sampling and analysis plan - step 4 baseline … · baseline ecological risk assessment sonford...

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Sampling and Analysis Plan - Step 4Baseline Ecological Risk Assessment

Sonford Products Site,Flowood, Mississippi

EPA Project ID: 08-0079

Prepared by:Sara Waterson

U.S. EPA Region 4Ecological Assessment Branch,

Bioassessment and Toxics Evaluation SectionScience and Ecosystems Support Division

980 College Station RoadAthens, Georgia

and

Joe Owusu-YawIntegrated Laboratory Systems, Inc.

Environmental Services Assistance Team Contractor980 College Station Road

Athens, Georgia

January 2008

10504730

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2 of 52EPA Project ID: 08-0079

Title and Approval Sheet

Title: Sampling and Analysis Plan - Step 4 Baseline Ecological Risk AssessmentSonford Products Site, 3506 Payne Dr, Flowood, Mississippi

This quality assurance project plan (QAPP) has been prepared according to:EPA Requirements for Quality Assurance Project Plans (EPA QA/R5 EPA/240/B-01/003, U.S.Environmental Protection Agency, Office of Environmental Information, Washington, DC, March 2001(USEPA, 2001).

This document will be used to ensure that environmental and related data collected, compiled, and/orgenerated for this project are of the type, quantity, and quality required for their intended purposeswithin the limitations of available resources.

Bobbi Carter, Section Chief, Bioassessment & Toxics Evaluation Section

Signature Date

Keriema Newman, RPM^ USEPA Region 4, Waste Management Division

Signature Date

Project Leader and Author:

Sara Waterson, Bioassessment & Toxics Evaluation Section

Signature

Co-aUthor:

Joe Owusu-Yaw, SESD ESAT-Contractor

Date

Signature

Upon Approval of this document it will be distributed to:

Keriema NewmanBobbi CarterLinda GeorgeJimEldridgeJoe Owusu-Yaw

Date


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TABLE OF CONTENTS

LIST OF TABLES .- '. , 7LIST OF FIGURES : : 7ACRONYMS AND ABBREVIATIONS 8SECTION 1 FIELD SAMPLING PLAN..... 111.0 Introduction; : 111.1 Site Background : '. 111.2 Organization of the Document 121.3 Project Objectives 121.4 Sampling Program, Rationale, and Locations 121.4.1 Surface Soil Sampling : 131.4.2 Surface Water Sampling 15SECTION 2 FIELD SAMPLING ACTIVITIES AND PROCEDURES 152.1 Site Mobilization 162.2 Control of Equipment, Supplies, and Containers 162.3 Sampling Activities 162.3.1 Soil Sampling 162.3.2 Surface Water Sampling 162.4 Sample Identification 172.5 Field Logbook Documentation 172.6 Packaging and Shipping of Environmental Samples 182.7 Equipment Decontamination 182.8 Site Mapping/GIS ..! 18SECTION 3 QUALITY ASSURANCE PROJECT PLAN 19GROUP A: PROJECT MANAGEMENT 19Al Title and Approval Sheet 20A2 Table of Contents '. 20A3 .Distribution List., 20A4 Project/Task Organization ....21A5 Problem Definition/Background : 21A6 Project/Task Description 21A7 Quality Objectives and Criteria 22A8 Special Training/Certification... 29A9 Documents and Records 29GROUP B: DATA GENERATION AND ACQUISITION 31Bl Sampling Process Design : 31B2 Sampling Methods for Soil/Surface Water :.... 31B3 Sample Handling and Custody 32B4 Analytical Methods '...; ". : .35B5 Quality Control 36B6 Instrument/Equipment Testing, Inspection, and Maintenance 36B7 Instrument/Equipment Calibration and Frequency ...... 37B8 Inspection/Acceptance of Supplies and Consumables 37B9 Non-direct Measurements ....„ 38BIO Data Management. .38GROUP C: ASSESSMENT AND OVERSIGHT 40


Cl Assessments and Response Actions : ,.„...: 40C2 Reports to Management ...........: 40GROUP D: DATA VALIDATION AND USABILITY 41Dl Data Review, Verification, and Validation , 41D2 Verification, and Validation Methods 41D3 Reconciliation with User Requirements '. 42SECTION 4 REFERENCES 43


LIST OF TABLES

Table 1-1 Concentrations and Locations of Pentachlorophenol and Dioxins Selected for the SoilToxicity and Bioaccumulation Tests with Eiseniafoetida, Sonford Products Site,Flowood, Mississippi.

Table 2-1 Sampling Station Identification, Sample Identification and Station Location, SonfordProducts Site, Flowood, Mississippi.

Table B-l Media, Method, Container, Preservative, Holding Time and Station ID, SonfordProducts Site, Flowood, Mississippi.

LIST OF FIGURES

Figure 1 Soil Sampling Locations, Sonford Products Site, Flowood, Mississippi.


ACRONYMS AND ABBREVIATIONS

ASB Analytical Support BranchASBLQQGM Analytical Support Branch Laboratory Operations Quality Control ManualASTM American Society for Testing and MaterialsBAF Bipaccumulation factorBERA Baseline ecological risk assessmentbgs below ground surfaceBIO BioaccumulationCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCLP Contract laboratory program.COC Contaminant of concernCOPC Chemical of potential concernCRQL Contract required quantitation limitDO Dissolved oxygenDQO Data quality objectiveEASOPQAM Ecological Assessment Standard Operating Procedures and Quality Assurance ManualERA Ecological risk assessmentESAT Environmental Services Assistance TeamFASP Field Analytical Support ProgramFEC Field equipment centerFSP Field sampling planGALP Good Automated Laboratory PracticeGLP Good Laboratory PracticeGPS Global positioning systemHWSI Hazardous waste site investigationIDW Investigative derived wasteDLS Integrated Laboratory Systems, Inc.LC50 Median lethal concentrationMBPC Mississippi Bureau of Pollution ControlMDEQ Mississippi Department of Environmental QualityMDNR Mississippi Department of Natural ResourcesNOAEC No-observed-adverse-effect concentrationMS Matrix spikeMSD Matrix spike duplicateNPL National Priorities listOP Operating procedurePARCC Precision, Accuracy, Representativeness, Completeness, ComparabilityPA/SI Preliminary Assessment/Site InvestigationPB Preservative blankPCP PentachlorophenolPSS Preliminary Scoring StrategyQA Quality assuranceQAO Quality assurance officerQAPP Quality assurance project planQA/QC Quality assurance/quality controlQC Quality controlQMP Quality management plan

8 of 52EPA Project ID:.08-0079

R4LIMS EPA Region 4 Laboratory Information Management SystemRI Remedial investigationROD Record of decisionRPD relative percent differenceRPM Remedial project managerRSE Removal Site EvaluationSAP Sampling and analysis planSESD Science and Ecosystems Support DivisionSHEM Safety, Health, and Environmental ManagementSOW Statement of workSD Sediment

. SP Sonford ProductsSPE Sonford Products EcologicalSS Surface soilSW Surface waterTAL Target analyte listTC Tissue concentrationTCL Target compound listTOC Total organic carbonTOX ToxicityTR Traffic reportUSDI United States Department of InteriorUSEPA United States Environmental Protection Agency


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SECTION 1 FIELD SAMPLING PLAN

1.0 Introduction N

The Field Sampling Plan (FSP) and Quality Assurance Project Plan (QAPP) comprise theSampling and Analysis Plan (SAP) for the Sonford Products (SP) site (USEPA, 1997). Thesetwo documents, in conjunction with the Study Design and Data Quality Objectives (DQO)Process (B&V, 2007) represent Step 4 of the 8-Step Ecological Risk Assessment (ERA) Process(USEPA, 1997). These documents will serve to guide site investigations to be conducted at theSP site. U.S. Environmental Protection Agency (USEPA) Region 4 Science and EcosystemsSupport Division (SESD) personnel will lead all of the site investigations to be performed at theSP site. They will be assisted by USEPA Region 4 Environmental Services Assistance Team(ESAT) contractors. All of the field measurements and techniques, sample collection, samplehandling and shipment procedures to be followed by field personnel during sampling activitiesare presented in the following sections.

1.1 Site BackgroundThe SP site encompasses a 6-acre site at 3506 Payne Dr, Flowood, Rankin County, Mississippi.The facility housed two separate chemical processing facilities operated by Sonford Internationaland SP from 1972 to 1985. The operations of both companies involved turning solidpentachlorophenol (PCP) into liquid formulations. Sonford International operated at the sitefrom 1972 to 1980 and produced a water-soluble product, sodium pentachlorophenate, used forthe short-termed protection of wood products (MBPC, 1989). Sonford Products operated at thesite from 1980 to March 1985 and produced PCP-based chemicals for the control of pests andproducts to control the growth of mold and sap stains in freshly cut lumber (MBPC, 1989;Weston, 2005).

The site was placed on the USEPA National Priorities List (NPL) on March 7, 2007, and severalenvironmental studies have been conducted on the site related to actions pursuant to theComprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

The Mississippi Department of Environmental Quality (MDEQ) conducted a hazardous wasteinspection in December 1980 at the Sonford facility. The inspection identified quantities ofchemicals and wastes generated during the facility's operations including 550 pounds of PCPand 6,000 pounds of sodium pentachlorophenate. The waste product was a sludge that was storedin drums on the site and transported for disposal at Chemical Waste Management in Emelle,Alabama (MBPC, 1980). The sodium pentachlorophenate was also stored on site in drums andthen transported to a Sonford facility in St. Paul, Minnesota for reuse (MBPC, 1980).

On April 18/1985, approximately 2,000 gallons of PCP were spilled into the wetland south ofthe property (USDI, 1974; USEPA, 1985). The Mississippi Department of Natural Resources(MDNR) responded to the spill and began remediation of the adjacent forest wetland area. On


April 21 and 22, 1985, USEPA assumed responsibility for remediation at the Sonford site(USEPA, 1985; MBPC, 1985). Remediation of the wetland included the excavation.and removalof approximately 2,500 cubic yards of impacted soils. The contaminated soils were transportedto a chemical waste disposal facility in Emelle, Alabama. The remediation efforts also includedthe disposal of more that 10,000 gallons of oil and treating solution at an incinerator in SouthCarolina arid the treatment and disposal of approximately 100,000 gallons of existingwastewater. The remedial action was completed on May 10, 1985 (USEPA, 1985).

In 2004, Weston Solutions, Inc. (Weston) prepared a Preliminary. Assessment/Site Investigation(PA/SI) for the Sonford site. The PA/SI was prepared in order to determine if the Sonford sitehad the potential to be placed on the NPL. Several soil, sediment, surface water and shallowground water samples were collected and elevated concentrations of PGP, dioxins, severalpesticides, and a few metals were reported (Weston, 2004),

In April 2005, Weston collected 24 surface soil, 18 subsurface soil, 6 groundwater, 8 sediment,and 6 surface water samples at the SP site as part of an Integrated Removal Site Evaluation(RSE) and Preliminary Scoring Strategy (PSS) (Weston, 2005). During the 2005 sampling eventconducted by Weston several inorganic, pesticide, and dioxin and dibenzofuran compounds weredetected in a soil sample from stockpiled soil north of the former PCP and oil mixing area.

1.2 Organization of the DocumentThis document is organized into 4 main sections. Sections 1 and 2 comprise the FSP and Section3 represents the QAPP. The QAPP is divided into 4 main groups as described in QA/R-5 "EPARequirements for Quality Assurance Project Plans" (USEPA 200la). Section 4 presents thereferences cited in the preparation of this SAP.

1.3 Project ObjectivesThe main objectives of the site investigations are to collect additional site-specific informationfrom the SP site to fill data gaps and answer ecological risk questions that were identified duringthe baseline ecological risk assessment (BERA) problem formulation (B&V, 2007). The ultimategoal of the project is to produce a defensible Record of Decision (ROD) for the SP site. ThisSAP serves as a tool to document the procedures and methods that will be used by the field teammembers to collect abiotic (surface soil and possibly surface water) samples from the site. Thesamples will be used to further characterize the site and to answer ecological risk questions ortest hypotheses concerning the assessment endpoints identified in Step 3 of the 8-Step ERAprocess. The information obtained will be input into food-web models to assess potential risks toecological receptors and to calculate ecological cleanup goals for the SP site.

1.4 Sampling Program, Rationale, and LocationsThe results of BERA problem formulation indicated that there is potential for adverse effects tothe ecological receptors from exposure to the chemicals of potential concern (COPCs) at the site.The main chemicals of concern were PCP and dioxins/furans, which are known to have beenused by the facility. In addition, quantitative information will be sought for the presence of


Target Analyte List (TAL) inorganic and Target Compound List (TCL) organic chemicals. Theproblem formulation process identified data gaps or additional data needs required to answerecological risk questions needed to complete an ERA for the site. This SAP has been developedto provide the rationale and procedures that will be followed during the site investigations. Thefrequency of sampling events, locations and number of samples, and field quality control (QC)procedures have been determined based on the site history reports arid the previousinvestigations performed at the SP site up to this point. The sampling procedures will beperformed based on guidance provided in the latest revisions of EPA SESD OperatingProcedures and ASBLOQAM (USEPA, 2007a). The official copy of these procedures resides onthe H; drive of the SESD local area network. The Field Quality Manager is responsible forensuring the most recent version of the procedure is placed on the H: drive .and for maintainingrecords of review conducted prior to its issuance.

The current site investigations will focus mainly on bioaccumulation of PCP and dioxins/furansin the site soils. Some toxicity tests will be conducted. The wetlands have previously beensampled as sediment when there was water present. However, these wetlands are dry most of theyear therefore all the soil/sediment samples will be collected as soil. If necessary, thecontaminant concentrations in the soils will be extrapolated to cover the sediment media in therisk characterization. Surface water samples have also been collected in the past. However,surface water is not expected to be present at the site during the current investigation. Pesticidesand other heavy metals will be evaluated but will not be the main focus of the currentinvestigation. Acute toxicity and bioaccumulation tests will be performed on selected surface soilsamples using a soil-dwelling invertebrate (i.e. earthworm, Eisenia foetida). The toxicity testswill be performed with PCP as the direct toxicant and the bioaccumulation tests will focus onboth PCP and dioxins/furans. If present during the site investigations, surface water samples wi l l .be collected for chronic toxicity tests with the cladoceran, Ceriodaphnia dubia.

Changes to the sampling plan made during the field investigation phase will be described in thetrip report.

1.4.1 Surface Soil SamplingSediments will be collected as soil samples if portions of the aquatic habitat are found to be dryduring the site investigations. If a sample location is inundated .with water, the sample with .bedried and tested as a soil sample since surface water is intermittent on the site. The concentrationgradient will be based on the levels of PCP and/or dioxins/furans in soil from previous samplingevents. (Table 1-1). The total number and locations of the soil samples to be collected for thissite investigation also are presented in Table 1-1. Samples will be grab samples. Soilsamples forchemical analyses and toxicity/bioaccumulation tests will be homogenized in the field. Thesample collection procedures to be used in the field are specified in the SESD OperatingProcedure for Soil Sampling^ SESDPROC-300 (USEPA, 2007b). All of the samples selected foroffsite laboratory analysis will be packaged, and shipped offsite to the EPA Region 4 SESDlaboratory or a Contract Laboratory Program (CLP) laboratory for chemical analyses. The soiltoxicity/bioaccumulation test samples will be shipped to the EPA Region 4 SESD laboratory fortesting. - .

All of the soil samples will be analyzed for TAL metals, TCL organic compounds (excluding


PCBs), pesticides, dioxins/furans, grain size distribution, pH, total organic carbon (TOC), andmoisture content. The analytical data from these samples will be used to supplement the existingdata and to complete the soil characterization for the SP site.

Site CharacterizationBased on previous sampling, seven surface soil samples (plus a split) will be collected from theadjoining habitats to the south and east of the site to determine if the contaminant concentrationsin these habitats are elevated enough to cause adverse effects to the ecological receptors (j.e.invertebrates and wildlife) at the site. One soil sample will also be collected from a background/reference location and will be used in bioaccumulation testing. The sampling locations arepresented in Figure 1. . ,

Soil Toxicity/Bioaccumulation Test SamplesSurface soil samples (including one background sample) will be collected to supplement theexisting data and to perform toxicity and bioaccumulation tests. The soil samples, representing aconcentration gradient for PCP, the direct toxicant, will be collected from the adjoining habitatsto the south and east of the site and used for the bioaccumulation tests. The locations wereselected to provide different concentrations, some of which are expected to show an effect. Thelocations selected for the dioxins/furans were based on the maximum detected concentrationsand possible co-location with PCP. Sample locations are presented in Table 1-1. The testconcentrations were selected based on sampling results from previous remedial investigations.This concentration gradient was selected to bracket concentrations that are known to causeadverse effects to ecological receptors. Laboratory control or artificial soil will also be used inthe bioaccumulation tests. The laboratory control soil has been chemically characterized andtested and determined to be non-toxic. The soil sampling locations for thetoxicity/bioaccumulation tests are presented in Figure 1.

Earthworm tissue from the bioaccumulation test will be analyzed metals, dioxins/furans,pesticides, organic compounds, % moisture, and % lipid content. A duplicate earthworm samplewill be submitted for analysis.

The solid-phase soil toxicity and bioaccumulation tests will be performed using the lumbricidearthworm, Eisenia foetida, using test procedures described in Greene et al. (1989)

Table 1-1 Concentrations and Locations of PCP and Dioxins/Furans Selected for use in theSoil Toxicity and Bioaccumulation Tests with Eisenia foetida, Sonford ProductsSite, Flowood, MS.

New Sample ID

Control

SPE-l-SS

SPE-2-SS

Measured PCPConcentration

(mg/kg)

<2.1

2

1.5

Measured DioxinTEQ (ng/kg)

<2.5

8500J

. 6300

. Required Test

Tox/Bio

Bio

Bio

Old SampleLocation

Laboratory

SP-03-SD-0405

SP-86-0507

14 of 52EPA Projccl ID: 08-0079

SPE-3-SS

SPE-4-SS

SPE-5-SS

SPE-6-SS*

SPE-7-SS

17

49

67

6600

<2.1

NA

NA- .

16000

NA

<2.5

Bio

Tox/Bio

Tox/Bio

Tox/Bio

Tox/Bio

SP-09-SS

SP-46-SS

SP-06SD-0405

SP-47-SS

SP-01-SS'(Background)

NA = Not analyzed'TEQ = Toxic equivalentsBio = Bioaccumulation • .Tox = Toxicity* Due to the high PCP concentration this sample may be diluted in order to obtain a median lethal concentration (LC50) and ano-observed-adverse-effect concentration (NOAEC)

1.4.2 Surface Water SamplingAs stated earlier, surface water may not be present during the site investigation. If present, up to4 surface water and one background water samples will be collected for site characterization andtoxicity testing. The surface water collection procedures to be used in the field are specified in.the SESD Operating Procedure for Surface Water Sampling, SESDPROC-201 (USEPA, 2007c).All of the samples selected for offsite laboratory analysis will be packaged, and shipped offsite tothe EPA Region 4 SESD laboratory or a CLP laboratory for chemical analyses. In-situmeasurements will, be taken using the SESD Operating Procedure for In-Situ Water QualitySampling, SESDPROC-111 (USEPA, 2007d')' Surface water will be analyzed for TAL metals,TCL organic compounds (excluding PCBs), and pesticides. pH will be analyzed in the field withadatasonde. ' ' ' >

Surface Water Chronic Toxicity TestsSurface water is not expected to be present at the site during the investigation. However, ifpresent up to 4 surface water and one background water samples will be collected for sitecharacterization and chronic toxicity tests with Ceriodaphnia dubia. The tests will be performedfollowing guidance provided in EPA/600/4-91/002 entitled "Short-Term Methods for Estimatingthe Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms" (USEPA,1994). The concentrations and locations of the surface water sampling stations will be selectedbased on the field conditions. ' .

SECTION 2 FIELD SAMPLING ACTIVITIES ANDPROCEDURES

Prior to initiating any field sampling activities, the remedial project manager (RPM) or fieldproject leader will notify the state of the proposed field activities and obtain any necessarypermission from property owners. The following sampling-related activities will be performedby the field crew:

15 of 52F.PA Pmi.^l ITV 08-0079

1. Site mobilization;2. Identification of sampling locations;3. Field QA/QC procedures including equipment calibrations and field measurements;4. Procurement of field equipment, supplies, and containers;5. Surface soil sampling;6. Completion and review of field logbook documentation;7. Labeling, packaging, preserving, and shipping of environmental samples;8. Equipment decontamination; and9. Management of investigative derived wastes:

Where applicable, the subsections in this section reference the latest revision of the followingEPA Region 4 SESD Field Operating Procedures (OP) and the Analytical Services BranchLaboratory Operations Quality Control Manual (ASBLOQAM) (USEPA 2007a).

2.1 Site MobilizationThe field project leader will identify and provide all of the necessary personnel, equipment, andmaterials for mobilization and demobilization to and from the site for the purpose of thesampling activities. A temporary field office will be set up and all equipment and supplies willbe stored in a locked vehicle. An onsite decontamination area will be constructed todecontaminate the field sampling equipment if necessary. •

2.2. Control of Equipment, Supplies, and ContainersAll sample containers will be pre-cleaned and traceable to the facility that performed thecleaning. Sample containers will not be cleaned or rinsed in the field. Sample containers andpreservation methods will follow USEPA requirements (SESDPROC -011,USEPA 2007d).

2.3 Sampling ActivitiesSampling activities to be performed at the site include environmental sampling of soiLandsurface water. The goal of the sampling activity is to yield quantitative data that accurately depictthe site conditions in a given time period. QA/QC measures specified in the sampling proceduresminimize and quantify the error in the data. The following sections describe or reference thesampling techniques and procedures to be performed during the site investigation.

2.3.1 Soil SamplingSurface soil samples will be collected from a depth of 0-6 inches below ground surface (bgs) andwill be grab samples. At each location sufficient sample volume will be collected and split in thefield for both the bioassays and chemical analyses as needed. Samples will be homogenized inthe field and the necessary volume of sample will be placed in appropriate sample containers forshipment to the testing laboratory. The sample volume requirements, containers, preservation,methods, and holding times are described in the QAPP (section 3 of this document).


used for QA/QC.

2.3.2 Surface Water SamplingThe sample collection procedures are specified in the SESD Operating Procedure for SurfaceWater Sampling, SESDPROC-201 (USEPA, 2Q07c). At each surface water sampling location, anadequate volume of sample will be collected after all in situ water quality measurements havebeen taken as described in section 1.4.2. In-situ water quality readings will be taken using SESDOperating Procedure for In-Situ Water Quality Sampling, SESDPROC-111 (USEPA, 2007e).

A duplicate of a water sample (if available), MS/MSD, temperature blank for cooler,preservative blank, field blank, and blind blank will be used for QA/QC.

2.4 Sample IdentificationThe following sample identification codes or similar nomenclature will be used to identify thesamples collected from the SP site.

Table 2-1 Sampling Station Identification, Sample Identification and Station Location

Site code:

Sample media code:

Sample identification:

SPE

SSSWRSBIOTOX

#

Sonford Products Ecological

Surface soil sampleSurface water sampleRinsate sampleBioaccumulationToxicityNumeric location

Additional details of the sample identification procedures are provided in the QAPP (section 3).

2.5 Field Logbook DocumentationField logbooks provide a means for recording all data collection activities performed at a site.The field logbook is a Controlled Evidentiary Document and will be maintained accordingly.The field operations manager will make logbooks available. Each logbook will be assigned adocument control number prior to use. Entries will be as descriptive and detailed as possible, sothat a particular situation could be reconstructed at a later date without reliance on the collector'smemory.

All measurements made and a detailed description of each sample collected is recorded. Alllogbook entries will be made' with indelible ink and legibly written. The language will be factualand objective. No erasures are permitted. If an incorrect entry is made, the data will be crossedout with a single line, initialed, and dated. Entries will be organized into tables if possible. Thefield operations manager will review the logbooks at the end of each working day to ensure thatthe logbooks are complete and correctly filled out. Field logbooks will be filled out inaccordance with SESDPROC-010 (USEPA, 2007f).


2.6 Packaging and Shipping of Environmental SamplesSamples will be packaged for shipment in accordance with the requirements of the U.S.Department of Transportation'and SESD Operating Procedure SESDPROC-209 (USEPA,2007g). For samples being sent to laboratories other than EPA SESD, a custody seal will beaffixed to the outside of each cooler. It will be placed over the cooler seam, and signed anddated. Nylon-reinforced tape will be placed over the seal to reduce the potential for tampering oraccidental tearing. A chain-of-custody form will be completed for all samples requiringlaboratory analysis.

Sampling personnel may contact Debbie Colquitt, EPA Region 4 SESD, at 706-355-8804 forfurther information regarding laboratory assignments, sampling problems, shipment delays, etc.

It is the CLP laboratory's responsibility to maintain internal logbooks and records that provide acustody record throughout sample preparation and analysis. To track field samples through datahandling, photocopies of all traffic reports and chain-of-custody records will be maintained bythe field personnel. .

2.7 Equipment DecontaminationDecontamination procedures will be. performed prior to the site investigation and will beperformed based on the SESD Operating Procedure for Field Equipment Cleaning and'Decontamination at the FEC, SESDPROC-206 (USEPA, 2007h). However, if required,decontamination in the field will be performed based on the SESD Operating Procedure forField Equipment Cleaning and Decontamination, SESDPROC-206 (USEPA, 2007i).

2.8 Site Mapping/CISAerial photography depicting the ecological habitats, existing structures, wetlands, drainageditches, creeks, etc. for the SP site exist. A base map for the site will be developed from theexisting aerial photography. The coordinates of all sampling stations will be horizontally (andpossibly vertically) located in the field and placed on the base map for the site using a globalpositioning system (GPS). All sampling locations will be referenced to the North AmericanDatum 1927. The procedures for recording the coordinates with the GPS system are provided inthe SESD Operating Procedure for the Global Positioning System, SESDPROC-110 (USEPA,2007J).


SECTION 3 QUALITY ASSURANCE PROJECT PLAN

GROUP A: PROJECT MANAGEMENTThis QAPP in conjunction with the FSP supports all of the sampling and analysis activities thatwill be performed at the SP site. The QAPP was prepared in accordance with EPA QA/R-5"Guidance for Preparing Quality Assurance Project Plans" (USEPA 2001a) and EPA Region 4SESD Operating Procedures. This section covers the basic areas of project management,including the project organization, background and purpose, project description, qualityobjectives and criteria, special training, and documentation and records. EPA Region 4 willprovide the necessary technical staff to perform the sampling and reporting aspects of theproject. They will be assisted by contractors from Region 4 ESAT. The project organization andresponsibilities are presented in the following sections.

Remedial Program Manager (RPM)The RPM for the SP site is Keriema Newman. She is legally responsible for the overallmanagement of the project. It is the responsibility of the RPM to ensure that EPA Region 4Management, data users, and decision makers (these include potential responsible parties, naturalresource trustees, local communities, state agencies, etc.) are informed of all field activities andthe results of the site investigation.

Field Project LeaderThe field project leader for the site is Sara Waterson. Some of the responsibilities of the fieldproject leader include but are not limited to the following:

Overseeing the overall field investigation and sampling phases of the project; x

Making all field decisions including field sampling, monitoring, field quality control;Scheduling and coordination of work and sample analyses activities;Ensuring that all field activities are properly performed and documented;Implementing corrective action in the field as necessary if problems arise;Ensuring that all field activities are properly documented in field logbooks; andCommunicating all site activities with the RPM and EPA contractors.

i ' " ' ' • • •

Health and Safety OfficerThe health and safety officer is responsible for ensuring that all field personnel are up-to-date ontheir health and safety requirements. He also monitors the health and safety of all field samplingand investigative personnel.

Quality Assurance ManagerThe Region 4 quality assurance (QA) manager, Bill Bokey, has the authority and responsibilityfor developing and implementing regional QA/QC policies hi accordance with the QualityManagement Plan (QMP) for EPA Region 4 (USEPA 2007k).

Field Quality Assurance ManagerThe Field QA Manager for the site investigation, Laura Ackerman, is responsible for managing


all QA activities for this investigation. She is responsible for implementing corrective actions ifproblems occur in the site investigation in the field. -

Field Team MembersField team members are expected to be EPA personnel and contractors from Region 4 ESAT. Allfield team members are responsible for the following activities:

Collecting and preserving abiotic samples as described in the FSP and QAPP;Performing field QA/QC activities as specified in the FSP, QAPP,.and SESD OPs;Performing field equipment calibrations as specified in the QAPP and SESD OPs;Ensuring that samples are properly packaged and shipped in a timely manner;Scheduling the shipment of investigative samples to the analytical laboratories;Ensuring that all field measurements are properly performed and documented;Documenting all field activities in field logbooks; andCommunicating all site activities with the field project leader.

Al Title and Approval SheetRefer to Page 3.

A2 Table of ContentsRefer to Page 5.

A3 Distribution ListThe following personnel shall receive copies of the FSP and QAPP.

RPM, Keriema NewmanField project leader, Sara WatersonEPA-SESD field sampler-Linda George*ESAT toxicologist/ecological risk assessor, Joe Qwusu-YawBlack and Veatch ecological risk assessor Jim Eldridge

*Note- after sampling event hi 2/08, Linda George will assume the role of Project Manager

20 of 52 .EPA Project ID: 08-0079

A4 Project/Task Organization v

A5 Problem Definition/BackgroundThe objectives of this assignment are discussed hi Section 1.3 of the SAP and will not berepeated hi detail hi this section. Briefly, the previous activities performed at the SP site resultedhi the contamination of local environment. A BERA problem formulation using the existing dataidentified several data gaps'and ecological risk questions (B&V 2007). A recommendation wasmade for the collection of additional site-specific information to answer the risk questions and tofill those data gaps. These documents (i.e. FSP and QAPP) are being prepared to aid in thecollection of additional site information to fill those data gaps and to answer the ecological riskquestions for the SP site. The purpose of this QAPP is to provide guidance to ensure that allenvironmentally related data collection procedures and measurements are scientifically soundand of known, acceptable, and documented quality for the intended usage.

A6 Project/Task DescriptionThe objectives of this investigation are to collect site-specific information to fill in data gaps andanswer risk questions in order to complete an ecological risk assessment and to prepare a RODfor the site. The objectives will be achieved by collecting abiotic (surface soil and surface waterif available) samples from the SP site as described hi the FSP, and performing habitat evaluation,chemical analyses, bioaccumulation tests, toxicity tests, and other physical/chemicalmeasurements on the samples. The data obtained will be used for the following activities:

• Further characterize the site and provide additional information for the ecological riskassessment;

• Identify the media and receptors that are potentially affected by the contaminants at


the site; ,• Answer ecological risk questions identified in the BERA problem formulation;

, • Perform an ecological risk assessment; and• Assist in the development of ecological clean-up goals.

Project ScheduleIt is anticipated that all chemical analyses will be provided by the EPA Region 4 SESDAnalytical Services Branch or a subcontracted CLP laboratory. The bioaccumulation tests will beperformed by EPA Region 4 ESAT contractors. The site investigation is tentatively scheduled tostart on the week of February 4, 2008 and anticipated to be completed that week. All of therequired chemical analyses including the toxicity tests are expected to be completed by July 30,2008.

A7 Quality Objectives and CriteriaThis section establishes an internal means of QC and review to ensure that environmentalmeasurements and data collected from the site investigations are of known quality and suitablefor making sound decisions about the site. To aid in the interpretation of the data, the two broadcategories of data developed by USEPA will be used: screening data and definitive data.

• Screening data with definitive confirmation: This category provides rapid, lessprecise methods of analysis with less rigorous sample preparation. Analyteidentification and quantitation are provided, although quantitation may be relativelyimprecise. At least 10 percent of the screening data are confirmed using analyticalmethods and QA/QC procedures and criteria associated with definitive data. Fielddata collected using portable field instruments belong to this category. To beacceptable, screening data must include chain-of-custody, initial and continuing

- calibration, analyte identification, and analyte quantitation.

• Definitive data: This category includes data generated using rigorous analyticalmethods. The data are analyte specific with confirmation of the identity andconcentration of analytes. The methods in this category may produce tangible rawdata (e.g. chromatograms, spectra, digital values) in the form of hard-copy printoutsor computer-generated electronic files. ,

The subsections below describe the DQOs and data measurement objectives for the siteinvestigations.

A7.1 Data Quality ObjectivesThe DQO process is a series of planning steps based on the scientific method that are designed toensure that the type, quantity, and quality of environmental data used in decision-making areappropriate for the intended purpose. The EPA has issued guidelines to help data users developsite-specific DQOs (USEPA 2000a). The DQO process is intended to:

• Clarify the study objectives;• Define the most appropriate type of data to collect;

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• Determine the most appropriate conditions from which to collect the data; and• Specify acceptable levels of decision errors that will be used as the basis for

establishing the quantity and quality of data needed to support the design.

The goal of the DQO process is to "help assure that data of sufficient'quality are obtained tosupport remedial response decisions, reduce overall costs of data sampling and analysisactivities, and accelerate project planning and implementation."

The DQO process specifies project decisions, the data quality required to support thosedecisions, specific data types needed, data collection requirements, and 'analytical techniquesnecessary to generate the specified data quality. The process also ensures that the resourcesrequired to generate the data are justified. The DQO process consists of seven steps and theoutput from each step influences the choices that will be made later in the process. These 7 stepsare identified as follows: .

Step 1: State the problem;Step 2: Identify the decision;Step 3: Identify the inputs to the decision;Step 4: Define the study boundaries; •Step 5: Develop a decision rule; .Step 6: Specify tolerable limits on decision errors; andStep?: Optimize the design.

During the first six steps of the process, the planning team develops decision performancecriteria (i.e. DQOs) that will be used to develop the data collection design. The final step of theprocess involves developing the data collection design based on the DQOs. A brief discussion ofthese steps and their application to this project is provided below.

Stepl: State the ProblemEnvironmental data is required to evaluate the impacts of the contamination at the SP site to theecological receptors at the site and vicinity. This site investigation will be conducted to collectadditional data to supplement the existing data collected from the site. The combined data will beused to assess the risks to ecological receptors and to establish clean-up goals for thecontaminants of concern (COCs) at the site. . . .

Step 2: Identify the DecisionAll data generated from collection of environmental samples during this investigation will bedefinitive level data. The data will be used to answer the following ecological risk questions:

• What is the nature/extent of contamination in the habitats at the SP site?• Are the contaminants in the soils at the SP site available for uptake by ecological

receptors? .• Are the contaminants bipaccumulating in potential prey (e.g., mammals)?• Does the potential exist for food-web transfer of the site contaminants?• Are the primary sources of contamination still present?• Are the contaminants in the habitats causing harm to the ecological receptors?


The results of the additional sampling, chemical analyses, and site-specific bioaccumulation testswill be used to answer the above questions. If the results are not sufficient to answer any of thequestions, possible explanations will be sought or additional sampling and analyses may berequired.

Step 3: Identify the Inputs to the DecisionThe decisions -listed above are linked to the following activities to provide site-specificenvironmental physical and chemical data.

1. Collect and analyze surface soil samples from habitats to the south and east of the siteand background locations for use in site characterization; .

2. Collect surface soil samples at the site and vicinity for use in bioaccumulation andtoxicity testing at the EPA Region 4 SESD laboratory

Step 4: Define the Boundaries of the StudyThis step defines the spatial and temporal boundaries of the study. Surface soil samples will becollected from the terrestrial habitats as shown in Figure 1. The surface soil samples will becollected from 0-6 inches bgs. The precise locations for collecting the samples will be identifiedbased on the observations of the field conditions.

Step 5: Develop a Decision RuleThe purpose of this step is to define the parameter of interest, specify the action level, andintegrate previous DQO outputs into a single statement that describes a logical basis for choosingamong alternative actions. The data collected during this site investigation will be evaluated andcompared to action levels for each constituent. The action levels may be a permitted limit,background concentration, toxicity benchmarks, or risk-based concentrations. The primaryparameters of interest are the concentrations of PCP and dioxins/furans in the abiotic media. Ifthe data collected exceed any action levels, it will be discussed in the baseline ecological riskassessment. • .

Standard rounding rules will apply. If the next decimal place after the decimal place to berounded to is 5: (a) plus the slightest remainder (i.e., 1.151), then the number will be rounded up(1.2); or (b) with no remainder (1.150 or 1.450), then the number will be rounded to the nearesteven number (1.2 or 1.4, respectively).

Step 6: Specify Tolerable Limits on Decision ErrorsDecision maker's tolerable limits on decision errors, which are used to establish performancegoals for the data collection design, are specified in this step. Decision makers are interested inknowing the true value of the constituent concentrations. Since analytical data can only estimatethese values, decisions that are based on measurement data could be in error (decision error).There are two reasons why the decision maker may not know the true value of the constituentconcentration, these are: .

1. Concentrations may vary over time and space. Limited sampling may miss somefeatures of this natural variation because it is usually impossible or impractical to


measure every point of a population. Sampling design error occurs when the samplingdesign is unable to capture the complete extent of natural variability that exists in thetrue state of the environment.

2. Analytical methods and instruments are never absolutely perfect; hence ameasurement cari only estimate the true value of an environmental sample.Measurement error refers to a combination of random and systematic errors thatinevitably arise during the various steps to the measurement process.

The combination of sampling design and measurement error is the total study error. Since it isimpossible to completely eliminate total study error, basing decisions on sample concentrationsmay lead to a decision error. The probability of decision error is controlled by adopting ascientific approach such that the data are used to select between one condition (the nullhypothesis) and another (the alternative hypothesis). The null hypothesis is presumed to be truein the absence of evidence to the contrary. For this project the null hypothesis is that the truevalues of the constituents are at or below action levels. The alternative hypothesis is that the truevalues of the constituents are above the background levels.

A false positive or 'Type I" decision error refers to the type of error made when the nullhypothesis is rejected when it is true and a false negative or 'Type II" decision error refers to thetype of error made when the null hypothesis is accepted when it is false. For this project, a TypeI decision error would result in deciding that the site was contaminated above background levels("duty") when it is not and a Type II decision error would result in deciding that the site was notcontaminated above action levels ("clean") when it is. For example, if the action level for aconstituent is 2,300 mg/kg, the reported concentration is 2,200 mg/kg, and the true value is 2,400mg/kg, a Type I error could easily be made by not applying any decision error limits. For thisproject, a Type II error is less acceptable (worse case) than a Type I error because a Type II errorcould result in ecological and/or human harm, whereas a Type I error could result in spendingmoney for further investigating a "clean" site. .

The closer the reported concentration is to the background concentrations, the higher theprobability that an incorrect decision will be made and, therefore, tolerable decision limits areestablished outside the action level to allow decision makers to make a decision based onprofessional judgment. A tolerable limit has been identified as the .background concentrationplus/minus 10 percent. In this area, the decision makers may decide that although the reportedconcentration is below the background concentration, so as to not make a Type II decision error,the null hypothesis is rejected.

Step?: Optimize the Design for Obtaining DataThis step identifies a resource-effective. data collection design for generating data that areexpected to satisfy the DQOs. The data collection design (sampling program) is described indetail in the work plan and SAP.

Precision, Accuracy, Representativeness, Completeness, and Comparability RequirementsPrecision,1 accuracy, representativeness, completeness, and comparability (PARCC) parametersare indicators of data quality. The PARCC goals are established for the site characterization toaid in assessing data quality. The precision and accuracy criteria for this investigation are defined


by the EPA CLP Statement of Work (SOW). PARCC criteria for field"measurements and othernon-CLP measurements are discussed in the 2007 USEPA SESD Standard Operating Proceduresand in the following sections.

PrecisionPrecision measures the reproducibility of measurements under a given set of conditions.Specifically, it is a quantitative measure of .the variability of a group of measurements comparedto their average value. Precision is usually stated in terms of standard deviation but otherestimates such as the coefficient of variation (relative standard deviation), range (maximumvalue minus minimum value), and relative range (relative percent difference) are common. Theoverall precision of measurement data is a mixture of sampling and analytical factors. Analyticalprecision is much easier to control and quantify than sampling precision. Whereas samplingprecision is unique to each site, historical data is related to individual method performance and "islimited to the samples received in the laboratory.

Sampling precision may be determined by collecting and analyzing co-located or field splitsamples and then comparing the results obtained to the results obtained for laboratory duplicatesfrom one of more of the field samples. The analytical results from co-located or field duplicatesamples provide an indication of overall measurement precision. The analytical results from thelaboratory duplicates provide an indication of analytical precision. Sampling precision may beestimated by comparing the analytical precision to the measurement precision.

Precision will be assessed by the measurement of separate replicates of a particulardetermination. Generally, standard deviation (SD), relative standard deviation (RSD), or relativepercent difference (RPD) is used to assess precision according to the following formulae.Standard deviation:

n-l

where: .x, = individual measurement

X .= average of the individual measurementsn = number of individual measurements

Percent relative standard deviation:

RSD = SDx 100X

where: SD - standard deviation

X = mean of the individual measurements


Relative percent difference: RPD = lOOTS-DI[S + D]

where:

S . = result obtained for the original sampleD = result obtained for the duplicate .

The objective for precision is to equal or exceed the precision demonstrated for similar samplesunder similar sets of conditions.

AccuracyAccuracy is the degree of agreement of a measurement (or an average of measurements of thesame quality or quantity) X, with an accepted reference or true value, T, usually expressed as thedifference between the two values, X-T, or the difference as a percentage of the reference or truevalue, 100 (X-T)/T, and sometimes expressed as a ratio, X/T.

Accuracy measures the bias in a measurement system, i.e., the error in a method whichsystematically distorts results. Sources of error include the sampling process, fieldcontamination, preservation, handling, sampling matrix, sample preparation and analysistechniques. Sampling accuracy may be assessed by evaluating the results of field/trip blanks.Analytical accuracy may be assessed through the use of known and unknown QC samples andmatrix spikes. . ' • • • •

Analytical accuracy will be assessed from measurements of samples spiked with knownconcentrations of reference materials (e.g. performance evaluation samples). The assessment foraccuracy will be independent of the routine calibration process. Normally, the percent recoverywill be used to assess accuracy. The following equation will be used under the CLP fordetermination of percent recovery:

Pi = rAi-Bn x 100•' . Ti

where: , .Pi = percent recoveryA, = result obtained from the spiked sampleBi = result obtained from the un-spiked sampleTI = true or known value of the spike

The objective for accuracy is to equal or exceed -the accuracy demonstrated for similar samplesunder similar sets of conditions.

RepresentativenessRepresentativeness is the degree to which data accurately and precisely represents acharacteristic of a population, a process condition, an environmental condition, or parametervariations at a sampling point. Representativeness of a data set is a quality objective attributable


to both the selection of type and number of samples to be taken and the analysis to be performedso that the data generated will adequately represent the conditions found at the site at the time ofsample collection. The representativeness criterion is best satisfied by making certain thatsampling locations are selected properly and a sufficient number of samples are collected. Otherconcerns, such as proper techniques for isolating a portion of sample to be analyzed from thequantity of sample taken from the field, and isolation of samples from subsequent contamination,may also be critical. The two concerns identified above may be evaluated through anexamination of co-located or replicate data and blank data. By definition, co-located samples arecollected so that they are equally representative of a given point in space and time. In this way,they provide both precision and representativeness information. During the data validationprocess, the factors that will be evaluated which influence representativeness include choice ofmethods, the level arid sources of contamination, accuracy, and precision. Data validators canassess representativeness best if they have information about field duplicates and other field QCsamples. • '

ComparabilityComparability is the measure of whether and to what degree a data set can be compared to otherdata sets. To optimize comparability, standardized analytical procedures and standard reportingunits will be used.

To determine whether data are comparable, the sampling methods employed in the site program,the chain-of-custody methods responsible for the transfer of the sampled items to the analyticallaboratories, and the analytical methodologies implemented at the laboratories will be evaluatedfor uniformity and conformity. Sample data shall be comparable with other measurement data forsimilar samples1 and sample conditions. Knowledge of what methods have been used previouslyto make measurements at the site can facilitate an evaluation of comparability during the datavalidation process. Comparability is dependent upon the other data quality parameters becauseonly when precision and accuracy are known can data sets be compared with confidence.

CompletenessCompleteness is a measure of the amount of valid data obtained from a measurement systemcompared to the amount that was expected to be obtained under normal conditions. If this goal isknown bythe data validators, percent completeness will be calculated by dividing the number ofvalid sample results by the total number of results that were expected to have been obtained, and

' multiplying the result by 100. It is generally understood that completeness is Only jeopardized byrejected data or data not collected.

Selectivity/SensitivityThe choices of methods made prior to the start of an environmental project are made afterconsideration of the ability of the method to identify the analytes of concern (selectivity) and toallow detection of each analyte at or below some concentration of concern (sensitivity). Certainprocedural choices made either in the field or in the laboratory can have an influence onselectivity and sensitivity. Losses of target analytes due to improper sample preservation orstorage will be assessed by the data validator by examining chain-of-custody information,laboratory sample receipt and tracking documentation, and pH measurement results. Choicesmade at the laboratory with respect to sample dilutions, based on appearance or initial sample

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results, directly affect reportable detection limits. The data validator will determine whetherappropriate dilutions were done to optimize method sensitivity, and whether method conditionswere adequately followed to ensure method selectivity to all target analytes.

A8 Special Training/CertificationThere are no specific special training/certification requirements for these investigations. All fieldsampling personnel are required to have 40 hours of OSHA mandated hazardous waste sitetraining and subsequent annual refresher training. Only experienced field sampling and analysespersonnel with specific knowledge and expertise hi sample collection, sample analyses, andsafety techniques will be used for these investigations. All professional and paraprofessionalinvestigators working at the WCW site will have the equivalent of six months field experiencebefore they are permitted to select sampling sites on their own initiative. This field experiencewill be gained by on-the-job training using the "buddy" system. Each new investigator shallaccompany an experienced employee on as many different types of field studies as possible.During this training period, the new employee will be permitted to perform all facets of fieldinvestigations, including sampling, under the direction and supervision of senior investigators.

Field and analytical personnel at the EPA Region 4 SESD are also required to undergo a Safety,Health, and Environmental Management (SHEM) training. All SHEM training will be performedin accordance with the SHEM Procedures and Policy Manual (USEPA 2002b). Training recordsfor. EPA personnel and ESAT contractors are on file at the EPA Region 4 SESD office.

A9 Documents and RecordsDifferent documents and records will be prepared for these investigations and every effort willbe made to ensure that the appropriate personnel receive the current version of the documents.The type of documents to be produced, information to be provided in the documents, proceduresfor disposition of the records are discussed in the following sections. Project files will bemaintained according to the SESD Operating Procedure for Control of Records, SESDPROC-002 (USEPA, 20071). '

Current Version of DocumentsIt is the responsibility of the field project leader to ensure that all appropriate project personnelpossess the most current version of the FSP and QAPP. Each QAPP will have a documentcontrol number and the field project leader will provide each field team member with the latestedition of the QAPP, If revisions are made to the QAPP, the field project manager may replaceonly the affected pages (if the changes are minor) or replace the entire QAPP (if the changes aremajor). In addition, all project personnel will have copies or ready access to the latest revision ofthe field OPs. :

Data Report PackagesData report packages produced by EPA Region 4 will follow the procedures provided/ in theappropriate EPA Manuals. Field records will be produced and stored in accordance with SESDOperating Procedure for Logbooks, SESDPROC-010 (USEPA, 2007f) and analytical recordscomply with the procedures in Chapter 5 of the ASEtLOQCM (USEPA 2007a). Contract


analytical laboratories will submit analytical data report packages to the EPA Region 4 SESDfield project leader. Both electronic and hard copy deliverables will be provided. At a minimum,each data report package will contain the following items:

• A case narrative that briefly describes the number of samples, the analyses, and anyanalytical difficulties or QA/QC issues associated with the submitted samples;

• Raw data (including chromatograms, sample preparation and analysis forms, andother bench sheets); . •

• Field records;. • Signed chain-of-custody forms; .• Cooler receipt forms;• Analytical data (including instrument printouts, calibration results, QA/QC results,

etc); and• QC package.

Reports to be ProducedAt the end of the investigation, a site investigation report will be produced. The final report willbe prepared hi accordance with the requirements of the SESD Operating Procedure for ReportPreparation and Distribution, SESDPROC-003 (USEPA, 2007m). The format of the report anditems included in the report will contain the following items:

1. Introduction - When the .investigation was conducted; EPA, state or other regulatoryagency participation; facility representatives and what their participation included;who requested the investigation; and the objectives.

2. Background — Study area descriptions, manufacturing process and waste handlingpriorities, results of previous investigations, etc. A site map depicting major structuresand facilities, as well as sampling locations will be included.

3. Summary - A brief summary of the key results and conclusions of the study. Thiswill include any unforeseen items or events.

4. Discussion — All aspects pertinent to the investigation, such as analytical results;deficiencies; a site map showing sampling locations, etc.

,. 5. Methodology — A statement indicating that this OP was followed and/or reasons whynot and whether or not samples were split and with whom.

6. Conclusions — At the discretion of the author, a conclusions section for complexinvestigations.

7. Reference and Appendices ~ Laboratory data sheets, checklists, etc.

Final Disposition of Records and DocumentsField records will be disposed of in accordance with SESD Operating Procedure for Control ofRecords, SESDPROC-002 (USEPA, 20071) and analytical records disposition will follow theprocedures in Chapter 4 of the ASBLOQCM (USEPA 2007a).

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GROUP B: DATA GENERATION AND ACQUISITION

This section covers sample process design, sampling methods requirements, handling andcustody, analytical methods, QC, equipment maintenance, instrument calibration, supplyacceptance, non-direct measurements, and data management. All data collected during this siteinvestigation is considered definitive data. The EPA and/or ESAT data validation staff willreview and validate all field and laboratory QC data for correctness. If the QC data indicatesampling or analytical errors, the cause of the errors shall be investigated and corrected, ifnecessary. :

Bl Sampling Process DesignThe general goals of the field investigation are to collect and analyze abiotic samples from theSP site in order to verify and quantify the presence of COPCs for use in an ecological riskassessment. One of the goals is to obtain a soil concentration gradient based on PCP anddioxin/furans concentrations for use in bioaccumulation tests. The concentration gradient wasselected based on PCP and dioxin/furans concentrations detected from previous siteinvestigations. The field investigation activities will comprise several individual tasks. Thespecific data collection efforts for the SP site will include surface soil sampling. Surface watersamples will be collected if it is present on the site.

The proposed sampling locations are presented in Figure 1. The number and types of samples,sampling locations, and analyses parameters for the site investigations are discussed in Section1.4 of this document. The number of samples, analysis methods, sample containers, samplepreservation methods, and holding times is located in Table B-l. .

B2 Sampling Methods for Soil/Surface WaterMechanical collection techniques and equipment will be used to collect soil and surface watersamples. The specific collection techniques and procedures will be based on the guidelines in thefollowing documents: SESD Operating Procedure for Soil Sampling, SESDPROC-300 (USEPA,2007b) and SESD Operating Procedure for Surface Water Sampling, SESDPROC-201 (USEPA,2007c), The field project manager will ensure that an adequate number of sampling equipment,personnel, and supplies are available for the" performance of all sampling activities. Anydeviations from the sampling protocols will be approved by the field project leader and will bedocumented in the field logbook(s). . .

B2.1 Sampling Equipment and PreparationSampling equipment required for the field program for environmental monitoring, sampling,health and safety monitoring, equipment and personal decontamination, and general fieldoperations are presented in the SESD Operating Procedure for Field Equipment Cleaning andDecontamination at the FEC, SESDPROC-206 (USEPA, 2007h) and SESD OperatingProcedure for Field Equipment Cleaning and Decontamination, SESDPROC-205 (USEPA,2007i).

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B2.2 Sample Containers, Preservation Methods, and Holding TimesProperly prepared sample containers that have been cleaned according to EPA-standards(certified clean) will be obtained from the EPA Region 4 SESD Field Equipment Center (FEC),in Athens, Georgia. The samples will be collected in approved containers and preserved asspecified in the appropriate sampling OPs. The sample containers, preservation methods, andholding times for this site investigation are provided in Table B-l.

B2.3 Sampling Equipment DecontaminationSee Section 2.7An area of the site that is minimally impacted by traffic and other site operations will be set up asthe decontamination area. All field-sampling equipment requiring decontamination will bedecontaminated in this area in the field after use and from one location to another. Large-scalefield sampling equipment decontamination will be performed at the EPA Region 4 SESD FEC.The field and FEC decontamination procedures are described in the following documents: SESDOperating Procedure for Field Equipment Cleaning and Decontamination, SESDPROC-205(USEPA, 2007i) and SESD Operating Procedure for Field Equipment Cleaning andDecontamination at the FEC, SESDPROC-206 (USEPA, 2007h).

All investigation-derived waste (EDW) and decontamination liquids will be collected andcontainerized and properly disposed. Clothing and miscellaneous trash generated during theinvestigation will be bagged and disposed of in a commercial dumpster. The procedures forcollecting and disposing of IDW and decontamination liquids are provided in the SESDOperating Procedure for Management of Investigation Derived Waste, SESDPROC-202(USEPA, 2007n). .

B3 Sample Handling and CustodyAll field sample collection, handling, and shipment procedures will adhere to those outlined inthe SESD Operating Procedure for Sample and Evidence Management, SESDPROC-005(USEPA, 2007o). After collection, all sample handling will be minimized. Field samplers willuse extreme care to prevent sample contamination. Samplers will ensure that if samples areplaced in an ice chest, melted ice cannot cause the sample containers to become submerged, asthis may result in sample cross-contamination. .Plastic bags, such as Zip-Loc® bags or similarplastic bags sealed with tape, will be used when small sample containers (e.g., VOC vials orbacterial samples) are placed in ice chests to prevent cross-contamination. Soil samples (non-volatiles only) will be mixed thoroughly to ensure that the sample is as representative as possibleof the sample media. The most common method of mixing is referred to as quartering. Thequartering procedure will be performed as follows:

1. The material in the sample pan will be divided into quarters and each quarter will bemixed individually.

2. Two quarters will then be mixed to form halves.3. The two halves will be mixed to form a homogenous matrix.

This procedure will be repeated several times until the sample is adequately mixed. If roundbowls are used for sample mixing, adequate mixing is achieved by stirring the material in a


circular fashion, reversing direction, and occasionally turning the material over.

B3.1 Sample Labeling and IdentificationAn alphanumeric coding system will uniquely identify each sample collected during the fieldinvestigation. A coding system is used to identify each sample collected during the samplingprogram. This coding system will provide a tracking procedure to allow retrieval of informationconcerning a particular sample and assure that each sample is uniquely identified. Each sampleidentification number is composed of a minimum of three components (sometimes four) that aredescribed as follows:

Site Code: A two-letter designation will be used to identify the sample collection site. Thedesignation for mis site will be as follows:

SPE - Sonford Products Ecological Study v

Sample Code: A letter designation will be used to identify the specific medium being sampled oranalysis. The sample media designation for the site investigations are as follows:

SS - Surface soilSW - Surface WaterRS-Rinsate

•BIO - Bioaccumulation testTOX - Toxicity testPB - Preservative blank

Number: A number designation will be used to number the sample according to sample locationor, for trip blanks and rinsate blanks, are numbered sequentially. Samples are numberedconsecutively within the sample type and are not related to the date of collection (i.e., 1,2, etc.).Duplicate/split samples are indicated by having a prefix of "5" (e.g., 521 = duplicate or split ofsample 21 for a given media).

Based on this numbering system, a sample labeled as SP-SS-20-BIO would represent a soilsample collected from the SP site location 20 for use in bioaccumulation testing.

B3.2 Sample TagA sample tag will be completed for each sample using waterproof non-erasable ink. Details ofthe sample tagging procedures are provided hi the SESD Operating Procedure for Sample andEvidence Management, SESDPROC-005 (USEPA, 2007o).

B3.3 Sample SealsSamples will be sealed as soon as possible following collection utilizing the EPA custody seal(EPA Form 750Q-2(R7-75)). Details of the use of the sample seals will be obtained from theSESD Operating Procedure for Sample and Evidence Management, SESDPROC-005 (USEPA,2007 o). The sample custodian will date, sign, and initial the seal.

B3.4 Chain-of-Custody Record


Chain-of-Custody procedures will be performed as discussed in the S.ESD Operating Procedurefor Sample and Evidence Management, SESDPROC-005 (USEPA, 2007o) and are brieflydescribed below. The field Chain-of-Custody Record will be used to record the custody of allsamples or other physical evidence collected and maintained by field samplers. This Chain-of-Custody Record documents transfer of custody of samples from the sample custodian to anotherperson, to the laboratory, or other organizational elements. A sample is considered in custody ifit is: . •

1. In one's actual possession;2. In one's view after being in his/her physical possession;3. Sealed so that sample^ integrity will be maintained after being in physical custody; or4. In a secure area, restricted to authorized personnel.

To simplify the Chain-of-Custody Record as few people as possible will have custody of thesamples or physical evidence during any field sampling event. The Chain-of-Custody Recordalso serves as a sample logging mechanism for the laboratory sample custodian. A Chain-of-Custody Record will be completed for all samples or physical evidence collected. A separateChain-of-Custody Record should be used for each final destination or laboratory utilized duringthe investigation. All of the information supplied in the indicated spaces on the field Chain-of-Custody Record. The Chain-of-Custody Record is a serialized document. Once the Record iscompleted, it becomes ah accountable document and will be maintained in the project file.

B3.5 Sample Shipment/TransportationSample shipment will be performed iri accordance with the procedures described in SESDOperating Procedure for Sample and Evidence Management, SESDPROC-005 (USEPA,2007o).

B3.6 Sample Receipt/StorageIn the lab, samples will be received by the EPA sample custodian or designate. Samples that are

.delivered after hours by field personnel will be secured in the custody room by the fieldpersonnel and will be received by the sample custodian or designate the following day. Ifsamples are received after hours or on weekends, the Facility Guard will secure the samples inthe custody room and then notify the sample custodian or designate the next business day. EPApersonnel sometimes receive samples from the field after hours. In these instances, the personreceiving the sample will sign the Chain-of-Custody form, check and record cooler temperature;and give the Chain-of-Custody to the EPA sample custodian. If there are any problems with thesamples the field program leader will be notified immediately.

Upon arrival at the SESD ASB laboratory, all samples will be stored in the EPA custody room.Access to the custody room is controlled by swipe card entry which is monitored by computer.Each time a swipe card is used; the name of the card user, the date, and time of entry are storedelectronically. At the time of receipt, the sample custodian will sign the Chain-of-Custody formand record the date and time of sample receipt.

The sample custodian will be responsible for the inspection of all shipping containers received inthe lab for overall integrity and to ensure that the containers were not altered or tampered with

34 of 52EPA Project ID: 08-0079.

during shipment. He/she will also check the cooler temperature and ensure that there were nosample container breakages or sample leaks during shipment. If there are any problems with anyof the samples, the sample custodian will record the problem and immediately notify the fieldproject leader for further action. Details of the sample receipt and storage procedures areprovided in chapter 3 of the ASBLOQCM (USEPA 2007a).

B4 Analytical MethodsBoth field and laboratory analytical methods will be performed for this site investigation. Inaddition to chemical analyses, laboratory analysis will include bioaccumulation testing:

B4.1 Chemistry Laboratory Analytical MethodsAll analyses will be performed in accordance with the current CLP SOW. The analyticalmethods, equipment and standards, calibration procedures, extraction and digestion procedures,laboratory decontamination procedures, waste disposal procedures, corrective actions, and anyspecific method performance requirements have been specified in the CLP SOW. The methodreporting units and minimum quantitation limits will be based on the CLP contract requiredquantitation limits (CRQL) provided in the SOM01.2 (USEPA 2007p) and ILM05.4 (USEPA2007q) SOW. If PCP is not detected, selected ion monitoring (SIM) will be run to determine thePCP concentration. Dioxin/furan reporting units and minimum quatitation limits will beprovided in DLM02.1 (USEPA 2005).

If a CLP method is not available for a particular analysis, other EPA-approved methods may beused. Details of other EPA methods to be used for this site investigation are provided in thechapters 8 and 9 of the ASBLOQCM (USEPA 2007a). For non-standard method applications,such as for unusual sample matrices and situations, appropriate method performance studyinformation will be used to confirm the performance of the method for the particular matrix asdirected by the project manager. If previous performance studies are not available, they will bedeveloped during the project, as directed by the project manager, and included as part of theproject results.

B4.2 Field Analytical MethodsField analytical methods will also be used to check the concentrations of selected inorganicspecies prior to sampling. The Field Analytical Support Project (FASPj equipment required, andsub-sampling or extraction methods and quantitation limits are provided in the FASP OPs and inthe QMP (USEPA, 2007k).

B4.3 Bioaccumulation and Toxicity Testing MethodsThe toxicity/bioaccumulation test methods, equipment required, and sub-sampling methods willbe obtained from the SESD toxicity laboratory OPs and the following documents:

• ASTM 1997. Standard Guide for Conducting Laboratory Soil Toxicity orBioaccumulation Tests with the Lumbricid Earthworm, Eisenia foetida. AmericanSociety for Testing and Materials. ASTM El676-97.

• Greene, J.C., C.L. Bartels, W.J. Warren-Hicks, B.R. Parkhurst, G.L. Linder, S.A.Peterson, and W.E. Miller. Protocols for Short Term Toxicity Screening of Hazardous


Waste Sites. EPA 600/3-88/029. USEPA. February 1989.• USEPA. 1994. Short-Term Methods for Estimating the Chronic Toxicity of Effluents

and Receiving Waters to Freshwater Organisms. EPA/600/4-91/002. United StatesEnvironmental Protection Agency. Office of Research and Development. July 1994.

B5 Quality Control .Each sampling, analysis, or measurement technique to be performed for this site investigationhas associated QC requirements. QC activities associated with the. field operations, include butare not limited to the following: field blanks, field duplicates, split samples, temperature blanks,equipment (rinse) blanks, and rinse blanks. Laboratory QC activities may include use of blanks,MS and MSD, surrogates, second column confirmation, laboratory control samples, initial and.continuing calibration verifications, etc. The specific QC requirements, acceptance criteria,corrective action in case of non-conformance and the procedures used to calculate applicablestatistics, are provided in the EPA Region 4 field and laboratory OPs and methods, and hi thefollowing QA/QC documents: SESD Operating Procedure for Field Sampling Quality ControlSESDPROC-011 (USEPA, 2007d)), chapter 5 of the ASBLOQCM (USEPA, 2007a), CLP SOWfor organic and inorganic analyses SOM01.2 (USEPA, 2007p) and ILM05.4 (USEPA, 2007q),respectively. Dioxin/furan reporting units and minimum quatitation limits will be provided inDLM02.1 (USEPA 2005). The procedures used to calculate applicable statistics are alsopresented in Section 3 of this QAPP.

B6 Instrument/Equipment Testing, Inspection, and MaintenanceInspections and acceptance testing of instruments, equipment, and their components affectingquality in the field and laboratory will be performed and documented in field notebooks andlaboratory instrument logbooks to assure their intended use as specified. Final acceptance of allinstruments, equipment, and supplies will be performed by the EPA Project Manager ordesignee. . . . . .

B6.1 Field InstrumentsProper testing, inspection, and maintenance of field instrumentation are critical to ensuring thelongevity of the useful life of the instrument, as well as providing reliable analyses and data. Allproject field personnel will be responsible for ensuring that primary maintenance is carried outon their field instruments. Typical field instruments will include pH meter, dissolved oxygenmeter, thermometer, specific conductivity meter, turbidity meter, air monitoring meter, etc. Thetypes of field instruments and procedures for carrying out preventive maintenance on the fieldinstruments are provided in SESD Operating Procedure for Equipment and Supply Management,SESDPROC-108 (USEPA, 2007r).

Critical spare parts will be kept for field instruments and instrument logs as determined by theEPA FEC manager. Records of instrument repairs will be kept in field instrument logbooks.Service agreements will be in place with the various instrument manufacturers to perform routinemaintenance of all field instruments as necessary. If any field equipment failure occurs thatcannot be readily remedied by the field personnel or any required equipment or supplies areunavailable to accomplish required work, the field project manager will take immediate action toresolve the situation.

36 of 52EPA Project ID: 08-0079'

B6.2 Laboratory InstrumentsProper testing, inspection, and maintenance of laboratory instrumentation is a key ingredient toboth the longevity of the useful life of the instrument, as well as, providing reliable analyses anddata. All project analysts will be responsible for ensuring that primary maintenance is carried outon their instruments. A list of the laboratory instruments requiring periodic maintenance may befound in chapter 7 of the ASBLOQGM (USEPA 2007a). The procedures'for carrying outpreventive maintenance on all analytical instruments are provided in chapters 8 and 9 of theASBLOQCM (USEPA 2007a).

Critical spare parts will be kept for all of the instruments and records of instrument repairs willbe kept hi instrument logbooks. Service agreements are in place with the various instrumentmanufacturers and vendors to perform routine maintenance of laboratory instruments asnecessary. If any laboratory equipment failure occurs that cannot be readily remedied by thelaboratory personnel ,.or any required equipment or supplies are unavailable to accomplishrequired work, the lab manager will immediately be notified for further action.

•B7 Instrument/Equipment Calibration and FrequencyLaboratory and field instruments and equipment used for data generation or collection will beinspected and calibrated according to the manufacturers' specifications. The frequency of thecalibrations is dependent on the type of instrument/equipment, manufacturer's recommendations,and intended use.

B7.1 Field InstrumentsCalibration procedures, frequency, and verification for field instruments such as pH, salinity,conductivity, and dissolved oxygen meters, turbidimeters, and organic vapor analyzers, will beperformed in the field prior to use and in accordance with the procedures described in SESDOperating Procedure for Equipment Inventory and Management, SESDPROC-108 (USEPA,2007r) and SESD Operating Procedure for In-situ Water Quality, SESDPROC-111 (USEPA,2007e)'.

B7.2 Laboratory InstrumentsCalibration procedures and frequency for laboratory instruments will be performed according tothe procedures described in chapters 8 and 9 of the ASBLOQCM (USEPA 2007a).

B8 Inspection/Acceptance of Supplies and ConsumablesPrior to acceptance, all field and laboratory supplies and consumables will be inspected to ensurethat they are in satisfactory condition and free of defects. The responsible personnel and specificprocedures to be used for the inspection and acceptance of supplies and consumables for the fieldare specified in the following procedures: SESD Operating Procedure for Purchasing ofEquipment and Supplies, SESDPROC-015 (USEPA, 2007s), SESD Operating Procedure forEquipment Inventory and Management, SESDPROC-108 (USEPA, 2007r), and SESD OperatingProcedure for Field Sampling Quality Control SESDPROC-011 (USEPA, 2007d). Laboratoryprocedures are specified in chapter 3 of the ASBLOQCM (USEPA 2007a). If any consumables,


supplies or services which are evaluated via the specified procedures.,prove to be unsuitable, theperson making that determination shall document the issue in an email to the Quality 'AssuranceOfficer and copy the email to the Chemical Hygiene Officer and/or Field Project Leader. Thedocumentation should include a description of die item, the deficiency and the vendor. Wherepossible, a copy of the purchase request shall be transmitted to the QA Officer (QAO). The QAOwill compile all occurrences of unsuitable consumables, supplies or services and determine whatfurther action may be necessary.

B9 Non-direct Measurements. • ' • • »

Non-direct measurement data include information from site reconnaissance, literature searches,and interviews. The acceptance criteria for such data include a review by someone other than theauthor. Any measurement data included in information obtained from the above-referencedsources will determine further action at the site only to the extent that those data can be verified.If any deficiencies are observed the QAO, field project leader and RPM will be contacted to aidin the resolution of the problem. Sometimes the limitations may involve problems with existingdata. If this happens, all of the data in the project files will be reviewed to ensure correctness. Ifthe problems cannot be resolved, the data may be flagged as unusable or, in the case of the-ecological risk aspect of the project the data will be discussed as an uncertainty.

BIO Data ManagementAll field and analytical data generated from the site Investigations will be managed through theEPA Region 4 data management and document control and security system. Field documentswill be kept in project files maintained by the Field Project Leader until project completion. TheField Project Leader will track all of the data and maintain the original chain-of:custody records.All data generated for this field investigation, whether hand-recorded or obtained using anelectronic data logger will be recorded, stored, and managed in accordance with the followingprocedures: SESD Operating Procedure for Control of Records, SESDPROC-002 (USEPA,20071) and SESD Operating Procedures for Logbooks, SESDPROC-010 (USEPA, 2007f).Laboratory data will be maintained through the Region 4 Laboratory Information ManagementSystem (R4LIMS). The LIMS software, now called ELEMENT, will be used to manage allanalytical data, their final use and storage, and provide security for all analytical data. Details ofthe data tracking procedures and data management and security procedures are specified in theASBLOQCM (USEPA 2007a).

EPA Region 4 computer databases will be used to store, track, and retrieve all projectinformation. Personnel training records, travel requests, travel requests, project status, progressreports, meeting records, correspondence, document control numbers, etc. will be trackedthrough these computer databases. Additional details of the data tracking and managementsystem, as well as the control mechanisms for detecting and controlling errors are provided inRegion 4 QMP (USEPA, 2007k). '

BiO.l Data Entry and CorrectionsAll data entries shall be made in indelible ink and shall be dated on the day of die entry and shallbe signed or initialed by the person entering the data. Corrections to project documents shall be


made according to Good Laboratory Practice (GLP) and Good Automated Laboratory Practice(GALP) guidelines. All records shall be made in indelible ink. Any change in entries shall bemade so as not to obstruct the original entry (a single line through the incorrect entry), shallindicate a reason for such change, and shall be dated and signed or identified at the time of suchchange.

In automated data collection systems, the individual responsible for the direct data input shall beidentified at the time of the data input. Any change in automated data entries shall be made so asnot to obstruct the original entry (a single line through the incorrect entry), shall indicate a^easonfor such change, and shall be dated and signed or identified at the time of such change.


GROUP C: ASSESSMENT AND OVERSIGHT

The elements in this section address the types of assessments and oversight activities to be-performed for the site investigations in order to ensure that the QAPP is implemented as planned.

Cl - Assessments and Response ActionsThe EPA Region 4 QA Program includes both self-assessments and independent assessments aschecks on quality of data generated for all work assignments. All documents prepared for theproject will undergo different levels of review starting from the primary person preparing thedocument, to higher-level peer reviews. No independent field or laboratory audits are scheduledto be conducted during these site investigations. However, routine audits of the laboratoryactivities may be conducted by the organic and inorganic Section Chiefs. The QA Officer mayalso perform independent audits of the field and laboratory operations. The Chiefs of theHazardous Waste Section and Ecological Assessment Branch may also perform audits of thefield activities pertaining to their sections. Also, QA personnel from the EPA headquarters mayperform audits of the laboratory. If any problems are identified during any of the audits,immediate steps will be taken to correct them. These steps may include correcting the problem inthe presence of the assessor, or if the problem cannot be immediately corrected, a memorandummay be sent to the field project leader or responsible party to correct any identified discrepancies.Further information on assessments and response actions may be found in the SESD OperatingProcedure for Project Planning, SESDPROC-016 (USEPA, 2007t), SESD Operating Procedurefor Corrective Action, SESDPROC-009 (USEPA, 2007u), SESD Operating Procedure forComplaint Resolution, SESDPROC-020 (USEPA, 2007v), and chapter 4 of the ASBLOQCM(USEPA 2007a).

C2 Reports to ManagementThe Project Leader is responsible for providing a QA report to the RPM and SESD managementat the completion of the site investigations. The QA report will Include project status and theresults of system audits and periodic quality assessments, if any. In addition, whenever majorquality problems are encountered, a QA report will be prepared to document the quality problemand proposed corrective measures. Field staff will note any quality problems hi a logbook orother form of documentation. Any procedures or actions used to resolve QA/QC problems willbe documented in the field logbooks.


GROUP D: DATA VALID ATION AND US ABILITY

All of the field and laboratory data collected during the site investigation will undergo rigorousreview, verification, and validation processes as discussed in the following sections.

Dl Data Review, Verification, and ValidationAll data derived from SESD field measurements will be reviewed, verified, and validated inaccordance with the SESD Operating Procedure for Report Preparation and Distribution,SESDPROC-003 (USEPA, 2007m). The EPA Region 4 Office of Quality Assurance will review,verify, and validate selected analytical data produced from the site investigations. Data generatedthrough the CLP SOW will be reviewed and validated based on the National FunctionalGuidelines for data review (organic and inorganic) by EPA Region 4 ESAT contractors. Datagenerated by the EPA Region Analytical Services Branch will undergo a peer review process asdescribed in chapters 8 and 9 of the ASBLOQGM (USEPA 2007a). All other data will bereviewed and validated using EPA Region 4 data review OPs. The specific procedures foraccepting, rejecting, and/or qualifying the data in a consistent and objective manner may beobtained from the following documents:

1. USEPA Contract Laboratory Program National Functional Guidelines for OrganicData Review. EPA 540/R-99/008. Office of Emergency and Remedial Response,United States Environmental Protection Agency, Washington October 1999. October1999.

2. USEPA Contract Laboratory Program National Functional Guidelines for InorganicData Review. Final. EPA 540-R-01-008. United States Environmental ProtectionAgency, Washington, DC. July 2002. (USEPA, 2002c)

3. Data Validation Standard Operating Procedures for Contract Laboratory ProgramRoutine Analytical Services, Revision 2.1, Office of Quality Assurance. United StatesEnvironmental Protection Agency, Region 4 SESD, Athens, Georgia. July 1999.

4. Data Validation Standard Operating Procedures for Chlorinated Dioxin/FuranAnalysis by High Resolution Gas Chromatography/High Resolution MassSpectrometry. Revision 3.0. United States Environmental Protection Agency, Region4, SESD, Athens, Georgia. May 2002. (USEPA 2002)

D2 Verification, and Validation MethodsData produced from all site investigations will be verified through the examination of field notes,field log books, telephone logs, site photographs, chain-of-custody and sample traffic recordswhich are all kept in the master project file by the Field Project Leader as part of the DocumentControl records. The data validators will review the sample handling and shipping records,holding times, laboratory .blank analysis, spike recovery, MS/MSD results, performanceevaluation sample results, and laboratory QC results. They. will also verify and performcalculations for the PARCC parameters as discussed in Group A. Issues involving missing data


from the laboratory (e.g. missing results, chromatograms, forms, qr documents, etc.) will beresolved by the data validators contacting the performing laboratory for the missing data. Issuesregarding the field will be resolved through the field project leader.

D3 Reconciliation with User RequirementsAll of the field and analytical data generated from the site investigations will be reviewed andvalidated for correctness and to ensure that the DQOs are met. The usability of all data derivedfrom SESD field sampling and measurements conducted during this field investigation will beevaluated in accordance with the SESD Operating Procedure for Report Preparation andDistribution, SESDPROC-003 (USEPA, 2007m). Any limitations to the data will be reported tothe decision makers in the form of flags or data qualifiers. A list of data qualifiers, theirdefinitions, and their effects on the reported results will be included in the project deliverables.The list of data qualifiers to be used to flag the data are provided the ASBLOQCM (USEPA2007a).

Additional information that will be used to determine if the DQOs have been met includes thefollowing:

IT Were the samples collected in the proper sampling containers?2. Was proper preservation employed for the collected samples?3. Were holding times met?4. Were samples collected from the intended locations?5. Were the desired concentration gradients achieved?6. Were the actual number of samples collected during this project consistent with the

number and type proposed in the SAP?

After data validation and evaluation, the RPM and risk assessment group will determine thesuitability of the data for their intended usage. This will be done by reviewing the available datato determine if all of the DQOs identified for the site investigations were met. Any limitations onthe use of the data,for the ERA will be communicated to the data users and discussed in the"Uncertainties" section of the project reports and ecological risk assessment.


SECTION 4 REFERENCES

ASTM 1997. Standard Guide for Conducting Laboratory Soil Toxicity or Bioaccumulation Testswith the Lumbricid Earthworm,' Eisenia foetida. American Society for Testing and Materials.ASTM E1676-97.

v

Black and Veatch. 2007. Ecological Risk Assessment, Steps 1-4 - Screening-Level Assessment,Problem Formulation, and Study Design. Sonford Products Site, Flowood, Rankin County,Mississippi.

Greene, J.C., C.L. Bartels, W.J. Warren-Hicks, B.R. Parkhurst, G.L. Linder, S.A. Peterson, andW.E. Miller. 1989. Protocols for Short Term Toxicity Screening of Hazardous Waste Sites. EPA600/3-88/029. USEPA. February 1989.

Mississippi Bureau of Pollution Control (MBPC). 1989. Preliminary Reassessment Report forthe Sonford Products Site, September 28, 1989.

MBPC. 1985. Site Inspection Report for Sonford Products, September 10, 1985.

MBPC. 1980. Hazardous Waste Inspection Form for the Sonford Products Corporation,Prepared by Freddie Roberts, December 31, 1980.

U.S. Department of the Interior (USDI). 1974. National Wetlands Inventory Maps forMississippi: Florence, Jackson, Jackson SE, and Whitfield Quadrangle Maps, Datum WGS84,Scale 1:24,000, September 1974.

USEPA. 2007a. Analytical Services Branch Laboratory Operations and Quality Control Manual(ASBLOQCM). United States Environmental Protection Agency. Region 4 Science andEcosystems Support Division.

USEPA 2007b. SESD Operating Procedure for Soil Sampling, SESDPROC-300. Region 4,SESD, Athens, GA

USEPA 2007c. SESD Operating Procedure for Surface Water Sampling, SESDPROC-2Q1.Region 4, SESD, Athens, GA .

USEPA 2007d. SESD Operating Procedure for Field Sampling Quality Control SESDPROC-011. Region 4, SESD, Athens, GA .

USEPA 2007e. SESD Operating Procedure In-situ Water Quality Sampling SESDPROC-111.Region 4, SESD, Athens, GA

USEPA 2007f. SESD Operating Procedure for Field Records (Logbooks), SESDPROC-010.Region 4, SESD, Athens, GA


USEPA 2007g. SESD Operating Procedure for Packaging, Marking, Labeling, and Shipping ofEnvironmental and Waste Samples, SESDPROC-209. Region 4, SESD, Athens, GA

USEPA 2007h. SESD Operating Procedure for Field Equipment Cleaning and Decontaminationat the FEC, SESDPROC-206. Region 4, SESD, Athens, GA

USEPA 20071. SESD Operating Procedure for Field Equipment Cleaning and Decontamination,SESDPROC-205. Region 4, SESD, Athens, GA

USEPA 2007J. SESD Operating Procedure for the Global Positioning System, SESDPROC-110.Region 4, SESD, Athens, GA

USEPA 2007k. Quality Management Plan for EPA Region 4. SESDPLAN-001.

USEPA 20071. SESD Operating Procedure for Control of Records, SESDPROC-002. Region 4,SESD, Athens, GA :

USEPA 2007m. SESD Operating Procedure for Report Preparation and Distribution,SESDPROC-003. Region 4, SESD, Athens, GA

USEPA 2007n. SESD Operating Procedure for Management of Investigation Derived Waste,SESDPROC-202. Region 4, SESD, Athens, GA

USEPA 2007o. SESD Operating Procedure for Sample and Evidence Management,SESDPROC-005. Region 4, SESD, Athens, GA

USEPA 2007p. Multi-Media, Multi-Concentration, Organic Analytic Service for Superfund(SOM01.2). EPA 540-FS-07-001. United States Environmental Protection Agency. Office of .Solid Waste and Emergency Response. Washington, DC. August 2007.

USEPA 2007q. Multi-Media, Multi-Concentration, Inorganic Analytic Service for Superfund(EJVI05.4). EPA 540-FS-07-004. United States Environmental Protection Agency. Office ofSolid Waste and Emergency Response. Washington, DC. January 2007.

USEPA 2007r. SESD Operating Procedure for Equipment and Supply Management,SESDPROC-108. Region 4, SESD, Athens, GA

USEPA 2007s. SESD Operating Procedure for Purchasing of Equipment and Supplies,SESDPROC-015. Region 4, SESD, Athens, GA

USEPA 2007t. SESD Operating Procedure for Project Planning, SESDPROC-016. Region 4,SESD, Athens, GA • ' '. '

USEPA 2007u. SESD Operating Procedure for Corrective Action; SESDPROC-009. Region 4,SESD, Athens, GA .


USEPA 2007v. SESD Operating Procedure for Complaint Resolution, SESDPROC-020. Region4, SESD, Athens, GA , "

USEPA 2005. Multi-Media, Multi-Concentration, Dioxin and Furan Analytic Service forSuperfund (DLM02.0). EPA 540-F-05-003. United States Environmental Protection Agency.Office of Solid Waste and Emergency Response. Washington, DC. September 2005.

-N

USEPA 2002. Data Validation Standard Operating Procedures for Chlorinated Dioxin/FuranAnalysis by High Resolution Gas Chromatography/High Resolution Mass Spectrometry.Revision 3.0. United States Environmental Protection Agency, Region 4, SESD, Athens,Georgia. May 2002.

USEPA. 2002b. Safety, Health, and Environmental Management (SHEM) Program Proceduresand Policy Manual. United States Environmental Protection Agency. Region 4 Science andEcosystems Support Division.

USEPA 2002c. Contract Laboratory Program National Functional Guidelines for Inorganic DataReview. Final. EPA 540-R-01-008. United States Environmental Protection Agency,Washington, DC 20460. July 2002.

USEPA 2001a. EPA Requirements for Quality Assurance Project Plans. EPA QA/R-5. Office ofEnvironmental Information. United States Environmental Protection Agency. EPA/240/B-01/003. March 2001.

/

USEPA 2000a. Guidance for the Data Quality Objectives Process, EPA QA/G-4. United StatesEnvironmental Protection Agency. August 2000.

USEPA 1999. Contract Laboratory Program National Functional Guidelines for Organic DataReview. EPA 540/R-99/008. Office of Emergency and Remedial Response, Washington, DC.October 1999

USEPA 1999. Data Validation Standard Operating Procedures for Contract Laboratory ProgramRoutine Analytical Services Revision 2.1, Office of Quality Assurance. United StatesEnvironmental Protection Agency, Region 4, SESD, Athens, Georgia. July 1999.

US EPA 1997. Representative Sampling Guidance Document, Volume 3: Ecological, InterimFinal. United States Environmental Protection Agency. Edison NJ: Environmental ResponseTeam Center, Office of Emergency and Remedial Response. March.

USEPA. 1994. Short-Term Methods for Estimating the Chronic Toxicity of Effluents andReceiving Waters to Freshwater Organisms. EPA/600/4-91/002. United States EnvironmentalProtection Agency. Office of Research and Development. July 1994.

4JSEPA. 1985. Removal Report for Sonford Products, TDD No. 04-8504-13, April, 1985.


Weston Solutions, Inc. (Weston). 2005. Letter Report, Revision 0, Sonford Products, Preparedfor EPA Region 4, TDD No. 4W-05-10-A-003, September 14, 2005. '

Weston. 2004. Sonford Products Preliminary Assessment/Site Inspection, Revision 1, Preparedfor EPA Region 4, August 24, 2004.


Tables


This Page Intentionally Left Blank


Table B-l. Proposed Number of Abiotic Samples, Analysis Methods, Sample Containers, Preservation Methods, andHolding Times, Sonford Products Site, Fldwood, Mississippi.

Soil Toxicity/Bioaccumulationand generalchemistry .

7 (4 for toxicity, 7forbioaccumulation,includes one forbackground) forchemical analyses.Additional samplewill be a split forQC.

CLP TAL Inorganics SOWILM05.4

CLP TCL Organics SOWSOMO 1.2 (except PCBs)

VOAs

Dioxins/furans DLM02.0

pH

Grain Size (ASTMD421/D422)

TOG (SW846 Method 9060)

Bioaccumulation/toxicitytests

8-oz wide-mouth jar

8-oz wide-mouth jar

3- Encore, 2ozsoil VOA

8-oz wide-mouth jar

In lab, frombucket

8-oz wide-mouth jar

Same jar asgrain size

3.5 gal plasticbucket

Ice 4 + 2 °C

Ice4±2°C

Ice 4 + 2 °C

Ice 4 + 2 °C

Ice 4 + 2 °C

Ice4±2°C

Ice 4 + 2 °C

Ice4 + 2°C

180 daysMercury 28 days

14 days toextract40 days toanalyze

48 hours

1 year

NS

NS

28 days

48 hours fromreceipt

If PCP is not detected, SV-SIM will be run.

49 of 52 .EPA Project ED: 08-0079

Table B-l. Cont. Proposed Number of Abiotic Samples, Analysis Methods, Sample Containers, Preservation Methods, andHolding Times if Surface Water is collected, Sonford Products Site, Flowood, Mississippi.

EarthwormTissue

Eisenia foetidatissue

9 tissue samples (6site, 1 background, 1lab control, and 1 sitesample split followingthe bioaccumulationtests) for chemicalanalyses

CLPTALInorganicsILM05.4

CLP TCL OrganicsSOWSOM01.2(excluding PCBs)

Dioxins/furansDLM02.0

Lipid content

8-ozjar

8-ozjar

8-ozjar

8-ozjar

Freeze withdry ice

Freeze withdry ice

Freeze withdry ice

Freeze withdry ice

NS (<28day)

NS (<28day)

1 year

NS (<28day)

Surface 'Water

Surface watersamples forchemical analyses

Up to 3 locationsplus background

CLP TAL Inorganics SOWILM05.4

CLP TCL Organics SOWSOM01. 2 (except PCBs)

VOAs

Toxicity test ;

1 Liter plasticpoly

2- 1 Literambers ••;

3- 40 ml glassVGA Vial

1 gal Amber

Ice 4 ± 2 °CHNO3topH<2

Ice4 + 2°C

Ice 4 ± 2 °C

Ice 4 + 2 °C

180 daysMercury 28 days

14 days toextract40 days toanalyze

14 days-

48 hours fromreceipt

NOTE: The usual field measurements of temperature, pH, conductivity, hardness, turbidity will be takenCLP = Contract Laboratory ProgramSOW = Statement of Work


Table B-l. Coot. Proposed Number of Abiotic Samples, Analysis Methods, Sample Containers, Preservation Methods, andHolding Times if Surface Water is collected, Sonford Products Site, Flowood, Mississippi.

TAL = Target Analyte List. . .TCL = Target Compound List . .TOC = Total organic carbon . . - .NA = Not applicable . . . . 'NS = Not Specified v , ' . . . . ' . . , ' . •SV = Semi-volatile . . ' ;• . , .SIM = Selective Ion. Monitoring .

Field QA/QC. . ' 'Soil- split field sample, MS/MSD, temperature blanlc (for cooler), field blankSurface Water- duplicate field sample, MS/MSD, temperature blank (for cooler), preservative blank, field blank, and blind blank


Figure I. Soil Sampling Locations, Sonford Products Site, Flowood, MS

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