ar3q0222 - united states environmental protection agencytable 1 . kinetic data for hydrolysis" of...

APPENDICESWORK AND QUALITY ASSURANCE PLAN

FOR THEHOSIER ROAD REMEDIAL INVESTIGATION

AND FEASIBILITY STUDY

Prepared for:

The City of Suffolk441 Market Street

Suffolk, Virginia 23434

Prepared by:

SCS Engineers11260 Roger Bacon DriveReston, Virginia 22090

(703) 471-6150

January 3, 1991File No. 289099-04

AR3Q0222

CONTENTS

Appendix Title

A Physical/Chemical Properties and Degradation of PesticidesDisposed at the Hosier Road Landfill

B 1. Summary of the Scoping Session2. VDWM's October 24, 1990 Letter and The City of Suffolk's

Response of January 11, 1991

C SCS Engineers Resumes

D General Physics Organization Chart and Resumes

E Field Instrument Operation Manuals for Calibration

F GP Environmental Services, Inc. (formerly JTC EnvironmentalConsultants, Inc.) Laboratory Quality Assurance/QualityControl Manual

SR300223

APPENDIX A

PHYSICAL/CHEMICAL PROPERTIES ANDDEGRADATION OF PESTICIDES DISPOSED AT THE

HOSIER ROAD LANDFILL

t

SR30Q22U

PHYSICAL/CHEMICAL PROPERTIES AND DEGRADATION OF PESTICIDESDISPOSED AT THE HOSIER ROAD LANDFILL

Pesticides reportedly disposed at the site include Dlsyston (Disulfoton), Cu7'Sulfur (Copper + Sevin + Sulfur), 7 Sulfur (Sevin + Sulfur), Thimet, andCyanox. Reportedly, Disulfoton made .up the bulk of the material disposed. Abrief discussion of the chemical properties of these pesticides follows.

DISULFOTON

Svnonvms and Trade Names

Synonyms and trade names include Disyston, ethylthiodemeton, thiodemeton, M-74,Frumin AL [FCH, 1989], dithiodemeton, Bay 19639, ENT 23347, Dithiosystox,Frumin G, Solvirex [Windholz, 1983], Solvigran [USDA, 1990].

Chemical Composition . . . . . . _ , .,.., .... .

Disulfoton is a member of the organophosphorus family, with a chemical formulaof CH 0 PS,. The molecule

3 19 2 3

The chemical structure is:

of C8H1902PS3. The molecular weight is 274.38, and the CAS number is 298-04-4.

P-S-CHj-CH,-S-C3HsC3H50X

Physical State

The technical grade is a colorless liquid at room temperature. Commercialformulations include a dry seed dressing (Frumin AL), emulslfiable concentrate,granules (15% and 1.5%) [FCH, 1989], pelleted and tableted formulations, andready to use liquids [USEPA, 1984a]. The Merck Index reports Disulfoton as acolorless oil [Windholz, 1983], It is also reported as a pale yellow liquid[Verschueren, 1983 and USEPA, 1984a].

Chemical Properties

The following chemical properties apply to technical grade Disulfoton:Property _ Value Reference

Density: 1.144 FCH, 1989Water Solubility: 25 mg/1 Verschueren, 1983

1

fiR300225

Insoluble Windholz, 198325 mg/1 @ 20°C WERL, 199012 mg/1 @ 20°C " - USDA, 199060 mg/1 - USEPA, 19845

Melting Point: Below -25°C RSC, 1989Boiling Point: 62°C (? 0.01 mm Hg FCH, 1989Vapor Pressure: -7.2x10"* mm Hg @ 20°C FCH, 1989

1.8x10"* mm Hg @ 20°C Windholz, 19831.8x10 mm Hg (? 20°C Verschueren, 19833.00x10"* mm Hg0 20 - 25°C USEPA, 1984b

7.2 mPa 0 20°C USDA, 1990Vapor Density: ——— ———Flash Point: > 200°F FCH, 1989

> 180°F " USEPA, 1984bLog Octanol/Water Partition

Coefficient 3.94 WERL, 19903.95 @ 20°C USDA, 19904.02 @ 0GC USDA, 1990

-Log Soil/Water PartitionCoefficient 3.25 (sandy loam) Sims et al., 1988

Soil/Water PartitionCoefficient 770 (sandy loam) USDA, 1990

578 (loam) USDA, 1990664 (sand) USDA, 1990

Henry's Law Constant 0.22 Pa nr/mol USDA, 19900.16 Pa nr/mol USDA, 1990

Field dissipation half-life -40 days USDA, 199028 days USDA, 199090 days USDA, 199060 days USDA, 1990

Half-life (biodegradation) 19 days (sandy loam) Sims et al., 1988Soil half-life (aerobic) 2.4 days (sandy loam) USDA, 1990Half-life (hydrolysis @ 70°C) 7.2 hours SRC, 1978Hydrolysis rate constant 0.0021/day @ 20°C

and pH 7 USDA, 1990Photolysis rate constant 0.063/day (soil) USDA, 1990

0.693/day (water) USDA, 1990

Figure 1 presents a graph of the first-order degradation of disulfoton byphotolysis.

Disulfoton is a systemic insecticide-acaricide. Uses include side dressing,broadcast, and foliar spray in the seed furrow to control many species ofinsects and mites. It is also used as a seed treatment for sucking insects.Disulfoton is currently marketed in the United States [FCH, 1989].

SR300226

o4->O_cQ.

co

Crt•îO

cro

s-O)C1Q

flR300227

Specific applications include grain crops, nut crops, cole crops, root crops,pome, strawberry and pineapple fruits, forage, field and vegetable crops,sugarcane, seed crops, forest plantings, ornamentals, and potted plants(including houseplants) . Both ground and aerial application are performed[USEPA, 1984a].

Disulfoton was originally registered in 1958. The EPA document Suspended,Cancelled, and Restricted Pesticides lists approximately 80 suspended,cancelled, or restricted pesticides. Oisulfoton is not on the list.

Persistence and .Degradation ._, .. .. . . . . . . . .

Disulfoton (Disyston) biodegrades under aerobic conditions [Verschueren, 1983]When used as an insecticide, control may persist for 6 to 8 weeks [FCH, 1989].It is stable under normal storage conditions, but it subject to hydrolysisunder alkaline conditions [FCH, 1989].

Disulfoton is absorbed by plants. The major plant metabolite appears to bedisulfoton sulfone [USEPA, 1984a]. Other metabolites include disulfoton,sulfoxide, disulfoton 0-analog, disulfoton 0-analog sulfoxide, disulfoton0-analog sulfone, diethyl phosphate, diethyl phosphorothioate, and phosphoricacid [USEPA, 1984c].

Alkaline hydrolysis of disulfoton proceeds by the following reaction:

s CB" s 'i or I_0 *Cc2i5o)2?sc2a4sc235 —— * — cc2BjO)2Po«

The products formed are diethylphosphorothioic acid and ethyl thioethylmercaptan. Diethyl phsophorothioic acid is relatively non-toxic. Sinceethanedlthiol , the parent compound of ethyl thioethyl mercaptan, is much lesstoxic than disulfoton, it is assumed that ethyl thioethyl mercaptan also is lesstoxic (SRC, 1978).

Complete hydrolysis of disulfoton requires an equimolar ratio of the pesticideand hydroxide. Since thiols are weak acids, it is recommended that excess basebe added to insure completion of the hydrolysis reaction. Since disulfoton isrelatively insoluble in water, the best decontamination solution would be a1 N sodium hydroxide, 50% ethanol solution (SRC, 1978).

Hydrolysis of disulfoton is pH and temperature dependent. Table 1 belowprovides kinetic data on the hydrolysis reaction in water. The data indicatethat the hydrolysis reaction proceeds more quickly as the pH and temperature ofthe water increase.

flR300228

Table 1 .Kinetic Data for Hydrolysis" of Disulfoton (SRC,1978)

T«p«r*tur«. *C j)gjr k(10 hour" ) _H«lf -llf •

70 oHCl 2. SB 24 hour*

1 1.11 62 hours

2 1.11 ' 62 houri

3 1.10 62 houri

4 1.11 62 heuri

5 1.16 60 hours

6 1.56 44, hour*

7 2. SO 27.6 hours

8 3.22 21.5 hours

9 9.61 7.2 hours

0 1-5 1.2xlO~* 232000

THIMET

Synonyms and Trade Names ._. . . . , , .

Synonyms and trade names include Phorate, Timet AAstar, AC 8911, Rampart, andThimenox [FCH, 1989], American Cyanimid 3911, El 39"11, ENTT24042 [Windholz,1983]. •

Chemical Composition _.,

Thimet is a member of the organophosphate family, with a chemical formula ofC,H 0 PS . The molecular v7 17 2 3

The chemical structure is:C?Hi7°2PS3* The molecular weight is 260.40, and the CAS number is 298-02-2.

C2H5OS

Physical StateThe technical grade is a clear liquid at room temperature [FCH, 1989 andWindholz, 1983], with a skunk-like odor [USEPA, 1985b], Commercialformulations include an emulsifiable concentrate and granules (10%, 15% and20%) [FCH, 1989].

Chemical Properties

The following chemical properties apply to technical grade Thimet:

Property Value Reference

Density: 1.156 Windholz, 1983Water Solubility: 0.5 ppm 0 21°C FCH, 1989

17.9 ppm 0 20°C USDA, 199022 ppm 0 25°C USDA, 199050 ppm 0 25°C FCH, 198950 ppm @ 25°C Windholz, 198385 mg/1 0 20°C Nye, 1985

Melting Point: Below -15°C(technical >90%) RSC, 1989

-42.9oC USDA, 1990Boiling Point: 118-120°C @ 0.8 mm Hg USEPA, 1985bVapor Pressure: 8.4x10 mm Hg 0 20°C Windholz, 1983

84.7 mPa 0 25T USDA, 1990158 mPa 0 35°C USDA, 1990270 mPa 0 45°C USDA,1990

Flash Point: 160°C' USEPA, 1985b

flR300230

Vapor Density: ——— ———Henry's Law Constant 1,8 Pa m3/mol p°C USDA, 1990Soil/Water Partition Coeff: ".3,200 . . FCH, 1989Log Octaoo.l/Water Partition _ . . . . . .

Coefficient " ". """ 2.92 WERL, 19903.92 0 25°C USDA, 19904.26 0 0°C USDA, 1990

. 3.33 0' 0°C USDA, 1990Log Soil/Water Partition

Coefficient ""* 2.54 (sandy loam) Sims et al., 1988

Soil/Water PartitionCoefficient 310 (sand 0 25°C) USDA, 1990

627(sandy loam 25°C) USDA, 1990322(silt loam @ 25°C) USDA, 1990545 (loam 0 25°C) USDA, 1990

Field dissipation half-life 2 days (Georgia soil) USDA, 19905 days (Nebr. soil) USDA, 199012 days (Iowa soil) USDA, 1990

Half-life (bibdegradation) 32 days (sandy loam) Sims et al., 1988Soil half-life (aerobic) 3 days (sandy loam) USDA, 1990Half-life (hydrolysis 0 70°C) 2 hours SRC, 1978Hydrolysis rate constant 0.2170/day 25°C pH 5 USDA, 1990Photolysis rate constant 0.3758/day(soil 25°C) USDA, 1990

0.229/day(water 25°C) USDA, 1990

Figure 2 presents a graph of the first-order degradation of phorate byphotolysis.

Use . . . . . . .......,.._ - --•

Thimet is the sixth most commonly used 'insecticide in American agriculture[Kearney, et.al, 1985]. It is a soil and systemic insecticide-nematicide.Applications include non-domestic terrestrial and aquatic food/feed crops andgreenhouse commercial nursery stock (both indoor and greenhouse). It is ,usedfor a wide range of insects on a variety of crops, including alfalfa, barley,rice (in India), beans, bermudagrass, corn, cotton, lettuce, peanuts, potatoes,rice, sorghum, sugar beets, soybeans, sugarcane, tomatoes, and wheat. It isalso used in combination with fertilizers and fungicides [FCH, 1989 and USEPA,1985b].. Thimet is currently marketed in the United States [FCH, 1989].

Phorate was originally registered in 1959 [USEPA, 19855], The EPA documentSuspended, Cancelled, and Restricted Pesticides lists 80 pesticides that havebeen either suspended, cancelled, or restricted because of their toxicity.Phorate is not on the list.-

AR30023I

Persistence and Degradation

Thimet is-considered stable under neutral and acidic conditions, and is subjectto hydrolysis, under alkal in.e..conditions, /It is considered non-persistent(half-life of 30 days or less). The shelf-life of Vegru Foratox, a thimetproduct of M/S Pesticides India^, is 2 years; for technical grade Thimet, it isat least 2 years at room temperature [FCH, 1989].

Thimet is stable.at room temperature, but is hydrolyzed in the presence ofwater and alkali [Windholz, 1983].

The soil/water partition coefficient of 3,200 indicates that it has a highpreference for soil adsorption over water solubility.

Phorate is metabolized in plants by rapid oxidation to the sulfoxide (someoxidation to the 0-analog may also occur), followed more slowly by oxidation tothe s.ulfone and/or the 0-analog sulfoxide; phorate sulfone and phorate 0-analogsulfoxide are'then further oxidized to the 0-analog sulfone. 'Available studiesindicate that hydrolysis of the oxidized metabolites eventually occurs to yieldnon-toxic water-soluble products. A field study of corn treated at 1 Ib.active ingredient/acre with 10% granular formulation indicate that phorateresidues were non-detectable (

The half-life of hydrolysis is pH- and temperature-dependent. Table 2 belowshows the temperature dependence of hydrolysis at pH 1-5. The data indicatethat the reaction proceeds more quickly as the temperature increases.

Table 2.Kinetic Data on Hydrolysis of Phoratea(SRC, 1978).

. 'C k fhouf'xIO Balf-llf«

0 0.014 200

10 0,08 36

20 0.4 72

30 1.83 1-6

40 7.14 0.4

* pi 1-3 in wiccr.

Most organophosphorus pesticides used currently are biodegradable and disappearrapidly from the soil[Kearney, et.al., 1985].

CYANOX

Svnonvms and Trade Names __.

Synonyms and trade names include Cyanophos, CYAP [FCH, 1989], Ciafos, Bay34727, S 4084, Sumitomo S 4084 [Windholz, 1983].

Chemical Composition _ ' - - —

Cyanox is an organophosphorus compound, with a chemical formula of C H NO PS.The molecular weight is 243.21, and the CAS number is 263-62-62.

The chemical structure is:

Physical State

The technical grade is a clear, amber liquid at room temperature. Commercialformulations include 3% dust, 50% emulsifiable concentrate, and 1% oil-basedliquid spray [FCH, 1989]. The Merck Index [Windholz, 1983] reports a it as ayellow to reddish-yellow transparent liquid.

10

flR30023t*

Chemical Properties ._._. . ......-„-,...... ,-- -.. - .

The following chemical properties apply to technical grade Cyanox:

Property _ „._ ,___^..._. ._ ...... . Value Reference

Density: • _! 1.255 - 1.265 RSC, 1989Water Solubility: • slight Windholz, 1983

46 mg/1 RSC, 1989Melting Point: 14 - 15°C FCH, 1989Boiling Point: decomposes f?

119 - 120°C RSC, 1989Vapor Pressure: 105 mPa 0 20°C RSC, 1989

Use . . .: ,.,._..__.....,. ...-....,--^ - —- —— - - - - - - --.-. - • -

Cyanox is used as^an insecticide for fruits and vegetables. When used on aregular schedule, it controls lepidopterous larvae on apples. It is also usedas a grain protectent [FCH, 1989]. The EPA document Suspended, Cancelled, andRestricted Pesticides lists 80 pesticides that have been suspended, cancelled,or restricted in their use because of their toxicity. Cyanophos is not on thelist.

Persistence and Degradation . . . _ . . , .,

Cyanox is rapidly decomposed under alkaline conditions or upon exposure tolight. It decomposes above 120°C. [Windholz, 1983].

Hydrolysis of cyanox proceeds through the following reaction:Crt,C\ 4$ +

The products of the reaction are dimethyl phosphorothioic acid andp-cyanophenol . Since diethyl phosphorothioic acid is relatively non-toxic, itis assumed that dimethyl phosphorothioic acid also is non-toxic. Data on thetoxicity of p-cyanophenol could not be located.

As with disulfoton and phorate, hydrolysis will proceed most rapidly underalkaline conditions. Most likely, the reaction needs to be carried out in anaqueous solution containing ethanol since cyanox is only slightly soluble inwater. An excess of hydroxide should be present to insure completion of thehydrolysis.

Hydrolysis of cyanox should be pH- and temperature-dependent, although datacould not be found to verify this assertion. Cyanox is a member of the same

11

flR300235

category of pesticides as disulfoton and phorate—the phosphorodithioates.Since the rate of hydolysis increases with pH and temperature for disulfotonand phorate, it probably will do the same for cyanox.

Most organophosphorus pesticides used.currently are biodegradable and disappearrapidly from the soil [Kearney, et al., 1985].

SEVIN

Svnonvms and Trade Names ' _; ._ . .. -

Synonyms and trade names include Carbaryl, Bug Master, Cekubaryl, Crunch,Denapon, Devicarb, Dicarbam, Hexavin, Karbaspray, Septene, Tercyl, Tricarnam[FCH, 1989], Carbatox-60, Crag Sevin, ENT 23969, Karbaryl (Polish),experimental insecticide 7744 [Sax, 1984], OMS-29, Ravyon, Seffein [Windholz,1983], Arylam, Patrin, Murvin, and Carylderm [USDA, 1990].

Chemical Composition

Sevin belongs to the carbamate family. The chemical formula is C H NO ,resulting in a molecular weight of 201.24. The CAS number is 63-25-7. Thechemical structure is:

Physical State

The natural physical state of technical grade (99%) Sevin is solid whitecrystals. It is essentially odorless. Commercial formulations include aqueousdispersions, dusts and powders, baits, emulsifiable concentrations, granules,and suspensions in oil [FCH, 1989 and'USEPA, 1985a]. Both ground and aerialmethods of application are practiced [USEPA, 198Sa].

Chemical Properties - - - - - - -The following chemical properties apply to technical grade Sevin:

Property Value Reference

Density: 1.232 FCH, 1989Water Solubility: 40 ppm @ 30°C FCH, 1989

120 ppm 0 30°C • Windholz, 198399 mg/1 @ 20°C Nye, 1985100 ppm @ 20°C USDA, 199083 ppm @ 25°C USDA, 1990590 ppm @ 25°C USDA, 1990

Melting Point: 142°C FCH, 1989

12

flR300236

Boiling Point: —-—. ———Vapor Pressure:

C/Jff—t/)

'oo0.

(OCJ

•*-*fO•o03s-o>4)

LUa:cfl

(sAop) 3[AH NOIlVQVd03a

" flR300238

The EPA document Suspended, Cancelled, and Restricted Pesticides lists 80pesticides that have been suspended, cancelled, or restricted in their usebecause of the.ir toxicity. Sevin is not on the list.

Persistence .a'nd.J]£jjrada..tion , ; . „_,.". ..,-, ̂ , ..... .

Carbaryl is considered moderately persistent, with a half life in the range of30 to 99 days. It hydrolyzes rapidly under alkaline conditions [FCH, 1989].It is stable to heat, light, and acids, but is hydrolyzed in alkalis [Windholz,1983]. _ . - - - - - -

Carbaryl is slowly taken up into plants, after which it is metabolized. Thedisappearance of carbaryl residue from plant surfaces is attributed tomechanical attribution, volatilization and uptake into the plant.Photochemical degradation does not appear to be a factor. 1-Naphthol is themajor metabolite [USEPA, 19.85a].

Carbaryl is degraded by fungi. The soil fungi attack carbaryl by hydroxylationof the side chain and ring structure. Carbaryl is metabolized by pure andmixed cultures of bacteria; fungi, and to some extent by other soil and waterorganisms. The half-life appears to range from 7 to 28 days in aerobic andanaerobic soils, respectively [USEPA, 1985a].

Animals also degrade carbaryl. The chemica.1 is metabolized by hydrolysis andhydroxylation. The most prevalent products are 1-naphthyl glucuronide,1-naphthyl sulfate, and 4-hydroxycarbaryl glucuronide (USEPA, 1980).

Alkaline hydrolysis of carbaryl proceeds through the following reaction (TRWSystems, 1975):

The products of the hydrolysis reaction are 1-naphthol,'methyl amine,. andsodium carbonate. 1-Naphthol is unstable and degrades further to carbondioxide and other .products. The main product is a precipitate that is toxic tocertain estuarine species (TRW Systems, 1975).

15

AR300239

Hydrolysis of carbaryl is pH- and temperature-dependent. Table 3 belowillustrates this dependence. As with the other organophosphate pesticides, threaction proceeds more rapidly as the temperature and pH of the solutionincrease.

Table 3.Kinetic Data on Hydrolysis of Carbaryl (TRW Systems, 1975).

Ŵ ^̂ MĤ MM

PH

8.08.03.0

10.55410.95410.95410.954

1010109.89.59.29.0

• ' —

Temperaturefc)

^̂ ^̂ ^̂••••̂••fcMÎM

172028

3132333

12253525252525

»«^^BB^___M__

Ha If- 11 Co

115.2 hr84 hr24 hr

32 min11 min3.8 mfn1.4 min

99 min20 min8 mfn

27 rain58 min1)6 nin173 tain

Btmolecular Activationrate constant energyl/fmole.-uln) (caynote) Reference

100U° 2̂ .090 Karinen et al48460

24.269.1204 16,900 Aly and El-0(b49537

70340900430 19.390 Wauchope and Hague50300380400

The following hydrolysis and direct photolyis half-lives are reported [Ver-schueren, 1983]:

Hydrolysis Direct Photolysishalf-life half-life

SM — --- fdavs) _ fdavs)_____5 1,500 ' 6.67 15 6.69 0.15 — -, -

The half-life by bacterial biolysis is reported as greater than 30,000 days,assuming a bacterial population of 0.1 mg/1 [Verschueren, 1983].

Field studies determined that approximately 90% of the applied Sevin disappears(by a variety of mechanisms) from surface soils within a period ofapproximately 10 to 15 days [Kearney, et al., 1985].

16

AR3002W

Persistence in river water in a sealed glass jar, under sunlight and artificialflourescent light is reported as follows [Verschueren, 1983], for an initialconcentration of 10 ug/1:

Percent of Initial Compound Detected

after: I hour . . ...Lw.eek .,... t weeks 4 weeks 8 weeks

90 5. 0 0 0

Sevin does not bioaccumulate in mammalian tissue [Sax, 1984].

17

flR3002m

REFERENCES FOR PESTICIDE INFORMATION

ACGIH, 1989: American Conference of Governmental IndustrialHygienists, Threshold Limit Values and BiologicalExposure Indices for 1989-90, ACGIH, Cincinnati, 1989.

Dlllon, 1981: Dillon, A.P., Editor, Pesticide Disposal andDetoxification Processes and Techniques, Noyes DataCorporation, Park Ridge, NO, 1981.

FCH, 1989: Farm Chemicals Handbook, 75th Edition, MeisterPublishing Company, Willoughby, Ohio, 1989

Kearney, et al., 1985 Kearney, Philip C., Ralph G. Nash, and Charles S.Helling, Pesticide Degradation Properties, presented atthe National Workshop on Pesticide Waste Disposal,Denver, Colorado, January, 1985.

NFPA, 1978: 'National Fire Protection Association, Fire ProtectionGuide on Hazardous Materials, Seventh Edition, NFPA,Boston, 1978.

NIOSH, 1985: U.S. Department of Health and Human Services, NIOSHPocket Guide to Chemical Hazards, U.S. GovernmentPrinting Office, 1985.

Nye, 1985: Nye, John C.., Physical Treatment Options: Removal ofChemical from Wastewater by Adsorption, Filtrationand/or Coagulation, presented at the National Workshopon Pesticide Waste Disposal, Denver, Colorado, January,1985

RSC, 1989: _.__. Royal Society of Chemistry, The Agrochemicals Handbook,Second Edition, Cambridge, England, 1989.

Sax, 1984: Sax, N. Irving, Dangerous Properties of IndustrialMaterials, Sixth Edition, Van Nostrand Reinhold Company,New York, 1984.

Sims et al., 1988: Sims, R.C., W.J. Doucette, J.E. McLean, W.J. Grenney,and R.R. Dupont, Treatment Potential for 56 EPA ListedHazardous Chemicals, for the Robert S. KerrEnvironmental Research Laboratory, Ada, Oklahoma, 1988.

18

AR3002«f2

SRC, 1978: Syracuse Research Corporation, Center for ChemicalHazard Assessment, Identification and Description ofChemical Deactivation/Detoxification Methods for theSafe Disposal of Selected Pesticides, for the U.S.Environmental Protection Agency, Office of Solid Waste,Syracuse, NY, 1978. •

TRW Systems, 1975: TRW Systems, Inc., Handbook of Pesticide Disposal byCommon Chemical Methods, For the U.S. EnvironmentalProtection Agency, Office of Solid Waste ManagementPrograms, Washington, D.C., 1975.

USDA, 1990: U.S. Department of Agriculture, Agricultural ResearchInstitute, Pesticide Properties Database, Beltsville,MD, 1990.

USEPA, 1980: U.S. Environmental Protection Agency, Carbaryl: DecisionDocument, Office of Pesticide Programs, Washington,D.C., 1980.;

USEPA, 1984a: U,.S... Environmental Protection Agency, Fact Sheet Number43: Disulfoton, issued December 31, 1984. in PesticideFact Handbook (a compendium of U.S EPA issued pesticide

:._. fact sheets), Noyes Data Corporation, Park Ridge, NewJersey, 1988.

USEPA, 1984b: U.S. Environmental Protection Agency, Review of In-placeTreatment Techniques for Surface Soils, Cincinnati, OH,1984.

USEPA, 1984c: U.S. Environmental Protection Agency, Guidance forReregistration of Pesticide Products ContainingDisulfoton as the Active Ingredient, Office ofPesticides and Toxic Substances, Washington, D.C., 1984.

USEPA, 1984d: U.S. Environmental Protection Agency, Guidance forReregistration of Pesticide Products Containing Carbarylas the Active Ingredient, Office of Pesticides and ToxicSubstances, Washington, D.C., 1984.

USEPA, 1985a: U.S. Environmental Protection Agency, Fact Sheet Number21: Carbaryl, revised September 5, 1985. in PesticideFact Handbook (a compendium of U.S EPA issued pesticidefact sheets), Noyes Data Corporation, Park Ridge, NewJersey, 1988

19

USEPA, 1985b: U.S. Environmental Protection Agency, Fact "Sheet34.1: Phorate (Thimet), issued February 1, 1985. inPesticide Fact Handbook (a compendium of U.S EPA issuedpesticide fact sheets), Noyes Data Corporation, ParkRidge, New Jersey, 1988

USEPA, 1986: U.S. Environmental Protection Agency, Superfund PublicHealth Evaluation Manual, Office of Emergency andRemedial Response, Washington, D.C., 1986.

USEPA, 1988: U.S. Environmental Protection Agency, Guidance forReregistration of Pesticide Products Containing Phorateas the Active Ingredient, Office of Pesticides and ToxicSubstances, Washington, D.C., 1988.

USEPA, 1990: U.S. Environmental Protection Agency, Suspended,Cancelled, and Restricted Pesticides, Office ofPesticides and Toxic Substances, Washington, D.C., 1990.

Verschueren, 1983: , Verschueren, Karel, Handbook of Environmental Data onOrganic Chemicals, Second Edition, Van Nostrand ReinholdCompany, New York, 1983.

WERL, 1990: Water Engineering Research Laboratory (WERL),Treatability Database, Revision 2, USEPA, Cincinnati,Ohio, 11/6/90

Windholz, 1983: Windholz, Martha, Editor, The Merck Index, TenthEdition, Merck & Co., Inc., Rahway, NJ, 1983.

20

AR3Q02UI*

APPENDIX B

1. SUMMARY OF THE SCOPING SESSION

2. VDWH'S OCTOBER 24, 1990 LETTER AND THE CITY OF SUFFOLK'S RESPONSE OFJANUARY 11, 1991

COMMONWEALTH of VIRQINIADEPARTMENT OF WASTE MANAGEMENT

11th Floor, Monroe Building101 N. 14th Street

Richmond, VA 23219(804) 225-2667

November 22, 19S9

Mr. John L. Rows, Jr.City ManagerCity of SuffolkP.O. BOX 1S5SSuffolk, VA 23434

Re: Suffolk City Landfill-SiteSummary of Discussions DuringScoping Session

Dear Mr. Rowe:

Attached, please find a summary of the discussions during theScoping Session held on November 20, 1989, at our office inRichmond, VA. This summary of discussions should provideadditional guidance in the development of the RI/FS Work Plan. Ifyou have any questions or comments, please call me at (304) 225-3263.

Sincerely,

A.M. TopiProject Coordinator

cc: K.C DasAndrew Palestini, EPAPhillip Koren, Esq.Jonathan Horli

Anaderson, Esq.

Summary of Discussions During the RI/FS Scoping Session

Suffolk City Landfill

November 20, 1939

Introduction

The project coordinator for the Department of Waste Management(DWM) gave a brief introduction and stated the ' purpose of themeeting. , - .. ..

There was an overview of site area by John Rowe (City of Suffolk)and a statement of their committment to ensuring the protection ofhuman health and the environment.

In response to a question by SCS (contractor for the City ofSuffolk) A.M... Tope, the DWM project coordinator, stated that -hemajor issue at the site is the organophosphate pesticides.

There was discussion of flaws in earlier studies by the-City ofSuffolk, .and their attorney - those mentioned were demographicinformation and chemical analyses.

Several points were made by K.C. Das, Director of the SuperfundProgram, DWM: 1) the initial study results are not intended toanswer all questions - that is the purpose of the RI/FS, 2) costeffectiveness is only one consideration in remediation, and 3) anyremedial action should be geared towards permanence.

Details of. the RI/FS(Presented by Mike McLaughlin of .SCS, on beh'alf of the City of•Suffolk) . - - - -

It was pointed out that background considerations will be importantbecause of the major agricultural usage in the area and theoresence of several other potential sources of contamination nearthe landfill.

Geology of the area was briefly discussed. There is a clayconfining layer beneath the site but it will be necessary todetermine the exact depth and thickness of this layer at the site.SCS proposes to do this with a boring in a background location justto the west of the site. They expressed concern about boring•through the clay layer in the landfill area itself.

Groundwater is to be investigated by installing 5 wells on-site inaddition to the background. These wells will be located for themost part on the periphery of the site and not within the fillareas. At a later point in the presentation there was somediscussion of the proposed plan to locate a well near the allegeddisposal site of the pesticides. . Several people mentioned that it

flR3002l{7

would be very difficult to bore in this area and there may be apotential to penetrate any liner present, therefore potentiallyfacilitating migration.

Surface water will be tested by taking two rounds (wet .and dryseasons) of S samples. Sediments will only be sampled in oneround. Two samples are to be taken upgradient of the site and therest in downgradient locations or on-site. Alyce Fritz of NOAAexpressed concern that depositional areas may not be sampled withthe suggested plan.

Other possible sources on-site are to be investigated by soilsampling. These will be determined by interviews, temporalconsiderations, and other information that comes to light in thestudy.

Groundwater levels in monitoring wells will be measured monthly todetermine groundwater flow direction. Stream flows will beestimated to aid in determining a hydrologic budget for the site.

A question was raised about why there were no deep wells plannedin the study. SCS argued that it was unnecessary because they feltthey could get some information from previous studies, and in anycase the lower aquifers are artesian, therefore they are unlikelyto be contaminated by the site.

Response to .RI/TS Plan bv DWM and Further Discussion

DWM felt that more soil sampling was needed to fully characterizethe problem and strongly suggested that this be incorporated intothe work plan. DWM suggested the use of test pits or borings asmeans to do this. SCS responded that they believe this would onlyresult in digging up garbage. It was agreed that some focused soilsampling could be considered such -as the alleged pesticide disposalarea and any cells at the landfill that were open during the timewhen the dumping may have occured, or where there is some suspicionthat pesticides may be buried.

EPA and DWM expressed concerns about proposed locations ofmonitoring wells. EPA also suggested additional wells to definesite-specific hydrogeologic conditions in the area.

DWM suggested additional on-site and off-site surface watersampling including leachate, retention basin, retention pond, andstreams.

SCS proposed a modification of full CLP protocol. They do not wantto obtain printouts of all QA/QC data from the contractedlaboratory due to the cost (although it would still be availableupon request) , DWM and/or EPA would recieve the QA/QC data for apercentage of samples for review, to be chosen in any manner wewish. All sample results will still undergo validation by thecontracted laboratory. DWM agreed to consider this request. I

SR3Q02U8

SCS stated that the analytical parameters to be tested include allTarget Compound List/Target Analyte List parameters except acidextractable organics. It also includes organophosphate pesticidesby the appropriate SW-846 method. Cyanox will not be measured bythis method, however it will be estimed by cyanide measunnents.

SCS requested that they only take filtered samples for metals 'ingroundwater. DWM agreed to consider.

SCS did not propose to take any homewell samples, based on recentconfirmatory sampling_ which showed no contamination. DWM expressedsome reservations about this.

Miscellaneous Topics

DWM discussed specific activities to be conducted at the SuffolkCity Landfill site during the RI/FS (Appendix C,. Guidance forConducting RI/FS •under CERCLA, EPA/540/G-89/Q04, October 1988).They include project plans, community relations, fieldinvestigations, sample analysis/validation, data evaluation, riskassessment, treatability studies (if any), RI reporting, remedialalternatives development and screening, detailed analysis ofalternatives, and FS reporting.

DWM discussed the deliverables that will be a part of this project.

In accordance with the AOC, the work plan is due by December 20,1989. SCS, on behalf of the City, requested extension of the duedate of the work plan to January 10, 1990. DWM requested.a writtenrequest from the City seeking such extension.

The time needed for the project was estimated to be 18 months bySCS and the city of Suffolk.

8R300249

RECEIVED OCT 2 9 1930

COMMONWEALTH of VIRGINIADEPARTMENT OF WASTE MANAGEMENT

11th Floor, Monroe Building101 N. 14th Street

Richmond, VA23219(804)725-2667

October 24, 1990

Mr. John L. Rowe, Jr.City ManagerCity of SuffolkP. O. Box 1853Suffolk, Virginia 23434

Re: RI/FS Work PlanSuffolk City LandfillHosier Road Landfill NPL Site . ,

Dear Mr. Rowe:

The Virginia Department of Waste Management (VDWM) hascompleted its review of the following documents prepared for theCity of Suffolk by SCS Engineering (SCS) and received by theDepartment May 4, 1990:

1. Work and Quality Assurance Plan for the RemedialInvestigation and Feasibility Study at the Hosier RoadLandfill

2. Memorandum of Preliminary Remedial Action Objectives andAlternatives

3. Quality Assurance Supplement for the Hosier Road RemedialInvestigation and Feasibility Study

4. Health and Safety Plan for Field Activities, RemedialInvestigation/Feasibility Study, Hosier Road Landfill-,Suffolk, Virginia.

They will hereinafter be -referred to as the Work Plan.

As discussed at the September 25, 1990, meeting, many of thecomments to follow stem from a mis-communication which resulted inchanges being agreed to by letter without having the actual wordingof the work plan changed to reflect the changes or to clarify theissues.

Since this is the second review of the documents, and as it

flR300250

John L. Rowe, Jr.Page 2

is in our mutual best interests to approve the work pi an andinitiate implementation of the remedial investigation, it isrequested that all responses (changes to the work plan) bereferenced by page number and.be italicized or otherwise marked toassist in the review of the document. If there are items in ourcomments to which you have an objection, please telephone me at(804) 225-3263 to discuss the matter prior to submitting yourwritten response.

The Department's comments are listed below in the order aspresented in the May 2, 1990, memorandum to Mark H. Woodward fromMichael Me Laughlin of SCS:

WORK AND QUALITY -ASSURANCE PLAN:

GENERAL:

1. The" reorganization of the Work Plan/Quality Assurance Planmakes it easier to locate the data quality objectives andcriteria.

SITE DESCRIPTION AND BACKGROUND;

LOCATION, OWNERSHIP, HISTORY (pages 2-1 through 2-8)

2. -Removal of the reference to "normal conditions" issatis factory.

3. Deletion of the paragraph comparing the land application rateof the material if it were to be used as a pesticide versusthe quantities disposed in the landfill is satisfactory.Since the hazards associated with the use of a commercialchemical product depend upon the use of proper managementprocedures, the associated hazards vary by application andcannot be adequately compared to the hazard potential ofexposure resulting from mismanagement of the waste material.

4. Please include a statement (s) in the Work Plan that statesthat the areas of the landfill where municipal waste wasplaced using the trench and fill method will be clearlydelineated on a map 6~f the site* Also, include similarstatements for areas where filling and compaction occurred inlifts above grade, being certain to include references tosupplemental diagrams of the cross sections of both thetrenches and the lifts.

5. Please "include specific wording in the Work Plan describingthe efforts which have taken place to solicit information

AR30025


regarding additional chemicals and/or pesticides which mayhave been disposed in the landfill. Such statements shouldinclude the contacts made to date, the information obtainedfrom each contact even if it did not prove fruitful, and anyother sources of information which can be identified at thistime as being a source worthy of further pursuit.

6. Inclusion of a reference to Appendix D of the Health andSafety Plan for technical data on the pesticides issatisfactory. It is commendable to eliminate redundancywherever possible.

GEOLOGY AND HYRDOGEOLOGY: (pages 2-8 through 2-15)

7. The modification of Figure 2-3 to show the approximatelocation of the Hosier Road Landfill is satisfactory. Pleaseinclude a statement in the Work Plan stating that the Sitehydrogeology will be shown in a cross sectional plan once thedata has been collected during the -RI sampling phase.

8. Please include a statement in the Work Plan stating that thelithologic and hydraulic properties of all sediments aboveth© Yorktown confining unit will be characterized at the siteand that diagrams will be developed to show the locations ofthese formations with respect to the Landfill.

PREVIOUS INVESTIGATIONS: (pages 2-15 through 2-17)

9. Enclosed, please find a copy of the NUS*January 9, 1987, fieldtrip report. This report states that the site was sampled fordisulfoton,, cyanophos, phorotoxon, and phorate sulfoxide.Both disulfoton and cyanophos were detected. Please refer tothis report and revise this section accordingly.

10. See 9 above.

11. Wording as provided is acceptable.

12. Please include the analytical results from the split samplesobtained by the City including any qualifying factors such asexceeds holding times or insufficient recovery of the spikeetc. Describe these results in the text of the Work Plan andcompare them to their "splits" in a table.

13. Please include statements in the Work Plan that figures willbe developed which show:

a. the topography of the Site (existing),

b. locations of all seeps,

AR300252


c. surface hydrology showing both natural and constructed. = drainage corridors,

d. a legend showing which streams are perennial and whichare intermittent,

e. the location of the confluence of all streams and ditchesin relation to the Pocosin Swamp,

f. the location of the perforated pipe which runs beneaththe fill and collects/carries leachate from the westernportion of the landfill to the retention basin,

g. the location and name of the stream positioned'approximately 3/4 of a mile south of the Site,

h. the locations of all drainage diversion ditches andsimilar structures,

i. 'the locations of the to-be-installed leachate collectionpiping, and

j. the location of the landfill cells including thepesticide disposal area. These cells/trenches/liftsshould be distinguished by type using different crosshatch or shading techniques.

14. Please include tables of all available data including the NUSreports, and the two TAT team reports. Include the samplingdate on each table. Where split samples were analyzed, pleaseindicate the pairs.

15. The rainfall data as presented is acceptable,

PROJECT. DESCRIPTION;

OBJECTIVES: (pages 3-1 through 3-3)

16. The wording as provided is acceptable in reference to theU. S. Fish and Wildlife Service participation in thedevelopment of the Work Plan.

17. We were unable to locate the attachment containing the summaryof the RI/FS scoping session discussion held 11/20/89. Pleaseprovide a copy and a reference as to its location in the nextrevision of the Work Plan.

SCOPE OF WORK: (pages 3-3 through 3-17)

/JR300253


18. The wording change from "feasibility" to "implementability11is satisfactory.

Task 3:

19. Addition of the appropriate objectives to this section issatis factory.

20. The Department is allowing slug tests to be performed on themonitoring wells in lieu of pump tests as a concession to thebudget constraints of Suffolk City. Please be advised thatit may be found necessary to perform pump tests at a laterdate in order to evaluate the feasibility of variousgroundwater remediation techniques.

21. The wording describing the acquisition of additionalgroundwater data is acceptable.

22. Please state in the Work Plan the sources to be searched tolocate previous groundwater monitoring data in the area.Please state that this data will be included in the RI andthat if the data is deemed not to be valid or reliable it willstill be included via appendix with the reasoning forinvalidating the data clearly presented.

23. Adding a statement that home wells down gradient of the sitewill be sampled immediately upon detecting pesticides inmonitoring wells is satisfactory.

24. The Work Plan must identify the sources to be searched toidentify the exact locations of the pesticide disposaltrenches and the area(s) in the landfill where pesticides weredisposed. It must also identify any other potential sourcesof hazardous constituents. Such information could be obtainedby researching the files and contacting entities which mayhave disposed of potentially hazardous materials at the Site.

24a. In addition the Work Plan must state that six continuous splitspoon soil boring samples will be obtained in the vicinity ofthe pesticide disposal trenches. Two of these samples willbe obtained within the central area of the trenches, and theother four will be obtained from locations 5 to 15 feet fromeach side of the assumed disposal site. Each soil boring willgo to a depth of 10 feet or until subsurface waters arecontacted, whichever is less. The borings will be visuallyinspected and a sample will be obtained from the area wherevisual contamination can be determined and at three to fivefeet below this level. If visible contamination is not

AR30025U

John L. Rowe, Jr.Page 6 • . -

observed and another indication such as changes from disturbedto undisturbed soils can be detected, samples shall ' beobtained just above the interface and three to five feet belowthe interface. If no interface is observed, samples shall beobtained at depths of six and ten feet. The sampling shallbegin in the area of most likely contamination and proceeduntil a sample showing visible signs of contamination isobtained or until .all six soil borings have been completed.If "trash" is encountered in the boring process, that samplinglocation will be omitted.

All of these samples will be analyzed for organophosphoruspesticides and for Cyanox as per methods already discussed inthis letter.

The exact sampling locations and samples to be obtained willbe determined at the site by the VDWM project coordinatorafter consultation with the City's contractor. This changefrom the tentative agreement made at the September 25thmeeting has been made based upon information obtained from theTAT team officer(s) that sampling in the area of the assumedpesticide disposal trenches did not go below 3 feet in depth.This information was confirmed by telephone discussion withMr. Jim Wilcox of Weston. The power auger had a maximum depthcapacity of three feet at the time the sampling took place.He did not know any thing about an extension being used to

- sample to depths of five feet. A copy of the two TAT teamreports are included for your reference.

Please revise the Work Plan to include all of the activitiesaddressed in this item.

Task 5:

25. The wording as provided is acceptable.

26. The wording as provided is acceptable.

27. It is unclear as to why discussion of the water budget wasdeleted from this section of the Work Plan rather thanmodified to incorporate the comments of the April 4, 1990,notice of deficiency. Please address this in your responsecover letter.

28. Updating the Work Plan to include references to the mostcurrent revision of the appropriate guidance documents issatisfactory.

29. Please add statements to the Work Plan indicating what fieldoperations are to take place to identify receptors (such field

flR300255


operations might identify the locations where the benthicsurveys are to take place, etc.) and what documents are to besearched and contacts investigated to assist in identifyingall potential receptors.

29a. Please add statements to the Work Plan requiring physicalproperties of the habitats such as the depth and width of allstreams/channels, the substrates, and the volume of flow.

30. Please identify the literature and other sources which hasand/or will be searched to assist in identifying allpesticides and other hazardous contaminants, organophosphateand otherwise, and their physical properties, hazardpotential, treatability, persistence and biodegradationproducts which may be present at the site.

Task 6:

31. The update of the Work Plan to reflect the current NCP issatisfactory.

32. Please change the last sentence on page 3-17 to eliminate anyreference' to a recommendation of a remedial actionalternative. This recommendation will come only after VDWMand EPA have reviewed the data provided in the RI/FS andevaluated it using the criteria in the NCP. In order toprevent bias in the decision making process it is imperative.that a recommendation not be made during the RI/FS process.

33. Inclusion of the no action alternative in the Work Plan hasbeen satisfactorily done.

3 4, Please include a statement in the Work Plan that noalternative treatment technologies or resource recoverytechnologies appear germane to the Site at this time andprovide a basis for this statement. Also state if suchtechnologies later appear potentially applicable at the Site,they will be addressed in the FS.

PROJECT SCHEDULE: (pages 3-18 through 3-21)

35. Please state in the Work Plan that all sampling data will beprovided to the VDWM immediately following laboratory and SCSdata validation or earlier upon request by the VDWM. Pleasealso specify at what period of time relative to approval ofthe work plan that this data will be provided to VDWM for eachround of sampling.

36. Please ravise the wording on page 3-19, Task 3 to reflect thatthe months of May, June and September are also acceptable

• flR300256


• sampling months. Also note that the year must be changed to1991. - - -

37. The summary of the project schedule is acceptable in the formof a Gant Chart. Please be certain to make the appropriatemodifications to this chart as indicated elsewhere in thisletter.

38. Please change the first sentence of page 3-20 to state thatthe final Remedial Investigation and Baseline Risk AssessmentReports will be submitted to "VDWM within 30 days of receiptof the latter of: 1) the written comments from VDWM on thePreliminary Report, or 2) the written comments from VDWMfollowing a meeting requested by the City of Suffolk todiscuss the initial set of VDWM comments.

39. Two copies of each deliverable must be sent both to EPAto VDWM when the submittal is made. Please state this in theWork Plan.

40. The PRAOA has been received.

PROJECT ORGANIZATION AND RESPONSIBILITIES (pages 4-1 through 4-4_

41. The reference to the appropriate companies on Table 4-1 isacceptable.

42. The name of the person representing EEI on Figure 4-1 isacceptable as presented.

43. Inclusion of the areas of responsibilities for your juniorstaff in this section is acceptable.

FIELD OPERATIONS (pages 6-1 through 6-12)

44. Please include statements in the Work Plan indicating that allmonitoring wells shall be placed so as to avoid boring throughtrash, and that the exact locations of the wells are subjectto the on-site approval of the VDWM project coordinator.

44a, Please revise Figure 6-1 to reflect the modified monitoringwell locations agreed to during the September 25, 1990,meeting.

44b. After discussion with the VDWM staff it has been decided thatthe approximate locations of the surface water/sedimentsampling sites shall be in the approximate locations of

flR30Q257


(1 through 5) the current HRS-1, HRS-2, HRS-3, HRS-4, HRS-6

(6) and include a sampling point on unnamed stream S justprior to the confluence with unnamed stream N,

(7) at the bottom of the drainage diversion ditch near HRS-2at'the Retention Pond (the current figure 6-1 does not showthe drainage diversion d^tch around the retention pond),

(8) after the filter at the discharge of the retention Basin,

(9) from the drainage ditch south of the pesticide disposaltrench,

(10) near the entrance to the Retention Basin,

(11 through 13) and at three leachate seeps whose locationsare to be identified by the VDWM project coordinator on-site.

This results in a total of 13 surface water/sediment samplingsites". The exact locations of all sampling sites shall beapproved by the VDWM project coordinator at the time ofsampling. Due to unforseen conditions the locations of thesampling sites may change but the number of 'samples to beobtained will not change for the Phase I sampling.

45. The Work Plan must state that all samples from the monitoringwells will be tested both filtered and unfiltered forinorganics. This data will be used in the risk assessment.

46. Please state the sampling and analytical methods to be usedin determining if the drummed wastes generated during wel1cutting and purging activities are hazardous wastes. Alsoplease identify the alternate management and disposal methodswhich will be used to comply with either the VirginiaHazardous Waste Management Regulations (VHWMR) or the VirginiaSolid Waste Management Regulations (VSWMR) as appropriate.

47. Please include a statement in the Work Plan that asappropriate materials are encountered during the RI, sampleswill be collected for Total Organic Carbon (TOC) analysis.

48. Please include statements in the Work Plan to the effect thatall sediment samples will be obtained in calm areas where themajority of the sediments would be expected to collect andthat surface water samples will be taken so as to reflect thehighest concentrations of contaminants.

49. The wording as provided in the last sentence of page 6-4 is

AR300258


acceptable.'

50. Please include a statement in the Work Plan that allmonitoring wells will be installed in accordance with TEGD,Chapter 3. Where this is not to be done, please provide adetailed explanation as to the reasoning behind and need foran alternate design and installation.

51. Please see the Department's comments in items 24, 24a, 44,44a, and 44b above. We have noted your reluctance to performadditional sampling in the vicinity of the assumed pesticidedisposal area since the TAT team has already sampled thislocation. However, the Department does not find that theproposed sampling locations and number of sampling locationsproposed will provide sufficient data to adequately identifythe presence or -absence and likely source of hazardousmaterials at the Site. Please be advised that based upon theinformation currently available with respect to the site, alesser number of samples would not be acceptable to theDepartment.

52. Please modify the second paragraph of page 6-11 to indicatethat sediment samples shall be taken to a depth of six inchesunless otherwise approved by the VDWM project coordinator on-site.

53. Please state in the Work Plan that all non-detects will bereported as per Risk Assessment Guidance for Superfund and theEPA Region III guidance. Where "other rules" are to be used,state the values as per the guidance as well as the rationalebehind the use of the "other rule". A statement to the effectof the preceding sentence must be included in the Work Planor all reference to "other rules" must be eliminated.

54. Please modify the Work Plan to include analyses for hardnessand pH. The hardness value directly affects the impact ofvarious inorganic constituents on aquatic life. TheDepartment has agreed to waive the requirement for .totalsuspended solids testing since the City chooses not to performthis test which could indicate that the presence of heavymetals in the surface water samples are associated withparticles, not solubilized and are less likely to adverselyimpact aquatic life.

55. See item 24a of this letter. The pesticide disposal area hasnot been adequately investigated. The information which wasprovided by SCS that the soil samples in the vicinity of theassumed pesticide disposal area were obtained at depths offive to six feet is incorrect. The deepest samples wereobtained at three feet below grade.

AR30G259


56. The pesticide Sevin (Carbaryl) has reportedly been disposedat the Site. This is a carbamate pesticide and will requirean additional analytical method (it is not measured withMethod 8140).

56a. The. detection limits in Table 8-1 are not low enough todetermine whether there are any adverse impacts to aquaticlife. Please modify the Work Plan to use SW-846 Method # 8141as it has lower Practical Quantitation Limits (PQL's) thanMethod £ 8140 for the compounds in question.

56b. Also, as of this point in time, we have been unable todetermine if either of these methods detect the disulfotondegradation products, disulfoton sulfoxide and disulfotonsulfone, as disulfoton. Please be certain that the analyticalmethods used either include the degradation products with thedisulfoton or detect and report them separately.

56c. Please modify the Work Plan to reference the analytical methodnumber to be used and the EPA publication in which it iscontained. Each constituent should be identified as well asthe method number and PQL.

56d. Cyanox is not included in either Method # 8140 or # 8141. Canits environmental concentrations be estimated by cyanidelevels? If so, please provide documentation of the technicalbasis for such a decision and a full discussion of theassociated uncertainties and assumptions in the Work Plan.If not, please provide an analytical method for detectingcyanox in the environment and its associated PQL in the WorkPlan and include a copy of the method for reference.

57. Please modify the Work Plan to identify seep locations. Then,identify those seep locations which should be sampled andprovide the rationale behind their selection. Please includea table of the locations and a brief description of the sourcearea for each seep in the Work Plan, state in the Work Planthat all seep sampling will take place in the spring.

58. See item f 4 above.

59. Please state the diameter of the concrete apron to beinstalled around each monitoring well in the Work Plan. Notethat a minimum of three feet is acceptable.

60. Figure 6-1 is satisfactory.

61. Please include a statement in the Work Plan that bailer cordswill not be allowed to contact the ground prior to sampling

flR300260

O

John L. Rowe, Jr.Page 12 _..-

and that clean cords be used for each set of samples at eachwell.

MEMORANDUM OF PRELIMINARY REMEDIAL ACTIONOBJECTIVES AND ALTERNATIVES fPRAOAi

PRELIMINARY OBJECTIVES: (pages 2-1 through 2-2)

62. The requested change has been adequately addressed.

63. This section has been adequately relabeled.

64. Please cite all references used in identifying and complyingwith ARARs and also identify which were used in developingthis section.

65. Please include a statement that Federal and state criteria,advisories, guidances, and local ordinances will be consideredin developing the remedial action alternatives.

66. Page 2-2 is missing from the copy of the PRAOA submitted tothe Department. Please be certain that item # 66 of the April4, 1990 letter is adequately addressed in the revised copy tobe submitted. Based upon what is currently in this section,it does not appear that the contaminants of concern or the.receptors have been clearly identified, nor have theacceptable contaminant levels for each exposure route beenaddressed.

POTENTIAL REMEDIAL ALTERNATIVES:

67. Reorganization of the PRAOA has been completed as instructed.

68. Tables 3-1, 3-2 and 3-3 are referenced in your letter but aremissing from the PRAOA. Please submit a complete revisedcopy. If Tables 4-1 through 4-3 are the tables in question,then no column indicating environmental media is present asrequested in the April 4, 1990 letter.

69. See item #68 above. Please include a statement in the PRAOAindicating that the data requirements necessary to evaluatethe various remedial action options will be obtained once theextent of contamination becomes more apparent.

.70. No further comment.

71. Ingestion of surface soils has been included among thepathways for exposure.

flR30026l

*̂wfcnis '' ". 11260 Roger Bacon Or --^-^- ^C3 J"--4'50Seston.VA 2209Q ._ =..".- 5M "Cj'̂ '-

SCS ENGINEERS

January 11, 1991File No. 289099-04

Mr. Khoa NguyenVirginia Department of Waste ManagementMonroe Building, llth Floor101 North 14th StreetRichmond, VA 23219

Mr. Andrew PalestiniU.S. Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Subject: Submission of the RI/FS Work Plan/Quality Assurance Plan and RelatedDocuments, Hosier Road Landfill RI/FS

Gentlemen:

On behalf of the City of Suffolk, we are pleased to submit two copies each ofthe Work and Quality Assurance Plan (with Appendices) and the Memorandum ofPreliminary Remedial Action Objectives and Alternatives (PRAOA). Theinformation in the Quality Assurance Supplement (previously submitted) hasbeen incorporated in the Work and Quality Assurance Plan, eliminating theSupplement document. All comments on the Health and Safety Plan have beenpreviously resolved, so that document is not enclosed.

The enclosed documents are the result of extensive discussions between theCity, its advisors, the Department, and the Agency. The approach described inthe Work and Quality Assurance Plan represents a consensus between allinterested parties. Formal comments on the earlier draft were provided byletter dated October 24, 1990 from Ms. Wilcox of the Virginia Department ofWaste Management; other comments were provided by a VDWM memorandum of June 1,1990 by Glenn Metzler and a U.S. EPA memorandum of July 31 by AndrewPalestine

We understand that the October 24 letter by Ms. Wilcox summarizes all thesignificant outstanding concerns at that time. To assist you in your reviewof the changes made in the enclosed documents, we provide below a response toeach of the 85 comments in Ms. Wilcox's letter. Many of the 85 comments wereto the effect that the Department agreed with previous changes made to theWork Plan, thus indicating that the issue was resolved in the previous draft.

The responses to the October 24 letter are:

1. Issue resolved in draft; document reflects this comment.


Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991Page 2.

3. Concur. A comparison of the amount of pesticides disposed comparedto that which would be applied in normal agricultural practice isInstructive but more appropriate in an RI Report than in a Work Plan.The discussion about the associated hazards thus becomes moot.

4. Concur. Page 2-2, line 11.




8. Concur. Page 2-25,. line 2.

9. Concur. Page 2-29, paragraph 3.

10. See 9 above.


12. Concur. Page 2-36, line 1 and table 2-8.


14. Concur. Tables 2-3 through 2-7.


16. Issue resolved 1n draft; document reflects this comment.

17. Concur. Appendix B.





22. Concur with modifications. The sources to be searched are given onpage 3-10, last paragraph. As agreed in a telephone conversationwith Ms. Wilcox on November 5, 1990, all data will be summarized butonly the valid, reliable data will be given in detail; criteria forvalidity and reliability will be given. Thus, possibly large amountsof useless information need not be copied.


24. Concur. Page 2-10, line 1 and page 2-3, bullet 7.

flR300265


24a The sampling plan proposed by VDWM on December 17 and incorporated inthis Work Plan obviates the need for soil sampling in the pesticidedisposal area.



27. Concur. We prefer to remain silent on the matter of a water budgetin the Work Plan rather than to promise to perform an activity whichmay be unnecessary or require a drastic increase in effort to attaindata for a defensible budget. If the results of the fieldinvestigation would be better interpreted by means of a water budgetand if the necessary data (e.g., streamflow values,evapotranspiration and infiltration rates) can be collected to thedegree .required, a water budget may be calculated.


29. Concur. Page 3-15, line 13 to page 3-17, paragraph 4.

29a Concur. Page 3-17, line 3.

30. Concur. Appendix A summarizes the physical/chemical properties anddegradation of pesticides reportedly disposed at the site.


32. Concur with reservations. A recommendation of a remedial actionalternative will not be submitted as part of the Feasibility StudyReport. However, the City reserves its right to request a separatereport from its contractor which will recommend a remedial actionalternative based on the RI/FS investigation.


34. Concur. Page 3-22, paragraph 2.

35. Concur with modifications. Page 3-27 and Project Schedule, page3-23. The analytical data will not be submitted to VDWM until it hasbeen validated. The validation will be done expeditiously as shownby the schedule. Data will not be submitted before validation inorder to prevent needless concern by the public.

36. This comment has been obviated by finding detailed groundwater levelrecords for a monitoring well near the site (see page 2-23 and Figure2-4). The project schedule reflects this direct information ratherthan the indirect information from precipitation alone.

37. Concur. Figures 3-2 and 3-3.

flR300266

Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991 • •Page 4. , -

38. The project schedule reflects a 45 day period for submission of Rland FS Reports after receipt of VDWM's comments or a meeting con-cerning those comments. This time period has been agreed upon by allbecause of the need for the City Council to meet and approve thefinal reports.

39. Concur. Page 3-27, paragraph 2 and page 3-30, last line.40. The revised PRAOA also is included in this submission.





44a. Concur with updating to reflect the latest monitoring welllocations proposed by VDWM on December 17, 1990.

b.. Table 6-3 and Figure 6-1 show the surface water/sediment samplingsites proposed by VDWM on December 17,1990.

45. Concur. Page 6-17, paragraph 2.46. Concur. Page 6-13, paragraph 4,

47. Concur. Page 6-22, last paragraph and Table 6-5.48. Concur. Page 6-22, paragraphs 3 and 4.

50. Concur. Page 6-5, last paragraph.51. Noted^ This comment_no longer pertains because the sampling

locations agreed upon are those proposed by VDWM.

52. Concur. Page 6-22, last paragraph.

53. Concur. Page 3-14, first bullet.

54. Concur. Tables 6-2, 6-4, and 6-5.

55. See 24a above.56. Concur. The High Performance Liquid Chromatography methods listed in

Tables 6-2 and 6-4 are more sensitive than the colorimetric methodproposed earlier and thus are the ones selected.

56a Concur. Tables 6-2, 6-4, and 8-1.

AR3Q0267

Mr. Knot NguyenMr. Andrew Palestinl . .._ . .January 11, 1991Page 5.

56b Concur. A note in Table 8-1 indicates that the breakdown products-will be detected and quantified separately. Standards for thebreakdown products have been located.

c Concur. Tables 6-2, 6-4, and 8-1.

d Concur with modification. Cyanox can be analyzed by either EPAmethod 8140 or 8141 if a standard 1s available. The General PhysicsLaboratory has made arrangements to obtain such a standard from USEPA Chemical Standards Repository in Research Triangle Park, NorthCarolina. Method 8141 will be employed. This method is described inTest Methods for Evaluating Solid Waste, Physical/ Chemical Methods -Third Edition Proposed Update Package, U.S. EPA PB89-148076. 1989.The PQL's are currently not documented in the record but will bedetermined by method detection limit studies as part of the analysesand reported with them.

57. Concur with modifications because of the new sampling plan.' Allseeps will be located (Page 2-6, bullet 2); source areas will beidentified at that time. We intend to do this in the spring byupdating the map of seep locations that is part of the TemporaryLeachate Collection Plan. A copy of that Plan was previously sent toVDWM. One seep is to be sampled (sample HRS-10E in Table 6-5) andthis will be done in the spring.

58. See 4 above.




62. Issue resolved in draft; document reflects this comment.63. Issue resolved in draft; document reflects this comment.

64. Concur. Page 3-1 of the PRAOA, paragraph 2.

65. Concur. Page 4-1 of the PRAOA, line 4.66. Concur with exception to the last sentence. Page 2-2 (Figure 2-1) Is

Included. A major purpose of the RI is to actually identify thecontaminants of concern, the receptors, and the acceptablecontaminant levels (by risk assessment where no standards currentlyexist). This is stated on page 2-4 Of the PRAOA.

67. Issue resolved in draft; document reflects this comment.68. Concur. Tables 4-1 through 4-3 are the tables in question.

Environmental media are now explicit in column 1 of Table 4-1; theyare Implicit in the titles of Tables 4-2 and 4-3.

SR300268


69. Concur. .Page 4-7, line 16.

70. Issue resolved in draft; document reflects this comment.' •






76. Concur. Page 3-13, paragraph 2 ff.




80. Issue resolved In draft; document reflects this comment.81. Noted.

82. Concur. Table 6-5 on pages 6-26 and 6-27.

83. Concur. Page 3-12, last paragraph.

84. Concur., Project Schedule subsection,, page 3-23 ff. Validation oflaboratory data will be the responsibility of SCS Engineers. Thecomplete laboratory deliverable documents which will be used tovalidate the data will be submitted upon request only (page 3-30,line 5).


Section 3 of the Work and Quality Assurance Plan provides alternate schedulesfor completion of the RI/FS. The Department previously has indicated that itplans to promptly approve the Work and Quality Assurance Plan; if formalapproval is provided by January 28, then field work can begin in February.

flR300269


If you have any questions of a minor or technical nature, please telephoneus. Any other questions or comments should be addressed to Mr. ThomasUnderwood, the new Project Coordinator for the City of Suffolk.

Very truly yours,

RoWrt W. Luce, PhD, CPG Michael W. McLaughlin, PEProject Manager Project DirectorSCS ENGINEERS SCS ENGINEERS

RWL/jwg

Enclosures

cc: T.G. UnderwoodM.H. WoodwardW.A. Anderson, II, Esq.A.T. Ellis

SR300270

Company "resume'S~cron"taihed ."on pages 300271-300355have been removed,, - '

APPENDIX E

FIELD INSTRUMENT OPERATIONMANUALS FOR CALIBRATION

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APPENDIX F

GP ENVIRONMENTAL SERVICES, INC.(FORMERLY JTC ENVIRONMENTAL CONSULTANTS, INC.)

LABORATORY QUALITY ASSURANCE/QUALITY CONTROL MANUAL

RR3QQ369

copy v * w of 75

JTC ENVIRONMENTAL CONSULTANTS, INC.

LABORATORY QUALITY ASSURANCE/

QUALITY CONTROL MANUAL

REVISED AND APPROVED BY

QUALITY CONTROL OFFICER

JOHN T. COOKSON,

AR300370

JTC QA/QC MANUAL

Table of Contents

EAOEI. INTRODUCTION 1

A. QA/QC Objectives 1

B. Policy Statement 1

C. Scope and Approach 1

II. LABORATORY ORGANIZATION AND PERSONNEL 2

A. Overview 2

B. Roles and Responsibilities 2

C. Assignment of Responsibilities 3

D* Personnel Qualifications 6

III. GENERAL QA/QC PROGRAM 8

A. Program Requirements 8

B. Data Requirements . 8

C. ""Program Goal 9

IV. GUIDELINES FOR QA/QC PROCEDURES 10

A. . Baseline Laboratory Assurance 10

B. Sample Handling Assurance 13

C. Analytical Methods Assurance 17

D. Data Handling Assurance 22

9R30037

JTC QA/QC MANUAL

Table of Contents (cont'd.)

V. QUALITY CONTROL DOCUMENTATIONAND CONTROL CHARTS 24

VI. MANAGEMENT OF OUT-OF-CONTROL EVENTS 25

A. Definition of Out-of-Control Events . 25

B. Responsibilities and Procedures forResponding to an Out-of-Control Event 27

C. Documentation of Out-of-Control Events 31

D* Corrective Action 34

E. Examples of an Out-of-Control-Event ' 35

VII. SAMPLE COLLECTION ' 37

VIII. FACILITIES, EQUIPMENT, AND SUPPLIES 38

A. Facilities 38

B. Equipment _ 39

C. Supplies 39

IX. DATA GENERATION 40

A* Quality Assurance Modification 40

5. Standard Operating Procedures 40

C. QA/QC Plan Review and Approval 42

X. DATA PROCESSING 43

A. Collection . . ... . ._ 43

-ill- flR'300372

--— JTC QA/QC MANUAL

Table of Contents (cont'd.)

PAGE

X. B. Validation " 43

C. Storage 44

D. Transfer , 44

E. - Reduction 44

XI. REFERENCES 46

APPENDIX A

Tables 1 through 5

APPENDIX B

Quality Control,Forms used for Inorganic and OrganicAnalyses

APPENDIX C

Generation and Use of Control Charts

APPENDIX D

Tables of Content for Individual SOP's

flR300373-iv-

JTC QA/QC MANUAL

List of Figures

FIGURE ' PAGE

1 JTC Organization Structure 4

2 Chain-of-Custody Record 14

3 Sample Receipt Form . 15

4 Sample Checkout Log 16

5 Sample Disposal Log 17a

6 Management of Out-of-Control Events 28

7 Quality Control **S~ituation Alert** 32

BR30037U-V-

JTC ENVIRONMENTAL CONSULTANTS, INC.

LABORATORY QUALITY ASSURANCE/QUALITY CONTROL MANUAL

I. INTRODUCTION

This document describes the Quality Assurance/QualityControl (QA/QC) Plan for analytical services performed by JTCEnvironmental Consultants, Inc. (JTC). This plan is designed toensure that quality data are generated for all JTC clients.Items addressed by the plan include personnel responsibilities,sampling, chain-of-custody, laboratory operations, analyticalmethods, data handling, quality control charts, management ofout-of-control situations, and standard operating procedures.

A. QA/QC Objectives

The objective of the QA/QC program is to assess,ensure, and document that all data generated, stored, andreported by JTC are scientifically valid, defensible, and ofknown precision and accuracy.

B. Policy Statement

It is the policy of JTC to establish and maintain aprogram of quality assurance and quality Control to assure thatall data collected are of known and documented quality. TheQA/QC program^ requirements cover all activities which generatemeasurement data.

C. scope and Approach

. . The scope of the QA/QC program is over alllaboratory operations, from sample receipt, through analysis, todata reporting. The approach is to ensure that a uniform basisis used for sample handling, methods control, instrumentconditions, performance evaluation, and data generation andreporting for all samples received for analysis.

AR300375

II. LABORATORY ORGANIZATION AND PERSONNEL

A. 'Overview

JTC Environmental Consultants, Inc., provides avariety of professional services that address environmental andhealth-related problems. Founded and managed by experiencedprofessionals, JTC provides innovative and high quality servicesin the analytical, research and development, and engineeringconsulting fields. The staff at JTC consists of individualsskilled in the physical, chemical, biological, engineering, andsocial sciences, backed up by exceptional laboratory and supportcapability. This provides the JTC client with problem-solvingflexibility which is strengthened by rigorous quality control andproject management.

JTC has developed extensive analytical laboratorycapabilities to support our scientific and technical services.The JTC laboratory was one of the first qualified by the U.S.Environmental Protection Agency for priority pollutant analyses.It has extensive capabilities in the area of environmentalanalysis. We are staffed and equipped to provide a completeinvestigation of waste discharges, from sampling programdevelopment through trace chemical analysis, includinginterpretation of results in accordance with the latestregulations. The JTC laboratory is divided into four sections:Wet Chemistry, Metals, Organic Chemistry, and Biology. Eachlaboratory section is managed by an experienced LaboratoryDirector.

B. Roles and Responsibilities

The authority and responsibility for directingQA/QC activities within JTC are delegated to the QualityAssurance Officer (QAO) and include all areas covered by thequality assurance program. Each JTC Project Manager (PM) setsthe level of quality assurance required for the individualproject and has the responsibility for implementing the qualityassurance program outside of the laboratory, such as fieldactivities which include sample collection and fieldmeasurements. Each Laboratory Director (LD) has the overallresponsibility for implementing the quality assurance programwithin each laboratory. The following persons are designated forthese positions at JTC:

Quality Assurance Officer John T. Cookson, Ph.D.

Project Managers As designated by theExecutive Committee

Metals and wet ChemistryLaboratory Director Mr. Edward Dantsker

-2- HR300376

Organic Laboratory Director Alien Brause, Ph.D.

Biology Laboratory Director Mr. Paul Haynos (Acting)

Director of Analytical Services Ms. Ann E. Rosecrance

In addition to the above, the Quality AssuranceCommittee will be called upon when an out-of-control situationcannot be adequately resolved by the LDs. A chart depictingJTC's organizational structure is provided in Figure l.

C. Assignment of Responsibilities

Each person involved in the generation of data isimplicitly a part.of the QA/QC program. The follow ingindividuals have specifically delegated QA/QC responsibilities.

o Quality Assurance Officer

All QA/QC management responsibilities for JTCshall be directed by the Quality Assurance Officer (QAO). Theindependence and objectivity of the QA/QC program depends on theQAO's being independent of the data generation process.

The QAO has primary responsibility for alllaboratory QA/QC activities. The QAO reports directly to the JTCPresident. His/her responsibilities include the development,evaluation, and documentation of QA/QC policy and proceduresappropriate to the JTC mission.

The QAO performs the day-to-day auditing oflaboratory activities to ensure that the QA/QC plan is beingimplemented. The QAO has the authority to perform laboratoryaudits without notice, submit control samples, and request accessto data files and' other information to satisfy the goals of anindependent audit.

The QAO periodically reports on the progressand - deficiencies of the laboratory QA/QC program, identifiesspecific needs (e.g., methods development and problem areas), andrecommends specific courses of action for strengthening theprogram.

Motivation of personnel is a critical factorin the success of the laboratory QA/QC program. A majorresponsibility of the QAO is to ensure that all personnel have agood understanding of the laboratory QA/QC plan, an understandingof their respective roles to __one another, and an appreciation ofthe importance of their roles to the overall success of.theprogram. - * -

HR300377

UJO

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\— UJz c:UJ

o project Manager

The JTC Project Manager (PM) is responsiblefor managing and implementing the technical and administrativerequirements of the.project. He/she must ensure and document thequality of each task output'. The PM collaborates with the JTCQA/QC organization to formulate and fulfill a suitable QA/QCproject plan for each task under his/her purview, in conformitywith the quality assurance .requirements of the client.

The PM has overall responsibility fordesignating the level of quality control necessary for theintended use of the data, and for formulating the QA/QC projectplans and activities. He/she will also enlist and encourage thecooperation of all JTC personnel in the QA/QC project plan andprogram.

o Laboratory Directors

The JTC Laboratory Directors (LD) haveoverall responsibility for all laboratory activities, includingQA/QC. The success of the QA/QC program ultimately depends onthe LD's full support of QA/QC management. The LD will enlistand encourage the cooperation of all JTC personnel in theprogram. . ._.,_._ :_.. .._.

Each LD is responsible for seeing that thequality assurance requirements are implemented for each analysisperformed in his/her laboratory. The quality assurancerequirements shall encompass those established by the PM and QAO,in addition to further QA/QC requirements of the specificanalytical methods. The laboratory staff will be directed by theLD in the performance of QA/QC protocol for all analyses.

o Quality Assurance CommitteeThe Quality Assurance Committee (QA

Committee) is designated by JTC's Board of Directors. It iscomposed of technical personnel with extensive experience inareas such as chemistry, microbiology, and engineering. Themembers are responsible for providing the necessary technicalexpertise to ensure adequate implementation and review of thelaboratory QA/QC programs. In particular, they are available forconsultation on the technical aspects of specific task activitiesthat affect overall data quality, and aid to the QAO in thedevelopment, implementation, and evaluation of audit programs.

The QA Committee reviews proposals,recommends improvements in QA/QC policies and procedures, andreports and evaluates potential data quality problem areas. It

-5- flR300379

also acts as a QA coordinator, consulting on matters of QA/QC,serving as a source of information on QA/QC matters, and helpingto implement the laboratory QA/QC program.

The QA Committee serves as an advisorycommittee to promote the continuity and application of the QA/QCprogram. The Committee's functions include assisting in theevaluation and refinement of the data quality objectives of theQA/QC program, so that they meet laboratory needs with a minimumdisruption of existing work loads and procedures, reviewingrecommendations presented to the QAO and the Committee, andassessing the effectiveness of the QA/QC program.

D. Personnel Qualifications

All personnel within JTC must have adequateeducation, training, and experience in the area of theirtechnical expertise and in quality assurance to meet theirdesignated responsibilities. To ensure that their knowledge isboth sufficient and applicable to the tasks at hand, and thatthey continue to keep abreast of new developments in the field,the QAO shall periodically recommend training to all personnelengaged in QA activities within JTC. Where appropriate,participation in relevant seminars, short courses, andprofessional meetings is recommended and supported.

1. Quality Assurance Officer

The Quality Assurance Officer for JTC willhave at least the following qualifications:

o Sufficient professional and adminis-trative stature and experience to dealeffectively with project officers,program managers, and organizationaldirectors, and administrators

o Demonstrated QA/QC experience

o Knowledge and experience in a scientificdiscipline; a knowledge of statistics ishighly desirable

o Knowledge of appropriate Federal laws,Agency regulations, and guidelines formethod-related QA/QC requirements

-6-ftR3QQ380

o Effectiveness in meeting and dealingwith the general public, privateindustry, and officials of Federal,State, and local agencies

2. Project Managers and Laboratory Directors

In order to provide the necessary technicalexpertise to the JTC QA/QC organization and to ensure adequateimplementation and review of the laboratory QA/QC program, the PMand LD shall have demonstrated technical competence in areas suchas chemistry, microbiology, and engineering. They shall havesufficient knowledge of the principles and practice of QA/QC toconsult with investigators in developing and implementingappropriate QA/QC project plans.

3. Laboratory Personnel

All personnel participating in datacollection-related activities under the auspices, of JTC shallpossess adequate experience and training to satisfactorilyperform all technical tasks assigned. The LD will review theanalyses and QA/QC related activities performed by the laboratorystaff. At the project level, personnel qualifications shall bereviewed and evaluated by the PM. In addition, the QAO may, atany time, review and evaluate task personnel qualifications.

Where appropriate, personnel will be expectedto participate regularly in certification programs, includingexternal audit program for performance evaluation and/oraccredited training courses in their areas of specialization.

4. Sample Custodian

The sample custodian will have sufficientexperience in clerical and data handling procedures to log andmaintain tracking records on sample receipt in a responsiblemanner. Professional experience with computerized data entry,chart and form preparation, and knowledge of sample sizerequirements for various analyses is required.

-7- flR30038l

III. GENERAL.QA/QC PROGRAM

All laboratory activities within JTC shall be performed inconformity with the approved QA/QC project plan. Approval of aQA