98
Quality Assurance Project Plan for the Sharon Steel Corporation Fairmont Coke Works Site Fairmont, WV preparedfor submission to: U.S. Environmental Protection Agency 841 Chestnut Street Philadelphia, Pennsylvania 19107 ERA prepared on befiatfof: Exxon Company, U.S.A. P.O. Box 728 Linden, NJ 07036 preparedBy ICF Kaiser Engineers, Inc. Gateway View Plaza 1600 West Carson Street Pittsburgh, PA 15219-1031 IGF KAISER August 1998 KHurSQS ARIOI756

QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

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Page 1: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

Quality Assurance Project Plan

for theSharon Steel CorporationFairmont Coke Works SiteFairmont, WV

prepared for submission to:U.S. Environmental Protection Agency841 Chestnut StreetPhiladelphia, Pennsylvania 19107 ERAprepared on befiatfof:Exxon Company, U.S.A.P.O. Box 728Linden, NJ 07036

preparedByICF Kaiser Engineers, Inc.Gateway View Plaza1600 West Carson StreetPittsburgh, PA 15219-1031

IGF KAISER

August 1998KHurSQS

A R I O I 7 5 6

Page 2: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

Quality Assurance Project Plan

for the.Sharon Steel CorporationFairmont Coke Works SiteFairmont, WV

prepared for submission to:U.S. Environmental Protection Agency841 Chestnut StreetPhiladelphia, Pennsylvania 19107 ERAprepared on behalf of:Exxon Company, U.S.A.P.O. Box 728Linden, NJ 07036

prepared'fyICF Kaiser Engineers, Inc.Gateway View Plaza1600 West Carson StreetPittsburgh, PA 15219-1031

ICF KAISER

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Page 3: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

Distribution List:

Exxon:

ICF Kaiser:

Mr. Arthur Chin

Dr. W. James Bover

Mr. Douglas Taylor_

Mr. Frank Markert

Mr. Richard McCracken

Mr. George Werkman_

U.S. EPA:

Ms. Melissa Whittington

West Virginia DEP:

Accutest:

Mr. Tom Bass

Mr. Matt Cordova

Shoron Steel, QAPP70812-16-B

A R I O I 7 5 8Final

August 1998

Page 4: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

, , TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION .........................................................;...........................................,......,...........1-11.1 PROJECT BACKGROUND .,,,.,,,,„„„„„„,,„.,,,,,,,,,.,.,,.,,,,„.,,,,„,,,,„..„. 1-11.2 ESI PURPOSE.............................................................................^1.3 COMPLEMENTARY DOCUMENTS.....................™

2.0 PROJECT ORGANIZATION ,,,.,,,,,,.,,,,,,,,..,,,,,,.,,.,,.,..,,,,.,,,,.,,,,.,,,,,.2-l2.1 PRIME CONTRACTOR.......................................................................................................2-12.2 LABORATORY....................................................................................................................2-32.3 DATA QUALITY ASSESSMENT........................................................................................2-3

3.0 DATA QUALITY OBJECTIVES .................................................................................................3-13.1 PROBLEMTO BE RESOLVED.........................................................................................3-13.2 DECISION TO BE MADE....................................................................................................3-13.3 INPUTS TOTHE DECISION ............................................................................................3-13.4 BOUNDARIES OF THE STUDY........,................,,,,....,,,,,.,.,,,,,,,,.,,........,.......3-13.5 DECISION RULES ...................................:...........................................................................3-23.6 ACCEPTABLE DECISION ERRORS...................................................................................3-23.7 SAMPLE DESIGN,,,,,.,,..,,,,,,,.,..,.,,,,,,,,,,,,,,.,,,,,,,,,,..,,..,,,;.,,,,3-2

4.0 FIELD OPERATIONS,.,,,,,.......,.,,,,..,...,.,..,.,..,.,.,..,..,,,..........,.,..,...,,,,,,,,,,,4-1

5.0 LABORATORY OPERATIONS ..................................................................................................5-5.1 ANALYTICAL PROCEDURES...........................................................................................^-5.2 QC REQUIREMENTS..........................................................................................................5-

6.0 DATA REDUCTION, VALIDATION, AND REPORTING .........................................................6-6.1 DATA REDUCTION ...............................;...:.....................................................,,,,,.,,....6-6.2 DATAREVIEW.,.,,,...,.,,,,,,,,.,.,.,,,,,,,,.,,,.,.,.,,,,,,,,,,.,,,,,.,^^

6.2.1 Laboratory Data -First Level Review..............................................,,.,.,,,,..,,,,,6-26.2.2 Laboratory Data - Second Level Review „,„„„,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,.6-26.2.3 Laboratory Data - Third Level Review.,,.,...,,,,,,,,,,,,,,,,,,,,,..,,,.,,,,,,6-36.2.4 Compliance Review...,.,,,..,,,.,,,....,,,....,,,,,,,,,,,,,,..,...,.....,.,,,..,,,,6-36.2.5 Data Acceptance Review,,,,,.,.,,,,,,,,,..,,,,......,,,...................................,....6-36.2.6 Field Data - Review .,,,,.,,,,,,,,,,,,.,,,,,,,,,,,,,,.,.,,.,,.....,,..,,...........6-46.2.7 Data Usability Assessment,,,.,,,,,,..,.,.,,,,,...,,,,,,,,,,,,,,,,,,,,,,,,,,6-46.2.8 Data Validation...........,.,...................,,,.,,,,,,..,.....,,,,,,,,,,,,,,,,,,,,,,,6-6

6.3 DATAREPORTING.................,..,,,,....,,,.,,,,.,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,6-66.3.1 Reporting Units..............................................................................................6-66.3.2 Non-Contract Laboratory Program Method Report.,,,,,,.,,,,.,,,,,,,,,,,,,,,,.6-66.3.3 Contract Laboratory Program - Method Report ,,,,,,,,,,,,,,,,,,,,,,.,,,,,,,,6-76.3.4 Laboratory Diskette Deliverables..............................................................................,,6-76.3.5 Distribution of Reports and Diskette Deliverables .....................,,,,,,,,,,,,,,,,,,6-86.3.6 Project Database .,....,..........,,....,........,......,.,,.,,,,,,,,,,,,,,,,,,,,,.,:........6-8

7.0 PERFORMANCE AND SYSTEM AUD1TS.................................................................................7-17.1 FIELD PROCEDURES .........................................................................................................7-1

Shorten Steel, QAPP Final70812-16-B i August 1998

A R I O I 7 5 9

Page 5: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

TABLE OF CONTENTS (Continued)

Section Page

7.2 LABOfttTORY.....................................^

8.0 CORRECTIVE ACTION PROCEDURES....................................................................................8-18.1 FIELD ACTIVITIES.............................................................................................................8-18.2 LABORATORY......................................................................._

9.0 QUALITY ASSURANCE REPORTS..........................................................................................9-1

List of Figures

Figure Page

2-1 Project Organization Chart............................................................................................................2-4

List of Tables

Table Page

3-1 Field QC Samples.........................................................................................................................3-75-1 Analytical Methods and Required Detection Limits.......................................................................5-2

Anncndices

Appendix A Resumes of Key ICF Kaiser PersonnelAppendix B Accutest Organization Chart and QA Plan SummaryAppendix C Summary of Selected CLP QC RequirementsAppendix D Laboratory Audit Checklist

Sharon Steel QAPP70812-16-B

A R I O I 7 6 0Final

August 1998

Page 6: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

Section 1

1SAHCO

CD

oc

Page 7: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

1.0 INTRODUCTION

On September 23, 1997, the United States Environmental Protection Agency (USEPA) and ExxonCompany, U.S.A. (Exxon) entered into an Administrative Order on Consent, Docket No. III-97-103-DC(Consent Order) for a Remedial Investigation and Feasibility Study (RI/FS) at the Sharon SteelCorporation - Fairmont Coke Works Superfund Site (Site). Exxon has contracted ICF Kaiser Engineers,Inc. (ICF Kaiser) to develop the RI/FS scoping documents, including the Quality Assurance Project Plan(QAPjP) as presented herein. This QAPjP has been developed in support of the Expanded SiteInvestigation Work Plan (ES/WP) and subsequent Engineering Evaluation/Cost Analysis (EE/CA(s)), ifnecessary.

This QAPjP for the Site ESI RI/FS (together with the companion Field Sampling Plan) was developed tofulfill the requirements of the USEPA Quality Assurance (QA) program, as specified in the ConsentOrder for the RI/FS. The QAPjP will ensure that reliable environmental data is collected by serving asthe instrument of control for all field and analytical activities associated with the project. The overall QAobjective is to provide data and data reporting that is representative of Site conditions and legallydefensible in a court of law. The QAPjP Will ensure that this objective is met by providing details on thefollowing subjects:

• Data Management, including project data quality objectives;• Measurement and Data Acquisition Activities;• Assessment and Oversight;• Data Validation and Usability

1.1 PROJECT BACKGROUND

The project background is described in detail in the Site Work Plan

1.2 ESI PURPOSE

The ESI purpose is described in detail in the Site Work Plan.

1.3 COMPLEMENTARY DOCUMENTS

This QAPjP is being written in conjunction with the Site Work Plan and the Site Field Sampling Plan.Selected sections of the Work Plan and Field Sampling Plan will be referenced in this document so as toeliminate redundancies and excess verbiage. In addition, the Administrative Order on Consent forRemedial Investigation/Feasibility Study, Docket No. HI-97-103-DC, effective September 23, 1997, isalso referenced.

Sharon Steel, QAPP M Final70812-16-B August 1998

A R I O I 7 6 2

Page 8: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

Section 2

iEd *CO s

*

I

CO

CD

or

Page 9: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

2.0 PROJECT ORGANIZATION

2.1 PRIME CONTRACTOR

Exxon has the overall responsibility for compliance with the requirements contained in the ConsentOrder, including scoping and performing the RI/FS. Exxon has retained ICF Kaiser to prepare scopingdocuments and execute the field investigation activities as approved by USEPA.

ICF Kaiser will assume overall responsibility for QA. ICF Kaiser will provide guidance and coordinateall QA activities, conduct all field sampling, monitor the performance of subcontractors and field teams,and prepare site investigation reports. Key personnel for the remedial investigation are illustrated inFigure 2-1. Accutest Laboratories has been retained by Exxon to provide all analytical services needed tocomplete the remedial investigation. Additional subcontractors (driller, surveyor) will be identified priorto project initiation.

Key project personnel and their authority and responsibilities with respect to QA functions are brieflydescribed below. Resumes of key ICF Kaiser personnel are included in Appendix A.

Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395)

The Exxon project manager will act as the contact with USEPA for all matters concerning the ConsentOrder.

ICF Kaiser Project Manager Mr. Douglas B. Tavlor: (Telephone 412/497-2330

The ICF Kaiser project manager assumes overall responsibility for project quality and is the interfacebetween project staff, Exxon, and the ICF Kaiser and Exxon corporate QA and Health and Safetyorganizations. The ICF Kaiser project manager has the authority and responsibility to implementcorrective actions based on findings or recommendations from the QA, H&S, or USEPA oversight staff.The ICF Kaiser project manager is responsible for planning, scheduling, and assigning personnel tasks tobest meet project needs. Additional responsibilities of the ICF Kaiser project manager include oversightand coordination of all contractors and subcontractors. Mr. Taylor is the only person who can approvemajor changes to the scoping documents (with prior approval of Exxon and USEPA). He also has theauthority to require corrective action by subcontractors for work not performed in accordance with theFSPortheQAPjP.

Sharon Steel, QAPP 2-1 Final708I2-I6-B August 1998

A R I O I 7 6 U

Page 10: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

1CF Kaiser OA Officer. Mr. Richard McCracken: (Telephone 412/4*>7-J380)

The QA Officer (QAO) is responsible for development and implementation of the Quality AssuranceProject Plan. He is responsible for field sampling system audits, analytical subcontractor surveillance,data quality assessment coordination, and QA reports to management. Analytical subcontractorsurveillance will include determining that all laboratories operate under an established and approvedQA/QC program within the guidelines of this project. The QAO has the responsibility for reviewing andapproving this QAPjP. He also has full authority to require corrective action when field operations arenot in compliance with the QAPjP. The QAO has the authority and responsibility to stop field workwhenever subcontractor performance is not in accordance with the project requirements such that datausability would be adversely affected.

ICF Kaiser Remedial Investigation Lead. Mr. Frank Markert: (Telephone 412/497-21051

The ESI lead is responsible for coordinating and directing the technical efforts of the project staff andsubcontractors in conducting field investigations. Mr. Markert is responsible for generating the FSP,ensuring that all written sampling procedures are in accordance with appropriate guidance, anddissemihating QA/QC requirements to project staff and subcontractors. He also provides instruction to all

i . field personnel to ensure that field data is collected in conformance to project QA/QC requirementsspecified in the QAPjP and the FSP. He is responsible for project logistics and coordinating the technicalefforts of the project staff and subcontractors.

ICF Kaiser Field Team Lead. Mr. George Werkman or Mr. Brucc Brown (Telephone 412/497-2000)

Acting under the authority delegated by the PM, QAO, and ESI Lead, the Field Team Lead is the on-siterepresentative who will implement the day-to-day operations required during the remedial investigation.Principal responsibilities are as follows:

• Establish working relationships with the field project team, agency representatives, contractorpersonnel, and other on-site people.

• Plan and implement day-to-day operations at the site, in accordance with the project scopingdocuments.

• Conduct daily briefings for all on-site personnel.• Identify nonconformances, implement appropriate corrective actions, and document effectiveness of

the corrective action.• Oversee subcontractor activities and review subcontractor progress reports.• Issue weekly field activity reports.• Maintain on-site documentation for procedures, rules and regulations, drawings, surveys,

correspondence, and meetings.

Sharon Steel, QAPP 2-2 Final70812-16-B August 1998

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Page 11: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

1CF Kaiser Health and Safety Staff:

The health and safety staff includes the health and safety program manager, the project officer, and site-specific health and safety officers. The responsibilities and reporting requirements and qualifications ofthese project personnel are provided in the Health and Safety Program Plan.

2.2 LABORATORY

Accutest Laboratories will retain responsibility for all bench level QA/QC, data reduction, reporting andanalytical performance monitoring. Separate organization charts arc included for the laboratoryorganization in Appendix B. Accutest is located at: Fresh Ponds Corporate Center, Building B, 2235Route 130, Dayton, NJ 08810, 732/329-0200.

Accutest OA Officer. Mr. Matt Cordova (Telephone 732/329-02001

The Accutest QA Officer (QAO) coordinates and oversees data quality and corrective action. She has theability and authority to recommend and implement immediate corrective measures. The QAO reportsdirectly to the president of Accutest. A detailed list of duties is included in the QAO job description kepton file at Accutest.

2.3 DATA QUALITY ASSESSMENT

Gradient Corporation will be performing the data quality assessment functions for the project. Gradient'sproject manager, Ms. Linda Cook, is responsible to ensure that all laboratory analytical data is generatedin accordance with guidelines established by Exxon and in this QAPjP. Gradient is also responsible forthe data usability assessment of any laboratory analytical data generated by subcontracted laboratories.Gradient's address is 44 Brattle Street, Cambridge, MA 02138, and its telephone number is 617/234-2378.

Sharon Steel, QAPP 2-3 Final70812-16-B August 1998

A R I O I 7 6 6

Page 12: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

c cFigure 2-1

Project OrganizationSharon Steel Corp. - Fahmont Coke Works Remedial Investigation

C

££

*CD

*-JCT* mmmmm

I

ExxonPrnjwt ManagerArthur Chin,PhD

Corporate Health I D*»1 C £ 4

D. Webhrjts, YCSP .ICF Kajser &ad

Project Manager

Quality Assurance 1D. McCracken, CHMM I

i i iRemedial Investigation 1 Feasibility Study Data

Lead 1 Lead ManagemenF.Markert,PE,PG 1 L Martin, PE J.&air

—— Site Safety

••»• ReW Team Leader

^ Geology / Hydrojeology

^M Fate & Transport

11 1

ita Usability Analytical LaboratoryAssessment*nt Corporation Accutest Laboratory

• •• •• •

1Risk Assessment

it LeaderK. Super, DABT

ECMSG-MM

Page 13: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

ICF KAISERJt Excellence in Meeting Client Needs

A R I O I 7 6 8

Page 14: QUALITY ASSURANCE PROJECT PLAN (QAPP) · Exxon Project Manager. Mr. Arthur Chin: (Telephone 908-474-7395) The Exxon project manager will act as the contact with USEPA for all matters

3.0 DATA QUALITY OBJECTIVES

Data Quality Objectives (DQO) for the Fairmont Coke Works ESI and subsequent EE/CA(s), ifnecessary, were developed in accordance with "Guidance for Planning for Data Collection in Support ofEnvironmental Decision Making Using the Data Quality Objectives Process" EPA QA/G-4, September1994. The following seven steps were used in the development of DQOs for the Site.

3.1 PROBLEM TO BE RESOLVED

Historical records and the results of past investigations indicate that potentially hazardous materials mayhave been stored or disposed at the Fairmont Coke Works Site. The nature and extent of thecontaminants present in the soils and groundwater as well as the risk to human health or the environmentfrom the contaminants has not been fully evaluated.

3.2 DECISION TO BE MADE

The nature and extent of site-related risks must first be determined. This requires investigation of on-sitesoils and groundwater. The investigation data will then be used to assess the risks associated with currentand anticipated future land use.

3.3 INPUTS TO THE DECISION

Inputs to the decision include the type, quality, and quantity of data that will be sufficient to makedecisions. The type refers to the physical and chemical data needed for each matrix sampled. Qualityrefers to various aspects of the analytical data collected such as precision, accuracy, representativeness,comparability, and completeness (PARCC), required and achieved detection limits, and data qualityassessment documentation requirements. Quantity refers to the amount of data necessary to makeremedial decisions. Specific information about data type and quantity are provided in the Work Plan.PARCC goals as other quality parameters are defined in this Quality Assurance Project Plan.

Samples will be collected using a combination of random and biased sample collection programs. Samplecontainer and preservation requirements are defined in the FSP. Analytical protocols and holding timerestrictions are detailed in Section 5.0 of this QAPjP.

3.4 BOUNDARIES OF THE STUDY

Spatial boundaries of the decision statement are limited to the contaminants within the on-site soils andgroundwater that pose an unacceptable risk to human health or the environment. Data collected will

Sharon Steel, QAPP 3-1 Final708I2-I6-B August 1998

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represent current site conditions as well as site conditions as they are expected to exist over the next 100years.

3.5 DECISION RULES

If analytical data indicate an unacceptable risk to human health and the environment, then remedialalternatives will be identified and evaluated.

3.6 ACCEPTABLE DECISION ERRORS

DQO guidance indicates that the worst-case scenario should be assumed at a given site; the data is thenrequired to prove that the worst-case scenario does not exist. For example, based on the decision rulegiven above it would be assumed that the site does present an unacceptable risk to human health or theenvironment. It is then incumbent on the data to show otherwise. This definition of the situation to betested (termed the null hypothesis) is critical for defining the acceptable decision errors.

Site measurement data can only estimate the actual Site conditions; decisions based on the measurementdata could be in error (known as decision error). Statistical sampling designs attempt to control designerror by defining two types of errors and including them in the statistical sampling design process.

Possible types of decision errors include:

• Type I errors: Concluding that no risk exists at the site when there is a risk• Type II errors: Concluding that there is a risk when no risk exists.

Both types of errors have consequences, and should be minimized to the extent possible without going toextremes (e.g. collecting an inordinate number of samples or requiring extreme QC controls duringsample analysis) Confidence is defined as the probability of not committing a Type I error, and has beenset at 95 percent for this project. Power is defined as the probability of not committing a Type II error,and has been set at 90 percent.

3.7 SAMPLE DESIGN

The sampling program will employ a combination of biased and unbiased (random) sampling strategies.Biased or directed sampling will be conducted at known or potential point sources. Random samplingwill be used at areas where the location of contamination, if any, is unknown or unclear.

Sharon Steel, QAPP 3-2 Final708I2-16-B August 1998

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PRECISION

. ." • 'Precision refers to the level of agreement among repeated measurements of the same parameter. It isusually stated in terms of standard deviation, relative standard deviation, relative percent difference,range, or relative range. The overall precision of a piece of data is a mixture of sampling and analyticalfactors. The analytical precision is much easier to control and quantify because the laboratory is acontrolled, and therefore measurable environment. Sampling precision is unique to each site, making itmuch harder to control and quantify. The goals for each factor are addressed here separately.

Sampling precision will be checked by obtaining a duplicate sample for every 20 samples collected foreach type of media. Precision will be evaluated by calculating the relative percent difference (RPD) asfollows:

opn = d*fference 'between the two measured valuesaverage of the two measured values

The RPD will be calculated for each analytical parameter. It is expected that the soil field duplicates willhave RPDs £50% and water field duplicates will have RPDs £ 35%. If these criteria are not met, acareful examination of the sampling techniques, sample media, and analytical procedure will beconducted to identify the cause of the high RPD and the usability of the data.

Laboratory precision will be evaluated by the analysis of one duplicate sample for every sample batch. Asample batch is defined as a group of twenty samples of similar physical media collected within one workweek, or all such samples collected in a work week (if less than twenty), whichever occurs first. TheRPD for each analytical parameter will be calculated as a measurement of precision. For the CLPanalyses to be completed during this RI/FS, the precision criteria are defined by the analytical method.Alt other analyses have a precision criteria of < 35%. If these criteria are not met, a careful examinationof the sampling techniques, sample media, and analytical procedure will be conducted to identify thecause of the high RPD and define the usability of the data.

ACCURACY

Accuracy refers to the difference between a measured value for a parameter and the true value for theparameter. It is an indicator of the bias in the measurement system. Sources of error measured by thisparameter include the sampling process, field contamination, preservation, handling, sample matrix,sample preparation, and analytical technique.

Sharon Steel, QAPP 3-3 Final70812-16-B August 1998

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The sampling accuracy will be assessed by collecting and submitting one rinsate blank per twenty (20)samples or per week in which sampling occurs, (whichever occurs first), and one trip blank for eachsample shipment that contains samples to be analyzed for aqueous volatile organ ics. The accuracy goalfor the trip and rinsate blanks will be that they contain less than the method detection limit for eachanalytical parameter. If analytes are detected in the blanks above these levels, the sample data will becompared with the blank data and may be qualified or rejected, depending on the relative amountspresent.

Laboratory accuracy will be evaluated by the analysis of one method blank per sample batch and onespiked sample per sample batch. For samples being analyzed using CLP or SW-846 methods, the spikeacceptance criteria specified in the method are adopted. The accuracy goals for all other analyses are setat 50% to 150% spike recovery. Spike recoveries will be calculated as follows:

Spike Sample Result - Sample ResultRecovery = -£ ———— *- ———————— *- ———— x 100Spike Added

Volatile and semi volatile method blanks must contain no more than the detection limit for targetcompounds and no more than five times the detection limit of common lab contaminants includingmethylene chloride, acetone, 2-butanone, and phthalate esters. The inorganic method blanks must containless than the detection limit for each analyte. AH other analytical blanks results must be less than themethod detection limit. If these criteria are not met, a careful evaluation of the data will be performed todetermine the source of the error and usability of the data. A summary of the field precision and accuracygoals are provided in Table 3-1.

REPRESENTATIVENESS

Representativeness is a measure of the degree to which the measured results accurately reflect themedium being sampled and the overall situation at the Site. It is a qualitative parameter which isaddressed through the proper design of the sampling program in terms of sample location, number ofsamples, and actual material collected as a sample of the whole.

The sampling program has been designed to be unbiased or biased as appropriate, to ensure thatstatistically derived sample numbers meet the minimum number required. Sampling protocols (discussedin the FSP) have been developed to assure that samples collected are representative of the media. Fieldhandling protocols (e.g., storage, handling in the field, and shipping) have also been designed to preservethe integrity of the collected samples. Proper field documentation and audit results will be used to

Sharon Steel, QAPP 3-4 Final70812-16-B August 1998

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establish that protocols have been followed and that sample identification and integrity have beenmaintained.

COMPARABILITY

Comparability expresses the confidence with which one data set can be compared to another. Whencomparing data, it is important to compare data collected under the same set of conditions. Seasonaltrends, depth of sample collection, analytical protocol, method detection limits, and any othersampling/analytical variables must be taken into account when comparing data sets. This will beaccomplished via the sampling design described in the Work Plan, using established USEPA methods forcollecting and analyzing the samples, and documenting the methods used.

COMPLETENESS

Completeness is a measure of the amount of information that must be collected during the fieldinvestigation to allow for successful achievement of the project objectives. The overall objective of theRI at the Site is to characterize the nature and extent of contamination at the Site, so that a risk assessmentcan be performed. A certain amount and type of data must be collected for the characterization to bevalid. Missing data may reduce the precision of estimates or introduce bias, thus lowering the confidencelevel of the conclusions. While completeness has historically been presented as a percentage of the datathat is considered valid, this does not take into account critical sample locations or critical analyticalparameters. The completeness goal for the RI activities will be 90% for the field sampling and 90% forthe laboratory analyses. Completeness will be calculated as follows:

„ . Number of usable resultsCompleteness - —————~———————— x 100Number of planned results

The amount and type of data that may be lost due to sampling or analytical error cannot be predicted orevaluated in advance. The importance of any lost or suspect data will be evaluated in terms of the samplelocation, analytical parameter, nature of the problem, decision to be made, and the consequence of anerroneous decision. Critical locations or parameters for which data is determined to be inadequate may beresampled.

SENSITIVITY

Quantitation limits for all analyses are specified in Section 5.0 of this QAPjP. Quantitation limits may beaffected by matrix interferences, such as those caused by highly contaminated samples. If a dilution is

Sharon Steel, QAPP 3-5 Final70812-16-B August 1998

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required, the lowest dilution necessary to bring the compound within range should be performed in allcases. In cases where the specified detection limits (or project-specific reporting limits) are not achieved,the usability of the data will be evaluated during data quality assessment.

Sharon Steel, QAPP 3-6 Final70812-I6-B August 1998

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Table 3-1Field QC Samples

Type

Duplicate

Field blank

Trip blank

Matrix

Water

Solid

Water

Solid

Water

Solid

Frequency

1 per 20

1 per 20

1 per 20

1 per 20

1 per VOA shipment

1 per VOA shipment

Requirement

RPD<35%

RPD < 50%

<MDL

<MDL

<MDL

<MDL

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Section 4

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4.0 FIELD OPERATIONS

All aspects of field operations are detailed in the Field Sampling Plan.

Sharon Steel, QAPP 4-1 Final70812-16-B August 1998

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ICF KAISER JpExcellence in Meeting Client Ntedt

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5.0 LABORATORY OPERATIONSw

5.1 ANALYTICAL PROCEDURES

Solid and aqueous samples collected during the Expanded Site Investigation will be analyzed todetermine the nature and extent of chemical impact as needed for risk assessment or engineeringpurposes. The specific analyses to be performed (based on the purpose of the sampling) are detailed inthe Work Plan.

** . • '

Remedial Investigation samples will be analyzed using current CLP methods, as detailed in Section XIIIof the Consent Order. If not appropriate for CLP analysis, samples will be analyzed in accordance withthe procedures set forth in the following methods:

• SW-846, Test Methods for Evaluating Solid Waste, 3rd edition, update 3,12/96,• Methods for the Analysis of Water and Wastes, U.S. EPA 600/4-79-010, March 1983.• Standard Methods for the Examination of Water and Wastewater, 19th edition, 1995.

Table 5-1 summarizes the specific analytical methods to be used as well as the required detection limits.Selected QC requirements for the CLP SOW are detailed in AppendixC.

I , All quality control, analytical documentation, and record maintenance will be in accordance with CLP orSW-846 requirements, as appropriate. Analytical reports will require full documentation of each analysisperformed, including all QC and calibration information and the raw data necessary to allow forrecalculation of the result. .

5.2 QC REQUIREMENTS

Accutest Laboratories has implemented a Quality Assurance Plan which is in compliance with the ISOGuide 25 requirements. The QA Plan addresses client services, purchasing, method quality control,document control, data validation, audits, subcontracting, corrective action, analyst training, samplehandling, and security. A copy of QA Plan table of contents is included in Appendix B. The completeplan is available upon request through Mr. Richard W. McCracken, project QA Officer, at 412/497-2380.

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TABLE 5-1Analytical Methods and Required Detection Limits

Matrix

Solids

Aqueous

Parameter

Volatile OrganicsSemivolatiles Organics

PCBs

TAL InorganicsMetals except HgMercuryCyanide

PHTOGTCL VolatilesTCL Semivolatiles

Pesticides

TAL InorganicsMetals except HgMercuryCyanide

Total Suspended SolidsTotal Dissolved Solids

Analytical Method

CLP SOW OLM03.2CLP SOW OLM03.2

CLP SOW OLM03.2

CLP SOW ILM04.0

SW846 9045CASA 29-3 (2)CLP SOW OLM03.2CLP SOW OLM03.2

CLP SOW OLM03.2

CLP SOW ILM04.0

EPA 160.2EPA 160.1

RequiredDetection Limit

CRQLCRQL

CRQL

CRDL

Not applicable1 mg/kgCRQLCRQL

CRQL

CRDL

1mg/l1 mg/I

Holding Ti me (1)

14 days14 days to extraction,40 days to analysis14 days to extraction,40 days to analysis

180 days28 days14 days7 days28 days14 days7 days to extraction,40 days to analysis7 days to extraction,40 days to analysis

180 days28 days14 days7 days7 days

COO

(1): All holding times are based on the technical requirements of SW846rather than the contractual requirements of CLP.(2): American Society of Agronomy, Methods of Soil Analysis, Part 2,2nd Edition (1982), Chapter 29-3

Sharon'v ., QAPP70812-16-B 5-2

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Section 6

EdCO

fc-1.r

GO

CD

or

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6.0 DATA REDUCTION, VALIDATION, AND REPORTING

All data collected during the ESI activities, including field and laboratory activities, will be recorded,reduced, reviewed, and reported. ICF Kaiser is responsible for these functions for field sample data.Each off-site contract laboratory receiving field samples is responsible for the recording, reduction,reviewing, and reporting of the corresponding analytical results. Designated aspects of the data review,assessment, and validation are assigned to members of the investigation team as described below.

6.1 DATA REDUCTION

Raw data consists of instrument responses in the form of meter, recorder, or printer output. Thetechnician/operator performing the analysis either will enter the field or bench generated data in a field orlaboratory workbook/worksheet specific for each parameter or will reduce the data via specificcomputerized software programs. These data must include: instrumental responses (absorbances,concentrations, etc.), standard and spike concentrations, sample identification numbers, and all otherpertinent information. All reductions of data, whether manual or computerized, must follow theprocedures and equations provided in the respective testing protocols. The reduction of field data willconsist of summarizing the raw field data, which may be presented in the form of tables, logs,illustrations, and graphs, as deemed appropriate by the task manager.

For laboratory analyses in which the raw data consist of instrument responses in the form of computer-generated data files, data output will be stored by the laboratory in project-specific files. The computer-generated data files must be archived electronically for possible retrieval at a later date.

The field measurement data will be reduced into a tabulated format suitable for inclusion in the ESIreport, and will be designed to facilitate comparison and evaluation of the data. These tabulations willinclude but not be limited to the following information:

• Field screen results• Field analyses (e.g., pH, temperature)• Well construction details• Water-level measurements and surveyed measuring point elevations.

Field logs will be transferred into typed formats or organized in their original form for inclusion in theESI report as appendices. The tables and logs will be compiled, whenever, feasible, by the fieldhydrogeolegist, who will inform the task manager of any problems encountered during data collection,identify apparent inconsistencies, and provide opinions on the data quality and limitations.

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6.2 DATA REVIEW

The following sections discuss the specific details of laboratory data and the first level review, secondlevel review, third level review, compliance review, data acceptance review, and the final data reviewincluding delineating responsibilities for each level of review.

6.2.1 Laboratory Data - First Level Review

The laboratory analyst generating the analytical data has the prime responsibility for the correctness andcompleteness of the data. All laboratory data will be generated and reduced following protocols specifiedin the appropriate EPA CLP SOW, EPA SW846 methods, or other approved method referenced in thisQAPjP. The review conducted by the laboratory analyst constitutes the first level review. At a minimum,the primary analyst will review the data package to ensure that:

Analysis information is correct and completeAppropriate test method was usedAnalytical results are correct and complete (including calculations)QC samples are within established control limitsBlanks are within established control limitsAll corrections on raw data and any generated forms are appropriately documentedRaw data, calculations, and results are correctly transcribed

This review is documented by the analyst and included with the data package. In the case of workperformed by subcontracted laboratories, the first level review would be performed by the subcontractedlaboratory.

6.2.2 Laboratory Data - Second Level Review

The laboratory will also conduct a secondary review of the data as an independent and detailed review toensure that the data set is acceptable for release. The secondary review process will ensure that:

Chain-of-Custody information is correctHolding times were met (exceeded holding times will be documented in the case narrative)Sample preparation information is correct and completeAnalysis information is correct and completeAppropriate SOPs have been followedAnalytical results are correct and complete (including calculations)QC samples are within established control limitsBlanks are within established control limitsSpecial sample preparation and analytical requirements have been metDocumentation is completeCorrections on raw data and any generated forms are appropriately documentedAll documents have been initiated and dated in accordance with laboratory SOPs

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The secondary review must be conducted by experienced laboratory personnel who perform data reviewas a primary function, are organizationally separate from the operating analysts, and have direct access tothe laboratory's QA Manager. Any errors found in this review should trigger appropriate actions resultingin the correction of the data. The secondary review process must be documented in the data package.

In the case of work performed by subcontracted laboratories, the data must be reviewed and approved bythe primary laboratory in a manner similar to their secondary review process.

6.2.3 Laboratory Data - Third Level Review

The third level of review for laboratory data is accomplished by the Laboratory project manager duringpreparation of the final laboratory report. A Case Narrative will be prepared for each Sample DeliveryGroup (SDG) as documentation of the review. This narrative will include comments as appropriate forthe proper interpretation of the data as reported. The signature of the laboratory Project Manager,laboratory director, or designated senior QA staff on each SDG report constitutes acceptance and releaseof the report from the third level review.

6.2.4 Compliance Review

A basic Compliance Review will be conducted by the data assessment contractor, Gradient Corporation,to ensure completeness and deliverable compliance with method and contractual requirements for eachSDG submitted by the laboratory. This review will be conducted primarily to confirm contractualcompliance by the laboratory and will include the following:

• Comparison of the laboratory work request and chain-of-custody information with the submittedresults

• Verification of holding times for each sample and analytical fraction• Verification of the report delivery within the contractual window

This review primarily consists of production of a sample Analysis Verifications Report from the databasesystem, the centralized redemption database system for this project. The results of the review will beforwarded to Exxon for appropriate action on the corresponding laboratory invoices.

6.2.5 Data Acceptance Review

A Data Acceptability Review (DAR) will be conducted by Gradient Corporation or its subcontractor onapproximately 10 percent of the SDGs received from the laboratory. The DAR is intended as a tool tomonitor laboratory performance with respect to contract issues (e.g., EPA CLP SOW) in a timely manner.This review is intended to be completed and reported within five working days after receipt of data. TheDAR report will be delivered to Exxon and to the Laboratory project manager for immediate action, as

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needed. The time factor in this review process is important in order to influence laboratory activitieswhile they are still working on samples for the project. With this in mind, most of the SDGs submittedfor a DAR will represent the first ones produced by the laboratory for a given sampling program unit.

The DAR will consist of a checklist review to determine if the data met the program's data qualityobjectives. The checklist employed will essentially serve as a portion of the Data Usability Assessmentas described below. As a minimum, the DAR will include: data package completeness review accordingto the EPA CLP Document Inventory Sheet (Form DC-2); review of the CLP-required summary forms todetermine if the QC requirements were met for accuracy, precision and sensitivity; overall review of thedata package to determine if contractual requirements were met; and review of one sample per fraction todetermine if the sample results and quantitation limits were correctly calculated and reported.

The data reviewers will communicate to the ICF Kaiser QAO and the Exxon Quality Assurance Officerany data quality problems or issues uncovered during the DAR and will assist in interacting with thelaboratory to correct any data omissions and/or deficiencies.

6.2.6 Field Data - Review

The tables and logs compiled by the field hydrogeologist and used as the basis for data interpretation, willbe checked against the original field documentation by an independent reviewer prior to inclusion in theRI report. ICF Kaiser is responsible for coordinating and documenting this review activity.

6.2.7 Data Usability Assessment

Data usability is the process of assuring or determining that the quality of data generated meets theintended use. The primary objective of the data usability assessment is to make known and quantify,where applicable, the uncertainty in the data such that the end user (e.g., risk assessor) is aware ofpotential biases, false positives and false negatives in the analytical data. Qualifiers are applied to thedata during the usability assessment process to flag these uncertainties. Data that are unqualified orqualified with a "U" (not detected), a T (estimated), or a "UT (estimated quantitation limit) are usablefor project decisions including risk assessment. Data qualified with an "R" (rejected) are unusable as thelevel of uncertainty in the value is unacceptable for basing project decisions or risk calculations.

The Data Usability Assessment (DUA) will be conducted by Gradient Corporation or its subcontractor onall samples submitted for TAL/TCL analysis. The DUA will be performed in accordance with criteriadefined in the U.S. EPA Region III Modifications to the National Functional Guidelines for EvaluatingOrganic and Inorganic Analyses (EPA, 6792, 4/93), Guidance for Data Usability in Risk Assessment

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(EPA, April 1992), EPA CLP Statement of Works for Organics and Inorganics Analyses, andprofessional judgment. The DUA will use a data usability checklist in conjunction with data summarytables generated from the project database. The focus of the checklist review will be to determinelaboratory contractual compliance and technical usability of the data.

The data usability checklist review will include the following steps:

• Review of data package completeness according to the EPA CLP Document Inventory Sheet (FormDC-2)

• Review of the CLP-required summary forms to determine if the QC requirements were met and todetermine the affect of exceeded QC requirements on the precision, accuracy, and sensitivity of thedata

• Review of the overall data package to determine if contractual requirements were met• Review of raw data associated with one sample per fraction (volatile organic compounds,

semi volatile organic compounds, pesticides/poly chlorinated biphenyls, metals, and cyanide) todetermine if the sample results and quantitation limits were correctly calculated and reported

• Review of additional QA/QC parameters — such as field duplicates, field blank contamination, andmatrix interference — to determine technical usability of the data

• Application of standard data quality qualifiers (U. J, UJ, R) to the data• Update of the project database with the data quality qualifiers

In accomplishing these steps in the DUA the following QA/QC parameters will be evaluated:

• Holding times to assess potential for degradation that will affect accuracy• Method, field, trip, and rinsate blank results to assess contamination for all compounds/ana I ytes:

instrument blank results for inorganics to assess contamination and instrument performance problemsthat may result in false positive or false negative results

• MS/MSD recoveries for organics, and MS and laboratory control sample (LSC) recoveries forinorganics to assess accuracy of the methods

• Inorganic instrument calibration check sample results to assess accuracy and sensitivity• Organic instrument calibration compliance• Surrogate spike recoveries for organics to assess accuracy of the extraction and analysis• MS/MSD relative percent differences (RPDs) for organics, and sample and matrix duplicate RPDs for

inorganics to assess precision of the method relative to the specific sample matrix• Field duplicate RPDs to assess precision of the method relative to field sampling techniques, the

specific sample matrix, and representativeness of the sample aliquot to the area sampled• Matrix interference effects on inorganic analytes that may affect accuracy (false positives and

negatives) using method QC results for inductively coupled plasma atomic emission spectroscopy,cold vapor atomic absorption spectrometry, graphite furnace atomic absorption, and semi-automatedcolorometric analyses (cyanide)

• Detection and quantitation limits to assess sensitivity as compared to data user needs• The data reviewer will determine which set of analyses to report when multiple analyses for one

sample have been submitted by the laboratory (e.g., due to dilutions, re-extractions, reanalyzes).

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6.2.8 Data Validation

Data validation is the process of reviewing data and accepting, qualifying, or rejecting it on the basis ofcriteria using established EPA guidelines. Validation of analytical data will be conducted by GradientCorporation or its subcontractor in accordance with the procedures described in the U.S. EPA Region IIIModifications to the NFG described above.

The data validation approach would consist of a systematic review of the analytical results, associatedquality control methods and results, and all of the supporting data. Professional judgment would beutilized in any area not specifically addressed in the USEPA guidelines. The data reviewers willcommunicate any data quality problems or issues uncovered during the validation and will assist ininteracting with the laboratory to correct any data omissions and/or deficiencies.

Fifty percent of the soil and groundwater analytical data specified in the final ESI Work Plan(September 1998) will be validated using the approach described above. If subsequent sampling andanalyses are needed, the percentage of data validated may be varied as appropriate for the intended use ofthe data. The samples selected for validation would be identified as soon as possible so that this activitycan be accomplished in a timely manner. ICF Kaiser, with input from Exxon and USEPA, is responsiblefor the identification of any specific samples for validation.

6.3 DATA REPORTING

This section describes the following: reporting units, CLP-method report, non-CLP method report,laboratory diskette deliverables, and the project database.

6.3.1 Reporting Units

All analytical results will be reported in the units specified in the analytical methods. All soil andsediment results will be reported on a dry-weight basis.

6.3.2 Non-Contract Laboratory Program Method Report

The data package deliverable format for analytical data obtained following non-CLP protocols orguidelines will follow a CLP-like format and will include:

• Title page and table of contents• Sample control data

- Chain-of-custody documentsLaboratory work request

- Airbill

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Laboratory sample log-in sheetsInternal laboratory sample transfer records

• Method reference and methodology review• Case narrative - nonconformance summary report• Analysis data sheet (for each sample in SDG):

Information similar to CLP Form 1Method detection/reporting limitQuality control summaryReagent blank summaryDuplicate summary including relative percent difference (when specified)MS/MSD summary including percent recovery (when specified)Calibration summary

• Raw QC and standards dataInitial calibration dataContinuing calibration data (where specified by method)Reagent blank data

- Matrix spike dataDuplicate dataRaw sample dataSample preparation (extraction) logs

Non-CLP analyses may be combined into CLP packages where samples were analyzed for both CLP andnon-CLP parameters.

6.3.3 Contract Laboratory Program - Method Report

For analytical data obtained in accordance with the EPA CLP SOW, the laboratory is responsible for thepreparation of the standard data detiverables (reports) in the format specified by these guidelines.

6.3.4 Laboratory Diskette Deliverablcs

Diskette deliverables will be required for all laboratory analytical results delivered for the project. Thesedeliverables will be in a project-specific format to facilitate upload into the project database. The disketteformat and content requirements will be coordinated with the laboratories to facilitate efficiency in thetransfer of data.

Any diskette deliverable provided to the project as a modification, revision, or update to a previouslydistributed diskette must be appropriately marked and accompanied with the following documentation:

Sharon Steel QAPP 6-7 Final70812-16-B August 1998

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• Notation indicating the version numberi , • Description of the modifications made to the diskette that are contained in the version being^^ distributed

• Description of the diskette structure including field names, examples of field contents, and definitionof any abbreviations used

The analytical data diskette deliverable received, along with the laboratory report (hard copy) deliverablefor use in the data review, assessment, and validation processes, will be reviewed and uploaded into atemporary analytical database (see Section 6.3.6 Project Database below). This temporary database willallow for timely access to the electronic data, which needs to be reviewed in parallel with the hard copy(i.e., some reviews must be completed within days of the issue date of the data reports by the laboratory).The structure of this temporary database will be coordinated to facilitate the ultimate transfer of thequalified analytical data (in electronic format) into the project database.

6.3.5 Distribution of Reports and Diskette Del ive rabies

ICF Kaiser will submit field information on a regular basis to Gradient Corporation who will coordinatethe distribution schedule for the analytical reports and diskette deliverable produced by the analyticallaboratories. As a minimum, both hard copy and diskette deliverables will be provided to GradientCorporation. After conducting the Data Acceptance Review, the hard copy report will be made available

, , to ICF Kaiser. The reports delivered to ICF Kaiser will be made available to the Exxon team on an asneeded basis. After conducting complete Data Usability Assessments and or Data Validation as required,complete final reports and electronic database will be provided by Gradient Corporation to the Exxonteam.

6.3.6 Project Database

A project database has been developed to meet users' (e.g., remediation engineers, risk assessors) needs.This system is designed to maintain and integrate field information (such as station location, constructioninformation, sampling team, etc.), analytical information (such as results, lab qualifiers, analysis dates,etc.), and data assessment information (such as assessment status, qualifiers, etc.). A temporary or bufferdatabase for analytical data undergoing data review, usability assessment, and/or validation will bemaintained as described above. This temporary database will periodically (e.g., upon completion of thedata usability assessment for a sampling unit) be updated to the overall project database with the reviewedand assessed analytical data.

ICF Kaiser is responsible for the field sample collection portion of the database and wilt forward thisdatabase to Gradient Corporation on a routine basis as a means of notifying Gradient Corporation of

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anticipated laboratory results. Gradient Corporation is responsible for the chemistry and validationportion of the database and will forward results upon completion of the usability and validation reviews toICF Kaiser.

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Section 7

1«ICd ?

enr^oor

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7.0 PERFORMANCE AND SYSTEM AUDITS

7.1 FIELD PROCEDURES

During field activities, the ICF Kaiser QA/QC Officer or his designee will observe and audit field samplecollection activities, sample handling procedures, and chain of custody/documentation proceduresemployed by Site personnel against the FSP and QAPjP requirements. The specific checklist to be usedwill be generated once the FSP and QAPjP have been approved. The field audit will be performedfollowing the initiation of major field activities, to verify the following conditions:

• Field activities are in conformance with documents governing project operations;• Actual practice agrees with written instructions;• Appropriate field logbooks have been established; and• Deficiencies have been addressed and appropriate corrective actions have been initiated.

The QA/QC Officer will have full authority to stop Site operations if procedures are not in conformancewith the QA objectives set forth in the FSP or QAPjP. Serious deficiencies will be reported to theUSEPA and WVDEP, and corrective actions will be taken within 2 business days of discovery of thedeficiency.

A report documenting the audit findings and recommendations will be sent to the Project Manager forinclusion in the project files. The report will be submitted to the USEPA and WVDEP within 30 calendardays of completion of the audit.

The contractors) affected by the audit will also be notified of the audit findings and recommendedcorrective action.

7.2 LABORATORY

The analytical laboratory will be audited by the ESI Contractor's QA/QC Officer or his designee duringthe time the lab is analyzing samples collected at the site. The audit checklist is included in Appendix D.Serious deficiencies discovered during the audit will be reported to the USEPA and WVDEP andcorrective actions will be taken within 2 business days of discovery of the deficiencies. Samples will notbe analyzed until all major deficiencies have been corrected by the laboratory.

A copy of the audit report will be sent to the Project Manager for inclusion in the project files. The reportwill be submitted to the USEPA and WVDEP within 30 calendar days of completion of the audit.

Sharon Steel, QAPP 7-1 Final

708.M6-B A R 1 0 1 7 9 2 AU8US""8

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Section 8

CO

o

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8.0 CORRECTIVE ACTION PROCEDURES

8.1 FIELD ACTIVITIES

The initial responsibility for reporting and documenting an out-of-control event lies with the ICF Kaiser'son-Site personnel. The Field Team Lead is responsible for investigating identified problems andimplementing corrective action, or for assigning other personnel to perform these tasks. The Field TeamLead must also verify that the corrective action has eliminated the problem in question. The Field TeamLead is responsible for documenting and reporting out-of-control events to the Project Manager. TheProject Manager will in turn notify the QA/QC Officer of the incident or event. All ESI Contractor fieldpersonnel have the authority to stop work when an out-of-control event has occurred that could impact thequality of the data. Corrective actions will be decided upon by the Field Team Lead in consultation withthe Project Manager and QA/QC Officer.

Corrective actions in the field are likely to be immediate in nature and can be implemented by fieldpersonnel or the Field Team Lead; the corrective action will usually involve recalculation, reanalysis,

repeating the instrument calibration or resampling at a particular location. Once an out-of-control eventhas occurred and the Field Team Lead has been notified, the following steps will be taken to regaincontrol:

1. The Field Team Lead will investigate and determine the probable cause of event.

2. The Field Team Lead will consult with the Project Manager or QA/QC Officer if the event warrantssuch consultation.

3. The Field Team Lead will decide on an appropriate corrective action.

4. The Field Team Lead will implement or direct the Contractor(s) to implement immediate correctiveaction and shall notify the QA/QC Officer of the event and corrective action.

5. The QA/QC Officer will verify the effectiveness of the corrective action and decide on further actionsif necessary.

6. The USEPA and WVDEP will be notified via the Exxon Project Manager of serious deficiencies, out-of-control events, and planned corrective actions within 2 business days of the event discovery.

ICF Kaiser will document an out-of-control event by recording the situation and its resolution (includingall notifications and corrective actions taken) in the field logbook. Possible causes, proposed correctiveaction(s), and the date the corrective action(s) occurred will be recorded. The Field Team Lead will

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check to be sure that corrective action has been taken, the corrective action appears effective, and thesituation has been folly resolved. The Project Manager will receive a copy of the field logbooks and willfile them in the project file.

8.2 LABORATORY

At the laboratory level, re-analysis and other corrective measures are contractually required if specificcontrol limits established in the standard methods are exceeded. The bench chemist directly, responsiblefor the test must know the current operating and acceptance limits, and take the required correctiveactions (including sample re-analysis). Bench results must also be reviewed by the laboratory staff toinsure that all method-specified QA requirements have been met. The report is then prepared andsubmitted for final QA check. Each person in the review process has the authority to require re-extractionand re-analysis of a sample if QC problems are identified.

Gradient Corporation is responsible for proper data quality assessment in accordance with Section 6.0 ofthis QAPjP and all applicable requirements of the Consent Order. If data quality assessment or QC auditsresult in detection of unacceptable conditions, ICF Kaiser will be responsible for developing and initiatingcorrective action. The USEPA and WVDEP will be notified of serious deficiencies via the Exxon ProjectManager and corrective action will be taken within 2 business days of discovery of the deficiency. Thelaboratory Quality Assurance Officer will be notified of the non-conformance and will oversee anycorrective action to verify resolution. Corrective action may include:

• Re-analyzing samples if holding time criteria permit;• Re-sampling and analyzing;• Evaluating and amending sampling and analytical procedures; and• Accepting data acknowledging level of uncertainty.

Data inadequacies attributable to Site-specific interferences or conditions may require that samplingprocedures or analytical methods be modified.

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Section 9

QC•I

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9.0 QUALITY ASSURANCE REPORTS

ICF Kaiser's QA/QC Officer or his designee will prepare the following quality assurance reports:

• Field audit results, including situations identified, corrective actions implemented, and overallassessment of field operations.

• Laboratory audit results, including major and minor situations identified, laboratory response to theproblems, impact on data quality and overall assessment of the laboratory.

• Data Quality Assessment summary reports for each data package, as obtained from GradientCorporation (the Data Quality Assessment subcontractor).

The field and laboratory audit reports will be submitted to the USEPA and WVDEP via the Exxon ProjectManager within 30 calendar days of audit completion as required by the Consent Order. Seriousdeficiencies identified during field or laboratory audits will be reported to the USEPA and WVDEP viathe Exxon Project Manager within 2 business days of their discovery, as required by the Consent Order.The data quality assessment summary reports will be given to the ICF Kaiser QA/QC Officer prior toreleasing the data for staff use.

QAPjP Modifications

The following procedure provides a means for controlling and documenting changes to the approvedQAPjP. The objective of the process is to maintain the level of QA/QC provided in the original reviewand approval process.

If changes to the QAPjP are required, the requesting party will initiate the desired change by editing theexisting procedure (indicating changes by underlining) and developing a schedule for implementation.The revision will be submitted with a cover letter to the other party for review, comment, and/or approval.Upon acceptance or approval of the revision, the change will be added to the appropriate section of theQAPjP. Changes will be incorporated and documented by marking the revised pages with the revisionnumber and date in the lower right hand comer.

Sharon Steel, QAPP 9-1 Final70812-16-B August 1998

A R I O I 7 9 7

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IGF KAISERWorldwide Excellence in Meeting Client Netdt

A R I O I 7 9 8

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APPENDIX A

RESUMES OF KEY ICF KAISER PERSONNEL

A R I O I 7 9 9

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DOUGLAS B. TAYLOR, P.E.

EDUCATION

M.Engr, Environmental Engineering, The Pennsylvania State University, 1980B.S., Environmental Engineering, The Pennsylvania State University, 1979

PROFESSIONAL REGISTRATIONS AND CERTIFICATIONS

Professional Engineer. Arizona, Colorado, California, Kansas, Kentucky, Michigan, New York,Ohio, Pennsylvania, South Carolina, Virginia, West Virginia

Certificate Holder, National Council of Engineering Examiners

EXPERIENCE

Mr. Taylor is currently a Senior Project Manager and Vice President with ICF Kaiser, responsible for siteinvestigation, field studies, engineering programs, and quality assurance in the Pittsburgh office. He isperforming project management and engineering functions on major investigation, design, and remediationprojects throughout the United States. His experience covers a wide range of hazardous waste siteinvestigation, RCRA Corrective Action, Superfund remedial actions, RI/FS, environmental survey, andwater quality programs. He is currently serving as project manager and technical advisor to private sectorclients on four large multitask investigation, design, and corrective action programs. Mr. Taylor formerlyworked in ICF Kaiser's Los Angeles office for three years managing a series of large private sector projectsand a project office in Northern California. Before joining ICF Kaiser in 1987, he was both projectmanager and corporate health and safety officer at AeroVironment Inc. in Los Angeles. In this position, hemanaged a four-year, multimillion-dollar waste site investigation contract for the U.S. Air Force. He alsoworked on the EPA Field Investigation Teams in Regions III and VIII with Ecology and Environment Inc.In Region VIII, Mr. Taylor was the preliminary assessment group leader and served as liaison to REMengineering activities. His background includes the following project experiences:

Environmental Assessments/Site Investigations

Suoerfund Remedial Investigation/Feasibility Studv f RI/FS V Sharon Steel Corporation • Fairmont CokeWorks. Fairmont. West Virginia. Managing the initial phases of a new RI/FS project at a World War I-cracoke oven facility in Fairmont, West Virginia. The RI/FS work plan is currently being prepared and theRI, FS, and risk assessment will follow. The site is unique in that the client is attempting to have the siteincluded in the USEPA's XL Pilot Program. If selected, this would be the first CERCLA XL site in thecountry. In addition to managing the RI/FS portion, serves as the lead consultant for site strategy, agencynegotiations, and technical direction.

Chemical Plant RCRA Investigation. Confidential Client. New Martinsville. West Virginia. CorporateAccount Manager overseeing the RCRA Facility Investigation process for a chemical plant thatmanufactures a variety of organic and inorganic chemicals. Developed an innovative approach for theplant's submissions that met regulator,- requirements, closed a variety of outstanding (unresolved) issues

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DOUGLAS B. TAYLOR, P.E. (continued)

and gained approval for reduction of groundwater monitoring costs. The Description of CurrentConditions and RFI Work Plan have both been submitted to USEPA. Both documents stressed a strategybased on risk assessment as the basis of decision making. A significant reduction in groundwater sampleshas been achieved which could save 5250,000 per year in sampling and analytical costs. A 3-DGeographical Information System (GIS) was developed to prepare graphics for those documents, plusdemonstrate that the monitoring well network was excessive and fewer wells were needed. Finally, amanagement document was prepared for the client to evaluate best case, probable case, and worst casecorrective action costs. This document will be revised at each step of the process to help keep financial andmanagement levels aware of overall risks and strategies.

Chemical Plant. Natrium. West Virginia. Managed a RCRA Facility Investigation at an inorganicschemical plant. ICF Kaiser has submitted a Description of Current Conditions Report and an RFI WorkPlan for submittal to USEPA Region HI. Also was responsible for the preparation of a pre-investigationevaluation of corrective measures technologies, landfill O&M manual, and the design of a landfill cover.The ICF Kaiser team completed a detailed sampling plan to investigate nearly 60 solid waste managementunits and areas of concern. Some of these units are tanks, sewers, landfills, waste piles, and sumps.Chemicals of concern at the site are acids, caustics, mercury, and miscellaneous organics generated at aformer operation that manufactured chlorinated organics. Groundwater is being handled as a singlecorrective action management unit, and other SWMUs are being grouped according to chemical type,location, process, and data quality need. As part of the overall strategy the RFI Work Plan was specificallysplit into a distinct DOCC to allow USEPA to formally approve the list of SWMUs and available data

i before beginning the RFI Work Plan. Almost 20% of SMWUs were eliminated from the RFI process.

RCRA Investigation and Remediation. Baver. Damascus. Virginia. Served as project manager for a PhaseII RFI, CMS, and Corrective Action project at a former manufactured dye plant in southeastern Virginia.ICF Kaiser was selected to take over the RFI work and complete a second phase of field work, assist inreestablishing credibility with US EPA Region III, perform detailed data validation, and conduct a fullhuman health and ecological risk assessment. Worked with the client, a former property owner, and ICFKaiser technical staff to develop a strategy to obtain rapid approval of field procedure changes andupgrades, handling of data, and risk scenarios. The field program began in March 1992, only weeks afterthe initial agreement was reached. Because of a change in contractors, ICF Kaiser was responsible formaking up schedule slippage that had resulted. Initial meetings emphasized close coordination betweenfield areas and the client's laboratory to assure that data quality was maintained. In addition to well drillingand soil sampling, oversaw subcontracted work to uncover drums and perform aquatic sampling and fishpopulation counts. In the risk assessment section, the ICF Kaiser team used innovative techniques todemonstrate PAH, chrome, and lead concentrations did not require extensive remedial actions. In addition,a corrective measures study work plan was prepared. ICF Kaiser argued that a CMS is not needed becauseof the limited actions which are possible and limited hazard. USEPA guidance was cited for this position.The RFI report was submitted on time in December 1993. The RFI report made extensive use of riskassessment to evaluate remediation needs. As part of the RFI, ICF Kaiser argued that a CMS is not neededbecause of the limited actions which are possible and limited hazard. Bayer was successful in proposing afast-track corrective action limited to soil excavations and site improvements. The program was completedin 1996; over 16,000 CY were excavated. USEPA approval of the action was obtained without comments.The site was successfully remediated in 1996.

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DOUGLAS B. TAYLOR, P.E. (continued)

Public Utility Site Investigations. PCBs and PNAs. California. Has also conducted a series ofinvestigations of gas manufacturing plants and service centers for a major utility. These investigationsrequired intensive coordination with the California state regulatory' agencies for approval. A very proactiveprogram has been implemented by the utility to identify and solve potential problems at sites throughoutNorthern California, including transformer storage, fuel storage, and gas plant residue areas. Wasresponsible for planning, drilling and sampling, data analysis, and risk assessment. Also was responsiblefor management and technical completion of the entire investigation. Since both sites were active serviceareas, the ICF Kaiser team was required to drill and sample at odd hours and had to maintain strictschedule compliance.

U.S. Air Force Audits. Government Owned Contractor Operated Plants. Managed a series of 11environmental audits conducted at Air Force industrial plants throughout the country. These audits wereperformed by a two-person contractor team in conjunction with Air Force and plant personnel. Plantsaudited by the ICF Kaiser team included facilities which manufacture aircraft (cargo, fighters, andbombers), engine parts, missiles, and electronic assemblies. The results of these audits allowed the AirForce to minimize its environmental risk, and plant operators were advised on ways to more effectivelyhandle wastes generated at the plant. The audits were unique because they involved cooperation betweenthe Air Force, consultants, and the plant contractors. Difficulties occurred when poor waste practices wereencountered because the plant operators often objected to the findings; however, the Air Force was theowner of the facility and was ultimately responsible for the liabilities associated with the property.

NOAA Ocean Research Facility Audit and Anaconda Smelter Audits. Washington. Has conducted room-by-room inventories of a copper smelting operation, metal refining plant, and a marine biology researchfacility. The purpose of the NOAA survey was to identify chemicals present at the facility/plant, determinethe current waste/material handling procedures and to document the amount, type and location of thechemicals. Assisted in the preparation of a user-friendly manual for facility personnel (non-chemists) touse when handling, storing or disposing of hazardous materials. The Anaconda Smelter audits involvedevaluation of waste remaining in a smelter, which was at one time the world's largest, and was over 100sears old. Drums of unidentified waste had to be sampled by personnel in self-contained breathingapparatus (SCBAs).

Remediation

Morgantown Ordnance Works. Three Confidential Industrial Companies and the U.S. Armv Corps ofEngineers. Morcantown. West Virginia. Managed the completion of a Superfund RI/FS and remediationfor a group of three industrial companies and the U.S. Army Corps of Engineers. ICF Kaiser took over theproject at the completion of the RI field effort and was tasked with the preparation of the RI report, aninnovative, focused, FS-like evaluation of options on an administrative proposal to move the site directly toremoval action. The document had to be prepared in a very short time and the entire risk assessment had tobe prepared to support the conclusions. The overall document has been reviewed by USEPA and approvedwithout comment (including the risk assessment section). The proposed removal actions were negotiatedand field work, consisting of soil removal and water treatment, was completed within 18 months of RIcompletion.

South Vallev Supertund Site. Albuquerque. New Mexico. Managed a design review project at the SouthValley Superfund Site, where aircraft manufacturing activities have been in operation since World War II.

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DOUGLAS B. TAYLOR, P.E. (continued)W

A groundwater cleanup design was conducted under a ROD with USEPA. ICF Kaiser provided anindependent review of the technical and cost elements to provide assurances to former property owners(who are still PRPs) that the design in optimized. As pan of this project, ICF Kaiser reviewed groundwatermodels, extraction scenarios, treatment schemes, and detail designs for the pump, treat, and reinject system.

L.A. Clarice Suoerfund Site. Virginia. Managed the first two years of a large multitask, multimillion-dollarinvestigation and remediation project at a former wood-treating facility where railroad ties were treatedwith creosote. The project involved taking over midway through the investigation and design process froma small contractor who experienced significant problems. ICF Kaiser was responsible for negotiation ofRecord-of-Decision modifications and revisions to cleanup standards for the first Operable Unit (on-sitesoils and process areas), as well as remedy implementation. Possible remedies include landfarming, RCRAlagoon demolition and closure, in-situ bioremediation, site water control, and wastewater treatment. TheICF Kaiser team was responsible for completing the Rl/FS on OU2, off-site soils and sediment, and allgroundwater. Had full responsibility for project startup, staffing, budgeting, scheduling, and negotiation.The initial phase of the project was to prepare a program plan that will map out the initial managementsystems to be used for project control. A significant step in the program has been a renegotiation ofsurface soil cleanup levels. The ROD selected landfarming technology, but specified a cleanup standardthat cannot be met using landfarming. ICF Kaiser was successful in getting USEPA Region III to acceptMonte Carlo modeling for determining cleanup standards; the first time Monte Carlo has been used for thispurpose. Finally, ICF Kaiser has already completed remediation of 200,000 gallons of creosotecontaminated water from a RCRA lagoon.

Private Lead Superfimd Site. Phoenix. Arizona. Serves as the project manager for a four-year multitaskpilot study, design and construction project to treat solvent-contaminated groundwatcr and chrome-contaminated soils in Phoenix, Arizona. This work has been performed for a private corporation in strictaccordance with EPA consent decree requirements, and all data and design work will be reviewed andapproved by EPA. Was responsible for geochemical and groundwater modeling, work plan preparation,water treatment, pilot study completion, drilling, detailed design, procurement, construction management,and O&M planning. The groundwater study consisted of groundwater extraction/recharge systemevaluation and air stripping system testing. His team evaluated the performance of withdrawal wells,scaling inhibition systems and recharge wells. This required the management of multidisciplinary staff inseveral offices and field program planning and implementation.

The construction phase was completed in 1989, and was responsible for the management of nearly $2million in construction drilling, permitting, and engineering costs. The treatment plant was constructedwithin nine months of conceptual design approval by EPA and included a 40-foot, 1,200 gpm air stripper,10 extraction wells, and 17 injection wells. ;' . '

The client's consent decree specified design and construction milestones and imposed $5,000/day stipulatedpenalties for delays. All milestones, including plant startup, were completed by the designated date. Hasalso been responsible for retrofitting and warranty repair work on items found to be malfunctioning duringthe initial operation of the plant.

Also manages ICF Kaiser's Phase II groundwater extraction work on the site. In Phase II, the full and final. set of wells were installed to meet consent decree requirements. The program was severely constricted

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DOUGLAS B. TAYLOR, P.E. (continued)

when a leaking aviation fuel tank was discovered. Helped to negotiate a cooperative remediation thatallows minimized costs to both panics and avoids legal and regulatory problems.

RCRA Corrective Action. Private Client. San Jose. California. For three years, served as programmanager for a major investigation and cleanup program at a 5.000-acre facility located in northernCalifornia. In this role, he has overall responsibility for schedule, cost, and technical performance of theclient's entire RCRA Corrective Action program. Helped to start an eight-man field office at the client'splant within one month of contract award. The project had a budget of approximately S20 million over fiveyears. The ICF Kaiser team included an eight-man, on-site team and approximately 10 additionalpersonnel in offices throughout the country. The project involved assisting the client with negotiation ofconsent orders with both state and federal governments, investigation of scores of potential sites,preparation of dozens of government-dictated reports, and construction of cleanup systems to prevent off-site migration of contaminants. The ICF Kaiser team assisted the client with responding to requirementsthat included both RWQCB and EPA cleanup orders. Over 200 monitoring wells were installed, and fivegroundwater extraction and treatment systems were designed and built. Soil/source remediation was amajor concern and technologies employed included soil venting, bioremediation, capping, and directremoval.

Within the first five months of the project, the ICF Kaiser team prepared a complete QA and safety plan,proposals/work plans for investigation and remedial actions, and final reports for groundwater extractionsystem. Over 100 deliverables were submitted to the customer and regulatory agencies on time. Also setup a cost-and-schedule control system using the Kaiser Engineering Management System (KEMS). TheKEMS computer software allowed tight cost control and scheduling updates in accordance with clientrequirements. After two years of project operation, over SI30,000 was de-obligated from various budgetsand returned to the customer.

Private Sector LJST and Groundwater Cleanup. California. Provided project management and technicalleadership for a groundwater investigation of a manufacturing and research facility in the Los Angeles area.This project was a multi-phase program that started as an underground tank investigation and progressedinto a facility-wide, two-aquifer study. Directed the installation of a series of monitoring wells, soil/watersampling, and a survey of potential sources. The interrelationship of the two water-bearing formations wasinvestigated with an extensive series of a pump tests, geochemical testing, and geotechnical testing. Closelycoordinated all work with the Los Angeles Regional Water Quality Control Board which gaveunconditional approval to work plans and final reports for all phases of the investigation.

RI/FS at Operating Industries Landfill. Los Angeles. California. Has managed a project supporting theEPA REM IV effort at the Operating Industries Landfill in Los Angeles. ICF Kaiser staff provided healthand safety, equipment/inventory' coordination, and geotechnical support to the project team from spring1987 to February 1988. Set up systems to assure equipment tracking during the late stages of this majorfield effort. Also managed and trained a team of 20 professionals who were routinely utilized on theproject. Extensive coordination was necessary because of multiple activities being carried out and the highsafety concerns on all activities. Drilling activities were routinely carried out in Level B, using air lines andbottled air. Conditions when drilling through the fill material often included concentrations of methaneabove the upper explosive limit, lethal concentrations of hydrogen sulfide and hydrogen cyanide and acutelevels of vinyl chloride. Also provided technical oversight for geotechnical engineers installinginclinometers to evaluate the threat of slope instability and gas monitoring wells that were part of the

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DOUGLAS B. TAYLOR, P.E. (continued)

system to vent gas and prevent explosive conditions. Worked extensively with the REM IV site manager toprovide performance tracking and cost reviews. Consistently completed tasks below the budgeted level ofeffort.

Air Force 1RP Contract. California. Arizona. Oregon. Served as project manager for a $4.5-million levelof effort contract with the U.S. Air Force, performing Installation Restoration Program (IRP) studies atfour bases in California, Arizona, and Oregon. Hired and trained a core group of chemists, engineers, andgeologists, and was responsible for administration, subcontracting, schedule, technical performance, andclient interface. Effected the assignment of additional task orders to the ICF Kaiser team. The client had anumber of contractors available for assignments, but as a direct result of the high quality andresponsiveness, the ICF Kaiser team received three additional tasks within one year of their first completedtask, each with a value of over $500,000. These additional tasks involved successively larger budgets andmore complex environmental problems. Was also responsible for coordinating with drilling and laboratorysubcontractors and setting up a computer data base to allow magnetic reporting of all analytical data.Received two letters of commendation on the quality of the reports submitted under the IRP contract. Onecommendation was in response to a detailed photographic log which was prepared to document samplinglocations and procedures. Base personnel used this document for management briefings. As a result of thisfirst-of-its-kind submission, other contractors doing work for OEHL were required to prepare similardocuments.

Managed the completion of Air Force contract assignments which included four RI projects ranging invalue from $160,000 to $1.5 million. Two studies were completed at Mather AFB in Sacramento. Theseprojects involved studying potential groundwater contamination at 18 sites at the base, including oneNational Priority List site. Over 70 groundwatcr monitoring wells were drilled into the two aquifersystems. Also managed two studies at Williams AFB near Phoenix, Arizona. The initial study was a semi-quantitative analysis of potential problems at six sites. The follow-on program focused on contaminationof soil and groundwater from those most serious sites. Twenty-one groundwater monitoring wells and over120 soil borings were drilled. Additional Rl/FS planning was added by the client to prepare the sites forfinal remediation. At one point in the Williams AFB investigation, an active fuel leak was identified.Prepared an impromptu briefing for the base commander and initiated emergency investigation andremediation studies. Additional investigations were conducted at Beale AFB, California, and KingsleyField, Oregon.

Rockv Mountain Arsenal. Denver. Colorado. Served as the lead engineer on a study performed to assessremedial alternatives for the Basin F impoundment at the Rocky Mountain Arsenal. As part of amultidisciplinary team, collected samples, analyzed previous analytical and engineering data, andperformed a preliminary feasibility study to evaluate destruction and burial alternatives. One of the tasksperformed was a complex three-dimensional groundwater model that was intended to predict the movementof the chemicals from the plant area and disposal ponds and basins. The effort was difficult because ofchemical and sanitary sewers that were submerged in some parts of the base, serving as conduits forgroundwater infiltration into the sewers and subsequent movement throughout the base.

Engineering Services, Design, and Construction

Engineering Feasibility Studv. Biomass-to-Ethanol Plant Project. Confidential Client. Served as ProjectManager for a year-long feasibility study of a $40-50 million turnkey biomass-to-ethanol plant that would

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DOUGLAS B. TAYLOR, P.E. (continued)

produce 10 to 20 million gallons of industrial-grade alcohol. The plant would use patented technology,provided by the client, to break new ground in the ethanol industry. The feasibility study required detailedcost estimated, preparation of piping and instrument diagrams, electrical drawings, and detailed equipmentlists. The project included receipt of quotations from equipment vendors, development of process guaranteepoints and language for a lump sum EPC contract, completion of bench and pilot work, and preparation ofa comprehensive technical report to document the design basis.

Brvan Mound. Strategic Petroleum Reserve. Texas. Worked extensively on a raw water treatment systemthat was a part of the DOE's Strategic Petroleum Reserve for oil storage in salt caverns. Analyzed waterquality data from the Brazos River in the Texas Gulf and prepared cost and technical evaluation oftreatment alternatives to assure adequate supply of fresh water for cavern expansion. The cavernexpansion process required very large quantities of water, and pumps operated at very high impellervelocities. Because storm events resulted in very turbid water in the Brazos River (which was the source ofwater), severe pump damage occurred after every rain. Was able to track the occurrence of the damageand calculated the cost of treatment alternatives. Because of the high flows, treatment options were tooexpensive; developed the lowest cost alternative which was to change out pump impellers immediately aftereach storm event.

Colonv Oil Shale Protect. Parachute. Colorado. Served as the field geotechnical engineer and lead designerfor a non-hazardous landfill at the Mobil Colony Shale Oil processing plant in Western Colorado. Thislandfill was designed to handle Class III, non-hazardous, waste from the plant and offices. No commerciallandfills existed in the area, and the non-hazardous waste could not be mixed into the retort waste/tailingspile. Geotechnical, hydrological. and soils testing were performed in the field. Completed design andconstruction drawings.

Environmental Management

Lime Lake Reclamation Project. Confidential Industrial Client. Ohio. Since 1994, managed an innovativeproject for a major industrial customer in Ohio. The plant has a series of Lime Lakes that were createdfrom the production of soda ash: the total area covered is over 600 acres. ICF Kaiser was retained to assistin the permitting of an innovative reclamation process that mixes sewage sludge with the lime spoil tocreate an artificial soil capable of supporting vegetation (the lime spoil has no organic content and istherefore barren). The other key objective of the process is to reduce infiltration and maximize runoff byadding topography. The ICF Kaiser team has been involved in an extensive community contact program toinform local citizens and elected officials about the benefits of the project. Recognition from the WildlifeHabitat Council was sought and gained for the aesthetic and wildlife aspects of the project. Extensivepermit negotiations have been conducted to receive permission to move to a second lake after the initialexperimental permit expires. Civil engineering design, air permitting, risk assessment, and RCRAcompliance issues have also been significant parts of the project. The efforts have been successful, apermit has been obtained to move to the next lake, and studies of alternate construction materials are nowunderway for work on a third lake.

Coal Gasification Siting Studv. Gillette and Buffalo. Wyoming. Served multiple roles as part of a largeenvironmental investigation study in Wyoming and Montana. In this project, served as leader of the noiseassessment task, field engineer (geological task), and quality assurance engineer (all tasks). The QA

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';.' :-•, -'t>

DOUGLAS B. TAYLOR, P.E. (continued)

function involved field and office audits of prime and subcontractor activities and recordkceping, andpreparation of corrective action reports and foUowup.

PROFESSIONAL AFFILIATIONS

American Water Works AssociationChiEpsilonWater & Environment Federation

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DOUGLAS B. TAYLOR, P.E. (continued)

SELECTED PUBLICATIONS AND PRESENTATIONS

Real-World Use of Innovative Techniques and Technologies in RCRA and CERCLA. D.B. Taylor.Invited presentation at American Law Institute-American Bar Association course on Hazardous Wastes,Superfund, and Toxic Substances. Washington, D.C. October 1995

"Conception d'un Systeme D'extraction des Eaux Souterraines pour L'Aeropon de Phoenix-Goodyear(Groundwater Extraction System Design, Phoenix-Goodyear Airport." Taylor, D.B., G. Marceau, G.Morekas. Presented at La Pollution Accidentelle des Eaux Seminaire, Paris, France. November 1992.

Identification of Multiple Groundwater Sources with Soil Gas Sampling. P. D. Herrera and D. B. Taylor.Presented at the 4th Annual National Outdoor Action Conference, sponsored by the N.W.W.A. Las Vegas,Nevada. May 1990.

An Examination of Siting Problems for Off-site TSDFs. D.B. Taylor. Presented at the Hazardous Wastesand Hazardous Materials Conference, sponsored by the Hazardous Materials Control Research Institute.Atlanta, Georgia. March 1986.

The Status of Off-site TSDF Siting. D.B. Taylor. Presented at the Hazardous Wastes and EnvironmentalEmergencies Conference, sponsored by the Hazardous Materials Control Research Institute. Cincinnati,Ohio. March 1985.

A Practical Guide to CERCLA Investigations. D.B. Taylor. Paper presented at the National Conferenceon Environmental Engineering, sponsored by the American Society of Civil Engineers. Los Angeles,California. June 1984.

Preparation of a Remedial Investigation Plan to Assist EPA Superfund Cleanup at McAdoo. Pennsylvania.D.B. Taylor. Paper presented at the National Conference on Environmental Engineering, sponsored by theAmerican Society of Civil engineers. Boulder, Colorado. July 1983.

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FRANCIS X. MARKERT, P.E., P.G.

EDUCATION

M.S., Civil Engineering, University of Pittsburgh, 1992B.S., Geological Engineering, Colorado School of Mines, 1987

PROFESSIONAL REGISTRATIONS AND CERTIFICATIONS

Professional Engineer, Pennsylvania, 1993Professional Geologist, Pennsylvania, 1993Professional Engineer, New York (Pending)

OSHA 40-hour Health and Safety TrainingOSHA 8-hour Supervisory TrainingOSHA 8-hour Refresher TrainingOSHA Confined Space EntryOSHA Drill Rig SafetyDOE Radiation Hazard Worker TrainingRed Cross First Aid TrainingRed Cross CPR TrainingGovernment Compliance Assistance Program - Managing Government ContractsGovernment Compliance Assistance Program - Pricing Government ContractsMODFLOW for Simulation of Groundwater Flow and Advective Transport

EXPERIENCE

Francis Markert serves as a Senior Engineer with ICF Kaiser responsible for remedial system selection,design, and installation. He specializes in evaluating, designing, and implementing remedial technologies forsoil and groundwater contamination problems for all manners of environmental contaminants. Mr.Markert's background includes geological engineering and civil engineering, with specializations inhydrogeology, geotechnical design, and water resources. He has more than 10 years of experience in theenvironmental arena working on management of remediation projects, site assessments, treatabilityinvestigations, and remedial designs, installations, and operations. Experienced in both the government andprivate sectors, Mr. Markert has performed project management, remedial design implementations, fieldsupervisory work, system start-ups and shakedowns, and environmental and geotechnical sitecharacterizations. His experience includes:

Environmental Assessments/Site Investigations

RCRA Facility Investigation. Confidential Chemical Company. Natrium. West Virginia. ProjectHydrogeologist for a RCRA facility investigation for the hydrogcologic investigation and characterizationof the waste impoundments and lagoons. Performed aquifer testing, hydrogeologic data evaluation, andlong-term trend analysis to support the RFI work. Data evaluation work included statistical analysis of

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FRANCIS X. MARKERT, P.E., P.G. (continued)

aquifer testing data and creation of one-dimensional analytical groundwater flow models. Assisted inpreparation of RFI reports and data reports and presentation of results to client.

CERCLA Site Remediation. Confidential Superfund Site. Nitro. West Virginia.Senior RemediationEngineer for a remedial alternatives analysis and future projection at the Fike-Artel superfund site. Workconsisted of characterization and extrapolation of site data into uncharacterized areas, evaluation andscreening of remedial alternatives, selection of preferred alternatives, and FS level implementation costing.The analysis evaluated best, worst, and mid-case scenarios for remediation and presented varyingalternatives based on degrees and extents of contamination.

CERCLA Facilitv Investigation and Cleanup. DOE-Femald Environmental Management Project (FEMPVSouthern Ohio. Project Hydrogeologist and Senior Groundwater Modeler for investigation of thegroundwater beneath the 1,050-acre superfund site containing uranium and other mixed wastes. Dutiesincluded extensive field investigations involving soil and groundwater sampling, monitoring of over 200groundwater monitoring wells, stream gaging and sediment sampling, bioassay work, subsurfacegeophysical investigations, and field soil radiation screening. Data interpretation work consisted ofdevelopment, construction, and calibration of an 11,000-cell, regional, 3-dimensional groundwater flowmodel encompassing 29 square miles and a 40,000-cell, local, 3-dimensional groundwater flow and solutetransport model. Both models were fully calibrated and validated using multiple data sets and were used inremedial selection and design, fate and transport simulations, and risk assessment alternative selection.Total modeling budget for the project was in excess of $800,000. Mr. Markert was in charge of final modelcalibration and model implementation and presented the results in numerous meetings with U.S. EPA,OEPA, DOE, and DOE subcontractors. Final modeling work for the project involved coupling the 3-dimensional solute transport model to a model of surface water flow and infiltration across the site tosimulate the complete uranium transport mechanism off-site.

RCRA Facilitv Investigation. Confidential Chemical Company. Northeastern Ohio. Project Hydrogeologistfor a RCRA facility investigation for a 1,500-acre site in continuous operation since 1899. Mr. Markertoversaw field subcontractors and designed field work plans for investigation of the facility, which wascontaminated with organics, heavy metals, and asbestos. Facility work included construction andcalibration of a 3-dimensional, regional, groundwater flow and solute transport model of the site andsurrounding area.

RCRA Facilitv Investigation. Teledvne-Monarch Rubber. Hartville. Ohio. Performed a geological andhydrogeological characterization of a rubber casting facility contaminated with chlorinated solvents andvolatile organic compounds. Duties included field work consisting of hydrogeologic pumping tests,groundwater and surface water sampling, and borehole geophysics. Hydrogeologic data evaluation wasaccomplished through the construction of a 3-dimensional groundwater flow model to predict well-fieldcapture zones and effectiveness.

CERCLA Facilitv Investigation and Remediation. Allied-Sienal Corporation. Ironton. Ohio. SeniorHydrogeologist and Engineer for the investigation and remediation of a 95-acre coke facility. The facilitywas contaminated with heavy coal tars and DNAPLs throughout the site. Additional complicationsincluded the presence of coal waste sludge lagoons and the close proximity of the site to the Ohio River.Mr. Markert performed numerous hydrogeologic investigations including aquifer pumping tests,aquifer/river response tests, and DNAPL evaluations. Site data was incorporated into a regional

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FRANCIS X. MARKERT, P.E., P.G. (continued) !'.. >

groundwater model to determine the effects of groundwater pumping, slurry walls, and capping of thewaste disposal area.

Site Investigation. Duriron Corporation. Davton. Ohio. Mr. Markert performed a hydrologic andhydrogeologic assessment of a landfill contaminated with heavy metals and arsenic to characterizegroundwater/surface water interactions. A long-term monitoring system was installed at the site and thedata used to predict the surface water and groundwater interactions over the course of a water year.Results were used to predict the effectiveness of final site remediation.

RCRA Site Investigation. Kaiser Aluminum. Ravenswood. West Virginia. Project Geologist for the siteinvestigation. Duties included groundwater sampling, aquifer testing, waste lagoon characterization, andhydrogeologic interpretations. The site was contaminated with waste oils and solvents and was beingevaluated for the potential for in-situ bioremediation.

Remediation

RCRA Facility Remediation. The Shenvin-Williams Company. Chicago. Illinois. Project Manager for pre-remedial investigation, design, installation, and operation of a vacuum-enhanced pumping system toremediate solvent-contaminated soil and groundwater originating from leaking USTs. Project workconsists of field investigations and design, installation, and operation of a combined dewatering/SVEsystem with passive air inlet wells to address multiple contaminated areas on the same site. Regulatory

\j closure is to be achieved through industrial reuse of the property and eliminating potential exposurepathways.

Site Remediation. Aluminum Metal Casting Operation. Columbus. Ohio, Senior Project Engineer forinterim action remediation of a nine-acre manufacturing building contaminated with chlorinated solvents insoil and groundwater beneath the plant. Work consisted of target area delineation, preliminary and finaldesign, installation, and operation of an air sparge/SVE system at the site. The system was designed tooperate unattended with only occasional maintenance and was sized to meet cleanup goals within a one-year time period. '

RCRA Landfill Remediation. NAS Whidbev Island. Washington. Project Hydrogeologist and QC Officerfor installation of groundwater pumping wells and infiltration galleries for remediation of chlorinatedsolvents from a deep aquifer over ISO feet below ground. Site activities included subcontractor oversight,project cost estimating and cost control, field engineering modifications, and maintaining daily contact withU.S. navy personnel.

RCRA Facility Cleanup. Confidential Steel Processor. Northwestern Pennsylvania. Senior Engineer andConstruction Manager for remedial design and cleanup of a steel processing facility contaminated withchlorinated solvents. The remediation system covered 3 acres and addressed the residual source area andcombined air sparging, soil vapor extraction, ozonation, and in-situ bioremediation to remediate the soil andgroundwater. Mr. Markert oversaw the installation, start-up, shake-down, and long-term operation of this$700,000 system.

. ; Site Investigations and Remediations. BP Oil Company. Various locations in Pennsylvania Ohio, and WestVirginia. Provided program support as a Senior Hydrogeologist for the characterization and remediation of

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FRANCIS X. MARKERT, P.E., P.G. (continued)^~/

gas stations located within the tri-state area. Mr. Markert performed hydrogeologic data interpretation,fate and transport analysis, source-receptor evaluation, and remedial design. Stations were contaminatedwith leaded and unleaded gasoline, diesel fuel, and used motor oil. Remediations were accomplished usingpump and treat, air sparging, soil vapor extraction, and vacuum-enhanced pumping technologies.

Pilot Remediation System Installation and Operation. U.S. ACE - Andrews AFB. Washington. D.C. Mr.Markert acted as Senior Hydrogeologist to oversee pilot system construction and implementation at afueling depot contaminated with floating JP-4 fuel. Duties included preparation of work and field samplingplans, oversight of subcontractors, performance of groundwater pumping tests, and remedial alternativeselection and design.

Engineering Services, Design, Construction

Pilot Remediation Svstem Design and Installation. AFCEE-Air Force Plant 4. Ft. Worth. Texas. SeniorHydrogeologist and Design Engineer for pilot testing of a vacuum-enhanced pumping system at achlorinated solvent and petroleum hydrocarbon containing landfill. Work included preparation of all workplans, QA/QC plans, and project designs and presentation to AFCEE, Texas Water Commission, and U.S.EPA. Field work consisted of supervision of field crews and subcontractors to pilot test the remediation ofLNAPL and DNAPL at the site. Following pilot test completion, Mr. Markert performed groundwatermodeling and transport simulations to design the remedial well field for remediation of the site.

Landfill Stabilization. Confidential Client. Northwestern Pennsylvania. Mr. Markert oversaw thegeotechnical investigation and evaluation of a construction landfill to be developed into a strip mall. Workperformed included stratigraphic borehole installation, geotechnical sample collection and analysis, andevaluation of the geotechnical stability of the landfill. Based on these findings, Mr. Markert prepared alandfill stabilization plan and cost estimate for development of the site.

Environmental Management

RCRA Land Reclamation. Confidential Chemical Company. Northeastern Ohio. Project Manager andHydrogeologist for land-reclamation of a 117-acre lime spoils disposal area for three projects totaling over$400,000. The project was a pilot and full-scale implementation of the creation of an innovative artificialsoil cover using municipal sewage sludge as a mixing agent followed by final cover placement and re-vegetation. Activities included site baseline characterization, evaluation of different capping technologies,prediction of short- and long-term impacts, and examination of transient effects during construction. Thesetasks were accomplished by coupling surface runoff, infiltration, and groundwater flow and solutetransport models together to predict the effects of reclamation. This innovative technology was able toreclaim the land at virtually no cost to the client by using municipal sewage sludge previously destined fordisposal.

RCRA Emergency Response. NFESC-Orote Point Naval Facility. Guam. Site Manager and Senior ProjectEngineer for the installation of a 51.8 million emergency response remediation system at the Orote PowerPlant to remediate a 200,000-gallon diesel fuel spill. Mr. Markert was responsible for all aspects of theproject, including remedial selection, design, costing, and contract negotiations with NFESC. Design workincluded preparation of all design and project documents, and construction and calibration of a density-driven salt-water intrusion model to predict the impacts of the remedial alternatives on the island's fresh ^-/'

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FRANCIS X. MARKERT, P.E., P.O. (continued)

water supply. Field work consisted of engineering modifications, oversight of equipment operators and a15-person local labor crew, communications with navy and Guam EPA personnel, subcontractor selectionand management, materials and labor forecasts, and hydrogeological interpretations. The remedial systemwas constructed of over 3,500 linear feet of groundwater extraction/injection trenches to protect the aquiferfrom salt-water intrusion and to enable in-situ bioremediation of the diesel fuel. A biodegradable guar-gumslurry was used to stabilize the trenches below the water table during construction. The treatment systemused was a fluidized bed bioreactor and was totally automated to operate unattended with only occasionalmaintenance. •

PROFESSIONAL AFFILIATIONS

American Geophysical UnionAssociation of Groundwater Scientists and EngineersPittsburgh Geological SocietyScientific Awareness through Geosciencc Education (SAGE) program, sponsored by Geological

Society of America (GSA)

SELECTED PUBLICATIONS

Markert, F.X., "Evaluation of the Fresh/Salt Water Interface in an Island Aquifer for Remedial Design,"*Proceedings of the American Geophysical Union 1996 Spring Meeting, Baltimore, Maryland, 1996.

Markert, F.X., "Effects of Transient Flow Conditions in an Intermittent Stream on the Groundwater SoluteTransport System," Proceedings of the American Geophysical Union 1995 Spring Meeting, BaltimoreMaryland, 1995.

Markert, F.X., "The Use of Vacuum Enhanced Pumping (VEP) Wells in Groundwater and Vadose ZoneRemediation." Proceedings of the ASCE-CSCE Environmental Engineering Conference, Pittsburgh,Pennsylvania, 1995.

Markert, F.X., "Transient Flow Conditions in an Intermittent Stream and Their Effects on GroundwaterFlow,'1 Proceedings of the Eighth International Conference of the International Associations for ComputerMethods and Advances in Geomechanics, Morgantown, West Virginia, 1994.

Markert, F.X., Graves, DA., and Weber, S.W., "Biological Denitrification in High pH Lime SpoilsWastes," Proceedings of the American Geophysical Union 1994 Spring Meeting, Baltimore, Maryland,1994.

Markert, F.X. and Quimpo, R.G., "Shifts in Solute Transport Direction Induced by Transient Flow,"Proceedings of the ASCE Hydraulics Conference, San Francisco, California, 1993.

Markert, F.X., 'Transient Flow Conditions in an Intermittent Stream and Their Effects on GroundwaterFlow," Master of Science Thesis, University of Pittsburgh, Pittsburgh, Pennsylvania, 1992.

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FRANCIS X. MARKERT, P.E., P.G. (continued)

Markert, F.X., Kester, L.C., and Gaillot, G., "Application of Complex 3D Groundwater Flow and SoluteTransport Models to Support Feasibility Study and Risk Assessment Activities," Proceedings of the FifthInternational Conference on Solving Ground Water Problems with Models, Dallas, Texas, 1992.

Kester, L.C., Markert, F.X., and Gaillot, G., "The Design of Complex 3D Groundwater Flow and SoluteTransport Models to Support Remedial Investigation, Feasibility Study, and Risk Assessment Activities,"Proceedings of the International Conference on Computer Applications in Water Resources, Tamsui,Taiwan, Republic of China, 1991.

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RICHARD W. MCCRACKEN

EDUCATION

B.S.f Chemistry, Allegheny College, 1976

PROFESSIONAL REGISTRATIONS AND CERTIFICATIONS

Registered Environmental Manager, NREP (1992)Certified Hazardous Materials Manager, CHMM (1993)

EXPERIENCE

As a project manager with ICF Kaiser Engineers since 1985, Mr. McCracken has been involved innumerous phases of hazardous waste site investigation and feasibility study projects. His experienceincludes sample collection, sample analysis, and report generation for a variety of state-lead and federal-lead cleanup projects. Additionally, Mr. McCracken has been involved in the planning phases of hazardouswaste projects and has trained new personnel on proper sampling techniques. He also is the QA managerfor several sample collection activities for USEPA-lead Superfund and other projects. In this capacity, hehas written Quality Assurance Project Plans in accordance with USEPA and state requirements, specifiedsampling and analytical protocols, coordinated with CLP and non-CLP laboratories, and managed the

s—/ validation of all laboratory analytical data. Mr. McCracken is also responsible for auditing samplecollection and analysis methods and for specifying alternative methods when existing techniques areinadequate to achieve QA objectives. In addition to technique modifications, Mr. McCracken coordinatesdocumentation procedures, including log books, files, and other project records. Prior to joining ICFKaiser, Mr. McCracken was the CLP coordinator for the REM office in Zone 1 under the REM-FITprogram. As CLP coordinator, Mr. McCracken managed the scheduling of analyses, problem solving,SAS consulting with individual site managers, coordina-tion and tracking of all paperwork, andimplementation of corrective actions.

Hazardous Waste Investigation

• PPG Industries. Barberton. Ohio. Project manager for brine well investigation at an industrial facilityin Ohio. Led a team of three engineers in formulating and implementing the work plan/qualityassurance plan for sampling the gas being emitted from 19 abandoned brine wells. Developed ascheme for identifying the formation or origin for each gas. Evaluated and interpreted the analyticaldata which was used as one of the remedial action criteria for brine well replugging. Developed aninnovative data presentation format using multivariate analysis, carbon isotopic analysis, and existingDOE/USGS information! Assisted PPG in negotiations with the state and federal agencies as to themeaning of the data and the remedial actions that need to be taken. Developed bid specifications,conducted bidding process, and provided construction management for all well replugging activities,which included direct oversite of four ICF Kaiser personnel plus four subcontractor personnel duringthe replugging of six brine wells. Wrote the final report showing that the welts were no longer a threatto human health or the environment.

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RICHARD W. MCCRACKEN (continued)

Confidential Manufacturer. Pennsylvania. Project manager for a Remedial Investigation reportpreparation. Project included an evaluation and interpretation of existing chemical data. Usedestablished statistical methods to compare background and on-site soils data, plus upgradient anddowngradient groundwater data. Compared the chemical concentrations with the Pennsylvania LandRecycling Program default background values and statewide health standards, as well as the U.S. EPARegion 3 risk based concentrations. Assisted in client in determining if the TCE spilled at the site wasa listed waste or only a characteristic RCRA waste. Based on all of the evaluations performed, TCE insoil and groundwater and PCBs in soil were identified as the problems needing attention at the site.

Hudson Countv Chrome Remediation Project. PPG Industries. Inc.. New Jersey. Assisting projectmanager during a remedial investigation of chromium ore residue deposition sites. Prepared the FieldSampling-Quality Assurance Project Plan. Negotiated with the New Jersey Department ofEnvironmental Protection and Energy regarding numerous technical issues, including samplingtechniques, QA objectives, validation requirements, laboratory' operations, and performance audits.Studied chromium chemistry to understand the effect of eH/pH, organic material, and otherreducing/oxidizing species on chromium fate mobility and fate. Concluded that Eh/Ph, ferrous iron,manganese oxides, and organic matter play a major role in determining chromium oxidation state.Reevaluated the sampling and analytical requirements based on the insights gained into chromiumchemistry.

Evaluated, selected, audited and coordinated project start-up with the analytical laboratory.Participated in methods development and evaluation for hexavalent chromium analytical methods. Themethods included existing and newly proposed soil analytical procedures. Provides oversight for sevendata validation chemists to ensure compliance with the NJDEPE data validation standard operatingprocedures for TAL metals, TCL organics, total chromium only, and hexavalent chromium.

U.S. EPA. Michican. Assistant project manager for a Superrund site located in eastern Michigan.Responsible for sample collection as well as data tabulation and reduction. Performed data analysisand interpretation which led to the development of a conceptual contaminant model for the site.Coordinated with U.S. EPA and state of Michigan during all phases of the project.

NJDEP. New Jersey. Assistant project manager and quality assurance director for an NJDEPE-leadSuperrund investigation. Wrote the background report and quality assurance project plan. Conductedlaboratory and field audits to determine compliance with the QAPP. Tracked the budget using a self-developed Lotus program. Prepared monthly progress reports, including budget and scheduleinformation. Served as the laboratory contact and oversaw the analytical data validation. Coordinatedthe database management during the validation and data usage phases of the project.

Confidential Nuclear Fuels Manufacturer. Pennsylvania. Assisted a local industrial facility thatformerly manufactured nuclear fuel with site remediation. Evaluated the existing soils data todetermine if hazardous wastes were present and if additional sampling was needed. Developed asampling plan that minimized the additional samples required while meeting the technical requirements.Evaluated the data once it was received from the laboratory and assisted in presenting the informationto the Pennsylvania Department of Environmental Resources, to show that no hazardous wastes werepresent at the facility. Evaluated the post-remediation needs at the site in terms of risk assessment and

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RICHARD W. MCCRACKEN (continued)

groundwater monitoring. Developed a groundwater monitoring plan and a soil sampling plan (whichincluded background and off-site samples) to address post-remediation needs.

• PPG Natrium. Virginia. Served as the Quality Assurance Officer for the PPG Natrium project.Managed the laboratory selection process which included identifying six laboratories capable ofperforming the work, interviewing each laboratory, evaluating the proposal submitted by each tab, andauditing the successful bidder. Also provided guidance and oversite to junior level QA staff for thepreparation of the Quality Assurance Project Plan in accordance with U.S. EPA QAMS-005/80,"Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans" and U.S. EPARegion III specifications. Managed the data validation task, which included distribution of the work toproject staff and technical review of the data validation reports.

• Baver Incorporated. Damascus. Virginia. Served as the Quality Assurance Officer for the MilesDamascus project. Coordinated with the Miles laboratory in specifying the analytical methods to beused, quality assurance requirements, electronic and hard copy data deliverable format, and projectschedule. Also provided guidance and oversite to junior level QA staff for the preparation of theQuality Assurance Project Plan in accordance with U.S. EPA QAMS-005/80, "Interim Guidelines andSpecifications for Preparing Quality Assurance Project Plans" and U.S. EPA Region HI specifications.Provided technical support during agency negotiations on several quality assurance issues, and arguedforcefully for validation of a limited percentage of the analytical data. Served as the laboratorycoordinator, and managed the data validation task, which included distribution of the work to project

. ,. staff and technical review of the process. Was responsible for completing the data validation taskunder budget and ahead of schedule.

• Developed plans for the performance of remedial investigations and feasibility studies for numerousSuperfund sites. Prepared work plans for more than five sites, which included scoping of RI/FSactivities, development of schedules and the preparation of budgets. Prepared more than 10 FieldSampling/Operations Plans that included specification of sampling techniques to be used for specialsituations, sample preservation and shipping techniques and sample documentation procedures to beutilized.

• Performed validation of analytical data from the Contract Laboratory Program for more than 20Superfund sites. Performed validation for organic and inorganic analytical data using several regionalvariations of the USEPA National Functional Guidelines as well as the NJDEP procedures.

• Collected environmental and waste samples at more than 15 Superfund sites. Sampled surface water,groundwater, air, soil, sediments and wastes from lagoons, drums, and industrial outfalls. Performedfield audits at several sites during sample collection activities. Conducted training sessions forpersonnel to be utilized on hazardous waste sites. This training included methods on proper sampling,packaging, shipping and documentation of samples collected.

Environmental Assessments

• Conducted numerous audits to support real estate transfers of commercial properties, as well as\ , industrial facility regulatory compliance. Evaluated solid, liquid, and vapor-phase waste disposal

practices. Determined compliance with environmental regulations, including RCRA, CWA, TSCA,

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RICHARD W. MCCRACKEN (continued)

CAA as well as state and local laws. Collected samples as appropriate to determine the presence ofgroundwater contaminants, asbestos, etc. Tabulated results and made recommendations to the clientregarding further actions which need to be taken.

• Participated in an environmental assessment at a major university in the Pittsburgh area. Numerousbuildings at the university had been purchased from a federal agency which had used them for chemicallaboratories and process research. Researched the process/laboratory history of the facility; developeda list of potential contaminants based on the historical information; recommended sampling locationswithin each building to assess the presence of contaminants. Assisted with data evaluation andinterpretation.

• Performed on-site evaluations of nuclear power plants to collect data for use in the preparation ofdischarge, cleanup, and removal plans, as well as discharge, prevention, containment andcountermeasure plans.

• Assisted a steel company in Pennsylvania to evaluate their waste streams for compliances with RCRAregulations. Recommended the appropriate sampling techniques to develop an analytical scheme.Assisted with regulatory agency communications regarding the client's waste minimization and disposalefforts.

Air Toxins

• Project manager for ICF Kaiser's benzene NESHAP program at four coke by-product recovery plants.Responsibilities included preparing budget and schedule, laboratory subcontracting, reviewing plantdrawings to determine appropriate sampling locations, training sampling technicians, and coordinatingwith plant personnel so that sampling did not interfere with normal operations. Prepared a report foreach plant which summarized the data. Recommended actions for ensuring that benzene emissionswould be below the regulatory level by the appropriate date.

Laboratory

• Project manager for ICF Kaiser's mobile lab effort for a client in the state of Michigan. Oversaw thetraining of two lab technicians. Developed and wrote the analytical methods, which required EPAreview and approval. Coordinated with the client regarding budget and schedule.

• Operated field laboratories for on-site analysis of soil and water samples for volatile and semi-volatileorganic contamination using GC techniques. Developed laboratory QA methods that were reviewedand approved by USEPA. Established field laboratories and performed the analyses.

• Analyzed water, soil, and waste samples for inorganic parameters using spectrophotometric, ionchromatographic. and wet chemistry techniques. Analytical procedures included those from "Methodsfor Chemical Analysis of Water and Wastes," "Standard Methods for the Examination of Water andWastewater" and ASTM Part 3 1 . Mr. McCracken spent three years in the laboratory' as a benchchemist, during which time he became thoroughly familiar with the previously-mentioned analyticalmethods.

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GEORGE WERKMAN, P.G.

EDUCATION

M.S., Earth Sciences - Emphasis in Hydrogcology, California University' of Pennsylvania. 1994Graduate Certificate, Practical Approaches to Groundwater Hydrology and Contamination,Oklahoma State University. 1989B.S., Geology, California University of Pennsylvania, 1987

EXPERIENCE

Mr. Workman has eight years of experience serving as a geologist/hydrogeologist on environmentalprojects. He has planned, executed, and directed various field activities as a field operations manager. Hisbroad experience includes supervising field operations for drilling, monitoring well and piezometerinstallation in various stratigraphic and lithologic units, aquifer testing, underground storage tank testingand removal, soil/sediment/surface water and groundwater sampling including low-flow purgaig andsampling, active and passive soil surveys, immunoassay field-based PCS tests, site inspection of hazardouswaste areas, and geophysical investigation (electromagnetic survey). Some of these projects have involvedsoil and groundwater remediation.

He also performs subcontractor negotiations, administration, and compliance monitoring and serves as anon-sitc liaison with private clients, subcontractors, the U.S. military, PADEP, and Guam E?A. Mr.Werkman also has experience in various drilling methods, including air-foam rotary, rotasonic. coal-wallreverse circulation, mud rotary, hollow stem augering, geoprobe, wireline, and rock coring. His experienceincludes:

Remedial Investigations/Feasibility Studies

Andersen Air Force Base. Guam. Project field operations manager for a RI/FS being conducted under ICFKaiser's 550 million contract with the Air Force Center for Environmental Excellence. The RI/FS included39 hazardous waste sites, 53 potential source areas, and groundwater that underlies 20.000 acres of AirForce property. His responsibilities included organizing and scheduling field tasks for 16 sciexnisis/fieldengineers and two subcontractors, subcontractor and client liaison, as well as organization and writing ofreports quantifying the results of the field effort.

Those activities included topographic surveys, aerial photography, geophysical exploration-electromagnetic induction and downhole borehole surveys, verticality surveys, air-foam rotary aad dual-wall reverse circulation drilling, expanded source investigation, visual site inspections of hazardous wasteareas, site characterization, a detailed record search of the base records, active and passive soil gas survey,shallow and deep monitoring well installation, groundwater sampling, and a dye tracer study.

Additional responsibilities included preparation of dye standards, operation and calibration of aspectrofluorometer for dye analyses, and assistance in the injection of dyes into bedrock and groundwaterboreholes. Also designed a successful monitoring well network that intercepted dyes in karst geology.Prepared the Phase II, Stage 3 Work Plan that included interpretation of existing geologic and geophysicallogs and well data to determine groundwater gradients and flow direction for well design zad wellplacement within two subbasins of the Northern Guam Lens.

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GEORGE WERKMAN, P.G. (continued)

Served as a task manager for Operable Unit 1, responsible for planning, coordinating, and directing variousfield activities including Phase I site inventory, topographic survey, geophysical investigation to locate thesuspected waste burial areas, test pit and trench construction to delimit the burial areas and depths, wastecharacterization, active and passive soil gas survey, and surface and subsurface soil sampling.

Fort George G. Meade. Anne Arundel County. Maryland. ICF Kaiser was contracted by the U.S. ArmyEnvironmental Center (USAEC) to conduct a RI/FS at five landfills and to evaluate residual explosivescontamination at the Range Training Area, Served as site geologist and field operation leader for oversightof mud rotary drilling operations and installation of three mid-depth and 15 deep double-cased monitoringwells. Responsibilities included lithologic description and stratigraphic characterization of soils using theUnified Soil Classification System (USCS). He also performed low-flow purging and sampling ofgroundwater monitoring wells with a non-dedicated system. Also responsible for protecting against cross-contamination for the installation of mid-depth and deep wells, the upper water-bearing zone through whichdrilling proceeds below will be effectively sealed off in the confining clay formation to prevent downwardmigration of contaminants during drilling into the lower aquifer.

PPG Industries. Natrium. Vireinia. Mr. Werkman served as the on-site senior geologist/hydrogeologistresponsible for logging the rotasonic borings and installation of the deep wells at a Phase III RFI atNatrium. He ran a drilling program that included 31 monitoring wells being installed with hollow stemaugers and rotasonic rigs. The drilling program is valued at approximately $150,000. Otherresponsibilities included planning and coordinating the field effort for low-flow (minimal drawdown)groundwater sampling of 64 monitoring wells using Hydrolab low flow pressure cells for measuring aquiferparameters. He is also responsible for review/preparation of boring logs and report sections.

Confidential Rocket Manufacturing. California. Performed geologic investigations and developed geologiclogs for the study of extensive groundwater contamination containing organic solvents.

Tri-State Plating RI/FS. Indiana. Used Prickett's Random Walk/Mass Transport model to delineate thechromium contaminant migration. Designed the placement of extraction wells and determined capture zonesby modeling with DREAM.

Confidential Acrichemical Client. Tennessee. Assisted in procuring and organizing the sampling equipment,monitoring well development and purging, and performing groundwater sampling with dedicated bailersusing QA/QC integration of blanks, spikes, and duplicates for documentation and procedures.

Baltimore Mass Transit Authority Metro Line. Man-land. Performed geologic investigations and developedgeologic logs for the study of volatile compounds. Also responsible for borehole logging, monitor wellinstallation, groundwater sampling, and soil sampling using split-spoons with brass sleeve inserts.

Alcoa. Wearever Site. Chillicothe. Ohio. As a site geologist, responsible for hydraulic head measurementsand collecting groundwater samples. Also assisted in the preparation of the hydrogeologic report whichincluded discussions of regional and site specific groundwater flow paths and geological maps and cross-sections.

Alcoa. Cleveland Works. Cleveland. Ohio. Served as a site geologist and field operation leader forcollection of surface and subsurface soil, surface water, and seep samples. He used an enzymeimmunoassay-based field test (EnviroGard® PCB test kit) to delineate the extent of PCB-containing soils.Assisted in the organization and writing of the report quantifying the results of the field effort.

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GEORGE WERKMAN, P.G. (continued)_4~ '"'" '*! $'*••" '*f i

Alcoa. Davenoort Works. Riverside. Iowa. Served as the on-site geologist responsible for conductingfalling and rising head tests at a Phase I RI. Conducted slug tests that included the use of Telog® pressuretransducers linked to electronic data loggers to measure and record the water levels to define the water levelresponse. Other responsibilities included reducing the test analysis data set measurements to calculate thehydraulic properties by using the Bouwer and Rice Analysis Method.

ARCO Chemical Company. Monaca. Pennsylvania. Served as site geologist for a site investigation underthe Site Specific Remediation Standard, Act 2 Remediation that has elevated levels of benzene identified inthe soil and groundwater. Responsibilities included oversight of hollow stem auger drilling, the installationof multi-cluster wells, groundwater sampling, and hydraulic head measurements. Assisted in preparing thegeological/hydrogeological report, preparation of geological maps and cross-sections, hydrogeologicalmaps, and in defining aquifer characteristics from field data.

Koppers Industries. Follansbee. West Virginia. Served as a site geologist for an RI/FS at an active RCRAsite which is currently an operating pitch (coal tar) plant. Responsibilities included collecting groundwater,product, and surface soil samples and surface water samples from the Ohio River.

Miles Incorporated. Baver. New Martinsville. West Virginia. Responsible for logging geoprobe boringsand collecting subsurface soil samples for analysis.

Confidential Client. Suoerfimd Site. West Virginia. Assisted in the collection of soil samples from rolloffcontainers.

Geotechnical

UNOCAL 76. MOLYCORP. Washington. Pennsylvania. Served as site geologist and provided oversightfor rock core drilling. Responsible for the classification, identification, and description of rock cores.Performed a constant head hydraulic conductivity field test to determine values of permeability in isolatedfracture zones. Quantified the results of the field effort by preparing and developing the hydraulicconductivity tables and permeability values. Also responsible for the preparation of the geological cross-sections.

Confidential Client. Stueben Plaza Site Development. Robinson Township. Pennsylvania. Served as sitegeologist and provided oversight for rock core drilling. Responsible for the classification, identification, anddescription of rock cores. He also prepared the geologic cross-sections.

Underground Storage Tanks

LIST Closures and Site Assessments/Remediations. Served as a site geologist and field operation leader atvarious sites in the tri-state area to investigate the leakage from USTs that had contaminated both the soiland groundwater. Was responsible for numerous monitoring well installations in various stratigraphic andlithologic units in accordance with USEPA and state monitoring well construction protocol. He also wasresponsible for the compliance with federal and state regulations. Assisted in identifying all applicable stateand local regulatory requirements, including 30-day notification, permits, sampling procedures, siteinformation and preparation site assessment documentation and scope of work. Also provided oversight inUST testing for suspected releases of stored petroleum hydrocarbons.

Other Experience

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GEORGE WERKMAN, P.G. (continued)

Mr. Workman also possesses 12 years of experience in construction-related activities. His academicbackground includes coursework in stratigraphy, geomorphology, scdimentology, structural geology,hydrology1, hydrologic modeling, site investigation, and aquifer testing. Prior to joining ICF Kaiser, heperformed an independent hydrogeological assessment for an acid mine seep into a stream at a reclamationsite.

Hydrology Course. While a graduate student, assisted a professor of earth science in the development offield problems.

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WILLIAM A. RANDALL, P.O., CP.G.

EDUCATION

M.S., Geology (Hydrogeology and Geophysics Options), Wright State University, 1988B.S., Geology, Northeastern University, 1983

PROFESSIONAL REGISTRATIONS AND CERTIFICATIONS

Registered Professional Geologist: Tennessee, Pennsylvania, WisconsinCertified Professional Geologist: Indiana, Delaware, VirginiaEPA Certified Asbestos Building Inspector

EXPERIENCE

William Randall serves as a geologist with ICF Kaiser with eleven years of experience performing siteinvestigations and site assessments. His principal area of expertise is geologic and hydrologiccharacterization applied to contaminant transport and remediation. Mr. Randall has provided technicaloversight on landfill remediation projects, including state approval of site clean-up. He has performedpumping tests, packer tests, and slug tests for aquifer characterization, as well as soil sampling andgroundwater sampling under numerous levels of QA/QC, including stringent USEPA and NJDEPEprotocol.

Mr. Randall has participated in more than 200 site assessments of commercial and industrial properties.These have included Phase I, II, and HI site assessments for property transactions, New Jersey ECRA sites,New Jersey State Superfund sites, Pennsylvania Corrective Action sites, and USEPA CERCLA Sites(including National Priority Listed sites). As part of these investigations, he has performed asbestosbuilding inspections and sampling, and underground storage tank testing. He has completed subsurface soiland groundwater investigations necessary for state-approved closure of underground storage tanks, soil gassurveys for identifying volatile organic contamination, soil remediation, and confirmatory sampling. Mr.Randall's experience includes:

Environmental Assessment/Site Investigations

Allegheny Ludlum Steel - Sites throughout United States. Performed site assessments/facility audits ofnumerous properties located throughout the United States, including operating steel mills and steelfabricating facilities. Scope of work included providing cost estimates for environmental liability identifiedwith the proposed acquisitions. Properties investigated included numerous CERCLA sites, RCRAcorrective action sites, and ERNS sites.

GATX. Masurv. Ohio. Performed Phase I site assessment of this 100-year-old railroad tank car fabricatingfacility which included RCRA closures and CERCLA sites at various stages of regulatory compliance.

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WILLIAM RANDALL (continued)

Environmental Site Assessments. Various Locations. Eastern United States. Performed over 70 Phase Ienvironmental site assessments of commercial properties for Mellon Bank, FDIC, RTC, PNC Bank, andothers in accordance with ASTM or specific financial institution requirements.

Numerous Sites. EPA Re2ion III - Delaware. Maryland. Pennsylvania. Virginia, and West Virginia.Worked as a dedicated contractor on the EPA Region HI - Field Investigation Team Contract. Acquiredtraining in EPA protocol for sampling, field methodologies, and the Hazardous Ranking System. Wroteover 100 geologic, hydrogeologic, and soil characterizations for CERC LA/SARA sites for preliminaryassessments, site investigations, target population studies, extended site investigations, and screening siteinvestigations. Field work included well installation, video and geophysical well logging, soil and rockboring, site reconnaissance, surface geophysics (magnetics and electromagnetics), and soil and watersampling. All work was performed in accordance with strict EPA protocol.

PPG Industries Natrium. Virginia. Mr. Randall is currently acting as RFI lead, responsible for technicalexecution of a $600,000 Phase 3 RFI investigation at Natrium. He has total field responsibility for theinstallation of 31 monitoring wells, both shallow and deep. He is coordinating the activity of two drillingrigs, a HSA rig for shallow wells and a rotasonic rig for deep wells, as well as well development activities.Future activities will include directing field delineation of soil affected with pesticides using a geoprobe rigand quick screen turnaround at a nearby off-site lab. Ten percent confirmatory soil samples will be sent tothe laboratory at the delineated edges. Other activities will include monitoring well and production wellsampling, a pumping test, and on-site sieve analysis to determine the appropriateness of the well screen slotsize.

Remediation

PNC Bank. Town Dump Remediation. Southeastern Pennsylvania. Performed site investigation and wastecharacterization of municipal waste dumps in conjunction with a property transaction. Wrote work planand health and safety plan for site investigation and remediation activities. Performed technical and healthand safety oversight during site investigation and remediation of the identified waste disposal areas.Installed and sampled groundwater monitoring wells to assess the impact on the groundwater system.Negotiated closure of the landfill with both the Waste Management and Water Quality Units of thePennsylvania Department of Environmental Resources. Site is officially closed.

Confidential Client. Pottstown. Pennsylvania. Provided technical and health and safety oversight for theremoval of over 600 drums. The site clean-up started as a Pennsylvania Department of EnvironmentalResources enforcement action to remove surface drums. During the surface drum removal, evidence lead tothe suspicion that some buried drums might be present. Performed and interpreted a magnetometer surveyisolating potential disposal areas. Test pits discovered the presence of drums in these areas, and the drumswere then removed. The waste in the drums was then characterized and disposed of in an approved facility.Confirmatory sampling was performed on the site. The clean-up received PADEP approval and theproperty has subsequently been sold. Provided assistance, including testimony, to the legal team pursuingrecovery of clean-up costs.

Stecco. St. Clair Pennsylvania. Performed technical oversight on the remediation of a former bumpit/landfill. Designed groundwater monitoring system. Upon completion of our project, site required nofurther action pending waste disposal by owner.

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WILLIAM RANDALL (continued)

Ground water Studies

• Andersen AFB IRP. Guam. Co-author of the remedial investigation report for Operable Unit 2 pertainingto the groundwater on section of the site. Mr. Randall analyzed geophysical logs, aerial photographs,chemical data, well logs, and geology in preparing this report which characterized the groundwater flowand quality of the Northern Guam Lens, designated as a sole source aquifer. The hydrogeology of northernGuam is highly complex, consisting of a freshwater lens within a highly faulted and solutioned carbonateaquifer. Additionally, decades of heavy well production further complicated the groundwater flow pattern.The remedial investigation report summarized the complex flow and transport mechanisms operating in thearea.

In addition, was the principal author of the waste characterization report and the no further response actionplanned decision document for Operable Unit 2. These reports concern three waste piles located on thebase.

Natrium RFI. PPG Industries. New Martinsville. West Virginia. Site Manager of Phase HI of this RCRAfacility investigation. This phase included the installation of 30 monitoring wells using hollow stem augerand rotosonic methods; a soil investigation, which included over 100 geoprobe borings; and the sampling ofover 80 wells using traditional and low-flow purging techniques. The field work was completed on timeand within budget. Currently writing the final RCRA Facility Investigation Report, which covers all work

i j performed for Phases I, II, and III of the investigation.

Pittsburgh Coke Plant. LTV Steel Company. Pittsburgh. Pennsylvania. Co-wrote the Phase I-PreliminarySite Evaluation (geology and groundwater portions) and was the primary author of the work plan for thePhase II - Initial Site Characterization pertaining to groundwater at the LTV Pittsburgh Coke Plant. Thiswork is being performed in accordance with the Pennsylvania Land Recycling and EnvironmentalRemediation Standards (Act 2). The work plan has been submitted to PADEP for review and approval.

Handv & Harmon Electronics Materials. Montvale. New Jersey. Served as site manager for siteinvestigation portion of this ECRA enforcement action. Produced the site sampling work plan and sitesampling results and participated in the development of the site clean-up plan. The site investigationincluded geophysical, hydrogeological, and soil investigations. The geophysical survey successfullyidentified the location of a septic system thought to be the source of contamination. Provided technical andhealth and safety oversight for the removal of the septic system and associated soils. Performed completesubsurface investigation including welt installation, packer testing, and dovvnhole geophysical logging. Theresults of the investigation proved that most of the contamination was isolated, and an upper glacial aquiferand a lower bedrock aquifer was primarily contaminated by leaking wells improperly installed by aprevious consultant. This downgraded the concern of NJDEPE and helped reduce die number and depth ofwells required by the state, resulting in lower overall cost to the client. Other information gathered in thiscase based on the types of contamination and relative concentrations proved to the previous owner of theproperty that they were partly to blame for the contamination.

Pohl Corporation. Southeastern Pennsylvania. Acted as liaison between Pohl Corporation (Rail Fabricator)and PADEP for contamination identified in wells on the Pohl Property. Performed on-sitc fractureanalysis, aerial photograph fracture trace analysis, and neighboring well survey to identify the groundwater

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WILLIAM RANDALL (continued)

flow regime and likely contaminant pathways. Performed regulatory records searches on neighboringproperties identifying confirmed releases of the same chemicals identified on Pohl property. Performedadditional groundwater analysis on the Pohl property to identify a marker chemical identified on theneighboring property. The marker chemical was identified in the groundwater, further supporting PohlCorporation's stance that the contamination originated off-site. PADEP stated that no further action wasrequired on the part of Pohl Corporation concerning this matter.

Wisconsin Department of Natural Resources. Wisconsin. Applied hydrogeochemical and geochemicalspeciation theory to a groundwater contamination case. A low pH and high metals concentration wasassociated with a drinking water well. Based on the chemical species present and chemical mass balance,theorized that the dissolution of pyrite via bacterial action was the probable cause of the reduced pHresulting from elevated metals concentrations. The regional geology was reviewed for a potential source ofpyrite. Glauconite, which is often associated with a reducing environment and pyrite, was indicated in aunit overlying the contaminated aquifer. A rock core was obtained in the vicinity of the contaminated well.Analysis of the core showed a high concentration of pyrite just below the static water level in the well. Alow-cost solution was recommended to remedy the well contamination.

Denzer and Schafer. Bawille. New Jersey. Performed site characterization and co-wrote Phase II RI/FS forthis New Jersey Superfund site. Performed groundwater and soil sampling under EPA CLP protocol.Performed an interpreted aquifer pumping tests. Interpreted EM magnetic survey to identify the extent of aplume of groundwater contamination.

Deluca Property. Lahaska. Pennsylvania. Reviewed hydrogeologic and geotechnical reports on a proposeddevelopment. Provided Expert's Opinion on the work performed and opinions rendered.

Aewav. Souderton. Pennsylvania. Performed soil and groundwater investigations in response to leakingunderground storage tanks. Acted as liaison with state through the closure process. Based on the results ofthe investigation, the site received no further action status from state.

WEMPCO. Brodheadsville. Pennsylvania. Provided technical support and Expert's Opinion to law firmnegotiating with a citizens action group concerning the effect of mining on a nearby lake. Using standardhydrogeologic principles, mathematically supported the h\polhesis that the proposed mining operationswould have minimal, if any, effect on the nearby lake. Also recommended field controls which could beused to monitor the effect on groundwater prior to producing any impact on the lake.

Kings Manor Development. Monroe County. Pennsylvania. Performed aquifer testing for a new communitydrinking water source. Testing included eight-hour step tests, a 72-hour constant rate pumping test, andrecover.- tests. Additionally, analytical samples were collected and analyzed to meet PennsylvaniaDepartment of Environmental Resources New Source Standards. The well was determined to produce atover 300 gallons per minute. Based on fracture trace and geologic analysis of the area, locations forauxiliary' wells were selected

Woodloch Country Club. Northeast. Pennsylvania. Performed analysis of pumping tests on nine productionwells for this golf course community. Wrote new source report for submittal to the Delaware River BasinCommission which allocates groundwater withdrawals in the site area.

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WILLIAM RANDALL (continued)

Geophysical Surveys

Confidential Client. Horsham. Pennsylvania. Interpreted downhole geophysical logs to identify theconfining layer between an upper contaminated aquifer and a lower uncontaminated aquifer. By definingand sealing off the lower aquifer, the efficiency of the treatment system was greatly increased.

Naval Air Development Center. Warminster. Pennsylvania. Performed electromagnetic conductivitysurveys to isolate pre-1950 disposal areas. The geophysical survey was followed by a soil boring programto characterize the waste contained in the fill areas.

Confidential Client. State College. Pennsylvania. Performed and interpreted downhole and surfacegeophysical surveys to characterize the contaminant transport through a highly sotutioned limestone aquiferat a EPA National Priority List site. The surface geophysics included resistivity and seismic refractionsurveys. The downhole geophysics included: neutron, gamma, caliper, temperature, resistivity, SP, anddensity methods. Fracture trace analysis of aerial photographs was also performed. Mr. Randall'sinterpretation of the groundwater flow regime was contrary to previous theories. However, his theory waslater proved through a drilling program and resulted in modifications to the groundwater remediationsystem to fully capture the contaminant plume.

Michigan Basin Project. Central Michigan. Collected seismic reflection and refraction data in the Michiganbasin. Duties included drilling shot holes with small auger rig, testing continuity of recording equipment,repairing broken geophones and cables, surveying shot points and recording stations with infraredtheodolite, mixing and placing arrays of explosives, and operating recording equipment.

Southwest Indiana Oil and Gas Exploration Project. Indiana. Collected over 100 miles of high qualitymagnetic data at various locations throughout southwest Indiana to locate pinnacle reef deposits. The datawas dumped to a portable computer daily where diurnal drift corrections were made. Profiles of the driftraw, and corrected data were made on a daily basis and correlated with topographic maps and well data forfurther interpretation.

Handv and Harmon. Fairfield. Connecticut. Performed gravity and seismic refraction surveys to delineateburied glacial valley and approximate bedrock surface. Also performed well monitoring and sampling.Study indicated several subsurface bedrock valleys which dictated groundwater flow and contaminantmigration. The bedrock interpretation, when correlated with the analytical data and known contaminantsources, resulted in acknowledgment by the state regulatory agency that the on-site contamination waslimited in nature and reduced the number of required compliance wells.

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WILLIAM RANDALL (continued)

Waste Characterization Studies

Bethlehem Steel - Southwestern. Pennsylvania. Performed waste inventory and characterization for clean-up of an idle steel mill. This project included characterizing over 50 waste streams for disposal ashazardous and non-hazardous waste for disposal prior to a property transfer. Hazardous andnonhazardous chemicals were bulked, and PCB-containing materials were laboratory packed for disposal atappropriate disposal facilities. The project culminated in PADEP inspection which required no furtheraction.

Teledvne Allvac. Latrobc. Pennsylvania. Performed environmental inspections to identify environmentalconcerns associated with heat treatment of specialty steel alloys and estimate clean-up costs associated withthe hazardous materials identified. Inspection included identification of waste streams, and wastecharacterization. The final phase of this project determined appropriate clean-up technologies and providedbid quality estimates for the waste clean-up.

Landfill Permitting and Compliance

Experimental Flvash Landfill. Southeastern Pennsylvania. Performed sampling and prepared annual reportsfor an experimental flyash landfill in southeastern Pennsylvania. Instituted a quality control and qualityassurance program into the groundwater sampling program. These QA/QC procedures reduced theoccurrence of erratic analytical results. The preparation of the annual reports submitted to PADEPincluded the statistical analysis of 10 years of groundwater monitoring data.

PENNDOT • Maver Landfill Project. Southeastern Pennsylvania. Performed long-term environmentalmonitoring for the Mayer Landfill Project. This included stream gauging and water quality sampling ofCobbs Creek to determine the environmental impact on the stream. Well installation and groundwatermonitoring was also performed as part of the long-term environmental monitoring. Also performedenvironmental oversight on the excavation of the landfill and acted as liaison to PADEP concerning theproject. Activities included daily reports with weekly summaries of activities at the landfill, supervision ofwaste handling and sampling.

Inland Steel. East Chicago. Indiana. Co-wrote residual waste landfill permit application for this proposedmonofill disposal facility. This included the waste stream characterization, geology/hydrogeology sections,and many aspects of the landfill operating procedures.

White Pines Landfill. Columbia Co.. Pennsylvania. Co-wrote RCRA Part B Permit Application for thisproposed landfill. Work performed included preparation of the geology and hydrogeology portions of thepermit.

Environmental Compliance Studies

GM. Fredericksburg. Virginia. Wrote asbestos abatement specification and tank management report forthis facility. Tank management report investigated the current and pending regulations to determine thebest management of the an above ground storage tank.

A R I O I 8 2 8

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WILLIAM RANDALL (continued)

EXXON. Pennsylvania. Wrote hazardous waste minimization plans for five fuel distribution centerslocated throughout Pennsylvania.

Ouarrv Monitoring. Southeastern Pennsylvania. Performed stream gauging and NPDES compliancesampling for several quarries in southeastern Pennsylvania. Groundwater monitoring was also performed tomonitor the environmental impact of the quarries.

ADDITIONAL REGISTRATIONS AND CERTIFICATIONS

Asbestos Building Inspectors Course(USEPA-approved), Temple University, 1989Annual Refresher, 1996Asbestos Project Designers Course (USEPA-approved) CEOT, 1995Underground Storage Tank Course, (NJDEPE approved course for removal, inspection andinstallation of underground storage tanks), Rutgers University, 199240 Hr. OSHA Health and Safety TrainingOSHA Site Supervisor Training

PROFESSIONAL AFFILIATIONS

National Association of Groundwater ProfessionalsPennsylvania Association of Environmental ProfessionalsPittsburgh Geologic SocietyReviewer - Groundwater MagazineISO 9000 - Internal Auditor

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Appendix B

oooooCD

or

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APPENDIX B

ACCUTEST ORGANIZATION CHARTAND QA PLAN SUMMARY

A R I O I 8 3

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Accutest Laboratories Organizational Chart

Vincent J PugllesePresident, CEO

Vincent J RuaaoVie* President, CFOH

IRegional Laboratory I

Southeast

Harry BahzadlILaboratory Director)

Ralph J PugliaseVlca President, Adm

Naw EnglandRaglonal Laboratory

Raza TandLaboratory Director

Matthaw CordovaProject Managamant

Kathleen O'NelllBualneaa Oav

William S herdingVP, Operations

Andrew DexterMIS Director

Tammy McCloakeylSample Login |

' 'Nancy Cole

Inorganic* Manager

We) Zhou |_Data Validation p

i 'Brant Buaae

Metala

R Van BlarcomSample Manager

Am

Harold Me leanerField Services

Cheng-Hwan Aosistant Org Manager

Wen-Wen Chl 1Organlca Manager |

Mary O* Brian IWetCnem |

-

Philip ChangReport Prod

Jeaafca ReltanlData Validation |

G ZhangTech Support

Ronald LeaExtra ctiona

B R I O I 8 3 2

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I

Quality Assurance Plan

Document Control Copy Number: 044

4/97 Revision

A R I O I 8 3 3

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TABLE OF CONTENTS

Section 1

QA101

QA102

QA103

Section 2

QA20I

QA202

Section 3

QA301

Section 4

QA401

QA402

QA403

QA404

QA405

Section 5

QA5Q1

QA502

QA503

General

Statement of Quality

Statement of Confidentiality

Management Organizationand List of Signatories

Client Services

Compliance with ISO GUIDE 25/Environmental Program Section(s)

5.2<a).5.4

4.2<b,i).5.2(r),l3.7

4.2<dLe,f,g,h),S.2(b,c,e,f).6.I/6E.2(c)

Client Inquires

Review of Incoming Work

Purchasing

Purchasing Supplies

Quality Control Protocol

Analytical Method Performance Criteria

5.2(q). 16.1

5.2(g), 5.6(c), 9.2, 9.7, 10.8, 15.0

5.2(g), 5.6(a), 10.4 /5B.1.8,S&5, 10.E.10.4

QC Requirements for Metals Analysis 5.2(j,m), 5.6(d)

QC Requirements for General Chemistry Analysis 5.2(f>m), 5.6(d)

QC Requirements for Organic Analysis 5.2G,m), 5.6(d)

Analytical Instruments Preventive Maintenance 5.2(ra), 8.2

Document Control

Document Archiving and Retention Policy 12.1-2

Procedure for the Correction of Analytical Reports 13.5

Laboratory Documents 5.2(d)/10E.I

Pagcl A R I O I 8 3 L *

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TABLE OF CONTENTSSection 6 QA Processes Compliance with ISO GUIDE 25/

Environmental Program Section(s)

QA601

QA602

QA603

QA604

QA605

QA606

QA607

Section 7

SMP001

Section 8

MIS001

Data Validation 5.6(0.10.6, 10.7710E.2, 10E.4

Internal Audits / Corrective Action Procedure 5.2(s), 5.3,5.5

Procedure for Subcontracting Analytical Services 5.2(j),14.1-2

Corrective Action for Analytical Discrepanacies 5.2(o), 5.3,16.2 710E5

Exception to Standard Policy or Procedure

Verification of QA Process

Analyst Training

Sample Handling

Chain of Custody and Login Procedure

Security

Data System Maintenance

5.2(o,p)

4.20), 5.2(n),5.6(b,e). 9.3 /5E.1.5

6.2,6.376E.4.6E.6.1.6E.7

5.200,1U-.4/IIE.6

10.7

Page 2 A R I O I 8 3 5

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IGF KAISERWorUtuiJt Excellence in Meeting Client Netdi

f l R I O I 8 3 6

I

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APPENDIX C

SUMMARY OF SELECTEDCLP QC REQUIREMENTS

A R I O I 8 3 7

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TABLE C-1LABORATORY QUALITY CONTROL CHECK SUMMARY

CD

COCOCO

QC ChecksMethod (Preparation) Blank (MB)Matrix Spike (MS)

Matrix Spike Duplicate (MSD)Matrix Duplicate (MD)Laboratory Control Sample (LCS)

Initial Calibration Check (ICAL)

Continuing Calibration Check (CCAL)

Initial Calibration Verification Check (ICV)

Initial Calibration Blank (ICB)

Continuing Calibration Verification Check (CCV)

Continuing Calibration Blank (CCB)

Surrogate SpikeICP Interference Check Sample

ICP Serial Dilution

Minimum Frequency1 per 20 or prep/analysis batch per SDG1 per matrix per 20 or SDG

1 per matrix per 20 or SDG (organics only)1 per matrix per 20 or SDG (inorganics only)1 per analytical batch not to exceed 20 samples(inorganics only)Beginning of each analytical sequence (organics)

Every 12 hrs. or per shift not to exceed 12 hrs.(GC/MS). Every 10 samples during analytical run(GC)1 per analytical run immediately followingcalibration (inorganics only)1 per analytical run immediately following the ICV(inorganics only)Every 10 samples during analytical run(inorganics only)Every 10 samples immediately following CCV(inorganics only)Every analytical run (organics only)Beginning and End of analytical run (ICPinorganics only)1 per matrix per 20 or SDG (ICP inorganics only)

CriteriaNo detectionsCompound specific as stated in CLP SOW(organics), 75-125% recovery (inorganics)Compound specific (organics only)20% RPD or ± CRDL if < 5X CRDL80-120% recovery; except for Ag & Sb

Minimum RRF and maximum % RSD as statedin CLP Organic SOWMinimum RRF and maximum %D as stated inCLP SOW

90-110% recovery; except Hg 80-120% andcyanide 85-1 15%No detections

90-110% recovery; except Hg 80-120% andcyanide 85-11 5%No detections

% Recovery as stated in CLP SOW80-1 20% Recovery

10 %Difference if detects >50X the IDL

Sharon Steel, QAPP70817 '-B

Finaly ' 1998

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N.I TABLE C-2 . . „ , . ; . .INORGANIC TARGET ANALYTE LIST (tAL) AND CRDLs

Analyte

AluminumAntimonyArsenicBariumBerylliumCadmiumCalciumChromiumCobattCopperIronLeadMagnesiumManganeseMercuryNickelPotassiumSeleniumSilverSodiumThalliumVanadiumZincCyanide

Contract RequiredDetection Limit (ug/L)

2006010

20055

50001050251003

5000150.240

5000510

500010502010

Sharon Steel, QAPP70812-16-B

A R I O I 8 3 9

FinalAugust 1998

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TABLE C-3VOLATILE COMPOUND LIST AND CONTRACT REQUIRED QUANTITATION LIMITS

Compound

ChloromethaneBromo methaneVinyl ChlorideChloroethaneMethylene ChlorideAcetoneCarbon Disulfide1,1-Dichloroethene1,1-Dichloroethane1 ,2-Dichloroethene (total)Chloroform1 ,2-Dichloroethane2-Butanone1,1,1-TrichloroethaneCarbon TetrachlorideBromodichloro methane1 ,2-Dichloropropanecis-1 ,3-DichloropropeneTrichloroetheneDibromochloromethane1,1,2-TrichloroethaneBenzenetrans-1 ,3-DichloropropeneBromoform4-Methyl-2-pentanone2-HexanoneTetrachloroethene1 ,1 ,2,2-TetrachloroethaneTolueneChlorobenzeneEthylbenzeneStyreneXytenes (total)

Quantitation LimitsWater(ug/L)

101010101010101010101010101010101010101010101010101010101010101010

Soil(ug/Kg)

101010101010101010101010101010101010101010101010101010101010101010

Medium Soil(ug/Kg)

120012001200120012001200120012001200120012001200120012001200120012001200120012001200120012001200120012001200120012001200120012001200

Sharon Steel, QAPP70812-16-B

FinalAugust 1998

f l R I O I S U O

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i I TABLE C-4SEMIVOLATILE COMPOUND LIST AND CONTRACT REQUIRED QUANTITATION LIMITS

Compound

Phenolbis-(2-Ch!oroethyl) ether2-Chlorophenol1 ,3-Dichlorobenzene1 ,4-Dich!orobenzene1,2-Dichlorobenzene2-Methylphenol2.2'*oxybis (1-Chloropropane)4-MethylphenolN-Nitroso-di-n-propylamineHexachloroethaneNitrobenzeneIsophorone2-Nitrophenol2,4-Dimethylphenotbis(2-Chloroethoxy) methane2,4-Dichlorophenol1 ,2,4-TrichlorobenzeneNaphthalene4-ChloroanilineHexachlorobutadiene4-Chloro-3-methylphenol2-MethylnaphthaleneHexachlorocyclopentadiene2,4,6-Trichlorophenol2,4,5-Trichlorophenol2-Chloronaphthalene2-NitroanilineDimethylphthalateAcenaphthylene2,6-Dinitrotoluene3-NitroanilineAcenaphthene2,4-Dinitrophenol4-NitrophenolDibenzofuran2,4-DinitrotoIueneDiethylphthalate4-Chlorophenyl phenyl etherFluorene4-Nitroaniline4,6-Dinitro-2-methylphenolN-Nitroso-diphenylamine4-Bromophenyl phenyl etherHexachloro benzenePentrachlorophenolPhenanthrene

Quantitation LimitsWater(ug/L)

10101010101010101010101010101010

• 10101010101010101025102510101025102525101010101025251010102510

Soil<ug/Kg)

330330330330330330330330330330330330330330330330330330330330330330330330330830330830330330330830330830830330330330330330830830330330330830330

Medium Soil(ug/Kg)1000010000100001000010000100001000010000100001000010000100001000010000100001000010000100001000010000100001000010000100001000025000100002500010000100001000025000100002500025000100001000010000100001000025000250001000010000100002500010000

Sharon Steel, QAPP70812-I6-B

A R I O I 8 M

FinalAugust 1998

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TABLE C-4SEMIVOLATILE COMPOUND LIST AND CONTRACT REQUIRED QUANTITATION LIMITS

AnthraceneCarbazoleDi-n-butylphthalateFluoranthenePyreneButy Ibenzy 1 phth al ate3,3'-DichlorobenzidineBenzo(a)anthraceneChrysenebis(2-Ethylhexyl)phthalateDi-n-octylphthalateBenzo(b)fluorantheneBenzo(k)fluorantheneBenzo(a)pyreneIndeno (1,2,3-cd) pyreneDibenz (a,h) anthraceneBenzo (g,h,i) perylene

1010101010101010101010101010101010

330330330330330330330330330330330330330330330330330

1000010000100001000010000

L 100001000010000100001000010000100001000010000100001000010000

Sharon Steel, QAPP70812-16-B

f l R I O I 8 l 4 2Final

August 1998

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; TABLE C-5PESTICIDE/AROCLOR COMPOUND LIST AND CONTRACT REQUIRED QUANTITATION

LIMITS

[ .

Compoundalpha-BHCbeta-BHCdelta-BHCgamma-BHC (Lindane)HeptachlorAldrinHeptachlor epoxideEndosulfan 1Dieldrin4,4'-DDEEndrinEndosulfan II4,4'-DDDEndosulfan sulfate4,4'-DDTMethoxychlorEndrin ketoneEndrin aldehydealpha-Chlordanegamma-ChlordaneToxapheneAroclor-1016Aroclor-1221Aroclor-1232Aroclor-1242Aroclor-1248Aroctor-1254ArocIor-1260

Quantitation LimitsWater (ug/L)

0.050.050.050.050.050.050.050.050.10.10.10.10.10.10.10.50.10.1

0.050.05

51211111

Soil (ug/Kg)1.71.71.71.71.71.71.71.73.33.33.33.33.33.33.3173.33.31.71.717033673333333333

Sharon Steel, QAPP70812-16-A

A R I Q I 8 l * 3

FinalAugust 1998

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TABLE C-6MATRIX SPIKE RECOVERY AND RELATIVE PERCENT DIFFERENCE LIMITS

Compound

1,1-DichloroetheneTrichloroetheneBenzeneTolueneChlorobenzenePhenol2-Chorophenol1 ,4-DichlorobenzeneN-Nitroso-di-n-propylamine1 ,2,4-Trichlorobenzene4-Chloro-3-methylphenolAcenaphthene4-Nitrophenol2,4-DinitrotoluenePentachlorophenolPyrenegamma-BHCHeptachlorAldrinOieldrinEndrin4,4'-DDT

% RecoveryWater61-14571-12076-12776-12575-13012-11027-12336-9741-11639-9823-9746-11810-8024-969-10326-12756-12340-13140-12052-12656-12138-127

RPDWater

14141113134240283828423150385031152022182127

% RecoverySoil

59-17262-13766-14259-13960-13326-9025-10228-10441-12638-10726-10331-13711-11428-8917-10935-14246-12735-13034-13231-13442-13923-134

RPDSoil22242121213550273823331950474736503143384550

Sharon Steel, QAPP70812-16-B

FinalAugust 1998

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TABLE C-7SYSTEM MONITORING COMPOUND RECOVERY LIMITS

CompoundToluene-d8Bromofluorobenzene1,2-Dichloroethane-d4Nitrobenzene-dS2-FluorobiphenylTerphenyl-d14Phenol-dS2-Fluorophenol2,4,6-Tribromophenol2-Chlorophenol-d41 ,2-Dichlorobenzene-d4Tetrachloro-m-xyleneDecachlorobiphenyl

% Recovery Water88-11086-11578-11435-11443-11633-14110-11021-11010-123

33-110jadvisoryL16-110 (advisory)30-1 50 (advisory)30-1 50 (advisory)

% Recovery Soil84-13859-11370-12123-12030-11518-13724-11325-12119-122

20-1 30 (advisory)20-1 30 (advisory)30-1 50 (advisory)30-1 50 (advisory)

Sharon Steel, QAPP70812-16-B

A R I O I 8 1 + 5

FinalAugust 1998

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Appendix D

1H soeft 1

* —

GO

CD

or

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APPENDIX D

LABORATORY AUDIT CHECKLIST

A R I O I 8 l * 7

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LABORATORY AUDIT CHECKLIST

A. OrganizationLab:

Date:

Laboratory manager:

Project manager:

• who is our contact person?

• how available are they?

Do lab personnel have the appropriate educational background?

Do lab personnel have the appropriate level and type of experience?

What is your turnover rate?

Is the lab adequately staffed to analyze the samples in a timely manner?

# samples per month?

avg turnaround time? (do you track?)

# analysts?

A R I O I 8 l * 8

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S. Sample Receipt and ControlPerson in charge:

Are there SOPs to cover the receipt, storage, and tracking of samples? Where?

Describe the sample check-in/Iog-in process. What information is recorded about eachsample? Where is it recorded?

How does sample prep know that samples need analysis?

What if the COC does not agree with the expected analysis?

Describe your internal custody procedures.

Where and how are samples stored (4 °C)7

Are there adequate sample storage facilities?

Is the temperature of the cold storage area recorded daily?,

Describe lab security.

A R I O I 8 U 9

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C. Sample PreparationSource of demineralized/distilled water? Organic-free water?

Is the balance routinely checked?

Are the sample prep SOPs available?

Are reagents dated upon receipt?

Are reagents used on a first in first out basis?

D. Standards PreparationWhat grade chemicals are used?

Are reagents dated upon receipt?

Are reagents used on a first in first out basis?

Are reference materials labeled with concentration, date of prep, and ID of person?

Is a logbook maintained for standards preparation and tracking?

Are primary standards traceable to NIST or A2LA certified?

Are VOA and B/N/A solutions stored separately?

Are standards stored separately from sample extracts?

A R I O I 8 5 0

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£. MaintenanceWhere are the service (maintenance) logbooks?

Do you have a service contract?

What is the preventive maintenance schedule?

Are spare parts kept at the lab?

F. Analytical ProceduresHow often are instruments calibrated? How is the calibration performed?

What QC is included in each sample batch?

Is the interference correction performed during ICP analysis?

Do you routinely measure sample pH?

What corrective action is taken if an LCS recovery is out during VOA analysis?

an internal standard area?

a continuing calibration?

a target analyte is detected in the blank?

How is the corrective action documented?

A R 1 0 I 8 5 I

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G. Data Generation and Record KeepingDescribe your record keeping procedures.

Are data results reviewed by the QC manager/department?

How are records maintained? For how long?

Do analysts record:

• deviations from procedure

• corrective actions

• manual integrations

• Where? How is this communicated to the client?

Where are completed lab notebooks stored (if used)?

A R I O I 8 5 2

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H. Internal Quality ControlAre QC reference samples routinely analyzed as blind or unknown samples?

How often are method detection limit studies performed?

• how performed?

• copy of most recent available?

How are out-of-control situations documented?

• adequacy of corrective action?

What training do the analysts receive?

• general?

• method specific?

• check sample?

• documentation?

Are calculations checked by a second person?

How are QC limits calculated?

• how updated?

• how often?

Oo supervisors review the data and QC results?

How often are SOPs updated?

• analyst training after updates?

• available in lab?

A R I O I 8 5 3