Section: 8Revision No: 1Date: Aug 10, 1988Page 5 of 6

The high volume air sampler of theVenturi/Magnehelic type will be used tomonitor the air flow through the system. Thesampling head consists of a PUF cartridge anda quartz filter. The air sample is drawnthrough the head by the pump, monitored by aMagnehelic gauge and venturi assembly,regulated by a flow control valve, thevoltage variator controls the speed of thepump motor. The apparatus is also equippedwith an elapsed time meter.

A semi-annual multi-point calibration isperformed using an audit calibrationorifice.1 A single point calibration isperformed before and after each samplingevent.

Before calibration a blank PUF cartridge andfilter are placed in the sampling head andthe sample pump is turned on. The flowcontrol valve is opened fully and the voltagerheostat is adjusted so that the sample flowrate corresponds to approximately 110% of thedesired flow rate indicated on the Magnehelicpump motor is allowed to warm-up for aboutten minutes, and the flow control valve isadjusted to the desired flow rate. Recordthe ambient temperature and barometricpressure in the field notebook plus any otherpertinent information such as weatherconditions.

Place the calibration orifice on the samplehead and attach a manometer to the tap on thecalibration orifice. Turn the sampler power'off momentarily to zero the manometer. Thesampler power is turned-back on and the

Reference method for Determination of SuspendedParticulates in the Atmosphere (High Volume Method).Federal Register. Sept. 14, 1972 or 40 CFR 50 AppendixB.

Appendix I

AR303M I

Section: 8Revision No: 1Date: Aug 10, 1988Page 6 of 6

manometer reading is recorded (whenstabilized) in the field notebook. Turn thesampler off until the sampling event isready.

d. The calibration curve for the audit orificeis to calculate the sample flow from the dataobtained in step c above. The calibrationcurve for the Venturi/Magnehelic assembly isused to calculate the sample flow from step babove. The calibration data is tabulated inthe field notebook and referred to after thesampling event. If the post-calibrationreading does not agree within 10% of the pre-calibration, the assembly should be inspectedfor flow block or damage. If no obviousproblems are discovered, recalibrate theassembly by the multi-point high volumemethod.

e. An annual multi-point calibration of thecalibration orifice against a primarystandard should be obtained.

Appendix I

'lf 12

Section: 9Revision: 1Date: Aug 10, 1988Page: 1 of 3

9. ANALYTICAL PROCEDURES

9.1 Laboratory Analyses

The methods indicated in Tables 3-3 and 5-1 are derived fromthe following referenced manuals:

1. "Statement of Work for Organics Analysis,"Multi-Media, Multi-Concentrations USEPAContract Laboratory Program, October 1986,and Revision of August 1987.

2. "Methods for Chemical Analysis of Water andWastes", USEPA Environmental Monitoring andSupport Laboratory, Cincinnati, OH, EPA

' 600/4-79-020. Revised March 1983.

3. The Analysis of Polychlorinated Dibenzo-p-dioxins and polychlorinated dibenzofurans;Method 8280 organics in soil and hazardousmaterial characterization. "Methods forEvaluating Solid Waste," EPA SW-846, 3rdedition, November 1986.

The methods described above will be used by the designatedlaboratory to analyze all samples with the exception of compoundsthat are not detectable by the methods above. The laboratorywill submit its working standard operating procedures (SOP)manual along with a working Quality Assurance Plan. Thelaboratory will submit a method for the analysis of thetrichlorobenzene and tetrachlorobenzene isomers preferably byanalyzing standards to develop a calibration curve using purecompounds to determine retention time for positive identificationof each isomer.

Appendix I

AR303M3

Section: 9Revision: 1Date: Aug 10, 1988Page: 2 of 3

9.2 Method Selection

The methods specified cover the project compound list toinclude those compounds that may be found on-site. All methodsare selected to get the most accurate representation of thesampling point possible. Method detection limit selection isbased on the real assessment and analytical characterization dataquality objectives. The complete deliverables package was deemednecessary to ensure the best quality control data availability toGTI's Data Validation Chemist.

The methods selected specify the frequency and acceptancecriteria for all associated quality control samples.

Quality Control samples include one method blank, matrixspike, and matrix spike duplicate every twenty samples or everytwelve hours, whichever occurs most frequently. Surrogate spikesare compounds that are added to every sample, method, field ortrip blank, matrix spike and matrix spike duplicate sample; andsurrogate recoveries are monitored to indicate the necessity ofreanalysis if more than two surrogates in any analytical fractionand/or any one volatile surrogate is outside criteria.

Tables 5-2, 5-3. and 5-4 summarize the quality assurancerequirements set forth in this QAPP. Acceptance of the data willbe based on the results of a full-scale review of the entire datadeliverables package. A detailed account of the data validationprocess is presented in Section 10 of this document.

Appendix I

AR303UII*

Section: 9Revision: 1Date: Aug 10, 1988Page: 3 of 3

The PCS analysis will be performed with the sulfuric acidcleanup-^ procedure to eliminate potential phthalatecontamination.

9.3 Laboratory Selection

A laboratory currently participating in the USEPAj_s ContractLaboratory Program will be chosen to perform all analyses andprovide a' complete deliverables package. Additionally, thelaboratory will perform all analyses by current CLP protocols,including sample tracking, instrument capabilities, and personnelqualification.

"The Determination of Polychlorinated Biphenyls inTransformer Fluid and Waste Oil," EPA 600/4-81-045.

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 1 of 18

10. DATA REDUCTION, VALIDATION. AND REPORTING

Data validation practices will be followed to insure that newdata is not altered and an audit trail is developed for data thatwill be reduced. Data validation practices occur in the field,laboratory, and GTI office.

10.1 Data Reduct ion10.1.1 Field Data Collection and Reduction

GTI field personnel will log all field measurements,observations, and field instrument calibrations in bound, water-proof field notebooks. Notebook entries will be dated, legible,and contain accurate and inclusive documentation of anindividual's project activities. Because the logbook will be usedto write reports, it will contain only facts and observations.Language will be objective, factual, and free of personal feelingsor other terminology that may prove inappropriate. Eachindividual making an entry into the field notebook will date andsign the entry.

It is anticipated that the data reduction for thisinvestigation will be minimal and will consist primarily oftabulating analytical results.

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 2 of 18

10.1.2 Laboratory Data Collection and Reduction

The data reduction scheme used in the lab for each of themeasurement parameters, including the formulas used forconcentrations for water, soils, sediment, biota, air, surfacewipes, and core samples will be that stated in the standardoperating procedure for the analytical method used. The "methodreference" column of Table 5-1 lists the analytical methods foreach measurement parameter. All analyses will utilize a boundnotebook into which will be recorded the following items, at aminimum:

(a) analyst,(b) date,(c) sample number (lab #), and(d) analysis set-up conditions, e.g., dilutions, auto-

sampler position number, or other instrumentspecifics not covered by an SOP.

*

For instrumental analysis, this analysis notebook will beinstrument-specific and referred to as an instrument log. Forother types of analyses, this analysis logbook will also containall raw data collected by the analyst.

• The PCS analysis involves electronic data handling, resultingin values bearing the conventional units (Table 10-1), alreadycorrected for dilutions (Equations 10.3 and 10.4). The analystwill need to round the answers appropriately and sometimes sumcolumns of data. The in-process data report forms onto which dataare to be transcribed are shown in Appendix B.

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 3 of 18

For spectrophotometric analyses the raw data output will bein proportional .units, such as peak height. This output will berecorded in hardcopy with sample ID, date, and dilutions.Subsequent data reduction will involve the use of a fully-documented calibration curve, as indicated in the specific methodSOP.

For soil analyses, the separate determination of the dryweight (Equation 10-2) of the soil sample will be necessary. Theworksheet for this process is in Appendix B.

For all analyses, the data will not be blank-corrected andwill be flagged if blanks do not meet acceptability criteria.Additionally, any result that is less than ten times the value ofthe blank will be considered suspect.

Chemists and technicians will be responsible for themeasurement/analysis of any specific parameter, and for anycalculations associated with the determination of parameterconcentrations. All calculations are made with respect to themethod listed in the "method reference" column of Table 5-1. Thechemists and their supervisors will be responsible for reviewingall results, applying calculation checks on a minimum of 10percent of the results on each report. These individuals will beresponsible for determining whether or not the results areacceptable, though the ultimate authority to determineacceptability will be with the Director of Quality Assurance. Thelaboratory section manager will be responsible for the finalreview of all data and for the proofing of reports prior tosubmittal of the reports to GTI.

Appendix I . , nRR303UI8

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 4 of 18

Final reports to GTI will be typed from the in-process reportforms approved . by the supervisor after the review of allsupporting data. The in-process forms along with all hardcopydata output and other case records will be stored together in asingle secure location indexed by project number for at least fiveyears. This location will be in GTI's Chadd's Ford, PA office.

• All data will be cross-checked for correctness by GTI' s QAOfficer for reported values, detection limits, percent moistureand dilution factors (if applicable), after data has been reducedand transcribed into the final reporting format. The procedure tobe used in the final cross check of the data in the final reportformat will be as follows;

1) obtain the laboratory data or field notebooks and finalreports

2) compare the sample numbers and description

3) compare the sample date and time (if provided)

4) compare all positive results with those reported in thelaboratory report.

5) laboratory data will be checked for corrections withmathematical calculations during the Data Validationprocess.

10.2 Field and Laboratory Validation10.2.1 Field Validation

The GTI Quality Assurance Officer will proof ten percent ofthe entries in the bound field notebook for completeness andcorrectness.

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 5 of 18

10.2.2 Laboratory Validation

A complete record of each sample's history will be availablefor documenting its progress from the time of sample collectionto arrival at the laboratory and through the laboratory fromsample receipt to reporting. Data validation will include the useof dated entries, signed by analysts and supervisors, on work-sheets and log books used for all samples, the use of sampletracking and numbering systems to logically follow the progressof samples through the laboratory, and the use of quality controlcriteria to reject or accept specific data (see Section 11).

(text continues on p. 8)

Appendix I

Section No.: 10• Revision No. : 1Date: Aug 10, 1988Page No.: 6 of 18

TABLE 10-1

POLYCHLORINATED BIPHENYLSGAS CHROMATOGRAPHY/ELECTRON CAPTURE DETECTOR

WATER

Concentration, ug/1 = _(Ax) ds) (Vt)__ (Eq. 10-1)(Ais)(V±)(Vs)

where:Ax = area of the characteristic ion for the compound

to be measured,Aj_s = area of the characteristic ion for the internal

standard,Is = amount of internal standard injected, in nanograms

(ng) ,Vs = volume of water extracted in milliliters (mL),Vi = volume of water injected in milliliters (mL), and

= volume of total extract. (Use 2000 uL or a factorof this when dilutions are made).

Appendix I

Section No. : 10Revision No. : 1Date: Aug 10, 1988Page No.: 7 of 18

SOLIDS

Percent Moisture = g of sample - g of dry sample (Eq. 10-2)g of sample

Sediment/Soil (medium level):

Concentration, ug/kg =, __(Ax) (Is) (V )_____ (Eq. 10-3)(Ais)(Vi)(Ws)(D)

Sediment/Soil (low level):

Concentration, ug/kg = ____LAxl_LIsj___ (Eq. 10-4)(Dry weight basis) (Ais)(Ws)(D)

where:Vj_, Ax, Is, A^s, V^. = same as for water, above,D = 100 -% moisture

100Ws = weight of sample extracted (g) or

purged.

Appendix I

Section Np.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 8 of 18

Total Organic Carbon - Method 415.21

Digital Readout (ug/1) - System Blank Result = Final Result

Total Dissolved Solids (Filterable Residue) - Method 160.I2

fA - B) X 1000 = Filterable Residue, (mg/1)C

Where A = weight of dried residue and weight of dish (mg)B = weight of dish (mg)C = volume of sample used (ml)

Dioxin/Furan - Method 8280 Concentration of Individual Isomers oftetra-, penta, and hexa-CDD/CDF according to the equation:

Concentration, ng/g = Qjs X AsG X Ais X RRF

Where:

Q-is = n<3 of internal standard 13Ci2 -2 , 3 ,7,8-TCDD, addedto the sample before extraction.

.G = g of sample extracted

As = area of quantitation ion of the compound ofinterest.

Ais = area of quantitation ion (m/z 334) of the internalstandard, —C12-2.3.7.8-TCDD added to the samplebefore extraction.

Methods for Analysis of Water and Wastes, EPA 600/04-79-020, Reevised March 1983.

EPA Office of Solid Waste and Emergency Response(OWSER), Test methods for Evaluating Solid Wastes,EPA SW-846, 3rd Edit, Revised Sept. 1986.

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 9 of 18

RRF = -response factor of the quantitation ion of thecompound of interest relative to m/z 334 of —C^2-2; 3 ,7,8-TCDD

NOTE: Any dilution factor introduced by multiplying thedilution faction should be applied to thiscalculation.

Concentration of Individual Isomers of hepta-CDD/CDF and theConcentration of OCDD and OCDF According to the Equation:

Concentration, ng/g = Qis AsG X Ais X RRF

Where:

Qis = n9 of internal standard 13C^2 -2,3,7,8-TDCC, addedto the sample before extraction.

As = area of quantitication ion of the compound ofinterest.

G = g of sample extracted.

Ais = area of quantitation ion (m/z 472) of the internalstandard, 13C12-OCDD •

RRF = response factor of the quantitation ion of thecompound of interest relative to m/z 472 of 13ci2 ~OCDD.

NOTE: Any dilution factor introduced by multiplying thedilution factor should be applied to thiscalculation.

Relative response factors are calculated using data obtainedfrom the analysis of multi-level calibration standards-accordingto the equation:

RRF = AS X CisAis x cs

•

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 10 of 18

Where:

As = a'rea of quantitation of the compound of interest.

Ais = area of quantitation ion of the appropriateinternal standard (m/z 334 for 13C12~2,3,7,8-TCCD;(m/z 472 for 13C12-OCDD).

cis = concentration of the appropriate internal standard,13C12-2,3,7,8-TCDD, or 13C12-OCDD.

Cs ' = • concentration of the compound of interest.

The concentration of unknown isomers will be calculated usingthe procedures described in the method.

10.2.3 Project Data Validation

The purpose of the project data validation performed by GTI'sData Validation Chemist is to verify and retrace the path of thesample from the time of receipt of analysis to the time the finalreport is generated. The data validation chemist will review theentire deliverables package for chain-of-custody completeness,holding time limitation, blank contamination, instrument tuning,initial and continuing calibration surrogate spike compoundrecovery, matrix spike and matrix spike duplicate recovery andprecision, and overall system performance.___A brief reportdescribing the difficulties encountered and shortcomings of thedeliverables package will be written to assist the Project Managerin making decisions based on the analytical results.

Upon receipt of the hardcopy analytical results, the GTIData Validation Chemist will validate the data using theprocedures outlined in "Laboratory Data Validation, Functional

Appendix I

AR3U3i*25

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 11 of 18

Guidelines for Evaluating Organics Analysis.3 In addition, theresults of the field duplicates and blanks will be evaluated atthis time along with comparisons using previous and fieldscreening data.

10.3 Identification and Treatment of Outlier

Outlier are unusually large or unusually small values in apopulation of observations. Outlier may be the result of avariety of -circumstances, including any of the following:

(a) errors in recording of data,(b) calculation errors,(c) analytical errors,(d) inaccurate reading of meters,(e) faulty or defective instruments,(f) actual values due to comparatively unique

conditions,(g) sample identification incorrectly transcribed in

the field or lab,(h) sampling artifact, or(i) sample integrity problem.

10.3.1 Identification of Outliers

Procedures for the identification of outlier will befollowed at both the analytical stage and at the ensuing datareduction stage.

Technical Directive Document No. HQ-8410-01, preparedfor Hazardous Site Control Divisionn (USEPA) byUSEPA Data Validation Work Group, April 11, 1985.

Appendix I

Section No.: 10Revision No.: lDate: Aug 10, 1988Page No.: 12 of 18

Outlier in .laboratory data can arise from errors in analysisor from site-specific conditions that are out of control of thelaboratory. Errors in the laboratory are most often detected inthe data review and validation process. In the event that qualitycontrol processes, which directly affect only 20 percent of thesamples, detect an outlier, the statistical approach of Dixon(1953) will be used to eliminate outlier.

It is necessary to eliminate outlier from QC data because ofthe skewing effect which can destroy the effectiveness of the QCdata.

Outlier will be identified at the data reduction stage by theProject Manager, Project Hydrogeologist, or Project Geologist.When any particular value is suspected to be an outlier, thefollowing steps will be taken:

(a) Other data from the same sample will be checked tosee if they are also anomalous.

(b) The Project Manager will interrogate anyindividuals involved in generating the anomalousvalue. This will include questioning the fieldcrew and the analyst(s).

(c) Field crew - If samplers demonstrate standardcompetency in the sampling procedure used at thetime the sample with the anomalous value wasobtained, then sampling error will be dismissed asa possible cause of the outlier.

(d) Analyst(s) - The analyst(s) will be asked toexamine his notes and calculations and, ifpossible, to rerun the sample for the specific

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 13 of 18

parameter in question. The sample will be reruneven if the holding time has been exceeded, but thererun value will be used for purposes of comparisononly.

10.3.2 Treatment of Outliers

Rejection of any suspect data or outlier will only be done bythe Project Manager. The data will be rejected as anunacceptable outlier by the Project Manager if:

(a) A problem with equipment or an incorrect procedureduring the sampling stage is identified.

(b) The rerun by the Analyst generates a value thatsignificantly differs from the value beingexamined.

10.4 Data Flow

An overall view of data flow from the point of raw datacollection through storage of validated data is shown in Figure10.1.

10.5 Laboratory Data Reduction. Reporting and Report Storage10.5.1 Data Reduction

Analytical data will be generated from direct-readinginstruments, reporting integrator or data management computersoftware. The automated outputs will include identifications ofcompounds, concentrations, and retention times. Outputs will bein graphic form (chromatograms), spectra, recorder charts, and inprinted tabular form. The outputs will be in a standard formal^

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 14 of 18

specified for each analysis and monitored for consistency. Fordirect reading instruments, the Analyst will be required to recordall results into a bound lab notebook.

Auxiliary data produced for internal records, which will notnormally be reported to customers as part of the analytical data,will include the following: laboratory worksheets, laboratorynotebooks, sample tracking system forms, instrument logs,standard records, maintenance records, calibration records, andassociated quality control records. These sources will beavailable, however, for inspection during audits to determine thevalidity of data.

Appendix I

?.e sample

Section No.: 10Revision No.: lDate: Aug 10, 1988Page No.: 15 of 18

Samplecollection

Analysisof samples

Laboratory

r~s -, -Review

Prepare results

Submit toClient

QA Officer

QA officerreviews data

Data reportsto file

Data reportsto projectmanager .

Reject

Projectreport

FIGURE 10.1DATA FLOWPAOL1 RAILYARDPAOLI, PA GROUNDWATER

OLOGY. I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 16 of 18

10.5.2 Data-Reporting

A typical standard data report form is included in Appendix B.Standard lab reports will contain as a minimum, the followinginformation:

(a) laboratory ID number;(b) site ID number;(c) sample ID number;(d) date sampled;(e) date analyzed;(f) parameters measured;(g) units in which each parameter is reported;(h) analytical methods used;(i) detection limits;(j) certification statement by the person responsible

for validation of the data concerning sampleintegrity and QA acceptance, and

(k) date of extraction, if applicable;(1) calibration curves;(m) percent moisture;fn) weight or volume of sample taken for analysis;

and sample matrix(o) results for parameters analyzed.

The field notebook will require, at minimum, the followingentries:

fa) date and time of information recorded;(b) all personnel on-site on that date;(c) sampling location (and map referenced);(d) sample date, time, source of sample containers;

Appendix I

Section No.: 10Revision No.: 1Date: Aug 10, 1988Page No.: 17 of 18

(e) weather conditions (temperature, barometricpressure, humidity, wind speed and direction,observation of skies, and other physicalobservations);

(f) sample matrix;(g) sample depth;(h) note if sample is duplicate, blank, composite or

grab ;,(i) well purging information (volume purged,

111

analyzed;(k) the method of sample shipment with air

number, name of overnight courier and laboratoreceiving the samples;

(I) all samples shipped on the chain-of-custody;(m) calibration of all instruments (pH pens,

conductimeters, OVMs, turbidity meters, etc); andfn) readings from all field parameters measured.

temperature , pH and conductivity. depth to water.depth of water) ;number ofchronological

sampleorder

containers collectedand the parameters to

inbe

10.5.3 Report Storage

All final report folders will be filed in a secure area atGTI's (Chadds Ford West, Concord building, Chadds Ford, PA)office. Quality control sample reports are maintained in aseparate file. All data, chromatograms, calculations, andreports will be stored for a minimum of five years.

Appendix I

Section No.: 10Revision No.: lDate: Aug 10, 1988Page No.: 18 of 18

10.6 Reference

Dixon, W.J., Processing Data for Outlier, BiometricsfVol. 9, No.l, March 1953, pp. 74-89.(see Appendix E)

Methods for Analysis of Water and Wastes, EPA 600/04-79-020,Revised March 1983.

EPA Office of Solid Waste and Emergency Response (OWSER), TestMethods for Evaluating Solid Wastes, EPA SW-846, 3rd Edit,Revised Sept. 1986.

Laboratory Data Validation, Functional Guidelines for EvaluatingOrganics Analysis. Technical Directive Document No HQ-8410-.01, prepared for Hazardous Site Control Division CUSEPA) DataValidation Work Group, April 11, 1985.

Appendix I

CASfeLABORATORY-

SOP WORK SHEETS FOR PESTICIDES / PCBs

HOLDING TIMES

* INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE

w,--:- -——————————-^------ . ------ .-sot 2 OF 8LABORATORY———————————

*» SOP WORK SHEETS FOR PESTICIDES / PCBs

INSTRUMENT PERFORMANCE

INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE

R3031»35

CAS£NO.LABORATORY-

SOP WORK SHEETS FOR PESTICIDES / PCBs

* INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE

i*''—• ___ .. .._______" r/-iGc 4 (jr GLABORATORY———————————

SOP WORK SHEETS FOR PESTICIDES / PCBs

INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE

CASE NO.LABORATORY-

t. .SOP WORK SHEETS FOR PESTICIDES / PCBs

SURROGATE RECOVERY

.

0

* INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HEREim

£-

• SOP WORK SHEETS FOR PESTICIDES / PCBs.-

MATRIX SPIKE / MATRIX SPIKE DUPLICATE

•<u

£

t—f

i

/MATRIX SPIKES FOR /ADVISORY LIMITS FOR / ADVISORY LIMITS FOR //EACH MATRIX IN EACH / SPKE RECOVERIES MET / SPIKE RECOVERIES // CASE (OR EVERY 20 / / RPDsMET / A*/ SAMPLES) / / / 6

/•/•/'/• r*/ •/„

"•

-

-

* INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE

LABORATORY-

SOP WORK SHEETS FOR PESTICIDES / PCBs

COMPOUND IDENTIFICATION

COMPOUND COMPOUND GC/MSRETENTION TIMES / RETENTION TIMES / CONFIRMATION OFWITHIN STANDARD / WITHIN WINDOWS FOR COMPOUNDSWINDOWS FOR / CONFIRMATION.

PRIMARY COLUMN / COLUMN

/*

•* INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE

LJ*-V U \-/ I v/-v I \^ i v i — — — —— "" ——————— • — "

F SOP WORK SHEETS FOR PESTICIDES /PCBs^

OVERALLASSESSMENT

// / OVERALL /* / IDENTIFY FACTORS / ASSESSMENT /

<f / CONTRIBUTING TO / OF DATA FOR THE // / OVERALL ASSESSMENT / SAMPLE (e.g. U,J,R,Q, /$ / / N QUALIFIERS) /

1

i

1

-

_ .^_ - - •

0

-

-..

i* INCLUDE MATRIX SPIKES, BLANKS AND RE-RUNS HERE 1

Section: 11Revision No. : 1Date: Aug 10, 1988Page: 1 of 5

11. INTERNAL QUALITY CONTROL CHECKS

The intent of the internal quality control program is todetect potential problems at the source and, if necessary, tracethe sample analytical pathways for introduction of contamination..The quality control data generated in the field will be used tomonitor sampling technique reproducibility and cleanliness.Quality control data generated by the laboratory will not onlymonitor reproducibility (precision) in laboratory methods andcleanliness but accuracy in analyzed samples submitted foranalysis. During the data validation process (performed by GTI'sdata validation chemist) variability in sampling technique andlaboratory performance will be assessed separately.

11.1 Field Quality Control Checks

The field quality control checks monitor the data quality asit is affected by field procedures and conditions to the degreefeasible as discussed in Section 5. The degree of effort(number of check samples per total samples taken, see table 3-1)is stated below for each category: The acceptability criteriawere outlined in Section 5.6. All field quality control sampleswill be submitted to the laboratory and labeled as such.

11.1.1 Blanks

Equipment (or Rinsate) blank - Reagent water poured throughthe sampling equipment after routine cleaning. This sample ispreserved and subsequently handled like all others. This blankis used to assess the potential for carryover contamination on

Appendix i

'\j/* '* '

Section: 11Revision No.: lDate: Aug 10, 1988Page: 2 of 5

non-disposable* sampling equipment. These blanks may be appliedto all matrices sampled by equipment cleaned in the field. Aminimum of one rinsate blank will be submitted per sampling day.

Field blank - a sample of theequipment blank, preserved and nanblanks are always water and are ap^field blank per equipment blank will

Trip blank - Reagent water prsealed in the proper .sampling contaisampling, the field blank is surrounded with activated carbonuntil the sampling event. It is henceforth handled as othersamples except that it is not opened or preserved (other thanchilling) . This sample focuses on external sources ofcontamination and sampling container quality and cleanliness.For each shipment of at least 20 samples, one trip blank will besubmitted. A minimum of one trip blank will be submitted foreach batch of glassware (plastic included) received by the fieldcrew .from the laboratory. If time and conditions permit a set ofsoil trip blanks will be prepared utilizing clean,muffle-furnaced sand. Otherwise the water travel blanks willserve for both matrices.

The acceptability limits for all blanks is to be below thecontract required quantification limits or less than 1/10 of thelevel in the lowest sample in the batch.

Matrix or site control - For each significant geological orgeographical feature identifiable among sampling sites arepresentative uncontaminated sample, such as an upstream surfacewater sample or an upgradient soil sample from similar strata,

Appendix I

AR303M»3

Section: 11Revision No. : 1Date: Aug 10, 1988Page: 3 of 5

will be sought." This sample will provide perspective to the siteconditions found and demonstrate the ability of the entiremeasurement system to generate a clean sample given thetechniques and ambient conditions. This sample is taken as acollocated duplicate because it is often depended upon to provideperspective to site conditions and to site remediation goals.

11.1.2 Duplicates

Blind field duplicates (as opposed to duplicate containersfull of sample intended as backup) are sequential or collocatedgrab samples collected to monitor field precision (actuallyentire measurement system precision as described in Section 5) .One duplicate will be taken and submitted per twenty (20)samples, or one (1) per area and matrix type, as described inSection 5, whichever is greater.

11.2 Laboratory Quality Control

The laboratory will be required to analyze the followinglist of quality control samples for each of the matrices; soil,sediment, garden vegetables, aquatic biota, surface water, andambient air. Samples will be collected to provide the properamount required to analyzed matrix spikes and matrix spikeduplicates.

The internal quality control checks to be routinelyimplemented by the lab include the following:

A) Replicates - A minimum of 5% of all samples will beduplicated in the lab, usually in the form of a spiked

Appendix I

4

Section: 11Revision No.: 1Date: Aug 10, 1988Page: 4 of 5

sample duplicate (MSD).

B) Spikes - Spiked samples will be prepared in the lab andwill be analyzed with the samples at a rate of 5%. Thecontrol limits are outlined in Table 11-1.

C) Surrogate spikes - surrogate compound spikes are placedinto all samples of every matrix for PCS analysis priorsample prep. (See the control limits outlined above).

D) Blanks - Blanks will be analyzed at a minimum of onedaily. These blanks are referred to as method blanks.

The acceptability limits for method blanks is to be belowthe contract required quantification limits or less than 1/10 ofthe lowest sample in the batch.

E) Quality Control Standards - Quality control standards(often referred to as spiked reference materials)traceable to the U.S. EPA or generated fromconcentrates prepared separately from calibrationstandards, will be included at a rate dependent onsample matrix and lab performance with matrix spikes.The minimum is one QC standard to validate the initialcalibration. For inorganic analysis after every twenty(20) samples, a QC or mid-range calibration standardwill be analyzed to continuously verify that thecalibration is within 10% of the initial calibration.

For PCB analyses after every 12 hours ofoperating a QC or mid-range standard will beanalyzed for verification.

. Appendix I

Section: 11Revision No.: 1Date: Aug 10, 1988Page: 5 of 5

EPA or. NBS traceable standards will be run at leastquarterly. The acceptability limits will be 90 - 110%for inorganic QC samples and as determined by the EPAfor organic analyses.

F) The method detection limit will be determined for allanalyses within one month of the start of the projectand subsequently quarterly. See Section 14 for thedefinition of detection limit. The detection limit sodetermined must be equal to or below the contractrequired quantification limits listed with the projectcompound list in Section 3.

Appendix I

HR303UU6

Section: 12Revision No.: 0Date: May 27, 1988Page: 1 of 6

12.0 PERFORMANCE AND SYSTEM AUDITS

12.1 Performance Audits

Laboratory QC audits are to be carried out by the LaboratoryQuality Assurance staff semi-annually for each method. Blindaudit samples will be utilized. Results of blind audit sampleanalyses will be reviewed by the Quality Assurance Officer andwill be reported as part of the Quality Assurance Reports toManagement.

in addition to blind audit samples, the laboratory will beinvolved in performance audits conducted semi-annually by the EPAin which EPA performance evaluation samples will be analyzed.

12.2 System Audits

The GTI Quality Assurance Officer will conduct a systemsaudit of field quality control procedures (see Figure 12-1) andof laboratory quality control procedures shortly after thesesystems are operational for the project, and on a monthly basisthereafter.

12.3 On Site Inspections

The laboratory should be regularly inspected by stateagencies in order to document compliance with the variouscertification programs in which the Laboratory participates.

Appendix I

Section: 12Revision No.: 0Date: May 27, 1988Page: 2 of 6

All audit reports will be incorporated into quarterlyquality assurance reports, one copy of which is provided to theEPA Project Officer.

12.4___Field Audit

The field audit will be conducted on a monthly basis,employing the form in figure 12-1. The field proceduresapplicable to the audit must exceed 90% positive (proper)responses to meet the acceptance criteria.

Appendix I

AR303H8

Section: 12Revision No.: 0Date: May 27, 1988Page: 3 of 6

FIGURE 12-1GTI QA/QC

FIELD AUDIT/EVALUATION

Y N N/A

Field Notebook: - Bound-Page Numbered, No missing pages __ __ __

Pre-Task Info: - personnel and. responsibilities Noted __ __ __- field checklist on hand and followed __ __ __- sampling location (on-site specific map) __ __ __- location number (well boring, etc.) __ __ __- weather conditions __ __ __- additional pre-sampling observation

(if applicable) __ __ __- parameters to be sampled noted? __. __ __

Sample Containers: - proper type and size- proper preservation- proper labeling- proper quantity- proper source of container- cooler- proper ice- proper packing material- proper custody seals- proper courier

Field QC Samples: - proper frequency- proper field blank- proper travel blank- proper duplicate sample- proper water source for blanks

Field Measurements: - proper calibration of pH pen- conductivity meter- thermometer

- proper standards for pH pen- conductivity meter- thermometer

- proper units for pH- conductivity meter- thermometer

Appendix I

'1*3031

Section: 12Revision No.: 0Date: May 27, 1988Page: 4 of 6

GTI QA/QCFIELD AUDIT/EVALUATION

Y N N/A

proper frequency of pH __ __ __conductivity meter __ __ __thermometer

- steady state achieved for pH- conductivity- temperature

- proper times/dates purged for pH- conductivity- thermometer

- gallons of water purged

Sampling Technique- volatiles first- stored properly- sample bottles inspected- consistency in technique- SOP available

Chain-of-Custody Form Complete with- Client & Location- Date- Sample Numbers- Time Collected- Matrix- Number of Containers- Preservation Technique- Blanks Labeled- Proper Signatures- Proper Time & Date- Proper Continuity- Sample TravelTime Reasonable

Appendix I

Section: 12Revision No.: 0Date: May 27, 1988Page: 5 of 6

GTI QA/QCFIELD AUDIT/EVALUATION

Y N N/A

Decontamination:- Proper Frequency __ __ __- Proper method __ __ __- Each Device Cleaned

List 1) __ __ __List 2) __ __ __List 3) __ __ __List 4) __ __ __List 5) ' __ __ __

- Disposable Equip. Collected & Removed ____ __- Proper Decontamination Area Used __ ____- Dedicated Equipment __ __ __- Clean Plastic Sheeting __ __ __

General:- Personnel- Records- Proper Attire/Job Level- Legible- Organized- Continuous

Appendix I

HR303l*51

Section: 12Revision No.: oDate: May 27, 1988Page: 6 of 6

x

FIGURE 12-2

GTI'S SYSTEM AUDIT CHECKLIST FOR LABORATORY

I. Chain-of-Custody

- Log-in procedures evaluated

- Sample Custodian is assigned and oversees sampletransfers

- Sample routing and pickup is documented and accountedfor

- Separate Area for sample storage and maintained inlocked storage

II. Sample Preparation

Correct sample preparation procedures are followed

Areas designated for sample preparation (organics andinorganics)

Holding times maintained

III. QA/OC Procedures

Procedures are being followed according to methodsspecified

Data validation and reduction process reviewed by groupleaders

Proper documentation of QA procedures

Internal QC maintained

Data transfers and reporting checked by group leaders

Awareness of personnel of QA requirements

Appendix I

AR303U52

Section: 13Revision No.: lDate: Aug 10, 1988Page: 1 of 4

13. PREVENTATIVE MAINTENANCE

13.1 Laboratory Maintenance

To assure minimum storage times for samples, the laboratorywill maintain equipment to the manufacturer's specifications andkeep enough overcapacity to have instruments available should onefail.

The following maintenance and assurance procedures will befollowed routinely:

A. Gas Chromatograph and Gas Chromatograph/MassSpectrometer (GC and GC/MS)

1. Maintenance log will be kept for each instrument

2. GC septa will be changed daily

3. Detectors will be cleaned on a schedulerecommended by the manufacturer or more frequentlyas needed: FID monthly, PID monthly, MSquarterly.

4. Laboratory will be vacuumed weekly

5. Instrument electronics will be visually inspectedand cleaned quarterly.

6. Room temperature and humidity will be maintainedaccording to manufacturer's specifications.

7. Refrigerator temperatures will be logged daily.

8. Raw data will be archived electronically ifpossible at least until report is accepted by theclient or the GTI office QA officer.

Appendix I

Section: 13Revision No.: 1Date: Aug 10, 1988Page: 2 of 4

9. Fume hoods will be cleaned and checked quarterlyto assure minimum laboratory contamination andmaximum safety conditions.

10. Broken glassware will be sent for repair bi-monthly.

11. GC columns and PAT traps will be numbered andlogged and will be baked out daily. Changes andmonthly flow checks will be logged.

12. Teflon tips will be replaced bi-weekly.

13. Temperature measurement devices will be checkedagainst NBS traceable standards ami-annually.

14. Analytical balances will be under service contractand maintained semi-annually.

15. PAT devices will be pressure-tested monthly andwhenever glassware is changed.

16. Electronic flow meters will be calibrated monthly.

B. Infrared/Spectrophotometers. for Total Organic CarbonAnalysis.

Daily maintenance:

1. Clean windows with freon and lens paper.

2. Check sensitivity and adjust gain, if necessary.

3. Run spectrum of polystyrene or other standard forultraviolet such as holmium oxide glass.

C. The following maintenance supplies are kept on hand forregular and emergency maintenance:

1. septa

2. purge-and-trap sparger

Appendix I

AR303t*55

Section: 13Revision No. : 1Date: Aug 10, 1988Page: 3 of 4

3. purge-and-trap traps

4. tubing and fittings

5. thermal conductivity leak detector

6. chart paper

7. column ferrules

8. u.v. lamp for PID detector

9. syringes for spiking

10. mass spectrometer source filaments

11. jet separator

12. pump oil

13. analytical columns (all analyses)

14. flow meter bubble solution

15. extra flow meter

The laboratory will maintain written logs defining specificroutine and preventive procedures for all instruments. Also, allinstruments will be maintained through service contracts with themanufacturers.

13.2 Field Maintenance

GTI's field equipment is maintained through the use of atracking system incorporating the tagging of each equipment item.This tag identifies its most recent maintenance, battery charge,and condition. When damaged equipment in need of repair isreturned to the equipment warehouse, it is appropriately flaggedfor the required maintenance to be performed. This process

Appendix I

AR303V56

Section: 13Revision No.: IDate: Aug 10, 1988Page: 4 of 4

assures only operable and properly maintained equipment entersthe field. Routine daily maintenance procedures conducted in thefield will include:

1. Removal of surface dirt and debris fromexposed surfaces of sampling equipment andmeasurement systems;

2. Cleansing of filters in the organic vaporanalyzer;

3. Storage of equipment away from the elements;

4. Daily inspections of sampling equipment andmeasurement systems for possible problems(e.g., cracked or clogged lines or tubing orweak batteries);

5. Check instruments calibrations; and

6. Charging any battery packs for equipment whennot in use.

Spare replacement parts stored in the field to minimizedowntime include:

1. Appropriately sized batteries;

2. Locks;

3. Extra sample containers and preservatives;

4. Extra pH probes, conductivity probes,thermometers, sample coolers, packingmaterial, and sample location stakes;

5. Additional supply of health and safetyequipment (i.e., respirator cartridges,boots, gloves, tyvek, etc.); and

6. Additional equipment as necessary for thefield tasks.

,

Section: 14• Revision No. : 0Date: May 27, 1988Page: 1 of 5

14. SPECIFIC ROUTINE PROCEDURES USED TO ASSESS DATA PRECISION.ACCURACY. COMPLETENESS. DETECTION LIMIT. AND METHOD OFCONTROL

14.1 Precision

When more than two measurements are to be evaluated, such asfor a series of daily reference samples, the standard deviationis derived from equation 14.1:

.S = [Sni=1(Xi-x)2/n-l]1/2 (Equation 14.1)

Where: S = standard deviationXj_ = each observed "valuex = the arithmetic mean of all observed

valuesn = total number of values

The precision of laboratory test results will be expressedas the percent relative standard deviation (RSD) or relativepercent difference (RPD) . The % RSD is obtained by dividing theS by X, expressing the ratio as a percent. RPD is derived fromthe absolute difference between duplicate analyses divided by themean value of the duplicates (Equation 14.2).

| Dl - D2 | (Equation 14.2)—————————— x 100 where Dl and D2 are(Dl + D2)/2 the two replicate values

RSD is related to RPD by the relationship in Equation 14.3

% rel. std. dev. = 0.707 RPD ' (Equation 14.3)

Appendix I

AR3Q3U58

Section: 14Revision No.: 0Date: May 27, 1988Page: 2 of 5

As the RPD generally has a dependency on concentration, itmay be necessary to apply these statistics over a limited rangeof concentrations.

The day-to-day acceptability of the analytical precisionwill be based on the QC charts with the control limit at the 99%confidence level (3.27 times the mean RPD as discussed in Section14.5).

14.2 Accuracy

Bias (accuracy) will be based on the average % recoveries ofspiked samples (Equation 14.4).

SSR - SR%R = ——————————— X 100 (Equation 14.4)

SA

Where: %R = % RecoverySSR = spiked sample resultSR = sample resultSA = amount of spike

The accuracy interval reported to management will beexpressed as follows: accuracy interval = mean recovery +/- 2std. dev. Day-to-day acceptability of accuracy will be based onthe QC charts with the control limits at the 99% confidence level(see Section 14.5).

Appendix I

Section: 14• Revision No.: 0

Date: May 27, 1988Page: 3 of 5

Reference materials are essential to the evaluation ofaccuracy. Stock solutions for accuracy spikes shall be traceableto a source independent from the calibration solutions. QualityControl Standards (used for calibration verification) will, ifpossible, likewise be traceable to a source independent from thecalibration solutions. In such cases, QC Standards will beacceptable to use for accuracy assessments in addition to matrixspikes. When using commercial sources for solutions, the QADepartment will verify that the materials are from an independentsource.

14.3 Completeness

Completeness is evaluated by dividing the total number ofverifiable data points by the maximum number of data pointspossible and expressing the ratio as a percent. The followingcalulation is useful in random sampling procedures.

DC (%) = ———- X 100 • (Equation 14.5)

P x n

Where: D = number of verifiable quantifications(not suspect due to QC or sampleintegrity shortcomings)

P = number of analytical parameters persample requested for analysis

n = number of samples requested for analysis

Appendix I

Section: 14Revision No.: 0Date: May 27, 1988Page: 4 of 5

14.4 Definition of Detection Limit

For methods operating under this document, the MethodDetection Limit (MDL) will be defined according to Appendix A,EPA 600/4-82-057, "The minimum concentration that can bemeasured and reported with 99% confidence that the value is abovezero." The procedure for its determination is in Appendix A. Itis approximately three times the standard deviation of a set ofseven replicates at a concentration very near (within five times)the detection limit.

The MDL defines a limit above which false positives are veryunlikely. However, the relative precision at this .limit isexpected to be very large and quantification is not reliable.For methods operating under this document, quantification isconsidered reliable at 10 standard deviations above background,(i.e., at about three times the MDL.) Data above this level canbe reliably compared to regulatory limits.

14.5 Method Control

Method control is based on a statistical evaluation ofquality control results and is usually displayed as a qualitycontrol chart. The control limit for a method under statisticalcontrol is +/- three standard deviations. In the case ofprecision control charts the control limit and warning limit are3.27 and 2.51 times the mean RPD, respectively. In certaininstances where the method explicitly states a control limit thereferenced control limit will be used unless a statistical

Appendix I

1*303*61

Section: 14Revision No.: 0Date: May 27, 1988Page: 5 of 5

evaluation indicates that laboratory performance is significantlybetter than the'referenced limit. For certain difficult matricesit may be necessary to establish statistically-based limits whichare broader than initially accepted limits. This will be donewith a minimum of five samples and will be fully documented aspart of a corrective action.

Statistical control is also dependent on the followingtrends of greater than seven results:

a) ascendingb) descendingc) one side of mean (central) line

As a minimum, the lab will maintain control charts formatrix spikes for accuracy and either duplicate matrix spikes forduplicate samples for precision. Additionally for organicmethods, the lab will maintain charts for surrogate spikeresults.

Appendix I

AR303l*62

Section: 15Revision No.: 1Date: Aug 10, 1988Page: 1 of 5

«• *

15. CORRECTIVE ACTION

15.1 Laboratory Corrective Action

The quality control samples are designed to imitate samplesand indicate possible sources of error or laboratorycontamination.

Any corrective actions taken by the laboratory will all bedocumented and initialed. The Laboratory Manager will providedocumentation as to what, if any, corrective actions wereinitiated during this study and report them to GTI's QualityAssurance Officer or Project Manager.

The laboratory must take corrective action if any of thequality control data generated during the laboratory analysis isoutside criteria. By comparison of blank results, contaminationmay be attributed to either laboratory or field samplingtechniques.

Corrective action for out-of-control calibrations is to re-calibrate the instrument and reanalyze the samples. A sequenceis specified in the procedure to be used towhen problems in analyses are encountered theexpected to follow this procedure exactly.problems encountered and corrective action i

analvze the samplelaboratorv will beand document the

,n a case narrativeenclosed with each deliverables package.

The analyses for total organic carbon are prepared with adigestion method blank, a predigestion analyze spike in thedesignated sample, two duplicates of the designated sample, plus

Appendix I

Section: 15Revision No.: 1Date: Aug 10, 1988Page: 2 of 5

the sample (one of the two duplicates are used as a post-digestion spiked sample). The laboratory analyzes the series ofcalibration standards, a standard on the curve, and a methodblank. One calibration standard is analyzed every tenth sample.If the standard is outside the curve, the previous ten samplesmust be re-analyzed after the instrument problem has beencorrected. If the concentrations are outside the limits of thecalibration curve, sample dilution and re-analysis is required.The duplicate sample results may not differ by more than 20% RSD.

15.2 GTI'S Corrective Action

Field quality assurance activities will be reported to theProject Manager. Problems encountered during the study affectingquality assurance will be reported on a Corrective Action Form aspresented in Figure 15-2. If any data fail to meet theprecision, accuracy, and completeness criteria listed in Table5.2 (Field Accuracy, Precision, and Frequency), the lab managerwill be notified and will be required to make any necessarysystematic changes and then re-analyze the samples in question.If the samples in question cannot be re-analyzed for some reason,the GTI Project Manager will decide whether or not the suspectdata will be used.

If. for example, field or rinsate blank contamination is aproblem, the Quality Assurance Officer will notify the ProlectManager of the problem and a field audit by the QA Officer of thesampling and decontamination procedure will be conducted anddocumented. Field and rinsate blanks are reanalyzed and theresults are reviewed by the 0_uality Assurance officer.

The Project Manager will be responsible for initiating theAppendix I

Section: 15Revision No.: iDate: Aug 10, 1988Page: 3 of 5

corrective actions and for insuring that the actions are taken ina timely manner, and also that the desired results are produced.The Project Manager will report to the Quality Assurance Officerall the necessary corrective actions taken, the outcome of theseactions, and their effect on data produced. All correctiveactions taken will be reported to the appropriate regulatoryagencies in the final report.

Appendix I

LAB QA COORDINATOR CHECKSCALCULATIONS AND REVETS DATAFOR PRECISION AND ACCURACY

Section: 15Revision No.: 1Date: Aug 10, 1988Page: 4 of 5

CHECK FOR PROBLEMS. MAKENO

CORRECTIONS, REANALYZE SAMPLESIF NECESSARY, OR INVALIDATE DATA

YES

SUBMIT DATA TO .PROJECT QAOFFICER WITH CERTIFICATION MEMO

1PROJECT QA OFFICER REVIEWSDATA FOR PRECISION, ACCURACY.AND COMPLETENESS

NO

INFORM LAB MANAGER OFTHE PROBLEM WITH THE DATA

1 YES

SUBMIT DATA TO PROJECT MANAGERWITH CERTIFICATION MEMO

MAKE DECISION ONUSE OF DATA

YSS

FIGURE 15.1CORRECTIVE ACTION DECISION MATRIXPAOII RAIL YARDPAOLJ, PA,

8397-E ffl GROUNDWATERTECHNOLOGY, INC.

u

Section: 15Revision No.: lDate: Aug 10, 1988Page: 5 of 5

Figure 15-2Corrective Action Form

CORRECTIVE ACTION FORM

Date:Job Name and W.O. No.:Initiator's. Name and Title:

Problem Description:______

Reported To:

Corrective Action Taken:

Reviewed and Implemented By:

CC:

Appendix I

Section: 16Revision No.: oDate: May 27, 1988Page: 1 of 2

16.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT

Every thirty days after project initiation, the ProjectManager, in conjunction with the Quality Assurance officer, willsubmit reports of all applicable quality assurance activities.These reports, which will be provided to the EPA Project Officer,will contain at least the following information:

1. The status and coverage of various laboratory and fieldquality assurance project activities;

.2. Data quality assurance reviews including assessmentaccuracy, precision, completeness, representativeness,'and comparability;

3. Significant quality assurance problems discovered,corrective actions taken, progress and improvements,plans and recommendations for further implementation orupdating of the investigative QAPP. The QA reportshave been specified'to contain any and all changes inthe Quality Assurance Project Plan during the course ofthe project;

4. Any significant field observations noted in the fieldnotebook during the sampling procedure; and,

5. A summarization of the results of performance andsystem audits, if conducted.

Examples of items considered during quality control checksare as follows:

1. Field Activities Which are Discussed in Various Sectionof the QAPP

o Standardized checklists and field notebooks;o Verification of checklists' information by an

independent person;

Appendix I

Section: 16Revision No.: 0Date: May 27, 1988Page: 2 of 2

o Strict adherence to chain-of-custody procedures;o Calibration of field devices;o Collection of replicate samples; ando Submission of field blanks, where appropriate.

2. Analytical Activities:

o Method blank(s);o Laboratory control sample(s);o Calibration check sample(s);o Replicate sample(s);o Matrix-spiked sample(s);o "Blind" quality control sample(s);o Control charts;o Surrogate samples;o Zero and span gases; ando Reagent quality control checks.

The level of laboratory reporting will be equivalent to EPASuperfund Contract Laboratory Program (CLP) deliverables package.

Appendix I

Section: Appendix ARevision No.: 0Date:' May 27, 1988.Page: 1 of 5

APPENDIX A" DEFINITION AND PROCEDURE

FOR THE DETERMINATIONOF THE METHOD DETECTION LIMIT

The method detection limit (MDL) is defined, as the minimumconcentration of a substance that can be identified, measured andreported with 99 percent confidence that the analyteconcentration is greater than zero and determined from analysisof a sample in a given matrix'containing analyte.

Scope and Application

^ " "This procedure is 'designed for applicability to a widevariety of sample types ranging from reagent (blank) watercontaining analyte to wastewater containing analyte. The MDL foran analytical procedure may vary as a function of sample type.The procedure requires a complete, specific and well definedanalytical method. It is essential that all sample processingsteps of the method be included in the determination of the MDL.

9

The MDL obtained by this . 'procedure is used to judge thesignificance of a single measurement of a future sample.

The MDL procedure was designed for applicability to . a broadvariety of physical and chemical methods. To accomplish this,the procedure was made device or instrument independent.

Appendix I - RISOP

Section: Appendix ARevision No.: 0Date:' May 27, 1988Page: 2 of 5

Procedure:

1. Make an estimate of the detection limit using one of thefollowing:

a. The concentration value that corresponds to aninstrument signal/noise ratio in the range of 2.5 to 5.If the criteria for qualitative identification of theanalyte is based upon pattern recognition•techniques,the least abundant signal necessary to achieveidentification must be considered in making, theestimate.

"v""liB." The concentration value" that corresponds to three timesthe standard deviation of replicate instrumentalmeasurements for the analyte in reagent water.

c. The concentration value that corresponds to the regionof the standard curve where the-re is a significantchange in sensitivity at low analyte concentrationsi.e. a break in the slope o£ the standard curve.

d. The concentration value .that corresponds to knowninstrumental limitations.

It is recognized that the experience of the analyst isimportant to this process. However, the analyst mustinclude the above considerations in the estimate of thedetection limit.

Appendix I - RISOP

*/|

Section: Appendix ARevision No.: 0Date: May 27, 19.88Page: 3 of 5

2. Prepare reagent (blank) water that is as free of analyte aspossible. Reagent or interference free water is defined asa water sample is which analyte and interferantconcentrations are not detected at the method detectionlimit of each analyte of interest. Interferences aredefined as systematic errors in the measured analyticalsignal of an established procedure caused by the presence ofinterfering species (interferant). The interferantconcentration is presupposed to be normally distributed inrepresentative samples of a given matrix.

3. a. If the MDL is to be determined in reagent water*~ (blank), prepare a laboratory standard (analyte in

reagent water) at a concentration which is at leastequal to or in the same concentration range as theestimated MDL (Recommend between •1 and 5 times inestimated MDL). Proceed to Step 4.

b. If the MDL is to be determined in another samplematrix, analyze the sample. If the measured level ofthe analyte is in the recommended range of one to fivetimes the estimated MDL, proceed to step 4.

If the measured concentration of analyte is less than theestimated MDL add a known amount of analyte to bring theconcentration of analyte to between one and five times theMDL.

If the measured level of analyte is greater than five timesthe estimated MDL, there are two options:

Appendix I - RISOP

Section: Appendix ARevision No.: 0Date: May 27, 1988•Page: 4 of 5

»

1. Obtain another sample of lower level of analyte is samematrix if possible.

2. The sample may be used as is, for determining the MDLif the analyte level does not exceed 10 times the MDLof the analyte in reagent water. The variance of theanalytical method changes as the analyte concentrationincreases from the MDL, hence the MDL determined underthese circumstances may not truly reflect methodvariance at lower analyte concentrations.

4. Take a minimum of seven aliquots of the sample to be used tocalculate the MDL and process each through the entire"analytical method. Make " all computations according to thedefined method with final results in the method reportingunits. If blank measurements are required to calculate themeasured level of analyte, obtain separate blankmeasurements for each sample aliquot analyzed. The averageblank measurement is subtracted from the respective samplemeasurements.

5. Calculate the standard deviation(S) of the replicates.

6. Calculate the MDL as follows using (T) from the table below:

MDL = T x S

Appendix I - RISOP

Section: Appendix ARevision No.: 0Date: May 27, 1988Page: 5 of 5

Table of Students' t values at the 99 Percent Confidence Level

Number of Degrees of FreedomReplicates (n-1) t(n-l, 1-a = .99)

7 , . 6 3.1438 7 . 2.9989 8 2.89610 9 2.821

REFERENCE: "Appendix A, Methods for Organic Chemical Analysisof Municipal and Industrial Wastewater", EPA600/4-82-057, July 1982.

Appendix I - RISOP

Section: Appendix,BRevision No.: 0Date: May 27, 1988Page: 1 of 12

APPENDIX B

Appendix I - RISOP

"13031,75

Labof a-.orv Name

Case NoS a T, p. c N j m r<

Organics Analysis Data Sheet(Page 3}

Pesticide/.PCBs.G?C Cleanup CYes QNo

Date Extracted/Prepared ________________ Sepa'atory funnel Extraction CYes

Date Analyzed. —————————'.————————————— Continuous Liquid - Liquid Extraction QYesCone/Oil Factor: ————————————————————————

Percent Moisture (decanted)

CAS . ug/Iorug/KgNumber (Circls One)319-S-J-6319-35-7319-85-353-89-976-1--33DS-CO-2102^-57-3959.93-S63-57-172-55-972-20-8322i3-e:-S,72-5--S103: -07-850-25-372--O-S53-9--70-5S7.7i-9300' -35-21267^-11-21 1 10^-28-2UUl.16-553«i55-21-912672-29-6•, 1097-69-11 1096-32-5

Aio.ia-SHC8eia-8HCOelia-BHCGa-nma-BMC (Lirida.ie1Heatacnio'A, (innHestacnio' Sscxiieenaasullan 1Oieic'.n«.<'-00£cni.'in£na;$j!ian ui. 4 -000Jnoos'jifar. Sullate4 d .QOTMe:^oivcnic'tnirin Keto.ieCnioi-iianeToxaoieieAroclo'-1016Arocio'-122lAfocior-1232Aroclor-12-i2Afocior-12«8Afoclor-1 25- -Arocio-- 1 260

V( - Volume of extract i'n]ected (ul)

V - Volume o! water extracted (ml)

W i Weight of sample extracted (g)

V( = Volume of total extract (ul)

V, —————————————— orWs ———————————— V,

Form 1

Revision fl R>3 Q 3 f. JcDate September 1986 ^ ' °

Organics Analysis Data Sheet

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APPENDIX C

OUTLIER TEST

An extreme observation (outlier) is a datum that appears tobe different from the main data pattern.

The principal safeguards against obtaining or using anoutlier are vigilance during all operations and visual inspectionof data before performing statistical analyses.

If a datum falls above or below the control limits of eitherthe X or R control chart, the value shall be investigated.v^ometimes the investigation will reveal a recording orcomputational mistake that can be revised to obtain the correctvalue. If an error is found but the correct value cannot bedetermined, the error is found but the correct value cannot bedetermined, the erroneous value shall not be used in statisticalcalculations. When errors are found, either correctable oruncorrectable, all analytical results for that lot must beinspected to ensure that erroneous results are not reported. Ifan uncorrectable error affected results of environmental samples,the lot shall be judged as out of control, and analyses must berepeated.

If no assignable cause for the outlier can be found, thedatum shall be statistically tested using tables of theprobability that an outlier would be observed if the data werenormal and conformed to the assumed model. Dixon's Test

Appendix I - RISOP

Section No.: CRevision No.:Date: April 6, 1988Page: 1 of 3

expresses the gap between an outlier and the nearest value as afraction of the range between the smaller and largest value. Adatum so determined to be an outlier will be removed from thedata set before statistical calculations. Likewise, data sets ofenvironmental measurements which can be assumed to be normallydistributed can be evaluated for outlier with this test.

Appendix I - RISOP

AR3Q3l*88

Dixon's Test

The datum to be tested will be X and/or R, depending onwhich values fall outside the control limits on X-R controlcharts.

The entire data set must be ordered from highest to lowest,with the highest value assigned a rank of 1 (x) and the lowestvalue a rank of N (x) . The test criterion (r) varies with samplesize, as follows:

For less than eight measurements, reject x if:

xH^N~l r10 (°r reject x if x2 1 r10)XN XN x - x

Between eight and ten measurements, reject x if:

l r____ (or reject x if x.2— iXN~X2 xN-l~xl

Between eleven and thirteen measurements, reject x if:

xN-N-2 r2i (or reject x if X3— IxN-2 xN-l-xl

Over thirteen measurements, reject x if:

xH-N-3 r22 (°r reject x if J j- l. r22)~ ~

The critical values for the test statistic at 99 percentconfidences level are shown in Table K-l. If the test statisticis greater than the critical value from the table, then the datumis an outlier.

Appendix I - RISOP

tlR3Q3l*89

Table K-l. Critical Values for Dixon's Outlier Test

Number ofMeasurements

(N)

34567

8910

111213

14 '151617 '18

- -119-- •202122232425

Criterion _ Critical Value(r)" or r

0.9880.889

10 0.7800.6980.637

0.68311 0.643

0.615

0.67921 0.642

0.615

, 0.6410.6160.5950.5770.5610.547

22 0.5350.5240.5160.5050.4970.489

Appendix I - RISOP

Appendix DKey Personnel

Appendix I - RISOP

AR 30549/

Paul M. Yaniga, P.G.Senior-Vice PresidentPrincipal Hydrogeologist

EDUCATION BA, Earth Science/Bloomsburg State CollegeMS, Geological Science/Lehigh University

PROFESSIONAL Senior Vice President and founder of GroundwaterPROFILE Technology, serving as Principal Hydrogeologist.

Contributes to the formulation of executive-levelcorporate policies, and provides personal liaison forclients to insure strategic quality control andassurance in the design of projects that effectivelymeet clients' needs. Has expertise in geology,hydrogeology, soils, geochemistry, geophysics andhazardous wastes. . Special interest is the practicalapplication of scientific principles to the solutionof "real-world" problems, thereby advancing the state-of-the-art in control and treatment of groundwatercontamination by hydrocarbons and other industrialchemicals/ and minimizing the potential risk andliability inherent in modern facilities, which allowners must face.

Expert standing in the field of applied hydrogeology^ ^^_ _. . . is based .on the successful completion of numerous_

projects worldwide. Has solved problems involving'solid waste disposal, hazardous waste assessment andcontrol, groundwater recovery and decontamination,aquifer restoration, community waste water treatment,and the development of potable water supplies.

Has prepared numerous detailed scientific reports andis an experienced expert witness.

Recent efforts have focused on advancing therecognition and development of in situ bioreclamationas a state-of-the-art aquifer remediation tool. He isalso making substantive technical contributions tocomplex situations requiring the abatement ofpollution from free- , dissolved- , vapor- andadsorbed-phase organic-chemicals in the subsurface.

Before he founded Groundwater Technology, Inc., Mr.Yaniga served as a project manager and hydrogeologistfor two consulting firms, where he managed manyprojects requiring the practical resolution ofgroundwater pollution and supply problems, andevaluation of site suitability for the land treatmentand renovation of domestic wastewater and landfillleachates, and as a hydrogeologist for thePennsylvania. Department of Environmental Resources,where his responsibilities included all aspects ofland and water quality protection.

Paul M. Yaniga, P.G.Page 2

SPECIALQUALIFICATIONS

Registration

Certified Professional Geologist - Delaware (342)Certified Professional Geologist - Indiana (222)Certified Professional Geologist - Virginia (656)Certified Professional Geologist - North Carolina(920)Certified Sewage Enforcement Officer - Pennsylvania(040130)

Professional Affiliation

American Institute of Professional Geologists(Received acknowledgement of professionalproficiency from the Michigan Section AIPGGroundwater Consultants Committee)National Water Well AssociationMichigan Well Drillers Association, Technical DivisionPennsylvania Petroleum Association

Presentations

"Aquifer Restoration; Comprehensive Address to OrganicChemical Contamination." National Water WellAssociation Conference: Agriculture Impact onGroundwater.

"Corrective Action for Containing and ControllingGroundwater Contamination." National Water WellAssociation Corrective Action, Atlanta, GA.

"X-Expo Sicion De Enaeniera Sanitary Y Ambiential."The Y Congreso Venezolano De Ingeneria Sanitaria YAmbiental. Maracaibo, Edo. Zubia. March 2-5, 1988.

"Monitoring and Remedial Actions for PetroleumContamination." Southern Company Services, Inc.Hershey, PA. Groundwater Short Course for Mid-AtlanticUtilities.

"Cleaning Up Petroleum Contaminated Aquifers."Implementing Groundwater Pollution Remedial Actions.January 20-22, 1988. Madison, Wisconsin.

"Aquifer Restoration: Comprehensive Address to OrganicChemical Contamination." World Conference on Hazardous/Waste, October 25-31, 1987. Budapest, Hungary.

ftR303l*93

Paul M. Yaniga, P.G. •Page 3

"Case Histories of . Petroleum Hydrocarbons Clean-Up."National Water Well Association: Corrective Actionsfo.r Containing and Controlling GroundwaterContamination. October 20-22, 1987. Raleigh, NC.

"Gasoline and Groundwater Clean-Up." Florida LocalEnvironmental Regulation Association Annual Meeting.October 15, 1987. Gainesville, FL.

"Aquifer Restoration: Alternatives for the Removal ofOrganic Contaminants." City College of the' CityUniversity of New York. September 16-18, 1987, ThirdAnnual Groundwater Conference.

"Aquifer Restoration Via Accelerated In SituBiodegradation of Organic Contamination." HazardousMaterials Control Research Institute SuperfundConference, December 1986, Washington, D.C.

"Aquifer Restoration: Comprehensive Address to OrganicChemical Contamination." National Water WellAssociation Conference: Petroleum Hydrocarbons andorganic chemicals in Groundwater Prevention, Detection

.. ^~ ^_ - - and Restoration,. November 1986, Houston, TX.

"Aquifer Restoration: Impacts of Fluctuating WaterLevels in Gasoline Cleanup, South-Central Texas"National Water Well Association Conference: Focus onSouthwestern Groundwater Issues, October 1986, Tempe,AZ.

"Groundwater Protection and Waste Treatment Practicesin the Electronics Industry; Practical Aspects ofTreatment." American Institute of Chemical Engineersmeeting, August 1986, Boston, MA.

"Restoration; Case histories" National Water WellAssociation: Underground Storage Tank Management shortcourse, August 1986, Edison, NJ.

"Monitoring and Remedial Action for PetroleumContaminants (Leaking Underground Storage Tanks)"Southern Company Services, Inc.: Groundwater shortcourse for the Southern Electric System, August 1986,Birmingham, AL.

"Case Histories of Petroleum Hydrocarbons Cleanup""Physical Recovery of Petroleum Hydrocarbons" NationalWater Well Association: Corrective actions forcontaining and controlling groundwater contaminants,July 1986, San Diego, CA.

Paul M. Yaniga, P.G.Page 4'

"Bioreclamation of Hydrocarbon and other OrganicContamination." (session moderator) National WaterWelJL Association: Sixth national symposium andexposition on aquifer restoration and groundwatermonitoring, May 1986, Columbus, OH.

"Solutions to Underground Tank Risks" GroundwaterTechnology, Inc. seminar, May 1986, Atlantic City, NJ.

"Hydrocarbon Contamination of Groundwater; Assessmentand Abatement" University of Wisconsin: Groundwaterpollution remedial actions, January 1986, Madison, WI.

"Underground Storage Tank Management" National WaterWell Association short course, January 1986, FortWorth, TX. ,

Frank Aceto, Jr., P.G.District ManagerSenior Hydrogeologist

EDUCATION BS, Geology/Bloomsburg State CollegeMS, Hydrogeology/Ohio University (thesis pending)

PROFESSIONAL Manager of the Chadds Ford District office of thePROFILE Mid-Atlantic Region. Directs staff of engineers,

hydrogeologists, geologists, and technicians engagedin comprehensive site remediation. Typical projectsinclude investigations, remedial action plans,recovery programs, and treatment systems. Manyprojects are Superfund sites listed on the U.S.Environmental Protection Agency's National PriorityList (NPL) .

As Senior Hydrogeologist, led the implementation ofsite assessment and remedial action programs. Alsoserved as an in-house consultant for the development

•- ^~-^~ - • and applica-tion-of- computer simulation techniques to-subsurface problems involving groundwater pollution.

PROJECT Projects include:EXPERIENCE

Remedial Investigation/Feasibility Study, PA - ProjectManagerSite investigation, design, and implementation ofremediation plan at NPL site to define volatileorganic compounds from contaminated soils andgroundwater *.

Industrial Site Assessment, PA - Project ManagerDeveloped programs for site clean-up remedy selectionrequired under CERCLA for definition ofpolychlorinated biphenyl (PCB) and dioxin compounds atan"active rail yard.

Leaking Underground Storage Tanks, Project ManagerSelected by the U.S. Department of Defense to performsite assessment, definition of contaminant plumes, andclean-up design at selected facilities throughout theNorthern Division Engineering Command.

Groundwater Pollution Abatement, PA - Project ManagerHydrogeologic assessment o-f bedrock aquifercontaminated by multiple ruptures of buried fuelpipeline indicated the appropriate abatement programto minimize impact on adjacent residential community.

Frank Aceto, Jr., P.G.Page 2

Risk Assessment, - Project ManagerHydrogeologic evaluations of service stations, storageterminals, and fuel transfer facilities torealistically assess risks and potential impactsresulting from possible losses of hydrocarbons.

Industrial Site Clean-Up, NJ - Project ManagerHydrogeologic site assessment formed the basis forremedial action program to clean up a chromiumcontaminant spill in an unconsolidated, coastal plainaquifer.

Industrial Site Mitigation, PAInvestigations to successfully define the extent offree-phase hydrocarbons and determine appropriateabatement program to minimize seepage into surfacestreams.

Groundwater Withdrawals, PA - Project ManagerExploration of new water supplies and development ofsupporting technical documentation. Gained permitsfor new wells in a groundwater-protected basin.

SPECIAL^QUALIFICATIONS

Publications;

Aceto, F., .Jr., Brenoel, M., Yaniga, P., "Chlorinated OrganicContaminants in Groundwater Assessment, Containment,and Abatement." Ninth Annual Spills Conference, Ohio,1984.

Aceto, F., Jr., Jasiulewicz, F. "Industrial FacilityDecommissioning: Geotechnical Considerations forEvaluating Impacts to the Environment From Chlorinatedand Other Organic Compounds." American Institute ofChemical Engineers National Meeting, 1986.

Aceto. F., Jr., "Considerations in Defining the Presence,Movement, and Removal of Chlorinated Organic CompoundsFrom Groundwater Systems." American Institute ofChemical Engineers, National Meeting, 1986.

Aceto, F. , Jr., Jacobson, J., Smith, W. "Considerations ForOptimization of Recovery Well Designs. PetroleumHydrocarbons and Organic Chemicals in Groundwater."National Water Well Association, 1986.

• Expert Witness for several litigation proceedings.

Q "7-> /

Frank Aceto, Jr., P.G.Page 3

Professional Affiliations;

Association of Groundwater Scientists and EngineersNational Water Well AssociationSociety of Professional Well Log AnalystsAmerican Associations of Petroleum Geologists

Registration

Certified Professional Geologist - Indiana (#668)

Continued Education

Certificate of Completion "Fundamentals of HazardousMaterials Management," 1986.

_Cathleen A. Collins' Project Hydrogeologist

EDUCATION BS, Geosciences/Pennsylvania State University

PROFESSIONAL Hydrogeologist managing projects in the Mid-AtlanticPROFILE Region. Conducts hydrogeological assessments of

commercial and industrial sites, and designsstatistically and technically sound investigations toacquire site-specific data. Implements fieldactivities and site remediation programs, as well asevaluates the resulting data. Prepares project reportsand proposals. Acts as Remedial Investigation Manageron Superfund projects. Monitors project budgets andprogress to provide efficiently-run services yieldingqualtiy data.

Previous experience includes preparation of NJPDESpermits and provision of technical support for CERCLA,RCRA, ECRA, and Spill Fund projects.

PROJECT L_ -• • Some of her-typical. projects include:EXPERIENCE

Remedial Investigation/Feasibility Study, PA - ProjectHydrogeologist/RI Manager. Wrote Work Plan, RISOP andQAPjP for EPA and PADER approval and consent decreecompliance for PRPs that used PCB fluids. Interactwith regulatory agencies, client council, in-housetechnical experts and subcontractors. Organize andconsult with project team.

Remedial Investigation/Feasibilrty Study, PA - ProjectHydrogeologist/RI Manager.Design of site-specific remedial investigation toidentify the most feasible alternative for removal ofvolatile organic compounds from soils and ground waterwill allow closure of "Superfund" landfill.

Leaking Underground Storage Tanks. PA - ProjectHydrogeologistInvestigation of built-up military sites underrestricted conditions successfully defined extent ofplumes and made possible the design of effectivecleanup strategies.

flR303if'99

Cathleen A.. CollinsPage 2

Industrial Site Remediation. PA - ProjectHydrogeologistHydrogeological assessment of truck depot revealedways to improve- the cleanup of petroleum hydrocarbonsin ground water on site.

Groundwater Monitoring, NJ, NC - ProjectHydrogeologistCompleted required hydrogeolpgical assessments ofindustrial facilities with RCRA-regulated surfaceimpoundments containing heavy metal sludges.

Site Closure and Post-Closure Plans. NJ - ProjectHydrogeologistPrepared the required documentation justifying cost-effective plans for in-place closure of RCRA-regulatedsurface impoundments.

Land Evaluation for Transfer of Ownership, NJ--Project HydrogeologistSpot excavation and classification of soilscontaminated with organic chemical compounds indicatedthe proper choice of disposal method and made possiblethe prompt transfer of land ownership for ECRA-regulated site.

Feasibility Study. IN - Project HydrogeologistEvaluation of acid sludges showed feasible treatmentalternatives and disposal options.

SPECIALQUALIFICATIONS

Professional Affilia'tion

National Water Well AssociationHazardous Waste Business

Continuing Education

Groundwater Pollution and Hydrology, PrincetonAssociates, NJ.

Hazardous Materials Incident Response Operations, USEnvironment Protection Agency meeting 40 hour OSHASafety Training Standard.

Train the Trainer, 8 hours Safety Supervisory TRainingmeeting OSHA standard.

Effective Supervision, University of Delaware-

8R3035GG

Cathleen A. CollinsPage 3

Engineering Coursework, Trenton State College.

Pursuing Master's Degree in Environmental Engineering,University of Delaware.

AR30350I

Susan E. DavisProject Administrator

EDUCATION BS, Communications/Appalachian State UniversityAA/Wesley College

PROFESSIONAL Project Administrator for all field work for projectsPROFILE conducted in the Mid-Atlantic Region. Duties include

project accounting, time line development, reportfiling, and general aid for all field work. Reportsto Project Manager

PROJECT Project experience includes:EXPERIENCE

Industrial Site Remediations, PA - AdministrationDuties include time line development, project reportupdate, supervision of data records, and sampling,labeling, and shipment coordination.

02.

Eric HenryChemical Engineer

EDUCATION BS, Chemical Engineering/Bucknell University

PROFESSIONAL Chemical Engineer in the Mid-Atlantic RegionPROFILE experienced in a range of physical and chemical

treatment methods. Evaluates available treatmentoptions and designs appropriate equipment, based onsite-specific assessments, to accomplish the removalof hydrocarbons and other chemical contaminants fromsurface and groundwater.

Regulatory experience includes NPDES, WQM Part II, andair quality permitting.

PROJECT Some of his typical projects include:EXPERIENCE

SUPERFUND Site RI/FS, PA - Project Engineer.Organized and carried out tasks for the evaluation ofinitial remedial measures. Developed cost estimatesfor remedial alternatives. Screened Feasibility Studyalternatives.

Various Sites, PA - Project Engineer... ~---L_ -• • Designed • a-nd .permitted (NPDES, Part II, Air).

groundwater cleanup systems including regulatorynegotiation.

Adhesives Plan PPC Plan, PA - Project Engineer.Prepared prevention, preparedness, and contingencyplan.

Industrial Site Evaluation. PA - Project Engineer.Designed an air stripping system with recirculation toaffect significant removals of poorly strippedketones. Design based on a single-pass pilot study.

SPECIALQUALIFICATIONS

Completed 40-hour Hazardous Site Safety TrainingCourse, meeting the requirements of 29 CFR 1910.120.

Professional Affiliations

American Institute of Chemical EngineersNational Society of Professional EngineersPennsylvania Society of Professional Engineers

Scott M. KeatingEnvironmental Scientist

EDUCATION BS, Biology/East Stroudsburg UniversityBS, Environmental Studies/East Stroudsburg University

PROFESSIONAL Environmental Scientist in the Mid-Atlantic Region.PROFILE Conducts site assessments for commercial and

industrial sites, develops sampling programs to obtainsite-specific data, collects field samples, organizesfield activities, designs site remediation programs,interprets analytical sampling data, and preparesproject reports and proposals.

Previous experience includes employment as an ECRAProject Manager. In this capacity he devised samplingprograms, collected field samples, operated severaldrill rigs, devised clean-up programs-, and preparedthe necessary ECRA documents for submission to theNJDEP. , •

PROJECT Typical projects include:EXPERIENCE

Leaking Underground Storage Tanks, PA - Environmental.. ~-'L. -• - Scientist.- . ..

Investigation of military sites. Project included thedesign of soil gas sampling program and supervision ofproper tank excavation, installation and sampling ofgroundwater monitoring wells, and completion of soilborings to define extent of hydrocarbon-laden soils.

Remedial Investigation/Feasibility Study. PA-Environmental Scientist.Compiled and synthesized recorded data for use inremedial investigation and assisted in developing soilsampling program for PCB-contaminated soils. FieldDocumentation Coordinator to monitor QA/QC protocolsfor initial soil sampling program; promoted to FieldOperations Manager in charge of all field programs forremainder of RI.

Paul C. Miller, P.E.Manager, Engineering

EDUCATION BS, Chemical Engineering/University of Maryland

PROFESSIONAL Manager of Engineering for Mid-Atlantic Region.PROFILE Currently leading a research project to develop

catalytic incinerators for in-field use (patentspending). Responsible for design and development ofwater and soil treatment systems used for sitemitigation and other hydrogeologic projects throughoutthe Region. Also responsible for senior management offeasibility studies performed under CERCLA.

Previous experience includes serving as a developmentand quality assurance engineer in both the private andpublic sectors. Also contributed to the developmentof a computer software package to model chemicalengineering process information and integrate the'results with economic data for given applications.Has researched, wrote, and taught a course on thecorrosion, cleaning, electroplating and surfacemodification of metals, including proper control ofassociated hazardous wastes.

PROJECTL_ - • Some of his-typical projects include:EXPERIENCE

Industrial Site Mitigation - Project Engineer.Air-stripping, carbon adsorption, and ion exchangesystem designed to treat water discharged from asedimentation. Reduced levels of BOD, COD, TSS,phenols and zinc.

Regulatory Compliance.System designed to treat storage tank water bottomslimited concentrations of dissolved hydrocarbons,emulsified hydrocarbons, phenols and suspended solidsfor compliance with NPDES permit.

Site Mitigation. PA.Designed system to protect residential area borderingan" industrial site. " Off-site migration of erodedsoils contaminated - with PCBs was limited by thiserosion control system.

Site Remediation.Comprehensive plan for removal of debris of unknownorigin from an unauthorized disposal site onresidential property.

"ftsossos

Paul Miller, P.E.Page 2

SPECIALQUALIFICATIONS

Professional Affiliations

American Institute of Chemical Engineers

Registration

Professional Engineer (PE)

^303506

Sharon A. PaceData Validation ChemistQA Officer

EDUCATION BS, Biology/Lycoming College

PROFESSIONAL Data Validation Chemist for the Mid-Atlantic Region.PROFILE Experienced in the compilation of QA/QC programs for

an environmental laboratory, setting standardoperating procedures for all laboratory analyticalservice groups including gas chromatography/massspectroscopy, atomic absorption, ICP, and wetchemistry. Implemented QA/QC protocols forenvironmental lab, audited data and verifiedcalibration curves, proper standards blanks,duplicates, and spikes. Wrote QA/QC Plans for areachemical companies.

Interfaces with clients presenting customized QA/QCpackages, and writing successful proposals.Interprets and validates GC/MS data with respect toUSEPA Contract Laboratory Program protocols. Conductson-line searches in chemical and biological abstractsthrough distributors, and performs statisticalanalysis and control charting on routine laboratory

. - - - - ; _ - - • data through LOTUS. 123, preparing tables and graphs,for presentations.

SPECIALQUALIFICATIONS

Continuing Education

Villanova University, pursuing Master's Degree inChemistry.

Attended USEPA CLP conferences, Quality Assurances andEnvironmental/Occupational Health Monitoring Course.

Professional Affiliations

American Chemical 'Society, National ChapterDelaware Valley Chromatography Forum Member

AR303507

Andrew C. ThomasEnvironmental Scientist

EDUCATION BS, Environmental Science/West Chester University

PROFESSIONAL Environmental Scientist for the Mid-Atlantic Region.PROFILE Responsible for site assessment for commercial and

industrial sites, developing sampling programs toobtain site-specific data, collecting field samples,organizing field activities, designing siteremediation programs, interpreting analytical samplingdata, and preparing project reports and proposals.

Previous experience includes RCRA TSDF permitting,safety and health training, NPDES and air qualitypermitting, SARA reporting, and site auditing forcompliance and maintenance, regulatory compliance andacting safety manager for a TSDF storage terminal inPA.

PROJECT ' Related project experience includes:EXPERIENCE

Remedial Investigation/Feasibility Study of FormerLandfill - Field Operations Manager, EasternPennsylvania.Site-specific remedial investigation to identify themost feasible alternative for removal of volatileorganic compounds from soils and groundwater to allowclosure of Superfund site.

SPECIALQUALIFICATIONS

Professional Affiliations• »

Pennsylvania Environmental Council

Continuing Education

Train the Trainer, 8 hours Safety SupervisoryTraining, meeting OSHA standard.

Hazardous Materials Train the Trainer, meetingDepartment of Transportation Standards for HazardousMaterials.

303508

Larry P. JacksonLaboratory DirectorGT Environmental Labs

EDUCATION BS, Chemistry/Florida State UniversityPhD, Chemistry/Wayne State University

PROFESSIONAL Laboratory Director of GT Environmental Laboratory,PROFILE a subsidiary of Groundwater Technology, Inc. Directs a

staff of analysts and administrative personnel.Responsible for all facets of laboratory operation andpersonnel management.

Previous experience includes employment as a seniorstaff research scientist, a project manager onresearch contracts, and also served as manager of thedivision of research support at the Laramie EnergyResearch Center.

PROJECT , A summary of relevant technical experience includes:EXPERIENCE

Methodology Development and Evaluation.Led projects evaluating the EP Toxicity Characteristic(EPTC) and the Toxicity Characteristic LeachingProcedure (TCLP) applied to various wastes. Managedand provided technical direction to develop standardwaste samples and a liquid release test standard.Directed the group working with an EPA industry groupto evaluate the proposed TCLP. Led in the ASTM effortto develop a standard leach test for solid wastes.These project have lead to the design, conduct, andevaluation of laboratory projects responsible for over2,500 separate leach tests. Organized andparticipated in multi-laboratory studies to evaluatethe leachability of organic compounds from fossilenergy wastes at the 10 ppb level. Investigated theleachability of trace elements from fossil energyresidues using compleximetric reagents. Developedanalytical procedures to measure environmentallysignificant constituents in fossil energy waste watersand solids. Developed a semi-micro procedure forguantitating alkanes, alkenes, and aromatics in fossilfuels.

^303509

Larry P. JacksonPage 2

Manual Preparation and Revision.Responsible for the preparation and updating of theGTEL QA/QC plan. Oversaw the development of a guidefor sampling fossil energy wastes. Applied the guideat 26 sites to over 100 materials in silos, trucks,ponds, piles, lagoons, pipes, and other sitelocations. Methods of sampling and sample preparationare described that are capable of producing sampleswith less than 1% bottle-to-bottle variation.

Public Involvement.Chairman of ASTM Committee D34 on Waste Disposal. InASTM and other related activities, organized foursymposia, two of which were international in scope.Helped organize six additional symposia, and organizedand chaired about 20 additional meetings open to thepublic for issues related to solid and hazardouswastes.

Technical Support to Regulatory Development.Coordinated the activities of ASTM Committee D34 withEPA OSW in the area of methods development. ProvidedDOI Office of Surface Mining with definitive study ofleachates from abandoned coal refuse used by OSM toformulate agency position of environmental impact.Managed a technical program to develop laboratory testmethods to predict potential leachability of coalrefuse.

Analysis of Regulatory Option and Other RegulatoryImpact Analysis.Conducted projects for the electric utility industryand the textile industry on the impact of the TCLP onthese industries. Provided input used to respond toEPA requests for public comment on the TCLP.

Hazardous Waste Repository.Designed and managed hazardous waste samplerepository. Developed sample processing protocols,QA/QC procedures, sample containerization methods, andlong-term storage procedures. Established andmaintained the DOE fossil energy waste samplerepository.

SR3035IQ

Larry P. JacksonPage 3

SPECIALQUALIFICATIONS

Professional Affiliations

American Chemical SocietyAmerican Society for Testing and Materials

Publications

Jackson, L.P., et. al. "Characterization of Solid Wastes fromConventional Coal Combustion Processes." WesternResearch Institute, March, 1986.

__________, and Susan Sorini. "Toxicity Characteristic LeachingProcedure Applied to Fossil Energy Wastes." WesternResearch Institute, February, 1986.

______, and C.C. Wright, eds. Analysis of Water AssociatedWith Alternative Fuel Production. ASTM SpecialTechnical Production 720. ASTM (Philadelphia, PA),'1980.

^30351

Russell E. Keenan, Ph.D.Director and PrincipalScientist of Risk AssessmentDivision, Envirologic Data

EDUCATION PhD, Forestry and Environmental Studies/DukeUniversity

BS, Biology/Bates College

PROFESSIONAL Director of the Risk Assessment Division ofPROFILE Envirologic Data, a subsidiary of Groundwater

Technology, Inc. Administers all client servicesrelated to the effects of chemicals on human healthand the environment. Directly supervises the RiskAssessment branch offices in California andPennsylvania.

Also serves as principal scientist and projectmanager, and has successfully directed over 100exposure or quantitative risk assessment projectsduring the last four years. His expertise extends toa variety of chemicals and environmental contaminantsincluding dioxins, furans, volatile organic compounds,PCBs, metals and pesticides. In particular, his workin quantitative risk assessment of dioxin in wastewater sludges, in bleached pulp, and in paper productsis internationally known. His experience includesmultiple-pathway exposure and risk assessment ofemissions from resource recovery facilities,environmental emissions, effluents, and soilcontaminants from chemical manufacturing facilities.He has evaluated the risks to humans and wildlife fromexposure to herbicides used for power line right-of-way maintenance. Dr. Keenan guides the development ofhealth-based, risk-driven remediation assessments forRCRA facility investigations and as part of the RI.FSprocess at CERCLA sites.

Dr. Keenan also specializes in providing regulatorysupport and communication with agency officials onquestions of potential risk to public health or theenvironment. His expertise in risk assessment hasbeen utilized at the local, state, and federal levelthrough the testimony he has given at the regulatoryproceedings and public hearings.

AR3035I2

AR3035J3

Russell E. Keenan, Ph.D.Page 2

Prior to his appointment as Director of the RiskAssessment Division, his project experience includedthe implementation and management of right-to-know andhazard communication compliance programs for employersin four northeastern states, including twenty acute-care and rehabilitation hospitals. He has conductedhazard communication training for over 3,000employees; and has planned, coordinated, and managedregional and international symposia on environmentalhealth related topics.

PROJECT Project experience includes:EXPERIENCE

North American Conference on Pesticide Spray Drift andChemical Trespass. Board of Pesticides Control, MaineDepartment of Agriculture, Food and Rural Resources,Augusta, Maine.Planned, coordinated, publicized, and managed theconference, an international symposium on the legal,environmental, human health, and technological aspectsof . off-target pesticide drift. Also edited and"coordinated publication of the proceedings of theconference.

Literature Review and Report.Conducted a literature review and comprehensive reporton the protection of red spruce from spruce budwormdefoliation.

Research and Report. Falmouth, Maine.Conducted research and produced a report forlaypersons about the ecological effects of biomass

• harvesting in the Maine Forest.«

Forestry Program. Falmouth, Maine - Forestry ProgramManager.Developed forestry program at Maine Audubon includingplanning, grant procurement, budgeting, andimplementation. Analyzed and researched forestresource issues. Developed policy positions withtrustees and staff. Presented Maine Audubon's policiesthrough appointments to statewide advisory boards,forestry working groups, special committees, andthrough a program of public education utilizingtelevision, radio, and the printed media.

Russell E. Keenan, Ph.D.Page 3

SPECIALQUALIFICATIONS

Publications

Keenan, R.E., Sauer, M.M., Lawrence, F.H. 1988. Examination ofPotential Risks from Exposure to Dioxin in Paper MillSludge Used to Reclaim Abandoned Appalachian CoalMines. Chemosphere.

Keenan, R.E., Sauer, M.M., Lawrence, F.H., and Crawford, D.W."Examination of Potential Risks from Exposure toDioxin in Sludge used for Strip Mine Reclamation." inEnvironmental Risk Assessment; A Textbook of CaseStudies. D.J. Paustenback (ed.) J. Wiley & Sons: New

- York, 1988.

Wenning, R.J. and Keenan, R.E. 1988. "Risk Driven Recommendationsand the Concept of Riskopleth Development in theAssessment of Cleanup of Contaminated Land." inMcKeown, J.J. (ed) Proceedings of the 1987 NortheastRegional Meeting of NCASI (National Council of thePaper Industry for Air and Stream Improvements, Inc.)(in press).

Keenan, R.E., Sauer, M.M.., et al. 1987. Assessment of Human HealthRisks Related to Exposure From Dermal Exposure toDioxin in Paper Products. NCASI Technical Document No534

Keenan, R.E., Sauer, M.M., Lawrence, F.H., Maritato, M.C. andCrawford, D.W. 1987. Assessment of Human Health Risksand Potential Impacts on Terrestrial Wildlife Relatedto Exposure to Dioxin from Land Application ofWastewater Sludge in Maine. NCASI Technical DocumentNo. 525.

"K3035/5

Russell E. Keenan, Ph D.Page 4

Selected Presentations

Keenan. R.E. 1988. How Clean is Clean? The Use ofRisk-Driven Remediation as an Approach to solving OurHazardous Waste Problems. Invited paper to the SeminarSeries: On Site Corrective Action Solutions forRCRA/CERCLA Sites.

Keenan, R.E. 1988 Risk-Driven Remediation as anApproach for Determining Clean Up of ContaminatedLand. Presentation at 1988 Groundwater TechnologySouthcentral Regional Seminar.

Keenan, R.E. 1986. Relevant Issues in Setting SludgeUtilization Regulations. Presented at NCASI 1986Northeast Regional Meeting. Boston, MA.

Television Productions

The Forest: Maine's Legacy and Future. 1983.

Three, One-hour public televisions documentaries.Written and co-produced with the Maine PublicBroadcasting Network, Portland, ME.

Bugged by Gypsy Moths. 1982.

Three public service announcement written for WCSH-TV,Portland, ME.

Professional Affiliations

Society for Risk AnalysisSociety of Sigma XI - the Scientific Research SocietyAmerican Phytopathological Society

fl DQ O C iM. r\ o Co

Russell E. Keenan, Ph D.Page 5

Expert Witness

Assessment of Potential Health Risks From DermalExposure to Dioxin in Paper Products. Testimonypresented on behalf of the American Paper Institute tothe U.S. Environmental Protection Agency, the Food andDrug Administration, and the Consumer Products SafetyCouncil.

Potential Impacts on Human Health and Wildlife Speciesfrom Forestland Application of Paper Mill Sludge.Testimony presented at public hearing before the Townof Standish regarding S.D. Warren application to applysludge and residuals under Chapter 567.

Risk Assessment Methodology to Place Paper Mill SludgeLevels of Dioxin in Perspective. Testimony presentedto the Pennsylvania Department of EnvironmentalResources.

Assessment of Human Health Risks and Potential Impactson Terrestrial Wildlife from Exposure to Dioxin inBYPROR Paper Mill Sludge Used to Reclaim AbandonedStrip Mine Sites. Testimony presented at publicHearing before the Ohio Environmental ProtectionAgency.

Frank H. Lawrence, M.D.President and Medical Director,Envirologic Data

EDUCATION MD, Indiana University

BA, University of Delaware

PROFESSIONAL President and Medical Director of Envirologic Data, aPROFILE subsidiary of Groundwater Technology, Inc. Founded

Envirologic Data in 1975. His methodologies forassessing health hazards and risks associated withtoxic chemicals formed the basis for the company'sdevelopment. As President, he directs the overalloperation of Envirologic Data.

As Medical Director, he serves as senior toxicologist.He also serves as technical advisor and reviewer of

• the risk assessment projects and is Envirologic Data'sprincipal spokesperson in regulatory hearings andadjudications. Developed health evaluation andmonitoring programs for hazardous waste siteinvestigators, as well as for employees in industriesutilizing toxic substances.

A nationally recognized authority on the human healtheffects of dioxins and furans, and a pioneer inassessing the hazards and risks associated with othertoxic chemicals

Previous experience includes:

Chief, Department of Emergency Medicine, MaineMedical Center, Portland, ME.*Duties and responsibilities included development andmaintenance of an emergency department in a 550-bedhospital: the handling of 44,000 Emergency Departmentcases per year, a staff of 65 people includingattending physicians, physician assistants, houseofficers and other trainees, and attendant budgetmanagement.

SPECIALQUALIFICATIONS

Professional Affiliations

American Occupational Medical AssociationMaine Medical Center Medical Staff MemberUniversity of Massachusetts at Amherst, Division ofPublic Health - Adjunct Staff MemberMaine Department of Agriculture, Chairman of EDBAdvisory Committee

- Medical Advisory Committee to Maine Pesticide ControlBoard

A* 3035 IB

Frank H. Lawrence, M.D.Page 2

Professional Affiliations (continued)

Maine Medical Association Committee on Occupationaland Environmental MedicineEmergency Department Chiefs of MaineAmerican College of Emergency Physicians

Publications

Campbell, B.A., R. Ph,; D.W. Crawford, M.P.H.; F.H.Lawrence, M.D.;et. al. 1985. Exposure and Risk Assessment, HealthMonitoring and Risk Management for HerbicideApplicators. Transportation Research Record, 1016:21-27.

Lawrence, Frank H.; R.A. Micheals, et al. 1984. Ethylene Dibromide(EDB): A Guide for Decision Makers; Exposure Effectsand Risk Assessment. Envirologic Data, Inc., Portland,ME.

«R3035I9

Richard J. Wenning, MEMEnvironmental Toxicologist,Envirologic Data

EDUCATION MEM, Ecotoxicology/School of Forestry & EnvironmentalStudies, Duke University

BS, Environmental Science/University of Denver

PROFESSIONAL Environmental Toxicologist for Envirologic Data, aPROFILE subsidiary of Groundwater Technology, Inc., in the

Risk Assessment Division. Specializing in biochemicalenvironmental toxicology, he has substantial expertisein mammalian and biochemical toxicology,ecotoxicology, applied ecology, marine pollution,water chemistry, and statistical analysis. Hisunderstanding of toxicological mechanisms andecological effects contributes significantly to thefirm's expertise in quantitative risk assessments ofa variety of chemicals and environmental contaminants.

Principal duties involve the development of sitesampling plans and toxicological data bases for the.purposes of conducting endangerment assessments andpublic health evaluations under RCRA and CERCLA. Inaddition, he serves as project manager on a .number ofprojects pertaining to chemical contamination ofpublic drinking water supplies, environmental fatemodeling, and risk assessments of municipal andhazardous waste landfills. Mr. Wenning is involved inthe development of risk driven remediation as a riskmanagement strategy to reduce potential public healthproblems.

Previous experience includes the development ofbiochemical methods for the subcellular analysis ofmarine shellfish and freshwater fish tissues. Hisresearch on oxidative stress in marine bivalves isconsidered by his peers to be an importantcontribution to the understanding of oxyradicaltoxicology

Also designed and conducted experiments in the fieldsof human lactation an human muscle protein synthesis.

SPECIALQUALIFICATIONS

Special Appointment

Environmental Health Advisory Committee. Department ofHuman Services.

^303520

Richard J. Wenning, MEMPage 2

Professional Affiliations

Society of ToxicologySociety of Environmental Toxicology and ChemistryAmerican Association for the Advancement of Science

Publications

DiGiulio, R.T. , Wasburn, P.C., Wenning, R.J., et al . 1988."Biochemical Responses in Aquatic Organisms: A Review,Plus Recent Studie.s on Oxidative Stress." Invitedpaper for the eighth annual meeting of the Society ofEnvironmental Toxicology and Chemistry. Journal ofEnvironmental Toxicology and Chemistry. •

DiGiulio, R.T., Wenning, R.J. 1988. The Effects of MicrosomalOxygen Reduction in the Ribbed Mussel (Geukensiademissa,1 and the Wedge Clam (Rangia cuneata) . Shortpaper for the fourth International Symposium on the.Effects of Pollutants on Aquatic Organisms. MarineEnvironmental Research.

Wenning, R.J. et al. 1988. Oxidant-mediated Biochemical Effects ofParaquat in the Ribbed Mussel, Geukensia demissa.Aguatic Toxicology.

Wenning, R.J., DiGiulio, R.T. 1988. Microsomal Enzyme Activities,Superoxide Production, and Antioxidant Defenses inRibbed Mussels, Geukensia demissa, and Wedge Clams,Rangia cuneata. Comparative Biochemistry andPhysiology, Part C; Pharmacology & Toxicology.

Wenning, R. J. , Keenan, R.E. 1988. Risk-Driven Recommendation andthe Concept of Riskopleth Development in theAssessment of Clean up of Contaminated Land. In:McKeown, J.J. (ed) Proceedings of the 1987 NortheastRegional Meeting of NCASI National Council of thePaper Industry for Air and Stream Improvements,Inc. ) .

Presentations

Risk Assessment and Toxicology: How Clean Is Clean?Guest Lecturer at Sterling College, VT.

Gary Westerman, PhDSenior Scientist and ProjectManager

EDUCATION PhD, Physical Geography/Indiana State UniversityMA', Geography/Indiana State UniversityBA, Geography/Middlebury College

PROFESSIONAL Senior Environmental Scientist and Project Manager forPROFILE Envirologic Data, a subsidiary of Groundwater

Technology, Inc. Primary responsibilities are in theareas of scientific research and regulatory policyreview and analysis, client consultation, and projectdesign/management, and market analysis anddevelopment. Has presented regulatory complianceseminars to representatives from industry, health-careassociations, and government. Has also consulted witha broad range of clients on matters pertaining to riskand exposure assessment, health monitoring, and publicpolicy.

3R303522

Joseph P. ForanDirector, CHAMP ProgramRegulatory Policy SpecialistProject Manager

EDUCATION BA, History/Carleton College

PROFESSIONAL Director of the Chemical Hazards Assessment andPROFILE Management Program for Envirologic Data, a subsidiary

of Groundwater Technology, Inc. Acting ProjectManager and consultant interacting with clients,helping them deal with the emotional and politicalaspects of community and employee reaction to chemicalhazards issues. Also designs and implements programswhich provide management solutions to chemical hazardsproblems.

Previous experience includes over a decade ofextensive management experience combined withexpertise in federal and state environmental andoccupational health law and policy.

Previous employment includes: Executive Director forthe Natural Resources Council of Maine; Deputy Chiefof Staff for the United States EnvironmentalProtection Agency, as well as Director, Program PolicyStaff, Management Analyst, and Management Intern forthe EPA.

fl.RJ303.523

Edward A. Wood, Jr., P.E.Senior EngineerStorage SystemsManagement Services

EDUCATION BS, Civil Engineering/University of VirginiaME, Civil Engineering/University of Virginia

PROFESSIONAL Senior Engineer for Groundwater Technology, Inc.PROFILE Responsible for developing and implementing both

government and private industry comprehensiveconstruction services programs. These programsinclude: surveys of existing environmental andoperating conditions, regulatory requirementassessments, risk assessments, system closure,replacement and retrofit, inventory monitoring, tanktightness testing, release investigation, andremediation, and staff training.

Previously employed by REI constructors, Inc. and ERT,Inc. as a Senior Engineer responsible for allactivities associated with the hazardous wastestorage tank evaluations and certifications program.

As the National Manager, Mr. Wood's activitiesconsisted of estimating project costs for programs,controlling expenditures within budgeted amounts,designing and supervising numerous storage systemcertifications.

While acting as the Manager, his main responsibilitywas to develop and implement design parameters andspecifications for the installation of double walledtanks and partial liner systems for secondarycontainment, interfacing with governmental agencies toensure compliance with local laws, testing andsupervising the testing and storage systems forcertification.

PROJECT Related job experience includes:EXPERIENCE

Coordinated field activities and assessment ofnineteen hazardous waste storage tanks and/or systems.Witnessed testing, conducted inspections, and preparedcertification.

Managed field activities and testing of four hazardouswaste storage tanks and ancillary system for aninjection deep well. Conducted field inspection oftanks and piping system, and prepared certification.

AR30352U

Edward A. Wood, Jr., P.E.Page 2

Directed field activities and testing of one hazardouswaste storage tank and ancillary system, and preparedcertification.

Coordinated field activities testing of 179 hazardouswaste storage tanks at 45 sites in 14 states.Conducted field inspections, witnessed tests forcertification, and supervised subcontractors.Designed distillation unit for waste minimization andwaste recovery to lessen impact of secondarycontainment requirements.

Designed buildings for the temporary storage ofdrummed hazardous wastes. • Responsible for theanalysis of building loads on the foundation and thedesign of the building foundations. Also generatedarchitectural details for offices and laboratoryfacilities, and analyzed the mechanical and electricalrequirements for the buildings and specifiedappropriate equipment. Prepared design drawings andspecifications for the construction of these buildingsand surrounding paving.

Responsible for site layout, structural, andmechanical design for a carbon adsorption unitinstalled at an operating manufacturing facility.Evaluated the routing of piping, and design of majorequipment foundations, structural supports, and anelectrical control building. Designed support for two6-foot diameter ducts to be attached to a roofstructure without interfering with interior operationsor the integrity of the roof structure. Designedenvironmental containment and control systemimplemented through the use of an integrally castconcrete slab and wall, collection system and storageand transfer facilities.

Prepared and designed drawings and specifications forthe removal and disposal of an underground hazardouswaste storage tank.

Edward A. Wood, Jr., P.E.Page 3

Supervised the design, drawing, and specification ofcivil/structural requirements for major oil refineryexpansion. Evaluated pipe routing, equipmentselection, and design of equipment foundations andstructural supports and control building. Designaccommodated the near-doubling of the wastewatertreatment facility. Wrote specifications for designand construction responsibilities.

Lead engineer for design of support structures,including massive reciprocating and rotatingcompressor functions. Utilized state-of-the-artfinite element computer programs for design of commonvessel foundations. Supervised designs, drawings, andspecifications for foundations, an extension andvertical expansion of existing pipe racks, roads anddrainage systems. Interfaced with the client tomodify two structures and design three buildings,including a two-story laboratory.

On-site construction engineer responsible forcoordination of planning, scheduling, purchasing,material control, and construction activities.Analyzed field alterations impacts overlooked ininitial design. Evaluated cost estimates and obtainedcustomer approvals for these modifications.

Designed concrete foundations and structural supportsfor horizontal and vertical vessels. Pre-castconcrete structures were designed to expediteconstruction and eliminate the need for fireproofing.

AR3Q3526

APPENDIX E

FIELD SAMPLING FORMS

3R303527

GROUNDWATER TECHNOLOGY, INC.FIELD DATA SHEETFISH SAMPLES

FOR PAOLI RAIL YARD RI/FS

Sample Number: _____________________ Collection Date;Collector's Name: •_____________ Collection Time:Sample Location:Collection Method : electro-shock

FIELD PARAMETERS

Stream Depth: ____________________ Water Temp:Stream Width:Plow Velocity

Dissolved Oxyc

Species

I

\/QC Sample coservations:

Collector's S:2A Auditor:

Air Temp:Conductivity:Eh:

jen:

Number Length (cm)

-

Weight (g)

Collected:-

Lanature: ' Date:

SR3Q3528

GROUNDWATER TECHNOLOGY, INC.FIELD DATA SHEET

SURFACE WATER SAMPLESFOR PAOLI RAIL YARD RI/FS

Sample Number:______________________ Collection Date;Collector's Name: __________________ Collection Time:Collection Method: Grab_______________________Sample Location: ______________________________________

FIELD PARAMETERS

Stream Depth: ______________________ pH: _______Stream Width: ______________________ Eh: _______Water Temp: _______________________ Conductivity:Dissolved Oxygen: ____;______________ Turbidity: _Stream Flow Velocity: _______________Duplicate Collected: ______________________________Source of Field Blanks: ___________________________Observations (water quality, problems) :______._____________

i- located Samples:Collector's Signature: _________________ Date:QA Auditor: _____________________________

Field sketch photograph

AR303529

GROUNDWATER TECHNOLOGY, INC.FIELD DATA SHEET

BENTHIC INVERTEBRATE SAMPLESFOR PAOLI RAIL YARD RI/FS

Sample Number: __________________ Collection Date:Collector's Name: ________________ Collection Time;Sample Location:,Collection Method: Hand or rake

FIELD PARAMETERSStream Depth:_____________\_______ Water Temp:Stream Width: ___________________ Air Temp: __Flow Velocity: ___:______________ Conductivity;pH: ______________________________ Eh: _______Dissolved Oxygen: _______________

Species Collected: _____________________________________Number Collected: _____________________________Average Shell'Length: __________________________QA/QC Sample Collected: ___________________________:servations:__________________________________

Hector's Signature: ____________________ Date:QA Auditor:

Photograph

AR303530

GROUNDWATER TECHNOLOGY, INC.FIELD DATA SHEETSEDIMENT SAMPLES

FOR PAOLI RAIL YARD RI/FS

Sample Number: _____________________ Collection Date:Collector's Name: _____,____________ Collection Time:Collection Method: _________________Sample Location:Sample Type: surface sediment or sediment core

FIELD PARAMETERS

Stream Width: _____________________ . Stream Depth:Duplicate Collected:

Source of Field Blank:Dbservations:Co-located Samples:Collector's Signature:2A Auditor:

Sample Depth

Date:

Sediment Description

V

'

•

.

flR30353l

Samp 1e 10

PAQLI RAIL YARD SAMPLE DATA FORM

_>r ' s Employee # _____ Sampling Date: _/_/__fder's Employee 8 _____ Sampling Time: _____ (0001-2 00)

Region: ____(0, I, II, UJ, IV, VC, LVC) Sampling Depth: ___._ - ___.__ (FT)lap Coordinates: North: _____. Stream Width: ___._

East: _____. Steam Depth: .

}rea: ______ # ___ (YARD, RAILYARD, CARSHQP, NVTRIB, CHTRIB, HTRIB, FILLSEPTANK, DUCKUNDR, DRQPBQX, BERMS, PILES, HIGHUSE)

aubArea: ________ # ___ (FLRGRDN, VEGGRDN, DRAINAGE, RDDRAIN)ledia: # (SURFSOIL, VERTSQIL, SEDIMENT, GW, SURFWATR, AIR,

—————— ——— CEMENT, BENTHIC, FISH)Type: ______ (COMP, GRAB)Method: _______ (SSPOON, WIPE, DREDGE, BAILER, T0<*, CORE,

BORING, ELECTRO,'HAND, TROWEL, 2EROCQN)Morphology: __________ (FLAT, SLOPE, DEPRESS, GULLY, HILLTOP)

Signed Access Letter? (Y/N) Was a split taken? (Y/N)Is this a QA/QC sample? (Y/N)' What kind? (DUP, COLL, RINS, FLD, TRIP)

Sample Observations: . '/. COARSE ____._ •/. FINE .__ '/. ORGANIC MATERIAL

Observations:

Data Entry by: _____ Entry Validation by: ____

SR3Q3532

Section: Appendix FRevision No.: 0Date: May 27, 1988Page: 1 of 6

APPENDIX F

METHOD: Fish, Raltech #896622-896626Received From State College, PA

LIMIT OF DETECTION: 0.05 ppm for Chlorinated Insecticides0.10 ppm for PCB and Toxaphene

STORAGE: All samples stored in a deep freeze prior toanalysis.

PREPARATION: Each composite was ground in a Hobart food grinderuntil homogeneous.

EXTRACTION: Approximately a 25 g sample was weighed into a 150mL beaker and mixed approximately 100 • g ofanhydrous sodium sulfate. The mixture was thentransferred to a Waring blender cup. Anadditional 100 g of sodium sulfate and 125 mL ofpetroleum ether were added to the blender cup andblended at a medium speed for about 2 minutes.The petroleum ether was decanted through a 100 mmpowder funnel plugged with glass wool into a 500mL Erlenmeyer flask. An additional 125 mL ofpetroleum ether was added to the blender cup,blended and decanted. The mixture remaining inthe blender cup was -rinsed with 50 mL of petroleumether and decanted"through the powder funnel. Theresulting solution was concentrated toapproximately 5 mL on a steam bath and then boughtto 25 mL with petroleum ether.

FLORISIL• CLEANUP: A 5 mL aliquot of the extract was placed on

previously standardized Florisil and eluted with150 mL of %5 ethyl ether in petroleum ether.followed by 250 mL of 15% ethyl ether in petroleumether. The resulting elutions were concentratedon a steam bath to approximately 5 mL and broughtto 25mL with petroleum ether. Sample of 10 mLchromatograph for quantification.

Appendix I - RISOP

AR303533

Section: Appendix FRevision No.: 0Date: May 27, 1988Page: 2 of 6

SILICIC ACIDSEPARATION: For further cleanup and separation, a 10 mL

aliquot of the first elution from Florisil wastransferred to a previously standardized SilicarCC-4 column and eluted first with 100 mL ofpetroleum ether, and then by a 300 mL mixture of1% acetonitrile, 19% hexane, and 80% methylenechloride, The fist two elutions were concentratedon a steam bath to approximately 2 mL,and broughtto 10 mL with petroleum ether. The third elutionwas concentrated on a flash evaporate tpapproximately 2 mL and brought to 10 mL withpetroleum ether. Samples of 10 mL of less of eachelution were injected into a gas chromatograph for.quantification.

.DETERMINATION: A 5 mL aliquot of the original extract was

transferred to a tared 2 gram vial. The solventwas removed and the vial was placed in a 40° C ovenfor 24 hours. The vial was removed, desiccated,re-weighed, and the amount of lipid wascalculated.

GAS CHROMATOGRAPHY:

Instrument: Hewlett Packard Model 5710A equipped with alinearized Ni63 detector, automatic injector,and 3352C data -system.

Column #1: For all chlorinated insecticides and PCBexcept chlordane isomers.

Packing: " 1.5% SP-2250/1 .95% SP-2401 and 80/100 meshSupelcoport

Column: 6 ft x 4 mm i.d. glassTemperatures: Column, 208° C

Injector, 250° CDetector, 300° C

Carrier gas: 95% argon, 5% methaneFlow: 35mL/minute of adjusted to give DDE retention

time of approximately 10.0 minutes

Appendix I - RISOP

Section: Appendix F - -Revision No.: 0Date: May 27, 1988Page: 3 of 6

Column #2 : For chlordane isomersPacking: 3% OV-1 on 80/100 mesh SupelcoportTemperatures: Column, 208° C

Injector, 250° CDetector, 300° C

Carrier gas: 95% argon, 5% methaneFlow: 35 ml/minute or adjusted to give DDE

retention time of approximately 10.0 minutes

Column #.2: For chlordane isomersPacking: 3% OV-1 on 80/100 mesh SupelcoportColumn: 6 ft x 4 mm i.d. glassTemperature: Column, 200° C

Injector, 250° CDetector, 300° C

Carrier gas: 95% argon, 5% methane' 33 ml/minute. -

Analysis of Fish for Chlorinated Pesticides andPolychlorinated Biphenyls

1 . Scope

1.1 The chlorinated pesticides and polychlorinatedbiphenyls (FCBs) listed in Table I are extracted fromfish using either method A or B as described below.Method A employs a blender, whereas a Tissumizer or theequivalent is required for Method B. Either procedureresults in an extract tHat can be incorporated directlyinto the approved procedures (1) for pesticides or PCBsas cited in the Federal Register (2).

2 . Special Apparatus and Materials

2.1 Method A Only

2.1.1 Blender, high-speed-Waring Blender,Gourdes , Omni-Mixer, or equivalent.Explosion proof model recommended.Quart container in suitable size forroutine use.

Appendix I - RISOP

AR303535

Section: Appendix FRevision No.: 0Date: May 27, 1988Page: 4 of 6

2.1.2 Buchner funnel - porcelain, 12-cm.

2.1.3 Filter paper - 110 mm sharkskin circles.

2.1.4 Flask, vacuum filtration - 500 ml.

2.2 Method B Only

2.2.1 Tissumizer SDT-182EN (available fromTekmar Company, P.O. Box 37207,Cincinnati, Ohio 45222), or equivalent.

2.2.2 Centrifuge - capable of handling 100 mlcentrifuge tubes.

2.3 Method A & B

2.3.1 Kuderna-Danish concentrator - 500 ml,with 10-ml graduated receiver and 3-ballSnyder column.

2.3.2 Chromatographic column - pyrex, 20 mm IDx approximately 400 mm long, with coarsefritted plate on bottom.

3. Procedures

3.1 Method A

3.1.1 Weigh a .25 to 50g portion of frozen, groundfish and add to a high-speed blender. AddlOOg anhydrous Naz S04 to combine with thewater present and to disintegrate the sample.Alternately, -blend and mix with a spatulauntil the sample and sodium sulfate are wellmixed. Scrape down the sides of the blenderjar and break up the caked material with thespatula. Add 150 ml of hexane and blend athigh speed for 2 minutes.

Appendix I - RISOP

Section: Appendix FRevision No.: 0Date: May 27, 1988Page: 5 of 6

3.1.2 Decant the hexane supernatant through a 12-cmBuchner filter with two sharkskin papers intoa 500-ml suction flask. Scrape down thesides of the blender jar and break up thecaked material with the spatula. Re-extractthe residue in the blender jar with two 100ml portions of hexane, blending 3 minuteseach time. (After one minute of blending,stop the blender, scrape the material fromthe sides of the blender jar, and break upthe caked material between extractions).

3.1.3 Decant the hexane supernatants through theBuchner and combine with the first extract.After one last blending, transfer the residueform the blender jar to the Bucher, rinsing-the blender -jar and material in the Buchnerwith three 25 to 50 ml portions of hexane.Immediately after the last rinse, press theresidue in the Buchner with the bottom of aclean breaker to force out the remaininghexane.

3.1.4 Pour the combined extracts and rinses througha column of anhydrous Na2S04 20 mm x 100 mm,and collect the eluate in a 500 ml Kuderna-Danish concentrator. Wash the flask and thenthe column with small portions of hexane andconcentrate the extract below 10 ml.

3.2 Method B

3.2.1 Weigh 20.Og of frozen, ground fish and add toa 100-ml centrifuge tube. Add 20 ml ofhexane and insert the Tissumizer into thesample. Turn on the Tissumizer and dispersethe fish in the solvent for 1 minute.Centrifuge and decant the solvent through acolumn of anhydrous Na2 S04 20 mm x 100 mm,and collect the eluate in a 500ml Kuderna-Danish concentrator.

Appendix I - RISOP

AR303537

Section: Appendix FRevision No.: 0Date: May 27, 1988Page: 6 of 6

3.2.2 Repeat the dispersion twice using a 20 mlaliquot each time, combining all driedportions of solvent in the concentrator.Rinse the Tissumizer and the column withsmall portions of hexane and concentrate theextract below 10 ml.

3.3 Cleanup and Analysis

3.3.1 Unless prior experience would indicate thefish species fat content is low (less than 3gper extract), the hexane/acetonitrile cleanupprocedures describe in the reference methodsshould be followed. In all cases, Florisilcolumn chromatography should be used to cleanup , the extracts before gas chromatography

— - • • • - - (1)-' "An electron capture detector is usedfor final measurement, and results arecalculated in ug/kg. Identifications can beconfirmed by GC/MS techniques as described inAppendix II of the Federal Register.

3.4 Quality Control

3.4.1 Standard quality assurance protocols shouldbe employed, including blanks, duplicates,and dosed samples as described in the"Analytical Quality Control Handbook".

3.4.2 Dose fish sample aliquots by injectingminimum amounts (< 20 ul total) ofconcentrated [pesticide or PCS solutions intothe solid sub-sample 10 to 15 minutes beforeextraction]. "

4. Reporting of Data

4.1 Report results in ug/kg on a wet tissue basis.Report all quality control data with theanalytical results for the samples.

Appendix I - RISOP

303538

APPENDIX II

REVISED HEALTH AND SAFETY PLAN

4R303539

ADDENDUM TO APPENDIX II

GROUNDWATER TECHNOLOGY, INC.

REVISED SITE SAFETY PLAN

TO CONDUCT THE RISOP

Prepared For:

Paoli Rail YardPaoli, Pennsylvania

Prepared By:

Groundwater Technology, Inc.Mid-Atlantic Region

Concord Building, Chadds Ford WestChadds Ford, Pennsylvania 19317

AR3035i*0

1. GENERAL INFORMATION

Site Safety Plan: Paoli Rail Yard, Paoli, Pennsylvania

Plan prepared by: Groundwater Technology, Inc.

Approved by:Frank AcetoDistrict Manager/Overall Project ManagerGroundwater Technology, Inc.

Cathy CoilinsSite ManagerGroundwater Technology, Inc.

Lieschen Fish \7Regional Safety DirectorGroundwater Technology, Inc.

Objective: Provide site safety planning for all GroundwaterTechnology, Inc. (GTI) personnel to performassociated work on this site.

Proposed Dates of Investigation: Summer 1988 through Summer 1989

Overall Hazard: Low to Moderate

Level of Protection: Level D to Modified Level C

Appendix II - 1

APPENDIX II

TABLE OF CONTENTS

Page

1. GENERAL INFORMATION II-1

2. INTRODUCTION II-22.1 Regulatory Requirements II-22.2 Intentions of the Site Safety Plan II-3

3. SITE INFORMATION II-53.1 General _ II-53.2 Physical Characteristics II-53.3 Nature of Field Activity II-53.4 Complying with Rail Road Safety Requirements II-6

4. . DESCRIPTION OF CHEMICAL HAZARDS II-7TABLE OF CHEMICAL INFORMATION ' II-9

5. SPECIFIC SITE SAFETY PROCEDURES 11-105.1 Site Control Procedures ' 11-105.2 Levels of Personal Protective Equipment (PPE) 11-10

5.2.1 Level A 11-105.2.2 Level B 11-115.2.3 Level C 11-125.2.4 Level D • 11-12

5.3 Safety Decision - Making 11-135.3.1 Site-entry/initial Protection 11-135.3.2 Working Level of Protection 11-135.3.3 Up-grading/Down-grading Protection Levels 11-145.3.4 Adjustments To Site Safety Plan 11-14

6. SPECIFIC WORK TASK SAFETY 11-176.1 Excavation/Trenching 11-176.2 Drilling II-176.3 Miscellaneous Safety Procedures 11-186.4 Meteorological Conditions 11-19

6.4.1 Heat Stress Prevention 11-196.4.2 Cold Stress Prevention 11-20

6.5 Fire Prevention 11-206.6 Electrical Equipment 11-206.7 Dust Control 11-20

7. SITE DECONTAMINATION PROCEDURES 11-21

8. EMERGENCY FACILITIES/TELEPHONE NUMBERS 11-23

9. SITE SAFETY PERSONNEL RESPONSIBILITIES 11-24

AR3035HZ

2. INTRODUCTION

2.1 Regulatory Requirements

The Site Safety Planning process is an integral function ofall treatment 'and disposal of hazardous wastes under theComprehensive Environmental Response, Compensation and LiabilityAct of 1980 (CERCLA) and the Resource Conservation and RecoveryAct (RCRA) . The risk of exposure and need for protectingemployees exposed to potentially hazardous wastes is addressed inthe "Superfund Amendments and Reauthorization Act (SARA) of 1986"(Vol. 52 Fed. Reg. 29261). The Occupational Safety and HealthAdministration (OSHA) requires that hazardous waste sitepersonnel work in safe conditions under the Hazardous WasteOperations and Emergency Response regulations (29 CFR 1910.120).Employees performing clean-up operations under CERCLA, RCRA(corrective actions) and state and local government designatedsites - generally those employees likely to have the highestexposures to hazardous substances over a longer period - would becovered by all provisions of this proposal (Vol. 52 Fed. Reg.29623) .

The employer's safety and health program must provide anorganizational structure, a comprehensive workplan, and a site-specific safety and health plan. The plan must specificallyaddress each work activity and operation, and the anticipatedsafety and health hazards associated with each operation andactivity [29 CFR 1926.20(b)(1)(ii) through (b)(l)(iv)].

Groundwater Technology, Inc.'s (GTI) field personnel arerequired to participate in an on-going health monitoring program.This program consists of a baseline medical exam in conjunctionwith annual examinations to update each employee's medicalhistory. This allows for determination of any physical healtheffects possibly caused by exposure to hazardous contaminants

Appendix II - 2

during, site work and' also defines any intolerances an employeemight have toward wearing any necessary personal protectiveequipment.

2.2 Intentions of the Site Safety Plan

GTI's Site Safety Plan is designed to ensure that employeesare aware of potential hazards which may be encountered duringthe Remedial Investigation and Feasibility Study (RI/FS) at thePaoli Rail Yard. The Plan is intended to address all concernsfor health, safety, and regulatory compliance related to theservices Groundwater Technology, Inc. is providing; and is meantto complement all existing elements of the rail yard's safetyprogram which is included in the RISOP.

Groundwater Technology, Inc. reco gnizes that the potentialexists for exposure to PCBs during site investigation, treatment,storage, and disposal operations. The degree of potentialexposure varies and is primarily dependent upon the type ofinvestigation to be performed and extent of compounds in eachwork area.

The Site Safety Plan establishes policies and procedures toprotect both workers and the public from potential hazardsduring routine activities and emergencies, should they occurwhile the project is in progress. This Plan shall be madeavailable to all Groundwater Technology, Inc. field personnel andany subcontractors working on-site, and will be revised as newinformation is obtained.

All Groundwater Technology, Inc. field personnel will berequired to read this Site Safety Plan and sign the PersonnelCertifications and Acknowledgements to certify that they haveread and understood the Plan. Only those personnel who have

Appendix II - 3

&R3G35UU

signed the Personnel Certifications and Acknowledgements will bepermitted to enter the site and begin work. The Site SafetyOfficer will review this Plan with site workers during periodicsafety meetings, review current site conditions, answer anyquestions, and discuss any short term alterations to the Plan ifnecessary.

.Appendix II - 4

3. SITE INFORMATION

3.1 General

Site Name: Paoli Rail YardSite Owner; National Railroad Passenger Corp.

(202) 383-2750Contact Person: Marty Brunges (SEPTA) (215) 296-2101Site Location: PA Route 30 West, Paoli, PA (Chester County)Type of Business: Commuter Rail Transportation, Rail Car

Repair

3.2 Physical Characteristics

Land Use: Commercial and residential.

Topography: Alternating wooded and open areas, varying hillsand flat areas.

Area of Construction Activity: Approximately 400 acres.

Location of Utilities: The location of all utilities willbe determined prior to initiating all fieldwork. Utilities will be marked by followingutility clearance procedures outlined in theFOP.

3.3 Nature of Field Activity

GTI is conducting a RI/FS at the Paoli Rail Yard inaccordance with the Third Partial Preliminary Consent Decreebetween the EPA, PADER, and the rail companies. The remedialinvestigation is fully discussed in the Second Revised Work Planand should be read in conjunction with the Health and SafetyPlan..

Appendix II - 5

3.4 Complying With Rail Road Safety Requirements

Before GTI personnel and subcontractors are permitted onrail yard property, everyone must complete a four-hour AMTRAKSafety Training program. Regulatory personnel and theirrepresentatives must also complete this training to enter on therail property. The program discusses the inherent risks anddangers associated with working on an active rail road facility.Upon the completion of the safety training program, eachparticipant will receive an emblem that will be affixed to theindividual's hard hat to be worn during on-site constructionactivities.

Furthermore, every individual working on-site must readthrough the AMTRAK and SEPTA Safety Procedures that are attachedto the end of the Site Safety Plan in the RISOP.

With EPA's approval, SEPTA is currently implementing theWorker Protection Stipulation, which outlines a number ofactivities that were completed in and around the car shop. Ofimportance to the remedial investigation being conducted in thecar shop is the Stipulation requiring the maintenance of a"clean" area and compliance with safety equipment use. On areasdefined on-site as work-side areas, tyvek lab coats and bootieswill be worn. Samplers will also wear latex gloves as discussedin Section 5.3.2.

Appendix II - 6

4. DESCRIPTION OF POTENTIAL CHEMICAL HAZARDS

The chemical compounds previously measured or anticipated inthe soils (PCBs) are set forth on the following table of chemicalinformation along with the highest levels reported and thestandards that have been established and/or recommended byvarious agencies. The table includes the permissible exposurelevels (PELs) established in the regulations of the U.S.Department of Labor Occupational Safety and Health (NIOSH) andthe American Conference of Governmental Industrial Hygienists(ACGIH). The OSHA PELs are the only standards that areenforceable regulatory requirements. The NIOSH recommended.levels are. more stringent than the OSHA standards but they arenot enforceable requirements. The ACGIH threshold limit values(TLVs) are identical to the OSHA PELs but like the NIOSHrecommended standards, they are not enforceable requirements. 'Inthe Federal Register for June 9, 1988, OSHA stated that it doesnot intend to change the PCB limits specified in the OSHA PELsbecause they are identical to the 1987-88 ACGIH TLVs for PCBs. ,

The data listed in this section is used to selectrespiratory and/or dermal protection for all site workers. Thisinformation will be updated and the Site Safety Plan adjustedaccordingly by addenda.

The selection of personal protective equipment for workerson-site is based upon the potential for respirable concentrationsof PCBs in air, and for dermal exposure. PCBs are relativelylarge-sized molecules and, although considered potentiallyhazardous to humans when breathed in vapor form, this chemicalhas been found mainly adsorbed to the soils at this site.Therefore, the most potentially dangerous exposure will be fromrespiration of particulates (dust) during operations where PCB-adsorb.ed soils are disturbed. Any work associated with the soilsin the investigation area should be monitored particularly

• Appendix II - 7

closely. Dust control, if needed, will minimize the potentialfor air entrainment of particulates. Workers will be aware ofthe possible hazards of dermal contact with PCBs. Appropriateprotective clothing will be worn to minimize contact withpotentially affected soils. Anyone that has come in contact withsoils will be instructed to immediately wash skin with soap andwater.

Appendix II - 8

AR3035i*9

H£W33U

ca

3R303550

5. SPECIFIC SITE SAFETY PROCEDURES

5.1 Site Control Procedures

Entry into the work site areas shall be permitted only byauthorized and trained work personnel. Each morning during thefield work, GTI personnel and subcontractors will meet at the GTIfield office, sign the log-in-book, and be required to don theappropriate, personal protective equipment before being allowedon-site. The Site Safety Officer shall be watchful to ensurethat this precaution is enforced. The appropriate rail yard andregulatory personnel shall be notified of all planned workoperations and locations.

5.2 Levels of Personal Protective Equipment fPPE)

There are four levels of personal protective equipment (PPE)as determined by federal safety regulations.

5.2.1 Level A

Level A is the highest level of both respiratory and dermalprotection, generally requiring a supplied-air respirator and afully-encapsulating suit. The following equipment is used toprovide Level A protection:

o Supplied-air respirator approved by the MineSafety and Health Administration (MSHA) andNational Institute for Occupational Safety andHealth (NIOSH). Respirators may be pressure-demand, self-contained breathing apparatus (SCBA)or pressure-demand, airline respirator (withescape bottle for Immediately Dangerous to Lifeand Health (IDLH) or potential for IDLH

Appendix II - 10

AR30355I

atmosphere).

o Fully encapsulating chemical-resistant suit,

o Coveralls (optional),

o Long cotton underwear (optional),

o Gloves (inner), chemical-resistant,

o Boots, chemical-resistant, steel toe and shank(depending on suit construction, worn over orunder suit boot),

o Hard hat,

o Disposable gloves and boot covers (worn over fullyencapsulating suit),

o Cooling unit (optional).

5.2.2 Level B

This level of PPE has the same respiratory protection asLevel A, but a slightly lesser degree of dermal protection. Thefollowing equipment is used to provide Level B protection:

o Supplied-air respirator (MSHA/NIOSH approved)pressure-demand, self-contained breathingapparatus, pressure-demand airline respirator(with escape bottle for IDLH or potential for IDLHatmosphere).

o Chemical-resistant clothing (overalls and long-sleeved jacket; hooded, one or two-piece chemical-splash suit; disposable chemical-resistant, onepiece suits),

o Long cotton underwear (optional),

o Coveralls (optional),

o . Gloves (outer), chemical-resistant,

o Gloves (inner), chemical-resistant,

o Boots (outer), chemical-resistant, steel toe andshank,

Appendix 11-11

Disposable boot covers (outer) ,' chemical-resistant(optional),

Hard hat.

5.2.3 Level C

Level C protection requires the same degree of dermalprotection as Level B, with a lesser degree of respiratoryprotection. The following equipment is used to provideLevel C protection:

o Air-purifying respirator, full-face, canister-equipped (MSHA/NIOSH approved),

o Chemical-resistant clothing (coveralls; hooded,one-piece or two piece chemical splash suit;chemical-resistant hood and apron; disposablechemical-resistant coveralls),

o Coveralls (optional),

o Long cotton underwear (optional),

o Gloves (outer), chemical-resistant,

o Gloves (inner), chemical-resistant (optional),

o Boot (outer), chemical-resistant, steel toe and shank,

o Disposable boot covers (outer), chemical-resistant(optional),

o Hard hat,

o Escape mask (optional).

5.2.4 Level D

Level D basically does not require any dermal or respiratoryprotection other than a normal work uniform. The followingequipment is used to provide Level D protection:

Appendix II - 12

3R303553

o Coveralls,

o Gloves (optional),

o Boots/shoes, leather or chemical-resistant, steeltoe and shank,

o Safety glasses or chemical splash goggles (optional),

o Hard hat.

5.3 Safety Decision-Making

5.3.1 Site-Entry/Initial Protection

Level D protective equipment is sufficient for site entry ofpersonnel.

5.3.2 Working Level of Protection

The actual level of protection that will be worn during thesampling activities is dependent upon the particular task that isbeing performed.

During the well installation and soil boring completion,0

modified Level C protection will be required. Personnel withinthe drilling areas will be required to wear Tyvek suits, orequivalent, Neoprene boots or disposable boots, and chemical-resistant gloves to provide dermal protection. Either a full-face respirator, or half-face respirator with safety glasses willbe worn if visibly dusty conditions arise. High efficiencycartridges will be used. A hard hat will be worn. Personnelworking on-site must wear orange safety vests.

Appendix II - 13

Personnel conducting the remainder of the investigationsampling will wear Level D protection. Latex gloves will beworn if the samplers come in contact with soil, water, or biotasamples. Hip waders will be worn by personnel wading in thestreams. Tyvek lab coats and booties will be worn by personnelwithin the work-side of the rail yard as outlined by the WorkerProtection Stipulation.

5.3.3 Up-grading/Down-grading Protection Levels

During all work performed on-site a task-by-task analysismust be performed by the Site Safety Officer to determine on-going and changing risks associated with the airborne compoundspossibly encountered.

Once the initial site entry evaluation has been performed,decisions may be made as to whether up-grading, down-grading ormaintaining the level of PPE is warranted. This decision will bemade on a case-by-case, location-to-location basis, according tothe Site Safety Officer.

5.3.4 Adjustments to Site Safety Plan

All decisions made shall be documented daily and added tothe Site Safety Plan as information is gathered.

Below is the set of procedures that will be followed whensite conditions encountered during work operations are differentthan those expected and accounted for in the Site Safety Plan.Examples of situations that may occur are the need to stop on-site work due to potentially hazardous conditions and the need tochange the necessary level of protection for on-site personnel.

Appendix II - 14

1. 'STOP WORK' ORDER

Site Safety Officer (SSO)

o Constantly assesses site conditions. If siteconditions are perceived as a threat to the healthand safety of field personnel, has the authorityto immediately stop on-site work.

o Notifies Regional Safety Director as soon asfeasible of a 'stop work1 order.

Regional Safety Director (RSD)

o Notifies1 the GT Project Manager, the NationalHealth and Safety Program Manager, and/or theIndustrial Hygienist of a 'stop work' order.

National Health and Safety Program Manager (NHSPM), and/orIndustrial Hygienist (IH) with the RSD

o Evaluate the conditions that prompted the stopwork order.

o Establish the actions necessary to take prior tostarting work again.

o Institute an action plan to prevent a similarsituation occurring again, if possible.

LEVEL OF PROTECTION UPGRADE

SSO

o Assessment of site conditions to ensure thatthe site conditions meet one or more of theconditions stated in the Level of ProtectionUpgrade Protocol.

o Stops on-site work if the necessary personalprotective equipment is not available.

Appendix II - 15

1R3.03S56

o If necessary personal protective equipment isreadily available, ensures that all fieldpersonnel conducting the remainder of theinvestigation don the necessary PPEimmediately.

o Notifies the Regional Safety Director of the Levelof Protection Upgrade.

RSD

o Notifies the NHSPM and/or IH.

NHSPM/IH

o Verifies the need to upgrade the Level ofProtection.

3. LEVEL OF PROTECTION DOWNGRADE

SSO

o Assessment of site conditions to ensure that siteconditions meet the standards stated in the Levelof Protection Downgrade Protocol.

o Notifies the RSD before taking any action todowngrade.

RSD

o Consults with the NHSPM and/or IH.

o Notifies the SSO of the final decision.

NHSPM/IH

o Verifies the need to downgrade the level ofprotection.

•

6. SPECIFIC WORK TASK SAFETY

6.l Excavation/Trenching

o All excavation and trenching work must complywith all safety regulatory agency rules.Prior to any excavation work the existenceand location of underground piping,electrical conductors, etc. must bedetermined.

o Daily inspections of excavations shall bemade. If there is evidence of possible cave-ins or slides, all work in the excavationshall cease until the necessary safeguardshave been taken.

o All equipment such as pipe, tools, etc. shallbe kept out of traffic lanes and access ways.Equipment shall be stored to prevent dangerto personnel at any time.

o All trenches shall be backfilled as soon aspractical after work is completed and allassociated equipment removed.

o All ladders and hoisting equipment used mustbe OSHA-approved.

6.2 Drilling

o During drilling operations two (2) personsdesignated as "driller" and "helper" must bepresent on the rig at all times.

o All workers shall remain upwind of theborehole as best possible.

o Only personnel authorized by GroundwaterTechnology Inc. are to be allowed within thearea of drilling. If any unauthorizedpersonnel enter the work area, GroundwaterTechnology, Inc. will shut down operationsuntil the area is cleared.

"Appendix II - 17

AR3G3558

o All workers in the vicinity o'f the drillingshall wear dust/mist masks and otherappropriate personal protective equipmment ifdusty conditions are encountered.

o The mast of the drilling rig must maintain aminimum clearance of 15 feet from anyoverhead electrical cables.

o All drilling operations will ceaseimmediately during any electrical storms.

o Groundwater Technology, Inc. has theauthority to shut down the drillingoperations any time a hazardous situation isdeemed present.

6.3 • Miscellaneous Safety Procedures

All workers should be aware of and stay clear of forkliftsand transportation vehicles on-site.

The work areas will be maintained clear of constructionmaterial and debris so as not to restrict operations or createhazardous conditions.

Unnecessary contact with suspected contaminated surfacesshould be avoided. Whenever possible, workers should positionthemselves upwind, and should avoid walking through puddles, mud,and other discolored substances; kneeling on ground; and leaning,or sitting on equipment, containers, or the ground.

All workers shall abide by the rail yard's designated safetyprotocol as set forth in SEPTA'S required safety orientation andin the initial on-site training program conducted by GTI. Nosmoking shall be permitted on-site during work operations.Eating, drinking, or smoking is allowed only in locationsdesignated by GTI/SEPTA personnel, during authorized lunchperiods and work breaks.

Appendix II - 18

SR303559

6.4 Meteorological Conditions

Adverse climate conditions, cold and hot, are importantconsiderations in planning and conducting site operations. Theeffects of ambient meteorological conditions on personnel cancause physical discomfort, loss of efficiency, personal injuryand increase accident probability.

6.4.1 Heat Stress

Heat stress, due to protective clothing decreasing bodyventilation, is an important factor. The followingrecommendations will help reduce heat stress. Theirapplicability is dependent on evaluating the conditionsparticular to a specific project.

Plenty of liquids must be provided to replace loss of bodyfluids. Employees should replace water loss with adequate intakeof like fluids such as water, juice, etc. These provisions mustbe made outside of the work area.

A work schedule must be established that will providesufficient rest periods for cooling down. As the temperatureincreases, more frequent and longer rest periods are required.

Heat stress symptoms should be monitored for all levels ofprotection.

6.4.2 Cold Stress Prevention

Cold stress symptoms will be monitored for all levels ofprotection.

Appendix II - 19

RR3G3560

6.5 Fire Prevention

Approved safety cans will be used to transport and storeflammable liquids.

All gasoline and diesel-driven engines requiring refuelingmust be shut down and allowed to cool before filling.

Smoking is not allowed during any operations in closeproximity to flammable liquids. Smoking is allowed only inlocations designated, and during authorized lunch periods andwork breaks.

No open flame or spark is allowed in any area containingpetroleum products, or other flammable liquids. In case o'f fire,do not extinguish. Call the fire department as designated in thelist of emergency telephone numbers.

6.6 Electrical Equipment

All electrical equipment used on-site must be equipped withthree wire-grounded leads.

6.7 Dust Control

Dust control shall be provided by GTI, as necessary.

Appendix 11-20

4R30356

7. SITE DECONTAMINATION PROCEDURES

At each work location reusable sampling equipment andpersonal protective equipment will be decontaminated prior toreuse in different activity areas. Equipment will bedecontaminated by steam cleaning or washing with water thenallowed to air dry on a clean plastic tarp. Disposable personalprotective equipment will be placed in plastic bags andtemporarily stored in designated drums in the decontaminationareas. These drums will be disposed of according to EPAguidelines, if necessary.

Following proper decontamination procedures (decon) is asimportant as donning the appropriate safety gear. If properdecon is not done, many of the protective measures taken whileworking on-site can be for naught. So, all workers on-site mustalways be conscious of the different ways they can be exposed tothe potentially hazardous material.

Drums will be set up near the decon station to be used fortemporary storage of disposable safety equipment. All gloves,boots, tyvek coveralls, and used respirator cartridges will beplaced in one drum. A hose can be used to clean the respiratorsand other equipment over the decontamination sink.

The sequence of steps for removing personal protectiveequipment is as follows:

o Wash outer boots, if non-disposable.

o Remove boots and outer Tyvek coveralls.Place boots in storage area, if non-disposable.

o Package and dispose of boots and outer Tyveksuits, if disposable.

o Remove respirator or mask, if used.Appendix 11-21

Wash respirator.

Package and/or dispose of respirator orfilters.

Place all disposable items in properlylabeled drums.

If necessary, copy notes from paper ontoclean paper while wearing inner gloves(surgical gloves) or other chemical-resistant gloves at decon station area.

Remove gloves.

Dispose of gloves and note paper.

Wash hands and face.

Appendix 11-22

*R303563

8. EMERGENCY FACILITIES/TELEPHONE NUMBERS

Location of nearest non-pay telephone: on-site inside GTItrailer adjacent to main gate (215) 640-2366.

Location of nearest pay telephone: inside cafeteria at carshop - main building on-site.

Ambulance Service: (215) 644-1224

Nearest Hospital: Paoli Memorial HospitalTelephone No. (215) 648-1000Directions: Turn left out of main gate at Rail Yardonto Central Avenue, follow to Route 30, turn right:hospital driveway is first right.

Back-up Hospital: Chester County HospitalTelephone No. (215) 431-soooDirections: Route 30 West to Route 29 North to Route202 South to West Chester (701 E. Marshall Street).

Police Department: (215) 647-1440

Fire Department: (215) 644-1224

Poison Control Center: (800) 492-8016(215) 648-1043

GTI Regional Health and Safety Director: (215) 388-1466Lieschen Fish, Chadds Ford, PA

Toxicologist Advisor: Dr. Frank LawrenceEnvirologic Data, Portland, ME (207) 773-3020.

PADER - 3rd and Locust Streets, Harrisburg, PA (215) 565-1687

Regional EPA Office: 841 Chestnut Street, Phila., PA (215)597-3169

Appendix 11-23

1R30356/4

9. SITE SAFETY PERSONNEL RESPONSIBILITIES

The responsibilities of all personnel involved in health andsafety operations are stated below:

NAME/TITLE____________________SAFETY RESPONSIBILITIES_________

Scott Keating o Monitors on-site hazards andSite Safety Officer/ conditionsTeam Leader/(recordkeeper)

o Enforces Site Safety Plan

o Periodically inspects andensures proper maintenance ofsafety equipment

o Knows emergency procedures andevacuation routes

o Notifies, when necessary,local public emergencyofficials

o Enforces safety procedures

o Dismisses personnel who, byunsafe action, endangerthemselves, co-workers, or thepublic

o Documents and coordinatesfield activities and samplecollection

o Manages field operations

o Notifies Regional SafetyDirector of unsafe workingconditions

o Stops work on-site ifconditions threaten the healthand safety of field personnel

Appendix 11-24

flR3Q3565

o Provides liaison withconsulting scientific advisors

o Oversees budget and selectionof air monitoring and personalprotective equipment

o Assesses site conditions on aperiodic basis to ensure thefeasibility and suitability ofthe Site Safety Plan

o Reports to the IndustrialHygienist and/or Health andSafety Program Manager aftereach site visit

o Responsible for upgrading anddowngrading the level ofpersonal protection duringwork activities in conjunctionwith the Site Safety Officerand the National Health andSafety Program Manager and/orthe Industrial Hygienist

o Monitors the compliance anddocumentation activities ofthe Site Safety Officer andother project personnel

o Approves all field personnelworking on the site, takinginto consideration their levelof safety training, theirhealth, and their ability tosafely wear the protectiveequipment necessary for theassigned tasks

Team Worker(s) . o Complies with Site Safety Plan

o Safely performs assigned worktasks

o Notifies Team Leader or SiteSafety Officer of unsafeworking conditions

Appendix 11-25

Pam Rugen/Toxicologist andLori St. Pierre/Industrial Hygienist o Serves as health and safety

consultant to the RegionalSafety Director and otherproject personnel as needarises

o Assesses site conditions on aperiodic basis to ensurefeasibility and suitability ofthe Site Safety Plan

o Prepares task specificaddendums to the original SiteSafety Plan

o Oversees all health and safetyactivities in conjunction withthe Regional Safety Director

Marilyn Grant/National Health andSafety' Program Manager o Serves as consultant to the

Regional Safety Director

o Oversees the activities of theRegional Safety DirectorIndustrial Hygienist, andToxicologist

o Services as liaison betweenRegional Safety Director,Industrial Hygienist,Toxicologist, and otherproject personnel as the needarises

Cathy CollinsSite Manager o Provides liaison between

GTI/SEPTA and regulatorypersonnel

o Informs Regional SafetyDirector and/or IndustrialHygienist and Toxicologist ofany modifications to ongoingwork activities

Appendix II - 26

Informs Regional SafetyDirector and/or IndustrialHygienist and Toxicologist ofnew job tasks before they areto take place.

Assists Team Leader with hisresponsibilities as needed

Frank Aceto/District Manager o Overall responsibility forWilliam Smith/ ensuring that the proceduresRegional Manager stated in the Site Safety Plan

and the Work Plans arefollowed

Appendix 11-27

SR3Q3568

ATTACHMENT A

SEPTA & AMTRAK Safety Guidelines for work on-site

NOTE: All contracted employees are also required toattend four two hour AMTRAK contracted safetytraining courses.

Appendix 11-28

3R303569

ATTACHMENT B

Due to the complexity of the project, the site has beendivided into five different sampling levels.

See Attachment and Figure 3-1

Appendix 11-29

JR303570

ATTACHMENT C

The location of all utilities has not determined at thispoint, since all our work has been on-site. Map #2 contains infoon utility locations, but they have not been verified bySEPTA/AMTRAK personnel in the field. Verification of allutilities were occur prior to all on-site field work this summer(1988).

Please note that there is an extensive system of electricalwires above each track, and there is also an electrical sub-station on-site.

Map #2 Attached

Appendix 11-30

SR30357I

SITE SAFETY PLAN:

PERSONNEL CERTIFICATIONS AND ACKNOWLEDGEMENT

All project personnel are required to make the followingcertification prior to conducting work at the Paoli Rail Yard, inPaoli, Pennsylvania.

certify that:

1. I have, read and fully understand the Health and Safety Plan•and my individual responsibilities.

2. I agree to abide by the health and safety provisions in thisplan.

Signature

Date

Appendix 11-31

APPENDIX Ilia

GTI LETTER TO AGENCIES REGARDING PROJECT SCHEDULE

GROUNDWATERTECHNOLOGY, INC.

August 4, 1988

Christopher B. PillaU.S.. Environmental Protection Agency, Region III841 Chestnut BuildingPhiladelphia, PA 19107

Express Mail

Dear Chris:

Thank you for your immediate attention to the issuesdiscussed at our 26 July 1988 meeting in Chadds Ford regardingrevisions to the 27 May 1988 Remedial Investigation SiteOperations Plan (RISOP) for the Remedial Investigation/Feasibility Study (RI/FS) at the Paoli Rail Yard, Paoli, PA. Atthat meeting, technical and procedural issues were discussed, andthrough the cooperative efforts over the last week, these issueshave been resolved. This letter confirms our agreement of theRI/FS schedule.

At our 26 July 1988 meeting, the RI/FS schedule wasdiscussed and several alternatives were proposed forconsideration to expedite the RI/FS process. The originalschedule, as submitted, outlines a 38-month RI/FS schedule. Weare currently prepared to agree to eliminate the iterative reviewcycle between the draft and final RI/EA, and FS reports. Thiswill expedite the overall schedule'by 7 months (approximately 210days). Additionally, because the Agencies' have committed tocomplete their review of each of the RI/EA and FS reports withina 45-day period instead of 60 days, a total of one month overallschedule reduction will occur. Taking into account theseschedule reductions, a 30-month RI/FS schedule will result. Itshould be noted that this schedule is projected from carefulreview of various work tasks as outlined in detail in the 27 May1988 RISOP. All RI/FS schedule projections are contingent onboth meeting the proposed work schedule, and receiving agencyreviews within the established review time projections.

Further schedule reduction topics were discussed at our 26July 1988 meeting and during subsequent telephone conversations.These topics focused on expediting laboratory turn-around andadjusting the engineering schedule of the FS. At this time,we cannot agree to. either of these options as schedule reductionitems.

f >//«v.v lltnmylHtttt the i '..s'.. CiiiutiUi ui

Christopher B. PillaPage Two4 August 1988

As you are aware, the RI/FS process being planned at therail yard and. adjacent community is a significant undertaking.Based upon the Agencies' approval of the Second Revised Work Plansubmitted 15 March 1988, the work tasks outlined represent abroad based investigative and reporting program, the findings ofwhich will have significant impact on evaluating the rail yardand surrounding community. We share your concerns for completingthe RI/FS as soon as possible, but feel the engineeringpreparation, analysis, and review times allotted in this scheduleare necessary and appropriate for what the RI/FS at the PaoliRail Yard is designed and required to achieve. As such, we areprepared to implement the RI/FS program over the projected 30-month time frame which we have discussed. The revised RISOPwill contain such a schedule.

We trust that the revised RISOP including the abovereferenced schedule will be acceptable to the Agencies'.

Please call should you have any questions or comments.

Sincerely,GROUNDWATER TECHNOLOGY, INC.

Frank AcetoDistrict ManagerSenior Hydrogeologist

cc: M. Bobek (PADER)B. StonelakeR. SiskindM. BurackC. CurryD. MooreM. BrungesL. LaCorteE. CiprianiJ. KilcurProject File

FA/kc:8-4-A