated stored or d.tspos.d only

before

the effective date

of

the

requirements

or

if treated in-situ

or consolidated within

area

of contamination Desi8ned

for cleanup

that willnot require lonterm mana5szsnt

Desi5ned

for cleanup

to health-based standards

40

CFR 26.111

Disposal or decontamination

of equipoent

structures

and soils

Removal or decontamination

of

aU waits

contaminated contaizznsnt system

conponents

e.j liners dikes

ccmtsminated subsoils

and structures

and

equipn.nt contaminated with waste

sad

leachate

and wena8emant

of them

hazardous waste

Kay appiy

to surface impournsnts

and containeror tank liners

and hazardous waste residues

end

to contaminated soil includlu soil fron

dxe4gin

or soil disturbed

in the course

of

drillth.5

or excavation

and returned

to land

40

CTh 264.111

40

CFR 264.178

40

CFR 264197

40

CFR 264288o1 and

40

CFR 264.258

Meet health-based levels

at unit

40

CFR 244.111

gi Sane action-specific requirements listed m

ay

be relevant

end appropriate even

if RA definitions

of storaS disposal

or hazardous waste a

re

not

met

or

if

the waste at

the site

is similar

to but

not identifiebie

as hazardous waste

See Chapter

for information on relevant

and

appropriate

RA requirements

CD

.0

SFCT ACTION-SPECIFIC POTENTIAL APPIICASIE

OR RELEVANT

AND APPROPRIATE RECUIREMENTS

Caçin5 continued

TABLE

4.3

Continued

SELEC ACflON-SpECJF POAi APPLICARLF OR

REt AffAD APPRppR RJREM

Action

Prsr.qizjsit. for 4plicabiljty

/g/

Citation

Ciosur with

lt PL EUa1ua fr. liquid

by ranov.J or Alicjl to

Land disposal

of hsza.rdos 40

264.2.282solidification

w.st..W 4licabl to h.azardo wait 40

CF 264.228a2list.d or Cb.aract.ristjc plac.d

at sit sft.r 40 CFR 264.258b

8tabjUt.jon of ranajnj waste

and

tb

effct.iv date

of

tb

requ.irsosnt orwaat residuss

to

support cover plac.d into anothar unit

$ot applicabl to

aat.rjaj tz.at.d stored or disposed onlyb.for th ffectjv d

at

of

the

requiran.rtsor

if

treated in-situ or conaoijdated wjthjar.a of ctaninujcInst.1.tion o

f find cover

to

provide

40

CFR 264.310lm-t.rmInig.tic of infi1t.ratiC

s. Cappinj

30-year post-cLos car

and g.rotd-

40 264.310water monitorin1.1/

Closur of

La4

Maximize dstaditi tranaformstj or Closur of land treatuant units 40 CFR 264.280ibjligatjon

of huardous catitu.t

within the treatmt son.1 ni.iso

ff

of conatjtu.cta Laint.aj rim-on

ctroL sys

tan

and run-off mana$anant

systan c3t.ro1 wind dispersal

of

hazardous wut.1 ms4ntsin unsaturateduitorjn establish ve$et.ativ

LII

cov.r

and establish background soil

vslu.s to determin cousistancy withpermit values

CaoUd within

jt

Noue applicabLe/ConaoUdtj within

yJ Ragiczjsj ackn.inistrator nay revise length

of post-cioa care period

40 264.117

TABLE

4.3

ContInued

With respect

to

the waits that

is moved

See Capping Closure with

see requirements

in the foll.owin$

WasteIn

Place Container

sections Cappins Closure with Waits

in Stora8e Construction

of

Place Containsr Storaie Construction

of

New Landfill On-Sit

Isw Land.filL On-Sit Construction

of

Construction

of

New

New Surface Io.mnent On-Sits

Surface Impouncent

Ckv

Incineration On-Sits Land Treatment Sits Incineration

On-

Operation

and M.s.intenancs Tank Storage Siti Land Treatment

and Treatment Operation

end Maintenance Tank Storage

and

Treatment

in this

exhibit

Storags

of hazardous waste listed or

characteristic

not nesting snaU quantity

ismerator criteria held

for temporary period

greater than

90 days before treatment disposal

or storage elsewhere

40R 264.10

in

container

is any portable d.vics

in which

material

is stored transported disposed

of

or

handled generator

who accti1atss or storse

hazardous waste on-sits

for

90 days

or less

in

compliance with

40

CYR 262.34Ca14

is not

subjectto jul.

RA storage rsquirweents

Smali quantity snsrators

ire

not subject

to

the

90

day limit

40

CFR 262.34cd

and

Cs

Closed during storags except

to

add

40

CFR 264.173

or removs waste

Inspect container storigs areas weekly

40

CFR 264.174

for deterioration

Place cont.athsrs

on sloped crack-free

bus

and protect from contact with

accuail.ated liquid Provide contaimaent

system with capacityof

10 percent

of

the volLan

of containers

of free liquids

Rvs spilled

or leaked waste

in

timely masr to

prevent overflow

of

the

containment system

LI

In many cases there are

no dsfinsd units at

C.A sits Inatsed there i

re areas

of contamination with diffsring concentration leve

including

hot spots

of hazardous substances pollutants

or contaminants

en

RA hazardous wastes axe moved into

or

out

of

an area

of

contamination disposal requirements

axe applicable

to

the waste being managed

and certain treatment storage

or disposal requirements such a

s

for closuxs a

re applicable

to

the area where

the waste

is received

SF1 FCTFI ori.rna sopi VAfli

ro

Di cuan Akin nD%nnATe tIflI arkrr

Actions Requirements Prsrsquisitss

for Applicability

/J Citation

ConsoLidation b.ti.sem Ckiita

Ztora3

tbvenant

of hazardous waste

and placement into

another unit

pç

CD

.0

111

u-I

-I

Containers

of RotA hazardous waste most

be

Maintained

in good condition

Cocrpatibls with hazardous waits

to

be

stored

and

40

CFR 264.171

40

CFR 264.172

40

CFR 264.17

TAflLE

4-3 Conrlnued

SELECTED ACTION-SPECIFIC POTENTIAL APPLICABLE

OR RELEVANT


Actions R.quirensnts Prer.qui.it.s

for Appl.icability Citation

ct

coutinuedK.ep containers

of ignitabl or reactive

waits at least

50 f..t fr the

facilitys property line

40

CFR 264.176

..p inccarçatthl.e materials separate

S.parate incpatible materials stored

near each other

by dike or other

barrier

40

CFR 264.177

At cloaur renove

all hazardous waste

md residu.s

trc

the otairisnt system

and decoutLnat or reemv

aU

containers liners

40

CFR 264.178

tEl

Stors8s

of bamisd waitis st

in

eccordsnc with

40

26$

scb

storage occurs b.yomd on year

the

cr.sier/op.rator b.ars

the burden or

proving that such storage

is

solely

for

th

purics

of sccszzil.ating sufficient

quantities

to allow

for proper recovery

treatment

end disposal

b/ Lax4f.ill %mits meeting

the r.quiremsnta

of

40 264.301f are

not subject

to minim technology requirements

40

CFR 268.50

.0

Ctruction of L.dfi11

iSita see Closure with

HinLD T.cbnolorv Reouirwxnti

RA

currently

hazardous waste listedbeing placed

in

or characteristic

40

CTh 264.301

replacement

or

Wait

in Place Install

two liners or more

top liner expanded landfiU

that prevents wuti migration into

the

Liner

end bott liner that prevent

wait migration throughthe liner.W

Install leachate collection systema above

end between

the liners

40

CFR 264.301

TABLE

43 Continued

SELECTFD ACTON-SPFCIRC POTENTtAL

APP

AB1

FOR RFtEVANT

AND APPROPALATE REQUIREMENTS

ActiooaR.quLzenta

Prerequisites

for Appl.iCaliLitY

jgi

Cit.it.ton

Cmstructi

of Lf4I1 Cstruct r

on

end xamoff contrOl

40

CF2

264 .301

i.e Closure with Waits

in

syt

oap.bte

of bandLin

th

p.sk

Place continued diacharie

of 257.sr storm

Cont.roi wind disp.rsal

of particul.t5i

40

CYR 264.301

Operation

and ma.intenCe

40

CYR 264.303304

C1se each eel. with final cover ait..r

40

CYR 264.310

the last wste

baa reosived

0O

Qptdwat.r P4mitorin

EstabliSh dstscUCE monit.OriD4 pro.r Creationof

new 1.indfiL1 emit

to treat store

40

CFR 264.91 264.100

264.98 Est.ibl.iih ocLtenCe

or dispose

of

RA hazardous wastes

as part

of

monLtoriZl8 prosren 264.99 response action

corrective acUon monitorini

F08

264.100 when required

by

40

CYR 264.91

LU mcnitorth5 pro5rs mast meet

sn.rai rowat.r nitoriU8

r.quireneflts 264.97

tn

Cczatuctj of zrfao

Iioit is

Closurs withWait in Plic a

nd Ciosur

with no PoatCiosur Cars

U.

two 11usrs top

mar that prsvitawait iaraticn into

th Unix and

bottc Unix that pr.vsnts waitsmixatic thrcuih

th

lthsr throujhout

tha

poat-cto.ur psrLod

Dsain Linars to p.vt failurs

du

to

prsssurs gr.dt.nts oitact with

ths

wait oiiatto cczdit.is

and

th

itr.ss

of instailation diLly

op.ration.RA hazardous wait list.d or charsct.rjstjc

curr.ntly bun8 pLscsd

in

surfsc.ioundusnt o

r us

of r.plscan.nt or Lstsra1

uxtansion

of aristin8 lsndfij.. or surfaca-nt.

h-ovid isachat coilot.ion sy.t.ab.tw.i th tw

o linars

40

CTh 264.221

U. l.sk d.t.ction .y.t that will

d.t.ct l...ks

at

th .arliut posithitims

round-wat.r I$nitorinz

Establish dstsctjcm monLtorjn3 progran264.98 Establish olLanoonitorin8 pro1r 264.99

and

corx.otiv aoUon onitorin program264.100 when r.quir.d

by

40 264.91A

U itorthi projr .t ms.t

RA

saj sroi.d-wst..r nLtorLn

r.quixwosnts 264.97

Cr.atjon

of n.w landfiU wait to

trsat stors

or d.tspos

of

RA hazardous wasts as part

of

ren.disl action

CD

I/

TABLE 4-3

Continued

SELECTED ACTION-S PECIFIO POTENI1AL APPLIOABLE

OR

flELEVANT

AND

ActionRaquizent.s Fr.r.qui.Lt.

for AppLtcsbility/g/ Citation

KinL T.crao1pzy R.autrenits

LII

40

CYR 264.220

40

CF 264.221

40

CFR 264.221

40

CFR 264.91264.100

TAULE

4-3 Condnued

________________________________________________FCTD ACTION-SPECIFiC POTEtflAI APPIiCABIE

OR REP/ANT

ANt APPROPRLTE REOUIREMENTS

tJ

ActioniPrerequtittis

for ApplicabiLitY

/./ Citation

Dike StobiLLT.4m Design

and operate facility

to

pr.vant Existini surface impotrident conta.tnin

40

CFR 264.221

ovsrtoppir4

due

to overfillini wind

and bzardoua waste or creation

of

n.w surface

wave aotion rainfall rton jounent.

malfmction5

of level controU.ers

alamns

and other .quiment

and tnan

error

Construct dikes with sufficient stranth

40

CFR 264.221

to pr.vant massiva failure

Inspect liners

and covur systana during

40

CFR 264.226

and after construction

Inspect weekly

for pxop.r operation

and

40

CFR 264.226

iuterity

of

the contairinant d.vic.s

Ranovs surface impoant fron operation

40

dR 264.227

if

the

dik leaks or there

is suddsn

drop

in liquid level

At closure

rvs

or decontaminate

.11

40 264.228

waste residues

and contaminated

materials Qthsrwis free liquids zi.st

be rvsd the ramainin wutes

stabilized

and

th facility closedin

the sane mimer

as landfill

tana4e i8nit.abls

or reactive wastes so

40

CFR 264.227

Ui

that

it is protected fras materials

or

conditions that

may cause

it to unite or

react

TA8LE

4-3

Condflued

POTFtTlAI APPUCAR1E

QR

VAwrAiipApppp1 REUIREfj1-$

Actjon

erjsjt for AppUcability

/.W

Cit.tjDipthi8 o

f tr..ta Dyitan Avej IsbiIfflTht

Us of b.st avsjl.bl t.co1oy SAl Foit source dtscbaxge

to water of

the Un.tted 40

CFR 122.44a

icaU.y acbi.vai

is

required

to Stat j/ j/Omotrol t.cxj

.x4 nmocvantjcal

pollut.a Use

of beat oomvtipOlltat omotrol tcoloy B

C La

r.qutr.d

to

cmotrol cmov.ntjmoalpoUutst.. Tacbnolcgrbu.d l.inLtatjm

ay

be d.tsmj.d m

o cas.-by-c.sbaai.

MIter OueItty 8t.andar

Applicable Federaliy Stat water

40 122

and Stat

quality standards moat

be

ccmpU.d with

reguLatimos approv

lb.. st.sndaxja may

be

in

acdftjmo to or

d.r

40 ci

131

more strjug than other Ysdsrsjstandard mdsr

tb 4A

kf

Discbag limjtatio most

be satabli

40 CFR 122.44

at more strLnge levels than teclsoogybu.d stand.r fo

r toxic pollutants

htt MnaMant Prsptft1

Dev.lop

and Le1ansit B.st Hsnag

40

dR 123.100

Practicea progrea

to

pr.vant

the relsasof toxic omostituant

to surfac waters

atr

of

the

U.S is dsnd broadly

in 40 122.2 and incinde .s.antiu w

at

bo and wetlandS.ctj 121

of SARA mo-sit aotivjtj. obtaining Eev.r th

e sstantjv r.quir of

law or reguistion most

be lu

particular -sit discharge tosurface waters a

re

er pet requis.1 Off-sit discharrs

ujd

be

rerjr.d

to

apply

for

and obtain an

IFD permit

Federal Water Quality Criteria may

be relevant appropriata dspandjn4 m

o

th

designated or potential use

of

the Water

the nodla effected

the

purposes

of

th

criteria

and currant LnfozLatj C4 1121d2gj Federal Water Quality Criteria for

the

protectimo

of aquatic life will

be

r.l.vent and appropriate itan envirctal factors

e.g

proteotimo

of aquatic organiana .rc being cousidered

30 30784 July

29 l983

TABLE

4-3 ConUnued

Action. R..quixenent$ Pr.r.quisit.s

for Applicability

/gJ Citation

D1p.dD.a18a

of Tr.at Syst

Tb Best Hana.genspt Practices progras Discharg

to waters

of

the

U.S

j/ 40

CF 125.104

Ifflant continued oust

Establish spicific procedure

for

the

control

of toxic

and hazardous

pollutant spill..

Include prediction

of direction

rat

of

fl

end total quantity

of

toxic pollutant-s where experience

indicates reasonable potential

for

.quipoant failure

Assure prop.r manag.oent

of solid

and

hazardous waste

in accordance with

regulations prczculgated under

t4zsitprthz Reciutrstnent4

Discharge oust

be itored to assure

40

CFR 122.41i

caapliance Discharge will monitor

The mass

of each pollutant

The voiDeD

of effluent

Frequency

of discharge other

measurements as appropriate

Approved test methods

for waste

40

CFR 136.1-136.4

constituent

to

hi itored must

be

followed D.t.ail.d requirementsfor

analytical procedures

end quality

controls re provided

Semple preservation procedures container

materials

end

m4 allowable holding

tines are prescribed

.IJ Section 1.21

of SARA .xempts onsite

LA activities iron obtaining permits Uowav.r

the substantive requirements

of

Law

or reutation oust

be mat

In

particular on-site discharges

to surfac waters are exempt iron procedural KPDES permit requirements Off-site dischergers would

be

required

to

apply

for

and obtain

en FIVES permit

CD

I-

SELECTED ACTION-SPECIEC POTENTIAl APPLABLE

OR RELEVANT

AND APPROPRVJE REQUIREMENTS

LI

TABLE 4-3 Connuod

Actions R..quixanants Prsr.qutsit.s

for AUcabiUty

5jg Citation

Diathar

of Trtit yvt

Cly with additional subatantiv

ff1 continu.d condition. such .1

Duty

to witigat any sdv.rs .ff.cts

of dtscharj

and

Propar ep.rst.ion maintananc of

tr.att syetDLr.ct Diadiax to O

o Dischar.s ouain wxsacnabi Discbarj

to

the naxin nviroxstit

JI

40

CFR 125.123bdairidation

of

ths .axin .nvixsct

axs

not p.xwitt.d

d.t.rminatjon of I.th.r d1.charg 40

CFR 125.122

will caua reasonable dsjxsdation

of

the

mann anviroant aat

be med based on

con.sid.nation

of

Quatlty ccoaition or p.nsistancs

of pollutant

to discbar.d

Pot.ntial txan.sport

of pollutants

by

biolo.jcal chemical or pbysical

prOC.ss.s

Ccmçosition

and vulnerability

of

spos.d cmiti.s

Importance

of

th

r.o.ivin water to

spemnini mt.nstory path.

end

surondLn biolo6ical ty

Exist..nc

of special aquatic sit.a

Impact

on huLan health

and csrcial

fisbin5

CL $403 r.quirss that an

NlD p.rmit

hi issued

for discbar.s into marine wat.rs inoiudin8 t.rritorial seas

he cont.i8uou gon

and

the

oc.ans

40 122.2 p.rnit

is not required

if

point

of discharj

is on-sit.

SELECTED ACTION.SPECIFIC POTENTIAt APPICARLE OR RELEVANT

AND APPROPRLjE REQUIREMENTSC

6

til01

40

CYR 122.41i

TABLE

4-3 Coninuod

Applicable r.qu.irecents

of

the Coastal

lots Kauagat Plan

Cs.

Vol

of

this nanuil szid

Harms Water Quality Crit.ria

d.v.1.psd mdsr

OA $304a1

Ccxzzply with

the limiting p.zmissible

ooncsntratiS LICe

at

the mixing ions

bowdari that ar ..tablished

in th

Discharge

of pollutants that passthrous.h

th ION without treatmt interfers

with

PON operation contininats

EON

sludge

or idanger bealth/safetl

of

EON

workers

is

prohibited

Specific prohibition preclude

the

discharge

of pollutants

to EONs that

Create firs or explosion hazard

in

the

EON

Will cause corrosive st.ruotura3 change

toPOT.I

cbatruct flow resulting

in

intsrfurance

Are discharged

at flow rats and/or

concentration that will result

in

interfsrlcce

ind

Increase

the tenp.ratuxe

of waste

water ant.rthg

the treathsnt plant

that would result

in int.rfsrsfloe

but

in uo case raise

the

EON influent

t.aç.rature above 104F

40C


OR RELEVANT


Action R.quirenanta Prerequisite

for Applicability

Citation

Direct Dircb.ar8S

to Oc.en

continued

40

CFR 125.123dl

is.axe to PthUcl.y

.d

Indirect dicbaxge

to

EON

40

CFR 403.5

tr..tect lzke P01W

otf

itt activity

see

footnote

Discharge

to POTWa

is considered

en offsite activity

i.e 3-21

for discussion

of requir.DeDts therefore requirecoenti

related

to dtachare

to POIW .rc

not AR.ARs

but

are included

in this eñd.bit

for reference Offsite actions

et conply with

all l.gsJ.ly applicable r.cjuirinint.5 bath

substantive

and sinistratiVI

The concept

of relevant

and appropriate

is not .vail1ble

for off-site actions

Lxi

Lfl

Diih.r8 to 1thijcyr.stcontinuid

Diath.ars

of Dr.d 7jlj

Hat.rjaj

to

lkt.ri

of

th

U.S or Oc.i Wutars

Dischax5 D.llt ccply with local

lO

pr.tr.atnt projr Lncludinj LOIWsp.cific pollutants spill prsvantionpror r.quirsnzt.a a

nd r.portinia

nd itorLnj rsquir.anta

p.xit-by-rul rsquiranta

ins inding oorxsetivs acticai wb.r

tb

DZS p.adt

wu issu.d aitsr Nov.er

1984 .zat oczzpU.d with

tar

discbax8

at hazardous wastas

to

IoWi

Tb four condition that

st

satisfi.d b.for dr.d .nd fill is an

allowsbl att.rnatjv ax

Thin .zst no practical

alt

mat

iv.

Transport

of

RA bazardua wait.

to POTWi by

truck rail or d.dicst.d pip

1..

pip

soisly d.dtcat.dfor haxaxdciis wait d.fjn.din 4

0 CFR 2643 which discbar8sa frca within

th

boundarj.s

of

tb sit

to within

tb

boimdariss of

tb POr4

Capping

dik stabilization constructic of

b.wxmand isv..

and disposal

of cont._inat.d

soil

wut nat.risl or dx.dsd at.rjsi ems

.xaql.s

of activitA. that may involve

dischaxjs

of dr.d8.d or fill m.t.ri.l

Lii

01

01

Discbsr5s

of drsd.d

or fill wat.rial

aist

not cauai violation

of Stat

wat.r quality stçd.xda vioLat any

applicab. toxic ftluant standardsj.opard.iz a

n dan.rd spsci.s or

injux mann sanctuary

No discbarj shallhi p.itt.d that

will Gauss or contribut to

sixificant dqradation

of

tb wat.

Appropriat st.ps

to m.iniolz adv.nssft.ct D.zat taksn

D.t.rmin lca4-

and short-tarn .ff.cta on

physical chsnical

and bioloiical

conpon.nt

of

tb

aquatic cosystmn

CD

-a

cJ

TABLE

4-3

Continued


OR RELEV A7D

APPROPRIATE REOJlREMJ-1

Actions R.quirsts 1r.r.quisjt.s for Appilcability C1ttjo

40

CFR 403.5 end local

IOV reulatjons

40

CFR 270.60

40

CFR

230

33

CFR 320330

CD

Dr.ding w.i.st With S.otion

10

of

the Rivsrs

and Eathors

Mt

and

U.S

Corps ig.ineSXI reulticms

vanant

of .xcsvated materials

to new

location

and pl.acanant

in or

on Land

wiU

trijer land disposal r.stxloUona

for

th excavated waste or closure

rsquirt$

for

the ixit

in ithich

the

waste

is beini placed

Area fron which materials are excavated

may require cisanup

to levels st.blisbed

by closure r.quixucents

CAA requiranents

to

be provid.d.1

Excavation

of

sot

for construction

of

slurry wall

may triusx closure o

r land

disposal restrictiofli

Analyze

the waite feed

Dispose

of

.11 hazardous waste

and

residues iuoludin

ash scrubber water

and scrubber sludje

Ho further requirements apply

to

incinerators that only burn wastes that

are listed as harardous solely

by virtue

of cocblnation with other wastes

and

if

the waste analysis duatrates that n

o

App.diXVII constituent

is

present that

mi8bt reasonably

be expected

to

be

present

hazardous waste placed

at

sit after

the

effective date

of

the requirements

or placed

into another imit

Dredini

in nivisble waters

of

the United

States

Materials ccntathin5 hazardous wast.a

subject

to Land disposal restrictions

axe placed

in another imit

Materials contathifl8 hazardous waste

subject

to land disposal raatrictions

are placed

into another tmit

RA hazardous waste

See Closure

in this

Exhibit

33 U.S.C

403

33

CFR 320-330

40

CYR

268 Subpart

See Closure

in

this

Exhibit

See Consolidation

in this

Exhibit

TABLE

4.3 Conflnued

SFLECTFD ACTON-SPECIFIC POTFNTtAI- APPL kABIE

OR RELEVANT

AND APPROPRLkTE REOUIRFMENTS

Actiou.s .quixements Prerequisites

for Applicability

Citation

Rval of

all contWsiuated soil

tj

Dr

xsivatizi

Cu ColL.ctix1

GroczxlWatr Diversion

Incineration

RA hazardous waste placed

at site after

the

effectiv date

of

the requirements

tnIt

40

CFR 264.341

40

CFR 264.351

40

CFR 264.340

ot russ. particulat

in

sxc.as

of

180 r/dac oorr.ot.d

for

of

0X7510

in StiOk gsa

Hitcrin.g

of various pa.ritsrs during

op.rsti

of

tb

incinerator

is

t.quir.dThus pax.t.rs inciud

Cuati tsp.r.turWait f..d

rat

indicator

of cothuaticn

vuLocityCarbcn noxids

CtroL fugitiv eissis ithsr

by

K.eping cuati zs s.elsd

Hatht.ainirig custi-gcn pr..iuxlow.r th atsi.rio pr.isur

Utilize autatic cutoff syst to

stopwaste f..d

ii

op.ratthg cditlind.vist.

TABLE 43 Continued

SELECTE ACTION-SPECIFIC POTENTIAI APPLICARLE OR flEE EVANT AND APPROPRIATE REQUIREMENTS

Action Raquirta Pr.r.qyiuit.s

for AppUcabiLtty I.gI Citatjm

Iiiratj continu.d Psrfoc

CD

tli

cbi.v destruction rs.ov.J

ffiei.ccy

of 99.99 p.rct

for ascb

principal orgic bizardouscouatitu.nt

in the waste t..d

99.9999 p.ro.nt

for dioxin

R.ô.sc qdrog.n chloride .issiczis to

1.8 kg/br or p.rc.nt

of

the

in

th stack gases b.fors snt.ringpoilution coutrol devious

40

CFR 264.343

40

dR 264.342

40

dR 264.343

40 CFR 264.343

40

CFR 264.345

t-

TABLE

4-3 Continued

FCT ACflON-SPECIF POTEWflAI APPtiCABIF

OR

RFI EVANT

AND APPROPRIATE RFOUIRFMENTS

Action-iR.quirinIotS

Pr.r.qutlttel

for AppUGlbil.itl sJ./

Citation

Incixrati ccntmuUSd Special p.rfoinCS .t..ndud

for

liquid

and n-on1.tquid

Fa

at ccintrti5

of

40

CFR 761.70

incineration

of PCSs

pm

or r.ater

AchieVe destruction

and rVal

fficianCl

of 99.9999 psrcant

Either second

eU tine

at 1200

d.5xe55

100

and p.rcint excess

in stack az

or

1.5 second

tin

at 1600 dsrees

and

peroant sxceiS

oan

in stack iu

0O

Per nontjc.aid PCBs mass

air

antision.5 iron

the incinerator ibsU

be no greater than 0.001

p.r

kg

of

tb antering

tb incinerator

La3d Trsat1t Prior

to 1.and treatment

the waste m.st

RA hazardous waste b.in8 tr.ated o

r pl..ced

treated

to EDAT levels

or nest no into another .mit

migration standard

ti

aure that hazardOus constituintlarI

40

CPR 264.271

degraded trsnsfoed

or LbiLized

within

the treatnant gone

depth

of treatnant zone ncst

be

40

CF

264 .271

no

ann than

1.5 m.t.ns feet iron

the

initial soil surfacs

and anne than

meter feet above

the s.uond high

water t.bL.

Danonstrat that hazardous conitituant.1

40

CYR

264 .271

for each waste

can

be conpietill

degraded tnsnifoed

or Lgznobiiized

in

the treatment zone

Minimize run-off

of hazardous

40

CYR 264.273

constituents

Maintain -on/rm0ff control

and

40

CYR 264.273

WinII gystan

ss

Special rsquiransnts

for init.abLs or

rasctivs waits

Special r.quirt for thcoatthl

Wast..i

40

CPR 264.278

40 264.281

40 CFR 264.282

sraticz Msintc

Flact of Liquid Wait in

Liffil

PLacit of Vast

in Ld

Di.posai tiit

Spsciaj tsstin

and loaitio rsquiran.ctsfo

r csrtain hazardous Wutis

30ysar post-closurs cars

to

ansurs thatsit

is

a.thtain.d

and nitorsd

Liquids in Landfill Prohthjtjon

Ko bulk or non-cofltain.rignd liquid

hazardous waits or hazardcia.i waste

contajnjn8

fr.

liquids

hi dispossdof

in

landfills

Ct.athsrs holdin1 free liquidsnotbe placed

in

landfill nlsss

the liquidis ix.d with a

n absorbant or soUdifisd

Land Disoospi Rsitrjctjc1

Attain land disposal treatnentstandards bsfors puttinj wuti intolandfill

in

ordsr

to cl.y with land

ban

rst.rjctjo trsatnan standard can

be siths.r conosnt.ration level to

bs acbi.vsd perfprano.bued or

specifi.d t.cboloy that anat

ha used

tlcbnoloy-bud

If the standard

is

psrfozancs-busd

any tiChnology can

be

usedto

achieve

the standard

S.

Treatcrt when Waits

wiU

be Land

Disposed

P1.acansnt

of bulk or floncofltatnsriged

hazardous waits in LandfiU

Placsoent

of hazardous waste

in

laadfiUsurface Lcodoen waits pile injection

weU

land treatnant facility salt dcs fozmatjon

salt

b.d fornation or tmd.rgrord nine or cave

TABLE

4.3

Continued

SELECTED ACToN.cPFtFr PTmAI ADDI VAbp fl

n.-

Action

tra.f ctjnusd

R.quirscnant.s

ROPRLTE REOJtRFMFj

Prerequisites

for

Applicabjl.jt.y

Special aUcation conditions if food-chain crops a

re

roa

in or

an treatcant

zone

Ci t.ation

40

CFR 264.276

waste P020 P021 7022 7023 7026 P027diaxjn-ccntainjn.1 Wastes

Land disposal closure

LII

01

40

CFR 264.283

40 CFR 264.310

40

CFR 264.314

40

Cia 264.314

40

CFR

268 Subpart

Ercivation

of soil

for construction

of

slurry wail may tri.r land disposal

restrictions

Prevent rim-on

and control

end collect

rirotf

fr 24-hour 23-year storm

waste piles land treatment faciLities

landfills

Prevent over-tOWlni

of surface

Tanks aist have sufficient structural

strecjth

to ensure that thai

do

not

cbU.apes rupture

or fail

Wait m..st

not inconpatthl.e with

the

tank mat.riel unless

the tank

is

prot..ctsd

by liner or

by oth.r miens

Tanks

st

be provided with secondary

containt

and controls

to

prevent

overfillini

and sufficient frssboard

maintained

in

open tanks

to prevent

ov.rtoppinl

by wave action or

pr.cipit.stion

Inspect

the followini overtiU..tni

control control .quipoect .itorini

data waste level

for uncovered tanks

tank condition sbove-roimd portions

of

tanks

to assess their structural

integrity

and

the aria surroimdiai

the

tank

to identity sins

of lsska8.

Rspatrany corrosion crack

or leak

Materials cont.ainLnA hazardous waste

subject

to Lend disposal restrictions

an placed

in another unit

S. Treatment section

for

LOR

schedule Also see Consolidation Excavation

sections

in this Exhibit

RA hazardous waste treated stored

or

disposed sitar

th ff.ctiv dateof

the

requirements

Storas

of

RA hazardous waste Listed

or

characteristic

not me.tin8 small quantity

ensrator criteria held

for temporary period

reater than

90 days before treatment disposal

or storaie eLseèers

40

CFR 264.10

in tank

Ci.e any portable device

in which material

is stored transported disposed

of or

handled 8enerator

who accianalates

or stores

hazardous waits onsite

for

90 days

or less

in

ccxnpliance with

40

CYR 26234al4 is n

ot

subject

to fuLl

RA storse requirements

iU

quantity 8eneratora

are

not subject

to the

90

day Limit

40

CIR 262.34cd

and

Ce

TABLE

4-3 ConUnued

SELECTE ACTiON-SPECIFIC POTENTiAL APPLICABLE

OR RELEVANT


LP

CD

-0

Actions Requirements Prerequisites

for AppLicabiLity

/g/ Citation

slurry Wail

Watar Crol

Store8 cka-Site

tIl

40

CFR 264.251c.d

40

CFR 264.273c.d

40

CFR 264.301c.d

40

CFR 264.221c

40

CYR 264.190

40

CFR 264.191

40

CFR 264.193194

40

CFR 264.195

40

CFR 264.196

Tuck 8tcr. i-3.ttcontthu.d

At cl.osur

rve

sit hazardous waste

hazardous waste residues fron tanksdiscbax control .quipe.nt

and

discharg confina.nt stxact.ures

40

CFR 264.197

-S

8tore ignit..bl.e reactive wait so

as

to

prevuct

th wait. frcu initLnj

or

r.sctth.i Ijnit.ahle

or rsactiv wastes

in covered tanks nat ccuzpiy with buff.r

zone reguirucucts

in 71

.t and

Custthl Liquid. Cods Tsbl.s 2-i

through

2-6 Istionsi

hr Protection

Association 1976

or 1981

St.orsz Prohibitions

40

CFR 264.198

Storag

of baed wastes w.ist

be

in

accordance with

40

CF

268

8uc such

storage occurs beyond

on year

the

o.esr/opsrat.or bears

the burd.a

of

proving that such storage

is

solely

for

the purpos

of aco1ating sufficiuct

quantities

to allow

for proper recovery

tzsatment

and disposal

40

CFR 268.50

in mit

tlj

U-I

tJ

D.sLgn

and operating standards

for

rit

in èich bazardons waste

is treated

See citations

at right

for d.sign

and

operating r.quirts for specific

emit

Treat.nt

of hazardous waste

in unit

40

CFR 264.190- 264.192

Tanks

40

CFR 264.221 Surface

Irçounn.nti

40

CFR 264.251 Wait

Piles

40

CFR 264.273 Land

Tr.atm.nt Unit

40

CFR 264.343-.345

Incinerst.-ors

40

CFR 264.601

Hiac.11.ansous Treatment

Units

40

CFR 265.373 Thermal

Treatment Units

4-3 Continued

SELECTEQ ACTION.SPECIEQ POTENTIAL APPLICABLE

OR RELEVMT


Actions Raquirucucta Prerequisites

for AppLtcshil..tty

/g/ Citation

TABLE .4-3 Coninued

Treatment

of Waite subject

to

ban

on land

disposal

nut attain levels achievable

by

best demonstrated available treatment

tedmoloiea BDAT

for sach hazardous

constituent

in each list.d waste

if

residual

is to be land disposed

If

residual

is to be further treated

initial treatment

and

any subsequent

treatment that produces residual

to

be

treated need

not

be UflAT

if it do.s

not

exceed value

in

JE Constituent

Concentration

in Waste Extract Table

for

.ach applicable water

S.c

51 40642

Nov.r 1986

Disposal

of contaaiinated soil

and debris

resulting from CL.A response actions or RCRA

corrective actions

is flQ subject

to land

disposal prohibitions and/or treatment standards

for solvents dioxin-

or California list wastes

until November 1990

and

for certain first

third wastes until Au5ust 1990

All wastes liited as hazardous

in 40

CFR Part

261

as

of November 1984 except

for spent

solvent wastes

and dioxin-containini wastes

have been ranked with respect

to vulme

and

intrinsic hazards

end

are scheduled

for land

disposal probthition and/or treatment standard

det.rminations as follows

40

CFR 268.10

40

CFR 268.11

40

CFR 268.12

40

CFR 268.41

40

CFR

268 Subpart

51

FR 40641

52 25760

Solvents

end dioxins

California list wastes

.-thirdof

all ranked

and

hazardous wastes

Underground injection

of

solvents

end dioxins

and

California list wastes

response action

and

corrective action soil

and debris

Two-thirds

of

aU ranked

and

listed hazardous wastes

All remaining ranked

and

listed hazardous wastes

identif

ted

by cbaxscteris

tic under

RA section

3001

Any hazardous waste listed

or identified under

R%A

section 3001 alter

November 1984

SEECTED

ann v-AOl

rn

nil vAlrr AHfl APPPPRIATF RFOtJIREMENTS

Treetmaut

em Wast. will

be

Lwxl Disposed

Actions Requirements Prerequisites

for Applicability

// Citation

Nov 1986

July 1987

Aug 1988

Aug 1988

Nov 1988

July 1989

Kay 1990

Within

mos

of

the date

of

identification

or listing

LII

01

jJ

Trstent liszt willLend Dispo..d continu.d

arrtw1 In3ectLm

of

Wsst.

x1 Tx.at.d

BflAT standards for sp.zit solvent wastes

and dioxin-containing wastes are based on

one

of four t.cmologies

or cinatiocs

for wasti waters st..an stripping

biological trastent or carbon

absorption alon or

in conbination with

or

23

and

for

all other wastes

incinaratlon

Any t.cboo1o nay

be

used bow.vsr

if it will achieve

th

concentration levels specified

UIC progran prohibits

Injection activities that allowonveosot

of contaninants into

d.rgrotd sources

of drinking water

which nay result

in violations of

PC.

or adversely affect. health

Construction

of

new Class

IV wells

and operation

and maintenance of

existing well.

Approved

UIC progran

is

required

in Stateslisted .n2d.r section 1422

AU States

have been listed Class wells

and Class IV

w.ll.s axe

the relevant classifications

for

C.A sites Class well .rc used to inject

hazardous wute beneath

the low.ucost formation

containing within one quarter

nil

an

id.rgrzd source

of drinking water USDW

ClassIV wells a

re used to

inject hazardous or

radioactive wait into or above formation

which contains within on quarter mile

of

the

well an gdergro.md source

of drinking water

40

CFR 268.30

RA Sections 3004d3

e3

42 U.S.C 6924d3

.3

CLass

IV wells are bazed except

for

reinjecticm

of treated $romd water into

the

san foation fron which

it

withdrai as part

of

CA cleanup

or

RA corrective action

40

CFR 144.13c

An undergxomd source

of drinking water

UW is

non-exanpted aquifer or

its

portion which supplies any public water systan or

which contains sufficient quantity

of grotnd water

to

supply piblic water systen

and currently supplies drinking water

for h.men conszDption or

contains fewer than 10000 ng/l t.otal dissolved solids

40

CFR 144.3

CD

TABLE 4-3 Continued

SELECTED ACTION-SPECIFIC POTENTIAl APPLICABLE

OR RELEVANT AND APPROPRIATE REQUIREMENTS

Actiors R.equiranents Prerequisites

for Applicability

/W

Citation

40

CFR 144.12

40

CFP 144.13

-I

TARL.E

4-3 Continued

SELECTE ACT1ON-SPECIF POTENTiAL APPI CABLE

OR RELEVANT


ActionsR.qui Pr.r.quisit.ss

for Appl.icahiLitY

/.J Citation

Lk4sI.IrOd Inj.ctii

of

The Dir.ct.or

of

th

UIC pro$x

in

40

CT 144.16

Wast.ew Treat.d stat.

a7 lessen

the t.rinanCi

of

40

Cl

%4at.ar continued 144.52 con_atruoti ap.rstLa2

.anifsstifl1 reçuirets

for well

if

inj.cti

do.

not

00

cur into throu5b

or abovs

tW or

if

th redius

of

endsn$erin$ influence

ass

40

Cl

146.060

is

Is. than

or equal

to tb

radius

of

th well

Report naioai4-ian5 orally within

24 Class w.Lla

40

Cl 144.28b

hours

40

Cl 144.51b

Prepare Ea.iDtain

and c1.y with

pluuin$

and sb.n1-t plan

Piccitor Class wells

by Class walls

.rc used

to

inject hazardous

40

CFR 144.2881

waste beneaththe lowsost formation

frequent analysis

of injeot.icc fluid ccctaInini within c

c quart.sr mile

an

wderiXouDd source

of drinkin8 water

US

continuOus mccitorin$

of inj.cucc

prss.uZe flow rats

ar4 vots

th.tattti

and .it4rifl$

of xomd

water nit.orifl1 waLls

Applicants

for Class permits anat

40

Cl 144.55

Identify

all thject.icc wells within

the area

of review

Task action as neosasaXy

to ensure

that such well ax properly sealed

cccçletad

or .hsndond

to prevent

conteniflatiOmof

UI

Crit.ria

for d.t.xinifl$ ièeth.r a

n

40

CYR 146.4

aquiferbe d.t.rmined

to

be en

ei

tad aquifer include currant

end

futureuse yield

and wst.r quality

characteristics

Pc-

Conduct appropriat drillin

1os

and oth.r t.sts rin$ construction

40

CFR 146.12d

Inj.ction pr.ssur

nay

not exceed

maxi level desin.d

to

ensure that

inj.ction

do not lnitiat n

.w fractures

or propa4at .xist.inj ones

and cause

th

novanant

of fluids into

UW

Continuous nonitorin

of injection

pressure flow rate

and volos

and

smual pressur

if

required

Dscnonstration

of nechanical intesrity

is

required every years

Ground-water gzmitorinj

nay also

requir.d

40

CFR 146.13

Conply with Stats underground injection

40 CFR

147

requirwnsnta

Hazrdoua wast

to be injsct.d

is

subject

to land

ban regulations

S.c section

4.2.2.1

of this nanual Treated ground

water that metsth definition

of

hazardous westand

is to

be injected

also

is

subject

to Land

ban regulations

TABLE

4-3 Condnuod

SELECTRD ACTION-SPECIFIC POTNT1AL APPI CABIF

OR

REt VANT A

ND APPROPRLATE REOJIREMFWrS

kxi.rr Injection

of

West. Tr..t.d oia4Wetar continued

Actions R.quiraneota Prerequisit.s

for AppLicability

gj/ Citation

Cas

and cansnt al.l Class wells

to

prevent novenant

of fluids into

UW

takln.g into consideration well depthinjection pressure bole u

se

conposition

of injected casts

and other

factors

S. above 40

CFR 144.28.1

Ll

01

40

CFR 268.2

Lxi

-l

0\

_1

TABLE

4-3

Continued

Wait into wsat

pit .u1j.ot

to Land

ban rsiulations

a. App.ndix

of this

anua1

40

CFR 268.2

SELECTR AC11ON-SPECIFIC POTENTIAl APPUCARLF

OR RFtEVANr4n APPROPRtATE REOUIREMErs

Wait

L1

Actions RaquLan.ct Pr.r.qui.it.s

for ApplicabiLity

/g/ Citation

U. sinl Lin.r a

nd t.scbat

coUsotion .7st

RA hazardous wasta non-contath.riz.d

acctIation

of solid nonflaabl hazardous

waste that

is u..d

for tr.atcant or stora8.

40

CFR 264.251

TABLE

4-3 ContInued

Incineration

general

Statutory

Gas

Turbines

Storage

of Petroleum

Liquids

Particulate emissions shall

be Less than 0.08

grains per

dry standard cubic foot corrected to

121 carbon dioxide

Standard

for

NO emissions

SO2

emissions shall be less than 0.0151

by volume

at

151 oxygen

and

on

dry basic

Floating roof vapor recovery system

or their

equivalents

Incinerator burning solid waste more than

501

of which

is

municipaltype wastefor

thó purpose

of reducing waste volumeby

removing combustible matter

Stationary

gas turbines with load heat input

equal

to or greater than 10.7 gigajoulee per

hour based on

the lower heating value of

the fuel fired

Storage vessel constructed after 6/11/73

and

prior

to 5/19/78 having storag capacitygreater than 40000 gallons storingpetroleum liquids with vapor pressure equal

to or greater than

1.5 psia

Floating roof or vapor recovery syatem Storage vessels constructed after 5/18/78

having storag capacity greater than 40000gallons storing petroleum liquids with

vapor pressure equal

to or greater than

1.5

pals

40

CFR aection 60.112a

CAA

lxi

IsOD

CHAPTER TOXICS/PESTICIDES

.1

Bulk storage requires

the preparation

and implementation

of an SPCC Plan

see

40

CFR section 76l.65c7ii for specifications

of container sizes

that are considered bulk storage containers Substantive requirements

may

be ARARs

if

bulk atorage

is

performed onsite

SELECTE ACTON-SPECFIC PbTENTIAL APPLICABLE

OR RELEVANT

AND APPROPRLATE REQUIREMENTS

CHAPTER CLEAN

AIR

ACT

Now Source Performance

Standards

Action Requirements Prerequiaites


40

CFR

CAA

40

CFR

CAA

40

CFR

CAA

40

CFR

CAM

aection 60.52

section 60.332

section 60.333

section 60.112

PCB Storage Prior to All Storaae Areas

1/

Di6posalStorage facilitiea must

be constructed

With an adequate roof

and walls

With floor

and curb

of impervious

materialsWithout drain valves floor-drainsexpansion Joint sewer lines o

r other

openingsAbove

the 100-year flood water level

Storage

of PCBe

at concentrations

of

50

or greaterand

ICB items with

PCB

concentrations

of

50 ppn

or greater

Toxic Substances Control

Act ISCA

40

CFR section 761.65

TABLE

4-3 Condnued

______________________

PCB articles

and equipnant that are

non-leaking

Leaking articles

and equinent placed

in

non-Leaking containers

PCB containers containing non-liquid

PCBs such as contaminated soil ragsdebris

Liquid

PCB containers containing PCBa

between 50-500 pçm

it covered

by

spill prevention control

and

countermeasur plan

40

CFR

TSCA

No item

of movabl .quipn.nt used to hendis PCBs 40

CFR

that comes into contact with FCBs shall

be moved TSCA

from

the storage area unless

it has bean

decontaminated under section 761.79

ALL stored articles must

be checked

for leeks

every

30 days

PCB Storage Prior to Containers must

be dated when they are placed

in

Disposal storage

All

PCB articles or containers must

be removed

and

disposed

of within year

of storage

40

CFR sections 76165

and 761.180 TSCA

CBAPT TOXICS

AND PESTICTDS

SEIECTED ACTON-SPECIF POTENTIAL

APP

OR RELEVANT


PCB Storage Prior to

Disposal continued

Action Requirements Prerequisites


Temporary Storage

30 days or less

Temporary storage

up to

30 days from

the date

of

initial storage need not comply with abov

storage regulations

for

the following items

00

All Storage Areas

Storag area must be properly marked

40

CFR section 761.65

TSCA

section 76165

section 761.65

section 76165

section 761.65

section 761.65

40

CFR

TSCA

40

CFR

TSCA

40

CFR

TSCA

TABLE

4-3 Condnued

SELECTED ACTION-SPECIFK IkTENTIAL APPLICABlE

OR RELEVANT

AND APPROPRIATE REQUIREMEN1

Act.ion Requirements Prerequisites


CHAPTER TOXICS AND PESTICIDES

Incineration

of Combustion requirements Incineration of liquid PCBs at

iO CFR section 761.70

Liquid PCSs concentrations

of

50 pçm

or greater jless TSCA

Either specified

in 40

CFR section 761.70

2-second dwell time

at 1200

100C and percent excise oxygen

in

stack gas

or

1.5 second dwell time at 1600

and

percent excess oxygen

in stack gas

Combustion efficiency

of at Least

99.9999 percent

Rate

and quantity

of FCBs

fed

to

the

combustion system shall

be measured

and recorded at regular intervals no

longer then

15 minutes

Temperature

of incineration shall

be

continuously measured

and recorded

Flow of FCBa to incinerator must atop

automatically whenever

the combustion

temperature drops below specified

temperature

An approved incinerator under section 761.70 can

be used to destroy any

concentration

of PCBs hish-effictency boiler approved under section

u-i 761.60a2iii c

an

be used for mineral

oil dielectric fluid from PCBcontemineted electrical equipment containing PCBs in concentrations greater

than or equal

to

50 ppc

but less than

500

ppm

and RCRAapproved incinerator under RCRA 63005a can

be used

for FCBs that are

not subject

to

the

incineration requirements

of TSCA

i.e

at concentrations lass than

50

pxx Except as provided

in section 761.75bii liquid PCBs shall

not

be

processed into non-liquid forms to circumvent

the hightemperature incineration requirements

of section 761.60s

iVpç

-a

TABLE

4-3

Continued

Whenever

the incinerator

is

incinerating PCBs

the

02 and

CO

levels must

be

continuously checked

CO2

must

be periodically checked

Water scrubbers must

be used

for

HCI control

40

CFR section 761.70

TSCA

Incineration

of Non-

Liquid PCBs

PCB

Articles

PCS

Equipiient

and

PCB

Containers

Treatment standards under RCRA land disposalrestrictions LORs

incineration or

burning

in

high efficiency boilers

Same as

for liquid PCBs

Mass

air emissions from

the incinerator shall

be

no greater than 0.OOlg

PCB

per

kg

of

the PCBs

entering

the incinerator

Incineration of liquid PCBa under

the

California List Waste land disposalrestrictions assuming that H

OC wastes are

mixed with RCRAlisted or characteristic

waste

and total

HOC concentration

is

equal

to or greater than 1000 mg/kg

or

PCB

concentration alone is 50

Incineration

of non-liquid PCBs

PCB

articles

PCB equipcent

and

PCB containers

at concentrations

of

50 or greater

unless specified

in 40

CFR section 761.60

Ui

Monitoring

is required

Same as

for liquid ECBs Incineration

of non-liquid PCBs regulated as

ROCs under

the California List Wastes land

disposal restrictions provided that

HOC

wastes ar mixed with RCRA-ljsted or RCRA

characteristic waste

and total HOC

concentrations equal

to or greater than

1000 mg/kg

40 CFR sections 761.70

and 761.180 TSCA

40

CFR section 268.42

RCRA

The incineration requirements

of

40

CFR Part264 Subpart

and Part

265 Subpart are listed

in Exhibit

1-3

of Part44

and 1-45

of this GuIdance pp

1-

Incineration of non-liquid PCBs can only

be carried out

in TSCAepproved incinerators under section 761.60 which may

be used to destroy any

concentration of PCBs

SELECT ACTION-SPECIFIC POTENTIAL APPLICABLE OR RELEVANT AND APPROPRIATE REOUIRFMENTS



CHAPTER TtiCS ANT FESTICDES

Incineration of Monitoring must occur 40

CFR section 761.70

Liquid PCBs ISCAcontinued When

the incinerator is first used or

modified monitoring must measure

for

CO

C02 Oxides

of Nitrogen

Ed

RCI PCBs Total Particulate Matter

Resource Conservation

and Recovery

Act RCRA

40

CFR section 268.42

40 CFR section 761.70

TSCA

40

CFR section 761.70

TSCA

TABLE 4-3 Condnued

SELECTED ACT1ON.SPECIFIC POTENTIAL APPUCABLE

OR RELEVANT AND APPROPRIATE REQUIREMENTS



CflAPTER TOXICS

AND PESTICIDES

Chemical Landfilling

of PCBs

Landfill must

be located

in thick relativelyimpermeable soil formation o

r on soil with high

clay

and silt content with

Soil thickness

of feet or compacted

soil liner thickness

of feet

ermeability cm/sec less than 1x10

Percent soil passing

No

200 sieve

greater than

30

Liquid limit greater than

30

Plasticity Index greater than

15

Synthetic membranes must

be used when landfill

conditions cannot fulfill permeabilityrequirement

Disposal

of PCBs

and

PCZ Items in chemical

waste landfill

Mineral

oil dielectric fluid from

FCB

contaminated electrical equipnentor

other liquids containing PCBs at

concentration

of

50 ppn

or greater

but

less than

500

pxn

Nonliquid ICBs

at concentrations

of

50

or greater

40

CFR section 761.75

TSCA

40

CFR section 761.75

TSCA

Avoid placing landfill

in

floodplain shoreline

or ground-water recharge areas

and below

the

historical high ground-water table

40

CFR soction 761.75

TSCA

Provide surface-water diversion dikes around

the

landfill

if the site is below

the 100year

flood-water elevation

Provide diversion structures capable

of diverting

all surface water from 24-hour 25-year storm

Locate landfill

in an area

of

low

to moderaterelief

Monitor ground water

and surface water in

disposalarea prior

to

building landfill

Sample surface-water courses designated

by the

Regional Administratorat least monthly

Analyze

all samplesfor

the following parameters

PCBs

pH

Specific conductanceChlorinated organics

40

CFR section 761.75

TSCA

40

CFR section 761.756

TSCA

40

CFR aection 761.65c

TSCA

.f

PCB Transformers

small capacitorsconcentrations o

f

other

PCB articles

PCB

and

PCB containers

at

500

pp

or greater

tj01

Action

CflAPT TTCS AND PESTICfl

Chemical Landfilling Install 3.eachate monitoring system

of PCBs continued

Place containers

in Landfill without damagingother containers

Segregate

PCB wastes from wastes

not chemically

compatible with ECBs

Mark ing

of PCBs

The following must

be marked as designated

in 40

CYP section 761.45

PCB containers containing greater than

50 PCBa

PCB transformers

PCB

Large High-Voltage Capacitorsequixcent containing

ECB transformer

or

FCB Large HighVoltage Capacitor

FCB Large Low-Voltage Capacitor

at

time

of removal electric motors using

PCB coolants hydraulic systems using

PCB hydraulic fluid heat transfer

systems using FCBs PCBartiol.containers containing

any

of

the

above storage areas used

to storePCBs

and

PCB items

for disposal

All marks must

be on exterior

of

PCB container

and

must

be clearly visible

Disposal Unacceptable disposal methodsPesticides

Those inconsistent with label

Open dumping

Open burning

Disposal into any body

of water

Those inconsistent with applicable

law

Incinerate pesticideat specified

temperature/dwell time that will ensure that

all

emissions meet requirements

of

CAA relating

to

gaseous emissions

40

CFR section 761.757

TSCA40

CFR section 761.758

TSCA

40

CFR section 761.758

TSCA

40

CFR section 761.40

TSCA

40

CFR section 761.40

TSCA

Federal Insecticide

Fungicide

and

Rodenticide

Act FIFRA

40

CFR section 165.7

40

CFR section 165.8a

FIFRA

Cfl

CD

TABLE

4-3 ConUnued

SFLFCTRD ACTION-SPECIFIC POTENTIAL APPLICARIF

OR RELEVANT ANOAPPROPRLATE REOUIPEMENTS

Requirements Prerequisites


tn

PCB article described

in 40

CFR section

761.45

Incineration recoarnended

of organic

pesticides except organic mercury leadcadmium

and areenic

TABLE

4-3 Condnued

Dispose

of liquids sludges or solid residues

generated

by incineration

in accordance with

applicable Pedaral State

and local pollution

control requirements

If incineration facilities are

not available

dispose

of pesticides

by

Burial

in designated landfill

Chethical degradation

and burial

Storage

Well injection

if all other

alternatives are more harmfuL

to

the

environment

Chemically

or physically treat pesticides

to

recover heavy metals then incinerate

the

pesticides

in

compliance with

CAA

Incineration recomended

of

metallo-organic pesticides except mercurylead cadmium

or arsenic compounds

40

CFR section 165.8b

FIFR.A

If

appropriate treatment

and incineration a

re

not

available

the pesticides

may

be

Chemically degraded

and buried

Stored

Injected into

the ground only

if there

is no alternative offering more

protection

to

the nvironment

Chemically deactivate pesticide

and recover

the

heavy metals

If chemical deactivation facilities

are

not available encapsulate

the pesticide

and

bury

it

Treatment recoxcended

for organic mercury

40

CFR section 165.8c

lead cadmium arsenic

and

all inorganic

pesticides

CHAPTER TOXICS

AND PESTICIDES

SELFCTH ACTION-SPECIF1C POTEN11AL APPUCARLE

OR RELEVANT


Di5posal

of

Pesticidescontinued



40

CFR section 165.8aFl

ERA

LII

Store pesticide

if neither deactivation nor burial

are available

iABLE 4-3 Continued

SELECTE ACTION-SPECIF POTEtAL APPUCABLE

OR RELEVANT

AND APPROPRIATE REOUIREMEIffS

CDAPTER TUXICS

AD PESTICIDES

Disposal

of

Pesticide Containers

and Residue

Non-combustible containers must

be

Triple-rinsed

Returned to

the pesticide manufacturer

for reuse

it in

good condition

Returned

to facility

for recycling

as scrap metal

if in

poor condition

Triple punctur containers

to facilitate drainage

and dispose

of

in sanitary landfill

Combustible containers that formerly held

organic or metallo-organic pesticides

except organic mercury lead arsenic

and

cadmium

Noncombustible containers that formerlyheld organic

or metallo-organic pesticides

with exceptions noted above

Combustible

and non-combustible containers

that formerly held organic mercury leadcadmium o

r arsenic or inorganic

pesticides

Labeling requirements

may apply when

pesticidesare considered products

and

not

RCRA hazardous wastes

40

CFR section 165.9b

Fl

FRA

40

CFR sectIon 165.9c

FIFRA

40

CFR section 162.10

Fl

FRA

Warnings

and precautionary statements

Toxicity

tlandling

of

Pesticides

Directions

for

use including storage

and disposal methods

Individuals handling certain pesticides mustbe

State- or Federally-approved applicators

40

CFR section 171.4

FIFRA



Cs

Incinerate or bury

in

designated landfill 40

CFR sectIon 165.9a

FIFRA

Labeling

of

PesticidesLabel pesticides legibly

and prominently

to

show

Ingredients

LrJ

31

Discharge

of

Radioactiveollutants to

Air

Discharge

of

RadioactivePollutants tu

Surface Waters

Airborne emissions shall not cause members

of

the

public

to receive doses greater than

25

Lnrem/yr

to

the whole body or

75 mrem/yr

to

the critical organ

Best AvaiLable Technology

The concentration

of pollutants discharged

in


not exceed

10 pCi/I

of dissolved rsdiumZZ6

in

any

one

day

or pCi/i

of dissolved

radium-226 averaged over

30

consecutive days

30 pCi/I

of total radium-226

in any

one

day

or

10 pCi/I

of total radium-

226 averaged over

30 consecutive days

and

mg/I

of uranium

in any

one

day

or

mg/i

of uranium averaged over

30

conecutivo days

Best Practicable Control Techoogy

The concentration


in

drainage from mines from which uranium radium

and vanadium ores are produced shall

not exceed

the same concentration criteria noted above

for

the Best Available Technology

Applicable

to airborne emissions from

DOE

NRC-licensed

and nonDOE Federal facilities

during their operational period

Not

applicable

to doses caused by radon220

radon-222

and their respective decay

products facilities regulated under40

CFR

Parts

190

191

or

192

and lowenergy

accelerators

and users

of sealed radiation

sources

Applicable

to dischargesof radium-226

and

uranium from open-pit or underground mines


and vanadium

ores are produced incling

mines that use

insitu leach methods

Applicable

to discharges

of radium226

and

uranium from open-pit

or underground mines


and vanadium

ores are produced excling

mines that use

in-situ leach methods

millirem mrem 0.001 rem where r

em

is measure ofdose equivalence

for

the biological effect

of radiation

of different types

and energies

on peopie

Lead agencies are cautioned that

the radionuclide NESRAPa a

re being reexamined subject

to voluntary remand

and that they

may

be revised

in

the

future

curie or

Ci

is the amountof radioactive material that produces

37 billion nuclear disintegratione

per second picocurie

or

pCi

is

equal

to io-12 curies

TABLE

4-3 Connued

SELEC1H ACTON-SPECIFIC POlE WTIAL APPliCABLE

OR RELEVANT

AND APPROPRLJE REQUIREMENTS

CflAPTER HANAT OP RADIOACTiVE WASTES

tJ1

tJ

Ui



iii

Clean

Air

Act

CAM

40

CFR

Pt

61 Subparts

and

Clean Water Act

CWA

40

CFR section 460.33

40

CFR section 440.32a

C%A

TABLE 4-3 Continued

SELECTS ACTION-SPECIFIC OTENT1AL APPLICABLE

OR RELEVANT

AND APPROPRLTE REOUIREMENTS



CUAF HARA3flENT

OP RADIOACTIVE WASTES

Discharge

of

RadioactivePollutants t

o

Surface Waters

continued

Best Practicable Control Technology

The concentration

of pollutants discharged from

mills shall not exceed

the concentration criteria

for radium-226 noted above

for

the Best Available

Technology

Applicable

to mills using

the acid leach

alkaline leach or combined acid

and

alkaline leach process

for

the extractionof

uranium radium

and vanadium including

mill-mine Cacilies

and mines using in-situ

leach methods

40

CFR section 440.32b

CWA

New Source Performance Standards

I-

The concentration


in mine


not exceed

the same concentration criteria noted

above

for

the Best Available Technology

There shall

be no discharge

of process wastewster

to navigable waters

Applicable

to discharges

of rsdium-226

and

uranium from open-pit

or underground mines


and vanadium

ores are produced e1qluding mines using

in-

situ leach methods

Applicable

to dischorges

of radium-226

and

uranium from mills using

the acid leach

alkaline leach

or combined acid

and

alkaline leach processes

for

the extraction

of uranium

and from min

and mills usingin-aituleach methods

40

CFR section 440.34a

40

CFR section 44034b

CWA

LII

31

Discharge

of

Radionuclidea to

Unrestricted Areas

Air

and Water

Airborne

and liquid discharges

to unrestricted

areas shall meet radionuclidsspeoificconcentration limit in

10

CFR Part

20 Appendix

Table

II These concentrations it designed

to

limit radiation exposure

to members

of

the public

to

0.5 rem/year

to the whole body bloodforming

organs

and gonads rams/year

to

the bone

xjd

thyroid

and

1.5 rems/year

to other organs

Applicable

to

all categories

of Nuclear

Regulatory Coaxaission

NRC licensees also

applicable

to Agreement State licensees

Applicable

to releases

of source byproduct

and special nuclear material

as well as

to

naturally occurring

and acceleratorproduced

radioactive material NARM released fromfacilities licensed to

possess source

byproduct


Energy

Act

10

CFR section 20.106

i/

Applicable only

to vanadium byproduct production from uranium ores

These dose limits are considered high relative

to recent

EPA standards

see discussion

in Section 4.2.1.1

of Chapter

of Part

II

Section 104a3A of CERCLA as amended

by SARA prohibits respons

to releases

of naturally occurring substance

in its unaltered form or

altered solely through naturally occurring processes

or phenomena from location where

it is naturally found HARM possessed

and used

by nuclear

material licensee

in almost

all cases would

not qualify

as naturally occurring substance as

it is defined

in this section.

These standards are potentially applicable only

for CERCLA actions

at sites licensed

by

the

NRC

but

may

be relevant

and appropriate

to

radioactively contaminated sites not licensed

by

the

NRC

Corrective Action of

RadioactivelyContaminated GroundWater

Radioactivity concentration limits

for

radium and gross alpha particleactivity a

re added to Ta of

40

CFR section 26494 and

Detection monitoring programs requiredunder section 26498

to

establish

the

standards required under siction264.92 shall b

e compleqd within on

year

of promulgation

If the ground-water atandards established under 40

CFR section 192.329a2 a

re exceeded

at

licensed site corrective action program as

specified

in 40

CFR section 264.100 shall

be put

into operation as soon as

is

practicable

and

in

no event

1st

than

18 months after finding

of

exceedance

If the above-background concentration

of

ra9ium_226

in land averaged over any area

of

100

in

is

pCi/g no further cleanupis

needed

Between

and

15 pcig decision

concerning

the need

for further

cleanup should

be made based on

the

volume

and depth

of

the contamination

as well as other sitespecific

characteristics further 5uidance fromEPAs

ORP should

be

sought

in

thesecases o

r

Applicable

to active conrnercial

and thoriumprocessing sites licensed b

y

the

NRC or

States

Applicable

to certain inactive uraniumprocessing sites designated

for remedial

action under Title of UMTRCA

see Chaptero

f Part

II for more detail as well as

active corrrnercial uranium

and thorium

processing sites licensed

by the

NRC or

States

40

CFR section 192.33

and 19241 UMTRCA

40

CFR section

192.12a 192.32b2

and 192.41 UMTRCA

15 pCi/g

the contamination should

be

removed

Gross alpha particle radioactivity moans

the total radioactivity

due

to all alpha particle emitters excluding

for

tho

purpose

of

40

CFR section14115 radon

and uranium

TABLE 4-3 Condnued

SELECTE ACTION-SpECIFiC POTEWRAL APPLiCABLE

OR RELEVANT

AND APPROPRLATE REQUIREMENTS

-I

Protection

of Ground

Water from

RadioactiveContamination



CHAPTER MARAG4ENT OP RADIOACTrVZ WASTES

Uranium mill tailings shall

be managed so

as

to

conform to

the

ground-water protection standard

in

40

CFR section 26492 except that

for

the

purposeof this standard

Molybdenum uranium

and thorium are

added to

the list of hazardous

constituents referenced in 40

CFR

section 264.93

Applicable

to active corinercial uranium

and

thorium processing sites licensed

by the

NRC

or States

Uranium Mill TailingsRadiation Control

Act

LJMTRCA

40

CFR section

192.32a2 and 192.41

intlj

-1

Cleanup

of

RadioactivelyContaminated Land

Refer to

Chapter

of Part

of this guide

for guidance on CERCLA compliance with RCRA

TABLE 4-3Connued

SELECTEO ACTlON-SPECFIC POTENTIAL APPI PCABLE

OR RELEVANT


Remedial actions should attempt

to achieve an

annual average radon decay product concentration

including background

of less than 0.02

WI

in any

occupied or habitable building

In any case

the

radon decX product concentration shall not exceed

0.03

WI.

Applicable

to certain inactive uranium

processing sites designated

for remedial

action under Title

of tJMTRCA

see Chapter

of Part

II for more detail

00

Control of Uranium

or Thorium Hill

Tat lings

The level

of ganasa radiation shall

not exceed

the

background level

by more than

20

microroents/hour

in any occupied or habitable

building

Control measures shall

be designed

to be effective

for

up

to 1000 years

to

the extent reasonably

achievable

and

in any case

for

at least 200

years

Control measures shall be designed

to ensure thatreleases

of radon-222 from residual radioactive

material to

the atmosphere will

not exceed an

average applied over

the entire surface

of

the

disposal

sit

and over l.ist onsyear period

releaae rate

of

20 pCi/m la.c or increase

the

averag annual concentration

of radon-222

in the

atmosphere

at or above any location outside

the

disposal site

by more than

0.5 pCi/l

Applicable

to certain inactive uranium

processing sites designatedfor remedial

action under Title

of LJHTRCA

see Chapter

for more detail

40

CFR section

192.12b2 UMTRCA

40

CFR section 192.02a

IJHTRCA

40

CFR section 192.02b

UMTRCA

At

the

end

of

the closure period disposal areas

shall

be designed

to be effective

for

up

to 1000years

to

the extent reasonably achievable

and

in any case

for

at least

200 years

At

the

end

of


shall

be designed

to ensure that releases

of

radon-222 from residual radioactive material to

the atmosphere will

not exceed an average Cappli.d

over

the entire surface

of

th

disposal site

and

over

at

east one-year period release rate

of

20

pCi/rn /sec

Applicable

to active cormrorcial uranium

and

thorium processing sites licensed

by

the

HRC

or States

40

CFR section

192.32b1i and

192.41 UMTRCA

40

CFR section

192.32b1ii and

192.41 UMTRCA

12

working level

or

WI means any combination

of short-lived radon decay products through polonium-214

in one liter

of

air that will result

in

the emission

of alpha particles with total energy

of

130 billion electron volts

An activity concentration

of

10 picocurias

per liter

of radon-222

in

equilibrium with

its daughters corresponds approximately

to one

WI.

microroentgen

io6 roentgen where roentgen

is unit

of exposure

to gana

or X-rays equivalent

to an absorbed dose

in tissue

of

approximately

0.9

rad

rad

is measureof

the energy imparted

to matter

by ionizing radiation defined as

100 erga/g

Cs

Pc

t.J

CHAPTER KARAGZNT OP RAflIQACTIV WASTES

Cleanup

of

RadioactivelyContaminated

Bui Idinis



40

CFR section

192.12b1 UMTRCA

txUi

Closure

of Uranium

and Thorium Hill

Tailings Sites

Closure

and Fost

closure Observation

and Haintenance

of

Low-Level

Radioactive Waste

Disposal Site

At

the

end

of


shall each comply with

the closure performance

standard

in 40

CFR section 261.111 with respect

to

non-radiological hazards

see Exhib

1-3

in Fart

for more discussion on 261.111

variety

of waste disposal requirements

are

set

including those specifying

how licensees may

dispose

of licensed material

see Section 4.2.1.1

of Chapter

of Part

II as well as concentration

limits

for disposal

of radioactive waste into

sanitary sewerage systems requirecnente

for

treatment

and disposal

by incineration

and

specific requirements

for

the disposal

of

radioactively contaminated animal tissue and

liquid scintillation media

Closure designs must assure that Longtermperformance objectives

of

10

CFR sections 61.41

61.44

see below are

met taking into account

site-specific geologic hydrologic

and other

conditions

Following completion

of closure

the

disposal site

must

be monitored

and maintained

for years

longer or shorter periods may

be allowed

and

then responsibility

is transferred

to Federal or

State government agency which will implementinstitutional care requirements

in 10

CFR section

61.23g

Applicable

to active comercial

and thorium

processing sites licensed

by

the

NRC or

States

Applicable

to

all categories

of

NRC


to Agreement

State licensees Applicableto releases

of

source byproduct

and special nuclear

material

Certain requirements also apply

to otherradioactive materials

i.e HARM releasedfrom facilities licensed to possess sourcebyproduct


Applicable

to NRC-licensed land disposal

facilities that receive low-level wastes

from others

i.e corracercial disposal

facilities

Not applicable

to disposal

of

Highlevel waste

and spent fuel

addressed

in 10

CFR Fart

60

and

40

CFR

Fart

191

Transuranic waste addressed

in 40

CFR

Fart

191

Uranium

and thorium mill tailings

addressed

in

10

CFR Fart

40

and

40

CFR

Fart

192

and

Radioactive waste

by an individual

licensee as provided

for

in

10

CFR Part

20

40

CFR section 192.32b

and 192.41 UMTRCA

10

CFR sections 20.301

through 20.311

AZA

10

CFR sections

20.302a

and 20.302b

AEA

10

CFR section 61.28

AEA LLW6

and

LLRWPAA

.L2

10

CFR sections 61.29

and 61.30

AZA LLWPA

and LLRWPAA

ia

Refer to Chapter

of Part

of this guide

for guidance on CERCLA compliance with RCRA

TABLE

4.3 ntjnu

SELECTED ACTION-SPECIFIC POTENTIAL APPUCABLE

OR REIEVANTAND APPROPRIATE REOUIREMEIITS

CRAPTER HANAGP3IENT OF RADIQACTVE WASTES

CD



Radioactive Waste

Treatment

and

Disposal

txj

Part

61 was promulgated primarily under the authority

of

the Atomic Energy

Act

but

two other statutes from which authority

was derived are

the

Low-Level Waste Policy

Act

of 1980 LLWPA and

the Low-Level Radioactive Waste Policy Amendments Act

of 1985 LLRWPAA

4-3 Continued

SECTB AC11ON-SPECFIC POTENTIAI APPUCALE

OR RELEVANT

AND APPROPRIATE RECUIREMENTS

Siting Designing

Operation Closure

and Control of

Low-LevelRadioactive Waste

Disposal Site

variety

of performance objectives

are

established including standards that

set limits

on radiation exposures

by members of

the public

protect people from inadvertently intruding ontoradioactive waste site

and stabilize

the

ite

after closure

The public exposure limits are

the

same dose limits as

in 40

CFR Part

190

Same prerequisites

as specified above for

10

CFR Part

61

10

CFR sections 61.41

through 61.44 Subpart

of Part 61

AEA LLWPA

and LLRWPAA

tl

Siting OperationDecontaminationDecon-scissioning

and

Reclamation

of

Uranium Mills

and

Hill Tailings

variety

of technical requirements

are

established

i.e minimum characteristics

disposal site must have

to be acceptable

Numerous technical financial ownership

and

longterm surveillance criteria are established

Same prerequisites

as specified above for

10

CFR Part

61 except that existing technical

requirements

are applicable only

to

the

near-surface disposal

of radioactive waste

near surface disposal facilityis defined

as

one that disposes

of wastein or within

the upper

30 meters

of

the earthi crust

Applicable

to active uranium or thorium

mills

and inactive mills that a

re

not

covered under

the remedial action program

of

UMTRCAS Titlesee Chapter

of Part

II

for more discussion on this remedial action

program

10

CFR sections 61.50

through 61.59 Subpart

of Pert 61

AZA LLWPA

and LLRWPAA

10

CFR Part 40 Appendix

AZA

and UMTRCA

tI.0

CHAPTER MARAENT OF RADIOACTIVE HASTES



TABLE4.4

OTHER FRDERAL AM STATE CRITERLA ADVISORIES

ANt GUIDANCE

TO BE CONSIDERED

k-

federal Criteria Advisories

and Procedures

Health Effects Assessments HEAs

end

Proposed HEAs Health Effects Assessment

for Specific Chemicals ECAOUSEPA 1985

References Doses RFDs Uverifiad Reference Doses

of USEPAU ECAOCIw-475 January 1986 See alsoDrinking Water Equivalent Levels DWELs set

of mediun-specific drinking water levels derived from RFDs

SeeUSEPA Health Advisories Office

of Drinking Water March

31 1987

Carcinogen Potency Factors CPF5 e.g

Dl Stars Carcinogen Assessment Gro4.ç

CAG Values Table

11 HealthAssessment Docunent

for Tetrschloroethylene Perchtoroethyleneu USEPA OHEA/6008.82/005F July 1985

Pesticide registrations

and registration data

Pesticide

and Food additive tolerances

and action levels Note Some tolerances

and action levels may pertain

andshould therefore

be considered

In certain situations

Waste load allocation procedure

EPA Office

of Water

40 CFR Part125

130

Federal Sole Source Aquifer requirements

See

52

6873 March 1987

PtLtic health criteria on 4iich

the decision

to

list pollutants as hazardous under Section

112

of

the Clean

Air

Act

was based

Guidelines

for Ground-Water Classification Under

the

EPA

Ground-Water Protection Strategy

TSCA chemical advisories issued to datO Nitrosamines Septeaber 1984 P/Tert/Buti/benzoic acid March1985 Burning used

oil space heaters Wovether 1985

44

Nethytinebis 12/Chloroanallne Deceober 1986Witropropene Dececber 1986

Advisories issued

by FWS

and NWFS under

the Fish


Act

TSCA CcmLiance Program Policy NTSCA Enforcement Guidance Manual Policy CoopendluflN USEPA

OCN OPTS March1985O

D

OSHA health

and

safety standards that may

be used

to

protect pthlic health nonworkptace

a/ This list tçdates

the list

of other Federal criteria advisories

and guidance

to

be considered

in the October1985 Ccapliance Policy

As cthtional or revised criteria advisories

or guidance are issued they should

bea6ed

to this listand also considered

b/ Proposed amenónents

to the Federal Insecticide Ftxgicide

and Rodenticide

Act introduced

the

concept

of GroundWater Residue Guidance Levels GRGLs These amencbnents have

not been passed

by Congress

and list

of GRGLS

has

not

yet been proimilgated

TABLE

4-4 ContInued

OTHER FFDRAL

AND STATE CRflTFRL ADVISORIES

AND GUIDANCE

TO BE CONSIDERED

Health Advisories

EPA Office

of Water

EPA Water Quality Advisories

EPA Office

of Water Criteria

and Standards Division

USEPA RCRA Guidance Docuents

Interim Final Alternate Concentration Limit Guidance Part

ACL

Pot

icy

and Information Reqirements JuLy 1987

EPAs RCRA Design Guidelines

Surface Ioutc

nts Liners Systems Final Cover

and Freeboard Control

West Pile Design Liner Systems

Lbnd Treatment Units

LandfiLl Design Liner Syst

and Final Cover

Permitting Guidance Manuals

Permit Writers Guidance Manual

for Hazardous Waste Land Treatment Storage

and Disposal Facilities

Phase February

15 1985 EPAI53OSW85O24

Permit Writers Guidance Manual

for SLtpart October 1983

Permit Applicants Guidance Manual

for

the General Facility Standards October

15 1983

EPA

OSU

00

OO968

Waste Analysis Plan Guidance Manual October

15 1984 EPA/530SW-84012

Permit Writers Guidance Manualfor Hazardous Waste Tanks July 1983

Model Permit Application

for Existing Incinerators 1985

Guidance Mari.ial

for Evaluating Permit Applications

for

the Operation

of Hazardous Waste Incinerator

Units July 1983

Guide

for Preparing RCRA Permit Ai9lications

for Existing Storage Facilities January

15 1982

Guidance Manualon closure

and postcLosure Interim Status Standards

RCRA permit manuals are listed

to indicated

the kind

of information used manner

of interpreting information

and determinations

in setting standards they

are

not used

to indicate proceckires

TABLE

4-4 Continued

OTHER FEDERAL

AND STATE CRITERL ADVISORIES

AND GIJIDANCEJO

BE CCNSIDERD

Technical Resource Doc.aents TROI

Ealusting Cover Systems

for Solid

and Hazardous Waste Septer 1982

EPA 0SW00-00867

HydrologIc Si.ilatton

of Solid Waste Disposal Sites Woveer 1982

EPA OSWOO00868

Lwdf

ill

ard Surfacs Iouxent Performsnce Evaluation April 1983

EPA OSW-00-00869

Draft Minimal Technology Guidelines on Do1e Liner System

for Landfills

and Surface 1upo..ncnentsK

ay 1985

PS 87151072A$

Draft Minimal Technology Guidelines on Single Liner Syste

for Landfills

and Surface IeotsnentsK

ay 1985

P8 871173159

Management

of Hazardous Vast Lsechate Septcer 1982 OSV-O0-00871

Guide

to the Disposal

of Chemically Stabilized

and SoLidified Waste 1982 EPA/530-SW872

0\

Closure

of Hazardous Waste Surface 1.çotrxtaents Septeer 1982 0SJ0000873

Hazardous Waste Land Treatment April 1983 OSWOO00874

10 Soil Properties CLassification

and Hydraulic Corxkictivity Testing March 1984 0SW0000925 OSUER

directive 9480.00Th

Test Methods

for Evaluating Solid Waste

Solid Waste Leaching Procedore Manual 1984 OSW000O-924

Methods

for

the Prediction

of Leachate PLuse Migration

and Mixing

Hydrotogic.EvaLuation

of Landfill Performance HELP Mode VoLu.aee

and 111984 EPA/530SW-84009

EPA/530SW84-010

CX

Hydrologic Sisulation on Solid Waste Disposal Sites HoveZer 1982

EPA 0SV00-00-868

Proceckires

for Modeling Flow throth Clay Liners

to

Determine RecJired Liner ThIckness 1984EPA/530SW84001 OSLER directIve 9480.00.90

Test Methods

for Evaluating Solid Wastes third edition Novether 1986 SW-846

Method

for Determining

the Ccqatibility

of Hazardous Wastes EPAJ6000280-076

Guidance Manual on Hazardous Waste Coapatibility

TABLE 4-4 Continued

OThER FEDERAL A14DSTATECRERA ADVISORIES ANDGUIDAlCE TOBE NSIDERCD

USEPA Office

of Water Guidance Docunents

Pretreatment Guidance Docunents

3049 Guidance Docunent Revised Pretreatment Guidelines Volunes

Guidance

for POTW Pretreatment PrQgram Manual October 1983

DeveLoping Requirements

for Direct

and Indirect Discharges

of CERCLA Wastewater Draft 1987

Donestlc Sewage Exeaption Study

Guidance

for Içleaentlng RCRA Permit

by Rule Requirements

at POIWs

Application

of Correction Action Requirements

at Piilicly Owned Treatment Works

Draft Guidance Manual on

the Develoxient

and

Uptementatlon

of Local Discharge Limitations Under

the

Pretreatment Program 1987

Water Quality Guidance Docunents

EcologicaL Evaluation

of Proposed Discharge

of Dredged Material Into Ocean Waters 1977

Technical St.çport Ma-sial Waterbody Surveys

and Assessments

for Cordxtlng

Use

Attainability Analyses1983

WaterRelated Enviromental Fate

of

129 Priority Pollutants 1979

Water Quality Standards Hwook Deceaber 1983

Technical Stççort Docunent

for Water Qualitybased Toxics Control 1983ti

NPOES Guidance Docueents

WPDES Best Management Practices Guidances Manual JuDe 1981U-

Case studies on toxicity redxtion evaluation

May 1983

Grou Weter/UIC Guidance Docunents

Designationof USDW

No

7.1 October 1979

Elementsof aquifer IdentifIcation

Wo

7.2 October 1979

Interim Guidance Concerning Corrective Action

for Primary

and Continuous Release

of Class

and

IV

Hazardous Waste wells

No

45 April 1986 requIrements

RequIrements applicable

to

welts injected into through

or above an aquifer that

has been exeipted

pursuant

to

Section 14.6.104bC4

No

27 July 1981

t.J

TABLE 4-4 Continued

OThER FEDERAL

AND STATE CRITERLA ADVISORIES

AND GUIDANCE

TO BE CONSIDEfl

Guidance

for

UIC iacleentatjon on Indian Lands

No

33 October 1983

Groutd-Wter Protection Strategy August 1984

CLean Water

Act Guidance Docusents

See Exhibit

31

$EPA Manual fron

the Office

of Research

end Devetoonent

SW

846 methods Laboratory analytic methods Woveober 1986

Lab protocols developed pursuant

to

Clean Water

Act Section 304h

WvrclTulgote State Advisories

State aççroval

of water supply syat aôiJtionsor devetopoents

State grotnd water withdrawal approvals

Note Many other State advisories could

be

pertinent Forthccaing guidance will include more coprehensfve ListIt

CERCLA Compliance with Other Laws Manual Part II Clean Air Act andOther Environmental Statutes and State Requirements August 1989EPA/540/G-89/009

ERM has identified site-specific ARARs Chemical- and location-specific ARARs will

be reviewed after the Phase la Initial Site Characterization and the action-specific

ARARs will be further refined after the Development and Initial Screening of the

Remedial Alternatives The following paragraphs partially list potential ARARs for

the Site

4.2 CHEMICAL SPECIFIC ARARs

4.2.1 Safe Drinking Water Act SDWM

The SDWA provides ARARs for contaminants in drinking water supplies

National Primary Drinking Water Standards Maximum Contaminant Levels 40 CFR141 The maximum level of contaminant in water is delivered to the free flowing

outlet of the ultimate user of public water system

Maximum Contaminant Level Goals 40 CFR 141 The maximum level of contaminant

in drinking water at which no known or anticipated adverse effect on the health of

persons would occur and which allows an adequate margin of safety

Secondary Drinking Water Standards Secondary Maximum Contaminant Levels 40CFR 143 Contaminants that primarily affect the aesthetic quality of drinking waster

and are not federally enforceable

4.2.2 Clean Water Act CWA

Toxic Pollutant Effluent Standards 40 CFR 129 The concentration of toxic

pollutant in navigable waters that shall not result in adverse impact on important

aquatic life or on consumers of aquatic life after exposure of that aquatic life to the

pollutant for periods of time exceeding 96 hours and continuing through at least one

reproductive cycle


mq215-02-02 EPA 04587 fJ

GroW

4.2.3 Toxic Substances Control Act TSCM

Disposal of PCBs 40 CFR 761 If the remedy involves excavation of soils that contain

PCBs the requirements of this section must be satisfied However TSCA does not

explicitly require excavation of PCB-containing soil

4.2.4 Radiological Hazards

Other chemical-specific ARARs particularly related to the radiological hazards at the

site may include provisions from one or more of the following

Low Level Radioactive Waste Policy Amendments Act of 1985

Atomic Energy Act 42 USC 2011 et seq and

Uranium Mill Tailings Radiation Control Act of 1978

Table 4-5 lists additional potential ARARs for the radiological wastes at the site

4.3 LOCATION SPECIFIC ARARs

Some examples of location specific ARARs include the ground-water classification for

the aquifer underlying the site wetlands protection statutes and fish and wildlife

conservation provisions

4.4 ACrION SPECIFIC ARARs

4.4.1 Clean Water Act CWA

Discharging to Surface Water 40 CFR 125 An NPDES permit may be required if

the remedy includes discharging to surface water off site The best available

technology that is economically achievable must be used

4.4.2 Resource Conservation and Recovery Act RCRA

In general the applicable or relevant and appropriate RCRA ARARs are action-

specific applying to the remedial activities undertaken The following are some

examples of RCRA requirements 40 CFR 264 that may be applicable or relevant and

appropriate


215-02-02

Table 4-5 Additional Potential ARARsfor Radiological Wastes

EXECUTIVE ORDERS

Executive Order 11490 Assigning Emergency Preparedness Functions toFederal Departments and Agencies TABLE 3-1

Executive Order 11514 Protection and Enhancement of EnvironmentalQuality

Executive Order 11738 Providing for Administration of the Clean Air Actand the Federal Water Pollution Control Act with Respect to FederalContracts Grants or Loans

Executive Order 11807 Occupational Safety and Health Programs for FederalEmployees

Executive Order 11988 Floodplain Management

Executive Order 11990 Protection of Wetlands

Executive Order 11991 Relating to the Protection and Enhancement ofEnvironmental Quality

Executive Order 12088 Federal Compliance with Pollution Control Standards

Elecutive Order 12146 Management of Federal Legal Resources

Executive Order 12580 Superfund Implementation

DEPARTMENT OF ENERGY ORDERS

Order 1540.1 Materials Transportation and Traffic Management

Order 4240.1H Designation of Major System Acquisition and Major Projects

Order 4320.1A Site Development and Facility Utilization Planning

Order 5400.5 Radiation Protection of the Public and the Environment

Order 5440.lC Implementation of the National Environmental Policy Act

Order 5480.IA Environmental Protection Safety and Health Protection

Program for DOE Operations -- Note Chapter XI of Order 5480.1A has beenamended

EPA 04589


215-02-02

Table 4-5 Additional Potential ARARsfor Radiological Wastes continued

DEPARTMENT OF ENERGY ORDERS continued

Order 5480.1B Environment Safety and Health Program for Department ofEnergy Operations -- Note Chapter XI of Order 5480.1B has been amended

Vaughn 1985 and subsequent updates of derived concentrationguides TABLE 3-1

Order 5480.4 Environmental Protection Safety and Health ProtectionStandards

Order 5480.11 Radiation Protection for Occupational Workers

Order 5480.14 Comprehensive Environmental Response Compensation andLiability Act Program

Order 5481.1B Safety Analysis Review System

Order 5482.1B Environmental Protection Safety and Health ProtectionAppraisal Program

Order 5483.1A Occupational Safety and Health Program for Government-Owned Contractor-Operated Facilities

Order 5484.1 Environmental Protection Safety and Health ProtectionInformation Reporting Requirements

Order 5000.3 Unusual Occurrence Reporting System

Order 5500.2 Emergency Planning Preparedness and Response forOperations

Order 5700.4A Project Management System

Order 5700.6B Quality Assurance

Order 5820.2 Radioactive Waste Management

EPA 04590


215-02-02

On-site Land Disposal 40 CFR 264 Subparts and .N Requirements for Landfills

are in Subpart and requirements for general land treatment biodegradation

volatilization land farming are in Subpart

Site Closure with Waste in Place 40 CFR 264 Subpart Certain sections of 40 CFR

may be applicable or relevant and appropriate if the waste is to be left in place This

could include among others capping installation of slurry walls grading and

covering with vegetation or consolidation of substances in one location Subpart

of 264 provides technical requirements for closure and post-closure activities

Ground Water Monitoring 40 CFR 264 Subpart This subpart provides RCRAground water corrective action requirements that may be relevant and appropriate

at the Site These requirements include ground water monitoring and ground water

protection standards

Chemical Physical and Biological Treatment Although standards do not yet exist

for general waste treatment in new facilities standards do exist for interim status

facilities 40 CFR 265 Subpart and include specific requirements for ignitable and

reactive wastes The interim status requirements are probably not applicable if the

treatment is performed on-site but they may be relevant and appropriate

Thermal Treatment Standards do not yet exist for thermal treatment in new

facilities but standards do exist for interim status facilities 40 CFR 265 Subpart

and provide for general operating requirements waste analysis monitoring and

inspections closure open burning and waste explosives The interim status

requirements are probably not applicable if the treatment is performed on-site but

they may be relevant and appropriate

Incineration 40 CFR 264 Subpart This subpart includes performance standards

for incinerators and monitoring inspection and operating requirements

Storage 40 CFR Subparts and Two subparts include standards for storage of

hazardous waste in containers Subpart and tanks Subpart In addition sections

of Subparts and relate to storage

EPA Q4591

Work Plan 4-70revised 1/21/9 mq215-02-02

4.4.3 Other

Other potential action-specific ARARs are

OSHA requirements for hazardous waste workers

Department of Transportation rules for transportation of hazardousmaterials 49 CFR 107 and 171 and

Regulations pertaining to activities that affect the navigation of waters ofthe United States 33 CFR 320-329

4.5 STATE OF MASSACHUSETTS ARARs

In addition to the federal ARARs ERM will consider all state ARARs particularly

those that provide more stringent cleanup standards The state ARARs that will. be

considered include but will not necessarily be limited to the following

310 CMR 30.00 Hazardous waste management requirements

310 CMR 19.00 Solid waste management requirements

310 CMR 6.00 Ambient air quality standards

310 CMR 7.00 Air pollution control regulations

310 CMR 10.00 Wetlands protection requirements

314 CMR 4.00 Surface water quality standards

314 CMR 9.00 Certification of dredging and filling

314 CMR 12.00 Wastewater treatment

310 CMR 33.00 Employee and community right to know requirements

The above list is not complete because the major investigative effort at the Site has

not yet been performed However the list will be used to focus tasks during the

RIIFS At points during the RI/FS other site-specific ARARs may be identified

EPA 04592


215-02-02

SECFION 5.0

DATA REqUIREMENTS FOR POTENTIAL REMEDIAL ALTERNATWES AND TECHNOLOGIES

5.1 IDENTIFICATION OF POTENTIAL REMEDIES

Potential remedial action objectives alternatives and associated technologies for the

Shpack Site are provide in Table 5-1 The objectives alternatives and technologies

are grouped by environmental media The remedial action alternatives include

options that will be evaluated in the feasibility study in which treatment is

component and that would significantly reduce the toxicity mobility or volume of

wastes In addition no action and containment-type alternatives that involve little

or no treatment will be developed and evaluated

Because the nature and extent of contamination at the Site and the affected media

have not been determined yet comprehensive cleanup alternatives for the Site could

utilize any combination of the technologies presented in Table 5-1 Consequently it

is not feasible to provide specific response objectives at this time nor is it feasible to

propose preliminary range of remedial action alternatives However for potential

sources of contamination including the radioactive wastes found at the Site the

following general response actions could apply

Removal of the source and off-site treatment or disposal

Removal of the source and on-site treatment and disposal

Containment of Contamination with little or no treatment

In-place in-situ treatment and

No Action

For managing the migration of contamination in ground water the following

general response actions apply

Removal and treatment followed by re-injection surface water dischargeor other use

Containment including gradient controls

Ground water use restrictions such as institutional controls and

No Action

EPA O459

Work Plan 5-1

revised 1/21/91 me15-02-02

Prevent ingestion/direct

contact with soil having

non-carcinogens

in

excess

of reference dosess

Prevent direct contact

ingestion with soil having

1OE-4

to bE-i excess cancer

risk from carcinogens

Containment Technologies

Capping

Vertical barriers

Horizontal barriers

Surface controls

Clay

cap synthetic membrane mulit-layer

Slurry wall sheet piling

Liners grout injection

Diversino/collection grading soil

stabilization

Table

5-b

Remedial Action Objectives Response Actions

and Technologies

Environmental

Media

Remedial Action Objectives

site Characterization

General Response Actions

all remedial action objectives

Remedial Technology Types

general response actions Process

Ground Water

For Human Health

Prevent ingeston

of water

having carcnogens

in

excess

of MCLs and

total excess cancer risk

for

all contaminants

of

greater

than IOE-4

to 1OE-7

Prevent ingestion

of water

having non-carcinogens

in

excess

of MCLs or

reference doses

For Environmental Protection

No Action/Institutional Actions

No action

Alternative residential water supply

Monitoring

Containment Actions

Containment

Collection/Treatment Actions

Collection/treatment dischargein-situ ground water treatment

Individual home treatment units

No Action/Institutional Options

Fencing

Deed restrictions


Capping

Vertical barriers

Horizontal barriers

Extraction Technologies

Ground water collection/pumping

Enhanced removal

Treatment Technolgoies

Physical treatment

Chemical treatment

Blolgical treatment

In-situ treatment

Options

Clay

cap synthetic membrane multi-layer



Wells subsurface or leachate collection

Solution mining vapor extraction enhanced

oil

recovery

Coagulation/flocculation oil-water separation

air

stripping adsoprtion

Neutralization precipitation

Ion

exchange

oxidation/reduction

Subsurface bioreclamation

Restore ground water aquifer

to

appropriate quality

Disposal Technolgoics

Discharge

to POTW

treatment

Discharge

to surface

Water treatment

It

Soil

For Human Health


No action

Access restrictions

Containment Actions

Containment


Fencing

Deed restrictions

Table

5-I Contd


and Technologies

En vironmental

Media


from Site Characterization


Ifor



for general response actions Process Options

Soil Sediment control barriers

Dust controls

Coffer dams curtain barriers

Revegetation capping

Prevent inhalation

of Excavation/Treatment Actions

carcinogens posing excess Excavation/treatment/disposal

cancer risk levels

of IOE-4

to In-situ treatment Removal Technologies

bE-i Disposal excavation Excavation Solids excavation

Treatment Technologies

For Enviornmental Protection Solidification fixation

stabilization immobilization

Sorption pozzolanic agents encapsulation

Belt filter press dewatering

and drying beds

Prevent migration

of Dewatering Water/sovient leaching with subsequent

contaminants that would Physical treatment liquids treatment

result

in

ground water Chemical treatment Lime neutralization

contamination

in

excess

of

Biological treatment Cultured micro-organisms

appropriate standards

and In-situ treatment Surface bloreclamation

risk levels Thermal treatment Incineration pyrolysis

tIl

01

Surface Water

For Human Health

Prevent ingestion

of water

having carcinogens

in

excess

of MCLs

and total

excess cancer risk

of greater

than IOE-4

to IOE-7

Prevent Ingestion

of water

having non-carcinogens

in

excess

of MCLs or

reference doses


No Actionflnstitutional Actions

No action

Access restrictions

Monitoring

Collection/Treatment Actions

Surface water runoff interception/

treatment/discharge


Fencing

Deed restrictions

Collection Technologies

Surface controls


Physical treatment

Chemical treatment

Grading diversion

and collection

Coagulation/flocculation oil-water separa

tion filtration adsorption

Precipitation

ion exchange neutralization

crystallization biological treatment

aerobic

and anaerobic spray irrigation

In-situ precipitatIon In-situ bioreclamatlon

Biological treatment

Restore surface water

to

ambient water quality In-situ treatment

criteria Disposal Technologies

Discharge

to POTWtreatment

tI1ij

1-fl

1-0

Table

5-I Contd


and

Technologies

.0

tJ

Environmental

Media






general

Sediment

For Human Health

Prevent direct contact with

with sediment having

carcinogens

in excess

of

IOE-4

to jOE-i excess cancer

risk


Prevent releases

of

contaminants from

sediments that would result

in surface water levels

In

excess

of ambient water

quality criteria


No action

Access restrictions

to

Monitoring

Excavation Actions

Excavation

Excavation/Treatment Actions

Removal/disposal

Removal/treatment/disposal

response actionsi


Fencing

Deed restrictions

Removal Technologies

Excavation


Capping

Vertical barriers

Horizontal barriers

Sediment control barriers


Solidification fixation

Process Options

Sediments excavation

Removal with clay

cap multi-layer asphalt



Coffer dams curtain barriers capping

barriers

Sorption pozzolanic agents encapsulation

stabilization

Dewatering

Physical treatment

Chemical treatment


In-situ treatment

Thermal treatment

Sedimentation dewatering

and drying beds

Water/solids leaching subsequent

treatment

Neutralization oxidation electrochemical

reduction

Landfarming

Surface bioreclamation

Incineration pyrolysis

Air

For Human Health

Prevent inhalation

of

carcinogens

in

excess

of

IOE-4

to bE-i excess cancer

risk

and State AALs


No action

Access restrictions

to

monitoring

Collection Actions

Gas collection


Fencing

Deed restrictions


Landfill

gas collection Passive vents active gas

collection systems

t1I.j

01

LO

Table

5-I


and Technologies

Environmental

Media




all remedial action oblectives


general response actions Process Options

Solid Wastes

For Human Health


No action


Fencing

Prevent ingestion/direct Access restrictions

to Deed restrictions

contact with wastes having

non-carcinogens

in

excess Containment Actions Containment Technologies

of reference doses Containment Capping

Vertical barriers

Clay

cap synthetic membranes multi-layer


Prevent ingestion/direct ExcavationlTreatment Actions Horizontal barriers Liners grout injction

contact with wastes having Removal/disposal Dust controls

IOE-4

to

IOE-7 excess cancer Removal Technologies

risk from carcinogens Removalltreatment/disposal Excavation Solids excavation

Drum removal Drum

and debris removal

Prevent innalation

of Treatment Technologies

carcinogens posing excess Physical treatment Water/solvent leaching with subsequent

cancer risk levels

of IOE-4

to

liquids treatment

1013-7 Chemical treatment


Neutralization

Cultured micro-organisms

Prevent migration

of Thermal treatment Incineration pyrolysis

carcinogens which would

result

in

ground water Solids processing Crushing

and

grinding screeningconcentrations

in

excess

of

classification

MCLs or IOE-4

to bE-i total

excess cancer risk levels


Prevent migration

of

contaminants that would

result

in

ground water

contamination

in

excess

of

appropriate standarda

and

risk levels

Prevent ingestion/direct


non-carcinogens

in

excess

of reference doses

Preent ingestion/direct


IOE-4

to IOE-7 excess cancer

risk from carcinogens

Precent inhalation

of

carcinogens

in

excess

cancer risk levels

of IOE-4

to

IOE.7

Prevent digestion

of


result

in

ground water

concentrations

in

excess

of

MCLs or IOE-4

to IOE-7 total

excess cancer risk levels


Prevent migration

of

contaminants that would

result

in

ground water

contamination

in excess

of


and

risk levels

No

Action/Institutional Options

Fencing

Deed restrictions


Vertical barriers

Horizontal barriers


Bulk liquid removal

Drum remvoal


Physical treatment

Chemical treatment


Thermal treatment

Disposal Technologies

Product reuse

Discharge

to POTW after

treatment

Bulk liquid removal

Drum removal

Coagulation/flocculation adsoprsion

evaporation distillation

Neutralization oxidation reduction

photolysis

Aerobic/anaerobic biological treatment

biotechnologies incineration pyrolysis

co-disposal

Liquid Wastes

For Human Health

Table

5-1 Contd


and

Technologies

Remedial

site

Action Objectives

Characlerizatloni

General Response

all remedial action

Actions

oblectivesi

Remedial Technology

general

Types

actions Process

CD

Environmental

Media

LII


No action

Access restrictions

Containment Actions

Containment

Removal/Treatment Actions

Removal/disposal

Removal/treatment/disposal

Slurry wall

Liners

Table

5-I


and

Technologies

For Human Health

Prevent direct contact with

sludge having carcinogens

in excess

of IOE-4

to lOB-i

excess cancer risk

Prevent ingestion/contact

with sludge having

non-carcinogens

in excess

of reference doses

Prevent migration

of


result

in

ground water

concentrations

in excess

of

IOE-4

to IOE-7 excess cancer

risk


Prevent releases

of

contaminants from sludge

that would result

in surface

water levels

in excess

of

ambient water quality

criteria

Prevent releases

of

contaminants from sludge

that would result

in

ground water levels

of


and

risk levels


No action

Access restrictions

to location

Containment Actions

Containment

Removal/Treatment Actions

Removal/disposal


Fencing

Deed restrictions


Vertical barriers

Horizontal barriers


Bulk sludge removal

Drum removal


Solidification fixation

Physical treatment

Chemical treatment


Thermal treatment

Dewatering

Dispsoal Technologies

Product reuse

Landfilling after treatment

Semi-solid excavation pumping

Drum removal

Freeze crystallization neutralization

oxidation electrochemical reduction

Oxidation reduction photolysis

Aerobic/anaerobic treatment land treat

ment

new biotechnology

Incineration pyrolysis co-disposal

Gravity thickening belt filter press

vacuum filtration

Environmental Remedial Action Objectives General Response Actions Remedial Technology TypesMedia from site Characterization


for general response actions Process Options


Liners

Sludges

ii

Removal/treament/disposal

As information on the nature and extent of contamination and environmental media

potentially affected is collected during the Phase la Remedial Investigation the

potential remedial action objectives will be refined and preliminary range of

remedial action alternatives and associated technologies will be developed

5.2 DATA REQUIREMENTS FOR POTENTIAL REMEDIES

Only the radiological content of the landfill has been well characterized therefore

additional data are required to address the organic and inorganic chemical

contamination other than the radionuclides at the site These additional data are

required before remedial technologies can be appropriately addressed The data

needs for focusing the RI as described in Section of this work plan are essentially

the same as the data needs for preliminary evaluation of remedial alternatives

Following the evaluation of data collected during Phase la of the RI ERM will define

additional data needs necessary to evaluate the appropriateness of specific remedial

technologies These needs along with the data that DOE requires to evaluate potential

remedies for radioactive wastes will be outlined in the Phase lb work plan In

particular the DOE will need to identify the organic and inorganic chemical content

of known radioactive hot spots to determine an appropriate remedial action for the

radioactive and mixed wastes

Based on the Steering Committees discussions with the DOE and their contractor

Bechtel it appears at this time that the most viable alternative for radioactive waste

and mixed waste if present is to remove it and dispose of it in permitted off-site

radiological waste repository

Work Plan 5-8

revised 1/21/9The

215-02-02 EPA 04600

SECflON 6.0

DATA NEEDS AND DATA OUAL1TY OBJECflVES

6.1 GENERAL DESCRIPTION OF DATA QUALITY OBJECFIVE DQO PROCESS

The EPAs guidance on Data Ouality Objectives for Remedial Response Activities

EPA/540/G-87/01J3 describes three-stage process for defining DQOs as shown in

Figure 6-1 Figure 6-2 depicts how the DQO stages overlay on the RI/FS process As

shown the process of defining DQOs is dynamic and is reevaluated at several points

during the RI/FS

Stage Figure 6-3 involves

reviewing existing data to define remaining data needs

developing conceptual model for the site and

specifying objectives for addressing data gaps


defining data quality and quantity needs to address data gaps identified in

Stage and

matching data quality objectives to particular intended data uses


designing the actual data collection program which contains the

components specified in Stages and

6.2 DESCRIPTION OF DATA QUALITY CATEGORIES

Tables 6-1 and 6-2 taken from Data Ouality Objectives for Remedial Response

Activities show the types of data quality that are necessary for certain intended data

uses As shown

Level data quality is appropriate for site characterization and monitoringduring remedial response implementation

Level II data quality is appropriate for site characterization evaluation ofremedial alternatives and monitoring during remedial responseimplementation

Work Plan 6-1

revised 1/21/91 Tb215-02-02

EPA 04601

STAGEIDENTIFY DECISION TYPES

IDENTIFY INVOLVE DATA USERS

EVALUATE AVAILABLE DATA

DEVELOP CONCEP11J4L MODEL

SPECIFY OBJECTIVES/DECISIONS

STAGEIDENTIFY DATA USES/NEEDS

IDENTIFY DATA USES

IDENTIFY DATA TYPES

IDENTIFY DATA QUALITY NEEDS

IDENTIFY DATA QUANTITY NEEDS

EVALUATE SAMPLING/ANALYSIS OPTIONS

REVIEW PARCC PARAMETERS

STAGEDESIGN DATA COLLECTION PROGRAM

ASSEMBLE DATA COLLECTION COMPONENTS

DEVELOP DATA COLLECTION DOCUMENTATION

Figure 6-1

DQO THREE-STAGE PROCESS

After Data Quality Objectives for Remedial Response Activities EPN540/G-87/oo3

Work Plan 6-2

revised 1/21/91 oruup

215-02-02 EPA 04602

Figure 6-2

PHASED RI/FS APPROACH AND THE OQO PROCESS

After Data Quality Objectives for Remedial Response Activities EPN54O/G-87/003

Work Plan 6-3

revised 1/21/91

215-02-02EPA 04603

Th

Lxi

SPECIFY OBJECTIVES/DECISIONS

Figure

6-3

DQO STAGE ELEMENTS

IDENTIFY INVOLVE DATA USERS

EVALUATEAVAILABLE DATA

DEVELOP CONCEPTUAL MODEL

CONTAMINANT SOURCES

MIGRATION PATHWAYS

POTENTiAL RECEPTORS

CONTAMINANTS

OF CONCERN

After Data Quality Objectives

for Remedial Response Activities EPA/540/G-871003

IDENTIFY

DATA USES

IDENTIFY DATA

TYPES

IDENTIFY IDENTIFYDATA OUALRY DATA QUANTITY

ES

EVALUATE

SAMPLING/ANALYTICALOPTIONS

REVIEW PARCCPARAMETERS

Figure 6-4

DQO STAGE ELEMENTS

After Data Quality Objectives for Remedial Response Activities EPAJ54O/G-871003

Work Plan 6-Srevised 1/21/91

215-02-02

EPA 04605 LISt

ASSEMBLEDATA COLLECTION

COMPONENTS

DEVELOP DATA COLLECTION DOCUMENTATION

WORK PLANSAMPLING ANALYSIS PLAN

Include QAP ElementsWORK PLAN

Figure 6-5

STAGE ELEMENTSDESIGN DATA COLLECTION PROGRAM

After Data Quality Objectives for Remedial Response Activities EPA/5401G-871003

ThQWork Plan u-u ----c-revised 1/21/91

215-02-02 EPA 04606

Table

6-1

SUMMARY

OF ANALYTICAL LEVELS APPROPRIATE

TO

DATA USES


for Remedial Response Activities EPA/5401G-87/003

DATA USES ANALYTICAL LEVEL TYPE

OF ANALYSIS LIMITATIONS DATA QUALITY

TOTAL OflOAflIC1NORGANIC INSTRUMENTS RESPOND

TO INSTRUMENTS CALIBRATEDSITE CHARACTERIZATION

MCINITORtIG DIBiNOVAPOR DETECTION USING

PORTABLE INSTRUMENTS

NATURALLY-OCCURINGCOMPOUNDS

AND DATA INTERPRETED

CORRECTLY

CAN PROVIDE

IMPLEMENTATIONFIELD TEST KITS

INDICATION

OF CONTAMINATION

VARIETY

OF ORGANICS

BY

CC INORGANICS

BY

AA

TENTATIVE

ID DEPENDENT

ON OMX

STEPS EMPLOYED

SITE CHARATERIZATION

XRF

EVALUATION OF ALTERNATIVES

aioa

IMPLEMENTATKN

LEVEL

II

TENTATIVE

ID ANALYTESPEGFJC

TECIIQIJESItSThUMENTSLIMITED MOSTLY

TO

VOLATILES METALS

DATA TYPICALLY REPORTED

IN CXNOSNIBATION RANGES

DETECTION LPMTS VARYFROM

LOW

ppii

TO LOW

ppb

RISKASSESSMENT

PF DETERMINATION ORGAN ICS/1NORGANICS TENTATIVE

IG IN SOME SIMLAR DETECTION

SITE CHARACTERIZATION USING EPAPRXEOURES CASES LIMITS

TO CLP

EVALUATION

OF ALTERNATIVES OTHER THAN

CI

CAN

BE

sii LEVEL

III ANALYTE-SPECIFCCAN PROVIDE DATA

OF LESS RIGOROUS QftOC

MONITORING DLRIPIG SAME OUALIY

AS

IMPLEMENTATION ACRA CHARACTERTIC TESTS LEVELS IV

NS

HSL ORGANICS/1NORGANICS TENTATIVE ICENTIFICATON

RISK ASSESSMENT

PfDErEF4INATIONEVALUATION

OF ALTERNATIVES

EEFGLEVE

BY GCflAS

.A ICP

LOW

ppb DETECTION LIMIT

OF NON-HSL PARAMETERS

-SOMETIME

MAY

BE REQUIRED

FOR VAJJDATION

OF PACKAGES

GOAL

IS DATA

OF KNOWN

QUALITY

-RIGOROUS

QC

HON-CONVENTLALPARAMETERS -MAY REQUIRE METHOD

DEVELOPMENTi%IODIFICATION

METHOD-SPECIFIC

RISK ASSESSMENT

PF DETERNINATION

LEVELV METHOD-SPECFIC

DETECTION LLUTS -MECHANISM TO OBTAIN

MODFICATN

OF

EXISTING METHODS

SVICES REQUIRES

SPECIAL LEAD TIME

APPENDIX PARAMETERS

Lii

Table

6-2

APPROPRIATE ANALYTICAL LEVELS

BY DATA

USE


for Remedial Response Activities EPA/540/G-87/003

ANALYTICAL

srrE

ciiviuF.WtGHEALTHSAFETY

R$K

ASSESSMENTEVALWTIONOF1_______ALTERNATIVES

DESIONCF

REMEDIAL ACTION

CNt1CRtlG

ij

IMPLEMENTATION

OF

REMEDIAL ACTIONDETERMINATION

011-ER

LEVEL

\//

\//

LEVEL

II \/ \//

\j

LEVEL

HI

\//

\4I

LEVEL

IV \//

.sLl.

\/

LEVELV

O1HER

\//

\//

00

Il00

NOTE CHEC1 APPROPRIATE

BOX

ES 0D

M

SF

DOO 1.001

REM 1006

Level III data quality is appropriate for risk assessment site

characterization engineering design evaluation of remedial alternativesand monitoring during remedial response implementation and

Level IV data quality is appropriate for risk assessment engineeringdesign and evaluation of remedial alternatives

For the Shpack RI ERMs site characterization tasks data collection and analysis

will meet either Level II or III data quality criteria and the risk assessment tasks

data collection and analysis will meet either Level III or IV data quality criteria

6.3 DATANEEDS

ERM has conducted thorough review of the available site information which is

described in Section of this work plan summary of environmental conditions

and general site history and layout are contained in Section of this work plan and is

based on the review of existing records

considerable amount of data collection has occurred at the site almost continuously

since 1979 These previous activities were sponsored primarily by the DOE howeverthe site has also been investigated by Massachusetts DEP and U.S EPA representatives

The DOE investigations have focused primarily within the borders of the Shpack

landfill and total volume of approximately 400 yards of radioactively contaminated

soils has been identified at several areas across the site The DOE through several

separate studies has essentially met the requirements of Phase Ia investigation

through its intensive coverage of the landfill interior

The DEP and EPA sponsored investigations have likewise provided data for assessing

environmental conditions within the landfill particularly with respect to chemical

contamination other than from radionuclides These investigations have also

included residential well sampling and other off-site sampling and analysis

activities Evidence has not been provided to date to show that contaminants at the

Shpack site are impacting water quality at residential wells or in downstream areas

of the Chartley wetlands surface water system

ERM has determined through its review of existing data that the primary data gaps

for the site are

Work Plan 6-9

revised 1/21/91mq

215-02-02

EPA 04609

migration pathways for ground-water and surface water contaminant

transport and

the depth of fill material and the actual bounds of fill deposits at the Shpacksite

The proposed RI tasks are intended to fill those gaps Specific objectives of specific

tasks are specified in Section 7.3 of this work plan

6.4 DATA QUALITY NEEDS

Table 6-3 lists the Phase Ia field tasks the type of media characterized the intended

data use and the data quality required As shown all of the data will be used for site

characterization Some of the Level III and IV will also be used for risk assessment

Finally some of the Level II III and IV data will be used for the FS Particular data

quality levels are specified within Section 7.3 of this work plan and within the FSP


10215-02-$ EPA 04

tzitj

Ii

Table

6-3

Data Quality/Data Uses

by Task

EPA Region

Shpack Landfill Supedund Site

Norton/Attleboro Massachusetts

Phase

la of

the

RI

rk

Description Type

of Media Characterized

Site Characterization

including health

and safety

Risk

Assessment

Evaluation

of

Alternatives

Engineering Design

of Alternatives

Remedial Action

Monitoring

Collect Ecological Data water

soil

sediment

Complete Health

and Safety Testing

and_Air_Monitoring

air

reeamptrç

is

possible

Sample Existing On-Site Wells waterresamplinglspoesible

Complete Soil

Gas Survey soil

gsa resarnpfing

is

possible

Excavate Test Pits soil

Install Micro-wells waterresamplin9lspossible

Install Ground-Water Monitoring

Wells

soil

waterresamplinispossibte

Sample Ground

and Surface Water

and Stream

and Wetlands Sediment

water

sedimentresampling

Is

possible

ata Quail Level

II and

III

Ill

and

IV II III

and

IV III

and

IV II and

I/I

SECTION 7.0

R/FS TASKS

7.1 PROJECT PLANNING ERM TASKS 1-3

As part of this task ERM completed the following activities

reviewed consent order statement of work

met with DOE and settling party representatives to detennine the status ofthe project assess the amount of available information and developcoordination plans

met with EPA and their representatives to present conceptual plans for

conducting the RIIFS and to obtain information regarding EPAs concernsat the site

visited the site to assess current conditions evaluate physical features as

they relate to site access and worker safety assess the condition of existingmonitoring wells preliminarily plan sampling locations and initiate thesite survey

collected and reviewed existing reports for the site and the adjacent ALlsite

developed conceptual model for the site relative to likely source areas andavenues of contaminant transport and general hydrogeology

identified data needs and data quality objectives

evaluated on preliminary basis available remedial alternatives

evaluated need for immediate treatability studies

identified on preliminary basis ARARs

prepared work plans

developed subcontractor contracts for surveying services and acquiredQAPPs from subcontract laboratories

established in-house data management procedures and

established in-house management structure for quality assurance/qualitycontrol purposes

EPA 04612

Work Plan 7-1

revised 1/21/91

215- Q2 02

The results of these activities are discussed in part within this work plan as well as

in the FSP QAPP HASP and SMP ERM will finalize the work plans following EPAs

review

7.1.1 ERM TASK Review Existing Data

The purpose of this task was to assess the quality and quantity of existing site data and

to determine how these data can be effectively and efficiently utilized in the RIIFS

detailed discussion of the data and the sources utilized is included in Section 2.0 and

3.0 of this work plan Data needs and data quality objectives for proposed work are

described in Section of this work plan To summarize existing data at the site ERMreviewed past reports aerial photos and other sources from state local and federal

government and academic and private data bases

7.1.2 ERM TASK Develop Site Plans

ERM contracted Holden Engineering of Salem New Hampshire Massachusetts RLSto complete site survey ERM also acquired aerial imagery from Eastern

Topographic which in conjunction with the land survey will be used to construct

topographic map of the site Holden will generate site base map referenced to NGVDwhich includes existing site conditions topography monitoring well locations and

site boundaries At the end of the Phase Ia field investigation Holden will update the

map to include any additional sampling points generated during Phase la of the RI

These will include but not be limited to

geophysical survey lines

monitoring and micro- well locations and elevations and

soil gas surface water surface soil stream sediment and test pit samplinglocations

The site base map is included as Figure 7-1 Topographic contours will have two

foot contour interval and map accuracy will meet the following minimum standards

for horizontal accuracy 90 percent of all defined points are within 1/40inch of their true position and 100 percent of all defined points are within1/20 inch of their true position

for vertical accuracy 90 percent of all contours are within one-half ofcontour interval and 100 percent of all contours are within one Contourinterval Ninety percent of all spot elevations are accurate to within one


215-02-02

EPA 04613

-t

TOWN

LIINE

NORTON

ATTLEBORO

SHPACKLANDFILL

SHPACK LANDFILLNorton Mti.achuaetta

lew England

Inc

fourth of the contour interval and all spot elevations are within one-half ofthe contour interval

mapping shows all planimetric features including but not limited tobuildings walks roads fences ditches trees utility poles tanks drumslagoons pits ponds and other such features visible on the photograph aswell as contours and spot elevations on roads dikes and ditch inverts

all horizontal and vertical control points are shown on the final map alongwith tabulation of coordinates and elevations The description originand elevations of the bench marks used for the mapping control are shownon the map

monitoring well locations were surveyed to horizontal plane surveyaccuracy of foot which was measured on the well casing cover Thevertical plane survey is accurate to 0.01 foot Three elevations weremeasured top of inner well casing if present top of outer protectivecasing if present and the concrete pad

photographic control points were kept outside the hazardous areas and

the map shows the basis of bearing north arrow date of photographynames of streets and highways project number project name and barscale

7.1.3 ERM TASK Develop Work Plans

ERM has developed work plans to ôomply with the Statement of Work for the RIIFS

for Shpack Landfill Superfund Site and in accordance with the Guidance for

Conducting Remedial Investigations and Feasibility Studies Under CERCLA The

work plan is dynamic document that may be reviewed and updated throughout the

RIIFS to ensure that the ultimate objectives of the RIIFS are met These documents

include the Project Operations Plan and the Initial Site Characterization Work Plan

7.1.3.1 Develop Project Operations Plan POP

The POP is made up of four components

The Site Management Plan SMP which addresses field responsibilities andorganization the site description and operational layout and data

management structures The SMP also contains the DOE Coordination Plan

The Sampling and Analysis Plan SAP includes the Field Sampling PlanFSP and the Quality Assurance Project Plan QAPP The FSP providesdetailed field procedures and the QAPP provides guidelines and standardsfor maintaining quality results


215-02-02 EP 04615

The Health and Safety Plan HASP identifies potential site hazards andprescribes preventative measures to reduce or eliminate risk to personnelIn preparing this document ERM addressed physical and chemical hazardsand the site and the DOEs amendment addressed radiological hazards at the

site and

The Community Relations Support Plan CRSP is designed to support EPAsown Community Relations Plan CRP This plan is not included as part ofthis submittal and will be completed upon receipt of EPAs CRP

7.1.3.2 Develop Additional Work Plans

As the RIIFS progresses additional work plans or work plan supplements may be

required to address developing circumstances and data needs This is further

addressed in Section 10.3 of this work plan

7.2 COMMUNITY RELATIONS

EPA has the lead in community relations and will be developing CRP for the site

that will detail the actions to be undertaken during the RIIFS In accordance with

EPAs Statement of Work ERM will develop CRSP that will outline ERMs and the

Settling Parties activities in implementing EPAs CRP

7.3 REMEDIAL INVESTIGATION ERM TASKS 4-14

ERM has developed phased approach for Phase la of the RI See Section

Schedule The completion of each task and the resulting information form the basis

for subsequent activities This approach ensures optimum results from each

investigative activity By carefully selecting sampling points based on data collected

earlier in Phase la ERM will characterize the site in more timely and efficient

manner than through random sampling Below is list of Phase la investigative

methods

sample existing wells

perform geophysical investigations

complete soil gas survey

excavate test pits

install micro-wells and monitoring wells and

sample ground and surface water and stream and wetlands sediment

Work Plan 7-5

revised 1/21/91 The

215-02-02 EPA 04616

As part of this approach ERM has initially addressed current data needs as identified

in -Section 6.1 of this work plan As preliminary data are evaluated ERM will reassess

data needs and will adjust subsequent Phase la activities to address these needs as

they arise rather than waiting until Phase lb In this manner ERM plans to

characterize the site and narrow the number of reasonable and technologically

feasible remedial options available at the earliest possible time in the RI/FS process

In implementing this phased approach ERM will submit work plan supplements

which describe the scope of later tasks In particular ERM anticipates that work

plan supplements will be required following ERM Tasks and 11 as described in

Section 10.3 of this work plan To meet the schedule of the Consent Order it will be

necessary for EPA to review and comment on work plan supplements in timely

manner To facilitate this ERM will inform EPA of all data as it is collected and advise

them of all planned sampling activities ERM will prepare conceptual model of the

site that will develop dynamically during the course of the RI

As currently planned ERM will conduct investigations within and around the

perimeter of the actual landfill Activities within the landfill currently include

seismic refraction surveys through the middle of the site

focused GPR and EM surveys in the area of proposed well couplet

potential soil gas surveys within the site perimeter especially in the areaof the power lines which may not be appropriate for geophysics

two well couplet in the area of drums south of the landlocked swamp andassociated soils and ground-water analyses

sampling of tar-like material exposed at surface of landfill and

surface water and wetlands sediment sampling in the landlocked swamp

The objectives rationale and brief description for each RI task are included below

Specific equipment and sampling methodologies for each task are described in the

FSP Data needs and data quality objectives are described in greater detail in Section

of this work plan

Work Plan 7-6revised 1/21/91 Tb215-02-02

7.3.1 ERM TASK Mobilize Personnel and Equipment

This task includes project orientation for all field personnel and subcontractors

ERM will inform all site workers of the site history project objectives quality

assurance requirements health and safety requirements contingency plans and

field procedures ERMs field team leader will ensure that members of the field team

are familiar with the field procedures specified in the FSP Specific lines of

communication will also be established at that time This task will also include

mobilizing field equipment and setting up field office and utilities

7.3.2 ERM TASK Collect Ecological Data

Limited ecological information about the site and off-site habitats is now available

The major habitat of concern is non-tidal wetland area to the east and north of the

Shpack landfill The Endangerment Assessment EA approach presented here

focuses on the wetland and aquatic habitat adjacent to the site The EA will also be

used to differentiate between any impacts attributable to the Shpack landfill and

other sources such as the AL landfill and background contamination from historical

industrial activity in the area

The EA program consists of the following elements

Identification of data needs available EA data and other information willbe reviewed to determine potential receptors and exposures site visitwill be conducted by experienced biologists with the objective ofidentifying any impacts attributable only to the Shpack landfill

Sampling plan development The media in the wetland will be selected andjustified At this time ERM proposes to conduct screening level EA usingavailable data and additional data collected as part of Phase la of the RIThe collection of these additional samples which will also be used for site

characterization is described in Sections 7.3.3 through 7.3.11 of this workplan and will include collection and analysis of upstream and downstreamsamples of water and sediment These data will be compared to ARARs andTBC to be considered guidelines potentially including sediment qualityguidelines screening level risk assessment makes use of available oreasily obtainable data and is based on established criteria and worst-caseassumptions concerning exposure

Wetland delineation jurisdictional delineation of the portion of thewetland near the Shpack landfill will be completed and mapped Thewetland vegetation known to be affected by the Shpack site contaminationwill be examined for signs of vegetative stress and the extent and severityof this stress will be characterized


revised 1/21/91 Tb71 215-02-02

7.3.3 ERM TASK Complete Health and Safety Testing and Air Monitoring

Two air quality surveys have been conducted at the site and are documented in

Bechtel 1984 and NUS 1985 as described in Section 3.0 of this work plan Bechtel

1984 focused on radiological analysis of air-bourne dust collected in filters and NUS

1985 focused on VOC parameters as captured in grab samples of ambient air Both

investigations concluded that radiological and VOC concentrations did not exceed

acceptable levels

During all on-site intrusive activities ERM will conduct worker health-based air

sampling for total VOCs using photo-ionization detector PID meter Each intrusive

sampling point will also be an ambient air monitoring location All monitoring will

conform to applicable OSHA provisions 29 CFR 1910 Air quality monitoring will be

conducted in accordance with the HASP and FSP and will be in accordance with Level

DQOs

In addition DOE representatives will screen ambient air quality and all

environmental samples for radioactivity as described in the HASP and FSP

7.3.4 ERM TASK Sample Existing On-Site Wells

This initial sampling round will be used to further characterize the site and to assist

in directing the locations for the soil gas survey and micro-well and monitoring well

installations

There are eight wells present within the fenced boundary of the Shpack site that

may be usable for ground-water sampling In addition one well DOE-3 lays outside

the fenced boundary north of the site These nine wells define the western eastern

and northern perimeters of the site

ERM will evaluate the suitability of utilizing these wells for sampling As part of this

evaluation ERM will

review original drilling and well construction logs

visually inspect the wells

verify the well construction including the presence or absence of lockingcasings and integrity of the cement cap

EPA 04619

Work Plan 7-8

revised 1/21/91 Th215-02-02

perform slug tests to determine in-situ hydraulic conductivity and whetherthe wells require re-development and

verify the locations of the wells and compare their locations to existingsite maps

The results of the evaluation will be used to assess what DQO levels may be attained

through sampling of those wells This assessment will be the basis for either

including or eliminating the wells from the RI program Those wells determined to

be adequate will be sampled according to the protocols established in the FSP

Samples will be collected and analyzed for volatile organic compounds VOCsconsistent with Level III DQOs The objective of the first sampling is to provide

preliminary and screening data therefore trip blanks will be the only QA samples

collected

7.3.5 ERM TASK Perform Geophysical Investigations

7.3.5.1 General Considerations

The purpose of the geophysical program is to

complement not duplicate initial surveys and previous studies

rapidly acquire as much information regarding subsurface conditions aspossible without the physical health and safety risks associated withintrusive investigations

define the subsurface stratigraphy depth to water depth to bedrock andbedrock condition on preliminary basis

determine the thickness of the landfill and the nature of the geologicmaterials beneath the landfill

delineate the perimeter of landfill deposits

delineate conductive ground-water contaminant plumes potentiallyemanating from the AL and/or Shpack landfills and

optimize the location of additional intrusive studies

All collected data will be correlated with previous data where possible and

integrated into the overall RI program

The geophysical program will utilize seismic refraction electromagnetic EM and

ground penetrating radar GPR surveys as shown in Figure 7-1 Areas of the site

Work Plan 7-9revised 1/21/91 mq215-02-02 EPA 04620

where geophysical methods may not be effective due to possible interference from

overhead power lines and fences will be investigated by the subsequent soil gas and

micro-well programs

7.3.5.2 Seismic Refraction Survey

Seismic refraction investigation will be conducted around the perimeter and

through the center of the site to

evaluate the boundary between the Shpack and the ALL landfills

determine the saturated thickness of unconsolidated sediments

determine the thickness of the landfill deposits

determine the potential presence and nature of bedrock fracture zonesand

evaluate the depth to relatively impermeable bedrock

7.3.5.3 Electromagnetic EM Induction Survey

The primary goal of the EM survey is to delineate EM anomalies which may indicate

areas of ground-water contamination and possible landfilled materials Landfill

leachate which Is highly conductive is particularly susceptible to detection by EMtechniques This method may be particularly useful in defining any contaminant

plume migrating onto the Shpack site from the adjacent ALL landfill and likewise

from the Shpack site to downgradient areas In addition the EM technique will detect

any buried metallic debris beneath the area surveyed

The EM survey will be primarily limited to the perimeter of the Shpack site howeverlimited EM data will also be acquired in the area of proposed well couplet near the

drum wastes adjacent to the landlocked swamp area The on-site survey will be used

for siting the well couplet by identifying subsurface anomalies prior to drilling

7.3.5.4 Ground Penetrating Radar GPR Survey

ERMs review of the previous GPR investigation indicated that only part of the site

was surveyed ERMs survey will add to the earlier work to attempt to define material

layering and objects below ground surface The GPR data will also be used in

conjunction with existing DOE data to locate and determine the limits of the landfill

Work Plan 7-10revised 1/21/91 Th215-02-02 EPA 04621

ERMs GPR survey will be conducted around the perimeter of the site GPR will also

be conducted near planned well couplet as described for the EM survey to identify

buried wastes which could influence the final well locations

7.3.6 ERM TASK Complete Soil Gas Survey

The objectives of the soil gas survey are to

characterize VOCs in soil and/or shallow ground water on preliminarybasis

provide data on geophysical anomalies

provide preliminary information in the areas where geophysics are not

appropriate

identify exceptionally hot spots and potential source areas of VOCs if

present

identify areas with clean shallow subsurface soils and

provide location guidance for subsequent micro-well and monitoring wellinstallations

The specific locations of the soil gas sampling points will be outlined in work plan

supplement to the EPA and will be based on

results of the sampling of existing monitoring wells

results of the geophysical program and

ERMs knowledge of subsurface conditions based on our review of existingdata

Approximately 60 soil gas points will be analyzed using PID meter for total VOCsThe analysis is consistent with Level DQOs which are appropriate for field

screening data used for focusing subsequent higher data quality activities These

sampling points will most likely be located around the perimeter of the landfill and

possibly below the power lines in areas unsuitable for geophysics however the

actual locations will be based on earlier information as specified above ERM will

collect soil gas samples from the unsaturated zone which will limit sampling to

shallow horizons


EP 04622215-02-02

7.3.7 ERM TASK 10 Excavate Test Pits

Following the completion and subsequent analysis of geophysical activities ERM will

submit work plan supplement detailing specific test pit locations This supplement

may be combined with the soil gas survey supplement

The purpose of the test pit program is to

confirm the results of the GPR investigation in terms of delineating the

edge of landfill deposits

visually observe subsurface conditions at the perimeter of the Shpacklandfill and

characterize soil quality at the edge of the landfill

The locations of the test pits will be based on

data from the geophysical surveys and

ERMs analysis of topography

Analysis of test pit soil samples will be according to standard headspace VOC analyses

using PID meter consistent with Level DQOs

ERM anticipates that test pits will not be excavated in the interior of the landfill

during Phase Ia since previous DOE investigations have adequately characterized this

area DOE will complete additional soil testing during Phase lb within the landfill to

characterize the organic and inorganic chemical content of known radioactive

areas In addition ERM will evaluate the appropriateness of test pits in the landfill

interior in the Phase lb work plan

7.3.8 ERM TASK 11 Install Micro-Wells

ERM will contract Pine Swallow Associates Inc to install eight micro-wells The

purpose of this task is to

help evaluate ground-water flow directions

provide additional information regarding the presence of VOCs in groundwater


EPA 04623Tb

begin to define the lateral outline of ground-water contaminant plumes if

present emanating from the AL and Shpack landfills and

focus the installation of subsequent ground-water monitoring wells

description of how micro-wells are installed is contained in the FSP Micro-wells

are only adequate for collecting data consistent with Level II DQOs which is suitable

for site characterization evaluation of remedial alternatives and monitoring during

implementation of remedial actions

The specific locations of the micro-wells will be outlined in work plan supplement

to the EPA and will be based on

results of the sampling of existing monitoring wells

results of the geophysical program

results of the soil gas survey and

ERMs knowledge of subsurface conditions based on review of existingdata

ERM anticipates that micro-wells will be installed at eight locations around the

perimeter of the Shpack landfill during Phase la of the RI Since the micro-wells do

not meet the more rigorous standards of monitoring wells ERM will only analyze

water from the micro-wells for VOCs using an on-site Photovac 10S50 Gas

Chromatograph GC which is consistent with Level II DQOs These data will be used

for characterizing ground-water quality and may also be used as part of later

conceptual engineering design activities

The micro-wells are constructed to allow for water level determinations The

elevations and locations of the micro-wells will be determined as part of Task 14

These data along with water levels from existing and new monitoring wells will be

used to construct water level maps for the Shpack site

7.3.9 ERM TASK 12 Install Ground-Water Monitoring Wells

7.3.9.1 General

The objectives of the monitoring well program are to

evaluate horizontal and vertical gradients


The

215-02-02 EPA 04624

determine the physical characteristics of the aquifer

characterize subsurface lithology and its effect on contaminant transport

assess ground-water flow directions

define the lateral outline of ground-water contaminant plumes if presentemanating from the edge of the ALl and Shpack landfills

determine potential pathways for off-site migration of contaminants

determine potential receptors and

provide data for the FS and Risk Assessment

If these objectives are not achieved during Phase Ia any remaining data gaps will be

identified in the Phase lb work plan and will be addressed during Phase lb activities

The specific locations of the monitoring wells will be outlined in work plan

supplement to the EPA and will be based on the results of

sampling of existing monitoring wells

geophysical program

soil gas survey

historical and Phase Ia preliminary water level measurements

micro-well sampling and

ERMs knowledge of subsurface conditions based on review of existingdata

The program will consist of drilling logging screening collecting soil and rock

samples and installing monitoring wells The wells will be installed in accordance

with ASTM standards by qualified OSHA-trained drilling contractor under the

direction of an ERM geologist Details of the program are included in the FSP

7.3.9.2 Number and Location

ERM estimates that seven wells will be installed around the perimeter and two wells

will be installed within the landfill during Phase Ia of the RI More wells may be

required during Phase la if the existing wells are unusable ERM currently

anticipates that

Work Plan 7-14revised 1/21/91 EPA 04625 Th

7/ 215-02-02

three perimeter wells will be drilled to the base of the overburden to assessvertical gradients within the overburden and horizontal gradients andwater quality at the overburden/bedrock interface Two of these wells will

be installed along the Shpack/ALI border and one will be installed alongthe northeastern side

four perimeter wells will be drilled to the water table Two of these will beinstalled adjacent to the two new deep overburden wells along the ALI/Shpack border The third will complement DOE-4 bedrock well and DOE-7

deep overburden well The final water table well will be installed alongthe eastern border along the power line access road and

two landfill interior wells will be installed as well couplet at the watertable and at the base of the overburden These wells will be drilled in thearea of stockpiled drums near the landlocked swamp along thenortheastern border of the site

As noted in Section of this work plan ground-water data currently exist for the

inierior of the landfill whereas little data are available regarding potential off-site

migration pathways of ground-water contamination To address the latter ERM will

concentrate Phase la activities on defining any potential off-site migration

pathways by installing primarily perimeter wells The Phase la data will be

evaluated to determine the appropriateness of additional interior landfill monitoringwells

7.3.9.3 Frequency of Soil Sampling and Analysis

Perimeter Wells

ERM will collect log and monitor split spoon samples at standard five foot interval

throughout the unconsolidated deposits in the seven perimeter wells utilizing

standard penetration techniques Analysis consistent with DQO Levels specified

below and described in the QAPP of the perimeter well split spoon samples will be

conducted as follows

field screening for VOCs using PID meter Level DQOs on all split spoonsamples

VOC analysis Level III DQOs on one sample from each boring selectedbased on total depth or PID results

SVOC analysis Level III DQOs on one sample from each of the threeproposed deep overburden wells as well as from one additional water tablewell at the same interval as the VOC analysis and

Work Plan 7-15revised 1/21/91 626215-02-02

total priority pollutant metals analysis Level III DQOs on one sample fromeach of the four shallow overburden wells from immediately below the

water table

The field screening results will be taken into account when the final screened

interval is selected and will be particularly important in selecting the screened

interval for the deep overburden wells In locations where well couplets are

proposed split spoon samples will only be collected from the deeper boring

Specifics of the split spoon sampling program are described in the FSP

The VOC and SVOC analyses will confirm the field screening results and will

demonstrate the concentration of contaminants if present within the strata with the

highest field screening results The metals analyses collected near the water table

will demonstrate whether metals known to exist at the landfill surface have leached

in significant concentrations to the water table interface

As part of the QA program one duplicate will be collected for each type of analysis

Landfill Interior Wells

Because of the nature of materials in the interior of the landfill ERM will sample and

analyze the split spoon samples from the deeper well continuously Since the landfill

interior wells will be installed as well couplet split spoon samples will only be

collected from the deeper boring Specifics of the split spoon sampling program are

described in the FSP

These samples will be analyzed as follows

field screening for VOCs using Photovac GC Level II DQOs on all split

spoon samples and

VOC SVOC priority pollutant metals DioxinsfFurans TPH and PCBs analysisLevel III DQOs of one sample from ground surface and one deeper sampleidentified as having the highest VOC content based on field GC results

The placement of the final screened interval will take into account the field

screening results and these results will be particularly important in selecting the

screened interval for the deep overburden well

Work Plan 7-16revised 1/21/91 lA7 Th215-02-02 EPA

The laboratory analyses will confirm the field screening results and will demonstrate

the concentration of contaminants if present within the strata with the highest

field screening results and at ground surface

rigorous approach to QA will be followed as described below

duplicate will be collected for each sample

matrix spike/matrix spike duplicate will be submitted for each methodand

trip blank will accompany each cooler

The exception to this approach is the dioxin/furan analyses for which distinct QAsamples have been assigned

7.3.10 ERM TASK 13 Sample Ground Surface Water and Stream WetlandsSediment

The ground and surface water and sediment quality data will be used for site

characterization risk assessment and engineering feasibility studies These data

will aid in defining contaminant migration pathways

7.3.10.1 Ground-Water Sampling

ERM will sample total of 18 wells including nine pre-existing and nine new

monitoring wells installed by ERM Of these 16 are perimeter wells and two are

landfill interior wells ERM is currently planning on the following analytical

scenario

all of the 16 perimeter wells will be analyzed for VOCs Level III DQOs

wells DOE-2 and within the fenced boundary of the site and ERMsseven proposed perimeter wells will be analyzed for SVOCs Level HI DQOs

wells ALI-8 -.9 and -10 and ERMs seven proposed perimeter wells will be

analyzed for dissolved priority pollutant metals Level III DQOs and

the two interior landfill wells will be analyzed for VOCs SVOCs prioritypollutant metals DioxinsfFurans TPH and PCBs Level III DQOs

Sampling of the micro-wells is described in Section 7.3.8 of this work plan and is

consistent with Level II DQOs No sampling and analysis of micro-wells consistent

with Level III DQOs is anticipated under this task since the methodology of


Th

215-02-02 EPA 046

construction of micro-wells is not as rigorous as that for monitoring wells and is not

adequate to meet Level III DQOs

The VOCs are likely to be mobile and therefore all wells will be analyzed for themSVOCs have never been detected in elevated concentrations in ground-water at the

site therefore only the ERM and DOE shallow wells within or along the fence will be

analyzed Since metals analysis is not recommended in stainless steel wells only the

on-site AL and ERM wells will be analyzed for priority pollutant metals Because the

two ERM interior landfill wells are near possible source area they will also be

analyzed for Dioxins/Furans TPH and PCB/Pesticidcs

ERM has outlined rigorous QA program for the ground-water samples total of 24

QA samples will be collected These will include

two-trip blanks or one per shipment

six-matrix spike/matrix spike duplicate pairs

one-equipment blank and

nine-blind duplicates

7.3.10.2 Aquifer Testing

As part of the monitoring well program ERM will complete in-Situ permeability tests

slug tests as described in the FSP These tests will aid in defining zones of greatest

ground-water flow and will help define contaminant transport pathways within the

aquifer For the duration of the Phase la investigation ERM will measure groundwater elevations monthly

7.3.10.3 Surface Water Sediment and Tar Material Sampling

Six surface water and six sediment samples will be collected as part of ERM Task 13South and east of the Site small stream flows northerly to Chartley Pond Between

the site and stream is variable expanse of wetlands Since both these areas are

potential receptors for surface runoff ground-water discharge and contaminant

migration surface water and sediment samples will be collected from pre-selected

locations Three surface water and three sediment samples will be collected from

within the landlocked wetlands area and the same number of samples from the

stream/wetlands system Figure 7-2


EPA 0462915-02-02

tIlal

tJJ

Shpack Landfill

Norton

MA

Ncw England

Locations

of Surface Water

and Sedlment Samples

Surface Water

and Sediment

Sample Locations

Figure

7.2 January 1991

Stream samples water and sediment will be taken upgradient of the site adjacent to

the site and downgradient from the site Samples will be taken in accordance with

the FSP ERM currently anticipates the following analytical program

VOC analysis Level III DQOs of surface water and sediment at all sixlocations

SVOC and priority pollutant metals analysis Level III DQOs of surfacewater and sediment at the farthest downstream sampling location and onesample from within the landlocked swamp and

additional SVOC and priority pollutant metals analysis Level III DQOs ofsediment at the upstream and midstream sampling locations

Four staff gauges will be installed as part of the hydraulic investigation at the

upstream midstream and downstream locations and within the landlocked swampSurface water elevations will be collected monthly in conjunction with ground-water

elevations

During ERMs recent site visit pit containing tar-like substance was identified

ERM proposes to sample this material for VOCs SVOCs priority pollutant metals

DioxinsfFurans TPH and PCB/Pesticides Level III DQOs

Due to laboratory difficulties in analyzing tar large number of QA samples will be

collected blind duplicate will be submitted for each analysis except dioxins/

furans Matrix spike/matrix spike duplicate pairs will be collected for VOCs SVOCsand priority pollutant metals and trip blank will be included with each shipment

7.3.11 ERM TASK 14 Update Site Survey

ERM will update the site survey by including all geophysical survey lines soil gas

points test pits micro-wells monitoring wells and surface soil surface water and

sediment sampling locations on the site base map This will enable ERM to accurately

locate sampling locations in the future and to aid in ensuring reproducibility of

results by allowing resampling

7.4 ERM TASK 15 ECOLOGICAL RISK ASSESSMENT

ERM will conduct screening level Endangerment Assessment EA to determine the

effects of contamination on the environment surrounding the Shpack Site


Th215-02-02

04631

screening level risk assessment is straight forward ecological risk assessment that

uses pre-existing data and Phase la site characterization data and is based on

established criteria and worst-case assumptions concerning exposure

The extent of the area studies will be based on the results of the characterization

work and review of information on wetlands adjacent to the site ERM will follow

the procedures and methods outlined in the Risk Assessment Guidance for Superfund

EPA 1989 and the Regional Supplemented Risk Assessment Guidance for the

Superfund Program EPA 1989

In the screening level risk assessment ERM will conduct the following tasks

An ERM field biologist will visit the site to delineate classify and determinethe function and value of the wetlands surface waters and othersenvironmental media surrounding the site The Federal Manual for

Identifying and Delineating Jurisdictional Wetlands USGPO 0234-01000683-8 and the Classification of Wetlands and Deeowater Habitats of theUnited States FWS/OBS-79/33 U.S Fish and Wildlife Service 1979 will beused for this task In addition the ten and hundred-year floodplain will bedescribed and delineated Information from FEMA maps will be reviewedand verified for this

ERM will evaluate habitat types in and around the site and will list plantand animal species both resident and transient

ERM will determine as appropriate if the species found at the site havesport or commercial uses or if they are protected endangered threatenedor are of some other special concern

ERM will use the data collected on the nature and extent of contaminationin surface waters ground water and sediments to evaluate how thatcontamination is or could affect the environmental media and potentialreceptors identified in Task through above For this task ERM will usereasonable worst-case assumptions regarding potential exposure toxicityand risk

Any data gaps remaining after completion of the EA will be identified in the Phase lb

work plan and will be addressed during Phase lb activities

Work Plan 7-21revised 1/21/91 EPA 04632215-02-02

7.5 ERM TASK 16 PREPARE INITIAL SITE CHARACFERIZATION REPORT

7.5.1 Sample Analysis/Validation

7.5.1.1 Sample Management

Sample management will be conducted as described in Section of the FSP ERM will

include any appropriate sample management documentation in the Site

Characterization Report These may include but are not limited to chain-of-custody

forms traffic reports photographs and copies of the field notebook

7.5.1.2 Data Validation

ERM will validate all data according to the QAPP Documentation from and results of

the validation will be included in the Site Characterization Report Data outside the

QAIQC limits will be qualified and discussed within the text of the report ERM will

also include the results of the laboratorys data validation with the RI report

7.5.2 Data Evaluation and Tabulation

All data collected during the record search and RI will be compiled on the computer

database discussed in Section 7.0 of the Site Management Plan Appropriate tables

and maps will be prepared to present as part of the Site Characterization report

Ground water elevation data and chemical concentrations will be plotted and

contoured on the site base map

7.6 ERM TASKS 17-23 PREPARE PHASE lb WORK PLAN

ERM will prepare work plan detailing the work to be completed in Phase lb

Though the existing site protocols will likely remain unchanged the work plan will

be necessary to outline subsequent activities designed to address remaining data

needs The work plan will include schedules procedures and sampling and analysis

plans The plan will be submitted to EPA for review and approval The Phase lb WorkPlan will also include the work plan submitted by the Department of Energy for

characterizing the radioactive component of the contamination


215-02-02 EPA 04633

7.6.1 Treatability Study/Pilot Testing

As preliminary RI data are evaluated the need for treatability study/pilot testing will

also be addressed The appropriateness of treatability study/pilot testing will be

evaluated on an ongoing basis during the course of the RI and FS If treatability

study/pilot testing is determined to be appropriate an addendum to the work plan

and the SAP will be issued to discuss the program

7.6.2 ERM TASK 23 Prepare RI Report

During Task 23 draft comprehensive report documenting Phase activities will be

prepared The draft report will be submitted to the Settling Parties for review and

comment and subsequently revised to address the comments The report format will

incorporate the elements listed below

RI Introduction Purpose and Objectives The introduction for the reportwill present the purpose scope and specific objectives of the report site

background information such as site description site history and previousinvestigations the organization of the report and DOE involvement

Field Activities Associated with Site Characterization. Details of the field

characterization activities including surveys of the various site media andall sampling and monitoring activities will be presented

Physical Site Characteristics. Characterization of the site will include

description of physical features surface water hydrology soils andgeology hydrogeology radiochemistry and ecology

Nature and Extent of Contamination. The nature and extent ofcontamination in environmental media as determined by the sitecharacterization will be discussed including source areas unconsolidatedand bedrock deposits surface water and sediments and ground water

Contaminant Fate and Transport. Contaminant fate and transport will beexamined based upon information gathered during site characterizedincluding potential routes of migration and contaminant mobilitymigration and persistence

Baseline Risk Assessment. The baseline risk assessment will evaluatehuman health impacts by assessing exposure and toxicity andcharacterizing associated risks

Summary and Conclusions The final section of the report will presentsummary and conclusions The summary will cover the nature and extentof contamination fate and transport of contaminants and risk assessmentConclusions will be presented regarding data limitations recommendationsfor future work and recommended remedial objectives


Th215-02-02

EPA 04634

ERM in conjunction with the DOE will prepare the Final RI report for submittal to

EPA

7.7 FEASIBILITY STUDY TASKS

As outlined in the NCP ERM will follow three phased approach to the FS In Phase

la ERM will establish remedial action objectives specifying contaminants and media

of concern potential exposure pathways and remediation goals As part of this first

phase of the FS ERM will also identify and evaluate potentially suitable technologies

including innovative ones

In the second phase of the FS ERM will assemble suitable technologies into remedial

alternatives and will conduct an initial screening of those alternatives based on

effectiveness implementability and cost

And in the final phase of the FS ERM will conduct detailed analysis of the

alternatives that remain after the initial screening

Each of these stages is explained more fully below

7.7.1 ERM TASKS 24-25 Develop Remedial Action Objectives and Identify and

Evaluate Technologies-

7.7.1.1 Develop Remedial Action Objectives

ERM will utilize the information generated by the DOE and earlier EPA reports and

the data from the RI to develop remedial action objectives specifying the

contaminants and media of concern the potential exposure pathways and remedial

goals

7.7.1.2 Develop General Response Actions

The general response actions are broad categories of possible cleanup methods that

may be used to address the remedial action objectives General response actions are

selected from among no action institutional controls containment removal

treatment and on-site or off-site disposal among others


EPA 04635215-02-02

7.7.1.3 Identfy and Evaluate Suitable Technologies

In this step ERM will identify and describe containment and treatment methods that

are potentially suitable for the site cleanup Each of these methods will be specified

for further evaluation in the technology screening However only an appropriate

number of representative process options for each method will be retained so the

number of technologies that must be screened and assembled into alternatives is

manageable

ERM will also identify appropriate innovative techniques if they potentially provide

similar degree of protection than conventionally employed technologies but at

lower cost or where conventional technologies cannot achieve the remediation goals

for the Site

Based on ERMs review of the available data on the site the types of feasible

technologies for Shpack will include for ground water restriction of ground-water

use through institutional controls and pump and treat techniques For contaminated

soil transport in surface waters and wetlands silt barriers or other erosion controls

And for soil and solid wastes in the landfill containment waste-in-place excavation

and treatment or possibly in-situ treatment

7.7.1.4 Technology Screening

In this step applicable technology process options will be screened based on

effectiveness implementability and cost The effectiveness screening will focus on

the ability of the technology process option to achieve necessary reductions in

contaminant mobility toxicity or volume in reliable manner Implementability

includes the topics of ease of installation and operation and regulatory/institutional

limitations on the process Relative cost among alternatives will be evaluated

qualitatively for both capital and operation and maintenance OM7.7.2 ERM TASK 26 Assemble Alternatives and Initial Screening

7.7.2.1 Assemble Alternatives

ERM will assemble suitable technologies into alternatives The selection of

technologies for assembly into alternatives will be based on the results of the


Tti

215-02-0204636

preliminary screening of technology and process options ERM understands the

types of problems associated with past waste disposal practices and mobility of

contaminants to other media from landfill facility To satisfy the Administrative

Order and requirements in the NCP alternatives will represent variety of remedial

options including no action containment and treatment measures including

innovative technologies

7.7.2.2 Initial Alternative Screening

The remedial alternatives assembled will undergo an initial screcning to reduce the

group of potential remedies to manageable number for further detailed screening

The criteria used for screening the alternatives are effectiveness implementability

and cost

The effectiveness evaluation considers the capacity of each remedial alternative to

protect human health and the environment during the construction and

implementation phase i.e short-term and the period after remediation is complete

i.e long-term Effectiveness in the short- and long-term is related to the reduction

in toxicity mobility and/or volume of contamination that each alternative provides

The implementability evaluation is used to assess the technical and administrative

feasibility of constructing operating and maintaining each remedial action

alternative In addition the availability of the pertinent component for technologies

involved in remedial alternative is considered Cost evaluation includes estimation

of capital OM and present worth costs These costs are order-of-magnitude

estimates and are prepared based on

Preliminary conceptual engineering for major construction components

Vendor information and ERMs previous site remediation experience

Unit costs of capital investment and general annual OM costs availablefrom U.S EPA documents

Capital cost estimates include the installed costs of such remedy components as

equipment and buildings site preparation and indirect costs such as engineering

health and safety legal and construction management Operation and maintenance

costs include such items as utilities treatment chemicals residuals disposal

monitoring and labor

Work Plan 7-26revised 1/21/91 EPA 04637215-02-02

7.7.3 ERM TASK 27 Detailed Analysis of Remedial Alternatives

The alternatives remaining after the preliminary screening will be subjected to

detailed screening with respect to the nine criteria This evaluation forms the basis

for the recommendation of proposed remedial measures for the site The NCP groups

the nine criteria under three categories

Threshold Criteria which include Overall Protection of Human Health andthe Environment and compliance with ARARs

Primary Balancing Criteria which include Long-term Effectiveness andPermanence Reduction of Toxicity Mobility or Volume Short-TermEffectiveness Implementability and Cost and

Modifying Criteria which include State Acceptance and Communitycc Pt an

The results of this screening against the nine criteria will be supplied in tabular

form Recommendations for site remedial measures will be developed from this

screening and presented at the conclusion of this task in the draft FS report

7.7.4 ERM TASKS 28-29 Feasibility Study Report

description of the screening process described and the results of the screening will

be summarized in draft FS report for Steering Committee and agency review This

report will conform to the format guidelines presented in the NCP and EPAs FS

guidance documents Comparative initial screening results for effectiveness

implementability and cost and the detailed analysis will be supplied in tabular form

The screening will be preceded by description of the site background and previous

work at the site The basis for items such as cost estimates and ground-water

extraction well design will be provided in appendices to the FS

Following receipt of agency and any public comments on the Draft FS ERM will

revise the draft FS to address these comments An itemized response to comments

received will be enclosed as an appendix to the final FS to aid in agency review

Work Plan 7-27revised 1/21/91 04638215-02-02

SECTION 8.0

BASELINE PUBLIC HEALTH RISK ASSESSMENT

baseline public health risk assessment will be conducted by the EPA to evaluate

potential human health risk The level-of-effort required to conduct baseline

assessment depends on the complexity of the site and the nature and extent of

contamination ERM will support the EPA assessment by providing data generated

during the RI As shown below there are four steps in the risk assessment process

that EPA will follow

Data Collection

Data collection and evaluation involve gathering and analyzing the sitedata relevant to the human health evaluation

Exposure Assessment

An exposure assessment is conducted to estimate the magnitude of actualand potential human exposures the frequency and duration of these

exposures and the pathways by which humans are potentially exposed

Toxicity Assessment

The toxicity assessment considers adverse health effects the relationshipbetween exposure and adverse effects and related uncertainties such as theweight of evidence of particular chemicals carcinogenicity or adverse

non-carcinogenic effects in humans

Risk Characterization

The risk characterization summarizes and combines information gained in

steps two and three both qualitatively and qualitatively Chemical-specifictoxicity information is compared against both measured contaminantexposure levels and predicted levels to determine whether current orfuture levels at the site are of concern

ERMs role in the Public Health Risk Assessment is supportive We will supply data on

the nature and extent of contamination found at the site EPA will be responsible for

assessing potential exposure and toxicity and characterizing risk

As described in Section of this work plan the data to be used in the risk assessment

will generally meet Level III and IV DQOs as recommended in the EPAs guidance on

Data Ouality Objectives for Remedial Response Activities EPA/540/G-87/003 The

Work Plan 8-1

revised 1/21/91 04639 mq215-02-02 EPJ

Level IV samples will generally be reserved for confirming some of the Level III

data ERM is anticipating collecting and analyzing three water either surface or

ground water and three soil either surface soil or sediment samples under Level IV

protocols as described in the QAPP The particular Level IV sampling locations will

be determined by ERM and EPA after preliminary Phase la data are evaluated

Work Plan 8-2

revised 1/21/91 EPA 04640215-02-02

--

SECTION 9.0

SCHEDULE

ERM will conduct its investigation in compliance with the schedule in the Statement

of Work and the Consent Order Table 9-1 Figure 9-1 indicates the general flow

diagram for an RIIFS project As shown the investigation and remedial action

selection is an iterative activity For planning purposes ERM has assumed one

month review period by EPA following each deliverable followed by one month

revision of documents and scheduling of activities period Figures 9-2 and 9-3 show

ERMs proposed overall schedule for the RIIFS at the Shpack Landfill site

Step Scoping the RIIFS

This includes ERMs Tasks through as described in Section 7.1 of this work plan

As shown in Table 9-1 the site work plans must be completed by January 28 1991

Figures 9-4 and 9-5 indicate the scheduling of Step activities

Step Initial Site Characterization Phase 1a

This includes ERMs Tasks through 17 as described in Section 7.3 of this work plan

As shown in Table 9-1 the initial site characterization report and Phase lb work plan

must be completed within 25 weeks from the authorization to proceed with Step

activities from EPA which is assumed to be March 1991 Thus the reports are due

on September 1991 Figures 9-6 and 9-7 indicate the scheduling of Step activities

Step Phase lb Field Work

This includes ERMs Tasks 18 through 23 as described in Sections 7.6 of this work plan

As shown in Table 9-1 the Draft RI report and Phase work plan must be completed

within 22 weeks from the authorization to proceed with Step activities from EPAwhich is assumed to be November 1991 Thus the reports are due on April 1992

Figures 9-8 and 9-9 indicate the scheduling of Step activities

Step Post-Screening Field Investigation and FS Development

This includes ERMs Tasks 24 through 28 as described in Section 7.7 of this work plan

As shown in Table 9-1 the Draft RIIFS must be completed within 26 weeks from the

Work Plan 9-1

revised 1/21/91 Th215-02-02

EPA 04721

Table 9--i

LIVERABL pU DAT

scoping Work Plan for RI/FS 14 afterthe RI/FS the ffectjvè

date of theConsent Order

Initial Site Initial Site 28 weeks afterCharacterization Characteizjzation EPA notice toPhase lit RI Report proceed with

Draft Baseline Risk StepAssessmentPhasi 1B Wôr Plan

Phase lB Draft RI 22 weeks afterField Work Development and EPA- notice toPhase lB RI Screening of proceed withPñase FS Alternatives Report step

Detailed AnalysisWork PlanPost-Screening FieldInvestigation Work Plan

Post-screening First draft RI/FS 26 weeks afterField Investigation EPA notice toand FS Development proceed withPhase RI next StepPhase FS

Additional RI/FS Second draft RI/FS to be

Drafts Reviews and subsequent drafts determinedand Revisions of the RI/FS is accepted by EPA

by EPA for public reviewand cotuinentresponsiveness sunmary is

completed and Record ofDecision is signed

1The.starting date for the Phase lit field activities shallbe March 1991 or the date of approval of the Work Plan for mqthe RI/FS whichever is later

Work Plan 9-2revised 1/21/91 EPA 04722

215-02-02

SCOPING

THE

RF3

POP

INITIAL SITE

CHAPACTE RIZATIONWORK PLAN

APA

AS

DATA REOUIREMENIS

FOR POTENTIAL REMEDIAL

ALTERNATIVES

AND

TECHNOLOGIES

BASELINE RISK

ASSESSMENT WORKPLAN

Af4 SC1Oj.4E

DEC

REViEW

STEP dTIAL

ShE CHARACTEF1ZAT PHASE

IA RI

FORRLFS

INiTIAL SITE

CHAPACTERIZATOu

PHASE

IA

FIELD WORK

BASELINE RISK ASSESMENT

INITIAL SITE

CHAPACTERIZATION REPORT

DRAFT BASELINE RISKASSESSMENT REPORT

PHASE

ID

WORKPLAN

STEP PHASE

18 FIELDWORK PHASE

18

RI

PE

PS

DEC\/

STEP POST.SCREENIUO FIELD RVESTGATON AND

IS

DEVELOPMENT PHASE

211 PHASE

PS

POSSCREEN1NGFIELD INVESTIQATOf

PiLOT STUDIES

Si

DETAILED ANALYSIS

Off ALTERNATiVES

FIR TOPFT RUIS

EPA

DEC

REViEW

DRAFT

RI

DEVCIOPMENT

AND

INITIAl SCREENING

Of

ALTERNATIVES REPORT

DETAILED ANALYStSWORPI.AU

POS1.SCREEMNOFIELD INVESTIÔAT1ONS

WcAKPt.AN

PHASE

IS

FIELD WORK

DEVELOPMENT

AND

IMTIAL SCREENING

OF

ALTERNATIVES

LII

NJ

.-LIEj-

FTR

NOTE Sb.p

Fry contht

o4

hye

m.eny

RIf

cshs

EPA desms

flt$by Topt.p.reub..quen

.ts o4

RVFS Siona1

IkI

o.tKni may

KEY

STEP ADDmOtIAL Rh/PS DRAFTS REVIEWS

AND REVSIOfts

PRP

Dh

PRPWc

FIGURE 9- FLOw DIAGRAM

OF RI/PS PROCESS

Pc

CD

Figure

9-2

Shpack Landfill Overall Rl/FS ProJect Schedule

LII

Rarlii StTt Latcul PInLib

IL1I

ZLIL9I 4/19/93

1/1190 411190 7/1/90 101190 111191 4/1/91 7/1/9 10/1/91 111192 411192 711192 1011/92 111191 411193 7/1/93

TEP SCOLlO

Ti p.1/Ft

EPAREVEWJ4J

TEP INITIAL SItZ CKAZ4CTUIWION PHAi2

IA

ThP pO21.3Cp WI/HG FLUD 1HVRSTX4Z1ON

AND

Ft DEVELOFVENT

ZPAEVIEW4

SThP NAtE 11 FlEW WORk

EPA REVIEW44

Firuri 9.3

EP REVIEW

ITEP ADDITIONAL P.1/Ft DRAFTS REVIEWS

AND REVISIONS

SJzpg.k Landfll Oyerpll Pj/FS ProlerL Schedgle

Figure

9-4

Sconin

the RI/FS

CD

20

12/5/9015/90

1/25/9

Earliest Start Latest Finish

LEGEND20

Duration

CD

10/22/90 11/5/90 11/19/90 12/3/90 12/17/90 12/31/90 1/14/91 1/28/91

Slit17 fIIlS

ERM contracted

to complete workplans

Task Review Existing Data

Task Develop Site Plans

Task Prepare Work

Figure

9-5

Plans

Submt Work Plans

Scoping

the RI/FS

Lii

00

L-I1

Figure

9-6

Initial Site Characterization Phase

la ScoDe

of Work

3I

HarIl.ut 3tart Lui.ai FtnI.h

Duration

Is

Jl

10/1/90 11/1/90 12/1/90 1/1/91 2/1/91 3/1/91 4/1/91 5/1/91 6/1/91 7/1/91 8/1/91 9/1/91 10/1/91 11/1/91 12/1/91

START PHASE

JA

Mobilize Personnel

and Equipmnt to Site

Task Collect Ecological Data

Task Complete Health

and Safety Testing

and

Air Monior4ng

fi

Task Sample E.eisig

On

Sag Wells JA

Task Complete Geophysical Investigatioiu SCOPE OF WORK

Task Perform Soil

Gas Survey

________ ________ ________ _________Task

10

Complete Test

Pit Program

__________ __________

Task

Ii

Install MIcro-Wells

Task

12 Install Ground-Water Monitortng Wells

Tas

13

Sample Ground Sirfacs Water

ind

Stream Wetland Sed..

fl

Task

14

Update Site Survey_________ _________ __________

Wait

for

CLP

ata

from Laboratory

Task

15 Conduct Ecological Rtsk Assessment

Task

16

Prepare Initial Site Characterization Report

Ta1sk

17

Prepare Phase

lb Work Plan

_______ ______ _______SUBMIT INtTIAL SITE CHARACTERTL4TION REPORT PHASE

lB WORKPLAN_______ ______

Figure

9-8

Phase

lb Field Work Scove

of Work

Lxi

11/19/91 11/20/91 11/22/91 3/11/92

Wait

for

CLP Data

11/12/91

from Laboratory

20

4/9/92

Earliest Start Latest FinishII

Duration

Liipj

CD

8/1/91 9/1/91 10/1/91 11/1/91 12/1/91 1/1/92 2/1/92 3/1/92 4/1/92 5/1/92

Task

22 Collect

STARTPHASEJB

Task

18 Remobilize

Task

19 Install Additional Wells

Tasks

20 Sample Grouzd Water

Additional Risk Assessment Samples

Task

21 Survey Site

Wait

for

CLP Data from Laboratory

Ph

Figure

9-9

ase

lb Field Work Scope

of Work

RT

eport

ES TIGA TION REPO

Task

23 Prepare Remedial

SUBMIT DRAFI

Investigation

REMEDIAL

JNV

authorization to proceed with Step activities from EPA which is assumed to be July

1992 Thus the report is due on December 1992 Figures 9-10 and 9-11 indicate the

scheduling of Step activities

Step Additional RIJFS Drafts Reviews and Revisions

This includes ERMs Tasks 29 and 30 as described in Section 7.7 of this work plan As

shown in Table 9-1 the due date for the Final RI/FS is to be determined by EPA ERMhas assumed that after two month review period by EPA that ERM can complete the

RIIFS by February 23 1993 Figures 9-12 and 9-13 indicate the scheduling of Step

activities


mq215-02-02

EPA 04732


LEGEND

Duration

iczu

re 9-10

Post-Scrcenin Field Investi2ation

and

FS Develooment Phase

3/24/92 711/92 10/20/92

3/1/91 11/20/91

3/1 5/91 12/9/92

LII

10 10

36

7/1/90 10/1/90 1/1/91 4/1/91 7/1/91 10/1/91 1/1/92 4/1/92 7/1/92 10/1/92

START FEASIBILITY STUDY

Task

24 Conduct Early Focused

FS Approach

EPA/DEP Review

Task

25

Develop Cleanup Actwties

and TechnoIoges

rask

26 Abemble Alternatives

and InitIal Screening

EPAIDEP RevewZ

Fifure

911 Task

27 Perform Detailed Evaluation

of Remedial Alternatives

fJjicreening Field Invesfiration Task

28

Prepare Draft Feasibility Study Repoi

nLY Developme.t Phase SUBMIT DRAFT

FS REPORT

1/1/93

Figure 9-12

ADDITIONAL RI/FS DRAFTS REVIEWS AND REVISIONS

2/9/93 2/22/93

Task

29

Incorporate

Comments/Revise

RI/FS Report

2/9/93 2/9/93

10

ARl

2/23/93 4/19/93

Task

30

2/22/93 2/23/93 Perform Post RI/FS

SupportEND_OF R1/FS _______________

40

-1111


IDI

Duration

CD

11/1/92 12/1/92 1/1/93 2/1/93 3/1/93 4/1/93 5/1/93

Task

29 Incorporate

START STEP1S

Comments/Revise RI/FS Report

ENDOFRI/FS4

Task

30 Perform Post RI/FS Support

Figure 9-13

ADD ITIONAL RI

IFS DRAFTS REVIEWS AND REVISIONS

tli

SECTION 10.0

10.1 STAFFING

PROJECT MANAGEMENT

This Work Plan includes general project staffing and responsibilities While all

personnel involved in an investigation and in the generation of data are implicitly

part of the overall project and quality assurance program certain individuals have

specifically delegated responsibilities The table below illustrates the staff

assignments and functions Task specific staffing responsibilities such as Quality

Assurance and Field Team are discussed more thoroughly in the appropriate

documents QAPP and FSP respectively

Staffing within ERM includes

Name

Robert Foxen P.E

John Drobinski P.G

Robert Dwyer Ph.D

John Gallagher

Duane Wanty

James Fitzgerald P.E

John McGlennon

John Starmer Ph.D

David Blye

Robert Deist C.E.T

Function

Coordinating Project Manager/Principal-in-Charge

Project Manager Remedial Investigation

Project Manager Ecological Risk Assessment

Project Manager Feasibility Study

Field Team Leader Remedial Investigation

Treatability Studies if needed

Community Relations Support

Radioactive Materials Specialist

Quality Assurance Manager

Health and Safety

CLP analytical services will be provided by Ceimic Corporation Ceimic of

Narragansett RI Non-CLP analytical services will be provided by Eastern Analytical

Laboratories EAL of Billerica MA Specific laboratory personnel with quality

assurance/quality control responsibilities include the Laboratory Quality Assurance

Officer and Laboratory Sample Custodian

EPA 04737

Work Plan

revised 1/21/91

215-02-02

10-1

10.1.1 Coordinating Project Manager/Principal-in-Charge

Robert Foxen will serve as the Coordinating Project Manager/Principal-in-Charge

The Coordinating Project Manager is an experienced manager and technical

professional who provides QA review and assists in the coordination of the RI RA and

FS components He also participates in major meetings and regulatory negotiations

and provides upper level ERM contact for the client

10.1.2 Project Manager Remedial Investigation

John Drobinski will serve as the remedial investigation project manager MrDrobinski is ERMs senior hydrogeologist and principal with ERM For the RI he

will manage overall project budget and schedule coordinate the RI on day-to-day

basis manage all day-to-day project activities maintain contact with the site

respondents prepare project status reports and participate in meetings and

regulatory negotiations

10.1.3 Project Manager Ecological Risk Assessment

Robert Dwyer will manage the Ecological Risk Assessment and has overall

responsibility for the day-to-day RA activities Mr Dwyer will direct the EA programand determine the need for additional data if necessary

10.1.4 Project Manager Feasibility Study

John Gallagher will serve as the Manager for the FS and has overall responsibility

for the day-to-day FS activities Mr Gallagher will also coordinate the FS tasks and

direct the FS team

10.1.5 Field Team Leader

Mr Duane Wanty will serve as the Field Team Leader for the Shpack Landfill RI/FS

In this position Mr Wanty is responsible for all field investigation tasks and for the

day-to-day activities of all ERM field personnel The Field Team Leader is also

responsible for all field quality assurance and all other non-analytical data quality

review Further responsibilities include the verification for accuracy of field

notebooks drillers logs chain-of-custody records sample labels and all other field

related documentation

Work Plan 10-2

revised 1/21/91iii

215-02-02EPA 04738

10.1.6 Treatability Studies if needed

James Fitzgerald will if needed coordinate direct and manage the treatability

studies

10.1.7 Community Relations Support

John McGlennon will act as project specialist for community relations support

Mr McGlennon will support negotiations and manage the community relations

activities

10.1.8 Radioactive Materials Specialist

John Starmer will act as the radioactive materials specialist for the project MrStarmer professional in nticlear waste management regulation will advise on all

radioactive aspects of the site work

10.1.9 Ouality Assurance Manager

Mr David Blye serves as Quality Assurance Manager on all projects requiring the

collection of data and as such is not directly involved in the routine performance of

technical aspects of the investigations The Quality Assurance Managers

responsibilities include the validation and qualification of all analytical data The

Quality Assurance Manager is also responsible for final review of all Tentatively

Identified Compound TIC mass spectra matching quality

10.1.10 Health and Safety

Robert Deist is the Health and Safety Manager and is responsible for overseeing the

development of the Shpack Landfill Health and Safety Plan HASP Although on-site

health and safety officers will be appointed for each task it is Mr Deists

responsibility to see that all field personal are familiar with and understand the

HASP

10.1.11 Department of Energy DOE Contacts

The following is list of the primary DOE personnel and DOE contractors

Work Plan 10-3

revised 1/21/91 Th215-02-02

EPA 04739

Name Company Position and Responsibility

Richard Robertson Bechtel PM ERM/DOE Coordination

Mike Redman Bechtel Health and Safety

Jim Wagner IXE FUSRAP PM

Bob Atkins IXE FUSRAP Site Manager

Technicians Eberline Health Safety Oversight Screening

Bechtel Subcontractor

10.2 MONTHLY STATUS REPORTS

The Steering Committee will submit monthly status reports to the EPA which will

include

summary of the work conducted during the past month including anyavailable results

schedule for work to be completed during the upcoming month and

discussion of any problems or delays which have been encountered or are

anticipated

10.3 SCOPE OF WORK MODIFICATIONS

Changes or amendments to ERMs work plan may be necessary through the course of

the RI/F5 as site conditions are better characterized and data needs are better

identified So that EPA is informed of all RIIFS activities by the Settling Parties ERM

will prepare work plan supplements as necessary to address work plan

modifications ERM currently anticipates submitting work plan supplements

after the geophysics program to scope out the test pitting and soil gas

programs

after the soil gas program to scope out the micro-well installation programand

after the micro-well program to scope out the monitoring well installation

program

Other modifications may be necessary

Work Plan 10-4revised 1/21/91 1h215-02-02

EPA 04740

SECTION 11.0

REFERENCES

Users Manual for Ecological Risk Assessment Oak Ridge National Laboratory 1986

Ambient Water Quality Criteria Documents for Priority Pollutants U.S EPA 1970-

1990

Quality Criteria for Water U.S EPA 1986

Ecological Endpoint Selection Criteria TRI and U.S EPA 1987

Ecosystem Model Selection Criteria TRI and U.S EPA 1987a

Ecological Risk Assessment Guidelines TRI and U.S EPA 1987b

Role of Acute Toxicity Bioassays in the Remedial Action Process at Hazardous WasteSites U.S EPA 1987

Superfund Exposure Assessment Manual U.S EPA 1988

Review of Ecological Risk Assessment Methods U.S EPA 1988a

Ecological Assessment at Hazardous Waste Sites U.S EPA 1989

Briefing Report to the EPA Science Advisory Board on the equilibrium PartitioningApproach to Generating Sediment Criteria U.S EPA 1989a and

Risk Assessment Guidance for Superfund Environmental Evaluation manual U.SEPA 1989c

RCRA Ground-Water Monitoring Technical Enforcement Guidance DocumentSeptember 1986 OSWER-9950.1

Compendium of Superfund Field Operations Methods December 1987 EPA/540/P-87/00

Guidance For Conducting Remedial Investigations And Feasibility Studies UnderCERCLA October 1988 EPA/540/G- 89/004

Interim Guidelines And Specifications For Preparing Quality Assurance Project PlansDecember 1980 EPA/600/H- 83/004

Data Quality Objectives for Remedial Response Activities March 1987 EPA/540/G-87/003

U.S.N.R.C 1979 Norton and Attleboro Surveys Radioactive Material in UncontrolledLocations February 12 1979

EGG 1979 Radiological Survey of the Shpack Site October 1979


Thq

215-02-02

Norton Conservation Commission 1980 Shpack Site March 17 1980

Shearer D.R 1980 Report on Results of Analyses of Test Well Water at AttleboroLandfill Site March 10 1980

GHR Engineering Corporation 1980 Report Evaluation of Attleboro Landfill

Monitoring March 25 1980

White R.A 1980 Memo re Shpack Site Visit from DEP Solid Waste Division toJeffrey Gould Southeast Region Water Pollution Control Engineer March 311980

DEP 1980 Letter re Monitoring at ALl and Shpack from DEP Southeast Region toMayor G..J Keane of Attleboro December 1980

Oak Ridge National Laboratory ORNL 1981 Radiological Survey of the ShpackLandfill Norton Massachusetts December 1981

Ecology and Environment 1982 Preliminary Assessment Form April 1982

Bechtel National Inc 1982 Project Report on Fence Construction at the FormerShpack Landfill Norton Massachusetts June 1982

Ecology and Environment 1982 Chemical Contamination at the Shpack LandfillNorton/Attleboro Massachusetts December 1982

Camp Dresser McKee Inc 1983 Preliminary Draft Remedial Action Master PlanShpack Landfill Site Norton/Attleboro MA February 1983

Massachusetts Department of Environmental Quality Engineering 1984 HazardousWaste Site Fact Sheet Shpack Landfill Norton/Attleboro MA February 1984

U.S EPA 1984 Site Analysis Shpack Dump Norton Massachusetts Interim April1984

Bechtel National Inc 1984 Radiological Survey of the Former Shpack LandfillNorton Massachusetts May 1984

EPA 1984 Hazard Ranking Score Worksheet May 24 1984

NUS Corporation 1985 Final Site Response Assessment SRA ReportShpack/Attleboro Landfill Incorporated Norton/Attleboro MassachusettsNovember 21 1985

Bechtel National Inc 1986 Site Plan for Shpack Landfill Norton MassachusettsNovember 1986

Wehran Engineering Corporation 1987 Shpack Residential Well Sampling ProgramRevised March 1987

ERT Analytical Laboratory 1987a Analysis of Water Samples from Shpack LandfillAttleboro Massachusetts April 28 1987


revised 1/21/91Tb

215-02-02

ERT Analytical Laboratory 1987b Analysis of Water Samples from Shpack LandfillAttleboro Massachusetts May 1987

ERT Analytical Laboratory 1987c Analysis of Water Samples from Shpack LandfillAuleboró Massachusetts August 12 1987

ERT Analytical Laboratory 1987d Analysis of Water Samples from Shpack LandfillAttleboro Massachusetts November 13 1987

Bechtel National Inc 1988 Record of Telephone Conversation with EberlineFebruary 18 1988

Agency for Toxic Substances and Disease Registry 1989 Preliminary HealthAssessment for Shpack Landfill Attleboro/Norton Massachusetts March 1989

U.S DOE 1990 Environmental Compliance Assessment for the Shpack Landfill SiteNorton Massachusetts July 1990

EPA Q4743


215-02-02

Cl

p.3

EPA 04744

QUALITY ASSURANCE PROJECT PLAN QAPP

EPA 04745

vI

TABLE OF CONTENTS

Page

1.0 PROJECT DESCRIPTION

1.1 SHPACK LANDFILL SUPERFUND SiTE 1-1

1.2 SHPACK QUALITY ASSURANCE PROGRAM 1-1

2.0 PROJECT ORGANIZATION AND RESPONSIBILITY 2-1

2.1 OVERVIEW 2-1

2.2 ERM QUALITY ASSURANCE STAFF 2-1

2.2.1 Coordinating Project Manager/Principal-in-Charge 2-I

2.2.2 Task Project Managers and Project Specialists 2-1

2.2.3 Quality Assurance Manager 2-1

2.2.4 Quality Assurance Chemist 2-3

2.2.5 Field Team Leader 2-3

2.3 LABORATORY QUALITY ASSURANCE STAFF 2-3

2.3.1 Laboratory Quality Assurance Coordinator 2-3

2.3.2 Laboratory Project Manager 2-3

2.3.3 Laboratory Sample Custodian 2-3

3.0 QUALITY ASSURANCE OBJECTIVES 3-1

3.1 DATA QUALITY OBJECTIVES 3-1

3.2 ERM QUALITY OBJECTIVES 3-2

3.2.1 Field Data 3-2

3.2.2 Non-CLP Analytical Data 3-3

3.2.3 CLP Analytical Data 3-8

EPA 04746

QAPPrevised 1/2/91

215-02-0


Page

3.3 LABORATORY DATA QUALITY OBJECTIVES 3-8

3.4 DATA MANAGEMENT OBJECTiVES 3-10

4.0 SAMPLING PROCEDURES CUSTODY AND ANALYTICAL METHODS 4-1

4.1 SAMPLING PROCEDURES 4-1

4.2 SAMPLECUSTODy 4-1

4.3 CALIBRATION PROCEDURES 4-2

4.3.1 Laboratory Calibration 4-2

4.3.2 Field Equipment Calibration 4-2

4.4 ANALYTICAL PROCEDURES 4-2

5.0 DATA REDUCTION VALIDATION AND REPORTING 5-1

5.1 DATA REDUCTION 5-1

5.2 ERMDATA VALIDATION 5-1

5.2.1 Field Data5-1

5.2.2 All Laboratory Data 5-2

5.2.3 Non-CLP Analytical Data 5-2

5.2.4 CLP Analytical Data 5-3

5.3 LABORATORY DATA VALIDATION 5-3

5.4 DATA REPORTING 5.3

EPA 04747

QAPP ii

Thqreviseu ijIyj215-02-02


Page6.0 INTERNAL QUALITY CONTROLS CHECKS AND FREQUENCY 6-1

6.1 LABORATORY INTERNAL QUALITY CONTROL CHECKS 6-1

6.2 FIELD INTERNAL QUALITY CONTROL CHECKS 6-1

7.0 PERFORMANCE AND SYSTEM AUDITS 7-1

7.1 ON-SITE AUDIT 7-I

7.2 LABORATORY AUDIT 7-1

8.0 PROCEDURES FOR ASSESSING PARCC 8-1

8.1 PRECISION8-1

8.2 ACCURACY8-1

8.3 REPRESEN1ITVENESs 8-2

8.48-2

8.5 COMPARABILiTy8-2

9.0 CORRECFIVEACTION9-1

9.1 LABORATORY CORRECTIVE ACTION 9-1

9.2 ERMCORRECrpjEAcrION 9-1

10.0 QAREPORTsToMAcip10-1

EPA 04748

QAPP iii

revised 1/22/91ii

215-02-02

LIST OF FIGURES

Page

Figure 1-1 Shpack Landfill Quality Assurance Program 1-2

Figure 2-1 Quality Assurance Project Personnel 2-2

Figure 5-1 Data Management Flow Chart 5-6

Figure 7-1 ERM Quality Assurance Audit Form 7-2

Figure 9-1 ERMs Corrective Action Form 9-2

1.1l

QAPP iv

revised 1/20/91Th

215-02-02

LIST OF TABLES

Page

Table 3-1 Quality Assurance Criteria for Field Data 3-4

Table 3-2 Quality Assurance Criteria for Laboratory Data 3-5

Table 3-3 Summary of Analyses 3-9

Table 4-1 Sample Handling Procedures 4-3

Table 5-1 Review of CLP Deliverables 5-4

EPA 04750

QAPPThrevisea i/u/yi

215 -02-02

APPENDICES

Appendix Laboratory Quality Assurance Project Plans

Ceimic Corporation

Industrial and Environmental Analysts Inc

formerly Eastern Analytical Laboratories

EPA 04751

QAPP vi

evisd 12091 ThQ

215-02-02

SECTION 1.0

PROJECT DESCRIPTION

1.1 SHPACK LANDFILL SUPERFUND SiTE

The Shpack Landfill site is an inactive mixed waste landfill that operated from 1946

until 1965 The landfill contains radioactive organic and inorganic wastes

The site is located about 40 miles southwest of Boston and covers an area of

approximately acres Of this area 5.5 acres is in the Town of Norton Massachusetts

and was owned by Mrs Isadore Shpack She sold the property to the Town of Norton

in 1981 The remaining 2.5 acres lie within the Attleboro Massachusetts and are

owned by the Auleboro Landfill Inc

1.2 SHPACK QUALITY ASSURANCE PROGRAM

This Quality Assurance Project Plan QAPP has been developed for the Shpack

Landfill RI/FS The QAPP provides concise guidelines and procedures for

maintaining the quality of all environmentally related measurements and results

This is accomplished by defining the following

project organization and quality assurance responsibilities

Data Quality Objectives DQO Levels least rigorous through Level IVmost rigorous DQOs are defined for each set of measurements or data

depending upon the type of data and the ultimate data use

methods and procedures used to evaluate data quality including the criteria

against which data quality is compared

standard procedures for reducing and reporting data

the number and type of quality control checks including both analytical

samples i.e trip blanks and field and laboratory audits and

procedures for corrective action

The Shpack quality assurance program addresses three major data types field data

non-CLP analyses and CLP analyses Figure 1-1 summarizes the ERM Shpack Quality

Assurance Program which is developed in this QAPP

EPA 04752

QAPP 1-1

revised 1/21/91

215-02-02

Figure

1-1

Shpack Landfill Quality Assurance Program

Field Non-CLP

CLP

Data Analyses Analyses

Levels

II Level

III Level

IV

Trip Blanks05

Calibration Duplicates

Equipment

Bla 4lanks

4J

Procedures

MS/MSD

Precision MS/MSD Precision

lab dupsPrecision/Accuracy

Accuracy trip blanksAccuracy lab/trip blanksDefined

by Manufacturer

Representiveness field dupsComparabilityComparability

Comparability equip blanksCompleteness

cO

CompletenessCompleteness11

Field Notebooks Field Notebook Field Notebook

Sampling

Log Sheets Chain-of-Custody Forms Sampling

Log Sheets

Equipment Calibration Sampling

Log Sheets Chain-of-Custody Forms

Calibration Frequency Sample Holding Times Traffic ReportsDetection Limits Laboratory Log-In Forms

Sample Holding Times

Lab

QA Report

Lab Standards

Detection Limits

Instrument Printouts

Quantitative Identification

Qualitative Identification

01

This document was prepared using the following references

EPA/600/4-83/004 Interim Guidelines and Specifications for Preparing

Quality Assurance Project Plans and

EPA/540/c3-87/003 Data Quality Objectives for Remedial Response

Activities

EPA 04754

QAPP 1-3

revised

SECTION 2.0

PROJECT ORGANIZATION AND RESPONSIBILITY

2.1 OVERVIEW

While all personnel involved in an investigation of this nature are implicitly part

of the Quality Assurance Program certain individuals are delegated the

responsibility for Quality Assurance Within the QAPP descriptions of the roles

related specifically to Quality Assurance QA and the personnel filling them are

included Figure 2-1 illustrates QA personnel and responsibilities

The CLP analyses will be conducted by Ceimic Corporation Ceimic in Narragansett

RI The non-CLP analyses will be conducted by Industrial and Environmental

Analysts lEA formerly Eastern Analytical Laboratory in Billerica MA

2.2 ERM QUALITY ASSURANCE STAFF

2.2.1 Coordinating Project Manager/Principal-in-Charge Robert Foxen

The Coordinating Project Manager is ultimately responsible for overall project

quality assurance

2.2.2 Task Project Managers and Project Specialists

Each project manager and project specialist is responsible for QA/QC within his

assigned task Each manager as appropriate is responsible for field and work audits

and all other non-analytical data quality review

2.2.3 Ouality Assurance Manager David Byle

The Quality Assurance Manager is not directly involved in the routine performance

of technical aspects of the investigations His responsibilities include the validation

and qualification of all reviewed data He is also responsible for final review of all

Tentatively Identified Compound TIC mass spectra matching quality

QAPP 2-1

revised 1/20/9

215-02-02 fJ

Figure

2-1

Quality Assurance Personnel

Shpack Landfill RIIFS

Coordinating

PM

Principal-in-Charge

Robert Foxen

P.E

LABORATORY QA/QC

ERM

NEW ENGLAND

INC QAIQC

Project ManagersCeimic Corporation Eastern Analytical Laboratories

QA/QC

for Designated Area

Quality Assurance Quality Assurance John Drobinski

RI

Coordinator Coordinator John Gallagher

FS

Dave DickinsonMike Wheeler Robert Dwyer

RA

Mike Wheeler

Lab Project Manager

Lab Project Manager

Diane Kenny

ANALYTICAL QAIQC FIELD QA/QC

Sample Custodian Sample Custodian

Ron Moretti Robert Peary

Quality Assurance Manager Field Team Leader

David BlyeDuane Wanty

Quality Assurance Chemist

Project Staff

Dan Cutugno

tl-n

2.2.4 Ouality Assurance Chemist Dan Cutugno

The Quality Assurance Chemist has primary responsibility for data validation and

review In this capacity the Quality Assurance Chemist will prepare analytical

quality assurance reports describing data usability

2.2.5 Field Team Leader Duane Wanty

The field team leader is responsible for all field quality assurance His

responsibilities include verification of field notes and sample chain custody field

team compliance with FSP protocols and laboratory coordination

2.3 LABORATORY QUALITY ASSURANCE STAFF

2.3.l Laboratory Ouality Assurance Coordinator

The Quality Assurance Coordinators duties specific to the project include

coordination with the ERM staff and the maintenance of all laboratory quality

assurance activities David Dickinson is the Quality Assurance Coordinator for Ceimic

Corporation Ceimic and Michael Wheeler is the Quality Assurance Coordinator for

lEA

2.3.2 Laboratory Project Manager

Laboratory Project Manager LPM has been assigned to the Shpack project by

both Ceimic and LEA The LPM is responsible for arranging for bottles scheduling

analyses and reporting to ERM The LPM is ERMs contact at the laboratory The LPM

at Ceimic is Diane Kenny Michael Wheeler will be acting as lEAs LPM as well as

their Quality Assurance Coordinator

2.3.3 Laboratory Sample Custodian

The Sample Custodians responsibilities include ensuring proper sample entry and

sample handling procedures by laboratory personnel The sample custodian are Ron

Moretti at Ceimic and Robert Peary at lEA

Pl

QAPP 2-3

rv 12091215-02-02

SECTION 3.0

OUALITY ASSURANCE OBJECTIVES

3.1 DATA QUALITY OBJECF1VES

The objective of the Quality Assurance Program is to ensure that data quality is

within an acceptable range that will not hinder the intended use of the data It is of

primary importance that the quality assurance/quality control activities described

in this QAPP achieve the Data Quality Objectives DQOs specified for each set of

measurements or data All data collected during the investigation will be analyzed

and reviewed according to DQO analytical support level which is appropriate to the

datas use The following five analytical support levels are defined by the EPA

Level Non-standard methods Analyses which may require methodmodification and/or development CLP Special AnalyticalServices SAS are considered Level

Level IV CLP Routine Analytical Service RAS This level is characterized

by rigorous QA/QC protocols and documentation and provides

qualitative and quantitative analytical data

Level III Laboratory analysis using methods other than CLP RAS This

level is used for investigations risk assessment and engineeringstudies using standard EPA approved procedures Someprocedures may be equivalent to CLP RAS without the CLPrequirements for documentation

Level II Field analysis This level is characterized by the use of portable

analytical instruments which can be used on-site or in mobilelaboratories stationed near site Depending upon the types of

contaminants sample matrix and personnel skills qualitativeand quantitative data can be obtained

Level Field screening This level is characterized by the use of portableinstruments which can provide real-time data to assist in the

optimization of sampling point locations and for health and

safety support Data can be generating regarding the presenceor absence of certain contaminants at sampling locations

The criteria by which the data are evaluated are dependent upon the DQO Level

Higher DQO levels require more rigorous data validation Data uncertainty may be

evaluated through review of field and laboratory QA procedures or of raw laboratory

QAPP 3-1

revised 1/21/91 EPA 04758215-02-02

Qro

data Additionally the data may be evaluated according to the parameters precision

accuracy representativeness completeness and comparability PARCC The

parameters are defined as follows

Precision measure of the reproducibility of measurements under

given set of conditions Precision will be assessed byanalyzing laboratory duplicates from the same samplejar and matrix spike duplicates which will be calculated

as relative percent difference RPDAccuracy measure of the bias that exists in measurement

system Matrix spike and laboratory control samplesperformed at the laboratory will be used to assess

accuracy which will be expressed in terms of percent

recovery

Representativeness The degree to which sample data accurately and precisely

represent selected characteristics Field replicate

samples will be used to assess representativeness whichwill be expressed in terms of RPD

Completeness measure of the amount of valid data obtained from the

measurement system compared to the amount that was

expected under ideal conditions Completeness will becalculated as the valid data percentage of the total tests

performed

Comparability measure that expresses the confidence with which onedata set can be compared with another Comparabilitywill be maximized by utilizing standard procedures for

field and laboratory operations and by participation in

performance evaluation programs

The Shpack QA Program Figure 1-1 is intended to fulfill data quality objectives and

to minimize uncertainty in the data To accomplish this goal DQO Levels and Criteria

objectives have been assigned to all data to be collected during the investigation

3.2 ERM QUALITY OBJECTIVES

3.2.1 Field Data

The QA objective with respect to the field investigation is to maximize the confidence

in the data Quality assurance of field data is accomplished through field equipment

calibration and standard field procedures

QAPP 3-2revised 1/21/91

EPA O475

Field screening data meets Level DQOs and includes pH conductivity and

temperature measurements water level readings and air quality readings Field

analysis with the Photovac field gas chromatograph GC meets Level II DQOs

All field data will be evaluated according to PARCC Instrument precision and

accuracy are usually specified by the manufacturer and are listed on Table 3-1

To ensure sample representativeness all sample collection will be performed in strict

accordance with ERMs Field Sampling Plan FSP Sample collection and handling

are discussed in detail in the FSP

The data quality objective for the completeness of data with respect to the sampling

field investigation is 100% Although this goal appears rather ambitious it can be

attained In the event 100% is not obtained the effect of the uncollected data will be

evaluated by the RI Project Manager as to its impact if any on project objectives

Corrective actions will be initiated to resolve any data gaps from the original

objectives found as result of less than 100% data completeness Every effort will be

made to obtain valid data for all sampling points particularly those considered to be

critical points

In order to establish degree of comparability such that observations and

conclusions can be directly compared with all historical data ERM will use

standardized methods of field analysis sample collection holding times and

preservation In addition field conditions will be considered in evaluating sampling

results in order to attain high degree of data comparability

3.2.2 Non-CLP Analytical Data

The majority of the samples to be collected will be used for site characterization

engineering design and risk assessment uses This objective can be met using non

CLP analysis and Level III DQOs

Evaluation of the non-CLP data will include collection of QA samples which will

provide the data for assessing PARCC The criteria for evaluating PARCC are listed on

Table 3-2

QAPP 3-3 EPA 04760revised 1/21/91

215-02-02

UfU

TABLE 3-1

Quality Assurance Criteria for Field Data

Measurement Instrument

ND HNU 101 0.2 ppm 0.5% for pure

Benzene

PID Thermo 0.1 ppm ApproximatelyEnvironmental 10%1OVM 580B

FID Foxboro 128 0.2 ppm

pH Ross pH Electrode 0.03 pH units 0.01 or 0.05%with an Orion SA whichever is

250 Meter greater

Conductivity YSI S-C-T Meter 10/25/250 5/25/250

umho/cm umho/cmdepending onthe scgle

Temperature ACT Orion Probe 0.1 degrees 0.1 degrees orModel 917001 with 1% whichever is

the SA 250 Meter greater

Water Levels Keck Water Level 0.01 feet 0.01 feet

Probe

Field GC Photovac 10S50

For QA criteria for the Photovac GC see FSP Appendix

QAPPrevised 1/20/9

215-02-02

3-4EPA Q476l

Precision Accuracy

Accuracy for the OVM 580B is dependent upon calibrationmaintained via standard calibration procedures

Accuracy will be

Accuracy for the OVA is dependent upon calibration and operatingtemperatures as shown in FSP Appendix Foxboro OVA 128 Instructions page

Accuracy varies with conductivity reading as shown in FSP Appendix YSIModel 33 SCT Meter Instructions page Figure

Table 3-2

Criteria Objectives for Laboratory Data

Precision Objectives Aqueous Solid/Other

Laboratory Duplicates and Field

Replicates unspiked

Volatiles all classes

Semivolatiles

Metals

PCBs

Dioxins/Furans

TPH

See EPA Method 8240

See EPA Method 8270

within 20% RPD1

See EPA Method 8080

See EPA Method 8280

within 21% RPD

See EPA Mcthod 8280 Table

within 21% RPD

See EPA Method

See EPA Method

within 30% RPD

See EPA Method

See EPA Method

within 9% RPD

QAPPrevised 1/21/91

215-02-02

3-5

EPA 04762

Table

Table

Table

Table

8240

8270

8080

8280

22%

24%

21%

21%

21%

23%

19%

47%

36%

38%

27%

47%

35%

50%

33%

50%

Table

Table

Table

Table

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

Laboratory Duplicates MSD2Vol at il es

1l-Dichloroethene

Trichlorobenzcne

Chlorobenzene

Toluene

Benzene

Semivolatiles

24-Trichlorobenzene

Acenapthene

24-Dinitrotoluene

Pyrene

N-nitroso-di-N-propylamine

4-Dichlorobenzene

Penthachiorophenol

Phenol

2-Chiorophenol

4-Chloro-3-methylphenol

4-Nitrophenol

Metals within 20%

PCBs within 30%

Dioxins/Furans

TPH

14%

14%

13%

13%

11%

28%

31%

38%

31%

38%

28%

50%

42%

40%

42%

50%

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

RPD

within

within

within

within

within

within

within

within

within

within

within

within

within

within

within

within

RPD

RPD

within

within

within

within

within

within

within

within

within

within

within

within

within

within

within

within

within 30% RPD

within 50% RPD

See EPA Method 8280 Table

within 9% RPD

Table 3-2 ContCriteria Objectives for Laboratory Data

Less than the quantitation limit Less than the quantitation limit

Less than twice the qualitation limit Less than twice the qualitation

Spikes Matrix SpikesMS GC/MS Target Compounds

Volatiles

MetalsLCS3 Data

PCBs

Dioxins/Furans

TPH

within 75-125% recovery

except Sb Ag

Not Established

see EPA Method 8280 Table



except Sb Ag

Not Established

see EPA Method 8280 Table


QAPPrevised 1/21/91

215-02-02

3-6

EP2 04763

Accuracy Objectives Aqueous

Blanks all Fractions

Field or Trip Blanks

Laboratory Blanks

limit

Solid/Other

11 -Dichioroethene within 61-145% recovery within 59-172% recovery

Trichlorobenzene within 71-120% recovery within 62-137% recovery

Chlorobenzene within 75-130% recovery- within 60-133% recovery

Toluene within 79-125% recovery within 59-139% recovery

Benzene within 76-127% recovery within 66-142% recovery

Semivolatiles

24-Trichlorobenzene within 39-98% recovery within 38-107% recovery

Acenapthene within 46-118% recovery within 31-137% recovery

24-Dinitrotoluene within 24-96% recovery within 28-89% recovery

Pyrene within 26-127% recovery within 35-142% recovery

N-nitroso-di-N-propylamine within 41-116% recovery within 41-126% recovery

14-Dichlorobenzene within 36-97% recovery within 28-104% recovery

Penthachiorophenol within 9-103% recovery within 17-109% recovery

Phenol within 12-89% recovery within 26-90% recovery

2-Chlorophenol within 27-123% recovery within 25-102% recovery

4-Chloro-3-methylphenol within 23-97% recovery within 26-103% recovery

4-Nitrophenol within 10-80% recovery within 11-114% recovery

Table 3-2 ContCriteria Objectives for Laboratory Data

Aqueous Solid/Other

Renresentativeness Objectives

Field Duplicates within 20% RPD within 20% RPDBlind or Labeled all analytes

Corn nieteness

All data will be assessed in terms of completeness by undergoing rigorous review with 100%objective Valid data will be complete without qualification while data considered deficient will be

qualified and their significance to the project described

ComparabilityAll field and laboratory methods will be standardized to provide maximum comparability bothwithin the overall investigation and with external sources of data

Notes

RPD relative percent difference

MSD matrix spike duplicate

LCS laboratory control sample

Control limits for the laboratories are listed in this table where applicable Objectives specified in

the current CLP SOW will be substitute where required

QAPP 3-7

revis1/21/91 EPA 04764

The QA samples include trip blanks equipment blanks and sample duplicates The

total number of samples to be collected the analytical parameters and frequency of

QA samples are outlined on Table 3-3 The submission of trip blanks will provide

check on accuracy Although accuracy is best assessed by evaluating the results of

blanks blanks do not monitor analyte losses The submission of blanks will

however monitor contaminants introduced with the sampling process preservation

handling shipping and the analytical process The data quality objective for trip

blanks and field blanks is to meet or exceed the contract required quantitation limit

CRQL CLP analyses In the event that the blanks are contaminated and/or poor

field duplicate precision is obtained the associated data will be qualified Through

the submission of field QC samples the distinction can be made between laboratory

problems sampling technique and sample matrix variability

3.2.3 CLP Analytical Data

Confirmatory samples to be used for the Risk Assessment will be analyzed using Level

IV CLP procedures This level is characterized by rigorous QA/QC protocols and

documentation and provides qualitative and quantitative analytical data

The CLP laboratory deliverables required by the Level IV DQOs will be closely

reviewed and evaluated

full assessment of PARCC will not be conducted for the CLP samples The CLP

samples will be chosen carefully so that the non-CLP PARCC evaluation will also

represent the CLP data To accomplish this ERM will collect non-CLP sample and

non-CLP sample duplicate at the same location and time as the CLP sample Criteria

objectives for PARCC are included on Table 3-2

3.3 LABORATORY DATA QUALITY OBJECTIVES

The laboratory will demonstrate analytical precision and accuracy by the analysis of

laboratory duplicates and matrix spike duplicates Precision as well as instrument

stability will also be demonstrated by comparison of response factors for calibration

standards Laboratory accuracy will be demonstrated by the addition of surrogate

and matrix spike compounds Accuracy will be presented as percent recovery

QAPP 3-8

revised 1/21/91 Th

215-02-02 EPA 04765

Votatiies

Semivotatlies

Dissolved

PP Metals

PCSs

Dioxin Furans

WH

13

19

48

48

48

58

23

27

30

23

21

MOTES

one trip blank will

be collected

for each

day

in the field

an equipment blank will

be collected

for

the metals filter

Analyses

for dissolved

PP Metals will

include field filtration through 0.45

micron membrane filter

TB-trip blanks

MS-matrix apikes

MSD-matrix spike duplicates

EB-equipment blanks

DUP-blind duplicates

Method numbers vary with metals

Metal Method

Antimony 5W6010

Arsenic SW7060

Beryllium SW6OIO

Cadmium SW6O1O

Chromium 5W6010

Copper 5W6010

Lead SW7421

Mercury SW7471

Nickel 8W6010

Selenium SW7740

Silver SW6O1O

Thallium SW7841

TABLE

3-3

SLLAMARY

OF ANALYSES

ANALt$is MATA$X ANALYTICAL REPOATtIG

NO4

OF

Th

MS

MSO

DUP TOTAL

hEThOD UNITS ANALYSES ANALYSES

pHF1 E150.1

pH units

48

Specific Conductance

FT E120.1 umho/cm

48

Temperature

FT E170.1 degC

48

30

13

19

SW8240

SW8270

SW8080

SW8280

E418.1

SW8240

SW8270

SW8080

SW8280

E418.1

Volatiles

ivot

at

les

Total

PP Metals

PCSs

Dioxin Furans

TPH

ug/L

ug/L

ug/L

ug/L

ug/L

ug/L

mg/kg

mg/kg

mg/kg

mg/kg

mg/kg

mg/kg

12

11

CLP Voiatiies

CLP

SOW 2/88 ug/L

CLP Semivolatifes

OLP

SOW 2/88 ug/L

CLP

PP Metals

CLP

SOW 7/88 ug/L

CLP Vofatiles

CLP

SOW 2/88 mg/kg

CLP Semivolatiles

CLP

SOW 2/88 mg/kg

CLP

PP Metals

CLP

SOW 7/88 mg/kg

Precision will be presented as relative percent differences RPD relative standard

deviation RSD or percent difference PD whichever is applicable to the type of QC

samples involved Laboratory method blanks will also demonstrate accuracy with

respect to the analyses The frequencies of laboratory duplicates matrix spike and

laboratory blanks are specified by the laboratories in their QAPPs Appendix

The analytical laboratory will be expected to process purge extract or digest an

aliquot of the sample such that the analytical results will provide high degree of

representation with respect to the sampling point In addition the analytical

laboratory will be expected to document all analytical problems encountered during

the course of the investigation Communication will be maintained with the

laboratory so that analytical problems encountered with critical sample points will

allow these samples to be re-collected if necessary Further the CLP laboratory will

be required to provide all data packages in CLP deliverable format to ensure that

analytical methods parameters and reporting units are compatible throughout the

investigation

3.4 DATA MANAGEMENT OBJECTiVES

It is data management objective that all aspects of the investigation from sample

design collection shipment analysis use/decisions etc be performed in

conjunction with rigorous QA/QC documentation

The overall data management objective is to provide complete data base with high

degree of confidence through the use of phased approach of sampling analysis

data assessment data review data qualification and feedback

ERM lEA and Ceimic will retain their data files for minimum of five years following

completion of the project

EPA 04767

QAPP 3-10revised 1/21/91 Th

215-02-02

SECTION 4.0

SAMPLING PROCEDURES CUSTODY and ANALYTICAL METHODS

4.1 SAMPLING PROCEDURES

The collection of all environmental samples will be performed in strict accordance

with U.S EPA recommended procedures as specified in the following documents

OSWER-9950.1 RCRA Ground-Water Monitoring Technical Enforcement

Guidance Document

EPA/540/G-89-004 Guidance for Conducting Remedial Investigations and

Feasibility Studies Under CERCLA

EPA/540/P-87/00 Compendium of Superfund Field Operations Methods

ERMs standard sampling protocols are applicable to wide type of environmental

investigations Site-specific procedures are presented in the Field Sampling Plan

4.2 SAMPLE CUSTODY

The primary objective of sample custody procedures is to create accurate written

records which can be used to trace the possession and handling of all samples from

the moment of their collection and shipment through analysis until their final

disposition Sample custody for samples collected during this investigation will be

maintained by the Field Team Leader FTL The FTL or field personnel are

responsible for documenting each sample transfer and maintaining custody of all

samples until they are shipped to the laboratory more specific discussion of the

field custody operations is included in Section 6.0 of the FSP

Laboratory sample custody begins when the sample arrives at the laboratory Details

regarding laboratory sample custody are included in Ceimics and LEAs QAPPs

PA04768

QAPP 4-1

revised 1/20/9

215-02-02 11w

4.3 CALIBRATION PROCEDURES

4.3.1 Laboratory Calibration

Laboratory calibration and frequency are specified in the required methods for both

the inorganic and organic analytes and are summarized in the laboratory QAPPs

4.3.2 Field Equipment Calibration

All field equipment will be calibrated at minimum at the beginning of each field

day Methods of and directions for calibration are detailed in the following sections

of the FSP

Photo Ionization Detectors

Flame Ionization Detector

Radiological Detectors air

Photovac Gas Chromatograph

pH Meter

Conductivity Meter

Radiological Detectors samples

4.4 ANALYTICAL PROCEDURES

FSP Appendix

FSP Appendix

FSP Appendix

FSP Appendix

FSP Appendix

FSP Appendix

FSP Appendix

All analytical procedures to be used are officially approved EPA procedures

appropriate methods and required holding times to be met are given in Table 4-1

analytical procedures will be conducted according to the following

Non-CLP Analyses SW846 Test Methods for the Evaluation of Solid Waste 3rd

Edition November 1986 and

EPA 600/4-82-057 Methods for Organic Chemical Analysisof Municipal and Industrial Waste-water July 1982

CLP Analyses CLP Statement of Work for Organic Analysis February1988 and

CLP Statement of Work for Inorganic Analysis July 1988

An Operations Summary for the Photovac field Gas Chromatograph is included in

the FSP Appendix

QAPPrevised 1/20/9

215-02-02

4-2

EPA 04769

Th

The

All

Table 4-1

4OmL l4days

4oz l4days

Total PP Metals

Total PP Metals

1L 7days

4oz l4days

500 mL 6mo8oz 6mo

cool

cool

HNO3topH2cool

Diss PP Metals 500mL 6mo HNO3topHc2field filter

1L 7/4odays

4oz 14/40 days

2L 7/40 days

oz 14/40 days

1L 28days

4oz 28days

8OmL4oz

cool

cool

cool

cool

cool

cool

CLPSVOCs

CLPSVOCs

3L 5/40 days

10/40 days

cool 4C

cool

CLP Total PP Metals

CLP Total PP Metals

1L 2sdays

4oz 28days

HNO3topH2

cool

CLP Diss PP Metals 1L 28days HNO3topH2field filter

Methods vary with metal see Table 3-2 of QAPPMethod numbers CLP Organic Statement of Work 2188

CLP Inorganic Statement of Work 7/88

first day indicates time to extract second day indicates time to analyze

G-glass VOCs- volatile organic compoundsP-plastic SVOCs- semivolatile organic compounds

QAPrevised 1/20/91

215-02-02EPA 04770

Sample Handling Procedures

VOCs SW8240VOCs SW8 240

SVOCs

SVOCs

SW8270

SW8270

HCI to pH2cool

PCBs/Pesticides SW8080PCBs/Pestlcldes SW8080

Dioxins/Furans SW8280

Dioxins/Furans SW8280

IPH E418.1

TPH E418.1

CLPVOCsCLP VOCs

10 days HCltopH210 days extract cool

waterS-soil

4-3

SECFION 5.0

DATA REDUCTION VALIDATION AND REPORTING

5.1 DATA REDUCFION

It is anticipated that ERMs data reduction for this investigation will be minimal and

will consist primarily of tabulating Ceimic and lEAs analytical results onto summary

tables through the use of computerized database management system All reduced

data will be assigned document control identification numbers and placed in the

central file maintained by the RI Project Manager

All analytical data obtained during the course of the investigation for ground water

will be reported as ig/L Analytical data for solid/soil samples will be reported as

xg/Kg on dry weight basis All laboratory analytical data will be summarized and

tabulated before final data submittal to the project team for use in the investigation

reports

All raw field data will be summarized reduced or tabulated for use in the

investigation reports by the Project Scientists Reduction of the data generated by

the Photovac field gas chromatograph will be conducted according to protocols

established in the Field Sampling Plan Appendix The results of the data reduction

will be included in the project files

5.2 ERM DATA VALIDATION

5.2.1 Field Data

Quality assurance of field data is accomplished through use of standard field

protocols To ensure that the correct protocols are in use all field team members will

be briefed by the Field Team Leader prior to beginning site work and will be expected

to be familiar with the site-specific Field Sampling Plan Additionally the RI Project

Manager will perform field audits during the initial sampling events of the

investigation to document that the appropriate procedures are being followed for

sample and blank collection These audits will include thorough review of the

field books used by the Project Personnel to ensure that all tasks were performed as

QAPP 5-1

revised 1/16/91EPA 04771

specified in the instructions The field audits will necessarily enable the data quality

to be assessed with regard to the field operations

Data review will occur to ensure that raw data are not altered and that an audit trail is

developed for those data which required reduction All the field data such as those

generated during field measurements observations and field instrument

calibrations will be entered in pen directly into bound field notebook Each project

team member will be responsible for proofing all data transfers made and the Field

Team Leader will proof at least ten percent of all data transfers Any corrections or

alterations of information in the field notebooks will be accompanied by the initials

of the person making the changes and the date of the change

Following each task the data collected will be evaluated for completeness and

comparability If either parameter does not meet the objective for field data an

explanation or qualifier will be added to the data Finally the evaluation data

review of trip and field blanks and other field QC samples will provide definitive

indications of the data quality If problem arises which can be isolated corrective

actions can be instituted for future field efforts

5.2.2 All Laboratory Data

preliminary review of the CLP and non-CLP data will be performed to verify that

all necessary paperwork chain-of-custodies traffic reports analytical reports

laboratory personnel signatures and deliverables are present for each laboratory

During the course of the data review an organic and inorganic support

documentation package is prepared which will provide the backup information that

will accompany all qualifying statements presented in the quality assurance review

Once the review has been completed the Quality Assurance Manager will verify the

accuracy of the review and will then submit these data to the RI Project Manager

These approved data tables and quality assurance reviews will be signed and dated by

the Quality Assurance Manager

5.2.3 Non-CLP Analytical Data

The non-CLP data will be evaluated according to PARCC Additionally the data will be

QAPP 5-2

revised1 1/16/91 EPI Q4772215-O2-02

reviewed regarding the following

Custody procedures

Presence of contamination in trip blanks

Sample holding times and

Detection limits

5.2.4 CLP Analytical Data

The CLP analyses will be prepared utilizing full CLP deliverables The required

deliverables are specified in Section of the CLP SOW both organics and

inorganics detailed quality assurance review will bç performed by the ERMQuality Assurance Chemist to verify the qualitative and quantitative reliability of the

CLP data as it is presented This review will include detailed review and

interpretation of all data generated by Ceimic The primary tools which will be used

by experienced data review chemists will be guidance documents established

contractual criteria and professional judgement Table 5-1 presents the items

examined during the quality assurance review for data reported using CLP

deliverables Precision accuracy comparability and completeness will be calculated

from the laboratory data

5.3 LABORATORY DATA VALIDATION

Specific measures that will be taken by Ceimic and lEA to assess data quality are

presented in Appendix

5.4 DATA REPORTING

ERM will require rigorous data control program which will ensure that all

documents for the investigations are accounted for as they are completed Figure 5-1

summarizes the data management and the flow of validated data Accountable

documents include items such as logbooks field data records correspondence chain-

of-custody records analytical reports data packages photographs computer disks

and reports The Project Manager is responsible for maintaining central file in

which all accountable documents will be inventoried

To maintain control in the transfer of data all copies of raw data from the field

notebooks and the data as received from the laboratory will be entered into data

QAPP 5-3

revised 1/16/91 EPA 04773 Thq

215-02-02

cItutip

Table 5-1

Review of CLP Deliverables

Area Examined Applicability

organic inorganic both

ERM and Laboratory Chain-of-Custodies Both

Traffic Reports Field Notes etc

Holding Times Both

Extraction/Digestion Logs Both

Blanks field and laboratory accuracy Both

Instrument Tune Organic

Standards Both

Linearity Both

Sensitivity/Stability Both

Selectivity Specificity Both

EPA Criteria SPCC LCS Both

Variability of Technique

internal standards Organic

Analyte Breakdown Both

Analytical Sequence Both

ICP Interference Inorganic

Control Standards Both

Samples

Detection Limits Both

Instrument Printouts

ICP Data Inorganic

AA Data Inorganic

GCData Organic

GC/MS Data Organic

Autoanalyzer Data Inorganic

Qualitative Identification Organic

Mass spectra Organic

Pesticide/PCB results Organic

Tentatively identified compounds Organic

QAPP 5-4revised 1/20/91 O47

Table 5-1 continued

Review of CLP Deliverables

Area Examined Applicability

organic inorganic both

Quantitative Reliability Both

Calculations/Equations

Matrix spikes accuracy Both

Bias

Matrix spike duplicated Organic

Bias

Accuracy Precision

Surrogate Spikes Organic

Bias

Duplicated field and laboratory Both

Precision

Representativeness

Post-Digestion Spikes Inorganic

Matrix Effects

EPA 04775

QAPP 5-5

revised 1/20/91

215-02-02

cjr

1i

Figure

5-1

Data Management Flow Chart

Validation _______Reduction

Non-CLP

Analytical

Results

ERM

Field

Data

ERM

Project

Files

Archiving

of Data

file and assigned an appropriate document control identification number The data

file will serve as the ultimate archive for all information and data generated during

this investigation

Based upon the review of the analytical data an organic and inorganic quality

assurance report will be prepared which will state in technical yet user friendly

fashion the qualitative and quantitative reliability of the analytical data The report

will consist of general introduction section followed by qualifying statement that

should be taken into consideration for the analytical results to best be utilized Based

upon the quality assurance review qualifier codes will be placed next to specific

sample results on the sample data table These qualifier codes will serve as an

indication of the qualitative and quantitative reliability

This report will be submitted to the RI Project Manager who will assess the quality of

the data from an overall management perspective This may be done by direct

comparison of analytical results with results obtained from previous sampling

rounds

EPA 04777

QAPP 5-7revised 1/16/9

215-02-02

SECTION 6.0

INTERNAL OUALITY CONTROLS CHECKS AND FREOUENCY

6.1 LABORATORY INTERNAL QUALiTY CONTROL CHECKS

Ceimics and lEAs Internal Quality Control Checks are presented in their respective

QAPPs in Appendix These will be continuation of ERMs Field Internal Quality

Control Checks presented below

6.2 FIELD INTERNAL QUALITY CONTROL CHECKS

Field Internal Quality Control Checks will be utilized during this investigation

through the use of the following

Trip Blanks These blanks consist of ultrapure deionized water contained in each

type of sample container with any preservatives required for that analysis Trip

blanks will normally be supplied by the analytical lab or be prepared by ERM

using ASTM Type II Water from chemical supply house These blanks will

accompany the samplers during the sampling process and will serve as QC check

on container cleanliness external contamination and the analytical method

Trip blanks will be submitted blind using fictitious sample location once per day

or per shipment cooler for ground water samples

Equipment Blank Equipment blanks will be collected to ensure that sampling

equipment is clean and that the potential for cross contamination has been

minimized by the equipment decontamination procedures These blanks will be

collected by decontaminating the sampling device and then passing ultrapure

deionized water as described above over or through the device This water will

either be poured directly into the sample container or first collected into clean

stainless steel bowl and then transferred to the appropriate sample container

One equipment blank will be collected for each sampling device associated with

the ground water sampling and soil sampling The ground water sampling

devices for which equipment blanks will be collected include the sampling bailer

and the MilliporeTM pressure filter The equipment blanks will be analyzed for

QAPP 6-1

revised 1/21/91

215-02-02 EPA 04778

the identical parameter as the samples Equipment blanks are not collected when

dedicated sampling equipment is used

Duplicate Samples Blind duplicate samples will be collected to allow

determination of analytical and sampling precision One duplicate sample in

every twenty 20 ground water or soil sample will be collected and submitted for

the identical parameters as the true sample

Matrix Spike Sample Matrix spike/matrix spike duplicates MSIMSD samples will

also be submitted as further QC checks These samples will be spiked at the

laboratory These will be collected at the frequency of one MS and MSD for every

twenty 20 field samples These will allow accuracy to be determined by the

recovery rates of compounds the matrix spike and/or surrogate spike compounds

defined in the analytical methods Precision will also be assessed by comparison

of matrix spike duplicate recoveries The purpose of these laboratory spikes is to

monitor any possible matrix effects specific to samples collected from the Shpack

site The addition of known concentrations of compounds/constituents into the

sample also monitors extraction/digestion efficiency

Matrix spike/matrix spike duplicate samples are collected as separate samples and

are noted as UMS/MSD on the container labels

The number of quality control samples collected by ERM will depend upon the sample

DQOs ERM will minimize the number of equipment blanks by dedicating sample

collecting equipment when possible

QAPP 6-2

revisefrl 1/21/91 ThQ

21542-02EPA 04779

SECTION 7.0

PERFORMANCE AND SYSTEM AUDITS

7.1 ON-SITE AUDIT

One on-site system audit will be performed during soil and ground water sampling

event to review all field-related quality assurance activities The system audit will be

conducted by ERMs RI Quality Manager Figure 7-1 presents ERMs Quality Assurance

Audit forms Deficiencies found during the audits will be brought to the attention of

the responsible individuals and corrective action as per Section 9.0 of this QAPP will

be initiated Copies of the audits will be distributed to all project personnel and to the

Shpack Steering Committee

Specific elements of the on-site audit include the verification of the following

Completeness and accuracy of sample Chain-of-Custody forms includingdocumentation of times dates transaction descriptions and signatures

Completeness and accuracy of sample identification labels includingnotation of time date location type of sample person collecting samplepreservation method used and type of testing required

Completeness and accuracy of field notebooks including documentation of

times dates drillers names sampling method used sampling locationsnumber of samples taken name of person collecting samples types of

samples results of field measurements soil logs and any problemsencountered during sampling and proper initializing/dating of notebook

changes

Adherence to health and safety guidelines outlined in the Site Health and

Safety Plan including wearing of proper protective clothing and properdecontamination prior to leaving the site

Adherence to decontamination procedures outlined in the FSP including

proper documentation of pumps and pump tubing bailers and samplingequipment

Adherence to sample collection preparation preservation and storage

procedures

7.2 LABORATORY AUDIT

Ceimic and lEA perform regular systems and performance audits and these are

described in their respective QAPPs in Appendix

QAPP 7-1

revised 1/21/91 Th

215-02-02

EPA 04780

Figure 7-1

ERM QUALITY ASSURANCE AUDIT

PROJECT ________________________ W.O

DATE ________________ TIME

AUDITORS

ON-SITE SAMPLING PERSONNEL ____________________

Audit Conducted on the Following

________ Soil Sampling Decontamination

_________ Surface Water/Sediment

_________ Ground Water

Yes No N/A Not Applicable N/D Not Determined

Sample Collection

Do sampling locations agree with those specified

in the Work Plan/Sampling Plan

Is the sampling location either documented

sufficiently or marked to allow it to be found/

sampled again in the future

Are sampling times ERM Traffic Report Numbers and

sample description noted in the FNB

Is sampling proceeding from the suspected least

contaminated area to the most contaminated area

Have all field measurements been properly taken as

per Sampling Plan

Have sample bottles been labeled properly

Have proper containers and preservatives been used

Are proper sample volumes procured

7-2ThQ

EPA 04781

Have MS MSDs been collected as per QAQC Plan

Does travel blank exist for each matrix present

Are samples being refrigerated/iced imrnediatly

after collection

Has condition of sample been recorded in the ENE

and in the traffic report

Does the potential for sample cross-contamination

exist based on procedures observed

Have legal seals been properly filled out and

attached to the shipping containers

Soil Sampling Check if not applicable

Type _____ Hand _____ Auger or Rig

Are samples being collected at proper depths

Are samples being screened with an OVA ifspecified in Work Plan and applicable

Is description of soils/materials being logged

Have soils been homogenized where applicablespecified by the Sampling Plan

Surface Water/Sediment Sampling Check if not applicable

Have stream flow and velocity parameters been noted

Estimated or Measured

Has sampling proceeded from downstream to upstream

locations

Has the sampler acquired the water sample upstream

of his position to minimize suspended sediment

from entering the sample

Have water samples been collected in the mixingzone not stagnant areas

Have sediments been characterized as to type and

size distribution

Has the proper sediment fraction fine depthbeen sampled for the analyses of interest

7-3

EPA 04782

Ground Water Sampling Check if not applicable _______Have depth to water level readings been taken for

all wells

Have the well specifications been noted properly

i.e total depth casing diameter depth-to- water

to the nearest one-hundredth of foot etcHas the purge volume been calculated properly

Have OVA readings been obtained when the well head

was opened

What evacuation method has been used

______ Bailer ______ Submersible ______ Bladder pump

_______ Other

Foltz pump

If metals are being analyzed have the samplesbeen field filtered

Are field pH conductivity and temperature beingmeasured and documented ______ Is there

documentation of calibrating the instruments

Has well yield been properly evaluated to

determine when sample aquisition should take place

i.e does well go dry and needs to recover

Is bailer line and bailer dedicated to each well

and line disposed of after useBailer type ____________ Line type ____________

Have appropriate measures been taken to dispose of

contaminated purge water pump lines bailers etcFor Domestic Wells Has as much information on the

well and distribution system been obtained

i.e depth casing type diameter treatment

present etcHas the sample been collected prior to treatmentand as close to the well head as possible

7-4Th

EPA 04783 -ciroup

Has the domestic well been purged sufficiently toreach temperature stabilization

Have any fixtures been removed from the domesticwell before the sample was taken

Have the weather conditions been recorded

Decontamination

Has sampling equipment been decontaminated

properly for the given analytes as per QA Plan

Have the proper decontamination solutions been used

For large equipment backhoes drill rigs hasdecontamination taken place in an appropriate area

Has decontaminated water/solution been collected for

proper disposal _____ Where disposed __________

Has disposable equipment that is contaminated

been properly deconned and disposed of

Kept containerized on site

Have decon samples been taken from the samplingequipment as per Sampling Plan

General

Has all appropriate information been recorded inthe FNB

Are employees conducting the investigation in

professional manner

Are the objectives of the sampling activitiesunderstood by the field personnel

Are weather 1condjtions affecting sample quality

75 EPA 04784

Audit Suxamary and Comment8

Signed bySampler _____________________________ Print Name

Auditor _______________________________

Dt _______________aetat

7-6 EPA 04785

Section 8.0

PROCEDURES FOR ASSESSING PARCC

8.1 PRECISION

Precision is assessed by analyzing laboratory duplicates from the same jar and

matrix spike duplicates Precision is calculate as relative percent difference RPD if

there are only two analytical points and relative standard deviation RSD if there

are more than two analytical points

RPD_MjMp_ 100%

Mi M2/2

where Ml and M2 are measurements and respectively

RSD SD 100%

where SD is the standard deviation and is the mean

8.2 ACCURACY

The submission of trip blanks will provide check on accuracy Although accuracy

is best assessed by evaluating the results of blanks blanks do not monitor analyte

losses In the event that the blanks are contaminated the associated data will be

qualified Accuracy is also evaluated through matrix spike and laboratory control

samples Accuracy is calculated as percent recovery as follows

PDQ xlOO%

Qa

where PD is the percent recovery Qd is the quantity determined by analysis and Qa is

the true value

revised 1/16/91

8-1

215-02-02 EPA 04786

8.3 REPRESENTITIVENESS

Representativeness will be expressed as RPD between duplicate samples and is

calculated using the equations listed under Precision

8.4 COMFtEENESS

Completeness is calculated as the percent of valid measurements divided by the total

number of measurements

bOY

where is percent completeness is the number of measurements judged valid and

is the total number of measurements

8.5 COMPARABIUTY

Comparability is assessed through establishing standard field procedures and

evaluating adherence to those procedures This is done by reviewing field notes and

conducting site audit

QAPP 8-2

revise7l/16/91EPA 04787

SECTION 9.0

CORRECTIVE ACTION

9.1 LABORATORY CORRECTIVE ACTION

Corrective actions procedures used by Ceimic and lEA are presented in their QAPPs

Appendix Both laboratories will provide documentation as to what if any

corrective actions were initiated concerning this study and report them to ERMs

Project Manager

9.2 ERMs CORRECTIVE ACTION

Field quality assurance activities will be reported to ERMs Project Manager

Problems affecting quality assurance that are encountered during the study will be

reported on Corrective Action Form as presented in Figure 9-1 The Project

Manager will be responsible for initiating the corrective actions and for ensuring

that the actions are taken in timely manner and for producing the desired results

The Project Manager will report to the Quality Assurance Manager and project team

on all necessary corrective actions taken the outcome of these actions and their

effect on data produced All corrective action taken will be reported to the Shpack

Steering Committee

QAPP 9-1

revised 1/21/91

215-02-02EPA 04788

Date

Job Name____________

Initiators Name and Title

Problem Description

Figure 9-1

Corrective Action Form

Reported To

Corrective Action

Reviewed and Implemented By

cc Project ManagerQA ManagerQA Officer-

11w

9-2 EPA 04789

SECIlON 10.0

OA REPORTS TO MANAGEMENT

After project initiation the Project Manager in conjunction with the Quality

Assurance Manager will submit progress report summary of all applicable quality

assurance activities These summaries shall contain at least the following types of

information

The status and coverage of various laboratory and field quality assurance

project activities

Data quality assurance reviews including assessment of accuracyprecision completeness representativeness and comparability

Significant quality assurance problems discovered corrective actions

taken progress and improvements plans and recommendations for

further implementation of updating of the investigative QAPP

Any significant field observations noted in the field notebook during the

sampling procedure

Results of performance and system audit reports

These summaries will be forwarded to the Shpack Steering Committee after review by

the Project Manager

QAPP 10-1

revised 1/21/91

215-02-02EPA LjiIP

EPA 04791

APPENDIX

LABORATORY QUALITY ASSURANCE PROJECr PLANS

QAPP EPA 04792

.3CE1MICCORPORATION.jfl

QAPPEPA 04793

CEI14IC CORPORATION

100 Dean Knauss Drive

Narragansett Rhode Island 02882

QUALITY ASSURANCE PLAN

Approved byOrganic Laboratory Inorganic Laboratory

Manager

idèit

Revision NoDate December 1989

EPl O479

Ceimic CorporationSection MoRevision NoDate December 1989Page of

2.0 Table of Contents

8ection Page

1.0 Title Page 1.-i

2.0 Table of Contents 2i3.0 Introduction 314.0 Quality Assurance Policy Statement 4I5.0 Quality Assurance Management

.Organizatiori and Responsibility 516.0 Quality Assurance Objectives for

Measurement Data in Terms of PrecisionAccuracy Representativeriess Completenessand Comparability 616.1 Precision and Accuracy 626.2 Representatjveness 626.3 Completeness 63

6.4 Comparability

7.0 Sampling Procedures 71

EPA 04795

Ceimic PlanSection NoRevision NoDate December 1989Page of

2.0 Table of Contents

Section Page

8.0 Sample Custody 81

8.1 Chain of custody 818.2 LaboratorySecurity 83

8.3 Duties and Responsibilities ofSample Custodian 83

8.4 Sample Receipt 888.5 Sample Identification and Login 8-9

8.6 Sample Storage 8-14

9.0 Calibration Procedures and Frequency 9-1

9.1 Instruments 919.2 Standards and Reagents 93

10.0 Analytical Procedures 10111.0 Data Reduction Validation and Reporting 111

11.1 Data Reduction 111

11.2 Data Validation 111

11.3 Data Reporting 112

12.0 Laboratory Quality Control Checks 12-1

EPA 04796

Ceimjc QA PlanSection MoRevision NoDate December 1989Paqe3of4

2.0 Table of Contents contdSection

13.0 Quality Assurance Systems AuditsPerformance Audits and Frequency 131

l3.lSysteinsAudjts 13113.2 Performance Audits 132

14.0 Preventive Maintenance 141

15.0 Specific Routine Procedures Used to AssessData Precision Accuracy and Completeness. 15115.1 Precision 15115.2 Accuracy 15215.3 Completeness 132

16.0 Corrective Action 161

17.0 Quality Assurance Reports to Management... 17-1

Appendices

Appendix Personnel Qualificationand Resumes AiAppendix Facilities and Equipment Bi

EPA 04797

Ceimjc QA PlanSection NoRevision NoDate DecelniDer 1989Page of

2.0 Table of Contents contdList of Figures Page

Figure 4-1 Quality Assurance Policy Statement 4-3

Figure 51 Ceimic Organizational Chart 54Figure 8.1-1 Chainofcustody Record 82Figure 8.12 Sample Control Record 84Figure 8.41 Sample Receipt Form 87Figure 8.51 Sample Information Form 811

Figure 8.5-2 Computer LogIn SOP 8-13

Figure 8.61 Temperature Log 815

Figure 11-1 Data Reporting Process 114

Figure 13.11 Audit Outline 133

Figure 14-1 CC/MS Routine Instrument Maintenancefor Semivolatijes 142

Figure 14-2 GC/MS Nonroutine InstrumentMaintenance 14-3

Figure 161 Ceimic Quality Assurance CorrectiveRequest Form 164

List of Tables

Table 71 Recommended Methods for Sampling andPreservation of Samples for Analysis. 72

Table 101 Inorganic Analytical Methods Summary 102Table 102 Organic Analytical Methods Summary 10STable 13.21 Ceimjc Performance Evaluations 134

EPA 04798

Ceimic QA PlanSection NoRevision NoDate December 1989Page of

3.0 Introduction

The Ceimic Corporation is an environmental testing and research

laboratory incorporated in the State of Delaware 1988 The

laboratory provides wide range of analytical services covering

soil air and water pollution environmental impact assessment

industrial prosess control effluent and emission pollution

control and research and development for hazardous waste

management These services are provided to various U.S

Government and State agencies and to private industries as well

The following Quality Assurance QA Plan describes the policies

organization objectives quality control activities and

specific quality assurance functions employed at Ceimic and

demonstrates Ceinics dedication to producing accurate

consistant data of known quality The QA Plan follows the

Interim Guidelines and Specifications for Preparing Quality

Assurance Plans published by the USEPA December 1980

EPA 04799

Cejmjc QA PlanSection NoRevision NoDate December 1989Page of

4.0 ua1ity Assurance Policy Statement

Caimjc Corporation is firmly committed to the production of valid

data of known quality through the use of analytical measurements

that are accurate reliable and complete To ensure the

production of such data Ceimic has developed an extensive

Quality Assurance/Quality Control QA/QC Program that operates

throughout the entire organization

Quality Control is defined as an organized system of activities

whose purpose is to provide quality data while Quality Assurance

is more broadly defined as system of activities designed to

ensure that the quality control program is actually effective

Quality Control is included as part of Quality Assurance In

supporting government regulatory and enforcement proceedings

high degree of attention to quality is essential Intense

application of quality control principles and routine quality

assurance audits are required The basic components of Ceiinics

QA/QC Program are control evaluation and correction

Control ensures the proper functioning of analytical systems

through the implementation of an orderly and wellplanned series

of positive measures taken prior to and during the course of

analysis including quality control practices training or

personnel routine maintenance and calibration of instruments

and frequent validation of standards

EPA 04800


Evaluation involves the assessment of data generated during the

control process For example precision and accuracy are

determined from the results of duplicates and spikes and other

check samples Evaluation measures over the longterm include

performance and systems audits conducted by the Ceimic quality

assurance group as well as outside regulatory agencies

Correction includes the investigation diagnosis and solution of

any problem detected in an analytical system Proper functioningof the system may be restored through method reevaluation

analysis of additional check samples troubleshooting and repairof instrumentation or examination and comparison with historical

data Confidential records are maintained of corrective actions

taken

The management at Ceimic considers Quality Assurance/Quality

Control to be of paramount importance in the success of the

company and fully supports the staff in the implementation of

sound and thorough Quality Assurance Program Our Ceimic Quality

Assurance Policy Statement is included as Figure 41

EPA 04641

Cejinjc QA PlanSection NoRevision NoDate December 1989Page of

Figure 4.-i

Quality Assurance Policy StatementCaimic Corporation

December 1989

The success of our laboratories is directly related to client

perception of the reliabiity and accuracy of the data we generate

From the moment an environmental sample arrives in our laboratory

each step it passes through in sample management preparation

analysis and reporting will affect data reliability and accuracy

Thus Quality Assurance and Control procedures have been imposed

at each step and operation in our laboratory to ensure our clients

satisfaction Ceimic is firmly committed to the effective

implementation of these procedures

It is incumbent on every employee at all operations and

management levels to thoroughly understand and carry out said

procedures

Our Quality Assurance and Quality Control Program is the key to

our success and as company policy will be strictly enforced

The Director of Quality Assurance will direct and oversee this

function but we are all individually responsible for its

execution.

John McGarry JrPresidentCeimic Corporation

EPA 04642

Cejrnjc QA PlanSection NoRevision NoDate December 1989Page of

5.0 Quality Assurance Management Organizatjo Responsjbi1j

Quality Assurance at Ceimic is companywide function that

depends on cooperative working relationships and multilevel

review Responsibilities for QA/QC functions begin with the

bench scientist and extend to the President of Ceiinjc

The primary level of quality assurance resides with the bench

scientist who after matriculation in the Ceimic training

program is responsible for precisely following the

analytical methods and Standard Operating Procedures SOPcarefully documenting each step in the appropriate format

conscientiously obtaining peer review as required and

promptly alerting laboratory managers and/or QA staff members

to problems or anomalies

The manager of each analytical laboratory is responsible for the

quality of the data generated by the scientists in that

laboratory The laboratory manager implements and monitors the

specific QC protocols and QA programs within the laboratory to

ensure continuous flow of high quality data It is the

laboratory managers responsibility to provide the bench chemists

with ample resources including space equipment personnel andespecially time in order to accomplish top quality performance

Additionally each laboratory has scientist specifically

designated to assist the laboratory manager with the QA function

Their responsibilities may include monitoring QC practices

EPA 04643

Ceixnic QA PlanSection NoRevision NoDate DeCember 1989Page of

updating laboratory SOPs and helping to manage analysis of

Performance Evaluation samples These scientists are part of

Ceiiaics QA staff and are important QA links to the laboratories

The overall Quality Assurance Program and associated activities

are directed by the Director of Quality Assurance While

interacting on daily basis with laboratory staff members the

QA Director remains independent of the laboratories and reports

directly to the President of Ceimic Laboratory compliance with the

QA program is evaluated through informal and formal systems and

performance audits by the QA Director Remedial action is

suggested if necessary

With input from the appropriate staff members the Director of

Quality Assurance writes and edits general and specific QA plans

QC protocols safety procedures and Standard Operating

Procedures An essential element of the QA program is

keeping records and archiving all information pertaining to

quality assurance including QA/QC data preaward check sample

results and scores performance evaluation sample results and

scores state certifications of-the laboratories EPA and other

audit comments recommendations and reports The QA Director

also plays an important role in the corrective action mechanism

described in Section 16

EPA 04644

Cejmjc QA PlanSection MoRevision MoDate December 1989Page of

semi-official QA function performed by the Director involves

working with scientists and management to continually upgrade

procedures and systems to make the laboratory work easier rather

than more difficult

Ultimately the success of the QA Program depends on the

cooperation and support of the entire organization Ceimics

most valuable resource is its staff of dedicated professionals who

take personal pride in the quality of their performance

EPA 04645

1YIO U1YZIY I1Va3d 31W13J

LIIti

II

MJ

SM/3D 31US0J0


6.0 Quality Assurance Objectives for Measurement Data Termsof Precision Accuracy Representatjvenegg Completeneand Comparability

Az part of the evaluation component of the QA Program laboratory

results are compared with certain data quality objectives These

objectives in terms of precision accuracy representativeness

completeness and comparability may be defined as follows

Precision the agreement or reproducibility among

individual measurements of the same property usually made

under the same conditions

Accuracy the degree of agreement of measurement with the

true or accepted value

Representatjveness the degree to which data accurately and

precisely represent characteristic of population

parameter variations at sampling point process

condition or an environmental condition

Completee measure of the amount of valid data

obtained from measurement system compared with the amount

that was expected to be obtained under correct normal

conditions

Comparability an expression of the confidence with which

one data set can be compared with another data set in regard

to the same property

EPA 04647

Ceimjc QA PlanSection NoRevision NoDate December 1989Page of

Quality Assurance objectives vary according to the specific

project and the parameters requested The accuracy precision

and representativeness of data will be functions of the origins

of the samples the procedures used to analyze samples and

generate data and the specific sample matrices involved in each

project Quality control practices utilized in the evaluation of

these data quality objectives include blanks replicates spikes

standards check samples calibrations and recoveries

6.1 Precision and Accuracy

For each parameter analyzed the QA objectives for precision and

accuracy will be determined from pu.blished historical data

method validation studies Ceimic experience with similar

samples and/or project specific requirements such as those

stipulated by the USEPA in the Contract Laboratory Program CLPprotocols

6.2 Representatjveness

The representativeness of the data from the sampling sites

depends on the sampling procedures The representatjveness

of the analytical data is function of the procedures used in

processing the samples The objective for representativeness is

to provide data of the same high quality as other analyses of

similar samples using the same methods during the same time

period within the laboratory Representativeness can be

determined for this objective by comparison of the quality

EPA 04648


control data for these samples against other data for similar

samples analyzed at the same times Differences within 20% are

acceptable

6.3 Completeness

Completeness of an analysis is documented by including in the

report sufficient information to allow the data user to assess

the quality of the results The objective is for completeness

to be 100% in most cases and includes analysis of all samplesgeneration and analysis of all required QC samples sufficient

documentation of associated calibration tuning and

standardization and records of data reduction processesCompleteness is ensured by assigning to each project specific

Proj ect manager whose functions include sample management and

tracking

6.4 Comparability

The results of these analyses can be compared with other analyses

by other laboratories because the objectives of the laboratoryfor comparability are to demonstrate traceability of standards

to NBS or EPA sources to use standard methodology to apply

appropriate levels of quality control within the context of the

Laboratory Quality Assurance Program and to participate in

interlaboratory studies to document laboratory performance By

using traceable standards and standard methods the analyticalresults can be compared to other laboratories operating

EPA 04649


similarly The QA Program documents internal performance and

the interlaboratory studies document performance compared to

other analysts at other locations

7.0 Samplinq Procedures

For most projects outside sampling teams deliver or send samples

to the Ceimjc laboratories When sampling by Ceimic personnel is

required the Ceimic sampling team follows the sampling

procedures outlined in the EPA/OSW Test Methods for Evaluating

Solid Wastes Physical/Chemical Methods SW 846 3rd Edition or

procedures found in the EPA Handbook for Sampling and Sample

Preservation of Water and c7astewater Safety during the sampling

process is discussed in the Ceimic document Safety Procedures for

Sampling Personnel Site specific sampling plans .are prepared

at Ceimic for projects requiring them

Appropriately prepared sample containers are supplied by Ceimic

if client so requests When required preservatives are added

to the sample containers by Ceimic scientists Table 71provides the Ceimic Recommended Methods for Sampling and

Preservation of Samples for Analysis Maximum holding times as

specified in 40 CFR Part 136 are included in the table

EPA 04650

TABL.E

2i

Rexminje P1tIxis

for PrsrvticE of Samples

fur Analysi

Parameter

No /Hame

Table lABacterial Tests

1-4 Collform fecal total

Fecal streptococciTable lB-Inorganic Tesçs

AcidItyAlkaflnityAniinIa

B1ocheiic oxygen demand11 BromIde

14 Biochemical oxygen demand

carbonaceous15 ChemIc oxygen demand1

6 ChlorIde

17 ChlorIne total residual2

1 Color

23-24 Cyanide total amenable

to chlorination25 FluorIde

27 Harlness

28

Hydrogen

Ion

31 1jeldahl

Met

18 Chromlug

VI35

Mercury

5-8

10 12

13 19

20

22 2629 30 3234

36

37

45

47

5152 58-60

62 63 70-72

74

75

Metals except chromium

VI mercury

P.C Cool

4C 0.008% Na2S203PG do

Cool

4C

do

Cool

4C

112S04

to

p112Cool

4C

None requiredCool

4C

Cool

4C

112S04to

p112Hone required

do

Cool

4C

Cool

4C HaGH

to p1112 O.6gascorbic acid5

None requiredMW3

to p112 H2S04

to

p112None requiredCool

4C

112504

to

p112

Cool

4C

HNO3

to

p112

do

MaximumHolding Time

hours

Do

14 days

Do

28 days

48 hours

28 days

48 hours

28 days

Do

Analyze Irned

48 hours

14 days

28 days

monthsAhalyze mined

28 days

24 hours

28 days

months

2.3

Container Preservation

P.6

.6-

P.C

P.6

P.6

P.C

P.6

P.C

P.6

PG

PG

P.6

P.6

PG

pH

organic nitrogen

Page

1977A

39A

in

.-_

Table

2-1

I-ITITIIbded tLxds for Preservtjot

of Samples

for Analysis

Parameter No./Narne

Metals continued38 Nitrate

39 NitratenItrite

40 Nitrite

41

OIl grease4

2

Organic carbon

44 Orthophosphate4

6 Oxygen Dissolved Probe47 Wlnkler

48. Phenols

49

Phosphorus elemental50 Phosphorus total5

3 ResIdue54 Residue5

5 Residue

56 ResIdue

57 ResIdue6

1 SilIca

64

SpecIfic conductance

65 Sulfate

66 Sulfide

67 SulfIte

68

Surfactants69

Temperature73

TurbidItyTable ICOrganic Tests1

3 18-20

22 24-28 34-37 39-43

45-47

56 66 88

89 92-95

97

Purgeable Ilalocarbons

Page1977A

39A

PG

P6

P.6

PG

P6

8ottle

Top

do

only

P.6PS

P.CP.6

P.C

P.C

PS

PG

P.6

P.6

P.6

P.6

Telflonlined septum

Cool

4C

Cool

4C

112504

to

p112Cool

4C

Cool

4C

H2S04

to p112Cool 4CIICL o

r 112504

to

p112Filter lirmedlately Cool

4C

None required

Fix

on site store

Cool

4C

112S04

to

Cool

4C

Cool

4C

112S04

to pH2

Cool

4C

do

Cool

add zinc acetate plus sodium

hydroxide

to p119None requiredCool

4C

None required

Cool

4C

Maximum

Holding Time

48 hours

28 days

48 hours

28 days

Do

48 hours

Analyze iutnedhours

28 days

48 hours

28 days

days

48 hours.

daysdaysdays

28 days

Do

Do

days

Analyze Inmed

48 hours

Analyze

48 hours

14 days

Container Preservation

2.3

total

Filterable

Nonfilterable

TSS

Settleable

volatile

In dark

p112

do

do

do

do

do

do

Cool

40C 0.008% Na2S203

gR

.4

.d

Table

21

RexmInded Pt.bods

fQr Presrvatjo of Saniples

for Ana1yis

2.3

MaxImumParameter Ho./t1ame Container PreservationHolding Timelabe ICOrganic Tests continued5

7

90 PurgeabIe aromatic hydro

do Cool

4C 0.008% Ha2S2O3

Docarbons H

CL

to

p1129Acrolejn acrylonitrile d

o Cool

4C 0.008% Ha2S2Q3 Do

Adjust

pH to 4_5W23

30

44 49

67 70

71

83 GTeflon-lned Cool

4C 0.008% Ha2S203 days until

85 96 Phenol11 c

ap

extractjon

40 days after

extract1on

38 Benzidlnesll do do

days untilextract 1ori

14

17 48 50-52 Phthalate do Cool

4C 40 days afterestersiz

extractioni72-74 HltramlneslIl4 do Cool

4C storein

darI0.008% Na2S2O3

Do76-82 PCBs acrylonltrle do

Cool

4C Do

54 55

65 Ultroaromatics do

Cool

4C store

In dark0.0O8% Na2S203

DoIsophorone

8-12

32

33 58

59 64 do do Do

68 84

86 olynuc1ear aromatic

hydrocarbons

i1

15 16 21

31

75

h1aloettersIl

do

Cool

4C 0.008% Ha2S203 Do

29 35-37 60fl

91 Chlorinated do

Cool

4C Dohydrocarbons

11

87 TC0011 do Cool

4C 0.008% Ha2S203

DoTable iD-Pesticides Tests

170 PesticIdes11 do

Cool

4C pH 5_915 DoTable 1ERadiological Tests1

-5

Alpha beta radium

PG

111103

to

p112JflOnths

Page31977A

Rvnced kt1xds for Preservatic of Samples

for Analysis

TABLE

11 HOTES

Polyethylene or Glass

Sample preservation should

be perfonned Iimediately upon sample collection

For composite chemical samples eachaliqout should

be preserved

at

the time

of collection When

use

of automated sampler makesit

Impossible

to

preserveeach aliqout then chemical samples

may

be

preserved

by maintaining

at

4C

until composlting

and sample splitting

Iscompleted

When any sample

Is to

shipped

by

coalnon carrier

or sent through

the

iS

MailsIt

must comply with

the Department

of Transportato Hazardous Materials Regulations

49 CFR Part

172

The

person offering such material

fortransportation

is

responsible

for ensuring such compliance

For

the

preservation requirements

of Table

11 the Office

of Hazardous Materials Materials Transportation 8ureau Departmentof Transportation

has determined that

theHazardous Meterlals Regulations

do not apply

to

the

following materials hydrochloric acid

HCL

in

water solutions

at concentrations

of 0.04%

by weight

or less

pH about 1.96 or greater Nitric acid 10103

In water solutions atconcentrations

of 0.15%

by

weight

or less

pH about 1.62

or greater Sulfuric acid H2so4

in

water solutions

of0.35%

by weight

or less

pH about 1.15 or greater

and Sodium hydroxide NaO1 in water Solutions at concentrations

of 0.080%

by weight or less

p11 about 12.30 or less

Samples should

be analyzed As soon as possible after collection

The times listed

are

the maximum times thatsamples

may

be held before analysis

and still

be considered valid Samples

may

be held

for longer periods only

If thepenn1ttee or monitoring laboratory

has data on file

to show that

the

specific types

of samples under study

are stable

for

the

longer time

and

has received variance from

the

Regional Administrator under Section I36.3e Some samples

may

not

be stable

for

the maximum time period given

in the table perinittee

or monitoring laboratory

Is

Oblfgted

to

hold

the

sample

for shorter timeif

knowledge exists

to show that this

Is

necessary

to

ma1ntajn.m1stability

See Section 136.3e

for details

i- -.1

Table

RecczIrkjeci Lbods for Preser-vBUOn of Samples

for Analysis

TAULE

11 HOlES continued

Should only

be used

In the

presence

of residual chlorine

MaxImum holdlg time

is 24 hours when sulfide

Is

present Optionally

All samples

may

be tested with leadacetate paper being

pH adjustments

In

order

to determine

If

sulfide

Is presentIf

sulfide

Is present

It can

beremeved

by

the addition

of cadmium nitrate powder until negative spot test

is

obtained

The sample

Is filtered

andthen HaOjl

l.s added

to pH 12

Samples should

be filtered Iinediatà1y on-site before adding preservative

for dissolved metals

Guidance applies

to

samples

to

be

analyzed

by

GC

LC or GC/HS

for specific compounds

Sample receiving

no

p11 adjustment must

be analyzed within seven days

of sampling10 The

p11 adjustment

is not required

if

acrolein will

not

be measured Samples

for acrolein receiving

no

pHadjustment must

be

Analyzed within days

of sampling1

1 When

the

extractable analytes

of concern fall within single chemical category

the specified preservative

andmaximum holding times should

be observed

for optimum safeguard

of sample integrity When

the analytes

of concern fallwithin

two or more chemical categories

the samplemay

be

preserved

by cooling

to

4C

reducing residual chlorinewith O.ooax sodium thiosulfate storing

In the dark

and adjusting

the

p11

to

6-9 samples preserved

in

this manner may

be held

for seven days before extraction

And

for forty days after extraction Exceptions

to

this optional preservation

And holding time procedure

are noted

in

footnote

re the requirement

for thiosulfate reduction

of residualchlorine

and footnotes

12

13

re the analysis

of benzidine1

2 It

2-dlphenylhydrazine

Is

likely

to be

present adjust .the

pH of

the

sample

to 4.0

0.2 peyentrearrengennt

to

benzidlne

Ijbi 2-I

RecJ 1thocjs for Presertj of Samples

for Analysis

TABLE NOTES continued

13 Extracts may

be stored up

to

days before onalyiis

If

storage

Is

conducted under an Inert oxidantfree

atmosphere..

14

For

the analysis

of d1phenyln1trosamin

odd 0.008%

Na2S203

and adjustPH to 7-10 with NaOH wIthin

24 hoursof sampling

15

The

pH adjustment may

be

performed upon receipt

at

the laboratoryand

may

be omitted

if the samples

are extracted

within

72 hours

of collection

For

the analysis

of aldrln

add 0.008%

Na2S203

Table.2 corrected

by

50 CFR 691k January 1985

Ceinijc QA PlanSection NoRevision NoDate December 1989Page of 17

8.0 Sample Custody

8.1 Chainof-Custody

Samples are physical evidence collected from facility or the

environment In hazardous waste investigations sample data may

be used as evidence in EPA enforcement proceedings En support

of potential litigation laboratory chainof-custody procedures

have been established to ensure sample traceability from the time

of receipt through completion of analysis

The National Enforcement Investigations Center NEIC of EPA

considers sample in custody under the following conditions

It is in your actual possession or

It is in your view after being in your physical possessionor

It was in your possession and then you locked or sealed itto prevent tampering or

It is in secure area

Chainofcustody originates as samples are collected Chainof

custody documentation accompanies the samples as they are moved

from the field to the laboratory with shipping information and

appropriate signatures indicating custody changes along the way

chainof-custody record is included as Figure 8.11

EPA 04657

DOWw.tfl

b--t%

0o

0j

Lu

-.Icr

tlI_

to03

.._J

L.s

tIIdpgIajU KI 020u14

01 7u2-cooj

CIg

Ut

Ceimjc QA PlanSection NoRevision NoDate December 1989Page of 17

Laboratory chainof-custody is initiated as samples are received

and signed for by the Sample Custodian at Ceimic Documentation

of sample whereabouts continues as samples are signed in and out

of the central storage facility for analysis in the several

Ceimic laboratories using the Sample Control Record Figure 8.1After analysis extracts and any remaining samples are held

in the central storage area to await disposal Prior to disposal of

the samples tags and other identification are removed and placed

in the case file

8.2 Laboratory Security

Samples at Ceimic are kept within secure areas during all stages

of tenure including the periods of time spent in preparation

analysis and storage

The laboratory area is designated as secure area The doors to

this area are kept locked at all times and may be accessed by

key or combination Authorized personnel only are allowed to

enter the secure areas Visitors to the laboratories must be

accompanied by Ceimic staff members

8.3 Duties and Responsibilities of the Sample Custodians

Duties and responsibilities of the Sample custodian shall include

but not be limited to

8.3.1 Receiving samples

EPI 04659

Figure 8.22

Sanpla Control Record

Cejinjc Qi PlanSectjo NoRevision NoDate Deceer 1989Page oe 17

SPJcLE HTU CEIIC

PrJt quttthorTt5ry avid Ifw QwP mdSrI t.uu..4 tUr7t

EPA 04660

Cejmjc QA PlanSection NoRevision NoDate Decemj3er 1989Page of 17

8.3.2 Inspecting sample shipping containers for presence/abefl

and condition of

8.3.2.1 Custody seals locks evidence tape etc8.3.2.2 Container breakage and/or container integrity

8.3.3 Recording condition of both shipping containers and sample

containers bottles jars cans etc in appropriate logbooksThis also includes recording if the samples were cool upàn

arrival and recording the pE of aqueous samples

8.3.4 Signing appropriate documents shipped with samples i.eairbjlls chainof--custody records Sample Management

Office SMO Traffic Reports.etc3.3.5 Verifying and recording agreement or nonagreement of

information on sample documents i.e sample tags

chainof-custody records traffic reports airbills etcin appropriate logbooks or on appropriate forms If there

is nonagreement recording the problems contacting the

SMO for direction and notifying appropriate laboratory

personnel SMOs corrective action directions shall be

documented in the case file

8.3.6 Initiating the paper work for sample analyses on appropriate

laboratory documents including establishing case and sample

files and inventory sheets as required for analysis or

according to laboratory standard operating procedures

EPA 04661

Ceimic QA PlanSection NoRevision NoDate December 1989Page6ofl7

8.3.7 Marking or labelling samples with laboratory sample numbers

as appropriate and cross referencing laboratory numbers to

SMO numbers and sample tag as appropriate

8.3.8 Placing samples sample extracts and spent samples into

appropriate storage and/or secure areas

8.3.9 Controlling access to samples in storage and assuring that

laboratory standard operating procedures are followed when

samples are removed from and returned to storage

8.3.10 Monitoring chainof-custody of samples in the laboratory

8.3.11 Assuring that sample tags are removed from the sample

containers and included in the appropriate sample file

Accounting for missing tags in memo to the file or

documenting that the sample tags are actually labels

attached to sample containers or were disposed of due to

suspected contamination

8.3.12 Monitoring storage conditions for proper sample

preservation such as refrigeration temperature and

prevention of crosscontamination

8.3.13 Returning shipping containers to the proper sampling

teams

8.3.14 Sending shipping containers prepared sample bottles andsampling instructions to clients who request them

04662

Cejjc QA PlanSection NoRevjsjo NoDate Decenber 1989Page of 17

Pigura 3.4i

3aple Receipt Porn

CEIliIC CORPORAflON

SVPtE REcZPT FO4

Or EPA Ca3 ID Nia.r

Pr.s.ni Abi.nr

Casiody .ai

EPA Ct.InoCustody For

EPA Trtt1c .Oor11 or SAS dInq Lii

Airbilis

SwuI .gi

Condition ot cuilody s.einPeP s.nCondition ot shiaoing CO1T1ifl.f

Condition oi aale 3ot-ttes describe briefly if brocen ba-rfei

sr r.i.nr record ID nuaeril

SI tg ID ni.ri recorded on cite nofciziody recardil or

peInq IIttsh

Y.r 1C3r ion sqrefrr ricri.r..amn1 of in orsIet ion on rece lv nq

R.gj ur ion of or rvanc -th Seav Jleneqent Of ices

ignrnir.t

EPA 04663

Ceimic QA PlanSection NoRevision NoDate December 1989Page of 17

8.4 Sample Receipt

Sample shipments are received at Ceiinic by the designated Sample

Custodian Shipping information is recorded in the sincomingI

logbook and the paperwork filed chronologically The shipping

containers are then inspected and opened by the Sample Custodian

who records the following information on the Sample Receipt Form

Figure 8.41 as he/she unpacks the coolers

Presence/Absence of

Custody seals

Chainofcustody records

SMO forms traffic reports

AJ.rbills or bills of lading documenting shipment ofsamples and

Sample tags

Condition of custody seal intact broken absent andshipping container

Condition of sample bottles

Sample tag ID numbers not recorded on chainof-custodyrecords or packing list

Verification of agreement or nonagreement of informationon receiving documents

Resolution of problems or discrepancies with the SampleManagement Office

Following resolution of any problems or discrepancies the Sample

Custodian signs the Sample Receipt Form and originates custody

file for the set of samples including in it the Sample Receipt

Fo rm

EPA 04664

Cejmjc QA PlanSection NoRevision NoDate December 1989Page of 17

When the Sample Custodian is not available to receive samples the

sample container is signed for by Ceimic staff member and the

time date and name of the person receiving the container are

recorded in the Incoming Log along with the appropriate shipping

information The samples are then stored under refrigeration in

the sample receipt area which is located within the secured

area The samples are officially received and documented

by the Sample Custodian or designee on the next business day

8.5 Sample Login and Identification

8.5.1 Sample Identification

In order to maintain sample identity each sample received at

Ceimic is assigned unique sample identification sample IDnumber

After inspecting the samples the Sample Custodian assigns each

sample Ceimic Sample ID Number These numbers are

chonologjcaljy sequential Ceimic Sample Identification Numbers

appear in the following format

ww cacc yy zz

where

represents the last two digits of the currant yearxxxx represents four digit project number which is

assigned sequentially when sample group case isreceived at Ceimic

represents the sample number within the groupcase and

EPA 04665

Ceimjc QA PlanSection NoRevision NoDate December 1989Page 10 of 17

zzz represents an individual laboratory code

e.g 87 0014 06 ABC

The Ceimic Sample Custodian assigns each sample ww-xxxx-yy

identification number The zzz suffixes are assigned within the

individual laboratories and vary from one laboratory to another

The Ceimic Sample ID Numbers are recorded on the Sample Receipt

Form Figure 8.41 in the Sample Receipt Log and on the Sample

Information Form Figure 8.51 where they are cross referenced

with SMO numbers sample tag numbers and other client

identifiers Each sample is clearly labelled with its Ceimic

Sample ID Number by the Sample Custodian The same Sample ID

Number appears on each sample preparation container and extract

vial associated with the sample

EPA 04666


Piqu.e 9.51

Ceiic Sap1a Inoratio Form

CIIC CORPORATION

SpL Lnor.C ion For

Client La

Project 370024 0e ateCeiic

S1c1 ID Client Id S.iie utrix Ar.a1yi eired37002.- 370606.4-014 Ag TS

870024 370606-014 Ag

37002 3706066013

370024 370606-0tR Ag

370024 3706070-014

37002 3706070014 Ag AI8-P9S3 IT.

370024 3706070014 AG370024 3706070-014 Pa

37002 37CG07G-013 Pa

370024 3706072014 AG IEiFZIfl WMPa ZN

370024 3706072-Oil Pa

370024 3706074-014

37002% 10 3706074-013 AG

370024 II 370601-01P Pa

370024 12 3706077-0111 AG AIG-IC870024 12 3706077-014

370024 30607T-014 Ag

370024 13 37060790111 AG

370024 13 3706079-0111

370024 13 3706019-014

370024 14 37060810111

370024 3706061-013

87002 16 3706083-0111

870024 17 11 370608.3-013

370024 18 37C6C8Mi1

Saf Ctcdun ___________________________Oate rje r.jrr rri.a __________________________

p2 Q4667

Cejmjc QA PlanSection NoRevision NoDate December 1989Page 12 of 17

8.5.2 Sample Logtn

The sample login system at Ceinic consists of computerized entryinto the Sample Receipt Log The information recorded includes

Ceimic Sample Identification Number

Date of Receipt

Client Name

Client Sample Identification

Sample Matrix

Analyses Required

Project Number

Due Date and -Comments and

Initials of Sample Custodian or designee

EPA 04668


8.5.3 Sample Information

After completing the Sample Receipt Form and making sample

entries in the Sample Receipt Log the Sample Custodian prints

out sample data on the Sample Information Form Figure 8.5-

including

Client Name

Ceimic Project Number

Number of Samples Received

Types of Samples Received Sample MatrixDue Date of Samples

Ceimic Sample ID Numbers

Client ID Number

Analyses to be Performed

Provision for Signature of Sample Custodian or designeeDate of Sample Logth arid

Provision for Signature of Project Manager

After signing and dating the Sample Information Form the Sample

Custodian notifies the Project Manager of the arrival of the

samples The Project Manager verifies that the information on

the Sample Information Form is correct by countersigning and

dating the form The original Sample Information Form is

placed in the chainof-custody file for the case or project

EPA 04669

Ceiutjc QA PlanSection NoRevision NoDate December 1989Page 14 of 17

The custody file is originated by and remains with the Sample

Custodian until the samples are disposed of At that time the

custody file is entered in the Ceimic central file for the case

or project

Copies of the Sample Information Form are distributed to the

Ceimic project manager accounting group and the appropriate

laboratory managers Another copy of the form may be sent to

the client as confirmation of sample receipt and specified

analyses

8.6 Sample Storage

Samples at Ceiinic are stored in central storage facility within

the secured area After sample receipt and login procedures are

completed the Sample Custodian places the samples in their original

containers within the appropriate refrigerators in the sample

storage area Refrigerators and are dedicated to

inorganic samples refrigerators and are dedicated to

organic samples Only samples for volatile organics analysis

VOA are stored in refrigerator No other type of sample

may be stored in this refrigerator The sample storage area is

for samples only no standards or reagents are present

Refrigerators are maintained at 5C /4c daily temperature

log is kept for each refrigerator by the Sample Custodian

Figure 8.61

EPA 04670

CIliIC CORPORrION

TDRATT.P LOG

Cejmjc QA P1aSectjo NoRevision NoDate DecaberPage 15 of 17

1989

Pigure 8.61

Teperture Log

EPA 04671

Cejmjc QA PlanSection NoRejsjo NoDate December 1989Page 16 of 17

Access to the sample storage area is controlled by the Sample

Custodian who is responsible for monitoring sample custody All

transfers of samples into and out of storage are documented on

laboratory chainof-custody form the Sample Control Record

Figure 8.12 When an analyst removes sample for preparation

and/or analysis the sample is signed out Similarly sample

is signed back in when the analyst returns it to storage prior to

the end of his/her working day

When analysis is complete extracts and any remaining sample

are retained in the central storage area until they may be

disposed of Broken or damaged samples are promptly disposed of

in safe manner and the disposal documented

All custody documentation is kept in case custody files originated

by the Sample Custodian until samples are removed from storage for

disposal At that time the case custody files are entered into

the central case files and the disposal of samples and extracts

documented

Chainofcustody of sample ensures that the sample is traceable

from when it was taken in the field through laboratory receipt

preparation analysis and finally disposal The primary chain

ofcustody documents which may be used to locate sample at any

point in time are

EPA 04672

Cejmjc QA PlanSection NoRevision NoDate December 1989Page 17 of 17

The chainof custody form from the field describing theorigin arid transportation of sample

The Laboratory Sample Receipt Log and supporting loginrecords documenting acceptance of sample by the Ceimiclaboratory and

The Ceiznic Sample Control Forms documenting the analystwho has custody and the reason for removal of sample fromstorage

EPA 04673


9.0 Calibration Procedures and Frequency

9.1 Im3truments

Instrument calibration establishes that the system is functioning

correctly and at level of sensitivity sufficient to meet

required detection limits Routine calibration provides means of

rapid detection of instrument variance and possible malfunction

ensuring that data quality is maintained Specific calibration

and check procedures are given in the analytical methods

referenced in Section 10 Frequency of calibration and

concentration of standards are determined by the cited methods

and special contract requirements as iel1 as manufacturer

recommendations

Standard calibration curves of signal response versus

concentration are generated on each analytical instrument used

for project prior to analysis of samples calibration curve

of the appropriate linear range is established for each

paramenter that is included in the analytical procedure employed

and is verified on regular basis with check standards In

general Ceimic adheres to the calibration criteria specified by

the USEPA for the Contract Laboratory Program for both organics

and inorganics For analyses outside of the CLP protocols other

specified calibration practices are stipulated and maintained

The following are examples of calibration procedures for various

instrument systems

EPA 04674

Cejiajc QA PlanSection NoRevision NoDate December 1989Page of

An initial calibration is performed using three different

concentration levels for each parameter of interest The initial

calibration is done on each quantitation column and each

instrument and is repeated each time new column is installed

or other major changes in the chromatographjc system take place

For CLPtype analyses continuing calibration takes place at

the beginning and once every five samples throughout the seventytwo hour analytical sequence The percent difference in

calibration factors for each standard must not exceed 20% 15%for any standard compound used for quantification

CC/MS Initial calibration at five different concentration

levels for each analyte is carried out for each systemRecalibration takes place whenever major change occurs in the

system such as column change in the CC or source cleaning of

the mass spectrometer Continuing calibrations take place everytwelve hours of instrument analysis time and for CLPtype

analysis must have percent difference of 25% or less in

response factors for calibration check compounds

Prior to analysis of any samples GC/MS systems are tuned to

tJSEPA specifications for BFB and DFTPP for volatile and semivolatile analyses respectively Verification of tuning criteria

occurs every twelve hours of instrument run time

EPA 04675


Mixed standards are used to perform the initial multi-level

calibration Calibration check standards are analyzed every ten

samples to verify instrument calibration If the signal response

of the check standard deviates by more than 10% from the initial

calibration the instrument is recalibrated An interference

control standard is run once every twenty samples to check

interference correction inaccuracies

Several concentrations of individual standards are analyzed

to establish the initial calibration curve for each metal

calibration check standard is analyzed at the beginning and end

of every analysis and after every twenty samples to verify the

initial calibration of the instrument If check standard falls

outside the control limit of 10% from the initial calibration

the instrument is recalibrated Calibration blanks are analyzed at

the beginning and end of the analysis and after every twenty samples

during the analysis

Standards and Reagents

Primary sources of standard reference materials used for

calibration calibration checks and accuracy control are the

tJSEPA and National Bureau of Standards NBS repositories Reliable

commercial manufacturers represent secondary source Certain

projects especially those involving pesticide registration may

necessitate the use of reference standards supplied by the

client

EPA 04676


New standards are routinely validated against known standards that

are traceable to EPA or NBS reference materials if possible

Reagents used in the preparation of matrix spike surrogate

standard and internal standard spiking solutions for EPA/cLp work

are validated using standards obtained directly from EPA or

traceable to EPA Quality Control Check Samples from the EPAEMSL Quality Assurance Branch in Cincinnati are routinely

requested received and analyzed by the Ceimic laboratories

Standards are periodically analyzed for concentration changes and

visually inspected for signs of deterioration such as color

change and precipitate formation Standards Preparation

Logbook which contains all pertinent information regarding the

source and preparation of each analytical standard is maintained

by each of the Ceimic laboratories

Reagents such as solvents that are produced and used in large

quantities are examined for purity by subjecting an aliquot to

analysis prior to purchase of an entire lot or shipment If the

material appears satisfactory the manufacturer or supplier is

requested to set aside sizeable portion of the same lot for

Ceimjc to be shipped over several months

EPA O467

Cejmjc QA PlanSection No 10Revision No 10Date December 1989Page of

10.0 Analytical Procedures

The analytical methods that Ceimic uses are contained in the

documents cited below The methods are suliunarjzed in Table biand Table 102 In addition Ceimic will use other methodology as

required by the specific project or contract

Methods Oanjc Chemical Analysis Municipal and IfldustrialWpstewater EPA600/482057 July 1982

Methods Chemical Analysis Water and Wastes EPA600/479020 3/83 Revision

Standard Methods the Examinatjo Water and Wastewater 16thEdition APHA Washing-ton D.C 1985

Chemical Characteristics of Marine Samples API Publication No4307 API Washington D.C

Test Methods Evaluating Solid Wastephysjca1/ChemjcaMethods SW846 3rd Edition Office of Solid Waste tJSEPAWashington D.C

Annual Book ASTM Standards Part 31-Water American Societyfor Testing and Materials Philadelphia PA 1981

Contract Laboratory Program Organic Caucus Protocol tJSEPA10/88 Revision

Contract Laboratory Program Inorganic Caucus Protocol tJSEPA7/88 Revision

EPI 04678

Table 102

Cejmjc QA PlanSection No 10Revision NoDate December 1989Page of

Inorganic A.nalyticaj Methods Stxmmary

Parameter Method Description Method Reference

Sample PreparationBulk Analysis

Acid Description Method 3050

Instrumental Analysis

AntimonyArsenicBariumBerylliumCadmiumChromiumCopperIronLeadManganeseMercuryNickelSeleniumSilverSodiumThalliumZincOther metalsas requiredEexavalent Cr

Cyanide total

Cyanide amenable

AcidityAlkalinitypki

Nitrate/Nitrite

Phosphorus

Ammonia

ICPColorjmetrjcdiphenylcar.b ideDistillationcolorjmetrjcChlorination Distillatiori colorjmetrjcTitrimetrjcTitrjnetricEl ectometrjcColorjmetrjc manualcadmium reductionColorinetrjcascorbic acidDistillationcolorjmetrjc

Method 200.7Method D168780

Method 335.2

Method 335.1

Method 305.1Method 310.1Method iso.iMethod 353.3

Method 365.3

Method 350.2

A.A-GF Method 204.2AAGF Method 206.2ICP Method 200.7icp Method 200.7A.A-GF Method 213.2ICP Method 200.7ICP Method 200.7IcP Method 200.7AAGF Method 239.2ICP Method 200.7Cold Vapor AA Method 245.5IC Method 200.7AA-GF Method 270.2IC Method 200.7IC Method 200.7AAGF Method 279.2IC Method 200.7

EPA 04679


Parameter Method Description Method Reference

Total KjeldahlNitrogen T1Chloride

Biological OxygenDemand BOOChemical OxygenDemand CODFliorjde

Digestion distillationcolorjmetrjcTitrimetrjc Mercuricnitratedays at 2C

Colorjmetrjc

Potentjometrjcspecific ionelectrodeDistillationSpectrophotometrjcTurb idimetrjcSpecific conductance

Method 351.3

Method 325.3

Method 405.1

Method 410.4

Method 340.2

Method 420.1

Method 375.4Method 120.1

-dissolved TDS

-suspended TSS

totals TSvolatile TVS

sett.leable SSColorSulfideSulfiteSurf actants mBAS

Gravimetricdried at 1800CGravimetrjcdried at 103105cGravimetrjcdried at 103105CGravimetrjcIgnition at 5500CVolumetricInhoff ConeColorjmetrjc Pt-CoTitrimetric IodineTitrimetrjcColorimetrjc

tJSEPA 1982 Test Methods Evaluating Solid WastePhysical/chemical Methods SW846 Second EditionOffice of Solid Waste tJSEPA Washington D.C

Table 10i contdInorganic Analytical Methods Summary

Phenols

Sulfate

Conductivity

Solids

Method 160.1

Method 160.2

Method 160.3

Method 160.4

Method 110.2

MethodMethodMethodMethod

110376.1377.1425.1

EPA 04680

Ceimjc QA PlanSection No 10Revision NoDate December 1989Page of

USEPA 1979 Methods Chemical Analysis Water andWastes EPA 600/479020 Revised March 1983 EPA/EMSLCincinnati Ohio

ASTM 1981 Annual Book ASTM Standards Part 31WaterAmerican Society for Testing and Materials PhiladelphiaPA 19103

ICP Inductively Coupled Argon Plasma Emission SpectroscopyAA-GF Graphite Furnace Atomic Absorption SpectrophotometryAA Atomic Absorption Spectrometry

EPA 04681


Table 102Organic Analytical Methods Summary

Parameter Method Reference Method Description

Volatile Organic Method 624 Purge and trap gasCompounds Aqueous Chromatography/massspectronetry

Volatile Organic Method 601 Purge and trap gasCompounds Cbromatography/Halogenated aqueous halogen specific

Hall detection

Volatile Organic Method 602 Purge and trap gasCompounds chromatography/Aromatic aqueous photoionization

detection

Semivolatile Organics Method 625 Solvent extractionAcid/Base/Neutral gas chromatography/Extractables Aqueous mass spectrometry

Pestjcjdes/pCBs Method 608 Solvent extractionAqueous gas chromatography/electronCapture detection

Herbicides Method 509B Solvent extractionAqueousderivatization gaschromatography/Electroncapture detection

USEPA 1984 Methods Organic Chemical Analysis of MunicioalIndustrial Wastewater Appendix 40 CFR Part 136 Federal

Register Vol 49 No 209 1984

APHA 1985 Standard Methods for the Examination of WaterWastewate Sixteenth Edition American Public HealthAssociation Washington DC

EPA 04682


Table 102 contdOrganic Analytical Methods Summary

Parameter Method Ref erencee Method Description

Petroleum Method 2/6 Solvent extractionHydrocarbonsgas cb.romatography/lane ionizationdetection

Oil and Grease Method 413.1 Solvent extractiongravimetricdetermination

Solvents Method D290874 Direct aqueousDirect Aqueous injection gasinj ectionchromatography/ flameionization detection

Warner 3.5 1987 Chemical Characteristics of Marine SamolesAPI Publication No 4307 API Washington DCtJSEPA 1979 Methods Chemical Analysis of Water aridwastes EPA 600/479020 Revised March 1983 EPA/EMSLCincinnati Ohio

ASTM 1981 Annual book ASTM Standards Part 31WaterAmerican Society for Testing and Materials Philadelphia PA19103

EPA 04683

Cejnjc QA PlanSection Mo 11Revision MoDate December 1989Page of

Data Reduction Validation and Reportjnct

11.1 Data Reduction

Instrumental printouts terminal readings chromatograms strip

chart recordings and physical measurements provide raw

analytical data that are reduced to concentrations of analytes

through the application of appropriate equations Equations are

generally given within the analytical methods referenced in

Section 10 Data reduction may be performed manually by

scientists or automatically by computerized data systems on the

instruments

11.2 Data Validation

Data validation is an essential element of the QA evaluation

component Validation is the process of data review and

subsequent acceptance or rejection based on established criteria

The following criteria are employed by Ceimic in the evaluation

of data

Accurance requirements

Precision requirements

Detection limit requirements

Completeness

Representatjveness

Correctness of manual and computer calculations

Contractual requirements and

Documentation requirements

EPA 04684


As in the case of EPA/CLP procedures data acceptance limits maybe defined within the method The same windows are used for

similar types of analyses if the sample matrix permits As

tracking mechanism of data acceptability quality control charts

may be plotted for specific parameters determined in identical

homogeneous matrices Control limits for methods development and

research data may be statistically determined as analytical

results are generated

Validation includes data review at both the technical and

editorial levels Technical review evaluates the application of

analytical protocols and resultant effects on the data generatedEditorial review assesses the content lucidity conciseness and

completeness of the data report

11.3 Data Reporting

Interpretation of raw data arid calculation of results are

performed by scientist experienced in the analytical

methodology Upon completion of data reduction the scientist

signs for the reported results on the data report form Another

scientist experienced in the same discipline reviews and

verifies the results also signing the data report form The

laboratory manager who is responsible for the data generated in

that laboratory often performs the second tier of review or may

OA6


independently review data and completed report forms Members of

the QA staff also check the results on selected sets of data

At minimum each data point is checked by two scientists

experienced with the analytical methodology Records are

maintained for all data even for those results that are

rejected as invalid

flow chart showing the data reduction validation and

reporting process is given in Figure 11-1

EPA 04686

Figiira i.LLData Reporting Procas

Ceijc QA PlanSection No 11Revision NoDate December 1989Page of

EPA 04687

Ceimic QA PlanSection No 12Revision No NoDate December 1989Page of

12.0 Laboratory Quality Control

Ceimic analytical and field procedures are based on sound quality

control methodology which derives from three primary sources

Standards for Good Laboratory Practice

Specific EPA and other approved analytical methods and

Handbook for Analytical Quality Control in Water andWastewater Laboratories EPA 600/479-01.9

In the application of established analytical procedures Ceimic

employs at minimum the QC protocols described in the

references found in the Analytical Methods section Specific

projects may require additional quality control measures due to

such factors as difficult sample matrices or use of innovative

techniques For those projects Ceimic will recommend and

implement subject to client approval the QC measures necessary

to produce data of known quality

Each of the Ceimic laboratories has an individual QC program

which includes but is not limited to the practices described

below

General QC Protocols Organics Laboratory

Trip blanks and holding blanks when applicable todetect contamination during sample shipping handlingand storage

Procedural blanks at minimum of one in every 20 samplesto detect contamination during analysis

EPA 04688


One matrix spike of laboratory water or soil every 20samples to determine accuracy

One matrix spike duplicate of laboratory water or soil every20 samples to determine precision

Sample spikes and spike duplicates as requisitioned by CLPto determine accuracy and the presence of matrix effects

Check samples periodically to document accuracy

Performance evaluation samples from EPA to verify continuingcompliance with EPA QA/QC standards

Surrogate standards and calculation of recoveries todetermine matrix effects

Internal standards for GC/MS analysis to account for sampletosample variation

GC analysis of EPA traceable standards to verifyworking standard accuracy and instrument performance

Initial multilevel calibration of instruments to establishcalibration curves

Daily calibration of instruments

Tuning of GC/MS systems once every 12 hours to EPAspecifications for consistency in data generation

Control limits to determine acceptability

EPA 04689


General QC Protocols Metals Laboratory

Analysis by ICP inductively coupled plasma spectroscopy orflame atomic absorption spectroscopy for most metals

Analysis by Zeeman effect graphite furnace atomic absorptionspectroscopy for low concentrations of certain metals

Initial and Continuing Calibration blanks and proceduralblank.s to detect instrumental or laboratory contamination

Initial multilevel calibration of instruments to establishcalibration curves by individual standards AA or mixedstandards ICPCheck standards every ten samples to verify instrumentcalibration

Control limit of -1-/ 10% recalibratjon if check standarddeviates by more than 10% from initial calibration

One matrix spike of laboratory water or soil every 10samples to determine accuracy for AA analysis

One sample spike of one element every 10 samples todetermine accuracy and matrix effects for AA analysis

Method of standard additions if sample spike recovery fallsoutside 15% control limit for AA analyses

One sample duplicate every 20 samples to determine precisionand matrix effects for AA and ICP analyses

Interference control standard every 20 samples to checkinterference correction inaccuracies for ICP analyses

Check samples every 20 samples to document accuracy

Performance evaluation samples from EPA to verifycontinuing compliance with EPA QA/QC standards

EPA 04690


General QC Protocols Classical Chemistry LaboratoryCyanide/Xercury

One procedural blank per sample batch minimum of per 20samples to detect contamination during analysis

One matrix spike of laboratory water or soil every 20samples to determine accuracy

One matric spike duplicate of laboratory water or soil every20 samples to determine precision

One sample spike every 20 samples to determine accuracyand matrix effects

One sample duplicate every 20 samples to determine precisionand matrix effects

Check samples periodically to document accuracy

Performance evaluation samples from EPA to verify continuingcompliance with EPA QA/QC standards

Initial multilevel calibrations to establish calibrationcurves

Calibration checks to verify calibrationCN every samplesHg every 10 samples

Control limits to determine acceptability

EPA 04691

Ceimic QA PlanSection No 13Revision NoDate December 1989Page of

13.0 Quality Assurance Systems Audits Performance Audjtg andFrequency

As participant in several certification programs and various

contracts the Ceimic laboratory is frequently subjected to

rigorous performance evaluations and onsite inspections by

regulatory agencies and commercial clients The Ceimic Quality

Assurance staff performs routine internal audits of the laboratory

as well The audits ensure that all laboratory systems including

sample control analytical procedures data generation and

documentation meet contractual requirements and comply with good

laboratory practice standards

13.2 Systems Audits

The director of the laboratory approval program for the

Department of Environmental Monitoring DEM in the State of Rhode

Island recently inspected the Caimic laboratory facilities

as part of the Rhode Island certification process

EPA 04592


The Ceimjc laboratories are audited rouinely by QA staff members

in order to detect any problems in sample flow analytical

procedures or documentation problems and to ensure adherence

to the good laboratory practices as described in Ceimic

laboratory operating manuals The items covered in an internal

systems audit at Ceimic are outlined on general basis in

Figure 13.11

1.3.2 Performance Audits

The Ceimic laboratories are also subjected to freguertt performance

evaluations

EPA 04693


Figure 13.11Audit Outline

Laboratory Audit General Considerations

Sample Ploy Through LabChain of Custody

UsualStrict

Sample StorageControlled AccessProximity to Chemical StoragePhysical Conditions e.g TemperatureHolding Times

Sample Work-up and/or AnalysisSOPsLogbooks

Standards PreparationInstruments Sample AnalysisCalibration/TuneStandards AnalysesCheck SamplesBalanceTemperature

NotebooksDatesSignatureFilled PagesInitialed Errors with Singleline CrossoutsUnits Recorded

QC SamplesBlanksSpikesDuplicatesSurrogatesControl Charts

Data File StorageHard CopiesOther Media Magnetic Tape Disk

Laboratory SafetyOrganization Order

SamplingContainer PreparationPreservativesTechniguea

QA Access Corrective Action Forms

EPA 04694


The USEPA Contract Laboratory Program requires successful

performance of preaward performance evaluation samples prior to

acceptance into the program Once established in the program

lab must continue to demonstrate performance capabilities by

successfully analyzing blind samples sent by the EPA each quarter

Ceimic also participates in the Water Supply WS and Water

Pollution WP Series of Performance Evaluations sponsored by the

Quality Assurance Branch of the EPA Successful analyses of

these samples are required as part of the laboratory

certification process for the environmental agencies of several

states

ab.a 1.3.2i

Ceimic Performance valuatjons

enc7/proqra Parameters Date

tJSEPAEMSL/Water Supply VOA Pesticides/ July 1988StudyWS022 PCBs Metals

tJSEPASL/water VOA Pesticides/ October 1988Pollution StudyWPO21 Metals

Performance is monitored internally on daily basis at Ceimic

through the use of surrogate standards and matrix control

samples Check samples obtained from EPA-EMSL Cincinnati QA

Branch and from independent commercial sources are employed

routinely in each of the Ceimic laboratories and ensure

continuing high level performance

EPA 04695

Cejjnjc QA PlanSection No 14Revision NoDate December 1989Page of

14.0 Preventive Maintenance

Preventive maintenance is routine practice at Ceinic for each

analytical instrument Scheduled preventive maintenance

minimizes instrument downtime and consequent interruption of

analysis The laboratory personnel at Ceimic are familiar with

maintenance requirements of the instruments they operate This

familiarity is based on conventional education specialized

courses and handson experience Designated staff members are

trained at manufacture facilities in the routine maintenance

procedures for major analytical instrumentation An example

logbook page for GC/MS routine maintenance is presented as Figure14i

Ceimic maintains an inventory of replacement parts required for

preventive maintenance and spare parts that often need

replacement such as electron multipliers for GC/MS systems and

the more mundane fuses and ferrules

In the case of downed instrument the problem is diagnosed as

quickly as possible If necessary replacement parts are ordered

and repairs performed by skilled inhouse personnel Key

instrumentation is maintained under service contract As third

option service call is placed with the manufacturer

Instrument problems and repairs are documented in iogbooks kept in

each laboratory an example is given in Figure 142

EPA 04696

Figiira 14I

Cejmjc QA PlanSectjo 1o 14Revision IToData December 1989Paqe of

GC/XS Routine tn3tment Maintena.ca fo 3e.i-Vo1a.tj1e

GCfl attTTE tZITtflVT MA1nTEfMc FC SEflT-IQLATTLE

CSIIIC CCRPCRA1I

1ZTST SPTUNoc ro aIArnra QANCZD

-CCI.W MMZITENAKCC-DETECTCR-f OTfl CP4NT

.1

_____________________

.j

.___ .r___E__ .-

I_______2______________________________________E_________i

Ceijc QA PlanSection No 14Revision NoDate December 1989Page of

Figira 142

GC/43 NoRoutina Instrument Mainteanca

GC/PeS ONCUN1TNE LNSTRUziEMT xNTEuAsCE

CKIIC CUR ORTIOIse__a__s cease seas.aaeaeeaa

PROaLZrl StT

Oat .Dar.s 3yt _________

Oat .adt 3y LLn

C3m.nt ____________________

_________________________________________ Otn.r COE3CRI3E

eeeeeee eneeeaaae __fle__e__eefl

DEscrPr rap

RSCLUT

EPA 04698

Cejmjc QA PlanSection No 15Revision NoDate December 1989Pagelof3

15.0 Specific Routine Procedures trsed to Assess DataPrecision Accuracy and Completeness

Precision accuracy and completeness are discussed in Section

as well

15.1 Precision

Precision is frequently determined by the comparison of

replicates where replicates result from an original sample that

has been split for identical analyses Standard deviation of

sample is cotnmonly used in estimating precision

Sample standard deviation

SUM xi x2i1

where quantity e.g concentration is measured times with

mean

The relative standard deviation RSD or sample coefficient of

variation CV which expresses standard deviation as percentage

of the mean is generally usefu in the comparison of three or

more replicates although it may be applied in the case of n2RSD 100 s/x

or

CV 100 s/xwhere RSD relative standard deviation or

CV coefficient of variation

standard deviation

mean

69

Ceimjc QA PlanSection No 15Revision NoDate DecenhlDer 1989Page of

In the case of duplicates samples that result when an original

sample has been split into two for identical analyses the

percent difference %D between the two samples may be used to

estimate precision

D1 D2/D1 D2

where %D percent difference

D1 first sample value

D2 second sample value duplicate

15.2 Accuracy

The determination of accuracy of measurement requires

knowledge of the true or -accepted value for the signal being

measured Accuracy may be calculated in terms of bias as

follows

BiasT%Bias 1OO T/T

Where average observed value of measurement

true value

Accuracy may also be calculated in terms of the recovery of

spiked samples

%Recovery 100 X/T

EPA 04700


1.5.3 Completeness

Determining whether data base is complete or incomplete may be

quite difficult To be considered complete the data set must

contain all QC check analysis verifying precision and accuracy for

the analytical protocol Less obvious is whether the data are

sufficient to achieve the goals of the project All data

are reviewed in terms of goals in order to determine if the data

base is sufficient

Where possible the percent completeness for each set of samples

is calculated as follows

valid data obtained%coinpleteness 100

total data planned

EPA 04701

Ceim.ic QA PlanSection No 16Revision NoDate December 1989Page of

16.0 Corrective Action

Art essential element of the QA Program Corrective Action

provides systematic active measures to be taken in the resolution

of problems and the restoration of analytical systems to proper

functioning

Corrective actions for laboratory problems are described in Ceiinic

laboratory operating manuals Personal experience often is most

valuable in alerting the bench scientist to suspicious results

or malfunctioning equipment Specific QC procedures are designed

to help analysts determine the need for corrective actions SeeSection 11 Data Reduction Validation and ReportingCorrective actions taken by scientists in the laboratory help to

avoid the collection of poor quality data

Examples of conditions that may warrant corrective actions are

given below

Tuning or calibration of instruments outside ofspecifications

QC data for precision and accuracy outside ofacceptance limits

Undesirable trends in concentration surrogate andspike recoveries response factors or relative percentdifference

Abnormal variation in detection limits

Check sample results out of range

EPA 04702


Problems not immediately detected during the course of analysis

may require more formalized longterm corrective action The

essential steps in the corrective action system are

Identify and define the problem

Assign responsibility for investigating the problem

Investigate and determine the cause of the problem

Determine corrective action to eliminate the problem

Assign and accept responsibility for implementing thecorrective action

Establish effectiveness of the corrective action andimplement it

Verify that the corrective action has eliminated theproblem

This scheme is generally accomplished through the use of

Corrective Action Request Forms Figure 161 available to all

Ceimic staff members Using this form any laboratory scientist or

project rnember may notify the QA Director of problem The QA

Director initiates the corrective action by relating the problem to

the appropriate laboratory managers and/or project managers iho

investigate or assign responsibility for investigating

the problem and its cause Once determined an appropriate

corrective action is approved by the QA Director Its

implementation is later verified through laboratory audit

EPA 04703


Information contained on Corrective Action forms is kept

confidential within Ceimic and is generally limited to the

individuals involved Severe problems and difficulties may

warrant special reports to the President of Ceimic who will

ensure that the appropriate corrective actions are taken

EPA 04704

Ce.jmjc QA PlanSection No 16Revision NoDate December 1989Paqe of

Figure 161Ceim.jc Quality A3surance Corrective Action Request Form

CEII4IC CORPORATIQU

Quality A.auranàe Corrective Action Request

Originator _________________ Date________________

Laboratory ________________ Project___________Problem

Actjo Planned Luplementad

QA Director_______________ Date

EPA 04705


17.0 Quality Assurance Reports to Management

The Ceimic Director of Quality Assurance submits QA report each

quarter to the President of Ceimic and the Laboratory Manager

The report contains detailed information on QA activities during

the previous three months including

Summary of systems and audits

Performance evaluation samples analyzed and scores received

Status of certifications

Laboratory QA/QC review

Problems arid corrective actions

Comments and recommendations

In the case of severe problem or difficulty special report is

prepared by the QA Director and submitted in timely manner to

the management

EpA 04706

Ceimjc QA PlanAppendixRevision NoDate December 1989Pages 14

APPENDIX

PERSONNEL QUALIFIcATIONS AND RESUNES

EPA 04707

Cejmjc QA PlanAppendixRevision NoDate December 1989Page of 14

JOHN MCGARRY JRPRESIDENT

Mr McGarry is one of the most experienced administrators ofenvjrornnental laboratories in the country He has built ariddeveloped two other laboratories who were admitted to the Cpprogram in both organics and inorganics He is CertifiedPublic Accountant

EDUCATION

UNIVERSITy OF MASSACHtJSETrS A1IERSTM.B.A

BOSTON COLLEGEB.S Accounting

EXPERIENCE

1988 Present CEIMIC CORPORATIONNarragansett Rhode IslandPresident

1979 1987 BOSTON TECHNOLOGIES INCCambridge Massachusetts Austin TexasFounder and PresidentBTI provided environmental and energyconsulting services to both industry andgovernment

1976 1979 ENERGY RESOURCES CO.INC ERCOCambridge MassachusettsChief Financial OfficerERCO was an environmental laboratoryand consulting firm with annual sales of$10 million

1974 1976 KPMG PEAT MARWICKBoston MassachusettsSenior Accountant

EPA 04708

Ceimjc QA PlanAppendixRevision NoDate December 1989Page of 14

DIANE If KENNYQA/QC DIRECTOR

Ms Kenny was recently appointed as Ceixnics QualityAssurance/Quality Control Director She has nine yearsexperience in laboratory QA/QC

EDJCATION

Rochester Institute of TechnologyEnvironmental Science/Chemistry

EXPERIENCE

1989 Present CEIMIC CORPORATIONNarragansett RIQA/QC Director

1988 1989 NANCO LABORATORIESWappingers Falls NYMarketing RepresentativeResponsible for procuring laboratorywork from the New York/New England areas

1988 VERSAR ENVIRONMENTAL RISKMANAGEMENT FIRMLABORATORY OPERATIONSColumbia MDProject ManagerManaged commercial government and inhouseprojects Supervised data management groupReviewed QC data

1985 1988 HITTMAN EBASCO ASSOCIATES INCColumbia MDQA Manager/CoordinatorOversee development and enactrnent of QA/QCprogram revised QA Manual responsible forday to day QC activities

1980 1985 PHOTOCIRCUITSDIVISION OF KOLLMORGEN CORPORATIONGlen Cove NYQuality Control ChemistDeveloped statistical quality control chartsfor electroplating processes EstablishedQA/QC Plan for the laboratory

EPA 047Q9

Ceixnjc QA PlanAppendixRevision NoDate December 1989Page of 14

VERONICA MORETTIDOCUMENT CONTROL/SAMPLE CSTODIAN

Ms Moretti degreed MIS specialist is responsible for controlof client samples

EDUCATION

UNIVERSITY OF RHODE ISLANDB.S Management Information Systems

EXPERIENCE

1988 Present CEIMIC CORPORATIONnarragansett RISample Custodian

1984 1988 UNIVERSITY OF RHODE ISLANDKingston RIData Entry Clerk and Programmer

EPA 04710


KIN CKIUORGANIC LABORATORY MANAGER

Dr Chiu brings Ceimic superb combination of education andexperience He has performed both routine analytical work andspecialized research projects

EDUCATION

MASSACHUSETTS INSTITUTE OF TECHNOLOGYPh.D Analytical Chemistry

RUTGERS UNIVERSITYM.S Environmental Science

UNIVERSITY OF MARYLAND3.8 Chemistry

EXPERIENCE

1988 Present CEIMIC CORPORATIONNarragansett Rhode IslandOrganic Laboratory Manager

1983 1988 ENSECO

Cambridge MassachusettsManager Research and DevelopmentStarted with the firm as the manager ofthe Semj-Volitle GC/MS lab and was promotedin 1985 to direct special analytical projectsand research and development

1979 1983 MASSACHUSETTS INSTITUTE OF TECHNOLOGYMassachusetts

Research AssistantPerformed analytical chemistry researchutilizing GC/MS techniques

EPA 04711

Ceimjc QA PlanAppendixRevision NoDate December 1989Page6of4

REINIER COTJRANTINORGANIC LABORATORY MANAGER

Mr Courant is an analytical scientist who has over twenty yearsof experience in oceanographic and environmental chemistry Hewas formerly Laboratory Manager of E31 which under his directionwas admitted to EPAs Contract Laboratory Program in bothorganics and inorganics

EDaCATION

UNIVERSITY OF RHODE ISLANDM.S Chemical Oceanography

NORTHEASTERN UNIVERSITYM.S Mathematics

DELFT INSTITUTE OF TECIQOLOGY NetherlandsB.S Chemistry

EXPERIENCE

1988 Present CELIC CORPORATIONNarragansett RI1-norganic Laboratory Manager

1980 1988 ENERGY ENVIRONNTAL ENGINEERING INCCambridge MassachusettsVice President Laboratory Manager

1978 1980 INTERSTATE ELECTRONICS CORPORATIONAnaheim CaliforniaChief Scientist/Senior Oceanographer

1976 1978 ERCO now ENSECOCambridge MassachusettsSenior Oceanographer/chemist

1972 1976 UNIVERSITY OF RHODE ISLANDNarragansett Rhode IslandGraduate Research Assistant

1969 1972 WOODS HOLE OCEANOGRAPHIC INSTITUTEWoods Hole MassachusettsResearch Assistant

EPA 04712

Cejjc QA PlanAppendixRevision MoDate December 1989Page7of4

SKAWN DREWSAMPLE PREPARATION MANGER

Mr Drew is laboratory analyst with over years experience inenvironmental research and analysis

EDtTCATION

UNIVERSITY OF RHODE ISLANDB.S Zoology

EXPERIENCE

1989 present CEIMIC CORPORATIONNarragansett RIPreparation Laboratory Manager

1981 1989 NATIONAL MARINE FISHERIES SERVICENarragansett RILaboratory TechnicianMaintained large research aquarium areaand wet lab Also tested seawater for pHsalinity oxygen ammonia and flcw rateUtilized methodology for the analysis ofnucleic acids lipids and protein in fishAlso maintained equipment and labware inbiochemistry lab

EPA 04713


KEviN DUPPYGC LABORATORY MANAGER

Mr Duffy is an analytical chemist with four years of experiencein GC analysis of environmental samples He has extensiveexperience in the analysis of marine sediment and biologicalsamples for petroleum hydrocarbons

EDUCATION

UNIVERSITY OF MARYLANDB.S Chemistry

EXPERIENCE

1989 Present CEIMIC CORPORATIONNarragansett RICC Laboratory Manager

1986 1989 ENSECO/ERCO LABORATORYCambridge MAChemist main responsjbjlties included thepreparation and analysis of environmentalsamples by CC using EPA/CLP approved methods

1984 1986 FNC CORPORATIONBaltimore MDChemist responsible for preparation andanalysis of plant produced waste waterquality control and waste water toxicitystudies

1979 1983 MARYLAND DEPARTNT OF AGRICULTrJRSCollege Park MDTechnician

EPA 04714

Cejmjc QA PlanAppendixRevision NoDate December 1989Page of 14

ALFRED KWO LEX JRVOA LABORATORY MANAGER

Mr Kuolek is an analytical chemist with fourteen yearsexperience in environmental analysis using GC/NS He wasformerly principal/supervisor at the Rhode Island Departmentof Health and responsible for the supervision and operation ofthe Volatile Organic Laboratory

EDCCATION

UNIVERSITY OF RHODE ISLANDM.S Environmental Health ServicesB.A Biology

EXPERIENCE

1988 Present ciic CORPORATIONNarragansett RIVOA Laboratory Manager

1974 1988 RHODE ISLAND DEPARTNT OF HEALTHProvidence Rhode IslandPrincipal Chemist/SupervisorStarted as staff chemist and was promotedin 1984 to senior chemist and in 1987 toprincipal chemist/supervisor in the organiclaboratory

1988 FINNIGAN MATLivingston New JerseyManager Consulting Chemist ProgramManaged GC/MS Applications Program

EPA 04715

Cejmjc QA PlanAppendixRevision NoDate- December 1989Page 10 of 14

LI-PIN LEEGC/MS SUPERVISOR

Mr Lee is trained organic chemist with over four yearsexperience in GC/MS

EDCCATION

WORCESTER POLYTECHNIC INSTITUTEPh.D ABD Organic Analytical Chemistry

UNIVERSITY OF FLORIDAM.A Agriculture

UNIVERSITY OF NEBRASKAM.S Organic Chemistry

NATIONAL CHUNG-HSING UNIVERSITY TAIWANB.S Agricultural Chemistry

EXPERIENCE

1988 Present CEIIC CORPORATIONNarragansett RIGC/MS Supervisor

1988 1989 ALPHA ANALYTICAL LABORATORIESWarick RIGC/MS Supervisor

1985 1988 WORCESTER POLYTECIC INSTITUTEWorcester MAGC/MS Supervisor

EPA

Ceimjc QA PlanAppendixRevision NoDate December 1989Page 11 of 14

ROBERT FLYNNChief Financial Officer

Mr Flynn is Ceimics Chief Financial Officer He isCertified Public Accountant and most recently was the CFOfor $100 million firm As audit director with the WashingtonPost Company and IngersollRand he was responsible for bothcompanys financial quality control and quality assurance Hisexperience in operational auditing and in reviewing anddocumenting systems enable him to provide assistance to theCompanys Quality Control/Quality Assurance efforts

ED3CATION

Northeastern UniversityAccounting

College of the Holy CrossEconomics

EXPERIENCE

1988 Present CEINIC CORPORATIONNarragansett RIChief Financial Officer

1985 1988 THE WASHINGTON POST COMPANYWashington Phoenix ArizonaVice President Chief Financial OfficerStarted as Director of Auditing and thenpromoted to CFO of Cable TV subsidiary

1980 1985 INGERSOLL RAND COMPANYParamus New JerseyDirector Corporate Internal AuditStarted as supervisor and promoted toregional manager in 1981 and directorin 1983

1978 1980 POLAROID CORPORATIONCambridge MassachusettsSenior Auditor

1974 1977 KPMG PEAT MARW1CKBoston Massachusetts

EPA 04717


JAMES BENNETTMARXETING

Mr Bennett is responsible for customer service activitiesHe has seven years of experience in the service industry andis partner in Ceimic

EDUCATION

BROWN UNIVERSITYB.A Classics

EXPERIENCE

1988 Present CEIMIC CORPORATIONNarragansett Rhode IslandMarketing

1986 1987 ALBERT BENNETT AND COMPANY INCProvidence Rhode IslandPresidentInvestment Banking

1985 1987 PRUDENTIAL BACHE INCProvidence Rhode IslandStockbrokerSales of stocks municipal and corporatebonds tax shelters etc

1980 1985 KIDDER PEABODY INCProvidence Rhode IslandStockbrokerInvestment sales

1979 1980 ATLANTA FLAMES HocY CLUB INCBirmingham AlabamaProfessional athlete

EPA 04718


WILLIAM CALLANAN JRCustomer Service Manager

EDUCATION

tJniversity of Rhode IslandB.S Natural Resources

EXPERIENCE

1988 Present CEIMIC CORPORATIONAtlanta GACustomer Service Manager

1985 1988 ECHELON CORPORATIONProvidence RIAccount Representative

1979 1984 JINZER/IMSDallas TXDivision Sales Manager

1978 1979 NATIONAL OCEANIC AND ATMOSPHERICADMINISTRATIONNarragansett RIOceanographer

EPA 04719

Cejmjc QA PlanAppendixRevision NoDate December 1989Page 14 of 14

MARGARET NARPLECUSTOMER SERVICE MANAGER

Mrs Mar-pie is responsible for customer service activities Shehas twenty years experience in all phases of the commercialenvironmental laboratory business including bench analysesmanagement and customer service

EDICATION

PENNSYLVANL STATE UNIVERSITYChemistry

EXPERIENCE

1989 Present ciic CORPORATIONPittsburgh PACustomer Service Manager

1981 1989 NUS CORPORATIONPittsburgh PALaboratory ManagerStar-ted as supervisor of the inorganicchemistry section and promoted to laboratorymanager in 1983 Established the customerservice department in 1988 which was responsiblefor business development proposal preparationclient reporting and all customer serviceacitjvjtjes

1972 1981 PENN ENVIRQNNTAL CONSULTANTS INCPittsburgh PALab SupervisorResponsible for supervision of the analyticallaboratory training technicians and maintainingquality control

1970 1972 ENTIRONNT SCIENcES INCPittsburgh PALaboratory AnalystPerformed inorganic and microbiologicalanalyses of air and wastewater samples

1966 1969 BITUMINOUS COAL RESEARCIMonroevjlle PAPerformed analysis of coal gasificationsamples and treatability studies of coalmine drainage

EPA 04720

Ceimjc QA PlanAppendixRevision NoDate December 1989Page of

APPENDIX

FACILITIES AND EQUIPMENT

EPA 04801

Cejmjc QA PlanAppendixRevision NoDate December 1989Page of

Facilities Ceimic Laboratories are located in 12500

sq ft one story building Approximately 4400 sq ft is

actual laboratory space 5000 sq ft are offices and support

area and another 2500 sq ft is designated as storage area

Organic Laboratories The Organic Laboratories consist of two

preparation laboratories Organic Preparation Laboratory and

and two instrument rooms Volatile Organics and SemiVolatile

Organics/Pestjcjdes/pcgs The Organic Preparation Laboratorylis large 1170 sq ft laboratory for the routine

preparation of environmental samples The Organic Preparation

Laboratory2 is smaller 324 sq ft area where environmental

samples are prepared which require special handling

The Volatile Organic Analysis VOA instrument room 750

sq ft is situated well apart from the Organic Preparation

Laboratories is to avoid contamination of VOA samples by solvents

used in these Preparation Laboratories

The base neutrals and acid extractables ENA or semiVOA and

gas chromatograDhy GC instrument room 850 sq ft is located

between the VOA instrument room and the Organic PreDaratjon

Laboratories

EPA 04802

Cejmjc QA PlanAppendixRevisionDate December 1989Page of

Inorganic Laboratories The Inorganic Laboratories are divided

into an inorganic preparation/wet chemistry laboratory 950 sqft and an inorganic instrument room 350 sq ft.

Samples will be received and initially stored in designated

Sample Receiving Room 320 sq ft directly adjoining the

entrance hail of the Ceimic building Additional sample storage

space is available in the 2500 sq ft storage area

Equipment Organic Laboratories The Organic Preparation

LaboratoryI contains 90 linear feet of bench space and will

initially be outfitted with three fume hoods Bench space

has been allocated for three additional fume hoods This laboratory

contains solvent storage room with blowout roof

exposure Millipore Miii-Q ultrapure water system is located in

this laboratory Standard organic laboratory equipment located

in this labortory includes

mtiffle furnacedrying ovensonicatoranalytical balance 0.1 mg accuracysoxhlet extractorsRotovapswater bathscontinuous liquidliquid extractors

EPA 04803

Ceimjc QA PlanAppendixRevision NoDate December 1989Page of

The Organic Preparation Laboratory2 has 40 linear feet of bench

space and two fume hoods Standard organic laboratory

equipment located in this laboratory include

RotovapsSoxbJ.et extractors

The VOA instrument room contains 64 linear feet of bench

space and canopy hood and sink bench linear feet This

instrument room will be equipped with two Hewlett Packard 5970

CC/MS units and Hewlett-Packard iooo RTE-A data systems and

accessories There is also HP 5890 GC with dual Hall arid PID

capabilities tip to six additional GC/MSs and two 1000 RTE-A

data systems can be located in the VOA room

The BNA/GC instrument room contains 84 linear feet of bench

space and canopy hood and sink bench linear feetInitially this instrument room will be equipped with one

Hewlett-packard 5970 CC/MS and two Hewlettpackard 5890 GCsOne GC will be outfitted with dual electron capture detectors

ECDs and an automatic sampler the second CC will have dual

ECD and FID capabilities

Data acquisition on the GCs will initially be performed

through dedicated Hewlett-packard 3396A Integrators In the near

future data generated by the GCs will be offloaded onto the

1000 RTEA data system

EPA 04804

Cejmjc QA PlanAppendixRevision MoDate Decenther 1989Page of

Inorganic Laboratories The inorganic preparation/wet

chemistry laboratory will have 131 linear feet of bench space twofume hoods and two class 100 clean benches Space is

allocated for third fume hood This laboratory will contain

ten 10 cyanide distillation columns and mercury analyzer

Standard inorganic laboratory equipment includes

analytical balance 0.1 mg accuracydrying ovenair compressor and storage tankvacuum pump

The Inorganic Instrument Room will be equipped with Perkin-ElmerP40 inductively coupled argan plasma mmission Spectrophotometerand PerkinElmer Zeeman 5100 graphite furnace atomic absorption

soectrophotometer

EPA 04805

INDUSTRIAL AND ENVIRONMENTAL ANALYSTS INC

Formerly Eastern Analytical Laboratories

QAPPEPA 04806

INDUSTRIAL AND ENVIRONMENTAL ANALYSTS INCMassachusetts

CHEMISTRY LABORATORY

QUALITY MANAGEMENT PLAN

January 1991

149 Rangeway Road Phone 617 272-5212

Billerica MA 01862 Fax 508 667-7871

EPA 04807

TABLE OF CONTENTS

Introduction

Individual Responsibilities

Importance and Purpose of Quality Control

Quality Assuance Objectives

Introduction

Quality Assurance Objectives for Accuracy

Quality Assurance Objectives for Precision

Quality Assurance Objective for Data Completeness 10

Personnel and Training 11

Saftey 12

Sampling 13

Introduction 13

Sample Plan 13

Sample Containers 15

Sample Preservation and Holding Times 15

Chain of Custody 25

Receipt and Handling of Samples 27

Building Security 31

10 Analytical Procedures 32

Gas ChrmatographylMass Spectrometry GCIMS 32

Gas Chromatography 35

Graphite Furnace Atomic Absorption Spectrophotometry GFAA 36

Inductively Coupled Plasma ICP 37

Cold Vapor Mercury Analysis Flameless AA CVAA 38

Spectrophotometiy Colormetric Methods 39

Balances 40

11 Data Reduction and Reporting 41

Data Reduction 41

Reporting Results 41

EPA 04808

TABLE OF CONTENTS CONT

12 Internal Quality Control Checks 42

13 External Quality Control Programs 43

14 Chemistry Certifications

15 Instrument Maintenance 47

16 Corrective Action

Appendix Resumes 49

oAB9

INTRODUCTION

Industrial and Environmental Analysts IncfMass TEA is frill service laboratory offering

wide range of analytical services general overview of our capabilities would include electron

microscopy optical microscopy asbestos testing environmental analysis and industrial hygiene

testing The two main divisions of our company are microscopy and chemistry lhis manual outlines the quality management plan for the chemistry laboratory

This document describes the Quality Assurance procedures employed by Industrial and

Environmental Analysts to ensure that all data generated in the laboratory conforms to specific

requirements for accuracy precision and completeness These procedures are routinely incorpo-

rated into all analyses performed by lEAto ensure that the data produced in the laboratory are reli

able

Customized client-specific quality control measures can be added to or supersede these basic

guidelines to satist the needs of individual clients Laboratory personnel are available to discuss

the design and advantages of other quality control options

EPl 04810

INDIVIDUAL RESPONSIBILITIES AND ORGANIZATION CHART

The chemistry laboratory at lEA operates as separate entity from the microscopy

laboratory

The organization chart is illustrated in Figure 2-1 The following is summaryof major

responsibilities of each position

Chief Chemist The chief chemists are responsible for all of the activities in their depart

ment They oversee all of the methods equipment and personnel in their area They are responsible

for all results that are reported and sign-off on written reports The chief chemists also see that the

QC practices are followed and assist in the resolution of technical problems

Chemist The chemists work under the direct supervision of the chief chemists They carry

out the analysis of samples and associated QC practices along with the chief chemists The responsi

bilities of chemists include

Initial review of QC data for acceptability

Recording of data in bound laboratory notebooks or permanent records assigned to mdi

vidual analytical batches

Informing supervisors of problems with instruments or methods to ensure that prompt and

effective corrective action is taken

Assistant Chemist The assistant chemists aid the chief chemists and chemists in the workof the laboratory This classification is generally reserved for entry level chemistry employees who

are being trained in laboratory operations and procedures

Technical Assistant The technical assistant provides support to the chemistry staff Their

work is generally focused in the sample preparation area This classification is usually reserved for

entry level employees who do not have college degrees

EPA 04811

Figure

2-1

ORGANIZATION CHART

Director

David Houle

Technical DireciIliUCHEMISTRY LABORATORY

INORGANIC SECTION ORGANIC SECTION

Chief Chemist Chief Chemist

Robert Peaiy Michael Wheeler

_________IChemisti lAss istant Chemist Seniivolatile Organics Volatile Organics

Lisa Lane TonyYu _______IChemisti

GCfMSLucio Barinelli

lAssistant Chemist IChemisti lAssistant Chemist

Kim Keller Jenny

Lin Julie Griffin

LII

.tthemiGordon Tripp

IMPORTANCE AND PURPOSE OF OUALITY CONTROL

The purpose of this manual is to provide documentation of the standard practices at Industrial

and Environmental Analysts to ensure the quality and reliability of data returned to our clients

There are two reasons for this concern for quality First data is the product of this laboratory so it is

in our best intrest to produce reliable product Second important decisions as well as regulatory

compliance are based on our results Clients need maximum assurance that these decisions have the

support of high quality laboratory work

EPI 04813

QUALITY ASSURANCE OBJECTIVES

Introduction

The objective of this Quality Management Plan QMP is to provide framework to ensure that all

analytical data which are reported are of known quality The minimumrequirements of an effective

Quality Assurance program include

Sample Management sampling sample preservation chain-of-custody

Analytical Methodology documented analytical procedures calibration data handling

Laboratory Records measurement data maintenance records equipment manuals

Quality ControUQuality Assessment control charts quality control samples

Data Review Validation and Reporting

Performance and System Audits/Corrective Action

Personnel Training

All measurements made in this program will be representative of the matrix and conditions being

analyzed The data are generally calculated and reported in units consistent with standard reporting

conventions to enable comparability to existing data standards and/or regulatory action limits

Client requests for specific reporting requirements are honored

The specific procedures utilized by IEAin this program will be described in subsequent sections of

this QMP All of these requirements help to establish the QA objectives which are measured in

terms of accuracy precision and completeness

Oualitv Assurance Objectives for Accuracy

Analytical accuracy can be expressed as the percent recovery of an analyte which has been used to

fortify an investigative sample or standard matrix e.g blank soil analyte-free water etc at

known concentration prior to analysis and is expressed by the following formula

Accuracy Recovery AT A0 100

EPA 04814

where

AT Total amount found in fortified sample

A0 Amount found in unfortified sample

AF Amount added to sample

The fortified concentration will be specified by laboratory quality control requirements or may be

determined relative to backround concentrations observed in the unfortified sample In the latter

case the fortified concentration should be enough different from the background concentration to

times higher to permit reliable recovery calculation

The quality assurance objectives for organic and inorganic analyses are tailored to the analytical

technique used and are discussed separately below

Metalsflnorganics Analysis

For metals analysis analytical accuracy is obtained from the analyte recovery measured in labora

tory control standard and/or sample fortified with the element of interest The QA objectives for

accuracy in routine metals analysis for these QC samples are summarized below

Sample Recovery

Laboratory Control Standard LCS 80 120

Fortified Field Sample 75 125

Recovery values outside the QC limits for an LCS with the exception of antimony and silver will

trigger corrective action Recovery values for fortified field samples are advisory only

Organic Analysis GC and GCIvlS

For organic analysis analytical accuracy is obtained from the surrogate recovery measured in each

sample and blank and/or from the analysis of samples or blanks which have been fortified with

select number of target analytes

The Quality Assurance objectives for accuracy in determination of priority pollutant organic analytes

are summarized in Table 4-1 for GCIMS surrogates and in Table 4-2 for GCIMS target analytes from

fortified samples The recovery values for surrogate and target analytes in investigative sample

analyses are advisory for routine laboratory analysis Only recovery values for standard matrix

samples e.g blanks are used for triggering corrective action

EPA 04815

TABLE 4-1

OUALITY ASSURANCE OBJECTIVES FOR ACCURACY

FOR

ORGANIC SURROGATE ANALYSES

Percent Recovery

Low/Medium Low/Medium

Fraction Surrogate Compound Water Soil/Sediment

VOA Toluene-d8 88-110 81 117

VOA 4-Bromoflourobenzene 86 115 74- 121

VOA 12-Dichloroethane-d4 76 114 70 121

BNA Nitrobenzene-d5 35 114 23 120

BNA 2-Fluorobiphenyl 43 116 30 115

BNA p-Terphenyl-d14 33-114 18-137

BNA Phenol-d5 10- 94 24-113

BNA 2-Fluorophenol 21 100 25 121

BNA 246-Tribromophenol 10 123 19 122

Pest Tetrachlorometaxylene 24 154 20 150

These recoveries are advisory only No corrective action i.e sample reanalysis will be taken if

these criteria are not met

EpA

Fraction

TABLE 4-2

OA OBJECTIVES FOR ACCURACY AN PRECISION

FOR

ORGANIC TARGET COMPOUND ANALYSES

Limits

Soil/Sed

VOAVOAVOAVOAVOA

BNBNBN

BNBNBN

11 -Dichloroethene

Trichlorobenzene

Chlorobenzene

Toluene

Benzene

24-Trichlorobenzene

Acenapthene

24-Dinitrotoluene

Pyrene

4-Dichlorobenzene

61 145

71 120

75 130

76-125

76- 127

39- 98

46- 118

24- 96

26 127

41 116

36- 97

59-172

62 137

60-133

59-139

66- 142

38 107

31 137

28- 89

35 142

41 126

28 104

14 22

14 24

.13 21

13 21

11 21

28 23

31 19

38 47

31 36

38 38

28 27

ACIDACIDACIDACID

ACID

PEST

PEST

PEST

PEST

PEST

PEST

Lindane

Heptachior

Aidrin

Dieldrin

Endrin

44-DDT

103

12- 89

27-123

23- 97

10- 80

56-123

40 131

40 120

56-126

56-121

38 127

17 109

26- 90

25 102

26 103

11-114

46 127

35 130

34-132

31 134

42 139

23 134

50 47

42 35

40 50

42 33

50 50

15 50

20 31

22 43

18 38

21 45

27 50

PCB Arochlor 1254 Not Established 30 50

RPD Relative Percent Difference

This list includes those compounds most commonly used for QA/QC accuracy and precision control

in the groups of analytes shown based on current U.S EPA Contract Laboratoty Program CLPrequirements USEPA SOW 10/86 as revised through 8/87 Stated control limits will be updatedto the current CLP protocol as required

Matrix Spike Compound

Recovery Limits RPDWater SoillSediment Water

N-nitrosco-di-N-propylamine

Penthachiorophenol

Phenol

2-Chiorophenol

4-Chloro-3-methylphenol

4-Nitrophenol

EPA 04817

Accuracy objectives for other analyses are defined on case-by-case basis through the use of cali

bration and recovery flow charts

For the analysis of air samples breakthrough may result when the quantity of analyte sampled exceeds the capacity of the sampling device Unacceptable breakthrough is identified when the

amount of analyte found in the backup section divided by the amount found in the frount section

exceeds specified value Sample results may be rendered invalid depending upon the percentage of

breakthrough in the backup section of the sorbent tube or sampling device The fact that sampleresult is questionable does not mean nesessarily that the data needs to be discarded but they should

be viewed with care The possibility and feasibility of resampling should be considered in this case

If results accuracy is questioned because of breakthrough the result is reported as minimum

value with note that concentrations are likely to be higher In general if the percentage of the total

amount of analyte found in the backup section of the sampler exceeds one-half of the ratio of the

amount of sorbent in the backup section divided by that in the front section that sample should be

considered invalid because of significant breakthrough from front to backup section and possible

sample loss from the backup section

Oualitv Assurance Objectives for Precision

Analytical precision is calculated by expressing as percentage the difference between results of

analysis of duplicate samples relative to the average of those results for given analyte Precision

can be expressed by the formula

%RPD C1-C2 100

C1C2/2

where

RPD Relative Percent Difference

C1 Concentration of analyte in sample

C2 Concentration of analyte in replicate

On the occasion when three or more replicate analyses are performed precision is calculated by

expressing as percentage the standard deviation of the analytical results of the replicate determina

tions relative to the average of those results for given analyte This precision measurement rela

tive standard deviation RSD will have QA objectives identical to those for RPD and can be

expressed by the formula

RSD C.-C2In-1 100

C1C2...C/n

where

RSD relative standard deviation

C1 concentration of analyte measured in the sample and C1 C2 C/nrepresents the average result

number of replicate analyses

The QA precision objective for metals analysis and other inorganic parameters are different from

those for organic analyses These QA objectives are discussed separately in the sections below

Metals and Miscellaneous Inorganic Analyses

For metals except antimony and silver and inorganic analyses the QA objective for precision is

20% relative percent difference between replicate analyses RPD values outside the QC limits for

duplicate Laboratory Control Sample analyses will trigger corrective action RPD for duplicate

investigative sample analyses are advisory only

Organic Anavses GC GCMS

For organic analyses precision is measured by comparison of the recovery of surrogate compoundsin sample with those in standard matrix e.g blank blank spike and/or by comparison of the re

covery of select number of target analytes in duplicate fortified samples or duplicate fortified

blanks e.g matrix spike/matrix spike duplicate and/or blank spikelblank spike duplicate

IBSD The QA objectives for precision as expressed by the RPD for duplicate analysis of

target analytes are given in Table 4-2 For surrogate compounds laboratory control charts have been

established and will be used to define QA objectives These RPD limits are advisory only for inves

tigative samples Only evaluation of precision for standard matrices will trigger corrective action

Ouality Assurance Objective for Data Completeness

Completeness is measure of the relative number of analytical data points which meet all the acceptance criteria required by the specific analytical methods used The level of completeness can also

be affected by loss or breakage of samples during transport as well as external problems which

prohibit collection ofthe sample

The IEAQA objective for completeness is to have 80% of the data usable without qualification The

ability to meet or exceed this completeness objective is dependent on the nature of samples submit

ted for analysis For example if the analytical methods proposedfor use particularly for organic

analyses are intended for analyses of environmental samples of low to medium hazard the applica

bility of these methods to non-routine matrices such as drum samples wipes air samples etc mayresult in poor method performance and therefore adversely impact achievement of the data completeness goal

10EPA 04819

PERSONNEL AND TRAINING

Well-qualified and properly-trained personnel are key aspects of satisfactory laboratory performance Although good facilities and equipment are essential they are of little value without well-

trained personnel to utilize them

For small company it is not possible to set forth rigid list of qualifications for each particular position Education and experience are considered together in judging the suitability of

person for job As openings occur the appropriate combination of education and experience neces

saiy for the job is considered These are then evaluated in light of the individual applicants

Training is an on the job process New personnel work with an experienced staff member

on one-to-one basis Each task is explained and demonstrated to the trainee The necessary refer

ence methods and equipment manuals are given to the new employee to read and study Experi

enced people are always available to answer questions Free exchange of ideas and questions amongthe laboratory staff is strongly encouraged Trainees are instructed in the quality control practices of

the methods they are learning

All personnel are monitored by their supervisors for the correctness of their work Newemployees are required to achieve method specified levels of accuracy and precision before under

taking unsupervised analysis of investigative samples

11 EPA 04820

SAFETY

All new employees are instructed as to lEA safety practices and procedures All employees

are informed concerning the following safety items

Fire exits

Fire extinguishers

Emergency shower

Eyewash

Safety glasses

Gloves for using solvents acids and other hazardous materials

Fume hoods

Solvent storage

Chemical storage

Waste disposal

Material Safety Data Sheets MSDS are maintained in file for easy access by all employees

Saftey concerns are monitored by the company saftey officer This individual is responsible for the

records of saftey assessment e.g hood flow rate measurments and serves as liason between company management and lab personnel over saftey and health issues

Detailed company saftey policies are described in the Employee Chemical Saftey Handbook

12

SAMPLING

Introduction

While samples submitted to the laboratory for analysis are generally collected by non-laboratory

personnel lEA fully recognizes the importance of the sample collection program in the overall as

sessment of data quality and usability Sampling procedures must ensure the integrity of the samples

collected provide representative samples of the media being evaluated and be compatible with

planned laboratory analysis

Sample Plan

The objective of sampling is to àbtain information that provides qualitative and quantitative mess

ure of site conditions so that appropriate action can be taken relative to project goals These goals

encompass areas such as

preliminary site investigation

emergency cleanup operations

remedial response operations

backup for litigation purposes

monitoring

research or technology transfer

It is important therefore that the sampling effort be preceded by well-planned custom-tailored

sampling plan for each project This will help ensure that goals are met that sampling is completed

in timely cost effective manner safety of sampling personnel is maximized samples are represen

tative of the site sampling errors are reduced and integrity of the sample is preserved during and

after sampling

The sampling plan should address the definition of objectives selection of representative

sampling sites collection of sufficient volumes of material selection and preparation of

proper sample containers preservation of sample integrity identification of samples

proper sample holding times safe handling and transportation procedures and standard

chain-of-custody procedures

The following steps are essential in preparation of the sampling plan

Research background information on the site and samples evaluate the site history review

any data available from prior sampling excursions review available geotechnical data

consider the materials to be sampled composition form expected concentrations etcdetermine what analyses will best address the issues at the site

13

EPA 04822

Determine safety requirements and arrange for equipment and procedural needs for safe

sampling

Consider proper locations for sampling

Determine the sample volume required for each location with special considerations given to

the type of sample container and preservative needed for each analyte Analytes with the

same container/preservative requirement may be able to be combined into one large container

e.g rather than three 250 mL bottles Allow sufficient volume for field and laboratory

QC samples

Determine the sampling equipment needed and arrange to have the necessary facilities and

supplies for proper decontaminationbetween samples

Review procedures for sample collection and plan training or refresher courses for samplers

Review procedures for containing and handling samples

Properly execute chain-of-custody procedures beginning with bottle preparation

Identify necessary packaging labeling and shipping requirements including the following

Identify samples and protect from tampering secure evidence tape if available

Record all sample information in bound field notebook

Fill out the chain-of-custody sample analysis request form

10 Deliver or ship the samples to the laboratory for analysis

11 Consider analyte holding times when determining shipping frequency Many laboratorycontractual agreements measure holding times from the date of receipt at the laboratory

while regulatory holding times are measured from the date of sample collection

14

EP 04823

Sample Containers

All containers provided by lEA will be obtained from 1-Chem Hayward California or be of equiva

lent quality 1-Chem is the bottle contractor to the U.S EPA-Contract Laboratoiy Programs These

containers are cleaned by 1-Chem in accordance with U.S EPA protocols

All sample containers provided by lEA will be shipped with chain-of-custody sheets These chain-

of-custody sheets will be completed by the field sampling personnel and returned with the samples

Sample Preservation and Holding Times

The required preservation methods and holding times will be in accordance with those given in SW-

846 Test Methods for Evaluation of Solid Waste Third Edition November 1986 or EPA Methods

for Chemical Analysis of Water and Wastes March 1983 see Table 7-1 and 7-2 The holding

times for all required analyses are measured from sample collection

15 04824

Table 7-1 SW846

RFJIRED arAnS PRESERVATI ThiNIQUES 11LDIN TIMES

Nne Container1 Preservation Ibxinuu bolding time

Bacterial Tests

ODliforru fecal and total Cool 4C O.CX8% Na2S01bours

Fecal streptococci Cool 4C O.X8Z Na2çCç bours

Inorganic Tests

idity Cool 4C 14 days

Alkalinity Cool 4C 14 days

imxxia Cool 4C R24 tO ç2 28 days

Biocknical oxygen dend Cool 4C 48 bours

anlde ne required 28 days

Biocliical oxen denand Cool 4C 48 txurs

carbonaceous

Qnical oxygen dnand Cool 4C 11804to pH2 28 days

Coloride require 28 days

Colorine total residual ie required Analyze 1mt1iately

Color Cool 4C 48 bours

Cyanide total and ainable Cool 4C NaCU to t12 14 days

to chlorination O.6g ascorbic acid

Fhxride Zbne required 28 days

Hardness 1Q to p112 112S04to p112 annths

Hydrogen ion pH Fbne required Analyze fmnMfately

Kjeldahl xI organic P1 Cool 4CH2S04

to p112 28 days

nitrogen

talsQiruniun VI Cool 4C 24 ursfero.zry to p112 28 days

ttals except chraniun VI to p112 ithsand meriryNitrate Cool 4C 48 bours

Nitrate-nitrite Cool 4CR2S04

to p112 28 days

Nitrite Cool 4C 48 bours

Oi1igrease Cool4CHSO4topH2 28days

gic carbon Cool 4C FEI orF1804

to 28 days

Ortbopbosphate Filter iuiiately cool 4C 48 Fours

Ccygen Dissolved Probe Battle and top ne required Analyze rmwliately

Winkler do Fix on site and store in dark l-xirs

1tnols only Cool 4CR2S04

to p112 28 days

PFospborus eleiental Cool 4C 48 Fours

FtospForus total Cool 4C R2S04to p112 28 days

Residue total Cool 4C days

Residue Filterable Cool 4C days

Residue Fbrifilterable TSS Cool 4C days

Residue Settleable Cool 4C 48 Fours

Residue volatile Cool 4C days

Stlica Cool 4C 28 days

Sjecific conductance Cool 4C 28 days

Revision

Date Septernber 1986

16

EPA 04825

Table 7-1 ContREXJIR NEDS PtVAIIaJ 1mNIcES ND HJiDfl l1ES rIMJ

Nane Cocwainer Preservation MaxixTzzn Folding tl

.ilfate

Sulfide

Sulfite

Lrfactants

1içerature

Dirbidity

Organic Tests

Purgeable Halocarbons

Reools

Benzldincs

Rthalate esters

NLtrosanirs

Es acrylonitrile

Nitroaracjc.s arilsolblyrixlear araatic

hydrocarbons

Ibloethers

aiI.orinatari hydrocarbons

Ibtal organic halogens

Pesticides TestsPesticides

Radiological Tests

ALpha beta aii rafiun

Teflon-UzI

sepTeflon-lined

sepznTeflon-lirl

sepbTeflon-lined cap

Teflon-lined

Teflon-li.i

Teflon-lined cap

Teflon-lined capTeflcn-l.ixi cap

Teflon-lined cap

Teflon-lined cap

Teflon-Ur1 cap

Teflon-liri cap

Teflon-liri cap

Cool 4CCool 4C aId zinc acetate

plus sod jun hydroxide to pff9

Nne required

Cool 4CNonc rredCooL 4C

CooL 4C 0.W8ZNa2S203

Cool 4C 0.08ZNa2S203

Wi to pH2

Cool 4C 0.W8ZNa2S203

Mjust pH to 45Cool 4C 0.008X

Na2S203

cap Cool 4C 0.00Na2S203

cap Cool 4C

CooL 4C store in dark0.X8Z

Na2S203CooLCooL 4C 0.X8Z

Na2S203store in dark

Cool 4CNa2S203

store In dark

Cool 4CO.X8ZNa2S203

Cool 4CCool 4C 0.C08Z Na

CooL 4C 112504tO

28days

7days

Analyze iflEdiately48FjrsAnalyze

48Fours

14 .days

l4days

14 days

days mtil extraction40 days after extraction

days until extraction

days until extraction

40 days after extraction





40 days after extracti40 days after extraction


7days


mxiths

1Polyethyleoe P.or Class

17

RevisionDate September 1986

Purgeable arnatic

hydrocarbons

crolein aix acrybonitrile

TefLon-Liri cap Cool 4C pH 59

l03 to pH2

EPA 04826

Tible 71 ContRECOMMENDED SAMPLE CONTAINERS PRESERVATION TECHNIQUES AND HOLDING TIMES

parter Container Presetvative IbI.dlng Time

Volatile Organ.ics

Qxcentrated Waste Sanples 8-oz widenuth 14 days

glass with Teflon

liner

Liquid Samples

N3 Residual thiorine

Present 40-inL vials with drops ic MCI Cool 4C 14 days

Teflon lined septun

caps

Residual thlorine

Present 40-mL vials with Collect sauple in oz soil 14 days

Teflon lined septun container which has been

caps prepreserved with drops of

10% s1un thiosulfate Gently

mix sauple aid transfer to

40-mi vial that has been

pre-preserved with drops

conc HC1 Cool to 4C

Acrolein axi

Acrylonitrile 60-mL vials with Mjust to pH 45 Cool 4C 14 days

Teflon lined septun

caps

Soi1/SM1rrnts aid Sledges 4-oz 120-mi widuth Cool 4C 14 days

glass with Teflon liner

Revision

Date September 1986

18

EP 04827

Table 7-1 Cont

Paraiter Container Preservative Ibidlng Tine

Senivolatile Organics

Qxcentrat1 Waste Sauples 8-oz widetxuth IL 14 days

glass with Teflon

ii.ner

Liquid Sanples

Residual thlorine

Present 1gal or 1/2gal Cool 4C Sasples must beaber glass with Teflon extracted withliner

in7daysandextracts analyzi within

AOdays

Residual thlorine

Present 1gal or 1/2gal kId niL 10% sodiun Sanples must beaiiber glass with Teflon thiosulfate per extracted with-liner gallon Cool 4C in days and

extracts analyzed within

4Odays

Soil/Sedhinr.s SlxIges 8oz widuth glass Cool 4C 14 dayswith Teflon liner

Copied frorn SW-846 Test Methods For RevisionEvaluation of Solid Waste Third Date pçember 1986Edition November 1986

19

EPA 04828

Table 72 .EPA600/479020

RECOMMENDATION FOR SAMPLING AND PRESERVATIONOF SAMPLES ACCORDING TO MEASUREMENT

Vol

Req HoldingMeasurement ml Container2 Preservative3 Time5

100 Physical Properties

Color 50 PG Cool 4C 48 I-Irs

Conductance 100 PG Cool 4C 28 Days

Hardness 100 PG HNO3 to pH Mos

Odor 200 only Cool 4C 24 Hrs

pH 25 PG None ReqIi inediiu lv

Residue

Filterable 100 PG Cool 4C Days

Non-

Filterable 100 PG Cool 4C Days

Total 100 P.O Cool 4C Days

Volatile 100 PG Cool 4C Days

Settleable Matter 1000 PG Cool 4C 48 Hi-s

Temperature 1000 PG None Req AualyLelniintliatclv

Turbidity 100 PG Cool 4C 18 Hrs

200 Metals

Dissolved 200 PG Filter on site MosHNO3 to p1-12

Suspended 200 Filter on Site Mos.8

Total 100 PG HNO3 to pH.2 Mos

20

EP 04829

Table 7-2 Cant

Vol

Req Holding

Measurement ml Container2 Preservative34 Time5

Chromium46 200 P.c Cool 4C 24 Hrs

MercuryDissolved 100 PG Filter 28 Days

HNO3topH2

Total 100 PG HNO3 to pH.2 28 Days

300 Inorganics Non-Metallics

Acidity 100 P.G Cool 4C 14 Days

Alkalinity 100 PG Cool 4C 14 Days

Bromide 100 P.G NoneRcq 28Days

Chloride 50 PG None Req 28 Days

Chlorine 200 PG None Req Analyze

Immediately

Cyanides 500 PG Cool 4C 14 Days1NaOH to p1-I 12O.6g ascorbic acid6

Fluoride 300 PG None Req 28 Days

Iodide 100 PG Cool 4C 24 Hrs

Nitrogen

Ammonia 400 P.O Cool4C 28 Days

H2S04 to pH

Kjeldahl Total 500 P.O Cool 4C 28 Days

H2S04 to pH

Nitrate plus Nitrite 100 PG Cool 4C 28 Days

1-ISO4 to pH

Nitrate9 100 PG Cool 4C 48 Hrs

Nitrite 50 P.O Cool 4C 48 Hrs

EPA 04830

Table 72 Cont

Vol

Req Holding

Measurement ml Container2 Preservative34 Time5

Dissolved Oxygenlrohe 300 loti Ic and top None Req Analyze

mrnediatelv

Winkler 300 bottle and top Fix on site Hours

anl StoI

Phosphorus in dark

Ortho

phosphate 50 PG Filter on site 48 HrsDissolved Cool 4C

Hydrolyzable 50 P.O Cool 4C 28 Days

H2S04 to pH

Total 50 P.O Cool 4C 28 Days

H2S04 to pH

Total 50 P.O Filter on site 24 HrsDissolved Cool 4C

H2S04 to pH2

Silica 50 only Cool 4C 28 Days

Sulfate 50 PG Cool 4C 28 Days

Sulfide 500 PG Cool 4C Daysadd ml zinc

acetate plus NaOHtopH9

Sulfite 50 PG None Req Analyze

Immediately400 Organics

BOD 1000 PG Cool 4C 48 Hrs

COD 50 P.O ool 4C 28 Days

H2S04 to pH

Oil Grease 1000 only Cool 4C 28 lays

1-12S04 to pH

Organic carbon 25 P.O Cool 4C 28 Days

H2SO4 or HCI to pH

Phenolics 500 only Cool 4C 28 Days

H2SO4to pH

22

EP1 04831

Table 72 Cont

Vol

Req Holding

Measurement ml Containcr2 Preservative34 Time5

MBAS 250 PG Cool 4C 48 Hrs

NTA 50 P.O Cool 4C 24 Hrs

More specific instructions for preservation and sampling are found with each procedure as

detailed in this manuaL general discussion on sampling water and industrial wastewater maybe found in ASTM Part 31 7282 1976 Method D-3370

Plastic or Glass For metals polyethylene with polypropylene cap no liner is

preferred

Sample preservation should he performed immediately upon sample collection For

composite samples each aliquot should be preserved at the time of collection When use of

an automated sampler makes it impossible to preserve each aliquot then samples may be

Irservl by maintaining at 4C until compositing and sample splitting is completed

Iwo any sample is to be shipped by common carrier or sent through the United States

Mails it must comply with the Department of Transportation Hazardous Materials

Regulations 49 CFR Part 172 The person offering such material for transportation is

responsible for ensuring such compliance For the preservation requirements of Tablethe Office of Hazardous Materials Materials Transportation Bureau Department of

Transportation has determined that the Hazardous Materials Regulations do not apply to

the following materials Hydrochloric acidHCI in water solutions at concentrations of

0.04% by weight orlesspH about 1.96 or greater NitricacidHNO3 in water solutions at

concentrations of 0.15% by weight or less pH about 1.62 or greater SulfuricacidH2S04in water solutions at concentrations of 0.35% by weight or less pH about 1.15 or greaterSodium hydroxide NaOH in water solutions at concentrations of 0.080% by weight or

less pH about 12.30 or less

Samples should be analyzed as soon as possible after collection The times listed are the

maximum times that samples may be held before analysis and still considered valid

Samples may he held for longer periods only if the permittee or monitoring laboratory

has data on file to show that the specific types of sample under study are stable for the

longer time and has received variance from the Regional Administrator Some samplesmay not be stible for the maximum mine period given in the table penn tiec or

monitoring laboratory is obligated to hold the sample for shorter time if knowledgrexists to show this is necessary to maintain sample stability

Should only be used in the presence of residual chlorine

23

EPA 04832

Table 7-2 Cont

Maximum huklitig line is 24 hours when sulfideis present Optionally all samples marbe tested with leal acetate IxIlr before the p11 adjustment in order to determine if sulfide

is present If sulfide is present it can be removed by the addition of cadmium nitrate

powder until negative spot test is oltained The sample is fil tereci nd then NaOH is

lllel to pH 12

Samples should he filtered immeliately onsite before adding prcseraive for dissolved

IntillS

lor samples Front nonchlorinated drinking water supplies conc HSO4 should be added

to lower satnitle p1 to less than rhc sample should be analyzed before 14 days

Copied from EPA-600/4-79-020 Methods for Chemical Analysisof Water and Wastes March 1983

24

EPA 04833

CHAIN-OF- CUSTODY

The purpose of chain-of-custody procedures is to document the history of samples from time

of sample collection through shipment to the laboratory An item is considered to be in ones cus

tody if

It is in the physical possession of the responsible party

It is in the view of the responsible party

It is secured by the responsible party to prevent tampering

It is secured by the responsible party in restricted area

When sample containers are provided by lEA chain-of-custody documents see Figure 8-1 will be

shipped with the sample containers These forms will be completed by field personnel

25

EPA 04834

INDUSTRIAL

AND

ENVIRONMENTAL ANALYSTSCustody TransferRecord

Lab Work Request

149 Rangeway Road North Billerica

MA 01862 Phone

617

272 5212

Client_________________________

Project

ID ___________Address

________________________ P.O

Number__________

_________________________Contact Person

Phone Date Collected

Fax

508

667 7871 LJ

Date_____________

Turnaround_____________

lEA

Job Number

Page_

of

lEAuse

OnlY

LahiD

Sample

ID E-

E-

zo

Analyses_Requested

Comments

Custody Record Signature Required Remarks

Relinquished

By Date Time Received

By Date Time

A_

RECEIPT AND HANDLING OF SAMPLES

When samples first arrive at the laboratory they are examined with regard to their overall condition

The labels are verified with the attached documents Accompanying chain of custody records are

signed dated and copied Each batch of samples is entered into the log-in-database and receives

unique job number At this time job record sheet is started and individual sample containers are

assigned unique numbers based on decimal extensions of the batch job number status sheet for

each job describing the required analyses is prepared This sheet is cued on bulletin board to allow

the analytical staff to plan their work accordingly The paperwork generated in the course of completing the analyses for given batch chromatographic output computer generated data reduction

etc is centrally located in convenient file Rush work is clearly marked with red tag in the upper

right corner The samples are taken to the lab area where they are stored appropriately

formal written purchase order is desireable at the time of sample receipt Clients are encouraged

to submit samples accompanied by purchase order purchase order number or written authorization

to perform the services Clients are notified that analytical results may not be released until such

authorization has been secured

Samples are usually retained for two months after completion of the work unless other arrangements

are specified by the client Samples that are legal evidenc are retained indefinitely

Any samples that contain hazardous materials are disposed of properly

Samples will be maintained in storage in one of the storage refrigerators prior to sample preparation

and analysis The standard operating procedures for sample storage are described in detail in lEA

SOPs summary of these procedures follows

Storage refrigerators are maintained at 2C The temperature is monitored by sample custo

dian and recorded in log Refrigerator storage is designed to segregate samples prevent cross-

contamination and prevent sample mix up This includes storage of volatiles samples separate from

semivolatiles and inorganic samples Within the refrigerators samples are stored by batch number

for easy retrieval

Samples received for analysis in organics are in some cases subject to extraction or desorption

Extraction and desorption events are recorded in laboratory log designed for this purpose see

Figures 9-123 or in laboratory notebook Samples received for analysis in inorganics are in

some cases subject to digestion or filtration Details of these activities are recorded in laboratory

notebooks

Analysts are required to maintain up-to-date laboratory notebooks and QC records which are ready

for audit at any time Corrections to entries are made by drawing single line through the erroneous

entry and writing the correct entry adjacent to the one crossed out All corrections are initialed and

dated by the analyst

27

EPA 04836

txj

cc

INDUSTRIAL

AND ENVIRONMENTAL ANALYTICAL

Air Sample Desorbate

Log

page

lEA

ID

Client

ID

Desorb

Date Analyst

Sorbent

Type

Desorbing DesorbingSolvent Volume

Desorbing

Periodmin

Desorbing

agitation

Conditions

ultrasonication

etc Comments

INDUSTRIAL

AND ENVIRONMENTAL ANALYTICAL

PesticidesPCBs Extraction

Log

page

Client Extr Extract Sainp Extract Wt/Vol Solid Extr Spike Conc Conc Final Final

lEA

ID ID Date Analyst Type Method Samp

p11

Sol IDNoI Date Analyst

Vol

Sol

MS

MSD

LIIii

INDUSTRIAL AND ENVIRONMENTAL ANALYSTS

Scinivolatile Organics Extraction

Log

page

Client Extr Extract Sainp Extract WE/Vol Solid/ Extr Spike Conc Conc FinalNoteslE

A

ID ID Date Analyst Type Method Samp

p11

Sol IDNoI Date Analyst

Vol

MS

MSD

Building Security

lEA maintains controlled building access at all times During working hours all non-TEA personnel

are required to sign in with the receptionist and are escorted by laboratory personnel while in the

building

The laboratory is locked between the hours of 530 p.m and 800 a.m Monday through Friday and

during the weekend The building is secured during non-working hours by an electronic security

system

The building as accessed by laboratory employees during non-working hours by using key and the

passcode for the Building Security System

Any breach of security during non-working hours releases an alarm to security agency who alert

the local law enforcement agency and one of two laboratory personnel

31

EPA 04840

10 ANALYTICAL PROCEDURES

Routine analytical services are performed using standard EPA or NIOSH-approved methodology In

some cases modification of standard methods may be necessary to provide accurate analyses of particularly complex matrices When modification of standard methods are performed the specific al

terations as well as the reason for the change will be reported with the results of analysis Choice

of method is determined by the type of samples and the client/agency program represented These

programs include but are not limited to the following

Drinking Water

Waste Water

Hazardous Waste

Air

For non-routine analytical services e.g special matrices research projects non-routine compoundlists etc the method of choice is selected based on client needs and available technology

The laboratoiys reported method detection limits MDLS are based on program requirements

sample matrix and in-house instrument capabilities These MDLs may be higher than published

method detection limits However published MDLs are generally determined using clean matrices

which are free of interferences such as deionized water and which are analyzed under optimal

laboratory conditions For actual sample analysis these MDLs may not be routinely achievable

Procedures in place to demonstrate that reported detection limits are obtainable are described in the

ensuing subsections of this section

Individual sample detection limits may vary from the laboratorys routinely reported detection limits

This may be due to dilution requirements variability in sample weight or volume used to performthe analysis dry weight adjustment for solid samples the presence of analytical background contaminants or other sample-related or analysis-related conditions

Gas ChromatographvlMass Spectrometrv GCfMS

GCIivIS Tuning and 1\Iass Calibration

Once an instrument has been tuned initial calibration curves for analytes appropriate to the analyses

to be performed are generated for at least four solutions containing known concentrations of authen

tic standards of compounds of concern Mass spectrometers are calibrated with perfluorotributylam

me as required to ensure correct mass assignment and relative peak heights In addition once per

day these instruments are tuned with decafluorotriphenylphosphine DFTPP for semivolatiles analysis and 4-bromofluorobenzene BFB for volatiles analysis Ion abundances will be within the

windows dictated by the specific program requirements

32EPA 04841

GCMS Initial Calibration

These solutions are generally cocktails of the method target analytes The calibration curves will

bracket the anticipated working range of the analysis Linearity is verified by evaluating the re

sponse factors RF for the initial calibration standards For an acceptable calibration the relative

standard deviation of the specified Calibration Check Compounds CCCswill be 30 percent In

addition minimum average RF of 0.050 must be demonstrated for specified System Performance

Check Compounds SPCCs These specified CCCs and SPCCs for routine volatile and semivola

tile organics analysis are listed in Table 10-1 Calibration data to include linearity verification will

be maintained in the laboratorys permanent records of instrument calibrations

GCIMS Continuing Calibration

During each 12-hour operating shift daily midpoint calibration standard is analyzed to verify that

the instrument responses are still within the initial calibration determinations The response factor

for each target compound in the daily standard is calculated and recorded then compared to the

average RF from the initial calibration If significant RF drift is observed for the CCCs 30%appropriate corrective actions will be taken to restore confidence in the intnimental measurements

In addition minimum RF of 0.050 must be reported for SPCCs

GCIMS Oualitv Control

All GCIMS analyses will include analysis of method blank and matrix spike matrix spike dupli

cate in each lot of twenty samples The matrix spike solutions will contain the compounds listed in

Table 4-2 and will be used for both matrix spikes and any blank spikes In addition appropriate sur

rogate compounds as specified in Table 4-1 will be spiked into each sample Recoveries from

method spikes and surrogate compounds are calculated and recorded on control charts to maintain

history of system performance

Audit samples will be analyzed periodically to compare and verify laboratory performance against

standards prepared by outside sources

GCMS Detection Limits

The laboratorys quantitation limits routinely used for reporting GCIMS data are compared with

laboratory-determined instrument detection limits to ensure that the reported values are attainable

Instrument detection limits are determined from at least three analyses of target compounds measured at three to five times the reporting limit The calculated instrument detection limit is three

times the standard deviation of the measured values

Ep4z04842

Votatiles

TABLE 10-1

GC1MS CALIBRATION CHECK COMPOUNDS CCCsAND SYSTEM PERFORMANCE CHECK COMPOUrflS SPCC

Semivolatiles

chioromethane

vinyl chloride

11-dichioroethene

11-dichioroethane

chloroform

2-dichloropro pane

bromoform

11 22-tetrachloroethane

toluene

chlorobenzene

ethylbenzene

calibration check compounds

system performance check compounds

phenol

4-dichlorobenzene

N-nitroso-di-N-propylamine

2-nitrophenol

24-dichiorophenol

hexachiorobutadjene

4-chloro-3-methylphenol

hexachiorocyclopentadiene

246-trichiorophenol

acenapbthene

24-dinitrophenol

4-nitrophenol

N-nitrosodiphenylamine

pentachiorophenol

fluoranthene

di-N-octylphthalate

benzo-a-pyrene

34EPA 04843

Gas Chromatovaphv CC

GC Initial Calibration

Once an instrument has been tuned initial calibration curves for analytes appropriate to the analyses

to be performed are generated for at least four solutions containing known concentrations of authen

tic standards of compounds of concern The working standards will include calibration blank and at

least four calibration standards covering the anticipated range of measurement At least one of

the calibration standards will be at or below the desired instrument quantitation limit The correla

tion coefficient of this calibration must be equal to or greater that 0.990 to consider the response

linear over range If correlation coefficient of 0.990 cannot be achieved additional standards

must be analyzed to define the calibration curve

GC Continuing Calibration

The response of the instrumentwill be verified for each analysis sequence by evaluation of mid

range calibration check standard In order to demonstrate that the initial calibration curve is still

valid the calibration check standard must be within 20% recovery of the initial calibration for the

compounds of interest or the instrument must be recalibrated For multi-analyte methods this check

standard may contain representative number of target analytes rather than the full list of target

compounds Optionally initial calibration can be performed at the beginning of the analysis se

quence

Within the analysis sequence instrument drift will be monitored by analysis of mid-range calibra

tion standard every 100 samples The difference in calibration factors CFs for the con

tinuing calibration standard compared to the average CF from the initial calibration will be calcu

lated and recorded If significant 20%calibration factor drift is observed for the compounds of

interest appropriate corrective actions will be taken to restore confidence in the instrumental measurements

CC Oualitv Control

At least one method blank and one matrix spike will be included for each 20 samples processed

The method blanks will be examined to determine if contamination is being introduced in the labora

torty

The matrix spikes will be examined to determine both precision and accuracy Accuracy will be

measured by the percent recovery of the spikes These recoveries will be plotted on control charts to

monitor method accuracy Precision will be measured by the reproducibility of duplicate method

spikes and will be calculated as relative percent difference RPD These RPDs will be plotted

on control charts to monitor method precision

In addition appropriate surrogate compounds as specified in Table 4-1 will be spiked into each

environmental sample These recoveries are also recorded on control charts to maintain history of

system performance

EPA 04844

GC Detection Limits

The Laboratorys quantitation limits routinely used for reporting GC pesticide data are compared

with laboratory determined instrument detection limits to ensure that the reporting values are attain

able Instrument detection limits aredetermined from the replicate analysis of target compounds

measured at three to five times the reporting limit The calculated instrument detection limit is three

times the standard deviation of the measured values For non-routine compounds the reported

detection limits will be limited by the lowest calibration standard analyzed for the respective

method

Graphite Furnace Atomic Absorption Spectrophotometrv GFAA

GFAA Initial Calibration

Atomic absorption spectrophototmeters will be calibrated prior to each sample batch Calibration

standards will be from appropriate reference materials and working calibration standards prepared

fresh daily Initial calibration will include analysis of calibration blank and minimum of three

calibration standards covering the anticipated range of measurement Duplicate injections will be

made for each concentration At least one of the calibration standards will be at or below the re

ported detection limit The calibration curve generated must have correlation coefficient equal to

or greater than 0.996 in order to consider the responses linear over range If the correlation coeffi

cient criteria of 0.996 are not met the instrument will be recalibrated prior to analysis of samples

Calibration data including the correlation coefficient will be entered into laboratory notebooks to

maintain permanent record of instrument calibration

GFAA Continuing Calibration

The initial calibration is verified during the analysis sequence by evaluation of continuing calibra

tion blank CCB and continuing calibration standard CCS after every ten 10 samples are ana

lyzed The response of the continuing calibration verification standard must be within 10% recov

ery of the true value The continuing calibration blank must be free of target analytes at and above

reporting detection limit

GFAA ualitv Control

At least one method blank and one method blank spike laboratory control sample LCS will be

included in each laboratory lot of samples Regardless of the matrix being processed the LCS and

blanks will be in aqueous media The LCS will be at concentration of approximately five times

the detection limit


tory and will be analyzed at frequency of one per analytical lot or five percent of the samples

whichever is more frequent The LCS will be examined to determine both precision and accuracy

Accuracy will be measured by the percent recovery of the spikes The recovery must be

within the range 80-120 percent to be considered acceptable with the exception of antimony and

36

EPA 04845

silver due to documented method deficiencies in achieving reliable recovery reference EPAsContract Laboratory Program Additionally the LCS will be plotted on control charts to

monitor method performance

Precision will be measured by the reproducibility of duplicate LCSs and will be calculated as rela

tive percent difference RPD Results must agree within twenty 20 percent RPD in order to be

considered acceptable The LCS RPD will be plotted in control charts to monitor performance

GFAA Detection Limits

The laboratorys routinely reported quantitation limits are compared with laboratory-determined Instrument Detection Limits JDLs to ensure that the reported values are attainable

Inductively Coupled Plasma ICP

ICP Initial Calibration

The inductively coupled argon plasma spectrophotometer will be calibrated prior to each samplebatch Calibration standards will be prepared from reliable reference materials The instrument will

be calibrated using minimum of standards and blank The calibration curve generated must

have correlation coefficient equal to or greater than 0.996 in order to consider the responses linear

over range If the correlation coefficient criteria of 0.996 are not met the instrument will be

recalibrated prior to analysis of samples

ICP Continuing Calibration

The initial calibration is verified during the analysis sequence by continuing calibration blank

CCB and continuing calibration standard CCS after every ten 10 samples are analyzed The

response of the continuing calibration verification standard must be within 10% recovery of the

true value The continuing calibration blank must be free of target analytes at and above the reported

detection limit

ICP Ouality Control

At least one method blank and one method blank spike laboratory control sample LCS will be

included in each laboratory lot of samples Regardless of the matrix being processed the LCSs and

blanks will be in aqueous media The LCS will be at concentration of approximately five times

the detection limit


tory

37 EPA 04846

The LCS results will be examined to determine both precision and accuracy Accuracy will be

measured by the percent recovery of the spikes The recoveiy must be within the range 80-

120 percent to be considered acceptable Additionally the the LCS %R will be plotted on control

charts to monitor method accuracy

Precision will be measured by the reproducibility of the LCSs and will be calculated as relative

percent difference RPD Results must agree within 20% RPD in order to be considered ac

ceptable

ICP Detection Limits

The laboratory routinely reported quantitation limits are compared with laboratory-determined In

strument Detection Limits IDLs to ensure that reported values are attainable

Cold Vapor Mercury Analysis Flameless AA CVAA

CVAA Initial Calibration

The initial calibration procedures are as described for GFAA Initial Calibration The correlation

coefficient of the standard curve must be equal to or greater than 0.996

CVAA Continuing Calibration

After every ten samples continuing calibration blank CCB and continuing calibration verification

standard CCS are analyzed The response of.the CCS must be within 20% recovery of the tnie

value The CCB must be free of target analyte at and above the reported detection limit

CVAA Ouality Control

At least on method blank and one method blank spike laboratory control sample LCS will be

included in each laboratory lot of samples Regardless of the matrix being processed the LCS and

blanks will be in aqueous media The LCS will be at concentraion of approximately five times

the detection limit


tory and will be analyzed at frequency of one per analytical lot or five percent of the samples

whichever is more frequent The LCS will be examined to determine both precision and accuracy

Accuracy will be measured by the percent recovery of the spikes The recovery must be

within the range 80-120 percent to be considered acceptable Additionally the LCS will be

plotted on control charts to monitor method performance

Precision will be measured by the reproducibility of the LCSs and will be caluculated as relative

percent defference RPD Results must agree within 20% RPD in order to be considered

acceptable The LCS RPD will be plotted on control charts to monitor performance

38 EPA 04847

CVAA Detection Limits

The laboratorys routinely reported quantitation limits are compared with laboratory-determined In

strument Detection Limits IDLs to ensure that the reported values are attainable

Spectrophotometrv Colorimetnc Methods

Spectrophotometrv Initial Calibration

Spectrophotometers will be calibrated prior to use The calibration standards will be prepared from

reference materials appropriate to the analyses being performed and working standards will include

minimum of four concentrations which cover the anticipated range of measurement At least one

of the calibration standards will be at or below the desired detection limit Additionally calibra

tion blank will be analyzed The requirement for an acceptable initial calibration will be correla

tion coeffecient criteria of 0.996 or greater in order to consider the response linear over the measured

range If the correlation coefficient criteria of 0.996 is not met the instrument will be recalibrated

prior to analysis of samples Calibration data to include the correlation coefficient will be entered

into laboratoiy notebook with the sample data to maintain permanent record of instrument cali

brations

Before sample analysis an initial calibration verification standard is analyzed The response calcu

lated as percent recovery of this standard must be within 15% of the true value or the instrument is

recalibrated

Spectrophotometers Continuing Calibration

continuing calibration standard CCS and blank CCB will be analyzed at frequency of 10%The response calculated as percent recovery of the true value must be 15% of the true value

The response of the blank must be less than the detection limit.

Spectrophotometers Oualitv Control

At least one method blank and one method spike will be included in each laboratoiy lot of samples

Regardless of the matrixbeing processed the method spikes and blanks will be in aqueous media

Method spikes will be at concentration of approximately five times the detection limits The

method blanks will be examined to determine if contamination is being introduced in the laboratorty

The method spikes will be examined to determine both precision and accuracy

Accuracy will be measured by the percent recovery of the spikes The recovery must be in the

range 80-120 percent in order to be considered acceptable Additionally will be plotted on

control charts to monitor method accuracy

Precision will be measured by the reproducibility of method spikes and will be calculated as relative

percent difference RPD Results must agree within twenty percent in order to be considered

acceptable

-39EPA 04848

Spectrophotometers Detection Limits

The detection limits are based on the concentration of the lowest standard analyzed Results below

the lowest standard are reported as below the quantitation limit

Balances

Laboratory balances will be calibrated and serviced annually by qualified engineer In addition an

analyst will verify the balance calibratins with NIST traceable Class weights on days when the

balance is used record of calibrations and checks will be kept in the balance log

EPA 04849

11 DATA REDUCTION AND REPORTING

Data Reduction

Data reduction is performed or monitored by the individual analysts and consists of calculating concentrations in samples from the raw data obtained from the measuring instruments The complexity

of the data reduction will be dependent on the specific analytical method and the number of discrete

operations extractions dilutions and concentrations involved in obtaining sample that can be

measured

For those methods utilizing calibration curve sample response will be applied to the linear regression line to obtain an initial raw result which is then factored into equations to obtain the estimate of

the concentration in the original sample Rounding will not be performed until after the final result

is obtained to minimize rounding errors and results will normally be expressed in three significant

figures

Copies of all raw data and the calculations used to generate the final results will be retained on file to

allow reconstruction of the data reduction process at later date

Reporting Results

The primaiy responsibility for the completeness and accuracy of all results and documents

rests with the chief chemists At the conclusion of the analytical work chief chemist in conjunc

tion with the persons assigned to perform the analyses will reconcile all documents In particular

he/she will veril the sample IDs the analyses requested by the client and the test results The

results will be reviewed and verified for accuracy The final report is then prepared for typing At

this time the billing information is completed and verified The chief chemists will sign or authorize

employees to sign all reports Another technical staff member rechecks each final report and co

signs it with their initials

All records are the property of Industrial and Environmental Analysts Inc and are consid

ered proprietary and confidential Disclosure of information to third parties will be made only on

request of the original client or by order of court of law

Records are kept in active files for one year and are then moved to permanent storage

inactive files

41EPA 04850

12 INTERNAL-QUALITY CONTROL CHECKS

The quality of analytical data generated by lEA is controlled by the implementation of this Analyti

cal Laboratoiy Quality Management Plan The types of internal quality control checks are described

in this section

Method Blanks Method blanks usually consist of laboratory reagent grade water treated in

the same manner as the sample i.e digested extracted distilledetc which is then ana

lyzed and reported as standard sample would be

Method Blank Spike method blank spike is sample of laboratory reagent water forti

fied spiked with the analytes of interest which is prepared and analyzed with the associated

sample batch Method blank spikes are not included with volatiles analysis since the same

function is served by the calibration standard analysis

Laboratory Control Sample for Inorganics This is standard solution with certified

concentration which is analyzed as diluted sample and is used to monitor analytical accu

racy Equivalent to method blank spike

Matrix Spikes matrix spike is an aliquot of an investigative sample which is fortified

spiked with the analytes of interest and analyzed with an associated sample batch to monitor the effects of the investigative sample matrix matrix effects on the analytical results

Laboratory Duplicate Samples Duplicate samples are obtained by splitting field sampleinto two aliquots and performing two separate analyses on the aliquots The analysis of

laboratory duplicates monitors method precision however it may be affected by sample

inhomgeneity particularly in the case of nonaqucous samples Laboratory duplicates are performed only in association with selected protocols and at the clients request

Known OC Check Sample This is QC sample of known concentration obtained from the

U.S EPA NIST NIOSH or commercial source

42EPA 04851

13 EXTERNAL QUALITY CONTROL PROGRAMS

lEA participates in several external audits sponsored by the U.S EPA NIOSH and the U.S Army

Corps of Engineers These audits include performance and system audits

The performance audits are in the form of performance samples submitted by the auditing agency

System audits involve on-site evaluation of the FAL laboratory system

The chemistry laboratory participates in the following performance audits

EPA Water Pollution

EPA Water Supply

NIOSH AIHAU.S Army Corps of Engineers

WP Series Semi-AnnualWS Series Semi-AnnualPAT Rounds Quarterly

DERA as required

43

EPA 04852

14 CHEMISTRY CERTIFICATIONS

EPA DEP Environmental Protection Agency Massachusetts Department of Environmental

Protection

AIHA American Industrial Hygiene Association

U.S Army Corps of Engineers Contract Specific

EPA 04853

e/aiment iinmen/aj luai zthzeeinj2aulence /zeilmenl 9aIon

S7 i/ha i4ccA 4ee 1a4ace4ut4 th84J

CERTIFICATION FOR ENVIRONHENTAL ANALYSIS

LABORATORY MAO 38

Eastern Analytical Labs149 Rangeway Road

B1J.lerica .MA 018b2

DATE 01/01/91

EXPIRATION DATE 12/31/91

DIRECTOR Michael Wheeler5082725212

PRIMARY CATEGORIES DRINKING WATERS

FULL CERTIFICATION Trace Metals Nitrate Fluoride Pesticides TrihalomethanesVolatile Organics 5DB DBCP Corrosivity Series Sulfate

PROVISIONAL CERTIFICATION A/p Sodium

SECONDARY CATEGORIES OTHER MATRICES

FULL CERTIFICATION Metals Minerals PCUs Pesticides Volatile Halocarbons Volatile

Aromatics Oil Grease

PROVISIONAL CERTIFICATION Nutrients

This certificate supercedes all previous certificates issued to this laboratoryReporting ot analyses other than those authorized above shall be cause for revocation ofcertification

Original Certificate riot copies must be displayed in prominent place at all timesCertification subject to approval by OGC

èiLT1Delaney Ph.D Direc

ivision of Environmental An4ysisNCWIS

15 EPA 04854

AMERICANINDUSTRIALHYGIENEASSOCIATION

cPLthiS

aV4b iCCcrwc1

has fulfilled AIHA criteria for

Industrial Hygiene Laboratory Accreditation

since Sprimher 1g7This accreditation shall be effective until

the 1st dayof September 1990

subject to continued compliance with

AIHA accreditation criteria

dlqChairman Presi ant

ttioryAccreditation American lndusuial HygieneCommittee Association

___________________ November 23 1987Accreditation Number Date

46EPA 04855

15 INSTRUMENT MAINTENANCE

The ability to generate valid analytical data requires that all analytical instrumentation be properly

and regularly maintained The analytical staff at lEA is responsible for implementing routine main

tenance and minor repairs Major repairs are performed by the service staff of given instruments

manufacturer When necessary to satisfy holding time requirements these repairs are upgraded to

rush status

Each analytical instrument has an instrument log book where all maintenance activities are recorded

If service is performed by the manufactures copy of the service record is placed in the log book

Most equipment is serviced on an as needed basis The balances are serviced and calibrated annu

ally

47EPA 04856

16 CORRECTIVE ACTION

The initial responsibility to monitor the quality of an analytical system lies with the analyst In this

pursuit the analyst will verify that all quality control procedures are followed and results of analysisof quality control samples are within acceptance criteria This requires that the analyst assess the

correctness of all of the following items as appropriate

sample preparation procedure

initial calibration

calibration verification

method blank result

duplicate analysis

laboratoiy control standard

fortified sample result

If the assessment reveals that any of the QC acceptance criteria are not met the analyst must immediately assess the analytical system to correct the problem The analyst notifies the appropriate

supervisor of the problem and if possible identifies potential causes and corrective action

The nature of the corrective action obviously depends on the nature of the problem For example if

continuing calibration verification is determined to be out of control the corrective action mayrequire recalibration of the analytical system and reanalysis of all samples since the last acceptable

continuing calibration standard

When the appropriate corrective action measures have been defined and the analytical system is

determined to be in control the analyst documents the problem and the corrective action

Data generated with an out-of-control system will be evaluated for usability in light of the nature of

the the deficiency If the deficiency does not impair the usability of the results date will be reported

and the deficiency noted Where sample results are impaired the chief chemist is notified and appropriate corrective action e.g reanalysis is taken

48 EPA 04857

17 APPENDIX

Resumes of chemistry laboratory personnel

EPA 04858

MICHAEL WHEELER

EDUCATION University of Maiyland B.S Chemistiy 1974Cornell University M.S Chemistiy 1977Cornell University Ph Inorganic Chemistiy 1981Varian NIvIR Short Course 1984

HONORS AND HONOR SOCIEIThS

American Chemical Society Achievement Award 1973American Institute of Chemists Award 1974Phi Kappa Phi

Noxell Foundation Scholarship 1973-74Graduation with High Honors of MDGraduate Research Assistantship 1979-80

TEACHING EXPERIENCE

Assistant Professor Houghton College 1979-84

Houghton NYAssociate Professor Houghton College 1984-1985Assistant Professor Kearney State College 1985-86

Kearney NE

Planning and execution of analytical chemistiy courses qualitative and instrumental analy

sis Duties included lab selection and development ordering lab supplies supervising

undergraduate lab assistants and instrument maintenance and minor repair GC HPLCfurnace and flame AA UVIVIS IR NMIR MS electroanalytical instrumentation Organi

zation of career and research oriented seminars Direction of undergraduate research projects

INDUSTRIAL EXPERIENCE

Staff Scientist Industrial and Environmental Analysts Inc 1986-Present

Billerica MA

Manager of Organic Chemistiy Section Responsible for training and supervision of

employees in GC GCIMS and Industrial Hygiene organics areas Duties include

scheduling client interfacing problem-solving assessment of data quality Development ofnew market opportunities Participate in field sampling programs Maintenance of data

quality and laboratoiy certifications

EP Q485950

ROBERT PEARY JR

EMPLOYMENT HISTORY

August 1985 to Present CHEMIST Industrial and Environmental Analysts Inc

BillericaMA

Manager of Inorganic chemistry sectin responsible for the chemical analysis of air soil

water wastewater and wide variety of organic and inorganic materials Hands-on experi

ence in AA ICP D.C Plasma G.C FTIR HPLC UV VIS Spectrophotometers

June 1984 to July 1985 CHEMICAL RESEARCH LAB SUPERVISOR Crystal Diagnostic

Systems Inc Wobum MA

was part of small research staff of start-up company which was developing Personal

Environmental Monitoring Device for the detection of formaldehyde This involved the

testing of many materials and reagents to finalize the badge configuration was responsible

for overseeing many of the day-to-day operations of the lab Hands-on experience in spec

trophotometer G.C and Custom Build Formaldehyde Generator and Testing System

October 1983 to June 1984 CHEMIST Thorstensen Laboratory Westford MA

Analysis of water and waste-water for organic and inorganic compounds by both instru

mental and wet methods Hands-on experience in Atomic Absorption G.C Spectro-

photometry

September 1982 to August 1983 W.O.W Ambassador Outreach Program State College PA

Participated in special one year program that involved overseeing Biblical research fellow

ships and classes in the Penn State area

Worked part time at Mariotts Printing assisting with the work at the print shop and doing

maintenance

September 1980 to August 1982 CHEMIST Morse Laboratories Inc Sacramento CA

was responsible for overseeing the inorganic department and had two technicians whoassisted me with the work Complete physical chemical and mineral analysis of water

Inorganic analysis of food products crops soil feeds fertilizers and other agricultural

materials Testing of concrete gasoline fuels ores metals construction materials etc

Hands-on experience in AA radioactivity counter visible and IR spectrophotometers Parr

bomb Fluorometer pH conductivity and turbidity meters viscosity and flash point apparatus

AB6051

ROBERT PEARY JR cont

July 1975 to September 1980 CHEMIST LUVAK Inc Boylston MA

Originally was the only full-time chemist and was responsible for the wet chemical work

instrumental analyses Over period of time trained four additional chemists who were

added to handle the increasing work load The majority of the work was the analysis of

metals and alloys for both major and trace elements including-N and This was done

by wet methods AA and D.C Plasma emission spectrometry also did inorganic analysis

of water and various other organic and inorganic materials Hands-on experience in AAD.C Plasma spectrophotometers pH/specific ion meter LECO carbon and oxygen and

sulfur analyzers Parr bomb vacuum fusion and vacuum hot extraction equipment

EDUCATION

B.A Clark University Worcester MADate 1975 Major Chemistry

ADDITIONAL COURSES

Techniques of Management and Small Business Essentials

American River College Sacramento CA

GENERAL

Possess good mechanical aptitude and am able to work well with little supervision It is felt

that the training experience and supervisory skills gained during my employment are applicable to wide variety of activities

52EPA 04861

LISA .1 LANE

Job Description Assistant Chemist

Education University of New Hampshire

B.S Biochemistry 1987

Employment History

Oct 1989 to

present Industrial and Environmental Analysts Rangeway Road Billerica MA

Determination of trace metals by ICP and graphite furnace AAMercury analysis by cold vapor AAColorimeteric titrimetric and gravimetric analyses for inorganic constituents

Oct 1987 to

OcL 1989 Stevens Analytical Laboratories 39 Montvale Stoneham MA

Supervisor of Inorganic Chemistry

Responsible for testing required for EPA Certification

Coordinate the six chemists to ensure that all tests are completed before the

holding time and the due date of the project

Maintain the inventory of chemicals and glassware for the department

Training all new employees to perform testing

Troubleshooting any equipment or procedures also setting up new tests

Solely responsible for setting up petroleum hydrocarbon by JR analysis

May 1987 to

Oct 1987 Inorganic Chemist

Performed wide variety of analyses including demand nutrients phenols

cyanides and membrane filter microbiology techniques

Academic Years University of New Hmnpshire Durham Nil1986-1987 Laboratory Prep Technician

Prepared classrooms for the experiments to be performed by students This

included making all solutions and setting up equipment needed

Resident Assistant

Aided students who lived on campus with any problems they might have

academically or personally

Worked with University administration to maintain the smooth operation of

the residence hall

Enforcement of university policies

Educational programming pertaining to life issues-for residents

53

EPA 04862

.IENNY WANG UN

Education

1982to

Present Ph Candidate Departmentof Chemistry

Case Western Reserve University

Cleveland Ohio

Thesis The Modifiers Effect on Supercritical Fluid Chromatography

1978 M.A Chemistry University of Texas

Austin Texas

Thesis Spectroscopic Study of Cytochrome Modified with 4-Bromom-

ethylbenzoic Acid

1974 B.S Chemistry National Taiwan Normal University

Taipei Taiwan

Experience

Oct 1989 to Staff Scientist Analysis of Pesticides PCBs and air

present Industrial and Environmental Analysts samples

Jan 1980 to Teaching and Research Assistant Supervised 20 students

June 1986 Department of Chemistry

Case Western Reserve University

Jan 1979 to Junior Research Assistant Biotech research

Dec 1979 Case Western Reserve University

Jan 1976 to Teaching Assistant Supervised 30 students in the

May 1978 Department of Chemistry chemistry labs

University of Texas at Austin

Spt 1975 to Graduate Fellow Graduate studies

Dec 1975 Department of Chemistry

Texas AM University

College Station Texas

Aug 1974 to Teaching Assistant Supervised 40 students in the

July 1975 National Chaio Tung University Chemistry Labs

Hsinchu Taiwan

Aug 1973 to Chemistry Teacher

July 1974 Provincial Hsinchu Girls High School

Hsinchu Taiwan

54EPA 04863

LUCIO BARINELU

Professional Experience

Nov 1989 to Chemist Industrial and Environmental Analysts

Present Oversee complete operation of volatile organic analyses Screen and analyze

samples review data generate reports for clients Operate and maintain

instruments Knowledge of EPA methods for the analysis of volatile organic

analytes

Safety Director Impliment and administer company health and safety pro

gram Maintain compliance with OSHA Regulations Train employees

regarding safety proceedures Maintain company safety records

Oct 1988 to Postdoctoral Fellow Brandeis University

Oct 1989 Synthesis and characterization of organometallic polymers

May 1984 to Graduate Research Assistant

Sept 1988 University of Oklahoma

Jan 1986 to Graduate Teaching Assistant

May 1986 University of Oklahoma

Spt 1983 to Graduate Teaching Assistant

May 1984 Boston College

Spt 1982 to Teaching Assistant

Dec 1982 Boston College

Education

B.S Chemistry 1983 Boston College

M.S Organic/Organometallic Chemistry 1988 University of Oklahoma

Ph.D Organic/Organometallic Chemistry 1988 University of Oklahoma

Dissertation Title The study of Nucleophilic Additions to n4Diene tricarbonylcobalt

Cations

Professional Affiliations and Honors

American Chemical Society

Division of Inorganic Chemistry ACSPhi Lambda Upsilon Chemistry Honor Society

Sigma Xi Scientific Research Society

Conoco Research Fellowship University of Oklahoma 1987-1988

Clarence Karcher Scholarship University of Oklahoma 1986-1987

John Assinarri Memorial Scholarship 1979-1980

0486k

KIMBERLY KELLER

EXPERiENCE

9/90-Present Industrial and Environmental Analysts

Assistant Chemist

Responsible for semi-volatile sample thoughput by GCIMSResponsible for trouble-shooting and basic instrument maintenance

10/88-8/90 Metpath Inc Cambridge MAToxicology Technologist

Responsible for Stat sample preparation and alnalysis on GC GCIMSHPLC and instrument maintenance

6/88-9/88 Wilson Farms Inc Lexington MAAssistant Manager Garden Shop

Ordered and maintained plants for retail greenhouse

Counseled customers about plants fertilizers and insect control

9/87-5/88 Hartwick College Oneonta NYHerbarium Assistant

Processed specimens

Supervised other student assistant

9/86-5/87 Hartwick College Oneonta NYGreenhouse Assistant

Maintained environment

Gained valuable greenhouse skills

RESEARCH EXPERIENCE

5/87-5/88 Hartwick College Senior Thesis

Survey of Aquatic Plants at Pine Lake

Collected and processed specimens

Established base-line data as reference for future studies

5/87-8/87 Hartwick College Research Assistant

The Flora of Otsego County NYCollected and processed specimens for checklist that is to be

published

EDUCATION Hartwick College BA Biology May 1988

GENERAL President Sigma Alpha Iota

Field Biology in the Galapagos .Islands

Electron Microscopy

56

EPA 04865

Julie Anne Griffin

EDUCATION

University of Lowell

College of Health Professions

BS Clinical Laboratory Science

Chemistry Specialization

June 1990

Northern Essex Community College

Haverhill MAAssociate Degree Business ManagementJune 1985

EvWLOYMENT

9/90 Present Industrial and Environmental Analysts

Position Assistant Organic Chemist

Supervisor Micheal Wheeler PhDResponsibilities Screen and analyze samples for volatile organics review data and

generate reports

9/89 7/90 University of Lowell Research Foundation

Position Laboratory Technician

Supervisior Dr Gene Rogers

Responsibilities Extrations of serum lipids preparatory TLC derivitizations

and GLC-Ffl identification and quantification of methylated serum fatty

acids

1/87 9/89 Kraz Co Property Management

Position Office Manager part time

Supervisior Jack Krasnecki Owner

10/85 7186 Purity Supeme Inc

Position Accounting Clerk

Supervisior Margaret Guarino

57

EPA 04866

Gordon McKenzie Tripp

EDUCAHON

Bachelor of Science Chemistry

May 1990

State University of New York at Stony Brook

Stony Brook New York

EMPLOYMENT


Position Assistant Organic Chemist

Involved with sample preparation and analyzation in semivolatile PCBfPesticideand Industrial Hygiene divisions

5/89 9/89 SUNY at Stony Brook Division of Campus ResidencePosition Summer Operations Assistant

Supervised student summer work crew of six Assisted with the

organization of summer conferences

9/88 12/88 SUNY Stony Brook Biology DepartmentPosition Laboratory Assistant

Prepared equipment and restocked supplies

9/87 5/89 STJNY Stone Brook Division of Campus ResidencePosition Resident Assistant

Enforced University niles and regulations Coordinated several educationaland social activities for the residence hail

5/87 9/87 Laubach Literacy

Position Office Assistant

Performed data entry filing and order preperation

RESEARCH EXPERIENCE

6/88 5/90 Organo-Metaljjc Reactions The research dealt with the exchange of organicligands on metal atom centers in an anhydrous environment under nitrogenatmosphere This study focused on the types of bonds formed between theorganic ligand and the metal atom center

58

EPA 04867

Tony Yn

EDUCATION

Northeastern University Boston MAMaster of science in Chemistry candidate

Participation in Part-time Program

Bachelor of Science in Chemical Engineering

Graduated with honors in June 1989

Recipient of Scholar Award from Dow Hemical Company 1986

ChambrlyneJUnior College Boston MA 1/83-12/84

Major Chemistry Completed 40 of 64 credits

EMPLOYMENT


Position Assistant Inorganic Chemist

Operate computer-aided FTIR DCP and ICP Prepare samples and report

analytical results

4/86 4189 Albany International Research Company Mansfield MACooperative Education placement involved the arialysis of polymer materials

Operated computerized DSC TGA and UV Performed thermal analysis stability

testing and polymermolecular weight measurement Responsible for sample

preparation and other chemical experiments

59 EPA 04868

RAP3709j - LM Sites - Department of Energy

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