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( SDMS Document 115548 ISLAND CHEMICAL COMPANY, INC. REMEDIAL INVESTIGATION ST.CROIX. U.S. VIRGIN ISLANDS DRAFT WORK PLAN Volume I of II Work Plan and Appendices A through C Prepared For Island Chemical Company, Inc. By Harding Lawson Associates Philadelphia, Pennsylvania March 17, 1994 ro Ol o o cn Draft Remedial Investigation Work Plan Island Chemical Company, Inc. St. Croix, U.S. Virgin Islands Prepared for Island Cliemical Company, Inc. HLA Project No. 24231 2.C.1 Jason M. Schindler Senior Geologist Edward A. Nemecek, R.G., C.P.G. Principal Hydrogeologist March 14, 1994 Harding Lawson Associates Engineering and Environmental Ser\ 131 North Third Street Philadelphia, PA 19106 - (215) 627-4505 3 0 0 9 3 8 CONTENTS 3.6 Area F - Concrete Storage Pad 17 3.7 Other Areas 17 3.7.1 Storm Drains and River Gut 17 3.7.2 Sump 20 3.7.3 Septic Tanks 20 3.7.4 Dryer Building 20 3.7.5 4,000-Gallon AST Area 20 3.7.6 Former Location of Paint Cans and Drums 20 3.7.7 Groundwater 20 3.8 Results of Previous Removal Actions 21 3.8.1 Remedial Preliminary Assessment 21 3.8.1.1 Laboratory 21 3.8.1.2 Dnun Storage Warehouse 21 3.8.2 USEPA Phase I Removal Activities 21 3.8.3 First Fuming Drvun Emergency Response Action 22 3.8.4 Phase II Removal Activities 22 3.8.5 Second Fuming Drum Emergency Response Action 22 3.8.6 Phase III Removal Activities 22 3.8.7 Response to VandaHsm 22 3.8.8 Final Phase Removal 22 3.9 National Priorities List ' 23 4.0 WORK PLAN RATIONALE 24 4.1 Data Needs 24 4.2 Work Plan Approach 24 4.3 Data Quahty Objectives 26 4.4 Preliminary Identification of ARARs 26 4.4.1 Definition of ARARs 26 4.4.2 ARAR Categories 28 4.4.3 ARARs Associated With State-Authorized Programs 29 4.4.4 Preliminary Lists of ARARs 29 5.0 REMEDIAL INVESTIGATION TASKS 30 5.1 Project Planning and Management 30 5.1.1 Meetings with USEPA 30 5.1.2 Monthly Progress Reports 30 5.2 Background Investigation 30 5.2.1 Obtain and Review Well Records 30 5.2.2 Obtain and Review Historic Aerial Photographs 31 5.2.3 Obtain and Evaluate Additional Existing Data 31 5.2.4 Obtain Information on Potential Offsite Source Areas 31 5.3 Acquire Access and Permits 32 5.3.1 Access Agreements 32 5.3.2 Well Drilling Permits 32 5.3.3 Customs Permits for Samples 33 5.3.4 USEPA Disposal Permission ; 33 \WORK\2423l\02\WORKPLAN.REP HARDING LAWSON ASSOCIATES li 3 0 0 9 3 9 : CONTENTS ., 5.4 Site Clearing and Reconnaissance ..; .,.'. 33 5.5 Field Sampling Program . .'. 33 5.5.1 , Soil Sampling Program 33 5.5.1.1 |Soil Boring Locatioiis and Rationale 33 5.5.1.2 Drilling, and Soil Sampling Procedures . . . . . . . . . . 34 5.5.2 Groundwater Monitoring Well Installation 35 5.5.2.1 ; Monitoring Well Locations 35 5.2.2.2 Drilling and Completion of Monitoring Wells . . . . . 36 5.5.3 Rehabihtate Existing Wells . 36 5.5.4 Survey . . . . .|. 37 5.5.5 Groundwater Monitoring arid Sampling 37 ' 5.5.5.1 First Round of Groimdwater Sampling . . . . . . . . . . 37 . ; 5.5.5.2 Water Level Monitoring 37 5.5.5.3 Quarterly Groundwater Sampling . 38 5.6 Data VaHdation . . . .i . . . . . . 38 5.7 Data Evaluation 38 5.8 Development of ARARs , 39 5.9 Remedial Investigation Report . . . . . . . ; . 39 5.10 Management of hivestigation Derived Wastes 39 6.0 PROJECT ORGANIZATION j . . . . . . . . . . . . . . . . 41 7.0 ANTICIPATED SCHEDULE , . . . . . . . . . . . . . . ,.'., . . . '. 42 8.0 ACRONYMS AND ABBREVL^TIONS 43 9.0 REFERENCES . 45 List of Tables :' 2-1 Wells Within One Mile of Site . • 2-2 Summary of Events . ' 2-3 . Summary of ICC Disposal Activities 2-4 Summary of Substances Reported \ 3-1 Areas of Potential Environmental Concern ' 3-2 Summary of Environmental SampUng - Area B - Above-Ground Storage Tank Farm 3-3 Summary of Environmental Sampling - Soils in Dryer 3-4 , Summary of Environmental Samphng - Area C - Former Process Pit 3-5 Summary of Environmental SampUng - Area D - Loading Dock and Lab Pit Area ,, 3-6 Summary of Environmental Sampling - Area E - Soil Beneath Concrete Pad 3-7 Summary of Environmental Sampling - Background, River Gut and Drains 3-8 Summary of Environmental SampUng - Water Samples 3-9 Summary of Environmental Sampling - Chemical Abbreviations 4-1 Potential Chemical-Specific ARARs and TBCs 4-2 Potential Action-Specific ARARs . 4-3 PotenUal Location-Specific ARARs \WORK\24231\02\WORKPLAN.REP 'HARDING LAWSON ASSOCIATES iii 300940 CONTENTS List of Figures 2-1 Site Location Map 2-2 Site Map 2-3 Soils Map 2-4 Generalized Geologic Map of St. Croix 2-5 Approximate Locations of Nearby WeUs 3-1 Areas of Concern 6-1 Project Organization 7-1 Work Plan Implementation Schedule List of Appendices A Sampling and Analysis Plan B QuaUty Assurance Project Plan C Health and Safety Plan D Rainfall Summary E Clean Air Act Correspondence F Cooper Laboratories Geotechnical Investigations G Report Conceming SmaU Quantity Generator Status of Island Chemical H May 17,1983 RCRA Inspection Form I Waste Classification Analyses and Disposal Profiles J Disposal Manifests K ESI February 7, 1986 Letter to USEPA Regarding Waste Disposal L USEPA PoUution Reports M Laboratory Results N Figures Shovdng Previous SampUng Locations O Compendium of Groundwater Data \WORK\24231\02\WORKPLAN.REP HARDING LAWSON ASSOCIATES iv 300941 1.0 BACKGROUND 1.1 Introduction This Remedia] Investigation Work Plan (RIWP) has been prepared by Harding Lawson Associates (HLA) to address environmental conditions at the former Island Chemical Company, Inc. (ICC) facility located on Route 66 (Melvin Evans Highway) near the ; intersection with Route 64 in St. Criaix, U.S. Virgin Islands. This document has been prepared to be consistent with the requirements of the National Contingency Plan (NCP). This RIWP discusses the site, sumrharizes work performed to date and describes the scope of work intended to document current conditions at the site. Pursuant to discussions with the U.S. Environmental Protection Agency Region n (USEPA), supporting documents have been included as appendices to this RIWP. The project Sampling and Analysis Plan (SAP) is included as Appendix A, the project Health and Safety Plan (HASP) is included as Appendix B, and the project Quality Assurance Project Plan (QAPP) is included as Appendix C. 1.2 Objectives The objectives of this Remedial Investigation are: • To evaluate whether onsite conditions currently pose a cause forenvirormiental concern; ,; ' • To evaluate whether piotential source areas not previously identified are present" onsite; • • To identify potential contaminant pathways; - • To assess the possible presence of a shaUpw clay layer reported by others; and • To determine the horizontal; direction of shaUow groundwater flow. The Remedial Investigation tasks described in Section 5 of this RIWP are designed to acHieve these objectives. ' \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 1 2.0 SITE BACKGROUND 2.1 Site Description On July 2, 1993, HLA performed a preliminary inspection of the site. At that time, the site was found to be abandoned and overgrovra with heavy vegetation. 2.1.1 Site Location The site occupies approximately three acres in south central St. Croix, U.S. Virgin Islands (Figure 1). The site is located on Route 66, approximately 1,500 feet north of the Alexander Hamilton Airport. The property is located on Plot 13Q of Estate Bethlehem Middle Works at 17°42'26" north latitude, 64'>47'25" west longitude. The site is bordered to the northeast and southeast by an intermittent stream (River Gut). The site is bordered to the northwest by an asphalt batch plant and to the southwest by Route 66. A concrete or cement batch plant and an automobile body repair shop are located to the east of the site, across the gut. 2.1.2 Site Structures The current layout of the facility is shown in Figure 2-2. Major onsite structures include the foUowing: Laboratory and Warehouse Building which housed the analytical laboratories, rest rooms, offices, storage, the dryer area and a cafeteria; Maintenance BuUding which houses two boilers, refrigeration units, air compressors and a maintenance shop; Above-ground Storage Tank (AST) farm. •' Loading Dock (former location of laboratory pit) Concrete Pad Adjacent to Tank Farm Concrete Storage Pad Production Area which includes a centrifuge and dryer building; Reactor Area; Two cooling towers; Generator BuUding; Generator and Fire Pump Building; \WORK\2423l\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 2 300943 • Two 4,000-gallon ASTs; ; .- ' .. • One 250,000-gallon fire water AST; and . • Reduction/oxidation Unit and Water Storage BuUding. 2.2 Site Setting . 2.2.1 Topography and Drainage ' The site is located in a valley. Surface eleyations at the site range from approximately 30 to 40 feet above mean sea level (MSL).jj Land to the southwest (approximately 200 feet) and to the^east (approximately 1,000 feet) of the site slope steeply upward to roughly 150 to 200 feet above,MSL. A preUminaiy review of U.S. Geologicjal Survey (USGS) 7V^ topographic quadrangles for the area suggests that this yalley receives drainage from approximately 6,300 acres to the northwest of the site. Based on drainage area comparisons, the gut adjacent to the site appears to receive approximately one third of that flow. The remainder is drained by another intermittent stream that joins the gut approximately 800 feet southeast bf the site (Bethlehem Gut). AU of the stream channels in the drainage basin are identified as intermittent. Ogdeii (1974) reported that there are no permanently flowing streams on the island. ., ; The surface slopes gentiy across the site from southwest to northeast. Ground surface just beyond the northeastern and easternuence lines slopes steeply downward approximately 12 to 15 feet into the gut. A berm partially separates the aboveground storage tanks in the western part of the facility from the remainder of the site. On the western side bf the berm, runoff flows from southwest to northeast. ] Surface flow on the eastern portion of the site is controlled by the buUdihgs, concrete? paved areas and two storm drains that channel runoff to the gut along the southeastern site; boimdary. AU surface runoff from the site drains to the gut. The^gut drains to the Caribbean Sea, approximately 4,500 feet to the south. ..Flow.in.the,River put is intermittentiand generaUy only occurs during the rainy season which occurs between September arid December. According to Enviro-Science, Inc. (ESI), a sewage outfall discharges to the gut downstream frpm the site. HLA did not observe the sewage outfall during a preliminary site walk on July 2, 1993. . 2.2.2 Climate and Air Quality i> The climate is dry and tropical vidth average monthly temperatures between 75 and 83°F. Throughout much of Ihe year, the trkde winds blow steadily out of the northeast at 10 to 20. miles per hour (Multer, 1974). i, , Data on precipitation and temperature were obtained from the Alexander HamUton Airport, approximately 1/2 mile southwest of the site. Average total annual precipitation is 44.57 inches. Greatest rainfaU occurs between August and November. Average annual arid monthly rainfall for the area are summarized in Appendix D. According to Forman (1974), long term average rainfaU has not changed'over the last 112 years. \WORK\2423l\02\WORKPLAN.REP 03/17/94 02:33 pm . HARDING LAWSON ASSOCIATES 3 300944 On April 5, 1979, ICC submitted information regarding air emissions to the USEPA. Because the potential hydrocarbon emissions were calculated to be less than 100 tons per day, the USEPA determined that the faciUty was not subject to Federal Prevention of Significant Air Quality Deterioration. A copy of the USEPA correspondence is included in Appendix E. 2.2.3 Soil SoU type was determined from a soU map constructed by the Cartographic Division of the United States Department of Agriculture (USDA) SoU Conservation Service (SCS) using 1962 and 1963 aerial photographs. The map was taken from the 1970 SCS SoU Survey of the U.S. Virgin Islands. Figure 2-3 shows the soU types in the vicinity of the site. The entire site Ues on Coamo clay loam with slopes of 2 to 5 percent. The Coamo series consists of gentiy sloping, deep, weU-drained soils over volcanic and Umestone rocks. These soUs formed sediments derived from the rocks they overlay, and therefore occur as alluvial fans and terraces. These soUs range in texture from sand to clay. A typical profile has an approximately eight-inch thick surface layer consisting of very dark grayish-brown clay loam, containing rock fragments. The subsoil is a very dark grayish- to yeUovidsh-brown clay, also containing rock fragments. The substratum begins at a depth of approximately 2 feet and consists of a yeUovdsh- to dark yellowish-brown, friable, calcareous clay loam stratified with sand and gravel. According to the SCS, since the field work for the 1970 survey was performed almost 30 years ago, the information in the report may be out of date. However, this is the only existing soil survey of St. Croix, and a new survey wiU not be published for at least two years. The new survey wUl be more detaUed and reflect changes in taxonomy, wetiands, and land use. 2.2.4 Geology a n d Hydrogeology 2.2.4.1 Regional Geology St. Croix is an island composed primarily of limestone and volcaniclastic sediments. It is located at the juncture of the Greater AntUles and Lesser Antilles Geologic Provinces in the northeastern comer of the Caribbean Sea. The island lies upon a submarine platform that is separated from Puerto Rico and the Virgin Islands Platform by the Virgin Islands Basin and the Anegada Passage (GiU, 1989). The ICC site is located in the central basin of St. Croix. The central basin is a graben structure containing primarily late Cretaceous Age and younger calcareous sediments. Figure 2-4 is a generalized geologic map of the island. A brief discussion of the major geologic formations of the central basin follows. .\WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 300945 Mt. Eagle Group ! , The deepest formations reached through soil borings in the central basin, consist of tuffaceous and volcaniclastic sediments of the Mt. Eagle Group. These sediments are beUeved to have eroded from nearby islands during, the Cretaceous. • • ' , " • . • - . • . . * . • / ' . ' ' . - • • • ' " • • . . • - • Jealousy Formation , ^ , The Jealousy Formation is believed to unconforroably overUe the Mt. Eagle Group in the central basin. According to GUI (1989), "the Jealousy Formatiori is remarkably uniform, consisting of blue grey foramniferal riiarls." GUI reports that in the central basin, the bottom of the Jealousy Formation has neverj been'reached. However, based on gravity surveys, Shurbet et al. (1956) estimated a total thickness greater than 6,000 feet. Gill (1989) noted that the Jealousy Formation is entirely subsurface. Areas mapped by previous res_earchers as outcrops of the Jealousy Formation (Figure 2-4) are beUeved to be the overlying KingshiU Limestone. , ; . ' . ' \ y • • •• - - • ' ' . Kingshill Limestone The KingshiU Limestotie includes a variety of sedimentary facies. It includes beds of sandy, limy clay and sUtstone and beds df nearly pure to clayey Umestone (Robinson, 1972). It conformably overUes the Jealousy Fqrriaation and reinges up to 600 feet in thickness. The contact between the KingshiU Limestone and the Jealousy Formation is reportedly readUy visible in soU borings. The upper KingshiU Limestone is exposed less than one rnUe north of the site (Gill, 1989) . ' ' I t • • • ' ' ' < ' . - . • AUuvium ' The site is situated on aUuvial deposits which have fiUed many of the valleys on the island. A minimum thickness of 50 to 100 feet of, aUuvium is believed to be present in the eixial parts of the valleys (Cederstrom, 1941). A, maximum thickness of approximately 100 feet ' reportedly occurs, at the lower reach of River Gut (Geraghty &.MiUer,,1983)., The aUuvium is composed primarily of montmorillinitic clay, is similar in appearance to the Kingshill formation, because both contain soft sandy, silty buff to white material (Robinson, 1972). . The alluyium, however, lacks limestone beds and has more sand and gravel deposits than the KingshUl. ;, 2.2.4.2 Site Geology • ' ' ' - ' • ' ' . ' - \ '' • " Z - ' ' - ' ' Geotechnical soil borings were completed at the site by Caribbean DrilUng Services, Inc. • . (CDS) on April 18, 1979 and July 21, jl980 prior to expansion of the laboratory faciUty and construction of the fire water storage tank.. Three soil borings were completed in each area. The borings in the laboratory expansion area were 20 to,25 feet deep. The borings in the fire water tank area were driUed 10 td 15 feet below grade. Copies of the soil boring reports are included in Appendix F. > Borings in the vicinity of the laboratory expansion ericountered 0 to 2.5 feet of silty clay. The sUty clay was underlain by 3.5 td 7~ feet of sandy sUt and sUtysand v^th gravel and \W0RK\2423l\02\WORKPLAN.REP 03/17/94,02:33 pm . HARDING LAWSON ASSOCIATES 5 300946 rock fragments which extended from approximately 12 to 14.5 feet below grade. A 1.5 to 3 foot thick layer of tough sandy clay was encountered beneath the sandy silt/silty sand in two of the soU borings identified as B-2 and B-3 in this area (CDS, 1979). Although the sandy clay was not reported in the third boring, B-1, a soU sample was not coUected at the bottom of the sandy sUt/silty sand layer. It is therefore possible that the sandy clay is present in this location at a depth not sampled, possibly between 10 and 13 feet below grade. Four to nine feet of sUty sand and gravel was encountered at the bottom of aU three soil borings in this area. The fire water tank area is underleiin by at least 10 to 13 feet of sandy sUts and clays. A layer of silty sand and gravel was encountered in two borings at 12 and 13 feet below grade. The third boring did not extend to this depth. 2.2.4.3 Regional Hydrogeology Geraghty & Miller performed an aqiufer pumping test in the nearby Fairplain well field between March 9 and 11, 1982. Based on results of the pumping tests, the aUuvial aquifer appears to be under semi-confined conditions. Estimated specific capacities for the five weUs monitored ranged from 1.5 to 3.4 gaUons per minute per foot of drawdovni (gpm/ft) (Geraghty & Miller, 1983). Results of previous testing performed by Cederstrom (1950) on two wells, possibly located in the Old Golden Grove weU field, indicated specific capacities of 4.5 to 5.6 gpm/ft. Insufficient data are avaUable to determine the exact location of the wells tested by Cederstrom. Geraghty & Miller postulated that the weUs may be existing Golden Grove wells, abandoned weUs or they may have been damaged and covered during construction in the area. The alluvium is predominantly low permeabUity, montmorillinitic clay with relatively higher permeability layers of sand and gravel, ranging from one to eight feet in thickness. The interconnection between the higher permeabiUty layers is unknown. Geraghty and MiUer (1983) noted that during the pumping test, ponded water in the River Gut exhibited no change. They suggested that water in the gut may be perched above groundwater. According to Geraghty & Miller (1983) the Fairplain and Golden Grove well fields "apparently derive all of their water from the sand and gravel layers present in the alluvium." Most groundwater appears to be under partially confined conditions. Robinson (1972) reported that it is possible to construct wells which 5deld a few hundred gallons per minute (gpm) in one area of the KingshiU aquifer. However, more often 5delds are closer to 5 to 40 gpm for other areas in the Kingshill and the alluvium. Reported yields for wells identified vdthin one mile of the site range from less than 2 gpm to 62 gpm. Information on wells within one mile of the site is summarized on Table 2-1 and is further discussed in Section 2.4. It is estimated that groundwater recharge is approximately 3% of rainfall, or 1.75 million gaUons per day (Robinson, 1972). The remainder of the rainfall is lost to evaporation and transpiration. Robinson estimated that the Kingshill Formation and overlying alluvium contain 130 billion gallons of water. However, very UtUe of the ground water is potable: most of it is too high in dissolved soUds, due to mixing with the underlying sea water. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 6 300947 2.2.4.4 Site Hydrogeology f There are two pumping well fieldsli located near the ICC site: the Fairplain and Adventure ' fields. Both pump from alluvial deposits and the underljang KingshUl formation. Both had, declining well yields as of 1972 (Robinson, 1972). Groundwater was encounteired in the borings that were drUled in the laboratory expansion area (see previous section). The water table was reported at approximately 20 feet below grade, (approximately 10 to 20 feetlabove MSL). 2.2.4.5 Regional Groundwater Quality ' . - • j , ' ' ' ' . , During the pumping test in the Fairplaiii well field, Geraghty & MUler detected sewage odors in some of the wells. They noted that groundwater contamination from sewage is a primary concern at the Fairplain well field and that "well construction and operational practices in St. Croix's public-supply well fields are not fully adequate to insure the quahty and quantity of the groundwater source," (1983). Geraghty & Miller indicated that lubricating oils from the weU pumps have accumulated in the wells and distribution system. "As much as eight feet of black oU was detected floating on top of the water [in wells in the iFairplairi and Barren Spot well fields] in 1982." The oU also reportedly coated the inside of many of the water storage tanks in the well fields. High concentrations of cliloride, from salt water intrusion, have been detected in much of the groundwater on the island. Geraghty & MUler (1983) reported that "almost aU of the groundwater in,the Kingshill Limestone contains chloride concentrations in excess of 250 mg/L and total dissolved soUds (TD?) in excess of 500 mg/L, the maximum levels set in the USEPA secoridary drinking water standards." ' It is possible that the high chloride and TDS concentrations reported may affect analyses of inorganic substances. The effect of these conditions on groundwater quaUty has not been determined. ' ' 2.3 Potential Receptors 2.3.1 Surrounding Facilities S - ' • ' ' . • . " • The location of the three nearest well fields are shov\m in Figure 2-5. The closest residences are approximately 0.1 miles east of the site. 2.3.2 Exposure The faciUty is.currently abandoned.} A chain link fence surrounds the site, however there is no security, the front gate is damaged and trespassing has been documented in the past. Actual and potential exposure pathways will be evaluated during this investigation \WORK\24231\02\WbRKPLAN.REP 03/17/94 02:33ipm : HARDING LAWSON ASSOCIATES 7 300948 2.3.3 Sensitive Populations No sensitive populations were identified during previous work at this site. 2.4 Water Supply Potable water is supplied from both municipal well water and desalinization plants. However, roof-catchments and cisterns are required for aU houses (Multer, 1974). Most private dwellings have their ovra cistern systems for water supplies (ESI, 1987d). There are 37 potable water weUs located in eight major weU fields on St. Croix. Approximate locations and available information on wells identified vdthin one mile of the site are summarized on Table 2-1 and Figure 2-5. The quaUty of water obtained from the weU fields is generally poor due to mineralization and oU contamination from pump lubrication. These contaminants are often pumped into the supply system (ESI, 1987d). Two onsite weUs were used to supply process water and the fire fighting system. Both weUs were installed by Schuster Services, St. Croix. WeU logs, construction, and operations information is not available. HLA was able to locate one of the production weUs (P-1) during the site inspection on June 30, 1993. Heavy vegetation obscured the location of the second well (P-2). The current condition of the onsite supply wells is unknown. Water cisterns are located beneath the cafeteria in the main building, beneath the warehouse and near the maintenance shop. AU water is collected from roof drains. 2.5 Site History FaciUty ownership and significant environmental activities are summarized on Table 2-2. 2.5.1 Owners and Operators The site is currently unoccupied. It is owmed by CHS Holding Corporation (CHS). On May 1, 1969, CHS leased the site to Houston Chemical Industries, Inc (Houston). Caribe Chemical Co. Inc. (Caribe), a wholly-ovraed subsidiary of Houston operated the facility. In March 1972, Pierrel International S.A. acquired all of the shares of Caribe. Caribe's name was subsequentiy changed to Pierrel America, Inc. Information regarding the use of the faciUty by Houston, Caribe and Pierrel is currently unavaUable. On June 30, 1978, Pierrel assigned the ground lease to Cooper Laboratories (Cooper). ICC, a wholly-owmed subsidiary of Cooper incorporated in Delaware on July 21, 1978, operated the facility. In 1979, Cooper assigned the lease to its subsidiary, ICC. On November 1, 1979, Cooper sold its stock in ICC to Berlex Laboratories, Inc. (Berlex). On September 14, 1984, ICC sold its assets to Virgin Island Chemical Company (VICHEM). \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 8 300949 In January 1989 the USEPA conducted a Preliminary Assessment and Removal Evaluation at the site. At that time the site was operated by St. Croix Security Kennels and VIAG Fuels, Inc. (VIAG). The operator of the kennel, Kate Wesp, was evidently living onsite. VIAG used some office space in the main buUding and stored ethanol in four of the aboveground tanks. Activities performed by the USEPA are discussed in Section 3.8. 2.5.2 Chemical Processes jj ESI reported that prior to acquisition by Cooper, it is beUeved the facUity was used to manufacture phenacetin and ethoxyquin. Before Berlex acquired ICC, the faciUty was being used by Cooper to perfect a process to convert quinine to quinidine. Cooper's process used both toluene and pyridine. For approximately one year during Berlex's ownership of ICC, ICC attempted to develop a quinidine processing operation at the facility. The process that ICC sought to develop during the periodof Beriex's ownership used toluene, but did not use pyridine. (A detaUed discussion of; the process and substances generated is presented in Appendix G.) However, this operation never got beyond the developmental stage. From 1980 untU the end of 1982, ICC experienced problems related to the purity and yield of the product. Early in 1982 ICC abandoned plans to use the site and the plant was permanently closed by the end of 1982. In 1982, ICC sent matierials from the faciUty for disposal. During an inspection in May 1,983, Robert P. van Eepoel of the Government of the Virgin Islands (GOVI). stated that no hazardous waste was onsite. A copy of the inspection form is included in Appendix H. •'- 2.5.3 History and Nature of Waste Handling Information on waste handling procedures of operators other than ICC under Berlex is not avaUable. i . 2.5.3.1 Sanitary Wastes I Septic tanks were used for all sanitary wastes. According tp available information, no process of laboratory drains were connected to the septic system. Reported septic tank locations are shown in Figure 2-2. j, 2.5.3.2 Process Wastes • ; "• . ; , • ; • - ' i ; • " . ' - ' y . y Wastes drained from the laboratories to a cobble-fiUed tank or pit located below a concrete pad west of the warehouse (Figure 2-2). This pit was connected via a 4-inch diameter PVC pipe to a second cobble-filled pit near the fence. However, during excavation activities in the area, in June 1985, ESI reported that no tank was present beneath the loading dock (ESI site description document, page 9, item 2). . SpiUs in the process area were charmeUed to an 8,600-gallon underground concrete pit (Process Pit). The spilled liquids were collected in the pit and reportedly reprocessed or recycled. The Process Pit was connected to a storm drain by a 4-inch PVC Pipe. The storm, t . • • - . • \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm , HARDING LAWSON ASSOCIATES 9 i; 3 0 0 9 5 0 drain was constructed of 55-gallon steel drums that had been welded end to end. Surface runoff from the concrete pad between the Maintenance BuUding and the Laboratory was channelled to this drain through three inlets. 2.5.3.3 Waste Removal During the period from 1980 through 1982, when ICC operated under Berlex, the only wastes regularly generated were those stemming from the process and analytical laboratories. Waste volumes reported exceeded no more than a few gaUons per quarter (ESI, 1985b). When Berlex acquired the faciUty, ICC discovered hazardous materials had been left onsite by the previous occupant. ICC analyzed the material and removed it from the site in 1982 and 1983. Waste removal actions performed by ICC are summarized on Table 2-3. The faciUty was permanentiy closed in the end of 1982. Between November 27, 1982 and February 1, 1983, ICC removed 26,748 gaUons of toluene emd 6,946 gaUons of xylenes from the faciUty for offsite disposal. These waste Uquids were shipped via eight bulk tanker loads to Inland Chemical on Puerto Rico. Copies of waste classification analyses are included in Appendix I. Copies of waste manifests are included in Appendix J. FoUowing closure of the faciUty, the GOVI inspected the site pn May 17, 1983. According to the inspection report, no hazardous waste was present onsite at that time. A copy of the inspection report is included in Appendix H. During limited investigation and remediation activities performed by ESI, various wastes were generated. 192 drums containing various wastes were shipped offsite to Chem-Waste Management, Inc. (CWM) on December 2, 1985. A variety of wastes were apparentiy generated by subsequent operators of the faciUty between 1986 and 1989. Surficial hazardous waste was removed from the site by the USEPA in 1989 and 1990. Copies of USEPA reports documenting removal activities are included in Appendix L. 2.6 Description of Known Contaminants Based on previous work at this site, toluene and pjoidine represent the largest volume releases at the site. These compounds were used by many of the occupants and were detected in soil samples collected by ESI. After the waste removal, waste likely remainirig onsite consists of impacted soils and groundwater. The current conditions of soil and groundwater have not been fully characterized. Substances reported at the site during waste inventory activities performed by ESI and OHM as well as environmental testing performed by ESI and HaUiburton NUS Corporation (NUS) are summarized on Table 2-4. Available information regarding the toxic effects of these substances is included in Appendix BA (see HASP). Most, U not all, of these substances \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 10 300951 were removed from the site. Therefore, current conditions at the site would likely consist of affected soil, if any, impacted by the residual waste. The only suspected groundwater " contaminant identified at the site is Jchloroforin. This substance was detected in samples collected from the two onsite wells and from other weUs near the site. The source of the chloroform has not been identified. , , , Areas of potential environmental concern are summarized in Section 3 of this RIWP. The simimary includes descriptions of the areas, results of previous environmental testing and other activities performed. ! HLA observed no obvious evidence of hazardous waste onsite during the site visit on June 30, 1993. 2.7 Contaminant Migration Pathways Information regarding contaminant migration pathways, if any, is not avaUable at this time. Potential migration pathways wiU be evaliiated preliminarily during the site investigation. 2.8 Human Health and Environmental Assessments , Information regarding huirian health and environmental assessnient of site related \ contamination, if any, is not available at this time. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 11 ! 300952 3.0 EXISTING DATA In September and October 1984, ESI began investigation activities. Results of this work were documented in a Progress Report, including preliminary cleanup plan was submitted to USEPA in December 1984 (ESI, 1984b). Through March 1986, ESI performed a number of supplemental investigations, culminating tn the Remedial Investigation Work Plan (ESI, 1987c). The work plan generated by ESI generated a number of comments by USEPA. Where appropriate, the USEPA comments have been incorporated into this RIWP. A summary of activities performed between September 1984 and March 1986 was prepared by ESI. NUS investigated the site on February 28, 1991. Results of work performed by NUS are described in the Final Draft Site Inspection Report - Island Chemical Companyp/I Chemical, St. Croix, U.S. Virgin Islands (NUS, 1991). Six areas of potential environmental concern were identified through the work performed by ESI and NUS. These areas are identified as: Area A Laboratory and Warehouse BuUding Area B Above-Ground Storage Tank Farm Area C Former Process Pit Area D Loading Dock and Former Lab Pit Area Area E Soil Beneath Concrete Pad Near ASTs Area F Concrete Storage Pad Locations of the areas of concern are shown on Figure 3-1. Descriptions of these areas are summarized on Table 3-1 Results of work performed and data generated are described in the follovydng sections. Analytical results for samples collected from each area are summarized on Tables 3-2 through 3-8. Chemical abbreviations used in the tables are defined on Table 3-9. Copies of original lab reports and/or results reported by other parties are included in Appendix M. I Area A - Laboratory and Warehouse Buildings d on the inspection report generated by GOVI on May 17, 1983 (Appendix H), no irdous waste was present in this area when ICC ceased operations. On January 31, 1989 USEPA responded to a complaint and found approximately 400 drums containing ious materials and wastes in the laboratory and warehouse. Between March 1989 and ril 1991, USEPA contractors removed the drums and waste. Activities associated vdth removal action are further discussed in Section 3.8. \WORK\2423l\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 12 300953 Based on avaUable information, the only samples coUected from this area were used for waste classification. No environmental'samples were coUected. 3.2 Area B • Above>Ground Storage Tank Farm Between October 25 and November 2,1982, ICC analyzed samples from four ASTs (Identified as Tanks 7, 8, 9 and 13) to identify their contents. "Contents identified were toluene, xylene, para-phenetiduie a!rid 9-fluoren6ne. Copies of the analytical reports are included in Appendix I. 3.2.1 Description , • ' . • • • • • • " j ' . ; • " • • • • . • - 7 • ' ' • : . ' • • ' The tank farm is located along the northwestern site boundary. According to avaUable information, twenty, 8,500-gallon ASTs were originally located here. Six tanks were repbrtediy sold locaUy in the l98bsl At the time ICC acquired the site, the foUovidng substances were present in the ASTs. ' . s . ' '• • • • • . • , • ' • ' Approximately 6,900 gaUons of xylene mixed with p-phenetidine left by a previous operator. After the plant shutdovm, this material was shipped to PhUip Brothers Chemicals, Inc. in New York fpr sale. Because the sale was not completed and no other purchaser was found, the rriaterial was manifested as a hazardous waste and shipped to Inland CheiTucal, Puerto Rico, for burning. • Xylenes from the tank farm from previous ownership were shipped to PhUUp Bros. Chemical Co. . • According to the February 7, 1983 ICC in-house memorandum regarding disposition, aU benzpphenone/toluene solutions were shipped to Inland Chemical Co. in Puerto Rico for burning, • . •• • • , " • , . , , • • ' , • r ; ' " . •. . - A -. • ^ - . . , ' Based on Uquid samples collected from nine of the ASTs by ESI on March 12, 1986 (see Table3-2), the tanks cbntaihedthe foUov^drig Uquids: Tank 4 coritained a solution of benzoquinone and fluroendne Tanks 7, 8 and 14 containedjsolutions of benzophenone and fluorenone vidth traces of volatUe organic compounds Tanks 9 and 13 contained p-phenetidine (the solution in Tank 9 included 10,9% afomatics) . Tanks 10 and 11 contained hydroxyfuranocoumarin i • . - • ' Tank 12 contained a mixture of hydroxyfuranocoumarin and p-phenetidine At the time of the USEPA investigation (January 1989), 14 ASTs were present. Four of the tanks were filled with ethanol. The pther ten were empty. / \WORK\24231\a2\WORKPLAN.REP,03/17/94 02:33 pm ' HARDING LAWSON ASSOCIATES 13 3 00954 According to USEPA Pollution Report No. 2, dated June 7, 1989 (Appendix L), on May 25, 1989 the USEPA visited the site. At that time the "first four tanks contain[ed] ethanol and the fifth tank contain [ed] diesel fuel." Four tanks were apparentiy removed and one was relocated sometime between 1990 and the present. Ten tanks remain onsite in the Above-Ground Storage Tank Farm. 3.2.2 Previous Investigations Between September 11 and October 28, 1984, ESI completed twelve test pit frenches at the site. Locations of the trenches are shov^m on Figure 1 in the ESI Progress Report (1984b). A copy of the figure is included in Appendix N. Three of the trenches, identified as Trenches 1, 2 and 3 were located near the tank farm. SoU samples from the frenches were screened in the field for volatUe organic compoimds (VOC) using a portable flame-ionization detector (FID). Based on these results, ESI concluded that "the entire area between and in front of Tanks 8 and 9 was contaminated with toluene which escaped from Tank 8 during cleaning. (ESI 1987c). One sample of soU, identified as T8-1, was analyzed for toluene, pyridine, quinidine gluconate (QG), and quinine sulfate (QS). Three of these compounds were detected in the sample: toluene at 694 parts per miUion (ppm), QG (274 ppm) and QS (101 ppm). A hard clay layer was reported beneath the excavated material. ESI collected one sample, identified as T8-2 from the clay. The sample was analyzed for the four parameters previously noted. Toluene, pyridine and QS were not detected, however, ESI did not report the method detection limit. QG was reported in the clay sample at 47 ppm. Soil and liquid samples coUected from this area aie summarized on Table 3-2. 3.2.3 Previous Remediation Activities ESI excavated the affected soil between Tanks 8 and 9 to a depth of approxiriiately one foot. According to ESI, the excavated soil and the contents of Tank 8 were placed in 55-gallon drums and placed in the warehouse. Between June 6 and July 3, 1985, ESI placed the contents of eight drums containing toluene contaminated soil on drying trays. The trays were placed in the dryer building at 42°c. .ESI coUected samples of the soil in the dryer roughly every two weeks between June 14 and August 7, 1985. Reported results of samples from the soils in the dryer are summarized on Table 3-3. Reported results indicate that toluene concentrations in the soil declined from a maximum of 1,500 ppm in June to 0.66 ppm in August. The USEPA collected two composite samples from the dryer on September 9, 1985. The two composite samples were analyzed for "purgeable and non-volatile organic priority poUutants," (USEPA, 1985). Toluene was detected at 0.46 to 0.56 ppm. Other semi-volatUe compounds were detected at higher concenfrations, including benzophenone at 15,000 ppm. The USEPA report noted that "confirmation of on-site treatment of soil by Berlex (ICC) for toluene and pyridine was made" (USEPA, 1985). \WORK\2423l\a2\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 14 3 0 0 9 5 5 Two 20 gallon drums containing soil arid water were placed in the dryer in an attemplto evaporate the water before putting,,the soil on the trays for. drying. • • 3.3 Area C • Former Process Pit The Former.Process Pit consisted of an IB.OOO-gaUon (ESI, 1987d) or 17,000-gaUon (USEPA, " 1985) underground concrete pit lopatedin the central portion of the site (Figure 3-1). The pit received waste water from spills (ESI, 1987d) and cooling water (USEPA, 1985) from production operations. During plarit pperations, the contents of the pit were sampled to determine whether any product had been released. The water was then reused in the system (ESI, 1987d) or, if the sample results were negative, the waste water was discharged through the central storm sewer (USEPA, 1985). The central and southern storm sewers exited the site via drums which had the tops and bottoms removed and were welded end-to end. ' ' . '. '! Waste generated from the pit, including water and sludge, as well as drums and soU used to construct the two storm sewers, were removed from the site on December 2, 1985. This waste was included in the shipment of 192 drums previously discussed in Section 2.5.3.3 arid summarized on Table 3-4. "Oiie line [presumably the central storm sewer] was replaced with 10-inch PVC pipe" (ESI, 1987) ESI coUected isamples from the Process Pit on June 14 and July 19, 1985. The Process Pit was then abandoned and sealed with concrete later in 1985 (USEPA, 1989a). On February 28,1991, NUS collected a sediment sample from the cenfral storm drain. Based on Figure 3 from the NUS report (1991), the sarriple was located at the coimection between the Former Process Pit and the storm sewer. N|JS sample locations are shown on Figure 3 of the NUS report (1991). A copy of the figure is iocluded in Appendix N. Results of sariaples coUected by ESI and NUS are summarized ori Table 3-4. ." : 3.4 Area b • Loading Dock and Former Lab Pit Area 3.4.1 Description i Area D is located to the north of the warehouse (Figure 3-1). It consists of the loading dock area and drains leading toward the River Gut. The Former Lab Pit was located beneath the loading dock. It consisted of a cobble-fiUed pit that received v\rastes drained from the lalDoratbry (ESI, 1987d). The cobble-filled pit beneath the loadirig dock was connected to a .second pit near the fence line by a 4-inch PVC pipe. A diagram shovdng the layout of the Laboratory pit area was included as Figure 9 in the ESI Progress Report (ESI, 1987d). A copy of the diagram is, included in Appendix N. According to ESI, former facUity personnel reported that, prior to construction of the loading dock, the Lab Pit was open. 'During the rainy season, the pit Pccasionally - overflowed and discharged to the River Gut. The pit was later fiUed and the area covered by the loading dock (ESI, 1987d). | ESI reported that a clay^underUes the stone filled pit and the soil in the loading dock area. ESI did not state the depth to, or the thickness of, the clay layer. However, because the soil \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 15 300956 borings driUed by ESI were reportedly 4 to 8 feet deep, it is presumed that the clay is less than 8 feet below grade in this area. ESI noted that "the underlying clay material has probably prevented dowmward percolation since the FID reading [sic] for clay samples [were] low. Also the materials are highly volatile," (ESI, 1987d). 3.4.2 Previous Investigations and Remediation Activities On or about September 17, 1984, ESI excavated a french, identified as Trench No. 9, in this area. During excavation, the PVC pipe was ruptured and a release of pyridine was reported. They noted that "a sfrong p3Tidine odor was prevalent during the excavation and sampling period," (ESI, 1987d). Surface samples, identified as D-1 through D-5 were collected and analyzed for toluene, pyridine, QG and QS. Pyridine and QG were detected in three of the samples. QS was detected in one of the samples. Sample locations are shown on the figure referenced above, which is included in Appendix N. Analytical results are summarized on Table 3-5. On September 18 and 19,1984, ESI completed 22 soU borings through the Loading Dock area, in an effort to locate and investigate the Lab Drain. The borings were driUed to field selected depths ranging from 4 to 8 feet below grade. SoU samples were screened in the field for VOCs using an FID. ESI coUected four soU samples for analysis of VOCs by Industrial Corrosion Memagement Incorporated (ICMI) of Randolph, New Jersey. In October 1984, ESI returned to the site and completed 18 additional soil borings in the area. ESI collected two soil samples for analysis of toluene and pyridine and nine additional samples for analysis of toluene, pyridine, VOCs and oil and grease. SoU boring locations are shown on the previously referenced figure. Analytical results for the samples collected from this area are summarized on Table 3-5. ESI also reportedly performed further excavation activities in this area in October 1984. They stated that at that time "the pyridine odor was no longer noticeable." In June 1985, ESI returned to the site to remediate the affected soUs. The method used to freat the soils appears to have been a form of biodegradation. During the freatment program, pyridine concentrations were monitored through sample collection and analysis on June 14, July 1, July 17, and August 7, 1985. SampUng locations for these dates are not available. Reported pyridine concentrations fluctuated throughout this period. In September 9,1985, the USEPA collected samples from the site. USEPA collected four composite samples from the area for analysis of "purgeable and non-volatile organic priority pollutants." Results indicated that several phthalates and toluene were present in the soU samples. On March 13, 1986, USEPA returned to the site to collect additional samples. ESI obtained splits of the USEPA samples for independent analysis. One sample, identified as 085252, was collected from the River Gut sediments at the discharge point of the Lab Drain. The other two samples, identified as 085284 and 085284, were collected from the loading dock area. Sample locations are shov^m on Figure 3 of the USEPA report (1986). Several metals and di-n-octyl phthalate were detected in the samples. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 16 3 0 0 9 5 7 On February,28,1991, NUS collected two saniples from this area. Sample SED 2 (and duplicate sample SED 4) wascollected from the River, Gut at the Lab Drain discharge point. Sample Si was collected from the Lab Pit area near the center of the loading dock. Results were generaUy consistent with the data collected by USEPA in 1986, discussed above, wdth - the exception that several pesticides were detected at estimated concentrations. - . 3.5 Area E > Soil Beneath Conbrete Pad Near ASTs A concrete pad, constructed of seven slabs is located in the northern comer of the site. During the investigation in late September 1984, ESI cpmpleted three frenches, identified as Trench 4, 6 and 7, along the edge of the concrete pad near the ASTs. ESI noted evidence of affected soU in Trench 4, adjacent lb and beneath the third slab. ESI collected five soU samples from the area and submitted therii to for analysis of toluerie. Analytical results are summarized on Table 3-6. \ . Although toluene was not detected, ESI noted that the samples were held for three weeks prior to analysis. This period exceeded analytical holding times. The conditions under which the samples were held are uriknovm. ESI noted that "the time lag....may account for the difference between field readings and laboratory analytical results." (ESI 1984b). ESI excavated approximately 4 cubic yards of soU from this area. The excavation was backfUled with clean soU. , ' i 3.6 Area F • Concrete Storage Pad A concrete storage pad is located north of the Laboratory and Warehouse buUding. The pad was used for storage of drums)of ravv materials when the faciUty was operating. MisceUaneous debris were observed on the pad during HLA's June 1993 inspection. ESI completed one french along the southeastern side of the storage pad. They did not report any evidence of contamination at this location. ; 3.7 Other Areas 3.7.1 Storm Drains and River Guil Two storm drains are located on the site (Figure 3-1). The central storm drain runs beneath the paved area between the laboratory and maintenance buildings. The southem storm drain, where observed, is a concrete lined depression along the southern wall of the Maintenance Building and the edge of the Reactor Area. Both storm drains discharge to the River Gut along the eastern side of thfe site. According to ESI, the two storm drairi lines were excavated and replaced between June 6 . and 15,1986 (ESI, 1987d). The old lines were constmcted of 55-gaUon drums that were welded together. According to ESI, the drums from one line contained an oily sludge, however ESI did not specify which line. . , \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm . HARDING LAWSON ASSOCIATES 17 I 300958 The drums that formed the drain lines were placed in containers for later disposal. One line was reportedly replaced with a 10 inch PVC pipe by ESI. The River Gut borders the northeastern and southeastern sides of the site. Several drain lines reportedly discharged from the site to the River Gut. Samples were collected from the drain lines and from the gut by ESI, USEPA and NUS. Analytical results for these samples, as well as results for a background soil sample collected by NUS, are sunamarized on Table 3-7 and are discussed below. On June 7, 1985, ESI collected two soU samples identified as "Drain Line #1" and "Drain Line #2." Although information regarding the actual sample locations is not available, it is presumed that these samples were coUected from drain Unes that discharged to the River Gut. The two samples were spUt and submitted to ICMI and YWC, Inc. York Laboratories Division (York) of Monroe, Connecticut for laboratory analysis. Based on avaUable information, ICMI analyzed sample Drain Line #1 for benzene, toluene, ethylbenzene and xylenes (BTEX) and analyzed sample Drain Line #2 for VOCs. York apparentiy only analyzed the samples for toluene. Toluene was detected in all of the samples at concenfrations ranging from 140 mg/kg to 5,600 mg/kg. Chloroform and methylene chloride were reported in sample Drain Line #2 at 68 mg/kg and 1,260 mg/kg, respectively; these VOCs were not analyzed in sample Drain Line #1. Other VOCs including benzene, carbon tefrachloride, ethylbenzene and xylenes were detected at concenfrations 0.1 to 10 mg/kg. On February 19, 1986, ESI coUected sediment samples from 11 locations along the gut. The samples were submitted to ICMI for analysis of metals, cyanide, phenols and VOCs. ESI sample locations are shown on Figure 13 of the Progress Report (ESI, 1986d). A copy of this figure is included in Appendix N. Several metals, including cadmimn, chromium, copper, lead, and zinc, were detected in the sediment samples from the River Gut. Cadmium was detected in samples G-6 and G-7 at 1.0 mg/kg and 2.4 mg/kg respectively. Cadmium was not detected in any of the other samples from the gut. Chromium, copper, lead and zinc were detected in all of the gut samples. With one exception, the concenfrations of these metals were lowest in sample G-4 and highest in sample G-11. Chromium was detected in at concentrations ranging from 12 mg/kg in sample G-4 to 41.1 mg/kg in G-11; copper was detected at concentrations ranging from 25.3 mg/kg in G-4 to 69.7 mg/kg in G-11; lead concentrations ranged from 13.2 mg/kg in G-4 to 46.7 mg/kg in G-7; zinc concentrations ranged from 37.1 mg/kg in G-4 to 871 mg/kg in G-11. The metal concentrations reported do not appear to pose a cause for concern. None of the other parameters analyzed were reportedly detected in the River Gut sediment samples collected on February 19,1986. ICMI also reported results of a leachate generated from a composite of samples from locations G-6 and G-7. Barium and lead were reported in this sample at concentrations of 1.2 milligrams per liter (mg/L) and 0.24 mg/L, respectively. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 18 300959 On March 13, 1986, USEPA coUected three sediment samples from the River Gut. ESI obtained split samples for independent analysis by ICMI. Sample locations are shown on Figure 3 of the USEPA report (198i5). A cdpy of the figure is included in Appendix N. USEPA analyzed the three sediment samples for VOCs, semivolatUe organic compounds (SVO), pesticides, polychlorinated biphenyls (PCB), metals and dioxins. ICMI analyzed the samples for VOCs, SVOs and PCBs. Results reported by USEPA and ICMI were not consistent. Iri the background sample, 085251 USEPA reported butyl benzyl phthalate, di-n- octyl phthalate, and several metals at relatively low concenfrations. ICMI reported all of the parameters analyzed as not detected. In Sample 085252, coUected near the discharge point of the lab pit, USEPA reported di-ri-octyl phthalate and several metals at relatively low concentration, The only substance reported by ICMI in this sample was methylene chloride (flagged as a possible laboratory-induced contairiinarit).' In Sample 085253, coUected near the discharge point of the Process Pit drain, USEPA reported xylene, several SVOs and several metals at rielatively low concenfrations. ICMI reported chloroform, ethylbenzene and toluene only. The reason for the discrepancies between the data reported by USEPA and ICMI are uiiknown. On February 28,1991, NUS coUected three sedirrient samples from the River Gut, two ' sediment samples from the storm drains and one background soil sample neair the Vfrgin Islands Port Authority (VIPA) -weU field located west of the site. Sample SEDl was located in the gut approximately 500 feet downsfream from the site. Sample SED2 (and dupUcate sample SED4) was located in the gilt near the discharge point of the loading dock surface and lab pit drains. Sample SED3 was coUected in the gut near the upsfream property boundary. Samples SED4 and SED5 were collected from the cenfral and southem storm drains, respectively. Sample locations are shown on Figure 3 from the NUS report (1991). A copy of the figure is included in Appendix N. , , The samples collected by NUS were analyzed for VOCs, SVOs, pesticides, PCBs and metals. No VOCs or SVOs were detected in the three samples coUected from the gut. _ The VOC 2- butanone (methyl ethyl ketone) was detected in the two sediment samples from the storm . drains and in. the background sample. The only.other. VOCs.reported.were.xylenes.inthe two drairi samples and frichloroethene in the background sample, all of which were reported at estimated concenfrations below the method detection limits (MDL). Several SVOs and pesticides were detected in the two samples from the storm drain sediments, aU at estimated concentrations bfelow the MDLs. Metals vk^ere detected in all of the samples collected by NUS. Chromium, copper, lead and zinc were generally, detected at- concentrations similar to those repprted by ESI for the samples collected from the River Gut on February 19, 1986. The metals antimony, arsenic and nickel were reported at relatively low concentrations by USEPA. These metals were not reported by ESI. Several other metals, apparently not previously analyzed, were also detected. These included aluminum, barium, calcium, iron, magnesium, manganese,, potassium, sodium and vanadium. The concentrations reported for these ifletals dp not appear to pose a cause for environmental concern. ' \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm . HARDING LAWSON ASSOCIAT-ES._.t9_ 3 0 0 9 6 0 • 3.7.2 Sump During the inspection in June 1993, HLA observed a simip located to the west of the Maintenance Building. This sump is located near the edge of the concrete paved surface and receives runoff from the paved portion of the site. During the site visit in June 1993, HLA observed several pipes entering the sump. HLA has been unable to find data regarding the conditions in the vicinity of this feature. 3.7.3 Septic Tanks According to ESI, there were three septic tanks on the site (ESI, 1987d), two of which were identified. The location of the septic tank that serviced the office lavatories was unknovim. 3.7.4 Dryer Building The dryer building is located in the southem portion of the site (Figure 3-1). Affected soUs and water were placed in this buUding by ESI as part of thefr remediation program. 3.7.5 4,000-Gallon AST Area Two vertical, 4,000-gallon ASTs are located adjacent to the Production Area. At the time of the USEPA removal action, these ASTs contained approximately one inch of Uquid. USEPA confractors cleaned these tanks as part of the removal action. 3.7.6 Former Location of Paint Cans and Drums During the removal action conducted by the USEPA, paint cans and drums were identified on the concrete paved area near the southem comer of the Laboratory and Warehouse building. A sketch map shovdng the approximate location of these materials was included in tiie USEPA PoUution Report dated October 25, 1991. Copies of avaUable USEPA Pollution Reports are included in Appendix L. The USEPA did not report evidence (presence or absence) of staining or affected soU associated wdth the paint cans and drums. This area was heavily vegetated at the time of HLA's site visit. 3.7.7 Groundwater In October 1990, USEPA prepared the "Compendium of WeU Water Data Collected at the Virgin Island Chemical Co. by the USEPA (1986-1990)." The compendium summarizes chloroform concentrations detected in selected wells during five sampling eVfents between March 13, 1986 and June 25, 1990. These data are summarized with other available data on Table 3-8. ' A " """^.' In all but the first sample from the onsite monitoring well, chloroform concentrations were below the federal Maximum Contaminant Level (MCL) of 0.1 mg/L for trihalomethanes. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 20 3 0 0 9 6 1 3.8 Results of Previous Removal Actions This section discusses the removal actions, performed by USEPA. Previous removal,actibns performed by ICC are discussed in Section 2.5.3.3. , . - " 3.8.1 Remedial Preliminary Assessrnent On January 31,1989, the USEPA Response and Prevention Branch conducted a Preliminary Assessment and Removal Evaluation at the site. This work was in response to a request from Mr. George Pavlou, the Associate Director of Enforcement Programs. The results of the inspection and subsequent removal activities undertaken by the USEPA are documented in 30 PoUution Reports. Copies of the USEPA Pollution Reports are included in Appendix L., At that time of the PreUminary Assessment and Removal Evaluation, the USEPA identified the foUowing three areas of concern: • Laboratory (main buUding);' . • • Drum Storage Warehouse (Main Building); and , • Grounds outside the building including the reactor and centrifuge. 3.8.1.;1 Laboratory Items noted during the USEPA evaluation included the foUowing: Two boxes of sodium; Six cans of ethyl ether; - " Two botties of potassimn cyanide; Phosphorous pentoxide; • Sodium hydride; t Two.flammable storage cabiriets containing various materials; and Two office cabinets with spUled chemicals. , ' Many other chemicals were noted but not inventoried. 3.8.1.2 Drum Storage Warehouse Approximately 400 drums in various condition, soriie severely deteriorated, were identified in the warehouse. The contents of the drums included: ethyl alcohol, an unidentified sludge,'methanol, glacial acetic acid; benzyl acetate, toluene, antifreeze/glycol, salicylic acid, methyl isobutylxarbinol, sodiurii hydroxide, paint and unidentified substances. 3.8.2 USEPA Phase I Removal Activities ll ,' ' . I , ' " , Phase I,removal activities are docurriented in USEPA Pollution Reports 2 through 13 (Appendix L). Activities performed included relocation of drums to the warehouse, opening and sampling contairiers and sampUrig the fire water tank. \WORK\24231\02\WORKPLAN.REP 03/17/94 02.33 pm HARDING LAWSON ASSOCIATES 21 i 3 0 0 9 6 2 3.8.3 First Fuming Drum Emergency Response Action On May 9, 1990 the USEPA performed an emergency response action foUowing a report of a fuming drum. The drum was identified as No. 29, then located in the rear of the warehouse. The response action was completed by May 12. Activities associated -wiih the emergency response action are summarized in USEPA Pollution Report 14 (Appendix L). 3.8.4 Phase II Removal Activities Phase n removal activities performed by the USEPA between June 15 and JxUy 10, 1990 are documented in PoUution Reports 15 through 19. Activities included obtaining bids for waste classification analyses, lab packing and drum segregation, drum crushing and remote detonation of several containers. As part of this action, the USEPA sampled groundwater from weUs identified as VIPA and WAPA on June 25. 3.8.5 Second Fuming Drum Emergency Response Action On July 25, 1990, the USEPA performed an emergency response action foUowing a report of a fuming drum. The drum was identified as No. 22. This drum had been found to contain benzyl chloride, a severe skin irritant. The response action was completed on July 27 when this drum and two other drums containing benzyl chloride were stabiUzed using lime and the bungs were replaced. Activities associated with the emergency response action are summarized in USEPA PoUution Report 20 (Appendix L). 3.8.6 Phase III Removal Activities Between August 6 and November 8, 1990, USEPA performed Phase IU activities as documented in Pollution Reports 21 and 22 (Appendix L). Work performed included additional sampling and preparation of disposal arrangements. 3.8.7 Response to Vandalism Between July 27 and November 9, 1990, the site was vandalized and various materials and equipment to be used for the final removal activities were stolen. The local police were notified and the USEPA returned to the site on November 11 to upright overturned drums, repair damage, and inventory equipment. These activities are summarized in Pollution Report 23 (Appendix L). 3.8.8 Final Phase Removal Final disposition of the waste generated is summarized in Pollution Report 30 (Appendbc L). According to USEPA, cleanup activities were completed by April 1991 and all waste was removed from the site by October 24, 1991. HLA has not been able to obtain copies of Pollution Reports 24 through 29. VWORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 22 300963 3.9 National Priorities List On January 18, 1994, The USEPA issued National Priorities List for UricontroUed Hazardous Waste Sites (NPL) Proposed Rule No. 16. This document proposes the site for the NPL. However, as of the time this document was prepared, the site had not been Usted. The NPL includes two sections. The first, or General Superfund, Secti on, consists of sites being addressed by the USEPA. The second section, or Federal Facilities Section, consists of sites being,addressed by other federal agencies. Currentiy, the General Superfund Section includes 1,069 sites and 67 proposed sites. The Federal FaciUties Section includes 123 sites and 30 proposed sites. . The site has been proposed for the NPL General Superfund Section based on its score under the Hazard Ranking System (HRS), fwhich is Appendix A of 40 Code of Federal Regulations (CFR) Part 300. The HRS evaluates four pathways: groundwater, surface water, soU exposure and air. Based on discussions with USEPA during the meeting on February 7, 1994, the site received an HRS score of 50 and the site was ranked based solely on groundwater pathways. Sites that score a 28.50 or greater on the HRS are eUgible for the NPL. • • ' ' • : - • . • ) l - • ' • . • ' USEPA -will accept comments on the proposed rule submitted on or before March 24, 1994. Although USEPA will attempt to address comments received after the comment period, only those comments postmarked by the' end of the comment period are guaranteed to be considered. . • . ' - • . ' \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 jjm HARDING LAWSON ASSOCIATES 23 4.0 WORK PLAN RATIONALE 4.1 Data Needs In preparing this RIWP, HLA reviewed existing documents provided by USEPA and ICC. Based on this review and the remedial investigation objectives outlined in Section 1.1, the following data needs have been identified for the ICC site: More detaUed understanding of site geology and hydrogeology; Groundwater flow direction(s); Effect of seasonal changes in groundwater flow dfrection, if any; Magnitude, nature and extent of potential impacts to soU and/or groundwater; Information on sewage freatment plant operations and discharges near weU fields; Whether areas of potential concern exist other than those identified during previous investigations; Existence of third septic tank reported by ESI; ^ Possible source of chloroform detected in the onsite and nearby wells; Effect of high chloride and TDS concenfrations on groimdwater chemistry; Other potential sources of groundwater contamination which may have an impact on the Study Area; Location of the contaminated container burning area; and Updated information on use of groundwater in the viciiuty of the ICC site. 4.2 Work Plan Approach The tasks outlined in Section 5 of this RIWP were developed to satisfy the data needs Usted in Section 4.1. Comments received from USEPA have included the follovdng, have been considered in developing this RIWP: • Discussions during the pre-scoping meetings on August 13 and November 18, 1993; • Comments from the Technical Document Review by Camp, Dresser & McKee (1987); and • Comments from USEPA on the Remedial Investigation Work Plan prepared by ESI (USEPA, 1990e). \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 24 300965 rd The tasks to be accomplished are as foUows: ; • Project Planning ' . .. • Obtaining access to site ' , , , • . Clearing site of heavy vegetation • I Performing reconnaissance of site and surrounding area ,. ' Onsite areas of poteiitial concern riot previously identified . - Areas discussed in Section 3.7 of this RIWP Identification of other possible sources of contamination both onsite and offsite. • Reviewing records for other,offsite potential sources of groundwater contamination • Identifying weUs within three mUes of the site Records search, if avaUable • _ - Field reconnaissance'. . ' . - • Interviewing former ICC employees ^ i • Investigating hydrogeology aind groundwater quaUty ' ^ I ' '• y . _ • , - , , • • ' Complete 10 exploratory spU borings • ' Collect approximately 75 soil samples to investigate site stratigraphy - CoUect 30 soU samples for labpratory analysis .- Complete five soU borings as groundwater monitoring wells Collect five groundwater samples for laboratory analysis - Repair or modify existing W,^Us Survey relative monitoring weU elevations Measure water levels in seven monitoring wells ' - • Construct water table contour maps to assess grouridwater flow direction i , _ - . Quarterly groundwater sampling for one year Water level mpnitoring for one year , - Water level recording at selected weUs Evaluate subsurface stratigraphy, hydraulics arid groundwater chemistry , • Meetings and Progress Reports . - . Meeting vdth USEPA to discuss preUminaiy results - Document and address changes in scope of work, if any • Validatirig laboratory data . y • • ' • , - - • • . " t " . • ' . , . , • ' . " ' ' • • Identifying appUcable or relevant and appropriate requirements (ARAR) \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 25 3 0 0 9 6 6 • Preparing Remedial Investigation Report • Managing and disposing of investigation-derived wastes As discussed at the pre-scoping meetings, because it is not certain whether the site is in fact contaminated, the scope of work does not include a baseline Risk Assessment; development, screening and analysis of Remedial Alternatives; or a complete and final feasibiUty study at this time. Based on the anticipated low concenfrations of residual waste, quantitative air sampling is not proposed as part of this investigation. Air quality monitoring for health and safety purposes will be performed during intrusive activities. Ah quaUty moiutoring procedures are discussed in the project HASP (Appendix B). 4.3 Data Quality Objectives Data quaUty objectives for the project are discussed in the Quality Assurance Project Plan (Appendix C) and are not repeated herein. 4.4 Preliminary Identification of ARARs This describes the procedvires used to identify and evaluate ARARs for the ICC site. This discussion is not intended to serve as the final determination of all ARARs for the site. Instead it is an identification of a nmnber of ARARs that may pertain to the site based on currentiy avaUable data. The identification of ARARs is an iterative process carried on throughout the Remedial Investigation. The final determination of ARARs wdU be made as part of the selection of a remedy, if any. HLA is unaware of any identification of ARARs for the site by the GOVI pursuant to Section 121(d)(2)(A) of the Comprehensive Envfronmental Response Compensation and UabUity Act (CERCLA) 42 U.S.C. §9621(d)(2)(A). The ARARs evaluation was performed in a manner consistent with USEPA guidance, including the NCP found in 40 CFR 300, the NCP preamble found in 55 Federal Register (Fed. Reg.) 8666 (March 8, 1990), and tiie "CERCLA CompUance With Other Laws Manual: Parts I and U" (Office of SoUd Waste Emergency Response [OSWER] Directives 9234.1-01 and 9234.1-02) (CompUance Manual). This discussion describes the procedures used in the identification and evaluation of ARARs. Specifically, this discussion: summarizes the definitions and procedures used to evaluate the applicabUity or relevance and appropriateness of potential ARARs; describes ARARs categories; and identifies potential ARARs associated vidth state authorized programs. 4.4.1 Definition of ARARs Remedial actions selected under CERCLA must attain a degree of cleanup that, at a minimum, assures protection of human health and the environment (42 U.S.C. § 9621 [d][l]). When a hazardous substance remains onsite, CERCLA requires that remedial actions meet a level or standard of control that at least attains standards, requirements or \WORK\2423l\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 2 6 3 0 0 9 6 7 Umitations under any federal or stricter state envfronmental law, if such requirements are legaUy applicable or relevant and appropriate under the circumstances:(42 USC § 9621[d][2]). Guidance and health advisories may also be used as matters "to be .' considered." To-Be-Considered (TBC) requirements are not identified in this preliminary identification of ARARs. { • Applicable Requfrements, AppUcable requirements are those cleanup standards, standards of confrol, and other substantive requfrements, criteria, or Umitations promulgated under feideral or state envfronmental or facUity siting laws that specifically address a hazardous substance; pollutant, contaminant, remedial action, location, or other cfrcumstances found at a CERCLA site (NCP, 40 CFR § 300.5) • RiBlevant and Appropriate Requfrements. Relevant and appropriate requfrements are those cleanup standards, standards of control, and other substaritive envfronmental protection requfrements, criteria, or limitations promulgated under federal or state environmental or facUity siting la>vs that, while not "appUcable" to a hazardous - substance, poUutant, contaminant, remedial action, location, or other circumstance at a CERCLA site, address problems or situations sufficiently siriiilar to those encoun- tered at the CERCLA site that thefr use is weU suited to the particular site (NCP. 40 CFR § 300.5). i / : • To-Be-Considered Requfrements. TBCs are non-promulgated advisories or guidance issued by federal or state govemment that are not legaUy biriding and do not have the status of potential ARARs. In many circumstances, however, TBCs will be considered along with ARARs as part of the site risk assessrnent, if performed, and may be used in detennininglithe necessary level of cleanup for protection of health or the envfronment (NCP, 40 CFR § 300.400[g][3]). The terms "applicable" and "relevant and appropriate" are mutuaUy exclusive. Therefore, a requirement under environmental laws may be either,"appUcable" or "relevant and appropriate," butnot both (CompUance Manual, Vol. 1, p. xin). For a requirement to be "applicable," the remedial action or the cfrcumstances at the site must satisfy all the jurisdic- tional prerequisites for the requirement. If a requirement is not appUcable, it nonetheless may still be relevant and appropriate. In deciding whether a requirement is relevant arid appropriate the follovdng factors, fourid in 40 CFR § 300.400(g)(2), are evaluated: (1} the purpose of the requirement; (2) the medium regulated or affected by the requirement; (3) the substances regulated by the requirement; (4) the actions or actiyities regulated by the requirement; (5) the variances, waivers, or exemptions to the requirement; (6) the type of place regulated or affected by the requirement; (7) the tj^e and size of stmcture or facility regulated or affected by the release; and (8) any consideration of use or potential use of affected resources associated with the requirement. _ , i . • The evaluation of relevance considers the above factors with respect "to whether a requirement addresses problems or situations sufficiently simUar to the circumstances of the contemplated remediation. If the requirement is relevant, the evaluation of appropriateness \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm . HARDING LAVVSON ASSOCIATES 2 7 wiU consider the above factors with respect to whether the requirement is well suited to the particular site (55 Fed. Reg. 8743) CERCLA response actions are subject only to substantive, not administrative, requirements (55 Fed. Reg. 8758). Substantive requirements are those that pertain directly to actions or conditions in the environment, such as concenfration-based standards, technology-based standards, and resfrictions upon activities in certain special locations. Adminisfrative requfrements, on the other hand, are those mechanisms that facUitate the implementation of the substantive requfrement and include the approval of, or consultation wdth, adminisfrative bodies issuance of permits, documentation and reporting and record keeping (55 Fed. Reg. 8758 and CompUance Manual, Vol. 1, p. 1-11). The concept of ARARs pertains to those portions of actions conducted wholly onsite. However, both substantive and adminisfrative requirements are applicable off-site. For example, if the discharge point to surface waters is located on-site, a discharge permit is not requfred. However, if the discharge point is considered to be offsite, a permit would be required. Also, certain requfrements are not considered to be ARARs because the relevant activities do not occur onsite. For example, pretreatment requfrements are not ARARs because, even if CERCLA waste water is discharged to a sewer located on sile, freatment by a publicly owned freatment works (POTW) located offsite is considered an offsite activity (CompUance Manual, Vol. 1, p. 3-21). CERCLA expressly provides for state standards to be ARARs at a site. However, only those standards that are more stringent than federal requirements may be considered. In addition, the state standards must be promulgated (i.e., the requfrement must be of general applicabUity and legaUy enforceable). Finally, the requfrements must be identified in a timely manner by the particular state (40 CFR § 300.400[g][4]). Only requfrements that could possibly pertain to the site were Usted and evaluated. For example, mining laws were not listed because no mines are present onsite. 4.4.2 ARAR Categories ARARs are divided into three groups: chemical-, action-, and location-specific ARARs. These categories are described as foUows: • Chemical-Specific ARARs. These ARARs are usually health- or risk-based numerical values or methodologies which, when applied to site-specific conditions, result in the establishment of numeric values. These values establish the acceptable amount or concentration of a chemical that may be found in, or discharged to the ambient environment (CompUance Manual, Vol. 1, p. 1-13). • Action-Specific ARARs. Action-specific ARARs are usually technology- or activity- based requirements or limitations on actions taken vdth respect to hazardous substances (Compliance Manual, Vol. 1, p. 1-29). • Location-Specific ARARs. Location-specific ARARs are restrictions placed on the concentration of hazardous substances or the conduct of activities solely because \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 2 8 3 0 0 9 6 9 "^ they occur iri special locations. Location-specific ARARs relate to the geographical ^ • or physical position of the site (e.g., presence of wetiands, endangered species, flood plains, etc.) (Compliance Manual, Vol. 1, p. 1-25), , / 4.4.3 ARARs Associated With State-Authorized Programs For those, state programs vvhich have received federal .authorization pursuant Jo federal law, generaUy both the federal and state requfrements are provided. Most envfronmental statutes authorizing delegation to states of a federal program do not address how quickly states must incorporate federal changes into the state's delegated prograrri. Thus, state programs rnay lag behind federal programs. Also,'the federal statutes require that state requfrements be at least as stringent as the federal requfrements. Therefore, a listing of both the state and federal'requfrements is provided. , States may be authorized by the USEPA to implement the hazardous waste management program in Ueu of the USEPA in accordance with 42 u s e § 6926. The extent of ' authorization and the portion of the SoUd Waste Disposal Act (SWDA) pursuant to which USEPA has promulgated regulations is relevant to whether the state or federal requfrement is considered the ARAR. The SWDA was amended by the Resource Conservation and Recovery Act (RCRA) and later by the Hazardous and Solid Waste Ameridments of 1984 (HSWA).' When new federal regulations are promulgated under HSWA, the regulations remain under federal jurisdiction until the state receives authorization frorii the USEPA. Thus, the federal HSWA regulations are applicable or relevant and appropriate. When federal regulations are promulgated pursuarit tp RCRA, however, the regulations are not appUcable uritU the state program (if the state has been authorized to implement RCRA) adopts those regulations. (CpmpUance Manual, Vol 2, App. B). ' . . - • ' . . The U.S. Vfrgin Islands do not haveRCRA authorization nor clean up standards for groundwater or soil, besides soil standards for total pefroleum hydrocarbons (100 mg/kg), total benzene, toluene, ethylbenzene and xylenes (50 rng/kg) and lead (5 mg/kg). The r ' USEPA Region II has authorization over the Vfrgin Islands through thefr New York , Caribbean Prograrin. Through this prograrii, federal clean up standards would apply. There are no final standards for soil,remediatioii. Groundwater remediation levels are site specific and are based on the National Revised Primary Drinking-Water Standards. . i " •' • , ' • " ' , • • ' • , • 4.4.4 Preliminary Lists of ARARs • • • ' • • • . ' • • • • - . ' ^ ' • ' Chemical-specific,-action-specific, and location-specific ARARs are preliminarily identified • in Tables 4-1, 4-2 and 4-3, respectively. The tables identify the requirements and their legal citations, describe the requirements,! and comment on the applicability or relevance and appropriateness of each requirement. .,, \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm , , . HARDING LAWSON ASSOCIATES 2 9 5.0 REMEDIAL INVESTIGATION TASKS The tasks to be completed as part of the Remedial Investigation are outiined below. As discussed in Section 4.2, specifics of well locations, wells to be sampled, analytical parameters and other activities may need to be modified based on the findings of various tasks. USEPA -will be notified of any substantive changes, and any changes in approach vnU be discussed with, and approved by, USEPA prior to implementation. Field activities wiU be conducted foUowing procedures outlined in the SAP. Health and Safety precautions for field activities wiU be as presented in the HASP. QuaUty assmance measures for Remedial Investigation activities are outUned in the QAPP. 5.1 Project Planning and Management 5.1.1 Meetings w i t h USEPA Two meetings with USEPA are currentiy planned for this project. A project kick-off meeting will be requested immediately foUowing USEPA approval of the work plans. The kick-off meeting wUl include a brief review of the scope of work to ensure the parties involved are in agreement vidth the planned scope of work. A second meeting wUl be requested foUowing receipt, interpretation and validation of data and prior to preparation of the Remedial Investigation report (see Section 5.11). At that time, the findings wiU be discussed along with the format for the RI Report. 5.1.2 Monthly Progress Reports Monthly progress reports wUl be prepared and subnntted every 30 days beginning 30 days after the date work plan approval is received from USEPA. The monthly progress reports vidll include the following: • Description of actions taken toward compUance v^dth the consent order and work plan tasks implemented; / • Copies of data obtained including laboratory results (whether or not reviewed and interpreted); • Description of data anticipated to be received and activities scheduled for next 30 day period; and • Description of problems encountered and actions taken or to be taken to mitigate/remedy problems and a schedule for those actions. 5.2 Background Investigation 5.2.1 Obtain and Review Well Records HLA vidll contact the St. Croix Department of Planning and Natural Resources (DPNR) regarding well records vdthin three miles of the site. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 30 300971 5.2.2 Obtain and Review Historic Aerial Photographs • ' • - ' ^ , ' ' - ' • . . . • HLA wUl obtain avaUable aerial photographs of the site and surrounding area. Based on discussions with private and goverriment resources the following photographs are available for St. Croix: - • . • 1953 photograph from Iiiterra (Available at a scale of 1 inch to 1,500 feet) • 13 photographs from the U.S. Department of the Interior at scales ranging from 1:23,600 to 1:124,755 including: - - One 1954 photograph - Two 1974 photographs - 10 Photographs taken between 1990 and 1991. It is uncertain at this time whether the photographs Usted can be expanded to show useful detaUs or if the site is in fact covered. National Ocean Services wUl also be contacted to determine whether any additional photographs are avaUable. 5.2.3 Obtain and Evaluate Additional Existing Data HLA wUl obtain any additional data; and data packages avaUable. ICC files v\dll be inspected for any additional data. Additional data, if any, avaUable from the USEPA wiU be requested under the Freedom of Information Act (FOLA). The additional data, if any, wiU be validated, if practicable, and preliminarUy evaluated with respect to existing data. HLA wiU also research possible effects of elevated chloride and TDS on groundwater chemistry. 5.2.4 Obtain Information on Potential Offsite Source Areas i ' . ' • , - , . . • Other potential sources of groimdwater cpritamination may be present in the vicinity of the site. A records reyie\y. to identify.other, sites that may be potential contaminant- sources v^dll be conducted. i The review v\dll initially focus on the area within one-quartermUe of the site. When the lateral dfrection of groundwater flow is better defined and more information is available on the extent of contamination, if any, the focus of the review may be expanded or reduced. Types of sites to be identified include the following: RCRA facilities j Leaking underground storage tank facilities CERCLA Information System sites National Pollution Discharge Elimination System dischargers Virgin Islands Usted hazardous waste sites ^ Emergency Response Notification System and Hazardous Materials Incident Report System spill sites I . " ' Solid waste disposal facilities , \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 31 3 0 0 9 7 2 Commercial databases categorize sites in the U.S. Vfrgin Islands as unmappable. Sites identified using a commercial database will be indicated by zip code or locality only. All sites that have a zip code in the area wUl be considered for inclusion. Records may be excluded in it can be determined to be outside the radius searched. Sites identified by the commercial database wdll be evaluated based on tj^e, location and proximity to the site. Further information on selected sites wdU be obtained through the federal Freedom of Information Act or equivalent local laws from the USEPA, GOVI, DPNR, local health department, local buUding inspector, fire department or other local agencies maintaining such information. The information obtained wUl be evaluated for relative potential for contribution to groundwater conditions at the site. Available information on the nearby sewage freatment plant wiU be obtained. If sufficient information cannot be obtained, HLA will request permission from the St. Croix Department of Public Works (DPW) to inspect the sewage freatment plant and interview plant personnel regarding sewage freatment, waste disposal and freated water discharge practices. 5.3 Acquire Access and Permits 5.3.1 Access Agreements Prior to initiation of field activities, access agreements must be obtained from the owner of the properties on which field work wdU be performed or which must be crossed to access field work areas. At this time, all field work wiU be performed on property beUeved to be ov^med by CHS. Access agreements wiU be negotiated with the property owners by the Respondents's legal counsel. Efforts to obtain access agreements wiU include, but not be limited to, use of letters sent by certified mail to the property owners requesting access for field personnel and subconfractors, USEPA, and thefr authorized representatives. DUigent efforts wUl be made to finaUze access agreements in a timely maimer so as to avoid delays in RIWP implementation. To this end, efforts to acquire access agreements will be initiated prior to receipt of RIWP approval. 5.3.2 Well Drilling Permits Based on discussions with representatives of the DPNR, the following procedures will be necessary to obtain permits to install the monitoring wells: 1. Drilling permits will be obtained from the DPNR for each of the wells to be installed. 2. Plot map vidll be obtained from the DPW. 3. The site location and wells wdll be indicated on the plot map and returned to DPNR with the appropriate permit fees. 4. DPNR official will examine the site and then issue the permit. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 3 2 300973 According to DPNR and local drillers, this process is expected to take three to four weeks. At this time it is expected that thejidrilUng contractor wiU obtain the permits. 5.3.3 Customs Permits for Sarriples Permits required to bring the environmental samples into the U-S. wall be obtained by the laboratory contractor prior tp begirining;work on this project. Contractors currentiy anticipated for use on the project afready have the necessary permits in-place. 5.3.4 USEPA Disposal Permission , / ' l l • • • ; - • ' • • • . ' . • • . • : Waste classification samples wiU be analyzed to classify \yaste soil and water generated . during this investigation. Based onl resiUts of the waste classification samples, potential disposal sites will be identified. Results of waste classification samples and names of proposed disposal sites wdll be forwarded to USEPA wdth a request for permission tp dispose of the waste generated. Proposed analyses and procedures for management of investigation derived wastes are discussed in Section 5.12. 5.4 Site Clearing and Reconnaissance The site is overgrown and wiU have to be cleared fpr access. Site clearingWill not include vegetation within 25 feet of the River Gut as requfred under the Vfrgin Islands Statute pertaining to trees and water courses (see Table 4-3). Once the site is cleared of heavy vegetation, a general site inspectioriwUl be performed. The areas described tn Section 3.7 (with the exception of groundwater) vdU be inspected visuaUy for evidence of contamination. ' . • • • , • ( ' " • • •" • • • ,1 5.5 Field Sampling Program | ' ' I . . . • - . ^ • • The field sampling program is described in detaU in the SAP (Appendix A). 5.5.1 Soil Sampling Program | 5^5.1.1 Soil Boring Locationis and Rationale • . • • j | • ' . • . . ' • . The proposed locations for the soil borings are shown in Figure 3-1. The general objectives of soil boring placement applicable to aU 10 proposed borings are as follows: • Investigate site stratigraphy . , ' . • \ - ' • ' ' • • • • - ' • ' • • • • ' • - Evaluate existence and extent of low permeabUity layer previously reported by ESI The location and rationale for each boring are discussed below: • , ' • • ' • • * ^ . ' • ' . SBBl This boring wiU be located in to the east of tank No. 8 in the area of the reported toluene release. Samples vdll be collected to evaluate whether historical releases in _ this area have affected soil conditions and, if so, the vertical extent of impact. Boring SBBl vvdU be completed as Monitoring WeU MW-1. \WORK\2423l\02\WORKPLAN.REP 03/17/94 02:33fpm \ HARPING LAWSON ASSOCIATES 33 300974 A SBCl This boring weU be located to the east of the Former Process Pit. This dfrection is believed to be hydraulically downgradient from the pit. Samples wiU be collected to evaluate whether soil has been affected through historical use of the pit. This boring wiU be completed as Monitoring Well MW-2. SBC2 This boring will be located near the end of central storm drain that crosses the site. Overflow from the Former Process Pit is beUeved to have discharged via this sewer. Samples wUl be collected to evaluate whether this discharge has affected soil quaUty near the property boundary. Boring SBC2 wiU be completed as Monitoring WeU MW-3. SBDl This boring will be completed through the loading dock area, through the reported location of the Former Lab Pit. Samples wiU be coUected to evaluate whether soU has been affected through historical use of the pit. Boring SBDl wUl be completed as Monitoring Well MW-4. SBD2 This boring wiU be completed through the Former Lab Drain where it exited beneath the paved area near the loading dock. Samples wiU be collected to evaluate whether soU in this area has been affected by discharge from the drain as weU as runoff from the loading dock and paved area. This boring wUl be abemdoned upon completion. SBD3 This boring will be completed near the end of the Loading Dock Surface Drain. Samples will be collected to evaluate whether soU near the property boundary have been affected by discharge from this drain. Unless evidence of affected soil is detected in the field, this boring wiU be abandoned upon completion. If evidence of affected soU is detected in the field at this location, boring SBD3 may be completed as a monitoring weU. SBD4 This boring wiU be completed near the southeastern comer of the site. SoU samples from this location wiU be collected for field screening purposes only. ,This boring wdll be completed as Monitoring WeU MW-5. SBEl This boring will be located adjacent to the Concrete Pad Near the AST Farm in the location of a previously reported release. Samples viiW be collected to evaluate whether historical releases in this area have affected soil conditions and, if so, the vertical extent of impact. Boring SBEl vvriU be abandoned upon completion. SBFl, SBF2 andSBF3 These borings will be located on the north, east and west sides of the Concrete Storage Pad. Samples will be collected to evaluate whether runoff from this structure has affected soil quality in this area. These three borings vdU be abandoned upon completion. 5.5.1.2 Drilling and Soil Sampling Procedures The soil borings v^dll be advanced using hollow-stem auger drilling techniques. This method has been selected based on procedures previously used at the site as documented in the geotechnical reports (CDS, 1979 and 1980) and through discussions with local drillers. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 3 4 300975 The soil borings wall be sampled continuously using a split-spoon sampling device to lO feet i^k below grade and at 5-foot intervalsfto completion depth at the water table. Samples vvill be ^ ^ coUected more frequentiy at suspected changes in Uthology and at the anticipated water table depth (20 feet below grade). As discussed in Section 2.2.4.4, groundwater is expected to be encountered al approximately 20 feet below grade. A portion of material from each split sppon sample vvdU be placed in a plastic bag and - screened in the field for relative VOC concenfrations using an FID or photo-ionization detector (PID). Sample material collected for laboratory analysis of VOCs wiU nol be subjected to field screening. Samples for laboratory analysis vtdll be collected frorii the 0- to 2-foot interval below grade; above the water table; and at an intermediate depth interval. The intermediate depth interval wdll be selected based on relative VOC Concenfrations and/or vvisible evidence of coritamination. If none of the samples from a given boring exhibit VOCs or visible e\ddence of contamination, the intermediate depth sample wiU be collected immediately above the first layer of relatively low permeabiUty encountered. All samples from each boring will be analyzed for Target Compound list VolatUe Organic Compounds plus a library search of up to 15 tentatively identified compounds by Confract Laboratory Program 3/90 Scope of work (TCL VOCs+15). The shallow sample from each boring will also be analyzed for the ifoUowing parameters: j • TCL SVOs plus a library search of up to 15 tentatively identified conipounds by Confract Laboratory Program 3/90 Scope of work (TCL SVOs-hl5); • TCL Pesticides and PCBs; j • Target Analyte List (TAL) Inorganics; and , • Pyridine. I If any analytes are detected at concentrations exceeding the proposed Examples of Concenfrations Meeting Criteria for Action Levels (July 27, 1990 federal register), the samples from the deeper intervals vml be analyzed for those parameters'as well. The shallow samples v\dll be analyzed using a one-week laboratory TAT to allow the remaining samples to be analyzed, if necessary, within the 14-day technical holding time (see SAP, Appendix AB). The additional samples, if ariy, vaU be analyzed using a standard 3- to 4- week laboratory TAT. •' . • • , i ' • ' ' • , , . • 5.5.2 Groundwater Monitoring Well Installiation 5.5.2.1 Monitoring WellLocations , Monitoring well locations are shown! on Figure 3-1. General objectives of well placement applicable to aU five proposed well locations are as foUows: . ' ' • • ' ' • • il • • . ' ' • Obtain water level data onsite. • , . ' ' - • • ; . • ' • • . \WORK\24231\D2\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 35 • Evaluate the distribution of chemicals, if any, present in the groundwater near potential source areas. The location and specific rationale for each well location are discussed below. MW-1 This monitoring well wiU be installed near the reported release in the Above-ground Storage Tank Farm. This well vidU be used to evaluate groundwater conditions in the area of the reported historical release. If free from contamination, this weU may serve as an upgradient moiutoring location for water levels and water quaUty. MW-2 This monitoring weU will be installed on the anticipated hydraulicaUy dowmgradient side of the Former Process Pit. The weU v ^ be used to evaluate groundwater conditions near the center of the site. The well v\dU provide water level and water quality data in the immediate vicinity of the former process pit. MW-3 This monitoring weU wiU be instaUed near the eastern property bovmdary along the cenfral storm drain. This weU wiU be used to evaluate groundwater conditions near the anticipated dowmgradient property boimdary. MW-4 This weU wall be instaUed in the location of the Former Lab Pit beneath the loading dock. Samples from this weU wiU be used to evaluate whether historical operation of Former Lab Pit affected groundwater quaUty. i MW-5 This weU wiU be installed near the southeastern comer of the site. This weU wiU be used to evaluate groundwater quaUty in the dfrection anticipated to be hydraulicaUy dowmgradient from the Former Lab Pit, Loading Dock and associated drains. 5.2.2.2 Drilling and Completion of Monitoring Wells WeU consfruction procedures and detaUs are described in the SAP (Appendix A). WeU screens wdU be placed across the water table. This v\dU be done to allow detection of any light and separate-phase floating contaminants, should they be present. The total thickness of the saturated zone at the site is unknovkoi. However, based on avaUable information, the River Gut alluvial deposits in this area may be greater than 100 feet thick in this area. There are currentiy no plans to install monitoring wells deeper into the aquifer. The wells will be developed as described in the SAP. Development water will be placed in 55-gallon drums and staged onsite pending disposal. 5.5.3 Rehabilitate Existing Wells Assuming the well labelled P-1 (Figure 3-1) can be located, both existing wells will be modified to facilitate access. This will include removal of the pumps and well heads. Locking protective steel casings will be installed to protect the tops of the wells and water- tight plugs wUl be placed at the top of the inner casings. Immediately after removal of the well cap, the air above and within the well casing will be screened for VOCs using an FID or PID. The bottoms of the wells vidll be sounded and a \WORK\2423lV)2\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 3 6 300977 caliper wdU be lowered into the wells in an attempt to determine the screened intervals, if any. A grab sample will be collected frorii the,sediment at the bottom of each •vyell and inspected in the field. ' ; . A surge block wall be used to redevelop the weUs. Because information regarding the construction and integrity of the vvells is not currenlly available, the two existing wells are not currentiy anticipated to be used for groundwater sampUng. Assuming it can be determined that the wells are screened in the shallpw portion of the aquifer, water levels vdU be taken ifor use in constructing water table contour maps for the s i t e . • • • ;• ^ ' • .^. . \ 5.5.4 Survey ' 1 The latitude, longitude and elevations of the two existing production weUs and the new . moiutoring weUs wiU be surveyed by a Ucensed surveyor. Elevations surveyed will include the inner, outer and ground elevations with respect to MSL. The locations of the inner casing elevation measurements wUl bie marked for future water level measurements. 5.5.5 Groundwater Monitoring and Sampling '\: ' -: y . • ' > " • ' •. ' " 5.5.5.1 First Round of Groundwater Sampling Approximately two weeks after instaUation and development, groundwater samples wiU be coUected froni the fiye new monitoring weUs. Groimdwater sampling procedures are described in the SAP. - , ;•• Z ' ':• Prior to collecting samples, water levels wiU be measmed in all of the wells onsite. Groundwater elevktions wUl be calculated by subtracting the measured depth to water from the surveyed referenced elevation described in Section 5.5.4. Groundwater contour maps wiU be prepared using the water table elevations. These wiU be used to evaluate lateral groundwater flow dfrections. j • . - • ; - . r ' • •• : • . • ' " - • ' , The groundwater samples will be analyzed by a Superfund Corilract Laboratory Program (CLP) laboratory for TCL VOCs+ls! SVOs+15, Pesticides and PCBs, TAL inorganics and pyridine. Libraiy searches of up toj, 15 TICs wall be performed on both the VOC and SVO fractions. Both field-filtered and unfUlefed samples wiU be analyzed for TAL metals in _ accordance wdth the USEPA Regiori' IU QA Dfrective Fjfe7d Filtration Policy for Monitoring Well Groundwater Samples Requiring Metals Analysis, BuUeiin No. QAD009 (AprU 23, 1990). Specific conductance, temperature and pH will be measured in the field. The parameters were selected based on substances previously reported at the site. 5.5.5.2 Water Level Monitoring Water level measurements and survey data wiU be used to construct groundwater contour maps to determine the direction of | horizontal groundwater flow at the site. Groundwater at the site may be influenced by seasonal effects from the nearby River Gut. \WORX\2423l\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 3 7 • • " . • ' " . • . ' ' • ' • . • i y • 3 0 0 9 7 8 To evaluate potential seasonal fluctuations in water levels and direction of flow, quarterly water level measurements wall be recorded al each monitoring well for a period of one year. One or more continuous water level recorders will be instaUed in selected wells to supplement the quarterly measurement data and to evaluate diumal or other short term water level fluctuations. The wells to be monitored and the wells in which continuous water level recorders will be placed wiU be selected based on evaluation of water level data for the initial three month period of water level measurements. The water level data wUl be compared to previously coUected data and water level elevation contour maps wdU be prepared periodicaUy. Data from the continuous recorders is also anticipated to be used in conjunction with the quarterly water level measvu-ements and precipitation records to evaluate the potential recharge effects at the site. 5.5.5.3 Quarterly Groundwater Sampling Three additional rounds of groundwater samples wiU be coUected from selected weUs on a quarterly basis. The quarterly sampling data wdU be used to evaluate seasonal frends in contaminant concenfrations and wdU provide a more statisticaUy representative groundwater quaUty database. The weUs to be sampled and the parameters to be analyzed wiU be determined based on interpretation of the water level data and results of initial sampUng discussed above. The wells to be sampled and analytical parameter Ust wall be discussed with EPA prior to sample collection. Based on avaUable data, HLA anticipates sampling three of the monitoring weUs on a quarterly basis for TCL V0Cs-H5 and pyridine. 5.6 Data Validation All laboratory data wdU be validated as discussed in the QAPP (Appendix C). 5.7 Data Evaluation Following completion of data validation, the laboratory data wdU be compiled and summarized along with the field data. Laboratory and pertinent field data wall be input into a computerized database for subsequent tabulation and analysis. The data wall be plotted and evaluated for patterns of distribution, degradation, migration and other such relationships. Data generated during this project wdU be used to: • Determine hydraulic gradient; • Identify constituents in soU and groundwater; and • Evaluate site conditions wdth respect to ARARs. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 38 300979 5.8 Development of ARARs { ^ • ' • . , 1 . • , . • • • • • ' . • • • ' • • The preliminary listing of ARARs provided in Section 4.4 will be refined, developed and revised, as needed, throughout completion of the Remedial Investigation activities to lake into consideratiori new chemical data, sile conditions and potential remedial actions. Further, stale and federal registers will be reviewed periodically to identify changes to the ARARs that have already been identified. • 5.9 Remedial Investigation Report FoUowdng completion of aU Remedial Investigation activities, a draft Rerriedial hivestigation report will be prepared and subrnitted to USEPA. The Remedial Investigation report wdU include the foUpwing: ^ Discussion of the history of ithe site; Summary of previous investigations and remedial actions; Description of the site including the physical setting, cUmate, surface water hydrology, geology and soUs; Summary of sampling locations and procedures; Discussion of deviations, if any,; from the RIWP; i . Tabulated summaries of soU and groundwater quaUly data; Data on groundwater flow dfrection; Listing of ARARs; and , Recommendation's regarding identification of other potential sources of cbritariiiriatibri in the vicinity of the site. After incorporation of USEPA's comrrienIs j'the report will be finaUzed. 5.10 Management of Investigation Derived Wastes ^ Investigation-derived wastes generated,during the Remedial Investigation activities will generally be managed iri accordance wdlh USEPA's Guide to Management of Investigation- Derived Wastes quick Teierence fact sheet {USEPA, 1992c). The types of wastes anticipated to be generated include the foUowing:' • ' Decontamination fluids • DrUling fluids and cuttings ! • WeU development and purgeji water ; • Used personal protective equipmerit . y ' \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33]|pm HARDING LAWSON ASSOCIATES 39 300980 Decontamination fluids, drilling fluids and cuttings wall be containerized (e.g., in drums or portable above-ground storage tanks for liquids, in drums or roll-offs for solids) and stored in the warehouse building. This storage area was used by USEPA confractors during previous removal activities. The containers wall be labelled wdth regard to contents, date of generation and boring of origin. Representative composite samples wdU be collected from the containers and laboratory tested for RCRA characteristics. Based on the resiUts of the analyses, the waste materials may be disposed offsite in accordance with CERCLA 121(d)(3) and the CERCLA Off-Site Policy dfrective (USEPA, 1987d). For aU shipments of 10 cubic yards or more, written notification will be provided to envfronmental officials of the receiving state and the USEPA project coordinator. WeU development and purge water wiU also be containerized in drums or portable tanks, labeUed wdth regard to contents, date of generation and weU of origin, and stored in the warehouse. If the results of analyses of groundwater samples indicate that no chemicals of concern are present, the water may be discharged at a local facUity, if approved by the St. Croix DPW. If not approved, these wastes wUl be stored in the warehouse for eventual characterization and disposal. Solids that may accumulate at the bottom of the containers, particularly those of development water, will be freated in the same manner as the drilling fluids and cuttings. Personal protective equipment and disposable field equipment wdU be decontaminated, if appUcable, coUected in drums or an indusfrial dumpster, and disposed at a RCRA Subtitie D faciUty. Containment systems that can contain at least 110 percent of the volume of the containers stored wdU be provided for liquid wastes stored in the warehouse. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 0 300981 6.0 PROJECT ORGANIZATION I , • , • . • . • ' . HLA, as a confractor to ICC, has responsibiUty for designing the samplirig and analysis programs necessary to^achieve the'project objectives. HLA's project management structure is iUusfrated in Figure 6-1. . • , ' - • . . ' • ' • • ' ' , ' HLA wall provide project managenient, perform and/or observe field investigations, and prepare and submit project deliverables to USEPA. To achieve these goals, HLA wall retain experienced subcontractors in the specific discipUnes necessary. The ICC project wdU include several subconfractors. Selection of qualified subconfractors will include assessment of technical and professional quaUfications, experience, proposed methodologies and cost. Where appropriate, HLA wall address a request for proposal to several qualified subconfractors tobbtairi the most experienced and cost-competitive subconfractor. i Subcontractors wdU be requfred to review and sign the HASP (Appendix B) and wdU be advised by HLA personnel in possible hazards associated wdth their particular tasks. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 41 . ,» 7.0 ANTICIPATED SCHEDULE The anticipated implementation schedule is presented as Figure 7-1. It has been prepared based on the number of weeks from receipt of USEPA approval of the work plan. The proposed schedule is based on the following assumptions: • Access agreements for locations of aU field activities wall be obtained at least one week prior to the intended start date for field activities • Inclement weather conditions wdU not delay any segment of field activities by more than one week • Access to work areas wiU be avaUable for a ininimum of ten consecutive hours per day The schedule also assumes that site conditions encountered in the field wall not vary greatiy from those emticipated. If site conditions do differ greatiy, additional time may be needed to amend the work plan. If this is the case, the work plan schedule wiU have to be modified accordingly. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 2 3 0 0 9 8 3 8.0 ACRONYMS AND ABBREVIATIONS ARARs" Applicable or Relevant and Appropriate Requirements AST Above-ground Storage Tank BTEX Benzene, toluene, ethylbenzene and xylenes , CDS Caribbean Drilling Services. CERCLA Comprehensive Environmental Response, Compensation and LiabiUty Act CFR Code of Federal Regulations CLP Confract Laboratory Program CWM Chem-Waste Management; Inc. , , - DPNR St. Croix IDepartment of Planning and Natural Resources DPW St. Croix Departinent of Public Works ESI Envfro-Science, Inc. s , FID Flame-Ionization Detector FOIA Freedom of Information Act SAP Sampling and Analysis Plan gpm Gallons per minute ; gpm/ft Gallons per minute per foot (Specific Capacity) GOVI Govemirient of the Vfrgin Islands HASP Healtii and Safety Plan HLA ' . Harding Lawson Associates HRS Hazard Ranking System HSWA Hazardous and Solid iWaste Amendments of 1984 ICC Island Chemical Company , ICMI Indusfrial Corrosion Management Inc. MCL Maximum Contaminant Levels ^ MDL • Method detection liriiit mg/L MiUigrams per Uter . MSL Mean Sea Level ' • ' . • • - NCP National OU and Hazardous Substances PoUution Contingency Plan NPL National Priorities List NUS - Halliburton NUS Corporation NWI National Wetiands Inventory OSWER Office of SoUd Waste Emergency Response ^ PCB \ Polychlorinated biphenyls PID Photo-ionization detector POTW Publicly owned treatment works ppm Parts per million QAPjP QuaUty Assurance Project Plan QG Quinidine gluconate , QS Quinine sulfate i - RCRA. Resource Conservation and Recovery Act RIWP Remedial Investigation Work Plan SCS Soil Conservation Suiyey SVO Semi-volatUe organic compound , i SWDA SoUd Waste Disposal Act . TAL Target Analyte List '; . - TBC : To-Be-Considered \WORK\24231\02\W,ORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 43 300984 TCL Target Compound List TDS Total dissolved solids USDA United States Department of Agriculture USEPA Uruted States Environmental Protection Agency USGS United States Geological Survey VICHEM Virgin Islands Chemical Company VIPA Virgin Islands Port Authority VOC VolatUe organic compovmd m \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 4 3 0 0 9 8 5 9.0 REFERENCES " Caribbean Drilling Services Incorporated. 1979. Suhsurface Investigation - Proposed Cooper Laboratories Plant Expansion, Estate BethIehem,.St. Croix, May 12. ) • . • ' Caribbean Drilling Services IncorjDbrated. 1980. Subsurface Investigation. Proposed Firewater Tank, Cooper Laboratories Plant, FYederiksted, St. Croix, August 19. . ' Cedersfrom, D.J. 1941. Notes on the Physiography of St. Croix, Virgin Islands. American Journal of Science, V. 239, No. fl> August. Cederstrom, D.J. 1950. Geology arid Ground-Water Resources of St. Croix, Virgin Islands. U.S. Geological Survey Water: Supply Paper 1067. ' . il ' ' ' • • . ' ' • ' ' CDM Federal Programs. 1987. Island Chemical Company, Technical Document Reiiew, August 5. ' Colon-Ramos, H.M. 1983. Ground-Water records for St. Croix, U.S. Virgin Islands, American Journal of Science, V. 239, p. 533-576 Comprehensive Environmental Response, Compensation and LiabUity Act of 1980 (CERCLA): Public Law 96-510, 42 jUSC 9601 et.seq. , Diax, P.L., Aquino, Z., Figueroa-Alamo, C, Vachier, R.J., and A.V. Sanchez. 1993. Water resources data, Puerto Rico and the U.S. Virgin Islands, water year 1992. U.S.G.S. Water Data Report PR-92-1. . ~ Envfro-Science, Inc. 1984a. Progress Report for Island Chemical CompanylChemiccd Contamination, October 1. Erivfro-Science, Inc. 1984b. Progress Report, Island Chemical Company, Inc. (Berlex), St. Croix, Virgin Islands, DecemheiT. Enviro-Science, Inc. 1985a. Addendum to Progress Report, Island Chemical Comipany. Inc. (Berlex). St. Croix, Virgin Islands, April 4. Enviro-Science, Inc. 1985b. Report Conceming Small Quantity Generator Status of Island Chemical, May 7. » Enviro-Science, Inc. 1986. Project Summary for Island Chemical Company, Inc. (Berlex). St. Croix, Virgin Islands, April 17. j Enviro-Science, Inc. 1987a. Attachment, Site Description for Island Chemical Company, St. Croix, U.S. Virgin Islands, A'pvil B.' Enviro-Science, Inc. 1987b. Remedial Investigation Work Plan for Island Chemical Company, St. CroixyUSVI. April 9. ' \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 5 3 0 0 9 8 6 Envfro-Science, Inc. 1987c. Remedial Investigation Work Plan for Island Chemical Company, St. Croix, USVI, AprU 16. Enviro-Science, Inc. 1987a. Attachment. Site Description for Island Chemical Company. St. Croix, U.S. Virgin Islands, April 16. Forman, R.T.T., 1974. An Introduction to the Ecosystems and Plants on St. Croix, U.S. Vfrgin Islands. In Guidebook to the Geology and Ecology of Some Marine and Terrestrial Environments, St. Croix, U.S. Virgin Islands. Special Publication No. 5. West Indies Laboratory, Farleigh Dickinson University. Garcia, R. and M. Canoy, 1984. Reconnaissance of Ground-water QuaUty in the U.S. Vfrgin Islands, July 1984, U.S.G.S. Water-resources Division, Open-file Data Report 84-807. Geraghty & MiUer, Inc. 1983. Report on Current Groundwater Conditions in the U.S. Virgin Islands, April 29. GiU, LP., 1989. The Evolution of Tertiary St Croix. Ph.D. dissertation, Louisiana State University and Agricultural and Mechanical CoUege. GiU, LP. emd D.K. Hubbard, 1986. Subsurface geology of the St. Croix carbonate rock system. Water Resources Research Center, College of the Vfrgin Islands, Capsule Report No. 8. Haire, W.J. and K.G. Johnson, 1978. Floods of November 11-13, 1974, in St. Crobc, U.S. Vfrgin Islands. U.S.G.S. Water Resources Investigations 77-136 Open-fUe Report. Johnson, K.G., R.A. CarrasquiUo, and R. Gonzalez, 1982. Flood of October 8, 1977 in St. Croix, U.S. Vfrgin Islands. U.S.G.S. Water-Resources Investigations 82-262 Open-file Report. Lidz, B.H. 1988. Upper Cretaceous (Campanian) and Cenozoic Stratigraphic Sequence, northeast Caribbean (St. Croix, U.S. Virgin Islands). Geological Society of America Bulletin. v. 100, p. 282-298. Febmary. Multer, H.G. and L.C. Gerhard ed. 1974. Guidebook to the Geology and Ecology of Some Marine and Terrestrial Environments, St. Croix, U.S. Virgin Islands. Special Publication No. 5. West Indies Laboratory, Farleigh Dickinson University. NUS Corporation, a Halliburton Company. 1991. Final Draft Site Inspection Report, Island Chemical Companyp/I Chemical, St. Croix, U.S. Virgin Islands. September 11. Ogden, J.C. 1974. The Major Marine Environments of St. Croix, U.S. Virgin Islands. In Guidebook to the Geology and Ecology of Some Marine and Terrestrial Environments, St. Croix, U.S. Virgin Islands. Special Publication No. 5. West Indies Laboratory, Farleigh Dickinson University. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 6 300987 Rivera, L.H., Frederick, W.D., Farris, C, Jensen, E.H.,. Davis, L., Palmer, C.D., Jackson, L.F., and W.E. McKinzie, 1970. Soil Suijvey of the Virgin Islands of the Umted States. U.S.D.A, SoU Conservation Service, 1970. , , • ; Robinson, T.M., 1972. Ground-water in central St. Croix, U.S. Virgin Islands. U.S.G.S. Open-File Report, Caribbean District. Speed, R.C, L.C. Gerhard, and E.H. McKee. 1979. Ages of Deposition, Deformation, and Intrusion of Cretaceous Rocks, Eastern St. Croix, Vfrgin Islands. Geological Society of America Bulletin, Part I, V. 90. p. 629-632, ]uly. " Superfund Amendments and Reauthorization Act of 1986: PubUc Law 99-499. Torris-Gonzalez, S. and F. Rodriguez delRio, 19i9b. Potentiometric surface of the KinshiU aquifer and hydrologic conditions, St. Croix, U.S. Vfrgiri Islands, U.S.G.S. Water-resources Investigations Report 89-4085. JulyJ Torres-Gonzalez, S., 1987. Steady-State SiriaiUation of Ground-Water Flow Conditions in the KingshiU Aquifer, St. Croix, U.S. Vfrgin Islands, July 1987. American Water Resources Association, Monograph Series No. 15. . ; Torres-Sierra, U., 1987. Estimated water use in St. Croix, U.S. Vfrgin Islands, October 1983- Septemiier 1985. U.S.G.S. Open-FUe Data Report 86-537. U.S. Department of Agriculture, SoU Conservation Service, 1970. Soil Survey, Virgin Islands of the U n i t e d States, A u g u s t . . • • ' • - ' ' • - U.S. Envfronmental Protection Agency, 1983, Interiin Guidelines and Specifications for Preparing Quality Assurance Project Plcms: QAMS-OOSlSO; Office of Monitoring Systems and Quality Assurance, ORD, Washington, D.C, Fehruary. U.S. Envfronmerital Protectiori Agency, 1984, Guidelines Establishing Test Procedures for the Analysis-Final-Rule and Proposed liule, 40 CFR Part'136i October. U.S. Environmental Protection Agency. 1985. RCRA Enforcement. Berlex Laboratories, (a subsidiary of Island Chemical Co., Inc.), St. Croix, Virgin islands, VID980651095, September 9. [sic-ICC was a subsidiary of Berlex]. ' U.S. Environmental Protection Agency, 1986a Draft Supplement to Interim Guidelines and Specifications for Preparing Quality/issurance Project Plans: QAMS-OOSldO, Office ofMonitpr- ing Systems arid Quality Assurance, ORD, Washington, D.C, December; U.S. Envfronmental Protection Agency, 1986b, UsePs Guide to the.Contract Laboratory Program: Office of Emergency and Remedial Response, Sample Management Office, December. - U.S. Environmental Protection Agency, 1985c, National Enforcement Investigations Center Policies and Procedures Manual, EPA\-330-9-76-001-R. ' \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33,pm HARDING LAWSON ASSOCIATES 4 7 • 3 0 0 9 8 8 U.S. Envfronmental Protection Agency, 1986d, Test Methods for Evaluating Solid Waste: Office of Solid Waste and Emergency Response (OSWER) Directive SW-846, Vol. IB. U.S. Environmental Protection Agency. 1987a. Draft Administrative Order On Consent, Island Chemical Company, Inc., Berlex Laboratories, Inc., Respondents, March. U.S. Environmental Protection Agency, 1987b, A Compendium of Superfund Field Operations Methods, OSWER Directive 9355-0-14, December. U.S. Envfronmental Protection Agency, 1987c, Data Quality Objectives for Remedial Response Activities (development process): USEPAl540lC^87l003. Office of Emergency and Remedial Response, Washington, D.C, March. U.S. Envfronmental Protection Agency, 1987d, CERCLA Off-Site Policy, U.S. Environmental Protection Agency, 1988a, Laboratory Data Validation - Functional Guidelines for Evaluating Organics Analyses: TDD Doc. No. HQ-8401-01, Hazardous Site Evaluation Division, February. U.S. Envfronmental Protection Agency, 1988b, Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, Atmospheric Research and Exposure Assessment Laboratory, June. i U.S. Envfronmental Protection Agency, 1988c, Laboratory Data Validation - Functional Guidelines for Evaluating Inorganics Analyses,. Hazardous Site Evaluation Division, July. U.S. Envfronmental Protection Agency, 1988d, Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final, EPAj540l6-89l004, October. U.S. Envfronmental Protection Agency, 1989a, Preliminary Assessment, Removal Evaluation and Funding Authorization Request for a CERCLA Removal Action at the Virgin Island Chemical Company, Inc., Site, St. Croix, U.S.Virgin Islands - ACTION MEMORANDUM, August 8. U.S. Environmental Protection Agency, 1989b, Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual, Part A, Interim Final, Office of Emergency emd Remedial Response, December. U.S. Environmental Protection Agency, 1989c, Region II CERCLA Quality Assurance Manual, Revision I. U.S. Environmental Protection Agency, 1990a, Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Toxicity Characteristics Revisions; Final Rule, 40 CFR Part 261, Thursday, March 29. U.S. Environmental Protection Agency, 1990b, Contract Laboratory Program Statement of Work for Inorganic Analysis, ILMOl.O, March. \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 4 8 300989 , U.S.'Environmental Protection Agency, 1990c, Contract Laboratory Program Statement of Work for Organic Analysis -Multi-Media Multi-Concentration, OLMOl.O, April. U.S. Environmental Protection Agency, Region IU, 1990d, Fje7d Filtration Policy for Monitoring Well Groundwater Samples Requiring Metals Analysis, Bulletin No. QAD009, AprU • ^ 2 3 . • • • . ; • [ ' : , •: V - , ' , • " • • " ' • • . ' ^ , '• U.S. Environmental Protection Agency. 1990e. Cornments on Work Plan, October 19. U.S. Envfronmental Protection Agericy. i991a. Final PoUution Report, USEPA Region II Response and Prevention Bremch, October 25. . ^ -U.S. Environmental Protectiori Agericy, 1991b, Model Quality Assurance Project Plan: Office of Superfund, Region V, May. ' • ' . ^ ' ' ' I ' ' • - ' ' • . ' ' ' U.S. Envfronmental Protection Agency, 1991c, Contract Laboratory Pro-am Statement of Work for Low Concentration OrganiciAnalysis, June. U.S. Envfronmental Protection Agericy, 1992a, Region II SOP HW-6, CLP Organic Data Review and Preliminary Review, Revision 8, Januiary. U.S. Erivfronmental Protection Agency, 1992b,'i?eg70/7 II SOP #W-2 Evaluation of Metals Data for the CLP Revision]!, January. , , U.S. Envfronmental Protection Agency, 1992c, Guide to Management of Investigation-Derived Wastes, Quick Reference Fact Sheet, 1992c. ^ U.S. Envfronmental Protection Agencyi 1993, Admiiiistration Order on Consent for Remedial Investigation/Feasibility Study, Docket No. in-93-21-DC, July. Whetten, J.T., 1966. Geology of St. Croix, U.S. Virgin Islands: Geological Society of America Memoir 98. s • /^ ^ \WORK\24231\02\WORKPLAN.REP 03/17/94 02:33 pm HARDING LAWSON ASSOCIATES 49 3 0 0 9 9 0 m Number of Copies 7 Copies (1 unbound) 1 Copy 1 Copy 3 Copies Remedial Investigation Work Plan Island Chemical Company, Inc. St. Croix, U.S. Virgin Islands DISTRIBUTION COPY A United States Enviromnental Protection Agency Chief, Eastern New York/Caribbean Superfund Section II Emergency and Remedial Response Division United States Environmental Protection Agency 26 Federal Plaza, Room 747 New York, New York 10278 Attention: Virgin Island Chemical Site Project Coordinator Chief, New York/Caribbean Superfund Branch Office of Regional Counsel United States Environmental Protection Agency 26 Federal Plaza, Room 437 New York, New York 10278 Attention: Virgin Island Chemical Site Attorney Govemment of the Virgin Islands of the United States Department of Planning and Natural Resources Division of Environmental Protection Charlotte AmaUe St. Thomas, U.S. Virgin Island 00802 Attention: Virgin Island Chemical Site Project Manager Sills, Cummis, Zuckerman, Radin, Tischman, Epstein & Gross One Riverfront Plaza Newark, New Jersey 07102-5400 Copy Copy 1 Copy 2 Copy 3 Copy 4 Copy 5 Copy 6 Copy 7 (imboimd) Copy 8 Copy 9 2 Copies Quality Assurance/Quality Control Harding Lawson Associates Philadelphia, Pennsylvania Copy 10 Copy 11 Copy 12 Copy 13 Copy 14 Bharat Patel R.G., C.P.G. Associate Hydrogeologist This document was prepared for the sole use of the ICC and the regulatory agencies involved viath the project, the only intended beneficiaries of our work. No other parties should rely on the information contained herein without the prior written consent of HLA. No other parties should rely on the information contained herein without the prior written consent of HLA. \WORK\24231\02WORKPLAN.REP HARDING LAWSON ASSOCIATES 300991 Tables \WORK\2423l\02\WORKPLAN.REP HARDING LAWSON ASSOCIATES 300992 Table 2 - 1 . Wells Within One Mile of Site Island Chemical Company St. Croix, U.S. Virgin Islands Well Identification Reporied Use Distance from Site (feel) Direction from Site Reported Depth (feet) Rep)orted Static Water depth (feet)* Reported Water Elevation (feet above MSL)» Reported Yield (gpm) Year Installed Ui o o vo to Ui Virgin Islands Port Authority No. 1 Virgin Islands Port Authority No. 2 Fairplain 9 Fairplain 8 Fairplain 7 Fairplain 6 Fairplain 2 Old Golden Grove Fairplain 4 Fairplain 3 Fairplain 5 Fairplain 1 Golden Grove PWS Boring near Anguila Riggers and Erectors Golden Grove PW6 Negro Bay 9 Golden Grove PW9 See last page for notes Not Available Not Available Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply Test Hole Commercial? Public Water Supply Public Water Supply Public Water Supply NA NA W W 500 1.000 1.200 1.300 1,300 1.300 1,400 1,500 1,600 1,800 2,500 2,900 3,000 3,200 3,300 \ 3,300 SSE SE SE SSE SSE W SSE SE SE SE W E SE WNW WSW W NA NA 62 , 56 57 105 79 NA 100 97 96 100 NA NA NA NA 140 NA NA NA 62 56 57 18.1 23.3 NA 19.7 13.5 18.6 20.9 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA 6 NA 3 3 6 NA -4 NA NA NA NA 21 37.9 15;7 30 NA NA 21 NA 10.4 NA < 2 NA NA < 2 54-62 < 2 NA NA NA NA NA NA NA NA NA NA 1972/1973 NA NA 1972/1973 1979 1972/1973 \WORK\24231\02\WELLINFO.TAB HARDINQ LAWSON ASSOCIATES Table 2'1. Wells Within One Mile of Site Island Chemical Company St. Crobt, U.S. Virgin Islands Well Identification Reported Use Distance from Site (feel) Direction from Site Reported Depth (feet) Reported Static Water depth (feet)\ Reported Water Elevation (feet above MSL)' Reported Yield (spm) Year Installed Negro Bay 5 Golden Grove PW7 Negro Bay. 8 Golden Grove PWS Golden Grove PWt |>Iegro_Bay7. . „ Golden Grove PW4 Negjpq Bay 4 Negro Bay 3 Negro Bay 6 Golden Grove PW2 Goldeii Grove PW3 College of Virgin Islands Near Profit Airport Public Water Supply Public Water Supply Public Water Supply Public Water Supply Public Water Supply .^Public Water Supply „ Public Water Supply . Public Water Supply Public Water Supply Public Water Supply Unused Public Water Supply Domestic Unused Well , ^ Unused Well - 3.400 3,400 3.500 3,600 3,600 3.700 -.^ 3,700 3,700 4i000 . 4;ooo 4^100 4^400 4,600 4.'900 s.boo WSW w WSW w WNW -WSW WNW WSW WSW WSW w w NNE NE SE ~ 95 NA , 120 NA . NA 1 2 0 - — - iio 95 95 120 . NA NA 95? NA NA y _ .„., NA NA . NA NA NA NA . NA NA - NA NA NA NA NA NA NA NA NA NA 41 NA NA- NA NA 2 NA 25 NA 55 24 5 NA . • ' . . < 2 - 54-62 < 2 NA -"'54:62 NA NA NA 54-62 60 2 NA NA • NA 1973 1972/1973 1978 1972/1973 1972/1973 1978 ~ 1972/1973 1973 ,1973 1978. 1972/1973 1972/1973 . NA • - NA NA 1 Reported depth, cx)nstn]clion or sounding 1982 2 - Static water depth (Geraghty & Miller) . 3 Static water level elevation (Torres-Gonzales) NA Not available ' . Source: Adapted from Geraghty & Miller, 1983; Torres-Gonzales, 1990. t\WORK\24231\02\WELLINFO.TAB HARDINQ LAWSON ASSOCIATES Table 2-2. Summary of Events Island Chemical Company St. Croix, U.S. Virgin Islands Date Events May 1. 1969 March 20, 1972 June 30, 1978 November 1, 1979 1980 through 1982 November 27, 1892 through February 1, 1983 May 17, 1983 September 14, 1984 09/17/84 through 10/28/84 June 5, through August 7,1985 June 14, through July 19, 1985 September 9,1985 December 5, 1985 February 19, 1986 March 12, 1986 March 13, 1986 June 2,1986 through March 10,1987 January 31, 1989 March 30,1989 through April 30, 1991 September 17, through 19, 1989 February 28, 1991 December 11, 1991 Steffey leased site to Houston Chemicals Houston assigned the lease to Caribe Chemicals, subsequently known as Pierrel Pierrel assigned the lease to Cooper Laboratories. ICC was incorporated July 21, 1978 and the lease was assigned to ICC by Cooper in 1979 Cooper sold its stock in ICC to Berlex Berlex uses the facility in attempt to perfect a quinidine process. By the end of 1982 the plant was permanently dosed. ICC removes 26,748 gallons of toluene and 6,946 gallons of xylenes for disposal at Inland Chemical, Puerto Rioo. Approximately 15,000 gallons of a vtrater solution was removed from the d s t e m and disposed locally. GOVI ins[)ection indicated no hazardous waste on site ICC sold its assets to Virgin Island Chemical Co. (VICHEM) ESi investigates, soil conditions in the Loading Dock Area and AST Farm ESI investigates soil conditions in Drain Lines and Lab Pit area. Toluene affected soils are excavated and placed on trays in the dryer building for thermal treatment. Results of treatment are documented through periodic sampling. ESI collects sludge and liqtiid samples from Lab Pit and Process Pit. Samples submitted to ICMI for various analyses USEPA collects samples from Diyer and Lab Pit for. PPL analysis ICC disposes of 192 drums of waste at Chemical Waste Management in Emelle, Alabama ESI collects samples from River Gut. Analyzed for nietals, cjranide, phenols and VOCs. A few metals were detected ESI collects Uquid samples from nine ASTs for characterization by ICMI USEPA collects three additional samples from Cut, two from lab pit and one from northern onsite well. ESI obtains splits. ESI prepares waste profiles for 67 drums. Final disposition of these drums is unclear. USEIPA performs a Preliminary Assessment. At this time, the site was occupied by St. Croix Security Kennels and VIAG fuels. Inc. USEPA plans and performs waste removal activities. Final disposal of hazardous materials reportedly completed by 10/24/91 Hurricane Hugo strikes NUS collects groundwater, soil and sediment samples as part of the PreUminary Assessment/Site Investigation Draft PA/SI report Usued by NUS \WORK\2423lV)2\CHRONLGY.TAB HARDING LAWSON ASSOCIATES 300995 Table 2-3. Summary of ICC Disposal Activities Island Chemical Company St. Croix, U.S. Virgin Islands Date Manifest Waste Description (from manifests) Source Method Disposal Site 11/27/82 11/30/82 12/14/82 01/07/83 "02/6T/83~^ ICOl IC02 IC03, IC04 icds, IC06 " IC07r IC08 3,175 gal. Toluene 5,205 gal. Toluene 9,913 gal. Toluene 8,455 gal Toluene '" 6,946 gal Xylenes ~ " -" ASTs ASTs ASTs ASTs ! • i Bulk tanker - . Bulk tanker Bulk tanker Bulk tanker BiJk tanker Inland Chemical, Puerto Rico Inland Chemical, Puerto Rico Inland Chemical, Puerto Rico Inland Cherhical, Puerto Rico ! • i . Inland Chemical, Puerto Rico 1982/1983 NA , 15,000 gal aqueous/basic soliitlon Cistern Bulk tanker Disposed locally by Cruzan Environmental Services' ! i • NA Metal, plastic drums and ashes from ICC Cleanup burning of fiber drums, pallets and soil Unknown East Anguila Sanitary Landfill* 12/02/85 10/24/91 243031, 243032, 243033 USEPA Pollution Report 94 drums toluene/benzene 35 drums toluene/chlorobenzene 34 drums toluene/chloroform 15 drums toluene/acetone ." 14 drums containing drum pieces Various waste strearhs Process pit water and Driims sludge; soil and drums from waste water drain ' ' ' - line removal; toluene containing water and soil USEPA Removal Action Various' Chemical Waste Management, Inc., Emelle, Alabama Various' o o to \D cr. Notes: ' , * Information based on ICC in-house memorandum dated February 7, 1983. 2 Hy October 24. 1991. USEPA reported thai all waste had been shipped offsite. See USEPA Pollution Report No. 30 (Appendbc M). \WORK\24231\02\D1SPOSAL.TAB HARDINQ LAWSON ASSOCIATES Table 2>4. Summary of Substances Reported Island Chemical Company St. Croix, U.S. Virgin Islands Substance Reported ICC Contractors Laboratory Analyses Inventory OHM Inventory USEPA Contractors Lab Reagent List Drum Inventory Laboratory Analyses Acetic Add Acetic anhydride Acetone X X X Acetonitrile Acetylene Activated carbon X X Aldrin Alkalinity CJ),E,G All-weather patch material Aluminum Alumintun chloride Amersite 2 Corrosive Inhibitor Ammonia Uquid Ammonium acetate Anunonium Hydroxide X X Ammonium hydroxide Ammonium persulfate Ammonium thioc)ranate X X X Amyl alcohol Antifreeze Antimony Aromatic Solvents Arsenic Arsenic trioxide Ashland MeOH Barium Barium chloride Barium hydroxide See last piage for notes \WORK\24231\D2\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 300997 Benzaldehyde Benzene Benzene methanol Table 2-4. Summary of Substances Reported {! Island Chemical Company ' S L Croix, U.S. Virgin Islands Substance Reported ICC Contractors . Laboratory Analyses Inventory OHM Inventory USEPA Contractors U b Reagent List Drum Inventory Laboratory. Analyses X X X X X Benzhydrol Benzoic add Benzoin X X X -Benzophenone Benzoquinone Benzoyl chloride' X X Benzyl acetate, Benzyl alcohol Benzyl benzoate X X X Benzyl chloride Benzyl dnnamate Benzyl ether X X X Benzyl phenone Benzyltriethylammoniumchloride . Y B H C A BHC , Bis(2-ethyl hexyl)phlhate Bismuth subnitrate X X X Boiler Treatment Bromine Bromophenol blue. X X Brucine sulfate Buffer solution pH 4.00 Buffer solution pH 7.00 . X X X Buffer solution pH 10.00 See last page for notes •\WORK\24231\02\SUBSTNCS.TAB, HARDING LAWSON ASSOCIATES 300998 Table 2-4. Summary of Substances Reported bland Cbemical Company SL Croix, U.S. Vii^gin Islands Substance Reported ICC Contractors Laboratory Analyses Inventory OHM Inventory USEPA Contractors Ub Reagent List Drum Inventory Uboratory Analyses Butanol 1-Butanol 2-Butanone (see methyl ethyl ketone) 2-Butoxy ethanol Bufyl benzyl phthate Butyl chloride Butylated hydroxy toluene fj"^'"'um Caldum Caldum Hypochloride Caldum sulfate CAO-3 BHT X X Carbon Black Carbon tetrachloride Castor Wax Caustic Add Cello-Seal Charcoal a Chlordane Y Chlordane Chloride-F X X Chlorine Chlorobenzene 1-Chlorobutane Chloitxiiphenyl methane Chloroform Chloromethylbenzene X X X X l-Chloro-2-methyl benzene See last page for notes \WORK\24231\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 300999 Table 2-4. | Summary of Substances Reported Island Chemical Company St. Croix, U.S. Virgin Islands . ^ " ' . • Substance Rfeported ICC Contractors Uboratory lAnalyses Inventory OHM Inventory USEPA Contractors Ub Reagent List Drum Inventory Uboratory Analyses 4-Clilorobenzene sulfonamide Chromium Chromotropic add NA salt Cinchona Bark Cleen and Shine Multi Surface Cleaner Cobalt Cobalt chloride Color Standard 4 Congo Red X X X Contaminated Clothing Contaminated trash and wood Copper X X X \ Crofox - - Crystal Clear floor finish Cupric sulfate X X C)ranides 2-Cyclopyridine DDE 4,4-DDT Degreaser 20% Dibah in toluene Dibenzoyl tartaric add Dibenzo-18-CrowTi-6 1,1-Dichloroethane X X X 1,2-Dichloroethane trans-l,2-Dichloroe thene Dichlorophenyl methane X X X X Dichlorotoluene See last page for notes \WORK\24231\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301000 Table 2>4. Summary of Substances Reported Island Chemical Company SL Crobc, VS. Virgin Islands Substance Reporied ICC Contractors Uboratory Analyses Inventory OHM Inventory USEPA Contractors Ub Reagent List Drum Inventory Uboratory Analyses Dieldrin Diethylamine Diethylene glycol Diethylene Glycx>l Monomethyl Ether Floor finish (Sunnyside) Diisobutyl aluminum hydride 2,6-Dimethoxybenzoic add X X 1,3-Dinitrobenzene Di-n-butyl phthalate Di-n-oc:tyl phthalate X X Diphenyl methanone (see benzophenone) Diphenylmethane Diphenylthiocarbazone X X 2,6-DitertiarybutyL p-cacsol DPD #1,2,3 ReagenU Drewtrol 8500 Boiler water sludge and scale preventative X X Endosulfan I Endosulfan II Endosulfan Sulfate X X X Endrin Ketone Eosin Y EthanedioL 1>2- Ether anhydrous Ethoxyguin Ethyl Acxtate X X X Ethyl Alcohol Ethyl ether Ethylbenzene X X Ethylene glycol See last page for notes \WORK\24231\D2\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301001 Table 2-4. Summary of Substances Reported Island Chemical Company . SL Crobc, U.S. Virgin Islands' Substance Reported ' ICC Contractors Uboratory Analyses . Inventory • OHM Inventory USEPA Contractors Ub Reagent List Drum . Inventory Uboratory Analyses Ethylene Glycol Base Antifreeze Ferric ammonium sulfate Ferric chloride Ferrous ammonium sulfate Filteraid X X •Fluoranthene " Fluorene 9H7Fluorene-9-one X X Fluorenone Formic a d d . Clacdal Acetic A d d X \ Gluconofin Glucxiiio-delta-Udone Glycol • X X X Heptachlor Heptachlor epoxide Heropa 320 Texacx) Humisorb ' . X X Hydrazine sulfate Hydrochloric Add Hydrogen aminosulfate X X Hydrogen aminosulfonate Hydrogen tiJoride -^ 4-Hydroxybenzoic a d d 2-Hy(iroxybenzyl alcx>hol 9-Hydrox)rf]uorene Hydroxyfuraiicouinarin X X Hydrpxylainine hydrochloride; See last page for notes , \WORK\24231\02VSUBSTNdS.TAB HARDING LAWSON ASSOCIATES 301002 Table 2-4. Summary of Substances Reported Island Chemical Company St. Croix, U.S. Virgin Islands Substance Reported ICC Contractors Uboratory Analyses Inventory OHM Inventory USEPA Contractors U b Reagent List Drum Inventory Uboratory Analyses Hydroxy-4-methyl-2-pentanone, 4- Insulation, (asbestos?) Insulation (fiberglass) Iodine Iron Iron c:hloride Isoamyl alcx>hol Isobutyl aloohol X X X Isopropanol Karl Fisher Reagent (pyridine) Kenite 700 X X X Uporte Molecnilar Sieve Lead Lead acetate Lead nitrate Lithium perchlorate Lubric^ating oil X X Magnesium Magnesium sulfate Magnesium sulfate trihydrate Manganese Medical oxygen Mercuric chloride Mercuric oxide X X X Mercury Mesityl oxide Methanol X X Methoxychlor See last page for notes \WORK\24231\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301003 . # Table 2-4. fSummary of Substances Riaported ' Island Chemical Company , ji, St. Croix, U.S. Virgin Islands Substance Reported ICG Contractors Uboratory Analyses Inventory OHM- Inventory USEPA Contractors U b Reagent List Drum Inventory Uboratory Analyses Methyl alcxihol n-Methylaniline Methyl ethyl ketone (2-butanone) Methyl isobutyl carbinol Methyl isobutyl ketone : Methyl orange Methyl red Methyl tertiary butyl ether 2-methyl propanol 2-Methyl-l-heptene Mogul Water Treatment Molecular Sieve Monochlorobenzene Monoethanolamine Muriatic Add ' Naphthalene Na salt of ME salicylate Niacan N.F. Nickel Nitric add Nitrobenzene Non aqueous buffer solution Nutrizyme Oil #3 X X X I X 4-Melhylbenzophenone ' l,l-oxybis(Melhylene) bis-benzene • > X Methylene chloride , j X X, X X X X X X X X 2,2-Oxydielhanol See last page for notes \WORK\24231\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301004 Table 2-4. Summary of Substances Reported Island Chemical Company SL Crobc. U.S. Virgin Islands Substance Reported ICC Contractors Uboratory Analyses Inventory OHM Inventory USEPA Contractors Ub Reagent List Drum Inventory Uboratory Analyses Oxygen Pamt X X p-Chlorobenzene sulfonamide p-Naptholbenzein p-Phenetidine X X p-Toluenesulfoni(3nonohydrate Paraffin oil Parformaldehyde X X X Parformaldehyde prills Pentachlorophenol Pentosin Perchloric add pH indicator A Phenanthrene X X Phenol red Phenols Phenopthalein Phenyl acsetate Phenylhydrazine Phenylhydrazinehydrociiloride X X Phosporous pentoxide Piperazine Potassium X X X Potassium Acstate Potassium bromide Potassium butoxide Potassium cdiloride X X X Potassium cyanate See last page for notes \WORK\24231\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301005 # Potassium dichromate Potassium ferrocyanide Potassium hydroxide Potassiiun icxlide Potassium iodo platinate Potassium periodate Potassium platinate Potassium sulfate Potassium thiocyanate Powdered filter rnedia Propane. 1-Propanol Purafiin Pyrene Pyridine Quinact Quinidine Quinidine Base Quinidine Gluconate Quinidinone • Quinine Bisulfate Quinine Sulfate Resourcinol Table 2-4; Summary of Substances Reported ,! , Island Chemical (Company ' S t Cibbc.U5. Virgin Islands . • , r-' Substance Reported ! 'ICC Contractors 1 ' • . Uboratory • Analyses 'i • '' ' Inventory OHM Inventory USEPA Contractors U b Reagent List ' Drurn Inventory Uboratory Analyses X X X X X X X X X X X X X X X X X Results Crystal Clear Finish for Floors , Rinse Line'Injector Fluid ! ' Rout non foaming ceramic tile and grout condilioner X X X' X X Salicylaldehyde Salic:ylic add X X See last page for notes \WORk\2423l\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301006 Table 2-4. Summary of Substances Reported Island Chemical Company ' SL Croix, U.S. Virgin Islands Substance Reported ICC Contractors Uboratory Analyses Inventory OHM Inventory USEPA Contractors Ub Reagent List Drum Inventory Uboratory Analyses Salt Selenium SI 320 Total Water Treatment Sicapent Silica gel dessicant X X Silver Silver nitrate Soap? Soda Ash Sodium Sodium acxtate X X Scxlium amide Sodiimi benzoate Sodium bicarbonate X X X X Sodium borohydride Sodium carbonate Sodium c:hlorate X X X Scxlium chloride Sodium diduomate Sodiiun formate X X X Sodium hexa mela phosphate Sodium hydride Sodium hydroxide X X Sodium hypcxihlorite Sodium nitrite Sodium nitroferric:yanide X X Scxlium sulfate Sodium tartrate X X See last page for notes \WORK\2423lV)2\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301007 Sodium thiosulfate Table 2-4. Summary of Substances Reported Island Chemical Comp>any l! St. Gibix. V S . Virgin Islands Page l 2 o f 13 Substance Reported ICC Contractors 11 • 1 Uboratory , Analyses • Ir • •, • Inventory OHM , Inventory USEPA Contractors Ub Reagent List .Drum Inventory Uboratory • Analyses Sta-full repair matrix Sterling salt crystals Succinic anhydride Sulfamic a d d X X Sulfanilic a d d Sulfate A d d Sulfite 0,P,Q Sulfuric a d d Tartaric A d d Tetaric A d d Tetrachloroethene Telracdilorophenol Tetrahydrofuran X X Tetraphenolboron sudium Tetrasodium EDTA Thallium Thinner Thiopene Toluene, Total alkylinity indicator Tributyl borate 1,1,1-Trichloroethane Trichloroethene Triethanolamine Triethylamine X . X X Triethylenediamene ' Uranyl acetate X ' x See last page for notes \WOR102423l\02\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301008 Table 2-4. Summary of Substances Reported Island Chemical Company St. Croix, U.S. Virgin Islands Substance Reported ICC Contractors Uboratory Analyses Inventory OHM Inventory USEPA Contradors U b Reagent List Drum Inventory Uboratory Analyses Vanadium Variquat Waste oil Watei/Carbon Mix from flcxir cleaning Weedox C/R 250 heibidde Xylenes Tiinr Zinc chloride X X X X X X X ESI Inventory, OHM inventory, January 1990 USEPA Inventory \WORK\24231\D2\SUBSTNCS.TAB HARDING LAWSON ASSOCIATES 301009 Table 3-1. Areas of Potential Environmental Concern Island Chemical Company St. Croix, U.S. Virgin Islands Area Identification Location USEPA Identification Description D E F , Laboratory and Warehouse Building Above-Ground Storage Tank Farm Former Process Pit Loading Dock and Former Lab Pit Area Soil Beneath Concrete Pad Near ASTs Center of site 1 Northwest side of 2 Site East of Maintenance 3 Building . North of Laboratory 4 Northwest of ASTs 5 Concrete Storage Pad North of Laboratory 0 Location of drum storage during USEPA removal action. Former location of 20 ASTs, 10 tanks remain onsite. ESI identified and excavated area of soil between ASTs 8 and 9 nffocted by historical reloasos , . , • ^ • ' • • . " - ; i Former location of underground concrete storage tank used to i collect process waste water. Tank was reportedly empt^ied, [ , cleaned and filled with concrete by ESI in 1986?. Conflicting i information is available regarding the size of the tank {8,000 or 17,d60 gallons) " , Cobble-filled pit located beneath loading dock formerly received waste liquids from laboratory drains. Pit was connected to a '• second pit located near the property boundary by a 4-inch PVC] pipe. . i ' ' . . • • ' • • • • • " ! ESI identified and excavated one area of soil affected by historical releases. Used for storage of various materials. LO O M O O \WORK\24231\02\AOC.TAB HARDING LAWSON ASSOCIATES Table 3-2. Summary of Environmental Sampling Area B - Above-Ground Storage Tank Farm Island Chemical Company St. Crobc. U.S. Virgin Islands Sample Name T8-1 T8-2 Tanlc-8 Tank-4 Tank-9 Tank-7 #4 Sample # 4 High Cone S4-1 Tank 4 Tank 7 Tanks Tank 9 Tank 10 Tank 11 Tank 12 Tank 13 Tank 14 Sample Date ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 10/15/84 03/12/86 03/12/86 03/12/86 03/12/86 03/12/86 03/12/86 03/12/86 03/12/86 03/12/86 Matrix SoU Soil Soil SoU SoU SoU SoU SoU SoU Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid Liquid CoUect by/ Analyzed by ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESl/lCMl ESI/ICMI ESI/ICMI ESl/ICMl Uboratory Sample No. - - - - - - - - 53581 53582 53583 53584 58535 53586 53587 53588 53589 Parameters Arulyzed Toluene; pyridine; QG:QS Tnlllprip; pyrirlino; QG;QS Toluene; pyridine; QG;QS QG;QS QG;QS QG;QS QG;QS QG;QS Toluene; pyridine Benzcxiuinone; fluorenone Benzophenone; fluroenone VOCs: benzophenone; fluorenone VOCs; p- Phenetidine Hydroxyfurano- cx>tmiarin Hydroxyfurano- cornnaiiD Hydroxyfurano- coumarin; p- phenetidine p-Phenelidine VOCs; benrophenone; fluroenone Substances Detected' Toluene{694); QG(274); QS{101) QG(47) toluene{13.880); QG(4.050); QS(1,521) QG(8.227); QS(2,594) QS(354) None detected None detected None detec:ted None detecrted Ben2oquinone(30%); fluorenone(70%) Benzophenone(39.6%); fluorenone(43.8%); unknown alkane{lB.6%). Benzophenone(85.79<>); fluorenone{14.3%); toluene(8) Aoetone(4.2); ethylbenzene(0.15); p-PhenetJdine(69.1%); toluene(0.05); xylenes(14.1); unknown aroinatic(10.9%) HyciTOxyfuranoc»umarin(87.6%) Hydroxjfurancx30umarin(82.4%) Hydrox}'furanocx)umarin(50.7%); p-phenetidine(4B.3%) p-Pheneticiine(100%) Chloroform{0.008^); methylene chloride(O.Oll^); benzophEnone(64.8%); fluorenone(35.2%); loluene(0.0067^) \WORK\24231\02\PREVSMPB HARDING LAWSON ASSOCIATES 301011 Table 3-2j Summary of Environmental Sampling • AieaB - Above-Groimd Storage Tank Farm ' Island Chemical Company ' S L Croix, U.S. Virgin Islands Sample : • Naine T8-1 VI25-S2 „ Sample Date ca. 09/17/84 02/28/91 Matrix SoU Colled by/ Analyzed by ESI/Berlex ' !' • ' ' " EPX/Compu- Cliem Uboratory ; Sample No. BGL ,. Parameters Analyzed .Toluene; pyridine; QG; QS VOCs; AECs; B/Ns; Pest; PCBs; metals. Substances Detected^ Toluene{694); QG{274); QS(lOl) Heptachlor epoxide(Jl; DieldrinQ); y-Chlc3rdaneg); Al(21,700); As(7.65); Ba(136); 08(23,300); V125-S3 02/28/91 EPA/Compu- BGL Chem ; VOCs; AECs; B ^ s ; Pest; PCBs; metals Cr<27.9j); Co(21.1); Cu(99.8); Fe(44.100); Pb{35.3); Mg(7,800); Mn(1.050); Ni(18.8]); K(2,990); NaO); V{97.2); 21n(387j) Aldrin(30j); Heptachlor epoxide(lOj); DieldrinQ); 4-4'- DDE(5.8J); Endrin(J); Endosulfan sulfated); 4-4'-DDT(J); Endrin Ketone0); gainna-Chlordane(7.Sj); Al(21,000); SBg); As(9.1j); Ba(196); Ca(43,100); Cr(49j); Co(22.3); Co(73.7);'Fe(81,700); Pb(322); Mg(7,420); Mn(987); Ni(33.Sj); K(2,920); NaQ); V{63.5); Zn(362j) Notes: B ] • I T B/N AECs PCBs Pest. VOCs Reported concentrations in parentheses, presented in parts per million (ppm). See Table 3-9 for list of chemical •^abbreviations Uboratory reported fluorethyne "jxissibly from plastic bag" Compound detected in blank sample Estimated concentration . ! Tentatively identified compound Base/neutral extractable compounds Acnd extractable comf>ounds j ' , PolycJilorinated biphenyls I' PesUcrides / , ' • , VolatUe organic compounds . . - \WORK\24231\02\PREVSMPB HARDING LAWSON ASSOCIATES 301012 Table 3-3. Summary of Environmental Sampling Soils in Dryer Island Chemical Company St. Crobc, U.S. Virgin Islands Sample Name D i y e r # l Diyer#2 Dryer Diyer Dryer 5434-Dryer 5435-Dryer Diyer U b P i t #5967' (Dryer) ICC lrf)0 5753-Dryer 5754-Dryer Drying Oven (Uft side composite) Drying Oven (Right side composite) Sample Date OB/14/85 06/14/85 06/14/85 07/01/85 07/01/85 07/01/85 07/01/85 07/17/85 08/07/85 08/07/85 08/07/85? 08/07/85? 09/09/85 09/09/85 Collect by/ Analyzed by ESI/York ESI/York ESVICMI ESI/ICMI ESI/ICMI ESI/York ESI/York ESI/ICMI ESI/ICMI ESI/York ESI/York ESI/York EPA/EPA EPA/EPA Uboratory Sample No. - - 42889 43747 43752 - -- 44629 45364 - - - 087001 087002 Parameters Analyzed Toluene Toluene VOCs VOCs VOCs Toluene Toluene VOCs VOCs; Toluene Toluene Toluene "Pur;geable and Non-volatUe organic Priority Pollutants" "Purgeable and Non-volatUe organic Priority PoUutanU" Substances Detected* Toluene(1.500) Toluene(150) Benzene(6.6); chloroform(340); 1,2- DCA(4.2); t-l,2-DCE(4.0); ethylbenzene(16.1); toluene(4,000); xyIenes(32.B) Aoetone(7); toluene(0.41) Aoetone(2.0); toluene(1.5) Toluene(7.7) Toluene(0.g2) Aoetone(1.2); PCE(0.07); toluene(0J6) Acetone(0.23); benzene(O.Ol); chloroform(O.ll); t-1.2-DCE(0.03); ethylbenzene(0.04); toluene(0.05); xylenes(0.02) Toluene(0.36) Toluene{0.6) Toluene(0.66) Benzophenone(15,000); B2EHP(13); fluorene(9.2); toluene(0.46) Benzophenone(2,600); B2EHP(4.7); DNOP(0.5'); fluorene(1.3): toluene(0.S6) Notes: 1 Rep>orted concentrations in parentheses, presented in parts per miUion (ppm). See Table 3-9 for list of chemical abbreviations. Chain of c:ustody form indicates "Dryei" Estimated concentration VOC VolatUe organic compound • \WORK\2423l\D2\PREVSMPH.T/VB HARDING LAWSON ASSOCIATES 301013 Table 3-4. Summary of Environmental Sampling Area C - Former Process Pit Island Chemical Coihpany St. Crobc, U.S. Virgin Islands , Sample Name Sample Date Matrix Collect by/ /Analyzed by Uboratory Sample No. Parameters Analyzed Substances Detected* Pit-Duplicate Pit Sludge PitSludge St. Crobc VI25-SED5 06/14/85 . 06/14/85 '06/r4/85 07/19/85 . 02/28/91 Liquid Sludge "While Lump" Water Soil ESI/ICMI ESI/ICMI ESI/ICMI ,-; ESl/lCMl NUS/Compu -Chem - 42885 42886 & 42887- Composite —42888 " ' — 44418 ^ BGL Not analyzed VOCs; Pest; PCBs;/^Cs; B/Ns;metels; CN; phenol Unknown , VOCs; Pest: .rPCBs-B/Ns; " : AECs; metals;' CN; phenol VOCs; AECs; B/Ns; Pest; PCBs; metals --- 1 71 1 t I 1 Insufficient sample volume to analyze As(40); Cd(22.8); chloroform(220); Cr(592); Cu(327); CN(1.44); Pb(688); Hg(2.73); methylene chloride(125); Ni(134); phenol(9.01); toluene(l,560); Zn(3,594); benzene / methanol^(15,000'); benzyl acetate^(170,000'); chloromethylbenzene^(4,400'); l-chloro-2- methylbenzene'''(40'); diphenyl methanone''^(30,p00'); 9H-fluorene-9-one''"(3,000'); 1,1'- (oxybis (methylene)bis) benzene^(4,000') No laboratbry'repbrt'provlded: ' '^ t^-—— — ~ — - — • - -^ ,— Benzene(0.04); Cd(0.003); Cr(0.027); Cu(0.153); CN(0.053); Pb(O.Oll); Hg(O.OOl); Ni(0;08); phqriol(0:i61); Ag(0.008); Th(o:029);-tblueiie(0.38); Zri(4:85); "": 1 " benzaidehyde^(3.o'); chloromethyl benzene^(0.3'j; .benzene methanoF(24'j; phenyl J i n Ah. Uiyl acetate''^(26'); diphenyl methane^(0.4J); l-l'-(oxybls (methylene)bis benzene^(0.4'); 2-Butanone(0.085'); xylenes(0.086'); 2-methylnaphthalene(0.63'); acenapthBne('); fluorene('); phenanthrene('); DNBP('); nuoranthene('); pyrBne('); BBP('); B2EHP(2.2'); Y- BHC('); aldrin(0.012'); heptachlor epoxide(0.0048'); endosulfan 1(0.004');. dieldrin(0.004l'); 4,4'-DDT('); methoxychlor('); a^:hlordane(0.0035'); Y- " ' chloiclane(0.006l');>l(9,400); Sb(26.6'); As(8');-Ba(48.6); Ca(51,200); Cr(57.6'); Co(13.8); Cu(367);-Fe(183,000); Pb(466); Mg(4,740); Mn(925); Ni(47.8'); K('); Na('); V('); Zn(1.500') Ui o I-» o M 1 - I T B/N . AEC BTEX PGB Pest VOC Notes: Reported cx)nc»ntratipns in parentheses, presented in parts per million (ppm). See Table 3-9 for list of chemical abbreviations. Estimated concentration Tentatively identified compound Base/neutral extractable compound . . . ' Acid extractable cx)mpound . ' • _ - ' , _ Benzene, toluene, ethylbenzene and xylenes ^ Polychlorinated.biphenyls • ' ; , Pesticides, " - , ,, - . ' . . . Volatile organic compound - \WORK\24231\02\PREVSMPC.TAB March 17. 1994 HARDING LAWSON ASSOCIATES Table 3-S. Summary of ICC Environmental Sampling Area D - Loading Dock and Ub Pit Area Island Chemical Company St. Crobc, VS. Virgin Islands Pago 1 of 5 OJ o o H tJl Sample Name D-1 D-2 D-3 D-4 D-5 Loc.4-4'B Loc.l3-3'B Loc.20-1'B Loc.21-4"B H22 I'A H-21 3'D 20 SepUc 20 A-2' 21 A-2' 21 A-4' .^RA \atzl n.ion fnr nnlpf Sample Date ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 ca. 09/17/84 09/18-19/84 09/18-19/84 09/18-19/84 09/18-19/84 ca. 10/15/84 ca. 10/15/84 10/23-28/84 10/23-28/84 10/23-28/84 10/23-28/84 t Matrix SoU Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soli Soil Collect by/ Analyzed by ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/Berlex ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/Berlex ESI/Berlex ESIA'ork ESlA'ork ESI/York ESI/York Uboratory Sample No. NA NA NA NA NA 34625 34628 34624 34627 - - - - V Parameters Analyzed Toluene; pyridine; QG; QS Toluene; pyridine; QG; QS toluene; pyridine; QG; QS Toluene; pyridine; QG; QS Toluene; pyridine; QG; QS VOCs VOCs VOCs VOCs Toluene; pyridine Toluene; pyridine Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Substances Detected* PyridinB(920); QG(452); QS(82) Pyridlne(507); QG(96) None detected None detected Pyridine(3,014); QG(170) FluorBthyne'''"(0.38);2-methylpropanol''"(0.16) Fluorelhyne''''(0.31);2-methylproponol''"(0.16) Toluene(0.16); nuor8lhyne"(0.45); 2- methyIpropanoF(0.20); pontane^(O.Ol) FIuorBthyne*''"(0.06): 2-m8thyl-l-heptene''"(0.21); 2- methylpropanor(0.47); pyridine'^(0.02) Nona detected Pyridlne(1.2) Toluene(0.54); benzene(0.0005'); chloroform(0.012); diphenyl methanone(64); 1,1-methylene bis-Benzene(8.4); methylene chloride(0.0015l): 0&G(241) Toluene(0.69); benzene(0.0009'); chlorofonn(0.005); ethylbenzene(0.068); methylene chloride(0.0023'); xylenes(0.6); OftG(S66) Toluene(0.015): ben2ene(0.0006'); chloroform(0.0038'); ethylbenzene(0.007); methylene chloride(0.0024J); PCE(0.0009'); TCE(0.0008'); O&G(l,500) Toluone(0.043); benzene(0.0004'); chloroform(0.0026'); methylene chloride(0.0022'); 0&G(27.9) \WORK\24231\02\PREVSMPD.TAn HARDINQ LAWSON ASSOCIATES Table 3-5. Summary of ICC Environmental Sampling Area D - Loading Dock and Lab Pit Area ' - Island Chemical Company .' , . St. Crofac, U:S. Virgin Islands : Sample Name Sample Date Matrix .Collect by/ Analyzed by Uboratory Sample Np. Parameters Analyzed Substances Detected D-1 2 5 - 2 ' . 2 7 - 2 ' y 3 2 - 2 ' 35-4" 3 6 - 2 ' UbPil Lab Pit Duplicate, U b P i t # l U b Pit #2 Lab Pit #3 Lab Pit #4 U b Pit #1 U b P i l # 2 U b P i l # 3 See last page for notes ca. 09/17/84 . 10/23-28/84 . 10/23-28/84 10/23-28/84 10/23-28/84 10/23-28/84 . OG/14/85 06/14/85 06/14/85 06/14/85 06/14/85 06/14/85 07/01/85 07/01/85 07/01/85 \WORK\24231\02\PREVSMPD.TAn Soil Soil Soil . Soil SoU Soil 7 7 Soil •Soil Soil. Soil Soil Soil Soil ESI/Berlex - ESI/York ESI/York ESI/York ESI/York ESIA'ork • ESI/icMl . ESI/ICMI , ESI/York ' ESIA'ork ESI/York ESI/York - ESnCMI ESI/ICMI ESI/ICMI NA - - - ' • . 42883 42884 - - ;- -' • - 43748 43749 43750 Toluene; p3rridine; QG; QS Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Toluene; pyridine; VOCs; O&G Unknown , Unknovim Pyridine Pyridine • , P3Tidine Pyridine Unknown ' Unknown Unknown Pyridine(920); QG(452); QS(82) , Toluene(0.21); pyridine(13); benzene(0.0004'); chloroform(0.005);jnethylenechloride(0.0017'); — - 0&G(89.6) ^ Toluene(0:016); pyri(iine(26); benzene(0.0006'); chloroform(0.019); methylene chldride(p.0022']; 0&G(187) . > Toluene(d;oi5)^^pyfidiii5(43); benzehe(0.0008'); chlbroforin(0.0042'); methylene chloride(0.oa44'); 1,1,1- TCA(0.0008'); 0&G(50.6) ;, • Toluene(0.008); benzene(0.0004^); chloroform(0.013); methylene chloride(0.0024'); l,l,l-TCA(q.011); .0&G(39.5) - Toluene(0.007); benzene(0.0002'); chlqroform(0.0014'); methylene chloride(0.0016l); b&G(965J No report provided .- , • No report provided ^ Pyridine(3.9) " - None detected Pyridine(0.51) , . ' Pyridlne(0.18) No.report provided No report provided No report provided HARDINQ LAWSON ASSOCIATES Table 3-5. Summary of ICC Environmental Sampling Area D - Loading Dock and Ub Pit Area Island Chemic»l Company St. Croix, VS. Virgin Islands Pago 3 of S Sample Name Sample Date Matrix CoUect by/ Analyzed by Uboratory Sample No. Parameters Analyzed Substances Detected* U> O l-> O -J D-1 Ub Pit #4 5436-Ub Pit #1 5437-Ub Pit #2 5438-Ub Pit #3 5439-Ub Pit #4 Ub Pit Sample 1 Ub Pit Sample 2 Ub Pit #5967 COC indicates "Dryei' Ub Pil #5965 Ub Pit # 5966 UbPH Ub Pil 12:00 UbPit 12:00 UbPU 3:00 UbPU 3:00 ca. 09/17/84 07/01/85 07/01/85 07/01/85 07/01/85 07/01/85 07/17/85 07/17/85 08/07/85 08/07/85 08/07/85 08/07/85 08/07/85 See last page for notes \WORK\24231\02\PREVSMPD.TAB SoU SoU SoU SoU SoU Soil Soil Soil Soil 08/07/85 Soil 08/07/85 Soil 08/07/85 SoU Soil SoU Leachate? Leachate? ESI/Berlex ESI/ICMI ESI/York ESI/York ESI/York ESI/York ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/York ESI/York ESI/York ESI/York NA 43751 44630 44631 45364 45362 45383 45360 & 45361 Toluene; pyridine; QG; QS Unknown P)rridino Pyridine Pyridtao Pyridine Unknown Unknown VOCs: VOCs; VOCs: Unknown Pyridine Pyridine VOCs VOCs Pyridine(920); QG(452): QS(82) No report provided Pyridine(l.l) Pyridine(3.4) None delected None delected No report provided No report provided Acelone(0.23): benzene(O.Ol); cliloroform(O.ll): t-1,2- DCE(0.03); ethylbenzene(0.04); toluene(0.05); xylene8(0.02j) Ac8tone(0.32); benzene(0.34): 1,1-DCA(0.02); t-1.2- DCE(0.02); ethylbenzene(0.01); toluene(0.08); xylenes(O.OeJ) Aoelone(0.27): beiiZ0iie(1.37): 1,1-DCA(0.02): 1-1,2- DCE(0.01) No report provided Pyridlne(2.7) None delecHed Toluene(0.022) Toluene(0.021) HARDINQ LAWSON ASSOCIATES Table 3-5. Summary of ICC Environmental Sampling Area D - Loading Dock and Ub Pit Area Island CbemJcal Company St. Crobc. U.S. Virgin Islands Pago 4 of 5 Sample Name Sample Dale Matrix Collect by/ ^ Analyzed by Uboratory Sample No. Parameters Analyzed Substances Detected* o H O D-1 UbPU 3:00 5751-Ub Pil #2 5752-Ub Pil #1 Ub Waste Drainage Area (North side surface) Ub Waste Drainage Area (North side subsurface) Ub Waste Drainage Area (South side surface) Ub Waste Drainage Area (South side subsurface) 085252-ESI 085254-ESI 085255-ESI 085252 Ub waste pil seep 085254 Ub 1 waste pil #1 ca. 09/17/84 08/07/85 08/07/85? 08/07/85? 09/09/85 09/09/85 09/09/85 09/09/85 03/13/86 03/13/86 03/13/88 03/13/86 03/13/86 SoU l««chate? SoU Soil Soil SoU Soil Soil Soil Soil Soil Soil Soil ESI/Berlex ESIA'ork ESI/York ESI/York EP/V/EPA EP/V/EPA EPA/EPA EP/V/EPA ESWCMI ESI/ICMI ESI/ICMI EPA/EPA EPA/EPA NA - - - 087003 087004 087005 087006 53362 53365 53366 NA NA Toluene: pyridine; QG; QS VOCs Pyridine Pyridine "Purgeable and Non-volatUe organic Priority Pollutants" "Purgeable and.Non-volatile organic Priority Pollutants" "Purgeable and Non-volatile organic Priority Pollutants" "Purgeable and Non-volatile organic Priority Pollutants" VOCs; AECs; B/Ns; PCBs VOCs; AECs; B/Ns; PCBs VOCs; AECs: B/Ns; PCBs VOCs; AECs; B/Ms; Pesl; PCBs; metals: dioxins VOCs; AECs; B/Ns; Pest; PCBs; metals; dioxins 00 Pyridine(920); QG(452); QS(a2) Toluene(0.36) None defected None detected B2EHP(16); loluene(0.42) B2EHP(1.9); DNOP(4.2); loluene(0.44) B2EHP(51): DNOP(0.6'): toluene(0.36) B2EHP(36); DNBP(75): DN0P(2); loluene(0.4) Methylene chloride(0.015^ Chloroform(0.0092^); methylene chloride(0.0087^) Chloroform(0.0054^; methylene chloride(0.015^) DN0P(9); AsCl'): Be(7'); Cr(22); Cu(45); Ni(2o'); Sh(lO); Zn(63) DNOP(4.9): As(0.8'); Be(7'); Cr(27); Cu(55); Ni(25); Sb(8.4); Se(0.8'); Zn(80) \WORK\24231\02\PREVSMPD.TAB HARDINQ LAWSON ASSOCIATES Table 3-5. Summary of ICC Environmental Sampling Area D - Loading Dcx:k and Ub Pit Area Island Chemical Company St. Crofac, U.S. Virgin Islands Pago 5 of S Sample Name Sample Dale Matrix CoUect by/ Analyzed by Uboratory Sample No. Parameters Anal3rzed Substances Detecrted* D-1 085255 Ub waste pit #2 VI25-S1 VI25-SED2' VI25-SED4' ca. 09/17/84 SoU 03/13/86 Soil 02/28/91 Soil 02/28/91 Soil 02/28/91 SoU ESI/Berlex NA EPA/EPA NA NUS/Compu BGL -Chem NUS/Compu BGL -Chem NUS/Compu BGL -Chem Toluene; pyridhie; QG; QS VOCs; AECs; B/Ns; Pest; PCBs; metals; dioxins VOCs; AECs: B/Ns; Pest; PCBs; metals VOCs; AECs; B/Ns; Pest; PCBs; metals VOCs; AECs; B/Ns; Pest; PCBs; metals Pyridine(920); QG(452): QS(82) DNOP(3.2); yVs(2'); Be(7'): Cr(26); Cu(58); Ni(27); Se(0.8'); Zn(79) Of-Chlordane(4j); Y-Chlordane(4.9j); Al(13,600); Ba(108); Ca(69,300); Cr<19.8j); Co(13.4); Cu(58.7); Fe(21,500); Pb(9); Mg(3,830); Mn(735): Ni(10.7J); K(2,170); V(74.7); Zn(142/) Al(32,400); Sb('); As(3.2'): Ba(115); Ca(74,900); Cr(16.3'); Co(23.7); Cu(60.5); Fe(35,800); Pb(7.5); Mg(10.900); Mn(l,320): Ni(13.8'): K(l,490); Na(l,840'); V(62.1); Zn(73.5') Al(33.600); A8(3.6'): Ba(122); Ca(82,100); CKlB.s'): Co(25.4); Cu(64.e); F«(38.840); Pb(7.8); Mg(l 1.800); Mn(l,430): NI(15.2'); K(l,600): Na(1.750'); V(64.e): Zn(79.9') LO O H O to Notes: 1 ] 3 B I T B/Ns AECs PCBs Pesl VOCs Reported concentrations in parentheses, presented in parts per million (ppm). See Table 3-9 for list of chemical abbreviations. Uboratory reported fluorethyne "possibly from plastic bag" Duplicate samples Substance present in blank Estimated c»ncentralion Tentatively identified compound Base/neutral extractable compounds Acid extractable compounds Polychlorinated biphenyls Pesticides Volatile oi^anic compounds \WORK\24231\02\PREVSMPD.TAB HARDINQ LAWSON ASSOCIATES Table 3-6. Summary of Environmental Sampling Area;E - Soil Beneath Concrete Pad Near ASTs Island Chemical Company St. Croix, U.S. Virgin Islands Sample Name Sample Date Matrix Collect by/ Analyzed by Parameters Anal)rzed Substances Detected* S4-1 S4-2 S4-3 S4-4 ca. 09/17/84 Soil ca. 09/17/84 Soil ca. 09/17/84 Soil ca. 09/17/84 Soil S4-Surface ca. 09/17/84 Soil ESI/Berlex Toluene; pyridine; QG; QS None detected ESI/Berlex Toluene; pyridine; QG; QS None detected ESVBerlex Toluene; pyridine; QG; QS None detected ESI^erlex Toluene; pyridine; QG; QS None detected ESI/Berlex Toluene; pyridine; QG; QS None detected Notes: * Reported cxincenlralions in parentheses, presented In parts per mUlion (ppm). See Table 3-9 for list of chemical abbreviations to O l - » O to O \WORK\24231\02\PREVSMPE HARDINQ LAWSON ASSOCIATES Table 3-7. Summary of ICC Environmental Sampling Background, River Gut and Drains Island Chemical Company St. Crofac, U.S. Virgin Islands Pago 1 of 4 Area Sample Name Sample Date Matrix CoUect by/ Analyzed by Uboratory Parameters Sample No. /Analyzed Substances Detected* IO O H O to Unkhowrn Unknown Unknown Unknown Gut Gut Gut Gut Gut Gut • Gut Gut Drain Line #1 Drain Line #2 Drain Line #1 Drain Line #2 G-1 G-1 Dup G-2 G-3 G-4 G-5 G-6 G-7 06/07/85 06/07/85 06/07/85 06/07/85 02/19/86' 02/19/86' 02/19/86' 02/19/86' 02/19/86'. 02/19/86' 02/19/86' 02/19/86' SoU SoU SoU Soil SoU SoU SoU SoU Soil Soil SoU SoU ESI/ICMI ESI/ICMI ESI/York ESI/York ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI ESI/ICMI 42B82 42881 52463 52463 52464 52465 52466 52467 52468 52469 BTEX VOCs Toluene Toluene Metals: CN; phenols; VOCs Metals; CN; phenols; VOCs Metals; CN; phenols; VOCs Metals: CN; phenols; VOCs Metals: CN; phenols: VOCs Metals; CN; phenols: VOCs Metals; CN; phenols: VOCs Metals; CN; phenols; VOCs Benzene(O.l); toluene(235); elhylbenzene(0.25); xylenes(0.6) Carbon lelrachloride(lO): chloroform(68); ethylbenzene(9); methylene chloride(l,240); loluene(5,600); xylene8(18^) Toluene(140) Toluone(310) Cr(14.5): Cu(37.3); Pb(21); Zn(63.1) CK17.9); Cu(43.S); Pb(25.7): Zn(67.8) Cr(16.4); Cu(38.3); Pb(22); Zn(57.8) Cr(ie.7); Cu(33.8): Pb(14.5); Zn(12g) Cr(12): Cu(25 J): Pb(13.2): Zn(37.1) Cr(17.1); Cu(38.1); Pb(20.2): Zn(S7.2) Cd(l.O); Cr(46.6); Cu(40); Pb(32.9); Zn(349) Cd(2.4); Cr(71.1); Cu(51.4); Pb(46.4); Zn(861) See last page for notes \WORK\24231\02\PREVSMPI.TAB HARDINQ LAWSON ASSOCIATES Table 3-7. Summary of ICC Environmental Sampling Background, River Gut and Drains Island Chemical Company < St. Croix, U.S. Virgin Islands Area Sample Name Sample Date Matrix CoUect by/ Arial3rzed by Uboratory Parametera Sample No. Analyzed Substances Delected* O 1—1 O to to Gut Gut Gut Gut Gut Gut G-1 Gut G-2 Gut G-3 Gut Gut Gut G-8 G-9 G-10 G-11 G-6G-7 Comp. 085251-ESI 085252-ESI 085253-ESI 085251 Gul Background 085252 U b waste pit seep 085253 Drainage pit disch. 02/19/86' 02/19/86' 02/19/86' 02/19/86' 02/19/86' 03/13/86 03/13/86 03/13/86 03/13/86 03/13/86 03/13/86 Soil SoU Soil Soil Leac SoU Soil SoU Soil SoU Soil ESI/ICMI 52470 ESI/ICMI 52471 ESI/ICMI 52472 ESI/ICMI 52473 Leachate ESI/ICMI 54501 ESI/ICMI 53362 ESI/ICMI 53363 ESI/ICMI 53364 USEPA/USEPA NA USEPA/USEPA NA USEPA/USEPA NA Metals; CN; Cr(20.4); Cu(32.8): Pb(19.4): Zn(76.2) phenols; VOCs Metals; CN; Cr(19.8); Cu(34.9); Pb(21.4); Zn(75.7) phenols; VOCs Metals; CN: Cr(30.6); Cu(62.7); Pb(16.5); Zn(66.5) phenols; VOCs Metals: CN; Cr(41.1): Cu(69.7); Pb(12.8); Zn(871) phenols; VOCs RCRA Metals Ba(1.2): Pb(0.24) VOCs; SVOs; PCBs VOCs; SVOs: PCBs VOCs; SVOs; PCBs Pesl/PCBs; VOCs; SVOs; metals; dioxins Pesl/PCBs; VOCs; SVOs; metals; dioxins Pesl/PCBs; VOCs; SVOs; metals; dioxins None detected Methylene chloride(0.015^ Chloroform(0.0082^;elhylben2ene(0.0028'); toluene(0.0044°) BBP(l): DN0P(17); As(2'); Cr(10): Cu(40); Ni(19); Se{l'); Zn(lOO) DN0P(9): A8(l'); Be(7'): Ct<22); Cu(45); Ni(20'); Sb(lO); Zn(63) Xylerie{0.47); DNOP(7.7); 1,4-DCB(0.87); 1,2-DCB(2.9); naphthalene(3.1); nuorene(2.0); phenanlhreno(2.4); As(0.8'); Be(8'); Cr(52); Cu(52); Pb(30'); Ni(32); Se(l'); Zn(360) See Inst page for notes \WORK\24231\02\PREVSMPI.TAB HARDINQ LAWSON ASSOCIATES Table 3-7. Summary of ICC Environmental Sampling Background, River Gut and Drains Island Chemical Company St. Crofac, U.S. Virgin Islands Area Sample Name Sample Dale Matrix Collect by/ Analyzed by Uboratory Sample No. Parameters Analyzed Substances Detected* Gut 500" Downstream Gut Ub Drain Gut Upstream Gul Ub Drain Dup Central Storm Drain at Process Pil VI25-SED1 VI25-SED2^ VI25-SED3 VI25-SED4^ VI25-SED5 02/28/91 02/28/91 02/28/91 02/28/91 02/28/91 Sediment Sediment Sediment Sediment Sediment USEPA/ Compu-Chem USEPA/ Compu-Chem USEPA/ Compu-Chem USEPA/ Compu-Chem USEPA/ Compu-Chem BGL BGL BGL BGL BGL VOCs; SVOs; Pesl; PCBs; metals VOCs; SVOs; Pest; PCBs; metals VOCs; SVOs; Pest; PCBs; metals VOCs; SVOs; Pest; PCBs; metals VOCs: SVOs: Pest; PCBs: metals Dieldrin{'); endrin('); 4,4'-DDT{'); Al(15,700); As('); Ba(90.3): Ca(45,600); Cr(18.7'); Co(14.7); Cu(46.4): Fe(25,700); Pb(15.1); Mg(7,600); Mn(954); Ni(10.8'); K('); Na(J); V(82.4); Zn(53.9') Al{32,400); Sb('); As(3.2'): Ba(115); Ca(74,900); Cr(16.3'); Co(23.7); Cu(60.5); Fe(35,800): Pb(7.5); Mg(10,900); Mn(l,320); Ni{13.8'); K(l,490); Na(l,640'); V(62.1); Zn(73.5') Al(30,400); Sb('); As(4.l'); Ba(lll); Be('); Ca(79,900); Cr(17.6'): Co(24.8); Cu(62); Fe(39.200); Pb(7.5); Mg(ll,800); Mn(l,400): Ni(14.6'): K('); Na('); V(63.2); Zn(82.3') AI(33,600); A8(3.8'); Ba(122): Ca(82,100); Cr(16.8'); Co(25.4): Cu(64.8); Fe(38,400); Pb(7.8); Mg(l 1.800); Mn(l,430): Ni(15.2'); K(l,600); Na(l,750l); V(64.8); Zn(79.9') 2-Butancme(0.085'); xylenes(0.086'); naphlhalene('); 2- melhylnaphthalene(0.63'); ac:enaphthylene('); nuorene('); phenanthrene('): di-n-butyl phthalate('); fluoranthene('); P3rrene('); bulylbenzylphthalale('); bis(2-ethyl hexyl)phthalale(2.2'): T-BHC('); aldrin(0.012'); heptachlor epoxide(0.0048'); endosulfan I (0.004'); dieldrin(0.004l'): 4,4'-DDT('): molhoxychloi('): a-chlordane(0.0035'); Y- chloidane(0.006l'); Al(9,400): Sb(26.6'); As(8'); Ba(48.6); Ca(51,200): Cr(57.6'): Co(13.8); Cu(367): Fe(183.000); Pb(466); Mg(4,740); Mn(925): Ni(47.8'); K('): Na('); V('); Zn(l,500l) ( j J O M O to CO Sec last page for notes \WORK\24231\02\PREVSMPI.TAB HARDINQ LAWSON ASSOCIATES Table 3-7. Summary of ICC Environmental Sampling Background, River Gut and Drains Island Chemicxd Company Si. Crofac, U.S. Virgin Islands Area Sample Name Sample Dale Matrix Collect by/ Analyzed by Uboratory Sample No. Parameters Analyzed Substances Detected Southem Storm Drain VI25-SED6 02/28/91 Sediment USEPA/ BGL VOCs; SVOs; 2-Butanone(0.15); xylenesf'); pyrene('); A-BHC(0.0077'); Compu-Chem Pest; PCBs; aldrin(0.02'): dieldrin(O.Ol'): 4.4'-DDE(0.024'); endosulfan metals 11(0.0095'); methoxychlor('); T-chIordane(0.016'); Al(10,600); Sb('); As(5.5'); Ba(95.8); Cd{4.5); Ca(42,100); Cr(lio'); Co(17.3): Cu(109); Fe(121,000); Pb(187); Mg(5,000l; Mn(1.420); Ni(49.8'); K('); Na(I); V('); Zn(1.710') 02/28/91 Soil USEPA/ BGL VOCs; SVOs; 2-Butanone(0.01B'); trichloroethene(0.2l'); Compu-Chem Pest; PCBs; pentachlorophenol('); Al(19,200); As{'): Ba(113); metals Ca(18,000); Cr(2o'); Co(19.5); Cu(43.7); Fe(25.300); Pb(9.0); Mg(5,150); Mn(l,070); Nl(10.3'); K(2,500); Na('); V(84.9): Zn(44.3') Offsite VIPA virell field VI25-S6 Notes: 1 i 3 4 B I T SVO BTEX: GW PCB Pest VOC Reported oonoenlralions in parentheses, presented in parts per mUlion (ppm). See Table 3-9 for Ust of chemical abbreviations. Uboratory reported fluorethyne "possibly from plaslic;bag" ESI report indicates these samples were cx)Ilecled on January 30 and 31, 1986 (ESI, 1987, p.ll) Samples VI25-SED2 and VI25-SED4 vtrore duplicate samples. Substance roporlcxl in blank Estimated concentration Tentatively identified cximpound Semivolatile organic cxjmpound Benzene, toluene, ethylbenzene and xylenes Groundwater Polychlorinated biphenyls Pesticides Volatile organic ciompound CJ O I-» O to \WORK\24231\02\PREVSMPI.TAB HARDINQ LAWSON ASSOCIATES Table 3-8. Summary of ICC Environmental Sampling Water Samples Island Chemical CompMny St. Crofac, VS. Virgin Islands Area Sample Name Sample Dale CoUect by/ Analyzed by Uboratory Sample No. Parameters Analjrzed Substances Detected* CJ o M o to cn Well P-1 PW-2 (north weU) Fairplain 6 Fairplain 9 VIPAl VIPA 2 Fairplain 6 Fairplain 9 Fairplain 8 VIPA 2 Fairplain 6 Fairplain 9 085256-ESI On-site wel NA NA NA NA NA NA NA NA NA NA See last page for notes 03/13/86 ESI/ICMI USEPA/ USEPA 03/07/88- 03/10/88 03/07/88- 03/10/88 03/07/88- 03/10/88 03/07/88- 03/10/88 10/31/88- 11/02/88 10/31/88- 11/02/88 10/31/88- 11/02/88 10/31/88- 11/02/88 01/17/90 01/17/90 USEPA/NA USEPA/NA USEPA/NA USEPA/NA 53367 085256 NA NA USEPA/NA NA USEPA/NA NA USEPA/NA NA USEPA/NA NA NA NA USEPA/NA NA USEPA/NA NA Pesl/PCBs; VOCs; AECs; B/Ns; metals; CN; phenol Pest/PCBs; VOCs; meials; NA NA NA NA NA NA NA NA NA NA As(0.007); Cr(0.002): Cu(0.007): Pb(0.005): Hg(0.0005): Se(0.019); Ag(0.004): Zn(0.022); CN(0.007); DNOP(0.0024') Chloroform(0.13): DNOP(0.0039); B2EHP{0.28); As(0.002'); Be(0.005'); Cd(0.003'): Cii(0.007'); Cu(0.008'); Sb(0.003'); Zn(0.02'); Hg(0.0006j) Chloroform(0.024) Chloroform(0.07S and 0.070) Chlorofoim(0.0115) Chloroform(0.0113) Chloroform(0.0359) Chloroform(0.0104 and 0.0097 Chlorororm(0.0124) Chloroform(<0.0016) Chloroform(0.039) Chloroform(0.025) \WORK\24231\02\PREVSMPW.TAB HARDINQ LAWSON ASSOCIATES Table 3-8. Summary of ICC Environmental Sampling Water Samples Island Chemical Company St. Crobc, U.S. Virgin Islands Area Sample Name Sample Date Collect by/ Analyzed by Uboratory Sample No. Parameters Analjrzed Substances 0etec:ted* Fairplain 8 Water Tank Fairplain 6 Fairplain 9 VIPAl VIPA 2 PW-1 (south well) Fairplain 6 Fairplain 6 Fairplain 8 NA NA NA NA NA NA VI25-GW1 VI25-GW2 VI25-GW3 VI25-GW4 01/17/90 01/17/90 06/25/90 06/25/90 06/25/90 06/25/90 02/28/91 02/28/91 02/28/91 02/28/91 USEPA/NA USEPA/NA USEPA/NA USEPA/NA USEPA/NA USEPA/NA USEPA/ Compu-Chem USEPA/ Compu-Chem USEPA/ Compu-Chem USEPA/ Compu-Chem NA NA NA NA NA NA BGL BGL BGL BGL VIPAl VI25-GW5 02/28/91 USEPA/ Compu-Chem BGL NA NA NA NA NA NA VOCs; AECs; B/Ns; Pest; PCBs; metals VOCs; AECs; B/Ns; Pest; PCBs; metals VOCs; AECs; B/Ns; Pest; PCBs; metals VOCs; AECs; B/Ns; Pesl; PCBs; metals VOCs; AECs; B/Ns; Pesl; PCBs; metals Chloroform(0.005) Chloroform(0.0239') Chloroform(O.Oll) Chloroform(0.039) Chloroform(0.002') Chlorofonn(<0.005) Chloroform(0.031): BBP('): Al('); As('); Ba('); Ca(68.8); Cu('): Fe(0.121); Pb(0.0031); Mg(43.5); Mn('); Hg(0.002); K('); Se('): Na(548); V('): Zn(') Chloroform(0.012); phenol('): B2EHP('); Al('): Ba('); Ca(69.9); Cu('); Fe('); Pb(0.004); Mg(48.6); Mn(0.383); K('); Na(363); V('); Zn(') Chloroform(0.012); Al('); Ba('); Ca(74.1); Cu(I): Fe('): Pb(0.0042); Mg(50.5); Mn(0.4); Hg(0.0033); K('); Na(374); V('); Zn(0.0218) ChlorofoTm(0.012); BBP('); heptachlorf'); heptachlor epoxide('); DDE('); endosulfan II('): endosulfan sulfale('); endrin kolone('); Tchlordane('); AI('); Ba('); Ca(127); Cu('); Fe('); Pb(0.0039): Mg(71.6): Mn(0.0177); K('); Na(590); V('); Zn(') Chloroform('); 1.1,1-TCA(I); As('): Ba('); Ca(61.3); Cu('); Fe('); Pb(0.0037): Mg(40.1); Hg(0.0012'); K('); Na(572); V(0.0503'); Zn(') CJ O l-» O to cn See last page for notes \WORK\24231\02\PREVSMPW.TAB HARDINQ LAWSON ASSOCIATES CJ o O -J Table 3*8. Summary of ICC Environmental Sampling Water Samples Island Chemical Company St. Crobc, U.S. Virgin Islands Area Sample Name Sample Date CoUecf by/ Analyzed by Uboratory Sample No. Parameters Analyzed Substances Detected* VIPA 2 VI25-GW6 02/28/91 USEPA/ Compu-Chem BGL VOCs; AECs; B/Ns; Pest; PCBs; metals nuoranlhenB(O.Ol'): B2EHP('); Al('): Ba('); Ca(75.8); Cu('); Fe('); Pb(0.0059): Mg(58); Mn{'): Hg(0.00072'); K('): Na(237): V('): Zn(0.369) Notes: 1 2 J T NA B/Ns AECs PCBs Pest VOCs Reported cx)nc3entrations in parentheses, presented in parts pier miUion (ppm). See Table 3-9 for Ust of chemical abbreviations. Average concentration from three samples cxjllected. Estimated cx>ncentration TentaUvely identified cximpound Not avaUable Base/neutral extractable cx>mpound Acid extractable cxjmpound Polychlorinated biphenyls Pesticides VolatUe organic compound \WORK\24231\02\PREVSMPW.TAB HARDINQ LAWSON ASSOCIATES This page was intentionally left blank for pagination purposes. 301028 Table 3>9. Summary of Environmental Sampling Chemical Abbreviations Island Chemical Company St. Crobc, U.S. Virpn Islands Abbreviation Ag As B2EHP Ba BBP Be Ca Cd CN. , Cr Cu DCB DDE 1,2-DCA t-l,2-DCE' ,DNBP DNOP Fe Substance , r Silver Arsenic Bis[2-ethylhexyl)phlhalate Barium , Butylbenzyl phthalate Beryllium , Calcium . > Cadmium Cyanide i , Chromium Copper Dichlorobenzene 4,4'-DDE '; 1,2-Dichloroethane trans-l,2-Dichloroethene Di-n-butylphthalate Di-n-octyl phthalate Iron . ' Abbreviation Hg . K Mg Mn Na Ni O&G Pb PCE QG QS Sb Se 1,1,1-TCA TCE Th . Zn Substance Mercury Potassium Magnesium Maganese Sodium Nickel Oil and grease Lead Tetrachloroethene Quinidine glucoiiate Quinine sulfate Antimony Selenium 1,1,1-Trichloroethane Trichloroethene Thallium Zinc : . .' \W0RK\2 4 231\02\PREVPARA.TAB HARDING LAWSON ASSOCIATES 301029 Table 4*1. Potential Chemical Specific ARARs and TBCs Island Chemical Company Sile St. Crofac. U.S. Virgin Islands Standard, Requirements Criteria or Limitation Citation Description Comment FEDERAL ARARs AND TBCs Safe Drinking Water Act National Primary Drinking Water Standards (Primary MCLs) National Secondary Drinking Water Standards (Se<x)ndary MCLs) Maximum Contaminant Level Goals (MCLGs) O h-» O Ui o 42 USC §§ 300h - 300h-7 40 CFR Part 141 40 CFR Part 143 40 CFR §§ 141.50 and 141.51 Federal Water Pollution Conlrol Act as amended by the Clean Water Act Criteria and Standards for NPDES Toxic PoUutant Effluent Standards Water Quality Standards 33 USC §§1251 - 1387 40 CFR Parts 122 - 125 40 CFR Part 129 40 CFR Part 50 Establishes primary MCLs for pubUc ivater systems measured at the tap based on protection of health and consideration of technical and economic feasibility. Establishes non-enforceable secxtndary MCLs for pubUc water supply systems measured at the tap relaUng lo aesthetic qiulities. Establishes non-enforceable MCLGs for public water supply systems which are entirely health-based. Establishes a program for Issuing, moniloring, and enforcing permits for direct discharge Establishes poUutant efiluenl standards for 6 groups of toxic poUutants Requires NPDES permits to include effluent limitations and requires stales to promulgate water quality stan- dards PotenliaUy applicable if groundwater in the vicinity of the site is used or may be used as a sourc:s of water for a public water supply system and private water supply weUs. PotenUaUy applicable if groundwater in the vicinity of the site Is being used or may be used as a source of water for a public water supply system and private water supply weUs. CERCLA Sl21(d) provides that MCLGs shall be attained if lelevant and appropriate. The NCP states that non-ssro MCLX^ should be used for remedial actions. If groundwater in the vicinity of the site is used or may be used as a sourc» of water for a pubUc water supply system and private water supply weUs then non-zero MCLGs may be relevant and ap- propriate. SubstanUva requirements are potential ARARs. PotentlaUy relevant and appropriate if the remedy re- quires disc^hai^ of treated water to surfacse water. These requlrementa are implemented through Virgin Islands' regulations. \WORK\24231\02\ARARS1.TAB HARDINQ LAWSON ASSOCIATES Table 4-1. Potential Chemical Specific ARARs and TBCs Island Chemical Company Site • Si. Crofac, U.S. Virgin Islands Standard, Requirements Criteria or Limitation Citation Description Comment Clean Water Act Water Qual- ity Criteria (WQC) Clean Air Act National Ambient Air QuaUty Standanis (NAAQS) National Emissions Standards for Hazardous Air Pollutants (NESHAPs) New Source Performanc» Standards (NSPS) Solid Waste Disposal Act (SWDA) as amended by the Resource Con- servation and Recxjvery Act (RCRA) and Ihe Hazardous and Solid Waste Amendments (HSWA). RCRA MCLs RCRA Air Emissions Stan- dards Ui O M O CO Quality Criteria for Water (1986) fGold Book") 42 USC §§ 7401 - 7626 40 CFR Part 50 40 CFR Part 61 40 CFR Part 60 42 USC §§ 6901 - 6987 40 CFR § 264.94 40 CFR Part 264, Subparts AAandBB Non-enforceable guidelines lo be used in cx)n|unction with designated uses of stream segments to establish water quality standards EstabUshes ambient air quality standards for six "cnile- ria poUutants". (CO, Pb, NOj, PM,o, O,, SO,) Establishes emissions standards for designated hazard- ous air pollulanta from specific sources Establishes performance standards for emissions from new or mcxlified sources EstabUshes concentration limits for hazardous cxjnstilu- ents in groundwater beneath regulated units (landfills, surface impoundments, waste piles, and land treatment units) that received hazardous waste after July 26, 1982. Establishes air emissions standards for prcx:ess vents on equipment lhat treat hazardous wastes that have a total organics cx)ncenlration of 10 ppm (subpart AA) and for equipment leaks from equipment that treat hazardous wastes containing 10 percent or more of total organics (Subpart BB) CERCLA §121 requhw attainment of WQC where relevant and appropriate. However, according to EPA Guidance, the WQC are not relevant and appro- priate with respect to groundwater used for drinking water supply. Applicable through the State or Federal Implementa- Uon Plan. Potential ARAR if pollutant emitted is c»vered by NESHAP or MACT standard Potential ARAR if the poUutant emitted and alterna- tive developed are tha same as or sufficiently similar to the poUutanta and source category cxiveied by an NSPS. PotentlaUy appUcable if the jurisdic^tional criteria are fulfilled; potentiaUy relevant and appropriate, otherwise. Potentially appUcable if the (urisdictional criteria are fulfUIed; potentiaUy relevant and appropriate, otherwise. \WORK\24231\02\ARARS1.TAB HARDINQ LAWSON ASSOCIATES Table 4 - 1 . Potential Chemical Specific ARARs a n d TBCs Island Chemical Company Site Si. Crofac, U.S. Virgin Islands standard, Requirements Criteria or Lunltation Citation Description Comment Proposed RCRA Air Emission Standards Proposed RCRA Action Levels (ALs) Proposed RCRA Performance Standards (PSs) 56 Fed.Reg. 33490 (July 22, 1991) 55 Fed.Reg. 30798 (July 27, 1990) 55 Fed. Reg. 30798 Ouly 27, 1993) Proposes organic air emission standards for tanks, surface impoundmenta, and oonlainera Proposes health-based sca'eening levels for air, water, and soU, used to determine whether correcUve action Is necessary for solid waste management units Proposed PSs ore (»nc3entrations for establishing media protection standards for carcinogens Proposed RCRA air emission standards will be cx>nsidered. RCRA ALs wUl be considered. RCRA PSs will be c»nsidered. VS. VIRGIN ISLANDS ARARs* Virgin Islands Safe Drinking Water Act (VI SDWA) Virgin Islands Water Pollution Control Act Virgin Islands Air PolluUon Control Act Virgin Island Ccxle Annotated Title 19, Sections 1301-1310 (V.I. Code Ann. Ut. 19, §§ 1301-1310) V.I. Code Ann. til. §§ 181-198 12. V.I. Code Ann. lit. 12, §§ 201-217 Provides for the establishment of interim primary drin- king water standards. Provides for the establishment of water quality stan- dards for surface and groundwatera. Provides for the establishment of limitations of the levels, cx>ncenlrations or quantities of emissions of various air cx>ntaminanls. Prohibits the emission of obnoxious, pungent, cxlorous, or iU-smeUing gases, fumes, or other air poUutanta Interim primary drinking water standards promul- gated under the V.I. SDWA are potential ARARs if more stringent than the federal primary MCLs. V.I. Water Quality Standards are potential ARARs as cleanup standards or if Ihe alternative developed involves disc^harges to surfacse or groundwatera. V.I. emission limitations and odor prohibitions are potential ARARs if the altemative developed involves air emissions. * Potential ARARs are based upon Virgin Islands Ccxle Annotated (1993). Current regulations ore not readUy available. Ui O l-» O Ui IO \WORK\24231\02\ARARS 1 .TAB HARDINQ LAWSON ASSOCIATES Table 4«2. Potential Action-Specific ARARs Island Chemical Company Site St. Crofac, U.S. Virgin Islands Standard, Requirement, Criteria, or Limitation CitaUon Description Comment FEDERAL ARARs Safe Drinking Water Act Underground Injection Con- trol RegtUations Federal Water PoUuUon Control Act as amended by the Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) Criteria Standards Toxic PoUutant Effluent Standards Best Management Practices (BMPs) for Toxic PoUutants 42 USC §§ 300h-300h-7 40 CFR Parts 144 to 147 33 U.S.C. §§ 1251-1387 40 C.F.R. Parts 122-125 40 C.F.R. Part 129 40 C.F.R. Part 125, Subpart K Stormwater Requirements 40 C.F.R. § 122.26 CO O H» O CO CO Monitoring 40 C.F.R. § 122.41, and §§ 136.1-136.4 \WORK\24231\02\ARARS2.TAB EstabUshes procedural and permitUng standards for cx>nstrucUon and operation of injecUon wells in order to prolec:t underground sources of drinking water Requires permits for the discharge of pollutants from any point source into walera of the United States, inclucUng territorial seas. Establishes effluent UmitaUons, standards and prohibitions for certain toxic pollutants: aldrin/dieldrin, endrin, toxaphene, benzicUne, PCBs, and DDT. Establishes BMPs for ancillary industrial activities such as, loading and unloading operaUons, plant site runoff, and sludge and waste cUsposal areas. Establishes permitting requirements for point source discharges of stormwater associated with industrial activities to waters of the United States. Includes requirements for a BMP plan. General permita may contain additional requlrementa. Establishes discharge moniloring parametera, analy- tical procedures, and quality cxjntrol requirements. SubstanUve requlrementa are potentially applicable if reinjection wells are used for cUschaige of treated water. SubstanUve requlrementa are potentially applicable if remedial ac:tiviUes involve onsite discharges to sur- fac3e and marine waters. Potentially applicable if remedial activities involve discharges of toxic poUutants to onsite surface vratere. Remedial actions are not industrial acUvilies and so the BMPs are not appUcable. BMPs are potentiaUy relevant and appropriate if toxic poUutanta wiU be disc:Iiarged to onsite surface walera. CERCLA remedial acUviUes would nol be considered a discharge assoc:iated with industrial acUvity so the substantive stormwater requirements would not be c»nsidered appUcable. However, they are potentially relevant and appropriate If there is an onsite point source discharge of stormwater. Potential ARAR if there are point sourtje discharges to onsite waters. HARDINQ LAWSON ASSOCIATES Table 4-2. Potential Action-Specific ARARs Island Chemical Company Sile St. Crofac, U.S. Virgin Islands Standard. Requirement, Criteria, or LimitaUon Citation Description Comment Clean Water Ad § 404 Rivera and Harbore Act of 1899 Dredge and FUl Permits Guidelines for the Land Disposal of Solid Wastes Identification and Listing of Hazardous Wastes Standards Applicable to Generation of Hazardous Waste CJ O M O 00 Standards for Owmere and Operatora of Hazardous Waste Treatment, Storage, and Disposal FaclUlies General FaciUty Standards Subpart B Prejjaredness and Prevention Subpart C Contlngencqr Plan and Emer- gency Procedures \WORK\24231\02\ARARS2.TAB 33 U.S.C § 1344 33 U.S.C. § 403 40 CFR Parts 230 and 231 33 CFR Parts 320 • 330 40 C.F.R. Part 241 40 C.F.R. Part 261 40 C.F.R. Part 262 40 C.F.R. Part 264 Subpwirt D EstabUshes cx^ndiUons for discharge of dredge and fiU maierials lo walera of the U.S. or cx»an walera. EstabUshes requlrementa and prcx^edures for land disposal of aU soUd wastes except hazardous, agri- cnillural, and mining wastes. Defines soUd wastes which are subject to regulation as hazardous wastes. Establishes standards for generatore of hazardous waste. EstabUshes ininimum standards which define the acx»ptable management of hazardous waste for ownere and operatora of facilities which treat, store, or dispose of hazardous waste. EstabUshes general operating standards, including secnuity requlrementa, inspecUon standards, and personnel training. EstabUshes preparedness and prevention standards for a facility with respect to design, oonstruction, maintenance, and operation to minimize implanned . releases.' Establishes oontlngenc^y and emergenc^y response provisions lo follow in the event of an unplanned release. SubstanUve requlrementa are piotential ARARs if the altemaUve developed involves discharge of dredge and fiU material into walera of the U.S. (including wetlands and cx»an watera). The guidelines are potential ARARs if solid wastes wiU be land disposed. SubstanUve requlrementa are potential ARARs if Iiazardous wastes or substantially similar wastes are generated as a result of invesUgaUve and remedial ac:tiviUes. Potential ARAR for onsite treatment, storage, or dis- posal of Iiazaidous wastes or sufficiently similar wastes. Potential ARAR for onsite treatment, storage, or dis- posal of hazardous wastes or sufficiently similar wastes. Potential ARAR for onsite treatment, storage, or disposal of iiazardous wastes or sufficiently similar wastes. HARDINQ LAWSON ASSOCIATES Table 4-2. Potential Action-Specific ARARs Island Chemical Company Site St. Crofac, U5. Virgin Islands Standard. Requirement, Criteria, or Limitation Citation Description Comment CO O M O U i CJl Manifest S3^tem, Recx)idkeeping, snd Report- ing Water Quality Monitoring and Response Programs from Solid Waste Management Unita Closure and Post-Closure Financial Requirements Use and Management of C^ntalnere Tank Systems Waste Piles Land Treatment Landfills Subpart E Subpart F Subftart G Subpart H Subpart I Subpart; Surface Impoundments Subpart K Subpart L Subpart M Subpart N Establishes recordkeeping and reporting require- ments for hazardous waste manifesta. Establishes provisions for moniloring and response programs for releases firom soUd waste management unita and regulated unita. Administrative procsedures only. Creates no substan- tive cleanup requirement. PotenUal ARAR if Iiazardous waste or substantiaUy similar waste Is treated, stored, or disposed of onsite. EstabUshes closure and post-closure requlrementa. PotenUal ARAR If regulated units remain onsite. Establishes financial assurance requirements during closure and post-closure periods. Establishes design, operating, and procedural stan- dards for cxjntainera. Establishes design, operating, and procedural stan- dards for tank systems. Establishes design, operating, and prcxsedural stan- dards for surface impoundments. EstabUshes design, operating, and prcxxdural stan- dards for waste piles. EstabUshes design, operating, and procedural stan- dards for land treatment units. Establishes design, operating, and prcx»dural stan- dards for landfills. \WORK\24231\02\ARARS2.TAB Nol applicable or relevant and appropriate because csreates no substantive cleanup requirement. PotenUal ARAR if an altemaUve developed would involve storage of hazardous wastes or substantiaUy simUar wastes in cxintainera. Potential ARAR if an alternative developed would involve use of tanks to treat or store hazardous wastes or substantiaUy similar wastes. Potential ARAR if an alternative developed involves treatment or storage of hazaidous wastes or substan- tiaUy similar wastes In a surface impoundment. Potential ARAR if an altemaUve developed would involve treatment or storage of hazardous wastes or substantiaUy similar materials in piles. Potential ARAR if an altemative developed would involve treatment or storage in a land treatment unit of hazardous wastes or substantiaUy similar wastes. PotenUal ARAR if an altemative developed would involve disposal of hazardous wastes or substantially similar wastes in a landfill. HARDINQ LAWSON ASSOCIATES Table 4-2. Potential Action-Specific ARARs Island Chendcal Company Site SU Crofat, VS. Virgin Islands Standard, Requirement, Criteria, or Limitation Citation Description Comment Incineratore Corrective Action Manage- ment Unita (CAMUs) and TemjKjrary Units (TUs) MisceUaneous Units Process Vents and Equip- ment Leaks Containment Buildings Llnera and Leak Detection for Hazardous Waste Dispos- al Units Subpart O Subparts SubjMrt X Subparts AA and BB Subpart DD 57 Fed.Reg. 3462 (January 29, 1992) EstabUshes design, operating, and procedural stan- dards for inc:ineratore. AUows use of CAMUs for disposal of hazardous wastes writhout triggering LDRs or MTRs. AUows alternate design operating and closure standards for temporary tank and cx>ntainer storage areas of hazardous wastes. EstabUshes design, operating, and procedural stan- dards for other tjrpes of TSD units. EstabUshes air emission standards for prcxass vents on equipment that treat hazardous wastes that have a total of 10 ppm (Subpart AA) and for equipment leaks from equipment lhat treat Iiazardous wastes cx>ntaining 10 percent or more of total organlca (Subpart BB). Establishes design, operating and procedural standards for containment buildings. EstabUshes design criteria for llnera and leak detection and action lealcage rates for surface impoundmenta and landfills. Requires a oonstruc- tion qusUly assurance (CQA) plan for surface impoundmenta, landfiUs, and wastepUes. Potential ARAR if an altemative developed would involve incineration of iiazardous wastes or substan- tiaUy similar wastes. Potential ARAR if Iiazardous \vaste must lie land cUsposed or stored temporarily in tanks or cxintainera for greater than 90 days. PotentlaUy appUcable if hazardous waste or substan- tiaUy similar waste is treated, stored, or disposed at miscellaneous unite. Potential ARAR if air emissions result from treatment altemative. Potential ARAR if alternative developed involves use of a oontaimnent buUding for the storage or treatment of iiazardous waste or substantiaUy similar waste. Potential ARAR if treatment alternative involves a Burfece impoundment or landfill. CO O l - » O CO \WORK\24231\02\ARARS2.TAB HARDINQ LAWSON ASSOCIATES Table 4-2. Potential Action-Specific ARARs Island Chemical Company Site St Crofac, VS. Virgin Islands Standard, Requirement, Criteria, or Limitation Citation Description Comment Interim Standards for Own- ere and Operatora of Hazard- ous Waste Treatment, Stor- age, and Disposal FaciUties 40 C.F.R. Part 265 Thermal Treatment Chemical, Physical, and Biological Treatment 40 C.F.R. Part 265, Subpart P 40 C.F.R. Part 265, Subpart Q CO o l - » o CO -J Underground Storage Tanks (UST) Land Disposal Restrictions (LDR) Clean Air Act (CAA) National Ambient Air Quali- ty Standards (NAAQS) New Source Review/Prevention of Signifi- cant Deterioration (NRS/PSD) \WORK\24231\02\ARARS2.TAB 40 C.F.R. Part 280 40 C.F.R. Part 268, 57 Fed. Reg. 37194 (Aug. 8, 1992). 42 U.S.C. §§ 7401-7642 40 C.F.R. Part 50 EstabUshes minimum uterim status standards that define the acxsptable management of hazardous waste during the period of interim status and until certification of final closure, or if the faciUty is sub- ject to postclosure requirements, untU postclosure responsibUiUes are fulfilled. Establishes general operating and procedural re- quirements for thermal treatment other than incin- eration. Establishes general operating and procedural re- quirements for units which treat hazardous wastes by chemical, physical, or biological methcxls in other than tanks, surface impoundments, and land treat- ment faciUties. Establishes standards for design, cxinstmctlon, in- stallation, operations, maintenance, release detection, free product removal, closure and cxjrrective action. EstabUshes prohibitions on land disposal unless treatment standards are met. EstabUshes ambient air quality standards for six "criteria poUutanta" (CO, Pb, NO,, PM,o, Oj, SOJ Establishes cx>ntrol technology and moniloring requlrementa for attainment and non-attainment areas for major new sources. Except as noted Iielow, the more stringent piart 264 standards represent the ultimate RCRA cximpliance standards and are consistent with CERCLA's goal of long-term protec:tion of public health and welfare and the environmeni. The federal regulations provide interim status standards for thermal treatment and chemical, physical and biological treatment, but not standards for such treatment methods for permitted facriUties. Potential ARAR if an altemative developed would utilize thermal treatment of hazardous wastes or substantiaUy similar wastes. Potential ARAR if an altemative developed would utilize chemlcaL ph3rsical, and biological treatment of hazaidous ivastes or substantiaUy similar wastes. Substantive requlrementa are potentially applicable if USTs are present or remedial activities involve the use of USTs. PotenliaUy appUcable if Iiazardous vrastes are land disposed on-site. PotentiaUy appUcable through the State or Federal Implementation Plan. Potential ARAR If altemative developed emits a criteria poUutant and constitutes a major source. HARDINQ LAWSON ASSOCIATES Table 4-2. Potential Action-Specific ARARs Island Chemical Company Site St. Crofac, VS. Virgin Islands Standard, Requirement, Criteria, or LimitaUon Citation Description Comment Standards of Performance for New Stationary Sources (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAPs) 40 C.F.R. Part 60 40 C.F.R. Part 61 Seta NSPS for emissions from new or mcxlified sources. Seta NESHAPs for designated hazardous poUutanta from specific sources. Potential ARAR if the poUutant emitted and alterna- tive developed are tha same as or sufficiently simUar to the poUutanta and source category regulated by an NSPS. Potential ARAR if hazaidous air pollutants wUl be emitted as part of the remedial activities. U.S. VIRGIN ISLANDS ARARs* Virgin Islands Water Pollution Control Act Virgin Islands Well Driller Requirements Virgin Islands Requirements for Sealing Wells Virgin Islands Solid and Hazardous Waste Management Act V.I. Code Ann. tit. 12, Chapter 7 V.L Code Ann. tit. 12, § 157 V.I. Code Ann. tit. 12, § 161 V.I. Code Ann. til. 19. Part IV, Chapter 56 Provides for the establishment of requlrementa for the protection of surface and groundwatera. Requires weU drillera to obtain a license and for aU non-private wells to be drilled by a Ucensed driUer. Requires effective sealing of weli if highly mineral- ized water is encountered or well is abandoned. Provides for the establishment of regulations for the storage, cx}Ilectlon and transportation, disposal .resource recovery of solid and hazardous waste. Potential ARAR if alternatives developed Involves discharge to surface or groundwatera. All monitoring and extrac:tion wells wlU ba drilled by a licensed well drlUer. AU abandoned monitoring and sxtracHion wells wlU be effectively sealed as weU as any wells encxnmter- ing highly mineralized water. Regulations are potential ARARs if alternatives developed involve the treatment, storage or disposal of solid or iiazardous wastes. * Potential ARARs are based upion Virgin Islands Code Annotated (1993). Current regulations are not readily available. CO C M O CO 00 \WORK\24231\02\ARARS2.TAB HARDINQ LAWSON ASSOCIATES Table 4-3. Potential Location SpecHle ARARs Island Chemical Company St. Crofac, VS. Virgin Islands Pago 1 of 4 Standard, Requirement, Criteria, or Limitation CitaUon Description Comment FEDERAL ARARs Solid Waste Disposal Act (SWDA) as amended by the Resource Conserva- tion and Recxjvery Act (RCRA) and the Hazardous and SoUd Waste Amend- menta (HSWA) • Location Standards 42 USC §§ 6901-6992 40 CFR § 264.18 Siting is restricted in vicinity of recent faulting. Spe- cial prcxedures are required for facilities located within a 100-year flcxxiplain. Placement of non-contahierized liquid hazardous vraste in a salt-dome, salt bed, underground mine or cave Is prohibited. PotentiaUy appUcable if in the vicinity of re- cent faulting or in a flcxxiplain. National Historic Preservation Act (NHPA) 16 U.S.C. § 470 40 CFR § 6.301(b) 36 CFR Part 800 For properties Usted on the National Register of His- toric Places, or eligible for such UsUng, requires that impacts on cultural resources be avoided. Where impacts are unavoidable, mitigation through design and data recxiveiy is required. PotentiaUy appUcable if portions of the Study Area are listed on Ihe National Register of Historic places or are eUgible for such listing. Archaeological and Historic Preservation Act 16 U.S.C. § 469 40 CFR § 6.301(c) 48 Fed. Reg. 44716 (Sep- tember 29, 1983) Requires actions to recover and preserve artifacts if alteration of terrain threatens significant scientific, prehistorical, historical, or archeological data. PotentiaUy applicable if significant scientific, prehistorical, historical or archeological data are present at the Study Area. Fish and WUdlife CcwrdinaUon Act 16 U.S.C. §§ 661-666C 40 CFR § 6.302(g) Requires actions to be taken to protec:l fish and wUd- Ufe lhat may lie impacted by a diveraion, channeling, or other activities to mcxlify a river or stream. CO O h-» O CO VO \WORK\24231\02\ARARS3.TAB HARDING LAWSON ASSOCIATES Tablo 4-3. Potontlal Location SpocMe ARARs Island Chemical Company St. Crofac, U.S. Virgin Islands Pago 2 of 4 Standard, Requirement, Criteria, or Limitation Citation Description Comment Endangered Species Act 16 U.S.C. §§ 1531. 1544 40 CFR § 6.302(h) 50 CFR Part 402 Requires action to conserve endangered spiecies and critical habitats upon which endangered species depend, includes consultation with Department of Interior. PotentiaUy appUcable if endangered species are present at the Study Area. Clean Water Act § 404 33 USC § 1344 Rivera and Harbore Act of 1899 • Dredge and Fill Permits 33 USC § 403 40 CFR Parts 230 and 231 33 CFR Parts 320-330 Prohlbita discharge of dredge and fill material Into navigable walera (including wetlands) of the United Slates vtrithout a permit. Substantive requirements are potential ARARs if the alternative developed involves discharge of dredge and fiU materials into the watera of the U.S. (including wetlands and ocean watera) EJcecnitive Order on Protection of Wetlands Exec. Order No. 11,990 40 CFR § 6.302(a) & Appendix A Requires action to avoid, to the extent possible, the advene impacts asscxnated with the destruction or loss of wetlands and to avoid new cxinstruction in wetlands if a practicable altemative exists. Potentially appUcable if wetlands are icxated within the site. Executive Order on Floodplain Management Exec. Order No. 11.988 40 CFR § 6.302(b) and Appendix A Requires evaluation of the potential effect of actions taken in a flcxxiplain and requires avoidance of the adverae impacts associated with direct and indirect development of a flcxxiplain. PotentiaUy appUcable if the site is in a flocxl plain. National Wildlife Refuges 16 U.S.C. § 668dd 50 CFR Part 27 Restricts activities vtrithin a National Wildlife Refuge. Potenttally applicable if portions of Ihe site are within a designated National Wildlife Refuge. CO O O O \WORK\24231\02\ARARS3.TAB HARDINQ LAWSON ASSOCIATES Table 4-3. Potential Location Speclfle ARARs Island Chemical Company St. Crofac, U.S. Vu^in Islands Standard, Requirement, Criteria, or Limitation Citation Description Comment Wild and Scenic Rivera Act 16 U.S.C. §§ 1271 1287 40 CFR § 6.302(e) 36 CFR § 297.4 Prohibits any project that would dUrectiy or indirectly impact any river designated in U.S.C. § 127(a) with- out notifying DOI or the Forest Service PotentiaUy applicable if rivere in the site, if any, are designated as "wild and scenic or roc^reational." Coastal Zone Management Act 16 U.S.C. § 1451, et.seq. Requires oonduc:l of ac:Uvities in a manner censistent with approved state management programs for activi- ties affecting the cxMtstal zone and adjacent shorelands. Potentially appUcable if the site or remecUal activities wiU affect the cxHistal zone. Clean Air Act (CAA) National Ambient Air Quality Standard (NAAQS) Attainment Area 42 U.S.C. § 7401 - 7642 40 CFR Part 52 NAAQS Non-Attahiment Area CAA § 173 Major stationary sources (i.e., those sources in the Prevention of Significant Deterioration (PSD) program vifith a potential to emit 250 tons per year (TPY) or more of a regulated poUutant unless the site centains sources identified in 40 C.F.R. § 52.21) in which case the threshold is 100 TI^, shall apply best avaUable control technology (BACT) for each regulated poUu- tant. Any stationary facUity emitting 100 TPY or more must obtain emissions offseta, apply lowest achiev- able emission rale (LAER), and aU major stationary sources owned or operated by the person In the state must be in cximpUance or on a schedule for cx>mpU- ance with all applicable emission standards. PotentiaUy appUcable if remedial activities create emissions of 100/250 TPY in an attain- ment area. Potentially appUcable if remedial activities create emissions of 100 TPY or more in a non- attainment area. CO O l-» O il^ M SL CroU. U.S. Virgin Isbnds Virgin Islands Conservation and Pres- ervation of Historic and Cultural As- sets Act \WORK\2 4231\02\ARARS3.TAB V.I. Code Annotated Tille 12 Chapter 3, Sub- chapter III Prohibits oonstruction and demolintion within any Historic and Architectural Control District without approval by the V.I. Historic Preservation Commis- sion. Substantive portions of the V.I. Conservation and PreservoUon of Historic; and Cultural As- sets Act and potential ARARs if portions of the sile are Usted in the V.I. Registry of Historic BuUdings, Sites and Places. HARDINQ LAWSON ASSOCIATES Table 4-3. Potential Location Specific ARARs Island Chemical Company St. Crofac. U.S. Viiguii Islands Standard, i^uirement. Criteria, or Limitation Virgin Islands Protection of Indige- nous, Endangered, and Threatened Fish, WildUfe, and Planta Act Virgin Islands Statute Pertaining to Trees and Vegetation Adjacent to Watercourses Virgin Islands Coastal Zone Manage- ment Act. Citation Description Comment V.I. Code Annotated Title 12, Chapter 2 V.i. Code Annotated Title 12, Chapter 3 V.I. Code Annotated Titie 12, Chapter 21 Prohlbita the injury, liarassment. or killing of indige- nous, endangered, or threatened specues. Prohibits the dismption of mangrove growth and nesta of any incUgenous or endangered species (inclucUng aU sea biids). Prohlbita the culling or injury of any tree or vegeta- tion within 30 feet of the center of any watercoiuse or 25 feet of the edge. Requires a cx)astal zone permit for any development (including dredge and fUl) in the cxnstal zone (all territorial lands and watera specified on approved maps). Potential ARAR if alternatives developed cxiuld have the prohibited impacts on indigenous, threatened or endangered species Usted by the V.I. Endangered Species Preservation Commis- Potential ARAR if altemative developed in- volves the emitting or injury of any tree or vege- tation near a watercourse. Substantive requirements are potential ARARs for any remedial activities cxxurring within a defined cxjastal zone. PolenUal ARARs are based upon Virgin Island Code Annotated (1993). Current regulations are nol readUy available C*J O O to \WORK\24231\02\ARARS3.TAB HARDINQ LAWSON ASSOCIATES Figures \WORK\2423l\02\WORKPLAN.REP HARDING LAWSON ASSOCIATES 301043 . HolyvCrosS- • \:-AZ/ / \ . .c^'^''--yyykAz^ V^-r--'^* W a t • • " • • • ^ - ' ^ - * . --^-... . .: T^k'yp.Z7'^ZyZ}tk t , Z ^ -4 -^.J^aRein )'" ' " ^ r Bethlehem 0)d-WorV:. );/;^__,-^;^V%^^ "'' --'-^\ ^"^^ " ' v \ ? 7 k y m z y p / y ^ ' 7 y y f ^ ^ ^ ^ ^ ^ z.A^M^mzy. Wy^^^zkMyz. \ Harding Lawson Associates i Engineering and i Environmental Services = = = = 7 . - 1 3 1 North Third Street S — S SSr " C PhiiocJelphio. PA 19106 " " " * • " " " 215-627-4505 SITE LOCATION MAP ISLAND CHEMICAL COMPANY S t Croix, U.S. Virgin Islands 301044 nCURE 2-1 ; DRAWN •JSW JOe NUMBER 24231.2 APPRC3VED FILE 24231AOI DATE 8/25/93 REVISED DATE i§@§i@§@§lilil (ZD Barm.. Tonk Form Concrats Pod M7 p - 2 Pad Poved n Septic Tank Sump Generator Building n • I R/O Unit and | — • Woter Storage • — ' P - 1 Cooting Tow«r 8 Outtlde Storage : \ open Reactor Area o O ^ QProceea BoHers Molntenqnce Building ' ' f ' ^ f Concrete Surfoce 3 Inlet 1 IIInlet 3 . . Process Pit O ^ Cooling Tower i 1 J O Concrete ^ O O - Surfoce I L, CO o o cn G e n e r a t o r a n d Fire P u m p Building 0^5—I 4.000 Col. 11 Storage TonksU I" ill "II 111 •II. D Septic Tonk Pit pjpiof GO^ - X - I » \ I LEOENP FENCE EXISTING PRODUCTION WELL EXISTING ABOVE GROUND STORAGE TANK TANK PAD-FORMER ABOVE GROUND STORAGE TANK LOCATION 25 SO too APPROXIMATE SCALE IN FEET ^SE MAP SOURCE ADAPTED FRQM: SOPOSEO ICC SOIL SAMPUNG LOCATIONS BY ENVIRO-SOENCES. INC. DATED: 6 / 1 9 / 8 8 ANO TE MAP. VI CHEMICAl, ST. CROIX. U.S.V.l. BY NUS CORPORATION DOCUMENT 0 2 - 9 1 0 1 - 0 4 - 5 1 . UNDATED ; Harding Lawson Aasoclates ; Chflneering end ! CnvlronflMMol S«fvlc«e * f " S 131 N«rth -tart SlTMl : . . ^ PTilUdalpM*. PA 1t10« • »i»-e»7-4aos ; JSW JOB NUUBCR 24231.2 SITE MAP ISLAND CHEMICAL COMPANY S t Croix, U.S. V i r g i n I s l o n d s 2-2 "SWSWtE- TCE 2423IB01 K l f 1/31/94 ytm.b e»ic SOURCE: USOA SoU Survey Virgin Islonds of the United Stotes ^ t FOR ILLUSTRATION PURPOSES ONLY ; H a r d i n g Lawson Associates ^ ^ ^ Engineering and S S i S Environmentol Services r • " 131 North Third Street ' * -Philodalptiio, PA 19106 •==-S 2 1 5 - 6 2 7 - 4 5 0 5 SOILS-MAP ISLAND CHEMICAL COMPANY ST. CROIX, U.S VIRGIN ISLAND FIGURE 301046 2 - 3 ; DRAWN ;jsw JOB NUMBER 24231.2 APPROVED RLE S-BASE DAT! 1/31/94 REVISED DATE 54* 4 8' 52' 64'50' 48' 4 6 ' 44 42' 6 4 ' X c .1 R I B B /.•; .•/ y SALT mVtH tJTUAUT CO O O SOURCE: LIDZ. B. H. 1988 I Hording Lawson Associates ! Engineering ond ! Environmental Services : i 3 1 North Third Street • PhIlo<Jelphla. PA 19106 • 215-627-4505 GENERALIZED GEOLOGIC MAP OF ST. CROIX ISLAND CHEMICAL COMPANY ST. CROIX. U.S. VIRGIN ISLANDS DRAWN HLB JOB NUMBER 24231.2.C.1 APPROVED FILE 24231A02 DATE 8/31/93 FIGURE 2-4 REVISED DATE Harding Lawson Associates ^ _ ^ ^ Engineering ond — — Environmentol Services . . t s 131 North Third Street _ _ - P h i l o d e l p h i o . PA 19106 • — S 2 1 5 - 6 2 7 - 4 5 0 5 APPROXIMATE LOCATIONS OF NEARBY WELLS ISUND CHEMICAL COMPANY ST. CROIX, U.S VIRGIN ISLAND 301048 FIGURE 2-5 ; DRAWN •JSW JOB NUMBER 24231.2 APPROVED FILE S-BASE DATE 1/31/94 REVISED DATE GODDQDDJDDDDGO CZD % S B B 1 / M W - 1 Concrete Pod •tf Pod Fenced Storage CO o H o vo / / ^ S B F l A/SBF2 A S B F 3 / / V ^ D 2 p / ^ ^ V j y Former Lob ^ ^ "Drain TTSBDS /^—Loading Dock / Surface Drain A X CD I — - \ 1 I AREAS OF CONCERN . LABORATORY ANO WAREHOUSE BUILDING B ABOVE-GROUND TANK FARM C FORMER PROCESS PIT 0 LOADING DOCK AND FORMER L A B P I T * DRAIN AREA E SOIL BENEATH CONCRETE PAD F CONCRETE STORAGE PAD LE;GgND PROPOSED MONITORING WELL LOCATIOI PROPOSED SOIL BORING LOCATION FENCE EXISTING PRODUCTION WELL EXISTING ABOVE GROUND STORAGE TANK TANK PAD-FORMER ABOVE GROUND STORAGE TAIIK LOCATION 25 50 100 APPROXIMATE SCALE IN FEET BASE MAP SOURCF ADAPTED FRQM: PROPOSED ICC SOIL SAMPUNG LOCATIONS BY ENVIRO-SCIENCES. INC. DATED: 6 / 1 9 / 8 6 AND SITE MAP. VI CHEMICAL. ST. CROIX. U.S.V.l. BY NUS CORPORATION DOCUMENT 0 2 - 9 1 0 1 - 0 4 - 5 1 , UNDATED I Harding Lawson Associates : Cn^n*«riny and : Envlrenm*ntot S«rv1e«« ^XTZ 1^^ **r*^ ^^^^ S1»«l : .m— P»*od.*pN«. PA i»ioe ; ns-«»7-«5oa ; bfiAWN JSW AREAS OF CONCERN ISLAND CHEMICAL COMPANY SL Croix. U.S. Virgin Islands 3-1 24231.2 ' U-thlMb m l 24231B01 ECTS 1/J1/9< "SWSTBT; ISUND CHEMICAL COMPANY PROJECT MANAGER Edward Nemecek R.G., C.P.G. FIELD OPERATIONS Jim Collins HEALTH &c SAFETY John Kohler ASSIST. PROJ. MANAGER Jason Schindler QA/QC Bharat Patel Brian LaFlamme AIN'ARS DEVELOPMENT Nettie Corrigan CO o o cn o HYDROGEOLOGY Jason Schindler Harding Lawson Associates I Engineering and ZZZ!Z Environmental Services r . t = i 3 1 North Third Street '**-Philodelphio, PA 19106 " 215-627-4505 PROJECT ORGANIZATION ISLAND CHEMICAL COMPANY ST. CROIX, U.S. VIRGIN ISLANDS ncuRE 6-1 DRAWN JSW JOB NUMBER 2423l.2.C.i APPROVED RLE 24231A01 DATE 2/14/94 REVISED OATE lASK 1 Projected Plonning and Monogement 1.1 Project Monagement 1.2 Meeting with USEPA 1.3 Subcontractor Bid Proceee 1.4 Monthly Progreee Reports 2 Bockground Investigation 2.1 Obtain ond Review Well Records 2.2 Obloln and Review Historical Aerial Photographs 2.3 OI>tain and Evaluate Existing Data 2.4 Obtain Inrormotlon on Potentiol Offsite Source Areos 2.5 Interview Former ICC Ennployees 3 Acquire Access ond Penults 3.1 Access Agreements 3.2 Well Oriirmg Permits 3.3 Customs Permits for Somples 4 Site Clearing and Reconnaissance 5 Field Sampling Program 5.1 Soil Sompilng Program Moblllzotlon and Soil Borfngs Loborotory Anolytlcal Tumoround Time 5.2 Croundwoter Monitoring Well Installation 5.3 Rehabilitate Existing Wells Well Development ond Equilibration 5.4 Survey 5.5 Quarterly Groundwater Sampling and Woter Level Monitoring Laboratory Anolytieol Turnaround Time 6 Date Validation 7 Doto Evaluation 8 Develop ARARs 9 Remedial Investigation Report 10 Management of Inveetlgotlon Derived Woste 10.1 Wests Sampling and Anolysis 10.2 Disposal Permission 10.3 Waste Removol m - g i @ m^ mm ^ S liBI @ tSl S m @ rsa : t3s • C2E t j g myiiTi 153 lull^ll ll •>a'wjft'"r.'8."i.i m ca ^ t s j I » i j i n I lj rniiTiiiiiKiinil 14 ijimji III Es^ffis^ss; c - ' - ' - ' - ^ • ' • ~ - • • " ' - - ^SSBJ^^^jS^ m tgfei ta IS . . S @ 'mm^ : ^m fcsgl m m m. mm CO o »-» o cn M Notes: 1. Schedule Is based on weeks from receipt of USEPA's approval of Work Plan. '- 2. Schedule assumes final access agreements will be obtained within two weeks of USEPA approval of Work Plan. Schedule wDI require revisions If agreements cannot be ol>tolned In this time frame. 3. Assumes weather reloted delays will not exceed 10 working days totol. ' I H o r d i n g L a w s o n A a s o c l a t e s : En5)ln««rfng tma : CmHronmentel Servlovs — t m . 131 Noflh 1>iJrd Str..t r - • •> PWladatoMo. PA ISIOS : 116-817-4503 •.Basm : JSW JU N I U H 24231.S.C.I WORK PLAN IMPLEME^^•ATION SCHEDULE ISLAND CHEMICAL COMPANY ST. CROIX. U.S. VIRGIN ISIANOS -JfftiSHS 7-1 Til 24231B03 — B A K — 2 / 1 5 / 9 4 ~iifXsa o*tC Appendix A Draft Sampling and Analysis Plan Island Chemical Company Site Remedial investigation St. Croix, U.S. Virgin Islands Prepared for Island Chemical Company, Inc. HLA Project No. 24231 2.C.2 Jason M. Schindler Senior Geologist Edward A. Nemecek, R.G., C.P.G. Principal Hydrogeologist March 17, 1994 Harding Lawson Associates 8 - . ts- rl Engineering and Environmental Services ^ " ^ ^ - ^ 131 North Third Street Philadelphia, PA 19106 - (215)627-4505 301052 Appendix A Sampling and Analysis Plan \WORK\2423i\02\WORKPLAN.REP HARDING LAWSON ASSOCIATES 301053 CONTENTS Al.O INTRODUCTION 1 Al.l Purpose and Scope 1 Al.2 Background 1 A2.0 FIELD INVESTIGATION PROGRAM 2 A2.1 Acquire Access and Permits 2 A2.1.1 Access 2 A2.1.2 Permits 2 A2.2 Site Clearing ; . . . . 3 A2.3 Site Reconnaissance 3 A2.4 Soil Sampling Program 4 A2.4.1 Hollows Stem Auger Drilling Method 4 A2.4.2 Soil Sample Collection Procedures 5 A2.4.3 Field Headspace Screening Procedures 6 A2.5 Monitoring Well Installation and Development 7 A2.5.1 Well Construction 7 A2.5.2 Well Development 8 A2.6 Rehabilitate Existing Wells 9 A2.7 Survey 9 A2.8 Groundwater Sampling 9 A2.9 Procedures for Splitting Samples with USEPA 13 A3.0 SAMPLE DESIGNATIONS 14 A4.0 FIELD MEASUREMENTS 15 A4.1 Turbidity, Dissolved Oxygen, Oxidation-Reduction Potential, Electrical Conductivity, pH, Temperature, and Purge Volume and Rate Measurements 15 A4.2 Flow Rates and Purge Volumes 15 A5.0 SAMPLE HANDLING AND ANALYSES 17 A5.1 Sample Documentation - 17 A5.1.1 Field Data Forms 17 A5.1.2 Chain of Custody and Requests for Analyses 17 A5.2 Sample Transport 18 A6.0 BIBUOGRAPHY 19 UST OF APPENDICES AA Field Documentation Forms AB Container Preservation, Packaging and Shipping Requirements AC Well Construction Details \WORK\24231\02\SAPJ^PP March 17. 1994 HARDING LAWSON ASSOCIATES A-i 301054 Al.O INTRODUCTION This Sampling and Analysis Plan (SAP) has been prepared by Harding Lawson Associates (HLA) on behalf of Island Chemical Company, Inc. (ICC). It responds to requirements set forth in the National Contingency Plan. As requested by the U.S. Environmental Protection Agency Region II (USEPA), this SAP has been prepared as an appendix to the Remedial Investigation Work Plan (RIWP) for this site. The RIWP includes the following activities: Review existing data; Acquire access approvals and permits; Clear the site of vegetation and preform a recoimaissance; Collect surface soil samples; Collect subsurface soil samples; Repair existing wells; Install new monitoring wells; Collect groundwater samples; and Survey wells and borings. The objectives of the aforementioned activities are presented in the RIWP. This Draft SAP has been prepared in accordance with the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, (OSWER Directive 9355.3-01 11988]), A Compendium of Superfund Field Operations Methods (OSWER Directive 9355-0-14 [December 1987]), and EPA National Enforcement Investigation Center Policies and Procedures Manual (EPA 330/978-001 [May 1978 revised November 1984]) and other documents noted in the References section. A1.1 Purpose and Scope The objectives of the SAP are to present details (including sampling, testing, and analysis protocols) necessary to guide persormel performing the tasks outlined in the RIWP. The SAP includes sample locations, methods, and procediues and a discussion of how the Plan will produce data useful for the remedial design. The SAP was written consistent v/iih USEPA guidance docmnents and recently approved SAPs for EPA Region II. The SAP describes the specific activities to be conducted under the RIWP and presents methodology for the field investigation. A1.2 Baclcground Information regarding the location, setting, history and previoTis investigative and remedial activities is discussed Sections 2 and 3 of the RIWP and is not repeated here. \WORK\24231\02^SAPJ^PP March 17,1994 HARDING LAWSON ASSOCIATES A-1 301055 A2.0 FIELD INVESTIGATION PROGRAM Plaimed field activities are as follows: Acquire Access and Permits Site Clearing Site Reconnaissance Soil Sampling and Monitoring Well Installation Groundwater Groimdwater Sampling Rehabilitating Existing Wells Surveying Well Locations and Elevations These tasks will be performed sequentially. Field activities to be conducted are summarized in the following subsections by type of activity. A2.1 Acquire Access and Permits A2.1.1 Access The follovmig general procedure will be followed to obtain access to private property for the purposes of completing Remedial Investigation activities such as well installation. 1. Contact the Township of Christiansted to obtain a listing of landowners' telephone nimibers and addresses. 2. Contact landowners to achieve the foUowing: • Describe the Remedial Investigation program and the piirpose of the requested access • Record the correct name, address, and telephone number of the landowner(s). 3. Perform a field check of selected locations checking for the following: • Physical access • Hydrologic access and advantages/disadvantages (i.e., avoid tops of hill and bedrock highs) • Adjust locations if required and where appropriate 4. Prepare a detailed information package and letter agreement that includes the name, address, and telephone nvunbers of the ovvnner(s) and the map locations and legal description of the property. 5. Contact the landowner(s) to review the paperwork, and obtain and witness their signatuTe(s) and tell the landowner(s) when work is anticipated to start. A2.1.2 Permits At this time, several permits have been identified which may be required to initiate or complete Remedial Investigation activities. Permits and procedures to obtain them are discussed in the Section 5.3.1 of the RIWP. The following Remedial Investigation activities are expected to require permits and/or approvals: • Installation of monitoring wells \WORK\24231\02\SAPJ\PP March 17,1994 HARDING LAWSON ASSOCIATES A-2 zxiyjdii: 301056 • Shipment of samples to continental United States • Disposal of water and soil generated during field activities Throughout project implementation, planning of activities will be made with regard to permit requirements and regulatory time frames. HLA will coordinate with federal and local agencies to ensure compliance with applicable regulations and v^dll attempt to accelerate the permitting process as specific permit requirements are identified. A2.2 Site Clearing The ICC site has been ioactive for several years. Diuing that time, heavy vegetation has covered much of the site. The heavy vegetation obscures much of the site and impedes access to work areas, making a detailed inspection impractical. Prior to field investigation activities, HLA will contract a local firm to clear the site of heavy vegetation. Site clearing will not include vegetation within 25 feet of the River Gut as required under the Virgin Islands Statute pertaining to trees and water courses (see RIWP). A2.3 Site Reconnaissance In preparing work docviments, HLA conducted a preliminary review of information made available by ICC and the USEPA and performed a brief site visit. Based on this review, a more complete evaluation of existing data is required to provide a basis for further investigation and other activities, if necessary. HLA will obtain available background data for the ICC site and adjoining properties as discussed in Section 5.2 of the RIWP. A detailed site inspection vidll be performed after the vegetation is cleared. The site reconnaissance will include visual inspection of the following areas: Area A - Laboratory and Warehoxise Buildings; Area B - Above-Ground Storage Tank Farm; Area C - Former Process Pit; Area D - Loading Dock and Former Lab Pit Area; Area E - Concrete Pad Near ASTs; Area F - Concrete Storage Pad; Storm Drains and River Gut; Sump; Septic Tanks; Dryer Building; 4,000-Gallon AST Area; Former Location of Paint Cans and Drums; Other onsite structures including the Generator Building, R/O Unit and Water Storage Building; Cooling Towers; Generator and Fire Pump Building; Maintenance Building; Reactor Area and Process Area. Edges of paved areas and drains; Property boundaries; and Other areas, if any, identified during the Backgroimd Investigation (see Section 5.2 of the RIWP). The areas will be inspected for evidence of residual waste, staining, spillage, potential asbestos containing materials and other possible sources of environmental concern. \WORK\24231\02\SAP~APP March 17, 1994 *.' p n n p » \j> KJ tJ Q HARDING LAWSON ASSOCIATES A-3 301057 A2.4 Soil Sampling Program Ten soil borings will be completed to obtain supplemental data on the geology of the site and to collect soil samples for laboratory analysis. The proposed boring locations are shown on Figure 3-1 of the RIWP. Boring locations and rationale are discussed in Section 5.5.1 of the RIWP; however, soil boring locations may be altered based on the results of the Background Investigation and the Site Reconnaissance. Soil borings will be completed in overburden, and will be drilled using the hollow stem auger drilling method (Section A2.4.1). Sampling methods are discussed in Section A2.4.2. Soil samples will be screened in the field for the presence of volatile organic compounds (VOC) using a flame- or photo- ionization detector (FID or PID) as described in Section A2.4.3 to establish appropriate sample collection depths. Samples will be analyzed using Contract Laboratory Program (CLP) protocol by a CLP participating laboratory. A2.4.1 Hollow Stem Auger Drilling Method The hollow stem auger drilling method wiU be used for all borings and wells. Drilling proceduires will follow USEPA's A Compendium of Superfund Field Operations Methods (USEPA, 1987a). Soil borings will be advanced using a truck-mounted drilling rig capable of rotating a drill bit into the subsxuface on a string of hollow stem augers. Drill cuttings will be continuously lifted to the sinface on the outside of the auger flights while rods and a plug are used inside to prevent material from entering the interior of the augers. The plug will be removed for split-spoon sampling. Soil samples for lithologic, field screening and/or chemical analyses will generally be collected at continuous intervals to 10 feet and at 5-foot intervals past 10 feet, using a 2-inch outside diameter (O.D.) split- spoon sampler. Drilling equipment will be decontaminated by steam cleaning and a potable wash, in accordance with USEPA procedures (1989a). Sampling equipment will be decontaminated as described in the Quality Assurance Project Plan (Q/VPP) (Appendix C). Soil cuttings, water derived from development and decontamination activities and spent personal protective equipment vidll be contained onsite in 55- gallon driims. Drummed investigation-derived waste will remain onsite until proper disposal arrangements can be completed. Soils will be logged imder the supervision of an HLA geologist or engineer, iising the Unified Soil Classification System. Split-spoon samples wall be screened to evaluate the presence of VOCs in the soil as described in Section A2.4.3. This screening v^dll be used as a basis for selection of samples for soil chemical analyses. Five of the soil borings will be completed as described in Section A2.5. The remaining five borings will be abandoned using a 2 percent bentonite/Type II Portland cement slurry. The slurry wUl be emplaced using a tremie pipe after the augers are removed. The drilling rig and augers wUl be decontaminated upon mobUization, between soU boring locations, and prior to demobUization to prevent cross-contamination. DrUling equipment wUl be decontaminated by steam cleaning and/or a potable water wash. Sampling equipment wiU be decontaminated in accordance with the following eight-step procedure as described on page 38 of the USEPA Region II CERCLA Quality Assurance Manual (1989a): 1. Wash and scrub wnth low phosphate detergent; 2. Tap water rinse; \WORK\24231\02\SAPAPP March 17.1994 HARDING LAWSON ASSOCIATj^S A-4 V»r^yO£, I 301058 3. 4. 5. 7. 8. Rinse with 10 percent nitric acid; Tap water rinse; An acetone orUy rinse or a methanol rinse followed by hexane rinse (solvents must be pesticide grade or better); Thoroughly rinse with deionized analv-te-free water. The volume of water used during this rinse must be at least five times the volume of solvent used in step 5. Air dry; and Wrap in aluminum foU for transport. Tap water may be from any municipal water treatment system. The use of an untreated potable water supply is not an acceptable substitute. If metals samples are not being collected, steps 3 and 4 may be omitted. If organics samples axe not being taken, steps 4 and 5 may be omitted. When it is necessary to use split-spoon sampling devices which are composed of carbon steel instead of stainless steel, the nitric acid rinse may be lowered to a concentration of one percent instead of ten percent so as to reduce the possibUity of leaching metals from the spoon itself. A2.4.2 Soil Sample Collection Procedures SdU'sample's obtained for chemicalor lithologic description pvuposes wdU-be collected using split- spoon samplers. The spUt-spoon sampler is a thick-walled steel tube that is spUt lengthwise. A cutting shoe is attached to the lower end; the upper end contains a check valve and is connected to the drill rods. When the boring is advanced to the point that a sample wall be taken, the drUl rods will be removed and the sampler wUl be lowered through the hoUow-stem augers to the bottom of the boring. The sampler wdU be driven 24 inches into the ground in accordance wdth the American Society for Testing and Materials (ASTM) publication 1586-87 (1974). A conventional 140-poimd hammer will be dropped from a height of 30 inches onto the sampling assembly. The blow counts necessary to drive the sampler wall be recorded in the boring log in 6-inch intervals. A blow count of 50 for less than 6 inches of movement or 100 for 18 inches woU be considered refusal. SpUt-spoons wall be decontaminated prior to each use. Decontamination procedvires and quality assvuance protocol are discussed in the QAPP (Appendix C). A field geologist or engineer wdU keep a detaUed sample log for each borehole. The standard reporting sheets for soU borings are included in the Appendix AA. Information recorded will include the followdng; drilling contractor and drUler's name name of geologist or engineer maintaining the log boring designation and location drilling and sampling method date spUt-spoon sample depth blow counts length of sample recovered classification of the soU recovered as per the Unified SoU Classification System (based on factors including color, particle size, sorting, structure, plasticity, moisture content, stratification, cementation) Observations of changes in drUling speed and driU rig performance which could indicate differences in subsurface conditions, wUl also be noted. The field geologist or engineer wUl monitor drilling progress. \ W O R K \ 2 4 2 3 1 \ 0 2 \ S A P A P P March 17, 1994 HARDING LAWSON ASSOCIATES A-5 Vi]iiOB 301059 describe samples as detailed above, collect analytical samples and decontaminate the split-spoons in accordance with the following protocols: 1. The drUler wUl advance the augers to the desired sampling depth. A clean split-spoon sampler will bo given to the driller by the field geologist/engineer, both of whom will be wearing clean, disposable gloves. 2. The sample wUl be coUected by the drUler using the standard penetration method for split- spoon samples. 3. The field geologist/engineer \vUl take the split-spoon sampling device from the drUler and place it on clean polyethylene sheeting. 4. The end cap wall be unscrewed and the split-spoon opened. 5. Sample material wUl be placed into laboratory-prepared sample containers using a decontaminated staiiUess steel trowel or spatula. Decontamination procedures are discussed in the QAPP (Appendix C). Sample containers, preservation methods, packing and shipping requirements are summarized in Appendix AB. Sample material to be analyzed for VOCs wUl be collected first. 6. After the sample containers have been filled, a portion of the sample material wUl be placed tn a clean, resealable plastic bag for field screening as described in Section A2.4.3. 7. If insufficient sample material is obtained to adequately fUl the sample containers or for field screening, the split-spoon will be driven into the boring a second time, in an attempt to collect additional sample material from the selected depth interval (i.e. immediately below the selected sampling depth). 8. Excess sample material wUl be handled with the drUl cuttings. 9. The sample label wUl be completed as discussed in the QAPP, attached to the sample container, and covered wdth transparent tape. 10. The HLA sample log form wall be completed along wdth chain-of-custody documentation for each sample selected for laboratory submittal. Appendix AA contains copies of these forms. 11. Each sample scheduled for laboratory analysis will be preserved by cooling to 4°C using ice packs or wet ice and shipped to the laboratory via an overnight courier. 12. The sampling equipment wUl be decontaminated as described in the QAPP (Appendix C). A2.4.3 Field Headspace Screening Procedures SoU samples wUl be screened for VOCs using the followdng procedures. 1. Sample material to be screened wUl be collected after sample containers for all other parameters are secured; 2. The sample wall be placed in a clean, resealable plasUc bag (such as an unused Zip-Loc^' bag) and the bag wUl be sealed; \WORK\24231\02\SAPjyP March 17, 1994 HARDING LAWSON ASSOCIATES A-6 Vi^OO€ 301060 3. The sample material will be allowed approximately 15 minutes to one hour to reach approximate ambient air temperature; 4. The bag's seal wUl be broken and the probe of the PID or FID will be inserted. Care will be taken to limit the infiltration of ambient air by opening the seal only sufficiently to allow the instrument's probe to penetrate. 5. A duplicate headspace sample wdll be prepared for every 20 samples to assess the precision of the measxu'ements. The relative VOC concentration within the bag headspace wdll be read directly from the instrument and recorded in the field notes. The used sample material wdll be placed in the driuns wdth the drUl cuttings. A2.S Monitoring Well Installation and Development A2.5.1 Well Construction Five of the soU borings will be completed as groundwater monitoring wells. The wells wdll be constructed-such that .the screened, interval .intercepts the firs.t water bearing zone encountered (anticipated to be approximately 20 feet below grade). Proposed weU locations are showai on Figure 3- 1. however, these locations may be subject to change based on the results of the Background Investigation or the Site Reconnaissance. USEPA wdll be advised immediately, if proposed locations are altered more than 5 feet. Prior to the installation of any monitoring weUs, the proper St. Crobc Department of Planning and Natural Resomrces (DPNR) weU permits wdll be obtained (see Section 5.3.2 of the RIWP). The DPNR and USEPA wdll be informed by telephone two weeks prior to initiation of drUling to give them an opportunity to observe the well installation. The wells wdll be constructed using 10 foot lengths of schedule 40, flush-jointed, threaded PVC. The screened section wdll consist of 0.020-inch factory-slotted pipe installed approximately 5 feet above and 5 feet below the water table. A minimum annular clearance of 2 inches wdll be provided for final well construction. Riser pipe and screen wdll be steam cleaned prior to use in the weU. The bottom of the weU wdll be capped wdth a stainless steel or PVC bottom plug. The weU wdll be constructed using the followdng procedures: 1. The boring wdll be advanced five feet below the water table as initially encountered during drUUng; 2. The drUl rods and plug wUl be removed from the augers and the decontaminated screen and riser wUl be inserted through the augers to the bottom of the boring. The top of the well casing wdU be capped. 3. The drUler wdll back the auger out of the hole five feet or less to expose the annulus around the screen. 4. Nmnber 2 Jessie Morie^^ sand (or equivalent) wdll be poured slowly through the augers into the armtUus around the lower portion of the well screen. The sand level wdll be measured periodically, as it settles through the groundwater, using a properly decontaminated weighted tape. When the sand has reached the bottom of the augers, the drUler will back the auger out \WORK\24231\02\SAPJVPP March 17. 1994 HARDING LAWSON ASSOCIATES A-7 ^•eso£ 3,,o6i • 5. 7. 8. another 5 feet. This process wdll continue until approximately 2 feet of sand is accumulated above the screen interval. After installation of the sand pack, one to two feet of bentonite pellets will be poured into the hole utilizing the same method as for the sand pack. Approximately 5 gallons of potable water will be poured into the hole after the bentonite pellets to cause them to swell and seal the annular space above the sand pack. At least 1 hour wall elapse to enable the bentonite pellets to sweU properly. After the pellets have been allowed to swell, the augers wdll be removed from the hole completely and the remaining annular space wdll be filled wdth a 2 percent bentonite/Type n Portland cement slurry emplaced using a tremie pipe. The bentonite/cement slurry wUl extend to approximately three feet below grade. Pre-mixed concrete (such as Sacrete'™) wdll be emplaced over the cement-bentonite slurry. A steel protective casing wdth a locking cap wdll be set approximately 2 feet into the concrete mixture. The casing will be permanently marked wdth the weU designation and DPNR permit number. 10. The wells wdll be allowed to set for a 24-hour period to allow the cement slurry and concrete time to cure. 11. Followdng the waiting period, the wells wdll be developed as described in Section A2.5.2. Site persormel wdll stay clear of the well during development and wdll monitor breathing space using an FID or PID dming development. Personnel Protective Equipment levels wdll be commensurate wdth vapor levels recorded and compared to the action levels reported in the HASP (Appendix B). Development wdU continue for one hour or imtU the well discharge is free of visible sediments. Typical overburden monitoring well construction detaUs are showm in Appendix AC. A2.5.2 Well Development Followdng the 24-hour waiting period, the new monitoring weUs wdll be developed by pumping and surging. BaUing may also be performed if the amount of sediment is great. The water level in the weU wdll be measured prior to initiating development. Dvuing development, pumping wdU be performed alternately wdth surging. Turbidity, conductivity, pH, and temperature wdll be measured periodically during pumping. In general, the well wdll be pumped untU turbidity has decreased to a field determined level and pH, conductivity and temperature have stabUized. Pumping wdll then be discontinued and the well wdll be svirged. FoUowdng surging, pumping wdll be resumed. This process wdll be repeated untU the discharge water has a turbidity of 10 NTUs (nephelometric tm-bidity units) or less or remains stable through a period of surging. Conductivity, pH and temperature should also stabUize prior to cessation of development. If turbidity, conductivity, pH and temperature do not stabilize, the wells wdll be pumped for a period of one-hour or untU up to 100 gallons of water have been removed. Site persormel wdll stay clear of the well dming development and wdll monitor breathing space wdth a PID throughout. \WORK\24231\02\SAP.APP March 17. 1994 HARDING LAWSON ASSOCIATES A-8 301062 A2.6 Rehabilitate Existing Weils Two wells are present onsite. The age and construction of these wells is unknown. The wells wdll be modified as described in Section 5.5.3 of the RIWP. If possible these wells will be used to supplement water level data. The wells wUl be developed as described in Section A2.5.2. A2.7 Survey The relative locations and elevations of the new monitoring weUs and the rehabilitated existing weUs wiU be surveyed by a Ucensed surveyor. Elevations surveyed wiU include the inner casing, outer casing and groimd elevations. The surveyor wdll record the latitude, longitude, and elevation of the ground surface, top of weU casing wdth the cap off, and the top of the inner casing. Elevations wdll be measured wdth respect to mean sea level (MSL). Locations wdU be measured wdth respect to an assigned onsite benchmark. The surveyor wdU notch the inner casing to indicate the exact location surveyed. If practicable, the casing wdU be surveyed on the northern side. A2.8 Groundwater Sampling Groimdwater sampling wiU be performed approximately two weeks following well installation and development. Prior to sampling, water level measurements wiU initially be taken at the five new and two existing wells (Figure 3-1 of the RIWP). Procedures for water level measurements are described below. Groundwater samples wdll be collected from the five new monitoring weUs. Samples may also be coUected from the rehabilitated existing weUs. The groundwater samples wdll be analyzed for Target Compound List (TCL) VOCs, semi-volatUe organic compounds (SVOs), pesticides and PCBs, both total and dissolved Target Analyte List (TAL) inorganics, and pyridine. BEFORE ENTERING THE FIELD • Project objectives and quality assurance procedures, sampling locations, sampling procedures, preservation, packaging and shipping requirements, and analytical parameters wdll be reviewed wdth field personnel. • Previous water level measurements for each well, if avaUable, wdll be reviewed before leaving for the site, and a siunmary of previous water level data wdll be taken to the field. • Health and safety procedures wdll be reviewed with aU persormel. • A listing of wells to be sampled and analyses to be performed by the CLP protocol wdll be prepared and transmitted to the laboratory. • All field equipment wdl be tested to ensure that it is operating properly. Because of the remote location of the site, duplicate instruments wdll be mobiUzed to limit dowoi time due to possible equipment malfunction. • The laboratory wdll provide clean glassware required to collect the samples. The glassware wdll include required preservatives and a list of which preservatives correspond to each analyte wdll be included with the glassware. The laboratory wdll provide sufficient glassware and/or \WORK\2423l\02\SAPAPP March 17,1994 HARDING LAWSON ASSOCIATES A-9 y. A {\ ft P ^ " ^ ' ' ' ' 301063 samples for trip blanks, field blanks, and/or duplicate samples to be collected at the frequency described in the QAPP. IN THE FIELD 4.- 5. 7. 9. 10. 11. Sampling crews, consisting of two experienced geologists, hydrogeologists, or field technicians, wdll receive labeled sample kits from the field manager and wUl confirm that the kits contain appropriate sample bottles, preservatives, fUter pumps, ice, sample labels, chain-of-custody records, and weU completion information. Before purging or sampling each weU, equipment wdU be decontaminated. Decontamination of pimips wdll include rinsing the pump and tubing wdth soapy water and deionized water before use. For baUer decontamination, USEPA's eight-step procedure, described in the Region U Quality Assurance Manual, wUl be followed (see Section A2.4.1). Well number, date, pertinent observations (e.g., weather, well condition), station elevation, casing diameter, screened interval, and field instrument identification wdll be recorded on groundwater sampling forms (Appendix AA). Momtorinig iiistruinentswdU'be'cahbrated'against'knowm standards before rnaking well • • measurements (generaUy calibrated once per day). CaUbration wdll be recorded in field caUbration data sheets as included in Appendix AA. The weU wUl be uncapped from the upwdnd direction and a PID or FID wdll be used to record relative VOC concentrations upwdnd from the weU, at the top of the casing and wdthin the well casing. Procedures for use of the FID or PID wiU be consistent wdth the manufacturer's manual, which may vary sUghUy from model to model. The manual wdll be kept onsite at all times during equipment use. The first time a weU is sampled, the depth wdll be verified prior to sampling. This allows the sampling team to calculate the volume of water in the well and to determine if formation material has accumulated in the weU. The well depth wdU be measured to an accuracy of 0.1 foot wdth a steel tape with a steel weight secured to the end. The tape and weight wdll be decontaminated prior to use. Depth to water wdll be measured using cui electronic interface probe. The probe wUl be lowered into the weU untU a contact wdth the water surface is indicated by an electronic signal. The tape wdll be marked or held at the measuring point. The electric tape wdll be checked to ensure that it has not been cut by a sharp casing edge after it is placed in and removed from the well. The distance from the mark to the nearest tape band or marker wdll be measured by using a folding ruler. The depth to water to an accuracy of 0.01 foot wdll be determined. The probe wdll then be lowered below the water table and raised untU the signal indicates that the probe us above the water table. The depth to water wdU be measured again as described in steps 10 through 12 above. \WORK\24231\02\SAP~APP March 17, 1994 HARDING LAWSON ASSOCIATES A-10 eeuo 301064 12. The water-level elevation relative to mean sea level (MSL) wdll be determined by subtracting the depth to water from the surveyed top of casing elevation (measuring point). Measurements at each well wdll orUy be taken at the marked survey point on the iimer casing and wdll be repeated untU two consecutive measurements are obtained that agree within ±0.02 foot. Water level measurements wdll be recorded on water level measurement forms (Appendix AA). WeU identification, date, time, depth in feet to groundwater and remarks relevant to groundwater level measurements wdll be noted. Previous water level measurement for the well wdll be checked. If the difference between the current water level and the previous month's water level Is greater than one foot, the water level wdll be remeasured. 13. The volume of water (equal to three times the volume of standing water) to be removed from the weU casing prior to coUection groundwater samples wiU be calculated using the foUowing equation: V = irr'h where: V = well volume (ft') ir = 3.1416 r = weU radius (ft) h = column of water in the weU (total depth minus depth to water) (ft) 14. The weUs wiU be purged using a standard centrifugal or submersible pump or using a stainless steel or a Teflon^*^ baUer. Except as discussed in Step 16, a minimum of three weU volumes of water will be purged from each weU before sampling. 15. Field measurements of specific conductivity, temperature, and pH wdll be taken after each purged weU volume and before sampling. Calibration and operation and maintenance procedures for the conductivity, temperature and pH meters wiU be consistent with manufacturers' specifications. PID readings, pumping rate, cumulative purged volume, and time will also be recorded for each purged volume. Field measurements wdU be used to evaluate the stabilization of parameters to ensure the weUs have been sufficienUy purged. StabUization is defined as less than 10 percent variaUon between two successive measurements. 16. If a well is pumped or baUed dry before three weU volumes have been removed, weU purging activities wdU be halted and the weU wdll be aUowed to recover sufficiently to permit sample coUection. Efforts will be made to avoid pumping or bailing the wells dry. Purge rates wdU be lowered if insufficient recharge is occurring. Samples wdU be obtained wdthin a 3-hour period after purging and two hours after evacuation is completed to mmimize loss of volatUe constituents. 17. If the parameters measured during development (see Step 16) do not stabilize, a maximum of five weU volumes wdll be purged. 18. Data on method and amount of water purged wdll be recorded on a groundwater sampling form (Appendix AA). 19. Water purged from the monitoring weUs wdU be coUected and stored at the site in properly labeled 55-gallon drums. The information specified on the drum label(s) wiU include, at a minimum, the date and well number(s) corresponding to the wells from which the water was removed. The water wdll continue to be stored on-site in accordance wdth applicable Resource \WORK\2423l\02\SAPjyP March 17,1994 HARDING LAWSON ASSOCIATES A-11 - V i j 301065 Conservation and Recovery Act requirements until an appropriate treatment or disposal method is identified. The disposal methods \vi\\ depend on the concentrations and nature of constituents in the water. Potential disposal methods may include discharge to a publicly owned treatment works, surface water, or off-site transportation and disposal, as permitted. 20. If a sampling pump is used to purge the monitoring wells, it wdll be properly decontaminated and samples wUl be collected directly from the pump discharge at a low flow rate to avoid agitating samples. Teflon™ tubing wdll be used if the same sampling pump is to be used for both evacuation and sampling. 21. Samples wdll be coUected using decontaminated, stainless-steel or Teflon^^ bottom-filling baUers or a sampling pump. Dedicated cords wiU be used at each weU. BaUer cords wdll be stainless steel, single-stranded wdre, polypropylene monofUament or Teflon'™-coated wire, and wdll be cleaned with soap and water before use. 22. Except as noted in Step 23 and in Section A2.9, groundwater samples wdll be transferred directly from the baUer to the sample containers. VOC vials wdU be filled in a maimer that minimizes head space or air bubbles. Samples for VOC analyses wiU be collected first. VOC sample vials wdll be fUled to capacity and tightly capped to avoid retention of air bubbles. Remaihiiig sainple cohtaihers wiU be' filled to approximately' 90' piercerit of capacity;' VOC sample containers wdU be preserved and fiUed according to EPA Region II CERCLA QuaUty Assurance Manual protocol (p. 31) as follows: a. b. c. d. Collect three 40-millUiter vials of sample for VOC analysis. Adjust the pH of one of the vials to < 2 by carefuUy adding 1:1 HCl drop by drop to the required two 4d-milliUter VOA vials. The nimiber of drops of 1:1 HCl required should be recorded. The first vial may then be discarded. Carefully add the same number of drops to the remaining two vials to be submitted for laboratory analysis. (The pH in the two vials for laboratory analysis should not be tested direcUy.) Seal the vials. The pH test is to be performed at each sampling location. 23. 24. 25. A fresh sample wdth a fresh preserved vial wdll be collected if an air bubble is detected in a VOC sample vial after sampling is complete. Field-fUtered samples wdll be obtained for analysis of metals where required. A 0.45-micron fUter of compatible inert material wdll be used in filtering the samples. The fUtering device wdU be either an in-line fUter or pressure filter apparatus. A daUy rinse blank of the filtering apparatus wdll also be performed. Preservation of samples to be analyzed for metals wiU be conducted after fUtering. Immediately after fUling, samples wdll be placed in storage coolers on ice. Samples wdll be checked periodicaUy wdth a thermometer to ensure preservation requirements are met. The temperature of the samples wdll also be recorded by the laboratory upon receipt. Sample depth wiU be recorded, the groundwater sampling field data sheet wdU be completed and signed, and the chain-of-custody form wdll be signed. 26. The well cap wdll be closed and the well wdll be locked. \WORK\24231\02^SAP.APP March 17. 1994 ^^OOE HARDING LAWSON ASSOCIATES A-12 301066 27. The baUer line, gloves, and sheeting wdll be disposed in a proper marmer, and the bailer wdll be decontaminated and waapped in clean aluminum foU between uses. Surgical gloves will be changed between each sample location. The portion of the water level probe or steel tape that has been in contact wdth the well water will be cleaned in detergent and water, and rinsed with tap or distUled/deionized water prior to use at each well. Quality assurance/quality control (QA/QC) samples are discussed in the QAPP (Appendix C). The water level elevation relative to MSL wdll be calciUated by subtracting the depth to water from the elevation of the surveyed top of casing elevation measuring point. Newly acquired water level data wdU be compared with current and past water level data. Hydrographs for each well wdU be prepared and updated. A2.9 Procedures for Splitting Samples with USEPA USEPA or their oversight contractors may require spUt-samples. Solid or aqueous samples requested for spUtting by USEPA must be homogenized prior to distribution between HLA and USEPA sample containers. All sampling, homogenization, and fiUing of containers wdll be performed by HLA persormel. HLA wdU provide USEPA at least two weeks noUce in advance of any sampling activities. Sample containers for split samples wdll be provided by USEPA. USEPA wdll be responsible for handling, packaging and shipping of spUt samples. Solid samples being collected for volatUe organic analysis cannot be spUt. Samples for volatUe analyses must be coUected as co-located grab samples, as grab samples from the same spUt-spoon, trowel, or grab samples from other sampling devices. For aU remaining soUd sample analyses, a large enough sample volume must be procured to fill all necessary sample containers of both parties. FoUowdng the collection of the VOC porUon of the sample, the remaining sample volume wdll be placed in a staiiUess-steel bowl and thoroughly homogenized with a staiiUess-steel spatula or trowel. Sample aliquots for the remaining analyses (non-volatUe) wdll then be distributed to HLA's and USEPA's sample containers. Aqueous samples orUy require homogenization if heterogeneity is suspected. Again, sample aliquots for volatUe organic compound analysis are not to be homogenized. HLA and USEPA 'sampling representatives wdll jointly decide if homogenization is required for a particular split sample location. In the event of a dispute, USEPA or its representatives will make the final determinaUon. Homogenization is encouraged in questionable circumstances. A large (2 to 4 liter) glass container wdll be used to transfer the aqueous sample from the sample-collection device. When a sufficient volume has been procured to fUl all necessary HLA and USEPA containers, the sample aUquots wdll be dispensed to both parties. Aqueous samples for volatUe organic analysis wdll be collected as co-located grab samples. If sufficient volume is procured in the collection device the volatUe vials wdll be fUled concurrently from the same aliquot source. Both parties must document in their respective field books the sample identification numbers each party is using so that the results can be accurately cross-referenced in the future. \WORK\24231\02\SAPAPP March 17. 1994 HARDING LAWSON ASSOCIATES A-I 3 ^008 30^°^"^ A3.0 SAMPLE DESIGNATIONS HLA wUl use a standardized nomenclature for all samples coUected, and each sample wdll be assigned a unique name. Groundwater samples will be designated by the name of the well from which they are coUected and the date (sLx digit number indicating the calendar month, day and year) on which they are collected. For example a groujidwater sample collected from monitoring well MW-1 on August 1, 1994 would be designated MW-1/080194. SoU samples from soU borings wdll be identified by the prefix "SB" followed by the area of concern, the boring location wdthin that area, location of the soU boring sampled followed by the sample depth (measured in feet below grade) and the date. As an example a soU sample collected from 8 to 8.5 feet below grade in the first soU boring from Area B on March 1, 1994 would be designated SBBl/8.0- 8.5/030194. Quality assurance/quality control (QA/QC) sample designations wdll indicate the type of QA/QC sample, date collected, and for rinse blanks, the matrix of the associated environmental samples, following abbreviations wdll be used in addition to those listed above: The TB Trip.Blank RB Rinse Blank MS/MSD Matrix SpUce/Matrix SpUce DupUcate GW Groundwater SO SoU For example, a rinse blank collected during a groundwater sampling event on March 1, 1994 would be designated RBGW/030194, and a trip blank for that event would be designated TB/030194. Laboratory blind dupUcate samples wdll be designated the same as the dupUcated sample, but the digits "10" wdll be placed in front of the well number or sample location designation. For example, a laboratory blind dupUcate of a sample from well MW-2 collected on March 1, 1994 would be designated MW-102/030194. SimUarly, a dupUcate soU sample SBBl/0.0-0.5/030194 would be designated SBBlOl/0.0-0.5/030194. \WORK\24231\02VSAP.APP March 17. 1994 ziPA^^I^ '^ ,1 '' fi X J k ' K> HARDING LAWSON ASSOCIATES A-14 301068 A4.0 FIELD MEASUREMENTS A4.1 Turbidity, Dissolved Oxygen, Oxidation-Reduction Potential, Electrical Conductivity, pH, Temperature, and Purge Volume and Rate Measurements The field parameters turbidity, dissolved oxygen and oxidation-reduction potential wdll be measured while purging groundwater at each sampling location by using either an in-line device or external meters. Conductivity, pH and temperature wdll be measiu-ed prior to sample coUection using either an in-line device or conductivity, pH and/or temperature meters and/or a thermometer. In-line monitors will be flushed wdth potable or deionized water prior to use. The probe(s) on the meters wdll be thoroughly rinsed wdth deionized water prior to use. The pH meter will be recaUbrated using two standard buffer solutions before each use. The conductivity meter will be caUbrated before leaving the office and then onsite prior to the start of the sampling event using 200 /imhos/cm and 1000 /xmhos/cm or equivalent solutions. Calibration procedures for the in-line monitoring device and the various meters to be used wiU be in accordance with manufacturer's instructions and are discussed in the QAPP. Flow rate for low flow pumps wiU be measured by measuring wdth a stopwatch the time required to fiU a container of known volume. Flow meters wdll be used to measure the flow rate of standard submersible or centrifugal pumps. The flow meter wdll be caUbrated wdth a stop watch and 5- to 15- gaUon container during initial purging of the first weU to be sampled. The flow meter wdU he caUbrated for flow rate by starting the stop watch at an iniUal volume then stopping and stopping the watch at a later knovra volume. This wdll give the time, in minutes and seconds, that it took to discharge the known volume of water from the weU. The rate of discharge in gallons per minute (gpm) can then be calculated. Manufacturer instructions for use of the in-line monitoring device and meters wiU be foUowed and wdU be available for use in the field. Measurements made with external meters wiU be made direcUy at the weU discharge point. Procedures for measurements using these meters and measurement of flow rates consist of the foUowdng: • The monitoring chamber(s) and probe(s) wdU be rinsed wdth weU water prior to recording measurements. • Purge volumes and rates wdU be read directly from the calibrated flow meter. A4.2 Flow Rates and Purge Volumes Flow rate for low flow pumps, if used, wdll be determined by measuring the time required to fUl a container of known volume. Flow meters wdll be used to measure the flow rate of standard submersible or centrifugal pumps. The flow meter wdll be caUbrated wdth a stop watch and 5- to 15- gallon container during initial piurging of the first weU to be sampled. The flow meter wdU be calibrated for flow rate by starting the stop watch at an initial volume then stopping the watch at a later knowoi volume. This wdll give the time, in minutes and seconds, that it took to discharge the known volume of water from the weU. The rate of discharge in gaUons per minute (gpm) can then be calculated. Manufacturer instructions for use of the in-line monitoring device and meters wiU be followed and wdU be avaUable for use in the field. Measurements made wdth external meters wdU be made direcUy \WORK\24231\02\SAPAPP March 17. 1994 HARDING LAWSON ASSOCIATES A-15 301069 aeoOR at the well discharge point. Procedures for measurements using these meters and measurement of flow rates consist of the following: • The monitoring chamber(s) and probe(s) wdll be rinsed wdth well water prior to recording measurements. • Purge and rates wUl be read directly from the calibrated flow meter. During development and purging activities using pumps, purge volumes wdll be estimated based on calculated flow rates and purge time. Final purge volumes wdU be estimated based on the volume of water contained wdthin the 55-gaUon storage drums. If a baUer is used to purge the wells, the purge rate wdU be estimated based on the total volume of water removed during the time baUing activities were underway at each well. \WORK\24231\02\SAPAPP March 17. 1994 HARDING LAWSON ASSOCIATES A-16 ' 5tf: 3 0107 0 A5.0 SAMPLE HANDLING AND ANALYSES A5.1 Sample Documentation A5.1.1 Field Data Forms A record of sample identification numbers wUl be maintained on standardized groundwater sampling forms. Additionally, the groundwater sampling form includes a record of significant events, observations, and measurements dutring sampling, such as personnel present, site conditions, sampling procedures, measurement procedures, and instrument caUbration records. All entries on the groundwater sampling forms are to be in ink, signed, dated, and kept as a permanent record. The information contained in these forms is intended to provide sufficient data and observations to enable participants to reconstruct events that occurred during the project. Corrections of erroneous entries wdU be made by crossing a line through the error and entering the correct information. CorrecUons wdll be iniUaled and dated by the person making the re-entry. An example of the standardized groundwater sampling form used during water quality sampling is contained in Appendix A. A5.1.2 Chain of Custody and Requests for Analyses Sample identification docmnents are to be carefuUy prepared so that sample identification and chain of custody can be maintained and sample disposiUon can be controlled. The sample identification documents to be used as part of this investigation are defined as: • Sample identification labels • Chain of custody records • Laboratory analysis and scheduling form Examples of the sample identification label and chain of custody documents are provided in the QAPP. Pre-printed adhesive sample identification labels wdU be secured to the sample containers by the field personnel. Sample documentation forms and labels wdU be completed wdth waterproof ink. Sample documentation forms include the foUowdng informaUon: • Sample number • Project number • Sample site name/code • Sampling date and time • Sampling personnel • Shipping iriethod and date • Sample description • Sample matrix • Sample volume and number of containers • Sample destination • Preservatives used • Analyses required • Special handling procedures Official custody of samples is maintained and documented from the time of sample collection up to the presentation of analytical results in the final report. The chain of custody record form serves to ^ | ^ \WORK\24231\02\SAPJ\PP March 17, 1994 HARDING LAWSON ASSOCIATES A-17 ri iQ A ft C O^St'Ut. 301071 cross-reference with the sample identifier assigned by the Project Manager wdth the laboratory identification number. To document sample possession, chain of custody procedures are followed as outlined in the sections below. A5.2 Sample Transport Upon collection, all samples wdll be sealed wdth custody seals, labeled, and stored at 4°C in plasUc ice chests with ice or blue ice and kept chUled untU analyses are performed. For each group of samples transported to the laboratory by overnight transportation, all completed letters of transmittal, chain of custody records and laboratory schedules wdll be placed in a waterproof bag wdthin the cooler. Samples are to be packed in plastic packing material to avoid breakage. The ice chest containing samples wdll be clearly labeled and sealed to prevent tampering. The field sampler wdU be responsible for the care and custody of the samples coUected untU they are transferred or dispatched properly. The method of transport, courier name(s), and other pertinent inforination wdll be entered on the chain of custody accompanying the samples. Once received at the laboratory, laboratory custody procedures wdU apply. At that point, it is the laboratory's responsibiUty to acknowledge receipt of samples and .verify that the containers have not been opened or damaged. It wdll then be the laboratory's responsibiUty to maintain custody records throughout sample preparation and analysis. A designated sample custodian accepts custody of the shipped samples and verifies that the sample identificaUon numbers of the contents match those on the chain of custody record and notes the laboratory identification number on the form. Pertinent information as to shipment, pickup, and courier is entered in the "Remarks" section of the chain of custody record. A copy of the chain of custody record is then sent to the Project Manager. \WORK\24231\02\SAPJ\PP March 17. 1994 •J l>'-f,i-J) > •^ar'l.i mt HARDING LAWSON ASSOCIATES A-18 301072 A6.0 BIBLIOGRAPHY Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA): Public Law 96-510, 42 USC 9601 et.seq. U.S. Environmental Protection Agency, 1983, Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans: QAMS-005180; Office of Moniloring Systems and Quality /Assurance, ORD, Washington, D.C, February. U.S, Environmental Protection Agency, 1984, Guidelines Establishing Test Procedures for the Analysis - Final Rule and Proposed Rule, 40 CFR Part 136, October. U.S. Environmental Protection Agency, 1987a, A Compendium of Superfund Field OperaUons Methods, OSWER Directive 9355-0-14, December. U.S. Environmental Protection Agency, 1987b, Data Quality Objectives for Remedial Response Activities [development process): USEPAI540/C-87/003, Office of Emergency and Remedial Response, Washington, D.C, March. U.S. Envirormiental Protection Agency, 1986c Draft Supplement to Interim Guidelines and Specifications for Preparing Quality /^surance Project Plans: QAMS-005180,'Office ofMonitoring • Systems and Quality Assurance, ORD, Washington, B.C., December. U.S. Environmental Protection Agency, 1986e, National Enforcement Investigations Center Policies and Procedures Manual, EPA -330-9-78-001-R. U.S. Environmental Protection Agency, 1986f, Test Methods for Evaluating Solid Waste: Office of Solid Waste and Emergency Response (OSWER) Directive SW-846, Vol. IB. U.S. Environmental Protection Agency, 1986g, User's Guide to the Contract Laboratory Program: Office of Emergency and Remedial Response, Sample Management Office, December. U.S. Environmental Protection Agency, 1988a, Compendium of Methods for the Determination of Toxic Organic Compounds in /{mbient /dr. Atmospheric Research and Exposure Assessment Laboratory, June. U.S. Environmental Protection Agency, 1988b, Laboratory Data Validation - Functional Guidelines for Evaluating Inorganics Analyses, Hazardous Site Evaluation Division, July. U.S. Environmental Protection Agency, 1988c, Laboratory Data Validation - Functional Guidelines for Evaluating Organics Analyses: TDD Doc. No. HQ-8401-01, Hazardous Site Evaluation Division, February. U.S. Environmental Protection Agency, 1988d, Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final, EPAI540/6-89/004, October. U.S. Environmental Protection Agency, 1989a, Region ll CERCLA Quality Assurance Manual, Revision I. U.S. Environmental Protection Agency, 1989b, Risk /Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual, Part A Interim Final, Office of Emergency and Remedial Response, December. \WORK\24231\02\SAP.APP March 17, 1994 HARDING LAWSON ASSOCIATES A-19 , UAAP 301073 • U.S. Environmental Protection Agency, 1990a, Contract Laboratory Program Statement of Work for Inorganic /Analysis, ILMOl.O, March. U.S. Environmental Protection Agency, 1990b, Contract Laboratory Program Statement of Work for Organic Analysis - Multi-Media Multi-Concentration, OlAlOl.O, AprU. U.S. EnvLroamental Protection Agency, 1990c, Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Toxicity Characteristics Revisions; Final Rule, 40 CFR Part 261, Thursday, March 29. U.S. Environmental Protection Agency, Region HI, 199pd, Field Filtration Policy for Monitoring WeU Groundwater Samples Requiring Metals Analysis, BuUetin No. QAD009, AprU 23. U.S. Environmental Protection Agency, 1991a, Discharge of Extraction Well Effluent from the Kane and Lombard Site (Memorandum), AprU 29. U.S. Environmental Protection Agency, 1991b, Model Quality Assurance Project Plan: Office of Superfund, Region V, May. U.S. Environmental Protection Agency, 1991c, Contract Laboratory Program Statement of Work for Low Concentration Organic Analysis, June. U.S. Environmental Protection Agency, 1992a, Region II SOP HW-6, CLP Organic Data Review and Preliminary Review, Revision 8, January. • U.S. Environmental Protection Agency, 1992b, Re^on II SOP #W-2 Evaluation of Metals Data for the CLP Revision II, January. U.S. Environmental Protection Agency, 1992c, Ground Water Forum, Monitoring Well Development Guidenines for Superfund Project Managers, April. U.S. Environmental Protection Agency, 1993, Administration Order on Consent for Remedial Investigation/Feasibility Study, Docket No. m-93-21-DC, July. WORK\24231\02\SAPj\PP March 17, 1994 HARDING LAWSON ASSOCIATES A-20 301074 • APPENDIX AA FIELD DOCUMENTATION FORMS • \WORK\2423l\02\SAP.APP March 17,1994 HARDING LAWSON ASSOCIATES 301075 APPENDIX AA FIELD DOCUMENTATION FORMS Water Level Measurement Form Groundwater Sampling Form Field Log of Boring Form (2 pages) Field Well Completion Form Well Development Form Chain of Custody Form Sample Labels Field Calibration Data Sheets Custody Seal • \WORJC\24231\02\SAPAPP March 17.1994 HARDING LAWSON ASSOCIATES 301076 # U^TER LEMEL DATA 9-€ET INSTR/-ENT/MDDG1. « :__ PROJECT: H«HIn« LawMn A*»««ia^,, JOB rJJMBER:. DATE: 9-EET CF <i : UP) 1 : : NLMFFR : • • TirE i DEPTH TO : WAihH : 1st R£ADI^G : •I ; DEPTH TD : WAILH : 2nd READI^G -.: DEPTH TO : UAIbH : 5rd READirJG : crrre<nr5 b h L i i a j ' • • ' i . y- [ , - - "^i^XQll Harding Lawson Associates a i ^ - 1 Engineering and Environmental Services Job Name GROUND-WATER SAMPLING FORM Job Number _ Recorded by (S gnaturef Well No. Well Type: • Monitor Q Extraction Q Other _ Well Material: • PVC Q St. Steel Q Ottier Date Time Sampled by l.;^WELL PURGING t?^mmFz^^j, Casing Diameter (D in inches): Q 2-inch Q 4-inch Q 6-inch Q Other Total Depth of Casing (TD in feet BTCTC): _ Water Level Depth (WL in feet BTOC): Q Bailer - Type: Q Submersible Q Centrifugal Q Bladder; Pump No.: Q Other-Type: Number of Well Volumes to be purged (# Vols) Q3 0 4 QS OIO Q Other O Near Bottom Q Near Top Q Other Depth in feet (BTOC): Screen Interval in Feet (BTOC) from to Start Stop. Elapsed "^^mmm Initial. X 0.0408 = gpm Final Calculated Purge Volume gallons gpm gallons Minutes Since Pumping Began pH Cond. (nmhos/cm) ' a°F Other Minutes Since Pumping Began Meter Nos. pH Cond. (^mhos/cm) j O ' C ' Q-F Other Observations During Purging (Well Condition, Turbidity, Color, Odor): Discharge Water Disposal: Q Sanitary Sewer Q Storm Sewer Q Other Q Bailer - Type: Q Submersible Q Centrifugal Q Bladder; Pump No.: Sample Series:. Q Same As Above Q Grab - Type: Q Other - Type: Sample No. Volume/Cont. Analysis Requested Preservatives Lab Co'*^'*^"^ Duplicate Samples Original Sample No. Duplicate Sample No. Blank Samples Other Samo*« Type Sample No. Type Sd—t"* Sc 00 o H O ro RL004 Omct Co»T • W>»Ti Fm« Corr • Couffr 0746 # LOCATtOM OF B0RIN6: z a. et Ui Si I 1 « i . J CD > M ial Z o u oc u ae v» z o ? 5 kJ s! a FIELD LOG Of BORING 1 1 1 i d s o \ u It! z z »- 0. / - 2 - § I < K U M . SHEET PROJECT' JOB NO.: PWJ.MGR.; OF BORING NO. TOTAL DEPTH: LOGGED BY. EDITED BY: DRILLING CONTRACTOR: DRILL RIG TYPC: DRILLERS NAME: SAMPLING METHODS: HAMMER WT.: STARTED, TIME: COMPLETEO,TlME: BORING OEPTH (ft.) CASING DEPTH (ft.) WATER DEPTH (ft.) TIME: DATE: DROP: DATE: DATE: BACKFILLED, TIME: SURFACE ELEV.: DATE: BY: DATUM: CONDITIONS: f . a m ^ l B PF7 HANDING LAWSON ASSOCIATES 301079 X »- a Ul o Ul > • s OB . .... Ul > £ o o > "o Ul o z o o Ul d riELO LOG OF BORING (CONTINyEO) , ,- .,, . r •-a. Ul o 1 - 2 - " 3 - 4 - 5 - 6 - 7 - 8 - 9 - 0 - / - 2 • 3 • 4 5 6 7 0 9 0 o • PROJECT: SHEET AC NO BORING NO. 1 . - - ' • J PM ^ AROING LAWSON ASSOCIATES 301080 k<?J% m ./^ F I E L D W E L L C O M P L E T I O N F O R M H»«"'»fl «.**»on Associate* •lAMCi i.OOCCO M A M A C I H : c o i r c o • T: M A M t i emuutwc COMPAHTi • • u i r M C M T i p. INCH HOLLOW STEM AUGER INCH BOTABY WASH • ALLOM* e r •TATCW WtCO OUWIMO DMIkLIMCi OMIUUCN: HOUM* O n i k L t O : GALLONS MCTMOe e r eCCOMTAMIMATIOM VKIOM TO OMILUIMCs DEVELOPMENT •iCTMOo o r o e v « i . o r « i c K T < e c v c L e r M K M T • CCAH OATC: T I C b B : GPM VlCkO: GPM T l C k O : GPM V l C i , 0 : GPM T O T A L WATCH NC DUMIMC eCVCLOf TIWC! FROM TIMC: FROM TIMC: FROM T I K t : FROM MOVCO •MCHT: T l M C : TO TO TO TO OATC: OATC: OATC: OATC: GALLONS O c s c K i r r i O N O f TUHCIOITT AT CMO o r e c v K L O r M K H T : DCLEAR D MOD. TURBID QSLICHTLY CLOUDY D VERY MUDDY eooM o r « r A T I H ; «rATCH eiftCMAMSEO TO-. D G R O U N D SURFACE DSTORM SEWERS DORUMS DTANKTRUCK DrroRAG£TAN< P O T H E R DCrTw TO WATCH A r r C H OCVCCOrMCNTi FEET DCMHiSTYiox D LOCKING STEEL COVER ~ — INCHOIAMETCR tl^EEL CONDUCTOR CASING INCH DIAMETER •OREMOLE IENTONITE<:EM£NT SEAL CR • SACK CEMENT .SAND SEAL . f « t i TOP OF CASING AT FEET ABOVE.'AT; tELOW GROUND LEVEL • _ _ _ i N C H D I A M E T E R BOREHOLE i MATERIALS USED SACICS OF $ A C « OF .SAND .CEMENT GALLONS OF GROUT USED SACKS OF POWDERED BENTONITE — _ _ _ _ » POUNDS OF t E N T O N I T i PELLETS FEET 0F«_...«INCH PVC SLANK CASING FEET OF INCH PVC SLOTTED SCREEN — — « FEET O F _ _ „ I N C H STEEL CONDUCTOR CASING _ _ _ _ _ _ Y A R D ' CEMENT*AND (REOI-MIXJ ORDERED • Y A R D ' CEMENT-SAND JREDI-MIX) USED CONCRETE PUMPER USED? D^O Q Y E S . t o . . 1 t t \ — INCH D I A M E T E R SCHEDULE * 0 P V C BLANIC C A S I N G _ _ _ _ t e larl - D BENT0NITECEMEN7 SEAL OR - D SSACK CEMEN'T-SAND SEAL t o . . (ett BENTONITE PELLET SEAL . t e . . i t t x SAND PACK • t o . . i t t i INCH DIAMETER SLOTTED ( •Inehl SCREEN _ _ _ _ « " i t t x INCH DIAMETER SCHEDULE iOPvC BLANK SILT TRAP , t e . . I t t x BOTTOM WELL CAP HOLE CLEANED OUT TO iati BOTTOM OF lOREHOLE _ ^ f t n NOT TO SCALE AOOITIONAL INFORMATION: NAME WELL COVER USED: D L O C K I N G STEEL COVER DCHRISTY BOX DOTHER t I L T TRAP USED? D N O D Y E S 301081 # Well Peveiopment Form Hardhig Lmmon AsaodadM Prolect: Personnel: Development Method Well No. Date: 1 Time Oepth to Water 1 (N) \\ Qallons Removed j Turfoldlly 1 (Nlu) 1 1 pH ' ; .. ' Temp •. . \ 1 E.G. Recovery Rate inches/mIn 1 j Recovery Rata 1 w m 1 1 Observations { 1 301082 i Tolal Gallons Removed '^mn.C-.P iwson Associates Ird Street == 13 : Z z z s ^ z PhllaoT^nla, PA 19106-1903 ' " ^ " ^ — ^ " ' ^ ' 215/827-4505 Fax: 215/627-4250 Job Number: Name/Location: Project Manager: CHAIN OF cA . ODY FORM Samplers:. Recorder: luj \ t i oc UJ P2 O O |(/> u 1 MATRIX c E a> 5 V) 6 |?«;ONTAINERS 8.PRESERV. 1 a 1 c o v» t . X o z X SAMPLE NUMBER OR LAB NUMBER Yr Wk Seq "1 u n 1 c 1 Yr Mo Dy Time | (Signature fteguired) STATION DESCRIPTION/ NOTES Lab: ANALYSIS REQUESTED LAB NUMBER Yr ^ " Wk "^ Seq .._ ,—. - - —- -- — DEPTH IN FEET — - • • -— 1 — ^ i.- - ^ 1 COL MTD CD — QA CODE .— 1 1 MISCELLANEOUS . • [ ^.. r-.n.».i 0an.,nf^t rVff:..^.n r^nn.. c;nt^ ..-.. r\ CHAIN OF CUSTODY RECORD RELINQUISHED BY: (Signature) RELINQUISHED BY: (Signature) RELINQUISHED BY: (Signature) RELINQUISHED BY: (Signature) DISPATCHED BY: (Signature) METHOD OF SHIPMENT f f : » n f n n t . RECEIVED BY: (Signature) RECEIVED BY: (Signature) RECEIVED BY: (Signature) RECEIVED BY: (Signature) DATE/TIME RECEIVED FOR LAB BY: (Signature) DATE/TIME 1 DATE/TIME DATE/TIME 1 DATE/TIME DATE/TIME 1 6533 301083 t Harding Lawson Associates GROUNDWATER AND SOIL SAMPLE LABELS Harding Lawson Associates JehM>iTM J o h N u m h w Coll«rtor n a i l (Slgmlurt) T i m * Piae» Sampla No j;i^:i WKlURoring Mfl Ounth ;«{^-^ Harding Lawson Associates By: Date: Job:- Borini / i N o : / No:. Depth: FulID PartialD Remarks: ..CoritamlnaiTtr^^^- •-'•^^^--'iBoringNa;. ::R*rTUirir<* *^- .«Et:r5r^.r, vr;:.£-i»-yrTUnth«~ «"-. . v« - . vRemarks: ;Depth:j • . • j o r - w . f 1 •-•••• 301084 APPENDIX AB CONTAINER PRESERVATION, PACKAGING AND SHIPPING REQUIREMENTS \WORK\24231\02\SAP.APP March 17, 1994 HARDING LAWSON ASSOCIATES Analysis Appendix AB. Containers, Preservation, Pacicaging, and Shipping Requirements Island Chemical Company St. CroLx. U.S. Virgin Islands Containers. Preservation Technical Holding Time* Volume.of Container Shipping Normal Packaging CiDundwater Oi^ganic Analyses TCL VOCs TCL SVOs TCL Pesticides and PCBs Pyridine Crouiulwaicr.Iiiorgaiiic Analyses TAL metals Three 40-ml glass yials with Teflon septum-lined caps . Two 1-liter amber glass bottles with Tefloh™-lined caps Two 1-liter amber glass bottles with Teflon^^^-Iined . caps To be deterimined , HCl to pH <2, cool to 14 days 4°C in dark storage Cyanide One 1-liter polyethylene bottle One 1-liter polyethylene bottle Cool to 4°C in dark storage Cool to 4°C, NajSjO, To be determined .HNO3 topH <2.0 NaOH to pH >12, cool to 4°C Soil Organic Analyses TCL VOCs One 4-oz wide-mouth glass ,~ jar with Teflon™-lined lid , TCL SVOs Two 16-oz. amber glass jars with Tenon''"'^-lined lid TCL Pesticides One 4-oz wide-mouth glass and PCBs jar with Tenon™-lined lid Pyridine To be determined Cool to 4°C m dark storage Cool to 4°C in dark storage Cool to 4''C To be determined Ul 'KK,J«: 1; 1.. i S I ' ( l i M .\|-1' Fill completely, no DeUvered daily air bubbles Extract within 7 days, analyze within 40 days after extraction Extract within 7 days, analyze within 40 days after extraction / To be determined Fill 90% full FiU 90% Delivered daily Bubble pack Bubble pack DeUvered daily Bubble pack To be detennined To be determined To be determined 6 months, except Hg - 28 ; Fill 90% days 14 days FiU 90% Delivered daily Delivered daily Bubble pack Bubble pack 14 days Extract within 14 days and analyze within 40 days after extraction Extract within 14 days and analyze within 40 days after extraction To be detennined FUl completely DeUvered daily Fill 90% Fill 90% DeUvered daily Bubble pack Bubble pack Delivered daily Bubble pack To be determined To be determined To be dnlcrmined HARDING LAWSON ASSOCIATES Appendix AB. Containers, Preservation, Pacicaging, and Shipping Requirements Island Chemical Company St. Croix, U.S. Virgin Islands Analysis- Containers Preservation Technical Holding Time' . Volume of Container Shipping Normal Packaging Soil Inoi;ganic Analyses TAL Metals ~ One 4-oz wide-mouth glass Cool tp 4°C jar with Teflon™-lined lid Cyanide One 4-oz wide-mouth glass Cool to 4°C jar with Teflon™-lined lid 6 months, except Hg - 28 Fill 90% days- 14 days Fill 90% Delivered daily ' Delivered daily Bubble pack Bubble pack Parameters lincl detection limits will IKJ consislcnl with inciliods listed in Tables C1-2 llirough Cl-7 of llic Qn.nlity Assurance Projcol I'lnn Sample containers will be prepared according lo OSWER Directive No. 9240-05, "Specification and Guidance for Obtaining Conlaminant-frce Sample Containers, "or certified clean containers (e.g., I-Chem 200 series) will be used. , - * The time of sample collection to extraction/analysis. • > - greater than g - gram 7 i lljSO^ sulfuric acid '^ . IINO3 nitric acid NaOH sodium hydroxide oz. ounce TAL Target Analyle List VOCs volatile organic compounds < °C HCl Hg ml NajSjOj SVOs TCL less than ' degree Celsius hydrochloric acid mercury . milliliter Sodium thiosulfate semivolatile organic compounds Target Couijionnd List \ W O R K : \ 2 4 2 3 1 \ 0 2 \ F S P - C O N T . A P P HARDING LAWSON ASSOCIATES APPENDIX AC WELL CONSTRUCTION DETAILS 301088 UNCONSOLIDATED MONITORING/RECOVERY WELL SPECIFICATION DIAGRAM PROTECTIVE CAS ING STICK-UP ^1 RISER PIPE GROUT - SEAL SAND/ GRAVEL PACK WELL SCREEN IA ^ Z ^ l> HLA PROJECT NUMBER: WELL NUMBER: WELL LOCATION: DATE INSTALLED: DRILLING CONTRACTOR: DRILUNG SPECinCATlONS DRILUNG METHOD: BOREHOLE DIAMETER: DRILUNG FLUID: TOTAL BOREHOLE DEPTH: WELL SPECIRCATIONS SCREEN LENGTH: DIAMETER: SLOT SIZE: . MATERIAL- COUPUNG TYPE: RISER LENGTH: . DIAMETER: MATERIAL: COUPUNG TYPE: SnCK-UP: PROTECTIVE CASING HEIGHT: DIAMETER: MATERIAL^ OTHER: . SAND/GRAVEL PACK SIZE: MATERIAL: SEAL MATERIAL: GROLTT MATERIAL _ GROUTING METHOD: DEVELOPMENT METHOD: DEVELOPMENT TIME: ESTIMATED YIEUD: STATIC WATER DEPTH OC): DATE: : ELEVATION OF IC,(NGVD 29): ) 7MRKS: All measurements are from ground surface unless stated otherwise. ;_ NGVD 29 is National Geodetic Vertical Datum of 1929. .IN. .FT. FT. IN. IN. FT. IN. FT. (AGS) .FT. (AGS) IN. FT. \FORM\UNC0IAG.FRM Dcctmbar 17, 1992 301089 Appendix B Draft Health and Safety Plan Island Chemi(^al Company St. Croix, U.S. Virgin Island Prepared for Island Chemical Company HLA Project No. 24231 2.C.4 John J. Kohler ' ' - Designated Health and Safety Officer Jason M. Schindler Senior Geologist March 17, 1994 Harding Lawson Associates Engineeringl: and Environmental Services L y - S A J - 131 North Third Street Philadelphia! PA 19106 - (215)627-4505 301090 PREFACE Personnel participating in field activities!mustj'be trained in the general,and specific hazards unique to' this job and meet medical examination requirements as well as other requirements as set forth,in 29 Code of Federal Regiilations 1910.120 or other Occupational Safety and Health Administration regulations, as applicable. Site persormel and:visitors must follow the guidelines, rules, and procedures in this docimient. The Project Manager or Site Health and Safety Officer may impose any other procedures or prohibitions judged necessary for safe operations. This document is prepared to inform field persormel, including Harding Lawson Associates' contractors and subcoiitractors, of potential hazards,onsite. However, each contractor or subcontractor must assimie direct responsibihty for the health and safety of their ovim employees. , This document was prepared for the sole use of Island Chemical Company, the only intended beneficiary of our work. No other parties should rely on the information contaioed herein vdthout the prior written consent of HLAi ., ' \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-i 301091 CONTENTS B-l.O INTRODUCTION . . . . . ' . . . . ; . -- i i B-2.0 SITE BACKGROUND .'. ; . ; Z. • . 2 B-3.0 PROJECT ORGANIZATION AND •RESPONSIBILITIES . 3 B-3.1 Harding Lawson Associates . > . . . . . 3 < B-3.1.1 HLA Corporate Health; and Safety Officer . . ' . , ; . . 3 B-3.1.2 Regional Designated Health and Safety lOfficer . . .^ 3 B-3.1.3 Site Health and Safety:Officer 3 B-3.1.4 Field Operations;Manager 3 B-3.1.5 Assitant Project Manager 4 . B-3.1.6 Project Manager 4 B-3.2, Contractors and Subcontractors . . . . . . . . . . . . . . ; . 4 B-3.3 Others... , . ; 4 B-5.0 HARDING LAWSON ASSOCIATES' HEALTH AND SAFETY PROGRAMS 6 ^B-5.1 Reqxiired Personnel Training , 6 B-5.1.1 Reguilaf Site Personnel Exposed to Hazardoiis Material .6 B-5.1.2 Regular Site Personnel Potentially Exposed to Hazardous Materials Below Permissible Exposure Limits 6 B-5.1.3 Occasional Site I^ersonnel Potentially Exposed to Hazardous Materials • Below Permissible Exposure Limits ". . 6 B-5.1.4 Management and Supervisory Training 7 ^ B-5.1.5 Refresher Training . . : ••••., 7 ' B-5.1.6 Documentation . . . .1 I . . . 7 . ' B-5.1.7 Exempt Personnel . . . . . . . . . . . . . . . . : . 7 B-5.1.8 Tailgate Safety Meetings,; 7 B-5.1.9 Safety Inspections and,Audits 8 B-5.2 Medical Monitoring ; . . . . . .8 B-5.3 Respiratory Protection Policy . ; ' . . . . . ! . . . . 9 B-5.4 Hazard Communication . ; . . . . . . . 9 B-5.4.1 Container Labeling . . . .' : . . . . ' . . . .• \. 10 B-5.4.2 Material Safety Data Sheets ... 10 B-6.0 KNOWN SUBSTANCES IN THE STUDY AREA 11 B-7.0 HAZARD EVALUATION AND MITIGATION . 12 B-7.1 Chemical Hazards . . . . . . . . .,. . ; . . . . . . . . . . . . . 12 B-7.2 Physical and Mechanical [Hazards . . -12 • B-7.3 ' Electrical and Utility Hazards Z'. . . . . .' 12 B-7.4 Acoustical Hazards . . . I . . . .' 13 B-7.5 Heat Stress and Cold Stress . .;. ... . . . . . ... . . 13 B-7.6 Natural Hazards . . . . . . z':.. . .' • . . . . 13 B-7.7 Biological Hazards : . . 13 B-7.8 Fire/Explosion Hazards -. . 14 B-7.9 Airborne Dust Hazards . ; . . . . . . . . . 14 B-7.10 Other Hazards 14 \wORK\2423i\02\HASP.APP March 17,1994 Harding Lawson Associates B-ii • ' ' ' • \ ' • • • . ~ • . •• r ' ^ - • \ 3 0 1 0 9 2 CONTENTS (Continued) B-8.0 SITE OPERATIONS 15 Br8.1 Support Zone . . . . . . . ; . . . . . • . '...-. ., 15 B-8,.2 Contamination Reduction Zone ' A .... ...[ •. 15 ' B-8.3 Exclusion Zone ! . ' . . . . . . , 15 B-8.4 Work Zone Control . . . .[. ".'. . . : 16 B-8.5 Pre-determined Emergericy As'sernbly Point 16 B-9.0 PERSONAL PROTECTIVE EQUIPMENT AND ACTION LEVELS . . . . ' . . . 17 B-IG.O AIR MONITORING AND SITE OPERATIONS ; . . . . . . . . . ; . . . . . . . ; 19 ' B-10.1 Gases and Vapors . . . . 19 B-10.2 Explosion Hazard . . . . . ' ; •'. 19 B-10.3 Oxygen Deficiency in Confined Spaces 19 B-11.0 RECOMMENDED LEVELS OF PROTECTION AND SAFETY PRECAUTIONS 20 B-11.1 Site Clearance and Surveying . r.. ; . ., 20 B-11.2 Mpnitoring Well Installation, Soil. Sampling, and Groundwater Sampling 20 B-12.0 PERSONNEL DECONTAMINATION PROCEDURES . . . . ; . . . . 21 B-13.0 GENERAL HEALTH AND SAFETY PROCEDURES . ;. :'. . . . . . . . ' 22 B-14.0 EMERGENCY INFORMATION AND CONTINGENCY PLAN . 23 B-14.1 Emergency Phone Numbers and Directions to St- Croix Hospital . 2 3 B-14.2 Emergency Signals . . . , : . . . .:. 23 B-14.3 Contingency Plan 24 B-14.3.1 Response Sequence fpr First Arrivals 24 B^14.3.2 Response for Incidents Involving Another Contractor . . . . ' . 25 B^14.3.3 Emergericy Response for Severe Weather Conditions 25' B-14.3.4 Emergency Response for Earthquakes 26 B-14.3.5 Emergency Response for Flash Floods 26 B-14.3.6 Emergency Response for Fires 27 B-14.3.7 Fire Prevention . . 27 B-14.3.8 Emergericy Response for Explosions 27 B-14.3.9 Emergency Response for Spills 27 B-14.3.9.1 initiali Spill Response ; . . . . . 28 B-14:3.9.2 Spill Site Decontamination . . . . . • • , 28 B-14.3.9.3 Cleanup Materials and Used Personal Protective. Equipment Disposal .• 28 B-14.3.9.4 Spill Prevention . . . . . . , . . . . . . ; . . . . . . . . 28 .B-14.3.10 Responsibilities of Field Personnel 1 -. 29 B-14.3.11 Emergency Response Eqiiipment . . . . . . . . . . . . : . . . . . . . . . . . . 29 B-15.0 EMPLOYEE EXPOSURE/INJURY INCIDENT REPORT 30. TABLES B-1 Sximmaiy of Substances Detected ' ' \woRK\2423i\02\HASP.APP March 17,1994 Harding L a w s o n A s s o c l a t e s B-iil . 301093 CbNTENTS (Continued) FIGURES B-1 ., Site Location Map . B-2 , Site Map B-3 Typical Work Zone Location Map APPENDIXES , BA Hazardous Property Information BB Personnel Acknowledgement Records, BC ' Material Safety Data Sheets f BD First Aid and Emergency Care |', BE Equipment. Cahbration and Maintenance BF Accident Investigation \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-iv 301094 B-1.0 INTRODUCTION This Draft Health and Safety Plan (HASP) has been prepared by Harding Lawson Associates (HLA) on behalf of Island Chemical Cornpany. This HASP, describes health and safety aspects of work planned for the following activities, described in the Work Plan: , ' - • • ' , Site Clearing; , ' . , . ' • Monitoring well installation; . , ' • Soil arid groundwater sampling; . • ' • Surveying; . . . The purpose of this HASP is to assign responsibilities, specify mandatory operating procedures, establish personal protection standards, and provide for contingencies that may arise during completion of the tasks listed above. The HASP addresses safety protocols which will be followed during field operations to minimize the prpbabihty of employee exposure. The HASP has been developed to meet the requirements of the Occupational Safety and Health Administration (OSHA) regulations. Title 29, Code of Federal Regulations, Part 1910.120 (29 CFR ' 19W.120),.Hazardous Waste OperationsiOnd Emergency Response. \WbRK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-1 301095 B-2.0 SITE BACKGROUND The site occupies approximately three acres in south central St. Croix, U.S. Virgin Islands. The site is located on Route 66-approximately 0.5 miles north of Alexander Hamiltori Airport. A site location. , map is provided as Figure,B-1 and a sit6 map,is provided as Figure B-2. •-' _ ' > The site-is bordered by an intermittent streaih to the northeast, and southeast; Route 66 to the southwest; and a cement plant to the east. ' . The site was formerly used to store andji manufacture chemicals imder several different companies from approxiniately 1969 through 1982:' In January of 1989, the site vi^as occupied by the St. Croix Security Kennels and VIAG Fuels Inc. (VIAG). VIAG lised some office space in the main building and stored ethanol in four above-ground tanks. The facihty is currently unoccupied. .- A detailed description of the study area and history of the faciUty are presented in the project Work Plan. . • < '. \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-2 301096 B-3.0 PROJECT ORGANIZATION AND RESPONSIBILITIES - , . . . , . ^ , . , . ^ , B-3.1 Harding Lawson Associates The Island Chemical Company Work Plan, submitted to U.S. Environmental Protection Agency (USEPA) vvith this document, presents the overall project organization and responsibility structure. The health and safety responsibilities qf key project personnel are discussed below. B-3.1.1 HLA Corporate Healtii and Safety Officer Mr. Peter B. Rice is responsible for development and oversight of HLA's health and safety program. B-3.1.2 Regional Designated Health and Safety Officer Mr. John J. Kohler is responsible for ensuring that corporate Health and Safety procedures are implemented throughout the region and for the development of this HASP. Questions regarding specific items on the HASP should be directed through Mr. Kohler. As part of HLA's ongoing health and safety program, the CHSO has established a network of DHSOs who educate, update, and ensure compliance with HLA's Corporate Health and Safety Procedures Manual (HLA, November 1992). A DHSO is located in every HLA office. The DHSO vdll maintain contact vnth USEPA and the Government of the Virgin Islands (GOVI), as necessary, regarding health " and safety issues. The DHSO wdll also jbe-responsible for periodic field audits to verify compliance with the HASP. B-3.1.3 Site Health and Safety Officer Mr. Michael P. Sobel has been assigned, the role of Site Health and Safety Officer (SHSO) for this project. Mr. Sobel will check that the guidelines, rules and procedures in this document are followed for all site work. He will be familiarWith local emergency services. He. will conduct a tailgate health arid safety meeting before work start-up and at least weekly thereafter. Additional tailgate meetings may be required for specific job tasks, site activities, or when visitors come to the site. He vi/ill check that visitors have had hazardous waste site traiiiing arid a medical examination within the past year. He will maintain and inspect PPE, monitor work area hazards, and monitor the physical condition of site persoririeL He will shut down operations,that pose a potential threat to field personnel. The SHSO will be responsible for Health and Safety throughout the field operations. He/she will monitor work locations for proper procedures. The SHSO wdll have the authority to-stop work if health and safety procedures carmot be followed. In addition, the SHSO will be responsible for producing written r6ports of health and safety incidents. B-3.1.4 Field Operations Manager Mr. James L. Collins has been assigned the role of Field Operations Manager for this project. Mr. Collins will check that all field personnel have read arid signed the master copy of this document. He wall check that all site persormel meet Occupational Safety and Health Administration, (OSHA) requirements regarding training, medical' examinations, and fit testing. He will conduct accident investigations in conjimctiqn with, the DHSO, as necessary. \woRK\242'3i\o2\HASP.APP March 17,1994 Harding Lawson Associates B-3' 301097 B-3.1.5 Assistant Project Manager ; . Mr. Jason M,. Schindler has been assigned the role of Assistant Project Manager. .Mr. Schindler will acquaint field personnel with the overall scope, of the project and ensure that project persormel have signed the master.copy of this document. In^'conjunction nath the DHSO, Mr.' Schindler will check that all site personnel meet Occupational Safety and Health Administration (OSHA) requirements regarding training, medical examinations, and fit testing,..conduct accident investigations, as. necessary.' Mr. Schindler wdll be responsible for preparation of project documents. B-3.1.6 Project Manager Mr. Edward A. Nemecek as been assigned the role of Project Manager. Mr. Nemecek will be responsible for conduct of HLA's work effort,, coordination with ICC and regulatory agencies. Mr. Nemecek wdll complete an independent review of the data and final review of project docmnents. B-3.2 Contractors and Subcontractors. Subcontractors wdll receive a copy of HLA's HASP for use as a guideline and for reference; however, subcontractors performing site work wall be responsible for the health and safety of their own employees. The subcontractor(s) will identify a lead individual responsible for checking that each of their-employees are in compliance with health and safety procedures. Prior to start of work, each subcontractor conducting subsurface or onsite investigations wall supply HLA with documentation that personnel under their control are participants in a medical monitoring program and have acceptable health and safety training. This docvmientation wdll be iriaintained with the subcontractor at the site and wdll include'the followdng: • Worker's name; ' , • . Training program attended, traineri and hours of training received; • , Statement from an occupational physician certifying participation in ari annual and post employment medical surveillance program. The statement must include verification that the person is fit to wear a respirator; ' " ., - • Docimientation demonstrating successful respirator fit testing within the last year prior to Level C work activities. • ' ' , B-3.3 Others ' I , • • . ' . -- Other persons (visitors) such as USEPA and GOVI personnel who ma:y enter the work areas or otherwise observe field activities should follow the guidelines, rules, and procedures irv this document, and conduct work in a safe marmer. Pribr to entering any work areas, visitors supply the SHSO with documentation consistent with that listed iri Section 3i2 above, and must attend a tailgate safety briefing given by the SHSO. The SHSO may restrict visitors from work areas if they do hot have their owm FIASP or proper PPE. . ' \woRK\2423i\02\HASP.APP March 17,1994 Harding Lawson Associates B-4 .'. . . ' . - .- ( '—'~ —~ 3 01098 B-4.0 PLANNED FIELD ACTIVITIES Several types of field activities are plaimed. Sorhe, but not all, include intrusive work. The level of health and safety protection varies, according to the type of activity. Field activities are .listed below. • Site Clearance;. - ' , ", • Monitoring well installation; ~ . • Soil and groundwater sampUng; ^ • • Surveying; Detailed descriptions of the procedures associated wdth each activity,are provided in the Field Sampling Plan. Descriptions of health arid safety procedures associated with each of these activities as well as recommended initial PPE levels are addressed in Section 11.0. The recommended initial levels may be modified by the SHSO depending on site conditions. Hazardous property information on chemicals that may be encountered is-included in Appendix BA. \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-5 301099 B-5.0 HARDING LAWSON ASSOCIATES'HEALTH AND SAFETY PROGRAMS Required HLA health and safety programs, including training and medical monitoring, respiratory protection, and hazard communication are presented in this section.- , • -' - . I ' B-5.1 Required Personnel training Specific training requirements for personnel, including subcontractors conducting field activities, are divided into the followdng training categories: • Regular Site Persormel Exposed to Hazardous Materials • Regular Site Personnel Potentially Exposed to Hazardous Materials Below Permissible Exposure L i m i t s • - - . , . • • Occasional Site Personnel Potentially Exposed to Hazardous Materials Below Permissible Exposure Limits • Management and Supervisory Training - . • • Refresher Training ^ i , , , ' , These categories, as well as documentation, exempt personnel, tailgate meetings, and audits, .are discussed in the followdng sections. ; . ' B-5.1.1 Regular Site Personnel Exposed to Hazardouis Material Site persormel whose job responsibihties cause them to be exposed to or to have the potential to hi; exposed to hazardous materials or health hazards are required to comply with 29 CFR ' Section 1910.120(e)(3)(i) or applicable local regulatioris. This regulation requires site, persormel exposed to hazardous materials to complete 40 hours of offsite instruction and three days of field experience supervised by a trained supervisor. , . • • • B-S.1.2 Regular Site Personnel Potentially Exposed to Hazardous Materials Beiow Permissible Exposure Liniits Regular site persormel are persons whose job responsibilities cause them to be potentially expos«;(l ; ; hazardous substances below permissible exposure limits (PELs) or health hazards are reqiiired to comply with 29 CFR 1910.120(e)(3)(iii) or applicable local regulations. This regulation requires,! h.i' these personnel receive a minimum ofi24 hours of offsite instruction and one day of field expo:.'-;.. •• supervised by a trained supervisor. The project SHSO or designated representative must check y:-z' these persormel will iiot be exposed aBove PELs. This decision will be made based on a reviou : ' previous'monitoring in these work areas arid historical site background informatiorii B-5.1.3 Occasional Site Personnel Potentially Expoised to Hazardous Materials Below Permissible Exposure Limits Occasional site persormel who visit the site ifor a specific liniited task and whose exposure is designated by the SHSO to be under PELs are, required to comply with 29 CFR 1910.120(e)(3)(n I < r applicable local,regulations. This regulation requires, that these persormel receive the same tr.ii.':;:..: is that indicated in Section 5.1.2 above. . \woRK\2423i\02\HASP.APP March 17,1994 ' - Harding Lawson Associates B-e - • • - • . • • • ' • r : , ' - . ' • • ' . ' . < ^ ^ — 301100 r. In accordance with 29 CFR 1910.120(ei)(3)(iy) or appUcable local regulations, regular (as defined in. Section 5.1.2 above) and occasional site persormel having com.pleted an initial 24-hour classroom instruction inust complete an additional 16 hours of offsite instruction and two days of field experience supervised by a trained supervisor before they are qualified -to engage in activities that may expose them to hazardous substances above'PELs. ' .'" , " '- • . B-5.1.4 Management and Supervisory Training In accordance with 29 CFR 1910.120(e)(4) of appHcable local regulations, individuals who manage or supervise personnel engaged in hazardous waste operations at the site must receive 40 hovirs of offsite instruction and three days of field experience supervised by a trained supervisor. In addition, management and supervisory persormel shall receive an additional 8 hours of speciaUzed training that addresses the safety and health program, training requirements, PPE and respiratory equipment programs, health hazard monitoring procedures, accident investigation, and emergency response procedures. . ' . .. , , . B-5.1.5 Refresher Training Annual refresher training in accordancis wdth 29 CFR 1910.120(e)(8) or applicable local regulations shall be completed at least armually followdrig the completion of the individual's 40-hour or 24-hour training course. Personnel wall be required to attend the annual refresher training to maintain their qualifications for hazardous waste site operations. B-5.1.6 , Documentation Training must be properly documented and filed onsite for reference by the SHSO or designated representative. Persormel reqiiired to rheet' the traiiiing requirements must present evidence of this training at the site. The SHSO is responsible for checking before each activity to Verify complete and cmrent docimientation. A copy of the documentation will be kept readily available or onsite, as~ applicable. - ' < > ' ' , ' " B-5.1.7 Exempt Personnel Exempt personnel requesting access to the work areas could include persormel making deliveries or performing repairs to utilities, public or government officials, untrained visitors, or local residents. Individuals frpm these groups wdll not be requireci td comply with the training requirements as previously stated or the medical monitoring as discussed iri Sectiori 5.2. However, access will be limited to designated work, delivery, or. observation areas to minimize potential exposure. Observation areas will be located upwind from site joperations, as determined on the basis of predominant wand directions, so as to limit exposure to dvist or chemical contaminants. Access to observation areas may be restricted by weather conditions or site,activities. Approvals.for exempting persormel and decisions on access limitation for other persormel wdll be handled on a case-by-case basis by the Field Operations Manager in consultation with the SHSO. B-5.1.8 tailgate Safety Meetings A tailgate safety meeting shall be conducted at least weekly,, whenever risks or hazards change, whenever new site persormel arrive, and when site operations warrant indoctrination and training. Tailgate safety meetings shall be conducted by the SHSO or another qualified individual. Where \woRK\2423i\02\HASP.APP March 17,1994 ' Harding Lawson Associates B-7 procedural deficiencies are identified, additional safety meetings wall be conducted to address the situation. The followdng wdll be addressed during the meetings: ' ' - • Review of plarmed activities . , • • Hazards suspected • >- • • . - PPE required '., . • • Communications procedures ' ; • ". , • • - Field personnel responsibilities • • ^ Decontamination procedures , , ' ' • • Emergency procedures The tailgate safety meetings wall be documented on the appropriate form (see Appendix BB). B-5.1.9 Safety Inspections and Audits The SHSO wall inspect the site daily to identify potential hazardous conditions or work areas. The DHSO may visit the site periodically io evaluate whether that work operations are being conducted in compliarice wdth the protocols and procedures outlined in this HASP. J , . ' . . ' • - ' • - ' B-5.2 Medical Monitoring HLA field employees working at hazardous sites more than 30 days per year will receive a baseline > and armual comprehensive medical evaluatiori to qualify for hazardous waste site assigninents and to monitor work-related illness or contamination. Other employees who are exposed to hazardous substances or waste or who participate in physically challenging work wdll receive a baseline and periodic exams (less frequently ihan annually). The frequency of these exams will be determined upon consultation with HLA's medical consultant, Environmental Medicine Resources,"Inc. (EMR), in Atlanta, Georgia. Any employee who suffers an illness or injury that imposes a medical restriction on his or her job duties must have a physician's release statement indicating that he or she is fit for duty before the, SHSO wdll permit that employee to return to full duty. This release must be issued by the area office contract physician. : , Site persormel also receive exit medical examinations at the termination of their employment wdth HLA. Medical records of HLA employees are kept on file at EMR in Atlanta, Georgia. Clearance letters from EMR are kept at the HLA iPhiladeiphia office. HLA is,not responsible for subcontractor v medical monitoring; however, subcontractors are expected tp monitor their employees according to OSHA requirements. . • : - Medical monitoring wdll include a medical examination and work history fpr each erhployee. Each ; employee wdll be evaluated to assess their ability to wear required PPE for site work. EMR is acquainted wdth 29 CFR 1910.120 and applicable local regulations. EMR wdll also be supplied wdth " the employee's duty description, anticipated exposure levels, PPE to be used, and ariy applicable information from previous medical examinations. A copyof EMR's written opinion of the employee's. fitness fpr hazardous duty will be provided to the employee. Medical monitoring will be required for persormel at the site, including visitors, subcontractors, client representatives, USEPA and GOVI officials, and others visiting the work sites who may Be exposed to contaminants exceeding accepted PELs. HLA is responsible for providing medical monitoring to HLA personnel only. HLA is not resporisible for ^providing medical monitoring for other parties visiting the \woRK\2423i\02\HASP.APP March 17,1994 - Harding L^wson Associates , B-8 site. However, HLA wdll review visitor: certifications to assess whether the monitoring is lip to date. Copies of the documentation wdll be kept readily available or onsite, as applicable. B-5.3 Respiratory Protection Policy / . • - . • . ' ' ; • ". . ' . HLA's respiratory protection program is managed by the DHSOs of the individual offices. The purposes of the program are as follows: . • Provide adequate respiratory protection to site persoiinel where there is a potential for exposure ' to toxic or nuisance substances in excess of allowable concentrations. . . . . V '. '• . • Provide adequate respiratory equipment to employees who may request such equipment. • , Determine that employees assigned to site work requiring respiratory protection are physically able to wear respiratory protection equipment. • Protect the employee's health during normal job duties. . ; • Objectives of the respiratory protection'program are as foUows: • Address the site hazards;- the need for respiratory protection, and the selection of the appropriate National Institute for Occupational Safety and Health (NIOSH) or Mine Safety and Health Administration (MSHA)-approved,equipment during preparation of this HASP. • Use engineering controls at the work site, to minimize the potential for exposure. If engineering , controls are not feasible, respiratory equipment must be used. • M^Lke available to employees the HLA Health and Safety Policy and Procedures Manual describing the issuance, cleaning, inspection, and'storage of respirators. This document is in each HLA office and is available for review by employees upon request. '• r - • - • , • Fit test employees required to wear respirators using isoamyl acetate and/or irritant smoke or a quantitative fit test. ."Testing shall jbe conducted armually for work on hazardous waste sites or every six months for asbestos work. Records are maintained by the DHSOs iri each office regarding whether the employee passed ithe fit test and what type^ and size respirator he or she is assigned. • \ ' .'Z . ' •" ' . • Inspect, maintain, sanitize, and appropriately store respirators, as determined by the DHSOs. Site visitors, subcontractors, or others who rnay request eritry into the work area where the potential for Level C activities exists must show proof of current (armual) respirator fit testing. Copies of this documentation will be kept readily available onsite, as applicable. B-5.4 Hazard Communication The DHSO in each HLA office is responsible for administering the program in his or her office. The hazard commimication program governs "hazardous substances" and excludes "hazardous waste." This program is part of the Health-and Safety PoUcy and Procedures Manual, which is generally kept in the DHSO's office and is available to employees for review. \woRK\2423i\02\HASP.APP March, 17,1994 , ' Harding Lawson Associates - B-9 B-5.4.1 Container Labeling HLA requires that containers and secondary containers of hazardous substances both in the office and at the job site be labeled as to the contents and appropriate hazard warning. • • B-5.4.2 Material Safety Data Sheets ' y . \ Material Safety Data Sheets (MSDS) are; obtained from the manufacturer when hazardous substances are purchased to conduct field activities. If the manufacturer does not include the MSIDS when the item is shipped, the manufacturer will be contacted by telephone for a facsimile transmittal of the MSDS. The MSDSs are kept in the DHSO's office and at the support facility for field activities, as applicable. The DHSO of each office must maintain and review aU MSDSs fpr new information. Significant health and safety information is made available to affected employees. Employees may . request any or aU MSDSs for review at any time. MSDSs for substances expected to be used during this investigation are included in Appendix BC. , ' ' ' • \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-10 301104 B-6.0 KNOWN SUBSTANCES IN THE STUDY AREA Available information indicates that volatile organic conipounds (VOCs), semivolatile organic compounds (SVOs), and metals are the primary chemicals found in soils at the site. Chemicals previously identified as present onsite, the rnedia in which they were detected, and the maximum detected concentrations are listed in Table B-1. Table 2-4 of the RIWP presents, a complete list of substances reported-at the site. - ,! , • . \WORK\24231\02\HASP;APP March~17,1994 Harding Lawson Associates B-11 301105 B-7.0 HAZARD EVALUATION AND MITIGATION A summary of potential hazards thought be present in work areas are listed below. Procedures for first aid and emergency care are included in Appendix BD. B-7.1 Chemical Hazards i Based^on planned field activities, the following are potential chemical exposure pathways: • Inhalatiori of airborne vapors,and contarninated particulates; • Eye and skin contact and absorption due to direct contact wdth vapors, liquids, and contaminated soil and sediment; and ' • Incidental ingestion of contaminated Uquids, particulates, and sediment. ,' Symptorns of exposure to VOCs and SVOCs may include headache, vertigo, visual disturbance, tremors, somnolence, nausea, vomiting, eye irritation, dermatitis, cardiac arrhythmias, paresthesia, . central nervous system (CNS) depression, lassitude, fatigue, dilated pupils, insomnia and throat ,irritation. Carcinogenic effects may also be possible. Mitigation' of chemical hazards rnay include the .use of PPE indicated in Section 9.0 and air monitoring wdth direct reading instruments to evaluate respiratory and explosion hazards. Underground pipelines should be located before drilling or excavating and the use of spark-ignition equipment prohibited in areas where the potential for explosiori 'exists. No smoking wdll be permitted, except in designated areas. ' , • Hazardous property information for cornmon cheriiicals is included in Appendix BA. , B-7.2 Physical and Mechanical Hazards , . , ' ^ . - I ' ' ' - • : - ' '. ' ' - • - • ' • • • V . " • • Physical and mechanical hazards associated.wdth the heavy equipmerit, tools, and,field activities to be. conducted include the potential for being struck by flying or falling objects during site cleararice;. slipping and falling due to wet or uneven surfaces; backstrain when moving equipment. Tripping hazards may be present in umeven, sloping, or wooded terrain. Mitigatiori of physical and mechanical hazards rnay include the following: •. Stay clear of earth moving equipment whenever possible; • Verify that equipment is in good condition; • Use of proper lifting techniques; ,' , . " ' • Do not stand or walk under elevated loads or ladders; B-7.3 Electrical and Utility Hazards Subsurface utilities may be present in work areas. In addition', overhead power lines may also be present. Electrical generators, submersible pumps, and other electrical equipment may also be used , during this project. Mitigation of utility'and electrical hazards may include but riot be limited to the followdng: - . • Bin-ied utUities should be located and marked before drilling or excavating; • A minimum of 10-foot clearance shouldjbernaintainedJrom overhead power lines; • If unavoidably close to buried br overhead power lines, have the power turned off, wdth the circuit breaker locked and tagged; \wORK\2423i\02\HASPj\PP March 17,1994 ' Harding Lawson-Associates B-12 301106 Maintain at least a 30-foQt clearance from overhead power lines; ,i Properly groimded electrical equipment. Use only three-wire grounded receptacles and extension cords; • Do not stand in water when operating electrical equipment; , - . • If equipment must be connected by splicing wires, make sure all connections are properly taped; • Consider all wires live until locked and tagged out; ~ ^ .». Be familiar with specific operating instructions for each piece of equipment;, and • Obtain permits, licenses, or right bf entry required by local authorities. B-7.4 Acoustical Hazards Acoustical hazards may be present during drilling, pumping, and samplirig activities. When a noise level prevents conversation in a normal voice at a distance of 3 feet, use proper National Institute of Occupational Safety and Health (NIOSH)-approved hearing protection. B-7.5 ' Heat Stress and Coici Stress Heat stress may be a hazard depending Jon the time of year the work plan and sampling plans are implemented. See Appendix BD for ,first aid arid emergency care. B-7.6 Natural Hazards . Natural hazards such as sunburn or Ughtriing may be present during field activities. On sunny days,, wear long sleeves and/or suriblock. During severe storms, cease field activities and seek shelter until the storm has passed. For other natural hazards, corisult the DHSO. B-7.7 Biological Hazards I Biological hazards may include toxic plants, infectious waste, rabid, agitated, or disease carrying animals or pets, poisonous snakes, and disease carrying or stinging insects. Mitigation of these hazards may include the foUowdng: , , , • ~ • Learn to recognize toxic plants, such as poison ivy, poison oak, and poison sumac; • Wear long-sleeved shirts, sturdy trousers, and boots when working'near toxic plants to minimize the potential for skiri contact; , ji i ' • If exposed to toxic plants, shower as soon as possible wdth a strong soap (e.g.. Eels Naphtha). . .Launder clothing; , , , • Do not touch plants that have hairy leaves, milky sap, thorny leaves, or fruit or seed pods; • Do not touch infectious waste or any items suspected of being infectious waste; • Do not approach or agitate animals, especially ones behaving strangely or foaming at the mouth; • Use insect repellerit to avoid coritact wdth ticks, mosquitoes, and other insects, as necessary..' Avoid contamination of field samples when using repellent;^ • If possible, avoid contact wdth poisonous snakes or other reptiles by quietly walking away. If bitten, seek medical assistance imrnediately; . • Avoid contact with rodents because they are frequently hosts to fleas, which can carry typhus and other diseases. Rodent urine may also contain spirochetes harmful to-human health; and • Avoid encounters wdth stinging insects. \woRK\2423i\02\HASP.APP March 17,1994 ' Harding Lawson Assoclates B-13 "\ B-7.8 Fire/Explosion Hazards Fires and explosions are not expected;'however, ABC-rated fire extinguishers wdll be brought-to the site. Drill rigs must have a 20-pound ABC-ra^ed fire extinguisher. Fire extinguisher use is limited to fighting very small fires. Do not atterri'pt to fight large, fires. , ' , ' Explosive or flammable material should only be stored in approved facilities as described in 27 CFR' Sectionil81 or applicable, local regiilation, and there will be ho smoking or spark equipment aUowed wdthin 50 feet of explosive or flammable storage or where flammable liquid or vapor is present. The SHSO may use a combustible gas indicator if he/she deems there is potential for explosive gas. B-7.9 Airborne Diist Hazards Airborne dust hazards may develop when strong wdnds or vehicle traffic are present. Take precaution to avoid breathing airborne dusts. Dust originating from the site may be contaminated (see Section B- 7.1). If potentially contaminated dust is noticed in the breathing zone, employees must either don a respirator with HEPA filters, or spray the area with surfactant tominimize the respiration qf dust. particles. 1, - , * , B-7.10 Other Hazards I . ' ' , • -' Confined space work, radiation hazards, and hazards associated wdth impoundments or bodies of water are not anticipated at this time. Should these or other hazards arise, either known or suspected, consult the DHSO. ' --• ' , \WORK\24231\02\HASP.APP March 17, 1994 Harding LiawsOn Associates B-14 301108 B-8.0 SITE OPERATIONS Zones wdll be established to prevent orminimize exposure to hazards by establishing boundaries to reduce migration of contaminants into clean areas.. For this'site, a three-zone approach wall .be used for all field activities. The zones will be identified during safety'briefings and will be clearly marked- • by traffic cones, barricades, signs, or other means. These three zorieis shallbe designated as the ' . Support Zone, the Contamination Reduction Zone, and the Exclusion Zone. Work area, entrance and exit shaU be through controlled access points established for each work location. B-8.1 Support Zone The Support Zone is the clean area in which'the possibihty of encountering hazardous materials or conditions is minimal. PPE and respiratory equipment are not necessary in the support zone. Inside the Support Zone, the followdng wdU be available: an effective mearis of comrnunication, first-aid supplies, drinking water, and other equipment used on the project. The Support Zone shall- also serve as the main point of contact for the visitor check-in and initiation of emergency services when necessary. , , B-8.2 Contamination Reduction Zone The Contamination Reduction Zone (CRZ) is the area where equipment and personnel are decontaminated before leaving the Exclusion Zone. Persormel will remove and/or decontaminate PPE and place it in appropriate containers. Site vehicles will be washed,or steam cleaned and equipment wall be decontaminated with soap and water in the CRZ. The CRZ wdliconsist of a decontamination' pad; a means of washing PPE, site vehicles, and equipment; containers for waste liquids, solids,, COj- propeUed air horns, and PPE; an eyewash/emergency shower; and a fire extinguisher. Eating, drinking, chewdng gum or tobacco, srrioking, or any practice that increases the probability of hand-to-mouth transfer and ingestion of material is prohibited in the CRZ. B-8.3 Exclusion Zone The Exclusion Zone includes the work activities at the site (e.g., drillirig, sampling, etc.). Only authorized, trained, and qualified personnel wdth the appropriate PPE shall be admitted, Persormel entering the Exclusion Zone must use the buddy system. If a situation arises where the buddy system cannot be used, constant visual contact wdll be maintained wdth at least one other worker. The maximium distance permitted-for visual contact is 200 feet. \ ' ' • • , . • • , • ^ • Work activities wdthin the Exclusion Zorie pose the greatest possibility of exposure to persormel and equipment. The Field Operations Manager shall be rnsponsible for controlling the access points and . limiting needs for authorized personnel.! The Exclusion Zone wdll be clearly marked with flagging, barricade tape, traffic cones, or other signalstp limit ncccss. A "hot line" will be established betweenithe CRZ .in(i the P^xcliision Zone. Unless emergency conditions exist, (see Section B-14.0) no,one \vill exit the Exclusion Zone or CRZ wdthout first implementing decontamination procedures. For (inlii.ig, well installation, sampling, and other intrusive work, a central decontamination station wiil be established for decontamination of material and equipment. Unauthorized persormel will not ix? [)<^rmitted to pass the "hot line" and eriter the contamination reduction zone or the exclusion zone, .\s the locations of field activities change, differing contaminarit reduction and support zones n-.iy bo established. Work areas are tp be set-up similar to those depicted in Figure B-3. . , _ '\woRK\2423i\02\HASP.APP March 17,1994 Harding Lawson Associates . B-15 ^^^^^s^^skm B-8.4 Work Zone Control ^^^^^^:z;^^kzmsA±^ B-8.5 er suitable warning devices. Pre-determined EmLrgeAcy Assembly Point ^--stis^ss^sha^;;^-^^^ - " - . • I- \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-ie B-9.0 PERSONAL PROTECTIVE EQUIPMENT AND ACTION LEVELS PPE is required to be .worn by workers-while conducting intrusive field activities.- InitiaUy, Modified Level D protection wdll be used for all intrusive activities. This wdll be upgraded to Level C or Level B. as necessary, if- action levels or conditions warrant. Should air monitoring indicate sustained airborne concentrations of organic vapors in the breathing zone above 500 parts per million, Levei A PPE would be required. However, work requiring Level A,PPE.is beyond the anticipated scope of this project and ' is therefore, not described. Should a situation requiring Level A PPE arise, personnel shall evacuate the area-and the DHSO should be notified. PPE levels to be used are defined as foUows: ' , Level D PPE . - . y • ' • • ,' • - Cloth coveralls/field clothes ' " Cloth or latex gloves Chemical splash goggles when Uquids present or safety glasses ' Steel-toed chemical-resistant boots orj, leather workboots (use of butyl rubber overboots is dependent on site conditions and the likelihood of working in wet areas) , Modified D PPE Tyvek" or Saranex~ coveralls , ; , Inner latex gloves and nitrile outer gloves , , Hardhat ; i ,i ' ' Chemical splash goggles when liquids are present or safety glasses Steel-toed chemical-resistant boots with butyl rubber overboots ,- '^ Foam earplugs or ear muffs (when necessary as defined in Section B-7.4) Level C PPE < Inner latex gloves and nitrUe outer gloves Hardhat Safety glasses or chemical splash goggles (if use of a 1/2-face respirator is permitted by the SHSO) ;, '^ ' Steel-toed chemical-resistant boots wdth butyl rubber overboots Foam earplugs or ear muffs (when necessary as defined in Section B-7.4) Full-face or half-face air-purifying respirator Level B PPE NIOSH-approved supplied air respirator wdth escape self contained breathing apparatus Tyvek™ or Saranex™ coveralls, ;i ' ^ Irmer latex gloves and nitrile outer gloves Hardhat ," : ' Steel-toed chemical-resistant boots with butyl rubber overboots Foam earplugs or ear muffs (when necessary as defined in Section B-7.4) \WORK\2423i\02\HASP.APP March 17,1994 Harding Lawson Associates • B-17 Action levels for known contariiinants shaU be based on the PEL or Threshhold Limit Values (f LVs) of the contaminants, whichever is the most conservative. Air monitoring will indicate airborne concentration's of organic vapors in the breathing zone. Action levels for unknowoi contaminants are based on the followdng: ,- ' i Sustained Instrument Reading for One ' Minute of Unknown Substance lin Breathing Zone Action Background Above background to 5 ppm 5 to 500 ppm above background Greater than 500 ppm above background Modified Level D . Level C • Levels , Evacuate the area and notify the DHSO PPE for HLA employees wdll be supplied by the SHSO. Subcontractors and visitors •will be required to supply their owoa PPE. Organic Vapor respirator cartridges must be replaced daily or whenever evidence,of coiitaminant breakthrough pccurs. Breakthrough describes a situation where the respirator cartridge filtering media no longer fUters out contaminants,, and contaminants can pass through the respirator cartridge, rendering it ineffective. Noticeable odors inside the respirator indicate^ breakthrough has occurred., , \WORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-18 301112 B-10.0 AIR MONltORING AND SITE OPERATIONS This section describes instruments and procedures that 'wiU be used for air monitoring activities. It may not be necessary to perforrri all df these activities at every work location. Decisions regarding air monitoring wall be made-by the DHSO and the SHSO. / , , A daily monitoring log wdll be kept by the SHSO for each piece of air monitoring equipment. The foUowing mforination wiU be recorde.d: " '. ' • Name and riiodel number of the equipment; • CaUbration information; - . • Field work to be performed; ' ~ • Air monitoring results and mpnitoring locations; • PPE worn; ' ' " " , •. Accidents or incidents; and !, ' , . . • Unusual occurrences and personnel complaints. , \ , • • - . . • • ,B-10.1 Gases and Vapors A photoionization detector (PID) or a flame ionization detector (FID) wiU be used to mpnitor breathitig zone concentrations of VOCs. Monitoring wdll be conducted contiriuously during sampling or intrusive activities. Calibratiori of monitoring equiprnerit wdll be performed daily before start-up of work. Cahbration gases to be used will be specific to the instrmnent per manufacturer instructions. HLA's standard operating procedures for field calibration and maintenance, of direct reading instruments, , ^, personal sampling pimips, and detector tubes is presented in Appendix BE. . • , B-10.2 Explosion Hazard A combustible gas indicator (CGI) rnay be used at the Work areas as appropriate to monitor the possible presence of flammable gases (e.g;, methane) or vapors. Equipment calibrafiori will be performed daily before start-up of work as described in Appendix BE. The alarm wdll be set to 10 percent of the LEL. If feasible, the calibration gas used 'wdU be specific to the combiistible gases that may be present'. Periodic monitoring for the presence of coiribustible gases will be performed at the sampling point. If ihe inonitoring instrument indicates the LEL is greater than 10 percent, immediately shut dowm all equiprnent, if possible, and persormel rriust leave the area. Notify DHSO immediately. Explosion- proof engineering controls, such as supply fans should be used to lower the LEL if possible. Personnel must not reenter the area until the LEL is less than 10 percent. B-10.3 Oxygen Deficiency in Confined Spaces Confined space entry is not anticipated during this, project. Should the need arise, however, before entering a confined space, an oxygen rrieter riiust be used to measure the oxygen concentration in air. If the oxygen concentration is less thari 19.5 percent or greater than 23 percent, entry to the space is prohibited. Supply fans should be used to ventilate the area. If the oxygen concentration cannot be StabiUzed between 19.5 and 23.5 percent, Leyel B PPE must be dormed to enter the confined space. Contact DHSO before proceeding into confined spaces. Permits may be required to enter confined spaces. ' ' '' •. Z^. J ' - ' • , \vvoRic\2423i\02\HASP.APP March 17,1994 : .. Harding Lawson Associatos B-19 . ) • 301113 B-11.0 RECOMMENDED LEVELS OF PROTECTION AND SAFETY PRECAUTIONS Initial recommended levels of PPE for the various field acUvities are described below They may be upgraded or downgraded, as necessary; by the SHSO as air monitoring results or site conditions permit. . ', . . , - • B-11.1 Site Clearance and Surveying Site clearance and surveying should present the lowest chemical hazard to personnel since these pperations result in minimal disturbance of contaminated areas. Level D protection has been initially selected for site clearance and survejdrig. ,, -^ , B-11.2 Monitoring Weli Installation, Soil Sampling, and Groundwater Sampling Modified Level D PPE has been initiali} selecited for soU sampling, groundwater sampling and SIUR ' unJess air monitoring results exceed the action levels described in Section B-9.0, in which case the PPE Will be upgraded appropriately. For groundwater sampling, the weU head should first be opened and allowed to vent for at least one minute prior-tc performing the work and personnel should approach the weUs from an upwind direction. Personnel should remab in an upwind direction whenever possible. ' , > The-St. Croix, Department of PubUc Works (DPW) will be advised of proposed weU locations prior to drilling. The DPW will advise whether proposed drUling locations will mtercept underground utUities m the area, if any. ' , : Safety cones, safety vests, barrier ribbon, or other types of highly visible placarding dr warning devices wdll be used if drilling activities take place on or near roadways or railways. \W0RKV2423i\p2\HASP.APP March 17,1994 I; Harding Lawson Associates B-20, ' . • ' . ' • ' 1; \ \ • • • ' ' • • ' . 301114 B-12.0 PERSONNEL DECONTAMINATION PROCEDURES Equipment decontamination procedures are described in the Sampling and Analysis Plan (Appendix B). ' ' . . >- ' ' The sequence for personnel decontamiriafiori for Level C PPE or Level B PPE field activities is described below. Persormel decontariiiriation for Level D PPE or Modified Level D PPE activities will include the appUcable procedures' described below. Decontamination will occur at a temporary job site decontamination pad as follows: ' [ • ' , ' • 1. If gross contamination is present, remove using vvater or other appropriate solution and rinse in clean water taking'care to prevent moisture from entering respirator cartridges. 2. Remove disposable overboots (if used). Remove outer gloves. , 3. Wash chemical-resistant boots wdth detergent solution and rinse wdth clean water. 4. Remove belt of SCBA straps (if used) and remove coveralls. Starting at the neck, roll the , coveralls off froni the insid.e out and down past the boots. Take care to prevent the release' and dispersion of di;sts or prevent contact wdth decontamination water that may have accumulated on the coverallsl Do not contaminate clothing inside the coveralls during removal. - . 5. Place disposable PPE in an appropriate container for disposal. 6. Remove the respirator. Clean and disinfect the respirators and place into a plastic bag for storage. . • ' \ , , , • -, • - • ' • " • " • • ; 7. Remove inner gloves. . !, 8. Thoroughly wash hands and face. ' . InformaUon as to the container contents, the location the contents were collected, arid the date fii!'".i wdll be recorded on the container and in the daUy log. \W0RK\2423i\62\HASP_APP March 17,1994 Harding Lawson Assoclates . B-21 li i. B-13.0 GENERAL HEALTH AND SAFETY PROCEDURES The foUowing health and safety procedures wall be used: h ' • ' . ' • ' - ' • HLA personnel conducting work acti-vdties at the site wdll be participants in the Company's Health and Safety Program which includes mandatory OSHA training and medical surveUlance. , - • . . A copy of the HASP wdll be kept onsite at all times ' • A supply of PPE 'wiU be kept onsite in sufficient quantity to enable field persormel td conduct . their duties in a safe marmer. ' - ' • Weekly taUgate safety meetings will be conducted to discuss hazards associated wdth tasks to be performed, personnel protection protocol, and emergency procedures. • A copy of the HASP wdll be supiplied to all field HLA field employees for their review and signature. , ' • No eating, drinking, or smoking wdU be permitted in contamination reduction or exclusion zones. - , , 1. •_., • • No source ignition wall be permitted in contamination reduction or exclusion zones areas unless cleared by the DHSO or SHSO. . , • Work wall cease during hazardous weather coriditions such as thunderstorms or tornadoes. \WORK\24231\02\HASP.APP'March 17, 1994 Harding Lawson Associates B-22 301116 B-14.0 EMERGENCY INFORMATION AND CONTINGENCY PLAN B-14.1 Emergency Phone Numbers and Directions to St. Croix Hospital Pertinent phone numbers for emergency situations ^are listed below: Ambulance- Hospital- PoUce Fire 9 2 2 . •• (809) 778:6311 St. Crobc Hospital 915 921 St. Croix Hospital has been contacted to assure that they can handle chemical exposure cases. Directions to St. Croix Hospital are outlined below. . ' . ' . . Turn left put of facUity. Follow Melvin H. Eyans Highway east. Pass a shopping center and stay in the left lane. Make a left at the traffic light (at Texaco service station). Follow aroimd curve past a Kentucky Fried Chicken Restaurarit (KFC) and stay in the center lane. Make the next right (after the KFC) and follow signs to St. Croix Hospital. , Emergency Contacts: / - Corporate'Health and Safety Officer (CHSO) Peter Rice John Kohler Edward Nemecek Jason Schindler DHSO Project Manager Asst. Project Manager: Client Contact .......„„.»H-™H— USEPA Site Managet GOVI Site Manager _ _ . „ . „ _ B-14.2 Emergency Signals (415) 892-0821 (office) (215) 627-4505 (office) (609) 273-0194 (home) (215) 627-4505 (office) (215) 428-1950 (home) (215) 627-4505 (office) (215) 884-6085 (home) C ) ' (office) { ) ______ ioBcB) All field activities wdll cease in the event that an emergency situation occurs. The emergency situation wdll be signaled by a blast from a COj-propelled air horn. " . ~ The followdng hand/body emergency communication signals should be used when other forms of communication are difficult or impossible: Signal Meaning Hand clutching throat Hands on top of head , , Thumbs up T Grip partner's wo-ist or- both hands around partner's waist Out of air/can't breathe Need assistance OK/I'm all right/I understarid Leave area imrnediately If the emergericy occurs in the Exclusion Zone, all field persormel wdll quickly move to the Contamination Reductiori Zone for an appropriate decontamination before exiting to the Support Zone. \VVORK\24231\02\HASP.APP March 17, 1994 Harding Lawson Associates B-23 01117 • ' , , • . \ . ' . ^ - " . , In life-threatening emergencies, decontamination may not be appropriate. The emergency decon- tamination decision wdll be made by the SHSO. Emergency situations occurring outside of the. Exclusion Zone or when using Level Di'^PPE will not reqiufe decontamination at the Contamination Reduction Zone before, adrriinistering first-aid.' •' ' Minor emergencies will be handled witjiin tlie Support Zone utiUzing the onsite first-aid kit. A portable emergency eyewash or a total!pf 32,:ourices of eyewash fluid wdll be avaUable in the CRZ. If working at a remote location (more thari 15 minutes from an emergency medical facUity), at least one HLA field person wdU be tiained in first aid. 'The appropriate eniergency response persormel (i.e., ambulance and fire departrnent) wdU be contacted for all major emergencies. The SHSO wdll drive the hospital route before field activities begin. A wnritten report of aU emergen- cies woU be submitted to the DHSO. Accident related forrhs are located in Appendix BF. Copies of this report wdll also, be sent tOj the appropriate agencies. i B-14.3 Contingency Plan ! -. ' - ' ' - y z • ' • ' • ' ' ' • This Contingency Plan has been developed by HLA to present procedures that should,be followed in the event of ari emergency at a field operation. A variety of events that are potential hazards to human health and the environment are discussed, including the followdng: • Personnel Injury : • A funnel cloud or tornado sighting ' , • An explosion • A chemical or petroleum spUl or accident •' , • Other events presenting, a hazard to human health or the environment This section also specifies the general procedures you should follow, whorii you shoiUd notify, and the information you should report if you are the first "on the scene of an emergency'. . B-14.3.1 Response Sequence for First,Arrivals If you are first on the scene, respond as foUows: •' 1. Evacuate the incident area (if necessaiy). Remember tliat your safety must be the primary consideration.' ,v - 2. Restrict access to the incident area. • 3. Restrict the use of ignition sources for incidents involving flammable substances. ' 4. Contact the Field Operations Manager or the local ernergency response organization (see Section B-14.1 for telephone numbers). Report the followdng information: - Your name . , , - - ' - Company affUiation - Telephone number from which you are calling Location and type of incident . / Injuries, if any, and the nvimber,and type of those injuries (note respiration, consciousness and heart beat) DetaUs concerning the substarice(s) involved (identification, amount, spiU rate, size of area involved), if knowrri | \woRk\2423i\02\HASPjvpp March 17,1994 Harding Lawson Associates B-24 ' , .' . ' y • ^ . 301118 Direction the spUl is moving and the direction the wind may be dispersing airborne i contaminants . • ,. ' - Suorficial material on which.the.spUl occurred (i.e., asphalt, gravel, etc.) - , Any first response action that has been taken • ' - , The time the incident occurred or when you discovered it Any additional pertinent information 5. Notify the SHSO after the i'emergency response team has been contacted. The SHSO wall then notify the local DHSO. '' . 6. . Coordinate 'with emergency.response personnel when they arrive. A ' • . ' • . , ' , . . • ' . ' , ' • ' B-14.3.2 Response for Incidents Involving Another Contractor If the incident involves another contractor's activity: Evacuate the area immediately, Proceed'to the predetermined assembly point (see Section B-S^S). ' , : ' Decontaminate and remove PPE if the incident is not life-or health-threatening. - Make sure the SHSO knowrs you,,are present. ' B-14.3.3 Emergency Response for Severe Weather Conditions This section specifies what you shouldjdo injthe event,of a severe weather emergency, including electrical storms, high wdnds, heavy rain or haU, and tornados. Electrical Storms Seek shelter at the support jfaciUty or in the field vehicles. - Do not stand near or unde£high objects, such as trees and drUling rigs. - ' If possible, lower the driUing rig mast. ' , \ . High Winds Seek shelter at the support facUity (U anchored) or in the field vehicles; Do not drive high-profUe vehicles at high speeds. Park vehicles heading into the wdrid. - , , • Avoid breathing dust (don a respirator or wear safety goggles and a kerchief covering your nose and mouth). Heavy Rain or Hail Seek shelter at the support facUity or in the field vehicles. Do not attempt to drive a vehicle if you arc in an area that is or. has the potential for flooding unless you are moving out of a low area. \WORK\24231\02\HASP.APP March 17,1994 ' \ Harding Lawson Associates B-25 301119 Tornadoes , , • - - Seek shelter underground or in a closet, bathroom, or iriterior wall of a substantial , buUding. ' ," • [ , • , ' , ' • Get under something sturdy, and cover your head. ' , • . Do not stay in a traUer or vehicle. If you cannot get to shelter leave the traUer or vehicle and lie flat in the nearest ditch if substantial shelter is not ayaUable. Stay away from large areas of glass. Be aware of the potential for Uve downed wires. . Make sure the telephone handset is on the hook. Do not use the, telephone for non emergency calls. , -. • . , B-14.3.4 Emergency Response for Earthqual(es Inside - ' ' ':,.••-" ' .• '. '. _ . If an earthquake occurs whUe you are in a building, follow these instructions: If near an exit, leave the buUding fast. , - Stand in an interior doorway or get-under a desk or table. Stay away from areas containing a large amount of glass. Do not use stairways or elevators during the tremor. If possible, turn off gas supplies and ignition sources. > , - Be aware of the potential for live dowoied wares. Make sure the telephone handset; is on the hook. Do not use the telephone for non emergency caUs. • - Evacuate the buUding when the tremors have ceased. Be aware of the potential, for aftershocks. I f - Report to a predetermined assembly area and notify your supervisor or the area monitor that you are safe. " , , - Report missing persons. i ' ! , .'. . . Outside • ' , ' • , ' • ' • - , ' . •" , ' A ^ 7 ' . • ' . ;•• • If an earthquake occurs whUe you are outside, follow these instructions: Avoid buUdings, trees, areas wdth large amovmts of glass, and power lines. - , Avoid dowmed wires. , , , - If operating heavy equipmerit,or a motor vehicle, stop immediately but stay in the \ ••:... !•• ' untU the tremors have stopped. • ' . ' ' ' If operating a motor vehiclejon a bridge, proceed to solid ground if the end of the hmiw- :^ close. , , . ' ' I - If operating a motor vehicle on a bridge at mid-span, get out of the vehicle and w.iik ; •.• ' nearest solid ground., ! ; , ' • • , 'i '". ' , B-14.3.5 Emergency Response for Flash Floods If a flash flood warning is issued, climb to higher ground. Seek shelter on stable ground. Do r.i.i ^•,l. in an area, that is characterized by uincompacted material on a steep slope. \wORK\2423i\02\HASP.APP March 17,1994 . Harding Lawson Assoclatesi B-2« 301120 B-14.3.6 Emergency Response for Fires If a small fire occurs, extinguish it wdth the fire extinguisher in the field vehicle (ABC extinguisher). Remember to follow these directions tp put out the fire: Use the appropriate type of fire extingmsher (e.g., do not use a water type fire extinguisher . on an electrical fire). Aim at the base of the flame. . ^ Remember that the contents of the extinguisher only lasts a few seconds. If a large fire occurs at the work site, foUow these instructions: Move flammable and combustible iterns, if possible, out of the path of the fire. ' ., - Call the fire department. , ~ - Do not attempt to put out a large fire wdth the field vehicle fire extinguisher. Report the incident to the Field Operations Manager. , - , • ' , • • . , \ ' B-14.3.7 Fire Prevention Steps to be taken to minirnize the potential of a fire include the followdng: ,~ - • Obey "No Smoking" signs . ' . ' > ' Label and store flammable liquid containers in a protected, ventUated and approved area - ,Use only approved containers for flammable Uquid storage ' -, Use minimal amounts of flammable Uquids Shut off engines before refueling, if possible Do not refuel a hot engine unless an ABC-rated fire extinguisher is nearby Store oUy rags in a self-closing rrietal container. Dispose container properly Bond and ground all flamrriable Uquid containers and tiansfer equipment when transfer- ring or fUling product t . - Use intrinsically safe equipriaent in areas potentiaUy containing flammable vapor. B-14.3.8 Emergency Response for Explosions If an explosion occurs, foUow these instriictions: Evacuate the site immediately. - If feasible, decontaminate yourself and others. - Do not address medical emergencies untU you are out of danger. Call the Field Operations Manager or local emergency response organization when you are out of danger to report the incident. I - - •- B-14.3.9 Emergency Response for Spills The follovidng sections provide guidance regarding emergency response to a chemical spUl or accidental discharge of groundwater, including irutial response to the incident and cleanup. Precautions you should take to nUnirriize the likelihood of a spiU are preserited in Section B-14.3.9.4. \woRiO2423i\02\HASP.APP March 17,1994 ' Harding Lawson Associates B-27 301121 B-14.3.9.1 Initial Spill Response When a spill occurs: - , Mimrnize or contain the fldw by'shutting off a valve, repairing the leak, rightin-an over- -' turned barrel, or whatever action is appropriate. Remember that your safety is°of primary concern. Only attempt emergency^response actions U you can do so without injury or harm tp yourself. , , ; •''.-' Provide first-aid to injured persons as needed. - If the spUl occurs on a porous surface, (e.g., soU, gravel) mark the area in preparation for excavation if that is determined to be .\he appropriate response action. If the spUl occurs on concrete, asphalt, or simUar material, use sorbent material to contain tiie spUl Adsorbent materials wUl be kept -in tiie support facUity. Cover,the area witii soU, a tarp . plastic, or other appropriate material if tiie spUled material is volatUe and cannot be - cleaned up imrnediately. ' • • ' ' i- ' , , ' ' • • ' ' . ' -. • , - Contact tiie Field OpeTations^Marlager or tiie local-emergency response organization (as , applicable) to report tiie mcident, At least two HLA personnel must remain near tiie work ' area m a safe location 30 feet upwind of the spUl until emergency response representatives arrive. - Depending on the location and clieriiical nature of the spUled liquid, initial response action may reqmre donning Level C or Level B PPE. B-14.3.9.2 Spill Site Decontamination HLA and subconti-actor site personnel involved in tiie response action wUl undergo personal - decontamination up.wind of the incident site. The-SHSO wdll autiiorize field personnel to leave the job site or contmue work, as appropriate. "The Field Operations Manager wdll provide guidance regarding decontamination and/or disposition of equiprnent and vehicles. If personnel come in contact wdth fuel, they should remove and dispose contaminated PPE, chanoe out of contaminated field clothing, and wash exposed skin with soap and water. ° B-14.3.9.3 Cleanup Materials and Used Personal Protective Equipment Disposal - Materials used in spUl cleanup must be containerized. The Field Operations Manager should assess vvhetiier the surficial material on which the spUl is located requires trieatment or removal and relay this information to the project manager. - • Equipment and tools used during spUl cleanup 'wUl be decontaminated followdng procedures described in the Sampling and Analysis plan,(see Appendix A). B-14.3.9.4 Spill Prevention To minimize the potential for a spUl, yoii should follow these guidelines: - Inspect stored materials at the, beginning of each work shift. Any abnormaUties and steps . taken to remedy the situation must be reported immediately to the Field Operations Manager. •' - ' , \wORK\2423i\02\HASP.APP March 17,1994 , Harding Lawson Associates B-28 3 01122 Inspect equipment at the beginning of each day.. Equipment condition, as weU as any notation of leaks or staining that may be related to or indicative of a potential spUl, \\nl\ be recorded in a field logbookjand reported to the field operating manager. Loose and or • worn cormections and worri hoses wdU also be noted. Any abnormalities must,be.reported , immediately to the Field Operations Manager and steps wUl be taken to remedy the situation before continuing! tiansfer activities. Make sure materials being stored are compiatible with the containers in which they are being stored. Materials that are Ukely to react when exposed together wdli not be stored in the same area. Caustics and corrosives wdll be stored in separate cabinets affixed wdth caution labels. SpUlable items, if stored ori shelves, wdU be rio higher than 4 feet off the floor surface. (This height is to Umit the potential for getting a toxic substance in,the ' • e y e s ) . ' , • • • ' - ' ' • Liquid storage containers rriust have a secondary containment system such as a liner 'wdth a berm constiucted of 4-inch by 4-inch boarding that can contain a quantity 10 percent greater than that of the original coritainer. - Transfer Uquid wdth catch basins,vmder each joint or valve or wdth the hose or pipe lined so that no liquid can escape. B'14.3.10 Responsibilities of Field Personnel Wear the correct and appropriate PPE for the task. ; Use monitoring equipment applicable to the anticipated hazards Have a decontamiriationarea set up for fieldwork. Use approved decontamination procedures as discussed in Section'B-12.0 of this HASP and in the project SampUng and Analysis Plan (Apperidix A). Maintain a means to decontaminate affected personnel. Treat minor injuries using the onsite first-aid kit. Take personnel wdth serious injuries to St. Croix Hospital or contact a medical emergency response tearri. ! ? Contact emergency response for health- or life-threatening injuries. Victims should be taken to St. Croix Hospital by the medical emergency response team All persormel at the site where the incident has occurred must completely decontaminate and be debriefed by the SHSO before leaving the job site (see Section B-15.0). B-14.3.11 Emergency Response Equipment The followdng is a list of equipment that is required to be avaUable for emergency response actions: 10-pound ABC-rated fire extinguisher i - - First-aid kit Eyewash station or eyewash bottles - Celliilar phone or radio \WORK\24231\02\HASP.APP March 17. 1994 Harding Lawson Associates B-29 301123 B-15.0 EMPLOYEE EXPOSURE/INJURY INCIDENT REPORT In the event of an employee exposure br injury incident, an employee accident report wdU be fUed wdth the DHSO and Project Manager. This form is included in Appendix BF. \WORK\24231\02\HASPAPP March 17, 1994 Harding Lawson Associates B-30 301124 TABLES \WORk\24231\02\HASPAPP March 17j-i994' HARDING LAWSON ASSOCIATES 301125 Table B-1. Summary of Substances Detected Island Chemical Company. St. Croix, iU.S. Virgin Islands Substance Reported Maximum Concentration Detected (ppm) . Sou Groundwater Acetone Aldrin Aluminum 4.2 0.012' 21,700 Aritimony Arsenic Barium 26.6^ 8' 136 0.003' 0.007 Benzaldehyde Benzene Benzophenone 1.37 15,000 3.0' 0.04 0.4' Beryllium 7 BHC A BHC ^ 7^- I I Bis(2-ethyl hexyl)phthate 2-Butanone Butylbenzyl phthalate 51 ' 0.085' 1 0.28 Cadmium Calcium Carbon tetrachloride 2:4 82,100 J, 0.003 127 <S?^ : - Chlordane 7 Chlordane Chlorobenzene 4' ,4.9' I Chloroform Chloromethylbenzene l-Chloro-2-methyl benzene 0.11 0.039 4,400 40' Chromium 57.e 0.027 See last page for notes \WORK\Z4231\02\HASP-B1.TAB : HARDING LAWSON ASSOCIAtES 301126 . , ;- . • . ]' i ' Table B-1. Summary of Substances Detected Island Chemical Company '• St. Croix, U;S. Virgui Islands . . ' , - ' . \i Substance Reported • , • Maxirnum Concentration Detected (ppm) ' , SoU Groundwater Cobalt Copper . Cyanides 25,4 367 0.153 0.053 2-Cyclopyridine DDE 4,4-DDT , J 1,1-Dichloroethane ' 1,2-Dichlorbethane trans-1,2 -Dichloroethene 0.02 J ) Dichlorophenyl rnethane • Dieldrin • • Di-ri-butyl phthalate 0.02 0.0041' 75 Di-n-octyl phthalate Endosulfan I Endosulfan II 17 0.004' J 0.0039 Endosulfan Sulfate Endrin Ketone Ethylbenzene Fluoranthene Fluorene 9H-Fluorene-9-one Fluorenone FIuoreth5aie Heptachlor J 0.45 J Heptachlor epoxide 0.0048' See last page for notes \WORK\24231\02\HASP-Bl.TAB HARDING LAWSON ASSOCIATES 301127 ll \ '-' '• . Table B-1. Summary of Substances Detected Island Chemical Company St. Crobc, U.S. Vhgin Islands Substance Reported ', Maximum Concentiation Detected (ppm) . . • - SoU Ground^vater Iron Lead Magnesium 183,000 466 11,800 , 0.121 0.011 71.6 Manganese Mercury Methoxychlor 1,430 0.4 0.0012 Methyl tertiary butyl ether l,l-oxybis(Methylene) bis-benzene Methylene chloride 1,240 O.4J 2-riiethyl propanol 2-Methyl-l-heptene' 4-Methylnaphthalene 0.47 0.21 0.63 Naphthalene Nickel Pentachlorophenol 3.1 47.8' 0.08 Pentane Phenanthrene Phenols 0.01 2.4 0.161' Phenyl acetate Potassium Pyrene 2,990 I Pyridine Quinidine Gluconate Quinine Sulfate 3,014 8,227 2,594 Selenium J See last page for notes \WORK\2423i\O2\HASP-Bl.TAB HARDING LAWSON ASSOCIATES ' Table B-1. Summary of Substances Detected ' • Island Chemical Company , . St. Croix, U.S. Vugm Islands , ' • • Substance Reported • -[• , Maximum Concentration Detected (ppm) .1 \ SoU, Groundwater SUver Sodium Tetrachloroethene 1,840 0.0009' 0.008 596 ThaUium Toluene 1,1,1 -Trichloroethane 13,880 J 0.029 0.38 Trichloroethene Vanadium Xylenes Zinc 0.0008' 97.2 18 1,500' 0:0503^ 4.85 Notes., ' Estimated concentiation Substance not detected See last page for notes \WORK\24231\02\HASP-Bl.TAB HARDING LAWSON ASSOCIATES 301129 FIGURES \WORK\24231\02\HASP.APP March 17, 1994 HARDING LAWSON ASSOCUTC8 •'.^pl^^Crots g'.,"f""'T^'5i^<- •\ • y ^ . y \ x \' ^\" 7'r~7^fy-zky z :«;^jli,-'•- V , - . ' V j i ' ^ - . ^~i=^..''i='^>.-> - '.• . - ' Z - . . . K J - , - . . T V -yj^k^'- \ z z : • - ^ \ •• - • ^ y y k y ^ \ \ ^ , * . . \ z •: :.. 'V ••\-icai:;,.yy\'i )j^Z\\ \ ^ ^ ^ ^ ^ k k k k y ^ k y ^ ^ - \'"-- -'••' ('r •''', ? ••rii'^Z-!^ *'(p=^. (. y - . y y - ' i A y '^ '-. i ' - ' ^ - 'OZZ.- - . — ^Golden .,»«?-> •' •'Grove-: ^ A ^ • 'Zy^zyy^M '^zzyAmymA ZM V < - t ; * ^ ^ ' : U M Z \ Z '•' — - - f y -.^=y•• ' ^ x ^ ' ^ V ^ . y'k' Lzyzby^-y^yY • ' \ & ' • ' ^ ^ ^ Z L .,.—• Cooper, \-, .'• -kk^,z...^.^^''^k'^kkkS^^^^' ' y j V SOURCE: USCS 7.5 Mlnu'.t Cuod Mop: Chrlsllons'.sd. V.U ; 2000 .=^T. FOR ILLUSTRATION PURrCSIS ONLY H a r d i n g ' Lawson Associates SfTE LOCATION MAP — — . Engineering ond S S S Environmentol Servic'es ' . — 131 North Third Street " - Philodelphio. PA 19106 S S - : 2 1 5 - 6 2 7 - 4 5 0 5 ISLAND CHEMICAL COMPANY St. Crcix. U.S. Virgin Islands 301131 F1CUR£ B-1 ; DRAWN iJSW joe NuueER 24231.2 «>PROVE> FILE 24231AOI DATE 8/25/93 Rr/ISED OATE Generotor ond Hre Pump Building 25 50 100 APPROXIMATE SCALE IN FEET RAf^F MAP SOURCE ADAPTED FROM: PROPOSED ICC SOIL SAMPLING LOCATIONS BY ENVIRO-SCIENCES. INC. DATED: 6 / 1 9 / 8 6 AND SITE MAP. VI CHEMICAL. ST. CROIX. U.S.V.l. BY NUS CORPORATION DOCUMENT 0 2 - 9 1 0 1 - 0 4 - 5 1 , UNDATED = Hording Lawson Associates SSSI Engineering ond : = : Environmentol Services r . — 131 North Third Slr««t ' " - Philodelphio, PA 19106 " " " 215-627-4505 Loadino Dock Surface Drain CZD I i \ I SITE MAP LEGEND FENCE EXISTING PRODUCTION WELL EXISTING ABOVE GROUND STORAGE TANK TANK PAD-FORMER ABOVE GROUND STORAGE TANK LOCATIOM 3 01132 ISLAND CHEMICAL COMPANY ,St. Croix, U.S. Virgin Islands ncuRE B-2 DRAWN JSW JOB NUMBER 24231.2 APf'i^OVED RLE 2 4 2 3 1 8 0 1 DATE 1 / 3 1 / 9 4 REVISED DATE Prevailing wind direc:icn Support Zone Access Control Points. Contamination Reduction. Corridor. Contamination Reduction Zone (CRZ). - ' ' . • . • ^ , ' - Exclusion Zone. Note: Area dimensions not to scale. Distances between points may viary. Source: DAS Environmental Harding Lawson Associates Engineering ond Environmentol Services - S i S S r . — 131 North Third Street S — S ^ S " .Philodelphio. PA 19106 « — «215-627-4505 TYPICAL WORK ZONE LOCATION MAP ISLAND CHEMICAL COMPANY ST. CROIX. U.S. VIRGIN ISLAND FIGURE B-3 ;DRAWN I JSW JOB NUMBER 24231.2.C.4 Ai>PROVED S-BASE DATE 10/12/93 REVISED DATE APPENDIX BA HAZARDOUS PROPERTY INFORMATION \WORK\2423l\02\HASPAPP March 17, 1994 HARDING LAWSON ASSOCIATES 301134 Table BAl presents available hazaidous property information for the chemical compoimds identified as being present onsite. These compoimds are indicated by shading. The nonshaded compoimds were left in the table to provide information to job site personnel if these compoimds are imexpectedly encoimtered at the site. 301135 Table BAl. Hazardous Property Information Island Chemical Company, Inc. ComjMund Water Solubility* Specific Gravity Vapor Density Flash Point Vapor Pressure'^ LEyUEL TLV- TWA'' IDLH Levei Hazard Properties* Acute Exposure Symptoms' Acenaphthene Aoenaphthylene Acetic acid esters Ad««»«;ftlU|U>d»l) ^^m-AtthjitUMb A«^t#* UniMtm Acrolein Acrylonitrile Aldrin Alpha-«ndosu Aluminum msma Anthracene Antimony Ifan Arochlor 1254 Aiochlor 1260 iPii Asbestos Alrazino Ui O M M Ui Insoluble 3.93 @ 25'C Soluble Miscible U % Miscible Miscible 4096 7.0% liiMtlutila Insoliibla Insoluble Soluble Insoluble Insoluble 12 Mg/l Slightly — Insoluble 70 ppm 1.024 0.8988 1.0492 1.05 1.08 0.8 0.78 0.8410 0.8000 1 7 1.74 2.708 0.77 1.25 6.69 1.50 l.SB 5.727 Variable 1.87 S.32 NA 5.32 N/I N/I 2.0 N/I 1.9 1.8 S/A N/A N/A 0.59 6.15 N/A N/I N/I N/A N/A N/A N/A N/l 110 102 120 0 42 -15 30 121 N/A N/I N/A 250 N/A >286 >286 N/A N/F N/A 10 @ 131.2°F 9.12 X 10"* 11 mm 11 mm 4 mm 180 73 mm 210 83 6 X 10 • 1 X 1 0 ' N/A 6460 1.0 0.0 7.7 X l O ' 4.05 X l O ' N/A . N/A 3.0 X 10-' N/A N/I 5.4%/16% 4.096/19.996 2.796/10.396 2.596/1396 3.096/16.0% 2.896/31% 3%/17% N/A N/A h 1696/25% 0.696/? N/A N/l N/l N/A N/F N/A N/I 0.2 mg/m^ 10 mg/m' 10 ppm 5 ppm 750 ppm 20 ppm 0.1 ppm 1 ppm 0.25 mg/m' 0.1 mg/m' 5mg/m^ 25 ppm 0.2 mg/m^ 0.5 mg/m' 0.5 mg/m' 0.5 mg/m' 10 Mg/ro' 0.2 to 2 fibers/oc 5mg/m' N/I N/I 1000 mg/m' 1000 ppm 1000 ppm 20,000 ppm 4,000 ppm 5 ppm 50 ppm 100 mg/m' N/E N/I 500 ppm 200 mg/m^ 80 mg/m' 5 mg/m^ 5 mg/m' 100 mg/m' N/E N/E Tox Flam, Tox, Care Flam Comb, Cor, Tox Comb, Cor, Tox Flam. Tox. Vol Comb, Tox Flam, Tox, React, Vol Flam. Tox, React, Care Flam. Tox, Scare Tox Flam, Tox, Scare Cor, Tax Flam, Tox, Care Tox Tox, Scare Tox, Scare Tox, React, Care Tox, Care Tox Eye, Skin Eye, Resp, Skin Eye, Resp. Skin Eye, Resp, Skin Eye, Resp, Skin Diz, Drew, Eye, Resp, Skin CNS, Eye, Skin Abd, CNS, Conv, Diz, Diar, Draw. Eye. Head, Naus, Resp, Skin. Trem, Uncon, Vom, Weak. Diz, Eye, Head. Naug, Resp, Skin, Trem, Weak CNS, Coma, Conv, Diz, Eye, Head, Naus, Resp, Skin, Uncon, Vom Coma, Conv, Diar, Eye, Head, Naus, Resp Skin Eye Eye, Resp. Skin Skin Diar, Eye, Head, Vom Eye. Resp, Skin Eye, Resp. Skin Abd, Coma, Conv. Diar, Fevr, Resp, Skin, Trem, Vom, Weak Resp, Skin Eye, Roup, Skin See last page for notes \WORK\24231\02\HASPBA-1.TAB Compound mm Bentonite BeM^yeli^ Benz(a)anthraoene iie Slisiiili Benzenethiol Benzidine Benzo(a) pyrene Benzo(ghi)perylene BntuioScvM IJpswpJiOOqne lW«MwqflJ(«»«iw Benzo thiazol Benzyl aloohol Beryllium BHC, A. G (Undane) bis-2(EthyIhexyl)- phthalate Boron SOB k t l itaga lot inMra 1 Water Solubility* Soluble N/A Soluble Slightly 820 ppm Specific Gravity 3.6 2.5 1,043 N/I 0.8765 No Information Found Insoluble Soluble Slightly Insoluble SlighUy soluble Insoluble Slightly Slightly Slightly soluble _ ' Insoluble 2000 ppm @25''C Jnsoluble O H Ui - J 1.0728 1.250 1.351 N/I 1.2659 N/I 1.32 1.246 @ 20°C 1.040 to 1.050 1.85 1.85 0.9861 2.45 Vapor Density N/A N/A NI N/I 2.8 N/I 6.36 8.7 N/I 4.21 N/I N/I 3.72 N/A N/A 16.0 N/I Table BAl. Hazardous Property Information Island Chemical Company, Inc. Flash Point N/A N/A 62 N/I 12 127 N/A N/I N/I 121 N/I 100 N/I 220 N/A N/A 420 N/I Vapor Pressure'' N/A N/A NI 38 X 10"'' 75 2 N/I >1 1 X l O ' " 1 @ os-c N/I 0.1 mm N/I 0.0 N/A 0.32 N/I 11.856 x W^ @ 2140°C I,RI/UEL N/A N/A NI N/I 1.396/7.9% N/I N/A N/I N/l N/A N/I N/I N/I 0.0 h N/A N/I h TLV- TWA* 0.5 mg/m' 0.3 mg/m' NI N/l 0.1 ppm .05 ppm No safe level 0.1 mg/m' N/I N/l N/I 0.4 mg/m' N/I 0.5 mg/m^ 2/ig/ni^ 0.5 mg/m^ 5 mg/m3 N/I IDLH Level 250 mg/m^ N/I NI N/I 3000 ppm N/l N/E N/I N/l N/I N/I 300 mg/m' N/I N/I 10 mg/m' 1000 mg/m^ N/E N/I Hazard Properties' Flam, Tox Tox Cor. Tox Tox, Scare Flam, Tox, Care Flam, Tox Flam, Tox, Care Tox, Scare Tox, Scare Cor, Flam, Tox N/I Cor. Tox React Tox Tox, Care Tox, Care Tox, Tera Flam, React, Scare Expl P a g e 2 Of 1 5 Acute Exposure Symptoms' Eye, Resp, Skin Resp NI N/I CNS, Coma, Conv, Diz, Draw, Eye, Head, Naug, Resp, Skin, Trem, Vom, Weak Diz, Eye, Head, Naus, Resp, Skin, Vom Eye, Resp, Skin Eye, Resp N/I Eye, Resp, Skin N/I Eye, Skin N/I Diar, Head, Naus, Skin, Vom Resp, Weak CNS, Eye, Resp, Skin Abd, Diar, Eye, Resp, Naus N/I \WOKK\24231\02\HASPDA-1.TAB Compound l-Bromo-2- chloroethene Bromodichloro- methane Bromoform Bromomethane wmm Mfiityt**?^ ^ t « « ^Bntri>t)«t}t(tk>l Bulylbenzyl-phthalate Piiiitiiii Butylphthalate ^m (SIMum liypetdUloddb Carbon disulfide ^MliWi Carboxylic acids Cement Chlordane (alpha and gamma) Chloroacetic acid Water Solubility* SlighUy Insoluble 0.01 g 0.1 g Soluble 353 g/1 Soluble Soluble Insoluble Insoluble Insoluble 1 Specific Gravity 1.70 1.980 2.887 1.732 0.8063 0.805 0.9012 N/I 1.12 N/I 1.0484 8.642 No Information Found SUghUy 0.8% Insoluble Soluble Insoluble Verv soluble 1.2632 1.5967 0.982 Variable 1.59 to 1.63 1.58 Vapor Density 4.94 NA NA 3.3 2.6 2.41 4.07 NA 10.8 NA 9.58 N/A 2.67 5.3 NA N/A 14 3.26 Table BAl. Hazardous Property Information Island Chemical Company, Inc. Flash Point CF)" N/A Ul¥ NA? NA' 99 16 NA 260 390 -6.7 340 N/A -22 NA? NA N/A 225 302 Vapor Pressure" 760 @ 82.7°C N/A 5 1428.8 6 77.5 0.76 NA 8.6 X 10* NA <0.01 N/A 297 91 NA N/A 0.00001 @ 1 @ 43''C I.EIAJEL NA' NA? NA' 1096/16% 1.4%/11.2% 1.4%/11.4% NA NA NA NA 0.5%/? h 1.3%/50.0% NA' NA N/A 1296/74% mn TLV- TWA"" NA N/E 0.5 p p m 5 ppm* 50 p p m 200 p p m 25 p p m NA NA NA 5ixg/m^ 0.2 mg/m' 1 ppm 2 ppm* NA 5-15 mg'm' 0.5 mg/m* N/E IDLH Level NA N/E N/A 2000 ppm 8000 ppm 3000 ppm NA NA NA NA 9300 mg/m^ 50 mg/m' 500 ppm 300 ppm NA N/E 500 m ^ m ' N/E Hazard Properties' Tox Tox, Vol, Scare Flam Tox, Vol, Care Flam Flam. Tox Flam, Tox, Vol NA Flam, Tox Flam. Tox Flam Tox, Care Flam, Tox Tox, Vol, Care Tox Tox Flam, Tox Cor, Flam, Tox P a g e 3 of 1 5 Acute Exposure Symptoms' Eye. Resp, Skin CNS, Eye, Resp, Skin CNS, Conv, Eye, Head, Naus, Resp CNS, Coma, Conv, Conf, Eye, Fevr. Head, Naus, Resp, Skin, Trem, Vom, Weak Diz, Draw, Eye, Skin Diz, Eye, Head, Resp, Skin, Vom Diz, Eye, Resp, Skin NA Skin CNS, Exe. Resp, Skin Eye, Resp, Skin Abd, CNS, Diar, Dro«r, Eye, Head, Naus, Resp, Skin Vom, Weak Eye, Head, Naus, Resp, Skin Abd, CNS, Coma, Diz, Diar, Drow, Fevr. Head, Naus. Resp. Skin, Trem Eye. Skin Eye, Resp, Skin CNS, Conv, Eye, Resp, Skin, Unoon Eye, Resp, Skin See last page for notes LJ O M U> 00 \W0RK\2 4231\02\HASPBA-1 .TAB Table B A l . Hazardous Property Information Island Chemical Company, Inc. Compound Water Solubility* Specific Gravity Vapor Density Flash Point Vapor Pressure" LEI/UEL TLV- TWA"" IDLH Level Hazard Properties' Acute Exposure Symptoms [3»I«IO^O«PBP 0.05 g 1.11 3.9 i - C h U w SlighUy 1.06 m6thy{b«ax»tu 4-Chloro-3-methyl- Soluble NA phenol 2-ChloronaphUialene 6.74 mgA 1.1371 2-Chlorophenol SlighUy Chrysene Cobalt 1.24 No InformaUon Found _ ' 7.20 Insoluble 1.274 Insoluble 8.92 ' 8.92 Creosol (aU isomers) 2% 1.03 Cyanides 58 to 72% 1.5 •"••'""•••••""•"-•••• C O 2,4-D <--~, 0.07 ppm 1.416 CD See last page for notes_ NA NA NA NA N/A NA N/A N/A NA N/A N/A 65 123 N/A NA 107 N/A N/A N/A N/A 178 NA' N/A 8.8 4-Chloro-3-cresol Chloroethane 2 -Chloroethylv iny I ether CWoroform Chloromethane Soluble 0.6 g Insoluble 0.8 g 0.74% NA 0.8978 1.0475 1.4832 0.9159 NA 2.2 3.7 4.12 1.8 NA -58 80 NA' 32 NA 1033.6 30 160 38,000 NA NA 0.017 1.0 N/A 6.3 x 10"' 0.0 N/A 1.0 0.0 0.0 1.396/9.6% 75 ppm NA NA 3.8%/15.4% 1000 ppm NA N/E N/F 2 ppm* 8.1%/17.4% 50 ppm' NA 50 ppm N/A NA 2400 ppm NA 20,000 ppm N/E 1000 ppm Flam. Tox, Vol Tox Flam, Tox, Vol Flam, Tox, Vol Tox, Vol CNS, Coma. Diz. Eye, Head, Naus, Resp. Skin, Trem, Uncon, Vom, Weak Skin CNS, Diz, Drow, Eye, Head, Resp, Skin, Uncon Eye, Resp, Skin CNS. Coma, Conv, Diar, Eye. Head, Naus Resp, Skin 10,000 ppm Flam, Tox, Vol, Care NA N/A h N/A N/A h 1.196/? NA' N/A NA N/E NA NA NA N/E 0.5 mg/m^*' N/E 0.2 mg/m^ 200 mg/m' 0.5 mg/m' 20 mg/m' 1.0 mg/m^ N/E 5 ppm 5 mg/m' 250 ppm 50 mg/m' Tox Tox Tox Cor, Tox Tox, Care Scare Tox Tox Flam, Tox Tox, React 10 mg/m' 500 mg/m' Tox Abd, CNS, Coma, Conv, Conf, Diz, Diar, Eye, Fevr, Head, Naus, Trem, Vom, Weak CNS, Conf, Diz, Eye, Resp, Skin NA Eye, Resp, Skin Eye, Resp, Skin Diz, Resp, Skin, Vom Resp, Skin "^ Skin Diz, Diar, Eye, Fevr, Resp, Skin, Trem, Vom, Weak CNS, Conf, Resp, Eye, Skin Diz, Head, Naus, Resp, Uncon, Vom Conv, Conf, Eye, Resp, Skin, Trem, Weak \WORK\24231\02\HASPBA-t.TAB 6£II0£ Compound 4.4'-DDD 4,4'-DDE 4,4'-DDT p,p'-DDD p,p'-DDE p.p'-DDT Di-n-butylphthalate Di-n-octylphthalate Diazinon Dibenz(a,h)anthracene Dibenzofuran Dibromochloro- methane Dibromochloro- propane 1,2 -Dibromome thene Dichlorobenzene 1,2-Dichlorobenzene 3,3'-Dichloro- benzidine Dichlorodifluro- methane t^l-OldblowMUuuli; See last page for notes Water Solubility* Insoluble 0.010 ppm Insoluble 0.005 ppm 0.010 ppm NA Insoluble Insoluble SlighUy SlighUy Insoluble Insoluble 0.1% SUghUy SlighUy Insoluble Insoluble Insoluble 0.1 g CJJ O M M O Specific Gravity 1.476 0.99 0.99 1.385 NA 1.1678 1.05 0.09 1.117 1.282 1.08863 @99°C 2.451 2.8 2.48 1.30 1.234 NA 1.486 ©so-c 1.1757 ' Vapor Density 11 NA . NA 11 NA 3.73 9.58 16.0 N/A NA 5.8 NA 2.09 NA NA NA NA 4.1 8.4 Table BAl. Hazardous Property Information Island Chemical Company, Inc. Flash Point 150 N/A 1.62 NA NA NA 322 420 N/A NA 32 NA 170 NA' 151 150 NA N/A 22 Vapor Pressure" 10.2 x 10-' 6.5 X 10-* 1.7 X 10"' 10.2 X 10"^ 6.5 X 10"* NA 1 mm @ 150°C <0.01 4.1 X IO"* 1 X IO"'" 0.0044 @ 25''C NA 0.8 NA 1.2 1.2 NA 3800 © 1 6 . 1 ^ 182 LRTAJEL N/A N/A N/A NA NA NA 0.596/? NA N/A NA 2%/14% NA ti/F NA' 2.296/9.2% 2.2%/9.2% NA N/A 6%/16% TLV- TWA*" N/A NA 1 mg/m* NA NA NA 5 mg/m' 5 mg/m' 0.1 mg/m' NA N/E N/E 10 ppb NA 500 ppm 50 ppm N/E 1000 ppm 100 ppm IDLH Level N/A NA N/E NA NA NA 9300 mg/m' N/E 360 mg/m' NA N/E N/E NA NA 1000 ppm 1000 ppm N/E 50,000 ppm 4000 ppm Hazard ProperUes' Flam. Tox, Scare Tox, Scare Tox, Care Tox, Scare Tox Tox, Scare Tox Tox, Care Tox, React Flam, Tox Flam, Care Flam, Tox, Vol Cor, Flam, Tox, Care NA Flam, Tox Flam, Tox, Scare Tox, Scare Tox, Vol Flam, Tox, Vol P a g e 5 Of 15 Acute Exposure S)rmptoms' Abd, CNS. Coma, Conv, Head, Naus, Skin, Trem, Vom, Weak Eye, Resp, Skin CNS, Conv, Conf, Diz, Eye, Head, Resp, Skin, Trem, Vom CNS, Skin Eye, Resp, Skin Resp, Skin Eye, Resp, Skin Eye, Resp, Skin Skin Eye, Resp, Skin NA CNS, Diz, Drow, Eye, Resp, Skin, Uncon, Vom Eye, Naus, Resp, Skin NA Eye, Resp, Skin Diz, Eye, Head, Resp, Skin Eye, Resp, Skin CNS, Conf, Diz Abd, Diar, Drow, Eye, Resp, Skin, Trem \WORK\24231\02\HASPBA-1.TAB Table B A l . Hazardous Property Information Island Chemical Company, Inc. Compound Water Solubility* Specific Gravity Vapor Density Flash Point Vapor Pressure" LEiyUEL TLV- TWA"" IDLH Level Hazard ProperUes' Acute Exposure Symptoms' 1,1-Dichloroethene 0.9% 1.2554 2250 mgA NA 3.4 3.4 2.4-Dichlorophenol Soluble 1.383 5.62 Dicyclo|>enl*(ltar>e 1,2-Dich loroprc>|Mi>« Slightly 0 U.UI2 4 .SS 0 .'5^» Ifl :i U 55 14 1,2-Dichloroethene Dichlorome thane 2,3-Dichlorophenol Soluble Slightly soluble Miscible NA 1.27 1.2565 1.33 NA 3.34 NA 2.9 NA NA 36 N/A 237 200 32 72 64 591 NA 400 350 12%/19% 50 p p m 5000 p p m .179 mm NA NA NA 0.075 mm 1.4 40 cis-l.a-Dichloro- propena trans-l,3-Dichloropro- pene Dicyclopentadiene Dieldrin iliU ililiwi DieUiylphthalate 7.12-Dimethybenz(a)- anthracene Dimethylmelhylphosp honale (DMMP) >ee last page for notes Insoluble Insoluble SlighUy 0.02% Insoluble Miscible Insoluble Insoluble Soluble t J O l-» M 1.2 1.2 0.9302 1.75 0.81 to 0.90 0.71 1.12 NA 1.15 @ 20° C 3,8 3.8 4.55 NA NA 7.66 NA NA 83 83 32''C N/A 130 -15 325 187 NA 28 28 1.4 7.8 x 10"^ NA 192 mm 1.65 X 10-3 NA NA 6.296/16% 5.6%/11.4% 9.7%/12.8% 9.796/12.8% 1 ppm* 1 ppm* 200 ppm N/E 1000 ppm N/E 4000 ppm N/E Flam, Tox, Vol, Care Flam, Tox, Vol, React, Care Flam, Tox, Vol Flam, Tox, Vol N/A N/E 0.896/6.3% 5 ppm 3,496/14.5% 75 ppm 5%/14.5% 1 ppm* 5%/l4.5% 1 ppm* 0.8%/6.3% 5 ppm N/A 0.25 mg/m' 0.6%/7.5% N/E 1.896/10.1% 10 ppm NA 5 mg/m' NA NA NA NA N/E NA Tox, Care Cor, Flam, Tox, Scare Tox CNS, Coma, Diz, Diar, Eye, Naus, Resp. Skin, Trem, Vom CNS, Eye, Resp, Skin Eye, Resp, Skin Abd, CNS, Diz, Eye, Naus, Trem, Vom Eye, Naus, Resp, Skin Eye, Resp, Skin Abd, CNS, Conf, Eye, Head, Naus, Resp, Vom, Weak N/E 2000 ppm N/E N/E N/E 450 mg/m' N/E 2000 p p m NA NA Flam, Tox, Vol Flam, Tox, Vol, Care Flam, Tox, Vol Flam, Tox, Vol Flam, Tox, Vol Tox, Care Flam, Tox Flam Tox Flam, Tox, Care Diz, Eye, Resp, S k m Abd, CNS, Diar, Drow, Eye, Head, Resp, Skin, Trem, Vom Abd, CNS, Diar. Eye, Mead, Naus, Resp, Skin, Trem Abd, CNS, Diar, Eye, Head, Naus, Resp, SUn, Trem Diz, Eye, Resp, Skin Coma, Conv, Diz, Head, Naus, Vom Eye, Resp, Skin Eye, Resp, Skin CNS, Eye, Resp, Skin Eye, Resp, Skin NA NA \WORK\24231\02\iL\SPBA-l.TAB Compound 2,4-Dimethylphenol Dimethylphthalate Dimethyls ulfide 2,4-Dinitrophenol Dinoseb Dioxin 1,2-Dipheny I hydrazine Dithiane Dursban Endosulfan I and II Endrin EUumol EUiion Ethylene dibromlde EUi^bkM glycol Soe U>l ftmifa lof nub-* Water SolubUify* Specific Gravity Vapor Density Table B A l . Hazardous Property Information Island Chemical Company, Inc. Flash Point (•F)b Vapor Pressure" LEL/UEL TLV- TWA"* IDLH Level Hazard ProperUes' Acute Exf>osure Symptoms Soluble SlighUy Insoluble 0.9650 1.189 0.8483 @ 20°C 5600 mgA 1.683 No InformaUon Found 0.0052 g 1.2647 19.3 mgA NA Miscible 1.158 No Information Found No Information Found 1 g 1.625 0.7 ppm 1.398 Insoluble 1.74 Insoluble SlighUy SlighUy Slightly Miscible 0.015 g 1.70 0.789 1.22 0.90 NA 0.867 NA >112 6.69 295 2.14 .55 6.35 5.8 NA N/A NA 1.59 NA NA NA 3.7 Slightly 2.17 lo 2.18 5.07 soluble In^x.liuhla 1 4'.) Ui i O KA m m m NA 184^ N/A 100°C NA NA N/A N/A 12.8 -13°C 24 55.4 55 NA' 41<J 1 X IO-'' Low 40 1.5 @ 10"' 74 mm NA 10 NA 10 @ 92.3°C 0.01°C 15 2 X 10"' 1 @ 151°C 7.4 X IO"'" 1 @ 103°C <1 NA 1.87 X 10"' N/A NA NA 0.996/7 5 mg/m' 2.296/19.7% NA NA Tox, Scare 9300 mg/ mg' Tox NA Flam, Tox NA NA Flam, Tox NA Eye, Naus. Resp, Skin Diz, Eye, Resp, Skin Drow, Eye, Head, Resp, Skin, Uncon NA N/A 4.7 ppm 100 ppm NA No safe level 0.1 ppm NA N/E 80 ppm Flam, Tox Tox, Scare Flam, Tox, React, Care, Expl Eye, Resp, Skin Eye, Resp, Skin Eye, Resp, Skin N/A 1.0 mg/m' 0.1 mg/m' 0.1 mg/m' N/E N/A 0.1 mg/m' 3.396/19% 1000 ppm N/A 0.4 mg/m' 2.096/11.5% 400 ppm NA NA 1.096/6.75% 100 ppm 17.4 @ 30''C n/F 0 Of) mm NA 200 mg/m' N/E N/E 200 mg/m' N/E N/E 10,000 ppm NA 2000 ppm 400 ppm 500 ma/m' Tox Flam. Tox Tox Tox, Scare Flam, Tox, Tox Flam, Tox Flam, Tox Expl Flam, Tox, Vol Cor, Flam, Tox, Scare Expl. Eye, Resp, Skin Eye, Resp, Skin CNS, Conv. Conf, Diz. Head. Naus, Trem Uncon, Vom Abd, Conv. Diz. Head. Naus, Weak, Vom Eye, Resp, Skin NA Eye, Resp, Skin Drow, Coma, Diz, Uncon, Vom Abd, CNS, Diz, Drow, Eye, Head, Naus, Resp, Skin, Uncon, Vom, Weak Eye, Resp, Skin CVS, Skin \WORK\24231\02\IL\SPBA-1.TAB • Table B A l . Hazardous Property Information Island Chemical Company, Inc. Compound Water SolubUity* Specific Gravity Vapor Density Flash Point (•F)b Vapor Pressure" LEiyUEL TLV- TWA"" IDLH Level Hazard Properties' Acute Exposure Symptoms Fluoranthene Fltsmm FlWtWWTOfll' FluoroaceUc acid Freon 113 Gasoline Germanium iiiiiiiiiii lil mmn Heptachlor expoxide Heptachlor Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclo- pentadiene Hexane 2-Hexanone Ky3«fKfe{qti<r«?id Hydrocyanic acid *mh!i,o»tiU«t(« NA Insoluble NA NA No InformaUon Found Soluble in hot water SlighUy Insoluble Insoluble Soluble 1.3696 1.5635 0.72 to 0.76 5.323 NA No InformaUon Found No InformaUon Found Insoluble Insoluble 0.035 ppm Insoluble Insoluble 0.002% SlighUy Miscible Miscible NA 1.57 1.5691 @ 23.6''C 1.5542 1.7019 0.66 0.801 NA 0.69 INo InformaUon Found NA NA NA 6.5 3.4 NA NA NA N/A 9.83 8.99 9.4 2.97 3.5 NA 0.94 107 NA NA N/A -45 NA NA NA N/A N/A N/A NA' -21.67°C 64 NA O-F 0.0 10 @ 14 NA 284 Variable NA NA NA 0.0003 1.09 X IC 1.675 @ 0.080 10 16 NA 630 NA NA NA 0.1 mg/m' NA 2.5 mg/m' N/A 1000 ppm 1.4%/7.6% 300 ppm _'" NA NA NA 700 mg/m' NA NA 4500 ppm N/E NA NA 5.6%/40.0% 4.7 ppm 50 ppm Tox, Care Tox Tox Tox Flam, Tox, Vol Tox NA NA N/A N/A N/A NA' l.l%/7.5% 1.2%/8.0% NA N/E 0.5 mg/m' 0.5 mg/m' 0.02 ppm 0.01 ppm 50 ppm 50 ppm NA N/E 100 mg/m' N/E NA N/E 5000 ppm 5000 ppm NA Tox, Scare Flam, Tox, Tox, Scare Tox, Scare Flam, Tox Flam, Tox Flam Cor Tox Eye, Resp, Skin NA • Eye, Resp, Skin Drow, Resp Eye, Resp, Skin NA NA CNS, Conv, Conf CNS, Eye Eye, Head, Resp, Skin, Trem Eye, Resp, Skin CNS, Diar, Eye, Naus, Resp, Skin, Vom Diz, Eye, Head, Naus, Resp, Skin Eye, Resp, Skin Abd, CNS, ConV, Eye, Naus, Resp, Skin, Vom Eye, Head, Naus, Resp, Skin, Vom See last page for ncteg_r \WORK\24231\02\HASPBA-1.TAB e^TToe C o m p o u n d oiivtttifuit^ Indeiie Indeno(l,2,3-CD) pyrene Iron Isodrin ^SliU Kerosene EPS U n d a n e (BHC) Magnanese Magnesium iiBiiliiii Malalhinn P^M Methane ^ » Methycyclohexane 1.1-Mediyl bis benzene 2-Methyl-l-heptane See last page for notes Water SolubUity* Soluble in Warm Water Specific Gravity NA No InformaUon Found Insoluble ShghUy/ Insoluble Insoluble Soluble Insoluble 1 7.3 ppm _ ' Insoluble 145 ppm 1 ShghUy Miscible Insoluble 0.997 NA 7.87 1.31 0.79 0.83 to 1.0 11.3437 1.85 NA 1.74 1.23 13.5939 0.7168 NA 0.7694 No InformaUon Found No InformaUon Found 1 Vapor Density NA NA NA N/A N/A 2.08 NA N/A NA N/A N/A NA 7.0 0.554 NA 3.39 j J Table BAl. Hazardous Property Information Island Chemical Company, Inc. Flash Point (»F)b N/A 173 NA N/A NA' 53 100 to 165 N/A NA N/A N/A >325 N/A -306 54 NA Vapor Pressure" >/ATM NA 1 X 10"'° N/A N/A 33 5 N/A 9.4 X 10"* N/A N/A 1.25 X 10"^ 0.0012 1520 @ -152.3°C NA 43 I.EIAJEL N/A NA NA h N/A 2%/12% 0.7%/S.0% h m h h NA h 596/15% NA NA TLV- TWA"" 5 p p m 10 p p m 0.2 m g / m ' 5 m g / m ' N/E 400 p p m N/E 50 /tg/m^ 0.5 mg/m' 5 m g / m ' N/E l O m g / m ' 50 /xg/m'""' Asphyxiant NA 400 p p m IDLH Level 100 p p m N/E 700 mg/m' NA N/E 20,000 p p m N/E 700 mg/m' 1000 mg/m' NA N/E 5000 mg/m' 28 mg/m' NA NA 10,000 p p m Hazard ProperUes' N/A Tox Tox, Scare Tox Tox Flam, Tox Flam. Tox. Vol Tox Tox Tox Flam, Rad Flam, Tox Tox Asphyxiant Flam, Tox Flam, Tox Acute Exposure S y m p t o m s ' Eye, Resp, Skin Resp, Skin Eye, Resp, Skin Resp Eye, Resp, Skin Eye, Resp, Skin Eye, Resp. Skin Abd. Coma, Conv, Diz, Diar, Head. Trem, Vom, Weak, NA CNS. Fevr, Weak CNS, Resp, Vom Eye, Resp Abd. Diar, Naus, Resp, Skin, Trem, Vom NA Abd. CNS, Coma, Conf, Conv, Diz, Drow, Head, Naus. Nerv, Unoon, Vom CNS, Diz, Eye, Resp, SWn \WORIC\24231\02\HASPBA-1.TAB Table B A l . Hazardous Property Information Island Chemical Company, Inc. Compound Water Solubility* Specific Gravity Vapor Density Flash Point rF)"" Vapor Pressure" LEiyUEL TLV- TWA*" IDLH Level Hazard ProperUes' Acute Exposure Symptoms' M#sy(Hu»:«{i)tP^ 2% 1.335 1.33 M:«&ylig^bi||i SlighUy 2-Methylnaphthalene Insoluble 1.025 2-MeUiylphenol 2% 1.047 4-Methylphenol 2% 1.039 Mef!Ly^|>it>|Mbol No InformaUon Found M^fHyTtCPrtlfliybulyl No InformaUon Found 22.9 2.93 NA 3.72 3.72 Mirex Molybdenum MQ(»0eiIi)utoIomln« )l<TitwUR*<jl<J N-nitrosodi- phenylamine Naphthalene Naphthenes Naptha Insoluble NA Insoluble 10.2 No Information Found No InformaUon Found Insoluble NA Nitric acid 2-Nitrophenol Octane Pentachlorobenzene Pentachlorophenol See last page for notes Insoluble <0.01% NA Miscible SlighUy 0.7 ^g/ml 0.24 ppm ^>SJigh<ly 1.15 0.7083 0.89 to 0.97 8.9 1.50 1.495 0.7028 1.8342 1.98 N/A N/A NA 4.42 NA NA N/A NA NA 3.86 NA 9.20 None 22.78°C NA 178 187 NA' N/A NA 174 -4 20 N/A N/A NA 56 NA N/A 350 380 0.0661 1 0.2 N/A 20 NA 14%/22% 1.4%/7.5% NA 1.35%/? l.l%/2% 50 ppm* 50 ppm N/E 2.3 ppm 2.3 ppm 5000 ppm 5000 ppm N/E 250 ppm 250 ppm Tox, Vol, React Flam, Tox Tox Flam, Tox Flam, Tox NA' h NA N/E N/E 10 mg/m3 NA NA NA Tox, Scare Flam 1 @ 52.6°F NA <0.0 N/A 48 1 @ 49.3°C 14.1 16.416 X 10"^ 0.0001 0.9%/5.9% 1.3%/8.4% l.l%/5.9% h N/A NA l%/6.5% NA N/A 10 ppm NA 100 ppm 0.1 mg/m' 2 ppm NA 300 ppm NA 0.5 mg/m^ 500 ppm 10,000 ppm 10,000 ppm N/E 100 ppm NA 3750 ppm NA 150 mg/m' Flam, Tox Flam, Tox Flam, Tox Tox, Care Tox Tox Flam, Tox Flam, Tox Tox. Care CNS, Coma, Eye, Head, Naus, Resp, Skin. Unoon, Weak CNS, Conf, Eye, Resp, Skin Eye, Fevr, Head, Skin CNS, Conf, Eye, Resp, Skin CNS, Conf, Eye, Resp, Skin Skin Eye, Resp Flam, Tox, Scare NA CNS, Eye, Resp, Skin CNS, Eye, Resp, Skin Diz, Drow, Eye, Resp, Skin Conv, Diar, Drow, Naus, Resp, Skin, Vom Eye, Resp; Skin Diz. Eye, Head, Skin, Uncon Eye, Resp, Skin Diz, Eye, Resp, Skin Diz, Eye, Head, Naus, Resp, Skin, Vom, Weak \WORK\24231\02\HASPBA-1.TAB S^TTOe Table BAl. Hazardous Property Information Island Chemical Company, Inc. Page 11 of IS Compound Water SolubUity* Specific Gravity Vapor Density Flash Point (•p)b Vapor Pressure" LEIvOJEL TLV- TWA"" IDLH Level Hazard ProperUes' Acute Exposure S y m p t o m s ' 2-Pentanone P h e n a n t h r e n e |vPhfffM^]fiBfW PKMttdl Polychlorinated biphenyls (PCBs) Pota»>iuin •ulfatf PoiMtlUUtt-t-bOlpKid* 0.04 ppm Insoluble Insoluble 0.63 0.8051 1.06 No Information Foimd 8.4% Insoluble Insoluble 1.0576 NA 1.38 3.0 6.14 3.2 NA N/A -57 45 171°C 175 NA 200 400 @ 6 5 ' 16 1 @ 118.3°F 0.4 NA 0.0006 1.596/7.8% 120 ppm 1.596/8.2% 200 ppm N/A 0.2 mg/m' 1.896/8.6% 5 ppm NA NA N/A LOMg/m^"' 15,000 ppm 5000 ppm 700 mg/m' 250 ppm NA 5mg/m' Flam, Tox Flam, Tox Flam, Care Cor, Tox NA Tox, Care Eye, Resp, Skin Diz, Eye, Resp, SUn Resp, Skin Conv, Eye, Resp, Skin, Trem NA Coma, Drow, Naus, Unoon, Vom, Skin Soluble NA No Information Found .Solul>ls .VI 1,35 mg/l 1271 Miscible 0.9780 No Information Found NA sn m 0.982 NA NA NA 68 NA NA NA NA NA NA NA NA NA NA NA NA 6.85 X 10 ' @20°C 20 NA 0.2 mg/m^ 700 mg/m' 1.8%/12.4% 5 p p m 3600 p p m Flam, Tox, Care Eye. Resp, Skin Flam, Tox Diz, Eye, Resp, Skin ( ^ M i y ()ulftldtli^;$iUddna<A QfMa9^mymUi QfMmmSm Quinoline ^<s?Bc;««4 $BQd Sol^oiiud Ui Ci a\ Soluble Soluble Soluble Soluble Soluble SUghUy Soluble Insoluble Insoluble NA NA NA NA 1.0900 NA 2.65 4.5 NA NA NA NA 4.45 NA N/A N/A NA NA NA NA N/A NA N/A N/A NA NA NA NA 1 @ 59.7''C NA N/A N/A NA NA NA NA 1.296/? NA N/A N/A NA NA NA NA NA NA 5-15 mg/m' 0.2 mg/m' NA NA NA NA N/E NA N/A 100 mg/m' NA NA NA NA Flam, Tox NA Tox, Care Tox NA NA NA NA Eye, Resp, Skin NA Eye, Resp Eye, Skin, Resp See last page for notes \WORK\24231\02\HASPBA-1.TAB Compound « ^ Swi^um^tfiwtote SodtWIt iKKUSiMl^ Sodfaitt l)ti;»Aio(i|§| S^WtitMOKt^ fk)il&Mttalmi(to $pdHwnl>«(»t?n»tft smmi^^stoKtdA :§0q-wci%m^*ktf^^ BumntkM Supona 2,3,7,a-Tetrachloro-di- benzo-p-dioxin 1,1,2,2-Telrachloro- ethane ^iMiii Tetiachlorome thane ppiip^l W?.«5''KS?S Thiodiglyool o j Tin ° l - l Water SolubUit/ _ ' SUghUy Soluble Soluble SlighUy Soluble Soluble Soluble Specific Gravity 10.5 NA « No InformaUon Found Soluble Soluble 2.13 NA No Information Found 135 mgA 19.3 mgA 0.3% 0.15 g/ml SlighUy 1.36 NA 1.5953 1.6227 1.59 No InformaUon Found _ ' • Soluble Insoluble 11.85 1.18 5.75 7,28 Vapor Density N/A NA N/A NA NA NA 5.8 5.8 5.3 N/A NA N/A Table BAl. Hazardous Property Information Island Chemical Comfiany, Inc. Flash Point CF)'' N/A NA N/A NA NA NA N/F N/F N/A N/A 320 N/A Vapor Pressure" N/A NA 1.0 NA NA 7.4 x 10"'° 9 @ ao'F 14 91 N/A N/A N/A I.EIAJEL h NA N/A NA NA NA NA' NA' N/A h N/A h TLV- TWA"" 0.01 mg/m' NA 2 mg/m^ NA NA Lowest poss. exposure 1 ppm* 25 ppm* 2 ppm 0.1 mg^m' N/E 2.0 mg/m' IDLH Level N/E NA 250 mg/m' NA NA N/E 150 ppm 500 ppm 300 ppm 20 mg^m^ N/E N/E Hazard Properties' Tox NI Tox NA Tox Tox, Scare Tox. Vol, Care Tox, Vol, Care Tox, Care Tox Tox, React Tox Page 12 ef 15 Acute Exposure Symptoms' Eye, Skin NA Eye, Resp, Skin Eye, Resp, Skin Skin CNS, Eye, Resp, Skin, Weak Abd, CNS, Coma, Diz, Drow. Eye. Head. Naus, Resp, Skin, Trem, Vom Abd, Coma, Diz, Drow, Eye, Head, Naus. Resp. Skin, Uncon CNS, Eye, Fevr, Naus, Resp. Skin Abd, CNS, Diar, Naus, Skin, Trem, Vom Resp, Skin Abd, Head, Eye, Resp, Skin. Vom Saa U*l ftrnga (<» imtm \WORK\2 4231\02\HASPBA-1 .TAB • Compound " 2,4,5-TP (sUvex) Trichlorobenzene 1,2,4-Trichloro- benzene ^ s ^ ^ m 1,1.2-Trichloroethane ^ ^ ^ 1,1,2-TrichloroeUiene Trichlorofluoro- melhane 2,4.5-Trichlorophenol 2.4,5-T Trichloropropane TrimeUiyl benzene Trini trobenzene 2,4,6-Trinitrotoluene Vanadium See last page for notes Water SolubUity* 0.05 g 140 ppm 19 ppm 19 ppm @ 22°C 0.7 g 0.44 g/lOOg 0.1% 0.1% 0.11 g 1190 mgAcg Insoluble Soluble Miscible Soluble Insoluble SUghUy 0.01% Insoluble CO O l-» M 00 Specific Gravity 0.866 1.209 1.4542 1.4634 1.3390 1.4397 1.4642 1.4642 1.7 1.7 1.8 1.3889 NA NA 0.86 to 0.95 1.76 1.65 7.14 Vapor Density 3.2 NA 6.26 6.26 4.6 4.6 4.5 4.5 NA None 11 5.1 NA NA 4.15 NA 7.85 N/A Table BAl. Hazardous Property Information Island Chemica] Company, Inc. Flash Point CF)" 40 NA' 105 210 NA' NA' 90 90 NA' NA' N/A 180 365 NA 130 NA 240°C N/A Vajjor Pressure" 22 N/A 0.29 0.29 100 19 58 58 690 0.022 0.0 3 NA NA NA 3.2 X 10-* 0.04-0.109 N/A LEIAJEL 1.396/7.1% N/A 2.596/6.6% NA 7.5%" 12.5% N/A 896/10.5% 696/10.5% NA' NA' N/A 3.296/12.6% NA NA 0.996/6.4% NA NA h TLV- TWA"* 100 ppm NA 5 ppm 5 ppm 350 ppm 10 ppm 50 ppm* 50 ppm* 1000 ppm 10 mg/m' 10 mg/m' SO ppm NA NA 25 ppm NA 0.5 mg/m' 0.05 mg/m' IDLH Level 2000 ppm NA NA NA 1000 ppm 500 ppm 1000 ppm 1000 ppm 10,000 ppm N/E 5000 mg/m' 1000 ppm NA NA NA NA N/E N/E Hazard ProperUes' Flam, Tox, Expl Flam, Tox Flam, Tox Flam, Tox Flam, Tox, Vol, React Tox, Care Flam, Tox, Care Flam, Tox, Care Tox, Vol Tox Tax, Scare Flam. Tox NA NA Flam, Tox Flam, Tox, Expl Flam, Tox, Expl Tox P a g e 1 3 of 15 Acute Exposure Symptoms' CNS Conv, Conf, Diz. Drew. Eye, Head, Naus, Resp, Skin, Trem. Unoon. Vom, Weak Eye, Resp, Skin Eye, Resp, Skin Eye, Resp, Skin Abd, CNS, Conv, Conf, Drow, Eye, Head, Naus, Skin, Trem, Unoon CNS, Conv, Conf, Diz, Diar, Drow, Eye, Head, Resp, Skin, Trem, Unoon, Vom CNS, Diz, Eye. Head, Naus, Skin, Trem, Unoon, Vom CNS, Diz, Eye, Head, Naus, Skin, Trem, Uncon, Vom CNS, Diz, Drow, Head, Naus, Vom Abd, CNS, Conf, Eye, Naus, Resp, SUn. Vom Resp, Skm Eye. Resp, Skin NA Skin CNS, Eyie, Resp, Skin Eye, Resp CNS, Coma, Eye, Resp. Skin Eye, Resp, Skin \WORIC\24231\02\HASPBA-1.TAB Table BAl. Hazardous Property Information Island Chemical Company^ Inc. Compound Water SolubUity* Specific Gravity Vapor Density Flash Point CF)'' Vapor Pressure" LEUUEL TLV- TWA** IDLH Level Hazard ProperUes' Acute Exposure Sjrmptoms' Vinyl chloride Vinyl acetate ;ip^Pni^ m Negligible Insoluble 0.00003% — 0.9100 0.9345 0.8642 7.14 2.24 3.0 3.7 N/A -108 30 63 N/A 2515.6 115 @ 25°C 7 N/A 3.696/33% 1 ppm 2.6%/l3.4% 10 ppm 1.196/7% 100 ppm •• N/E N/E Flam. Tox, React. Abd, CNS, Diz. Drow, Eye, Head, Naus, Care Resp. Skin, Weak N/E Tox Eye, Resp, Skin 1000 ppm Flam, Tox, Vol Abd, Diz, Drow, Eye, Naus, Resp, Skin N/E Tox Conv, Diz, Naus, Vom CJ O VO See last page for notes \WORK\24231\02\HASPBA-1.TAB Teble B A l . Hazardous Property Information Island Chemical Company, Inc. Compound Water SolubUity* Specific Gravity Vapor Density Flash Point (opjb Vapor Pressure" LEiyUEL TLV- TWA"" IDLH Level Hazard ProperUes' Acute Exposure Symptoms Notes: SSt^iiiil indicates substance identified onsite. < °F degrees Fahrenheit Mg'ni' g/ml grams per milliUter IDLH m^ cubic meters mgA N/A not applicable N/E ppb parts per biUion PP<n Less than micrograms per cubic meter immediate danger to life and health miUigrams per Uter none established parts per miUion > Mg/l lbs mg/m' NA' UEL greater than °C micrograms per Uter g pounds LEL nulUgrams per cubic meter mg/kg nonflammable NA upper explosive limit degrees Celsius gram lower explosive limit milligrams per kilogram no information is available Water solubility is expressed in different terms in different references. Many references use the term "insoluble" for materials that will not readUy mix with water (e.g., gasoline). However, most of these materials are water soluble at the ppm or ppb level. Gasoline, for example, is insoluble in the gross sense and found as a discreet layer on top of the groundwater. But certain gasoline constituents (e.g., benzene, toluene, and xylene) are found in soluUon in the groundwater at the ppm or ppb level. Water solubiUty expressed as 0.2 g means 0.2 grams per 100 grams water. Several chlorinated hydrocarbons exhibit no flash point in the conventional sense but will bum in the presence of a high-energy ignition source or wUl form explosive mixtures at temfieratures above 200°F. Expressed as milligrams of mercury (mm Hg) under standard conditions (20°F). Values for Threshold Limit Value - Time Weighted Average (TLV-TWA) are OocupaUonal Safely and Health Administration (OSHA) Permissible Exposure Limits (PELs) except where noted. Hazard properties: Care carcinogen Mut mutagenic Tox toxic Acute exposure symptoms Abd abdominal pain Diar diarrhea Naus nausea Trem tremora TLV-TWA adopted by the American Conference of Goverrunental Industrial Hygienists (ACGIH), which is lower than the OSHA PEL. Explosive concentrations of airborne dust can occur in oonfined areas. SolubiUty of metals depends on the compound in which the metals are present. TLV-TWA recommended by the National Institute for Occupational Safely and Health (NIOSH). A TLV or PEL has nol been adopted by ACGIH or OSHA. Cocarc Narc Vol CNS Diz Nerv Uncon comb combustUe volatUe corrosive cocarcinogen Cor radioactive narcotic Rad central nervous system depression dizziness Drow drowsiness nervousness Resp respiratory system unconsciousness Vom vomiting Expl React Coma Eye irritation Weak explosive reactive comatose eye irritation weakness Flam Scare Conf Fevr Skin flammable suspected careinogen confusion fever skin irritation Inf Tera Conv Head Sweat infectious teratogen convulsions headache sweating \WORK\24231\02\HASPBA-1.TAB OJ O M Ul O APPENDIX BB PERSONNEL ACKNOWLEDGEMENT RECORDS \WORK\24231\02\HASPj\PP March 17. 1994 HARDING LAWSON ASSOCIATES 301151 PROJECT PERSONNEL LIST AND SAFETY PLAN ACBCNOWLEDGEMENT RECORD HLA Employees Project staff must sign the master copy of this document, indicating they have read and understand it. The employee's signature indicates acceptance and compliance with the requirements of the HASP. Copies of this document must be made available for their review and readily available at the job site. LOG OF HLA PROJECT PERSONNEL Date Employee Name/Tob Title Distributed Signature \WORK\2423l\02\HASPAPP March 17,1994 [JU-1 HARDING LAWSON ASSOCIATES 301152 Contractors and Subcontractors Copies of this document will be provided to contractors and subcontractors who may be affected by activities addressed herein. Contractors and subcontractors must comply with this document (and/or their ovra HASP if it is equally or more stringent than the HLA HASP), applicable OSHA, USEPA, and local govemment rules and regulations. The contractors' and subcontractors' signatures acknowledge reading and understanding the HASP and agreeing to comply with the procedures presented therein. LOG OF CONTRACTOR AND SUBCONTRACTOR PROJECT PERSONNEL Date Contractor Name/Company Signature Distributed \WORK\24231\02\HASPJ\PP March 17, 1994 BB-2 HARDING LAWSON ASSOCIATES 301153 VISITORS: It is HLA's policy that visitors must furnish their own PPE. Visitors are required to sign the Visitor Log and comply with guidelines, rules, and procedures presented herein. If the visitor represents a regulatory agency concerned with site health and safety issues, the SHSO must immediately notify the DHSO. VISITOR LOG Name of Visitor Company Name Date of Visit Signature \WORK\24231\02\HASP.APP March 17, 1994 BB-3 HARDING LAWSON ASSOCIATES 301154 HEALTH AND SAFETY MEETINGS: Project personnel must receive initial health and safety orientation. Thereafter, a brief tailgate safety meeting is required as deemed necessary by the SHSO. Health and safety meetings will be held at least once every week or when risks and/or hazards change. HEALTH AND SAFETY MEETING LOG Date Topics Name of Attendee Company Name \WORK\24231\02\HASP-APP Mareh 17. 1994 BB-4 HARDING LAWSON ASSOCIATES 301155 HEALTH AND SAFETY MEETINGS: Project personnel must receive initial health and safety orientation. Thereafter, a brief tailgate safety meeting is required as deemed necessary by the SHSO. Health and safety meetings will be held at least once every week or when risks and/or hazards change. HEALTH AND SAFETY MEETING LOG Date Topics Name of Attendee Company Name \WORK\24231\02\HASPJ\PP March 17, 1994 BB-5 HARDING LAWSON ASSOCIATES 3 0 1 1 5 6 HEALTH AND SAFETY MEETINGS: Project personnel must receive initial health and safety orientation. Thereafter, a brief tailgate safety meeting is required as deemed necessary by the SHSO. Health and safety meetings will be held at least once every week or when risks and/or hazards change. HEALTH AND SAFETY MEETING LOG Date Topics Name of Attendee Company Name \WORK\24231\02\HASPJ\PP March 17, 1994 HH-6 HARDING LAWSON ASSOCIATES 301157 APPENDIX BC MATERIAL SAFETY DATA SHEETS \WORK\24231\02\HASP.APP March 17,1994 HARDING LAWSON ASSOCIATES 301158 T Flinn Scientific, Inc. MATERIAL SAFETY DATA SHEET CHEMICAL NAME & SYNONYMS ACETONE FORMUU\ CH COCH FORMUl^ WEIGHT (FW.) 58.08 FLINN CATALOG NUMBER A X 0 0 9 , A X O l O , A X 0 8 1 CAS NO. 67-64-1 PHYSICAL DATA (DENSITY. SOLUBIUTY. ETC.) Specific Gravity .785 Miscible with water and most organic solvents APPEARANCE AND ODOR Clear liquid, sweetish odor COMPATIBLE CHEMICAL FAMILY Organic #4 S t o r e i n a f l a m m a b l e s c a b i n e t See Flinn Chemical Catalog/Reference Manual DOTCU^SS Flammable Liquid REACTIVITY Stable CONDITIONS TO AVOID (IF ANY): Avoid any source of ignition. Avoid breathing vapor. HEALTH HAZARDS (IF ANY): Irritation to eyes, skin and mucous membranes, causes weakness, fatigue, nausea and headache. Vapor TOLERANCE LIMIT VALUE (TLV) (IF ESTABLISHED) 750 ppm FIRE HAZARDS (IF ANY): Use ABC fire extinguisher Serious fire hazard SPILLS AND LEAKS: Absorb liquid with vermiculite or other absorbent material and follow suggested disposal procedure at right. DISPOSAL NO. 18 See Flinn Chemical Catalog/ Reference Manual SPECIAL PRECAUTIONS (IF ANY): Safety glasses Gloves (rubber) FIRST AID (IF SUBSTANCE DANGEROUS): External: Wash affected parts with copious quantities of water. Internal: Wash mouth; see a physician. Respiratory: Transport to fresh air. Consult your copy of the Flinn Chemical Catalog/Reference Manual for even more information about laboratory chemicals. N/A - NOT APPLICABLE 301159 348 Flinn Scientific, Inc. MATERIAL SAFETY DATA SHEET CHEMICAL NAME & SYNONYMS HEXANES FLINN CATALOG NUMBER HX002 FORMULA ^tz^i A (^2 Hexane) 5 14 FORMULA WEIGHT (F.W.) 86.18 (as Hexane) CAS NO. As Hexane 110-54-3 z z 0) o rn z H P z o PHYSICAL DATA (DENSITY. SOLUBILITY, ETC.) S p . G r . 0 . 6 6 S o l u b l e i n a l c o h o l a n d a c e t o n e ; n o t w a t e r . APPEARANCE AND ODOR C o l o r l e s s l i q u i d - __ p o 00 z o w c > •V X o z rn "w I o> to o o COMPATIBLE CHEMICAL FAMILY O r g a n i c #3 See Flinn Chemical Catalog/Reference Manual DOT CLASS Flammable Liquid REACTIVITY Stable CONDITIONS TO AVOID (IF ANY): Heat, sparks and open flame. HEALTH HAZARDS (IF ANY): I r r i t a n t to body t i s s u e s . Vapor t o x i c . TOLERANCE LIMIT VW-UE (TLV) (IF ESTABLISHED) 180 mq/H 3 FIRE HAZARDS (IF ANY): Fire hazard; store in a dedicated flammables cabinet; use Triclass, dry chemical fire extinguisher. SPILLS ANO LEAKS: Absorb on sand or vermiculite. Place in a suitable container and use suggested disposal method at right. SPECIAL PRECAUTIONS (IF ANY): Chemical gloves and goggles. Fume hood. DISPOSAL NO 18 See Flinn CJ>«»»*cj« C«alog/ Reference U»r»jtt FIRST AID (IF SUBSTANCE DANGEROUS): External: Wash affected parts with copious quantities of water. Internal: Wash mouth; see a physician. Respiratory: Transport to fresh air. Consult your copy of the Flinn Chemical Catalog/Reference Manual _ ^ for even more information about laboratory chemicals. N/A - NOT APPLICABLE ' 301160 35^ Flinn Scientific, Inc. MATERIAL SAFETY DATA SHEET CHEMICAL NAME & SYNONYMS HYDROCHLORIC ACID (36.5-38.0%) FLINN CATALOG NUMBER * * * FORMULA H C l FORMULA WEIGHT (F.W.) 3 6 . 4 6 CAS NO. 7647-01-0 PHYSICAL DATA (DENSITY. SOLUBILITY, ETC.) Sp.Gr. 1.2 Soluble in water. APPEARANCE AND ODOR Clear l i q u i d ; pungent odor; constantly fuming. COMPATIBLE CHEMICAL FAMILY I n o r g a n i c #9 See Flinn Chemical Catalog/Reference Manual DOT CLASS Corrosive Liquid REACTIVITY Stable CONDITIONS TO AVOID (IF ANY): Strong oxidants. Avoid breathing vapor. Avoid body contact.' HEALTH HAZARDS (IF ANY): Irritant to body tissues; fumes harmful. TOLERANCE LIMIT VALUE fTLV) (IF ESTABLISHED) 5 ppm in a i r FIRE HAZARDS (IF ANY): Non flammable. SPILLS AND LEAKS: Absorb on seind or vermiculite. Place in a suitable container and use suggested disposal method at r i g h t . DISPOSAL NO. 24b See Flinn Chemical Cauiog/ Reference Manual SPECIAL PRECAUTIONS (IF ANY): Chemical gloves and goggles. Fume hood. FIRST AID (IF SUBSTANCE DANGEROUS): External: Wash affected parts with copious quantities of water. Internal: Wash mouth; see a physician. Respiratory: Transport to fresh air. Consult your copy of the Flinn Chemical Catalog/Reference Manual for even more information about laboratory chemicals - z. "5 0 1 1 fii N/A - NOT APPLICABLE J u x J. o J. * HX031, HX004, HX005, HX006, H0013, H0014, R-2820A, R-2820B, R-2820C, R-2820D, R2820E 456 Flinn Scientific, Inc. MATERIAL SAFETY DATA SHEET CHEMICAL NAME & SYNONYMS METHYL ALCOHOL (Methanol; Wood Alcohol) FLINN CATALOG NUMBER MX054, MX055, MXG56 FORMUU CH OH FORMUU WEIGHT (FW.) 3 2 . 0 4 CAS NO. 67-56-1 PHYSICAL DATA (DENSITY. SOLUBILITY. ETC.) Sp.Gr. 0.7924 Miscible with water, alcohol and ether, APPEARANCE AND ODOR Clear, c o l o r l e s s , mobile, highly polar l i q u i d . COMPATIBLE CHEMICAL FAMILY O r g a n i c #2 See Flinn Chemical Catalog/Reference Manual DOT CLASS Flammable Liquid REACTIVITY Stable CONDITIONS TO AVOID (IF ANY): Avoid any source of ignition. HEALTH HAZARDS (IF ANY): Toxic by ingestion (causes blindness). TOLERANCE LIMIT VALUE (TLV) (IF ESTABUSHED) 200 ppm in a i r FIRE HAZARDS (IF ANY): Flammable liquid; dangerous fire risk; flash point 54''F. dry chemical fire extinguisher. Use Triclass,. SPILLS AND LEAKS: Absorb spill using sand or chemical absorption pillows or pads. Avoid amy source of ignition. Follow suggested disposal procedure at right. v. DISPOSAL NO. 18 See Flinn Chemical Catalog/ Reference Manual SPECIAL PRECAUTIONS (IF ANY): Avoid large containers; dispense and use under a hood; store in an approved flammables caibinet. Chemical gloves and goggles. FIRST AID (IF SUBSTANCE DANGEROUS): External: Wash affected parts with copious quantities of water. Internal: Wash mouth; see a physician. I Consult your copy of the Flinn Chemical Catalog/Reference Manual for even more information about laboratory chemicals. N/A . NOT APPLICABLE 301162 494 Flinn Scientific, Inc. MATERIAL SAFETY DATA SHEET CHEMICAL NAME & SYNONYMS NITRIC ACID , 70.0% FLINN CATALOG NUMBER R3800A, R3800B,NXA17 NX043, NX016, NX017 FORMULA HNO, FORMULA WEIGHT (F.W.) 63.01 CAS NO. 7697-37-2 Ui O m z PHYSICAL DATA (DENSITY. SOLUBILITY, ETC.) Sp.Gr. 1.504 Miscible with water. p z o •Ji p OD o X CO I z g U) c > T3 I o z m • w .tL to 0» • Oi (O o o APPEARANCE AND ODOR Transparent, colorless or yellowish, fuming, suffocating liquid. Yellow color (if present) results from exposure to light and release of nitrogen dioxide. COMPATIBLE CHEMICAL FAMILY I n o r g a n i c #3 See Flinn Chemical Catalog/Reference Manual DOT CLASS Corrosive Oxidizer .REACTIVITY Stable CONDITIONS TO AVOID (IF ANY): Avoid body contact; avoid breathing fumes; avoid storing near oxidizcible materials. HEALTH HAZARDS (IF ANY): Eyes: severe damage; possibly blindness. Skin: causes severe and deep burns. Respiratory: can cause respiratory passage damage. Ingestion: severe tissue damage. TOLERANCE LIMIT VALUE (TLV) (IF ESTABLISHED) 2 ppm in air FIRE HAZARDS (IF ANY): Dangerous fire risk in contact with organic materials. Store in a dedicated acid cabinet away from all other chemicals. SPILLS AND LEAKS: Absorb on sand or vermiculite. Place in a suitable container and use suggested disposal method at right. DISPOSAL NO. 2 4 b See FHnn Chemical CataJog/ Reference Manual SPECIAL PRECAUTIONS (IF ANY): Chemical gloves and splash goggles, concern in handling and storing. This substance requires utmost FIRST AID (IF SUBSTANCE DANGEROUS): External: Wash affected parts with copious quantities of water. Internal: Wash mouth; see a physician. Respiratory: Transport to fresh air. Consult your copy of the Flinn Chemical Catalog/Reference Manual for even more information about laboratory chemicals. N;A ~ NOT APPLICABLE 301163 APPENDIX BD FIRST AID AND EMERGENCY CARE \WORK\24231\02\HASPJ^P March 17, 1994 HARDING LAWSON ASSOCIATES 301164 m APPENDIX BD FIRST AID AND EMERGENCY CARE Most accidents occuxring at job sites require minimal first aid available through use of the first aid kit(s) at the work site or in the support facility. For more serious medical emergencies that may or may not require professional medical attention, the American National Red Cross (1988) has developed first-aid procedures that can be followed until professional medical attention is obtained. The following sections present a summary of these procedures. When temperature exceed 70^, take frequent breaks in shaded area. If working in a heat stress environment, unzip or remove coveralls during breaks. Have cool water or electrolyte replenishment solution available. Drink small amounts frequently to avoid dehydration. Count the pvilse rate for 30 seconds as early as possible in the rest period. If the pulse rate exceeds 110 beats per minute at the beginning of the rest period, shorten the work cycle by one-third. HEAT EMERGENCIES There are three forms of heat emergencies: heat stroke, heat exhaustion, and heat cramps. Of these three, heat stroke is the most serious because it is life-threatening. Heat Stroke Symptoms Hot, red skin Very small pupils Very high body temperature Skin may feel dry First Aid Call for medical assistance. Move the victim to a cool (not cold) place immediately. Cool the victim quickly by immersing him/her in a cool (not cold) bath, wrapping wet sheets around the victim and fanning him/her, or spraying the victim with cool water. Monitor the victim for shock until medical assistance arrives. Heat Exhaustion Symptoms Ckjol, pale, and moist skin Heavy sweating Dilated pupils Headache Naxisea Dizziness Vomiting Normal body temperature \WORK\24231\02\HASPAPP March 17, 1994 BD-1 HARDING LAWSON ASSOCIATES 30116S First Aid Move the victim out of the heat. Have the victim lie down with feet elevated. Loosen or remove the victim's clothes. Cover the victim with wet towels or sheets or apply cold packs wrapped in cloth. Fan the victim. Have the victim drink one-half glass of water every 15 minutes if they are conscious and able to keep the fluid down. Heat Cramps Symptoms Muscular pains and spasms First Aid Move the victim out of the heat. Have the victim drink one-half glass of water every 15 minutes for one hour. COLD EMERGENCIES Cold emergencies are not anticipated during this project. Severe cold exposure can be an immediate danger to life and health. The two most serious forms of cold exposvire are hypothermia and frostbite. Hypothermia Symptoms Shivering Dizziness Numbness Confusion Weakness Impaired judgement Impaired vision Drowsiness Stages Shivering Apathy Loss of consciousness Decreasing pulse rate and breathing rate - Death First Aid Call for medical assistance. Move the victim to a warm place. Remove the victim's wet clothing, as .ipplicable. \WORK\24231\02\HASPjyp March 17,1994 HD-2 HARDING LAWSON ASSOCIATES 301166 Cover the victim with a dry blanket. Warm the victim slowly. Monitor the victim's breathing and heart rate. Give the victim warm broth or water - no alcohol or caffeine. Frostbite Symptoms Area is very cold to the touch and numb Slightly flushed skin Mild frostbite will appear on the edges of appendages as white or grayish-yellow with hardened skin Moderate frostbite vnll show a larger portion of the appendages as white or grayish-yellow and skin will have blistered Severe frostbite is grayish-blue and skin will be hard, cold, and nvunb. There is a danger of gangrene developing from severe frostbite First Aid Move the victim to a warm place. Place the frostbitten ares in warm (not hot) water. Handle the frostbitten areas gently. Do not rub, massage, or apply imnecessary pressure to the frostbitten area. Place dry gauze between frostbitten toes or fingers. Bandage frostbitten areas loosely. ANIMAL BITES Infection from an animal bite can develop quickly: first aid shovdd be administered immediately. First Aid Control the bleeding. Gently wash the wound unless bleeding heavily. Cover the bite with a bandage. Have the victim see a trained medical person. RABID ANIMAL BITES Rabies can be found in the saliva of animals. First Aid Observe the animal for unusual behavior. Get the victim to medical care. Give a description of the animal and where it was last seen to the police and/or anim-il control so they can capture the animal for determination of rabies infection. Do NOT attempt to capture or restrain the animal yourself. \WORK\24231\02\HASPJ\PP March 17,1994 BD-3 HARDING LAWSON ASSOCIATES 301167 INSECT BITES AND STINGS Insert bites and stings may be tolerated by some individuals more so than others. A past history of bite and sting tolerance is not indicative of continued tolerance. All bite and sting victims should be monitored for allergic reactions. The following is a summary of symptoms and first-aid response for an allergic reaction to a bite or sting. Symptoms Pain Swelling of the bite or sting area, which may be accompanied by swelling of the throat Redness or discoloration of the bite or sting area Itching Hives Decreased awareness Breathing noisy or difficult First Aid Remove the stinger with tweezers or scrape with a rigid item without squeezing it (which may release more venom). Wash the area of the bite or sting. Place a cold pack wrapped in cloth on the area. Keep the bite or sting below heart level. Get the victim to medical assistance if an allergic reaction is observed. Provide over the coimter anesthetic if allergic reaction occurs. SNAKE BITES Quick response to a snake bite is imperative. First Aid Call for medical assistance. Immobilize the bitten area. Keep the bitten area below the heart level. Keep the victim calm and still. Observe victim for symptoms of shock. Give a description of the snake to the medical responder. Do not cut above the bite and aspirate the poison. Do not use a tourniquet. SEVERE BLEEDING First Aid Stop external bleeding by: Applying direct pressure to the wound using a clean cloth. Apply cloths on top of the first one if bleeding persists; do not remove original cloth. If there is no fractvire, raise the wound above the level of the heart. \WORK\24231\02\HASP.APP March 17, 1994 BD-4 HARDING LAWSON ASSOCIATES 301168 - Apply pressure at the appropriate pressure point (squeezing the main artery against the bone in the forearm or against the pelvis in the groin) while continuing pressure on and elevation of the wound. - Wrap the wound using subtle pressure to tighten the wrap. Check for a pulse on the injured limb to determine that the wrap is not too tight. Call for medical assistance. INTERNAL BLEEDING Internal bleeding may be as innocuous as a bruise to a condition that threatens life and health. Symptoms Tender, bruised, swollen or rigid abdomen Vomiting small to large amounts of blood Injuries that have penetrated the body cavity Rectal or vaginal bleeding Difficvilty breathing Pulse rate is abnormal Cool, moist skin First Aid Treat small bruises by applying a cold pack to the injury. Obtain medical help immediately if more severe internal bleeding is suspected. Observe the victim's breathing and monitor his/her pulse. Keep the victim calm and still. Loosen the victim's clothing. Place the victim on his/her side if vomiting. Monitor the victim for symptoms of shock (below). SHOCK Shock can be caused by internal and external bleeding, insect bites or stings, snake bites, electrical shocks, severe injuries or burns, as well as other medical conditions. First aid and medical assistance is imperative for shock victims because shock is caused by a lack of sufficient blood supply to such vital organs as the heart, the lungs, and the brain. Symptoms Confused behavior Either very slow or very fast pulse rate Either fast, shallow breathing or very slow breathing Weak and trembling limbs Cool, moist skin Pallor or bluish skin Pupils are dilated First Aid Improve victims's circulation by laying them down with feet elevated if there are no leg fractures or suspected neck/head injuries. (Lay the victim flat if injuries are suspected.) \WORK\24231\02\HASP.APP March 17, 1994 BD-5 HARDING LAWSON ASSOCIATES 301169 If no injuries are suspected, a semi-reclining position may be used to alleviate breathing problems. If the victim is vomiting turn him/her onto their side. Cover the victim with a warm blanket. Call for medical assistance. Monitor the victim's heart rate and breathing. VICTIM NOT BREATHING AND HAS PULSE First Aid Victim unconscious, tap or gently shake the victim to see if there is a response. Ask, "Are you okay?" Roll the victim onto his/her back and toward you. Tilt the head back while lifting the chin. Check for breathing for 3 to 5 seconds. Pinch the nose shut, seal your mouth over the victim's mouth and give two 1- to 1-1/2-second breaths while keeping the head tilted back. Call or send someone for help. Check victim for a pulse approximately every minute. Perform 6 to 10 abdominal thnists. Do finger sweep. Repeat last three steps until the obstruction is cleared or help arrives. Continue rescue breathing, if necessary, by breathing into the victim's mouth for 1 to 1-1/2 seconds every 5 seconds. VICTIM NOT BREATHING AND HAS NO PULSE First Aid Roll the victim onto his/her back and toward you. Tilt the head back while lifting the chin. Check for breathing for 3 to 5 seconds. Pinch the nose shut, seal your mouth over the victim's mouth and give two 1- to 1-1/2-second breaths while keeping the head tilted back. Check for a pulse. Call or send someone for help. Locate the notch at the lower end of the breastbone. Place the heel of your hand two fingers-wddth up from the end of the notch. Place your other hand on top keeping the fingers of your hands off the chest. Position your shoulders directly over your hands. Using a steady,, firm force, bending at the waist, compress the breastbone 1-1/2 to 2 inches for 15 counts in 10 seconds. Perform rescue breathing (2 quick breaths as above). Repeat this for a total of 4 cycles. Recheck pulse. Continue cardiopulmonary resuscitation (CPR) procedures as described above until medical assistance arrives. BURNS There are four t3T)es of burns: heat burns, chemical burns, electrical burns, and radiation burns. Each type has three degrees of bums: first degree, second degree, and third degree. \WORK\24231\02\HASP.APP March 17, 1994 BD-6 HARDING LAWSON ASSOCIATES 301170 First Degree Bum Symptoms Least severe Skin vnll be red or discolored Mild swelling Pain Second Degree Burn Symptoms Bum extends deeper into the skin Skin is red or mottled Blistering May appear wet from skin fluid loss Painful Third Degree Burn Symptoms Deepest bum; extends through all skin layers Skin appears white or charred Can look like second-degree bums Pain may be severe or, if nerve endings are destroyed, may not occur at all Can occur in patches vdth less severe bums First Aid for Heat Bums For first-degree bums and second-degree bums with no open blister, flush with lots of cool running water. Apply moist dressings, and bandage loosely. For second-degree bums with open blisters and third-degree bums, apply dry dressings and bandage loosely. Do not use water, as it increases the risk of shock. Have the victim lie down. Elevate the burned area if doing so does not cause further drain. Maintain normal body temperature. First Aid for Chemical Bums Flush the chemicals from the skin with lots of water. Continue flushing for 15 to 30 minutes. Remove any contaminated clothing or jewelry. Cover bums loosely with a dry bandage or dressing. Call for medical assistance. First Aid for Electrical Bums Avoid contact with electrical source. Shut down the electrical source. Cover all bums with a loose dry dressing and bandage. Provide care for shock as needed. Call for medical assistance. \WORK^4231\02\HASP.APP March 17, 1994 HD-7 HARDING LAWSON ASSOCIATES 301171 First Aid for Radiation Bums Decontaminate the victim. Obtain medical assistance immediately. EYE INJURIES Eye injuries should always be treated as a serious injury. Symptoms Visible foreign object Redness Burning - Pain Headache Tearing First Aid Use care and be gentle when touching the eyes. Wash hands before caring for an eye injury, if possible. If an object is in the eye, lift the upper eyelid, have the victim look down and flush the eye with clean water or eye wash solution. If there are chemicals in the eye, flush the eye wath clean water or eye wash solution from the nose outward for 15 to 30 minutes. For objects in the eye (whether removed through flushing or not) and for chemicals in the eye, wrap a bandage loosely around both eyes. If the eye is cut or there is a penetrating object in the eye, place a cup over the injured eye and wrap both eyes loosely with a bandage. Do not attempt to remove the penetrating object. Obtain medical assistance for all (even minor) eye injuries. NOSE INJURIES Nose injuries can be indicative of more serious injuries to the head, back, or neck. Caution should be used to assess this type of injury. Nosebleeds are typically a less serious injury but can be severe enough to cause shock from loss of blood. Be sure to ask the victim how the nosebleed began. First Aid Have the victim sit dov^m. Have him/her lean forward with the chin resting on the chest. Piiieh the nose. Keep the victim calm and quiet until the bleeding has stopped. Symptoms of a More Serious Nose Injury Swelling and pain Pupils dilated unevenly Bloody or clear fluid draining from either the ears or the nose Loss of feeling and movement in appendages \WORK\24231\02\HASPJ\PP March 17. 1994 BD-8 HARDING LAWSON ASSOCIATES 301172 First Aid for a More Serious Nose Iniurv Do not attempt to stop the flow of fluid from the nose. Keep the victim's head and neck stable. Keep the victim calm and quiet. Call for medical assistance. FRACTURES There are two tj^es of fractures: simple (one internal fracture) and compoimd (two or more fractures often breaking the skin). The compound fracture is more serious because of the accompanying open wound. Fractures occurring in the body may be indicative of internal injuries. Symptoms A grating sensation and/or a snapping sound when the appendage is moved Deformities Pain and tenderness Bruising and swelling Immobihty of the injured part Note: First aid for fractures, dislocation, sprains, and strains are similar for these injuries. The first aid for these injuries will be discussed after the symptoms. DISLOCATIONS Symptoms Deformity Swelling and tenderness Pain in the joint Loss of or limited movement SPRAINS OR STRAINS Sprains are the result of stretched or torn tendons or ligaments around the joints. Tom muscles are indicative of strains. Symptoms Pain in the joint Sharp pain Tender to the touch Bruising and swelling Stiffness First Aid for Fractures. Dislocations. Sprains, or Strains If the injury is to the head, neck, or back, stabilize the head and neck. Do not attempt to move the victim unless absolutely necessary. Obtain medical assistance immediately. Keep the victim calm and quiet. \WORK\24231\02\HASP.APP March 17,1994 BD-9 HARDING LAWSON ASSOCIATES 301173 Determination of the precise injury is often difficult, so remember this rule of thumb: "When in doubt, splint." Splint only if it can be done without causing more pain and discomfort to the victim. The injury must be splinted in the position in which it is foimd. Do not attempt to straighten the injured part. Splint the injured area as well as the surrounding joints so that the entire limb is immobilized. Check for a pulse before and after splinting. Call for medical assistance. First Aid for Head. Neck, and Back Injuries If the victim has obvious head injury, suspect the possibility of spinal cord injury also. If the victim is unconscious and your survey of the scene suggests traumatic injury to the head, care for him or her as if there is a spinal injury. If you suspect the victim has a head or neck injury, keep him or her lying flat and wait for EMS. Do not move the victim unless there is immediate danger from extreme hazards such as fire, toxic fumes, heavy traffic, electrical wires, or deep or swiftly moving water. If you must move him or her, try not to bend or twist the body. If you have any doubts about the victim's injuries, keep him or her lying flat. If you suspect a spinal injury, stabilize the victim's head and neck as you found them by placing your hands along both sides of the head. This keeps the head in line with the spine and prevents movement. i If you must move the victim, do it carefuUy, using the clothes drag rescue method. Stay with the victim and continue to stabilize the head and neck until EMS arrives. Monitor ABCs. \WORK\24231\02\HASPJ\PP March 17. 1994 BD-10 HARDING LAWSON ASSOCIATES 301174 APPENDIX BE EQUIPMENT CALIBRATION AND MAINTENANCE \WORK\24231\02\HASP.APP March 17. 1994 HARDING LAWSON ASSOCIATES 301175 This page was intentionally left blank for pagination purposes. 301176 APPENDIX BE EQUIPMENT CALIBRATION AND MAINTENANCE This appendix presents Harding Lawson Associates' (HLA's) standard operating procedures for field calibration and maintenance of direct reading instruments, personal sampling pumps, and detector tubes that may be used during field activities. Each equipment item is described and the calibration, operation, and maintenance procedures are detailed to the extent necessary to ensure proper care and use. Detailed procedures are provided in instrument-specific manuals from each manufacturer. These standard operating procedures are intended to ensure that equipment is properly maintained and operated. These procedures were developed on the basis of the following assumptions: Procedures are consistent with the manufacturer's calibration, operation, and maintenance guidelines. Equipment calibration, operation, and maintenance procedures wdll be performed by properly trained HLA personnel. Only designated persormel will calibrate, operate, and maintain certain instruments. Records will be maintained to allow tracking of the calibration, operation, and mainte- nance of a given instrument. PHOTOIONIZATION DETECTOR fHNU PI 101/HNU DLIOI/PHOTOVAC MICROTIP) Theory of Operation The portable photoionization detector (PID) detects the concentration of organic gases as well as a few inorganic gases. The basis for detection is the ionization of gaseous species. Every molecule has a characteristic ionization potential (IP) that is the energy required to remove an electron from the molecule, yielding a positively charged ion and the free electron. The incoming gas molecules are subjected to ultraviolet (UV) radiation, which is energetic enough to ionize many gaseous compounds. Each molecule is transformed into charged ion pairs, creating a current between two electrodes. Three lamps, each containing a different UV Ught source, are available for use with most PIDs. Ionizing energies of the lamp are 9.5, 10.2, and 117 'Mectron volts (eV). All three detect many aromatic and large molecule hydrocarbons. The 10 2 eV and 11.7 eV probes, in addition, detect some smaller organic molecules and some halogenated hyd.'ocarbons. The 10.2 eV lamp is the most useful for environmental response work because it is mo:". <iurable than the 11.7 eV lamp and detects more \W0RK\24231\02\RASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES BE-1 301177 compounds than the 9.5 eV lamp. The following sections detail the proper calibration and field maintenance methods to be used with these PIDs. HNU PI 101 The HNU PI 101 PID is designed for trace gas analysis in ambient air. The HNU PI 101 is factory-calibrated with certified standards of benzene, vinyl chloride, and isobutylene, with the reference standard being benzene. Because of the inherent toxicological risks associated with benzene and vinyl chloride, the primary calibration standard to be used should be isobutylene. When calibrating the unit vdth 100 parts per million (ppm) isobutylene, the SPAN control should be set at 9.8 and the unit should read approximately 70 ppm. This method of calibration converts the response of the unit to isobutylene to yield a direct reading of benzene that is based on the response factor of the unit using a 10.2 eV probe at a span setting of approximately 9.8. More simply stated, the required reading for calibration will be as follows: , , ^ 1 photoionization sensitivity (isobutylene) = 100 x T l l o ^ ^ "" phutuiunlzaliuu bbusiUvily (buiizeue) = 70 ppm When using probes vdth 9.5 eV or 11.7 eV lamps, consult the user's manual for photoionization sensitivities and required SPAN control settings because these units may change for each individu.il lamp. In cases where hazardous chemicals have been identified, the HNU PI 101 can also be r..il!!;:.r.-.; to provide direct reading results of these chemicals. Please consult the user's manual and the Designated Health and Safety Officer (DHSO) to select chemicals for concern of appropriate calibration. The steps calibration method for the HNU PI 101 with a 10.2 eV lamp follows: 1. Identify the probe by the lamp label. If a question exists, disassemble the probe and :^•.^; •• ' the lamp. The energy of the lamp should be etched into the glass envelope. 2. Connect the probe to the readout assembly, making sure the red interlock switch is depressed by the ring on the connector \WORK\24231\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES 8C-2 301178 • 3. Set the SPAN control potential to 9.8. 4. Battery check - turn the function svidtch to BATT. The needle should be in the green region. If it is not, recharge the battery. 5. Zero set - turn the function switch to STANDBY. In this position, the lamp is off and no signal is being generated. Allow the unit to sit for a minute to warm the parts. Set the ZERO point with the ZERO set control. 6. Fill a dedicated tedlar bag with the 100 ppm isobutylene in air SPAN gas. 7. Turn the function svdtch to the 0 to 200 range position. Attach the sampling bag to the probe inlet. Adjust the SPAN control setting to read approximately 70 ppm at a span setting of 9.8. 8. Record the units achieved at the set SPAN control and the calibration phase used. 9. Lamp cleaning - if calibration cannot be achieved at the desired span potential, the lamp must be cleaned. (See specific instrument manual for instructions) HNU DL-101-2 The HNU DL-101-2 applies microprocessor capabilities to the basic photoionization detection principles exhibited by the HNU PI 101. The microprocessor provides electronic zeroing, site and time data logging, and the ability to store up to 12 calibrations. The unit provides two basic modes of operation, the first being the survey mode and the second being the hazardous waste mode. Like the PI 101, the DL-101-2 is also factory-calibrated using benzene as the reference standard. The primary method of calibration will also use 100 ppm isobutylene in air (the calibration gas standard) with the unit in the survey mode. If several compounds are suspected, the hazardous waste mode may be utilized to store the needed amount of calibration curves. In either case, it is essential to identify the lamp voltage being used and the photoionization sensitivities of the chemical species of interest. To calibrate in the survey mode, follow these instructions: 1. Identify the lamp energy. If this information is not available on the outside of the probe, disassemble the probe and inspect the lamp. The energy of the lamp should be etched into the glass envelope. 2. Press the power button to start the unit. Wait one minute to allow the unit to warm up. 3. Fill a dedicated tedlar bag completely with isobutylene calibration standard. 4. Press the CALIBRATE key on the front panel. "Calibrate" should appear on the liquid \WORK\24231\02\HASPBD.APP March 17. 1994 HARDING LAWSON ASSOCIATES BE-3 301179 crystal display (LCD). 5. Press ENTER. "Zeroing Unit" will appear on the LCD. The unit will display the unit concentration before the electronic zero. The display will then prompt: CE/ENT/EXIT Cone = ppm. Enter the concentration of the calibration gas and press enter. "Attach gas to probe and /ENTER/" should appear on the LCD. 6. Attach the tedlar bag to the probe and press ENTER. Allow the sample to be naturally drawn into the unit. Press ENTER when ready, "xxxx ppm" should appear on the LCD. When the readings reach 100 ppm [+10 percent), press ENTER. The LCD should then display "Calibrating...please wait." In the survey mode, the unit wiU save the calibration and then the LCD reverts to the operation screen. When additional calibrations are called for, utilize the hazardous waste mode and cross reference calibration responses with the DL-101-2 user's manual. Photovac MicroTIP The MicroTIP must be calibrated to display concentrations in units equivalent to ppm. First, a supply of zero gas (total hydrocarbon concentration < 1 ppm) is used to set the zero point. Then Span Gas (100 ppm isobutylene in air) is used to set the sensitivity. Following these steps for MicroTIP calibratioii: 1. Turn the MicroTIP on and allow five minutes for warm up. 2. Fill the dedicated zero gas tedlar bag with zero gas calibration standard. 3. Fill the dedicated span gas tedlar bag with 100 ppm isobutylene in air calibration standard. 4. Press SETUP and select the desired Cal Memory (i.e., 100 ppm) with the arrow keys and press ENTER. Press EXIT to leave setup. 5. Press CAL and attach the filled zero gas bag to the MicroTIP probe. Press ENTER and the MicroTIP sets its zero point. 6. MicroTIP then asks for the span gas concentration. Enter 100.0 and then cormect the span gas bag to the MicroTIP probe. 7. Press ENTER and MicroTIP sets its sensitivity. \WORK\24231\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES BE-4 301180 8. When the display reverts to normal, the unit is calibrated and ready for use. Remove the span gas bag from the inlet. 9. Record applicable calibration information. Organic Vapor Analyzer Foxboro Model 128 Theory of Operation The Foxboro Model 128 organic vapor analyzer (OVA) is designed to detect and measure hazardous vapors and gases. The instrument utilizes the principle of hydrogen flame ionization for detection and measurement of organic vapors. The instrument measures organic vapor concentration by producing a response to an unknowm sample, which can be related to a gas of known composition to which the instrument has been previously calibrated. During normal survey mode operation, a continuous sainple is drawn into the probe and transported to the detector chamber by an internal pumping system. The sample stream is metered and passed through particulate filters before reaching the detector chamber. Inside the detector chamber, the sample is exposed to a hydrogen flame that ionizes the organic vapors. When most organic vapors burn, they leave positively charged carbon-containing ions. An electric field drives the ions to a collecting electrode. As the positive ions are collected, a current corresponding to the collection rate is generated. This current is measured with a linear electrometer preamplifier that has an output signal proportional to the ionization current. A signal conditioning amplifier is used to amplify the signal from the preamp and to condition for display on the probe/readout assembly. The OVA will primarily be used in the survey mode. In the survey mode, the OVA is internally calibrated to methane by the manufacturer. When the instrument is adjusted to manufacturer's instructions, it indicates the true concentration of methane in air. In response to all other detectable compounds, however, the instrument reading may be higher or lower than the true concentration. The following procedures detail the operation, calibration, hydrogen refilling, and recharging methods to be used vdth the OVA: \WORK\24231\02\HASPBD.APP March 17,1994 HARDING LAWSON ASSOCIATES BE-5 301181 1. Startup Procedures a. Connect the probe/readout assembly to the sidepack assembly by attaching the sample line and electronic jack to the sidepack. b. Select the desired sample probe (close area sample or telescoping probe) and connect the probe handle. Before tightermig the knurled nut, check that the probe accessory is firmly seated against the flat seals in the probe handle and in the tip of the telescoping probe. c. Move the INST/BATT svdtch to the test position. The meter needle should move to a point beyond the white line, indicating that the integral battery has more than four hours of operating life before recharging is necessary. d. Move the INST/BATT svdtch to the "ON" position and allow a five-minute warm up. e. Turn the PUMP switch on. f. Use the Calibrate Adjust knob to set the meter needle to the level desired for activating the audible alarm. If this alarm level is other than zero, the CALIBRATE svdtch must be set to a appropriate range. g. Turn the Volume knob fully clockwise (optional). h. Using the Alarm Level Adjust knob, turn the knob until the audible alarm is activated (optional). i. Move the Calibrate Svdtch to xl and adjust the meter reading to zero using the Calibrate Adjust (zero knob). j. Open the hydrogen Tank Valve one or two turns and observe the reading on the Hydrogen Tank Pressure Indicator. (Approximately 150 pounds per square inch [psi] of pressure is required for each hour of operation.) k. Open the Hydrogen Supply Valve one or two turns and observe the reading on the Hydrogen Supply Pressure Indicator. The reading should be between 8 and 12 psi. ' 1. After approximately one minute, depress the IGNITER BUTTON until the hydrogen flame lights. The meter needle will travel upscale and begin to read "Total Organic Vapors." Caution: Do not depress igniter for more than six seconds. If flame does not ignite, wait one minute and try again. m. The instrument is ready for use. NtVFK: If the ambient background organic vapors are "zeroed out" using the Calibrate Aciiust knob, the meter needle may move off-scale in the negative direction when the HVA i.s moved tn a location vdth lower background. If the OVA is to be used in the 0 to 10 ppm range, it should "zeroed" in an area with very low background. A charcoal filter (I'art No. 510095-1) can be used to generate the clean background sample. 2. Calibration Using Known Samples for F..it;h Range The accuracy is obtained when the instrumtml is calibrated vdth known concentrations for \WORK\24231\02\HASPBD.APP March 17. 1994 . HARDING LAWSON ASSOCIATES BE-G 301182 each range. Prepare separate samples of methane-in-air in these concentration ranges: 7 to 10 ppm, 90 to 100 ppm, and 900 to 1000 ppm. Calibrate the instrument as follows: a. Place the instrument in normal operation and allow a minimum of 15 minutes for warm-up and stabilization. b. Set the Gas Select control to 300. c. Set the Calibrate svdtch to xl. d. Set the Calibrate Adjust (Zero) knob so that the meter reads zero. e. Check that the meter reads zero on the xlO and xlOO ranges. f. Set the Calibrate svdtch to xl and introduce the sample with known concentration in the 7 to 10 ppm range. g. Adjust R31 so the meter reading corresponds to the sample concentration. h. Set the Calibrate switch to xlO and introduce the sample vdth known concentration Ln the 90 to 100 ppm range. i. Adjust R32 so that the meter reading corresponds to the sample concentration. j . Set the Calibrate svdtch to xlOO and introduce the sample with known concentration in the 900 to 1000 ppm range. k. Adjust R33 so that the meter reading corresponds to the sample concentration. 1. The instrimaent is now calibrated for methane and ready for service. If the flame-out alarm is actuated, check that the pump is running, then press the IC.MTKK button. Under normal conditions, flame-out results from sampling a gas mixture thai is above the lower explosive level, which causes the hydrogen flame to extinguish. If ihi.s is the case, reignition is all that is required to resume monitoring. Another possible cause f-r flame-out is restriction of the sample flow line, which would not allow sufficient air ir.M the chamber to support combustion. The normal cause for such restriction is a clog^>-ii particle filter. It should be noted that the chamber exhaust port is on the bottom of the case and hlc %.::-i this port with the hand will cause fluctuations and/or flame-out. 3. Shut Down Procedure a. Close HYDROGEN TANK valve b. Close HYDROGEN SUPPLY valve c. Move INSTRUMENT switch to OFF d. Wait five seconds and move PUMP svdtch to OFF. The instrument is now in a v: .• dovkm configuration. \WORK\24231\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES Bt-T 301183 \WORK\24231\02\HASPBD.APP March 17. 1994 HARDING LAWSON ASSOCIATES BE-8 301184 4. Fuel Refilling Note: Use Prepurified or Zero grade hydrogen (certified total hydrocarbons as methane <0.5 ppm is recommended). a. The instrument and the charger should be completely shut dov\m during hydrogen tank refilling operations. Refilling should be performed in a ventilated area. There should be no potential igniters or flame in the area. b. If you are making the first filling on the instrument or if the filling hose has been allowed to fill vdth air, the filling hose should be purged vdth hydrogen before filling the instrument tank. This purging is not required for subsequent fillings. c. The filling hose assembly should be left attached to the hydrogen supply tank when possible. Ensure that the FIT .1/BLEED valve on the instnmient end of the hose is in the OFF position. Connect the hose to the refill connection on the Side Pack Assembly. d. Open the hydrogen supply bottle valve on the instrument panel and place the FILL/BLEED valve on the filling hose assembly in the FILL position. The pressure in the instrument tank vdll be indicated on the Hydrogen Tank Pressure indicator. e. After the instrument fuel tank is filled, close the REFILL valve on the panel, the FILL/BLEED valve on the filling hose assembly and the hydrogen supply bottle valve. f. The hydrogen trapped in the hose should not be bled off to atmospheric pressure. Caution should be used in this operation as described in Step (g) below because the hose will contain a significant amount of hydrogen at high pressure. g. The hose is bled by turning the FIUVBLEED valve on the filling hose assembly to the Bleed position. After the hose is bled dov^m to atmospheric pressure, the FILL/BLEED valve should be turned to the FILL position to allow the hydrogen trapped in the connection fittings to go into the hose assembly. Then, again, turn the FILL/BLEED valve to the Bleed position and exhaust the trapped hydrogen. Then turn the FILL/BLEED valve to OFF to keep the hydrogen at one atmosphere in the hose so that at the time of the next filling there vdll be no air trapped in the filling line. h. Close the HYDROGEN TANK valve. i. With the HYDROGEN TANK valve and the HYDROGEN SUPPLY valve closed, a small amount of Hydrogen at high pressure will be present in the regulators and plumbing. As a leak check, observe the Hydrogen Tank Pressure indicator while the remainder of the system is shut down and ensure that the pressure reading does not decrease rapidly (more than 350 psi/hour), which would indicate a significant leak in the supply system. 5. Battery Charging Warning: Never charge in a hazardous environmeni. a. Plug charger cormector into mating connector on battery cover and insert alternating current (AC) plug into 115V AC wall outlet. b. Move the battery charger switch to the ON position. The lamp above the svdtch button \WORK\2423i\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES BE-9 301185 should illuminate. c. Battery charge condition is indicated by the meter on the front panel of the charger; . meter will deflect to the left when charging. When fully charged, the pointer will be in line with the "charged" marker above the scale. d. Approximately one hour of charging time is required for each hour of operation. However, an overnight charge is recommended. The charger can be left on indefinitely without damaging the batteries. When finished, move the battery charger svdtch to OFF and disconnect from the Side Pack Assembly. It has been established that these battery charging procedures may not be effective when the battery has completely discharged. When this happens and the above procedures fail to charge the battery, perform the following additional steps: e. Remove the battery from the instrument case. f. Connect to any variable direct current (DC) power supply. g. Apply 40 volts at 1/2 ampere (A) maximum. h. Observe the power supply meter. As soon as the battery begins to draw current, gradually reduce the power maintaining 1/2 A maximum until the meter reads approximately 15 volts. Note: The time required to reach the 15-volt reading vdll depend on degree of discharge. i. Repeat steps (a), (b), (c), and (d) above to complete the charging cycle. SAMPLING PUMPS fSKC. MSA, or Gillian) Sampling pumps utilized to collect personal and area samples will be calibrated before and after sampling. In each case, the sampling pumps vdll be calibrated in accordance vdth parameters established in National Institute of Occupational Safety and Health (NIOSH) Manual of Analytical Methods (1984). Calibration will be performed onsite using a primary standard (i.e., electronic bubble meter or 1-liter glass buret). Calibrations of sampling trains vdll be conducted vdth the collection media (i.e., charcoal tubes, XAD-2 tubes, tenax, cyclone separators, impingers, etc.) in line with the primary standard to ensure quality data. The following calibration procedures should be followed when calibrating sampling trains: 1. Electronic Bubble Meter Method \WORK\24231\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES BE-10 301186 a. Allow the pump to run five minutes before voltage check and calibration. b. Connect the collection media to the bottom of the calibration meter by Tygon tubing. Then connect the pump and the tubing to be used to the top of the meter. This \dll allow the sampling train to be calibrated as it is to be used. c. Visually inspect all Tygon tubing connections. d. Wet the inside of the electronic flow cell with the supplied soap solution by pushing on the button several times. e. Turn on the piimp and adjust the pump rotameter, if available, to the appropriate flow rate setting. f. Press the button on the electronic bubble meter. Visually capture a single bubble and electronically time the bubble. The accompanying printer vdll automatically record the calibration reading in liters per minute. g. Repeat step f until two readings are vdthin 5 percent. h. While the pump is stiU running, adjust the pump, if necessary. i. Repeat the procedure for all pumps to be used for sampling. The same cassette and filter may be used for all calibrations involving the same sampling method. Bubble-meter Method Perform calibration using the bubble-meter method as follows: 1. Allow sampling pumps to run for five minutes before calibration. Check voltage after five minutes. If the voltage is below the level specified by the manufacturer, the pump needs to be recharged. Check the manufacturer's instructions for proper charging procedures. 2. Wet the inside of the burette vdth the soap solution before setup. 3. Assemble the bubble meter and connect the sampling pump and the type of collection device intended for the field sampling. 4. Momentarily submerge the opening of the burette to capture a film of soap. 5. Draw two or three bubbles up the burettt; to ensure that they vdll reach the top. 6. Visually capture a single bubble and lime (with a stopwatch) the bubble from 0 to 1000 milliliter (ml) or 0 to 100 ml, d(;p<!n(ling on the pump being calibrated. 7. Adjust the pump flow rate until the desired How rate is achieved. For example, for a How rate of 2 liters per minute, the bubble must travel from 0 to 1000 ml in 30 seconds. Verify the flow rate at least tvdce. 8. For pumps with rotameters, mark or ro Dfd the position of the float (ball) when the pump is running at the desired flow rate. Thi.s will allow the industrial hygienists to adjust the \WORK\2423l\02\HASPBD.APP March 17. 1994 HARDING LAWSON ASSOCIATES BE-11 301187 pump flow rate back to the correct rotameter position if the float moves off the marked setting during sampling. DETECTOR TUBES/PUMPS fSensidyne/Gastech. Drager, MSAl Principle/Description 1. Detector tubes/pumps, when used vdth a variety of commercially available detector tubes, are capable of measuring the concentrations of a wide variety of compounds in industrial atmospheres. 2. Operation consists of using the pump to draw a known volume of air through a detector tube designed to measure the concentration of the substance of interest. The concentration is determined by a colorimetiic change of an indicator that is present in the tube contents. Applications/Limitations 1. Detector tubes/pumps can measure more than 200 organic and inorganic gases and vapors or for leak detection. Some aerosols can also be measured. 2. Detector tubes of a given brand are to be used only vdth a pump of the same brand. The tubes are calibrated specifically for the same brand of pump and may give erroneous results if used vdth a pump of another brand. 3. A limitation of many detector tubes is the lack of specificity. Many indicators are not highly selective and can cross-react vdth other compounds. Manufacturer's manuals describe the effects of interfering contaminants. 4. Another important consideration is sampling time. Detector tubes give only an instan- taneous interpretation of environmental hazards. This may be beneficial in potentially dangerous situations or when ceiling exposure determinations are sufficient. When long- term assessment of occupational environments is necessary, short-term detector tube measurements may not reflect time-weighted average levels of the hazardous substanrt-s present. 5. Detector tubes normally have a shelf-life at 25 degrees Celsius (°C) of one to two years Refrigeration during storage lengthens the shelf-life. Outdated detector tubes (i.e., bevT.-i the printed expiration date) should never be used. Performance Data 1. The specific tubes are designed to cover a concentration range that is near the Perm:s>.; •• Exposure Limit (PEL). Concentration ranges are tube-dependent and can be anywhi-r-- :• • one one-hundredth to several thousand ppm. The limits of detection depend on the particular detector tube. 2. Accuracy ranges vary with each detector tube [+_ 25 percent). 3. The pump may be handled during operation (weighing from 8 to 11 ounces) or it m.iv tx- -i \WORK\24231\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES Bt-12 .in 301188 automatic type (weighing about 4 pounds) that collects a sample using a preset number of pump strokes. A full pump stroke of either type of short-term pump has a volume of about 100 cubic centimeters (cm^). 4. In most cases where only one pump stroke is required, sampling time is about on minute. Determinations for which more pump strokes are required take proportionately longer. Leakage Test 1. Each day before use, perform a pump leakage test by inserting an unopened detector tube into the pump and attempt to draw in 100 ml of air. After a few minutes, check for pump leakage by examining pump compression for bellows-type pumps or return to resting position for piston-type pumps. Automatic pumps should be tested according to the manufacturer's instructions. 2. In the event of leakage that cannot be repaired in the field, notify the DHSO to expedite repairs. 3. Record leakage test on the HLA Air Monitoring Calibration Form. Calibration Test 1. Calibrate the detector tube for proper volume measurement at least quarterly. 2. Simply connect the pump directiy to the bubble meter vdth a detector tube in-line. Use a detector tube and pump from the same manufacturer. 3. Wet the inside of the 100 cm^ bubble meter vdth soap solution. 4. For volume calibration, experiment to get the soap bubble even vdth the zero mark of the buret. a. For piston-type pumps, puU the pump handle all the way out (full pump stroke) and note where the soap bubble stops; for bellows-type pumps, compress the bellows fully; for automatic pumps, program the pump to take a full pump stroke. For either type pump, the bubble should stop between the 95 cm^ and 105 cm^ marks. Allow four minutes for the pump to draw the full amount of air (This time interval varies vdth the type of detector tube being used in-line with the calibration setup). b. Also check the volume of 50 cm^ (1/2 pump stroke) and 25 cm^ (1/4 pump stroke) if pertinent. As in Section 1 above, a ±5 percent error is permissible. If error is greater that ±5 percent, send the pump for repair and recalibration. 5. Record the calibration information required on the Calibration Log. 6. It may be necessary to clean or replace the rubber bung or tube holder if a large number of tubes have been taken vdth the pump. Additional Information \WORK\24231\02\HASPBD.APP March 17,1994 HARDING LAWSON ASSOCIATES BE-IS 301189 1. Draeger, Model 31 (bellows) When checking the pump for leaks with an unopened tube, the bellows should not be completely expanded after 10 minutes. 2. Draeger, Quantimeter 1000, Model 1 (automatic) A battery pack is an integral part of this pump. The pack must be charged before initial use. One charge is good for 1000 pump strokes. During heavy use, it should be recharged daily. If a "U" (undervoltage) message is continuously displayed in the readout vdndow of this pump, the battery pack should be immediately recharged. 3. Mine Safety Apphances, Samplair Pump, Model A, Part No. 463998 (piston) The pump contains a flow rate control orifice protected by a plastic filter that periodically needs to be cleaned or replaced. To check the flow rate, the pump is cormected to a buret and the piston is vdthdrawn to the 100-ml position with no tube in the tube holder. After 24 to 26 seconds, 80 ml of air should be admitted to the pump. Every six months, the piston should be relubricated with the oil provided. 4. Sensidyne-Gastec, Model 800, Part No. 7010657-1 (piston) This pump can be checked for leaks as mentioned for the Kitagawa pump; however, the handle should be released after one minute. Periodic relubrication of the pump head, the piston gasket, and the piston check valve is needed and is use-dependent. Special Considerations 1. Detector tubes should be refrigerated when not in use to prolong shelf life. 2. Detector tubes should not be used when cold. They should be kept at room temperature or in a shirt pocket for one hour before use. 3. Lubrication of the piston pump may be required if volume error is greater than 5 percent. COMBUSTIBLE GAS INDICATOR (Model 361 or equivalent) Theory of Operation The Model 361 Hydrogen Sulfide combustible gas and oxygen sensors operate simultaneously. Each sensing circuit is equipped vdth an individual, visual alarm descriptor. There is a common, pulsating audible alarm. One position of the FUNCTION svdtch enables the audible alarm to be turned off, if so desired. The alarm descriptors will remain on until the concentration returns to vdthin the alarm setpoints and the reset button is depressed. A low-battery alarm vdll activate the BATT descriptor on the display and a continuous, steady- \WORK\2423l\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES BE-14 301190 sounding audible alarm. This steady sound indicates that the Model 361 must be removed from service and charged in a nonhazardous area. WARNING: Exposure of the combustible gas sensor to a concentration high enough to cause the readout to indicate a reading higher that 100 percent Lower Explosive Limit (LEL) will cause the readout to latch. When latched, the LEL readout will be blank and the descriptors for OVER and LEL ALARM vdll appear. This latching circuit is a warning that the gas concentration has exceeded the LEL and that all personnel must evacuate the area. This latching circuit can be reset by removing the Model 361 to an area known to be free of combustible gas (fresh air) and turning off the instiument. The Model 361 can then be turned on and rezeroed in fresh air. This latch circuit does not operate during the first 30 seconds after turning on the instrument, thus providing sufficient time for sensor warm-up and rezeroing. Toxic Gas Sensor The toxic gas sensor used in the Model 361 is a membrane-sealed electrochemical cell. The cell requires an external voltage source to function and produces a current output that is proportional to the amount of H2S present. The HjS diffuses through the front membrane of the cell and is oxidized at the working electrode. Current flows through the liquid electrolyte (acid solution) to the counter/reference electrode where oxygen reduction occurs. The amount of current produced for a concentration of HjS is dependent on the voltage across the working reference electrodes as well as the electrode materials and the electrolj^e. The choice of the particular noble metal electrodes and the setting of the cell voltage optimizes the sensor for the detection of HjS. The current from the cell is fed to a current-to-voltage converter. This voltage signal is applied to an amplifier that drives the toxic gas readout and provides and input for an alarm comparator circuit. Combustible Gas Sensor The flammable properties of combustible gases are used as the basis of detection. The sensor consists of a pair of pelletized filaments called Pelements™ arranged in an electrically balanced bridge \WORK\24231\02\HASPBD.APP March 17, 1994 HARDING LAWSON ASSOCIATES BE-15 301191 circuit. The detector pelement is treated vdth a catalyst that causes the combustible gases to combine vdth oxygen at much lower temperatures than would be required for normal burning. The inactive compensator pelement is also exposed to the sample flow and acts to offset any electrical changes caused by flow conditions, sample temperature, pressure, and/or humidity. Combustible gases in the sample combine vdth oxygen in the air at the surface of the catalyzed detector pelement. Heat is liberated by this chemical reaction, thus increasing the temperature of the pelement and causing an associated increase in the pelement electrical resistance. Incresised resistance of the detector pelement unbalances, the bridge circuit, causing a voltage change at the mid-point connection between the detector pelement and the compensating pelement. This voltage signal is applied to an amplifier that drives the combustible gas readout and provides an input for an alarm comparator circuit. Oxygen Sensor The oxygen sensor is a galvanic type cell containing gold and lead electrodes in a potassium hydroxide solution. The cell is sealed vdth a membrane that allows oxygen to diffuse into the active area. The current generated by the cell is proportional to the oxygen partial pressure in the atmospheric sample passing over the face of the membrane. The generated current passes through a resistance to provide a voltage input signal for an amplifier. The output of the amplifier drives the oxygen readout and also serves as an input to the alarm comparator circuit. The following instructions detail the procedures for operation and calibration of the MSA Model 361 Combustible Gas Indicator. Operating Instructions The Model 361 oxygen calibration and toxic and combustible zero checks must be made in fresh air or vdth the inlet end of the sampling line in fresh air. 1. Turn the FUNCTION control to the HORN OFF position; the HORN OFF indicator vdll light and the descriptor percent LEL vdll show in the readout. 2. Set the readout to zero (00) by adjusting the LEL ZERO control (NOTE: this must be done \WORK\24231\02\HASPBD.APP March 17,1994 HARDING LAWSON ASSOCIATES BE-IG 301192 vdthin 30 seconds of turning ON to prevent the possibility of activating the off-scale LEL latching alarm). 3. Press the SELECT button firmly to obtain percent OXY on the readout; then set the readout to 20.8 percent by adjusting the OXY CALIBRATE control. 4. Press the .SELECT button firmly to obtain PPM TOX on the readout; then set the readout to zero (00) by adjusting the TOX ZERO control. 5. Press the RESET button. 6. Turn the FUNCTION control to MANUAL for continuous readout of any one gas or to SCAN for automatic scanning of the three gas readings. (NOTE: All alarm functions operate in either position.) 7. Momentarily place a finger over the sample inlet fitting or the end of the sample line, if one is used. Observe that the FLOW indicator float drops, indicating no flow. If it does not, check the flow system and sample line for leaks. 8. The instrument is ready for calibration. WARNING: If an alarm is indicated by an ALARM or OVER sign in the readout or a pulsing hom, evacuate personnel from the area and notify the safety officer. A low battery condition is indicated by a BATT sign in the readout or by a steady hom; remove the Model 360 or 361 and recharge in a nonhazardous area to prevent potential ignition of combustible atmospheres. Model 361 Calibration 1. Attach the flow contiol to the 0.75 percent pentane/15 percent oxygen calibration gas tank. 2. Connect the adapter-hose to the flow control. 3. Open the flow contiol valve. 4. Connect the adapter-hose fitting to the inlet of the instrument; vdthin 30 seconds, the 1..KI. meter should stabilize and indicate between 47 and 55 percent. If the indicator is not in ;he correct range, remove the right end of the indicator and adjust the LEL SPAN control to obtain 50 percent. 5. Verify the oxygen reading; it should be between 13 and 17 percent. 6. Disconnect the adapter-hose fitting from the instrument. 7. Close the flow contiol valve. 8. Remove the flow contiol from the calibration gas tank. 9. Attach the flow control to the 10 ppm hydrogen sulfide calibration gas tank (40 ppm u.i» may be used; the choice of HjS calibration vdll depend on concentrations anticipated m !he \WORK\2423l\02\HASPBD.APP March 17,1994 HARDING LAWSON ASSOCIATES Bt-17 301193 work place). 10. Open the flow contiol valve. 11. Coimect the adapter-hose fitting to the inlet of the instrument; after approximately one minute, the TOX readout should stabilize and indicate between 7 to 13 ppm (35 to 45 ppm for 40 ppm HjS). If the indication is not in the correct range, remove the right end of the indicator and adjust the TOX SPAN contiol to obtain 10 ppm (40 ppm for 40 ppm H,S). 12. Disconnect the adapter-hose fitting from the instrument. 13. Close the flow control valve. 14. Remove the adapter-hose from the flow contiol. 15. Remove the flow contiol from the calibration gas tank. CAUTION: Calibration gas tank contents are under pressure. Do not use oU, grease, or flammable solvents on the flow contiol or the calibration gas tank. Do not store calibration gas tank near heat or fire, nor in rooms used for habitation. Do not throw in fire, incinerate, or puncture. Keep out of the reach of children. It is illegal and hazardous to refill this tank. Do not attach any gas tank other than MSA calibration tanks to the flow contiol. i \WORK\24231\02\HASPBD.APP March 17.1994 HARDING LAWSON ASSOCIATES BE-18 301194 APPENDIX BF ACCIDENT INVESTIGATION \WORK\24231\02\HASP.APP March 17,1994 HARDING LAWSON ASSOCIATES 301195 Harding Lawson Associates requires that an Accident Investigation form be completed for accidents occurring during working hours. The form, which is included in this appendix, can be obtained from the DHSO. This form must completed as soon as possible (limit - vdthin three working days) after occurrence of any injury that results in medical treatment or property damage. After completion, the form must be returned to the DHSO for processing. \WORK\24231\02\HASPAPP March 17. 1994 HARDING LAWSON ASSOCIATES 301196 A C C I D E N T INVESTIGATION COMPLETED FORM MUST BE FORWARDED TO CORPORATE HEALTH AND SAFETY WITHIN 10 WORKING DAYS Revision 1 L GENERAL DATA Employee name # OTRce OT last week /hrs Location of injury (address; description of job site) Social Security No. Immediate Supervisor Sex Age Case No. Date of injury Time of injury Date injury reported Date of Hire . IL MEDICAL DATA A. Class of injury (checic one only) Fatality Lost workday No lost time First aid only Other R Nature of injury (check all that apply) Amputation Asphyxiation Bum, scald Bum (chemical) Concussion Contagious, infectious disease Contusion, bruise Cut, laceration, bruise Dermatitis Dislocation Electric shock, electrocution Flesh bum Foreign body in eye Fracture Freezing, frostbite Hearing loss or impainnent Heat stroke, sunstroke Hernia rupture Poisoning—systemic Pneumoconiosis Radiation effects Scratches, abrasions Strains, sprains Occupational disease Other Unciassiiied, not determined C Part of Body Affected (check all that apply) Trunk (abdomen, back, Head and neck (ear, eye, chest, hips, pcMs, face, mouth, scalp, skull, shoulder, ottier) neck, other) m. ACCIDENT ANALYSIS A. Accident Type (check one only) m •ruck by uck against i from elevation lil to foot level Motor vehicle accident Public transportation Rubbed or abraded Bodily reaction Lower extremities (ankle, foot, knee, lower leg, thi^, toe, other) Upper extremities (upper arm, elbow, forearm, finger, hand, wrist, other) Overexertion Contact with electric current Contact with tempera- ture extremes Contact with chemical or toxic substance Exposure to physical hazards Qioise, IJV radiatioii) Body system (droilatoty, digestive, genitourinary, Eemato- Topc, inteeumental, musculo-skeletal, nervous, respiratory, other) Inhalation of toxic substance Other Caught in, under, or between B. Source of Injury (check all that apply) Air pressure Animals, insects, birds, reptiles Animal products (not food) Body motion Boilers, heating equip- ment, pressure vessels Boxes, barrels, containers, packages Building and structures Ceramic items Chemicals (liquids, solids, gases, vapors, fumes, etc.) Qothing, apparel, shoes Coal and petroleum products Cold (atmospheric, environmental) Conveyors, unpowered (chutes, rollers, etc) Dollies, hand trucks Drugs and medicines Electrical apparatus Excavations, trenches, tunnels Bame, fires, smoke Floors, level surface Furniture, fixtures, furnishings Glass items Hand tools, not powered Heat (atmospheric, environmental) Hoisting apparatus Infectious, parasitic agents Ladders, scaffolds Liquids Machines Mechanical power transmission apparatus - Metal (plate, sheet, coil) Noise, vibration Paper, plastic, foil Particulate (undefined) Plants, trees, vegetation Plastic items Pumps, prime movers Radiatmg substances, equipment Soaps, detergents, cleaning compounds Silicates Scrap, wastes, debris Steam Textile items Tiooling and fixtures Vehicles, powered Wood items (pulp, lumber, slabs, chips) Working surfaces Work area environments Other C Unsafe Act (check all that apply) Horseplay Failure to secure, warn, lockout, or assure clearance Improper lifting or canying Improper task selection Working on energized, R ressunzed equipment lisuse of equipment, tools, materials, vehicles Driver/operator error Failure to use equipment provided Failure to folk^r instructions Failure to use proper personal protective Improper UK of hands or body parts Unsafe ptacifi(, mudng, loading Operating or acting without authorization or in unauthorized location Taking an unsafe bodily position or posture (climbing, reaching, stretching) Failure to wear safe personal attire Inattention to footing or surroundings Using unsafe equipment Removing or making safety devices inoperative Other D. Unsafe Condition (check all that apply) Poor housekeeping Guarding not provided _ ^ ^ ^ - d e a u a t e traffic control, traffic _ l^Bfiects of machines, equipment, k-^'jols, materials, vehicles Inadequate illumination Inadequate or improperly designed ventilation Unsuitable design construction, layout of prescribed work method Natural hazards (terrain, elements, etc) Hazardous conditions Inadequate or improper guarding Other Unavailability of required equipment or devices No hazardous condition Improper stacking:, palletizing. and banding E. Supervisoiy Conditions (check all that apply) Failure to enforce safety rules, standards, or f irocedures nadequate inspection of equipment or work Failure to follow instructions Incorrect job assign- ment, layout, or design Inadequate training or instruction provided Failure to provide appropriate personal protective equipment Other Ineffective immediate supervision Failure to provide correct or safe tools 301197 DESCRIPTION OF ACCIDENT A. Names of witnesses How did accident happen? (Give a brief description) C Why did accident occur? (Explain more fully any unsafe acts/conditions which contributed to this accident) D. Was the peTSon(s) involved in the accident aware of the safe procedures to complete the job? Describe. E What corrective action is to be, or has been, taken to prevent a reoccurrence. Who is responsible for corrective action and when is the czpened compJetion date? ^ ^ ^ rated by: Date: Reviewed by DHSO: Date: Reviewed bv Project Manager Date: Reviewed bv Office Manaeer Due: Reviewed bv Manager H/S: Date: Office Manager Review with CEO: (required for all lost time injures) Due: Copies to: Project Manager, Office Manager, DHSO, Corporate Health and Safety Manager 301198 -ii Appendix C Quality Assurance Project Plan Prepared for Island Chemical Company St. Croix, U.S. Virgin Island 24231 2.C.3 James L. Collins Staff C^eologist Jason M. Schindler Senior Geologist March 17, 1994 Harding Lawson Associates Engineering and Environmental Services 131 North Third Street Philadelpfiia, PA 19106 - (215) 627-4505 301199 Section CO.O Revision 0 March 17. 1994 Paae 1 of 4 Quality Assurance Project Plan Approval Form The undersigned have read and approved this Quality Assurance Project Plan for Island Chemical Company St. Croix, U.S. Virgin Islands. _, ICC Project Officer , ICC QA Officer Edvi^ard A. Nemecek, HLA Project Manager Jason M. Schindler, Deputy Project Manager , HLA Quality Assurance Manager Sherrel Henry, U.S. EPA RI Project Manager , Laboratory QA Officer ( } - ( } - (609) 936-0700 (215) 627-4505 ( ) - (212) 264-8675 ( ] - Date Date Date Date Date Date Date \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301200 Section CO.O Revision 0 March 17, 1994 CONTENTS Cl.O QUALITY ASSURANCE OBJECTIVES Cl-1 Cl.l Level of Quality Control Effort Cl-1 Cl.1.1 Field Duplicate Samples Cl-1 Cl.l.2 Rinse Blank Samples Cl-2 Cl.1.3 Trip Blank Samples Cl-2 Cl.1.4 Matrix Spike/Matrix Spike Duplicate Samples Cl-2 Cl.2 Precision, Accuracy, and Sensitivity Cl-3 Cl.3 Representativeness, Completeness and Comparability Cl-4 Cl.3.1 Representativeness Cl-4 Cl.3.2 Completeness Cl-4 Cl.3.3 Comparability Cl-5 C2.0 INTENDED DATA USES AND DATA QUALITY OBJECTIVES C2-1 C3.0 SAMPLE CUSTODY C3-1 C3.1 Field Custody Procedures C3-1 C3.1.1 Field Procedures r C3-1 C3.1.2 Field Documentation C3-1 C3.1.2.1 Sample Labels ; C3-1 C3.1.2.2 Sampling Data Sheets C3-2 C3.1.2.3 Field Logbook (:.1-3 C3.1.2.4 Chain-of-Custody Record (:i-3 C3.1.3 Sample Custody Transfer and Shipment Procedures f M-4 C3.2 Laboratory Custody Procedures Clf) C3.3 Corrections to Documentation CIO C3.4 Final Evidence File Custody Procedures (..1 (i C4.0 CALIBRATION PROCEDURES AND FREQUENCY < •; l C4.1 Inspection of Field Equipment ' 4 1 C4.2 Field Equipment Calibration ( 4 1 C4.2.1 Organic Vapor Analysis ' -J J C4.2.2 Water-level Measurements '• -i J C4.2.3 pH Measurements ' -i : C4.2.4 Specific Conductance -i i C4.2.5 Water Temperature i -> i C4.3 Laboratory Instrument Calibration ' 4 4 C4.3.1 Organic Analyses ' 4 4 C4.3.2 Inorganics Analyses ' 4 '> C4.3.3 Non-Contract Laboratory Program Analyses ^ 4 "> C5.0 ANALYTICAL METHODS AND PROCEDURES C5.1 Non-Contract Laboratory Program Analytical Methods ' > ' \WORK\24231\02\QAPPJVPP Harding Lawson A s s o c l a t M 301201 • Section CO.O Revision 0 March 17, 1994 CONTENTS (Continued) C5.2 . Field Screening Analytical Procedures C5-1 C5.3 Quality Assurance/Quality Control Procedures for Field Analyses C5-1 C5.4 Laboratory Analytical Parameters and Methods C5-1 C5.5 Method Reporting Limit Requirements C5-2 C5.6 Laboratory Quality Assiirance/Quality Control Procedures C5-2 C6.0 INTERNAL QUALITY CONTROL PROCEDURES C6-1 C6.1 Field Quality Control Sample Collection C6-1 C6.1.1 Water and Soil Samples C6-1 C6.2 Field Measurement Quality Control Procedures C6-1 C6.3 Laboratory Quality Control Procedures C6-1 C6.3.1 Laboratory Quahty Assurance Program C6-2 C6.3.2 Organic Analysis C6-2 C6.3.3 Inorganic Analysis C6-3 C6.3.4 Miscellaneous Analyses C6-3 C7.0 DATA VALIDATION, REDUCTION AND REPORTING C7-1 C7.1 Data Validation C7-1 C7.1.1 Field Measurement Data Validation Procedures C7-1 C7.1.2 Analytical Data Validation ' C7-2 C7.1.2.1 Laboratory Data Validation Procedures C7-2 C7.1.2.2 Harding Lawson Associates Data Validation Procedures C7-3 C7.1.3 Data Qualifiers C7-5 C7.2 Data Reduction . C7-5 C7.2.1 Field Measurement Data Reduction Procedures C7-5 C7.2.2 Laboratory Analytical Data Reduction Procedures C7-6 C7.2.3 Harding Lawson Associates Analytical Data Reduction Procedures C7-7 C7.3 Information Transfer . C7-8 C7.4 Reporting Requirements and Document Control C7-9 C7.4.1 Laboratory DeUverables C7-9 C7.5 Reconciliation With Data Quality Objectives C7-9 C8.0 PERFORMANCE AND SYSTEMS AUDITS C8-1 C8.1 Field Audits C8-1 C8.1.1 Sample Labels C8-1 C8.1.2 Chain-of-Custody Records C8-1 C8.1.3 Field Logbooks C8-2 C8.1.4 Sampling Operations C8-2 C8.2 Laboratory Audits . C8-3 C8.3 Document Control C8-3 C9.0 PREVENTIVE MAINTENANCE PROCEDURES AND SCHEDULES C9-1 C9.1 Field Equipment C9-1 C9.2 Laboratory Instruments C9-1 \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301202 Section CO.O Revision 0 March 17. 1994 CONTENTS (Continued) ClO.O QUALITY ASSURANCE/QUALITY CONTROL PROCEDURES FOR DATA ASSESSMENT ClO-1 ClO.l Procedures for Assessing Field Data Precision and Accuracy ClO-1 ClO.2 Procedures for Assessing Laboratory Data Precision, Accuracy, Representativeness, Completeness and Comparability ClO-1 ClO.2.1 Precision Evaluation ClO-2 ClO.2.1.1 Duplicate Samples ClO-2 ClO.2.1.2 Matrix Spike Samples ClO-2 ClO.2.2 Accuracy Evaluation ClO-2 ClO.2.2.1 Blank Samples ClO-2 ClO.2.2.2 Matrix Spike Samples ClO-3 ClO.2.3 Representativeness Evaluation ClO-3 ClO.2.4 Completeness Evaluation ClO-3 ClO.2.5 Comparability Evaluation ClO-4 ClO.2.6 Sensitivity Evaluation ClO-4 Cll.O CORRECTIVE ACTION PROCEDURES Cll-1 Cll.l Field Situations Cll-1 Cll.2 Laboratory Situations Cll-1 Cll.3 Immediate Corrective Action ; Cll-1 Cll.4 Long-Term Corrective Action '• Cll-2 C12.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT C12-1 C13.0 ACRONYMS AND ABBREVIATIONS C13-1 C14.0 REFERENCES C14-1 TABLES Cl-1 Summary of Tasks Covered in QAPJP Cl-5 Cl-2 Groundwater Sampling Summary Cl-6 Cl-3 Soil Sampling Siimmary Cl-7 Cl-4 Target Compound List Volatile Organic Compoimds - Contract Required Quantitation Limits Cl-8 Cl-5 Target Compoimd List Semi-Volatile Organic Compounds - Contract Required Quantitation Limits Cl-10 Cl-6 Target Compound List Pesticides and PCBs - Contract Required Quantitation Limits . . . Cl-13 Cl-7 Target Analyte List Inorganics - Contract Required Method Detection Limits Cl-14 C4-1 Summary of Laboratory Data to be Collected C4-6 APPENDICES CA Resumes of Key Quality Assurance/Quality Control Professionals CB Corrective Action Form \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301203 Section Cl.O Revision 0 March 17, 1994 Cl.O QUALITY ASSURANCE OBJECTIVES The overall Quality Assurance (QA) objective for this project is to develop and implement standard United States Environmental Protection Agency (USEPA) procedures for field sampling, chain-of- custody, laboratory analyses and reporting that vail provide results that are technically usable and legally defensible in a court of law. Table Cl-1 presents a summary of tasks covered by this Quality Assurance Project Plan (QAPP). Specific QA procedures for sampling, chain-of-custody, laboratory instrument calibration, laboratory analyses, data reporting, internal quality control (QC), laboratory audits, preventive maintenance of field equipment and corrective action are described in other sections of this QAPP. The purpose of this section is to address the specific objectives for precision, accuracy, representativeness, completeness and comparability (PARCC). Definitions for PARCC follow (USEPA, 1986a): • Precision - a measure of mutual agreement among individual measurements of the same property, usually under prescribed similar conditions, usually expressed in terms of the relative percent difference. • Accuracy - the degree of agreement of a measurement with an accepted reference or true value. • Representativeness - the selection of analytical methods, sampling protocols and sample locaUons such that results are representative of the media being sampled and the conditions being measured. • Completeness - the amount of valid data obtained from a measurement System compared to the amount that was expected and needed to be obtained to meet the project data goals. • Comparability - the confidence vidth which one data set can be compared to another. C l . l Level of Quality Control Effort Project QC checks will be accomplished by submitting controlled samples to the laboratory from the field. Three types of QC samples will be used: field duplicates, blanks (rinse blanks and trip blanks) and matrix spike/matrix spike duplicates (MS/MSD). These QC samples will be analyzed to assess the data quality resulting from the field sampling program. Field duplicate samples will be submitted to the laboratory as blind samples. Any samples submitted as blind v^dll be noted in the field log and given a sample number that does not indicate to the laboratory that the sample is a QC check. QC samples will be collected and submitted to the laboratory to ensure that the data generated are representative of the study area environmental conditions. Soil and groimdwater samples, including QC samples to be collected during this project, are summarized on Tables Cl-2 and Cl-3, respectively. Each type of QC sample to be collected is discussed separately below. Cl.1.1 Field Duplicate Samples Field duplicates will be co-located, independent samples collected in such a manner that they are equally representative of the parameter(s) of interest at a given point in space and time. Co-located samples, when collected, processed and analyzed by the same organization, provide intra-laboratory precision information for the entire measurement system, including sample acquisition, homogeneity, handling, shipping, storage, preparation and analysis. Field duplicate samples can also be used to \W0RK\24231 \02\QAPP JIPP Harding Lawson Associates 301204 Section Cl.O Revision 0 March 17, 1994 estimate the overall precision of a data collection activity and to check sampling and analytical reproducibility. At least one field duplicate sample will be collected for every 20 investigative samples per sample matrix. Field QC samples will be handled identically to environmental samples. C l . l . 2 Rinse Blanic Samples Rinse blank samples will be obtained by running analyte-free distilled water through sample collection equipment after decontamination and collecting the rinsate in the appropriate sample containers for analysis. These samples will be used to evaluate the overall accuracy of the data by assessing whether decontamination procedures have been sufficient to minimize sample contamination. At least one rinse blank sample wdll be collected for every 10 investigative samples per sample matrix for non- aqueous samples and one rinse blank per day for aqueous samples. The water used for rinse blanks will be demonstrated analyte-free water. The water will be analyzed prior to use in the field and found to be contaminant-free to the levels required for the project. Cl.1.3 Trip Blank Samples Trip blank samples will be prepared by the analytical laboratory before the sampling event by filling 40-milliliter vials with reagent-grade demonstrated free of volatile organic compounds (VOC). The trip blanks are preserved in the same maimer as the groundwater samples. Trip blank samples are kept vdth field sample containers throughout the sampling event, then packaged for shipment with the other samples and sent to the laboratory for VOC analysis. One trip blank sample wall be included in each shipment that contains samples to be analyzed for VOCs. At no time after their preparation wdll the trip blank sample containers be opened before they are returned to the laboratory. Trip blank samples wdll be collected to assess the potential for VOC contamination introduced by sample bottles or sample handling during field operations and shipping. Cl.1.4 Matrix Spike/Matrix Spike Duplicate Samples MS/MSD saihples will be created in the laboratory by adding knowm amounts and concentrations of target analytes to a prepared portion of a sample immediately before extraction or analysis. MS/MSD samples provide information on matrix effects encountered during extraction, digestion and analysis (i.e., suppression or enhancement of instrument sij^nal levels). MS sample results are principally used to evaluate accuracy, but, when combined with MSD sample data, they also yield information on analytical precision. During the field activities, additional sample m.iiunal will be collected from field-selected locations to provide sufficient sample volume for the laboraiorv.to prepare MS/MSD samples. The MS and MSD for soil and water samples each require three aciiiiuon.il sample container volumes. Soil MS/MSD samples do not require additional sample volume. .\[ least one set of MS/MSD samples will be collected for every 20 investigative samples por s.i.'r.ple matrix. \WORK\24231\02\aAPP.APP Harding Lawson Associates 301205 Section Cl.O Revision 0 March 17, 1994 C1.2 Precision, Accuracy and Sensitivity The fundamental QA objective with respect to precision, accuracy and sensitivity of laboratory analyfical data is to achieve the QC acceptance criteria of the analytical protocols. The precision of the data will be evaluated by examining results obtained from the analysis of sample blanks, field and laboratory duplicate samples, laboratory MS/MSD samples and Contract Laboratory Procedure (CLP)-required laboratory QA/QC samples. The accuracy of the data wdll be evaluated for CLP methods by comparing the QC criteria stipulated in these methods to the results from laboratory MS/MSD samples. Analytical accuracy for non-CLP methods will be evaluated in relationship to method validation/start-up QC control criteria. Instrument sensitivity will be monitored by analyzing method blanks and calibration check samples (organic and inorganic analyses) and by laboratory control samples (inorganic analyses and organic samples analyzed by Superfund Analytical Method - Low Concentration [SAMLCj Water for Organic Analysis). The achievement of the method detection limits depends on instrument sensifivity and possible matrix effects. Therefore, it is important to monitor instrument sensitivity by regular instrument checks. Accuracy and precision goals for the study area will be adopted from the appropriate CLP statement of work (SOW) as available for the MS/MSD results. Data will be qualified in accordance wdth the appropriate USEPA functional guidelines if.either external (field) QC blanks or internal (laboratory) QC blanks indicate that the precision or accuracy of analytical results is compromised. Duplicate sample agreement goals wdll be compared with method QC criteria. The use of the method validation/startup QC criteria wiU also be used to evaluate MS/MSD results for non-CLP methods when specific MS/MSD control criteria are unavailable. If control criteria are unavailable for a targeted parameter, the laboratory-specific method control criteria will be adopted. Methods for calculating QA/QC sample precision and accuracy are provided in Section ClO.O of this document. The sensitivities required for these analyses will be the method reporting limits shown in Tables Cl 4 through Cl-7. Standard operating procedures (SOP) for selected laboratory analyses wdll be reviewed prior to selection. These SOPs include the required precision, accuracy and sensifivity of the analyses. .^( s^'s for the field equipment to measure pH, conductivity and temperature are outlined in the field sampling plan (FSP) presented as Appendix A of this Work Plan. C1.3 Representativeness, Completeness and Comparability This section describes the QA objecfives wdth respect to representativeness, completeness and comparability. Cl.3.1 Representativeness Representativeness expresses the degree to which sample data accurately and precisely represent .i characteristic of a population, parameter variations at a sampling location, a process condition (.: .ir. environmental condifion. Representativeness is a qualitative parameter most concerned with the \WORK\24231\02\QAPP.APP Harding Lawson Associat— 301206 Section Cl.O Revision 0 March 17, 1994 proper design of the sampling program, proper sampling locations, implementing proper sampling protocols and collecting a sufficient number of investigative samples. Representativeness is addressed in detail in the Workplan and FSP by describing the rationale used to select sampling locations and proper sampling techniques. Representativeness wdll be satisfied by ensuring that the FSP is followed, proper sampling techniques are used, proper analytical procedures are followed and technical holding times of the samples are not exceeded. Representativeness will be assessed by analysis of field dupUcate samples. Furthermore, representativeness wdll be assessed by the analysis and interpretation of the results of an appropriately defined number of internal (laboratory) and external (field) QC samples. Precision and accuracy information developed from the evaluation of QC samples wdll be used to qualitatively evaluate representativeness. A representativeness evaluation wiU be performed through a careful comparison of results from the study area. The chemical constituent type, breakdown characteristics and concentration will be used to qualitatively evaluate the representativeness of the reported results. C1.3.2 Completeness This QA program is designed to achieve a goal of 100 percent data completeness. Realizing that under normal conditions this goal may not be achievable, the completeness goal for this program, on the basis of HLA's experience, is 90 to 95 percent. This completeness goal is considered adequate to meet the intended data uses for this site on the basis of prior consideration of PARCC parameters, the sampling design plans and data collection activities proposed for the remedial action. Following completion of the analytical testing, the percent completeness wdll be calculated by the following equation: Completenes(%) = Number of valid samples X 100 (Number of samples collected for each parameter analyzed) C1.3.3 Comparability Comparability of the data collection activities must consider field conditions as well as sampling and analytical techniques. Comparability of the data will be enhanced through the use of standard sampling and analytical methods or analytical methods that are equivalent in method performance criteria and reported units. For the purposes of the remedial action, the analytical methods, the quality of the data and the sampling design wdll be evaluated for data comparability. The extent to which existing and planned analytical data wdll be comparable depends on the similarity of sampling and analytical methods. The procedures used to obtain the planned analytical data, as documented in the QAPP, are expected to provide comparable data. If data do not appear comparable after the initial evaluation, HLA wdll attempt to identify other components possibly affecting comparability, including, but not limited to, field conditions, sampling protocols and the occurrence of true data anomalies. \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 301207 Section Cl.O Revision 0 March 17, 1994 Table C l - 1 . Summary of Tasks Covered in Project Work Plan Island Chemical Company Site St. Croix, U.S. Virgin Islands Data Collection Activity Rationale/Objective(s) Covered in QAPP' Review existing data Validate existing sampling data Clear the site of vegetation and perform a reconnaissance Repair and re-sample existing weUs Install and sample new monitoring wells Acquire access approvals and permits Install soil borings Collect surface soil samples Survey wells and borings Understanding previous work and site conditions as known. Evaluate quality of existing data. Facilitate access to site; confirm areas of concern and sampling locations Confirm existing data regarding groundwater quality Evaluate whether affected groundwater is present; Assess groundwater flow Ensure compliance with local rules and regulations Evaluate local geology; determine if clay layer reported by ESI is present; determine if affected soils are present Evaluate whether affected sediments are present Measure exact locations of sampling points; ensure accuracy and consistency No Yes No Yes Yes No Yes Yes No ' See Work Plan and Samphng and Analysis Plan for additional details on items not specifically covered in this QAPP. \WORIC\24231 \02\QAPP.TAB Harding Lawson Associates 301208 i .i I t A ....4 i Section Cl.O Revision 0 Miircli 17, 1994 I'.age 0 of 14 Table C l - 2 . Groundwater Sampling Summary Islnnd Clinmicnl Coinp.Tny .Site St. Croix, U.S. Virgin Islands Analytical Parameter VOCs SVOs Pest/PCBs Inorganics Pyridine VOCs SVOs Pest/PCBs Inorganics Invest No. 5 5 5 5 5 gative Samples Freq. 2 2 2 2 2 Tol. Quality Control Samples Rinse Blank No. 10 1 10 1 10 1 10 1 10 1 Trcq. Tol. Field Duplicate No. Frcq. Tot. 2 2 1 2 2 2 2 1 2 2 2 2 1 2 2 2 2 1 2 2 2 2 1 2 2 Trip Blank No. Frcq. 1 2 0 0 0 0 0 0 0 0 Tot. 2 0 0 0 a M.ilrix Spike No. Fmq. 1 2 1 2 1 2 1 2 0 0 Target Compound List (TCL) Volatile Organic Compounds using low concentration USEPA CLP SOW (8/91). TCL Semi-volatile Organic Compounds using low concentration USEPA CLP SOW (8/91). TCL I Targe lesticides I analyte and PCBs list inorganics I Tol. 2 2 2 2 0 Mali No. 1 1 1 0 0 ix Spike Frcq. 2 2 2 0 0 Dup. Tol. 2 2 2 0 0 Tolal 20 18 IB 16 14 O M NJ O \WORK\24231\02\QAPP.TAB Harding Lawson Associates # .'V i Section Cl.O Revision 0 March 17, 1994 Table Cl-3. Soil Sampling Summary Island Chemical Company Site St. Croix, U.S. Virgin Islands Analytical Parameter Investigative Samples No. I VTC(\. Tot. Quality Conlrol Samples Rinse Blank No. F'rcq. Tol Field Duplicate No. Freq. lot. Trip Blank No. Freq. Tol. Matrix Spike No. I Fret). Tol. No, IVIalrix Spike Dup. Fru<|. Tol. Total VOCs SVOs iv-,i'i'(:ns I ' y i M l i i i t ; 20 20 20 .'(J J(l 20 20 20 .'II -'() 2 2 2 - 2 2 2 2 2 2 1 2 1 0 1 0 0 0 1 0 0 0 0 2 0 0 0 0 1 1 1 1 0 1 1 1 1 0 1 1 1 1 0 1 1 1 0 0 1 1 1 0 0 1 1 1 0 0 27 25 25 24 23 V()(;s Target Coni|K)uiul I.isl (TCL) Volatile Organic ComjxDiuids using low concentration USEPA CLP SOW (8/91). SVOs TCL Semi-volatile Organic Compounds using low concentration USEPA CLP SOW (8/91). Pest/I'CBs TCL pesticides and PCBs ' Inorganics Target analyle list inorganics Ui O M to O \WORK\24231\02\QAPP.TAB Harding Lawson Associates Section Cl.O Revision 0 March 17, 1994 Table Cl-4. Target Compound List Volatile Organic Compounds Contract Required Quantitation Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number 74-87-3 74-83-9 75-01-4 75-00-3 75-09-2 67-64-1 75-15-0 75-35-4 75-35-3 156-59-4 156-60-5 540-59-0 67-66-3 107-06-2 73-93-3 74-97-5 71-55-6 56-23-5 75-27-4 78-87-5 10061-01-5 71-01-6 124-48-1 79-00-5 71-43-2 10061-02-6 Parameter Chloromethane Bromomethane Vinyl chloride Chloroethane Methylene chloride Acetone Carbon disulfide 1,1 -Dichloroethene 1,1 -Dichloroethane cis-1,2 -Dichloroethene trans-1,2-Dichloroethane Total 1,2-Dichloroethane Chloroform 1,2-Dichloroethane 2-Butanone Bromochloromethane 1,1,1-Trichloroethane Carbon tetrachloride Bromodichloromethane 1,2-Dlchloropropane cis-l,3-Dichloropropene Trichloroethene Dibromochloromethane 1,1,2 -Trichloroethane Benzene trans-1,3-Dichloropropene Contract Required Quantitation Limits' Water Analyses (Mg/l)' 1 1 1 1 2 5 1 1 1 1 1 NA 1 1 5 . 1 1 1 1 1 1 1 1 1 1 1 Soil Analvses (Mg/kg)'^ 10 10 10 10 10 10 10 10 10 NA NA 10 10 10 10 ??? 10 10 10 10 10 10 10 10 10 10 \WORK\24231 \02\QAPP.TAB Harding Lawson Associato* 301211 Section Cl.O Revision 0 March 17, 1994 Table C l -4. Target Compound List Volatile Organic Compounds Contract Required Quantitation Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number 75-25-2 108-10-1 591-78-6 127-18-4 79-34-5 106-93-4 108-88-3 108-90-7 100-41-4 108-42-5 1330-20-7 541-73-1 106-46-7 95-50-1 96-12-8 Parameter Bromoform 4-Methyl-2-pentanone 2-Hexanone Tetrachloroethene 1,1,2,2 -Te trachloroethane 1,2-Dibromomethane Toluene Chlorobenzene Ethylbenzene Styrene Total xylenes 1,3 -Dichlorobenzene 1,4-Dichlorobenzene 1,2-Dichlorobenzene l,2-Dibromo-3-chloropropane Source: U.S. Environmental Protection Agency, 1991b. Contract Required Quantitation Limits' Water Analyses 1 5 5 1 1 1 1 1 1 1 1 1 1 1 1 Soil Analyses (Mg/Tcg)^ 10 10 10 10 10 NA 10 10 10 10 10 NA NA NA NA /xg/1 Micrograms per Uter ^g/kg Micrograms per kilogram CAS Chemical Abstract Service CLP Contract Laboratory Program NA Not analyzed SOW Statement of Work USEPA United States Environmental Protection Agency 1. Quantitation limits are matrix-dependent, and hsted quantitation limits may not always be achievable. Actual quantitation limits attained will be reported by the laboratory. 2. Quantitation limits from USEPA 10/92 SAMLC for water and CLP 3/90 SOW for soil. \W0RIC\24231 \02\QAPP.TAB Harding Lawson Associates 301212 Section Cl.O Revision 0 March 17, 1994 Pace 10 of 14 Table Cl-5. Target Compound List Semi-Volatile Organic Compounds Contract Required Quantitation Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number Parameter Contract Required Quantitation Limits^ Water Analyses (MgA)^ Soil Analyses (Mg/kg)^ 108-95-2 Phenol 111-44-4 bis(2-Chloroethyl)ether 95-57-8 2-Chlorophenol 108-60-1 2,2'-oxybis(l-Chloropropane) 95-48-7 2-Methylphenol 106-44-5 4-Methylphenol 621-64-7 N-nitroso-di-n-propylamine 67-72-1 Hexachloroethane 98-95-3 Nitrobenzene 78-59-1 Isophorone 88-75-5 2-Nitrophenol 105-67-9 2,4-Dimethylphenol 111-91-1 bis(2-Chloroethoxy)methane 120-83-2 2,4-Dichlorophenol 120-82-1 1,2,4-Trichlorobenzene 91-20-3 Naphthalene 106-47-8 4-Chloroaniline 87-68-3 Hexachlorobutadiene 59-50-7 4-Chloro-3-methylphenol 91-57-6 2-Methylnaphthalene 77-47-4 Hexachlorocyclopentadiene 88-06-2 2,4,6-Trichlorophenol 95-95-4 2,4,5-Trichlorophenol 91-58-7 2-Chloroanaphthalene 88-74-4 2-Nitroaniline 131-11-3 Dimethylphthalate 208-96-8 Acenaphthylene \WORK\24231 \02\C2APP.TAB 5 5 5 5 5 5 5 5 . 5 5 5 5 5 5 5 5 20 5 20 5 5 5 20 5 20 5 5 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 330 800 330 800 330 330 Harding Lawson Associates 301213 Section Cl.O Revision 0 March 17, 1994 Table Cl-5. Target Compound List Semi-Volatile Organic Compounds Contract Required Quantitation Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number Parameter Contract Required Quantitation Limits* Water Analyses (MgA)^ Soil Analyses (M&^g)' 606-20-2 99-09-2 83-32-9 51-28-5 100-02-7 132-64-9 121-14-2 84-66-2 541-73-1 106-46-7 95-50-1 7005-72-3 86-73-7 100-01-6 534-52-1 86-30-6 101-55-3 118-74-1 87-86-5 85-01-8 120-12-7 84-74-2 206-44-0 129-00-0 85-68-7 91-94-1 56-55-3 2,6-DinitTOtoluene 3-Nitroanihne Acenaphthene 2,4-Dinitrophenol 4-Nitrophenol Dibenzofuran 2,4-Dinitrotoluene Diethylphthalate 1,3-Dichlorobenzene 1,4-Dichlorobenzene 1,2 -Dichlorobenzene 4-Chlorophenyl-phenyl ether Fluorene 4-Nitroaniline 4,6-Dinitro-2 -methylphenol N-nitiosodiphenylamine 4-Bromophenyl-phenylether Hexachlorobenzene Pentachlorophenol Phenanthrene Anthracene di-n-Butylphthalate Fluoranthene Pyrene Butylbenzylphthalate 3,3-Dichlorobenzidine Benzo(a)anthracene 5 20 5 20 20 5 5 5 . NA NA NA 5 5 20 20 5 5 5 20 5 5 5 5 5 5 5 5 \WORK\24231 \02\QAPP.TAB 330 800 330 800 800 330 330 330 330 330 330 330 330 800 800 330 330 330 800 330 330 330 330 330 330 330 330 Harding Lawson Associates 301214 Section Cl.O Revision 0 March 17, 1994 Table Cl-5. Target Compound List Semi-Volatile Organic Compounds Contract Required Quantitation Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number Parameter Contract Required Quantitation Limits' Water Analyses (Mg/l)' Soil Analyses (MgAcg)^ 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 Chrysene bis(2-Ethymexyl)phthalate di-n-Octyl phthalate Benzo(b)fluoranthene Benzo(k)fluoranthene Benzo(a)pyrene Indeno(l,2,3-cd)pyrene Dibenzo(a,h)anthracene Benzo(g,h,i)perylene Source: U.S. Environmental Protection Aaencv. 1991b. Mg/l Mg/kg CAS CLP NA SOW Micrograms per hter Micrograms per kilogram Chemical Abstract Service Contract Laboratory Program Not analyzed Statement of Work 5 5 5 5 5 5 5 5 5 330 330 330 330 330 330 330 330 330 USEPA United States Enviromnental Protection Agency 1. Quantitation limits are matrix-dependent, and listed quantitation hmits may not always be achievable. Actual quantitation limits attained will be reported by the Uboratory. 2. QuanUtation hmits from USEPA 10/92 SAMLC for water and CLP 3/90 SOW for soil. \WORIC\24231 \02\QAPP.TAB Harding Lawson Associates 301215 Section Cl.O Revision 0 March 17, 1994 Table C1.6. Target Compound List Pesticides and PCBs Contract Required Quantitation Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number 309-00-2 319-84-6 319-85-7 58-89-9 319-86-8 5103-71-9 5103-74-2 50-29-3 72-55-9 72-54-8 60-57-1 959-98-8 33213-65-9 1031-07-8 72-20-8 7421-36-3 53494-70-5 76-44-8 1024-57-3 72-43-5 12674-11-2 11104-28-2 11141-16-5 53469-21-9 12672-29-6 11097-69-1 11096-82-5 8001-35-2 Parameter Aldrin alpha-BHC beta-BHC ganuna-BHC (Lindane) delta-BHC alpha-Chlordane gamma-Chlordane 4,4'-DDT 4.4'-DDE 4,4'-DDD Dieldrin Endosulfan 1 Endosulfan 11 Endosulfan sulfate Endrin Endrin aldehyde Endrin ketone Heptachlor Heptachlor epoxide Vfethoxychlor Arochlor 1016 Aiochlor 1221 Arochlor 1232 Aiochlor 1242 Aiochlor 1248 Arochlor 1254 Aiochlor 1260 Toxaphene Contract Required Quantitation Limits' Water Analyses 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.1 0.1 0.1 0.1 0.05 0.1 0.1 0.1 0.1 0.1 0.05 0.05 0.5 1.0 2.0 1.0 1.0 1.0 1.0 1.0 5.0 SoU Analvses 1.7 1.7 1.7 1.7 1.7 1.7 1.7 3.3 3.3 3.3 3.3 1.7 3.3 3.3 3.3 3.3 3.3 1.7 1.7 17 33 67 33 33 33 33 33 170 Mg/l Micrograms per hter CAS Chemical Abstract Service SOW Statement of Work /ig/kg Micrograms per kilogram CLP Contract Laboratory Program USEPA United States Environmental Protection Agency 1. Quantitation limits are matrix-dependent, and hsted quantitation limits may not always be achievable, quantitation limits attained wrill be reported by the laboratory. 2. Quantitation hmits from USEPA 10/92 SAMLC for water and CLP 3/90 SOW for soil. Source: U.S. Environmental Protection Agency. 1991b. Ac;;;..! \WORK\24231 \02\QAPP.TAB Harding Lawson Associates 301216 Section Cl.O Revision 0 March 17, 1994 Table Cl-7. Target Analyte List Inorganics Contract Required Detection Limits Island Chemical Company Site St. Croix, U.S. Virgin Islands CAS Number Parameter Contract Required Detection Limits' Water Analyses' (mg/l) Soil Analyses' (mg/kg) 7429-90-5 7440-36-0 7440-38-2 7440-39-3 7440-41-7 7440-43-9 7440-70-2 7440-47-3 7440-48-4 7440-50-8 7439-89-6 7439-92-1 7439-95-4 7439-96-5 7439-97-6 7440-02-0 7440-09-7 7782-49-2 7440-22-4 7440-23-5 7440-28-0 7440-62-2 7440-66-6 57-12-5 Aluminum Antimony Arsenic Barium BeryUium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Mercury Nickel Potassium Selenium Silver Sodium Thalhxun Vanadium 21inc Cyanide 0.2 0.06 0.01 0.2 0.005 0.005 0.005 0.01 0.05 0.025 0.1 0.003 5 0.015 0.0002 0.04 S 0.005 0.01 5 0.01 0.05 0.02 0.01 40 12 2 40 1 1 1,000 2 10 5 20 0.6 1,000 3 0.1 8 1.000 1 2 1,000 2 10 4 mg/l - Milhgrams per hter mg/kg - MiUigrams per kilogram CAS - Chemical Abstract Service CLP - Contract Laboratory Program USEPA - United States Environmental Protection Agency 1. Detection limits are matrix-dependent and hsted detection limits may not always be achievable. Actual quantitation limits attained wiU be reported by the laboratory. 2. QuanUtation hmits from USEPA 10/91 SAMLC for water and CLP 3/90 for soU. Source: U.S. Enviromnental Protection Agency. 1991b. \WORIC\24231 \02\QAPP.TAB Harding Lawson Associates 301217 Section C2.0 Revision 0 March 17, 1994 C2.0 INTENDED DATA USES AND SUPERFUND DATA CATEGORiES Intended uses for data gathered during the field activities include identifying contaminated media, estabhshing baseline data, performing treatability studies (if necessary) and, eventually, designing a remedial action. The Data Quality Objective (DQO) process (USEPA, 1993) provides a logical basis for linking QA/QC procedures to the intended use of the data. To assist in the interpretation of data, the Superfund program has developed the following tv^ro descriptive categories: • Screening data with definitive confirmation • Definitive data These two data categories are associated wdth specific QA and QC elements, and may be generated using a v^dde range of analytical methods. The particular type of data to be generated depends on the qualitative and quantitative DQOs developed during application of the DQO Process. The decision on the type of data to be collected should not be made prior to completion o f the entire DQO Process. Screening Data with Definitive Confirmation Screening data are generated by rapid, less precise methods of analysis with less rigorous sample preparation. Sample preparation steps may be restricted to simple procedures such as dilution with a solvent, instead of elaborate extraction/digestion and cleanup. Screening data prbvide analyte identification and quantification, although the quantification my be relatively imprecise. At least ten percent of the screening data are confirmed using analytical methods and QA/QC procedures and criteria associated with definitive data. Screening data without associated confirmation data are not considered to be data of known quality. QA/QC elements for screening data are as follows: Sample documentation (location, date and time collected and batch); Chain of custody (when appropriate); SampUng designation approach (systematic, simple or stratified random, judgmental, etc.); Initial and continuing calibration; Determination and documentation of detection limits; Analyte(s) identification; Analyte(s) quantification; Analytical error determination. An appropriate number of replicate aliquots, as specified in the QAPP, are taken from at least one thoroughly homogenized sample, the replicate aliquots are analyzed, and the standard laboratory QC parameters (such as variance, mean, and coefficient of variation) are calculated and compared to method-specific performance requirements specified in the QAPP; Definitive confirmation: at least ten percent of the screening data must be confirmed with definitive data as described below. As a minimum, at least three screening samples reported above the action level (if any) and three screening samples reported below the action level (or as non-detects) should be randomly selected from the appropriate group and confirmed. \WORK\24231 \02\QAPP JVPP Harding Lawson Associates 3 01218 Section C2.0 Revision 0 March 17, 1994 Definitive Data Definitive data are generated using rigorous analytical methods, such as approved USEPA reference methods. Data are analyte-specific, with confirmation of analyte identity and concentration. Methods produce tangible raw data (e.g. chromatograms, spectra, digital values) in the form of paper printouts or computer-generated electronic files. Data may be generated at the site or at an offsite location, as long as the QA/QC requirements are satisfied. For the data to be definitive, either analytical or total measurement error must be determined. QA/QC elements for definitive data are as follows: Sample documentation (location, date and time collected, and batch); Chain of custody (when appropriate); Sampling designation approach (systematic, simple or stratified random, judgmental, etc.); Initial and continuing calibration; Determination and documentation of detection limits; Analyte(s) identification; Analyte(s) quantification; QC blanks (trip, method, rinsate); Matrix spike recoveries; Performance Evaluation (PE) samples (when specified); Anal)dical error determination (measures precision of analytical method). An appropriate number of replicate aliquots, as specified in the QAPP, are taken from at least one thoroughly homogenized sample, the repUcate aliquots are analyzed, and the standard laboratory QC parameters (such as variance, mean, and coefficient of variation) are calculated and compared to method-specific performance requirements specified in the QAPP; Total measurement error determination (measures overall precision of measurement system from sample acquisition through analysis): An appropriate number of co-located samples as determined by the QAPP are independently collected from the same location and analyzed following standard operating procedures. Based on these analytical results, standard laboratory QC parameters such as variance, mean and coefficient of variation should be calculated and compared to established measurement error goals. This procedure may be required for each matrix under investigation and may be repeated for a given matrix at more than one location at the site. The Project DQOs have been developed to integrate the sampling activities with the intended data uses. The purpose of this project is to evaluate whether historical activities at the site have affected soil and/or groundwater quality. Because of the intended multiple uses of the data to be collected, the data categories are discussed separately according to data type. Details of the analytical methods to be used for the investigation are presented in Section C8.0 of this QAPP. Analyses of soil and groundwater samples collected as part of the field activities will provide DQO Definitive Confirmation type data for use in characterization of soil and groundwater at the site. Data collected during groundwater treatability test field activities wUl include both Screening With Definitive Confirmation and Definitive Data DQOs. Field measurements such as water levels. \WORK\24231\02\QAPP.APP Harding Lawson Associates 301219 58 Section C2.0 Revision 0 March 17. 1994 surveying organic vapor measurements, geophysical logging and geotechnical analyses (ASTM specifications) will be Screening Data with Definitive Confirmation. Other activities such as data validation, access and permitting require no sampling. These activities will be conducted consistent wdth state of the industry practices. \WORK\24231\02\QAPP.APP Harding Lawson Associates 301220 m SecUon C3.0 Revision 0 March 17, 1994 C3.0 SAMPLE CUSTODY This section describes SOPs for sample custody. Final custody procedures will be followed through sample collection, transfer, analysis and disposal. The purpose of these procedures is to ensure that (1) sample integrity is maintained during saniple collection, transportation and storage before analysis and (2) post-analysis sample material is properly disposed. Sample custody is divided into field procedures and laboratory procedures as described below. Originals of laboratory reports and purge files will be maintained under document control in a secure area. A file is considered under custody if the documents are in: • The custodian's possession or view. • A designated secure area. C3.1 Field Custody Procedures The sample packaging and shipment procedures summarized in this section are intended to ensure that the samples coUected wiU arrive at the laboratory with the chain of custody intact. C3.1.1 Field Procedures The HLA field sampler is personaUy responsible for custody of the collected samples until thev are properly shipped or transferred to the laboratory. Samples will be handled by a^ few people as possible. Each sample will be properly labeled and sealed immediately after collection. The HL-\ field supervisor wdll review field activities to evaluate whether proper custody procedures were foiiowijd during the field work and decide if additional samples are required. C3.1.2 Field Documentation Sample identification documents wiU be carefully prepared to maintain identification and chain of- custody records and to control sample disposition. Forms wdll be completed in water-proof ink. '. ht; followdng sample identification documents wdll be used for all sampling activities: • Sample labels • Sampling data sheets • Field logbook • Chain-of-custody forms C3.1.2.1 Sample Labels Sample labels are permanently affixed to sample bottles to provide sample identification. W'.^'T- necessary, the label will be protected from water and solvents with clear label-protection tap" \' i minimum, sample labels will contain the followdng information: • HLA office address and telephone number • Sequential label identification number • Sample identification number • Project code: an assigned HLA project number \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301221 Section C3.0 Revision 0 March 17, 1994 Name and iniUals of sample collector Date: a six-digit number indicating the day, month and year of collection Time: a four-digit number indicating the 24-hour clock time of collection Media type: the type of sample Sample location and depth Sample container type Sampling technique Preservative: the label wdU indicate whether a preservative was used and the type of preservative Analysis: the type of analysis requested (if no analyses are to be performed, this wdll be indicated) Remarks C3.1.2.2 Groundwater Sampling Data Slieets During groundwater sampling activities, information pertinent to field measurements and/or sampling wdll be recorded on groundwater sampling data sheets. The followdng entries wdU be contained in these sheets: Name and title of author, date and time of entry Weather conditions during field activity Location of sampling or measurement activity Name(s) and title(s) of field crew Type of sampled or measured media (e.g., groundwater) Sample coUection or measurement method(s) Number and volume of sample(s) collected Description of sampling points Description of measuring reference points Date and time of collection or measurement Sample identification number(s) Sample preservative (if necessary) Sample distribution (e.g., laboratory) Field observations/comments Field measurement data (pH, conductivity and temperature) References for maps and photographs of sampling area(s) Sample documentation including dates and methods of sample shipment and bottle lot numbers An example of a groundwater sampling data sheet is provided in the FSP. \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301222 Section C3.0 Revision 0 March 17, 1994 C3.1.2.3 Field L o g b o o k The field logbook wdll provide the means of recording data coUection activities. As such, entries will be described in detail so that persons going to the site may reconstruct a particular situation without rel3dng on memory. • Logbooks wdll be assigned to field persormel, but wdll be stored in the project file when not tn use. Each logbook wiU be identified by a project-specific number. • The title page of each logbook wdll contain the following information: Person to whom the logbook is assigned Logbook number Project name Project start date Project end date Information pertinent to a field survey, measurements and/or sampling wdll be recorded in a bound logbook. The following entries wdU be contained in the logbook: • Name and title of author, date and time of entry andjjhysical/environmental conditions during field activity Location of sampling or measurement activity Name(s) and title(s) of field crew Name(s) and title(s) of site visitors and purpose of visit Type of sampled or measured media (e.g., soU, sediment or groundwater) Sample coUection or measurement method(s) Number and volume of sample(s) and sample containers coUected Description of sampling point(s) Description of measuring reference points Date and time of sample coUection or field measurement Description of sample coUection equipment Description of deviations from the FSP and the rationale for the deviations. Sample identification number(s) Sample preservative (if necessary) Sample distribution (e.g., laboratory) Field observations/comments Calculations Description of field measurement instruments Field measurement data (pH, conductivity), including calibration data References for aU maps and photographs of sampling site(s) Sample documentation including dates and methods of sample shipment and bottle lot numbers Level of personal protective equipment being used The signature of the person making the entry A line wUl be drawn across the remainder of each incomplete page and initialed to indicate the end of an entry. \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 301223 Section C3.0 Revision 0 March 17, 1994 C3.1.2.4 Chain>of•Custody Record The chain-of-custody record for each sample wdll originate in the field where the sample is prepared for shipment to the laboratory. HLA will be responsible for completing the chain-of-custody record throughout the sampling program untU the samples have been shipped or delivered to the laboratory. The chain-of-custody record will accompany the sample through sample collection, shipment and analysis by the laboratory. This record wdll be completed to establish the documentation necessary to trace sample custody from sample coUection through sample analysis. The chain-of-custody form wdll contain, at a minimum, the followdng information: Project name Sample identification number(s) Laboratory identification Site identification Signature of sampler Date and time of sample coUection Sample location and depth Sampling technique Sample type (media sampled) Sample preservation Requested analysis Container type Signatures of persons involved in the chain of possession (inclusive dates and times of custody) Preservatives/remarks Designation of sample as grab or composite The laboratory portion of the form should be completed by the designated laboratory sample custodian and will contain the followdng information: • Name of person receiving the samples • Date and time of sample receipt by the laboratory • Sample condition and temperature (recorded in Remarks section) This form wdll be returned to HLA as part of the final project file upon successful completion of analysis. A copy of an example chain-of-custody form is provided in the FSP. C3.1.3 Sample Custody Transfer and Shipment Procedures During shipment, samples wdll always be accompanied by a chain-of-custody form. When transferring samples, the individuals relinquishing and receiving the samples wdll sign, date and note the time on the chain-of-custody form. The method of shipment, courier name(s) and other pertinent information wdll be entered in the chain-of-custody record. This record documents transfer of custody of samples from the sampler to another person, to a mobUe laboratory, to the permanent laboratory or to/from a secure storage area. \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 301224 -'n l i 3 Section C3.0 Revision 0 March 17, 1994 Samples wdU be properly packaged within 24 hours of collection for shipment via an overnight courier and dispatched to the appropriate laboratory for analysis with a separate signed chain-of-custody form enclosed in each sample cooler. Shipping containers wdll be secured with strapping tape and custody seals wdll be attached to the front right and back left of the cooler for shipment to the laboratory. The custody seals will be covered wdth clear plastic tape. A copy of a custody seal (evidence tape) is provided in the FSP. The cooler wdU be strapped shut wdth strapping tape in at least two locations. Each cooler wdll be marked "Box _ of_" (with appropriate numbers in the blanks) so that the recipient wdll know when the entire shipment has been received. Whenever samples are split with a recipient or government agency, a separate sample receipt vvdll be prepared for those samples and marked to indicate wdth whom the samples are being split. The person relinquishing the samples to the facility or agency should request the representative's signature acknowledging sample receipt. If the representative is unavaUable or refuses to sign, this wdll be noted in the "received by" space. All shipments wdU be accompanied by the chain-of-custody form identifying the contents. The original record wdll accompany the shipment and copies wdU be retained by the sampler for return to the HLA fUes. If the samples are sent by common carrier, a bUl of lading should be used. Receipts of bUls of lading wdll be retained as part of the permanent documentation. If sent by U.S. Postal Service, the package wdll be registered wdth return receipt requested. Neither commercial carriers nor the U.S. Postal Service are required to sign the chain-of-custody forms as long as the forms are sealed inside the sample cooler and the custody seals remain intact. C3.2 Laboratory Custody Procedures The laboratory contractor wdU follow the sample custody procedures specified in the CLP SOW for organic and inorganic analyses. A sample custodian wdll be designated by the laboratory to receive the sample shipment from the field. The custodian will accept custody of the samples shipped to the laboratory and wdll verify that the information on the sample label matches the information on the chain-of-custody form(s). Pertinent information relating to shipment, pickup and courier wUl also be verified on the chain-of-custody form(s). The custodian wdll enter the appropriate data from the chain- of-custody form into the laboratory sample tracking system, using the sample number from the sample label or assigning a unique laboratory number to each sample. The custodian wdU store the sample(s) in the defined secure area. The laboratory sample custodian wdU notify the HIA QA Manager of any discrepancies noted on the chain-of-custody form or sample labels. Samples will not be analyzed untU the HLA QA Manager resolves the discrepancy. Any changes made will be documented by the laboratory persormel and the HLA QA Manager. The name and telephone number of the HLA QA Manager are noted on the Approval Form at the beginning of this QAPP Laboratory personnel are responsible for cust(xiv of samples from the time they are received untU sample analysis is complete. Any unused portions of samples remaining after completion of analysis by the laboratory wdll be disposed in accordancL* with procedures developed by the laboratory and consistent wdth existing laws and regulations guvorning sample disposal. If for any reason unused \WORK\24231\02\QAPP.APP Harding Lawson Associates 301225 Section C3.0 Revision 0 March 17. 1994 Paee 6 of 6 sample portions cannot be disposed by the laboratory, these sample portions wdll be returned to the site to await final disposition. C3.3 Corrections to Documentation Original data recorded in field logbooks, chain-of-custody records and other forms wdll be written in waterproof ink. None of these documents wdll be altered, destroyed or discarded even if they are illegible or contain inaccuracies that require a replacement document. If an error is made on a document assigned to one individual, that individual wdll make the correction by drawing a single line through the error, entering the correct information and initialing and dating the change. The erroneous information wUl not be obliterated. Any additional error(s) discovered on a document wdll be corrected by the person who made the entry. All corrections wdll be initialed and dated by the author. C3.4 Final Evidence File Custody Procedures HLA is the custodian of the final project fUe and maintains the contents of project fUes. HLA will maintain the study area fUes along with relevant records, reports, logs, field logbooks, photographs, subcontractor reports and the data and data reviews of the laboratory data in a limited access secure area and under custody of the QA Manager. The final study area fUe wdU contain, but not be limited to, the foUowdng project data: '- Planning documents Field data records Field logbooks Sample tags Chain-of-custody forms Sample tracking records Copies of analytical logbook pages Bench sheets Instrument readout records Computer printouts Graphs Calculations Raw data summaries Data purge files Correspondence Data validation files and reports Progress reports Report notes Photographs, maps and drawings Final report \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 301226 Section C4.0 Revision 0 March 17, 1994 C4.0 Calibration Procedures and Frequency This section describes procedures for maintaining the accuracy of the instruments and measuring equipment that are used for conducting field tests and laboratory analyses. A variety of instruments, equipment and sampling tools wdll be used to collect data and samples and to monitor site conditions. Proper calibration, maintenance and use of instruments and equipment are imperative to ensure the quality of the data collected. A record of calibration and maintenance activities is important to provide legally defensible data. The Site Manager is responsible for proper calibration, maintenance and operation of field equipment. The laboratory QA officer is responsible for calibration and maintenance of laboratory instruments. C4.1 Inspection of Field Equipment Instruments and equipment purchased or used wdll be inspected to ensure that they conform to manufacturer's specifications. Equipment to be used during the field sampling activities wdll be examined to certify that it is in satisfactory operating condition. This examination includes checking the manufacturer's operating manual and instructions for each instrument to ensure that maintenance requirements are observed. Field notes from previous sampling activities wdll be reviewed so that the notes regarding previous equipment problems, if any, are not overlooked and necessary repairs to equipment have been performed, instruments meeting these requirements wdll be given a serialized number and made avaUable for project use. Instruments and equipment not meeting project requirements are labeled as such and are wdthheld from project use untU they are modified or repaired to meet project requirements. C4.2 Field Equipment Calibration Instruments and eqiupment used to gather, generate or measure environmental data wUl be caUbrated wdth sufficient frequency and in such a manner that accuracy and reproducibUity of results are consistent wdth the manufacturer's specifications. Each item of equipment used in field activities wdll be calibrated at a frequency specified by the owmer/operator manuals provided by the manufacturer. The operating instructions for each piece of equipment contains, at a minimum, the following information: Equipment identification number and serial number HLA inventory number CaUbration schedule and frequency Equipment specifications .. Specification verification (where applicable) Equipment necessary to accomplish calibration Procedure for caUbration Equipment calibration is recorded daUy or as required by the calibration schedule by HLA field persormel in bound field logbooks. Information to be recorded includes the following: • Date of calibration • Data pertaining to the calibration procedures \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301227 Section C4.0 Revision 0 March 17, 1994 • Initials of analyst performing calibration • Adjustments made to the equipment before and after calibration • Record of equipment faUure or inabUity to meet specifications If the calibration schedule is not adequately maintained or if accuracy as reported in the operations manual carmot be attained, that instrument wdll be unavaUable for use until it is repaired so that specifications are attained. The calibration, maintenance and operating procedures for instruments, equipment and sampling tools are documented in the owner/operator manuals supplied by the manufacturer. These manuals provide manufacturers' instructions and include specifications and criteria for calibration, maintenance and operation. A copy of the owmers' manuals supplied by the manufacturer wdll be kept with each instrument. General calibration requirements consistent wdth the manufacturers' owmer/operator manuals for field equipment to be used for field activities follow. C4.2.1 Organic Vapor Analysis The portable gas analyzers currently identified as being avaUable for onsite use during field operations are Thermo Environmental Instruments, Inc. OVM Model 580B photoionization detectors (PID). Equivalent instruments may also be used during the investigation. External standard calibration procedures specified in the factory-supplied instruction manual wdll be followed daily prior to the initiation of each day's field activities. These procedures include calibrating the instrument with an - appropriate calibration gas (e.g., isobutylene) in the concentration range expected to be used. The caUbration wdll be performed at ambient temperature and pressure. The instrument calibration wUl be checked daUy by using the internal caUbration mechanism. Specific procedures for instrument calibration are presented in the HASP for this project (Appendix BD). C4.2.2 Water-level Measurements The sounder wdll be checked against a steel surveyor's tape at the site. The graduated steel tape wdll have the manufacturer-supplied temperature correction applied if field conditions warrant. Pressure transducers used for water level measurements wdll be factory-calibrated once, caUbrated in- house wdth water columns before aquifer tests, checked weekly in the field against steel tape and against a sounder during use. C4.2.3 Water Temperature Temperature data are measured wdth a mercury thermometer. The thermometers wdll be inspected before use to ensure there is no mercury separation. The thermometers wdll be rechecked in the field before and after each use to see if the readings are logical and the mercury is stUl intact. The thermometers wdll be checked biarmuaUy for calibration, by immersing them in a water bath of knowm temperature until equUibrium is reached. Thermometers wdll be properly discarded if found to have more than 10 percent error. The reference thermometer used for the water bath calibration wUl \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301228 Section C4.0 Revision 0 March 17, 1994 be traceable to National Bureau of Standards (NBS) calibration thermometers. All temperature meters are calibrated weekly wdth a mercury thermometer. C4.2.4 pH Measurements The digital pH meter (Beckman Model 021 or equivalent) wdll be calibrated daUy wdth two standard buffer solutions before field measurements. Calibration procedures and frequency wdll be recorded in the field logbook along with the lot number of the buffer solutions. General procedures for caUbrating the digital pH meter are described below: 1. Connect pH electrode to pH meter and turn on the pH meter. 2. Measure temperature of buffer solution. 3. Adjust the temperature setting on the basis of the buffer temperature, then place the electrode in the first buffer solution. 4. Set the span or slope adjustment to display correct value after the reading has been stabiUzed. 5. Rinse electiode in distUled water and repeat this procedure for the second buffer solution. 6. Place pH electrode in the sample and record the pH measurement displayed. 7. Remove pH electrode from sample and rinse with distUled water. 8. Re-calibrate the pH meter every time it is turned off and turned back on or if it exhibits erratic results. The calibrations performed, standards used and sample pH values measured are recorded in the field logbook and sampUng forms, as appropriate. New batteries wdU be purchased and kept wdth the meters to facUitate immediate replacement in the field as necessary. C4.2.5 Specific Conductance The conductivity ceUs of the specific conductivity meter (YSI Inc. Model 33 S-C-T or equivalent) will be cleaned and checked daUy against known conductivity standards before use. The calibration procedure follows: 1. Place the probe in conductivity calibration standard solution. 2. Set temperature knob to the temperature of the standard solution. 3. Turn to the appropriate scale and set the instrument for the caUbration standard value including zeroing and red-lining the instrument as described in the manufacturer's set-up and operations procedures. 4. Rinse the conductivity electrode wdth distilled water. 5. Measure the conductivity of distUled water, ensuring the temperature is set correctly for the temperature of the sample to be measured. Sample readings and calibrations wdU be recorded in the field logbook and sampling forms as appropriate. C4.3 Laboratory Instrument Calibration Calibration of laboratory equipment wiU be performed on the basis of method-specific procedures. Records of calibration, repairs or replacement will be fUed and maintained by the designated \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301229 # Section C4.0 Revision 0 March 17. 1994 laboratory persormel performing QC activities. These records wdll be filed at the location where the work is performed and may be subject to a QA audit. For instruments, the laboratory wdll maintain a factory-trained repair staff wdth in-house spare parts or wdll maintain service contracts with equipment vendors. The calibration records wdU be maintained as follows: • If possible, each instrument wdU have a calibration record permanently affixed to it wdth an assigned record number. • A label wiU be affixed to each instrument showing description, manufacturer, model numbers, date of last calibration, calibrator's signature and due date of next calibration. Reports and compensation or correction figures wdll be maintained wdth the instrument. • Written step-wise calibration procedures wUl be avaUable for each measurement instrument. • Any instrument that is not caUbrated to the manufacturer's original specifications wdU display a warning tag to alert the analyst that the instrument has only a limited calibration. The caUbration procedures and frequency of calibration for laboratory equipment used for sample analysis wdll be consistent wdth CLP Routine Analytical Services (RAS) protocol as specified in the current CLP SQWs for organic and inorgaruc analyses. Calibration procedures and frequency of caUbration for laboratory equipment used for non-CLP sample analyses are discussed in appropriate laboratory method SOPs. C4.3.1 Organic Analyses Before calibration, the instrument(s) used for gas chromatography/mass spectrometry (GC/MS) analyses are tuned by analysis of p-bromofluorobenzene for VOC analyses and decafluorotriphenyl phosphine for semi-volatUe organic compound (SVO) analyses. The instrument tune wdll be verified every 12 hours of operation. Once the tuning criteria for these reference compounds are met, the instrument is initiaUy caUbrated by using a five-point caUbration curve. Continuing calibration is verified every 12 hours of operation. The caUbration standards wdll be fraceable to USEPA or NBS standards and are spiked wdth internal standards and surrogate compounds. CaUbration and continuing calibration verification of instruments wdll be performed at approved intervals as specified by the manufacturer or the analytical method (whichever is more frequent). C4.3.2 inorganics Analyses The Atomic Absorption Spectrophotometer and Inductively Coupled Plasma (ICP) Emission Spectrophotometer instruments are initially calibrated by use of a minimum of three calibration standards prepared by dUution of certified standard stock solutions. An analysis blank is prepared wdth one calibration standard at the quantitation l;.-nit for the metal. The other standards bracket the concentration range of the samples. CaUbration standards wdll contain acids at the same concentration as the digested samples. A continuing caUbration standard, prepared from a (iifferent stock solution that is used for preparation of the initial calibration standards, is prepared and analyzed after every 10 samples or every 2 hours of \WORiC\24231\02\QAPPJVPP Harding Lawson Associates 301230 -rt» # Section C4.0 Revision 0 March 17, 1994 continuous instrument operation. The continuing calibration standard concentrations must agree wdthin 10 percent of the initial calibration value or the appropriate corrective action is taken. Corrective action' may include re-calibrating the instrument and reanalyzing the previous 10 samples. For the ICP, linearity near the lower quantitation limit wdll be verified wdth a blank. This blank must be run at the beginning and end of each sample analysis sequence or a minimum of twice per 8-hour period of instrument operation. C4.3.3 Non-Contract Laboratory Program Analyses -a m Currently, the orUy non-CLP analyses to be performed wdll be analysis of water and soU samples for pyridine. The laboratory wdll develop a specific methodology for these analyses prior to project startup. Analytical accuracy for pyridine wdll be evaluated in relation to method vaUdation/startup QC control criteria. \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301231 Section C4.0 Revision 0 March 17, 1994 Table C4-1. Summary of Laboratory Data to be Collected During Remedial Investigation Activities Island Chemical Company Site St. Croix, U.S, Virgin Islands Sample Matrix Groundwater sample collection and analysis SoU sample collection and analysis VOCs CLP CLP Semi-VOCs Inorganics CLP CLP CLP CLP Pyridine NCLP NCLP CLP Confract Laboratory Program NCLP Non-Contract Laboratory Program (Analytical methodology to be developed by laboratory prior to implementation of sampling program # \WORK\24231\02\QAPP.TAB Harding Lawson Associates 301232 ^M Section C5.0 Revision 0 March 17, 1994 C5.0 ANALYTICAL METHODS AND PROCEDURES The analytical methods and procedures include a description of field and analytical parameters, method reporting limit requirements, QA/QC procedures for laboratory and field analyses and laboratory deliverables. Samples wiU be analyzed by USEPA-CLP laboratories as noted in the FSP. The intent is to have measurements required for plume definition be performed at a CLP laboratory using CLP protocol. Other analyses conducted for treatabUity, permitting and/or geotechnical purposes not requiring CLP protocol wdll also be performed at CLP laboratories, when feasible. C5.1 Non-Contract Laboratory Program Analytical Methods Non-CLP analytical methods have been selected for analyses of environmental media. These methods and associated parameters are discussed in Section C5.4 of this QAPP. C5.2 Field Screening Analytical Procedures The procedures for field measurement of pH, specific conductivity, temperature and relative VOC concentration are provided in the FSP. C5.3 Quality Assurance/Quality Control Procedures for Field Analyses HLA's Site Manager wdU be responsible for QA/QC procedures for field analyses. Field QA/QC analyses wdll include calibrating field measurement instruments and equipment and comparing data to previous measurements obtained at the specific location. Variations in field data measurements, greater than those specified by the manufacturer of the equipment, at a specific location wdll be examined to evaluate whether general frends may be developing. Variations in data that cannot be explained wdU be assigned a lower level of confidence and wdll be used for limited purposes. A variety of instruments, equipment and sampling tools wdll be used to collect data and samples and to monitor site conditions. Proper caUbration, maintenance and use of instruments and equipment are required to ensure the quality of data collected in the field. Equipment and instrument calibration, maintenance and operational procedures are described in detail in Section C4.0 of this QAPP. The QC objective of these data collection activities is to obtain reproducible and comparable measurements to a degree of accuracy consistent wdth the intended use of the data. The QC objectives wdll be accomplished through the use of documented standard procedures. The procedures for performing these activities and the standardized formats for documenting them are presented in the FSP. C5.4 Laboratory Analytical Parameters and Metliods Laboratory analytical parameters and methods are summarized in Tables Cl-2, Cl-3 and C4-1. \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301233 Section C5.0 Revision 0 March 17, 1994 C5.5 Method Reporting Limit Requirements Method reporting limits (MRL) for analytical data wdll be consistent wdth the objective of the investigation and the intended use of the data. The MRLs are reported in Tables Cl-4 through Cl-7 (see Section Cl.O). Contract required quantitation limits and MRLs for target analytes may be sample-specific for samples with complex matrices (i.e., samples containing one or more analytes at wddely varying concentrations). In this case, detection limits for certain samples wdll increase when a sample has to be dUuted to provide on-scale instrument response for high-concentration analytes. However, target analytes not requiring dUution wdll be analyzed accordingly and analytical results wdll be included in the laboratory deliverables. For samples requiring lower detection limits, the dUuted samples wUl be reanalyzed by the laboratory upon approval of HLA's QA review officer. Samples that require lower detection limits, if any, wdll be identified before analyses, if possible, and the laboratory wdU be notified in this event. C5.6 Laboratory Quality Assurance/Quality Control Procedures Analytical QA/QC for laboratory testing wdll be based on (1) CLP RAS requirements as stated in the current CLP SOW and (2) the laboratory's specific QA/QC procedures. Laboratory precision and accuracy wdll be evaluated on the basis of CLP-required system checks and results of required laboratory QA/QC samples infroduced into the sample analysis stream. The types and frequency of required system checks and laboratory QA/QC samples are provided in the CLP SOWs, SOPs and SAMLC. As listed in the SOW requirements, any non-CLP laboratories if used, wdll be amenable to ' analysis of performance evaluation samples submitted by USEPA for QA purposes. In addition to the laboratory QA/QC described above, project QA/QC checks wdll be used to quantitatively and qualitatively evaluate the analytical performance of the laboratory. QA/QC samples wdll also be used qualitatively to assess external effects on the accuracy and comparabUity of the reported results. Project QA/QC checks wdll consist of confrolled samples from the field. Project QA/QC samples wdll consist of rinse and trip blanks, field duplicates and MS/MSDs. Field duplicates and MS/MSDs wdll be designated in the field before analysis by the laboratory. \WORiC\24231 \02\QAPP.APP Harding Lawson Associates 301234 Section C6.0 Revision 0 March 17, 1994 C6.0 INTERNAL QUALITY CONTROL PROCEDURES QC procedures are designed to ensure and document data quality. Field and laboratory QC checks wdll be used to evaluate the laboratory's analytical procedures. Key project QA/QC persormel are identified on the Approval Form located at the beginning of this QAPP. Resumes of key QA/QC persormel are included in Appendix CA. C6.1 Field Quality Control Sample Collection QC samples wdll be collected in the field and submitted to the laboratory wdth the investigative samples. Three types of QC samples wUl be collected: blanks (rinse blanks and trip blanks), MS/MSDs and field duplicates. The QC samples wdll be used to assess the field sampling program data quality and the laboratory analytical data quality and are described in Section Cl.O of this QAPP. Field blanks wdll be collected at a rate of 10 percent for non-aqueous samples and one field blank per day for aqueous samples. Duplicates wdll be collected at a frequency of 1 per 20 investigative samples of each matrix. The levels and types of project QC check samples that wdll be infroduced into the analytical program are described below. C6.1.1 Water and Soil Samples The followdng project QC check samples wdll be submitted for analysis to ensure and document water and soU data quality for samples coUected from borings and monitoring wells: • Rinse blank for Target Compound List (TCL) organics. Target Analyte List (TAL) inorganics and pyridine • Trip blank for VOCs only • Field duplicate for TCL organics, TAL inorganics and pyridine • MS for TCL organics, TAL inorganics only • MSD for TCL orgarucs orUy Rinse blanks wdll not be collected if the sample is collected directly into the container. The frequency of QC sample coUection was previously presented in Tables Cl-2 and Cl-3 (see Section Cl.O). C6.2 Field Measurement Quality Control Procedures Field measurement QC procedures for pH, conductivity and temperature measurements are limited to checking the reproducibiUty of the measurement (1) hy obtaining multiple readings on a single sample or standard and (2) by calibrating the instrumnnis. Field measurement procedures are described in the FSP (Appendix B). C6.3 Laboratory Quality Control Procedures Laboratory QC checks (for CLP procedures) rpprtrscnt internal system checks and controlled samples introduced by the laboratory into the sample analysis stream. These procedures are used to validate the data and calculate the accuracy and precision of the chemical analysis program. The level of QC \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301235 Section CS.O Revision 0 March 17, 1994 effort provided by the laboratory wUl be equivalent to the level of QC effort specified in the CLP RAS methods. The level of QC effort for inorganics testing (metals and cyanide) wdll conform to the protocols of the SOW (3/90; mMOl.O). The levels of QC effort for TCL organics testing (VOCs, SVOCs, Pesticides and PCBs) wdU conform to the protocols of the SOW (3/90; OLMOl.O) or the Superfund Analytical Method Low Concentration Water for Orgaruc Analysis (SAMLC, 6/91), as appropriate. The QC level wdll meet the criteria in the CLP SOWs or appropriate SOPs or the SAMLC. These specifications include the types of QC checks required (method blanks, reagent/preparation blanks, MS/MSDs, calibration standards, internal standards, surrogate standards, the frequency of each QC analysis, specific caUbration check standards and laboratory duplicate/replicate analysis), compounds and concentrations to be used and the QC acceptance criteria. Laboratory system checks and QA/QC samples are required by the current CLP SOWs and are defined below. C6.3.1 Laboratory Quality Assurance Program The selected laboratory wdll have a •ivritten QA/QC program that provides rules and guidelines to ensure the reliabUity and validity of work conducted at the laboratory. Compliance wdth the Q.-VQC program is coordinated and monitored by the laboratory Quality Assurance Unit (QAU), which is independent of the operating departments. The stated objectives of the laboratory QA/QC are intended to: Ensure that procedures are documented, including any changes in administrative and/or techrucal procedures. Ensure that analytical procedures are conducted according to sound scientific principles and have been vaUdated. Monitor the performance of the laboratory by a systematic inspection program and provid-- !nr corrective action, as necessary. Collaborate with other laboratories in establishing quality levels, as appropriate. Ensure that data are properly recorded and archived. Laboratory procedures are documented in writing as either SOPs or Method Procedures, which .ir- edited and controUed by the laboratory QAU. Internal QC procedures for analytical services \N -.11 : •• conducted by the laboratory in accordance wdth their SOPs. Laboratory QC checks wdll be performed and samples wdll be analyzed at a frequency establish-,: ;.-. the appropriate CLP SOWs (or SAMLC) for organics and inorgarucs and by the SOPs for non-C^I.i' samples. C6.3.2 Organic Analysis The following QC samples are analyzed along wdth samples that are analyzed for organic com;:( ..:-. :•< • Initial Calibration - analysis of analytical standards for a series of different specified concentrations; used to define the linearity and dynamic range of the response of the ()(. r GC/MS to the target compounds. \WORIC\24231\02\QAPP.APP Harding Lawson Assoctatos 301236 Section C6.0 Revision 0 March 17, 1994 • Continuing Calibration - analytical standard run frequently to verify the calibration of the GC or GC/MS system. • Method Blank - an analytical control consisting of all applicable reagents, internal standards and surrogate standards carried through the entire analytical procedure. The method blank is used to define the level of laboratory background contamination. • Internal Standards - compounds added to every standard, blank, duplicate, MS, MSD, sample (for volatUe organic analysis) and sample extract (for SVOs), at a known concentration, before analysis. Internal standards are used as the basis for quantitation of the orgaruc target compounds. • Surrogates - organic compounds added to every blank, sample, duplicate, MS, MSD and standard; used to evaluate analytical efficiency by measuring recovery. Surrogates are brominated, fluorinated or isotopically labeled compounds not expected to be detected in environmental media. C6.3.3 Inorganic Anaiysis The following QC samples are analyzed along with samples that are analyzed for inorganic parameters: • CaUbration Blank - a volume of acidified deioiuzed and/or distUled water. • Continuing Calibration - analj^ical standard run every 10 analj^ical samples or every two hours, whichever is more frequent, to verify the calibration of the analytical system. • Instrument CaUbration - analysis of analytical standards for a series of different specified concentrations; used to define the quantitative response, linearity and dynamic range of the insfrument to target compounds. • Preparation Blank - an analytical control that contains distUled and/or deionized water and reagents, carried through the entire analj^ical procedure (digested and analyzed). An aqueous method blank is treated with the same reagents as a sample wdth a water matrix; a solid method blank is freated with the same reagents as a soU sample. • Laboratory DupUcate - a second aliquot of a sample, which is prepared and analyzed using the same procedures as the original sample, to evaluate method precision. • Interference Check Sample - consists of two solutions: Solution A and Solution AB. Solution A consists of the interferer and Solution AB consists of the analytes mixed with the interferer. The solutions are analyzed consecutively to verify inter-element and background correction factors. • Inter-element Correction Factors - values determined to correct for spectral interference caused by aluminum, calcium, iron and magnesium for ICP instruments at wavelengths used for each analyte. C6.3.4 Miscellaneous Analyses The followdng QC samples are analyzed, where appropriate, wdth samples for miscellaneous analyses. • Calibration Blank - a volume of distilled water containing the same reagents as the other calibration standards. • Continuing Calibration - analytical standard run every 10 analytical samples to verUy the calibration of the analytical system. \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301237 Section C6.0 Revision 0 March 17, 1994 Instrument Calibration - analysis of analytical standards for a series of different specified concentrations; used to define the quantitative response, linearity and dynamic range of the instrument to target compounds. Preparation Blank - an analytical control that contains distUled and/or deionized water and reagents, carried through the entire analytical procedure (digested and analyzed). An aqueous method blank is treated wdth the same reagents as a sample wdth a water matrix; a soUd method blank is treated wdth the same reagents as a soil sample. Laboratory Duplicate - a second aliquot of a sample that is prepared and analyzed using the same procedures as the original sample to evaluate method precision. \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 3 01238 C7.0 DATA VALIDATION, REDUCTION AND REPORTING Section C7.0 Revision 0 March 17, 1994 Data collected during implementation of the Work Plan wdll be managed, distributed and preserved to substantiate and document that data are of knowm quality and are properly maintained. Laboratory sample analyses wdU be tracked and validated to monitor performance. C7.1 Data Validation C7.1.1 Field Measurement Data Validation Procedures Field measurement data validation procedures include reviewdng the raw data and supportive docu- mentation generated from field investigations and wdll include, but not be limited to, the foUowing: Field logbooks Field investigation daUy reports Field instrument readings and calibration data sheets Field weU completion data Field boring logs WeU test data Groundwater sampling forms Sample tags Chain-of-custody forms Sample tracking records Elevation survey information Maps Validation of field data wdll be performed by HLA's QA Manager or designated representative. Data validation wdll be performed to meet the project's intended data uses by checking the procedures used in the field and comparing the data to previous measurements. The followdng areas wdU be addressed during validation: Sampling methodology Sample technical holding times and preservation Instrument selection and use Instrument caUbration and standardization Instrument preventative maintenance Field deviations Sampling limitations Field measurements that could affect the quality of the data (such as temperature, pH, conductivity, water level) wiU also be validated. Additional evaluations of data integrity, including those for non-CLP procedures, wdll be performed on 10 percent of the data, including the foUowing: • Review chain-of-custody forms. • Review the appropriateness of field methodologies. \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301239 Section C7.0 Revision 0 March 17, 1994 • Review data for transcription, calculation, completeness and accuracy. • Analyze field notes to evaluate possible bias. C7.1.2 Analytical Data Validation For parameters noted in the FSP, a C U laboratory wdU be selected to perform chemical analyses to ensure that laboratory QC and data packages comply wdth CLP guidelines and are completed within reasonable turnaround times. Laboratory validation of samples analyzed by methods under the CLP RAS wdll be performed in a marmer consistent with USEPA Functional Guidelines for Evaluating Organic and Inorganic Analyses (USEPA, 1988b; USEPA, 1988c). VaUdation of samples analyzed by non-CLP methods wdll be consistent wdth USEPA functional guidelines and/or method-specific SOPs. C7.1.2.1 Laboratory Data Validation Procedures Under the direction of the Laboratory QA Officer, the laboratory wdll review analytical data to ensure that results for investigative and QC samples meet CLP-specified criteria and USEPA Region U SOP Nos. Hazardous Waste Division memoranda 2 and 6 (January 1992). The following analytical data wdll be checked during the laboratory validation process: Sample technical holding times GC/MS tuning Calibration Irutial Continuing Blank results Surrogate recovery MS/MSD results Internal standards performance TCL compound identification Compound quantitation and reported detection limits Tentatively identified compound identification System performance OveraU data assessment The laboratory wdU perform analytical data reduction and in-house validation under the direction of the Laboratory QA Officer. The Laboratory Q.\ Officer wdll be responsible for assessing data quality and advising appropriate laboratory Section Suporvisors and HLA's QA Manager of any data that are rated "unacceptable" or have notations that would c:aution the data user to possible unreliabUity. Data reduction, validation and reporting by the labora;:;ry will be conducted as follows: 1. Raw data produced by the analyst will bo turned over to the respective Section Supervisor. 2. The Section Supervisor wdll review tho d.ir.i ;o ensure it has met QC criteria as outlined in CLP protocol and established USEPA mfrthcxis. 3. Upon acceptance of the raw data by the ,S.t iion Supervisor, a computerized report wUl be generated and sent to the Laboratory QA Officer. \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301240 Section C7.0 Revision 0 March 17, 1994 4. The Laboratory QA Officer wUl complete a thorough audit of the computerized reports at a frequency of 1 in 10 and audit every report for consistency. 5. The Laboratory QA Officer and Section Supervisor wdll decide whether any sample re-analysis is required. 6. Upon acceptance of the preliminary reports by the Laboratory QA Officer, final reports wdll be generated and signed by the Laboratory Director. The laboratory package wdll be presented to HIA in the sequence in which the samples were analyzed. The Laboratory QA Officer wdll evaluate the laboratory report package. These evaluations will consider the finished data sheets, calculation sheets, document control forms, blank data, dupUcate data and recovery data for mafrix and surrogate spikes. The material wdU be checked for legibUity, completeness, correctness and the presence of necessary dates, initials and signatures. The results of these checks wdll be assessed and reported to the HLA Project Manager and HLA QA Manager, noting any discrepancies and their effect on acceptabUity of the data. C7.1.2.2 Harding Lawson Associates Data Validation Procedures A description of the vaUdation steps that wdll be used by HLA's QA Manager or representative to independently vaUdate the laboratory data is provided in this-section. Consistent wdth USEPA Functional Guidelines, all sample cases wdll be vaUdated. The validation steps follow: 1. CompUe a Ust of investigative samples. 2. CompUe a list of QC samples, including the following: Rinse blanks Trip blanks Laboratory blanks Blind field dupUcate samples (replicated or co-located samples) Laboratory replicates MS/MSDs Review laboratory analytical procedures and instrument performance criteria as follows organic and inorgaruc analyses: Organic Analysis Sample technical holding time GC/MS instrument caUbration and performance GC/MS tuning and performance Blanks Surrogate recovery MS/MSD recovery Compound identification and quantitation System performance OveraU data assessment \WORIC\24231\02\QAPPJVPP Harding Lawson Associates 301241 Section C7.0 Revision 0 March 17, 1994 Inorgaruc Analysis Sample technical holding time Instrument calibration Blanks Interference check sample analysis Laboratory control sample analysis Mafrix spike recovery Laboratory replicates Quarterly verUication of instrument parameter report Overall data assessment 4. Evaluate the integrity of the data as follows: • Review chain-of-custody forms for completeness and correctness. • Review data for transcription, calculation, completeness and accuracy. • Review laboratory analytical procedures, appropriateness and instrument performance criteria. • 5. Prepare a data summary that includes the followdng:- Results Sample media identification Sample location and descriptions Appropriate concentiation units Appropriate significant figures Data qualifiers Defirutions 6. Review the data summary for potential data quaUty problems, including the following: • Unexpected results • Common laboratory contaminants • Field-induced contaminants • Unusual spatial concentration/identification relationships • Unexpected compound or parameter relationships • Samples in which dUution was necessary • Samples that may have been contaminated wdth carryover from the previous sample analyzed • Missed technical holding times Laboratory records and data package requirements wUl be checked to assess completeness of the data package. The validation effort wdll be performed by persormel qualified and experienced in laboratory data validation. The laboratory data validation and QA review summary wdll be provided as an appendix to the final report. \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301242 Section C7.0 Revision 0 March 17, 1994 Despite all efforts to achieve the objectives of the project, the potential for error exists in the laboratory chemical analyses and the data reporting process. Every reasonable effort wdll be made to compare and double-check data reported from the laboratory and data managed during the process. C7.1.3 Data Qualifiers Data qualifiers and definitions, consistent wdth CLP SOWs, method-specific SOPs and/or USEPA functional guidelines, wdll be used where appropriate in validation. Data qualifiers wdll be attached to the tabulated data to indicate the data quality according to intended data use. The qualUiers wdll be attached to the data whenever they appear in hard copy or computerized form to ensure that data users are aware of limitations and quaUty of the data. Upon completion of data validation, summary reports wdll be placed in the fUe along with qualified analytical result summary forms. C7.2 Data Reduction Reduction of analytical data wdll be performed in accordance wdth validation procedures described above. These procedures specify the documentation needed and the technical criteria required to validate the data. Data quality and utUity depends on many factors, including sampling methods, sampling preparation, analytical methods, QC and documentation. 7.2.1 Field Measurement Data Reduction Procedures Reduction of field measurement data wdll be performed in accordance wdth validation procedures described previously in Section C7.1. Validity of data wdll be evaluated by checking caUbration procedures used in the field and by comparing the data to previous measurements obtained at the site. The Site Manager wiU summarize the data obtained from field measurements and wUl include this information in the field activities documentation report, which will be submitted to the QA Manager and the Project Manager for review, independent data entry checks wdll be performed and computerized data storage wdll be routinely checked to verify accurate retrieval of data. To evaluate the field measurement data supporting the analytical data, the followdng items wUl be documented: Sampling date and time SampUng team, sampling observer and recorder and sampling crew leader Sampling location Physical description of sampling location ' Sample coUection technique Field preparation techniques (e.g., sample fUtration) Visual classification of sample using an accepted classification system (if applicable) A thorough description of the methodology used and a rationale for the use of that methodology Complete documentation of record keeping practices Field logbooks and all custody documents stored in a secure repository or under the control of a document custodian All forms completed in indelible ink wdthout alterations, except as initialed \WORK\24231 \02\QAPP.APP Harding Lawson Associates 301243 Section C7.0 Revision 0 March 17, 1994 C7.2.2 Laboratory Analytical Data Reduction Procedures The selected laboratory wdll perform in-house analytical data reduction under the dfrection of the Laboratory QA Officer. The Laboratory QA Officer is responsible for assessing data quality and advising of any data that were rated "preliminary" or "unacceptable" or other notations that would caution the data user of possible unreUabUity. Data reduction wdll be conducted as follows: 1. Raw data produced by the analyst is submitted to the respective area supervisor. 2. The area supervisor reviews the data (1) for attainment of QC criteria as outlined in CLP protocols and/or established USEPA methods and (2) for overall reasonableness. 3. Upon acceptance of the raw data by the area supervisor, a computerized report is generated and sent to the Laboratory QA Officer. 4. The Laboratory QA Officer wUl complete (1) a thorough audit of reports at a frequency of 1 in 10 and (2) an audit of every report for consistency. 5. The QA Officer and area supervisors wdll decide whether any sample re-analysis is requfred. 6. Upon acceptance of the preliminary reports by the QA Officer, final reports wdll be generated and signed by the Laboratory Project Manager. The laboratory package shall be presented in the same order in which the samples were analyzed. Data reduction reporting procedures wdll be those specified in the CLP SOWs for inorgaruc and organic analyses. The laboratory wdll prepare and retain full analytical and QC documentation simUar to that requfred by the CLP. Such retained documentation need not be hard (paper) copy but may be in other storage media (e.g., magnetic tape). As needed, the laboratory wdll supply the hard copy of the retained information. Data reduction procedures for non-CLP methods wdll be performed in accordance wdth method-specific SOPs. 7.2.3 Harding Lawson Associates Analytical Data Reduction Procedures When field measurements and chemical data are validated and assembled, these data are further evaluated wdth respect to PARCC parameters. The definitions of these parameters were presented in Section Cl.O and are repeated here for convenience. Precision - a measure of mutual agreement among individual measurements of the same property, usuaUy under prescribed simUar conditions, usually expressed in terms of the relative percent difference. Accuracy - the degree of agreement of a measurement vvith an accepted reference or frue value. Representative - the selection of analytical methods, sampling protocols and saple locations such that results are representative of the media being sampled and the conditions being measured. Completeness - the amount of valid data obtained from a measurement system compared to the amount that was expected and needed to be obtained to meet the project data goals. ComparabUity - expresses the confidence wdth which one data set can be compared to another. \WORK\24231 \02\QAPP JVPP Harding Lawson Associates 301244 ~J m Section C7.0 Revision 0 March 17, 1994 Satisfaction of these criteria wdll be documented as follows. Chemical data must meet criteria of (1) quantitative statistical significance in relationship to the standard analytical methods employed and (2) satisfactory custody and document control. Field measurement criteria include (1) complete documentation of sampling location, time and persormel; (2) satisfactory documentation of field activities; and (3) correct sampling methodologies. To determine the quantitative statistical significance of chemical data, the followdng items wdll be documented, as appropriate: Laboratory/field instrumentation, including calibration data, standard methods and references Laboratory analysis methods, including reference methods Laboratory method detection limits Analysis of laboratory (reagent) blanks at a frequency of at least 1 per 20 samples Analysis of laboratory mafrix spikes at a frequency of at least 1 per 20 samples if the analyte is amenable to spiking. Analysis of field dupUcates at a frequency of at least 1 per 20 samples for each matrix Analysis of laboratory repUcates (duplicates or splits) at a frequency of at least 1 per 20 samples for inorganic analyses Presentation of tabulated QC data or QC charts and acceptance criteria QA/QC certification of the laboratory and/or participation in round-robin testing by USEPA- accredited agencies • QC limits consistent wdth USEPA's CLP limits To evaluate the custody and document control for samples and resiUts, the following items wdll be documented: Field custody noted in field logbook or chain-of-custody form Samples hand-delivered to the laboratory with a chain-of-custody form Laboratory custody documented by chain-of-custody form from either field personnel or shipper to the designated laboratory sample custodian Sample designation number(s) fraceable through entfre field moiutoring system Field logbooks and all custody documents stored in a secure repository or under the control of a document custodian All forms completed in indeUble mk without alterations except as irutialed Identity of sampler Date of sample coUection and shipping To determine sample representativeness, the following items must be checked: • ComparabUity between field and laboratory measurements or suitable explanation of discrepancy Analysis wdthin time limits suitable for "he [iroservation and analysis methods used Sample storage within suitable temporal ure. light and moisture conditions Proper sample containers used Proper sample collection equipment usi^i Proper decontamination procedures usi-d :;!r sample collection equipment Proper sample preservation techniques used \W0RIC\24231 \02\QAPP.APP Hardino Lawson Associates 301245 Section C7.0 Revision 0 March 17, 1994 • Proper laboratory preparation techniques used • Factors to determine bias screening evaluated • Sample site selection criteria must provide representativeness C7.3 Information Transfer Data structures for the project database wdll be implemented using electronic media compatible with commercially avaUable computer software. C7.4 Reporting Requirements and Document Control Appropriate documents wdU be prepared and distributed to summarize both field activities performed and the results of aU data collected. These reports, to the extent possible, wdll include the foUowing: • Presentation of results • Summaries of data from field measurements • Field location of sampling points In addition, USEPA wdU be provided copies of the followdng documents for each sampUng event within 180 calendar days of the last sample shipment to the laboratory of that event: • Field measurements and logbooks • Laboratory purge fUes, including, but not limited, to sample tags, chain-of-custody records, copies of sample fracking records, analysts' logbook pages, instrument logbook pages (including instrument conditions), bench sheets, instrument readout records, computer printouts, chromatographic charts, raw data summaries, correspondence and memoranda and document inventory • Data vaUdation reports summarizing the validation process used and specific comments pertaining to a sample or group of samples C7.4.1 Laboratory Deliverables The laboratory wdU provide data deUverables consistent wdth that requfred by the CLP SOW for organics (6/91) or (3/90; OLMOl.O). Laboratories performing analysis of non-CLP target paramett^rs wdU provide raw data deliverables appropriate to the method-specific SOPs. The deliverables will include, but not be limited to, the foUowdng, where appropriate: QC summary packages Sample data package Standards data package Irutial and continuing calibration raw data Raw QC data Blank data MS/MSD data Additional performance criteria specific to analjrtical methods (e.g., pesticide evaluation standards individual standards and quantitation standards) \WORK\24231 \02\QAPP.APP Harding l.awson Associatoo 301246 Section C7.0 Revision 0 March 17, 1994 In addition, the followdng information wdll be included wdth the data deliverables, where appropriate: Case narrative Chain of custody or simUar documentation Copies of sample tracking records Analysis logbook pages Instnmient logbook pages Bench sheets Instrument readout records Computer printouts Chromatographic charts Raw data summaries Correspondence or memoranda C7.5 Reconciliation With Data Quality Objectives Insert language liere la describe liow the res^ults obtaiaed will fae ti$ad to compare -with DQOs stated earlier. Describe how issues wiU be x^olved. and how lixxatations on £he use of ths data will be hanrBed. Refer to section that identifies procedures to assessjpjrecision, acciryacy and compieteoess^ \WORK\24231 \02\QAPP JVPP Harding Lawson Associates 301247 at Section C8.0 Revision 0 March 17, 1994 C8.0 PERFORMANCE AND SYSTEMS AUDITS Field and laboratory audits are used to quantitatively evaluate the accuracy of the total measurement system. These audits will also verify that sampling and analysis activities are performed in accordance wdth the procedures established in the FSP and this QAPP. HLA's QA Manager wdll monitor and audit the performance of the field and laboratory activities. Information produced or obtained during the course of this investigation is subject to audit. As such, the information must be reliable, gathered wdth appropriate attention to detaU and maintained with integrity. The documentation may take any of several forms, including a field notebook, photographs, computer tape or a sample identification tag. C8.1 Field Audits The HLA QA Manager or designated representative wdll audit field activities to evaluate sample identification, sample control, chain-of-custody procedures, field documentation sampling operations, handling and packaging procedures. Persons conducting the audits in addition to the QA Manager wdll be seruor technical reviewers who are famiUar with the techrucal and procedural requfrements of field sampling. The field audits wdll not be announced to the field team before they occur. If problems are encountered during the audits, the frequency of the audits wdll be increased. The audits wdU include performance audits for each measurement parameter, including performance audits for all measurement systems. Follow-up audits wdll be conducted to correct deficiencies and to verify that QA procedures are maintained throughout the project. Following the audit, preliminary results wdll be reviewed wdth the person in charge of the sampling. The field audit wdll provide information to allow examination of the followdng field documents: sample labels, chain-of-custody records and field logbooks. In addition, external field audits may be conducted by USEPA Region U. C8.1.1 Sample Labels The auditor wdll examine a selected number of sample labels for completeness and accuracy and wdll determine whether the information identified in Section C3.1.2.1 of this QAPP is included on the label. The auditor wdll also determine whether the sampling methods used were as described in the USEPA- approved FSP. 8.1.2 Chain-of-Custody Records The auditor wiU select a predetemained number of the chain-of-custody records to be audited in the field. The records wdU be reviewed to determine whether (1) the station number, station description, date and time correspond to the sample label, (2) the parameters to be analyzed have been properly identified and (3) custody transfers have been documented and the date and time of transfer have been recorded. The auditor wUl also determine whether samples have been kept in custody at all times and have been properly and securely stored. C8.1.3 Field Logbooks Field logbooks wdll be reviewed during the field audit to determine whether each is signed and whether entries are dated. During field activities, notebooks wdll be kept in the possession of the \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 301248 Section C8.0 Revision 0 March 17, 1994 sampling team leader. The project number, site name, date of receipt and name of the person using the book wdll be recorded on each page. In situ measurements and field observations wdll be recorded in the notebooks with pertinent information necessary to explain and reconstruct sampling operations. Each page wdll be dated and signed by the individuals making entries on that page. The Site Manager and the field team on duty wdll be responsible for ensuring that the notebooks are avaUable during moiutoring activities and that they are safely stored at the end of each day's sampling activities and after the final day of field activities to maintain security. Any lost, damaged or voided notebooks wdll be reported to the Site Manager. Notebook entries must be legible, written in ink and contain accurate and inclusive documentation of project activities. Language should be factual, objective and free of speculation and inappropriate terminology. Entries made by individuals other than the person to whom the notebook was assigned must be signed and dated by the individual making the entry. Photographs may be taken and must also be controlled. The auditor wdll review the field notebook to determine whether the photographs are properly docmnented. When slides or photographs are taken that show sampling sites or provide other documentation, they wdll be numbered to correspond to the notebook entries. The name of the photographer, date, time, site location and site description will be entered sequentiaUy in the notebook as photographs are taken. The Site Manager's logbook wdU docimaent the transfer of notebooks to the individuals who have been designated to perform specific field activities. Pertinent information wdll be recorded in these logbooks from the time each individual is assigned to the project untU the project is completed. The auditor wdll review field notebooks for adherence to these procedures. C8.1.4 Sampling Operations The auditor wdU review sampling operations to determine whether they are performed as stated in the FSP or as dfrected by the Site Manager. The auditor wdll determine that the proper number of samples were collected at the assigned locations and that the samples were placed in proper j containers and properly preserved. The auditor wdll also determine whether the requfred field measurements and QA checks have been performed and documented. C8.2 Laboratory Audits Laboratory audits may be performed by USEPA Region II (external audits) or HLA (internal audits) at thefr discretion. Laboratory audits are performed to verify continuity of personnel, insfrumentation and QC requfrements. A laboratory audit typically consist of random data audits and review of continuous trend analysis of laboratory QC data. The internal audits of the subcontractor laboratory wdll be conducted by the HLA QA Manager or designated representative. The laboratory system audits wdll include the examination of laboratory documentation on sample receipt, sample log-in, sample storage, chain-of-custody procedures, sample preparation, sample analysis and instrument operating records. \WORIC\24231\02\QAPPJVPP Harding Lawson Associates 301249 Section CS.O Revision 0 March 17, 1994 As part of the laboratory audit procedures, provisions may be made to provide USEPA or other regulatory agencies split or duplicate samples collected by HLA field representatives upon request by USEPA. USEPA wdll provide HLA with such requests at least 3 work days in advance of the dav that the samples are to be collected. Procedures for collecting split or duplicate samples are set forth in the FSP. C8.3 Document Control The document confrol audit wdll consist of checking each document for accountabUity. Documents used for field activities wdll be checked against the list of field documents issued to the Site Manager or designated representative. Written explanations wdll be provided for any unaccounted documents. The documents wdU be examined to determine whether requfred items such as signatures, dates and project codes are included. The auditor wdll examine controlled documents and wdU evaluate whether they have been handled and stored in the proper manner. After a project has been completed, the individual fUes wdll be either assembled, organized and securely stored or returned to the client. \WORIC\24231\02\QAPP.APP Harding lawson Associates 301250 Section C9.0 Revision 0 March 17, 1994 C9.0 PREVENTIVE MAINTENANCE PROCEDURES AND SCHEDULES Preventive maintenance wdll be performed on both field equipment and laboratory instruments. C9.1 Field Equipment The field equipment includes thermometers, pH meters, conductivity meters, water level meters. pumps and afr sampling equipment. SpecUic preventative maintenance procedures are those recommended by the manufacturer. Field instruments wUl be checked before they are brought to the site. These instruments wdll be checked and calibrated daUy before use. Calibration checks wdll be performed regularly and wdU be documented in the field logbooks. Critical spare parts such as tape, pH probes, electrodes and batteries wdll be kept onsite to minimi7.fi insfrument downtime. Backup insfruments and equipment should be avaUable.onsite or wdthin one- day shipment to avoid delays in the field schedule. Each piece of equipment used for field activities wdll be maiiitained to specifications recommended by the manufacturer. The Site Manager wUl be responsible for performing routine maintenance and will have tools and spare parts avaUable to conduct routine maintenance. Repafrs that cannot be performed by the Site Manager wdU be performed by a person certified or trained to repafr the instrument. Procedures set forth in the QAPP for maintaining instruments are consistent with manufacturers' operations manuals. Insfruments wUl be calibrated to proper specifications follovving maintenance to ensure proper completion of the maintenance procedure. A record of maintenance, including a description of specific activities performed, wdU be made in i.he field logbook. Data recorded in the logbook wdll be simUar to the data recorded for calibration. If the equipment or insfrument cannot be maintained to the manufacturer's specifications or if it cannot be properly calibrated, it wdU be returned to the manufacturer or other repafr facUity for pr;);)*?: maintenance and repafr. When it is returned from the manufacturer, the insfrument wUl be c h (-';«. cd for compUance to project specifications before being returned to routine field use. C9.2 Laboratory Instruments As part of thefr QA/QC program, a routine preventative maintenance program wdll be conduct-.-c r \ the laboratory to minimize the occurrence of instrument faUure and other system malfunctions Laboratory instruments wdll be maintained in accordance with manufacturer's specifications a.-.d :h»f requfrements of the specific method employed. This maintenance is performed on a regular, scheduled basis and is documented in the laboratory instrument service logbook for each insir-.-,••:•.: Emergency repafr or scheduled manufacturer's maintenance is provided under a repafr and maintenance contract wdth factory representatives. \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301251 Section ClO.O Revision 0 March 17, 1994 C10.0 QUALITY ASSURANCE/QUALITY CONTROL PROCEDURES FOR DATA ASSESSMENT This section summarizes QA/QC procedures for assessing the quality of the field and chemical data generated and the format for presenting the results of the Q/VQC evaluations in the appropriate progress reports. C10.1 Procedures for Assessing Field Data Precision and Accuracy The precision and accuracy of the field data measurements wdll be assessed by the HLA QA Manager or designated representative. The field measurements wdll be reviewed for compliance with the QC criteria outlined in the FSP. The precision of the field measurements wdll be assessed by checking the results of dupUcate instrument readings for a single sample. Field measurement accuracy wiU be assessed by reviewing daUy instrument calibrations, calibration checks and blank sample analyses. Field measurement completeness wUl be calculated as follows: C(%) = _V_ X 100% T where: C = Completeness of field measurements in percent V = Amount of vaUd data obtained T = Amount of vaUd data expected to be obtained under normal conditions C10.2 Procedures for Assessing Laboratory Data Precision, Accuracy, Completeness, Representativeness and Comparability Chemical data wdll be assessed for precision, accuracy and completeness for both the laboratory analytical program and field sample collection activities. The primary goal of the program is to ensure that the data generated are consistent wdth the DQOs presented in Section Cl.4. To meet this goal, a combination of quantitative procedures and qualitative evaluations wdll be used to check the data quality. However, the quantitative procedure results wdll not be used to eliminate data from the database. A quantitative assessment of precision, accuracy and completeness along wdth a qualitative assessment of representativeness wiU be documented in progress reports. The goals of this assessment wdll be (1) to establish site-specific PARCC parameters, (2) to use these parameters to develop a database wdth knowm limitations of data usabUity and (3) to evaluate these liirutations in achieving the program-intended data uses. The QA/QC assessment program wdU evaluate data on the basis of the types of project and laboratory QC check samples described in Section Cl.O. External QC samples used to quantitatively and qualita- tively evaluate the accuracy of liquid sample analyses wUl not be applied to evaluate the accuracy of soU samples because of the inherent differences in the sampling and analytical protocols. Because the QA/QC samples are generated for analysis both in the field and internally by the laboratories, a system of cross-checking has been established that provides independent evaluations of the chemical data on project and laboratory levels. This system of cross-checking is described under \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301252 SecUon ClO.O Revision 0 March 17. 1994 validation procedures in Section ClO.O of this document. Completeness wdll be assessed before preparing each appropriate report. The procedures for evaluating both the project and laboratory QA/QC data are the same and are presented below for QA/QC duplicate (co-located or replicate), blank and matrix spike samples. C l 0.2.1 Precision Evaluation Precision for sample data wdll be calculated by evaluating data from duplicate and MS/MSD QC samples. Procedures for calculating precision are described below. C l 0.2.1.1 Duplicate Samples The procedure for assessing field and laboratory duplicate samples follows: Tabulate dupUcate data and calculate the relative percent difference (RPD) as shown below for each duplicate pafr: RPD(%) = fXl - X2] X 100 (XI -h X2)/2 where: XI X2 dupUcate sample 1 concentration dupUcate sample 2 concentration C10.2.1.2 Matrix Spike Samples The procedure for assessing and tabulating matrix spike sample data and calculating the spiked sample recovery (SSR) percent for each sample is shown below: SSR(%) = fT-X1 X 100 A where: T X A Total concentiation in spiked sample Original concentiation in sample before spiking Actual spike concentration added to sample C l 0.2.2 Accuracy Evaluation Accuracy for sample data wdll be calculated by evaluating data from blanks and matrix spike QC samples. Procedures for calculating accuracy are described below for each QC saniple type. \WORK\24231 \02\QAPP JVPP Harding Lawson Associates 301253 # Section ClO.O Revision 0 March 17, 1994 C l 0.2.2.1 Blank Samples The blank evaluation procedure is a qualitative review of the chemical analysis data reported by the laboratories. The procedure for assessing blank samples follows: 1. Tabulate the blank sample data. 2. Identify any blank samples exhibiting detectable concentrations of target analytes in the sample. 3. If no target analytes are detected in any blank samples, the tables are ready for entry into the appropriate report. 4. If any chemicals are detected in blank samples, the compound(s) and concentration(s) will be reported and the field data for that period of time wdll be assessed for potential problems with data interpretation. No data wdll be removed from the database on the basis of target analytes being detected in blank samples. Appropriate notations, however, wdll be made in the databa:se reports. 5. Chemicals detected in blank samples wdll be flagged with the appropriate notation as described in USEPA's Laboratory Data Validation Functional Guidelines for Evaluating Inorganic Analyses (USEPA, 1988b) and Laboratory Data Validation Functional Guidelines for Evaluating Organic Analyses (USEPA, 1988c). C l 0.2.2.2 Matrix Spike Samples The procedure for assessing and tabulating matrix spUce sample data and calculating the SSR percent for each sample is shown below: SSR(%) = rT-X1 X 100 A where: T = Total concentiation in spiked sample X = Original concenfration in sample before spiking A = Actual spike concentration added to sample C l 0.2.3 Representativeness Evaluation Representativeness wdU be assessed by the analysis and interpretation of the results of an appropriately defined number of internal (laboratory) and external (field) QC samples. Precision and accuracy information developed from the evaluation of QC samples wdll be used to evaluate representativeness qualitatively. C l 0.2.4 Completeness Evaluation The completeness of the data represents the amount of validated data obtained from the field programs versus the amount of data expected under normal conditions. Overall completeness for the sample data collected wdll be calculated according to the following equation: \WORIC\24231 \02\QAPP JVPP Harding Lawson Associates 301254 Section ClO.O Revision 0 March 17, 1994 C(%) = _V_ X 100% T where: C V T Completeness of analytical effort in percent Amount of valid data obtained Amount of valid data expected to be obtained under normal conditions Completeness wdll be based on vaUdation as described in Section C7.0 of this QAPP. C l 0.2.5 Comparability Evaluation The comparabUity evaluation wdll include a qualitative assessment of analytical techniques. The comparabUity evaluation wdll include rounds of analytical results previously collected by other parties, as avaUable. The comparabUity of the analytical techniques wdll be assessed by referencing the anal34ical data reports submitted by the laboratory. Specific items to be evaluated include analytical method equivalency, detection limits, reporting uruts,. equivalent laboratory faciUties and personnel and laboratory QA procedures. The comparabUity evaluation wUl be included in the report. C l 0.2.6 Sensitivity Evaluation The achievement of the method detection limits depends on instrument sensitivity and possible matrix effects. Therefore, it is important to monitor instrument sensitivity by regular instrument checks. Instrument sensitivity wdll be monitored by analyzing method blanks and calibration check samples (orgaruc and inorgaruc analyses) and laboratory control samples (inorgaruc analyses). \WORIC\24231\02\QAPP.APP Harding Lawson Associates 301255 SecUon Cll.O Revision 0 March 17, 1994 Paqe 1 of 2 C l l . O CORRECTIVE ACTION PROCEDURES This section describes the field and laboratory corrective action procedures. It also addresses (1) predetermined limits for data acceptabUity beyond which corrective action is requfred, (2) project personnel responsible for irutiating the corrective action and (3) individuals responsible for approving corrective action, if necessary. C11.1 Field Situations The need for corrective action wdU be identified as a result of the field audits previously described. If problems become apparent that are identified as originating in the field, immediate corrective action wdll take place. If the sampling methodology needs to be modified to complete a task successfully, the modification wUl be documented in the log book. If immediate corrective action does not resolve the problem, appropriate personnel wdU be assigned to investigate and evaluate the cause of the problem. When a corrective action is implemented, the effectiveness of the action wdll be verified such that the end result is elimination of the problem. Field nonconformances and subsequent corrective action wdll be documented on the form provided in Appendix CB, noted in the field logbook and reported to the Project Manager. Copies of the forms wUl be included in reports and kept onsite for reference purposes. C11.2 Laboratory Situations The laboratories participating in the CLP are requfred to have a written SOPs specifying correcti\'j actions to be taken when an analytical error is discovered or the anal3rtical system is determined to be out of control. The SOP requfres documentation of the correction action and notification to the analyst of the error and correction procedures. The need for corrective action resulting from QA audits or HLA validation activities wdll be initi.itiMl hy the Laboratory QA Officer in consultation wdth HLA's QA Manager. Corrective actions may im i^d*?. but are not limited to: • Re-analyzing the samples, if holding time criteria permit. • Evaluating and amending sampling and analytical procedures. • Accepting data with an acknowledged level of uncertainty. • Re-sampling and analyzing, if the completeness of the data set or intended use of the •l.t'-i :s recognized during a preliminary review to be insufficient to meet program DQOs. If the above corrective actions are deemed unacceptable, a backup laboratory wdll be selected '.•.; perform necessary or appropriate verification analyses. C11.3 Immediate Corrective Action Any laboratory or field equipment malfunctions wdll requfre immediate corrective actions. rh<' laboratory QC charts are working tools that identUy appropriate immediate corrective actions • : <• taken when a control linut has been exceeded. They provide the framework for uniform acu.r.s .is part of normal operating procedures. The actions taken should be noted in field or laborator\ logbooks, but no other formal documentation is requfred unless further corrective action is n-< i-ss.i.'\ \WORK\24231\02\QAPP.APP Harding Lawson Associates 301256 Section Cll.O Revision 0 March 17. 1994 These on-the-spot corrective actions wUl be applied daUy, as necessary. A detaUed description of method-specific laboratory corrective action limits is provided in the appropriate CLP SOW. Any deviation from the prescribed CLP corrective action protocols or control limits must be approved in writing by HLA's QA Manager. Exceedance of control limits specified in CLP SOWs or appropriate method-specific SOPs wdll trigger corrective actions. The exceedances and corrective actions will be reported to the Laboratory QA Officer. C11.4 Long-Term Corrective Action The need for long-term corrective action may be identified by standard QC procedures, confrol charts and/or field or laboratory audits. Any procedural or data quality problem that cannot be solved by immediate corrective action faUs into the long-term category. The essential steps in a corrective action system foUow: • Identification and definition of the problem • Investigation and determination of the cause of the problem • Determination and implementation of a corrective action to eliminate the problem • Verification that the corrective action has eliminated the problem Documentation of the problem is important in corrective action. The responsible person may be an analyst, Site Manager, Laboratory QA Officer, sampler, HLA's QA Manager or the Project Manager. In general, the respective QA Manager wiU investigate the situation and determine who wdU be responsible for implementing the corrective action. HLA's QA Manager wdU verify that the corrective action has been taken, appears effective and, at appropriate later dates, verify that the problem has been resolved. The requfred corrective action wdU be documented by the HLA's QA Manager and the Site Manager for field activities. The corrective action wdll be discussed wdth the Project Manager, Island Chemical Company and USEPA before implementation. Any changes proposed for amending sampling and analytical procedures wdU be approved by USEPA before implementation. These changes wdll be documented in progress reports and addenda to this QAPP. \WORK\24231\02\QAPP.APP Harding Lawson Associates 301257 SecUon C12.0 Revision 0 March 17, 1994 C12.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT Copies of analytical results from samples analyzed wdll be submitted to HLA's Project Manager and provided to the USEPA Remedial Project Manager followdng QA/QC review, in the progress reports and in report deliverables. The results wdll include a tabulation of the analytical data and an explanation of any field conditions or laboratory QA/QC problems and thefr possible effects on data quaUty. The monthly progress reports wdll also include the results of periodic assessment of measurement data accuracy and precision or proposed changes to the QAPP. Results of field audits and laboratory audits wdll also be included, as appropriate. Corrective actions wdll be recommended if QA problems are identified during the review of data quaUty or results of field or laboratory audits. HLA's QA Manager or designated representative wdll review aspects of the implementation of this QAPP on a monthly basis, as necessary and submit a summary report to HLA's Project Manager for inclusion in the progress reports. These results wdll include an assessment of data quality and results of laboratory and/or field audits, as appropriate. If significant QA problems are identified as a result of these assessments and audits, corrective actions wdll be recommended and included in the progress reports. \WORIC\24231 \02\QAPP.APP Harding Lawson Associates 301258 SecUon C13.0 Revision 0 March 17. 1994 C13.0 ACRONYMS AND ABBREVIATIONS ARAR Applicable or relevent and appropriate requfrement CLP Confract Laboratory Program DQO Data quality objective FSP Field Sampling Plan GC/MS Gas chromatography/mass spectrometry HLA Harding Lawson Associates ICP Inductively coupled plasma MRL Method Reporting Limit MS/MSD Matiix spike/matrix spike duplicate NBS National Bureau of Standards PARCC Precision, accuracy, representativeness, completeness and comparabUity PID Photoionization detector QA Quality assurance QAPP QuaUty Assurance Project Plan QAU QuaUty assurance unit QC QuaUty control RAS Routine Analytical Services RPD Relative percent difference SAMLC Superfund Analytical Method-Low Concentration ( Site Island Cbenucal Company, St. Croix, U.S. Vfrgin Islands SOP. Standard Operating Procedures SOW Statement of Work SSP Site Safety Plan SSR Spiked sample recovery SVO Semi-volatUe organic compound TAL Target Analyte List TCL Target Compound List TIC Tentatively identified compound USEPA U.S. Envfronmental Protection Agency VOC Volatile orgaruc compound \W0RiC\24231 \02\QAPP.APP Harding Lawson Associates 301259 SecUon C14.0 Revision 0 March 17, 1994 C14.0 BIBLIOGRAPHY Comprehensive Envfronmental Response, Compensation and LiabUity Act of 1980 (CERCLA): Public Law 96-510, 42 USC 9601 et.seq. Superfund Amendments and Reauthorization Act of 1986 (SARA): Public Law 99-499. U.S. Envfronmental Protection Agency, 1981, Process Design Manual for Land Treatment of Municipal Wastewater U.S. Envfronmental Protection Agency, 1983, Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans: QAMS-005/80; Office ofMonitoring Systems and Quality Assurcmce, ORD, Washington, D.C, February. U.S. Envfronmental Protection Agency, 1984, Guidelines Establishing Test Procedures for the Analysis - Final Rule and Proposed Rule, 40 CFR Part 136, October. U.S. Envfronmental Protection Agency, 1986, National Enforcement Investigations Center Policies and Procedures Manual. U.S. Envfronmental Protection Agency, 1986a, Data Quality Objectives for Remedial Response Activities, March. U.S. Envfronmental Protection Agency, 1986b, Drafi Supplement to Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans: QAMS-005180, Office ofMonitoring Systems and Quahty Assurance, ORD. Washington, D.C, December. U.S. Envfronmental Protection Agency, 1986c, Test Methods for Evaluating Solid Waste: Office of Solid Waste and Emergency Response (OSWER) Directive SW-846, Vol. IB. U.S. Envfronmental Protection Agency, 1986d, Laser's Guide to the Contract Laboratory Program: Office of Emergency and Remedial Response, Sample Management Office, December. U.S. Envfronmental Protection Agency, 1988a, Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, Atmospheric Research and Exposure Aissessment Laboratory, June. U.S. Envfronmental Protection Agency, 1988b, Lihomtory Data Validation - Functional Guidelines for Evaluating Inorgarucs Analyses, Hazardous Site Evaluation Division, July. U.S. Envfronmental Protection Agency, 1988c, Liitxjmtory Data Validation - Functioned Guidelines for Evaluating Orgarucs Amalyses: TDD Doc. No. HQ-8401-01, Hazardous Site Evaluation Division, February. U.S. Envfronmental Protection Agency, 1989, HrgiDn ll CERCLA Quality Assurance Manual, Revision I. \W0RIC\24231\02\QAPP.APP Harding Lawson Associates 301260 ri SecUon C14.0 Revision 0 March 17, 1994 U.S. Envfronmental Protection Agency, 1989, Risk/Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual, Part A, Interim Final, Office of Emergency and Remedial Response, December. U.S. Envfronmental Protection Agency, 1990a, Contract Lahoratory Program Statement of Work for Inorganic /inalysis, ILMOl.O, March. U.S. Envfronmental Protection Agency, 1990b, Contract Laboratory Program Statement of Work for Organic Analysis - Multi-Media Multi-Concentration, OLMOl.O, AprU. U.S. Envfronmental Protection Agency, 1990c, Hazardous Waste Management System; IdentificaUon and Listing of Hazardous Waste; Toxicity Characteristics Revisions; Final Rule, 40 CFR Part 261, Thursday, March 29. U.S. Envfronmental Protection Agency, 1991b, Contract Laboratory Program Statement of Work for Ixiw Concentration Orgaruc Analysis, June. U.S. Envfronmental Protection Agency, 1991c, Model Quality /Assurance Project Plan: Office of Superfund, Region V, May. U.S. Envfronmental Protection Agency, 1992, Region II SOP #W-2 Evaluation of-Metals Data for U^e CLP Revision II, January. U.S. Envfronmental Protection Agency, 1992, Region II SOP HW-6, CLP Organic Data Revieiv and Preliminary Review, Revision 8, January. U.S. Envfronmental Protection Agency, 1993, Data Quality Objectives for Superfund, Interim Final Guidance: USEPAI540-R-93I071, Office of Emergency and Remedial Response, Washington, D C \WORK\24231 \02\aAPP JVPP Harding Lawson Assoctates 301261 Appendic CA Resumes of Key Quality Assurance/Quality Control Persormel 301262 James L. Collins Staff Geologist Mr. CoUins has four years experience in supervising field activities, such as monitoring weU and soU boring installation; soU, groundwater, surface water, sediment and waste classification sample collection; and UST and soU excavation/removal, as part of CERCLA (Superfund) remedial investigations/feasibUity studies (RI/FS), ECRA compUance projects and envfronmental site assessments. He has served in the capacity of staff geologist in soUs and groundwater investigations and envfronmental site assessments. He has experience in sample coUection from a wdde variety of media, including soU, groundwater, surface water and sediment, and has supervised drilling, excavation and dowm-hole geophysics operations. He has completed and/or assisted other HLA professionals in performing additional activities related to Ri/FS, ECRA Compliance projects and envfronmental site assessments including report preparation, delineation of soU and groundwater contamination, evaluation of groundwater flow dfrection, permeabiUty testing, regulatory file reviews, aerial photo surveys, site walk throughs, and drainage system evaluations. Education B.S., Geology, LaSalle University, 1981 Training Health and Safety Training: Hazardous Waste Operations, OSHA 29 CFR 1910.120 Delineation of Wetiands Short Course: Rutgers University Employment History 1990 - Present: Harding Lawson Associates 1981- 1990: Non-envfronmental Employer Representative Projects Envfronmental Audits Phase I Envfronmental Site Assessments - Project manager for numerous ESAs of commercial and industrial properties ranging from vacant lots to complex multi-site industrial facUities. Projects addressed issues such as underground storage tanks (USTs), hazardous waste generation, storage and disposal, RCRA and New Jersey ECRA compliance issues, asbestos, lead-based paint, and development of unit costs for envfronmental UabUities. Clients: banks, attorneys, property developers, manufacturing and industrial facUities. 10-06-93/17 301263 James L. Collins - Page 2 Phase II and IU Envfronmental Site Assessments - Project manager for a wdde variety of projects including design and implementation of various investigation and remediation programs, negotiation with and preparation of submittals to regulatory agencies, and acquisition of negative declarations. Field activities included supervision of morutoring weU installations; soU, groundwater, and hazardous waste sampling; test pits and soU removal programs; and UST closures. Cable Manufacturer, Passaic, New Jersey - Supervised facUity decommissioning and decontamination activities and assisted in implementation of an iiivestigation to evaluate the extent of soU and groundwater contamination by pefroleum products and metals. Work included supervision of remedial subcontractors, soU and groundwater sampling, sfream sediment sampling, delineation of light, non-aqueous phase liquids (LNAPL) and utUization of dye tracers to investigate discharge points of faciUty drainage structures. Remedial investigations/Feasibiiity Studies/Remedial Actions CERCLA (Superfund) Sites - Responsible for implementing several phases of soU and groundwater contamination studies at sites contaminated wdth volatUe organics, solvents, petrolevim products, polychlorinated biphenyls (PCBs), pesticides, and heavy metals. Supervised and assisted wdth the interpretation of dowmhole geophysical investigations in order to correlate data used for defining complex lithologies within contaminated aquUers. Commercial Property, NashvUle, Tennessee - Supervised investigation of methane soU gas survey to evaluate potential impacts to property from neighboring abandoned landfill. Conducted a test pit program to locate and evaluate non-soU fUl materials present on the property. Investigated the property for the absence or presence of wetlands. IMemberships PhUadelphia Geological Society 10-06-93/17 301264 John J . Kohler Staff Industrial Hygienist Experience Mr. Kohler has over five years of experience conducting industrial hygiene surveys, health and safety audits, envfronmental site assessments, afr monitoring for afrbome chemicals and dusts, stack testing, and indoor afr quality surveys. Other experience includes asbestos project management, health and safety officer on hazardous waste sites, and worker exposure monitoring. Mr. Kohler is also responsible for developing hazard communication programs; waiting preparedness, prevention, and contingency (PPC) plans; preparing health and safety plans; developing operations and maintenance (O&M) programs for industrial clients; and, preparing final reports. Mr. Kohler is presently the Designated Health and Safety Officer for HLA's Northeast Regional Offices. Registration and Certification SeU-study program for ABIH certification in the comprehensive practice of industrial hygiene Health and Safety Trairung: Hazardous Waste Operations, OSHA 29 CFR 1910.120 Asbestos Project Inspector, City of PhUadelphia AHERA Contractor/Worker Supervisor AHERA/Peimsylvania BuUding Inspector and Management Planner New Jersey Certified Asbestos Safety Technician Education B.A., Geology, Miami University of Ohio, 1987 Representative Projects Two chemical waste Superfund sites in southem New Jersey - Heallh and Safety Officer and Industrial Hygienist during site restoration and various drilling, water sampling, and soU sampling activities. ResponsibilitiM included writing health and safety plans, overseeing HLA personnel and subcontractor persormel in health and safety matters, afr monitoring to determine the presence of VOCs, and personal afr morutoring to dfifrmine worker exposures. Precious metal recycling facUity, San Jose, California - Conduciwi indusfrial hygiene surveys and lead exposure moiutoring. Responsible for extensive field operations on a quarterly basis, data collection ami techrucal analysis, recommendation of options for remedial actinn.^ ,ind engineering controls, and preparation of final reports. Pefroleum refinery, Rodeo, Califomia - Extensive personal and envfronmental morutoring for various hydrocarbons and solvents at i.^.ia Northern Califomia oU refinery. Other responsibUities included trnhnicii and data evaluation, client negotiations, and preparing final rojx^rt* Harding Lawson Associates J :(> >j;vi7 301265 John J. Kohler • Page 2 Asbestos buUding inspection and management planning for schools in the PhUadelphia, Pennsylvania and Patterson, New Jersey Archdiocese - Team leader during AHERA inspection and sampling for asbestos in various school buildings throughout ten counties in New Jersey and Permsylvaiua. Prepared asbestos management plans to assist local education authorities in properly handling concerns associated with asbestos present in thefr buildings. Several projects for the San Francisco Department of Public Health - Project oversight during asbestos abatement. Managed subconfractor for the client during aU phases of asbestos abatement to ensure that stringent requfrements of the QA program and all associated regulations were met. Conducted an afr monitoring program to ensure that work practices and engineering confrols were adequate. Harding luiwson Associates 3-26-93/17 301266 -a Brian D. LaFlamme Associate Geochemlst Experience # Mr. LaFlamme has six years of experience in geochemistry, including managing chemical data for several Resource Conservation and Recovery Act (RCRA) and Comprehensive Envfronmental Response, Compensation and LiabUity Act (CERCLA) investigations, interpreting isotopic data for the delineation of hydrogeologic units, and designing analytical programs for remedial investigations (RIs). Mr. LaFlamme is experienced in the interpretation of radionuclide data with respect to the mobiUty of radio- nucUdes in the envfronment, and the data validation thereof. Mr. LaFlamme is experienced in designing and waiting quaUty assurance project plans (QAPPs) and sampling plans for a variety of projects. Mr. LaFlamme has interacted wdth several regulatory agencies (including EPA) during evaluation of best avaUable technologies for various media. He has also managed quarterly sampling of residential water-supply wells and the generation of a cbenucal evaluation and hydrogeological investiga- tion reports. Mr. LaFlamme has assisted in evaluating emerging and innovative technologies to assess thefr potential use for either bench- or pUot- scale testing. He is experienced in the analysis of radionuclides in water samples and the analysis of metals by atomic absorption spectro- scopy and colorimetry. Mr. LaFlamme has three years of experience in computer modeling and has wndtten and modified software to interface microsystems wdth data acquisition units. He has managed complex sampling programs that requfred selection of appropriate analytical methods and the design, preparation, and utUization of various laboratory instrumentation. Training Occupational Safety and Health Admirustration (OSHA) and EPA 40-hour safety training course The Use of the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) Installation Restoration Data Management System (IRDMS), seminar, Aberdeen, Maryland, AprU 1989 Analytical Laboratory Services: Solving the Mysteries, seminar, Chicago, Illinois, May 1989 Fundamentals, Applications, and Instrumentation of Gas Chromatography, seminar, Perkin-Elmer, March 1990 Physical/Chemical Treatment of Hazardous Waste, seminar by EPA, AprU 1990 2nd Forum on Irmovative Hazardous Waste Treatment Technologies: Domestic and Intemational, seminar by EPA, May 1990 Advanced RCRA Seminar, Monterey, California, May 1991 RCRA Seminar, Denver, Colorado, September 1992 Education M.S., Chemical Oceanography, Uruversity of Washington, Seattle, 1985 B.S., Geology and Chemistry, Bridgewater State College, Bridgewater, Massachusetts, 1982 Harding Lawson Associates 301267 10-07-92/10 Brian D. LaFlamme • Page 2 Representative Projects Evaluation of Technologies Lowry Landfill, Arapahoe County, Colorado - Interface wdth engineers on evaluation of technologies to treat radionuclides in waste-pit Uquid and groundwater. Support for treatabUity studies. Client: The Lowry CoaUtion Indusfrial solvents reclaiming site, Winnebago County, Ulinois - Evaluation of best avaUable technologies for contaminated soU/sludge material during EE/CA and RAAE reports. Interaction with EPA during revisions of reports. Client: Acme Solvents Technical Committee Rocky Mountain Arsenal (RMA), Denver, Colorado - Assisted in evaluating emerging and irmovative technologies to assess thefr potential use for either bench- or pUot-scale tests. Recommended technologies on the basis of giudelines established to evaluate freatment potential, merit, cost, and performance. Managed the generation of supporting documents for the demonstration of selected technologies. Documents include Technical Plan, Quality Control Plan, Health and Safety Plan, and Data Management Plan. Client: U.S. Department of the Army (Army) Mercury cell room, Longview, Washington - Evaluated technologies and commercial products to stabUize free mercury. Work was conducted in support of cleanup activities'in a mercury cell room used as part of a chloralkali process in the treatment of wood. Client: Confidential Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Investigations Industrial solvents reclaiming site, Wiimebago County, Illinois - Managed the development of a quality assurance project plan (QAPP) and a sampling plan (SP) for activities to be conducted under the remedial design/remedial action (RD/RA) phase. Client: Acme RD/RA Group Industrial solvents reclaiming site, Winnebago County, Illinois - Managed the residential water-supply wells sampling program that included quarterly monitoring, preparing reports for EPA and interacting wdth residents. Client: Acme Solvents Technical Committee Industrial solvents reclaiming site, Winnebago County, Illinois - Managed the revision of the EE/CA report to incorporate EPA comments. The EE/CA report included the evaluation of removal alternatives for contaminated soU and debris and costing of altematives with the Cost of Remedial Action (CORA) model. Client: Acme Solvents Technical Committee Industrial solvents reclaiming site, Winnebago County, Ulinois - Managed the revision of the Remedial Action Altematives Evaluation (RAAE) report to incorporate EPA comments. The RAAE report included the evaluation of remedial altematives for contaminated soU, bedrock, and groundwater. Client: Acme Solvents Technical Committee Harding Lawson Associates , ^ 10-07-92/10 301268 Brian D. LaFlamme • Page 3 Industrial solvents reclaiming site, Winnebago County, Illinois - Managed the generation of a report that included chemical data assessment and hydrogeologic investigation. Client: Acme Solvents Techrucal Committee Industrial solvents reclaiming site, Wiimebago County, Illinois - Managed the chemical data for the supplemental RI of a National Priorities List (NPL) site. Management activities included organizing data coUected from four different sources. Completed respective sections of the report for review by the client and the regiUatory agency. Client: Acme Solvents Technical Committee Lowry LandfUl, Arapahoe County, Colorado - Evaluated the nature and extent of contamination of radionuclides in groundwater and waste-pit liquid (source medium). Assessed potential contribution of radionuclides from anthropogeiuc sources. Coordinated closely wdth analytical laboratory in the development of a preparatory step for the analyses of complex matrices. Client: The Lowny Coalition Lowny LandfUl, Arapahoe County, Colorado - Managed chemisfry elements in support of an RI. ResponsibUities included data validation of organics, metals, and radionuclides, database management, development of analytical programs, management of subcontractor laboratories, and evaluation of nature and extent of contamination. Client: The Lowry CoaUtion RMA, Denver, Colorado - Managed the chemical data assessment for the armual surface-water monitoring report and generated appropriate sections of the report. Client: /^my, c/o R.L. StoUar & Associates, Inc. RMA, Denver, Colorado - Managed the inorgaruc data assessment for the annual groundwater monitoring report and generated appropriate sections of the report. Client: Army, c/o R.L. Stollar & Associates, Inc. RMA, Denver, Colorado - Assisted in WTiting sections of the annual report for a groundwater monitoring project. Performed extensive computer work involving generating contaminant plume maps and marupulating data for interpretive effort. Performed the quality assurance/quality control of the inorganic data. Client: Army, c/o R.L. Stollar & Associates, inc. RMA, Denver, Colorado - Data manager for an Rl/feasibUity study (FS) project involving data tracking from collection to report writing. Processed laboratory data through the USATHAMA IRDMS program. CUent: Army Marshall/Boulder Lmdfill, Boulder, Colorado - Interacted wdth the laboratory to dijsign an analytical program utUizing appropriate analytical methods for identifying volatile and semivolatUe orgaruc compounds, organochlorini!. [x'sticides, polychloride biphenyls (PCBs), chlorinated herbicides, and inor^^anic parameters at a landfUl site. Clients: City of Boulder and Lindfill. Inc. Harding l.awson Associates 10-07-92/10 301269 Brian D. LaFlamme • Page 4 RMA, Denver, Colorado - Interpreted isotopic data collected from ground- water wells and wrote assessment reports on the resiUts, including recommendations for future work. Client: Army, c/o R.L. Stollar & Associates, Inc. Resource Conservation and Recovery Act investigations Materials handling faciUty, Denver, Colorado - Wrote the Corrective Measures Study Work Plan for activities to be conducted as part of corrective actions. CUent: Confidential Site Assessment Lyon, France - Provided techrucal guidance and oversight during the investigation phase of a site assessment project that involved the collection of soU samples at two manufacturing faciUties. Client: Confidential Hazardous materials site assessment, Colorado - Provided oversight and technical assistance during the remediation phase of this site assessment project that involved underground storage tank (UST) systems. Also, generated reports for the client and the regulatory agency. CUent: Confidential Agency interaction Industrial solvents reclaiming site, Wiimebago County, Illinois - Assisted in negotiations wdth EPA for a remedial design/reriiedial action scope of work. ResponsibUities included low-temperature thermal stripping, soil/bedrock vapor extraction, multi-media cap, and groundwater pump and treat. CUent: Acme Solvents Technical Committee Previous Employment Under a grant from the National Science Foundation, managed a sampling program to study sediments and interstitial water in the Mariana basin of the west Pacific Ocean. Project involved research scientists from five universities (including two intemational participants) in a multidLv:iplinary study of the Mariana Mounds. Ocean bottom sediment and intersiiiial water samples were taken and bathymetry and heat-flow data W-TB collected. As project manager in a study funded by the National Sciem t! r ound.ition and Sea Grant, participated in a research project investigating ih.Tm.il output and seisnuc variabUity of oceaiuc hydrothermal vents ni! 'ho ( oast of Washington. In conjunction wdth pUots of the /VLVIN sut;mi'rMt)lc research vessel, two equipment manufacturers, and several n-s.-.irrh scientists, coordinated weight- and size-restricted design and i untirui tion of a remote camera system to be deployed at a depth of 2200 rrvNT^ Harding Lawson Associates 10 07 92/10 301270 Brian D. LaFlamme • Page 5 For the Office of Naval Research, designed and constructed a prototype incubating oven for culturing microbes sampled from hydrothermal vents. Design required development of software to interface a Hewlett-Packard microcomputer with a data acquisition uiut for morutoring thermocouples and maintaining oven temperature. In graduate research funded by the National Science Foundation, studied an alkaline lake (Soap Lake] in eastern Washington. Designed a field and laboratory program to investigate variations in concentrations of radioisotopes in the oxic and anoxic zones of the lake. Analytical results of laboratory adsorption experiments were modeled using a mineral equi- Ubrium FORTRAN program, modified to include adsorption reactions, to support the theory of carbonate complexes increasing the mobUity (solubiUty) of various radioisotopes. Memberships American Geophysical Union Geochemical Society Hazardous Materials Control Resources Institute Publications 1985. The influences of carbonate complexes on thorium adsorption. EOS (Transactions, American Geophysical Union), vol. 66, p. 1325 (wdth J. W. Murray). Presented at the American Geophysical Uiuon Conference, New Orleans, January 1986. 1987. Solid/solution interaction: The effect of carbonate alkaUiuty on adsorbed thorium. Geochimica et Cosmochimica Acta, vol. 51, pp. 243-250 (with J. W. Murray). Harding Lawson Associates 10-07-92/10 301271 Edward A. Nemecek, R.G., C.P.Q. Principal Hydrogeologist Experience Mr. Nemecek has 25 years of technical, administrative and management experience in both the private and public sectors including over 12 years of CERCLA work at more than 15 NPL or proposed NPL sUes. His RCRA experience includes consent order facility closures and RFI activities. Mr. Nemecek's recent experience encompasses miUtidisciplinary remedial investigation conceptualization, design and management and consultation on groundwater remedial design/remedial action projects. He has also provided technical advice and consultation to legal counsel and several PRP committees; expert witness services and technical preparations for cost recovery, toxic tort, multiple PRP and insurance coverage Utigation; and technical advice regarding state and federal reguJatory agency consent order negotiations and adversarial and public hearing preparation. Additional recent experience includes development and implementation of solute fransport groundwater models; several dozen complex leaking underground storage tank evaluations; and advice to major financial institutions regarding envfronmentally sensitive real estate fransactions. Mr. Nemecek also serves as Quality Assurance Manager for HLA's Northeast Region. Registration and Certification Registered Geologist - Arizona 1986, No. 19197 Certified Professional Geologist - American Institute of Professional Geologists 1986, No. 6980 Training U.S. Geological Survey, Water Resources Division Training Center: water use seminar; advanced groundwater covu-se; analytical methods to determine aquifer properties and to predict aquifer response Harding Lawson Associates' RCRA Training Program OSHA and EPA forty-hour safety training and supervisory courses Education B.S., Geology, Arizona State Uruversity, 1971 Groundwater Hydrology Course work. University of Arizona Representative Projects Hazardous Waste Sites CERCLA site; remedial investigation/feasibUity study for PRP Techrucal Committee. Client: Kane and Lombard Techrucal Committee, Baltimore. Project consultant RCRA site; RCRA facUity mvestigation; VOQDNAPL in fractured bedrock; dissolved VOC groundwater plume. Client: Confidential, Pennsylvarua. Project consultant; dissolved VOC groundwater plume; VOG/DNAPL interspersed with LN/^L problems in complex fractured bedrock envfronment. Client: Confidential, Pennsylvania. Harding Lawson Associates 7-08-93/1701 301272 Edward A. Nemeceic • Page 2 Dfrected investigation of closed specialty steel null to decommission and dispose of potentiaUy hazardous wastes in compliance wdth RCRA for potential site sale. Client: Confidential, Pennsylvania. Project consultant and expert witness; complex landfill groundwater VOC contamination investigation; state Superfimd oversight; multimUlion dollar CERCLA cost recovery litigation against former trustee. Client: City of Phoenix, Law fimns: Squfre, Sanders, Dempsey; Landels, Ripley, Diamond. Project manager for a major chemical disfribution company involved in a multiple PRP state Superfund groundwater VOC contamination problem over a 35-square-niUe area; conformance with NCP to preserve CERCLA litigation rights. Client: Confidential. Negotiated with EPA, conceptualized and developed work plans for all phases of NPL site soU and groundwater pesticide contamination study; managed several phases of field work at complex multi-aquifer site. Client: Latham and Watkins, Montrose Chemical Company, CalUomia. Dfrected hydrogeologic investigation of heavy metal, hydrocarbon, and volatUes contamination of soU and groundwater at 22 sites wdthin facUity; provided consultation regarding potential NPL listing; coordinated project, made technical presentations regarding annual work effort. Supervised monitoring/drUling program for approximately 200 on-site and off-site wells. Client: U.S. Afr Force/General Dynanucs, Fort Worth, Texas. Managed aU phases of two separate bulk pesticide facUity soUs/groundwater contamination studies; multiple regulatory agency and insurance company negotiations. Provided advice to counsel re: proposed NPL listings, insurance litigation, criminal indictments by Grand Jury. CUent: Latham and Watkins; Confidential Client, California. Wood freatment facUity; planning and supervision of 14 aquifer tests with multiple observation wells for a potential EPA Superfund site; soU and groundwater contamination, heavy metals. Client: Marley CooUng Tower Company, Califomia. CERCLA landfill; coordinated comprehensive techrucal review of Draft Remedial Investigation report for largest generator by volume. Provided detaUed comments to counsel, regulatory agencies, and client. Client: Montrose Chenucal Company, Stringfellow Site, Califoriua. Heavy metals contamination; developed strategy wdth counsel, negotiated technical provisions of Consent Order under State Superfund; designed and implemented remedial investigation. Client: Confidential. Expert Consultation and Advice Technical advisor lo major responsible party on Stringfellow Technical Committee. Harding Lawson Associates 7-O8-93/1701 301273 Edward A. Nemeceic • Page 3 Provided expert advice for law firms on behalf of several mutual clients with hazardous waste problems; negotiated with state and Federal regulatory agencies. CUents: Latham and Watkins; Squfre, Sanders, Dempsey; Streich, Lang; Snell and Wilmer; SUls, Cummis. Assisted legal counsel, negotiated technical appendix of Consent Order for CERCLA Enforcement Action, California. Client: Montrose Chemical Corporation, Califomia. Preparation for toxic tort defense; Hughes Afrcraft Companyn"ucson AiTjrart Authority NPL site. Client: Law firm of Latham and Watkins. Independent expert wdtness for plaintiffs in successful $45 million CERCLA cost recovery Utigation. Expert testimony in pubUc hearing regarding creation of 600-square-mUe irrigation nonexpansion area. Expert testimony in complex surface water/groundwater interaction hearing. Provided techrucal testimony at legislative committee hearings. Provided expert testimony regarding well construction problems. Provided expert testimony at series of 14 statewdde hearings regarding defiiution of legally defensible pumpage zones. Acted as technical liaison wdth state regulatory agency staff; techiUcal requfrements and strategies for adversarial hearings; provision of expert testimony. Client: State of Arizona Developed and initiated state envfronmental compliance and monitoring program. Client: State of Arizona. Digital IModellng Dfrected development of 3-D solute transport digital groundwater model of 115 square mile area; analysis of multiple PRP contamination scenarios over 50-year time frame in complex, highly-stressed hydrogeologic envfronment. Client: Confidential. Large, miUti-aquifer TCE plume; dfrected development of solute transport digital groundwater model; model used in cost recovery apportionment by EPA for remediation of 6- mUe-long plume; Tucson Afrport Authority/Hughes Aircraft Company NPL site. Assisted in development of digital groundwater model of 2,500-square-mUe aquifer; transient calibration; independent transient verUication; Salt River Valley, Arizona. Harding Lawson Associates 7-O8-93/1701 301274 Edward A. Nemecelt • Page 4 5,000 gpm groimdwater removal, treatment, and reinjection system; supervised digital model activities for obtaining poor water quaUty withdrawal permit; reclamation weU field. Client: U.S. Afr Force/Hughes Aircraft Company. Directed development of hydrauUc digital groundwater model; 1800-square-nule aquifer; Upper Santa Cruz Basin, Arizona. Revised and recalibrated multi-aquifer groundwater flow model in a complex hydrogeologic envfronment. CUent: State of Washington. HydrauUc modeling of several water supply problems. Miscoiianeous Technical Leaking underground storage tanks; project consultant on several dozen leaking underground storage tank projects; major soU and groundwater contamination problems including both free phase and dissolved constituents. Clients: ARCO, Unocal, Chevron, Texaco, Exxon, City of Phoenix, Arizona Public Service. Prepared Annual Groundwater Monitoring Report under State regulatory program for Palo Verde Nuclear Generating Station, Arizona 1987 - 1991. Planned, supervised, analyzed 175 aquifer tests within a 2,500-square-mUe aquifer. Conducted miUtiple aquifer tests for murucipal well field. Investigated, performed aquifer tests and prepared reports for complex groundwater/surface water interference problems, Washington. Agency oversight representative, dewatering project. Trident submarine base, Washington. Investigated salt water intrusion problem, Washington. Performed recoimaissance geologic mapping. Southem Apache County, Arizona. Memberships Association of Groundwater Scientists and Engineers National Water Well Association American Institute of Professional Geologists (AIPG) Harding Lawson Associates ? (^ 93/1701 301275 Bharat Patel, P.G. Associate Hydrogeologist Experience Over the past 12 years Mr. Patel has managed hydrogeologic, soUs, and geophysical investigations, and designed remedial actions, at hundreds of contaminated sites throughout the United States, India, and Puerto Rico. At landfills, landfarms, lagoons, underground storage tanks (USTs), aboveground storage tanks, buried drums, wetiands, septic systems, sole-source aquifers, and assorted manufacturing plants, Mr. Patel has successfuUy investigated and remediated hydrocarbons, polychlorinated biphenyls (PCBs), solvents, paints, inks, specialty chemicals, and other hazardous wastes. He has experience simultaneously managing multi-mUUon-doUar cleanups at multiple sites under multiple jurisdictions. Mr. Patel has negotiated on behalf of clients with sites regulated by the Comprehensive Envfronmental Response, Compensation, Cleanup and LiabUity Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), the Envfronmental Cleanup ResponsibUity Act (ECRA), and other laws. He has managed compliance with ECRA regulations, assisted wdth RCRA Part B permit applications, developed closure and post-closure plans, contingency plans, and groundwater monitoring systems. Under confract to U.S. Envfronmental Protection Agency, Mr. Patel has evaluated appUcations for RCRA Part B permits and assessed the potential identification of sites on the National Priority List. Registration and Certification Geologist - Arkansas 1987, No. 203, Florida 1988, No. 819 Geologist - American Institute of Certified Professional Geologists 1989, No. 7680 Training OSHA and EPA 40-hour safety training course Eight-hour hazardous materials supervisory course and refresher 40-hour hazardous field training course. Phoenix Safety Association Five-day seminar: Design Fundamentals for Site Characterizations and Remediations, Association of Groundwater Scientists and Engineers Two-day seminar: Critical Issues in Undergroimd Storage Tank Management, National Water Well Association Five-day senunar: Aquifer Analyses, Association of Groundwater Scientists & Engineers Education M.S., Geology, Rutgers Uruversity, 1983. M.S., Geology, Maharaja Sayajfrao Uruversity, Baroda, India, 1979 B.S., Geology, Gujarat University, Ahmedabad, India, 1977 Representative Projects # Polyurethane foam manufacturing plant. East Rutherford, New Jersey - Managed the investigation of and a feasibUity study for the remediation of a five-acre site regulated by New Jersey's Envfronmental Cleanup and ResponsibUity Act (ECRA). Client: General Foam Corporation Harding Lawson Associates 3-10-91/1701 301276 Bharat Patel - Page 2 Dura-Bond recycled waste foam plant in Newark, New Jersey - Managed successful remedial investigation at this ECRA site, including a soU-gas survey, and a feasibUity study at a site with volatUe organic compound (VOC) and trichloroethylene (TCE) contamination in the soU and groundwater. Designed and implemented a soU remediation program and provided expert testimony resulting in a settlement in favor of the client. CUent: General Foam Corporation Developed and unimproved property, Hopewell Towmship, Warren Towmship, Bernards Township, New Jersey - Managed detaUed environmental assessments of three sites: determined the extent of the sites' envfronmental liabiUties, performed phase II investigations of two of the sites where a substantial amount of waste was discovered, and instaUed potable wells. CUent: Confidential multinational commurucations company Two Superfund sites, Rocky HUl, New Jersey - Conducted hydrogeologic investigation in fractured shale on a groundwater divide wdthin the area of influence of public water supply well field, which are subject to EPA Superfund investigations. Work included installation of five 50-foot wells, the installation of soU borings, and a geophysical investigation to locate source of groundwater contamination. Successfidly delineated the responsibUities of PRPs other than the client and fought against more resfrictive regulatory designation. Client: Confidential Picture frame manufacturer, HoweU Towmship,,New Jersey - Managed the remedial investigation and remedial action at this ECRA site wdth more than 50 drums containing chenucals, paints, inks, and specialty chenucals, contaminated soUs, and septic material. Hydrogeologic investigation included installation of monitoring wells in the Kfrkwood-Cohansey Sand Formation, a designated sole aquifer that supplies drinking water to southem New Jersey. Client: Ffrst Fidelity Bank Matfress manufacturer. Linden, New Jersey - Designed and managed remedial investigation and remedial action at this ECRA site with hydrocarbon contamination. Installed shallow monitoring weUs in shale formation to evaluate the effects of leaky USTs on groundwater quality and conducted a short- duration aquifer pump test, supervised soU boring program. Designed a soUs excavation program and developed a pump and treat remedial system utUizing activated carbon fUters. Client: Simmons Unconfrolled landfUl, Edison, New Jersey - Managed a shallow soU boring program and a geophysical investigation to locate buried drums, coordinated an extensive trenching program prior to removal of more than 5,000 cubic yards of contaminated soUs and waste paint, supervised techrucal team and excavation contractor onsite, coordinated tiansportation and disposal of waste material, and worked closely wdth EPA persormel. Conducted fingerprinting investigation which identified responsible party for paint disposal. Client: Confidential Harding Lawson Associates 3-io-9Vi7oi 301277 Bharat Patel. Page 3 High-temperature brick manufacturer, Woodbridge, New Jersey - At this ECRA site, conducted a hydrogeologic investigation, risk assessment, and remediation plan. Determined the extent of groundwater contamination originating from a 30,00G-gallon above-ground fuel tank and five underground storage tanks (USTs) containing gasoline and pefroleum products. Designed and installed a system to monitor a groundwater regime that was influenced by tidal effects. Implemented soU remediation program approved by the New Jersey Department of Envfronmental Protection (NJDEP). Client: A. P. Green Refectories Paint research and development center, Newark, New Jersey - At this ECRA site, managed a hydrogeologic investigation and designed a cleanup plan approved by the NJDEP. Determined the extent of groundwater contamination originating from 11 USTs containing solvents, waste oU, and fuel oUs. Installed onsite and offsite moiutoring wells, evaluated field and analytical data, developed a groundwater cleanup plan, and installed a dual pump recovery well/interceptor trench system. Worked closely with city, state, and federal envfronmental protection and pubUc health and safety officials. Client: John R. Armitage & Co. Sprinkler system parts manufacturer. Linden, New Jersey - Conducted a soUs and hydrogeologic investigation and designed a remedial measure at this ECRA facUity, which operated three hazardous material drum storage areas and a 10,000-gallon UST. Discovered and removed five additional USTs, installed wells to measure groundwater quaUty, and successfuUy determined the extent of the client's responsibUity for contamination despite the site's location in a highly industrialized area where a number of neighboring facUities use simUar materials. Designed cleanup of site, inside and outside the buUding, including removal of floor and remediation of sub-floor. Consulted wdth client and NJDEP to allow the cUent, now bankrupt, to sell the property to finance the remediation. CUent: AHC Manufacturing Corporation Electric swdtch manufacturer, Parsippany, New Jersey - Managed hydrogeologic investigation to determine effects of retention pond operation on the groundwater quality at this ECRA site, installed wells, delineated extent of contamination, supervised removal of USTs and contaminated soU, installed interim product recovery system, and prepared a closure plan. Client: Confidential Large-diameter concrete pipe manufacturing plant, Wharton, New Jersey - At this 36-acre ECRA site across a river from a Superfund site and surrounded by numerous potential sources of contamination, managed a hydrogeologic investigation of two contaminant plumes and prepared a final remediation plan. Designed and oversaw the installation of 25 wells that monitored the impact on groundwater quality from process water discharged from a retention lagoon, outside painting operation, surface spUl areas, and 10 USTs. Conducted hydrogeologic investigation which identified an offsite contaminant source for a groundwater plume covering over 5-acres of the site. Designed and supervised site characterization and remediation program, which involved removal of the USTs and 8,000 cubic yards of contaminated soUs from two drum storage areas, USTs, and spUl areas. Client: Gifford-HUl American Harding Lawson Associates 3-io-9i/i70i 301278 Bharat Patel • Page 4 Landfarm, New Jersey - Prepared RCRA Part B permit applications. Client: Confidential petrochemical company. Hazardous waste landfUl and lagoon, Puerto Rico - Supervised intrusive and geophysical investigation involving installation and design of monitoring wells up to 350 feet deep and an aquifer testing program. Evaluated deep subsurface soUs and rock formation to determine presence of solution cavities in the limestone formation and had partial responsibUity for evaluating geophysical survey data, specificaUy micro-gravity anomaUes. Client: Confidential Numerous hazardous waste sites, lagoons, and disposal units, Louisiana, New York, and Puerto Rico - Evaluated RCRA Part B permit appUcations: included investigation of groundwater, monitoring systems, and local and federal regulatory compliance. CUent: U.S. EPA Hazardous jvaste sites, Louisiana - Managed investigations of more than 100 hazardous waste sites to assess the severity of potential problems and thefr potential identification as Superfund sites. Evaluated hazardous waste hcmdling procedures, including treatment, storage, and disposal and reviewed federal, state, and local govemment fUes, reports, and court cases, as well as facility envfronmental permits. Client: Louisiana Department of Envfronmental Quality Publications 1983. Geophysical study of talc deposits in the State Line Serpentiiute District, Lancaster, Pennsylvania. Master's thesis, Rutgers University, Newark, New Jersey. 1979. Geological field work around Bona, Gujarat. Master's Dissertation, M.S. University, Baroda, India. Harding Lawson Associates 3 io-9Vi7oi 301279 Jason M. Schindler Senior Geologist Experieneo Mr. Schindler has seven years of experience managing soU and groundwater investigation projects involving state and federal compliance activities, envfronmental site assessments, and underground storage tank investigations and closures. He is responsible for developing techrucal scopes of work and budgets; ensuring that techrucal, quality confrol, budgeting and scheduling objectives are met; and supervising preparation of technical reports and proposals. His experience also includes design and implementation of various investigation and remediation programs, preparation and review of submittals to regulatory agencies, assistance in emergency response activities, and negotiations wdth regulatory agencies, as weU as estimating potential remedial costs to assist cUents in business decision making. In addition, Mr. Schindler is experienced in a wdde variety of field activities including supervision of monitoring weU installations and soU gas surveys; groundwater, soU, and hazardous waste sampUng; aquifer testing; supervision of soU borings, test pits and soU removal progrcuns; and numerous storage tank closures in accordance wdth current federal and state programs. Registration and Certification Certified to practice Subsurface Evaluations in New Jersey, No. 0002005 Training OSHA and USEPA forty-hour safety training course OSHA eight-hour supervisor framing course Engineering Geology course, Drexel Uruversity, PhUadelphia, Pennsylvania, 1987 National Ground Water Association Applied Hydrogeology course Education B.A., Geology, University of Pennsylvania, PhUadelphia, 1985 Representative Projects Groundwater investigation Precision Equipment Manufacturer, PhUadelphia, Pennsylvania • F*ro)ect manager for soU and groundwater investigation to assess impacts lo site contaminated by solvents, PCBs and pefrolevim hydrocarbons from surface spiUs and leaking storage tanks. Investigation includes identification of potential source areas and investigation of soU and groundwater impacts including vapor, dissolved, and light and heavy non-aqueous phase contamination. The scope of the project includes a soU gas survey, soil and groundwater sampling and interim recovery of light, non-aqueous phase Uquids. Harding Lawson Associates 5-4-93/17 301280 Jason M. Schindler • Page 2 Envlronmontal Site Inspection Former Turbine and Heat Transfer Apparatios Manufacturing and Testing FacUity, Lester, Pennsylvania - Project manager for investigation of potential areas of envfronmental concern and regidatory compUance. Areas of concern include a landfUl, numerous underground and aboveground storage tanks, and hazardous and non-hazardous waste storage areas. The investigation includes surveys using ground penetrating radar and magnetometers, and soU boring, test pit, and monitoring weU instaUation and sampling. Remedial Investigation Abandoned Site, Edison, New Jersey - Project manager for investigation of site that had been used for iUegal dimiprng of liquid wastes including PCB oUs. Study involved soU sampling to determine the extent of PCBs, installation of monitoring wells and collection and analysis of groundwater and surface water samples. Landfill Closure Investigation Manufacturer of Asbestos Products, Manheim, Pennsylvania - Project manager for investigation of landfUl during closure under RCRA. The landfiU was located in a flood plain and contained phenolic resins, asbestos and other wastes. Study involved installation and sampling of soU borings and monitoring wells and aquifer testing to determine the volume of the landfill, the nature and extent of groundwater contamination, and groundwater movement through and around the landfiU. Environmental Site Assessment/Soil and Groundwater Investigation Polypropylene Manufacturer, West Deptford, New Jersey - Project manager for comprehensive site investigation during property tiansfer. The study involved identification of more than 30 areas of potential envfronmental concern, soU sampling, installation and sampling of monitoring wells and aquifer testing. Underground Storage Tanlcs ' Underground Storage Tank Investigations and Closures in New Jersey, Pennsylvarua, Maryland and Virginia - Managed investigations of more than 60 service stations and commercial facUities with leaking underground fuel storage tanks. Projects included initial response to and characterization of releases, management and evaluation of soU gas surveys, installation and sampling of soU borings and monitoring wells, delineation of extent of impact, aquifer testing, conceptual design of remediation programs including groundwater and hydrocarbon recovery and freatment and soU vapor extraction systems. Harding Lawson Associates 5-4-93/17 301281 Jason M. Schindler - Page 3 Environmental Site Assessment/Soil Investigation Furniture Assembly Plant, Fort Washington, Pennsylvania - Managing site investigation to identify and assess potential issues of envfronmental concern as part of property transaction. Work includes soU sampling program and background investigation. Environmental Site Assessmont/SoU and Groundwater Investigation Former Folding Box Company Facility, Canton, Pennsylvania - Managed site investigation of soU and groundwater impacts resulting from facUity operations. Scope of work included soU boring program, monitoring well instaUation, and soU, groundwater and waste sampling. Soli Investigation Precision Metal Grinding Plant, Pennsauken, New Jersey - Managing site investigation to evaluate residual contamination from former ash pUes. Oil Spill Cleanup New Jersey and Virginia - Managed cleanup and post-cleanup sampling of two residences following home heating oU spUls. Underground Storage Tanks US Afr Force Base, Maryland - Provided oversight during integrity testing of numerous underground fuel storage tanks. Underground Storage Tank Investigation and Remediation Mercer County Airport, New Jersey - Project geologist during investigation and recovery of jet fuel leak from underground storage tank. Project included installation of an interceptor trench to recover separate-phase pefroleum and installation and sampling of monitoring wells to assess the extent of impact. Memberships National Ground Water Association, Association of Ground Water Scientists and Engineers Harding Lawson Associates 5-4-93/17 3 01282 \% Appendix CB Corrective Action Form 301283 Corrective Action Form Oata: Job Name: Initiator's Name and Titlej Problem Description: Reported To^ Corrective Action: Reviewed and Implemented B ^ cc: Project Manager^, QA Manager - __ QA Offlcar- 301284