'•t l; .) 14.07 Superfund Chemical Division January 24, 1991 Mr. James E. McGuire Remedial Project Manager USEPA Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 Re: EPA Region IV review comments dated 19 December 1990 Final Workplans - Cold Creek Swamp Operable Unit Supplemental RI/FS Dear Mr. McGuire: The following final responses to comments the Final Project Plans are provided to US response to review comments submitted by E dated 19 December 1990. The attached resp revision pages (Attachment B) address all v;ill be considered as an addendum to the f the review comments do not significantly a final v.'ork plans previously submitted, add final plans will not be submitted. The re and attached revision pages will become pa Record and will be considered as an addend plans. and revision pages to EPA Region IV in PA to Akzo Chemicals onses (Attachment A) and EPA review comments and inal work plans. Since ffect the text of the itional copies of the sponses defined herein rt of the Administrative um to the final work Please note that criteria for determination of contaminants of concern is included in revised pages 4-16a through 4-17. The criteria are in accordance v/ith agreements reached during your 11 January 1991 telephone conversation with EA Engineering, Science, and Technology. In addition, please note that a revised Table 7-1 is provided to reflect schedule changes reguired based upon the methodology for determination of contaminants of concern. As agreed with EA Engineering, Science, and Technology, the scheduled project completion date is 21 October 1992. 10785291
Transcript
'•t l; .)
14.07 Superfund Chemical Division
January 24, 1991
Mr. James E. McGuire Remedial Project Manager USEPA Region IV 345 Courtland Street, N.E. Atlanta, GA 30365
Re: EPA Region IV review comments dated 19 December 1990 Final Workplans - Cold Creek Swamp Operable Unit Supplemental RI/FS
Dear Mr. McGuire:
The following final responses to comments the Final Project Plans are provided to US response to review comments submitted by E dated 19 December 1990. The attached resp revision pages (Attachment B) address all v;ill be considered as an addendum to the f the review comments do not significantly a final v.'ork plans previously submitted, add final plans will not be submitted. The re and attached revision pages will become pa Record and will be considered as an addend plans.
and revision pages to EPA Region IV in PA to Akzo Chemicals onses (Attachment A) and EPA review comments and inal work plans. Since ffect the text of the itional copies of the sponses defined herein rt of the Administrative um to the final work
Please note that criteria for determination of contaminants of concern is included in revised pages 4-16a through 4-17. The criteria are in accordance v/ith agreements reached during your 11 January 1991 telephone conversation with EA Engineering, Science, and Technology.
In addition, please note that a revised Table 7-1 is provided to reflect schedule changes reguired based upon the methodology for determination of contaminants of concern. As agreed with EA Engineering, Science, and Technology, the scheduled project completion date is 21 October 1992.
10785291
.) ' i
Mr. James E. McGuire January 24, 1991 Page 2
Akzo has been advised that EA intends to mobilize onsite by 4 February 1991.
Very truly yours,
^Y
Y^Y^' : ' -'̂ / t . ^ . '^ 3 . / - ^ ^ .J . ^ -T
Mariam R. Tehrani Manager, Environmental Affairs
MRT/lh Attachments
cc: L. Erickson, ICIA J. Johnson, TSL&A M. Tietze, ICIA J. Zarzycki, EA Engr.
ATTACHMENT A
RESPONSES TO COMMENTS
4
Responses to Comments
I. GENERAL COMMENT
It is understood that the RCRA "contained in" policy will apply to project activities at this site. It is further understood that the only impact to proposed RI data collection activities for this project will be that drill cuttings must be characterized through TCLP prior to offsite disposal or replacement onsite. If cuttings are found to be RCRA characteristic waste, they will be disposed of in accordance with provisions of 40 CFR 261-264.
The "contained in" policy applies to media which are contaminated with a listed hazardous waste. .Accordingly, media which are excavated or otherwise managed during workplan implementation which do not contain a listed waste and which do not exhibit a hazardous waste characteristic are not subject to management as a RCRA hazardous waste.
II. SPECIFIC COMMENTS
A. Workplan/SAP
1. Comment: "Page 4-6, Para 4 - Table 4-3 does not.."
Response: The text reference to inclusion of current Water Quality Criteria (WQC) values in Table 4-3 will be deleted. WQC values will be the probable surface water ARARs as indicated in the text. The actual numerical values will be based upon criteria for fresh water aquatic exposure and will be the most current WQC values at the time that RI data assessment is conducted. [Attached is revised page 4-6.]
2. Comment: "Page 4-10, Para 1 - In addition to the objectives.."
Response: The potential impact to the Mobile River from the swamp will be assessed through review of sediment and surface water sample data, surface water physical measurements, and data from other previous and ongoing studies at the site. In addition, sediment samples will be taken along the Mobile River shoreline downstream of the swamp during Stage II and both up and downstream of the swamp during Stage III, and surface water samples will be taken both upstream and downstream of the swamp during Stage I. [Revised page 4-10 is attached.]
3. Comment: "Page 4-12, Para 1 - Background samples should be..."
Response: The full analytical suite has been proposed for background sample N-1 (see Figure 5-1 and Table 5-1). As per paragraph 1 on 4-12, the four additional background samples have been included for the specific purpose of establishing "background"
•J 4
levels of naturally occurring inorganics (metals) in the site vicinity. Consequently, it is not necesary to conduct the full TCL/TAL/pesticide scans at these loctions. However, in order to obtain more complete background characterization, the full analytical suite has been increased to include two samples (N-1 and N-14). This approach will consider background conditions west of the site and in the upland portion of the site. [Table 5-1 is revised accordingly.]
4. Comment: "Page 4-12, Para 4 - A statement is made that..."
Response: Analyses for the full suite of compounds (TCL/TAL and thiocarbamates) will be conducted for 17 samples at 12 locations as part of the Stage I contaminant nature characterization. The activities described on page 4-12, paragraph 4 are part of the contaminant depth characterization which is a separate activity also conducted during Stage I. These samples will be analyzecl for total and organic mercury, sulfide, and pH only pursuant to responses EPA review comments on draft workplans.
5. Comment: "Page 4-16, Para 5 - As discussed, the selection of..."
Response: See Memorandum from J. Zarzycki dated 9 January 1991, Re: "Selection of Exposure Scenarios for Cold Creek Swamp." [Revision pages 4-16 through 4-17 are attached.] It is understood that EA will develop preliminary risk characterizations based upon Stage I data as described in para 4.2.2 and that we will submit a data assessment summary. It is further understood tht EPA will expedite review of this document to attempt to return comments within one week, in order to facilitate commencement of Stage II sampling at the earliest possible time. Those considerations are included in revised Table 7-1.
6. Comment: "Page 4-17, Para 2 - A statement is made that..."
Response: See response to comment #5.
7. Comment: "Page 4-20, Para 2 - Please revise to state all samples..."
8. Comment: "Page 5-4, Para 2 - Background samples should be..."
Response: See response to comment #3.
2 4 2 2 2 J
9. Comment: "Table 5-1 - Field duplicates is misspelled..."
Response: Acknowledged. The reference source for Method 6iiA is the USEPA, Determination of Thiocarbamate Pesticides in Industrial and Municipal Wastewater by Gas Chromatography. See revised Table 7-1 of the QAPP, reference #11. [Attached is revised Table 5-1.]
10. Comment: "Page 5-8, Para 1 - See comment for page 5-4..."
Response: See response to comment #3.
11. Comment: "Page 5-11, Para 1 - Filtering samples for dissolved..."
Response: Filtering will be done for dissolved mercury analysis oniy. Analyses for total mercury and other metals will be made on non-filtered samples (see Table 5-3).
12. Comment: "Table 5-3 - Please identify the source..."
Response: The reference source for procedure 160.1 (total dissolved solids) is EPA-600/4-79-020 Methods for Chemical Analysis of Water and Wastes. The reference source for procedure 314A is the Standard Methods for the Examination of Water and Wastewater, 16th edition American Public Health Association, 1985. Method 9250 and 314A will be used for chlorides and hardness analyses, respectively. Method 314A is applicable to all waters and yields the best accuracy for hardness. Water samples for VOC analyses will be preserved to pH <2 with HCl. Containers for VOC, semi-volatiles and pesticides will have teflon-lined caps. [Revised Table 5-3 is attached.]
13. Comment: "Page 5-17, Para 2 - All samples collected..."
Response: If additional contaminants of concern are identified as a result of the Stage I data assessment, the work scope for Stages II and III data collection will be revised accordingly. See response to Comment #5.
14. Comment: "Page 5-43, Para 5 - In addition to risk-based..."
Response: In the absence of specific ARARs pertaining to soil/sediment remediation, remedial action objectives for this project will be developed for soil/sediment remediation based upon the results of the ecological and human health risk assessments, and the contaminant fate and transport assessement from the RI.
J
The specific methodology for contaminant fate and transport assessment will not be selected until additional site specific data is collected. As part of the RI, the potential for surface water/ground-water interaction will be assessed as indicated on page 5-35, paragraphs 2 and 3. This information, as well as chemical and physical data collected from the three-stage field investigation, will be reviewed in order to determine the appropriate methodologies to examine contaminant fate and transport at the site. Contaminant fate and transport assessment results will then be used in conjunction with risk assessment data to establish remedial action objectives for soil/sediment remediation.
15. Comment: "Appendix C - Information must be provided..."
Response: Drilling logs are not provided with this submission. Drilling logs from an ongoing investigation at the site will be provided when available.
B. Quality Assurance Plan
1. Comment: "Table 4-1 and 4-3 - Please revise these tables..."
Response: Revised tables are provided as Attachment B-2 to be consistent with the Workplan/SAP.
2. Comment: "Table 7-1 - The date of the fourth reference..."
Response: Acknowledged. (See Table 7-1 in Attachment B-3)
3. Comment: "Appendix A - Resumes should be submitted..."
Response: Resumes for QA staff are provided in Attachment B-2.
4. Comment: "Appendix D - Please refer to the enclosed..."
Response: The holding times for VOC analyses indicated in EPA Region IV memorandum dated 29 August 1989 and the holding times for semi-volatiles indicated in Table 4-1 from SW-846 (revised December 1987) will be used.
B. Health and Safetv Plan
1. Comment: "Page 10-4, Para 2 - Figure 10-1 is missing..."
Response: Figure 10-1 for the SHSP is provided as Attachment B-3.
11653.02(6)
3 4 'v- ' I V ^
ATTACHMENT B
REVISIONS PAGES
B-1 Workplan/SAP Revision Pages
Revision 01 .5 4 0 ''l J /•' 17 January 1991
located north of the Hoechst-Celanese Plant (north of Cold Creek), and
the other is located approximately 100 ft north of the LeMoyne-Courtaulds
Fibers property line near the railroad tracks. Previous surface water
samples did not exhibit concentrations of priority pollutants above
detection levels, with the exception of mercury (0.0002 mg/L) and zinc
(0.31 mg/L) in one of the two samples.
Surface water data collection for this project is proposed to
characterize surface water quality within the Cold Creek Swamp, within
waters discharging to Cold Creek Swamp, at the mouth of Cold Creek and
within the Mobile River, upstream and downstream of the swamp discharge
location. The objectives of surface water data collection are to
characterize contamination upstream, downstream, and within the Cold
Creek Swamp; and to characterize contaminant transport via surface water
and the potential for ground-water contamination through surface water
aquifer recharge. Table 4-3 shows the proposed sampling program for
investigation activities for this supplemental RI/FS.
Since surface water quality data will be used in ecological modeling and
risk assessment, and since the site is an operable unit for two NPL
sites, EPA Level III analytical data levels will be utilized.
4.1.2.1 ARARs for Surface Vater Sampling
The Cold Creek/LeMoyne Superfund sites RI/FS concluded that surface water
exposure at the Cold Creek and LeMoyne plants does not constitute a human
health exposure pathway, based upon site use and limited site access.
Cold Creek Swamp, however, represents an excellent habitat for wildlife,
and potential receptors are the native plant and animal species. Uater
Quality Criteria (WQC) values established under the Federal Uater
Pollution Control Act, as amended by the Clean Uater Act of 1977, and the
Uater Quality Act of 1987, will be probable ARARs governing surface water
quality. Table A-3 shows the surface water parameters to be analyzed
during the field investigation for this project.
4-6
3 4 Q •-! J ''- Revision 01 17 January 1991
A program to identify the areal and ecological limits of the swamp
will be conducted. The program will include wetlands delineation,
qualitative modeling of the wetland, and an ecological assessment
based upon the flora and fauna identified within and around the swamp.
To further characterize surface water quality both within, and
upstream of. Cold Creek Swamp.
To assess surface-water/ground-water interactions based on data
collected in this Uork Plan, data from previous and ongoing
investigations at the site, and other available information.
To assess the potential impact to the Mobile River from the swamp
through review of sediment and surface water sample data, surface
water physical measurements, and data from other previous and ongoing
investigations.
As noted previously, based upon the project data requirements, a three
stage field investigation program has been developed. The program will
be implemented on a staged basis to allow results of previous stages to
be reviewed prior to initiation of subsequent stages, and to focus
subsequent stages on identified contaminants of concern. The following
sections describe field activities to be performed in the three stage
field investigation at Cold Creek Swamp.
4.2.1 Stage I Field Activities
The primary objectives of Stage I Field Activities will be to
(1) characterize the nature of contamination within and around the swamp,
(2) characterize the depth of contamination of selected locations within
the swamp, (3) characterize surface water quality both within and
upstream of Cold Creek Swamp, (4) delineate and map the wetlands at the
site and establish biophysical limits of the swamp, and (5) characterize
the Cold Creek Swamp ecological community via species monitoring. Based
upon data results obtained during Stage I, the Stage II data collection
program will be focused to concentrate on characterization of
wetland (e.g., sediment, ground water, and surface water). UET model
output will help explain observed pattern and importance of sediment,
water, and biological tissue data.
4.2.1.5 Biota Inventory
An inventory of biota present or potentially present is necessary to
develop site-specific food web models. An observation-based inventory
will be coupled with published data and experience in the ecosytem of
concern to compile an inventory of Cold Creek Swamp biota.
4.2.2 Stage II Field Activities
Primary objectives of Stage II field activities will be to (1) character
ize the vertical and horizontal extent of contaminants of concern within
and around the swamp, (2) examine the bioaccessibility of mercury in
soil/sediment samples, and (3) examine the physical characteristics (flow
rate, stream gage, dissolved oxygen content) of swamp surface water under
differing environmental conditions.
Review of existing data indicates that mercury represents the primary
contaminant of concern at this site. As such. Stage II field activities
as described in this Uork Plan have been focused upon further characteri
zation of mercury contamination. If it is determined, based upon results
of the Stage I contaminant characterization, that additional contaminants
should be characterized in greater detail, the scope of Stage II sampling
will be modified to include other contaminants of concern.
Determination of Contaminants of Concern - Ecological Risk Consideration
Determination of contaminants other than mercury to be analyzed in
greater detail during subsequent stages of investigation will be in
accordance with Risk Assessment guidance provided by USEPA 1989b. As
environmental issues are driving concerns for the site, and as the
primary route of human health exposure is via the food web, this guidance
is most appropriate.
4-16 a
Revision 01 2) 4 0 4 0 •') 17 January 1991
Chemicals of potential ecological concern will be identified according to
guidance (USEPA 1989b) on the basis of physico-chemical properties
(including water solubility, sorption tendency, and persistence), and
bioaccumulation potential. A concentration-toxicity screen for
ecological receptors will be applied through guidance provided for
USEPA 1989b by evaluating measured and potential concentrations in
various environmental components against available criteria (e.g., FDA
tissue limits) or against effects levels reported in the scientific
literature. Compounds that are found to represent ecological risk based
on projected tissue concentrations as identified through the risk
assessment will be examined in subsequent stages of the field
investigation.
Determination of Contaminants of Concern Human Health Risk Considerations
Uith regard to human health risk considerations, two exposure pathways
will be examined.
Ingestion of contaminants in fish caught during recreational
fishing
Dermal contact with contaminated water associated with the
recreational fishing
A series of exposure assumptions for each of the two exposure pathways is
addressed below. The results of the Stage I chemical analysis of
sediment and water samples will be used to assess the risk to humans
posed by these two exposure scenarios. This risk will determine whether
analysis of chemicals other than mercury will be required for Stage II
and Stage III analysis. Risk will be calculated separately for
carcinogenic and noncarcinogenic effects.
4-16 b
Revision 01 17 January 1991
The following is proposed as the set of assumptions for "Ingestion Due to
Recreational Fishing" and "Dermal Contact During Recreational Fishing."
a. Ingestion Due to Recreational Fishing
Scenario: Swamp is too dry for much of the year for fishing.
Fishermen would have to come in from the Mobile River because the
plant precludes access from the land side. Access by boat from
the Mobile River will be difficult if not impossible. Swamp is
posted "No Trespassing." Fish taken in the swamp are small and
only edible tissue is to be considered.
Exposure Frequency
Exposure Duration
6 meals/yr (based on our estimate of 1 recreational fish meal per month from Cold Creek Swamp for the months swamp has water)
30 years (based on the national upper-bound [90th percentile] estimate of time that people live at one residence, an EPA assumption per the guidance manual)
Body Weight of Fisherman
Ingestion Rate
70 kg (standard adult weight, an EPA assumption per the guidance manual)
113 grams/meal (the average [50th percentile] size of a fin fish meal, based on EPA assumptions in the guidance manual. Given the small size of the fish and crayfish captured in Cold Creek Swamp by BCM (1989) [average fish size, 5.2 g; average crayfish size, 1.0 g], ve believe it will be extremely difficult to catch a meal of even 113 g exclusively in the svamp.)
4-16 c
l.i
Revision 01 17 January 1991
Averaging Time 30 yr for noncarcinogenic effects 70 yr for carcinogenic effects
(EPA assumptions per the guidance manual)
The contaminant concentration expected in the fish will be based
upon the levels of the contaminant found in sediment and water in
Stage I. Bioaccumulation factors and partitioning coefficients
will be utilized to project concentration levels in edible
tissue.
b. Dermal Contact During Recreational Fishing
Scenario: Dermal contact with water will be incidental to
fishing due to water splashing on exposed body parts. It is
assumed that fishermen vill be wearing shoes or boots, shorts,
and shirts; i.e., arms, hands, and legs will be exposed.
Exposure Frequency 6 times/yr (same exposure frequency
as assumed for recreational
fishing)
Skin Surface Area
Exposure Time
Exposure Duration
Body Ueight
Averaging Time
Arms - .23 m^ Hands - .082 m^ Legs - .55 m^
.862 m^ (EPA assumption per guidance manual)
4 hrs/day (expected time of fishing event)
30 years (same duration as assumed for recreational fishing)
70 kg (standard EPA assumption per the guidance manual)
30 yr for noncarcinogenic effects 70 yr for carcinogenic effects (EPA assumptions per guidance manual)
4-16 d
U '-t
Revision 01 17 January 1991
Permeability Constants These are compound-specific and measure the amount of the compound which is absorbed through each cm^ of skin per hour of exposure. Values will be obtained from EPA guidance, other permeability information as available, or the permeability constant for water will be used if no compound-specific value is available (per EPA guidance manual).
Contaminant concentrations used in this exposure scenario will be
those found in the water analyzed from Stage I samples.
Ue will not consider incidental ingestion of contaminants
associated with water or sediment splashed on hands and
transferred to the mouth.
The following outlines the risk criteria upon which risk will be
judged as significant, i.e., requiring inclusion of a compound in
analysis of Stages II and III sampling.
a. Noncarcinogenic Effects
Noncarcinogenic risk posed by a compound will be considered
significant only if the hazard quotient for that compound
(average daily intake based on the outlined assumptions divided
by the reference dose [RfD] exceeds one.
b. Carcinogenic Effects
Carcinogenic risk posed by a compound will be considered
significant only if the excess lifetime cancer risk for that
compound (average daily intake based on the outlined assumptions
multiplied by the carcinogenic slope factor) exceeds 10~ .
4-16 e
Revision 01 U '1 • i i 17 January 1991
Determination of Contaminants of Concern - Summary
This approach maximizes the flexibility with which compounds of concern
may be carried into further field investigations should this prove
necessary or cost effective, or into risk evaluation calculations. It is
important to reiterate that the staged study approach being employed at
this site makes it imperative that compounds considered for inclusion in
further sampling efforts be fully justifiable.
Uhen the suite of compounds of potential concern has been derived from
Stage I data. Stage II will be modified to incorporate additional
analyses as necessary. Currently, Stage II is defined to include
subsampling and analysis for mercury. Compounds for which sufficient
data exist may be carried directly into risk evaluation phases vithout
additional sampling. For other compounds, additional field investigation
may be necessary.
In order to accurately identify and map Stage I and Stage II sample
locations, EA will conduct a field survey to locate sample points on the
site. The field survey team will re-establish the survey traverse that
was used in the original RI and will locate new sample points from the
completed traverse. The field survey is described in more detail in
Chapter 5.
4-17
- , .. , Revision 01 •J 4 U 4 4 ! 17 January 1991
4.2.3.1 Biological Tissue Characterization
Based upon the results of an ecological model that will be run using
Stage I and Stage II field data to evaluate potential biotic uptake,
representative ecological species will be selected for tissue
characterization. The number and type of samples cannot be defined at
this time. This Uork Plan will be updated pursuant to the results of
Stage I and Stage II data collection and the ecological modeling.
Once the number and type of species and the number of samples is defined,
representative samples will be collected. The samples will be analyzed
for concentrations of total mercury. Samples will also be examined as
appropriate, for other compounds that have been identified as
contaminants of concern during previous sampling stages.
Details on sample collection methods, sampling protocols, and number and
location of samples will be developed subsequent to ecological modeling
results. This Uork Plan will be updated to incorporate this information
Stage III bioaccessible contaminant characterization will be very similar
to Stage II bioaccessible contaminant characterization. Only a limited
number of sample locations will be used for this Stage. The objective of
this sampling is to further delineate the vertical distribution of
contaminants. Selected Stage II sampling locations will be chosen for
the Stage III characterization. The sampling sites will be selected on
the basis of observed organic (methyl) mercury concentration as
determined during Stage II. At least one sampling location will be
selected from each of the three ecological zones of the swamp (upper,
lower, middle).
4-20
1165301 Doc. 15
TABLE 5-1 SUMMARY OF SAMPLES, ANALYTICAL PROCEDURES, HOLDING TIME, AND CONTAINERS FOR STAGE I CONTAMINANT NATURE CHARACTERIZATION
Number of Number Field ,. Total Sample of Dupli- Field Trip ^ Total Analytical Number of
Pa ramete r Loca tions Sarapl es cates Blanks Blanks Samples P rocedu res Prese rvat ion Holding Time Conta ine rs Conta iners
Volatile 13 18 1 I 1 21 CLP Hold P 4 C 14 days 4 oz wide mouth 4 2*'^* Organics (2/88) glass jar with
Teflon 1iner t
Semivolatile 13 18 1 1 0 20 CLP Hold g 4 C 7 days extraction 8 oz wide-mouth 20 Organics (2/88) 40 days extract glass jar with
Teflon 1ine r
Pesticides/ 13 18 1 1 0 20 CLP Hold 9 4 C 5 days extraction 8 oz wide-mouth 20 PCBs (2/88) 40 days extract glass jar with
Teflon 1ine r
Metals 16 21 1 1 0 24 ' CLP Hold 9 4 C (f) 8 oz wide-mouth 24 (TAL) (7/88) glass jar with
Teflon 1ine r
Methyl 13 18 1 1 0 20 (e) Hold p 4 C 7 days extraction 8 oz wide-raouth 20 Mercury 40 days extract glass jar with
Teflon 1ine r
Thio- 13 18 1 1 0 20 EPA Hold 9 4 C 7 days extraction 8 oz wide-mouth 20 Carbamate 634 40daysextract glassjarwith Pesticides Teflon liner
Sulfide 13 18 1 1 0 20 9030 Hold 9 4 C 7 days 8 oz wide-mouth 20 glass jar with Teflon 1ine r
(a) Trip blanks taken for volatile organics analysis only. (b) All methods are EPA SW-846 unless otherwise noted. (c) No chamical preservatives added to soils. (d) From tine of sample collection. (eJ Method for methyl mercury analysis is described in the QAPP. (f) Holding tirae for all netals is 6 months, with the exception of mercury whose holding tirae is 28 days. (g) Two containers per sample, (h) See Table 7-1 in the QAPP.
1165301 Doc. 25
TABLE 5-3 SUMMARY OF SAMPLES, ANALYTICAL PROCEDURES, HOLDING TIME AND CONTAINERS FOR STAGE I IN SITU SURFACE WATER CHARACTERIZATION
Paramete r
Total dissolved solids
Ha rdnes s
pH
Chlo r ides
Sulfides
Total dissolved mercury
Total me rcury
Methyl mercury
Volatile Organics
Semivolatile Organics
Pesticides/PCBs
Metals (TAL)
Number of Samples and Locations
6
6
Fie Dupl i
d Fie ates Bla
d Total ks Samples
Analyt ical Procedure
EPA 160.1
APHA 314A
9040
9250
9030
2 4 5 . 1 CLP-M
2 4 5 . 1 CLP-M
( c )
CLP (2/88)
CLP (2/88)
CLP (2/88)
CLP (7/88)
(a)
Prese rvat ion
Hold 9 4 C
Hold 9 4 C HNO, to pH<2
None
None
Hold e 4 C Zinc acetate NaOH to pH>9
HNO, to pH<2
HNO, to pH<2
Hold § 4 C
pH< 2 Hold 8 4 C
Hold e 4 C
Hold e 4 C
Hold g 4 C
Holding Time (b)
Conta iners
7 days
6 months
Analyze immediately
28 days
7 days
28 days
28 days
7 days extraction 4 0 days extract
14 days
P , G
P , G
P, G
P , G
G, Teflon cap
G, Teflon cap
7 days extraction G, Teflon cap 40 days extract
5 days extract 40 days extract
(d)
G, Teflon Cap
P , G
(a) All anlaytical procedures are fron EPA SW-846 unless otherwise noted, see Table 7-1 in QAPP. (b) From time of sample collection. (c) Described in QAPP. (d) Holding tirae for all metals is 6 months, with the exception of mercury whose holding time is 28 days. P = plastic G = glass
1 1
5 1- LJ 'r
3 0 1
TABLE 7-1 PROJECT SCHEDULE
Submit Uork Plans to EPA Receive EPA review comments EPA review comment meeting Submit final plans to EPA Stage I field investigation begin Stage I field investigation end Stage I chemistry data available Propose contaminants of concern Discuss contaminants of concern Submit revisions to work plan Stage II field investigation begin Stage II field investigation end Stage II chemistry data available Revised Stage III field plan submitted to USEPA Receive EPA reviev comments Stage III field investigation begin Stage III field investigation end Stage III chemistry data available Nature/Extent Characterization complete
Ecological Risk Assessment complete Human Health Risk Assessment complete Draft RI to EPA RI Review Comments from EPA RI Review Conference (with regulators) at Region IV
Final RI to EPA Draft FS to EPA FS Review Comments from EPA FS Review Conference (with regulators) at Region IV
Final FS to EPA
This schedule assumes 30 day review period for all project submittals and all projected dates are dependent on timely document review.
It is imperative that Stage I and II sampling events occur during the drier season (November-March) and that Stage III sampling occur during the wettest season (July/August/September) to assure relatively accessible sampling conditions.
1 26 6 3 4 14 26 25 2 9 13 14 26 21 20 7 26 6 12
15
15 15 25 23 7
28 26 24 30
21
Oct Oct Nov Dec Feb Feb Mar Apr May May May June July Aug Sep Oct Oct Dec Dec
TABLE 4-1 SUMMARY OF SAMPLES, ANALYTICAL PROCEDURES, HOLDING TIME, AND CONTAINERS FOR STAGE I CONTAMINANT NATURE CHARACTERIZATION
Number of Number Field Total Sample of Dupli- Field Trip Total Analytical Number of
Pa ramete r Locat ions Samples cates Blanks Blanks Samples Procedu res Preservat ion Holding Time Containers Containers
Volatile 13 18 1 1 1 21 CLP Hold 9 4 C 14 days 4 oz wide mouth 4 2 '''' Organics (2/88) glass jar with
Teflon 1ino r I
Semivolatile 13 18 1 1 0 20 CLP Hold g 4 C 7 days extraction 8 oz wide-mouth 20 Organics (2/88) 40 days extract glass jar with
Teflon 1ine r
Pesticides/ 13 18 1 1 0 20 CLP Hold g 4 C 5 days extraction 8 oz wide-mouth 20 PCBs (2/88) 40 days extract glass jar with
Teflon liner
Metals 16 21 1 1 0 24 CLP Hold g 4 C (f) 8 oz wide-mouth 24 (TAL) (7/88) glass jar with
Teflon 1ine r
Methyl 13 18 1 1 0 20 (e) Hold g 4 C 7 days extraction 8 oz wide-mouth 20 Mercury 40 days extract glass jar with
Te flon 1ine r
Thio- 13 18 1 1 0 20 EPA Hold g 4 C 7 days extraction 8 oz wide-mouth 20 Carbamate - 634 40 days extract glass jar with Pesticides Teflon liner
Sulfide 13 18 1 1 0 20 9030 Hold g 4 C 7 days 8 oz wide-mouth 20 glass jar with Teflon liner
(a) Trip blanks taken for volatile organics analysis only. (b) All methods are EPA SW-846 unless otherwise noted. (c) No chemical preservatives added to soils. (d) From time of sample collection. (e) Method for methyl mercury analysis is described in the QAPP. (f) Holding time for all metals is 6 months, with the exception of mercury whose holding time is 28 days. (g) Two containers per sample, (h) See Table 7-1.
1165301 Doc. 67
TABLE 4-3 SUMMARY OF SAMPLES, ANALYTICAL PROCEDURES, HOLDING TIME AND CONTAINERS FOR STAGE I IW SITU SURFACE WATER CHARACTERIZATION
Pa ramete r
T o t a l d i s s o l v e d s o l i d s
Ha r d n e s s
pH
Chlor ide s
Sulfides
Total dissolved mercury
Tota 1 me rcu ry
Methyl mercury
Volatile Organics
Semivolatile Organics
Pesticides/PCBs
Metals (TAL)
Number of Samples and Locations
6
6
Field Fie Duplicates Bla
d Total ks Samples
Analytical P rocedu re
EPA 160.1
APHA 314A
9040
9250
9030
2 4 5 . 1 CLP-M
2 4 5 . 1 CLP-M
( c )
CLP ( 2/8 8 )
CLP (2/88 )
CLP (2/88 )
CLP (7/88)
(a )
Preservation
Hold g 4 C
Hold g 4 C HNO, to pH<2
None
None
Hold (J 4 C Zinc acetate NaOH to pH>9
HNO, to pH<2
HNO, to pH<2
Hold g 4 C
Hold @ 4 C
Hold g 4 C
Hold g 4 C
Hold g 4 C
Holding Time (b)
Containe rs
7 days
6 months
Analyze immediately
28 days
7 days
28 days
28 days
7 days extraction G, Teflon cap 40 days extract
14 days G
7 days extraction G 4 0 days extract
5 days extract G 40 days extract
(d) P, G
(a) All anlaytical procedures are from EPA SW-846 unless otherwise noted (see Table 7-1). (b) From time of sample collection. (c) Described in QAPP. (d) Holding tine for all metals is 6 months, with the exception of mercury whose holding time is 28 days. P = plastic G = glass
1. American Public Health Association, American Uater Works Association, Water Pollution Control Federation. 1985. Standard Methods for the Examination of Water and Wastewater, 16th edition. APHA, Washington, D.C.
2. Association of Official Analytical Chemists. 1984. Official Methods of Analysis, 14th edition. AOAC, Arlington, Virginia.
3. Page, A.L., R.H. Miller, and D.R. Keeney, eds. 1982. Methods of Soil Analysis, Part 2: Chemical and Microbiological Properties, 2nd edition. American Society of Agronomy, Madison, Wis.
4. United States Environmental Protection Agency. 1983. Methods for Chemical Analysis of Water and Wastes. EPA-600/4-79-020. U.S. EPA, Cincinnati, Ohio.
5. United States Environmental Protection Agency. 1981. Interim Methods for The Sampling and Analysis of Priority Pollutants in Sediments and Fish Tissue. EPA-600/4-81-055. U.S. EPA, Cincinnati, Ohio.
6. United States Environmental Protection Agency. 1984. Characterization of hazardous Waste Sites, A Methods Manual. Volume III. Available Analytical Methods. EPA-600/4-84-038. U.S. EPA, Las Vegas, _j.̂ Nevada.
7. United States Environmental Protection Agency. 1984. The Determination of Inorganic Anions in Water by Ion Chromatography. EPA-600/4-84-017. U.S. EPA, Cincinnati, Ohio.
ofa:> j p methods table doc. 291 Revised: 16-Jan-91
TABLE 7-1 ANALYTICAL METHODS
Page 6 of 6
8. United States Environmental Protection Agency. 1986. Test Methods for Evaluating Solid Waste. Physical/Chemical Methods. EPA SW-846, 3rd edition. U.S. EPA, Washington, D.C.
9. United States Environmental Protection Agency. 1987. U.S. EPA Contract Laboratory Program. Statement of Work for Inorganics Analysis. U.S. EPA, Washington, D.C.
10. United States Environmental Protection Agency. 1987. U.S. EPA Contract Laboratory Program. Statement of Work for Organics Analysis. U.S. EPA, Washington, D.C.
11. United States Environmental Protection Agency. No date. Determination of Thiocarbamate Pesticides in Industrial and Municipal Uastewater by Gas Chromatography, Method 634, draft. U.S. EPA, Cincinnati, Ohio.
12. Association of Official Analytical Chemists. 1984. Mercury (Methyl) in fish an shellfish. Gas Chromatographic Method First Action. ACAC, Arlington, VA.
's^'"^i
ATTACHMENT B
REVISIONS PAGES
B-3 SHSP Revision Pages
'S 4 Cf '•; [ ) -I
j ^r
Cold Creek Swamp Site
Mobile Bay
MILES
1.5 3
Rgure 10-1. Emergency route to Springhill Memorial Hospital, Mobile, Alabama.
