2014 data validation for 2013_5 may 2014

Erler &

Kalinowski,

Inc.

Consulting Engineers and Scientists

1870 Ogden Drive Burlingame, CA 94010

(650) 292-9100 Fax: (650) 552-9012

5 May 2014

Patricia Bowlin

EPA Project Coordinator - MGM Brakes Site

Superfund Division

U.S. Environmental Protection Agency

75 Hawthorne Street

San Francisco, California 94105

Janice Goebel

Environmental Specialist

California Regional Water Quality Control Board

North Coast Region

5550 Skylane Boulevard, Suite A

Santa Rosa, California 95403

Subject: Transmittal of Data Validation Report for April and October 2013

MGM Brakes Superfund Site -Cloverdale, California

(EKI 890016.34)

Dear Ms. Bowlin and Ms. Goebel:

On behalf of TBG, Inc. and Indian Head Industries, Inc., the “Settling Defendants,” Erler &

Kalinowski, Inc. (“EKI”) is transmitting data validation packages for samples collected at

the MGM Brakes Superfund Site, in Cloverdale, California (the “Superfund Site”).

Groundwater sample collection and analysis is being conducted pursuant to Consent

Decree No. C-89-4047 (JPV), entered 18 May 1990 (the “Consent Decree”) for the MGM

Brakes Superfund Site.

The United States Environmental Protection Agency (“EPA”) requested these data

validation packages in response to the EKI letter dated 29 January 2014. The January 2014

letter requested approval to abandon the remaining two monitoring wells at the Superfund

Site in view of the EPA determination that the Superfund Site qualifies for unlimited use

and unrestricted exposure (Army Corp of Engineers, 2013).

Data validation was performed for the two semi-annual groundwater sampling events

which occurred in April and October 2013. The result of the validation is included in the

report prepared by AQA Services which is included as Attachment A. All the data for

Letter to Ms. Bowlin and Ms. Goebel

5 May 2014

Page 2

chemicals of concern (“COCs”) defined in Section VI, Paragraph I of the Consent Decree

defines as Trichloroethene (“TCE”), vinyl chloride, benzene, and cis-1, 2-dichloroethene

(“cis-1,2-DCE”) were considered valid. AQA qualified analytical result of “not detected”

for dichlorodifluoromethane in two samples as biased low (UJ). Dichlorodifluoromethane

is not a COC at the Superfund Site1.

In view of the EPA determination that the Superfund Site qualifies for unlimited use and

unrestricted exposure and the validated data for samples collected in 2013, we ask that the

two remaining groundwater monitoring wells be permanently decommissioned following

the well abandonment protocols described in this letter. Upon approval of this request,

groundwater monitoring at the Site will be terminated. The groundwater monitoring wells

will be destroyed as described in the EKI letter dated 29 January 2014. A report will be

submitted to U.S. EPA and the RWQCB summarizing the fieldwork and forwarding copies

of permits, analytical data sheets, and the State of California Well Completion Reports.

We appreciate your review of this request. If you have any questions, please call.

Very truly yours,

ERLER & KALINOWSKI, INC.

Thomas J. Belick, P.E.

Chief Engineer

RCE 26845

Karen A. Gruebel, Ph.D.

Project Manager

cc: Ronald Parker (Indian Head Industries, Inc.)

Jim Udstuen (representing TBG, Inc.)

1 The LCS/LCSD for dichlorodifluoromethane associated with the sample B-93 collected April 2013 had a

low average percentage recovery. The MS/MSD for dichlorodifluoromethane associated with the sample B-

73 collected October 2013 had a low average percentage recovery. These recoveries resulted in the UJ flag

for these samples.

Letter to Ms. Bowlin and Ms. Goebel

5 May 2014

Page 3

List of Attachments

Attachment A: TBG Indian Head Project, Cloverdale California, Data Validation Report

TestAmerica Laboratories, Inc. Job Numbers:720-49392-1 and 720-53005-1, prepared by

AQA Services, April 2014

Attachment B – Analytical Report Job Number:720-49392-1, prepared by TestAmerica,

April 2014, with comments by AQA Services.

Attachment C - Analytical Report Job Number 720-53005-1, prepared by TestAmerica,

April 2014, with comments by AQA Services.

ATTACHMENT A

TBG Indian Head Project, Cloverdale California, Data Validation Report TestAmerica

Laboratories, Inc. Job Numbers:720-49392-1 and 720-53005-1

Prepared by AQA Services

April 2014

TABLE OF CONTENTS

Introduction

Table 1

Quality Assurance Review

1. Data Validation

A. Summary of Level 4 Data Validation of Laboratory Job Number 720-49392-1

B. Summary of Level 4 Data Validation of Laboratory Job Number 720-53005-1

2. Conclusions

Introduction

This quality assurance review is based upon an examination of the data generated from the analyses of samples that were collected as part of the TBG Indian Head Project located in Cloverdale, California. The samples were collected on April 23 and October 9, 2013, and were submitted to TestAmerica Laboratories, Inc. for analysis. The samples included in this quality assurance review are presented in Table 1.

This review has been performed in accordance with the “National Functional Guidelines for Organic Data Review” (U.S. EPA, October 1999) with guidance from the Region 9 Data Quality Indicator Table for EPA Method 8260 (U.S. EPA, December 1999).

The data deliverables were examined to determine the usability of the analytical results and compliance relative to requirements specified by the reported methodology. Qualifier codes have been entered into the appropriate field in the electronic data, where necessary, so that the data user can quickly assess the qualitative and/or quantitative reliability of any result based on the criteria evaluated.

This critical QA review identifies data quality issues for specific samples and specific evaluation criteria. The data qualifications allow the data end-user to best understand the usability of the analytical results. Data that have not been qualified in this report should be considered valid based on the QC criteria that have been applied.

TABLE 1

SAMPLES INCLUDED IN THIS QUALITY ASSURANCE REVIEW

Sample Identification

Laboratory Sample ID

Laboratory Job ID

Date Sampled

Parameter(s) Examined

April 2013 Sampling Event

B-50 720-49392-1 720-49392-1 04/23/2103 V

B-50MS (Matrix Spike)

720-49392-1MS 720-49392-1 04/23/2103 V*

B-50MSD (Matrix Spike Duplicate)

720-49392-1MSD 720-49392-1 04/23/2103 V*

B-73 720-49392-2 720-49392-1 04/23/2103 V

B-73MS (Matrix Spike)

720-49392-2MS 720-49392-1 04/23/2103 V

B-73MSD (Matrix Spike Duplicate)

720-49392-2MSD 720-49392-1 04/23/2103 V

B-91 720-49392-3 720-49392-1 04/23/2103 V

B-91MS (Matrix Spike)

720-49392-3MS 720-49392-1 04/23/2103 V

B-91MSD (Matrix Spike Duplicate)

720-49392-3MSD 720-49392-1 04/23/2103 V

B-92 720-49392-4 720-49392-1 04/23/2103 V

October 2013 Sampling Event

B-50 720-53005-1 720-53005-1 10/09/2013 V

B-73 720-53005-2 720-53005-1 10/09/2013 V

B-73MS (Matrix Spike)

720-53005-2MS 720-53005-1 10/09/2013 V

B-73MSD (Matrix Spike Duplicate)

720-53005-2MSD 720-53005-1 10/09/2013 V

B-91 720-53005-3 720-53005-1 10/09/2013 V

B-92 720-53005-4 720-53005-1 10/09/2013 V

Notes:

Bold - Samples included in the data validation report.

V - Volatile Organics by U.S. EPA (EPA) Method 8260B.

V* - 1,3,5-Trimethylbenzene by U.S. EPA (EPA) Method 8260B.

TBG Indian Head Project

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Quality Assurance Review

This report summarizes the findings of the Level 4 data validation performed on the data for the eight (8) aqueous samples and eight (8) project-specific laboratory QC samples specified in Table 1. The samples were collected as part of the TGB Indian Head Project located in Cloverdale, California. The samples were collected on April 23 and October 9, 2013. The samples were submitted to and analyzed by TestAmerica Laboratories, Inc.’s facility in Pleasanton, California. The samples were analyzed for Volatile Organic Compounds by EPA Method 8260B as specified in Table 1. 1.0 Data Validation

This section presents results of the Level 4 data validation of the samples with respect to each of the areas of data review listed above. Where appropriate, data have been qualified in accordance with the “National Functional Guidelines for Organic Data Review” (U.S. EPA, October 1999) with guidance from the Region 9 Data Quality Indicator Table for EPA Method 8260 (U.S. EPA, December 1999). These data qualifier flags indicate a bias in the reported data and should be considered during all project evaluations. Each analytical method was reviewed in the following areas to determine any impact to data quality and usability.

Data Completeness

Analytical Holding Times and Sample Preservation

Laboratory Method Blank Samples

GC/MS Tunes

Initial Calibrations

Initial Calibration Verifications

Continuing Calibrations

Surrogate Recoveries

Laboratory Control Samples/Laboratory Control Sample Duplicates (LCS/LCSD)

Matrix Spike/Matrix Spike Duplicate (MS/MSD) Samples

Internal Standard Areas and Retention Times

Compound Identification and Quantification

Verification of Electronic Data File 1.A Summary of Level 4 Data Validation for Laboratory Job Number 720-49392-1

This section presents results of the data validation of the samples with respect to each of the areas of data review listed in Section 1.0.

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1.A.1 Data Completeness

Four (4) aqueous samples were submitted for analysis. All sample analyses were performed as requested on the chain-of-custody (COC). According to the case narrative, one (1) vial for sample B-73 was received broken. According to the case narrative, the vials for sample B-50 were labeled B-73; however, the time of sampling matched the time of sampling recorded for sample B-50. Therefore, the vials were logged-in and analyzed as sample B-50. According to the case narrative, sample B-50 was reanalyzed for 1,3,5-trimethylbenzene due to concern over carryover due to the presence of high levels of 1,3,5-trimethylbenzene in the previous sample analyzed. Based on the reanalysis, 1,3,5-trimethylbenzene was not detected in sample B-50. The GC/MS VOA Manual Integration Summary (page 48) associated with sample B-92 was incomplete. Since the all of the analytes listed on the form are not detected, qualification of the data was not warranted on this basis. On all of the LCS/LCSD and MS/MSD Summary Forms (Form IIIs) and the ICV and CCV Summary Forms (Form VIIIs), xylenes (total) were not reported. In all cases, acceptable results were displayed based on the raw data provided. The laboratory included an initial calibration (ICAL) for instrument HP9 performed on 3/21/2013 in the data package. However, no data was associated with this ICAL; consequently, this ICAL and all of the associated data (pages 88, 254-314, 439-442, and 554) are superfluous and have not been reviewed. Sample B-73 (page 83) and Method Blank (MB-720-135536/5; page 86) were recorded on the incorrect GC/MS VOA Instrument Performance Check Summary Form (Form V). The data reviewer has corrected the Form V’s in the annotated data package. On all GC/MS VOA Internal Standard Area and Retention Time Summary Forms (Form VIII’s), the laboratory defined the RT Limit as “± 30 minutes of the internal standard RT” instead of ± 30 seconds of the internal standard RT. The data reviewer corrected the RT Upper and Lower Limits and the definition throughout the data package.

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For the ICV (ICV 720-134388/15) analyzed on 04/15/2013 at 19:40, the laboratory did not provide a GC/MS VOA Internal Standard Area and Retention Time Summary Forms (Form VIII). Based on a review of the raw data provided, acceptable internal standard areas and RT’s were displayed. Sample B-92, Method Blank (MB-720-135523/5), LCS (LCS--720-135523/6), and LCSD (LCSD-720-135523/7) were recorded twice once on the incorrect GC/MS VOA Internal Standard Area and Retention Time Summary Forms (Form VIII – pages 99 and 100) and then again on the correct GC/MS VOA Internal Standard Area and Retention Time Summary Forms (Form VIII – pages 101 and 102). The data reviewer has noted the issue on the incorrect Form VIII’s (pages 99 and 100) in the annotated data package. 1.A.2 Analytical Holding Times and Sample Preservation

The samples submitted to the laboratory for analysis were properly preserved according to guidelines established by the U.S. EPA. In addition, all samples were analyzed within the recommended holding times for EPA Method 8260B. 1.A.3 Laboratory Method Blank Samples

A laboratory method blanks was analyzed with each batch of samples. The laboratory method blanks were free of contamination at or above the laboratory reporting limits. 1.A.4 GC/MS Tunes

All GC/MS tuning and mass calibrations met the method-specified criteria (m/z ratios). All project samples were analyzed within the tune windows. 1.A.5 Initial Calibrations

For the initial calibration, the average relative response factors (≥ 0.05) and percent relative standard deviations (≤ 30%) were within QC criteria for all target compounds. 1.A.6 Initial Calibration Verifications

For the initial calibration verification, the recoveries were within the laboratory limits for all target compounds. 1.A.7 Continuing Calibrations

For the continuing calibration, the relative response factors (≥ 0.05) and percent differences (≤ 25%) were within QC criteria for all target compounds.

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1.A.8 Surrogate Recoveries

All surrogate recoveries met Region 9 QC criteria. 1.A.9 Laboratory Control Samples/Laboratory Control Sample Duplicates (LCS/LCSD)

LCS/LCSD were prepared and analyzed with each batch of samples. Except as noted below, the LCS/LCSD results (average percent recoveries and relative percent differences) were within acceptance criteria for accuracy and precision established by the laboratory and the appropriate guidance documents.

• A low average percent recovery (69.0%) was reported for dichlorodifluoromethane in the LCS/LCSD analyses associated with sample B-92; consequently, the non-detect for dichlorodifluoromethane in sample B-92 was qualified as biased low (UJ).

1.A.10 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Samples

All project samples used for the MS/MSD analyses are listed in Table 1. Acceptable precision and accuracy were demonstrated by the project samples used for the MS/MSD analyses except as noted:

• Although the MS/MSD recoveries for dichlorodifluoromethane in Batch 135422 (B-50) were outside of the control limits, only 1,3,5-trimethylbenzene was reported from the batch. Consequently, qualification of the data was not warranted on this basis.

1.A.11 Internal Standard Areas and Retention Times

For all project analyses, the internal standards met the criteria for retention times and areas. 1.A.12 Compound Identification and Quantification

All samples in this Laboratory Job Number underwent Level IV validation including recalculation of positive results, compound identification, and retention times. All results were verified within 10% of the value reported. 1.A.13 Verification of Electronic Data File

The sample data in the electronic file (XLS) provided by the client matched the sample data reported in the hardcopy laboratory report. The data reviewer added a field for the DV Qualifier to the electronic file. 1.B Summary of Level 4 Data Validation for Laboratory Job Number 720-53005-1

This section presents results of the data validation of the samples with respect to each of the areas of data review listed in Section 1.0.

TBG Indian Head Project

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1.B.1 Data Completeness

Four (4) aqueous samples were submitted for analysis. All sample analyses were performed as requested on the chain-of-custody (COC). According to the case narrative, three (3) Trip Blanks were received that were not on the COC. The Trip Blank were logged in and placed on hold. On all of the LCS/LCSD and MS/MSD Summary Forms (Form IIIs) and the ICV and CCV Summary Forms (Form VIIIs), xylenes (total) were not reported. In all cases, acceptable results were displayed based on the raw data provided. On all GC/MS VOA Internal Standard Area and Retention Time Summary Forms (Form VIII’s), the laboratory defined the RT Limit as “± 30 minutes of the internal standard RT” instead of ± 30 seconds of the internal standard RT. The data reviewer corrected the RT Upper and Lower Limits and the definition throughout the data package. 1.B.2 Analytical Holding Times and Sample Preservation

The samples submitted to the laboratory for analysis were properly preserved according to guidelines established by the U.S. EPA. In addition, all samples were analyzed within the recommended holding times for EPA Method 8260B. 1.B.3 Laboratory Method Blank Samples

A laboratory method blanks was analyzed with each batch of samples. The laboratory method blank was free of contamination at or above the laboratory reporting limits. 1.B.4 GC/MS Tunes

All GC/MS tuning and mass calibrations met the method-specified criteria (m/z ratios). All project samples were analyzed within the tune windows. 1.B.5 Initial Calibrations

For the initial calibration, the average relative response factors (≥ 0.05) and percent relative standard deviations (≤ 30%) were within QC criteria for all target compounds. 1.B.6 Initial Calibration Verifications

For the initial calibration verification, the recoveries were within the laboratory limits for all target compounds.

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1.B.7 Continuing Calibrations

For the continuing calibration, the relative response factors (≥ 0.05) and percent differences (≤ 25%) were within QC criteria for all target compounds.

1.B.8 Surrogate Recoveries

All surrogate recoveries met Region 9 QC criteria. 1.B.9 Laboratory Control Samples/Laboratory Control Sample Duplicates (LCS/LCSD)

LCS/LCSD were prepared and analyzed with each batch of samples. The LCS/LCSD results (average percent recoveries and relative percent differences) were within acceptance criteria for accuracy and precision established by the laboratory and the appropriate guidance documents. 1.B.10 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Samples

All project samples used for the MS/MSD analyses are listed in Table 1. Acceptable precision and accuracy were demonstrated by the project samples used for the MS/MSD analyses except as noted:

• A low average percent recovery (61.5%) was reported for dichlorodifluoromethane in the MS/MSD analyses of sample B-73; consequently, the non-detect for dichlorodifluoromethane in sample B-73 was qualified as biased low (UJ).

1.B.11 Internal Standard Areas and Retention Times

For all project analyses, the internal standards met the criteria for retention times and areas. 1.B.12 Compound Identification and Quantification

All samples in this Laboratory Job Number underwent Level IV validation including recalculation of positive results, compound identification, and retention times. All results were verified within 10% of the value reported. 1.B.13 Verification of Electronic Data File

The sample data in the electronic file (XLS) provided by the client matched the sample data reported in the hardcopy laboratory report. The data reviewer added a field for the DV Qualifier to the electronic file.

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2.0 Conclusions

This QA review has identified aspects of the analytical data that required qualification due to LCS/LCSD recoveries and MS/MSD recoveries. To confidently use any of the analytical data within this sample set, the data user should understand the qualifications and limitations of the results.

DATA QUALIFIER DEFINITIONS

U The analyte was detected above the laboratory-reported sample quantitation limit. However, due to contamination from an outside source such as laboratory or field equipment, the analyte should be considered “not detected” at or above the adjusted sample quantitation limit.

J The analyte was positively identified but the associated numerical value may not represent the actual concentration of the analyte in the sample due to an analytical bias in precision or accuracy, or because the resulting concentration has been reported at a confidence level of less than 99%.

UJ The analyte was not detected above the reported sample quantitation limit. However, the reported quantitation limit is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample.

R The sample results are rejected due to serious deficiencies in the ability to analyze the sample and meet quality control criteria. The presence or absence of the analyte cannot be verified and data are not usable.

N The analysis indicates the presence of an analyte for which there is presumptive evidence to make a tentative identification.

DNR Do Not Report in the final data set. The data were included in the hardcopy report for completeness only as the sample analyses were associated with laboratory Batch QC analyses. These results should not be used as part of the decision-making process nor reported as part of the final data set.

+ The result is biased high.

- The result is biased low.

NA Not analyzed.

µg/L micrograms per liter.

mg/L milligrams per liter.

ATTACHMENT B

Analytical Report Job Number:720-49392-1

Prepared by TestAmerica with Comments by AQA Services

April 2014

ATTACHMENT C

Analytical Report Job Number 720-53005-1

Prepared by TestAmerica with Comments by AQA Services

April 2014