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REVISED SAMPLING, ANALYSIS, AND MONITORING PLAN FOR WELLS TUTU WELLS SITE ST. THOMAS, U.S. VIRGIN ISLANDS September 1990 Revised September 1991 Prepared for Tutu Environmental Investigation Committee Prepared by Geraghty & Miller, Inc. 201 West Passaic Street Rochelle Park, New Jersey 07662 (201) 909-0700 *64421* 64421 REVISED SAMPLING, ANALYSIS, AND MONITORING PLAN FOR WELLS TUTU WELLS SITE ST. THOMAS, U.S. VIRGIN ISLANDS September 27, 1991 Geraghty & Miller, Inc. is submitting this plan on behalf of the Tutu Environmental Investigation Committee for work to be performed at the Tutu Wells Site in St. Thomas, U.S. Virgin Islands. The plan was prepared in conformance with Geraghty & Miller's strict quality assurance/quality control procedures to ensure that the report meets the highest standards in terms of methods used and the information presented. If you have any questions or comments concerning this plan, please contact one of the individuals listed below. Respectfully submitted, GERAGHTY & MILLER, INC. Thomas V. Danahy y Senior Scientist/Project Manager Dan1£i~7CNachman Vice President/Project Director TVD:gv #PR00801/sig.pg GERAGHTY & MILLER. INC. CONTENTS INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 SCOPE OF WORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 QUALITY ASSURANCE/QUALITY CONTROL PROGRAM . . . . . . . . . . . . . . . . . 7 SAMPLING QUALITY ASSURANCE/QUALITY CONTROL PROGRAM . . . . . 7 ANALYTICAL QUALITY ASSURANCE PROJECT PLAN . . . . . . . . . . . . . . . . . . 8 Project Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Project Organization and Responsibility . . . . . . . . . . . . . . . . . . . . . . . 8 Quality Assurance Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Sampling Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Sample Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Field Sample Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Laboratory Sample Custody . . . . . . . . . . . . . . . . . . . . . . . . . 10 Calibration Procedures and Frequency . . . . . . . . . . . . . . . . . . . . . . . 11 Analytical Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Data Reduction, Validation, and Reporting . . . . . . . . . . . . . . . . . . . . 11 Internal Quality Control and Quality Assurance . . . . . . . . . . . . . . . . . 12 Performance and System Audits . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Preventative Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Procedures to Assess Data Precision, Accuracy, Representativeness, Comparability, and Completeness . . . . . . . . . . . . . . . . . . . . . . . 13 Corrective Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Quality Assurance Reports to Management . . . . . . . . . . . . . . . . . . . . 13 INDEPENDENT DATA VALIDATION . . . . . . . . . . . . . . . . . . . . . . . . . 13 DATA SUBMISSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 PROJECT MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 PROJECT TEAM RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Tutu Environmental Investigation Committee . . . . . . . . . . . . . . . . . . 15 TUT 002 0695 GERAGHTY t* MILLER. INC. CONTENTS (Continued) Page Soil Tech . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Geraghty & Miller . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 PROJECT SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 NOTIFICATION TO USEPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 TABLES 1. Summary of Proposed Sampling and Analysis Effort, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 2. Project Analyte List and Contract Required Quantitation Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 3. Precision, Accuracy, and Completeness Objectives, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 4. Requirements for Sample Containers, Preservation, and Holding Times, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 5 Summary of Analytical Methods, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 6. Surrogate Spike Control Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. FIGURES 1. Study Area, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 2. Well Sampling Locations, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. GERAGHTY & MILLER. INC. FIGURES (Continued) 3. Site Plan, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. 4. Enseco Incorporated Internal Chain of Custody. 5. Enseco Incorporated Sample Custody Form. APPENDICES A. Additional Quality Control Requirements for Method 524.2 Analysis. B. Health and Safety Plan. C. Well Sampling Procedures. D. Sampling Quality Assurance/Quality Control Protocols. E. Enseco Incorporated Quality Assurance Program Plan for Environmental Chemical Monitoring, Revision 3.4, April 1991. F. Resumes of Key Personnel. GERAGHTY & MILLER. INC REVISED SAMPLING, ANALYSIS, AND MONITORING PLAN FOR WELLS TUTU WELLS SITE ST. THOMAS, U.S. VIRGIN ISLANDS INTRODUCTION This Sampling, Analysis, and Monitoring Plan (SAMP) has been prepared for the Tutu Environmental Investigation Committee (TEIC), which is comprised of Texaco Caribbean Inc. (Texaco), Esso U.S. Virgin Islands, Inc. (Esso), and L'Henri, Inc. (O'Henry) by Geraghty & Miller, Inc. for well sampling in the vicinity of the Tutu Wells Site, Anna's Retreat, St. Thomas, U.S. Virgin Islands (USVI). The SAMP was developed to satisfy requirements set forth in the Administrative Order issued on March 22, 1990 to Texaco, Esso, and O'Henry by the U.S. Environmental Protection Agency (USEPA) Region II. The original SAMP was submitted to the USEPA in September 1990. Three sampling events have been implemented under the original SAMP by Soil Tech Corporation. Geraghty & Miller has documented the sampling activities, coordinated laboratory analyses, validated laboratory data, and prepared reports on the quarterly sampling events and results (Geraghty & Miller, Inc., 1991a; 1991b; 1991c). The SAMP has been revised to (1) document a replacement analytical laboratory and (2) include more accurate descriptions of sampling and analytical procedures. Responding parties have denied any liability or responsibility, and the work to be conducted pursuant to this plan does not constitute any admission that the respondents are liable or responsible for any constituents that may be present in the wells sampled. TUT GERAGHTY & MILLER. INC OBJECTIVES The objectives of the SAMP are to identify, quantify, and monitor the occurrence of gasoline constituents and tetrachloroethene (and its breakdown products) in wells in the vicinity of Route 38 within the Tutu Wells Site. BACKGROUND The Tutu Wells Site is located in the upper Turpentine Run basin in east central St. Thomas (Figure 1). Various commercial establishments line the major roads in the area. These establishments include the Texaco Tutu service station at the intersection of Highways 38 and 384, the Esso Tutu service station on Highway 38, and O'Henry Dry Cleaners on Highway 38. Private homes and multi-family housing, such as the Virgin Islands Housing Authority (VIHA) buildings, generally occupy the less heavily traveled roads. Several water supply wells are located in the Turpentine Run basin (Figure 2). These wells are operated by the VIHA, water purveyors, and private concerns, and supply water for domestic and commercial purposes. The Texaco Tutu service station has been in continuous operation since 1964. The station is a retail outlet for gasoline and diesel fuel and also provides mechanical servicing of automobiles. Over the life of the station, fuel has been stored underground with the exception of the period from July 1987 to September 1988 when the fuel storage tanks and piping were replaced with new tanks and piping. The Esso Tutu service station has been in continuous operations since 1970. The station sells retail gasoline and performs mechanical repairs. The station has two underground storage tanks; one of them was removed from service from August 1987 to June 1989. Fuel has been stored underground over the life of the station except for a brief period in June 1989 when the tanks and piping were removed and replaced with new tanks and piping. T t-'>" 002 O6S>9 GERAGHTY & MILLER. INC. 3 O'Henry Dry Cleaners has been owned and operated by L'Henri, Inc. since 1981. Tetrachloroethene, commonly referred to as perchloroethylene and hence abbreviated as PCE, is used, stored, and handled at the establishment. A brief reconnaissance of the area conducted by Geraghty & Miller in August 1990 revealed that there are other establishments that represent potential sources of constituents of concern to soil and ground water. These establishments include but may not be limited to the following: A Jeep dealership and repair shop. The Ramsay Motor dealership and repair shop. The LAGA building, which formerly housed a textile processing operation. Tillett Garden, where silk screening and pottery manufacturing and glazing are performed. The paint store. The Fire Station. The Vitelco facility. Other small repair shops located on Highway 38. The sanitary/storm sewer line(s). The locations of these establishments, with the exception of the sanitary/storm sewer line(s), are shown on Figure 3. The following information is derived from the USEPA's Administrative Order of March 22, 1990 and other reports prepared by the USEPA and its consultants. Responding parties have not made an independent determination of these facts. In July 1987, water from the Tillett well was reported to have an unusual odor. Subsequent sampling and analysis of water from that well and other water supply wells in the area by the USEPA Technical Assistance Team (TAT) revealed the presence of volatile organic compounds (VOCs) in the well water. 'TUT OO2 07OO GERAGHTY & MILLER. INC 4 The compounds detected included gasoline constituents and chlorinated organic compounds. As a result of the presence of these constituents, the US VI Department of Planning and Natural Resources (DPNR) closed 18 wells in the area from July through September 1987. The wells have remained closed and have been sampled quarterly by the USEPA Region II TAT team. The majority of the quarterly sampling events performed by the TAT team involved analysis of the well water samples using a portable Photovac gas chromatograph (GC). Water samples were sent to a laboratory for chemical analysis on at least two occasions, in October 1987 and in November 1988. During both the October 1987 and November 1988 sampling events, the samples were analyzed for the EPA Target Compound List (TCL) of parameters. Based upon the analytical parameter list, it appears that an earlier sampling event occurred in July 1987, when the wells were first sampled and analyzed for VOCs using EPA Method 8240. SCOPE OF WORK The objective of the SAMP is to identify, quantify, and monitor the occurrence of gasoline constituents and PCE and its breakdown products in residential wells in the vicinity of Route 38 within the Tutu Wells Site. Twenty-five wells have been included in the sampling program. These wells are as follows: Bryan Eglin III Matthias Dede Four Winds I Ramsay Demitri Four Winds II Rodriguez Dench Gassett (formerly Hartman I - Bakery) Smith Devcon I Hartman II (Crusher) Steele Devcon II Hartman III (Estate) Tillett Eglin I Harvey VIHA I Eglin II LaPlace VIHA III The approximate locations of the wells are shown on Figure 2. ~r/ ' T 002 07O.1 GERAGHTY & MILLER. FNC 5 During the initial sampling event and once every year thereafter, the 25 wells will be sampled and submitted for laboratory analyses of the TCL and the Target Analyte List (TAL), with the exception of polychlorinated biphenyls (PCBs), under the Contract Laboratory Program (CLP). TAL analyses will be performed in accordance with the CLP Statement of Work (SOW) for inorganics analysis, as revised in March 1990. TCL analyses, with the exception of VOCs, will be performed in accordance with the CLP SOW for organics analysis, as revised in March 1990. All VOC analyses will be modified in accordance with a modified version of USEPA Method 524.2 Revision 3.0 in order to achieve lower detection limits. USEPA Method 524.2 analysis will be modified in accordance with the methodology described in Appendix A. VOC data reporting and validation will be performed in accordance with the CLP SOW for organics analysis, March 1990, and Method 524.2 Revision 3.0 criteria. Table 1 summarizes the proposed sampling and analysis effort. Table 2 lists the specific compounds and metals which are to be analyzed in support of this project. A Health and Safety Plan for the Tutu Wells Site sampling effort is presented in Appendix B. The HASP (Appendix B) has been prepared to address several tasks that will be performed in a future site investigation. For the purposes of the SAMP field work refer to Task 4: Evacuation and Sampling of Wells in Appendix B. During the other three quarterly sampling events per year, the 25 wells (or a more limited set of wells, approved by the USEPA) will be sampled and submitted for laboratory analysis of TCL VOCs under CLP using modified USEPA Method 524.2 to achieve lower detection limits. If the validated data from the initial sampling event indicates the presence of TCL semivolatiles, pesticides, or TAL constituents above the detection limit, then samples collected from those wells during subsequent quarterly sampling events will be analyzed for the analyte group detected, in addition to VOCs. Wells that do not show the presence of VOC parameters of concern for two consecutive quarterly sampling events will not be sampled during subsequent quarterly sampling events. After review of each quarterly sampling results, a list of wells to be removed from the sampling program will be submitted to the USEPA for approval. If VOC parameters of concern are detected in a given well sample, then that well will be sampled until at least two consecutive GERAGHTY & MILLER. INC 6 sampling events result in non-detection of VOC parameters of concern. Samples will be collected for TCL semivolatile and TAL metal analysis at least once a year. If TCL semivolatile parameters are detected in a given well sample, then that well will be sampled until the semivolatile concentrations are documented to be less than the applicable drinking water standards for at least two consecutive sampling events. If TAL metal or pesticide concentrations are reported above the applicable drinking water standard for a given well sample, then that well will be sampled for the specific metal parameter(s) and/or pesticide(s) until the results of at least two consecutive sampling events indicate that the concentrations are less than the applicable drinking water standards. However, if semivolatile, pesticide, or TAL concentrations above the detection limit do not pass data validation criteria or if there is reason to suspect that blank or laboratory contamination or matrix interferences have caused the detection of these constituents in the samples, then those wells will not be analyzed in subsequent quarterly sampling events for the analyte group detected. Instead, samples from those wells will be analyzed for TCL VOCs only. The analytical data will be reviewed after each sampling event to determine the appropriateness of reductions in sampling frequency or complete termination of sampling activities at individual wells. If sampling reduction or termination of sampling a particular well is warranted, such a proposal will be submitted to the USEPA for approval. If any two successive quarterly sampling events indicate that constituents of concern are not detected at concentrations above the detection limit for VOCs or above the applicable drinking water standards for the non-VOC parameters in a particular well, a proposal to terminate sampling of that well will be submitted to the USEPA for approval. The SAMP has been implemented by Geraghty & Miller and Soil Tech on behalf of TEIC, with oversight by USEPA and USVI-DPNR representatives. The first two sampling events, conducted in September/October 1990 and February 1991, indicated that nine well samples had non-detected results for VOCs of concern (Geraghty & Miller, Inc. 1991a; 1991b). Geraghty & Miller (1991b) recommended that these nine wells be removed from future sampling GERAGHTY & MILLER. INC TU1 7 efforts. In correspondence dated May 16, 1991 from Ms. Caroline Kwan, USEPA Project Manager to Ms. Ana Gloria Ramos, TEIC Designated Coordinator, the USEPA accepted the recommendation for removal of the nine wells for the third (June 1991) sampling round. Therefore, the following nine wells were not sampled during the third sampling event: Bryan, Dede, Bench, Devcon I, Devcon III, Demitri, Leonard, Rodriguez, and VIHA-IIL Results of the June 1991 sampling event were relatively consistent with the results of the first and second sampling events (Geraghty & Miller, Inc. 1991c). However, the cumulative nature of minor problems of quality assurance (QA) and quality control (QC) due to the laboratory subcontractor required the introduction of Enseco-East, Inc. (Enseco) as a replacement laboratory. QUALITY ASSURANCE/QUALITY CONTROL PROGRAM The objective of the QA/QC program is to provide defensible data of known quality. The QA/QC program consists of three parts: the sampling QA/QC program, the analytical Quality Assurance Program Plan (QAPP), and data validation by Geraghty & Miller. SAMPLING QUALITY ASSURANCE/QUALITY CONTROL PROGRAM The sampling QA/QC objectives are to ensure the reliability and integrity of all data and documentation generated as a part of the monitoring program. Well samples will be collected in accordance with USEPA-approved methods. Also, a Health and Safety Plan (HASP) has been prepared by Geraghty & Miller (see Appendix B). Prior to beginning field activities, all field workers will review the HASP. The HASP (Appendix B) has been prepared to address several tasks that will be performed in a future site investigation. For the purposes of the SAMP field work refer to Task 4: Evacuation and Sampling of Wells in Appendix B. Sampling will be conducted in such a way as to ensure that a water-quality sample representative of the hydrogeologic environment is obtained. Specific sampling protocols are described in Appendix C. TUT GERAGHTY & MILLER. INC. 8 Quality control sampling, sample custody, handling, and data management will be conducted in accordance with USEPA-approved methods. Sampling QA/QC protocols are detailed in Appendix D. ANALYTICAL QUALITY ASSURANCE PROJECT PLAN Laboratory analysis of well water will be performed by Enseco Incorporated of Somerset, New Jersey. Enseco routinely participates in laboratory performance evaluations for the USEPA as part of the Water Pollution (WP) program. The laboratory also undergoes quarterly audits by the USEPA as required by the CLP, and has been audited and approved by Geraghty & Miller's own internal laboratory contracting program. Enseco is a United States Department of Agriculture (USDA)-certified laboratory and may accept samples from the USVI. Project Description The analytical QAPP details the QA/QC procedures employed to ensure the accuracy, precision, comparability, representativeness, and completeness of analytical services to be provided for this monitoring program. Project Organization and Responsibility The organizational chart which delineates organization and responsibilities at Enseco is included in the Enseco QAPP for Environmental Chemical Monitoring, Revision 3.4, April 1991, which is included as Appendix D. Quality Assurance Objectives As part of the evaluation component of the QA Program, laboratory results are compared with certain data quality objectives. These objectives, in terms of precision, accuracy, representativeness, completeness, and comparability, may be defined as follows: TUT 002 0705 GERAGHTY & MILLER. INC 9 o Precision: The agreement or reproducibility among individual measurements of the same property, usually made under the same conditions. o Accuracy: The degree of agreement of a measurement with the true or accepted value. o Representativeness: The degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. o Completeness: A measure of the amount of valid data obtained from a measurement system compared with the amount that was expected to be obtained under correct normal conditions. o Comparability: An expression of the confidence with which one data set can be compared with another data set in regard to the same property. The accuracy, precision, and representativeness of data will be functions of the origins of the samples, the procedures used to analyze samples and generate data, and the specific sample matrices involved in each project. Quality control practices utilized in the evaluation of these data quality objectives include the preparation, collection, and analysis of blanks, replicates, spikes, standards, check samples, calibrations, and recoveries. Table 3 lists the precision, accuracy, and completeness objectives as defined for this project. Sampling Procedures Enseco will not perform any sample collection as a part of the SAMP. Sampling procedures are described in Appendix C. GERAGHTY & MILLER. INC 10 Sample Custody Field Sample Custody Sample custody procedures outside the laboratory are discussed in the Sampling QA/QC Program section of this SAMP and in Appendix D. Laboratory Sample Custody Chain-of-custody originates as samples are collected. Chain-of-custody documentation accompanies samples as they are moved from the field to the laboratory with shipping information and appropriate signatures indicating custody changes along the way. Laboratory chain of custody is initiated as samples are received and signed for on the Geraghty & Miller chain-of-custody form by the sample custodian at Enseco. The sample custodian documents the condition of the sealed sample shipment cooler on the chain-of-custody form. The sample label information is checked against the chain-of-custody record and proper container and preservative procedures as detailed in Table 4 are verified. The samples are then logged in by assigning laboratory identification numbers. The sample log-in record will include the sample identification, date of receipt, sample condition, the laboratory identification number, sample preparation, and sample distribution. The samples are secured in a refrigerator maintained at approximately 4°C prior to preparation and analysis. Documentation of samples signed in and out of the central storage facility for analysis in the Enseco laboratory is recorded using Enseco's Internal Chain of Custody and Sample Custody Forms (Figures 4 and 5). After analysis, extracts and any remaining samples are held in the central storage area for 30 days after project completion to await disposal. Samples at Enseco are kept within secure areas during all stages of custody, including the periods of time spent in preparation, analysis, and storage. The laboratory area is designated TUT GERAGHTY & MILLER. INC 11 as a secure area and the doors are kept locked at all times and only authorized personnel are allowed to enter the secure area. Visitors to the laboratories must be accompanied by Enseco staff members. Calibration Procedures and Frequency Instrument calibration procedures and frequency for organics analysis will be conducted in accordance with the methodology described in the CLP SOW for organics analysis, March 1990, and Method 524.2 Revision 3.0 for VOC analysis. Calibration procedures and frequency for inorganics analysis will be conducted in accordance with the methodology described in the CLP SOW for inorganics analysis, March 1990. Analytical Procedures Enseco will analyze TCL semivolatile organic compounds and pesticides in accordance with the methods detailed in the USEPA CLP SOW for organics analysis, March 1990, with revisions dated December 1990 and February 1991. TCL VOCs will be analyzed in accordance with a modified version of USEPA Method 524.2 in order to achieve lower detection limits. USEPA Method 524.2 analysis will be modified in accordance with the methodology described in Appendix A. TAL inorganic constituents will be analyzed for in accordance with the methods detailed in the USEPA CLP SOW for inorganics analysis, March 1990. Table 5 summarizes the analytical methods to be employed. Data Reduction. Validation, and Reporting Data reduction, validation, and reporting are examined in depth as part of the Enseco QA Plan dated April 1991, Section 10. This plan is attached as Appendix E. TIP GERAGHTY & MILLER. INC. 12 Internal Quality Control and Quality Assurance For this project, the internal quality control practices will include the following samples, analyzed one per batch of 20 samples, of the same matrix received by the laboratory: One Matrix Spike Sample One Matrix Spike Sample Duplicate (organics only) One Matrix Duplicate (inorganics only) One Method Blank Laboratory Fortified Blanks (Method 524.2 analyses; per calibration sequence) In addition, the following will also be required: Surrogate Standards: To be added to every organic sample analyzed. The control limits are those listed in Table 6. Performance and System Audits This section is examined in detail in the Enseco QAPP dated April 1991, Section 12, included in Appendix E. Preventative Maintenance This section is examined in detail in the Enseco QAPP dated April 1991, Section 13, included in Appendix E. GERAGHTY & MILLER. INC 13 Procedures to Assess Data Precision. Accuracy. Representativeness. Comparability, and Completeness Specific routine procedures to assess data precision, accuracy, representativeness, comparability, and completeness are examined in the Enseco QAPP dated April 1991, Section 14, included in Appendix E. Corrective Action This section is examined in detail in the Enseco QAPP dated April 1991, Section 15, included in Appendix E. Quality Assurance Reports to Management This section is examined in detail in the Enseco QAPP dated April 1991, Section 16, included in Appendix E. INDEPENDENT DATA VALIDATION Geraghty & Miller will validate the entire data set, independently of the laboratory. Data validation will be performed in accordance with the USEPA Standard Operating Procedures (SOP) No. HW-2, February 1989 for inorganics and the USEPA SOP No. HW-6, March 1990 for organics. In brief, the data will be reviewed for compliance with the QC criteria based on the spike, duplicate, and blank results provided by the laboratory. The data will be evaluated for its precision, accuracy, completeness, representativeness, and comparability. If any data omissions or out-of-control data points are identified, they will be discussed with the laboratory and accounted for or corrected. A summary of the data validation findings will be included in each sampling report. The qualifications of the data validator are provided in Appendix D. TUT OO2 O71O GERAGHTY & MILLER, INC. 14 DATA SUBMISSION A data package will be prepared and submitted to the USEPA Region II after the analytical results are received and validated from each quarterly sampling event. The package will include tabulated data, a figure showing the sampling locations, and the complete laboratory data package. The laboratory data package for organic data will include the sample data summary package and the sample data package, as described in the CLP SOW for organics analysis, March 1990, in Exhibit B, Section II, Items C and D. The laboratory data package for inorganic data will include the sample data package as described in the CLP SOW for inorganic analysis, March 1990, in Exhibit B, Section II, Item D. The data validation summaries and CLP data forms from each sampling event will be submitted to the USEPA. PROJECT MANAGEMENT A clear understanding of project team responsibilities and project schedule are essential to the timely and efficient completion of any sampling program. Maintaining open lines of communication between all parties is equally important, particularly for the completion of this potentially problematic sampling and analysis program. The following sections describe project personnel responsibilities, the project schedule, and procedures for notification to the USEPA Region II. PROJECT TEAM RESPONSIBILITIES The project will be overseen by the TEIC Designated Coordinator and will be implemented by qualified representatives of Soil Tech and Geraghty & Miller. Specific project team responsibilities are as follows: TUT GERAGHTY & MILLER. INC 15 Tutu Environmental Investigation Committee The designated coordinator (Ana Gloria Ramos) is responsible for overseeing the implementation of the Administrative Order and will make all final decisions regarding technical matters. The designated coordinator will act as the primary communicator for the respondents and their technical consultants with the USEPA and will review and approve all documents prior to submission. Soil Tech The project coordinator (Jose C. Agrelot) is responsible for the overall technical adequacy of the sampling and the performance of the sampling in conformance with the scope of work. The sampling team leader (Alberto Barrera) is responsible for coordination of each sampling event, management of field activities, conformance of sampling activities, and conformance of sampling activities with the scope of work. The health and safety officer (Alberto Barrera) is responsible for implementing the specific health and safety directives detailed in the HASP. The HASP (Appendix B) has been prepared to address several tasks that will be performed in a future site investigation. For the purposes of the SAMP field work refer to Task 4: Evacuation and Sampling of Wells in Appendix B. The sampling field team (Fernando Zavala and Alberto Barrera) are responsible for implementating sampling activities in accordance with the scope of work. The project electrician (Guillermo Gonzalez) is responsible for determining safe usage of well pumps and for making adjustments to existing systems, where applicable, for sampling activities. ! V .^ .'l •''•'•• TUT °°J-' GERAGHTY & MILLER. INC 16 Geraghtv & Miller The project officer (Daniel Nachman) is responsible for the overall technical adequacy of the SAMP and conformance with the scope of work. The project manager (Thomas V. Danahy) is responsible for coordinating the sampling, analysis, and data validation functions of the project and for overseeing preparation of the quarterly reports. The project QA/QC manager (Juan Garcia) is responsible for providing independent review of project documents and reports. The data validator (Cameron S. Dunnan) is responsible for reviewing the laboratory data for compliance with the quality objectives and for preparing the data validation findings. PROJECT SCHEDULE Three sampling events have been implemented at the Tutu Wells Site from September 1990 to June 1991 in accordance with the original SAMP (Geraghty & Miller, Inc. 1990). Data validation and report preparation were performed prior to each subsequent sampling event. Due to slow laboratory turnaround, data validation and final report preparation has previously required approximately 3 months to complete. Geraghty & Miller and Enseco will attempt to limit this process to no more than 2 months. This revised SAMP will become effective with the fourth sampling event which is scheduled to begin October 1, 1991. The fifth sampling event is tentatively scheduled for the week of February 10, 1991. GERAGHTY & MILLER. INC. 17 The analytical data will be reviewed after each sampling event to determine the appropriateness of reductions of sampling frequency or complete determination of sampling activities. If sampling reduction or termination of sampling certain wells is warranted, such a proposal will be submitted to the USEPA for approval. If any two successive sampling events indicate that constituents of concern are not detected at concentrations above the detection limit, a proposal to terminate sampling will be submitted to the USEPA for approval. The results of each sampling event will be available for data validation approximately 4 to 5 weeks after the samples are received by the laboratory. The analytical results will be submitted to the USEPA Region II within 4 to 6 weeks after the receipt of all of the laboratory data. NOTIFICATION TO USEPA The designated coordinator will notify the USEPA Region II of all on-site activities to be performed at least 15 days in advance. Any significant deviations in the work plan will be communicated to the USEPA Region II verbally and in writing within 5 days. *PR00801/S«mp2.Rev GERAGHTY & MILLER. INC. 18 REFERENCES Geraghty & Miller, Inc. 1990. Sampling, Analysis, and Monitoring Plan for Wells, Tutu Wells Site, St. Thomas,, U.S. Virgin Islands. Prepared for Tutu Environmental Investigation Committee, September 1990. Geraghty & Miller, Inc. 199la. First Sampling Report, September 1990, Tutu Wells Site, St. Thomas, U.S. Virgin Islands. Prepared for Tutu Environmental Investigation Committee, January 1991. Geraghty & Miller, Inc. 1991b. Second Sampling Report, February 1991, Tutu Wells Site, St. Thomas, U.S. Virgin Islands. Prepared for Tutu Environmental Investigation Committee, May 13, 1991. Geraghty & Miller, Inc. 1991c. Third Sampling Report, June 1991, Tutu Wells Site, St. Thomas, U.S. Virgin Islands. Prepared for Tutu Environmental Investigation Committee, September 1991. USEPA 1988. Methods for the Determination of Organic Compounds in Drinking Water, Revision 3.0. EPA-600/4-88/039, as Modified by the Methodology Described in Appendix A. USEPA 1990a. USEPA Contract Laboratory Program Statement of Work for Organic Analysis, Multi-Concentration, Revision December 1990 and February 1991. USEPA Contract Laboratory Program, Washington, D.C. USEPA 1990b. USEPA Contract Laboratory Statement of Work for Inorganic Analysis, Multi- Media, Multi-Concentration. USEPA Contract Laboratory Program, Washington, D.C. «>R00801/S«iip2.Rev •' >' 1 5 GERAGHTY c> MILLER. INC TABLES GERAGHTY & MILLER. INC. Table 1. Summary of Proposed Sampling and Analysis Effort, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, US Virgin Islands. Number of (a) Matrix Ground Water Residential Well Samples 25 Field Replicate Samples 2 Equipment (b) Blank Samples 3 Trip (c) Blank Samples Water (d) Blank Total (e) Samples Samples 1 35 Test TCL Parameters (f) VOCs (Modified EPA Method 524.2 (g)),TCL semivolatiles and pesticides, TAL metals and cyanide. Total 25 2 3 4 4 4 1 39 TCL VOCs (Modified EPA Method 524.2) (g). VOC Volatile Organic Compounds TCL Target Compound List. TAL Target Analyte List. (a) One matrix spike/matrix spike duplicate (MS/MSD) will be analyzed for organics for every 20 ground-water samples analyzed for organics. One duplicate and one spike sample will be analyzed for metals and cyanide for every 20 ground-water samples analyzed for metals and cyanide. (b) One equipment blank sample will be collected on every day that sampling occurs for which sampling equipment is used. Accordingly, the number listed is an estimate. Equipment blank samples will be analyzed for every parameter analyzed for in ground-water samples on that day. (c) One trip blank sample will be submitted for laboratory analysis on every day that sampling occurs. Accordingly, the number listed is an estimate. (d) One blank sample of the water to be used for equipment blanks and decontamination will be analyzed each quarter. The water blank sample will be analyzed for every parameter analyzed for that quarter. (e) The total number of samples is an estimate because the number of blank samples is estimated. (f) Sampling and analysis will be performed as summarized in this table on an annual basis. For the three remaining quarterly sampling events each year, samples will be analyzed for VOCs (using EPA Method 524.2), and for other TCL or TAL analyte groups if such compounds occur above the detection limit. However, if other TCL or TAL concentrations above the detection limit do not pass data validation criteria or if there is reason to suspect that blank or laboratory contamination or matrix interferences have caused the detection of these constituents in the samples, then those samples will not be analyzed for the other TCL or TAL analyte groups in the three remaining quarterly sampling events each year. (g) EPA Method 524.2 analysis will be modified in accordance with the methodology described in Appendix A. PR00801/TABLWK1 GERAGHTY & MILLER, INC. Table 2. Project Analyte List and Contract Required Quantitation Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Target Compound List CAS Number Quantitation Limits* Water (ug/L) VOLATILES 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. ug/L * Chloromethane Bromomethane Vinyl chloride Chloroethane Methylene chloride Acetone Carbon Bisulfide 1,1-Dichloroethene 1,1- Dichloroe tha ne 1,2-Dichloroethene (total) Chloroform 1,2-Dichloroethane 2-Butanone 1,1,1-Trichloroethane Carbon tetrachloride Bromodichloromethane 1 ,2 — Dichloropropane cis — 1 3 - Dichloropropene Trichloroethene Dibromochloromethane 1,1,2-Trichloroe thane Benzene trans - 1 3 - Dichloropropene Bromoform 4 —Methyl - 2 - pentanone 2-Hexanone Tetrachloroethene Toluene 1,1,2 ,2-Tetrachloroethane Chlorobenzene Ethyl benzene Styrene Xylenes (Total) Micrograms per liter. Snerifir nnantitatinn limits are hiohl 74-87-3 74-83-9 75-01-4 75-00-3 75-09-2 67-64-1 75-15-0 75-35-4 75-34-3 540-59-0 67-66-3 107-06-2 78-93-3 71-55-6 56-23-5 75-27-4 78-87-5 10061-01-5 79-01-6 124-48-1 79-00-5 71-43-2 10061-02-6 75-25-2 108-10-1 591-78-6 127-18-4 108-88-3 79-34-5 108-90-7 100-41-4 100-42-5 1330-20-7 v matrix— denenrtent The aui 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 imitation limits listed are nrnvirlerl for guidance and may not always be achievable. PR00801/tab2 UT GERAGHTY & MILLER. INC Table 2. Project Analyte List and Contract Required Quantitation Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Island. Quantitation Limits* Target Compound List CAS Number Water SEMIVOLATILES 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. 44. 45. 46. Phenol bis (2-Chloroethyl) ether 2-Chlorophenol 1 3 — Dichlorobenzene 1 ,4 — Dichlorobenzene Benzyl alcohol 1,2-Dichlorobenzene 2-Methylphenol 2,2 - Oxybis( 1 - chloropropoane) 4-Methylphenol N-Nitroso-di-n-dipropylamine Hexachloroethane Nitrobenzene Isophorone 2-Nitrophenol 2,4-Dimethylphenol Benzoic acid bis (2-Chloroethoxy) methane 2-4-Dichlorophenol 1 ,2,4 — Trichlorobenzene Naphthalene 4-Chloroaniline Hexachlorobutadiene 4-Chloro-3-methylphenol(para-chloro-meta-cresoI) 2-Methylnaphthalene Hexachlorocyclopentadiene 2,4,6— Trichlorophenol 2,4,5— Trichlorophenol 2— Chloronaphthalene 2-Nitroaniline Dimethylphthalate Acenaphthylene 2,6 - Dinitrotoluene 3— Nitroaniline Acenaphthene 2,4-Dinitrophenol 4-Nitrophenol Dibenzofuran 2,4-Dinitrotoluene Diethylphthalate 4-Chlorophenyl-phenyl ether Fluorene 4 -Nitroaniline 4,6 - Dinitro — 2 — methylphenol N-Nitrosodiphenylamine 4 - Bromophenyl - phenylether 108-95-2 11-44-4 95-57-8 541-73-1 106-46-7 100-51-6 95-50-1 95-48-7 108-60-1 106-44-5 621-64-7 67-72-1 98-95-3 78-59-1 88-75-5 105-67-9 65-85-0 111-91-1 120-83-2 120-82-1 91-20-3 106-47-8 87-68-3 59-50-7 91-57-6 77-47-4 88-06-2 95-95-4 91-58-7 88-74-4 131-11-3 208-96-8 606-20-2 99-09-2 83-32-9 51-28-5 100-02-7 132-64-9 121-14-2 84-66-2 7005-72-3 86-73-7 100-01-6 534-52-1 86-30-6 101-55-3 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10 10 10 10 10 10 50 10 50 10 10 10 50 10 50 50 10 10 10 10 10 50 50 10 10 * Specific quantitation limits are highly matrix dependent. The quantitation limits listed are provided for guidance and may not always be achievable. #PR00801/tab2a TUT' OO2 O719 GERAGHTY & MILLER. INC. Table 2. Project Analyte List and Contract Required Quantitation Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Target Compound List CAS Number Quantitation Limits* Water SEMIVOLATILES (Continued) 47. 48. 49. 50 51. 52. 53. 54. 55. 56. 57. 58. 59. 60. 61. 62. 63. 64. 65. 66. Hexachlorobenzene Pentachlorophenol Phenanthrene Carbazole Anthracene Di-n-butylphthalate Fluoranthene Pyrene Butylbenzylphthalate 33— Dichlorobenzidine Benzo(a)anthracene Chrysene bis(2-Ethylhexyl)phthalate Di-n-octylphtnalate Benzo(b)fluoranthene Benzo(k)Quoranthene Benzo(a)pyrene Indeno( 1,23 -cd)pyrene Dibenz(a,h)antracene Benzo(g4iJ)perylene 118-74-1 87-86-5 85-01-8 86-74-8 120-12-7 84-74-2 206-44-0 129-00-0 85-68-7 91-94-1 56-55-3 218-01-9 117-81-7 117-84-0 205-99-2 207-08-9 50-32-8 193-39-5 53-70-3 191-24-2 10 50 10 10 10 10 10 10 10 20 10 10 10 10 10 10 10 10 10 10 * Specific quantitation limits are highly matrix dependent. The quantitation limits listed are provided for guidance and may not always be achievable. #PR00801ATab2b GERAGHTY & MILLER. INC. Table 2. Project Analyte List and Contract Required Quantitation Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Quantitation Limits* Target Compound List CAS Number Water PESTICIDES 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18 19. 20. 21. alpha -BHC beta-BHC delta -BHC gamma -BHC (Lindane) Heptachlor Aldrin Heptachlor epoxide Endosulfan I Dieldrin 4,4'-DDE Endrin Endosulfan II 4,4-DDD Endosulfan sulfate 4,4'-DDT Methoxychlor Endrin ketone Endrin Aldehyde alpha -Chlordane gamma -Chlordane Toxaphene 319-84-6 319-85-7 319-86-8 58-89-9 76-44-8 309-00-2 1024-57-3 959-98-8 60-57-1 72-55-9 72-20-8 33213-65-9 72-54-8 1031-07-8 50-29-3 72-43-5 53494-70-5 7421-36-3 5103-71-9 5103-74-2 8001-35-2 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.10 0.10 0.10 0.10 0.10 0.10 0.10 0.5 0.10 0.10 0.5 1.0 Specific quantitation limits are highly matrix dependent. The quantitation limits listed are provided for guidance and may not always be achievable. #PR0080Vtab2coo GERAGHTY & MILLER. INC Table 2. Project Analyte List and Contract Required Quantitation Limits, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Contract Required* Detection Limit Water Target Analyte List 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. Aluminum Antimony Arsenic Barium Beryllium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Mercury Nickel Potassium Selenium Silver Sodium Thallium Vanadium Zinc Cyanide 200 60 10 200 5 5 5000 10 50 25 100 3 5000 15 0.2 40 5000 5 10 5000 10 50 20 10 The contract required detection limits (CRDLs) are the instrument detection limits obtained in pure water that must be met using the procedure in the CLP SOW for organics analysis, March 1990, Exhibit E. The detection limits for samples may be considerably higher depending on the sample matrix. #PR00801/tab2c GERAGHTY & MILLER. INC. Table 3. Precision, Accuracy, and Completeness Objectives, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Fraction Matrix Spike Compound/Element VOA 1,1-Dichlorethene VOA Trichlorethene VOA Chlorobenzene VOA Toluene VOA Benzene SV-BN 1,2,4-Trichlorobenzene SV-BN Acenaphthene SV-BN 2,4-Dinitrotoluene SV-BN Pyrene SV— BN N-Nitroso-di-n-propylamine SV-BN 1,4-Dichlorobenzene SV— A Pentachlorophenol SV-A Phenol SV-A 2-Chlorophenol SV-A 4-Chloro-3-methylphenol SV-A 4-Nitrophenol Pest. Lindane Pest. Heptachlor Pest. Aldrin Pest. Dieldrin Pest. Endrin Pest. 4,4'- DDT CN CN VOA Volatile Organic Analysis. Water* %R 61-145 71-120 75-130 76-125 76-127 39-98 46-118 24-96 26-127 41-116 36-97 9-103 12-110 27-123 23-97 10-80 56-123 40-131 40-120 52-126 56-121 38-127 75-125 %RPD 14 14 13 13 11 28 31 38 31 38 28 50 42 40 42 50 15 20 22 18 21 27 20 Completeness 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% SV-BN Semrvolatile Base-Neutral Extractables. SV— A Semivolatile Acid Extractables. Pest. Pesticides. * These limits are for advisory purposes % R Percent Recovery. % RPD Relative Percent Difference. only (as noted in CLP SOW 3/90). #PR00801A"AB3.WK1 TUT GERAGHTY & MILLER. INC Table 4. Requirements for Sample Containers, Preservation, and Holding Times, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Test Parameter Number of Containers Container Per Sample Preservation Maximum Holding Time Volatile Organic Compounds 2 (c) Semivolatile Organic Compounds 4 (c) and Pesticides 40-Milliliter glass with Teflon-lined septum and open—hole caps 1-liter glass, amber with teflon- lined cap Cool to 4 degrees C l:lHCltopH<2 Cool to 4 degrees C 14 days from time of sampling, (a) 7 days from time of sampling to extraction; 40 days after extraction. Metals Cyanide 1- liter polyethylene with polyethylene cap 1-liter polyethylene with polyethylene cap Cool to 4 degrees C HNO topH<2 Cool to 4 degrees C NaOHtopH>12 180 days from time of sampling, (b) 14 days from time of sampling. NA Not applicable; will be tested in the field immediately upon sample retrieval using field instruments. (a) If sample acidification causes effervescence, the sample will not be acidified but will be cooled to 4 degrees C. In this event, the holding time is 7 days from the time of sampling. (b) For mercury, the holding time is 28 days from the time of sampling. (c) Triple volume will be collected for matrix spike/matrix spike duplicate (MS/MSD) analysis for organics. (d) Double volume will be collected for matrix spike/matrix duplicate (MS/MD) analysis for inorganics. GERAGHTY & MILLER, INC. Table 5. Summary of Analytical Methods, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Test Parameter Method Reference Method Description TCL Volatile Organic Compounds TCL Semivolatile Organic Compounds TCL Pesticides TAL Metals Modified 524.2 (a) CLP SOW, 3/90 (b) CLP SOW, 3/90 (b) CLP SOW, 3/90 (c) Cyanide CLP SOW, 3/90 (c) Temperature, pH, Specific Conductance N/A Purge and trap, gas chromatography/mass spectrometry. Solvent extraction, gas chromatography/mass spectrometry. Solvent extraction, gas chromatography/electron capture detection. Inductively coupled plasma/graphite furnace atomic absorption spectrophotometry/ manual cold vapor method. Manual distillation/manual spectrophotometric determination. Tested in the field immediately upon sample retrieval using field instruments. TCL Target Compound List. TAL Target Analyte List. NA Not applicable. (a) USEPA 1988. Methods for the Determination of Organic Compounds in Drinking Water, Revision 3.0. EPA -600/4-88/039, as modified by the methodology described in Appendix A. (b) USEPA 1990a. USEPA Contract Laboratory Program Statement of Work for Organic Analysis, Multi-Media, Multi-Concentration, Revision December 1990 and February 1991. USEPA Contract Laboratory Program, Washington, DC. ) USEPA, 1990b. USEPA Contract Laboratory Statement of Work for Inorganic Analysis, Multi-Media, Multi-Concentration. USEPA Contract Laboratory Program, Washington, DC. 'R00801/TAB5.WK1 GERAGHTY & MILLER, INC. Table 6. Surrogate Spike Control Limits*, Tutu Wells Site Sampling, Analysis, and Monitoring Plan, St. Thomas, U.S. Virgin Islands. Fraction Surrogate Compound Water %R VGA d4-l,2-Dichloroethane VOA 4—Bromofluorobenzene VOA d8-Toluene SV-BN d5-Nitrobenzene SV-BN d4-l,2-Dichlorobenzene SV-BN d!4-Terphenyl SV-BN 2-Fluorobiphenyl SV-A d4-2-Chlorophenol SV-A 2-Flurophenol SV-A 2,4,6-Tribromophenol SV-A d6-Phenol Pest. Tetrachloro-m-xylene Pest. Decachlorobiphenyl 76-114 86-115 88-110 35-114 20-130** 33-141 43-116 20-130** 21-110 10-123 10-94 60-150** 60-150** * From CLP SOW dated 3/90. ** Laboratory optional surrogate only; no action limits at this time. VOA Volatile Organic Analysis. SV-BN Semivolatile Base-Neutral Extractables. SV-A Semivolatile Acid Extractables. Pest. Pesticides. % R Percent Recovery. *PR0080irTAB6.WKl GERAGHTY & MILLER. INC. FIGURES TUT 002 0727 GERAGHTY & MILLER. INC. 05*00' 18"2O' — 18°17 05"06' <H°r.6' 64° , , Qrool ^,_JS1. Jomos I. 'f^x STUDY AREA, TUTU WELLS SITE SAMPLING, ANALYSIS, AND MONITORING PLAN, ST. THOMAS, U.S. VIRGIN ISLANDS TEIC Geraghty & Miller. Inc. M. DANAHY i r> •• i~Sc«~ OAHAHY sou SHOWN 1 ^fe.^^^^%% LEGEND • RESDENTIAL WELL A BRYAN B DEDE C DEMITRI D DENCH E1 DEVCONI E2 DEVCON n (ALTERNATE) E3 DEVCON ZEE F1 EGUN I F2 EGUN n F3 EGLIN HI G FOUR WINDS I H FOUR WINDS H H GASSETT 12 HARTMAN TJ 13 HARTMAN HI J HARVEY K LaPLACE L LEONARD M LOCKHART (ALTERNATE) N MATTHIAS O RAMSEY P RODRIGUES Q SMITH R STEELE S TLLETT T1 VHAI T2 VIHAH (ALTERNATE) T3 VHATH T4 VWAE (ALTERNATE) WELL SAMPLING LOCATIONS, TUTU WELLS SITE SAMPLING ANALYSIS, AND MOMTORWG PLAN, ST. THOMAS, US. VIRGN ISLANDS [ TEIC SOURCE: USGS QUADRANGLE EASTERN ST.THOMAS.V.U1954) Geraghty & Miller. Inc. JUT 1 200 400 SCALE FEET V I M A SITE PLAN TUTU WELLS SITE SAMPLING, ANALYSIS, AND MONITORING PLAN, ST. THOMAS, US. VIRGIN ISLANDS Gcrashtv <fe MillerJnc. DAMAHY 1" PAOULA QABAHT 9/91 ^ Enseco * Commt Comnnv PROJECT I Enseco East INTERNAL CHAIN OF CUSTODY SAMPLE f STORAGE LOCATION Gas Soil Solid Solid-Waste Aqueous Aqueous-waste Sludge Oil TESTS REQUESTED: (Bottle numbers assigned:) ORGANICS ORGANICS PREP VO*** DAI_ ABN HERBICIDES PEST/PCB TPHC-IR ' FINGERPR._ OIL/GREASE. COMPOSITING RAOIOLOGICA1T % WATER___I OTHER ___ INORGANICS METALS PREP METALS___ CORROS___ IGNIT/FLASH REACT CN/S_ EPTOX METS_ EPTOX ORG_ TCLPV____ TCLPC____ TCLPH INORGANICS WET CHEM ALKALINITY ACIDITY *BOD__~~ CHLORIOE___ *RES.CHLORINE COD_____" *COLOR/OOOR_ CONDUCTIVITY ±6 INORGANICS WET CHEM AMMONIA(NH3) *NITRATE(N03)~ *NITRITE(N02)~ N03-N02___" TON** TKN ————— *pH TOT.CYAN IDE__ *DISS.02_____ *FECAL COL I FORM FLUORIOE____ *MBAS *ORTHO PHOS TOTAL PHOS PHENOL SULFATETSDTT *SULFITE(S03)' SULFIDE(S02)' *SET. SOLIDS ' TS_____~ TSS TDS TOC TOX—————— *TOTAL CGLIKJRM *TURBIDITY *** Sample aliquots for volatile organic analysis are stored in the GC/MS refrigerat **TON (Total organic nitrogen): Ammonia and Total Kjheldhal Nitrogen (TKN) is analyzed. The difference of the 2 parameters is TON. * Indicates 'Short Holding Time' parameter RELINQUISHED BY: RECEIVED BY: DATE TIME REASON FOR TRANSFER BOTTLE CODE •rut 002 0731 MILLER, INC. Environmental Strncts ENSECO INCORPORATED INTERNAL CHAIN OF CUSTODY FIGURE 4 tnaeca tost A »( i Co tpiny SAMPLE CUSTODY PROJECT NO. H —— i M c hj SAMPLE NUMBERS :! STORAGE LOCATION BOTlLE CODE ANALYSIS INITtAL 10 LAB DA IE / TIME - . S.CONIROL INITIAL 1 RETURN DATE / TIME f S.CON1RO INITIAL ^KGERAGHTY ENSECO INCORPORATED FIGURE ^^Ji-S,!S,9; SAMPLE CUSTODY FORM 5 APPENDIX A ADDITIONAL QUALITY CONTROL REQUIREMENTS FOR METHOD 524.2 ANALYSIS GERAGHTY & MILLER. INC. APPENDIX A ADDITIONAL QUALITY CONTROL REQUIREMENTS FOR METHOD 524.2 ANALYSIS 1. The parameter list for this site is the TCL. All method requirements must be followed for these compounds. 2. All samples and reanalyses are to be analyzed within holding times (i.e., 7 days from date of collection if sample is unpreserved; 14 days from date from collection when sample is preserved). 3. Sample batch is 20 samples maximum. 4. Detection limit determination must be performed for all analytes prior to start of sample collection. The lab must use the Method Detection Limit (MDL) determination procedures stated in Section 10.3 of Method 524.2. All results must be provided to Geraghty & Miller's Rochelle Park, New Jersey office. Include the following for each analyte: concentration spiked into blank water, concentrations obtained for each seven or more replicates, standard deviation, mean concentration of replicates, and the student t value used in the calculation. This information must enable the reviewer to regenerate the laboratory's calculations of the detection limit. 5. A five point initial calibration must be performed preceding sample analysis. It has been shown that the following five concentrations often yield results which meet the suggested QC criteria: 4, 10, 20, 30, and 40 ug/1. The lab may use these or may extend their calibration range, however, all QC criteria must be adhered to for each analyte. Previously, trichloroethene was detected in site samples up to 1500 parts per billion (ppb). 6. The continuing calibration standard must be analyzed prior to sample analysis and once per 12 hours in order to verify a valid initial calibration. The absolute areas of the quantitation GERAGHTY & MILLER. INC. A-2 ions of the internal standard and surrogates must not have decreased more than 30% from the areas measured in the most recent continuing calibration check, or by more that 50% from the areas measured during the initial calibration (per Section 9.3.4 of Method 524.2). The response factor (RF) for each analyte and surrogate in the continuing calibration check must be within 30% of the mean value measured in the initial calibration (per Section 9.3.5 of Method 524.2). If this criteria is exceeded for the parameters of concern at the Tutu site, a new calibration must be performed. The parameters of concern at the Tutu site include trichloroethene, tetrachloroethene, dichloroethene, vinyl chloride, benzene, toluene, ethyl benzene and xylenes. Cadmium is also a parameter of concern in the Eglin well samples. 7. A laboratory fortified blank at a concentration of 1 ug/1 for each analyte must be analyzed immediately following each continuing calibration. The accuracy for this standard must be between 80% - 120% recovery. (Exception for methylene chloride, acetone, 2-butanone and 2-hexanone, the accuracy must be between 50 - 150%). If this accuracy cannot be achieved, the problem must be located and corrected, then the instrument must be recalibrated prior to sample analysis. 8. The Mass Spectrometer (MS) tune, using bromofluorobenzene (BFB), must be verified at the beginning of each 12 hour period of analysis and all samples must be injected within this 12 hour period. 9. A lab method blank must be analyzed prior to the samples. The lab method blank must be shown to be free of contamination. Failure to obtain method blank values less than 1 ug/1 requires that all samples prepared with that method blank be reprepared and reanalyzed for the affected parameters. Exceptions for blank values for methylene chloride (less than 2 ug/L), and ketones (less than 5 ug/L) will be allowed. 10. All samples, blanks, duplicates, and calibration standards must be spiked with the three surrogates and three internal standard compounds stated in Organic Low Medium (OLM) 01 TUT 002 O / o , GERAGHTY & MILLER. INC A-3 (3/90 CLP SOW) at the specified concentrations. Reanalysis is required if one or more percent recoveries (%RS) as stated in the OLM 01 (3/90 CLP SOW) are exceeded. 11. The primary and secondary ions listed in the OLM 01 (3/90 CLP SOW) for organics must be used for identification of the TCL parameters not listed in Method 524.2. 12. A laboratory generated mass spectrum must be provided for all compounds detected above and below the detection limit. 13. All calibration and analytical procedures given in Method 524.2 whether presented as optional or required, must be followed unless stated otherwise in this Appendix. 14. Up to ten volatile organic compounds (not on the TCL) of greatest apparent concentration shall be tentatively identified via a forward search of the NBS mass spectral library as described in the OLM 01 (3/90 CLP SOW) for organics. Only tentatively identified compounds (TICs) with a peak area >40% of the nearest internal standard are to be reported. 15. If the USEPA Regional Project Manager (RPM) requests the Monitoring and Management Branch (MMB) to audit a certain percentage of the data validation effort of Geraghty & Miller, and EPA-CLP type deliverables package must be made available to the MWB. This will also include a detailed example calculation that clearly demonstrates the manner in which the final results were derived. Where applicable, each component of the calculation must be explained (eg. if the calculation includes a dilution factor, it must be clear how and why each dilution occurred). The laboratory must supply any and all information required to reproduce, during an EPA data validation, all results reported. GERAGHTY & MILLER. INC. APPENDIX B HEALTH AND SAFETY PLAN TUT 002 07.- GERAGHTY & MILLER. INC HEALTH AND SAFETY PLAN TUTU SERVICE STATION INVESTIGATION ST. THOMAS, U.S. VIRGIN ISLANDS September, 1991 Prepared for Tutu Environmental Investigation Committee Prepared by Geraghty & Miller, Inc. Environmental Services 201 West Passaic Street Rochelle Park, New Jersey 07662 (201) 909-0700 GERAGHTY & MILLER. INC. CONTENTS Page INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 BASIS FOR HEALTH AND SAFETY DIRECTIVES . . . . . . . . . . . . . . . . . . . . . . . . 3 INVESTIGATION TASKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 POTENTIAL HAZARDS EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 HNU CALIBRATION PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 OVA CALIBRATION PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ACTION LEVEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 LEVELS OF PROTECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Task 1: Soil Sampling of Borings and Monitoring Wells . . . . . . . . . . . . . 9 Task 2: Performance of Borehole Geophysical Surveys . . . . . . . . . . . . . . 9 Task 3: Well Installation and Development of Monitoring Wells ..... 10 Task 4: Evacuation and Sampling of Monitoring Wells . . . . . . . . . . . . . 10 Task 5: Performance of a Constant Rate Pumping Test . . . . . . . . . . . . 10 Task 6: Free Product Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Task 7: Potential Free Production Recovery . . . . . . . . . . . . . . . . . . . . . 11 PERSONAL PROTECTIVE EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Level D Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Level C Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 WORK ZONES AND SITE CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 EXCLUSION ZONES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 CONTAMINATION REDUCTION ZONES . . . . . . . . . . . . . . . . . . . . . . . . . 14 THE SUPPORT AREA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 GENERAL WORK PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 GENERAL WORK RULES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 DRILLING OPERATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 GERAGHTY & MILLER, INC. CONTENTS (Continued) DECONTAMINATION PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 PERSONNEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 SAMPLE CONTAINERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 EMERGENCY RESPONSE PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 HEALTH MONITORING AND FIELD PROTOCOLS . . . . . . . . . . . . . . . . . . . . . . 21 HEALTH MONITORING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 MOTOR VEHICLE HAZARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 HEAT STRESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 BASIC TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 SITE-SPECIFIC TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 TAILGATE SAFETY MEETINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 TABLES 1. Maximum Concentrations of Previously Detected Volatile Organic Compounds, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 2. Current Occupational Airborne Contaminants Standard and Guidelines, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 3. Emergency Telephone Numbers, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. GERAGHTY & MILLER. INC. FIGURES 1. Health and Safety Review Form, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 2. Turpentine Run Basin, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 3. Site Plan, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 4. Utilities and Structures Checklist, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 5. Route to the Hospital, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 6. Injury Report Form, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 7. Vehicle Accident Report Form, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 8. Tailgate Safety Meeting Form, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. 9. Field Audit Checklist, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. • V U T 002 0741 GERAGHTY & MILLER, INC. HEALTH AND SAFETY PLAN TUTU SERVICE STATION INVESTIGATION ST. THOMAS, U.S. VIRGIN ISLANDS INTRODUCTION This Health and Safety Plan (HASP) has been prepared by Geraghty & Miller, Inc. for the Tutu Service Station Investigation to be conducted by the Tutu Environmental Investigation Committee (TEIC) at Anna's Retreat, St. Thomas, U.S. Virgin Islands (USVI). TEIC is comprised of representatives of Texaco Caribbean Inc. (Texaco) and Esso Virgin Islands, Inc. (Esso). The Tutu Service Station Investigation will be performed in accordance with the scope of work detailed in the Tutu Service Station Investigation Work Plan, St. Thomas, USVI (Geraghty & Miller 1991a). The HASP has been prepared for the purpose of providing protocols that will minimize the potential for exposure to chemical constituents and for accidental injury to workers during investigatory activities. Anyone else such as responding parties', contractors, subcontractors, clients and visitors should review and adhere to this HASP. Copies of the HASP will always be onsite. All workers entering the site must first review the HASP and sign the Health and Safety Review Form (Figure 1). BACKGROUND The Tutu site is located in the upper Turpentine Run basin in east central St. Thomas. Various commercial establishments line the major roads in the area. These establishments include the Texaco Tutu service station at the intersection of Highways 38 and 384 and the Esso Tutu service station on Highway 38 (Figure 2). Private homes and multi-family housing, such as the Virgin Islands Housing Authority (VIHA) buildings, generally occupy the less heavily traveled roads. Both the Texaco Tutu service station and the Esso Tutu service station are retail outlets for gasoline and private mechanical servicing of automobiles. Additionally, the Texaco Tutu service station sells diesel fuel. GERAGHTY & MILLER. INC 2 A brief reconnaissance of the area, performed by Geraghty & Miller in September 1990, revealed that there are other establishments which represent potential sources of constituents of concern to soil and ground water. These establishments include but may not be limited to the following: A Jeep dealership and repair shop. The Ramsey Motor dealership and repair shop. The LAGA building, which formerly housed a textile processing operation. Tillett Garden, where silk screening and pottery manufacturing and glazing are performed. O'Henry dry cleaners. The paint store. The Fire Station. The Vitelco facility. Other small repair shops located on Highway 38. The sanitary/storm sewer line(s). The locations of these establishments, with the exception of the sanitary/storm sewer line(s), are shown on Figure 3. Sampling and laboratory analysis of residential and commercial wells in the area by the U.S. Environmental Protection Agency (USEPA) Technical Assistance Team (TAT) in 1987 and 1988 indicated the presence of some volatile organic compounds (VOCs) in ground water. In September 1990, February 1991, and June 1991, sampling and analysis of supply wells in the Tutu area was conducted by Geraghty & Miller and Soil Tech in accordance with a USEPA-approved work plan (Geraghty & Miller 1991b; 1991c; 1991d). GERAGHTY & MILLER. INC. BASIS FOR HEALTH AND SAFETY DIRECTIVES INVESTIGATION TASKS The objectives of the Tutu Service Station Investigation are to delineate the potential sources, the horizontal and vertical extent, and potential migration pathways of petroleum hydrocarbon products in soil and ground water in the vicinity of Route 38 within the Tutu Wells Site. The USEPA is also concerned about chlorinated hydrocarbon compounds (i.e., tetrachloroethene and its breakdown products) which have been detected in ground water in the Tutu area (Geraghty & Miller 1991b; 199Ic; 199Id). To assist the USEPA in evaluating the Tutu area, the TEIC has agreed to install deep monitoring wells (i.e., screened below the water table) and analyze all soil and ground-water samples for target compound list (TCL) volatile organic compounds (VOCs), which include petroleum hydrocarbon constituents and chlorinated hydrocarbons. To achieve this, the following tasks will be performed as a part of the investigation: Task 1: Soil sampling of borings and monitoring wells. Task 2: Performance of borehole geophysical surveys. Task 3: Well installation and development of monitoring wells. Task 4: Evacuation and sampling of monitoring wells. Task 5: Performance of a pumping test. Task 6: Free product investigation. Task 7: Potential free product recovery. A detailed discussion of these tasks are presented in the Work Plan (Geraghty & Miller 1991a). GERAGHTY & MILLER, INC. POTENTIAL HAZARDS EVALUATION Physical hazards which may be encountered during the investigation include those associated with (1) the operation of drilling rigs (2) the proximity of motor vehicle traffic and (3) heat stress. Potential chemical hazards may occur as a result of contact with site constituents of concern. The following exposure pathways have been identified: Dermal contact with ground water, cuttings, and soils, or with equipment which has been in contact with those media. Inhalation of vapors associated with constituents of concern. Ingestion of ground water or soil which contains constituents of concern. Constituents of concern which have been detected in site ground water and soil vapor are provided in Table 1. The time-weighted average (TWA) Threshold Limit Values (TLVs) and Permissible Exposure Limits (PELs) for each constituent are shown in Table 2. AIR MONITORING Air monitoring will be conducted during each field activity to ensure that the crew is adequately protected from potential chemical hazards. A photoionization detector (PID), such as an HNu will be used to detect volatile organic compounds (VOCs) in air in the parts per million (ppm) range. The HNu will be calibrated on a daily basis and all calibration records will be kept on site. If high humidity interferes with the sensitivity of the PID, a flame-ionization detector (FID) equipped organic vapor analyzer (OVA) will be used instead. An OVA will be kept onsite as a back-up for the HNu. To confirm the presence of specific compounds, Draeger tubes and a portable gas chromatograph (GC) will be used. An explosimeter will also be available to detect the presence of flammable/explosive gas. GERAGHTY6? MILLER. INC. !UT °iJ'2 °7"15 HNU CALIBRATION PROCEDURES An HNu Systems Model 81-HW101-100 or Model PI-101 photoionization detector with 10.2 electron-volt lamp will be used on a semi-continuous basis to monitor the breathing zone of workers during drilling and sampling activities. The instrument will be calibrated every day prior to initiating activities. The calibration gas will consist of a mixture of isobutylene and air. The calibration procedure is as follows: o A battery check will be performed to ensure that there is sufficient charge in the battery. o The function switch will be turned to the "standby" position. The "zero adjustment" knob will then be adjusted so that the instrument reading is 0 parts per million (ppm). o Fit the tip of the HNu 8-inch extension probe into the tubing from the calibration gas container. o Open the valve of the calibration gas container until there is a slight flow of gas. o Adjust the span on the HNu so that the instrument reading is the same as the calibration gas concentration. o If the adjusted span setting is below the manufacturer's recommendations, appropriate maintenance will be performed. TUT GERAGHTY & MILLER, INC. 6 Each time the instrument is calibrated the following information will be recorded: serial number of the instrument, time and date, span setting, instrument response, weather conditions, and the name of the person who performed the calibration. OVA CALIBRATION PROCEDURES High humidity may cause reduced sensitivity of the HNu due to condensation of water vapor on the ultraviolet lamp. Exposure of the HNu to abrupt changes in temperature or humidity should be avoided to minimize the effect of condensation. Due to convenient operational handling, the HNu is the preferred field instrument. However, if reduced sensitivity is suspected (i.e., poor detection of known VOC sources or low span setting required for calibration) then the OVA should be utilized. An OVA unit and calibration gas will be kept onsite at all times as an alternative air monitoring device. The OVA will be calibrated as follows: o Open the "H2Tank Valve" and check the reading on the "H@ Tank Pressure" indicator. Approximately 150 psi of pressure is needed for each hour of operation. o Open the "H2 Supply Valve" approximately 1/2 to 1 turn and check the reading on the "H2 Supply Pressure" indicator. The reading should be about 10 PSI o Electronic bias adjustments should be made in accordance with the manufacturer's instructions. o Leave CALIBRATE switch on X10 position and use CALIBRATE ADJUST (zero) knob to adjust meter reading to 4 ppm. GERAGHTY & MILLER, INC. 7 o Place CALIBRATE switch in XI position and, using trimpot R-31 on circuit board, adjust meter reading to 4 ppm. (See Figure 4-1). o Move CALIBRATE switch to X10 position again . Use CALIBRATE ADJUST (zero) knob to adjust meter to a reading of 40 ppm. o Move CALIBRATE switch to X100 position and use trimpot R-33 on circuit board to adjust meter reading to 40 ppm. o Move CALIBRATE switch to X10 position and use CALIBRATE ADJUST (zero) knob to adjust meter reading to zero. o Unit is now balanced from range to range, calibrated to methane, and ready to be placed in normal service. o Depress the ignitor button and listen for the "pop" as the hydrogen ignites. o Introduce a methane sample of known concentration and adjust trimpot R-32 on the circuit board so that the meter reads equivalent to the known sample./ o The OVA is now ready for use. o The OVA will be calibrated every day before use. o The calibration gas will consist of a mixture of methane and air. o The battery power will be checked. o Move the "Instr" switch to the on position and allow five minutes for warm up. TUT 002 O748 GERAGHTY & MILLER. INC. o Turn the "pump" switch to the on position, o Move the "Calibrate: switch to 10X. o Adjust the "Calibrate Adjust" knob so that the instrument meter reading is zero. o Place the instrument in an upright position and check the "sample Flow Rate" indicator. Indication should be approximately 2 units. ACTION LEVEL Based on the existing site history and the maximum level of contaminants detected in ground-water samples, the following action level has been established for upgrading the level of protection for the workers. For each individual task, a PID will be available to determine the presence of VOCs. An action level of 1 ppm above background for a sustained period of five minutes in the worker's breathing zone has been chosen based on the presence of benzene and vinyl chloride. The workers breathing zone will be sampled and analyzed for benzene and vinyl chloride using Draeger tubes. If the Draeger tubes confirm the presence of either benzene or vinyl chloride exceeding 1 ppm, work will be temporarily stopped and continued air monitoring will be performed. If the VOCs are vented and the air monitoring readings are below the action level, work will resume. However, if the levels continue to exceed 1 ppm above background, the level of personal protective equipment (PPE) will be upgraded to Level C. While in Level C protection, if HNu readings exceed 10 ppm above background regular monitoring with Draeger tubes for vinyl chloride will be performed. If the level of vinyl chloride in the breathing zone exceeds 10 ppm, work will stop until the VOCs are vented. Work will resume when the levels fall to less than 10 ppm of vinyl chloride. If total volatile readings exceed 50 ppm for a sustained period exceeding 5 minutes, then workers 1IJT GERAGHTY & MILLER. INC 9 in Level C will stop work and allow the VOCs to vent. Work will resume once total VOCs fall below 50 ppm and vinyl chloride values are below 10 ppm. An action level for flammable/explosive gases will also be used. If the reading on an explosimeter shows 10% lower explosive limit (LEL), the area will be continuously monitored with an explosimeter. If the reading shows 20% LEL, work will stop and the work area will be evacuated. LEVELS OF PROTECTION The anticipated level of personnel protection is discussed for each task to be performed. A description of the personal protective equipment is provided in the next section. Task 1 • Soil Sampling of Borings and Monitoring Wells Level D protection has been selected for this task, based on the current knowledge of contaminant levels. However, if air monitoring results exceed the action level, then the level of protection will be upgraded to level C. Task 2 - Performance of Borehole Geophysical Surveys Level D protection has been selected for this task based on current knowledge of contaminant levels and the fact that this task will cause minimal disturbance to the ground water. However, if the air monitoring indicates that the action level has been exceeded, then the level of personal protective equipment (PPE) will be upgraded to level C. "I'UT GERAGHTY & MILLER. INC. 10 Task 3 - Well Installation and Development of Monitoring Wells Level D protection has been chosen for this task. If, however, the air monitoring results indicate elevated levels of VOC's above 1 ppm for a sustained period of 5 minutes in the breathing zone, then the level of protection will be upgraded to level C with chemical resistant suits. If air monitoring indicates a decrease of VOCs below the action level, the level of protection may be downgraded to level D. Task 4 - Evacuation and Sampling of Monitoring Wells This task will be done in level D of protection, accompanied by air monitoring using a photoionization detector (PID) such as a HNu. If the action level is exceeded, the level of protection will be upgraded to level C. Task 5 - Performance of a Pumping Test Level D has been chosen for this task which will be upgraded to level C whenever the air monitoring indicates that the action level of 1 ppm has been exceeded. Task 6 - Free Product Investigation Level D will be primarily used accompanied by semi-continuous air monitoring if the air monitoring results exceed the set action levels of 1 ppm, the level of protection will be upgraded to level C with a full-face air-purifying respirator and organic vapor cartridges in combination with a particulate filter. GERAGHTY & MILLER. INC. 11 Task 7 - Potential Free Production Recovery This task will be done in level D of personal protective clothing. However, this will be upgraded to level C if the air monitoring shows that the set action level has been exceeded. PERSONAL PROTECTIVE EQUIPMENT Level D and Level C protection are described below. Level D Protection A basic modified Level D work uniform will be worn by all personnel working in on- site areas. This work uniform will consist of the following clothing: o Hard hat o Steel-toed and shanked boots (rubber boots or leather workboots) o Work gloves (when handling site media) o Disposable coveralls (woven Tyvek) for protection of work clothes are optional o Safety glasses, goggles, or face shield (optional) o Disposable ear plugs, noise reduction rating (NRR) of 35 decibels (optional) If there is potential for dermal contact, personnel will wear the following clothing: o Disposable coveralls (woven or chemical-resistant Tyvek suits) taped at the ankles o Inner vinyl gloves and/or outer neoprene or nitrile gloves taped at wrists (when sampling or handling potentially contaminated materials) GERAGHTY & MILLER, INC. 12 Level C Protection o Chemical resistant (Saran or PVC-coated) Tyvek suits taped at the ankles o Inner vinyl gloves and outer nitrile gloves taped at the wrists o Hard hat o Steel-toed and shanked chemical resistant boots (rubber boots or rubber boots over leather workboots) o Full-face respirator with organic vapor cartridges o Safety glasses, goggles, or face shield (optional) The following rules apply to respiratory protection: o Respiratory protection will be in compliance with OSHA, 29 CFR 1910.134. o Only properly cleaned, maintained, National Institute for Occupational Safety and Health (NIOSH)/Mine Safety and Health Administration (MSHA)- approved, positive pressure full-face respirators will be used onsite. o Air-purifying cartridges will be replaced daily at a minimum; immediately upon any signs of breakthrough (odors, physical effects, etc.) or at the Site Safety Officer's direction. o No employee shall be assigned to tasks requiring Level C protection, if based upon the health examination, the physician has determined that the employee will be unable to function normally wearing a respirator or that the safety or health of the employee may be compromised. GERAGHTY 6? MILLER, INC. 13 RESPONSIBILITIES Proper implementation of the HASP and the prevention of injury and exposure of site workers depends upon participation of all project workers. Open communication between site workers, supervisors and managers regarding health and safety issues is essential to the plan. A definition of the responsibilities of the project team with respect to health and safety issues is provided below. The Project Health and Safety Officer is responsible for the technical coordination of the health and safety program including medical and training program requirements, hazard assessments, air monitoring, personal protective equipment, and field implementation. The Project Health and Safety Officer will interact with the Project Manager and the Site Safety Officer concerning any changes in the site characterization and HASP requirements. The Site Safety Officer is responsible for the daily supervision and monitoring of field activities to ensure that all work is performed in accordance with the HASP protocols. The Site Safety Officer reports directly to the Project Health and Safety Officer and will refer all safety-related questions to him. The Site Safety Officer will notify the Project Health and Safety Officer and the Project Manager as soon as possible after any exposure incidents, accidents or emergencies. The Field Team Members are responsible for implementing the HASP under the supervision of the Site Safety Officer. The Project Manager is responsible for ensuring that all project workers abide by the requirements set forth in the HASP. The Project Manager will discuss any changes in the site characterization and health and safety plan requirements with the Project Health and Safety Officer and the Site Safety Officer. GERAGHTY & MILLER. INC. 14 WORK ZONES AND SITE CONTROL EXCLUSION ZONES Exclusion zones are defined as areas where the potential exists for worker exposure to contaminated materials. Exclusion zones will be designated by the Site Safety Officer based on the guidelines in this plan. Movement into and out of these zones will be controlled. Personnel entering or working within these zones will wear the designated protective equipment and perform environmental monitoring. Personnel and equipment exiting these zones will be decontaminated in accordance with the procedures described in this plan. All personnel working on-site areas outside of the Support Area will be required to wear a basic modified Level D work uniform. Exclusion Zones within which additional protective clothing and/or environmental monitoring may be required include a minimum of 20 feet around all drilling and sampling activities. CONTAMINATION REDUCTION ZONES Contamination reduction zones will be delineated by the Site Safety Officer for personnel and equipment. Decontamination of personnel and equipment will be performed in these zones. Personnel will wear appropriate Level D clothing while decontaminating equipment. Movement into and out of these zones will be controlled. THE SUPPORT AREA The support area is considered a clean area where no special protective gear is required. The support area will be delineated in an area considered to be free of contamination. TUT 002 0/bs GERAGHTY & MILLER. INC. 15 Access to controlled work areas shall be limited to authorized persons. Visitors must present proper identification and certification of training, and comply with all aspects of the HASP when in these areas. GENERAL WORK PRACTICES GENERAL WORK RULES General work rules to be employed on-site are as follows: o Field work will be conducted only during daylight hours unless adequate lighting is provided. o No eating, drinking, smoking, or any practice that increases the probability of hand-to-mouth transfer and ingestion of material, will be allowed in Exclusion or Contamination Reduction Zones. Smoking materials (matches, lighters) and other ignition sources will be forbidden in these zones. o Contact lenses will not be worn in Exclusion or Contamination Reduction Zones. All field personnel requiring corrective lenses must provide their own prescription glasses and lenses which may be fitted into the respirator masks. o No jewelry which interferes with protective clothing fit or respirator seals will be worn. o No beards, sideburns, or mustaches will be allowed which interfere with respirator mask seals. The Site Safety Officer will determine if facial hair presents an interference. Respirator mask seals will be checked by positive and negative pressure tests by each wearer each time it is used. TUT OO2 O7S6 GERAGHTY & MILLER. INC. 16 o Frequent and regular inspections of the site, materials, and equipment used during the field investigation will be conducted by the Site Safety Officer. Machinery, tools, material, and equipment and work practices that are judged unsafe, or not in compliance with OSHA or other applicable standards shall be removed or replaced or the work practices corrected. Equipment and machinery will only be operated by employees qualified by training and/or experience. (Figure 8, Field Audit Checklist) o Containers will be moved with the proper equipment and will be secured to prevent dripping or loss of control during transport. o Personnel will avoid contact with potentially contaminated substances. Walking through puddles or mud, kneeling on the ground, etc., will be avoided whenever possible. o The buddy system, wherein personnel will maintain contact will be observed at all times in the Exclusion Zones. A uniform hand signal to be used by all personnel in the event of an emergency will be instituted. o Field personnel will monitor each other for signs of chemical exposure. Indications of adverse affects include the following: Changes in complexion and skin discoloration. Changes in coordination. Changes in demeanor. Excessive salivation and pupillary response. Changes in speech pattern. o Field personnel will be cautioned to inform each other and the Site Safety Officer if adverse affects are felt. These affects may include the following: GERAGHTY & MILLER. INC. 17 Headaches Dizziness Nausea Blurred vision Cramps Irritation of eyes, skin, or respiratory tract o Health and safety related aspects of the field activities will be documented. The documentation will include any instances of potential chemical exposure, and also the lack thereof. DRILLING OPERATIONS Practices to be employed in connection with drilling operations are as follows: o Before drilling, the existence of underground utilities must be investigated and the location of any pipelines, electric lines, etc. must be determined. The appropriate utility companies will be contacted. Prior to the start of drilling, the Utilities And Structures Checklist shown on Figure 4, will be completed. o Drilling will not be performed in any areas where overhead power lines or telephone lines may present a hazard. o No drilling activities will be permitted during periods of thunderstorms and lightning. o Ambient air quality in the breathing zone around the drilling rig will be monitored continuously during all drilling activities. GERAGHTY & MILLER. INC. 18 o Workers will be constantly alert to the potential presence of obstructions during drilling operations. If an obstruction is encountered, work will stop immediately and the Project Manager and Project Health and Safety Officer will be notified. DECONTAMINATION PROCEDURES EQUIPMENT Decontamination of large equipment (drill rigs and associated equipment) will be performed at a specified cleaning station. Cleaning will consist of soap and water wash and potable water rinse using a steam cleaning unit. Any parts of the rig which are encrusted with dirt and mud or are suspected of having been splashed with materials at a sampling station (test boring) will be washed prior to moving to the next borehole location. Drill rigs will be fully decontaminated prior to and between borings at each new boring location. Drill rigs will be fully decontaminated prior to leaving the site. All reusable non-dedicated sampling equipment (spatulas, trowels, core barrel sampler, bailers, split spoons) will be decontaminated in accordance with the protocols specified in the Work Plan, initially, between each use for sampling, and prior to leaving the site. The required decontamination procedure for all sampling equipment is: a. Wash and scrub with low phosphate detergent, b. Tap water rinse, c. Rinse with 10% HN03 ultrapure. d. Tap water rinse. e. An acetone only rinse or a methanol followed by hexane rinse (solvents must be pesticide grade or better). GERAGHTY & MILLER, INC. 19 f. Thorough rinse with deionized demonstrated analyte free water. g. Allow to air dry. h. Wrap in aluminum foil for transport. PERSONNEL Personnel decontamination stations will be set up as appropriate at the edge of the Exclusion Zones and/or the Support Area. The procedure is as follows: 1. Place equipment and/or samples in designated area; 2. Wash boots using detergent solution; followed by a potable water rinse; 3. Wash and rinse outer gloves as above and remove; 4. Remove disposable coveralls (if used) and place in proper container; 5. Remove hard hat and respirator (if used) and store in appropriate place. 6. Removal disposable inner gloves (if used) and place in proper container; 7. Wash hands and face with water and hand soap. Respirators will be washed daily after use in warm water and mild detergent and sanitized in accordance with manufacturer instructions. They will be inspected regularly for cracks and dents, and stored in a clean plastic bag. Personnel will shower as soon as possible after leaving the site at the end of the work day. SAMPLE CONTAINERS The exterior of the sample containers will be decontaminated by immersing in the bottle up to the neck in a detergent solution followed by a potable or distilled water rinse. Solvents will not be used to wash sample containers. GERAGHTY & MILLER, INC. 20 EMERGENCY RESPONSE PLAN The Site Safety Officer will inform all field personnel of emergency and evacuation procedures. The route to the hospital and written directions are provided on Figure 5. Prior the start of field activities, the route to the hospital will be driven by the Site Safety Officer. All personnel will be aware of the location of the nearest accessible telephone before beginning work activities. Local and nationwide emergency numbers are listed on Table 3. The phone list will be provided to all field personnel and posted, if practicable, next to the telephone. The Site Safety Officer will designate a safety station where first aid and contingency equipment will be kept and will inform all field personnel of the location of this station. The following first aid and contingency equipment will be available: o First aid kit o American National Red Cross First Aid Handbook o Type A, B, and C fire extinguishers o Potable water Additionally, an eyewash station will be available within 10 feet of each Exclusion Zone and Contamination Reduction Zone. In the event of an injury requiring treatment, the person will be taken to the hospital. In an emergency, first aid will be given and the ambulance company and hospital will be called immediately. Medical and paramedical organizations (i.e., hospital, ambulance service, police and fire departments) will be notified in advance that the project is to begin. TUT GERAGHTY & MILLER. INC. 21 Any injuries or accidents will be thoroughly documented on the appropriate form. A sample Injury Report and Vehicle Accident Report Form are provided on Figures 6 and 7, respectively. The following people will be notified as soon as possible in the event of a personnel exposure incident, accident or emergency: Project Health and Safety Officer Site Safety Officer Project Manager Project Coordinator Designated Coordinator Project Officer Alberto Colberg (809) 725-6735 Ruben Ponciano (809) 725-6735 Thomas V. Danahy (201) 909-0700 Jose C. Agrelot (809) 792-8900 Ana Gloria Ramos (809) 792-2920 Daniel A. Nachman (201) 909-0700 HEALTH MONITORING AND FIELD PROTOCOLS HEALTH MONITORING PROGRAM Geraghty & Miller and Soil Tech participate in a Health Monitoring Program with occupational health specialists. Geraghty & Miller and Soil Tech employees receive yearly physicals consisting of the following: o Personal, family and environmental history o Hands-on physical examination o Snellen's eye examination o Hearing test o Respirator clearance (EKG and pulmonary function) for those involved in Levels C and B work HIT 002 0762 GERAGHTY & MILLER. INC. 22 MOTOR VEHICLE HAZARDS Motor vehicle traffic poses a potential hazard to site workers, particularly at some of the boring and well locations situated in the service station lots and parking lots. At these locations, orange traffic cones will be placed around the work area to mitigate the potential hazard. HEAT STRESS Heat stress may be of concern depending upon the ambient temperature and humidity. The task being performed, and the level of personal protection in use also influence the degree of heat stress imposed upon workers. Symptoms of heat stress include the following, in order of increasing seriousness: o Heat rash o Heat cramps (muscle spasms; pain in the hands, feet and abdomen) o Heat exhaustion (pale, cool, moist skin; heavy sweating; dizziness) o Heat stroke (red, hot, dry skin; lack of perspiration; nausea; dizziness and confusion; strong rapid pulse; coma) Heat stroke can result in serious injury or death; immediate action must be taken cool down a worker exhibiting these symptoms. The following measures should be implemented to prevent heat stress if conditions warrant: o Provide adequate liquids to replace lost body fluids and electrolytes lost from perspiration. Replacement fluids can be a 0.1 percent saltwater solution, commercial mixes such as Gatorade or Quick Kick, or a combination of these and fresh water. Encourage workers to drink more than thirst requires. GERAGHTY & MILLER. INC. 23 o Establish a work regimen that will provide adequate rest and cooling down periods. This may require adjusting work schedules, and/or rotating personnel. o Take breaks in an air conditioned (preferably) or a shaded rest area. Remove all impermeable protective garments during rest periods. o Inform all personnel of the importance of adequate rest, acclimatization, and proper diet. o In temperatures above 70°F, personnel using Level C will be monitored via heart rate and oral temperature at rest periods. If the heart rate exceeds 110 beats per minute or oral temperature is above 99.6°F, subsequent work periods are shortened by one-third. Repeat if necessary once only or remove from work site for rest and medical attention. Do not allow personnel to work in protective coveralls if oral temperature exceeds 100.6°F. TRAINING BASIC TRAINING Geraghty & Miller and Soil Tech employees attend a 40-hour health and safety training course and refresher training which satisfies the training requirements of OSHA, 29 CFR 1910.120. Subcontractors will be required to provide documentation stating that their employees have been trained in accordance with OSHA requirements. 'TUT 002 0764 GERAGHTY & MILLER. INC. 24 SITE-SPECIFIC TRAINING Prior to starting the field activities, all (Geraghty & Miller, Soil Tech, and subcontractor) personnel will attend an onsite training session by the Site Safety Officer. The topics of this session will include the following: o Reading and understanding the HASP o Site history o Constituents of concern o Hazard recognition o Environmental monitoring procedures o Personnel and equipment decontamination o Emergency procedures o Respirator use o First aid o Heat stress GERAGHTY & MILLER, INC. 25 TAILGATE SAFETY MEETINGS The Site Safety Officer will hold daily tailgate safety meetings. Attendance by the field team members and subcontractor personnel working onsite that day will be mandatory. Health and safety concerns and procedures specific to that day's tasks will be discussed and questions answered. A Tailgate Safety Meeting record shown on Figure 8, will be completed daily. TVD:gv #PR01301/H&SPU\N GERAGHTY & MILLER, INC. 26 REFERENCES Geraghty & Miller, Inc. 199 la. Tutu Service Station Investigation Work Plan. Prepared for the Tutu Environmental Investigation Committee, May 29, 1991. ___________. 199Ib. First Sampling Report, September 1990, Tutu Wells Site Quarterly Sampling, St. Thomas, U.S. Virgin Islands. Prepared for the Tutu Environmental Investigation Committee, January 1991. ____________. 1991c. Second Sampling Report, February 1991, Tutu Wells Site Quarterly Sampling, St. Thomas, U.S. Virgin Islands. Prepared for the Tutu Environmental Investigation Committee, May 13, 1991. ____________. 199 Id. Third Sampling Report, June 1991, Tutu Wells Site Quarterly Sampling, St. Thomas, U.S. Virgin Islands. Prepared for the Tutu Environmental Investigation Committee, September 1991. TVD:gv #PR01301/H&SPLAN GERAGHTY & MILLER. INC. TABLES GERAGHTY & MILLER, INC. Table 1. Maximum Concentrations of Previously Detected VOCs, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands." Ground Water Concentrations (PPB) 1,2-Dichloroethene 280 Trichloroethene 72 Tetrachloroethene 1500 Benzene 32 Vinyl Chloride 17 Toluene 44 Acetone 22 1,1,2-Trichloroethane 5 Air Total Volatile Organic Compounds 24 PPM (PID reading during evacuation of Tillett Well 2/6/91) Based upon Geraghty & Miller (1991b; 1991c;1991d) sampling reports. PPB Parts per billion. PPM Parts per million. PID Photoionization detector. GERAGHTY & MILLER. INC. Table 2. Current Occupational Airborne Contaminants Standards and Guidelines, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. ACGIH OSHA TLV-TWA TLV - STEL PEL STEL 1,2 Dichloroethene 200 - 200 Trichloroethene 50 200 50 200 Tetrachloroethene 50 200 25 Benzene^ 10 - 1 - Vinyl ChlorideA1 5 - 1 - Toluene 100 150 100 150 Acetone 750 1,000 750 1,000 1,1,2 - Trichloroethane 10 10 - (Skin) All values are in parts per million (ppm). ACGIH American Conference of Governmental Industrial Hygienists, 1990-91. OSHA Occupational Safety and Health Administration, 1989. TLV Threshold Limit Value. PEL Permissible Exposure Limit. TWA 8 Hour Time Weighted Average. STEL 15 Minute Short Term Exposure Limit. A1 Confirmed Human Carcinogen. A2 Suspected Human Carcinogen. Level not established. Skin - This notation refers to the potential contribution to the overall exposure by the cutaneous route including mucous membrane and eye, either by airborne or by direct contact with the substance. TUT GERAGHTY & MILLER, INC. Table 3. Emergency Telephone Numbers, Tutu Service Station Investigation, Health and Safety Plan, St. Thomas, U.S. Virgin Islands. Fire Department (809)921 Ambulance (809) 922 Hospital (809)776-8311 Police Department (809) 915 USEPA Caribbean Field Office (809)729-6951 USVI Department of Planning and Natural Resources (809) 774-3320 #PR01301/TAB7.WK1 GERAGHTY & MILLER, INC. FIGURES TUT •C*OT>- 077;:, GERAGHTY & MILLER, INC. FIGURE 1 HEALTH AND SAFETY REVIEW FORM TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS TLJT 002 0773 GERAGHTY & MILLER, INC. GERAGHTY PROJECT NUMBER: HEALTH AND SAFETY REVIEW FORM TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS I acknowledge that I have reviewed the above Health and Safety Plan (HASP). I understand the levels of personal protection that may be required by the HASP and I agree to the follow the requirements of the HASP. NAME (Please Print) COMPANY SIGNATURE DATE OO2 O774 FIGURE 2 TURPENTINE RUN BASIN TUTU SERVICE STATION INVESTIGAITON HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS GERAGHTY & MILLER. INC. 05*00' 10°17 TURPENTINE RUN BASIN tTUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN. ST. THOMAS,U.S. VIRGIN ISLANDS TEIC (icraghly Miller. Inc. NACHMAN PHI «-»M( [i R• MESSHGER »<•• RNDLAY sou SHOWN 2/90 FIGURE 3 SITE PLAN TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS 0777 GERAGHTY & MILLER, INC. \NV' >-00 ./\ »«.* •••*. * . *'- i ' : ' • "*r-\*~'*V "* *''* •"'"r;ii=^——- , i .".~^''<V=?i.l-'-''\ V\ V ,.-, NA A '". •'.,-. 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THOMAS, U.S. VIRGIN ISLANDS. TUT GERAGHTY & MILLER. INC. X^GERAGHTY '& MILLER. INC. Environmental Services UTILITIES AND STRUCTURES CHECKLIST Project: Prepared by: Location:. .Date: Instructions. This checklist has to be completed by a G&M staff member as a safety measure to insure that all underground utility lines, other underground structures as well as above-ground power lines are clearly marked out in the area selected for boring or excavation. DRILLING OR EXCAVATION WORK MAY NOT PROCEED UNTIL LINES ARE MARKED AND THIS CHECKLIST HAS BEEN COMPLETED. Arrangements for underground utility markouts are best made at the time of the preliminary site visit to allow client and/or utility company sufficient time. Keep completed checklist and maps onsits; send copy to Project Manager. Assignment of Responsibility. Client is responsible for having underground utilities and structures located and marked. Preferably, the utilities themselves should mark out the lines. Drilling or Excavation Sites. Attach a map of the property showing the proposed drilling or excavation site (or if sites are widely separated, several maps) clearly indicating the area(s) checked for underground utilities or underground structures and the location of above-ground power lines. Utilities and Structures Type Petroleum products line Natural gas line Steam line Water line Sewer line Storm drain Telephone cable Electric power line Product tank Septic tank/drain field Overhead power line Not Pres*<Tt Present How Marked?1' 1} Rags, paim on pavement, wooden slakes, etc. Name and affiliation of person who marked out underground lines or structures. Emergency Procedures Persons at site or facility to contact in case of emergency 1. 2. Phone Phone Fire Dept.: Phone Utility: Phone __ Utility: Phone __ Directions to nearest hospital (describe or attach map). Ambulance: Phone Utility: Phone ___ Utility: Phone ___ GAM Form X \\-fJ TU'T no, 0780 FIGURE 5 ROUTE TO HOSPITAL TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS GERAGHTY & MILLER. INC Li R 1-: A I -"'•; -N ()TR T HV : .S I I) E. ••• Drakes Sea: -""• '; .V xY;- v v ' .'"• ' '• ' •''• .'*... f.''••'Rosehdiil • . .'.•' ROUTE TO HOSPITAL X^V^SVrT'.. ,___~_P- ^L^j—— - ——•£.-- • : /• -- ^ / -^ SK^-^ --. ••-.'• v^.-;.'.:/-'---'!:"'.;"/'.' •: V. ^ ^.^- ""• ' - • • .. '-..'•'.•..'••..'!" P'TS?VV ! \\ x^v,. "> --^- . j •, '. •' ;0C Frvdenda! • : ;-;"-.. ••'•'•• •'-•:' ::'-•-'-• :...•"••••. ~. .' V^iU •—^'-'! ^-4''-J •-j'" *A/":' , " ^"' ' A <vT'i"s^^'C'i\Jn •C%.''v -•••--•«•"•-.-Ui-r-.^yX .:•^^•-^'C^\ p;r(^-v:v;;V• • -4.'^^••*|;UJ :^ .y^'->-v-'ri-::'-^l;:^^V/^V^.*^ '< -. ' ~- S"'-'-:'' ' ''"'"••'^^y /^'^^-:^?v'v^. >'^ '•'' : • . ' " • -N Carol " Pt ^: - - cr __•___ __:_ V _//_ RO, ' • \ ' -^ " ' CS^«y ~ •"•" L!~ ) * <**£_ ' I Dion Rock ^;L::!len!T.s ^F \* rl V» • ^t^.rJtt • • ' J/orriKips^ar ." Buy /•V ''••K'--^. 7. -' Mangrove Lagojfn *i&* Compass Pi i • Barrel JCAUt ) a> 2000 FEET V GERAGHTY f & MILLER, INC. Environmr. Ual 5«rvic«s ROUTE TO HOSPITAL TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN, ST. THOMAS, U. S. VIRGIN ISLANDS PREPARED FOR: TUTU ENVIRONMENTAL INVESTIGATION COMMITTEE FIGURE TUT 002 0782 FIGURE 6 INJURY REPORT FORM TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS GERAGHTY & MILLER. INC. Bureau o' Labor Statistics Supplementary Record of Occupational Injuries and Illnesses U.S. D«p«rtm«nt of Labor Thu l*rm Ii rKjvurtd »r » Lrw 1 1-6M i«« "mil »« Hal m iM «iioiii*m««i l»i f i In ihi '»vi"o al Mii<a"i i Cma4«Yir Cm 9' ' •>» 0 M 8 Na IJ200029 3. LeciKOO. II 4i"t'«n| ''Or"' lr>|u'*0 •' HI 4. Nim« I f i f l t , miaail. tn<3 lull Soc No . c/iy 8. 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Oil* 0' teon 'tc«'»o BY OSHA No 101 <F«o I98M 11JT 002 FIGURE? VEHICLE ACCIDENT REPORT FORM TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS. 0785 TU! v''••'•'- GERAGHTY & MILLER, INC. Figure 7. Vehicle Accident Report Form Tutu Service Station Investigation Health and Safety Plan, St. Thomas, USVI o4(t cm« Sufi.itud Av*nl e n / u r e a _ _ _ _ _ _ _ _ _ — — . — — — _ J.J. KJ. C) cy f.ctltt/ « YtMCU XJl« ?rw*€ *s.___________ CJMT«T» Lteinst ."o.___________ X.5. »._ •: (CiKX \t u»« il ar!r«- __J ______________.____ oisaut Mlt DUUUP WTIt5 (A Iu;e-Tlwr'j Injwy ttport fori «utt b« cwryltlH 1f I CM M^layM it <nvolv*4.) fc. t*jloy«r'j XJM J 2. .<!»>• i. ._,_________________________________ ___________________. citr. z. x*»*_________________________ ____________________ CJt/. OtSOIMICK » ACCICtXT: MH: _7 /——— TtX:. an rite. 14 Jiat) CffICCJl'J MJ*: .> _________ ^__———————————D4li- FIGURE 8 TAILGATE SAFETY MEETING FORM TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS TI 11 OO2 0787 GERAGHTY & MILLER, INC. Geraghiy& Miller TAILGATE SAFETY MEETING Prepared by Client _______________________ Project __ Date _________________________ Project Number Work Location ______________________________ Type of Work to be Done SAFETY TOPICS PRESENTED Chemical Hazards Physical Hazards/Underground Utilities Protective Clothing/Equipment Special Equipment _ Emergency Procedure* Hospital/Clinic ______________________ Phone ( ). Paramedic Phone ( )_______________ Hospital Address _______________________________ other _______________________________________ ATTENDEES NAME PRINTED SIGNATURE Meeting Conducted By Name Printed signature Note: This tailgate safety form must be completed daily, FIGURE 9 FIELD AUDIT CHECKLIST TUTU SERVICE STATION INVESTIGATION HEALTH AND SAFETY PLAN ST. THOMAS, U.S. VIRGIN ISLANDS. GERAGHTY & MILLER. INC. GERAGHTY & MILLER, INC. HEALTH AND SAFETY FIELD AUDIT CHECKLIST YES NO DOCUMENTATION _ __ Has a Health and Safety Plan (HASP) been prepared for this program? _ _ Is a HASP on-site and readily available? __ _ Is a Health and Safety Logbook in use? _ __ Have subcontractors and Geraghty& Miller staff been given a pre-startup safety briefing and have the personnel signed the acknowledgement form in the Logbook? __ __ Are other job-specific records being maintained, as outlined in the HASP (OSHA 101, training records, etc.)? __ __ Are monitoring equipment calibrations and readings being properly measured and recorded? _ __ Have any changes in the HASP been recorded? REMARKS: YES NO HEALTH AND SAFETY MONITORING - PROTECTION LEVELS _ _ Is atmospheric monitoring being performed in accordance with the HASP (OVA, TIP, LEL, etc.)? __ __ Is monitoring being performed at designated time intervals? __ __ Are monitoring results being properly recorded in the Health and Safety Logbook? _ _ Are action (upgrade/downgrade) levels being followed by field personnel? __ __ Are monitoring instruments being properly calibrated at designated time intervals? _ __ Does the atmospheric monitoring program appear adequate and capable of indicating the presence of contaminants at the site? TUT 002 0790 REMARKS-ACTION: YES NO PERSONAL PROTECTIVE EQUIPMENT - PPE Is the appropriate, designated PPE being worn for each work task by field personnel? _ __ Is all required safety equipment readily available? __ __ Does the safety equipment used by subcontractor meet HASP requirements? __ __ Does the PPE appear appropriate for the contaminant level(s) encountered? __ __ Are used PPE properly disposed of or adequately decontaminated? __ _ Are reusable PPE free from contamination once decontamination has been completed? Reusable PPE may not be appropriate in certain highly contaminated situations, or when specific types of contaminants maybe encountered. Refer to the site-specific HASP. __ __ Is stress monitoring being performed hi accordance with the HASP and generally accepted practice? REMARKS-ACTION: YES NO SITE CONTROL __ __ Have exclusion zones or work areas been established around the work areas, as described in the HASP? __ __ Are established zones sufficient to prevent the migration of contaminated media beyond these areas? __ __ Is a clearly defined contamination reduction corridor for decontamination in existence at the work area? __ __ Are designated decontamination procedures being employed? __ __ Is decontamination effective in removing contaminants and preventing the spread of contaminated media? TUT O02 079' REMARKS-ACTION: YES NO SAFE WORK PRACTICES Is the buddy system employed, and is it encouraged by project management? An eyewash station, fire extinguisher, and first-aid kit should be present on each site. Are they available? Are restrictions on the use of food, tobacco, or beverages in work/exclusion zone(s) being followed? Are field personnel washing at lunch and shift changes? Is all equipment kept in a safe, operating condition? Are safety glasses or goggles in use during all field activities not requiring a respirator? Are hard hats being worn, where required? Are steel toe and shank and/or chemical protective boots being worn for designated work tasks, as specified in the HASP? Are any slip-trip-fall or impalement hazards present, which have not been addressed? Are appropriate clearances being maintained between drilling equipment and overhead power lines? Are noise monitoring and bearing protection provisions being implemented? To the extent possible, are good housekeeping practices being implemented? Is a map to the hospital and a list of emergency telephone numbers conspicuously posted or available? REMARKS-ACTIONS: YES NO ENCLOSED SPACES/TRENCHES/PITS __ __ Are enclosed spaces, pits, etc. fully characterized for oxygen deficiency, combustible gasses, and toxic gasses? _ __ Are pits/trenches greater than 5 feet deep properly shored or sloped per OSHA 29 CFR 1910 Subpart P regulations? __ __ Are PPE requirements for enclosed space entry being properly employed per the HASP? __ __ Are properly equipped backup personnel on-site during enclosed space activities? REMARKS-ACTIONS: YES NO OTHER If there is potential for spillage of contaminated media, has a spill prevention plan been prepared with the HASP, and are spill prevention/cleanup equipment available? If underground storage tanks (USTs) arc being removed, have the USTs been properly purged of combustible vapors prior to removal? Have the displaced combustible vapors been vented through a stack extending 12 feet above the work area, per API Recommended Practice 1604? Are combustible gas measurements being performed during UST venting and removal activities? March 1991 TUT APPENDIX C WELL SAMPLING PROCEDURES TUT 002 0794 GERAGHTY & MILLER. INC. APPENDIX C WELL SAMPLING PROCEDURES Twenty-five wells along Route 38 within the Tutu Wells Site will be initially sampled and analyzed for TCL and TAL constituents with the exception of PCBs during the initial sampling event. During subsequent quarterly sampling events, samples from the 25 wells will be submitted for laboratory analysis of TCL VOCs. If the validated data from the initial sampling event indicates the presence of TCL semi-volatiles, pesticides, or TAL constituents above the detection limit, then samples collected from those wells during subsequent quarterly sampling events will be analyzed for the analyte group detected, in addition to TCL VOCs. • PREPARATION FOR SAMPLING The location of the well relative to the nearest road, the house, and other visible structures will be sketched and described. The location of septic systems, any work shops, and/or other potential constituent sources will be carefully noted, sketched, and described. The well and the piping system will be examined, sketched, and described. The sketch and description will include the type of pump and treatment systems, if present; any holding tanks; the piping material and solder, if possible; and the location of the sampling point. The well will be sampled as close to the pump as possible. It may be necessary to temporarily disconnect the pump from the piping to the point of use to ensure that the sample is collected before the water passes through a holding tank or treatment. Permission to disconnect the piping or to effect any other plumbing changes must be received in writing from the owner or resident. After sampling, the system will be restored immediately to its original configuration. • SAMPLING PROCEDURE For wells sampled from the tap, the pump, faucet, or outside tap will be run at full capacity to purge the well prior to collecting the sample. At least one well volume will be evacuated, if this calculation can be made from the information available. If the well volume cannot be estimated, the well will be pumped for a minimum of 15 minutes. The temperature, pH, and specific conductance of the discharge water will be measured at intervals no greater than 5 minutes in length during purging. If it is determined that one or more of these parameters continues to change after the evacuation of a well volume or at the end of 15 minutes, the purge time will be extended until stabilization occurs. TUT GERAGHTY & MILLER. INC. C-2 After the purge process, the flow rate will be reduced, and the samples will be collected directly into the sample containers. Sampling personnel will wear surgical gloves during handling of the containers. The gloves will be disposed after sampling is finished at each location. For wells sampled from the well head, at least one well volume will be evacuated prior to sample collection using a Teflon™ bailer, centrifugal pump, or submersible pump. The method of evacuation used will depend on well diameter, depth to water, and well head access. Temperature, pH, and specific conductance will be measured initially and after the removal of each well volume. If one or more of these parameters continues to change after the evacuation of one well volume, evacuation will continue until stabilization occurs. For wells sampled from the well head, samples will be collected using a Teflon™ bailer. Samples will be poured directly from the bailer into the sample containers. Bailer cord will consist of stainless steel wire, Teflon™ coated wire, or polypropylene monofilament. Bailers and bailer cord will be decontaminated prior to use by washing with laboratory-grade detergent (Micro™ or equivalent); rinsed with tap water; rinsed with ultra-pure grade 10% nitric acid (when metals are being analyzed for); rinsed with tap water; rinsed with pesticide-grade methanol; rinsed with pesticide- grade hexane; allowed to air dry; rinsed with demonstrated analyte free deionized water; allowed to air dry; wrapped in aluminum foil until use. Pumps which are to be used for well evacuation (other than pumps which are permanently installed in the well) will be decontaminated prior to each use by washing in tap water mixed with laboratory grade detergent. The detergent-water mix will be run through the pump to decontaminate the internal components. Next the pump will be washed/pumped with tap water, followed by a final wash/pump with deionized water. Samples to be analyzed for VOCs will be collected first. Samples will be preserved immediately upon collection. VOC samples will be acidified with ultra pure grade 1:1 hydrochloric acid (HC1) to pH <2. Metal samples will be acidified with ultra pure grade concentrated nitric acid (HNO3) to pH <2. Metals samples will not be filtered. In order to determine if VOC and metals samples are acidified to pH <2, a third portion of sample of equal volume will be acidified and its pH tested using pH paper. Acidification will be performed by adding the acid drop by drop until a pH of 2 or less is attained. An equal number of drops of acid will then be added to the sample to be submitted to the laboratory. If acidification of the VOC test sample causes effervescence, the sample will not be acidified, but will be cooled to 4°C. GERAGHTY & MILLER. INC. C-3 Sample containers will be labeled prior to sample collection. The following information will be recorded on each sample label: Project name Sample identification Sample matrix Requested analysis Chemical preservation and pH achieved (if applicable) Date and time of sample collection Sampler's signature FIELD ANALYSES After the laboratory containers are filled, approximately 0.5 gallon of sample will be collected in a clean, unpreserved glass container and its color, odor, and appearance will be noted. The pH, temperature, and specific conductance of the sample will be measured. Temperature will be measured immediately after collection of the sample with a mercury-filled Celsius thermometer in order to calibrate the pH and specific conductance meters. pH will be measured with a glass hydrogen-ion electrode against a reference electrode of known potential by means of pH meter. Calibration of the pH meter will be completed before analysis with two buffer solution standards bracketing the sample pH (nominal pH values of 4 and 7, or 7 and 11). The probe will be lowered into the sample and gently stirred to allow equilibration before the reading is taken. Specific conductance will be measured with a battery-powered specific conductance meter. The probe will be lowered into the sample and the reading will be immediately taken. The field analyses and sample descriptions will be recorded on a Geraghty & Miller, Inc. Water Sampling Log (attached). All parts of the field instrumentation which come in contact with the sample must be cleaned initially and between samples with a stream of deionized or distilled water. GERAGHTY & MILLER. INC. & MILLER. INC. Ground-Water Services WATER SAMPLING LOG Project/No.. Page_ .of. Site Location Site/Well No.. Weather __ Description of Measuring Point (MP). Coded/ Replicate No. _ Time Sampling Began____ Date _____ Time Sampling Completed __ EVACUATION DATA Height of MP Above/Below Land Surface Total Sounded Depth of Well Below MP Held_____ Depth to Water Below MP. Wet _____ Water Column in Well. Gallons per Foot. Gallons in Well. Evacuation Method____________ MP Elevation Water-Levd Elevation. Diameter of Casing __ Gallons Pumped/Bailed Prior to Sampling ___ Sampling Pump Intake Setting (feet below land surface) ___ Color. .Odor_ SAMPLING DATA/FIELD PARAMETERS _______ Appearance_______ .Temperature. Other (specific ion; OVA; HNU; etc.). Specific Conductance, umhos/cm______ Sampling Method and Material Constituents Sampled -pH. Container Description From Lab __ or G&M _ Preservative Remarks Sampling Personnel WELL CASING VOLUMES GAL/FT. 1-V4" » 006 1-Vi" - 009 2" 2-V4" 0.16 0.26 3" 3-V4" 0.37 0.50 TUT OO2 G4M Form 12 6-86 89-C-Oe APPENDIX D SAMPLING QUALITY ASSURANCE/QUALITY CONTROL PROTOCOLS GERAGHTY & MILLER. INC. APPENDIX D SAMPLING QUALITY ASSURANCE/QUALITY CONTROL PROTOCOLS The objective of the sampling quality assurance/quality control (QA/QC) program is to ensure the reliability and integrity of all data and documentation generated as a part of the monitoring program. Major elements of the program are quality control sampling, sample custody and handling, and data management. • QUALITY CONTROL SAMPLING • FIELD REPLICATE SAMPLES One field replicate water sample will be collected and analyzed for every ten water samples submitted to the laboratory. Care will be taken to ensure that each sample and sample replicate pair can be compared as a homogeneous sample split in two. Each field replicate sample will be given a fictitious sample identification so that it is not identified in the laboratory as a replicate sample. • BLANK SAMPLES One equipment blank sample will be collected on every day that sampling occurs for which sampling equipment is used. The equipment sample will be analyzed for every parameter analyzed for on that day in accordance with the CLP SOWs for Organics and Inorganics Analysis. The equipment blank sample will be collected by pouring deionized water over the bailer so that the rinsate flows directly into the sample container(s). One trip blank sample will be submitted to the laboratory for every day on which sampling occurs. Trip blank samples will be prepared at the beginning of each day that sampling occurs and will accompany the samples collected on a given day. Trip blank samples will be analyzed for volatile organic compounds (VOCs) in accordance with modified Method 524.2 Revision 3.0 for the 3/90 CLP Organics Volatile Target Compound List (TCL). Trip blank samples will be prepared in an identical manner to sample preparation for VOC analysis. • SPIKE SAMPLES One matrix spike/matrix spike duplicate (MS/MSD) will be analyzed for organics for each sample delivery group. Since all 25 samples will be collected and submitted to the laboratory within 14 calendar days, one MS/MSD sample will be analyzed for every 20 ground-water samples analyzed for organics. A triple sample volume of organics analysis will be collected for each MS/MSD analysis. TUT 002 O8OO GERAGHTY & MILLER. INC. D-2 One duplicate and one spike sample will be analyzed for metals for each sample delivery group. Since all 25 samples will be collected and submitted to the laboratory within 14 calendar days, one duplicate and spike sample will be analyzed for every 20 ground-water samples analyzed for metals. A double sample volume of inorganics will be collected for each MS/MD analysis. WATER BLANK SAMPLES One blank sample of the water to be used for equipment blanks and decontamination will be analyzed each quarter. The water blank sample will be analyzed for every parameter analyzed for each quarter. SAMPLE CUSTODY The sampling team will be responsible for maintaining custody of the samples until they are delivered to the courier for shipment to the laboratory. All samples shipped to the laboratory will be accompanied by the Geraghty & Miller Chain- of-Custody Record (attached). The Chain-of-Custody Record will be completed in the field; the original form will accompany the shipment and a copy will be retained in the field project file. The Chain-of-Custody form will include the project name and the signatures of the sampling team members who participated in collecting the samples. The following information for each sample container will be listed on the Chain-of-Custody form: Sample identification. Sample matrix. Requested analysis. Chemical preservation and pH achieved (if applicable). Date and time of sample collection. The original Chain-of-Custody Record form will be placed in a plastic bag and taped to the underside of the lid of the cooler. Samples will be placed in a clean, dry, undamaged cooler such that there is sufficient packaging material (vermiculite and/or bubble wrap) to prevent bottle breakage. Sufficient ice will be placed in each cooler to ensure that sample temperature is maintained at approximately 4°C until arrival at the laboratory. Ice will be placed in double Ziplock plastic bags. The ice-filled bags will be distributed in the cooler evenly, in order to ensure that all samples are maintained at approximately 4°C. The cooler will be sealed by wrapping nylon-reinforced packing tape entirely around it. TUT' 002 OSO; GERAGHTY & MILLER. INC. D-3 To provide a means of detecting any potential tampering during shipment, all shipment containers (coolers) will be affixed with signed Geraghty & Miller sample seals (attached). Two seals will be affixed to each cooler, on opposite ends. The courier service utilized for sample shipment and the number which identifies each shipment will be recorded on the chain-of-custody form. A receipt from the courier service, or copy of the airbill which identifies each shipment, will be retained in the field project file. Samples will be shipped to the laboratory daily. Shipment will be arranged such that samples arrive at the laboratory within 24 hours of collection. DATA MANAGEMENT Field data and documentation will be recorded in serialized sheets for every day during which activities occur at the site. Field procedures, measurements, and observations will be described in sufficient detail, so as to enable others to reconstruct the events. The project manager will maintain all project documentation in a central project file. This file will include the following items: Project plans and specifications. Field data and documentation. Chain-of-Custody documentation. Sample identification documents. Laboratory data packages. Data review notes Report notes and calculations Final maps and drawings SAMPLE CONTAINER QUALITY CONTROL To document the quality of sample containers, containers will be proven clean by analysis for each quarterly sampling event in accordance with the CLP Sample Bottle Repository (SBR) Statement of Work (SOW). Sample bottle analysis will be performed by either Enseco Incorporated upon I-Chem Series 200 sample bottles or by I-Chem upon their Series 300 sample bottles or Eagle Pitcher upon their Level I sample bottles. Results of the bottle blank analyses will be provided to USEPA Region II prior to each quarterly sampling event. TUT 002 0802 GERAGHTY & MILLER. INC & MILLER, INC. Environmental Services Laboratory Task Order No._ CHAIN-OF-CUSTODY RECORD Page_ .of. Project Number Project Location Laboratory __ SAMPLE BOTTLE / CONTAINER DESCRIPTION Sampler(s)/ Affiliation Date/Time SAMPLE IDENTITY Code Sampled Lab ID TOTAL Sample Code: L = Liquid; S = Solid; A = Air Total "VonSefs Relinquished by: Organization: Received by: Organization: Date / / Time Relinquished by: Organization: Received by: Organization: Oatn / / Time Seal Intact? Yes No N/A Seal Intact? Yes No N/A Special Instructions/Remarks: CHAIN-OF-CUSTODY SEAL • CHAIN-OF-CUSTODY SEALl GERAGHTY & MILLER, INC. CHAIN-OF-CUSTODY SEAL • CHAIN-OF-CUSTODY SEAL APPENDIX E ENSECO INCORPORATED QUALITY ASSURANCE PROGRAM PLAN FOR ENVIRONMENTAL CHEMICAL MONITORING, REVISION 3.4, APRIL 1991 GERAGHTY & MILLER. INC. "LIT OO2 O8OS ENSECO INCORPORATED QUALITY ASSURANCE PROGRAM PLAN FOR ENVIRONMENTAL CHEMICAL MONITORING Prepared by: Enseco Incorporated 2200 Cottontail Lane Somerset, NJ 08875 Revision 3.4 April 1991 c Enseco Incorporated, 1988 Approval: Margaret S. Sleevi Director of Quality Assurance X. Gary Ward Director of Quality Assurance & Technology /Robert S. Hulsy/ President E-22 TO' Table of Contents Paoe = 1. Introducti on...................................................... 1 2. Quality Assurance Pol icy.......................................... 3 3. Purpose and Scope of Document..................................... 4 4. Definition of Terms............................................... 7 5. Responsibilities and Authorities.................................. 9 6. Sampling Procedures............................................... 17 7. Sample Custody.................................................... 19 8. Calibration Procedures and Frequency.............................. 23 9. Analytical Procedures............................................. 28 10. Data Reduction, Validation, and Reporting......................... 30 11. Internal Qua!ity Control Checks................................... 35 12. Performance and System Audits..................................... 47 13. Preventive Maintenance............................................ 49 14. Specific Routine Procedures Used to Assess Data Quality and Determine Detection Limits.................................... 50 15. Corrective Action................................................. 57 16. Quality Assurance Reports to Management........................... 58 17. Laboratory Documentation.......................................... 59 Appendix I Enseco Recommended Maximum Holding Times and Sample Collection/Preservation Information Appendix II Formats for Standard Operating Procedures (SOPs) TUT List of Figures Figure Pace 5-1 Enseco Incorporated Quality Assurance Organizational Chart... 10 7-1 Enseco Sample Processing Flow Chart.......................... 20 7-2 Chain-of-Custody Record...................................... 21 7-3 Inter!aboratory Analysis Custody Record...................... 22 10-1 Data Validation Scheme....................................... 31 11-1 Laboratory Performance Quality Control Sample Evaluation..... 39 14-1 Graphical Representation of Detection Limits................. 56 ii „,,<:> 0808 TUT List of Tables Table Pace 1-1 Enseco Laboratory Locations.................................. 2 3-1 Elements of QA Program PI an.................................. 6 14-1 Definition of Detection Limit Terms.......................... 55 111 TUT OO2 O309 Enseco QA Program Plan Section No. Revision No. 3.4 Date A/91 Page 1 of 6Z 1. INTRODUCTION Enseco Incorporated (Enseco) is the largest and most experienced environmental testing laboratory in the United States. The environmental component of Enseco consists of the combined resources of: Enseco-Erco Laboratory in Cambridge, Massachusetts, Enseco-East in Somerset, New Jersey, Enseco-Rocky Mountain Analytical Laboratory in Denver, Colorado, Enseco-Houston in Houston, Texas, Enseco-California Analytical Laboratory in Sacramento, California, Enseco-CRL in Garden Grove, California, Enseco-El Monte in El Monte, California, Enseco-Santa Maria in Santa Maria, California, Enseco-Ventura in Ventura, California, and Enseco-Mobile Laboratories headauartered in Garden Grove, California. Addresses and telephone numbers for these Enseco laboratories are listed in Table 1-1. This document describes the Enseco Quality Assurance policies and procedures related to chemical monitoring for environmental pollutants. rnseco QA Program Plan Sect:on No. Revision No. Date TABLE 1-1 ENSECO LABORATORY LOCATIONS Enseco-California Analytical Laboratory 2544 Industrial Boulevard West Sacramento, CA 95691 (916) 372-1393 Facsimile (916) 372-1059 Enseco-CRL 7440 Lincoln Way Garden Grove, CA 92641 (714) 898-6370 Facsimile (714) 891-5917 Enseco-East 2200 Cottontail Lane Somerset, NJ 08875 (201) 469-5800 Facsimile (201) 469-7516 Enseco-El Monte 9537 Telstar Avenue #118 El Monte, CA 91731 (818) 442-8400 Facsimile (818) 442-3758 Enseco-Erco Laboratory 205 Alewife Brook Parkway Cambridge, MA 02138 (617) 661-3111 Facsimile (617) 354-5258 Enseco-Houston 1420 East North Belt Suite 120 Houston, TX 77032 (713) 987-9767 Facsimile (713) 987-9769 Enseco-Mobile Laboratories 7440 Lincoln Way Garden Grove, CA 92641 (714) 898-6370 Facsimile (714) 891-5917 Enseco-Rocky Mountain Analytical Laboratory 4955 Yarrow Street Arvada, CO 80002 (303) 421-6511 Facsimile (303) 431-7171 Enseco-Santa Maria 2325 Skyway Drive, Suite K Santa Maria, CA 93455 (805) 922-2776 Facsimile (805) 922-5897 Enseco-Ventura 2810 Bunsen Avenue, Unit A Ventura, CA 93003 (805) 650-0546 Facsimile (805) 650-0756 Enseco, Inc. (Corporate Office) 2200 Cottontail Lane Somerset, NJ 08875 (201) 469-5800 Facsimile (201) 469-5257 TIT Of)' OS 11 Enseco OA Proaram Plan Sec:::n .NO. Revision No. Date Pace 3.4 A/91 3 or •? 2. QUALITY ASSURANCE POLICY Enseco is committed to providing quality environmental analytical services to both the public and private sectors. To ensure the production of scientifically sound, legally defensible data of known, documentable and verifiable quality, an extensive Quality Assurance (QA) program has been implemented within Enseco. This program relies on clearly defined objectives, well-documented procedures, a comorehensive audit system, and management support, both Corporate and Divisional, for its effectiveness. TUT Enseco CA Program Plan Sec*:en No. Revis:on No. Date a/91 Paae <t of ?2 3. PURPOSE AND SCOPE OF DOCUMENT Purpose This QA Program Plan presents an overview of the essential elements of the Enseco QA program. Enseco has modeled this plan along EPA guidelines as outlined in "Interim Guidelines and Specifications for Preparing quality Assurance Program Plans," QAMS-004/80, December 29, 1980 and "Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans," QAMS-005/80, February, 1983. Both of these documents have been issued by the Office of Monitoring Systems and Quality Assurance, Office of Research and Development, U.S. Environmental Protection Agency (U.S. EPA). Elements above and beyond those specified in these two documents have been included in this QA Program Plan in order to completely describe the Enseco QA/QC system. Scope The Enseco QA program is designed to control and monitor the quality of data generated in Enseco laboratories. The program has four key elements. Demonstrating laboratory caoability by providing information wnich documents the overall qualifications of the laboratory to perform environmental analyses; Controlling laboratory operations by establishing procedures which measure laboratory and instrument performance on a daily basis; Measuring matrix effects to determine the effect of a specific matrix on method performance, and Reporting appropriate QC information with the analytical results to enable the end-user to assess the quality of the data. The specific procedures involvea in implementing each aspect of the Enseco program are described in this document. An overview of these QC procedures, along with the sect:en number *:: wnich sacn is iiscussaa. :: given in Table 3-1. TUT 002 0813 Enseco QA Program Plan Section No. Revision No. 3.4 Date d/gi Paae 5 of -52 The QA/QC policies and procedures described herein are designed to eliminate systematic errors and minimize the occurrence of other errors. However, no QA program, regardless of how elaborate, can eliminate all errors which may occur during an analysis. The QA program forms the framework for minimizing errors and identifying and correcting those errors which do occasionally occur. These QA/QC policies and procedures must be coupled with the professional judgment of the technical staff in interpreting the events surrounding the generation of the final result to ensure that quality data is consistently produced, and decisions and corrective actions are fully documented. In many instances, Enseco participates with its clients in the preparation and evaluation of project-specific Quality Assurance Project Plans (QAPjP). Typically the elements of the Enseco QAPP are incorporated into these documents. In some instances other requirements may be specified. Each QAPjP must be reviewed and approved by the QA Director of the Enseco facility entering into the client agreement to assure that minimum standards of quality exist by which the work can be evaluated as to its scientific and legal integrity. The QA Director rnust assure that both the analytical testing objectives and regulatory requirements of the project are met. All requirements in a QAPjP which do not meet the minimum requirements as stated in the Enseco QAPP must be approved by the Corporate Director of QA. In the presence of an approved QAPjP, Enseco laboratories must follow the specific requirements of that project plan which supersedes the Enseco QAPP for any work exolicitly associated with that QAPjP. TUT OO2 OS14 Enseco OA Program Plan Sect:on No. Revision No. Date Page 3.4 4/91 a or Table 3-1 ELEMENTS OF QA PROGRAM PLAN Evaluation Criteria LABORATORY QUALIFICATIONS LABORATORY PERFORMANCE MATRIX EFFECTS DATA REPORTING Operational Elements Section of OA Plan Facilities/equipment/staff................. * Written SOPs for all laboratory procedures, including:..................... 17 Sample custody.......................... 7 Calibration procedures.................. 8 Analytical procedures................... 9 Data validation......................... 10 Documented QA program...................... 1-15 Laboratory certifications.................. 12 Check samples.............................. 12 Method blanks.............................. 11 Calibration data/calibration verification.. 8 Method detection limits.................... 14 Matrix spike/matrix duplicate/ matrix spike duolicate analyses............ 11 Sample surrogate recoveries................ 11 Standard additions......................... 11 Field blanks............................... 11 Method detection limits (determined with specific sample matrix)............... II Data reduction ana validation.............. 10 Data reporting............................. 10 Reporting Limits........................... 14 Described in a separate document available from Enseco. OB 1 •- Enseco QA Program Plan Section No. Revision No. Date Paae 3.4 7 of 62 4. DEFINITION OF TERMS Quality Assurance (QA): the total integrated program for assuring the reliability of data generated in the laboratory. Qua!ity Control (QC): the routine application of specific, well- documented procedures to ensure the generation of data of known ana accepted quality, thus fulfilling the objectives of the QA program. Quality Assurance Program Plan (QAPP): an assemblage of management policies, objectives, principles, and general procedures outlining the techniques by which the laboratory produces data of known and accepted quality. Standard Operating Procedure (SOP): a detailed, written description of a procedure designed to systematize and standardize the performance of the procedure. Quality Assurance Project Plan (QAPjP): an assemblage of detailed procedures describing how the laboratory will generate aata that ~eet the Data Quality Objective (DQOs) of a specific project. Legally Defensible Data: data which are supported by a QAPP ana documentation adequate to reconstruct the analytical process. Legal defensibility is not dependent on the level of deliveraoles. Holding Time: the period of time during which a sample can be storea after collection and preservation without significantly affecting the accuracy of the analysis. Sample Delivery Acceptance: the point in time at which Enseco determines that it can proceed with the analytical work. Sample delivery accentance follows receipt ana inspection of the samoles and comolete definition of analyses requirea. TUT O02 0816 znseca OA Program P"!an Sect;cn No. Revision No. 3.4 Date A/91 Page 8 of Initiate Preparation: the point in time at which the separation of organic extractafale compounds or metals from the sample matrix by solvent extraction or acid digestion is begun. Initiate Analysis: the point in time at which the sample, extract or digestate is introduced into an instrument or process which complies with the SOP for analysis of the parameter of interest. TUT Enseco CA Program Plan Seen on No. Revision No. Date Page 3.4 9 of 5Z 5. RESPONSIBILITIES AND AUTHORITIES Executing an effective QA program in a large and complex multi-laboratory system demands the commitment and attention of both management and staff. The QA effort at Enseco is administered by the Director of Quality Assurance and Technology who manages the Corporate Quality Assurance Office. The Director of QA and Technology reports directly to the President and has the responsibility for overseeing and regulating all laboratory functions (see Figure 5-1). The Corporate QA Director reports to the Director of QA and Technology and has the responsibility of the day-to-day functions of the QA office. The QA Office operates independently of all areas generating analytical data to ensure complete objectivity in the evaluation of laboratory operations. The implementation of the QA program within each individual Enseco laboratory is administered by the Division QA Director. The QA Director reports to both the Corporate QA Director and to the General Manager, who manages the laboratory. In aadition, all scientists within the organization play a vital role in assuring the quality of their work. We believe that the success of Enseco is dependent upon the continued commitment of all within the organization to a strong and viable QA Program. The responsibilities and levels of authority within the organization are described below. Corporate Quality Assurance Office Members The QA effort within Enseco is directed by the Corporate QA Director under the management of the Director of Quality Assurance and Technology to carry out the responsibilities of the department. TU 08 Enseco OA Program Plan Section No. Revision No. Date Paae 3.4 A/91 '.0 of f2 Figure 5-1 ENSECO QA ORGANIZATIONAL CHART General Manager Division Management Division Personnel President of Enseco Division QA Director Director-QA/ Technology Corporate QA Director TUT 002 O Enseco OA Proaram Plan Section No. Revision No. Date Paae 3.4 11 of ~l Responsibilities The Corporate QA Director under the direction of the Director of QA and Technology is responsible for: Developing and implementing a Corporate QA program that ensures that all data generated in Enseco laboratories are scientifically sound, legally defensible, and of known precision and accuracy; Monitoring the QA Plan to ensure compliance with QA objectives in all Enseco laboratories; Developing and implementing new QA procedures within the corporation to improve data quality; Conducting audits and inspections of all Enseco laboratories on a regular basis, reporting the results of those audits to management, and applying corrective actions as needed to ensure compliance with the Enseco QA Plan; Coordinating the distribution of Performance Evaluation (PE) samples to all Enseco laboratories on a routine basis, evaluating the results of those samples, reporting to management, and applying corrective actions as needed to ensure that all Enseco laboratories are able to generate data that meet the data quality objectives defined in the QA Plan; Establishing databases that accurately reflect the performance of eacn of the Enseco laboratories; Directing Division QA Directors in the implementation of the Enseco QA Plan within individual facilities; Chairing the Enseco QA Committee, a working committee which includes all of the Division QA Directors and deals with QA issues on an ongoing basis; Coordinating certification programs within Enseco: Conducting seminars on QA issues for both clients and laboratory staff; and Promoting sound QA practices within the environmental regulatory and analytical communities. TUT Enseco QA Proaram P"=n Sect:en No. Revision No. 3.4 Date A/91 Page \Z of Authority Both the Director of QA and Technology and the Corporate QA Director have the authority on issues dealing with data quality and have the authority to require that procedures be amended or discontinued, or analyses suspended or repeated. The Director of QA and Technology and the Corporate QA Director have the authority to suspend or terminate employees on the grounds of dishonesty, incompetence, or repeated non-compliance with QA proceaures. In addition, these Corporate Directors have the authority to overrule decisions and actions of the Division QA Directors and must approve the termination or transfer of any Division QA Director. The authority of the Corporate QA Director and the Director of QA and Technology comes directly from the President of Enseco. Divisional Quality Assurance Departments Members Each divisional QA Deaart~ent is managed by a QA Director, "he QA Director reports directly to the General Manager and indirectly to the Corporate QA Director. The QA Director is supported by a QA staff within the laboratory. Responsibilities The Division QA Director is responsible for: Implementing Enseco QA policies; Monitoring the implementation of the QA Plan within the laboratory to ensure complete compliance with QA objectives; Canduct:r,g in-nouse auaits to icentify potential prooiems and ensure compliance with written SOPs: 0821. •ri |J 002 Ensec3 CA Proaram Plan Sect:en No. Revision No. 3.4 Date A/91 Page 13 of il Performing statistical analyses of QC data ana establishing databases that accurately reflect t^e performance of the laboratory; Prescribing and monitoring corrective actions; Serving as the in-house client representative on all project inquiries involving data quality issues: Monitoring the preparation and verification of analytical standards; Assisting cnemists in the writing of SOPs; Reporting the status of the laboratory QA program to the Corporate QA Director with formal and informal communications; Maintaining records and archives of all QC data, ?E results, audit comments, and customer inquiries concerning data quality; Assuring that the laboratory staff has access to current SOPs; Monitoring laboratory performance in the areas of holding times, turn-around times, and meeting contractual obligations; Conducting seminars on QA issues for clients ana laboratory staff; Preparing QA Project Plans when needed; Assisting the Corporate QA office in the writing of QA policies and procedures; Serving as a member of the Enseco QA Committee: ana Auditing subcontractors. TU E.iseco QA Program Plan Section No. Revision No. Date A/PI. Page '.* o- -: Authority The Division QA Director is the final authority within each laboratory on all issues caaling with data quality. He/she r.as the authority to require that procedures be amended or discontinued or analyses suspended or repeated. He/she can make recommendations to the General Manager and the Corporals Director of QA regarding susoension or termination of employees for incompetence or non-compliance with QA procedures. The authority of the Division QA Director comes directly from the Corporate Director of QA. Divisional Management Members The managers and supervisors wno direct the analytical work at aacr, laboratory are directly responsible for ensuring that all employees reporting to them are complying with the Enseco QA Plan. ResponsibJ1ities Laboratory management is responsible for: Actively suoporting the implementation of the Enseco QA Plan within the laboratory; Maintaining accurate SOPs ana enforcing their use in the laboratory; Maintaining a work environment that emphasizes the importance of data quality; and Providing management support to the Corporate and Divisional C.A departments. "UT OO2 082-.:'' i.nseco QA Program Plan Section No. Revision No. 3.4 Date -1/91 Page 15 or 62 Authority The managers and supervisors of the laboratory have the authority to accept or reject data based on compliance with well-defined QC criteria. In addition, managers and supervisors, with the approval of the QA department, can accept or reject data that fall outside of established QC guidelines if, in their judgment, there are technical reasons which warrant the acceptance or rejection of the data. These circumstances must be well documented and any need for corrective action identified by the incident must be defined and initiated. The authority of the laboratory management comes directly from the President of Enseco and the General Manager. Divisional Personnel Members All laboratory personnel involved in the generation and reporting of data have a responsibility to understand and follow the Enseco QA Plan. Responsibilities Laboratory personnel are responsible for: Having a working knowledge of the Enseco QA Plan; Ensuring that all work is generated in compliance with the Enseco QA Plan; Performing all work according to written SOPs; Ensuring that all documentation related to their work is complete and accurate; and Providing management with immediate notification of quality problems. TUT OO2 0824 Enseco QA Program Plan Seci::n No. Revision No. ,3.4 Date -1/9! Paae 15 of ••Z Authority Laboratory personnel have the authority to accept or reject data based on compliance with well-defined QC criteria. The acceptance or rejection of data that fall outside of established QC guidelines must be approved by laboratory management and the QA department. The authority of the laboratory personnel flows from the General Manager. TUT Enseco CA Program Plan Sect:on No. Revision No. ; .4 Date A / g i Page 17 of •?; 6. SAMPLING PROCEDURES The generation of quality data begins with the collection of the sample. and therefore the integrity of the sample collection process is of concern to the laboratory. Samples must be collected in such a way that no foreign material is introduced into the sample and no material of interest escapes from the sample prior to analysis. To ensure sample integrity, the following must be considered: Samples must be collected in appropriate containers. In general, glass containers are used for organic parameters and polyethylene containers for inorganic/metal parameters (see Appendix I); The sample containers must be properly cleaned to ensure that the sample is not contaminated during the collection process; Samples must be preserved appropriately to minimize the loss of materials of interest due to adsorption, chemical or biological degradation, or volatilization (see Appendix I); Appropriate volumes of sample must be collected to ensure that the required detection limits can be met and quality control samples can be analyzed (see Appendix I); and Samples must be properly shipped to the laboratory, in the appropriate time frame, to ensure that holding times for the analyses can be met (see Appendix I). Sample Containers and Preservatives Enseco can assist in the sample collection process by providing consultation and assistance to clients designing sampling programs. Also Enseco can make available to the client sample containers that are properly cleaned and preserved for use in sample collection. Enseco has had its coolers, sample containers and packaging methods independently tested to demonstrate that Department of Transportation standards are met. Appropriate containers and preservatives, and minimum sample volumes required for analyzing routine organic, metal, and conventional parameters are listed in Appendix I. Enseco CA Proaram Plan Section No. Revision No. Date Page 2.4 -1/91 of 62 Holding Times EPA has established holding time requirements for some analyses. These holding time requirements are listed in Appendix I, along with container and preservative requirements. As indicated in Appendix I, holding time requirements differ depending on the regulatory program. Enseco follows the holding times given in SW-846, Update I, Federal Register, October 25, 1984 or Methods of Chemical Analysis of Water 4 Waste, basea on the method source, unless otherwise instructed by the client. ZIP holding times are followed when CLP protocols are requested by the client. Other holding times can be honored if special arrangements are made with the laboratory. Enseco is obligated to initiate preparation and/or analysis of the sample within holding times if sample delivery acceptance occurs within 72 hours of sampling or before one-half of the holding time period has expired, whichever is less. (See Section 4 for definition of above terms.) On occasion, a sample must be reanalyzed to comply with this QA Program Plan. If this reanalysis is conducted outside of the holding time, the laboratory will be considered to have fulfilled its obligation to meet holding times if the first preparation and/or analysis was initiated within the prescribed holding time. Sample Disposition All soil samples, sample extracts, and aqueous samples that meet Federal or applicable State definitions as a hazardous waste are incinerated at a RCRA Part 8 permitted facility or returned to the client. Emoty sarnole containers are disposed of by shredding and incineration. An alternate procedure for disposal of empty containers involves triple rinsing the container, blanking out the label and disposal as a solid waste. Sample disposition procedures meet Federal and State regulations. 002 0827 Enseco OA Prooram Plan Sect::n No. Revis;on No. Date Page 3.4 19 of 6Z 7. SAMPLE CUSTODY Upon receipt by Enseco, samples proceed through an orderly processing sequence specifically designed to ensure continuous integrity of both the sample and its documentation. All samples are received by Enseco's Sample Control Group and are carefully checked for label identification, and completed, accurate chain-of-custody records. Photographs document the condition of samples and each sample is then assigned a unique laboratory identification number through a computerized Laboratory Information Management System (LIMS) that stores all identifications and essential information. The LIMS system tracks the sample from storage through the laboratory system until the analytical process is completed and the sample is returned to the custody of the Sample Control Group for disposal. This process is summarized in Figure 7-1. Access to all Enseco laboratories is restricted to prevent any unauthorized contact with samples, extracts, or documentation. An examoie of the Enseco Chain-Of-Custoay Recora usea to transmit samples from the client to the laboratory is given in Figure 7-2. The Chain-Of- Custody Recora (Inter!aboratory Analysis Form) used to transmit samples between laboratories within Enseco is given in Figure 7-3. Sample bottles provided to the client by Enseco are transmitted under custody. E.nseco QA Program Plan Section No. Revision No. Date Page 3.4 1/91 of ?; Fiaure 7-1 ENSECO SAMPLE PROCESSING FLOW CHART Sample Control Proper Storage Laboratories Sample Control * * * * Check and document physical conaition of sample Verify documentation and parameter assignment Log into LIMS Send acknowledgement letter to client Store sample according to preservation guidelines Transfer sample to lab with proper documentation Document analytical work Return unused samples to Sample Control Return sample to client or arrange for sample disposal N OF CUSTODY riseco A Coming Company Kuiky Muuiiluin Aitulylliul lulioiuluiy 4Vii Yunow Slieal Arvu.l... CO UOO02 303/42166)1 fAX: 303/431 7 1 / 1 SAMP1E SAFE'" CONDITIONS COMPANY it At ml ACT UPON HECEIPT UY SAMPI itlG COMPANY SEAL NUMIILH SEAL INTACI UPON HECCIPT BY LAS a v., a NO SI At NUMUCR CONDITION Of CONtlNIi iMITlAl CONIIIIfJ II MP SAMPLING STATUS LJ Don* LJ Continuing Until COMUNTt TCMPCRATUNt LPON HtCtlPT UY I All TIME SAMP1E ID/DESCRIPTION SAMPIETYPE tCONUINHS ANALYSIS PARAMETERS REMARKS CUSTODY TRANSFERS PRIOR TO SHIPPING J BY (SIGNED) bY (SlGMtU) DATE TIME SHIPPING DETAILS QCUIVCHCO TO &IIIPPCH UY MCTIIOO OF SHIPMENT IIICEIUIDIOII I AU I IIUI <!O TIM! I* I I HIIMIil II H- •Oc:n ID ERLABOf TORY AIN OF CbaTODY 1!'1S( X) Company I PACE 01 II ION EXPORT ID TEST PRICE SUBTOTAL DISCOUNT^/ SURCIWIGE_ TOTAL ANALYTICAL REQUESTS •(•• SAMPLE CONDITION UPON RECEIPT SEND RESULTS TO ATTENTION COMMENTS WRITTEN RESULTS REQUIRED BY (DA1E) VERBAL/F AC RESULTS BEOUMEO BV (OATtl CO No Q.C. Q STANDARD ENSECO Q Cl P PROTOCOL D PROJECT SPECIFIC ___ "J I- •nc M (l) SAMPLE DISCOSAL__nENbEco_DREniHN 10CIIENT OPIIONE __..... DETECTION LIMITS D COMMON PHODIICIS Cloii.iii* HOLDING TIMES O ENSECO DEPA-CIP DTIEH DouitH* RAW DATA COPIES NEEDED Qvks UNO ——— ——————...— ————————————.— ..__._.—— — ——— CUSTODY SEALS INTACT DYES ONO I OwtiwEictu DOHYWEI liEiiNQtibiiVu ~ "~ "" " ~~" OAu7"fiMr~" DECEIVED D*lt / IIML E.nseco QA Program Plan section No. Revision No. Date Page 3.4 23 of 62 8. CALIBRATION PROCEDURES AND FREQUENCY Standard/Reagent Preparation A critical element in the generation of quality data is the purity/quality and traceability of the standard solutions and reagents used in the analytical operations. Enseco continually monitors the quality of reagents and standard solutions througn a series of well-documented procedures. Primary reference standards and standard solutions used by Enseco are obtained from the National Institue of Standards and Technology, an EPA Cooperator Supplier, or other reliable commercial sources to ensure the highest purity possible. All standards and standard solutions are catalogued to identify the supplier, lot number, purity/concentration, receipt/preparation date, preparer's name, method of preparation, expiration date, and all other pertinent information. Stanaard solutions are validated prior to use. Validation procedures can range from a check for chromatographic purity to verification of the concentration of the standard using a standard prepared at a different time or obtained from a different source. Stoc< and working standards are checked regularly for signs of deterioration, such as discoloration, formation of precipitates, or change in concentration. Care is exercised in the proper storage and handling of standard solutions, and all containers are labeled as to compound, concentration, solvent, expiration date, and preparation data (initials of preparer/date of preparation). Reagents are examined for purity by subjecting an aliquot or subsample to the analytical method in which it will be used; for examole, every lot of dichloromethane (for organic extractaules) ~s analyzed for undesiraole contaminants prior to us0 in tho ;shnramrv ___________________________________________ TUT OO2 0832 Ir.seco QA Program Plan Section No. Revision No. 3.4 Date 4/9! Page 24 of 5Z Instrument Calibration and Tuning Calibration of instrumentation is required to ensure that the analytical system is operating correctly and functioning at the proper sensitivity to meet established reporting limits. Each instrument is calibrated with standard solutions appropriate to the type of instrument and the linear range established for the analytical method. The frequency of calibration and calibration verification and the concentration of calibration standards are determined by the manufacturer's guidelines, the analytical method. or the requirements of special contracts. Gas Chromatooraphy/Mass Spectrsmetry Each day prior to analysis of samples, the instrument is tuned with bromofluorobenzene (BFB) for volatile compounds and decafluorotriphenylphosphine (DFTPP) for semivolatile compounds or other tune criteria as specified by the method used. No samples are analyzed until the instrument has met the tuning criteria of the method. In general, the instrument is then calibrated for all target compounds. An initial calibration curve is produced to define the working range to establish criteria for identification. This initial calibration is evaluated on a daily basis to ensure that the system is within calibration. If the daily standard does not meet the established criteria, the system is recalibrated. 002 0333 E.nseco QA Proarani Plan Section No. Revision No. 3.4 Date Page 25 of il ChromatooraDhv The field of chromatograpny involves a variety of instrumentation ana detection systems. While calibration standards and acceptance criteria vary depending on the type of system and analytical methodology required for a specific analysis, the general principles of calibration apply uniformly. Each chromatographic system is calibrated prior to performance of analyses. Initial calibration consists of determining the working range, establishing limits of detection, and establishing retention time windows. The calibration is checked on a daily basis to ensure that the system remains within specifications. In addition, continuing calibrations are performed at frequencies required by the method used. If the calibration checks do not meet established criteria, corrective action is taken which may include recalibration and reanalysis of samples. The procedures include examination of instrument performance and analysis information, consultation with the Supervisor and a decision path to determine if recalibration and reanalysis of samples back to the previous acceptable calibration check is warranted. Metals Metals analysis basically involves two types of analytical instrumentation: inductively coupled argon plasma emission spectroscopy (ICP), and atomic absorption spectroscopy (AA). Each ICP is calibrated prior to any analyses being performed using criteria prescribed in the CLP protocol. The calibration is then verified using standards from an independent source. The working range of the instrument is established once every quarter using a linear range verification check standard. No values are reported above this upper concentration value without dilution. TUT OO2 0834 E.nseco QA Program Plan Section No. Revision No. 5.4 Date A/91 A calibration curve is established daily by analyzing a minimum of two standards, one of which is a calibration blank. The calibration is monitored throughout the day by analyzing a Continuing Calibration Blank (CCB) and a Continuing Calibration Verification standard (CCV). If the verification standard does not meet established criteria, corrective action must be performed. The procedures include examination of instrument performance and analysis information, consultation with the Supervisor and a decision path to determine if recalibration and reanalysis of samoles back to the previously acceptable calibration check is warranted. An interelement check standard is analyzed at the beginning and end of each analytical run, to verify that interelement and background correction factors have remained constant. Results outside of the established criteria trigger reanalysis of samples. Each AA unit is calibrated prior to any analyses being conducted. A calibration curve is prepared with a minimum of a calibration blan< and three standards and then verified with a standard that has been prepared from an independent source at a concentration near the middle of the calibration range. The calibration is then verified on an ongoing basis with a calibration blank and a midpoint calibration standard. If the ongoing calibration standard does not meet established acceptance criteria, corrective action must be performea. The procedures include examination of instrument performance and analysis information, consultation with the Supervisor and a decision path to determine if recalibration and reanalysis of samples back to the previously acceptable calibration check is warranted. All samples are spiked to verify the absence of matrix effects or interferences. The method of standard additions or samole dilution is used when matrix interferences are present. inseco OA Proaram Plan Section No. Revision No. 3.4 Date A/91 Page 11 of Wet Chemistry The field of conventional, non-metals analysis (wet chemistry) involves a variety of instrumental and wet chemical techniques. While calibration and standardization procedures vary depending on the type of system and analytical methodology required for a specific analysis, the general principles of calibration apply universally. Each system is calibrated prior to analyses being conducted. Calibration consists of defining the working range by use of a series of standard solutions, establishing limits of detection, and identifying potential interferences. The calibration is checked on an ongoing basis to ensure that the system remains within specifications. If the ongoing calibration check does not meet established criteria, corrective action must be performed. The procedures include examination of instrument performance and analysis information, consultation with the Supervisor and a decision path to determine if recalibration and reanalysis of samples back to the previous acceptable calibration check is warranted. Continuing calibrations are not performed for non-instrumental methods such as Total Dissolved Solids. Enseco OA Proram P'an Section No. Revision No. 3.4 Date A/91 Page 23 of 9. ANALYTICAL PROCEDURES Most analyses performed by Enseco are driven by regulatory concerns. Therefore, methods used at Enseco predominantly originate from regulatory agencies. Generally the methods used are those specified by the U.S. EPA and other federal agencies, state agencies, and professional organizations, as provided in the following references: Current EPA (CLP) protocols for the analysis of organic and inorganic hazardous substances including chlorinated dioxins and furans. "Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act," 40 CFR, Part 135. "Methods for Chemical Analysis of Water and Wastes," EPA-600/4-79-020 (revised March, 1983 or subsequent revision). "Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater," EPA-600/4-82-057 (July, 1982). "Test Methods for Evaluating Solid Waste" (SW-846), 2nd Edition (revised), Update I (1984), Update II (1985), 3rd Edition (1986), Update I (1989), Office of Solid Waste and Emergency Response, U.S. EPA. "Stanaard Methods for the Examination of Water and Wastewater.-' 15th Edition (1985) and 17th Edition (1989) American Public Health Association, American Water Works Association, Water Pollution Control Federation, Washington, DC (1985). "Official Methods of Analysis," 14th Edition, Association of Official Analytical Chemists, Arlington, VA (1984). "Methods for the Determination of Organic Compounds in Finishea Drinking Water and Raw Source Water," U.S. EPA, Environmental Monitoring and Support Laboratory - Cincinnati (September, 1986 or subsequent revision). "Annual Book of ASTM Standards," Volumes 11.01 and 11.02, American Society for Testing and Materials (ASTM), Philadelphia, PA (1987). "Techniques of Water Resources Investigations of the United States Geological Survey (USGS), Book 5, Laboratory Analysis," USGS, Washington, DC (1979). TU" Enseco CA ?-oaram Plan Sect::n No. Revision No. 3.4 Date A/91 Page 29 of ;Z The choice of method is dependent on the objectives of the study in terns of qualitative certainty, quantitative sensitivity, precision and accuracy, the type of matrix to be analyzed, and the regulatory program. Each method used routinely is documented in the form of an SOP. The SOP contains detailed instructions concerning both the use and the expected performance of the method. Enseco may deviate from standard methodologies if necessary or appropriate due to the nature or composition of the sample, based on the reasonable judgment of Enseco. Any deviations will be made consistent with recognized standards of the industry and/or this QA Program Plan. Any deviations from published methodology are documented and explained in the SOP. A complete description of the contents of laboratory SOPs is given in Section 17. Before any methods are routinely used to generate analytical data, the method is validated. Validation criteria consist of: Method selection by a senior staff member; Documentation of the method in an SOP. This includes a summary of the method, detailed description of the analytical procedure, calculations, reporting formats, safety concerns, ana special remarks: Testing of the method to verify detection limits ana linear range, establish reporting limits and precision and accuracy criteria: ana Establishment of data acceptance criteria that must be approved by a senior staff member and the Divisional QA Director. TUT 002 Enseco OA Program Plan Section No. Revision No. Date A/91 Page 30 of 10. DATA REDUCTION, VALIDATION, AND REPORTING Data Reduction and Validation All analytical data generated within Enseco laboratories are extensively reviewed prior to report generation to assure the validity of the reported data. The data validation process consists of data generation, reduction, and three levels of documented review, as described below (also see Figure 10-1). In each stage, the review process is documented by the signature of the reviewer and the aare reviewed. The analyst who generates the analytical data has the prime responsibility for the correctness and completeness of the data. All data are generated and reduced following protocols specified in laboratory SOPs. Each analyst reviews the quality of his or her work based on an established sat of guidelines. The analyst reviews tr.a data package to ensure that: Samoie preparation 'nformation is correct ana comolete: Analysis information is correct and comolets: The appropriate SOPs have been followed: Analytical results are correct and complete; QC samples are within established control limits; Blanks are within appropriate QC limits; Special sample preparation and analytical requirements have been met; and Documentation is comolete (e.g., all anomalies in the preparation and analysis have been documented, anomaly forms are complete: holding times are documented, etc.). Figure 10-1 Initiate Sample Analysis Chemist Reviews Data Data Validation Scheme Results Acceptable I Perform Corrective j Action___j Yes Data Review Specialist X Results Acceptable No [ Perform Corrective j I Action I Yes Program Administrator Results Acceptable 5% Audits Hardcopy Report to Perform Corrective Action Quality Assurance Office Enseco QA Program P:an Seci::n No. Revision No. 3.4 Date 4/91 Page 32 of 6; The data reduction and validation steps are documented, signed ana dated by the analyst. This initial review step, performed by the analyst, is designated Level 1 review. The analyst then passes the data package to an independent reviewer, who performs a Level 2 review. Level 2 review is performed by a supervisor or data review specialist whose function is to provide an independent review of the data package. This review is also conducted according to an established set of guidelines and is structured to ensure that: Calibration data are scientifically sound, appropriate to the method, and completely documented; QC samoles are within established guidelines; Qualitative identification of sample components is correct; Quantitative results are correct; Documentation is complete and correct (e.g., anomalies in the preparation and analysis have been documented; anomaly forms are complete: holding times are documented, etc.); The data are ready for incorporation into the final report: ana The data package is complete and ready for data archive. Level 2 review is structured so that all calibration data and QC sample results are reviewed and all of the analytical results from 10% of the samples are checked back to the bench sheet. If no problems are found with the data package, the review is complete. If any problems are found with the data package, an additional 10% of the samples are checked to the bench sheet. The process continues until no errors are found or until the data package has been reviewed in its entirety. An important element of Level 2 review is the documentation of any errors that nave oeen identifiea ana corrected durina tne review Tl.il OO2 i.Tseco QA Proaram Plan Section No. Revision No. 3.4 Date A/91 Page 33 of ;; process. Enseco believes that the data package suomitted by the analyst for Level 2 review should be free of errors. Errors that are found are documented and transmitted to the appropriate supervisor. The cause of the errors is then addressed with additional training or clarification of procedures to ensure that quality data will be generated at the bench. Level 2 data review is also documented and the signature of the reviewer and the date of review recorded. The reviewed data are then approved for release and a final report is prepared. Before the report is released to the client, the data are reviewed for completeness and to ensure that the data meet the overall objectives of the project. This review is labeled Level 3 review and is typically done by the Program Administrator. Each step of this review process involves evaluation of data quality based on both the results of the QC data and the professional judgment of those conducting the review. This application of technical knowledge and experience to the evaluation of the aata is essential in ensuring that data of high quality are generated consistently. In addition to the three levels of review discussed above, the Divisional QA department randomly audits 5% of all projects reported. The QA audit includes verifying that holding times have been met, calibration checks are adequate, qualitative and quantitative results are correct, documentation is complete, and QC results are complete and accurate. During the review, the QA department checks the data from 20% of the samples back to the bench sheet. If no problems are found with the data package, the review is complete. If any problems are founa with the data package, an additional 10% of the samples are checked to the bench sheet. The process continues until no errors are found or until the data oackaoe has been reviewed in its entirety. Enseco QA Program Plan Section No. Revision No. Date Page 34 of -.2 Data Reporting A variety of reporting formats, from computerized data tables, to complex reports discussing regulatory issues, to a CLP-deliveraoles package, are available. In general, Enseco reports contain: General Discussion: Description of sample types, tests performed. ; problems encountered and general comments are given. Analytical Data: Data are reported by sample or by test. Pertinent information including dates sampled, received, prepared, and extracts are included on each results page. The Enseco reporting limit for each analyte is also given. Laboratory Performance QC Information: The results (Percent Recovery and Relative Percent Difference) of the Laboratory Control Samoles analyzed with the project are listed, together with the control limits. Also, the analytical results for method blanks generated during analysis of organic and metals parameters are given. Matrix-Soecific QC Information: Results of any samoie duplicates. matrix spikes, matrix spike duplicates or other project-specific QC requested fay the client are also reported. Methodology: Reference for analytical methodology used is cited. Custom Services: Special services including data interpretation. special consultation, and raw data packages (when requested) are included. Enseco CA Program Plan Section No. Revision No. Date Page 3. A 4/91 35 or 62 11. INTERNAL QC CHECKS The Enseco QA/QC program monitors data Quality with internal QC checks. Internal QC checks are used to answer two questions: 1) Are laboratory operations "in control," (i.e., operating within acceptable QC guidelines), during data generation? 2) What effect does the samole matrix have on the data being generated? The first question is answered by Laboratory Performance QC. Laboratory performance QC is based on the use of a standard, control matrix to generate precision and accuracy data that are compared, on a daily basis, to control limits. This information, in conjunction with method blank data, is used to assess daily laboratory performance. The second question is addressed with Matrix-Specific QC. Matrix- Specific QC is based on the use of an actual environmental sample for precision and accuracy determinations and commonly relies on the analysis of matrix spikes, matrix duplicates, and matrix spike duolicates. This information, supplemented with field blank results, 'is used to assess the effect of the matrix and field conaitions on analytical data. Laboratory Performance QC is provided as a standara part of every routine Enseco analysis. Matrix-Specific QC is available as an option to the client and should be specified based on the types of matrices to be analyzed and the Data Quality Objectives (DQOs) ana regulatory requirements of the project. A complete discussion of the Enseco Internal QC Check program follows. Laboratory Performance QC Program Laboratory Performance QC is performed for every routine Enseco analysis to demonstrate that laboratory operations are "in control". The main elements of Laboratory Performance QC are: TLH Enseco QA Program Plan Section No. ! 1 Revision No. 3.4 Date 4/91 The analysis of Laboratory Control Samples, which include Duplicate Control Samples (DCS), Single Control Samoles (SCS), and method blanks, and The use of calibration standards to assure that both qualitative identification and quantitative measurements are within control limits. The Laboratory Control Sample program is discussed below. Please refer to Section 8 of this manual for a discussion of calibration procedures. Laboratory Control Samples fLCS) Laboratory Control Samoles (LCS) are well-characterized, laboratory generated samples used to monitor the laboratory's day-to-day performance of routine analytical methods. Three types of LCS are routinely analyzed: Duplicate Control Samples (DCS), Single Control Samples (SCS), and method blanks. Certain LCS (DCS, SCS) are used to monitor the precision and accuracy of the analytical process, independent of matrix effects. Other LCS (method blanks) are used to identify any background interference or contamination of the analytical system which may lead to the reporting of elevated concentration levels or false positive data. Each of these LCS are described below. The results of the LCS are comoared to well-defined laboratory acceptance criteria to determine whether the laboratory system is "in control." Controlling lab operations with LCS (as opposed to matrix spike/matrix spike duplicate samples), offers the advantage of being able to differentiate quality problems due to laboratory procedural errors from those due to matrix effects. As a result, procedural errors can be identified and corrected by the analyst at the bench, without waiting for extensive senior level review or costly and time-consuming reanalysis of the samole. Til Enseco OA Program Plan Sect:cn No. Revision No. 3.4 Date 4/91 Page 37 of Duplicate Control Samples (DCS) Duplicate Control Samples (DCS) are used to monitor the precision and accuracy of the analytical system on an on-going basis. Each DCS consists of a standard, control matrix that is spiked with a group of target compounds representative of the method analytes. A DCS pair is analyzed for every 20 samples processed by the method. DCS are analyzed with environmental samples to provide evidence that the laboratory is performing the method within accepted QC guidelines for accuracy and precision. Accuracy data (average recovery of each analyte in the DCS pair) and precision data (Relative Percent Difference [RPD] between each analyte in the DCS pair) are compared to control limits that have been established for each of the analytes contained in the DCS. Initially, control limits for analytes spiked into the DCS are taken directly from the CLP program. If CLP limits are not available, Enseco historical data are used to set the control limits. The control limits are recalculated periodically, as sufficient laboratory data become available. Control limits for accuracy for each analyte are based on the historical average recovery (mean of the average recoveries of the DCS pairs) plus or minus three standard deviation units. Control limits for precision for each analyte are basea on the historical RPD. Acceptable RPDs range from zero (no difference between DCS results) to the average RPD plus three standard deviation units. Analytical data that are generated with a DCS pair which falls within the established control limits are judged to be in control. Data generated with a DCS pair which falls outside of the control limits are considered suspect and corrective action must be performed. The procedure used to evaluate data from control samples is given in Figure 11-1. The procedures include examination of instrument performance and preparation and analysis information, consultation with the supervisor, and finally a decision path for determining whether reanalysis is warrantee;. 0846 Enseco QA Program Plan Section No. Revision No. Date 4/91 Page 38 or i2 DCS have been established for each routine analytical method. Reagent water is used as the control matrix for the analysis of aqueous samples. The DCS compounds are spiked into reagent water and carried through the appropriate steps of the analysis. The control matrix for solids samples for organic analyses is standard Ottawa sand, an ASTM approved material for use in highway construction, due to its homogeneity. The DCS compounds are spiked into the Ottawa sand and carried through the appropriate steps of the analysis. For metal analyses, a spiked solid matrix from a commercial source is used. As stated previously, DCS are analyzed at a frequency of no less than one DCS pair per 20 samples. The DCS program is supplemented with the SCS program to ensure that Laboratory Performance QC is available with each batch of samples processed (see following subsection). I JQiiro 11-1 Laboratory Performance QC Control Sample Evaluation ooralory Conirol mple Generated DCS/SCS Analyzed Yes Ho Renorl data with all associated samplos VallUale operatio sensitivity Problem Identified I Yes I Correct & reanalyze Refer problem to Supervisor Confer wllli Sample Prep' Group Is problem related • only la DCS/SCS Yfes Report data with all associated samples (w/uxpliiiiatlon) No Yes Reextracl & Heunulyte Yes Renorl data with all associated samples Report data with all associated samples Can all samples be ruexlracied? Document on I1CU/SCS I Report data wllli all associated samplou (w/explanallon) Enseco QA Program Plan Section No. Revision No. 3.4 Date 4/91 Page 4Q Of 62 DCS precision and accuracy data are arcnived in the LIMS. In addition, the associated DCS data are reported with each set of sample results to enable the client to make a quality assessment of the data. Single Control Samples (SCSI As stated above, a DCS pair is analyzed with every 20 samples to measure the precision and accuracy of an analysis on an ongoing basis. However, samples are often analyzed in lots of less than 20, due to holding time or turn-around time requirements. Since it is necessary to have a measure of laboratory performance with each batch of samples processed, Enseco has instituted the SCS program. An SCS consists of a control matrix that is spiked with surrogate compounds appropriate to the method being used. In cases where no surrogate is available, (e.g., metals or wet chemistry) a single DCS serves as the control sample. An SCS is prepared for each sample lot for which the DCS pair are not analyzed. Recovery data generated from the SCS are compared to control limits that have been established for each of the compounds being monitored. Initially, CLP control limits or Enseco historical data are used to set the control limits. Control limits are recalculated periodically as sufficient SCS data are available. Control limits for SCS components are based on the historical average recovery in the SCS plus or minus three standard deviation units. Analytical data that are generated with an SCS which falls within the control limits are judged to be in control. Data that are generated with an SCS which falls outside of acceptance criteria are considered suspect and corrective action must be performed. The protocols for evaluating SCS are identical to those established for DCS (see Figure 11-1). SCS recovery (accuracy) data are archived in the LIMS. In addition, the associated SCS data are reported with each set of sample results to enable the client to make a quality assessment of the data. Enseco QA Program Plan Section No. Revision No. 3.4 Date A/91 Page Al of 62 Method Blank Method blanks, also known as reagent, analytical, or preparation blanks, are analyzed to assess the level of background interference or contamination which exists in the analytical system and which might lead to the reporting of elevated concentration levels or false positive data. As part of the standard Enseco QC program, a method blank is analyzed with every batch of samples processed. A method blank consists of reagents specific to the method which are carried through every aspect of the procedure, including preparation, clean-up, and analysis. The results of the method blank analysis are evaluated, in conjunction with other QC information, to determine the acceptability of the data generated for that batch of samples. Ideally, the concentration of target analytes in the blank should be below the Reporting Limit for that analyte. In practice, however, some common laboratory solvents and metals are difficult to eliminate to the parts-per-billion levels commonly reported in environmental analyses. Therefore, criteria for determining blank acceptability must be based on consideration of the analytical techniques used, analytes reported, and Reporting Limits required. For organic analyses, the concentration of target analytes in the blank must be below the Reporting Limit for that analyte in order for the blank to be considered acceptable. An exception is made for common laboratory contaminants (methylene chloride, acetone, 2-butanone, and phthalate esters) which may be present in the blank at up to 5 times the Reporting Limit and still be considered acceptable. This policy is consistent with the CLP policy and has been established in recognition of the fact that these compounds are frequently found at low levels in method blanks due to the materials used in the collection, preparation, and analysis of samples for organic parameters. Enseco QA Program Plan Section No. Revision No. 3.4 Date A/91 Page <*2 of 62 For non-routine organic analyses, other components may be established as common contaminants for that particular analysis. For example, naphthalene is frequently found in PAH-SIM analyses. If, upon thorough review of the method during validation (see Section 9) it is deemed impossible to eliminate trace amounts of analytes from the process, these analytes are likewise allowed at up to 5 times the reporting limit. For metals and Wet Chemistry analyses, where the Reporting Limits are typically near the Instrument Detection Limit (IDL), the policy is that the concentration of the target analytes in the blank must be below two times the Reporting Limit. If the blank value for a target analyte lies below the Reporting Limit, the Reporting Limit for that analyte in the associated samples is unaffected. If the blank value lies between the Reporting Limit and two times the Reporting Limit, the Reporting Limit for that analyte in the associated samples is raised to the level found in the blank. A blank containing an analyte(s) above two times the Reporting Limit is considered unacceptable unless the lowest concentration of the analyte in the associated samples is at least ten times the blank concentration (as per CLP protocol) or the concentration of the analyte in all samples associated with the blank is below the reporting limit. In addition, for Wet Chemistry tests, the method SOP directs how the blank is treated. Generally, a reagent blank is used both to zero the equipment and as one of the calibration standards. If a preparation step is required for the analysis, then a prep blank is also analyzed to determine the extent of contamination or background interference. The concentration found in the prep blank is subtracted from the concentration found in any associated sample prior to calculating the final result when specified by the method. Blanks have no application or significance for some Wet Chemistry parameters (e.g. pH). TUT Enseco QA Program Plan Section No. 11 Revision No. 3.4 Date 4/91 Page A3 of 52 If the blank does not meet acceptance criteria, the source of contamination must be investigated and appropriate corrective action must be taken and documented. Investigation includes an evaluation of the data to determine the extent and effect of the contamination on the sample results. Corrective actions may include reanalysis of the blank, and/or repreparation and reanalysis of the blank and all associated samples. For organic and metals analyses, and selected Wet Chemistry tests, method blank results are reported with each set of sample results. Sample results are not corrected for blank contamination unless required by the analytical method or requested by the client. Occasionally, due to limited sample volume or other constraints, the laboratory reports data associated with an unacceptable blank. In these cases, the Reporting Limit for each analyte contained in the blank is raised to the level found in the blank for all sample results associated with that blank. Matrix-Specific QC Matrix-Specific QC is used to assess the effects of a samole matrix or field conditions on the analytical data. The main elements of Matrix- Specific QC are: The analysis of matrix spikes, matrix duplicates, and matrix spike duplicates; Monitoring the recovery of surrogate compounds from environmental samples; Monitoring the results of standard additions in environmental samples; The analysis of field blanks; and The determination of method detection limits in a specific matrix. TUT Enseco QA Program Plan Section No. 11 Revision No. 3.4 Date 4/91 Different regulatory programs have different requirements in terms of Matrix-Specific QC. In order to ensure that the data generated meet all Data Quality Objectives, Enseco recommends that its clients include Matrix-Specific QC that fulfills the Data Quality Objectives and regulatory requirements of the project. A discussion of the different elements of Matrix-Specific QC follows. Matrix Spikes. Matrix Duplicates, and Matrix Spike Duplicates A Matrix Spike (MS) is an environmental sample to which known concentrations of analytes have been added. The MS is taken through the entire analytical procedure and the recovery of the analytes is calculated. Results are expressed as percent recovery. The MS is used to evaluate the effect of the sample matrix on the accuracy of the analysis. A Matrix Duplicate (MD) is an environmental sample that is divided into two separate aliquots. The aliquots are processed separately and the results compared to determine the effects of the matrix on the precision of the analysis. Results are expressed as RPD. A Matrix Spike Duplicate (MSD) is an environmental sample that is divided into two separate aliquots, each of which is spiked with known concentrations of analytes. The two spiked aliquots are processed separately and the results compared to determine the effects of the matrix on the precision and accuracy of the analysis. Results are expressed as RPD and percent recovery. Surrogate Recoveries and Standard Additions Surrogates are organic compounds which are similar to the analytes of interest in chemical behavior, but which are not normally found in —————————————————————————————————————————————— TUT OO2 0853 Enseco QA Program Plan Section No. Revision No. 3. Date A/91 Page *5 of 5Z environmental samples. Surrogates are added to samples to monitor the effect of the matrix on the accuracy of the analysis. Results are reported in terms of percent recovery. Enseco routinely adds surrogates to samples requiring GC or GC/MS analysis and reports these surrogate recoveries to the client. The laboratory does not control its operations based on surrogate recoveries in environmental samples. As discussed earlier in this section, Enseco controls its operations based on the results of Laboratory Control Samples. The surrogate recoveries are primarily used by the laboratory to assess matrix effects. However, obvious problems with sample preparation and analysis (e.g. evaporation to dryness, leaking septum, etc.) which can lead to poor surrogate spike recoveries must be ruled out prior to attributing low surrogate recoveries to matrix effects. Standard Additions (SA) is the practice of adding a series of known amounts of an analyte to an environmental sample. The fortified samples are then analyzed and the recovery of the analytes calculated. The practice of SA's is generally used with metal and wet chemistry to determine the effect of the sample matrix on the accuracy of the analyses. Field Blanks Field blanks are check samples that monitor contamination originating from the collection, transport or storage of environmental samples. One example of a field blank is an equipment blank. An equipment blank is blank water that is poured through the sample collection device to check the adequacy of the cleaning procedures for the sampling equipment. Another type of field blank is a trip blank. A trip blank is a laboratory control matrix (typically water) which is sent to the field in an appropriate sample container, remains unopened in the field, and then TUT 002 OS54 Enseco QA Program Plan Section No. Revision No. 3.4 Date 4/91 is sent back to the laboratory. The purpose of the trip blank is to assess the impact of field and shipping conditions on the samples. The results from field blanks are reported to the client as samples in the same concentration units as the samples. No correction of the analytical data is done in the laboratory based on the analysis of field blanks. Matrix-Specific Detection Limits Method Detection Limits (MDL's) determined on a specific sample matrix are called Matrix-Specific Detection Limits. See Section 14 for a discussion of detection and reporting limits. TUT 00:,:' Enseco QA Program Plan Section No. \2 Revision No. 3.4 Date 4.91 12. PERFORMANCE AND SYSTEM AUDITS Enseco laboratories participate in a variety of federal and state programs, (including the U.S. EPA CLP), that subject each of the laboratories to stringent system and performance audits on a regular basis. A system audit is a review of laboratory operations conducted to verify that the laboratory has the necessary facilities, equipment, staff and procedures in place to generate acceptable data. A performance audit verifies the ability of the laboratory to correctly identify and quantitate compounds in blind check samples submitted by the auditing agency. The purpose of these audits is to identify those laboratories that are capable of generating scientifically sound data. Enseco is certified to perform environmental analyses under programs administered by the U.S. Department of Energy, U.S. Air Force, U.S. Navy, and over 20 states. The most current list of Enseco certifications is available upon request. In addition to external audits conducted by certifying agencies or clients, Enseco regularly conducts the following internal audits: Quarterly systems audits conducted by the Divisional QA Director. Periodic (at least yearly) audits conducted by the Corporate QA Office. Special audits by the Divisional QA Director or Corporate QA Office when a problem is suspected. Enseco laboratories also routinely analyze check samples as described below: Laboratory Control Samples (DCS, SCS, and method blanks) are analyzed at a frequency equal to at least 10% of the total number of samples analyzed (see Section 11). TUT Enseco QA Program Plan Section No. v. Revision No. 3.4 Date 4.91 Page -13 of 52 All Enseco laboratories participate in the analyses of EPA check samples provided under the Water Supply (WS) and Water Pollution (WP) Performance Evaluation Studies. The results of these PE samples are tabulated by the Corporate QA Office to identify performance trends within the Enseco laboratories. The majority of the Enseco laboratories are CLP labs and thus analyze organic and/or inorganic CLP PE samples on a quarterly basis. The results of these analyses are also tabulated and evaluated by the Corporate QA Office. The laboratories participate in multiple state certification programs (including New York, New Jersey and California) which require that PE samples be analyzed periodically. Blind check samples from an independent commercial firm are sent to the laboratories periodically by the Corporate QA Office. The frequency and type of samples sent is based on problem areas identified by evaluation of tabulated PE results. The results of these check samples are used to identify areas where additional training is needed or clarification of procedures is required. Enseco QA Program Plan Section No. Revision No. Date Page 3.4 of 52 13. PREVENTIVE MAINTENANCE To minimize downtime and interruption of analytical work, preventive maintenance is routinely performed on each analytical instrument. Designated laboratory personnel are trained in routine maintenance procedures for all major instrumentation. When repairs are necessary, they are performed by either trained staff or trained service engineers employed by the instrument manufacturer. Each laboratory has detailed SOPs on file that describe preventive maintenance procedures and schedules. The laboratories also maintain detailed logbooks documenting the preventive maintenance and repairs performed on each analytical instrument. Enseco QA Program Plan Section No. Revision No. Date -1/91 Page 50 of 14. SPECIFIC ROUTINE PROCEDURES USED TO ASSESS DATA QUALITY AND DETERMINE REPORTING LIMITS Data Quality Assessment The effectiveness of a QA program is measured by the quality of data generated by the laboratory. Data quality is judged in terms of its precision, accuracy, representativeness, completeness and comparability. These terms are described as follows: Precision is the degree to which the measurement is reproducible. Precision can be assessed by replicate measurements of DCS, reference materials, or environmental samples. Enseco routinely monitors precision by comparing the RPD between DCS measurements with control limits established at plus three standard deviations from the mean RPD of historical DCS data. Precision is frequently determined by comparison of replicates. The standard deviation of "n" measurements of "x" is commonly used to estimate precision. Standard deviation (s) is calculated as follows: s - / J_ 2. (xi - x)2 n-1 1-1 where a quantity "x" (e.g., a concentration) is measured "n" times. Enseco QA Program Plan Section No. Revision No. 3.4 Date 4/91 The relative standard deviation, which expresses standard deviation as a percentage of the mean, is generally useful in the comparison of three or more replicates (although it may be applied in the case of n = 2). RSD = 100 (s/x) where: RSD = relative standard deviation s = standard deviation x = mean In the case of duplicates, the RPO between the two samples may be used to estimate precision. - 02 | RPO = x 100 + 02)/2 where: RPO = relative percent difference DI = first sample value D2 = second sample value (duplicate) Accuracy is a determination of how close the measurement is to the true value. Accuracy can be assessed using LCS, standard reference materials, or spiked environmental samples. Unless specified otherwise in special contracts, Enseco monitors accuracy by comparing LCS results with control limits established at plus or minus three standard deviation units from the mean of historical LCS results. Enseco QA Program Flan Section No. Revision No. 3.4 Date A/91 The determination of the accuracy of a measurement requires a knowledge of the true or accepted value for the signal being measured. Accuracy may be calculated in terms of percent recovery as follows: x Percent Recovery = y x 100 where: x =• the observed value of measurement T = "true" value Representativeness is the degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. Analytical data should represent the sample analyzed regardless of the heterogeneity of the original sample matrix. Enseco strives to accommodate all sample matrices. Some samples may require analysis of multiple phases to obtain representative results. Completeness is a measure of the amount of valid data obtained from a measurement system compared with the amount that, was expected to be obtained under normal conditions. To be considered complete, the data set must contain all analytical results and data specified for the project. In addition, all data are compared to project requirements to ensure that specifications were met. Any deviations are reported in the report narrative. The percent completeness for each set of samples can be calculated as follows: valid data obtained Completeness = ———————————— x 100% total data Enseco QA Program Plan Section No. Revision No. 3.4 Date Comoarability expresses the confidence with which one data set can be compared to another data set measuring the same property. Comparability is ensured through the use of established and approved analytical methods, consistency in the basis of analysis (wet weight, volume, etc.), consistency in reporting units (ppm, ppb, etc.), and analysis of standard reference materials. Reporting Limits Assuring the validity of quantitative measurements at low concentrations is an extremely difficult technical problem. With regulatory action levels being pushed lower and lower, the validity of any given measurement becomes even more important. The consequences of false positive or false negative data can be significant. A number of terms have been used, by the EPA and other technical groups, to express the lowest concentration of an analyte which can be measured. Some of these terms, their definitions, and sources are listed in Table 14-1. A graphical representation of these terms is given in Figure 14-1. Enseco takes very seriously its responsibility to report technically defensible data. Therefore, we have established a Reporting Limit (RL) for each analyte in each method. The RL represents the value above which we believe reliable data can be routinely obtained. These Reporting Limits were established by collecting Method Detection Limit (MDL) data for organic and wet chemistry analyses and Instrument Detection Limit (IDL) data for metals analyses from each Enseco laboratory. The MDL data were collected using the procedures described in 40 CFR 136 Appendix B. IDL data were calculated using the procedures outlined in the EPA Contract Laboratory Program (CLP) Statement of Work dated 7/88. The MDL/IDL data were then compared to various limits published in EPA methods and in the regulations. For example for Enseca QA Program Plan Section No. Revision No. 3.4 Date a/91 Page :4 of 5Z Volatile Organics, the MDL data generated in Enseco laboratories were compared to the Practical Quantitation Limits (PQLs) published in SW-846 method 8240; the PQLs contained in the July 9, 1987, Federal Register Final Rulemaking on Appendix IX; the Contract Required Quantitation Limits (CRQLs) in the CLP Method for Volatile Organics; and the MDLs in Method 624. Then a Reporting Limit for each analyte was established which considered all of this information. The RL was set at a level above which we were confident that our laboratories could detect and quantify the analyte consistently. Using this procedure, the Reporting Limits established are generally between 2 to 5 times the laboratory MDL/IDL. This range is consistent with the American Chemical Society definition for the Limit of Quantitation (LOQ). (See Table 14-1) Enseco routinely reports results below the reporting limit as Not Detected (ND) because, by definition, the reliability of the data at that level is questionable. As an option, Enseco can report data below the reporting limit and flag the data. Reporting limits are adjusted for sample dilution. ,..,-^ 0863 TUT '••>-••- TABLE H-1 DEFINITION OF DETECTION LIMIT TERMS itectlon LI rait (DL) DEFINITION Tho concentration which Is distinctly detectable above, but close to a blank. DETERMINATION Analysis of replicate standards CALCULATION Two times the standard devlatIon SOURCE Methods for Analysis of Wastes ChomlcaI Water and mi t of Detection (LOD) The lowest concentration Analysis that can be determined to samples bo statistically different from a blank of rep!Icate Three times the standard deviation ACS Definition it hod Detection LImlt 401.) The minimum concentration of a substance that can be Identified, measured and reported with 99% confidence that the analyte concentration Is greater than zero. Analysis of a minimum of seven replIcates spiked at 1 to 5 times the expected detection l i m i t . The standard deviation times the Student t- value at.the desired confidence level. (For seven replicates, the value Is 3.14) 40 CFR 136 D a f I u l t I o n for ERA Water Program: istrument Detection i m i l (IIJL) The smallest signal above background noise that an Instrument can detect rellably. Analysis of seven replicate standards on three non-consecutive days. Three times the Contract Laboratory standard deviation Program at hod Quant I tat Ion Limit '401.) The minimum concentration of a substance that can be measured and reported Analysis of replicate samples Five times the standard deviation SW-846 of Quant I tat Ion The level above which quantitative results may be obtained wltha speclfled degree of confidence Analysis of samples replIcate Ten times deviation the standard ACS Definition cal Quant I tat Ion (PQD The lowest level that can be reliably determined within specified limits of precision and accuracy during routine laboratory operating condlI Ions Interlaboratory analysis of check samples 1) Ten times the MDL 2) Value where BOX of laboratories are within 20X of the true value RCRA SDWA Programs mil i in.I |loi|ii|| oil ,......» i i i ,„ i» /,..,,,. llopuitlnij l i m i t o|io(, I f I oil Unknown Unknown Enseco QA Program Plan Section No. Revision No. Date Page 3.4 i/91 E5 of 62 FIGURE 14-1 Graphical Representation of Detection Limit Terms (See Table 14-1 for Definitions) DL LOD/IDL MDL MQL LOQ PQL i i MULTIPLIER OF STANDARD DEVIATION OF REPLICATES NOTE: The values along the horizontal "Standard Deviation (SO)" axis are approximate values and are meant to show the relative, not absolute, relationship between the terms. Enseco QA Program Plan Section No. Revision No. 3.4 Date 4/91 15. CORRECTIVE ACTION When errors, deficiencies, or out-of-control situations exist, the QA program provides systematic procedures, called "corrective actions," to resolve problems and restore proper functioning to the analytical system. Laboratory personnel are alerted that corrective actions may be necessary if: QC data are outside the acceptable windows for precision and accuracy; Blanks, DCS or SCS contain contaminants above acceptable levels; Undesirable trends are detected in spike recoveries or RPD between duplicates; There are unusual changes in detection limits; Deficiencies are detected by the QA department during internal or external audits or from the results of performance evaluation samples; or Inquiries concerning data quality are received from clients. Corrective action procedures are often handled at the bench level by the analyst, who reviews the preparation or extraction procedure for possible errors, checks the instrument calibration, spike and calibration mixes, instrument sensitivity, and so on. If the problem persists or cannot be identified, the matter is referred to the laboratory supervisor, manager and/or QA department for further investigation. Once resolved, full documentation of the corrective action procedure is filed with the project records. 1 UT Enseco QA Program Plan Section No. Revision No. Date Page 3.4 4/91 58 of 6Z 16. QA REPORTS TO MANAGEMENT The reporting system is a valuable tool for measuring the overall effectiveness of the QA program. It serves as an instrument for evaluating the program design, identifying problems and trends, and planning for future needs. Divisional QA Directors submit extensive monthly reports to the Corporate QA Director, the Director of Quality Assurance and Technology, the General Manager and the President. These reports include: The results of internal systems audits including any corrective actions taken; Performance evaluation scores and commentaries; Results of site visits and audits by regulatory agencies and clients; Performance on major contracts, (including CLP); Problems encountered and corrective actions taken; Holding time violations; Comments and recommendations; and A summary of the 5% QA data audits conducted. The Corporate QA Director regularly reports on the status of the QA Program to the President and each General Manager. These reports summarize the information gathered through the laboratory reporting system and contain a thorough review and evaluation of laboratory operations throughout Enseco. T OO2 086V Enseco QA Program Plan Section No. Revision No. 3.4 Date A/91 17. LABORATORY DOCUMENTATION Complete and accurate documentation of analytical and procedural information is an important part of the QA program. The following describes different types of documentation used in the Enseco laboratories. SOPs Details of analytical and QC protocols are contained in SOPs. SOPs are documents that contain detailed proprietary information on how to perform a laboratory procedure. Enseco has four categories of laboratory SOPs: SOPs for Performance of an Analytical Method; SOPs for Preparation of Standards and Reagents; SOPs for Equipment Operation, Calibration, and Maintenance; and SOPs for General Laboratory Procedures. The formats for these SOPs are given in Appendix II. All SOPs are approved by the QA Department before being implemented. The distribution of current SOPs and archiving of outdated ones is controlled through the QA Department. Because of the detailed nature of SOPs, Enseco considers them to be proprietary documents. SOPs are available for review at each location. Enseco QA Program Plan Section No. Revision No. 3.4 Date 4/91 LIHS Enseco laboratories rely on a customized Laboratory Information Management System (LIMS) as the primary database. Client information, sample results, and QC results are all stored in the LIMS. Reports are generated directly from the database to eliminate transcription errors. A tiered security system is in place to control the ability of lab personnel to change results, and the system is designed with an audit trail that identifies when information has been changed and who changed it. The most recent data are kept on-line. Data are periodically archived on magnetic tape or optical disk. Laboratory Bench Sheets Laboratory bench sheets are used to document information from routine laboratory operations, including sample preparation and analysis. Bench sheets are used to ensure that the information is recorded in a complete and organized manner and that the analysis can be reconstructed, if necessary. Portions of information from the bench sheet are also stored in the LIMS. Each bench sheet is initialed and dated as information is entered. Laboratory Notebooks Laboratory notebooks are used to document information that cannot easily be recorded on benchsheets such as methods development information. Each page in a laboratory notebook is initialed and dated as information is entered. Enseco QA Program Plan Section No. Revision No. 3.4 Date 4/91 Control Charts Enseco laboratories use control charts to visually track the LCS precision and accuracy data. These control charts are used to identify trends in the analyses which may indicate a problem with the analytical procedure. When an adverse trend is detected corrective action is performed. Anomaly Forms Any situation which is outside of the normal scope of operations, as described in the laboratory SOPs, is documented on an Anomaly Form. Examples of anomalous situations include: formation of a precipitate in an extract; formation of an emulsion during an extraction step; or missed holding times. These situations are documented to enable a thorough review of the data to occur. Out-of-Control situations are also documented on Anomaly Forms. An Out- of-Control situation occurs when QC data fall outside of established control limits. The documentation associated with an Out-of-Control situation is reviewed by the supervisor and the QA Department. Out-of- Control situations trigger Corrective Action. Corrective Actions taken are also documented on the Anomaly Form. Project Files The project file consists of a project summary file and a raw data file. The project summary file includes correspondence from the client, (letters, phone logs, contracts, project plans) copies of preliminary ana final reports, chain of custody, air bills, photographs of samples, level 3 review checklists, QA review checklist when applicable and the summary Enseco QA Program Plan Section No. Revision No. 3.4 Date */91 file inventory. The raw data file includes sample data, QC data, benchsheets, level 1 and level 2 review checklists, instrument logbook pages pertinent to the project and the raw data file inventory. Contracts, project plans, calibration data and QC data may be stored separately from the project record. All project records contain cross- references to this information. When a project is complete, all records are passed to the Document Custodian who inventories the file, checks for completeness, and puts the file into document archive. TUT 002 08: APPENDIX I MAXIMUM HOLDING TIMES AND SAMPLE COLLECTION/PRESERVATION INFORMATION Sources: Tables A-E Federal Register, October 26, 1984 Methods for Chemical Analyses of Water and Wastes SV-846, 3rd Edition, Update I State of California Leaking Underground Fuel Tank Field Manual, May 1988 Table F: Contract Laboratory Program Statement of Work for Organic Analysis dated 3/90 (as amended) Contract Laboratory Program Statement of Work for Inorganic Analysis dated 7/88 Table G: Federal Register, June 29, 1990 (QA Program Plan, Revision 3.4) 002 0872 A. VOLATILE ORGANICS Matrix Container Minimum Sample Size Preaervative Holding Time (From Date Sampled) Water Sanples No llculdual Chlorine Present Residual Chlorine Present Acrolein and Acrylonltrlle Soil/sediments and Sludges Concentrated Haste Samples 3 40 ml. vialn with Teflon lined septum cape 3 40 mL vials with Teflon lined septum caps 3 40 mL vials with Teflon lined septum cape Glass jar with Teflon liner or core tube Glass jar with Teflon liner or core tube 4O mL HC1 to pll<2, 4°C 40 mL 4 drops of 10% sodium thiosulfate, HCl to pH<2, 4°C 40 mL Adjust to pH 4-5, 4°C 10 g 4°C 10 g None 14 dayu 14 days 14 days 14 dayu 14 dayu The above information applies to the following parameters and methods: garameter Method Volatile llalocarbons Volatile Aromatica Volatile Organics Acrolein/Aerylonitrile 601/8010 (GC) 602/8020 (GC) 624/8240/8260 (GC/MS), 8015 (GC) 603/8030 (GC) AI-1 (QA Program Plan, Kuviuimi .). -I) SEMIVOLATILE OKOANICS Matrix Container Minimum Sample Size Preservative Holding Time (From Date Sampled) Hater Samples No Residual Chlorine Present Residual Chlorine Present Soil/Sediments and Sludges Concentrated Waste Sanples 1 liter glaau with Teflon liner 1 liter glass with Teflon liner Glass jar with Teflon liner or coro tube Glass jar with Teflon liner or core tube 1 liter 4°C 1 liter Add 3 mL 101 sodium thlosulfate per gallon, 4°C 5O g 4°C 50 g None Samples must be extracted within 7 days and analyzed within 40 days of extraction. Samples must be extracted within 7 days and analyzed within 40 days of extraction. Samples must be extracted within 14 days and analyzed within 40 days of extract. 1 on . Samples must be extracted within 14 days and analyzed within 40 days of extraction. above Information applies to the following parameters and methods: Parameter Phenols Phthalate Esters Organochlorine Pesticldes/PCHa Polyaromaltiu Hydrocarbons Organophosphate Pesticides 1'henoxy acid Herbicides Semivolatile Urganics Catbamate & Urea Pesticides 604/8040 (GC) 606/8060 (GC) 608/8080 (GC) 610/8310 (IIPLC) 614/8140 (GC) 615/8150 (GC) 625/8270 (GC/MS) 632 (IIPLC) C. OTHER ORGANICS Parameter Dioxlns/Furans Petroleum Hydrocarbons as Gasoline Petroleum Hydrocarbons as Gasoline Petroleum _: acarbons '^ Lesel :' :> 1 euro Dcarbona Method No. Matrix 8280 Water Soil/Waste TPH-Gasoline Water Purge & Trap (LUFT manual) Soil/Waste TPH-Gaaoline Water Extractable (LUFT manual) Soil/Waste TPH-Diesel Water Extractable (LUFT manual) Soil/Waste TPH-IR Water (418.1) Holding Tlme(a) (from Date Sampled) 30 days extn. 45 days anal. (b> 30 days extn. 45 davs anal, (&) 14 days 14 days 14 days extn. 40 days anal. 14 days extn. 40 days anal. 14 days extn. 40 daya anal. 14 days extn. 40 d>ys anal. 28 days Min. Sampl b Container Preservative Size One liter glass core tube or qlasa 1ar 3 40 mL vials with Teflon liners Core tube or qlasa jar One liter glass Core tube or qlaas 1ar One liter glass Core tube or qlaaa jar One liter glass 4°C 1000 HI] 4°C SO ,j 4°C, HCl 40 ml. to pH < 2 4°C iiO .j 4°C, HCl 500 ml. to pll < 2 4°C b() <j 4°C 500 ml. 4°C 50 .j 4°C, H2S04 1000 ml. to pll < 2 extni extraction anal: analysis from date of collection D. METALS Parameter Metals (ICP) Arsenic (GF-AA) Mercury (CV-AA) Selenium (GF-AA) Thallium /r:"?-AA) 9; >M » 5 \ um Method No. Matrix 200.7/6010 Water Sol] /Waste 206.2/7060 Water So| 1 /waste 245.1/7470 Water So|]/VfaBte 270.2/7740 Water Soil /Waste 279.2/7841 Water So| 1 /Waste 239.2/7421 Water Soi ] /Waste (III/VI) 220. 7/218. 4/ Water 312B/7197 Soil /Waste Holding Time (from Date Sampled to Analysis) 6 months 6 months 6 months 6 mopths 28 days 28 days 6 months 6 months 6 months 6 months 6 months 6 months 24 hours 24 hours extn. (b) Container Poly core tube/nlaas Poly core tube/q)ass, Poly core tube/qlaes Poly core tube/qlass Poly core tube/q}ass Poly core tiibe/qlass Poly core tube/al ass Preservative<a) HN03 to pH < 2.0 lar 4°C HN03 to pH < 2.0 lar 4°C HNO3 to pll < 2.0 1ar 4°c HNO3 to pH < 2.0 1ar 4°C IINO3 to pli < 2.0 1sr 4°C IIN03 to pll < 2.0 1ar 4°C 4°C lar 4°C Mln. Sample: Size 100 ml 10 o 100 ml 10 n 100 ml 10 '1 100 ml 10 c, 100 ml 1O q 100 ml 10 <, 100 ml 10 q (< a Led preservative is for total metalu. Dissolved or suspended metals require filtration prior to pll iid justment. (l>) extn: extraction E. WET CHEMISTRY Method Parameter No. Acidity 305.1 Alkalinity 310.1 Ammonia 350.1 Biochemical 405.1 Oxygen Demand Bromide Dionex Chemical 410.4 Oxygen Demand '?_ oride 300.0 0 rine, 330.1 •- lual '^ :>rm, Total 909A/ . »1 909C Holding Time(a) Min. (from Date Sampled Sample Matrix to Analysis) Container Preservative Size Water 14 days Poly 4°C 50 ml Water 14 days Poly 4°C 50 ml Water 28 days Glass 4°C, 112804 50 ml to pll < 2 Water 48 hours Poly 4°C 200 ml Water 28 days Poly 4°C 50 ml Water 28 days Glass 4°C, I!2SO4 100 ml to pll < 2 Water 28 days Poly 4°C 50 ml Water ASAP Poly 4°C 100 ml Water 6 hours Sterile poly 4°C, Na2S2O3 100 ml Color 110.2 40 liouru l>o 1 y 4°C 100 in) E. WET CHEMISTRY (Cont.) Method Parameter No. Matrix Cyanide 335. I/ Water 335.2/335.3 Fluor Ida 340.2 Water Groaa Alpha, Beta 9310/ Water and Radium 9315 HardneBB 200. 7/ Water 314A/314P Iodide Dlonex Water Nitrate 353.2/300.0 Water Nitrite 354.1 Water Nitrite plus 353.2 Water Nitrate Oiloc 140.1 Water Holding Tlme(a) Min. (from Date Samplu Sampled) Container Preservative Size 14 daya Poly 4°C, NaOH 250 ml to pH > 12 28 days Poly 4°C 50 ml 6 months Poly HNO3 2000 ml to ph < 2 6 months Poly HNO3 to pit < 2 50 ml 28 days Poly 4°C 50 ml 48 hours Poly 4°C 50 ml 48 hours Poly 4°C 50 ml 28 days Glass 4°C, 112804 50 ml to pH < 2 ASAP Glauu 4°C 1000 iril. TUT M-e» (Ql\ I'l i i i j i iini I ' l i i l l , I d i v l u l i i i i I I) B. HET CHEMISTRY (Cont.) Method Parameter No. Matrix oil and Grease 413. If Water 413.2 Organic Carbon 415.1 Water (TOC) Organic Halogen 9020 Water (TOX) OrthophOBphate 365.3 Water pll 150.1 Water Phenol ice 420. 1/ Water 420.2 Specific 120.1 Water Conductance Sulfate 300.0 Water Sulfide 376.2 Water Holding Time(a) (from Date Sampled) Container 28 days Glass 28 days Glass 28 days Glass 48 hours Poly ASAP Poly 28 days (b) Glass 28 days Poly 28 days Poly 7 daya Poly Min. Sample Preservative Size 4°C, H2S04 1000 ml to pH < 2 4°C, H2S04 100 ml to pH < 2 4°C, H2&04 200 ml to pH < 2 4°C 100 ml 4°C 50 ml 4°C, H2S04 100 ml to ph < 2 4°C 50 ml 4°C 50 ml 4°C, NaOH to 100 ml pll > 9 Zn<C9lliOil2 E. HEX CHEMISTRY (Cont.) Method Paramuter No. Matrix Sulfite 377.1 Water Surfactants (MB AS) 425.1 Mater Total Dissolved 160.1 Water Sollda Total Kjeldahl 351.2 Water Nitrocjen Total Phosphorus 365.3 Water Total Solids 160.3 Water Total Suspended 160.2 Water Solidu Holding Tlme(a) (from Date Sampled) Container ASAP Poly 48 hours ' Poly 7 days Poly 28 days Glaao 28 days Glaao 7 daya Poly 7 days Poly Mln. Sampler Preservative Size 4°C 100 ml 4°C 100 ml 4°C 100 ml 4°C, H2S04 100 ml to pll < 2 H2S04 to 100 ml pll < 2 4°C 100 ml 4°C 100 ml Total Volatile Solidu 160.4 Water 7 days Poly 4°C 100 ml E. WET CHEMISTRY (Cont.) Parameter Method No. Holding Tima(a) (from Date Matrix Sampled) Container Mln. Sampl u Preaervative Size Turbidity 180.1 Hdter 48 houra Poly 4°c bt) nil a) Parametera with holding timea of 24 houre or leaa are analyzed on the day of receipt In the laboratory. Parameteru with holding times between 24 and 48 hours are analyzed within one day of receipt in the laboratory. b) The 20 day holding time comes from Table 1 of Methods for Chemical Analysis of Hater and Wastes, issued March 1'JUJ. Tliiu information supercedus that contained in Method 420.1/420.2 published in 1979. F. CLP HOLDING TIMES Parameter Volatile Organ Lea Extractable Organi.cs Metal a (other than Mercury) Mercury Cyanide Matrix Water Soil Water Soil Water Soil Water Soil Water Soil Holding Time(a) (from Date Received) 10 days 10 daya S days extn. 40 dayu anal. 10 days extn. 40 days anal. 1BO daya 180 days 26 days 26 days 12 days 12 daya Container 3 40 mL vials with Teflon lined caps Glass jar with Teflon liner or core tube 1 liter glass with Teflon liner Glass jar with Teflon liner or core tube P,G (b) P,G P,G P,G P,G P,C Preaervative 4°C 4°C 4°C 4°C HNO3 to pH < 2 4°C HN03 to pH < 2 4°C 0.6 g ascorbic acid, (c) NaOH to pH >12, 4°C 4°C Min. Sample Size 40 ml. 10 y 1000 ml. 50 <j 100 ml. 10 <j 100 ml. 10 cj 100 ml. 10 y (a) Holding times calculated from date of receipt in laboratory (b) Polyethylene (P) or glass (G) (c) Only used in the presence of residual chlorine G. TCLP HOLDING TIMES •(••muter Matrix •olatiles Waste .enivolattles Waste lercury Waste letals Waste (Except Mercury) From; From: from: Field Collection KIP Extraction Prep Extraction lo: To: To: TCLP Extraction Prep Extraction Determination Analy. Container 14 NA 14 Glass H 7 40 Glass 28 NA 28 Glass 180 NA 180 Glass Hin. Sample Preservative Site 4 degrees C 4 01 4 degrees C 32 01 (1) 4 degrees C 32 01 (1) 4 degrees C 32 01 (1) (1) Smaller sanple size is adequate for solid samples or Individual fractions. A combined volume of 32 01 Is reconmended for seal volatile! and metals. A separate I 01 container should always be used for the volatile fraction. Volatile fractions should be stored with nininal headspace. A I - I I (1>A IVoi|l .1111 I'l.in, Hnw I H I c >n I I) APPENDIX II FORMATS FOR STANDARD OPERATING PROCEDURES (SOP) (QA Program Plan, Revision 2.- FORMAT FOR SOP - LABORATORY, ANALYTICAL METHOD Title (includes method number) 1. Scope and Application 1.1 Analytes 1.2 Detection limit (instrument and method) 1.3 Applicable matrices 1.4 Dynamic range 1.5 Approximate analytical time (i.e., 5 minutes, 2 days) 2. Method Summary 2.1 Generic description of method and chemistry behind it (i.e., extrac with solvent, convert to methyl ester, analyze by electron-capture gas chromatography) 3. Comments 3.1 Interferences 3.2 Helpful hints 4. Safety Issues 5. Sample Collection, Preservation, Containers, and Holding Times 6. Apparatus 7. Reagents and Standards 8. Procedure (detailed step-by-step) 8.1 Sample preparation 8.2 Calibration 8.3 Analysis AII-1 (QA Program Plan, Revision 2.1} ]UT 002 0385 FORMAT FOR SOP - LABORATORY, ANALYTICAL METHOD (cont.) 9. QA/QC Requirements 9.1 QC samples 9.2 Acceptance criteria (precision and accuracy, " of multi-component QC analytes which must be within windows) 9.3 Corrective action required (reference current QC manual) 10. Calculations 11. Reporting 11.1 Reporting units 11.2 Reporting limits 11.3 Significant figures and reporting values below detection limit 11.4 LIMS data entry 12. References 12.1 Method source 12.2 Deviations from source method and rationale 13. Appendices (optional) Additional information may be placed in appendices. This may include supporting data (e.g. method validation information), tables, flow charts. etc. AII-2 (QA Program Plan, Revision 3.-' FORMAT FOR SOP - LABORATORY, STANDARDS AND REAGENTS Title 1. Reagent/Standard Name 2. Type (reagent, calibration standard, DCS, SCS, stock solution, etc.) 3. Constituents/concentration/solvent 4. Safety Issues 5. Shelf Life 6. Procedure 6.1 Preparation 6.2 Documentation (purchase date, open date, labeling, etc.) 6.3 Verification 7. Responsibilities 8. Appendices (optional) Any additional information. AII-3 (QA Program Plan, Revision 3.4; TUT' FORMAT FOR SOP - LABORATORY, EQUIPMENT OPERATION, CALIBRATION, AND MAINTENANCE Title 1. Purpose 2. Safety Issues (applicable to the specific equipment) 3. Procedure 3.1 Initial start-up 3.2 Calibration and performance documentation 3.3 Example output 3.4 Shut-down sequence 3.5 Maintenance and maintenance records 4. Responsibilities 5. Comments 5. Definitions 7. Appendices (optional) Any additional information. AIM (QA P FORMAT FOR SOP - LABORATORY, PROCEDURAL Title 1. Purpose 2. Policies 3. Safety Issues 4. Procedure 5. Responsibilities 6. Comments 7. Definitions 8. Appendices (optional) Any additional information. AII-5 (QA Program Plan, Revision ^r 002 O8B9 APPENDIX F RESUMES OF KEY PERSONNEL TUT GERAGHTY & MILLER. INC. Ana Gloria Raaoa Zaragoza H2 Villa Eapafia Bayamon, Puerto Rico 00619 Rome: (809) 780-5577 Office: (809) 792-2920 Environmental/Safety/Health/Project Engineer Twenty years of Environmental Protection Safety and Health Management, and all Phases of Project Engineering and Coordination. EMPLOYMENT HISTORY Easo Standard Oil Company (Puerto Rico) Environmental Protection, Safety and Health Coordinator 1985 To Present * Coordinate all environmental, safety and health efforts and procedures for Esso's Central Caribbean operations which includes Puerto Rico, U.S. Virgin Islands, Dominican Republic and Haiti 9 Direct supervision and evaluation of UST assessments and corrective actions under the EPA Underground Storage Tank Regulations for the Easo service stations in Puerto Rico and U.S. Virgin Islands 9 In charge of corporate environmental compliance audita at Esso's bulk terminal facilities and service stations 9 Corporate coordinator for environmental, safety and health local and federal regulatory affairs, including the following governmental agencies: U.S. Environmental Protection Agency, Puerto Rico Environmental Quality Board, Department of Planning and Natural Resources of the U.S. Virgin Islands; OSHA, OSHO, among other . 9 Direct coordinator for all environmental, safety and health consultants retained by Esso for its Central Caribbean operations T T ,-T TAT T — >- • ~? T T C ' O "7 ' T Ana Gloria Ramos Resume 0 Responsible for environmental reporting and record-keeping requirements under all applicable federal and local environmental laws and regulations Union Carbide Caribe Inc. (TJCCI) - Ponce, P.R. Safety & Health Coordinator 1980 to 1985 * Control of annual department budgat of SIMM which led. Co the reduction of S300M annually 6 Direct Supervision and evaluation of two exempt (Safety and Health Supervisor) and four technicians ' Developed and recommended annual Safety & Health Program, new Safety & Health Procedures, and Mandatory Training program 0 Coordinated test, inspection and maintenance of fire and respiratory protection equipment Prepared report and analysis of safety statistics, i.e., on-the-job and off-the-job injury analysis, unsafe condition reports, accidents and incident reports, OSHA Form 209 report and Chemical Manufacturers Association injuries report, also classification of injuries in accordance with. ANSI. 9 Member of multidivision Fire Protection, Process & Personnel Safety and Occupational Health Audit Teem * Conducted in-house safaty and health audits «very year Screened, interpreted- and procured line management action of OSHA and PROSHO regulations also of Corporate Safety and Health procedures Senior Proleet Engineer 1978 to 1980 * Designed, cost estimated and field inspected A rotal of 33MM in capital projects, a partial list followst - Internal'Floating Roof installation - Unit Control Room building expansion - Deminralized water Neutralization System - Energy conservation projects (heat exchangers) T J Ana Gloria Ramos Resume Environmental Protection and Fire Protection related projects Advanced Project Engineer 1974 to 1978 0 Designed, cost estimated and field inspected and controlled engineering projects for: Utilities unit including sewer revisions and raw water storage and transfer facilities Wastevater effluent pipe - fiberglass installation Purchased and installed 10 high-spaed surface aerators ($400M) at waatcwater Treatment Plant Designed and installed distillation column Area Project Engineer 1971 to 1974 9 Designed, coat estimated and implementation of engineering projects Area Process Engineer 1970 to 1971 ' Supervised and improved efficiency of operational units (training purposes) Area Process Engineer 1969 to 1970 * Trainee at the Plant Engineering Department becoming familiar with cost estimate procedures, preparation of projects for drafting, reading of troop, electrical* piping and instrument drawings EDUCATION B.S, in Chemical Engineering, 1969 - University, of Puerto Rico Radiation Protection Officers West Virginia - 1983 - Obtained License Construction- Supervisors and OSHA Nev Developments Safety Seminar • 1981 rUT P T A TAT ,-r f? r : 7 T T p • o 7 • T n Ana Gloria Ramos Resume 0 Interaction Management, (1980); Time Management (1979)t Professional Management (Louis A. Alien Associates, 1974) * Fundamentals of Fire Explosion Hazards, AlCHE, Charleston, w,Va., 1980 * Management and Control of Toxic and Hazardous Substances, CIA, 1979 * Advanced Water Pollution Control, University of TeXaa at Austin, 1974 * Process Design in Water Quality, Vanderbilt University, 1973 * Annual Environmental Update Seminar of the Puerto Rico Manufacturers Association (PRMA) - (1986, 1987, 1988, 1989) LAHGUAGZS English and Spanish ASSOCIATIONS 9 Association of Engineers and Surveyours of Puerto Rico P,E. License #5891 ' Sociedad Profeftionalea de Ptcvencion de Accidentes de Puerto Rico - 1984 9 Industrial Hygiene Association of P.R. * Chairperson of the Safety & Health Committee of the Puerto Rico Manufacturing Association (PRMA) 0 Member of the Environmental Committee of PRMA V I d WJ frP : 7 T T R '0'?' 'I r I SOIL TECH NAME t ADDRESS : SOCIAL SECURITY NO. : DAZE AND PLACE 0? BIRTH > TITLE : LICENSE : ACADEMIC PREPARATION : High School : University : Joaf C. Agrelot-Pefia P.O. Box 1704 Hato Ray Station Rato Ray, P.*. 00919 583-50-9762 July 1, 1951 - Sancurca., Puerto Haater of Science in Civil Engineering Puerto Rico ffo* 7362 - laasiedt July, 1975 San JOBa School - Rio Fiedraa, P.R. 1966 - 1769 - General Diploma U.P.R. Mayague* Caopua - Mayaguez, P*&. 1969 - 1974 - Bachallor of Science in Civil Enginaaring O.P.R* Mayagua* Campus • Mayagua*, P.R* 1974 - 1977 - Maater of Selenea in Civil Engineering, *p«cialixed in Soil Mechanics and Foundations PROFESSIONAL EXPERIENCE > 1. Soil Tech Corporation Address; Corner of Amir and Duina Straac Raparto Laadrau Rio Piadraa, Puerto Rico 00927 Tftlaphooe: 792-8900 Responsibilities: 1. President of Soil tech Corporation 2. Administrative Coordination 3. Raport writing, invoicing and personnel aupervision. 5 I d W T R '37. '1 I SOIL TECH RESUME (Joaft* C. Agrelot) 2. Partner - Ortiz, Agrelot & Cardoaa Address i State Road '838 - Xonacillos Ward #1757 Rio Piedraa, Puerto Rico 00928 Telephone* i 731-4994 / 763-4753 / 751-4639 Responsibilities: 1..R«porc writing and invoicing. Field personnel supervision* 2. Secretary/Treasurer of Corporaci6n Geotac 3. Partner - Paniagua, Rodrfguea, Cards, Crualey fr Solum de Puerto Rico, lac* Address t Mayafue* Street No* 70 Bato JUy, Puerto Rico 00917 Time Employed i May 1977 until November 1978 Poaitioni Soila and Foundation Engineer Responsibilities i Report writing and invoicing. Performance of special laboratory testa. Field per*ann«l supervision. 4. Employer - University of Puerto Rico - Hay ague 2 Ctuspua Addresst Civil Engineering Department - R.U.M. May agues, Puerto Rico Time Employsdl August 1974 until May 1977 Poaicioni I na tract or Director of the Soil Mechanics Laboracory (June 30, 1976 until June 30, 1977) I OO2 0896 i T T C 'O 7 ' T 0 *.I SOIL TECH RESUME (Jose1 C. Agralot) Responsibilities: Teaching Soil Mechanics- I - (INCI 441) Soil Mechanics Ub. I * (INCI 443) Soil Mechanic* Advanced Lab. - (ISCl 643) Soil Mechanic^ II - (ZNC1 542) Director of the Soil Mechanic* Laboratories Employer - University of Puerto Slice - Mayagusz Campus Addrtts: Technical Institute Mayajuer Campus Mayague*, Puerto Rico Tiae Employedt August 1976 until May 1977 Position: Instructor Rasponsibilicles: Teaching Advanced Mathematics TUT 002 0897 L i d T/\TJ" . . , i K f SOIL TECH RESUME (Jose C. Agrelot) MEMBERSHIP IN PROFESSIONAL SOCIETIES: 1. Aaaociaca M»«b«r - (American Soeiacy of Civil Engineer*) (Section Prtaldatxt) 2. Meaber - "colagio d« Iag»ni«to» 7 Agrimanaowa d« Puerto Rico" 3. Maaber - TAU 8STA PI Honorary Society 44 Metsber - AaaricAQ Concrete Institute 5. Member - Home Builders Association 6. Miabar - Association of General Contractors 7. Hiaber - "Sociedad de Znganieroa Coocficnicoa da Puerto BJLco" Past Prwidant (1981 - 1983) S. M«ab«r - National Water tforlto Aisociatioa 9. Member - Aoociaci6n de Recursos de Agua da P.R. (?a*e President 1986-1987) PUBLICATIONSJ 1. "AaAlisis de la Hinca da Pilot** por la gcuae!6n de PropagaciSn dg Onda" Bibliotaca de la P.P.R. - Recinco da Mayaguss - 1977 2. Croueing CaveTUB and Soft Zones by Concrata Pump» Aa«rican Sociacy of Civil Bogin»«r*, Grouting in C«ot«chnical Engineering Specialty Conference - 1982 3. Vacuum.- Defanea Syeten for Ground .Wacer VOC Contamination Proceedings of Fifth National Syopoaiutt and Exposition of Aquifer Restoration and Ground W«ter Monitoring, May 21-24 1985. Q T J " T A T T T r r > ' 7 T T C ' n - 7 ' T n f SOIL TECH RSSUME (Josfi C. A$r«lot) luTtacigacion, Analysis and^Itaaedial Actions taken for th« containment of gtfouttdyatet contamination in a fcarat environ- a«nc. (Iac0rnacienai SytBposiua oa Tropical Rydtolog? and Second Caribbean Islands W»t4ff 2e«6ur<ies Congrtas, 1985). Sun-Off Disposal in tha Liaestong Rtgico of Sort ham P.R, (International Sympexiun oa Tropical Hydrology and Second Caribb«an Islands Wat«r Resources Congreaa, 1985,) r filrT T A T J ' ; f 7 C : 7 T T P ' O - 7 ' T O DANIEL A. NACHMAN Vice President CREDENTIALS/REGISTRATION B.S. Geology, New York University, 1973 M.S. Geology, Oregon State University, 1977 Certified Professional Geologist: AIPG No. 6524 Registered Geologist, Commonwealth of Virginia No. 000425 PROFESSIONAL AFFILIATIONS National Water Well Association Geologic Association of New Jersey FIELDS OF SPECIALIZATION Regional hydrogeologic assessments and management programs, well head and aquifer protection strategies. Exploration and development of ground-water resources. Design of test-well and production-well drilling programs. Development of well field maintenance and rehabilitation programs. Ground-water contamination investigations and design of monitoring programs. Evaluation of ground-water flow regimes in complex alluvial, glacial, and other sedimentary depositional environments. Interpretation of ground-water quality data. Expert testimony. EXPERIENCE SUMMARY Mr. Nachman has over 12 years of experience in hydrogeology. He has directed and implemented a wide variety of ground-water supply and contamination studies throughout the United States, particularly in New Jersey, New York, and Puerto Rico. He has developed regional aquifer assessment and ground-water exploration programs for industries, private water companies, and public utilities. He has extensive experience in the design and implementation of remedial investigations under Superfund, RCRA, and state regulations. Mr. Nachman has lectured at graduate level courses in hydrogeology at Stevens College in Hoboken, New Jersey and at the New Jersey Institute of Technology in Newark, New Jersey. He has also presented several talks on ground-water contamination and aquifer protection at seminars sponsored by various agencies and associations. Mr. Nachman has served as the manager of Geraghty & Miller's Hackensack, New Jersey office and is presently manager of the firm's office in Santurce, Puerto Rico. GERAGHTY & MILLER. INC. DANIEL A. NACHMAN/2 KEY PROJECTS Carried out field investigations and supervised test drilling and pumping operations for expansion of the ground-water supply system for the Puerto Rico Water Resources Authority power plant in Aguirre, Puerto Rico. Responsible for data collection and supervision of test drilling at several proposed power-plant sites in Puerto Rico. Coordinated and supervised an extensive investigation of existing and potential ground-water resources for the government of the U. S. Virgin Islands. Contributed to the preparation of a ground-water management plan and a strategy for assessment of Class V underground injection wells for the U. S. Virgin Islands. Coordinated and managed a Remedial Investigation/Feasibility Study (RI/FS) at an industrial facility in northwestern New Jersey, under an Administrative Consent Order issued by the New Jersey Department of Environmental Protection (NJDEP). Study involved geophysical surveys, monitoring well installation, and sampling of ground water, soils, surface water, and surrounding domestic wells, to define contaminant extent and assess the feasibility of remedial alternatives. Served as project officer/senior technical advisor for the Phase n RI. Conducted a ground-water contamination and remedial investigation in Morris County, New Jersey. Studies included delineation of two separate contaminant plumes, the design of recovery-well networks for the removal of contaminated water, and the design of injection-well networks for the reinjection of treated ground water. Project involved the preparation of permit applications for working in designated wetlands, injecting treated water, and long-term remediation and monitoring. Implemented several projects at an oil refinery in Puerto Rico, including ground-water exploration programs to augment the refinery's water supply; the modification and regular sampling of a RCRA monitoring well network; and a subsurface investigation associated with a fuel spill. Assisted property owners and a New Jersey township in evaluating the suitability of a site designated for a hazardous waste incinerator within the hydrogeologic parameters specified in the New Jersey Hazardous Waste Facility Siting Act. The project included field data collection, interpretation of hydrogeologic and climatological data, and the presentation of findings at public hearings. As a result of this study, the site was delisted as a possible incinerator location. TUT GERAGHTY & MILLER. INC DANIEL A. NACHMAN/3 KEY PROJECTS (Continued) Conducted a soil and ground-water quality study at an industrial facility as part of a Superfund investigation at a site in western New York State. Project included collection of soil samples for chemical analysis, monitoring well installation, slug tests, and long-term pumping tests to define the plant production well's capture zone. Coauthored report that assessed the facility's potential as a source of contamination to a municipal well field, and participated in negotiations with the USEPA on the need for additional investigative and remedial work. Assisted a township in Sussex County, New Jersey in assessing the state's plan to blend and dispose radium-contaminated soils at a sand and gravel quarry. The project involved preparing an independent environmental site assessment and identifying potential impacts to ground-water quality from the proposed disposal. Coordinated a study to identify alternative sources of water for a water company in Burlington County, New Jersey. Project was initiated in response to the state's plan to curtail pumpage from the Potomac-Raritan-Magothy aquifer system. Tasks included identification of sources of ground water and surface water, the selection of test-drilling sites, and predictions of long-term yields from well fields. Coordinated an extensive well-field rehabilitation program for a private water company in Essex County, New Jersey. Project included selection of well-development techniques and design of pumping tests to evaluate effectiveness of well redevelopment. Responsible for preliminary assessment of ground- and surface-water resources for a resort complex on St. Croix. Coordinated a complex seismic investigation on an undeveloped site in Dutchess County, New York. The project included mapping of buried bedrock surface, siting of monitoring wells, and interpretation of subsurface hydrogeologic conditions. Assisted with a complex study of ground-water contamination at the Rocky Mountain Arsenal in Denver, Colorado. Compiled geologic and water-quality data, and prepared contaminant distribution maps, cross sections, and water-level maps. Investigated regional aquifer conditions in the area. TUT GERAGHTY & MILLER, INC. DANIEL A. NACHMAN/4 KEY PROJECTS (Continued) Supervised drilling operations and prepared reports in connection with ground-water contamination investigations in Pittsfield, Massachusetts, Fort Edward, New York, Baton Rouge, Louisiana, and Rockford, Illinois. Designed and managed several projects at industrial properties carried out in compliance with New Jersey's Environmental Cleanup Responsibility Act. Projects involved soil sampling, monitoring well installation and sampling, pumping tests, assessment of remedial alternatives, preparation of cleanup plans, and negotiation with the NJDEP to establish cleanup levels. Responsible for several litigation-related projects. Work included evaluation of reports prepared by other consultants, identification of key hydrogeologic and water- quality issues, preparation of expert reports, and presentation of testimony at depositions, public hearings, and court proceedings. 5/91 GERAGHTY & MILLER, INC. .)9o TUT °°'-i THOMAS V. DANAHY Senior Scientist CREDENTIALS/REGISTRATION B.S. Chemistry and Geology, State University of New York at Cortland, 1982 M.S. Geology, East Carolina University, 1986 Health and Safety at Hazardous Waste Sites - 40-Hour, 1987 and 8-Hour Supervisor, 1990 Registered Professional Geologist: State of North Carolina No. 1039 PROFESSIONAL AFFILIATIONS National Water Well Association Geological Society of America Sigma Gamma Epsilon National Geology Honor Society FIELDS OF SPECIALIZATION Ground-water contamination investigations. Assessment of potential NPL hazardous waste sites. Regional hydrogeological studies. Soil-gas and geophysical surveys. Exploration and development of ground-water resources. Remedial design for ground-water contamination. EXPERIENCE SUMMARY Mr. Danahy has 7 years of experience hi hydrogeology and geotechnical engineering. Since joining Geraghty & Miller in 1991, he has been the project manager for a Remedial Investigation and Feasibility Study (RI/FS) in St. Thomas, U.S. Virgin Islands. Mr. Danahy was previously a consultant hydrogeologist with Dunn Geoscience Corporation in Albany, New York. He has also been employed with Law Engineering Testing Company in Greenville, North Carolina and Soil and Material Engineering, Inc. in Raleigh, North Carolina. Mr. Danahy's experience has been in the fields of geology, chemistry, hydrology, and geotechnical engineering. He has conducted several field investigations, including aquifer evaluations, hazardous waste site assessments, solid waste landfill siting and closure studies, RI/FS projects, and ground-water monitoring programs. KEY PROJECTS - Project Manager of a $1.5 million contract with the New York State Department of Environmental Conservation. Included development of project tasks and budgeting and implementation of hazardous-waste investigations at nine sites. Project Manager of an investigation of PCB content and geotechnical characteristics of Hudson River bottom sediment for a proposed hydroelectric facility. -PIT *>02 0904 GERAGHTY & MILLER. INC. ' THOMAS V. DANAHY/2 KEY PROJECTS (Continued) Project Hydrogeologist/Principal Investigator for a hydrogeologic assessment of a manufacturing facility in Central New Jersey. The assessment demonstrated that the facility was not the source of contamination at a nearby municipal water-supply wellfield. Project Manager/Project Hydrogeologist for a hydrogeologic investigation and Closure Design of a solid waste landfill in northeastern New York. Hydrogeologic characterization of the site formed the basis for negotiation of an approved Closure Plan with the New York State Attorney General's Office and New York State Department of Environmental Conservation. Provided technical review of remedial alternatives, closure report preparation, and regulatory liaison/negotiations. Project Manager of a hydrogeologic investigation in support of a Petition to Delist a landfill from the New York State Registry of Inactive Hazardous Waste Sites. Project Hydrogeologist for a Superfund site in central New York. Conducted a subsurface investigation for the remedial design of groundwater control at this PCB- contaminated site. Project Hydrogeologist for a RI/FS of a public-water supply well field contaminated with trichloroethene and tetrachloroethene. Project Manager of a closure investigation for a municipal sanitary landfill. The investigation included leachate outbreak mapping, landfill gas evaluation, landfill cover evaluation, leachate and groundwater sampling. PUBLICATIONS Danahy, T.V., Howard, W.O. and Wolterding, D.J., 1988, Hydrogeologic and Soil Gas Evaluation of Groundwater Contamination at a Municipal Landfill in New York State, Proceedings of Focus Conference Eastern Regional Ground Water Issues, National Water Well Association pp. 613-633. Howard, W.O., Danahy, T.V. and lanniello, M., 1988, An Air-Lift Development System for Deep Wells, Proceedings of Focus Conference Eastern Regional Ground Water Issues, National Water Well Association pp. 559-564. Danahy, T.V., 1986, Petrology, Depositional Environment and Diagenesis of the Hillsdale Limestone (Mississippian, Meramecian) in Washington County, Virginia, M.S. Thesis, East Carolina University. (Included trace element and stable isotope analysis). 5/91 GERAGHTY & MILLER. INC. JUAN A. GARCIA. Jr. Project Scientist Regional Data Quality Assurance Manager (RDQAM), Northeast CREDENTIALS/REGISTRATION B.S. Chemistry, University of Tampa, 1983 PROFESSIONAL AFFILIATIONS American Chemical Society American Society of Quality Control FIELDS OF SPECIALIZATION Analytical chemistry. Laboratory automation systems. Data validation. Analytical procedure evaluation. Data management (reduction and reporting) Field analyses. EXPERIENCE SUMMARY Mr. Garcia has 8 years of experience in applied analytical chemistry. At Geraghty & Miller, Inc. he leads a Data Management and Data Validation group. The work includes validation of analytical data in compliance with various state and federal guidelines and standard operating procedures. Mr. Garcia has prepared a number of Quality Assurance Project Plans in compliance with CERCLA, RCRA, and other state and federal regulations. Prior to joining Geraghty & Miller, Mr. Garcia was associate scientist in the Quality and Technical Affairs Division of Ortho Pharmaceutical Corporation, a Johnson & Johnson Company. While at Ortho, he performed a variety of analyses including high performance liquid chromatography (HPLC), gas chromatography/mass spectrometry (GC/MS), GC electron capture detection (ECD), flame ionization detection (FID), and thermal conductivity detection (TCD). He was also responsible for contract laboratory compliance, gas chromatography instrumentation (maintenance and upgrades), and all data generated by the marketed product stability program. He was also the back-up manager for laboratory automation. KEY PROJECTS Prepared Quality Assurance Project Plan and managed laboratory contract for an ECRA Case in Great Meadows, Warren County, New Jersey. Performed data validation and managed the database generated by this project. GERAGHTY & MI LLER, INC. JUAN A. GARCIA/2 KEY PROJECTS (Continued) Prepared Quality Assurance Project Plan and managed laboratory contract for a RCRA Facility Investigation in Puerto Rico. Prepared Quality Assurance Project Plan for a NPL CERCLA in Dublin, Pennsylvania. Prepared Quality Assurance Project Plan for a CERCLA investigation in St. Thomas, U.S. Virgin Islands, Performed validation of data for a RCRA investigation in Newark, New Jersey. Performed validation of data for a residential well project in St. Thomas, U.S. Virgin Islands in accordance with CERCLA requirements. Audited Ekotek, Inc. laboratory in Atlanta, Georgia and RECRA Environmental Laboratories in Buffalo, New York for their inclusion in the Geraghty & Miller Analytical Quality Assurance/Laboratory Contract Program (AQA/LCP). 5/91 GERAGHTY # MILLER. INC. T,, T 002 0907 ALBERTO COLBERG NEVARES Project Scientist CREDENTIALS/REGISTRATION A.D. Liberal Arts, Boston University, 1979 B.S. Geology, University of Puerto Rico, 1985 License for purchase, transport, and use of explosives SHORT COURSES/SEMINARS Hazardous Waste Site Activities Health and Safety Training, 1987; Refresher Program 1989 Analysis of Groundwater Data, Oklahoma State University, 1988 PROFESSIONAL AFFILIATIONS National Water Well Association Geological Society of Puerto Rico Puertorican Water Resource Association FIELDS OF SPECIALIZATION Design and implementation of ground-water contamination investigations. Monitoring well installation and sampling. Specialized product and ground-water recovery systems. Field gas chromatography studies; interpretation of ground-water quality data. Health and safety procedures for hazardous waste sites. RCRA closure plans. EXPERIENCE SUMMARY Prior to joining Geraghty & Miller, Inc., Mr. Colberg was employed by Terra Vac, Inc. of San Juan, Puerto Rico for 5 years as a hydrogeologist, project manager, and Health and Safety Officer. He has been involved in ground-water contamination and remediation projects in a wide variety of geologic terrains in Puerto Rico and the United States. He has conducted hydrogeologic investigations at gasoline service stations, has managed a subsurface product recovery project at a petroleum refinery in Puerto Rico, and has extensive experience in the design and implementation of in-situ vacuum extraction systems. Mr. Colberg has prepared and implemented RCRA closure plans for container storage areas and wastewater lagoons for several industrial facilities in Puerto Rico. GERAGHTY & MILLER. INC. CAMERQN S. DUNNAN Staff Scientist CREDENTIALS/REGISTRATION B.S. Biochemistry, Brown University, 1985 M.B.A. Rutgers University Graduate School of Management, 1991 PROFESSIONAL AFFILIATIONS American Chemical Society National Alumni Schools Program FIELDS OF SPECIALIZATION Analytical chemistry. Gas and liquid chromatography. Statistical analysis. Data validation. Data management. Technical editing. EXPERIENCE SUMMARY Mr. Dunnan has been part of the newly created data validation group at Geraghty & Miller, Inc. since October 1990. He has been involved in the streamlining of the validation process and the standardization of validation reports. Prior to joining Geraghty & Miller, Inc., Mr. Dunnan was employed as an analytical chemist at a major pharmaceutical corporation. While in the pharmaceutical industry, he was responsible for raw material, finished product, and stability analyses, as well as instrument maintenance and calibration. His other duties included the evaluation, purchasing and set-up of laboratory equipment to support the newly created biotechnology division. KEY PROJECTS Carried out domestic well resampling project for an ECRA site in Warren County, Great Meadows, New Jersey. Authored organic and inorganic data validation reports in accordance with USEPA Functional Guidelines for a proposed municipal pool site in Newark, New Jersey. Coordinated data management and authored technical memorandum in conjunction with an outside environmental consultant for a ground-water project in Vega Alta, Puerto Rico. GERAGHTY & MILLER. INC. CAMERON S. DUNNAN/2 KEY PROJECTS (Continued) Authored multiple organic and inorganic data validation reports in accordance with USEPA-Region HI guidelines for water and soil samples from a landfill in South Whitehall Township, Pennsylvania. Authored organic and inorganic data validation report in accordance with USEPA Functional Guidelines for a non-regulated environmental site in Dos Campos, Brazil. Authored inorganic data validation report in accordance with NJDEP guidelines for a chemical production facility in Morristown, New Jersey. 7/91 TUT OO2 0910 GERAGHTY & MILLER, INC.