removal action sampling & analysis planhave entered into a tailored collaboration to remediate...

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SAMPLING AND ANALYSIS PLAN

RELIEF AND GAS HOLDER REMEDIATION

UGI COLUMBIA GAS PLANT SITEColumbia, Pennsylvania

SDMS DocID 2080800

Preparedfor:

PENNSYLVANIA POWER AND LIGHT COMPANYTwo North Ninth Street

Allentown, Pennsylvania 18101-1179

Prepared by:

REMEDIATION TECHNOLOGIES, INC.9 Pond Lane, Suite 3A

Concord, Massachusetts 01742-2851

RETEC Project # 3-1612-200

JUNE 1996

AR400545

REMOVAL ACTIONSAMPLING AND ANALYSIS PLAN

RELIEF AND GAS HOLDER REMEDIATION

UGI COLUMBIA GAS PLANT SITEColumbia, Pennsylvania

Prepared for:

PENNSYLVANIA POWER AND LIGHT COMPANYTwo North Ninth Street

AUentown, Pennsylvania 18101-1179

Prepared by:

REMEDIATION TECHNOLOGIES, INC.9 Pond Lane, Suite 3A

Concord, Massachusetts 01742-2851

Prepared by.

Reviewed by:/ ^ ^ ^

RETEC Project # 3-1612-200

JUNE 1996

AR400546

TABLE OF CONTENTS

NO. DESCRIPTION PAGE NO.

1.0 INTRODUCTION 1-1

2.0 SAMPLING OBJECTIVES 2-12.1 Performance Sampling and Analytics 2-12.2 Process Monitoring 2-12.3 Process Sampling 2-12.4 Waste Characterization Sampling 2-22.5 Health and Safety 2-22.6 Monitoring Summary 2-2

3.0 DATA GATHERING ACTIVITIES 3-13.1 Holder Sampling and Analysis 3-13.2 Process Sampling and Monitoring Locations 3-23.3 Data Display Systems 3-33.4 Process Water Sampling 3-33.5 Waste Characterization Sampling 3-43.6 Field Quality Assurance Sampling 3-83.7 Decontamination 3-83.8 Sample Handling 3-9

3.8.1 Field Sample Handling 3-93.8.2 Sample Preparation and Analysis 3-9

4.0 QUALITY ASSURANCE OBJECTIVES 4-1

LIST OF TABLESNO. DESCRIPTION PAGE NO.

2-1 Summaries of Field Monitoring and Sampling Activities 2-33-1 Summary of Analytical Samples 3-63-2 Analytical References 3-7

APPENDICES

APPENDK A SOP 210: Soil Sampling CollectionAPPENDK B SOP 120: DecontaminationAPPENDK C SOP 110: Packaging and Shipment of SamplesAPPENDK D Effluent Limitations

F:\PROJECTS\3-1612\DOCS\SAK>.PLN 1 June 7, 1996AR400547

1.0 INTRODUCTION

The former MGP Site in Columbia, Pennsylvania was placed on the National Priorities List

in June 1994. The process of site remediation has been initiated under the Superfund Accelerated

Cleanup Model (SACM) as a non-time critical removal action. RETEC prepared an engineering

evaluation/cost analysis (EE/CA) for the relief and gas holders at the site. The results of the

EE/CA showed that the selected remedy for the relief holder should be enhanced recovery using

steam injection. The selected remedy for the gas holder should be conventional pumping. The

final step will be to remove residual liquids from both holders and grout them closed. The

Electric Power Research Institute (EPRI) and Pennsylvania Power and Light Company (PP&L)

have entered into a Tailored Collaboration to remediate the relief and gas holders at the site.

This Sampling and Analysis Plan (SAP) has been prepared for the removal of MGP

residuals from two former gas holders in Columbia, PA. The purpose of the SAP is to outline

the sampling objectives, to describe the sampling procedures, and to specify the analytical

requirements.

The work to be performed at the site includes removing MGP residuals from two former

holders, a relief holder (60 feet diameter, 27 feet deep) and a gas holder (40 feet diameter, 17 feet

deep). The relief holder is filled with soil and debris and is saturated with tar and water. The gas

holder is also filled with soil and debris and is saturated with water and aqueous tar constituents.

The selected remedy for removing the MGP residuals from the relief holder is an enhanced

recovery process. The enhanced recovery process involves injecting steam into the holder,

pumping tar and water out of the holder, separating the tar from the water, disposing of the tar,

heating the water and recycling it back through the holder. Once all separable tar has been

removed from the holder, the remaining water will be pumped from the holder, treated in an on

site water treatment system, and discharged to the Susquehanna River. The selected remedy for

the gas holder involves pumping the liquids out of the holder, treating with the on site water

treatment system and discharging them to the river.

The purpose of this SAP is to identify the tasks required to monitor and verify the recovery

of tar from the relief holder and to quantify and document the water treating and water discharge

processes. This SAP is presented in four sections: Section 1 is an introduction; Section 2 defines

the sampling objective; Section 3 describes the sampling procedures; and Section 4 discusses the

quality assurance objectives.

F:\PROJECTS\3-1612\DOCS\SAP2.PI_N 1-1 June 7, 1996AR400548

2.0 SAMPLING OBJECTIVES

The purpose of the SAP is to specify the manner in which to collect specific data on the

implemented remedy for holders at the Columbia Site. The data will be collected to meet data

quality standards for accuracy, precision, completeness, representativeness, and comparability as

defined in Section 4 of this document. The data will be used to monitor the performance of the

enhanced recovery system and the water treatment system.

2.1 Performance Sampling and Analytics

Performance analyses will occur before startup and after completion of the project. In

order to assess the initial composition of each holder, split spoon samples will be collected prior

to the construction of the removal system. Following remediation, and stabilization, an additional

set of split spoon samples will be collected and analyzed in order to quantify treatment

performance.

2.2 Process Monitoring

The objective of the process monitoring is to determine if the enhanced recovery system

is operating properly. Process monitoring, described in Section 3.1, will be performed to

determine if the operating parameters are within predefined ranges. Additionally, this monitoring

will aid in identifying any component of the system which may require adjustment. Process

monitoring includes monitoring electronic data and analyzing process fluid samples.

2.3 Process Sampling

The purpose of the process sampling is to characterize the liquids prior to discharge. The

results of the analyses of these samples will demonstrate that effluents are in compliance with the

substantive requirements of a National Pollutant Discharge Elimination System (NPDES) permit.

In order to demonstrate compliance, the sampling described in Section 3.2 will be performed.

F:\PROJECTS\3-1612\IXDCS\SAP2.PLN 2-1 June 7, 1996AR400549

2.4 Waste Characterization Sampling

The objective of the waste characterization sampling is to determine the quality of the coal

tar produced for recycling or disposal purposes. The coal tar will be sampled as described in

Section 3.5.

2.5 Health and Safety

All sampling and monitoring activities will be performed in such a manner as to protect

site workers and the public from exposure to the physical and chemical hazards at the site. All

on site activities will be in compliance with the Site-Specific Health & Safety Plan.

2.6 Monitoring Summary

Table 2-1 summarizes all of the field monitoring and sampling activities to take place

throughout the project.

F:\PROJECTS\3-1612\DOCS\SAP2.PLN 2-2 June 7, 1996AR400550

Table 2-1

Summaries of Field Monitoring and Sampling Activities

"f/.",.

^

Performance Sampling

Process Monitoring

Process Sampling

Waste CharacterizationSampling

s.-^i^^^^^^^^^^^l*^1:^?!,.; • '•;>;•: i*;* .»;;.;; • Frequency % & -:: ̂ pa. • •

Pre- and Post-Remediation

Daily by gauge readingsWeekly for analytics

Weekly

Before coal tar is removed fromthe site

:::.\Sv;;:>i?:J;̂ :-;;'S«. •• -P; ̂ ^^^'•."^k:'.^'H^;K^;?Pmv&^.'J"&^&.i

To evaluate remediationperformance

To optimize die treatmentprocess.

To demonstrate compliance withNPDES effluent limitations

To properly transport and disposeof coal tar


3.0 DATA GATHERING ACTIVITIES

Data will be gathered to monitor the treatment performance, the enhanced recovery process

and the water treatment process. Data from these processes will be gathered, by field personnel,

throughout the duration of the remediation. The pre and post-remediation data will be obtained

by analyzing soil samples for polynuclear aromatic hydrocarbons (PAHs) before and after

treatment. The majority of the process data will be temperatures, pressures, and flow rates from

various parts of the system. All of these data will be read from direct-reading gauges and meters.

These data will be recorded daily. Other data to be gathered will include analytical data on water

samples collected from various sample ports throughout the system. The water samples will be

analyzed for oil and grease (O&G) content and for total organic carbon (TOC). In addition, the

effluent from the water treatment system will be sampled and analyzed for an extensive list of

compounds including PAHs. The separated coal tar will also be sampled and analyzed for toxicity

(TCLP) before it is removed from the site.

This section identifies the required data gathering activities, identifies monitoring points

and sample ports, and discusses the water sampling details.

3.1 Holder Sampling and Analysis

Split spoon samples will be collected from each of the two holders before and after

remediation. All subsurface sampling will be performed in compliance with RETEC Standard

Operating Procedure (SOP) 210 (Soil Sampling and Subsurface Exploration) presented in

Appendix A. The samples will be collected at two foot intervals in five borings in each holder.

The relief holder will be sampled from 0 to 24 feet and the gas holder will be sampled from 0 to

14 feet. Therefore, a total of 60 samples will be collected from the relief holder and a total of 35

samples will be collected from the gas holder. Each sample will be analyzed for total PAHs using

the microscale solvent extraction (MSE) technique followed by GC/FID analysis. Ten percent

of these samples will be analyzed using EPA Method 8270. Similarly, after remediation is

complete, an equal number of samples will be recovered from each holder to determine the post

treatment content of each holder.

The general MSE approach for soil, as developed for EPRI, involves the extraction of 1

to 3 grams of soil with approximately 10 to 20 ml of a common solvent. Extractions are

performed using one of several shaking methods, sonication, or micro-soxhlet apparatus.

F:\PROJECTSU-1612\DOCS\SAP2.PLN 3-1 June 7, 19%AR400552

Concentration of the extracting solvent is performed using the Kuderna-Danish (KD) technique

or gentle evaporation. The concentrated extracts are analyzed by capillary column's GC Methods.

3.2 Process Sampling and Monitoring Locations

Ports for obtaining samples for oil & grease and TOC analyses as well as monitoring points

for temperature, pressure and flow rate will be integrated into the system.

Monitoring locations for temperature will be:

• at twelve points within the relief holder;

• at the top of the production well pumping column;

• within the separation vessel; and

• in the pipes flowing into the injection wells.

Monitoring locations for pressure will be:

• at four points within the relief holder;

• at the production wellhead;

• prior to the bag filters;

• prior to the first carbon adsorption unit; and

• within the pipes flowing into the injection wells.

Monitoring locations for flow rate will be:

• within the pump lines from the production wells;

• in the pipe flowing out of pump number 3 (the water out of the separationvessel); and

• in the lines flowing into the injection wells.

F:\PROJECTS\3-1612\DOCS\SAP2.PLN 3-2 June 7. 1996AR400553

Data on each of these parameters will be continually referenced and recorded on a daily

basis in the operations log. Sample ports and locations for oil & grease and TOC concentrations

will be:

• within the pump line before entering the separation vessel; and

• in the water line exiting the flow equalization tank.

Samples will be collected and analyzed from these locations at a frequency of once per

week. The locations of these monitoring points and sample ports are shown in the design plans.

A copy of the plans will be kept on site at all times.

3.3 Data Display Systems

Various data display systems will be utilized to record temperature, pressure, and flow

rates of all monitoring points described above. The systems will include inline indicators that are

wired to direct-reading gauges and meters. The system operator will read the gauges and adjust

the system as required. Mercury level switches will be utilized where appropriate to maintain

optimal tank levels. The system operator will be required to continually monitor the gauges until

the readings stabilize, at which point the gauges should be monitored at least twice per day. All

data collected from the system will be available upon request for U.S. EPA and PADEP review.

3.4 Process Water Sampling

Process water sampling will take place at four locations. The first location is in the pipe

prior to entering the separation vessel. The second location is in the pipe entering the boiler. The

third location is in the pipe after the first carbon adsorption unit. The fourth location is in the

discharging pipe after the second carbon adsorption unit. The analytical results of the samples

collected from the discharge pipe will serve to demonstrate compliance with NPDES effluent

limitations.

F:\PROJECTS\3-1612VDOCS\SAP2.PLN 3-3 June 7, 19%AR400554

•'V

The first two of these locations will be sampled on a weekly basis for TOC and oil and

grease. The line containing the third and fourth sampling locations will not be operating until the

final holder pump down occurs or at a time when production must exceed injection. Effluent will

not be discharged until a sample of the treated water has been analyzed and meets the discharge

criteria. Once discharge commences, samples will be collected from this line weekly. The

samples will be analyzed for VOC's by Method 8260. The discharge criteria associated with the

NPDES permit equipment are as follows:

Parameter

Naphthalene

Benzene

Monthly Average

Values Oig/L)

50

10

Measurement

Frequency

2/month

2/month

Sample Type

GRAB

GRAB

A copy of the effluent limitations letter from PADEP is included in Appendix D.

Table 3-1 provides a summary of analytical samples.

3.5 Waste Characterization Sampling

The coal tar that is recovered from the holders will be analyzed for toxicity (TCLP), flash

point, and BTU content prior to removal from the site for recycling or incineration. The

analytical methods for these analyses are listed in Table 3-2.

F:\PROJECTS\3-1612\DOCS\SAP2.PLN 3-4 June 7, 19%AR400555

I I I

TABLE 3-1SUMMARY OF ANALYTICAL SAMPLES

Location

Relief Holder

Relief Holder

Gas Holder

Gas Holder

Tar Storage Tank

Tar Storage Tank

Tar Storage Tank

CA Uni t# l Line

Water Discharge Line

Production Line

Production Line

Injection Line

Injection Line

Number of:vSamples

60

6

35

4

1

1

1

3-30

3-30

30

30

30

30

Matrix

Soil

Soil

Soil

Soil

Tar/Water

Tar/Water

Tar/Water

Water

Water

Water

Water

Water

Water

AnalyticalParameters

PAH

PAH

PAH

PAH

TCLP

BTU

Flash Point

VOCs

VOCs

TOG

Oil&Grease

TOG

Oil&Grease

Method

MSB

8270

MSB

8270

8240//H

405.1

1010

8260

8260

9060A

413.2

9060A

413.2

.-" •••" ", ' ;- ' Rationale •'••' /. "• ' : ;

Characterize Holder

Confirmation

Characterize Holder

Confirmation

Determine Hazardous Characteristics

Determine Fuel Potential

Determine Flammability

Monitor CA Effectiveness

Demonstrate Compliance

Process Monitoring

Process Monitoring

Process Monitoring

Process Monitoring

Additional field screening will be performed for total and dissolved iron and for pH. The results of these analyses will be used tooperate the iron removal system.

AR400556

TABLE 3-2ANALYTICAL REFERENCES

Analysis

PolynuclearAromatic Hydrocarbons

PolynuclearAromatic Hydrocarbons

Oil and Grease

Volatile Organic Compounds

Total Organic Carbon

BTU Content

TCLP

Flash Point

Media

Soil

Soil

Water

Water

Water

Tar

Tar

Tar

• : • ' / 'i Method ;:':;/v • : ' . • ' : • • .

Microscale SolventExtraction

EPA Method 8270

EPA Method 4 13.2

EPA Method 8260

EPA Method 9060A

ASTM D2382-76EPA Method 405.1

EPA Method8240/H

EPA Method 1010

v Container

4 oz. glass jar,teflon-lined cap

1 liter amber glass,teflon-lined cap


40 ml glass vial,teflon septum

8 oz. glass jar,teflon septum


40 ml glass vial,teflon septum

8 oz. glass

.:;•••/ No. of";.;,:••; Containers

1

2

1

3

1

1

3

1

: Preservative

Cool to 4°C

Cool to 4°C

Cool to 4°C

HCltopH <2Cool to 4°C

H2SO, topH <2Cool to 4°C

Cool to 4°C

Cool to 4°C

None

Holding Tune

7 days (extraction)40 days (ajialysis)

7 days (extraction)40 days (analysis)

28 days

10 days

14 days

NA

14 days

None

AR400557

3.6 Reid Quality Assurance Sampling

When samples are collected for chemical analysis, as described above, field quality

assurance samples will be collected to document the accuracy and precision of sampling. Field

quality assurance samples to be collected will include the following:

• Trip Blanks: Trip blanks will be collected for volatile organic compounds

(VOC) samples only, and consist of HPLC grade water in sealed 40 ml

VOA vials, and will accompany sample containers to and from the field.

These samples are used to detect any cross-contamination of samples to be

analyzed for VOCs during handling and transportation. Trip blanks will be

prepared and analyzed at a rate of one sample per laboratory per cooler.

• Field Duplicates: Field duplicates will be collected to document precision.

The precision resulting from field duplicates is a function of the variance

of waste composition, the variance of the sampling technique, and the

variance of the analytical technique. One duplicate sample will be collected

per analyte for every 4 sampling events.

• Matrix Spikes: These samples are laboratory quality assurance samples

which require field collection of double sample volume. The purpose of

the analysis of matrix spikes is to provide accuracy and precision data on

the analytical method. These samples will be collected and analyzed for

VOCs at one per 8 sampling events.

3.7 Decontamination

Decontamination of all materials, equipment, and personnel will be in accordance with

RbT.bC SOP 120 (Decontamination) presented in Appendix B and the Site-Specific Health and

Safety Plan.

F:\PROJECTS\3-1612\DOCS\SAP2.PLN 3-8 June 7, 1996

AR400558

3.8 Sample Handling

3.8.1 Field Sample Handling

All field sample handling, including packaging, shipping and chain-of-custody procedures,

will be carried out in accordance with RETEC SOP 110 in Appendix C of this document. A brief

summary of these procedures is presented below.

Samples will be protected from breakage and shipped in coolers. Each cooler will be

sealed with chain-of-custody tape, so that any opening of the cooler during shipment will be

indicated. Ice (or equivalent) will be used to maintain a temperature of 4°C. A carrier will be

selected which will insure delivery to the laboratory within 24 to 36 hours after collection.

In addition to coal tar, small quantities of other wastes will be generated on site. These

wastes will include common refuse including boxes, wrappings, food wastes, paper towels, etc.

These items, if determined to be uncontaminated by visual inspection, will be collected in a

dumpster and hauled to a local, licensed solid waste landfill. A permit for the transport and

disposal of these items is not needed. Other wastes .generated on-site may include cuttings from

soil borings and used personal protective equipment (PPE). These materials will be collected

separately and characterized for disposal. To appropriately manifest the contaminated cuttings,

a provisional Generator I.D. number will be used.

3.8.2 Sample Preparation and Analysis

Table 3-2 presents analytical methods to be used for laboratory chemical analyses, along

with description of sample containers, preservation methods, and allowable holding times.


4.0 QUALITY ASSURANCE OBJECTIVES

Quality assurance objectives are established to ensure that the measurement data is of

known and acceptable quality for the intended data use. The data generated during the removal

action will be used for the following purposes:

• assessment of the initial composition of each holder;

• assessment of the final composition, and PAH content, of each holder following

removal and stabilization;

• assurance that the coal tar removal system is operating properly;

• demonstration that water from the site water treatment system meets NPDES

requirements for discharge to the Susquehanna River; and

• characterization of coal tar removed from the holders for disposal.

In order to met the objectives listed above, data collected during removal activities will be

evaluated in terms of five parameters which are discussed below.

PRECISION

Precision measures that reproducibility of measurements under a given set of conditions.

Specifically, it is a quantitative measure of the variability of a group of measurements compared

to their average value. Precision is usually stated in terms of standard deviation, but other

estimates such as the coefficient of variation, range, and relative range are common. Most EPA

analytical methods have established standards of precision included in the method. The precision

of other methods should be expressed as relative percent difference (RPD):

RPD = ((Xi- X^ / (Xt + Xj)) x 200

where: Xj = first duplicate value, and

X2 = second duplicate value.

The RPD for analytical methods associated with the removal action is < 20 % .

F:\PROJECTS\3-1612\DOCS\SAP2.PLN 4-1 June 7, 1996

AR400560

ACCURACY

Accuracy measures the bias in a measurement system; it is difficult to measure for the

entire data collection activity. Sources of error are the sampling process, field contamination,

preservation, handling, sample matrix, sample preparation and analysis techniques. Sampling

accuracy may be assessed by evaluating the results of field/trip blanks, analytical accuracy may

be assessed through use of known and unknown QC samples and matrix spikes.. Accuracy should

be expresses as a percent of recovery (P):

P = ((SSR-SR) / (SA)) x 100

where: SSR = spiked sample result,

SR = native sample result, and

SA = spike added.

The percent of recovery (p) for the analytical methods associated with the removal action is 80% -

120%.

REPRESENTATIVENESS

Representativeness expresses the degree to which sample data accurately and precisely

represent a characteristic of a population, parameter variations at a sampling point, or an

environmental condition. Representativeness criterion is best satisfied by making certain that

sampling locations are selected properly and a sufficient number of samples are collected.

COMPLETENESS

Completeness is defined as the percentage of measurements made which are judged to be

valid measurements. The completeness goal is essentially the same for all data uses: That a

sufficient amount of valid data be generated. It is important that critical samples are identified

and plans made to achieve valid data for them. EPA Guidance (EPA, 1988) has identified 80%

as a historically achievable level of completeness.

COMPARABILITY

Comparability is a qualitative parameter expressing the confidence with which one data set

can be compared with another. Sample data should be comparable with other measurement data

F:\PROJECTS\3-1612YDOCS\SAP2.PLN 4-2 June 7, 1996AR400561

for similar samples and sample conditions. This goal is achieved through using standard

techniques to collect and analyze representative samples and reporting analytical results in

appropriate units.

F:\PROJECTS\3-1612\DOCS\SAK.PLN 4-3 June 7, 1996AR400562

oration

AR400563

SOP No: 2:0Rev. Date: 9/01/95

Rev. By: LDN/AMC

SOP 210

SOIL SAMPLE COLLECTION

1.0 PURPOSE AND APPLICABILITY

This SOP describes the methods used in obtaining soil samples for physical testing,

stratigraphic correlations, and chemical analysis. Soil samples are obtained in conjunction with

surface sampling, test pit excavation, soil boring, and monitoring well installation programs.

These procedures provide direct information as to the physical makeup of the surface and

subsurface environment as well as to estimate the extent and magnitude of soil contamination, if

present. This SOP will discuss sampling of the surface material with hand tools and sampling of

the subsurface material by augers and split spoons, and within test pits by backhoes and hand

tools.

Specific project requirements as described in an approved Work Plan, Sampling Plan,

Quality Assurance Project Plan, or Health & Safety Plan will take precedence over the procedures

described in this document.

2.0 RESPONSIBILITIES

The project geologist/engineer will be responsible for the proper use and maintenance of

all types of equipment used for obtaining soil samples. The geologist/engineer will determine the

location, total depth, and overall size of each surface sample collection point and test pit, and the

location and depth of all subsurface borings based on the project specific sampling plan. The

project geologist/engineer will be responsible for locating any subsurface utilities or structures,

and disseminating this information to the contractor prior to commencing the sampling program.

The location of overhead utilities and obstructions relative to the sampling locations will also be

noted.

It shall be the responsibility of the project geologist/engineer to observe all activities

pertaining to soil sampling and subsurface investigations to ensure that all the standard procedures

1 of 13AR400564

SOP No: 210Rev. Date: 9/01/95

Rev. By: LDN/AMC

are followed properly, and to record ail pertinent data on a field log or field book. The collection,handling and storage of all samples will be the responsibility of the geologist/engineer.

It is the responsibility of the contractors to provide the necessary equipment for obtainingsubsurface samples in borings and for the decontamination of the equipment. Test pitconstruction, split-spoon sampling, and subsurface augering will be conducted by the contractor.In addition, the contractor will be responsible for containment of cuttings, if required.

3.0 SUPPORTING MATERIALS

In addition to materials provided by the contractor, the geologist/engineer will provide:

• Sample bottles/containers and labels;

• Boring or test pit logs;

• Field notebook;

• Chain-of-custody forms;

• Depth-measurement device;

• Stakes and fluorescent flagging tape;

• Decontamination solutions;

• Camera for photographing sections;

• Sampling equipment (e.g., knives, trowels, shovels, hand auger, aluminumfoil, etc); and

• Plastic garbage bags.

2 of 13AR400565

SOP No: 210Rev. Daw: 9/01/95

Rev. Bv: LDN/AMC

4.0 METHODS AND PROCEDURES

Specific sampling equipment and methodology will be dictated by the characteristics of the

soil to be sampled, the type of soil samples required, and by the analytical procedures to be

employed. Soil samples obtained at the surface may be collected using a shovel, trowel, or hand

auger. A hand auger can be used to extract shallow soil samples up to 10 feet below the surface.

Sampling to obtain uniform coverage within a specified area will often require the use of an area

grid. These considerations will be followed based upon project specific requirements.

There are two types of samples that may be required by the project sampling plan: grab

or composite. A grab sample is collected from a specific location or depth and placing it in the

appropriate sample container. A composite sample consists of several discrete locations (or

depths) mixed to provide a homogeneous, representative sample. To ensure that the sample is

representative, the soil volume and collection method from each discrete location should be as

identical as possible. It should be noted that samples analyzed for volatile organic compounds

cannot be composited since it is necessary to expose the soil to the atmosphere prior to transfer

into the sample container.

The sampling depth interval in borings is typically one sample for every five feet with

additional samples taken at the discretion of the project geologist/engineer when significant color,

textural, or odor changes are encountered. Deviations in the standard operating procedure will

be covered in the project specific operating procedures.

Most subsurface explorations by RETEC will be on privately owned land, often an

industrial facility. Prior to commencing subsurface exploration, RETEC will work with the

facility manager to locate any subsurface utilities or structures. Utility companies (electric, gas,

water, phone, sewer, etc.) who may have equipment or transmission lines buried in the vicinity

will also be notified. Many regions have organizations which represent all utilities for these

notification purposes. Allow enough time after notification (typically three working days) for the

utilities to respond and provide locations of any equipment which may be buried on site.

Overhead lines must also be kept in consideration when a drilling rig is used. As a rule of thumb,

the rig and derrick should be at least 25 feet away from overhead lines unless special shielding and

grounding are provided.

3 of 13AR400566


Rev. By: LDN/AMC

4.1 General Applications

General locations shall be mapped by the field geologist/engineer using a stationary

structure as the reference point. Specific locations for test pits and sampling locations will be

documented by survey or by using topographic maps and/or plans. A preliminary log of the test

pit, or boring shall be prepared in the field by the field geologist/engineer. A sketch of the test

pit may be necessary to depict the strata encountered. Before measuring the depth to groundwater,

if encountered, the field geologist/engineer will allow sufficient tune for stabilization of the water

table in the excavation or boring. All information shall be recorded on the field log or the field

book.

4.2 Surface Sampling

Prior to surface sampling, remove all surface materials that are not to be included hi the

sample such as rocks, twigs, and leaves. For sample collection within the upper two to three feet

use a shovel or trowel. A hand auger may be used to depths of up to 10 feet. When using the

hand auger, auger the hole to the required depth, then slowly remove the auger and collect the soil

sample from the auger flight or auger bucket at the point corresponding to the required depth. A

tube sampler can be attached to the auger rods after augering to the desired depth, inserted into

the open borehole, and then advanced into the soil at the base of the boring. If sampling is hi

sandy or non-cohesive soil, a shovel may be necessary to collect samples. Sample logging is

described hi Section 4.5.

Photographs of specific geologic features or sample location may be required for

documentation purposes. A scale or item providing a size perspective should be placed hi each

photograph. The frame number and picture location shall also be documented in the field book.

All equipment shall be decontaminated following SOP 120 between sample locations unless

otherwise specified in the project specific sampling plan.

4 of 13AR400567


Rev. By: LDN/AMC

4.3 Test Pit Excavation and Sampling

The test pits shall be excavated in compliance with applicable safety regulations. Walls

should be cut as near vertical as possible to facilitate stratigraphic logging. Field personnel will

not enter an open test pit deeper than four feet without shoring or benching present. Samples shall

be collected from the backhoe bucket with a trowel or from the side of the test pit wall (depending

upon the depth of the test pit and the safety precautions hi place). The size, depth, and orientation

of the test pit shall be recorded on the test pit log (Figure 1). Sample logging is described in

Section 4.5.


documentation purposes. A scale or item providing a size perspective should be placed in each


The test pit shall be inspected and the test pit log reviewed to ensure that all the appropriate

and/or required data and samples have been collected. All test pits will be backfilled to original

grade and compacted. All equipment shall be decontaminated following SOP 120 between sample

locations unless otherwise specified in the project specific sampling plan.

4.4 Subsurface Sampling

Borings are typically advanced by two methods: rotary drilling and augering. The casing

shall be of the flush-joint or flush-couple type and of sufficient size to allow for soil sampling,

coring, and/or well installation. All casing sections shall be straight and free of any obstructions.

Hollow-stem augers or solid-flight augers with casing may be used according to specific project

requirements. Rotary drilling with water, mud, or air may be used hi dense or indurated

formations to advance to the required sample depth where a split spoon sampler or a coring device

will be used to obtain the sample. Recircuiated water shall not be used when casing is being

driven unless specified hi project specific sampling plans and/or directed and properly documented

by the field geologist/engineer. If recirculated water is used, all loose material within the casing

shall be removed by washing to the required sampling depth using a minimum amount of water.

Care should be taken to limit recirculation of the wash water to those tunes when the water supply

5 of 13AR400568

REMEDIATION TTST PFT T Ctr TEST PITTECHNOLOGIES, INC 1U-O1 ril l^Uijr SHEET OF

ntoiEcr DATE CONTBJLCTO*

ratoitcr* si

LOCAHON LOCdDBY TOTAL DDTH

MMAKB:

SAMPLE

NAME

l

DEPTHRANGEFEET

HEAD-SPACE

TEST PIT PLAN

A

DOTHFZET

•- 2

— 3

•• 4

•• 5

•• 6

~ 7

•• 8

•— 9

— 10

^ 11

-• 12

*—

SOIL AND ROCKDESCRIPnON & COMMENTS

—

NORTH GROUNDWATER

6 of 13 FIGURE 1

AR400569

SOP No: 210Rev. Dace: 9/01/95

Rev. By: LDN/AMC

is extremely limited or unavailable. The amount of water used should be documented in the

project field book or on the field form.

Generally subsurface soil samples shall be obtained using a split-tube type sampler (split

spoon), however, other devices (Shelby tubes, core, etc.) may be used as specified in the project

specific sampling plan. Split-spoons come in a variety of sizes with the most standard having a

2-inch OD, a 1 3/8-inch ID and a 24-inch long barrel with an 18-inch sample capacity. Split

spoons shall be equipped with a check valve at the top and a flap valve or basket-type retainer at

the bottom. Samples shall be obtained using the standard penetration test (SPT), which allows for

qualitative determination of mechanical properties and aids hi identification of material type. The

number of hammer blows shall be recorded on the boring log (Figure 2) for each 6-inch drive

distance.

The split spoon shall be opened immediately upon removal from the casing. If the

recovery is inadequate (i.e., most of the penetrated material was not retained inside the sampler),a

note will be made on the boring log stating that "no recovery" was possible at that depth. In the

event that gravels or other material prevent penetration by the split spoon, samples may be

collected from the auger flights. Slowly remove the auger and collect the sample at the point

corresponding to the required depth. Samples collected in this manner must be documented on

the boring log. Sample logging is described hi Section 4.5.


documentation purposes. A scale or item providing a size perspective should be placed hi each


All equipment will be decontaminated following SOP 120 between sample locations and sample

depths unless otherwise specified in the project specific sampling plan.

Upon completion of the boring, backfill may be required. The backfill may consist of

native material, hydrated bentonite chips/pellets, portland cement/bentonite grout, or other low

permeability material as specified in the project specific sampling plan. All applicable

state/federal regulations concerning plugging of boreholes should be reviewed prior to the

commencement of field activities.

7 of 13AR400570

51 ITREMEDIATION

TECHNOLOGIES, INC. BORING LOGBORING

OF

PROJXCT CUNXltAClUU

LOCATION BIGTYPX

lUIALUUCf 1H MTTHOD RLZZBPACX

DA.TX

5ZAXT BOBWCID csocrr

1XXX3DBY BTTTVK

SAMPLZ

TVPEAMD

.VUMBER

BLOWS7CR

CINCH

DtTTHRANGE

DEPTHFEET 1AMTX DESCRIPTION

CLASSDICATION SCflEME_

GROUNDWATER DEPTH (FT) DATE/TIMEREMARKS:

8 of 13 FIGURE 2

AR400571

SOP No: 210Rev. Daa: 9/01/95

Rev. By: LDN/AMC

4.5 Sample Logging

To ensure consistent descriptions of soil or rock material, the following criteria should be

included on the sampling logs:

• Soil or rock type;

• Depth ranges, recorded in feet;

• Grain size;

• Roundness;

• Sorting;

• Moisture;

• Color;

• Degree of oil contamination; and

• Remarks.

Examples of soil types would be gravel, sand, silt, or clay. The soil types should be based

on the Unified Soil Classification System (USCS). Figure 3 shows the USCS table. Examples

of rock types include limestone, shale, claystone, siltstone, and sandstone. Soil/rock

classifications determined in the field may be subject to change based upon laboratory tests.

Factors to consider before changing a field determination include the expertise of the field

geologist/engineer and laboratory personnel, representative character of the tested sampling,

labelling errors, etc. Any changes made after this consideration shall be discussed and

incorporated in the project report.

Grain size, roundness, and degree of sorting should also be included on the log if they are

discernable. Field guides such as the Geotechnical Gauge (Figure 3) are available to assist in

determining these properties. In addition to composition, blow counts and the length of the

sample recovered should also be recorded on the sampling log. The degree of sample moisture

should be described as dry, moist, and wet.

9 of 13AR400572

--•I

FIELD GUIDE AND USCS CLASSIFICATION TABLE

oo

j U

|]H

slt

ffjipiisllSili

I

i;at§5

il}mi

a a

BOULDERS

COBBLES

ORAVEL:COARSE

FINE

SAND:COARSE

MEDIUM

FINE

FINES:SILTS

CLAYS

Unified Soil Classification System (USCS)

Ii!

MILLIMETERS

> 300

75 - 300

75 - 19

19 - 4.8

4.8 - 2.0

2.0 - .43

.43 - .08

< .08< .08

INCHES

> 11.8

2.9 - 11.8

2.9 - .75

.75 - .19

.19 - .08

.08 - .02

.02 - .003

< .003< .003

SIEVE SIZES

-

-

-

3/4' - No. 4

No. 4 - No. 10

No. 10 - No. 40

No. 40 - No. 200

< No. 200

< No. 200

&wiH=f:^

i i i i i iOmm 10 KQ 3D <O BO I I I I I_ro mo 00 100 110

e o t e c h n l c a la u g ell ki:

W . f . M t C . l l t u . KI I I ! f l k i l t f i l lllHl.llll, llD HHI

L!

I X 1 5 X J 5 X 4 0 X

MAJOR DIVISIONS SYMBOL

COARSEGRAINED

SOILS

wnnuiitLAMUTHAHHa•OUCVlMt

FINEGRAINED

SOILS

MM nun M* or

GRAVELAND

GRAVELLYSOILS

•DM mumorcoutunuc-

GW

GP

QM

GC

SANDAND

SANDYSOILS

MOM THAN m OfcoAMinuenoN

WQ wx 4

sw

SP

SM

SC

ML

SILTSAND

CLAYS

TYPICAL DESCRIPTIONS

WIU-OMMDIVUVtU.ouvn. - too mruiu,

OMHO aiumi- UK) mnim.

unuaoamn

HIT UUtftU, QMVtt . 1AMlunnvui

Will - MWCD MWl OMVUI•AIM. umi on w> nm

romtn - OMMO HUM, auv

cunt WJM, uac • cutWXTVKf.

VMX, HOCKman rutun «™ wow

noun JUT oi«JUBI b* curnow KJunatt.

cuvt of IM lawnuH rturcm. OIUVIUTam, umn cun. un

OKUM: mil uto OMUCun aiti tf un rutm

HOWUJIC un, Huaoui o*CUTOIUIOUI mi uwmnrrtoii

HIGHLY ORGANIC SOILS

Mwcmr.n

O*UMC cun or HMM toMH putnan. OMAMCun.

Oll» Oil)

Out a«i

FIGURE 3

AR400573

SOP No: 210Rev. Daw: 9/01/95

Rev. By: LDN/AMC

The color(s) or range of color(s) of the soil or rock type should be defined. If a Munsell

color chart is used, the number designation of the color will also be recorded in the description.

A notation of the degree of oil coma mi nation should be included on the sample log. The

contamination should be noted as high (i 30 %), medium (10-30 %), low (1-10 %), or none.

Other classifiers may include odor (low to high) and mottling (low to high).

Remarks should include anything pertinent to the sample description or sample collection

that is not described above. Other information to be placed on the logs as appropriate is:

• HNU readings;

• Appearance of contamination (consistency);

• Degree of fracturing or cementation in the rock;

• Drilling equipment used (rod size, bit type, pump type, rig manufacturerand model, etc.);

• Special problems and their resolution (hole caving, recurring problems ata particular depth, sudden tool drops, excessive grout takes, drilling fluidlosses, lost casing, etc.);

• Dates for start and completion of borings;

• Depth of first encountered free water; and

• Definitions of special abbreviations used on log.

4.6 Sample Handling

Specific procedures pertaining to the handling and shipment of samples shall be hi

accordance with SOP 110. A clean pair of gloves and decontaminated sampling tools will be used

when handling the samples during collection to prevent cross contamination. A representative

11 of 13AR400574


Rev. By: LDN/AMC

sample will be placed in the sampling container. Sample containers (jars or bags) shall be labelled

with the following information:

• Client or project name, or unique identifier, if confidential;

• Unique sample description (i.e., test pit, boring, or sampling point numberand horizontal/vertical location);

• Sample collection date and time;

• Sampler's name or initials; and

• Analyses to be performed.

These data shall be recorded on the field logs and/or field book. Larger, bulk samples

shall be placed in cloth bags with plastic liners or plastic 5-gallon buckets. Sample bags shall be

marked with the information listed above.

5.0 QUALITY ASSURANCE/QUALITY CONTROL

QA/QC requirements include, but are not limited to, blind field duplicates, blind rinsate

blanks, and blind field blanks. These samples will be collected on a frequency of one QA/QC

sample per 10 field samples or a minimum of one QA/QC sample per day unless otherwise

specified in the project specific sampling plan.

6.0 DOCUMENTATION

Documentation may consist of all or part of the following:

• Test pit or boring log;

• Sample log sheets;

• Field log book;

12 of 13AR400575


Rev. By: LDN/AMC

• Chain-of-custody forms; and

• Shipping receipts.

All documentation shall be placed in the project files and retained following completion of the

project.

REFERENCES

Handbook of Suggested Practices for the Design and Installation of Ground-Water Monitoring

Wells, EPA 600/4-89/034, published by National Water Well Association, 1989.

RCRA Ground Water Monitoring Technical Enforcement Guidance Document, published by

National Water Well Association, 1986.

A Compendium of Superfund Field Operations, EPA 540/P-87/001, published by the Office of

Emergency and Remedial Response, Office of Waste Programs Enforcement, US EPA, 1987.

13 of 13AR400576

APPENDIX B

SOP 120: Decontamination

AR400577


Rev. By: LDN/AMC

SOP 120

DECONTAMINATION


This SOP describes the methods to be used for the decontamination of items which may

become contaminated during field operations. Decontamination is performed as a quality

assurance measure and as a safety precaution. It prevents cross-contamination between samples

and also helps maintain a clean working environment. The equipment requiring decontamination

may include hand tools, monitoring and testing equipment, personal protective equipment, or

heavy equipment (e.g., loaders, backhoes, drill rigs, etc.).

Decontamination is achieved mainly by rinsing with liquids which may include: soap

and/or detergent solutions, tap water, distilled water, and methanol. Equipment may be allowed

to air dry after being cleaned or may be wiped dry with paper towels or chemical-free cloths.

All sampling equipment will be decontaminated prior to use and between each sample

collection point. Waste products produced by the decontamination procedures such as rinse

liquids, solids, rags, gloves, etc. will be collected and disposed of properly based on the nature

of contamination and site protocols. Any materials and equipment which will be reused must be

decontaminated or properly protected before being taken off site.

Specific project requirements as described in an approved Work Plan, Sampling Plan,

Quality Assurance Project Plan, or Health & Safety Plan will take precedence over the procedures

described in this document.


It is the responsibility of the field sampling coordinator to ensure that the proper

decontamination procedures are followed and that all waste materials produced by decontamination

are properly managed. It is the responsibility of any subcontractors (e.g., drilling or sampling

1 of 4 AR400578

SOP No: 120Rev. Da»: 9/01/95

Rev. By: LDN/AMC

contractors) to follow the proper designated decontamination procedures that are stated in theircontracts and outlined in the project health and safety plan. It is the responsibility of all personnelinvolved with sample collection or decontamination to maintain a clean working environment andto ensure that no contaminants are negligently introduced into the environment.


The following materials should be on hand in sufficient quantity to ensure that properdecontamination methods and procedures may be followed:

• Cleaning liquids and dispensers (soap and/or detergent solutions, tap water,distilled water, methanol, or isopropyl, etc.);

• Personal safety gear, as defined hi the project health and safety plan;

• Paper towels or chemical-free cloths;

• Disposable gloves;

• Waste-storage containers (e.g., drums, boxes, plastic bags);

• Drum labels, if necessary,

• Cleaning containers (e.g., plastic and/or galvanized steel pans or buckets);

• Cleaning brushes; and

• Plastic sheeting.


The extent of known contamination will determine the degree of decontamination required.If the extent of contamination cannot be readily determined, cleaning should be done accordingto the assumption that the equipment is highly contaminated.

2 of 4AR400579

SOP No: 120Rev. Datt: 9/01/95

Rev. By: LDN/AMC

The standard procedures listed below describe the method for foil field decontamination.

If different technical procedures are required for a specific project, they will be spelled out in the

project plans. Such variations hi decontamination may include all or an expanded scope of the

decontamination procedure stated herein.

• Remove gross contamination from the equipment by brushing and thenrinsing with tap water.

• Wash with a detergent or soap solution (e.g., Aiconox and tap water).

• Rinse with tap water.

• Rinse with methanol or isopropyl.

• Rinse with distilled water.

• Repeat entire procedure or any parts of the procedure as necessary.

• After decontamination procedure is completed, avoid placing equipmentdirectly on ground surface to avoid re-contamination.o-1

Downhole drilling equipment, such as augers, split spoons, Shelby tubes, and sandlines,

will be decontaminated with a pressurized hot water or steam wash followed by a fresh water

rinse. No additional decontamination will be required if the equipment appears visually clean.

If contamination is visible after hot water/steam cleaning, a detergent wash solution and brushes

(if necessary) will be used.


To assess the adequacy of decontamination procedures, rinsate blanks should be collected

and analyzed for the same parameters as the field samples. The specific number of blanks will

be defined in the project specific sampling plan. In general, one rinsate blank will be collected

per ten samples.

3 of 4AR400580


Rev. By: LDN/AMC

6.0 DOCUMENTATION

Field notes describing the procedures used to decontaminate equipment/personnel and tocollect the rinsate blanks will be documented by on-site personnel. These field notes will be keptin the project files.

4 of 4AR400581

:.•;•••',: :j^-\:];.;?:;;'APPENDIX cvr .:f -

:(M^- •••

SOP 110: Packaging and Shipment of Samples

AR400582


Rev By: LDN/AMC

SOP 110

PACKAGING AND SHIPMENT OF SAMPLES


This SOP describes proper packaging methods and shipment of samples to: (a) minimize

the potential for sample breakage, leakage, or cross contamination, and (b) provide a clear record

of sample custody from collection to analysis. Specific project requirements as described in an

approved Work Plan, Sampling Plan, Quality Assurance Project Plan, or Health & Safety Plan

will take precedence over the procedures described in this document.

The EPA RCRA regulations (40 CFR Section 261.4 [d]) specify that samples of solid

waste, water, soil, or air collected for the purpose of testing are exempt from regulation when any

of the following conditions apply:

• Samples are being transported to a laboratory for analysis;

• Samples are being transported to the collector from the laboratory after analysis;

• Samples are being stored: (a) by the collector prior to shipment for analyses, (b)by the analytical laboratory prior to analyses, or (c) by the analytical laboratoryafter testing but prior to return of sample to the collector or pending the conclusionof a court case.

Samples collected by RETEC are generally qualified for these exemptions. This SOP deals only

with these sample types.


The field sampling coordinator is responsible for the enactment and completion of the

chain-of-custody and the packaging and shipping requirements outlined here and in project specific

sampling plans.

1 of 8AR400583


Rev By: LDN/AMC


The following materials must be on hand in sufficient quantity to ensure that proper

packaging and shipping methods and procedures may be followed:

• Chain-of-custody forms and tape;

• Sample container labels;

• Coolers or similar shipping containers;

• Duct tape or transparent packaging tape;

• Zip-lock type bags;

• Protective wrapping and packaging materials;

• Ice or cold packs;

• Shipping labels for the exterior of the ice chest; and

• Transportation carrier forms (Federal Express, Airborne, etc.).


All samples must be packaged so that they do not leak, break, vaporize, or cause cross-

contamination of other samples. Waste samples and environmental samples (e.g., groundwater,

soil, etc.) should not be placed in the same container. Each individual sample must be properly

labeled and identified. Each shipping container must be accompanied by a chain-of-custody

record. When refrigeration is required for sample preservation, samples must be kept cool during

the time between collection and final packaging.

All samples must be clearly identified immediately upon collection. Each sample bottle

label (Figure 1) will include the following information:


2 of 8

AR400584

R E M E D I A T I O NT E C H N O L O G I E S I N C

23 Old Town SquareSuite 250

Ft. Collins, CO 80524(303) 493-3700

Fax* (303) 493-2328

SAMPLE l.D.

LOCATION _

DATE TIME SAMPLED BY

TEST(S)_

PRES.

SAMPLE LABEL FIGURE 1

3 of 8AR400585

SOP No: 110Rev. Dale: 9/01/95

Rev By: LDN/AMC

• A unique sample description;

• Sample collection date and time;

• Sampler's name or initials;

• Indication of filtering or addition of preservative, if applicable; and

• Analyses to be performed.

After collection, identification, and preservation (if necessary), the samples will be

maintained under chain-of-custody procedures as described below.

4.1 Chain-of-Custody

A sample is under custody if it is in one's possession, in one's view, or in a designated

secure area. Transfers of sample custody must be documented by chain-of-custody forms (Figure

2). The chain-of-custody record will include, at a minimum, the following information:


• Sample collector's name;

• Company's (RETEC) mailing address and telephone number;

• Designated recipient of data (name and telephone number);

• Analytical laboratory's name and city;

• Description of each sample (i.e., unique identifier and matrix);

• Date and time of collection;

• Quantity of each sample or number of containers;

• Type of analysis required; and

• Date and method of shipment.

4 of 8AR400586

CUSTODY SEALDATE

O•-f>

OoSIGNATURE

SEAL NO.

R E M E D I A T I O NT E C H N O L O G I E S I N C

REMEDIATION TECHNOLOGIES23 Old Town Square

Suite 250Ft. Collins, CO 80524

J303) 493-3700Fax* (303) 493-2328

CHAIN OF CUSTODY SEAL FIGURE 2

AR400587


Rev By: LDN/AMC

Additional information may include type of sample containers, shipping identification airbill

number, etc.

When transferring custody, both the individual(s) relinquishing custody of samples and the

individual(s) receiving custody of samples will sign, date, and note the time on the form. If

samples are to leave the collector's possession for shipment to the laboratory, the subsequent

packaging procedures will be followed.

4.2 Packaging for Shipment

To prepare a cooler for shipment, die sample bottles should be inventoried and logged on

the chain-of-custody form. At least one layer of protective material should be placed in the

bottom of the container. As each sample bottle is logged on the chain-of-custody form, it should

be wrapped with protective material (e.g. bubble wrap, matting, plastic gridding, or similar

material) to prevent breakage. Each sample bottle should be placed upright in die shipping

container. Each sample bottle cap should be checked during wrapping and tightened if needed.

Avoid overtightem'ng, which may cause bottle cap to crack and allow leakage. Additional

packaging material such as bubble wrap or styrofoam pellets should be spread throughout the

voids between the sample bottles.

Most samples require refrigeration as a minimum preservative. Reusable cold packs or

ice placed in heavy duty zip-lock type bags should be distributed over the top of die samples.

Two or more cold packs or bags should be used. Additional packing material should dien be

placed to fill the balance of the cooler or container.

Place the original completed chain-of-custody record in a zip-lock type plastic bag and

place die bag on die top of die contents widiin the cooler or shipping container. Alternatively,

the bag may be taped to the underside of die container lid. Retain a copy of the chain-of-custody

record with die field records.

Close die top or lid of die cooler or shipping container and rotate/shake die container to

verify that the contents are packed so that mey do not move. Add additional packaging if needed

and reclose.

6 of 8AR400588

SOP No: 110Rev. Dare: 9/01/95

Rev By: LDN/AMC

Place signed and dated chain-of-custody tape (Figure 3) at two different locations (front

and back) on the cooler or container lid and overlap with transparent packaging tape. The chain-

of-custody tape should be placed on the container in such a way that opening the container will

destroy the tape. Packaging tape should encircle each end of the cooler at the hinges.

Sample shipment should occur via an overnight express service that can guarantee 24-hour

delivery. Retain copies of all shipment records as provided by the shipper.


Recipient of sample container should advise shipper and/or transporter immediately of any

damage to container, breakage of contents, or evidence of tampering.

6.0 DOCUMENTATION

The documentation for support of proper packaging and shipment will include RETEC's

or the laboratory's chain-of-custody records and transportation carrier's airbill or delivery invoice.

All documentation will be retained in the project files.

7 of 8AR400589

OO

O•-n00

REMEDIATION TECHNOLOGIES23 Old Town Squait Sit 250

Ft Collins. CO 80521(303) 493-3700

Fax(303)493 2328

MIDRfSS-

BOjfcl HAMt;

HOHf:

MOD SAMPLE ID

by. (Signalun)

by (Sl|nohx<)

CHAIN OF CUSTODY RECORDPROJCCT NUMIK

(PR!«I

(PRINT

UtTMOO:

HWE)

AlftBU MDUBCR.

UBOIUICIRY REC£MNC:

SAUPICnut

SAUPIEUMRIX

Received by: (Signalufi)

(Slgnol̂ i)

chiid by: (Signotufi)

IIUUBtR OFCOtnAIHERS

Ooli:

PACE __OF_

Time

. sptcw L« swift, He (la I, tsmiMti bj lob)

SAJJPL£ CUSTOOWI RCUAflKS (COUPIHED BY LABORATORY):

lEVtl

UVU I U

Lfva ii airva in DOTHER D

1URHAROUHD:

ROUnNE D

24 HOUR D

I WEEK D

OIMEJI

SAHPIE RfCOPT

TOJAL I COMTAHIEflS RECEMD7

COC SEALS PRESENT 7

COC SEAiS WTACT 7

RECEKED COHTAJNEHS WTACT 7

TEMPERATURE 7

CHAIN OF CUSTODY RECORD FIGURE 3

AR400590

APPENDIX D

EFFLUENT LIMITATIONS

AR400591

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES

-Please note our new name-DEPARTMENT OF ENVIRONMENTAL PROTECTION

D E POne Ararat BoulevardHarrisburg, PA 17110

November 3, 1995

(717) 657-4592Southcentral Regional Office

Mr. Mark W. MoellerDamon Mill SquareNine Pond LaneConcord, MA 01742-2851

Dear Mr. Moeiler:

Re: CJGI - Columbia Gas SiteNPDES RequirementsColumbia Borough, Lancaster County

This is in response to your letter requesting approval to commence a con-tinuous discharge of treated groundwater from a groundwater remediation system.The discharge will be to the Susquehanna River in Columbia Borough, LancasterCounty. Approval of your request to discharge is granted subject to the follow-ing conditions:

1. Effluent Limitations and Monitoring Requirements:

MonthlyAverage Values

(UQ/1)Parameter

NaphthaleneBenzene

5010

MeasurementFrecruencv

2 /Month2 /Month

SampleTvne

GRABGRAB

2.

3.

Effluent samples shall be collected weekly for the first month ofoperation and then at the above indicated frequency. Benzene shallbe measured by an EPA approved method with a sensitivity of 1. 0 ug/1or lower.

The monitoring results must be submitted monthly to Anthony Martinelliat the letterhead address.

4. Groundwater Monitoring and Reporting Requirements:

The groundwater treatment system operation and total volumeof contaminants recovered shall be monitored. The monitoringmust include:

a. Monthly measurements of groundwater elevation anddaily flow rates at all extraction wells.

An Equal Opportunity/Affirmative Action Employer Recycled PaperAR400592

Mr. Mark W. Moeller - 2 - November 3, 1995

7.

8.

b. Monthly sampling and analysis of Benzene and Naphtha-lene .

c. Summation of the total volume of contaminants removedfrom each and all wells.

If the permittee monitors any pollutant, more frequently thanrequired above, the results of this monitoring shall be sub-mitted with the summary reports discussed below.

The discharge system shall be monitored daily through visual inspec-tion to ensure that the system is operating properly. A log ofthese inspections shall be kept and shall denote the date and timewhen the visual inspections of the system were made and an indica-tion as to whether any problems in operations were observed.

Sludges and/or other waste shall be handled and disposed of incompliance with 25 Pa. Code, Chapters 262, 263, and 264 (relatedto permits and requirements for landfilling and storage of hazard-ous sludge) and applicable federal regulations, the Federal CleanWater Act, RCRA and their amendments.

No erosion of ground surface, banks, or stream bed shall beinduced by this discharge, appropriate erosion and sedimentationcontrols shall be installed.

Mr. Martinelli shall be notified 24 hours prior to initiating thedischarge.

9. There shall be no discharge of stripper tower cleaning wastewatersto waters of the Commonwealth. Cleaning wastewaters shall be dis-charged to the sanitary sewer or hauled off site for proper disposalunless otherwise authorized by the Department.

This letter does not waive, either expressly or by implication, the poweror authority of the Commonwealth of Pennsylvania to prosecute for any and allviolations of law arising prior to or after the issuance of this approval or theconditions upon which the approval is based. This letter shall not be construedso as to waive or impair any rights of the Department of Environmental Protection.

If you have any questions, please contact Mr. Martinelli, Project Officerat the above number.

Arthur Dalla PiazzaChief, Hazardous Sites Cleanup SectionEnvironmental Cleanup Program

cc: Steve Donohue, EPA (3HW24)Doug McClure, Clean Sites

AR400593

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES

- Please note our new name - "-=Department of Environmental Protection ' ' "II

DEPOne Ararat Boulevard, Room 131Harrisburg, Pennsylvania 17110

November 6, 1995

Oi995

(717) 657-4592

Southcentral Regional Office

Mr. Mark W. MoellerRETECDamon Mill SquareConcord, MA 01742-2851

Re: UGI Columbia GasFinal Design SubmittalColumbia Borough, Lancaster County

Dear Mr. Moeller:

The Department has reviewed your Final Design Submittals dated September 29, 1995, and has the followingcomments:

- Work Plan Figure 8.1 - the site schedule should be revised and updated.

- The information submitted to the Department regarding the holder pits at UGI Columbia Gas Plant Psite dated August 18, 1995, has not been added to the submittals we have received. '

- The Department has received the NPDES Permit submitted by RETEC. A letter containing the requirements fordischarge is attached

If you have and further questions or concerns please feel free to contact me at the above referenced address andtelephone number.

Sincerely,

Anthony L. MartinelliProject OfficerEnvironmental Cleanup Program

ALM:dms

cc: DougMcClureSteve Donahoe, EPA

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