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MEMORANDUM

16 January 2009 TO: Mark Ridgway, USCG Bob Brock, USAED FROM: Jon McVay SUBJECT: Final August 2008 St. Paul Annual Groundwater Sample Results Jacobs Engineering Group Inc. (Jacobs) conducted groundwater monitoring activities at U.S. Coast Guard (USCG) LORAN Station St. Paul on 16 August 2008. The objectives of this monitoring event were as follows:

Conduct baseline groundwater sampling as part of an Alaska Department of Environmental Conservation (ADEC) and National Oceanic and Atmospheric Administration (NOAA) approved landspread plan.

Assess diesel-range organics (DRO) concentration levels and survey free product in monitoring and extraction wells in accordance with the agreement between USCG and ADEC.

Evaluate groundwater quality as part of a comprehensive site characterization in accordance with the Civilian Federal Agency Task Force Guide for Evaluating Environmental Liability.

The purpose of this technical memorandum is to document and distribute the results of the groundwater monitoring event. These results will also be presented under separate covers to meet other stated objectives.

Groundwater samples were collected from six of the seven monitoring wells located around the perimeter of the LORAN Station (Attachment 1 � LORAN Station Well Maps). The USCG well, which is the former LORAN Station drinking water well, was removed from the sampling program because it was not associated with a contaminant plume and was no longer used as a drinking water well.

Groundwater samples were analyzed for DRO by laboratory method AK102. Table 1 summarizes sample results from the last eight monitoring events. Analytical results from all monitoring wells sampled in 2008 were below the ADEC groundwater cleanup level of 1.5 milligrams per liter (mg/L) (ADEC 2008) (Attachment 2). With permission from ADEC, purge water from the monitoring wells was discharged to the ground surface adjacent to each well.



Table 1 U.S. Coast Guard Groundwater Diesel-Range Organics Data

Monitoring Well Sep-00 Oct-01 Oct-02 Sep-03 Oct-04 Oct-05 Oct-06 Aug-08

DM-7 ND 0.356 ND 0.193 J 0.585 ND [0.313] 0.016 J,B 0.034 J,B,JTE

DM-8 0.16 ND 0.259J 0.146 J 0.852 0.105 J 0.088 J 0.038 J,B,JTE

DM-8 (FD) - - 0.171J 0.093 J 0.992 - - -

DM-12 2.2 1.45 0.728 8.35 0.711 1.18 1.6 0.21 J

DM-12 (FD) - - - - - - - 0.32 J

DM-13 ND 0.332 ND 0.118 J 0.45 ND [0.316] 0.015 J,B 0.039 J,B

DM-14 ND 0.842 ND 0.102 J 0.769 ND [0.319] 0.016 J,B 0.029 J,B

DM-14 (FD) - - - - - ND [0.300] 0.021 J,B -

DM-22 ND ND ND 0.131 J 0.632 ND [0.313] 0.017 J,B 0.043 J,B,JTE

USCG 0.16 ND ND 0.183 J NS NS NS NS

Notes:

All results in mg/L

Bold = a value above the ADEC DRO groundwater cleanup level of 1.5 mg/L (ADEC 2008)

B = The analyte was detected in the method blank or the trip blank above the method detection limit, and the concentration in the sample did not exceed the blank concentration by a factor of five.

FD = field duplicate

J = estimated value that falls below the laboratory reporting limit but above the method detection limit

JTE = Sample cooler temperature upon receipt at the laboratory was outside the range of 4±2°C.

ND = not detected

NS = not sampled

�� = data not available or not applicable

A Data Quality Assessment and ADEC laboratory data review checklists were completed to assess the overall quality and usability of data from the 2008 St. Paul groundwater activities (Attachment 3). The Jacobs Project Chemist performed a data quality review using the 2008 Phase II/III Environmental Due Diligence Audit Investigation Quality Assurance Project Plan. Six primary water samples and one duplicate were submitted for DRO analysis. Columbia Analytical Services of Kelso, Washington, provided primary analytical support for these groundwater samples.

The overall quality of the data was acceptable as qualified with the anomalies below. Data qualifiers are defined at the bottom of Table 1.

AK102 method blank had DRO concentrations above the method detection limit. Associated samples that have a concentration within a factor of 5 of the method blank contamination are qualified �B�. There is no impact on the data since results are

biased high and below the ADEC screening criterion of 1.5 mg/L (ADEC 2008).

Water samples 08-STP-DM22-WG, 08-STP-DM7-WG, and 08-STP-DM8-WG were qualified �JTE� due to cooler �We�ll All Go Down Together� having a temperature

blank of 6.9 °C. The results were minimally affected because they were sampled for DRO only.

In addition to groundwater sampling activities, a free-product survey was conducted in accordance with the shutdown agreement between USCG and ADEC. The 12 free-product extraction wells located at the LORAN Station will continue to be surveyed for free product until two consecutive events are clean. During this field effort, DM-2 and DM-18 could not be located. The use of a metal detector did not reveal DM-2, and


DM-18 was likely covered during construction activities in 2006. Wells DM-4 and DM-15 were dry, and the well vault of DM-5 was full of water. A potential safety hazard was noted by the sampling team because some of the plywood covers to the vaults have decomposed over time. Table 2 presents groundwater depths and free-product survey results for the 7 monitoring wells and 12 extraction wells.

Table 2 August 2008 Groundwater Depth and Free Product Survey Results

Well Depth to Water (feet) Depth to Product (feet) Free Product Thickness (feet)

DM-1 25.21 NA 0.0

DM-2 Could not be located using metal detector.

DM-3 20.63 NA 0.00

DM-4 Dry

DM-5 Vault full of water

DM-6 19.9 19.3 0.5

DM-7 14.86 NA 0.00

DM-8 31.69 NA 0.00

DM-12 25.11 NA 0.00

DM-13 9.42 NA 0.00

DM-14 19.33 NA 0.00

DM-15 Dry

DM-16 20.78 NA 0.00

DM-17 18.61 NA 0.00

DM-18 Could not be located; possibly covered during construction

DM-19 Dry NA 0.00

DM-20 20.82 NA 0.00

DM-21 21.69 NA 0.00

DM-22 10.86 NA 0.00

USCG Removed from sampling program

Note:

NA = not applicable (i.e., no free product measured)

Table 3 provides the free product survey data collected since the HVE system shut down.

In 2008, Wells DM-2 and DM-18 were not located. However, Well DM-1 was located and was in close proximity to Well DM-2. Wells DM-4 and DM-15 were dry and therefore contained no product. The well vault for DM-5 was full of water, but no product or sheen was observed. The product level in DM-6 was measured in a bailer at 0.5 feet. Therefore, all the wells that had product during past events are now free from product, except well DM-6, within which the product level appears to remain stable.


Table 3 Extraction Well Free Product Survey Data

Extraction Well

Number

Jun-03 Product

Thickness

Sep-03 Product

Thickness

Dec-03 Product

Thickness

Mar-04 Product

Thickness

Oct-04 Product

Thickness

Oct-05 Product

Thickness

Oct-06 Product

Thickness

Aug-08 Product

Thickness

DM-1 -- -- -- -- -- -- -- 0.00

DM-2 0.05 0.04 0.03 0.00 0.10 0.01 0.00 --

DM-3 0.00 0.01 0.00 0.00 -- -- 0.00 0.00

DM-4 0.00 0.09 0.03 0.06 0.20 Sheen 0.29 --

DM-5 0.03 0.19 0.03 -- -- 0.00 0.01 --

DM-6 0.00 Sheen 0.01 0.02 0.14 0.64 0.36 0.5

DM-15 0.00 Sheen 0.00 0.00 0.00 0.00 0.00 --

DM-16 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

DM-17 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

DM-18 0.00 0.01 0.05 0.03 Sheen -- -- --

DM-19 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

DM-20 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

DM-21 0.00 0.00 0.00 0.00 0.00 -- 0.00 0.00

Average Thickness

0.01 0.03 0.01 0.01 0.04 0.08 0.06 0.04

Notes:

�--" = Indicates that no product thickness measurement was collected

All results in feet

Conclusions and Recommendations

No analytical results from the monitoring wells exceeded the ADEC groundwater cleanup level for DRO of 1.5 mg/L (ADEC 2008). Results of the monitoring wells were at least one order of magnitude below the cleanup level.

Free product is present only in one well (DM-6), which has had a relatively stable product level since 2005. The product thickness measurement from 2008 (0.5 feet) is equivalent to approximately 0.082 gallons of free product in a 2-inch-diameter well and 0.33 gallons of free product in a 4-inch annulus.

Based on these data, it is recommended that annual groundwater monitoring be conducted for well DM-12 until such time that cleanup levels are achieved for one additional consecutive monitoring event. It is also recommend that free-product surveys continue on wells that previously contained free product until such time that no free product has been detected for two consecutive monitoring events. Free-product surveys should continue for monitoring wells DM-1, DM-2, DM-4, DM-5, DM-6, and DM-18.

It is also recommended that although the integrity of most vault covers appears to be intact, they be inspected occasionally and repaired if necessary to avoid potential physical hazards. USCG should also evaluate pumping the water-filled vault.


Attachments:

1. LORAN Station Well Maps

2. Laboratory Data

3. ADEC Data Quality Checklist

4. Comment Response Form

Attachment 1 � LORAN Station Well Maps

POLOVINA TURNPIKE

WELL ROAD

FREDREKA 3

FREDREKA 2

FREDREKA 1

FREDREKA 4

FREDREKA 5

USCG WELL

NORTH WELL

LARGELAKE

CUPLAKE

SAUCERLAKE

CITY DRINKING WATER WELLS

LEGEND

COAST GUARD MONITORING WELL

DM-8

EUREKA WELL

DM-7

DM-14

DM-12

DM-13

LEACH FIELD

HELICOPTERPAD

DM-1

ROCKYLAKE

DM-3

DM-5

DM-4DM-6

DM-2

DM-22

05M31301

CITY AND MONITORINGWELL SITE MAP

ST. PAUL ISLAND LORAN STATION, ALASKAJOB NO:

DATE: FIG1.DWG

L.A.Y.DRAWN:

FILE:1/20/00FIGURE 1

250 500 1000

SOUTH WELL


Attachment 2 � Laboratory Data

Sample IDSDG

Sample DateMatrixLab

08-STP-DM12-WGK08077348/16/2008

WCASK

08-STP-DM12-WG-DK08077348/16/2008

WCASK

08-STP-DM13-WGK08077348/16/2008

WCASK

08-STP-DM14-WGK08077358/16/2008

WCASK

Method Analyte Units Screening Level1

AK102 Diesel Range Organics mg/L 1.5 0.21 [0.77] J 0.32 [0.77] J 0.039 [0.79] J,B 0.029 [0.78] J,B

mg/L = milligram per liter[ ] = practical quantitation limit

2008 St. Paul Phase II-III Water Samples

B = The analyte was detected in the method blank or the trip blank above the MDL, and the concentration in the sample did not exceed the blank concentration by a factor of 5 (factor of 10 for common volatile laboratory contaminants acetone and methylene chloride).


Notes:

1 = criteria 18 AAC 75 Table C, Groundwater Cleanup Levels.J = The analyte was positively identified, but the associated result was less than the PQL but greater than or equal to the MDL.


Sample IDSDG

Sample DateMatrixLab

Method Analyte Units Screening Level1

AK102 Diesel Range Organics mg/L 1.5

mg/L = milligram per liter[ ] = practical quantitation limit

2008 St. Paul Phase II-III Water Samples

B = The analyte was detected in the method blank or the trip blank above the MDL, and the concentration in the sample did not exceed the blank concentration by a factor of 5 (factor of 10 for common volatile laboratory contaminants acetone and methylene chloride).


Notes:

1 = criteria 18 AAC 75 Table C, Groundwater Cleanup Levels.J = The analyte was positively identified, but the associated result was less than the PQL but greater than or equal to the MDL.

08-STP-DM22-WGK08077348/16/2008

WCASK

08-STP-DM7-WGK08077348/16/2008

WCASK

08-STP-DM8-WGK08077348/16/2008

WCASK

0.043 [0.8] J,B,JTE 0.034 [0.8] J,B,JTE 0.038 [0.8] J,B,JTE










Attachment 3 � ADEC Data Quality Checklist

Version 2.5 Page 1 of 8 04/08

Laboratory Data Review Checklist

Completed by: Title: Date: CS Report Name: Report Date: Consultant Firm: Laboratory Name: Laboratory Report Number: ADEC File Number: ADEC RecKey Number: 1. Laboratory

a. Did an ADEC CS approved laboratory receive and perform all of the submitted sample analyses?

Yes

No

Comments:

b. If the samples were transferred to another �network� laboratory or sub-contracted to an alternate

laboratory, was the laboratory performing the analyses ADEC CS approved?

Yes

No

Comments:

2. Chain of Custody (COC)

a. COC information completed, signed, and dated (including released/received by)?

Yes

No

Comments:

Angela Elmore - Jacobs Engineering

Project Chemist

October 21, 2008

2008 St. Paul Phase II and Phase III

November 2008

Jacobs Engineering

Columbia Analytical

K0807734

2644.38.031

N/A

CAS signed for the coolers twice.



b. Correct analyses requested?

Yes

No

Comments:

3. Laboratory Sample Receipt Documentation

a. Sample/cooler temperature documented and within range at receipt (4° ± 2° C)?

Yes

No

Comments:

b. Sample preservation acceptable � acidified waters, Methanol preserved VOC soil (GRO, BTEX,

Volatile Chlorinated Solvents, etc.)?

Yes

No

Comments:

c. Sample condition documented � broken, leaking (Methanol), zero headspace (VOC vials)?

Yes

No

Comments:

d. If there were any discrepancies, were they documented? For example, incorrect sample

containers/preservation, sample temperature outside of acceptable range, insufficient or missing samples, etc.?

Yes

No

Comments:

e. Data quality or usability affected? Explain.

Comments:

4. Case Narrative

a. Present and understandable?

Yes

No

Comments:

Cooler "We'll all go down together" cooler temperature 7.0°C, temperature blank 6.9°C. Cooler "Movin Out" cooler temperature 5.5°C, temperature blank 6.5°C.

Samples were received in good condition.

Discrepancies are noted in the case narrative and the cooler receipt form

Samples in cooler "We'll all go down together" are flagged JTE due to temperatures exceeding 6°C. The affect is minimal since the samples were analyzed for DRO.


b. Discrepancies, errors or QC failures identified by the lab?

Yes

No

Comments:

c. Were all corrective actions documented?

Yes

No

Comments:

d. What is the effect on data quality/usability according to the case narrative?

Comments:

5. Samples Results

a. Correct analyses performed/reported as requested on COC?

Yes

No

Comments:

b. All applicable holding times met?

Yes

No

Comments:

c. All soils reported on a dry weight basis?

Yes

No

Comments:

d. Are the reported PQLs less than the Cleanup Level or the minimum required detection level for

the project?

Yes

No

Comments:


Comments:

No anomalies were identified by the lab.

No corrective actions were necessary.

Data quality/usability has not affected according to the case narrative.

N/A

Data quality and usability has not been affected.


6. QC Samples

a. Method Blank i. One method blank reported per matrix, analysis and 20 samples?

Yes

No

Comments:

ii. All method blank results less than PQL?

Yes

No

Comments:

iii. If above PQL, what samples are affected?

Comments:

iv. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

Yes

No

Comments:

v. Data quality or usability affected? Explain.

Comments:

b. Laboratory Control Sample/Duplicate (LCS/LCSD)

i. Organics � One LCS/LCSD reported per matrix, analysis and 20 samples? (LCS/LCSD required per AK methods, LCS required per SW846)

Yes

No

Comments:

No analytes were detected above the PQL in the method blank. DRO was detected above the MDL in batch KWG0808161.

According to the project QAPP samples within a factor of five of method blank contamination will be qualified "B" and considered biased high. AK102 - DRO was detected in the method blank associated with batch KWG0808161 samples 08-STP-DM13-WG, 08-STP-DM14-WG, 08-STP-DM22-WG, 08-STP-DM7-WG, and 08-STP-DM8-WG were within a factor of five.

According to the project QAPP samples within a factor of five of method blank contamination will be qualified "B" and considered potentially biased high.

Data qualified "B" should be considered potentially biased high. The impact is minimal since all results are below screening levels.


ii. Metals/Inorganics � one LCS and one sample duplicate reported per matrix, analysis and 20 samples?

Yes

No

Comments:

iii. Accuracy � All percent recoveries (%R) reported and within method or laboratory limits?

And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, AK102 75%-125%, AK103 60%-120%; all other analyses see the laboratory QC pages)

Yes

No

Comments:

iv. Precision � All relative percent differences (RPD) reported and less than method or

laboratory limits? And project specified DQOs, if applicable. RPD reported from LCS/LCSD, MS/MSD, and or sample/sample duplicate. (AK Petroleum methods 20%; all other analyses see the laboratory QC pages)

Yes

No

Comments:

v. If %R or RPD is outside of acceptable limits, what samples are affected?

Comments:

vi. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

Yes

No

Comments:

vii. Data quality or usability affected? Explain.

Comments:

c. Surrogates � Organics Only

i. Are surrogate recoveries reported for organic analyses � field, QC and laboratory samples?

Yes

No

Comments:

N/A

All LCS and MS recoveries were within AK method control limits.

N/A

N/A



ii. Accuracy � All percent recoveries (%R) reported and within method or laboratory limits? And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other analyses see the laboratory report pages)

Yes

No

Comments:

iii. Do the sample results with failed surrogate recoveries have data flags? If so, are the data

flags clearly defined?

Yes

No

Comments:

iv. Data quality or usability affected? Explain.

Comments:

d. Trip blank � Volatile analyses only (GRO, BTEX, Volatile Chlorinated Solvents, etc.): Water and

Soil i. One trip blank reported per matrix, analysis and cooler?

Yes

No

Comments:

ii. All results less than PQL?

Yes

No

Comments:


Comments:


Comments:

e. Field Duplicate

i. One field duplicate submitted per matrix, analysis and 10 project samples?

Yes

No

Comments:

N/A


N/A

N/A

N/A

N/A

The project frequency of 10% duplicates was met.


ii. Submitted blind to lab?

Yes

No

Comments:

iii. Precision � All relative percent differences (RPD) less than specified DQOs?

(Recommended: 30% water, 50% soil) RPD (%) = Absolute value of: (R1-R2)

x 100

((R1+R2)/2)

Where R1 = Sample Concentration R2 = Field Duplicate Concentration

Yes

No

Comments:


Comments:

f. Decontamination or Equipment Blank (if applicable)

Yes

No

Not Applicable

i. All results less than PQL?

Yes

No

Comments:

ii. If above PQL, what samples are affected?

Comments:

iii. Data quality or usability affected? Explain.

Comments:

Duplicate pairs were compared to EM 200-1-6, Table 4-1 "Criteria for Comparing Field QC and QA Sample Data". Duplicate pair 08-STP-DM12-WG/08-STP-DM12-WG-D was associated with this SDG. DRO results were in "agreement".



7. Other Data Flags/Qualifiers (ACOE, AFCEE, Lab Specific, etc.)

a. Defined and appropriate?

Yes

No

Comments:

Data qualifiers that apply to this data set are defined in the DQA.


Laboratory Data Review Checklist

Completed by: Title: Date: CS Report Name: Report Date: Consultant Firm: Laboratory Name: Laboratory Report Number: ADEC File Number: ADEC RecKey Number: 1. Laboratory

a. Did an ADEC CS approved laboratory receive and perform all of the submitted sample analyses?

Yes

No

Comments:

b. If the samples were transferred to another �network� laboratory or sub-contracted to an alternate

laboratory, was the laboratory performing the analyses ADEC CS approved?

Yes

No

Comments:

2. Chain of Custody (COC)

a. COC information completed, signed, and dated (including released/received by)?

Yes

No

Comments:

Angela Elmore - Jacobs Engineering

Project Chemist

October 01, 2008

2008 St. Paul Phase II and Phase III

November 2008

Jacobs Engineering

Columbia Analytical Services, Kelso, WA.

K0807735

2644.38.031

N/A



b. Correct analyses requested?

Yes

No

Comments:

3. Laboratory Sample Receipt Documentation

a. Sample/cooler temperature documented and within range at receipt (4° ± 2° C)?

Yes

No

Comments:

b. Sample preservation acceptable � acidified waters, Methanol preserved VOC soil (GRO, BTEX,

Volatile Chlorinated Solvents, etc.)?

Yes

No

Comments:

c. Sample condition documented � broken, leaking (Methanol), zero headspace (VOC vials)?

Yes

No

Comments:

d. If there were any discrepancies, were they documented? For example, incorrect sample

containers/preservation, sample temperature outside of acceptable range, insufficient or missing samples, etc.?

Yes

No

Comments:


Comments:

4. Case Narrative

a. Present and understandable?

Yes

No

Comments:

Cooler "You may be right" temperature blank 6.0°C, cooler temp 5.7°C Cooler "We didn't start the fire" temperature blank 6.2°, cooler temp 4.9°C

All samples received in good condition.

There were no discrepancies according the case narrative and cooler receipt form.



b. Discrepancies, errors or QC failures identified by the lab?

Yes

No

Comments:

c. Were all corrective actions documented?

Yes

No

Comments:

d. What is the effect on data quality/usability according to the case narrative?

Comments:

5. Samples Results

a. Correct analyses performed/reported as requested on COC?

Yes

No

Comments:

b. All applicable holding times met?

Yes

No

Comments:

c. All soils reported on a dry weight basis?

Yes

No

Comments:

QC failures identified by the laboratory are noted in the appropriate sections of this checklist. Other QC items include: Manual integrations for SW8260B

No further corrective action was taken.

There is not affect on data quality/usability according to the case narrative.


d. Are the reported PQLs less than the Cleanup Level or the minimum required detection level for the project?

Yes

No

Comments:


Comments:

6. QC Samples

a. Method Blank i. One method blank reported per matrix, analysis and 20 samples?

Yes

No

Comments:

ii. All method blank results less than PQL?

Yes

No

Comments:

Laboratory PQLs were evaluated against one-tenth of the regulatory screening levels listed in the project QAPP. If the PQL did not meet these qualifications, then the MDL was evaluated. The MDLs associated with these PQLs were reviewed and SW8260B analytes for sample 08-STP-GB-TB-09A did not meet these data quality objectives: Benzene, Carbon tetrachloride, 1,2-Dichloroethane, 1,1-Dichloroethene, 1,2-Dichloropropane, 1,2-Dibromoethane, 1,1,2,2-Tetrachloroethane, Tetrachloroethene (PCE), 1,1,2-Trichloroethane, Trichloroethene (TCE), 1,2,3-Trichloropropane, and Vinyl chloride. The MDL for benzene did not meet data quality objectives for samples: 08-STP-LS-TB-10A, 08-STP-LS1, 08-STP-LS2, 08-STP-LS3, 08-STP-LS4, 08-STP-GB-SO-01D, and 08-STP-GB-SO-53D. The following MDLs exceeded ADEC screening levels: 1,2,3-Trichloropropane, 1,2-Dibromoethane, and Vinyl chloride.

The MDL did not meet project goals for several analytes due to limitations in the analytical methodology. Therefore, the impact on the data is minimal.

According to the project QAPP all samples associated with method blanks with detections above the MDL and within a factor of five would be qualified "B" and considered potentially biased high. Method blanks had detections above the MDL but below the PQL.


iii. If above PQL, what samples are affected? Comments:

iv. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

Yes

No

Comments:

The following samples are affected by method blank contamination found above the MDL but below the PQL and within a factor of five: Samples 08-STP-LS1-4 are part of the St. Paul landspreading activities and are not included in this report. SW8260B - soils 1,2,3-Trichlorobenzene, 1,2,4-Trichlorobenzene, Acetone, and Naphthalene were detected in the MB associated with batch KWG0808584. The associated results for 08-STP-GB-TB-09A were less than 5 times the concentration found in MB. These results are not qualified because this is the trip blank, no other samples were affected. SW8270 Naphthalene was detected at 0.0004 mg/kg in batch KWG0808515 method blank, which is greater than the MDL and less than the PQL. The associated results for 08-STP-LS4, 08-STP-LS3, and 08-STP-LS1 were less than 5 times the concentration found in MB and were qualified "B". AK102 DRO was detected at 3.6 mg/kg in batch KWG0808567 method blank, which is greater than the MDL and less than the PQL. The associated DRO results for 08-STP-LS3, 08-STP-LS2, and 08-STP-LS1 were less than 5 times the concentration found in MB and were qualified "B". DRO was detected at 3.2 mg/kg in batch KWG0808625 method blank, which is greater than the MDL and less than the PQL. The associated DRO result for 08-STP-GB-SO-53D was less than 5 times the concentration found in MB and was qualified "B".These results are listed in the DQA. AK103 RRO was detected at 8.4 mg/kg in batch KWG0809042 method blank, which is greater than the MDL and less than the PQL. The associated RRO results for 08-STP-GB-SO-53D, and 08-STP-GB-SO-01D were less than 5 times the concentration found in MB and were qualified "B". RRO was detected at 11 mg/kg in batch KWG0808929 method blank, which is greater than the MDL and less than the PQL. The associated DRO result for 08-STP-LS4, 08-STP-LS3, 08-STP-LS2, and 08-STP-LS1 were less than 5 times the concentration found in MB and were qualified "B".These results are listed in the DQA. AK102-aqueous DRO was detected at 0.037 mg/L in batch KWG0808161 method blank, which is greater than the MDL and less than the PQL. The associated DRO result for 08-STP-DM14-WG was less than 5 times the concentration found in MB and were qualified "B".These results are listed in the DQA.

Please refer to the DQA and the statement above. Samples associated with method blanks with detections above the MDL and within a factor of five would be qualified "B".


v. Data quality or usability affected? Explain. Comments:

b. Laboratory Control Sample/Duplicate (LCS/LCSD)

i. Organics � One LCS/LCSD reported per matrix, analysis and 20 samples? (LCS/LCSD required per AK methods, LCS required per SW846)

Yes

No

Comments:

ii. Metals/Inorganics � one LCS and one sample duplicate reported per matrix, analysis and

20 samples?

Yes

No

Comments:

iii. Accuracy � All percent recoveries (%R) reported and within method or laboratory limits?

And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, AK102 75%-125%, AK103 60%-120%; all other analyses see the laboratory QC pages)

Yes

No

Comments:

iv. Precision � All relative percent differences (RPD) reported and less than method or

laboratory limits? And project specified DQOs, if applicable. RPD reported from LCS/LCSD, MS/MSD, and or sample/sample duplicate. (AK Petroleum methods 20%; all other analyses see the laboratory QC pages)

Yes

No

Comments:

v. If %R or RPD is outside of acceptable limits, what samples are affected?

Comments:

All results qualified "B" may be considered potentially biased high. However, all results were below the ADEC screening levels. There was minimal impact on the data.

N/A

All LCS recoveries were within AK Method or DoD QSM v.3 control limits The following matrix spike recoveries were not within control limits SW8260B Recoveries of ethylbenzene and m,p-xylenes were slightly lower than control limits in the MS (batch KWG0808584) performed on sample 08-STP-LS4. Results were qualified "JM-". Samples 08-STP-LS1-4 are part of the St. Paul landspreading activities and are not included in this report.

The parent sample 08-STP-LS4 is affected by the matrix spike associated with batch KWG0808584.


vi. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

Yes

No

Comments:

vii. Data quality or usability affected? Explain.

Comments:

c. Surrogates � Organics Only

i. Are surrogate recoveries reported for organic analyses � field, QC and laboratory samples?

Yes

No

Comments:

ii. Accuracy � All percent recoveries (%R) reported and within method or laboratory limits?

And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other analyses see the laboratory report pages)

Yes

No

Comments:

iii. Do the sample results with failed surrogate recoveries have data flags? If so, are the data

flags clearly defined?

Yes

No

Comments:


Comments:

d. Trip blank � Volatile analyses only (GRO, BTEX, Volatile Chlorinated Solvents, etc.): Water and

Soil i. One trip blank reported per matrix, analysis and cooler?

Yes

No

Comments:

Sample 08-STP-LS4 is qualified "JM-" for ethylbenzene and m,p-xylenes because the analyte failed recovery in the MS sample.

Although "JM-" qualified data may be considered potentially biased low, the MSD and LCS were within control limits so there is no impact on the usability of the data.

N/A



ii. All results less than PQL?

Yes

No

Comments:


Comments:


Comments:

e. Field Duplicate

i. One field duplicate submitted per matrix, analysis and 10 project samples?

Yes

No

Comments:

ii. Submitted blind to lab?

Yes

No

Comments:

iii. Precision � All relative percent differences (RPD) less than specified DQOs?

(Recommended: 30% water, 50% soil) RPD (%) = Absolute value of: (R1-R2)

x 100

((R1+R2)/2)

Where R1 = Sample Concentration R2 = Field Duplicate Concentration

Yes

No

Comments:

According to the project QAPP all samples associated with trip blanks with detections above the MDL and within a factor of five would be qualified "B" and considered potentially biased high.

The following analytes were detected above the MDL but below the PQL in trip blank (08-STP-GB-TB-09A): Acetone, Toluene, 1,4-Dichlorobenzene, Methylene chloride, Naphthalene, 1,2,3-Trichlorobenzene, and 1,2,4-Trichlorobenzene. Samples in this SDG were not affected by the trip blank contamination because they were analyzed for BTEX only.

Data quality has not been affected.

The project frequency of 10% duplicates was met for all methods. SW8260B was submitted for both full list and the BTEX list. They did not meet the frequency goals for the full analyt list. No field duplicates were submitted with this sample delivery group.

N/A

N/A



Comments:

f. Decontamination or Equipment Blank (if applicable)

Yes

No

Not Applicable

i. All results less than PQL?

Yes

No

Comments:

ii. If above PQL, what samples are affected?

Comments:

iii. Data quality or usability affected? Explain.

Comments:

7. Other Data Flags/Qualifiers (ACOE, AFCEE, Lab Specific, etc.)

a. Defined and appropriate?

Yes

No

Comments:

N/A

All data flags were defined in the Data Quality Assessment and the QAPP.

Attachment 4 � Comment Response Form

REVIEW PROJECT: USCG St. Paul LORAN Station EDDA LOCATION: St. Paul, AK COMMENTS DOCUMENT: DRAFT ST. PAUL ANNUAL GROUNDWATER SAMPLE RESULTS DECEMBER 19, 2008 COMPANY: ADEC

DATE: 12/19/2008 REVIEWER: Louis Howard PHONE: (907) 269-7552

Action taken on comment by: Jacobs

Item No.

Drawing Sht. No., Spec. Para.

COMMENTS REVIEW CONFERENCE A - accepted

W - withdrawn (if neither, explain)

JACOBS RESPONSE USACE RESPONSE ACCEPTANCE

(A-AGREE) (D-DISAGREE)

I:\ERS-UR\TO09-13 USCG\TO09 St Paul\COMMON\Report\2008 GW Tech Memo\Comments_ADEC.doc Page 1 of 1

1 Conclusions and

Recommendations The text states that no analytical results

from the monitoring wells exceeded the

ADEC groundwater cleanup level for

diesel range organics (1.5 mg/L). ADEC

concurs, however, efforts should be

made one more time to locate DM-2 and

DM-18 which could not be located in

August 2008. Cooler temperatures

appears to be outside the acceptable

range of 4 degrees C plus or minus 2

degrees C (e.g. cooler temperatures of 7

degrees and 6.4 degrees C).

A Agreed. Wells DM-2 and DM-18

will continue to be included among

the free product survey wells as

recommended in this section.

Attempts will again be made to

locate these two wells within the

LORSTA parking lot using a metal

detector and survey coordinates.

The temperature issue is discussed

in the DQA and ADEC checklist.

The data results are flagged �JTE-�

indicating results may be biased

low; however, these samples were

only analyzed for DRO, which is

not a volatile analyte, minimizing

the effect of increased

temperature to these samples.

2 6.0 References Page

6-1

Contaminated sites regulations have

been changed. ADEC requests the Coast

Guard change the text to reflect the

most current version in effect (revised

as of October 9, 2008).

A Agreed. Any references to ADEC

regulations will be updated to

reflect the October 9, 2008

version.


Documents

Final GW Memo 2008.doc - pdfMachine from Broadgun Software, … · 2009-01-19 · I:\ERS-UR\TO09-13 USCG\TO09 St Paul\COMMON\Report\2008 GW Tech Memo\Final GW Memo 2008.doc AKERS-UR-05F509-J02-0002