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SAMPLING AND ANALYSIS PLAN

DRAFT

QUALITY ASSURANCE PROJECT PLAN

Bennington Landfill Site Bennington, Vermont

Submitted to:

U.S. Environmental Protection Agency Region I

Prepared by:

McLaren/Hart Environmental Engineering Corp. 25 Independence Blvd.

Warren, New Jeisey 07059

February 3, 1992 Revised: May 22, 1992

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QUALITY ASSURANCE PROJECT PLAN BENNINGTON LANDFILL SITE

BENNINGTON, VERMONT

APPROVALS:

McLaren/Hart Environmental Enineerin: ~

ie^ Project Manager

David Everitt, QA/QC Officer

Date

Date

Environmental Protection Agency. Region I:

Terrence Connelly, Remedial Project Manager Date

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HA. DRAFT SAMPLING AND ANALYSIS PLAN IIA.2 Draft Quality Assurance Project Plan

TABLE OF CONTENTS

Section Title Page

DA.2 QUALITY ASSURANCE PROJECT PLAN (QAPP)

1.0 PROJECT DESCRIPTION 1 1.1 Introduction 1 1.2 Project Background 2 1.3 Project Objectives 2 1.4 RI/FS Study Objectives 2

2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES . . . 4 2.1 Project Organization 4 2.2 Subcontractors 4

3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT DATA 5 3.1 Precision and Accuracy 5 3.2 Completeness 7 3.3 Comparability 7 3.4 Representativeness 8

4.0 SAMPLING PROCEDURES 10 4.1 Selection of Sampling Locations 10 4.2 Sample Collection 10 4.3 Sample Preservation 12 4.4 Field Documentation 13

5.0 SAMPLE CUSTODY 15 5.1 Field Sample Custody 15 5.2 Sample Packaging and Shipment 16 5.3 Laboratory Sample Custody 17

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TABLE OF CONTENTS (Continued)

Section Page

6.0 ANALYTICAL PROCEDURES 18 6.1 Organics 19 6.2 Inorganics 20

7.0 EQUIPMENT CALIBRATION AND MAINTENANCE 21 7.1 Responsibility 21 7.2 Field Instruments 21 7.3 Laboratory Instruments 23

8.0 DATA DOCUMENTATION, REDUCTION, VALIDATION AND REPORTING 24

8.1 General 24 8.2 Data Reduction 24 8.3 Data Reporting 26 8.4 Data Validation 28

9.0 INTERNAL QUALITY CONTROL CHECKS 30 9.1 Laboratory QC Checks 30 9.2 Field QC Checks 30

10.0 PERFORMANCE AND SYSTEM AUDITS 32 10.1 Laboratory Performance and Systems Audits 32 10.2 Field Team Performance Audits 32

11.0 PREVENTIVE MAINTENANCE 34

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TABLE OF CONTENTS (Continued)

Section Page

12.0 SPECIFIC ROUTINE PROCEDURES TO ASSESS PRECISION, ACCURACY AND COMPLETENESS DATA 35

13.0 CORRECTIVE ACTION 36

14.0 QA REPORTS TO MANAGEMENT 37

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IIA. DRAFT SAMPLING AND ANALYSIS PLAN IIA.2 Draft Quality Assurance Project Plan

Figure 1:

Table 1:

Table 2:

Table 3:

Table 4:

Table 5:

Appendix A:

Appendix B:

Appendix B C:

Appendix D:

Figures

Project Management Organizational Structure

Tables

QA Objectives for Precision, Accuracy and Completeness of Analyses

QC Sample Summary

Sample Collection Requirements

Methodology Summary

Field Equipment Calibration Schedule

Appendices

Aquatec Quality Assurance Program Plan

McLaren Analytical Laboratory Quality Assurance Manual

Contract Required Quantitation Limits

Methods for Air Sarapte Analysis

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LIST OF RECIPIENTS OF THE QUALITY

ASSURANCE PROJECT PLAN

Terrence Connelly EPA Remedial Project Manager

Bruce Mackie McLaren/Hart

David Everitt McLaren/Hart

James Peterson McLaren/Hart

Quality Assurance Officer Aquatec

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QUALITY ASSURANCE PROJECT PLAN (QAPP)

1.0 PROJECT DESCRIPTION

1.1 INTRODUCTION

A Remedial Investigation/Feasibility Study (RI/FS) will be conducted at the Bennington

Landfill Site (the Site) pursuant to an Administrative Order by Consent issued by USEPA

Region I, CERCLA Docket No. 1-91-10-93.

The Settling Parties have retained McLaren/Hart Environmental Engineering, Inc.

(McLaren/Hart) to prepare an RI/FS Work Plan. A Quality Assurance Project Plan

(QAPP) has been prepared as part of the RI/FS Work Plan. The purpose of the QAPP is

to outline the specific quality assurance/quality control (QA/QC) objectives and procedures

for all sampling and analysis conducted at the Site. The appropriate use and application of

QA/QC procedures will ensure that environmental samples are collected, transported, and

analyzed in ways which fulfill the needs and regulatory requirements of USEPA, Region I.

This QAPP has been prepared in accordance with applicable USEPA guidance including:

Statement of Work for Remedial Investigation and Feasibility Study for the Bennington

Landfill Site and Interim Guidelines and Specifications for Preparing Quality Assurance

Project Plans. All sampling and analysis will be conducted according to USEPA or other

appropriate standard methods as detailed in this QAPP and in the Field Sampling Plan

(FSP). All project activities throughout the RI/FS shall comply with the QAPP.

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HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Draft Quality Auuraace Project Plan

1.2 PROJECT BACKGROUND

The Bennington Landfill Site is an inactive municipal landfill which occupies approximately

15 acres of a 28 acre parcel of land. The landfill is located on Houghton Lane,

approximately 3 miles north of Bennington in southern Vermont. Currently, the only

operations taking place at the Site arc conducted by the Town of Bennington, which uses

the Site for iuchiuie ihe temporary storage of brush and white goods, and fef- & transfer,

recycling, and sorting of municipal solid waste.

A discussion of the history, environmental setting, and previous investigations of the Site can

be found in the Site Background (FSP Section 2.0).

1.3 PROJECT OBJECTIVES

The primary objective of the RI/FS is to assess Site conditions and evaluate remedial

alternatives to the extent necessary to select a remedy for the Site, as defined in the

Administrative Order by Consent (Consent Order), EPA Docket No. 1-91-1093, that is

consistent with the National Contingency Plan (NCP).

1.4 RI/FS STUDY OBJECTIVES

The Remedial Investigation (RI) objectives are to:

1. define the sources, nature, extent, and distribution of contaminants

released;

2. determine and quantify potential exposure pathways;

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3. provide sufficient information to assess the risks to human health and to the

environment;

4. provide sufficient information to evaluate remedial alternatives,

conceptually design remedial actions, select a remedy, and issue a record

of decision.

The Feasibility Study (FS) objectives are to:

1. review the applicability of various remedial technologies, including

innovative technologies, to determine whether they are appropriate

remedies for the Site;

2. determine if each alternative developed by combining technologies is

effective, by evaluating in the short and long term whether it is:

a. effective

b. implementable

c. cost effective

3. evaluate each alternative or combination of alternatives through a detailed

and comparative analysis based on the criteria listed in the EPA references:

Guidance for Conducting RI/FS Studies under CERCLA : and Conducting

RI/FS Studies for CERCLA Municipal Landfill Sites and any criteria

identified in the NCP or CERCLA as amended;

4. provide direction to the RI portions to ensure that sufficient and

appropriate data are gathered to allow for the selection of a remedy.

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2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES

2.1 PROJECT ORGANIZATION

The project management organization provides clear lines of authority and a control

structure to support this RI/FS. The organizational structure for the project is shown in

Figure 1. A summary of each team member's responsibilities is provided in Section 5.0 of

the Site Management Plan (SMP).

2.2 SUBCONTRACTORS

McLaren/Hart will retain qualified subcontractors to perform specific tasks of the RI/FS

process. McLaren/Hart will provide overall management, coordination, and quality control

and review of subcontractors' activities. The project tasks which will be subcontracted are

discussed in the SMP.

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3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT DATA

The overall QA objective is to ensure that the field and laboratory procedures employed

during the project will generate data of sufficient and adequate quality for its intended use.

The data will be used to characterize the Site so that remedial alternatives can be evaluated

and ultimately, a remedy for the Site can be selected. In order for the data to be used for

these purposes, the data must be of a known and acceptable quality.

The quality of measurement data is characterized by the accuracy, precision, completeness,

representativeness, and comparability of the data collected. Each of these elements is

discussed below in relation to the data which will be generated from sampling and analysis

activities conducted at the Site. Table 1 presents these QA objectives for each of the major

parameter groups for sod* water, aad air aattlces, Accuracy and precision objectives are

based on prior knowledge of the measurement system employed and on method validation

studies. The objectives referenced in Table 1 are based on the attainable/acceptable ranges

as specified in the analytical methods to be used in this project, and are based on Level 4

data quality objectives.

3.1 PRECISION AND ACCURACY

Accuracy is the degree of agreement of a measurement with an accepted reference or true

value. Accuracy is often expressed as the percent difference between two values. Precision

is a measure of mutual agreement among individual measurements of the same property and

is often expressed as the standard deviation or relative percent difference (RPD). The

accuracy and precision associated with the measurement of inorganic and organic

parameters are discussed in the analytical methods and in data validation guidance to be

employed for this investigation.

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Analytical accuracy is determined by comparing results from the analysis of surrogates,

matrix spikes, or check standards to their known values. Every sample analyzed for organics

is spiked with compounds (surrogates) which behave chemically and physically like target

compounds. The percent recoveries of the surrogates from all samples and blanks are

reported as a measure of the accuracy of the method. Matrix spike recovery can also be

used to assess analytical accuracy. Acceptable percent recovery ranges have been proposed,

and are presented in Table 1.

The equation used to calculate percent recovery (%R) is as follows:

PercentRecovery(SpikeSample)= RSS~RUSxlOO

Where: RSS = Results of Spike Sample RUS = Results of Unspiked Sample SA = Amount of Spike Added

Precision is measured by analyzing field duplicates and laboratory duplicates. Duplicate

samples from each matrix are spiked (Matrix Spike/Matrix Spike Duplicate). Percent

recovery and relative percent difference of the matrix spikes are reported. RPD measures

the precision of the method for the particular matrix. The maximum RPD limits for

organics are presented in Table 1. One of every twenty samples is designated as the

MS/MSD sample. Accuracy and precision limits for inorganic analytes are also based on

spike and duplicate analyses and are presented in Table 1. The particular compounds and

concentrations to be used for spiking are specified in the referenced methods.

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HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Draft Quality Auurance Project Plan

The equation used to calculate % RPD is as follows:

D.-D. RelativePcrcentDifference(RPD)= -*100

Where: D, = First Sample Results D2 = Duplicate Sample Results

3.2 COMPLETENESS

With respect to data collection, completeness is a measure of the amount of valid data

obtained compared to the amount that was specified or expected to be obtained under

normal conditions. The measure is usually expressed as a percentage. Occasionally,

completeness is something less than 100 percent due to difficulties in collection and analysis

of environmental samples. An overall completeness rate of 90% is generally acceptable and

will be the standard applied to this project.

PercernCompletcness- ">**rofVaUdtesuhS NumberofExpectedResults

3.3 COMPARABILITY

The data generated from this Site should be comparable with similar measurements made

by others at this or a similar site. To assure that the measurements are comparable, sample

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collection and analysis will follow standard EPA methods; also, standard reporting units will

be used for all data. All aqueous sample data for organic and inorganic analytes will be

reported in ug/1. All sediment or soil sample data will be reported in ug/kg for organic

analytes and in mg/kg for inorganic analytes. All ambient air sample results will be

reported in ug/m 3.

3.4 REPRESENTATIVENESS

Data representativeness is ensured by using standard sampling procedures as well as

standard analytical methods. Blank and && fepBeate duplicate samples will be collected

for comparison to the environmental samples. Specific approaches are incorporated into

sample collection for each medium as outlined below.

Monitoring wells will be flushed three to five casing volumes prior to collecting samples to

ensure that a representative sample has been obtained from the aquifer. During collection

of ground water samples, one field blank per day of sampling, one replicate per twenty

samples, and a trip blank for each sample shipment, will be collected to check for

laboratory/field contamination.

During the collection of surface water and sediment samples, all downstream sampling will

be performed prior to upstream sampling. A field blank, a trip blank, and replicate surface

water and sediment samples will be collected to check for laboratory/field contamination.

Air sampling will be conducted by staging six sample collection points around the perimeter

of the site at 60 degree angles. After sampling is completed, a review of the wind direction,

as recorded by a meteorological monitoring station during sampling, will be used to

determine upwind and downwind locations. The samples collected at the upwind and

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HA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Draft Quality Auunnce Project Plan

downwind locations will be sent for analysis. Ail air samples

OA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Dnft Quality AMunnce Project Plan

4.0 SAMPLING PROCEDURES

The Phase IA field investigation program is designed to determine the existing

environmental conditions and to define the general extent of contamination resulting from

past operations at the Site. Through the field investigation process, the nature and extent

of contamination in the soil, ground water, surface water, leachate, sediments and air will be

determined. The FSP specifies the field tasks to be carried out during the Phase 1A

Investigation.

4.1 SELECTION OF SAMPLING LOCATIONS

All available data was reviewed, including results from previous sampling events to identify

sample locations, the number of samples to be collected, and the target analytes. Areas of

potential contaminant migration were also considered during selection of sample locations.

A complete discussion of sampling rationale and the number of samples to be collected with

maps depicting sampling locations are presented in the FSP. H&le I

HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Drift Quality Auunoce Project Plan

Sampling procedures were developed according to guidance given in A Compendium of

Field Operations Methods . EPA/540/P-87/001.

Replicate samples will be collected from each matrix at the frequency of one replicate per

twenty samples as designated in Table 2. Replicate samples will be collected from every

matrix, except air. The replicate sample will be collected at the same location and if

possible from the same sample aliquot as the original sample. Replicates of water samples

will be obtained by alternately filling sample containers from the same sampling device.

Replicate soil or sediment samples will be obtained by homogenizing the sample aliquot

prior to filling the sample containers, with the exception of the sample portion for volatile

organics analysis. Volatile organic samples will be taken prior to mixing the sample.

Replicate air samples will be collected by collocating air sampMng trains at a given::16 cartridges (two cartridges connected in series)

as an additional quality control measure.

Trip blanks for all matrices except air will consist of a set of sample bottles filled at the

laboratory with demonstrated analyte free water. Trip blanks will be handled and

transported in the same manner as the samples acquired that day, except that the sample

containers are not opened in the field. Trip blanks will be analyzed for volatile organics

only. The trip blanks for air sampling will consist of clean sample collection media which

will not be usod for sampling, but will be transported to and from the Site like the other

samplcs, and analyzed for the some parameters as other air samples. Trig blttk$

sampling

Field blanks for all matrices except air will be aqueous rinsate samples. Analyte free water

from the laboratory will be passed through decontaminated sampling equipment and

collected into the appropriate empty sample bottles. Field blanks are analyzed for the same

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HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Drift Quality AMunnce Project Plan

parameters as their associated matrix. A field blank for air analysis consists of exposing the

sampling medium to ambient air but not actively drawing air through the medium. All field

blanks will be packaged and shipped to the laboratory with samples of the same matrix.

4.3 SAMPLE PRESERVATION

Sample preservation, containers, and holding times for each analytical parameter are

specified in Table 3. Holding times have been specified from the time of sample collection.

All sample preservation will be performed in the field immediately after collecting samples.

Aqueous samples and blanks to be analyzed for volatiles will be acidified with 1:1 HC1 to

pH 12. Any

deviations from the preservation methods as described will be noted in the field notebook

and on the chain-of-custody form.

After collection samples will be cooled to approximately 4 degrees Celsius and will be

maintained at a reduced temperature during shipment to the laboratory. All samples will

be shipped to the laboratory within 24 hours of collection via an overnight carrier or

laboratory courier service.

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4.4 FIELD DOCUMENTATION

Field notebooks will provide the means of recording any field events including data

collection and sampling activities. The notebook will be bound and maintained by the Site

Sampling Task Manager to provide daily records of significant events, observations, and

measurements during the field investigation. All entries are to be signed and dated. All

members of the field investigation team are to use this notebook, which is to be kept as a

permanent record.

Field notebooks are intended to provide sufficient data and observations to enable

participants to reconstruct events that occurred during projects and to refresh the memory

of the field personnel if called upon to give testimony during legal proceedings. The field

notebook entries should be factual, detailed, and objective. Unless restricted by weather

conditions, all original data recorded in field notebooks and on sample identifications tags,

chain-of-custody records, and receipt-for-samples forms are written in waterproof ink.

If an error is made on an accountable document the correction is made by simply crossing

out the error and entering the correct information. The erroneous information should not

be obliterated. All corrections must be initialed and dated. Whenever a sample is collected

or a measurement is made, a detailed description of the event will be recorded. The

sampler, sample time, sample location, sample description, sample measurement, and any

field observations will be included in the field notebook. All equipment used to make

measurements will be identified, along with the date of calibrations. Sample custody will

be documented in the field notebook. Field data sheets, including boring logs and air

monitoring data sheets, may also be used to record field data.

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Notebooks will be assigned to field personnel, but will be stored in the project file when not

in use. Field data sheets will also be maintained in the project file.

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5.0 SAMPLE CUSTODY

Chain-of-custody procedures provide an accurate written record which can be used to trace

the possession of samples from the time of collection through sample analysis and data

reporting by the laboratory. Both the field team and the laboratory are responsible for

documenting sample custody. A sample is considered to be in an individual's custody if any

of the following criteria are met: 1) the sample is in your possession; 2) it was in your

possession and then locked up or sealed to prevent tampering; or 3) it is in a secured area.

5.1 FIELD SAMPLE CUSTODY

Custody documentation will be maintained for each sample collected in the field. The field

team member performing the sampling is responsible for the care and custody of the sample

until they are properly dispatched. Chain-of-custody forms will be used to document sample

custody. The following information will be specified for each sample on the field

chain-of-custody form: sample number; sample matrix; date and time of sample collection;

analysis requested; number of containers per sample; sample preservation; and method of

shipment. One chain-of-custody form will be used for each sample shuttle shipped for

analysis. All other pertinent sample information including sample location will be recorded

in the field notebook.

The chain-of-custody form will be signed by sampling personnel. The forms will be placed

in a water-tight plastic bag and taped to the underside of the lid of the cooler containing the

samples designated on the form. A copy of the form is retained by the sampler for the

project file.

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5.2 SAMPLE PACKAGING AND SHIPMENT

The laboratory will provide the field personnel with all the sample containers necessary for

completing the field sampling. Sample containers will be obtained directly from the

laboratory to ensure that the containers are free of contamination and are the appropriate

volume for the requested analysis. Air sampling media which require precleaning will also

be obtained directly from the laboratory to ensure that the appropriate cleaning procedures

have been performed a$ described by tfce re&remaed method*. Preservatives used in field

sampling will be reagent grade and will be supplied by either the laboratory or purchased

directly.

Following sampling, the sealed sample container will be rinsed with tap water, dried and

labeled. The bottles will be labeled with the following information: site name, sample

number, initials of collector, date and time of collection, type of sample, analysis required,

and preservative.

Sample labels will be completed in waterproof ink. Labels will be taped onto the sample

bottles. Following labeling, sample containers will be placed in sealed clear plastic zip lock

type bags and placed in a cooler for storage and shipment. Ice, sealed in double plastic

bags, or "blue ice" will be placed in each cooler to maintain all samples at 4C. The

samples will be cushioned using vermiculite, foam rubber or other similar packaging

material. Chain-of-custody forms will be enclosed in each cooler. Coolers will be sealed

with custody seals in such a manner that the custody seal would be broken if the cooler were

opened. The lid of the cooler will be securely taped shut. Sample coolers will be shipped

to the analytical laboratory on the same day as sampling via overnight delivery or laboratory

courier service.

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5.3 LABORATORYSAMPLE CUSTODY

Samples will be received at the laboratory by the sample custodians who examine each

sample to ensure that it is the expected sample, inspect the sample containers for possible

damage, and ensure that the documentation is complete and adequate. The sample

custodians will ensure that each sample has been preserved in the manner required by the

particular test to be conducted and stored according to the correct procedure. Samples will

be maintained at 4C until analysis begins. Details of the laboratory's procedure for sample

receipt, storage, and tracking are included in Appendix A Appendices A asd B*

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6.0 ANALYTICALPROCEDURES

Aquatec, one of the laborator y fas tentatively identified to perform routine analysis of the

samples, is certified by the Vermont Department of Health and has been a participant in

the EPA Contract Laboratory Program (CLP). Aquatec's Quality Assurance Program Plan

has been included as Appendix A. McLaren Analytical Laboratory has also beea

selected to provide analytical services for this project McLaren

demonstrated performance wi& CSLF methods and maintains a Basic Ordering witn EPA, which preqtiatifies &e laboratory for EPA contracts, Mctareo

participates in the EPA's profideJicy testiig programs, Water Pollution Studies

Supply Studies. The McLaren Analytical Quality Assurance Manual has been fag) Appendix B.

EPA or other standard methods will be used for all analyses. A methodology summary is

presented in Table 4. The CLP methods to be used for this project include "USEPA

Contract Laboratory Program Statement of Work for Inorganics Analysis", Document No.

ILMO I.O.March 1990; and "USEPA Contract Laboratory Program Statement of Work for

Organic Analysis",Document Number OLMO 1.0including revisions through OLMO 1.8,

August 1991. Contract required quantitation limits (CRQLs) have been established for CLP

methods. The CRQLs for the detection of organic compounds in water samples are at the

parts per billion range (ppb). Approximate sample quantitation limits for soil samples can

be calculated based on the sample size and on concentration/dilution factors. The CRQLs

for inorganic analytes in water samples are in the ppb to low part-per-million (ppm) range;

CRQLs for soil samples can be achieved in the low-to mid-ppm range. Appendix B-C; lists

all the target analytes with their respective CRQLs. Deliverables will be supplied in the

CLP format. Complete documentation will be provided for those analyses performed

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according to CLP modifications or SW-846 methods so that Level 4 data quality objectives

are met.

6.1 ORGANICS

The analysis of any organic compounds (volatiles, semivolatiles, PCBs) in soil or water

matrices will be performed according to the CLP protocols. For the analysis of volatiles in

groundwater and surface water samples, a larger sample volume will be analyzed to achieve

a detection limit of 0.5ug/L. This method modification will provide lower detection limits so that

the groundwater and surface water sample results can be compared to water quality criteria and

be used for risk assessment purposes.

Air samples will be analyzed for select volatile organic compounds including benzene,

chlorobenzene, chloroethane, dichlorobenzenes, dichloroethenes, dichloroethane, ethyl benzene,

tetrachloroethane, trichloroethane, vinyl chloride, and xylenes. Air samples will be analyzed

according to EPA Method TO-2, Method for the Determination of Volatile Organic Compounds

in Ambient Air by Carbon Molecular Sieve Adsorption and Gas Chromatography/Mass

Spectrometry. The detection limit for TO-2 analytes is 10 ng/tube.

Air samples will also be analyzed for PCBs according to EPA Method TO-4, Method for the

Determination of Organochlorine Pesticides and Polychlorinated Biphenyls in Ambient Air.

Detection limits of > 1 ng/m 3 can be achieved using a 24-hour sampling period.

Copies of the TO methods to be used fortes project are included as Appettdhc D. A$oatie*$ TO-2 method specifications are also included.

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6.2 INORGANICS

Analysis of metals in all sample matrices except air will be performed according to the CLP

protocols. The analysis of metals in air sampling filters will be conducted according to SW 846

flfclftlMlNj f>UI iHTlIi GOnTOrin SHrl^n i .\ ^r \^f\ prOvPO*lfv^ ft,* l"" O^T?*M pO^fy*f**^t I'fty ffffJr tBCTlB jtPRSJRnlTwBHy

wiljbc trcattxi flaa aolid mat^, and digest Detection limits for metals

in air samples ore as follows: arsenic, 0.5 ug/filtcr; lead, 0.5 ug/filter; nickel, 4 ug/filter.

All other chemical analyses will be performed according to standard methods as described in: Test

Methods for Evaluating Solid Waste: Physical/Chemical Methods SW-846. Third Edition; Methods

for Chemical Analysis of Water and Wastes EPA-600/4-79-020; or Standard Methods for the

Examination of Water and Wastewater .

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7.0 EQUIPMENT CALIBRATION AND MAINTENANCE

7.1 RESPONSIBILITY

A calibration and maintenance program will be implemented to ensure that routine calibration and

maintenance is performed on all field instruments. The program provides equipment of the proper

type, range, accuracy, and precision to provide data compatible with the specified requirements and

desired results. Calibration of measuring and test equipment is performed internally using in-house

reference standards or externally by agencies or manufacturers. The Site Sampling Task Manager

is responsible for ensuring that the field instruments used in the investigation are calibrated and

maintained according to manufacturers specifications. Field instrument manuals describing

calibration, maintenance, and field operating procedures for these instruments will be available for

easy reference by field and project personnel.

Team members will be trained in the field calibration, operation and maintenance of the

equipment, and will perform the prescribed field operating procedures outlined in the operation

and field manuals accompanying the respective instruments. They will keep records of all field

instrument calibrations and field checks in the field notebooks.

Aquatec is responsible for the routine calibration and maintenance of analytical equipment used

for the subcontracted analysis of samples to provide compliance with the referenced methods.

7.2 FIELD INSTRUMENTS

The field instruments are maintained and calibrated in accordance with identified maintenance and

calibration procedures. Records will be prepared and maintained for each piece of calibrated

measuring and test equipment to indicate that established calibration procedures have been

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followed (e.g. results of calibration, problems, corrective action). Records for field equipment used

only for this specific project will be kept in the project files.

Instrument response will be checked prior to bringing the instruments to the Site and prior to

operation at the Site. Equipment that fails calibration or becomes inoperable during use will be

removed from service and tagged to prevent inadvertent use. If on-site monitoring equipment

should fail, the Site Health and Safety Officer will be contacted immediately and will either provide

replacement equipment or have the malfunction repaired immediately.

Groundwater temperature, pH, and coi^ik^ty will be measured in the conductivity meter will be calibrate^ daily t>y a trained team member using sta $oiotioiis. Standard tRiffet^i^it^^W'p^-^4v7rliflil "lO'^lfffStlfifli focal Standard buffer sdutised, The cotuioctivity standard will chloride solution obtained as a 720 uMf solution, traceable to the HBS; Fresh will be used for daily calibration Calibratiofi solutions are pwcfeased from * *

Periodic preventive maintenance is required for sensitive equipment. The field instruments are

maintained through periodic calibration and adjustment by the instrument manufacturer as needed.

In general, an HNu is serviced by the manufacturer every 3 months or less; an OVA is serviced

every 6 months or less.

Routine maintenance is performed whenever an instrument is acquired for field use, and when

returned from field use. Instrument manuals are kept on file for reference purposes should

equipment need repair. Troubleshooting sections of manuals are often useful in assisting personnel

performing maintenance tasks. A schedule for field equipment calibration is included as Table 5.

Preventive maintenance, other than routine maintenance and calibration, is performed as needed.

C476 -22

HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Draft Quality Auurance Project Plan

7.3 LABORATORY INSTRUMENTS

All laboratory equipment will be maintained in accordance with manufacturer's specifications.

Quality assurance, tuning, and calibration procedures will be conducted according to the current

EPA CLP protocols or other method specific protocols where CLP is not applicable.

C476 -23

HA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Drift Quality Auunnce Project Plan

8.0 DATA DOCUMENTATION, REDUCTION, VALIDATION AND REPORTING

8.1 GENERAL

The Project Manager will maintain project files which will contain complete project documentation.

These files will include project plans, field notebooks, field data sheets, photographs, maps and

drawings, sample identification documents, chain-of-custody records, the entire analytical data

package provided by the laboratory including QC documentation, copies of raw data computer

printouts, gas chromatograms, mass spectra, data validation notes, references and literature, report

notes and calculations, progress and technical reports, correspondence and other pertinent

information. The project file will be kept at the McLaren/Hart office in Warren, NJ; the file will

be maintained for the duration of the project.

8.2 DATA REDUCTION

Data reduction techniques and all equations used to calculate concentrations are specified by the

analytical methodology. The equations presented below are for the quantitation of inorganic and

organic analyzed according to CLP protocols. Data from these analyses will be converted to

concentration units using the following equations:

For volatiles in aqueous samples:

Concentration ug/L = (AJ1 flj (Dfl (A J (RRF)

C476 -24

HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Draft Quality Auunoce Project Plan

For volatiles in soil or sediment samples:

Concentration ug/kg =(A j (I,) (Dry weight basis) (Aw (RRF) (W^ (D)

For semivolatiles in aqueous samoles:

Concentration ug/L = (A.) m fV,) (Oft (AJ(RRF)

For semivolatiles in soil or sediment samples:

Concentration ug/kg = (A.) (I,) rv,") (Dry weight basis) (AJ (RRF) (V) (WJ (D)

Where

Ax = Area of the characteristic ion for the compound to be measured

Au = Area of the characteristic ion for the internal standard

I, = Amount of internal standard added in nanograms

RRF = Relative response factor

V0 = Volume of water purged or extracted in milliliters

V j = Volume of extract injected in microliters

V, = Volume of the concentrated extract in microliters

Df = Dilution factor

D = 100 - % moisture/100

C476 -25

HA. DRAFT SAMPLING AND ANALYSIS PLAN OA.2 Draft Quality Auunnce Project Plan

W, = Weight of sample purged or extracted in grams

For metals in soil or sediment samples:

Concentration (mg/kg) = C x V (dry weight basis) W x S

Where

C = Concentration found in sample extract in mg/1

V = Final volume in liters after sample preparation

W = Weight in kg of wet sample

S = % Solids/100

8.3 DATA REPORTING

The analytical laboratory will prepare and retain full analytical and QC documentation as required

by the CLP protocols or other referenced methods. The analytical laboratory will supply complete

data packages consisting of all results, the raw data and all relevant QA/QC documentation. All

data will be transmitted in hard copy and on diskette. All original data files will be stored in a

manner which precludes manipulation of the original data, and all manipulation, editing, and

presentation will be performed on data copied from the original data files. Data compilations will

be provided in formats that are compatible with EPA Region I databases and will be organized to

facilitate data review and evaluation. The analytical laboratory will provide the following

information in each analytical data package submitted:

0 Analytical results with detection limits and appropriate data quality notations.

C476 -26

HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Draft Quality Auunnce Project Plan

0 Narrative including statement of samples received, description of any deviation from the

QAPP, explanation of qualifications regarding data quality, and other significant items

encountered during analysis.

0 According to CLP protocol, the laboratory is required to tentatively identify unknown

compounds not included in the TCL list. This includes twenty (20) semivolatile

compounds, and ten (10) volatile organic compounds.

0 For analyses conducted by the CLP protocols, the deliverable format is specified by the

protocol. CLP QA/QC information to be reported includes at a minimum, the following:

Organic parameters

surrogate spike results for each sample

matrix spike and matrix spike duplicate results

method blank results

initial and continuing calibration data

GC/MS tuning and mass calibration

Compound identification spectra

Inorganic parameters

spike and duplicate results

method blank results

initial and continuing calibration verification results

instrument detection limits

laboratory control sample results

ICP interference check sample analysis

C476 -27

nA DRAFT SAMPLING AND ANALYSIS PLAN OA 2 Draft Quality Auunnce Project Plan

8.4 DATA VALIDATION

The analytical laboratory will review appropriate quality control data to assure the validity of the

analytical results provided to the McLaren/Hart. A qualified chemist from McLaren/Hart will

conduct an independent data validation review. The data validator will conduct a systematic review

of the data for compliance with the established QA/QC criteria based on the calibration, spike,

duplicate and blank results provided by the laboratory. All data produced according to CLP

protocols will be evaluated according to the following EPA Region I guidance:

Region I Laboratory Data Validation Functional Guidelines for Evaluating Organics

Analyses, February 1, 1988; revised November 1, 1988.

Region I Laboratory Data Validation Functional Guidelines for Evaluating Inorganics

Analyses, June 13, 1988; revised February 1989.

Criteria which will be osed'W^ew ipn^ V analysis of air samples will adherence; matrix spike recovery; matrix duplicate and field replicate results; blank where apoBcable* ftmiae z^faMwft^&ti&flfai, ffie EPA TO Met&ods- contain ^^Ha&W^Mi^~* *" w" f f .. .. v s*AjiM.ffjff,firW f v f - _/"" AM* f *i.->5S.... 3s:x3a&2w t&C CV3*U&tiQlt '' O* ft ffM^ffOff':^fylvB^T^ 'pfl^rftrJT^-' 3IICI'''J5CKFK5S'

The data validator will identify any out-of-control data points and data omissions and interact with

the laboratory to correct data deficiencies. Decisions to repeat sample collection and analyses may

be made by the QA Officer based on the extent of the deficiencies and their importance in the

overall context of the project. Decisions to resample will be communicated to the Remedial

Project Manager.

C476 -28

HA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Drift Quality Auunoce Project PUn

Following data validation, any data qualifiers will be entered into the sample results summary

tables. The computerized data set will include the data qualifiers provided by the laboratory in

accordance with the documents referenced above as well as additional comments of the data

reviewer. The data qualifiers which will be used are defined as follows: 1) U, compound was

analyzed for, but was not detected above the associated detection limit; 2) J, usable with caution

as an estimated concentration, or 3) R, unusable due to out-of-control QA results. Those results

which are usable as quantitative concentrations will be reported withouth qualifiers.

C476 -29

HA. DRAFT SAMPLING AND ANALYSIS PLAN EA.2 Drift Quality Auunnce Project PUo

9.0 INTERNAL QUALITY CONTROL CHECKS

9.1 LABORATORYQC CHECKS

Aquatec has been selected based on their performance in the CLP program and their overall ability

to perform the analyses specific to this project. Certain minimum requirements must be met for

laboratory participation in the CLP program. In general these requirements specify the

qualifications of personnel, available instrumentation, analysis of performance evaluation samples,

and adherence to and documentation of standard operating procedures and quality assurance plans.

It will be the responsibility of the Laboratory QA Officer to document, in each data package

provided, that both initial and ongoing instrument and analytical QC functions have been met.

Internal quality control checks, including spiked samples, duplicate samples, laboratory control

samples, reagent specifications, and calibration checks, are performed in accordance with the

specific methodologies used. Specific QC procedures and their frequency are incorportated into

the referenced methods. The minimum criteria for most analyses generally consist of a daily

calibration check, method blank analysis, analysis of spike or control samples, and duplicate analysis

for each parameter.

9.2 FIELD QC CHECKS

For field quality control, replicate and field blank samples will be obtained for each sample matrix.

Trip blanks will be used in conjunction with all samples (except 'air} to be analyzed for volatile

organic compounds. The procedures for obtaining or preparing these QC samples are discussed

in Section 4.0. The frequency of QC sample collection is given in Table 2.

C476 -30

HA. DRAFT SAMPLING AND ANALYSIS PLAN DA 2 Draft Quality Auurance Project Plan

The standard frequency for obtaining field replicates and samples designated as MS/MSDs is one

per twenty samples per matrix. Held repEcate samples serve as & check on the overM precision of the sampling and analytical method. Matrix duplicate samples check on laboratory analytical

precision, and may be used la assess matrix effect

Field blanks will be collected throughout the sampling event for each matrix. Field blanks will be

collected on a daily basis for the matrices sampled that day. Field blanks will be obtained by

pouring laboratory provided distilled analyte-free water over decontaminated sampling equipment

(trowels, mixing bowls, bailers, etc). The water will pass over this equipment and be allowed to

run directly into laboratory prepared bottles. All field blank information will be noted in the field

notebook. Trip blanks will only be sent with each shipment of samples to be analyzed for volatile

organics.

Field blanks measore Incidental or accideotial sample cotrtanunatioo

OA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Drift Quality Auunnce Project Plan

10.0 PERFORMANCE AND SYSTEM AUDITS

10.1 LABORATORYPERFORMANCE AND SYSTEMS AUDITS

The analytical laboratory will conduct internal quality control checks and audits in accordance with

specific methods and criteria required under their internal operating procedures and under the

governing laboratory programs (CLP, VT DOH). The frequency of and procedures for laboratory

performance and system audits are outlined in the laboratory Quality Assurance Program Plan.

The laboratory QA Officer will be primarily responsible for conducting these audits.

The systems audit consists of evaluation of all components of the measurement systems to

determine their proper selection and use. Systems audits are normally conducted prior or shortly

after systems are operational, and are then performed on a regularly scheduled basis. Performance

audits are conducted periodically, and includes the analysis of performance evaluation samples.

10.2 FIELD TEAM PERFORMANCE AUDITS

The QA officer or designee will be responsible for auditing the field team. A performance audit

will be conducted during the field activities to ensure that proper procedures are followed and that

subsequent data will be valid. The audit will focus on the details of the QA program, and will

evaluate the following: 0 Project Responsibilities 0 Sample Custody Procedures 0 Document Control 0 Sample Identification System 0 QC Corrective Action Procedures 0 Sampling Techniques

C476 -32

DA. DRAFT SAMPLING AND ANALYSIS PLAN OA.2 Draft Quality Auunoce Project Plan

Adherence to the Approved QA Project Plan

The audit will evaluate the implementation of the project Sampling and Analysis Plan, that is the

FSP and QAPP. Checklists appropriate to the task being audited will be used as the guide for the

performance audit.

The QA officer will also be responsible for conducting one evidence audit. The purpose of the

evidence audit is to ensure that proper project documentation is maintained and has been

distributed to project personnel.

C476 .33.

HA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Drmft Quality Auurance Project Plan

11.0 PREVENTIVE MAINTENANCE

For preventive maintenance procedures in the field see Section 7.0. Preventive maintenance

procedures for analytical laboratory instruments are discussed in the laboratory's Quality Assurance

Program Plan provided as Appendix A.

C476 -34.

DA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Drift Quality Auunnce Project Plan

12.0 SPECIFIC ROUTINE PROCEDURES TO ASSESS PRECISION, ACCURACY AND COMPLETENESS OF DATA

The procedures and control limits used for assessing the precision, accuracy and completeness of

data have been discussed in Section 3.0. It will be the responsibility of the Project QA Officer and

the Laboratory QA Officer to ensure that these procedures are followed. The control limits and

data evaluation procedures have already been specified in the analytical and validation guidance

documents referenced in Sections 6.0 and 8.0.

The following items will be considered for all data: custody documentation; adherence to holding

times; calibration documentation; duplicate, spike, and blank sample results; raw data, spectra,

calculations and reporting units; and completeness of documentation.

C476 .35.

HA. DRAFT SAMPLING AND ANALYSIS PLAN DA.2 Drift Quality AMunnce Project Plan

13.0 CORRECTIVE ACTION

Corrective action on a day-to-day basis for field activities will be handled by consultation between

team members and the Field Sampling Task Manager. The Field Sampling Task Manager will

make immediate decisions with the team members on new protocols to be followed. All changes

in field procedures will be documented in the field notebook, reported to the Project Manager, and

reported in the final report. Corrective actions will be taken if performance audits reveal the need

to amend field procedures.

The Field Health and Safety Officer will have ultimate authority to make decisions regarding

modifications to health and safety practices and regarding safety emergencies. The EPA Remedial

Project Manager will be notified of any such field decisions or corrective actions that result in

modification of protocols as outlined in any of the project plans, i.e. the FSP, QAPP or HASP.

Corrective action in the laboratory will be handled by consultation between the Laboratory QA

Officer and the Project QA Officer. Corrective actions are implemented when accuracy, precision,

calibration or other internal method specific quality assurance criteria can not be met. All changes

in laboratory procedures will be documented and reported.

All modifications to procedures during the course of the project will be documented and these

exceptions will be permanently incorporated into the project file.

C476 -36

OA. DRAFT SAMPLING AND ANALYSIS PLAN QA.2 Draft Quality Auunnce Project Plan

14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT

The QA Officer will periodically report to the Project Manager on the status of the investigation.

This report will include, as appropriate, a summary of the sampling results with appropriate data

qualifications; audit findings; and any necessary corrective action procedures. A data quality

assessment, which summarizes the measurement data accuracy, precision, and completeness will

be prepared using all information for the available data. The data quality assessment prepared by

the QA Officer and data validator, and reviewed by the Project Manager, will be incorporated into

the final report submitted to EPA.

C476 -37.

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Quality Amnace Project Plaa

Matrir PanaMtan*

Groundwater TCL VoUtilei, Base Neutrals, PCBa; TAL Meuli

Surface Water, Sediment TCL Volatile*, Base Neutnli, PCBa; TAL Meuli

Soili TCL Volatile*, PCS*

Leachate TCLP, PCBi, Leachate Treatment Panmeten

Ambient Air Volatilci PCBi , Lttd, .\rnnio Niobil

TCL: Target Compound List TAL: Target Analyte List

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1 per shipment

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TABLES

Field Equipment Calibration Schedule Quality Assurance Project Plan

Equipment 1 Minimum Calibration Freauencv 2

HNU Model HW-101

Century OVA Model 128

YSI T L C Meter Model 3000 (temperature,conductivity meter)

Conductivity Meter

Cole-Parmer pH Meter Model 5996-805995-30

Gilian HFS 513 Air Sampling System (high flow sampling pumps)

Gilian Low Flow Industrial Hygiene Calibrator Pack (rotameter)

Meteorology Research Inc. Model 1071 meteorological monitoring station

Turbidimctcr Model 8391 35

HFScienti Turbidity

Daily

Monthly

Daily

Daily

Flow rate measured immediately before and after sample collection

Every six months or before each sampling event

Annually

Daily

1 Equivalent field instrumentation may be used. 2 Operation, calibration, and maintenance instructions for all field equipment will be

available with the equipment.

HA. DRAFT SAMPLING AND ANALYSIS PLAN HA.2 Draft Quality Auunoce Project Plan

APPENDIX A

AQUATEC QUALITY ASSURANCE PROGRAM PLAN

C476

AQUATEC QUALITY ASSURANCE

PROGRAM PLAN

Prepared by

Aquatec,Ir.c. 75 Green Mountain Drive

South Burlington, Vercont

Revision 5 Approval

//

''/h^~_ ;/t-tl&.?*+.-/. George W. Starbuck

President

fry*ft.. Comeau, ?h. D.

Vice President, Chemistry

* / Neal E. Van Wyckk/

Chemistry Laboratory Directorirec

Vo c. Philip) C. Downey,

Biology Laboratory Director

A L/U r f.Karen R. Chirgwitl

Quality Assurance Officer

; hereby authorize and approve the following Quality Assurance Program :lan fcr use in Aquatec's Analytical Laboratory.

"=orge W. StarbuCf: 7Date President

Aquatec believes tr.at :r = comnit-ert . f all -Lthir. _ts

:rganization to a comprehensive C-aiitv -ss_r;rc5 Program Plan ;s B.

necessity to meet "he objectives of rr.is aralvrical laboratory ar.c of

the Contract Laboratory Programs. The follcv-.r.g Laboratory Qaality

Management Plan is an embodiment of tr.e carrant practices of quality

assurance/quality control at Aquatec. The ir.--.cuse quality assurance

program is aimed at the production of data of known quality and

integrity, while sustaining a minimura loss of data due ro

out-of-control conditions.

Each laboratory section is responsible :;r keeping an upcated

"ersion of Standarc derating Procedures 5CP applicable ro tnat

section. To ensure continuity of analysis tr.rc-ig.-.ouc the laboratory,

specifics in the areas sue.- as sample .-.sndling, inscru.T.enc

calibration, quality control r.=asures, injection technique, data

acquisition, data processing, and autosazpler procedures are

thoroughly explained in each SOP. Following the guidelines stated in

SOPs, contractual obligations and method specifications can be met.

The constituents that tr.ake up Aquatec's quality assurance/quality

control program have been greatly influenced by the contractual

obligations. Currently, Aquatec is a participant in the United States

Environmental Protection Agency's Contract Laboratory Program. RE.M

Contract Laboratory Program, and the "ew York State Contract

Laboratory Program. As a result, many of the routine quality

assurance/quality control measures and restrictions utilized by the

laboratory are designed to meet the obligations as set forth in these

contracts. When "contractual obligation" is mentioned in the

following text, it is in reference to these contracts.

The practices of quality assurance/qualitv control presented in

the following text are set forth as minimuss, and any additional

measures that the client requires can be incorporated into the quality

assurance/quality control project plan. The mini-urns set forth should

be considered, as such, a minimun. Any tailoring or customizing the

client may require, based on individual r.eeds, can usually be

implemented within the laboratory structure.

Table of Contents

\ Physical Facilities -.-1

3. Personnel 3-1 B.I Roles and Responsibilities 3-1 B.2 Training 3-

Page A-l Revisicn Date

A. PHYSICAL FACILITIES

The physical facilities available for analytical vork at Aquatec

are housed in one building vith a total of 22,200 square feet of floor

space. This comprises the corporate headquarters vith an additional

off-site bioassay laboratory and storage facility. The floor plan in

Figure A.I shows the location, size, and utilities available on an

individual laboratory basis. Over 12,000 square feet are utilized by

the chemistry division; approximately 2,500 square feet are devoted to

analytical activities. The laboratories occupy 3,000 square feet;

sample management, 250 square feet; and incubators, the analytical

balance, and desks for computations and transcription are located in

an 190 square foot room. Linear bench space in the laboratories are

made of synthetic stone and occupy a total of 317 feet. The entire

facility is air conditioned, has overhead fluorescent lighting, and

the flooring is comprised of epoxy, tile, or raised computer flooring

depending on the needs of the vork space. The gas chromatography/nass

spectrometry laboratory has a positive pressure air system vith

make-up air drawn through activated carbon filters. All other

laboratories utilize a negative pressure air system. The laboratory

also has many facilities to support the analytical effort in the form

of a reverse osmosis system, deionization system, and computer

networking.

Because of the nature of our vork at Aquacec, adequate security

of the facilities, methodologies, and project files is necessary.

Access to the train building is controlled through a system of

combination-locked doors and, during business hours, reception log-in

procedures for visitors. In addition, anti-intrusion devices and

key-control are employed to secure access to the facilities and its

contents. Visitors register upon entering the building and are

accompanied by an employee while visiting the facility. Aquatec

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are expects- t2 oe familiar --it.-, arc acr.ere to stancards of

confidentiality u.anaatea ;y individual cc-tracts and common sense

Business practices laooratorv Section .-.eacs '-ill .r.sure that their

personnel are familiar v-.th Aauatec's securitv policies.

3 PERSONNEL

The organization of -aooratorv rersonre. -~t-_- :~e -:_5;ec

-.naj.vtical Laboratories is presented in Figure 3 1 Tre .ascratorv

structure provides a means for communication fron tr.e rer.c.i .eve. -p

co the Laboratory Director This organization facilitates the

generation of data, several levels of data review, ana the monitoring

of tne overall quality of the cata produced in tr.e laaoratorv Before

it .s reported to the client The Quality Assurance Program -icr.in

the laboratory is operated .ndenendently of the laooratorv sections

generating cata and reports directly to upper -ar.agete-t leve.s If

ciscrscar.cies are founa _n tre performance cf -r" s = cti;-. ;f '--.&

laboratory, it .s reported to the Laborator" I.rectcr -r.o _s

responsible for initiating the proper corrective acticn .itr.in tne

section In this way, objectivity in the evaljatior. of laboratory

operations can be ootained.

B.I Roles and Responsibilities

Each section within the laboratory has specific roles and

responsibilities in terms of producing a procuct of -.novn quality

All laboratory personnel are expected to have a '-orkir.g rvrowieage of

the ^quatec Quality Assurance Program Plan (QAP?) It is expected

that employees at every level vill ensure that data .3 generated in

compliance with the Aquatec QAPP

At the bench level, analysts are responsible for tr.e generation

of data by analyzing samples according to written SCP's They are

also responsible for ensuring thac all documentation related to the

sample is complete and accurate. The analyst sr.ouid provide

management with immediate notification of quality problems within the

laboratory. The analysts have the authority to accept or reject data

based on compliance with well-defined QC acceptance criteria The

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. The response of each compound within the

internal standard is plotted on a control chart (Figure F.2). The

tolerance ranges of these charts are contractually set. In the

absence of any other criteria, the following working rule applies: the

area of any compound cannot fall below 30X of its value in the

preceding check standard nor can it rise above 100Z of its value. If

internal star.card areas in one or more samples exceeds the specified

tolerances, then the instrument will be recalibrated and all affected

samples reanalyzed.

F.7 Biological Standards

F.7.1 Microbiological Standards

All equipment and supplies used in the microbiological analyses

are routinely checked for sterility. Laboratory dionized water is

monitored monthly for bacterial densities and required water quality

characteristics. If any of the parameters are out of the specified

tolerances, the personnel responsible for the dionized vacer system

are notified and corrective action is taken. The laboratory water is

tested annually for suitability for culturing bacteria. Glassware is

tested annually usir.g the inhibitory test to insure that the glassware

cleaning procedures do not inhibit bacterial growth. Bacteria sample

containers are prepared in lots and each lot is checked for -sterility.

If the tested container is not sterile, then all the associated

containers will be re-sterilized and re-tested.

A positive and negative control sample is run with each daily set

of bacteriological samples. The negative control is conducted using

the dilution water appropriate for the test. This dilution water is

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typically sterile phosphate rinse buffer. Tr.e rosirive control

consists of the use of a target bacteria for t.-.e siecifiea test, such

as Esterichia coli. Salror.ella spp., or r.terct:ter sp. , which are

routinely maintained in the laboratory. Positive controls are diluted

to an appropriate concentration and are carriec through the entire

analysis to insure that cultural conditions are maintained. If the

results of the negative or positive control samples indicate

contamination or cultural problems, then all affected samples will be

resaapled and reanalyzed.

F.7.2 Bioassay Standards

The sensitivity of the lineages of all test :r;ar.isrr.s used in the

bioassay studies are routinely evaluated -sing reference toxicants

obtained from USEPA Quality Assurance Program anc or internal toxicant

standards. Test organism sensicivices are compared to specified

tolerances. Control limits are calculated as outlined in Section

F.2.1 of this QAPP. Fresh and saltwater test organisms cultured in

our laboratory are maintained under the recommended environmental

conditions and monitored daily by laboratory personnel.

In accordance with bioassay method protocols, each test

concentration and control samples are analyzes in replicate. A

control sample consisting of the dilution water -sed in the bioassay

are analyzed with every test series. If the response of the control

test organisms are outside control limits, the test conditions are

scrutinized for out-of-control situations. The response of the

control test organisms and the test conditions are reported with each

bioassay. The interpretation of the response and test conditions may

influence the final report. If the test is judged by the Biological

Laboratory Director as unacceptable due to orgar.isa response and/or

laboratory conditions, the test results will be rejected and a new

sample analyzed.

Page 7-8 Revision : Date 01/11/91

F.8 Software Quality Control

Aquatec's Technical Support Division develops software for data

reduction and reporting for the Analytical Laboratory Division. These

programs are requested and specified by the laboratory in terms of

valid assumptions, calculations, and presentation of data. All

software requests are presented to the Laboratory Director who will

evaluate the request in terms of applicability and pass it on to

Technical Support personnel. After the programs are developed but

before they are put into general use by the laboratory, they are

checked and approved by a laboratory representative. Once the

programs have been approved, they are introduced to the laboratory

personnel and the appropriate SOPs are updated ~o reflect changes in

procedures for an analytical method. Record of all software requests,

developments, improvements, and approvals are filed in the project

files.

F.9 Audits

F.9.1 Audits from Regulatory Agencies

As a participant in state and federal certification programs, the

laboratory sections at Aquatec are audited by representatives of the

regulatory agency issuing certification. Audits are usually conducted

on an annual basis and focus on laboratory conformance to the specific

program protocols for which the lab is seeking certification. The

auditor reviews sample handling and tracking documentation, analytical

methodologies, analytical supportive documentation, and final

reports. The audit findings are formally documented and submitted to

the laboratory for corrective action.

F.9.2 Internal Audits

All laboratory sections of the Chemistry Division at Aquatec are

required to participate in semi-annual internal audits which are

administered by the Quality Assurance Officer. The findings of these

audits are formally documented and submitted to the Laboratory

Director and to corporate management. The Laboratory Director will

Page F-9 Revision 5_ Date 01/11/91

-,ave --= responsibilitv for resolving points at issue or for effect:

.-.ecessary changes to the laboratory's practice .:es

.r.e audit program will focus on the following areas:

1. Maintenance of acceptable and complete SOP's in company format.

2. Maintenance of training records. 3. Maintenance of notebooks. 4. Maintenance of instrument records. 5. Evaluation of standards control records. 5. Evaluation of sample handling procedures. 7. Evaluation of data handling and storage procedures.

F.10 Corrective Action

VTnen deficiencies or out-of-control situations exist, the Quality

Assurance Program provides a means of detecting and correcting these

situations. Samples analyzed during out-of-control situations are

reanalyzed prior to reporting of results. There are several levels of

out-of-control situations that raay occur in the laboratory during

analysis.

F.10.1 Bench Level

Corrective action procedures are often handled at the bench level.

If an analyst finds a nonlinear response during calibration of an

instrument, then the instrument is recalibrated before sample analysis

commences. The problem is often corrected by a careful examination of

the preparation or extraction procedure, spike and calibration mixes,

or instrument sensitivity. If the problem persists, it is' brought to

the management level.

F.10.2 Management Level

If resolution at the bench level was not achieved or a deficiency

is detected after the data has left the bench level, then corrective

action becomes the responsibility of the Laboratory Section Head or

Laboratory Director. Unacceptable matrix or surrogate spike

recoveries detected by data review are reported to the Laboratory

raee T-10 Revision 5

11~- -"o ^' '' Q1^ a c6 ^~ / I *. x 7 I

Seccion Head. A decision to rear.alvze the sample or report the

results is r.ade depending on the circumstances. Documentation

procedures :;r sample reanalysis are initiated at this point if

necessary.

F.10.3 Receiving Level

If discrepancies exist in either the documentation of a sample or

its container, a decision nust be trade after consulting vith the

appropriate management personnel. All decisions will be fully

documented. Some examples of container discrepancies are broken

samples, inappropriate containers, cr improper preservation. In these

cases, corrective action involves the Project Director contacting the

client to resolve the problems.

F.10.4 Statistical Events

This type of corrective action can only be monitored if control

charts are kept for an analyte. An out-of-control situation is

defined as data exceeding control limits, unacceptable trends detected

in the charts, or unusual changes in the instrument detection limits.

VThen these situations arise, it is brought to the attention of the

Laboratory Director who will initiate corrective action.

F.10.5 Audit Response

The laboratory is required to respond with corrective action to

the audit findings and recommendations of the regulatory agencies

before certification for a. particular program can be granted. If a

recommendation is related to document format (for example, laboratory

name is absent from a preprinted benchsheet), then the laboratory

personnel will revise the document format and a copy of the revised

document format will be submitted to the appropriate representatives

of the regulatory agency. If a recommendation is related to an actual

procedure (for example, error correction), then the recommendation

will be communicated to the laboratory personnel informing them of the

correct procedure and a record of this communication will be submitted

to the appropriate representatives of the regulatory agency. If a

recommendation is related to the written procedures (for example,

Page ~-ll Revision : Dace 01/11 =1

-ritter. SOPs), tr.en rr.e laboratory -ersonne. -ill revise the -ritts-.

50Ps and a copy of "a rew SC?s -ill be sjsanted to tr.e apprornare

representatives of tra regulatory agencv The Laboratory 7-alitv

Assurance Officer -ill conauct a follow-uo audit to verify at

corrective action nas oeen implemented within one to two weeks of tr.e

audit report. Observations made during this follow-up audit will :e

submitted to the appropriate representatives cf the regulatory agency

F.ll Interlaboratory Testing

The analytical laboratory participates in the EPA

inter-laboratory performance evaluation program for water (VS) S.T.C.

-rastewater (UP) in acciticn ~o evaluations conducted by the states cf

Vermont and New YOTK The analytical laboratory also participates .

the inorganic and organic quarterly performance evaluations conducted

by the EPA. Employee performances are annually evaluated. In sorre

cases, extenuating circumstances will require more frequent

evaluations.

F.12 Inventory Procedures

Purchasing guidelines for all equipment and reagents effecting

data quality are well defined and documented in the sectional SOPs.

Similarly, performance specifications are documented for all items of

equipment having an effect on data quality. Any item critical to the

analysis, an in situ instrument or reagent, received and accepted by

the organization Ls documented. This includes type, age, and

acceptance status of the item. Reagents are dated upon receipt to

establish their order of use and to minimize the possibility of

exceeding their shelf life.

Requests for equipment affecting the quality of analytical data

will be submitted in writing to the Laboratory Director for technical

approval. After approval, the requisition will be submitted to the

company president for purchase approval.

Revision 5 Date 01/11/91

G. DATA VALIDATION AND REPORTING

Each laboratory section provides extensive data validation prior

to reporting results to the client. In general, there are three

levels of review as outlined below. For a complete description of

validation steps and processes, refer to the sectional SOPs or to the

Analytical Laboratories SOP.

The analyst is responsible for primary review of data generated

from sample analysis. If recoveries of all quality control samples

are within specified tolerances, then the data are presented to data

review groups for secondary review. If recoveries cf any quality

control samples exceed specified tolerances, then affected samples are

reanalyzed.

Secondary review is conducted by data review groups to determine

if analytical results are acceptable. If recoveries of all quality

control samples are within specified tolerances, then the data are

presented to Project Directors for final review. If recoveries of any

quality control samples exceed specified tolerances, rhen affected

samples are submitted for reanalysis.

Project Directors determine if all analytical results of a

sample(s) are consistent. If so, then the data are presented in a

final report to the client. If discrepancies or deficiencies exist in

the analytical results, then corrective action is taken. Audits cf

final reports by the Quality Assurance Officer will be conducted to

determine the precision, accuracy, completeness, and

representativeness of sample analyses.

After all analytical data has been reviewed, the final report can

be assembled for submission to the client. Aquatec offers five levels

for reporting analytical results based on Data Quality Objectives

(D.Q.O.). Level I data consists of measurements taken during field

analysis.

Page Revision 5_ Date 01/11 ?1

Level II data requires a specified degree of confidence in the

compound ider.cif ication and quantitaricn. Compound identification

specificity can range from group identification to single compound

identification. Level II reporting consists of an analytical report

with internal quality control results retained at Aquatec.

Level III data requires a high degree of confidence in the

compound identification and quantification, but not necessarily to the

standards of level IV. This degree of confidence is achieved by

examination of the raw laboratory data and the use of applicable

laboratory QA/QC requirements. The frequency of QA/QC checks and

standardizations are less than for level IV analysis. Level III

reporting consists of an analytical report with some internal quality

control results reported; these include reference standards and rethod

blanks.

Level IV data requires the highest degree of confidence in the

compound identification and quantitation. Level IV is defined by the

QA/QC supporting material which is provided by a CLP Regular

Analytical Services Request. The high degree of confidence in the

data are achieved by a thorough examination of the raw laboratory data

and strict laboratory QA/QC controls. These controls include frequent

standardization, spikes, duplicates, blanks, and strict compound

identification criteria.

Level V data has unique requirements in either compound

identification, quantisation, detection limits, cleanup or QA/QC

requirements. Level V analytical procedures are defined through the

use of Special Analytical Services (SAS) requests for CLP. The

procedures and QA/QC are specified through these requests. The QA/QC

for Level V data usually requires frequent standardization, spikes,

duplicates, blanks, and strict compound identification criteria.

Page G-3 Revision : Date 01/11/91

There are five (5) general sections ~o any CL? data package.

Seccicr.s nay be added or deleted depending on the scope of vork.

Section 1 - Narrative

The information contained in the narrative consists of (a) client name and address: (b) cross reference to Aquatec's ETR >/; (c) date of receipt of samples; (d) cross reference of Aquatec's lab number to clients sample ID; (e) a discussion of the analytical work.

Section 2 - Analytical Results

The results of all analyses will be contained in this section including any external quality control as specified by contractual obligations.

Section 3 - Supportive Documentation

This section contains any printouts, chromatograas, and raw data generated from the analyses.

Section 4 - Sample Preparation

Extraction sheets, digestion sheets, I solids, logbook pages, and runlog pages are found in this section.

Section 5 - Sample Handling

All documentation accompanying samples such as sample receipt sheets, internal Chain-of-Custody forms, correspondence,and telephone logs.

Once ;he document is assembled, che sections are distinguished with

blue paper with their respective titles. The pages are paginated in

numerical order and photocopied. Copy(s) of the documentation are

sent co the client, and the original document is retained at Aquatec

in storage for a minimum of seven (7) years.

Page Revision Date 01/11/91

H. SAFETY CONSIDERATIONS

Aquatec has a fundamental responsibility to provide facilities,

equipment, maintenance, and an. organized program to make necessary

improvements to ensure a safe working environment. Unless employees

fulfill their responsibilities for laboratory safety, the

safety-related features of rhe facility and established safety

programs will be ineffective.

The Aquatec building is equipped with many structural safety

features. These include:

* Fire Alarm System * Sprinkler System * Exit Signs * Emergency Lighting System * Fire Extinguishers * Laboratory Showers * Fire Doors * Fire Blankets * Fume Hoods

Each employee will be familiar with the location, use, and

capabilities of general and specialized safety features associated

with their workplace. To protect employees from potential workplace

hazards, Aquatec provides and requires the use of certain items of

protective equipment. These include safety goggles, protective

clothing, gloves, respirators, etc. If employee owned safety

equipment is used, these items will be inspected to assure adequacy

and conformity to applicable regulations. For a complete description

of the types of personal safety equipment available, refer to the

Laboratory SOP Section H.6.

Precautions to be taken in the transportation, storage, and use

of chemical substances are outlined on Material Safety Data Sheets

provided by chemical supply companies. Employees using chemical

substances are to become familiar with the Material Safety Data

Sheets, especially those pertaining to routinely handled chemicals.

These are maintained in a file, available to all employees.

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Resume

JANINE L. BANKS

Sample Management

EDUCATION Rensselear Polytechnic Institu