STATE OF NEW HAMPSHIRE Department of Environmental Services

November 29, 2012

August 2012 Technical System Audit (TSA) Coakley Landfill Superfund Site North Hampton, New Hampshire

DES# 198712001

Prepared by: Sharon G. Perkins, Remedial Project Manager Hazardous Waste Remediation Bureau Telephone: (603) 271-6805 Fax: (603) 271-2181 E-Mail: Sharon.Perkins@des.nh.gov

Prepared for: Drew Hoffman, NHDES Project Manager

Distribution List: Gerardo Millan-Ramos, USEPA, Region I Robert Reinhart, USEPA, Region I Mike Jasinski, USEPA, Region I

Attachments: Request for 2012 Coakley Audit CoakleyLandfill-2011Report QA RFA # 10084 Low Flow Setup Diagram from EPA EQASOP-GW 001; January 2010 August 28, 2012 Discrete Sampling Worksheet August 28, 2012 Low Flow Sampling Worksheet August 28, 2012 Calibration Log

I. SCOPE

Gerardo Millan-Ramos, the EPA Remedial Project Manager, requested that we perform a field technical system audit during the August 2012 sampling event at the Coakley Landfill. The scope of the audit was to observe Provan & Lorber’s sampling personnel perform calibration and calibration checks of field equipment, and collect groundwater samples using low-flow sampling and discrete interval groundwater sampling procedures to determine if Provan & Lorber are adhering to the approved Project Operation Plan (POP), April 2010, and the revised Discrete Interval Sampler standard operating procedure (SOP), January 2011. The POP includes the Environmental Monitoring Plan, Attachment I and the Assurance Project Plan, Attachment II.

II. PERSONNEL

The following people were on-site during the August 28, 2012 audit: Gerardo Millan-Ramos, Remedial Project Manager and Robert Reinhart, Quality Assurance (auditor) from EPA; Andrew Hoffman, Project Manager and Sharon Perkins, Quality Assurance (auditor) from NHDES; Peter Britz from the City of Portsmouth representing the Coakley Landfill Group, the potentially responsible parties; Kevin McKibben, the primary sampler, and another unidentified sampler who assisted with the discrete interval sampling, from Provan & Lorber, the sampling contractor.

III. EXECUTIVE SUMMARY

While Provan & Lorber generally followed the sampling protocols in the January 2011 revised Discrete Interval Sampler SOP, many details in the Calibration and Low Flow SOPs, and in the

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Quality Assurance Project Plan and Environmental Monitoring Plan in the POP were overlooked. It appears that Provan & Lorber is not all that familiar with the SOPs and in general, the POP. Corrective action is required. Additional training of the correct procedures is warranted.

There is considerable concern that while two of the findings in this audit were brought to the attention of Provan & Lorber in a previous quality assurance review, the turbidity meter not being calibrated prior to use and the missing information on the sampling worksheets, it appears that no corrective action was taken by Provan & Lorber and the same issues are being readdressed here.

IV. OBSERVATIONS, FINDINGS, CORRECTIVE ACTIONS AND RECOMMENDATIONS

Audit Procedures and Observations:

The field equipment was calibrated prior to sampling according to the EPA Standard Operating Procedure Calibration of Field Instruments, EQASOP- FieldCalibrat (Cal SOP); January 2010 as provided in the Environmental Monitoring Plan.

Discrete interval sampling was conducted at monitoring well GZ-125 using a two person team. The Discrete Interval Sampler SOP was revised in January 2011 after EPA and NHDES observed Provan & Lorber sample GZ-125 using the discrete sampler in November 2010. Modifications included utilizing a two person sampling team for this type of sampling; using a nitrogen tank instead of a hand pump to make the sampling less labor intensive; and installing a pressure gauge between the pressure/vent valve and the tubing to the interval sampler to monitor the pressure while sampling. It appears that the modifications in the revised SOP have been implemented.

The low flow sampling procedure was conducted at monitoring well GZ-123 using a peristaltic pump and the EPA Low Stress (low flow) Purging and Sampling Procedure for the Collection of Groundwater Samples from Monitoring Wells, EQASOP-GW 001; January 2010 SOP (LF SOP) as provided in the Environmental Monitoring Plan.

Morning Calibration and Calibration Check

The YSI 600 XL multiparameter meter was calibrated in the morning prior to sampling. NHDES and EPA also requested that the sampler perform a mid-day calibration check after sampling the two wells to ensure that the calibration check procedures were being adhered to as well.

1. Finding – Turbidity Calibration

The turbidity meter was not calibrated by the sampler during the audit or prior to sampling. This issue was previously brought to the attention of Provan & Lorber in the attached EPA quality assurance review of the 2011 Annual Report by Charles Porfert, dated April 24, 2012. His review noted that all the instrument calibration logs were missing the turbidity calibration data.

Corrective Actions –

a. The turbidity meter must be calibrated daily prior to use and a check of the calibration must be performed at the end of the day and at any required mid-day calibration

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checks.

b. Revise the Calibration Log to include a space for the turbidly calibration, listing the standards used for calibration and calibration check.

2. Finding – YSI Calibration Cup

The sampler didn’t wipe the calibration cup dry between standards. The standards were poured back into the original bottle, thereby diluting the standard each time. Corrective Action – The calibration cup must be wiped dry between standards to prevent dilution of the standards.

3. Finding – YSI Temperature

While this is not calibrated or checked in the field, the sampler did not provide any information showing that the temperature unit on the YSI instrument had been checked against a certified thermometer that is traceable to the National Institute of Standards and Technology (NIST) within the year by either Provan & Lorber or the vendor, as required in Cal SOP.

Recommendation – Documentation that this requirement has been met (name, date, time and findings) either by the vendor or Provan & Lorber must be kept with the instrument in the field.

4. Finding – YSI Conductivity Standard

a. The conductivity standard used was a 1000 mg/l standard. Table 3.2 Field Sampling Equipment Calibration Requirements in the Environmental Monitoring Plan requires a 1413 mg/l standard.

Corrective Action – The sampling team must use the correct 1413 mg/l specific conductivity standard as required in the POP.

b. The Cal SOP requires a second standard to check the linearity of the instrument in the range of measurements. No second standard was used.

Corrective Actions –

1) The sampling team must use a second standard to check the linearity of the instrument in the range of measurements. The specific conductance values recorded on the worksheets was 200 µS/cm at GZ-123 and 408 µS/cm at GZ-125. It is recommended that the second standard be closer to the values found at the site.

2) Revise the Calibration Log to include a space for the second standard.

5. Finding – YSI Oxidation Reduction Potential (ORP)

a. The Calibration Log used by the sampler has a typed in millivolt (mV) value of 240 for the Zobell solution, which is what the sampler entered into the instrument during calibration. According to the Cal SOP, the Zobell solution is temperature dependent. The sampler did not check, or write down, the temperature of the Zobell solution, and did not check the chart that comes with the Zobell solution for the correct mV value at the temperature of the solution during calibration or the calibration check. The temperature

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was observed to be 22⁰C according to the instrument during calibration. The correct mV value for a temperature of 22⁰C is 235, not 240.

Corrective Actions –

1) Removal of the typed in 240 ORP value from the Calibration Log.

2) Revise the Calibration Log to include spaces for the Zobell temperature and the temperature corrected mV value to be entered during calibration.

3) The sampling team must have, and use, a chart for the Zobell solution mV values based on temperature for ORP calibration.

b. The mid-day calibration check value of 222.3 is not with in the +/- 10 mV criteria (230­250 for an initial value of 240), however the meter was not recalibrated.

Corrective Action –

If the mid-day calibration check does not meet the criteria for a parameter then the instrument must be re-calibrated for that parameter using all the calibration standards for that parameter. In addition, any readings collected prior to the recalibration must be qualified for use on the appropriate worksheets.

For example, the ORP mid-day calibration check was not within the calibration criteria, therefore the values obtained during the sampling of both GZ-123 and GZ-125 must be qualified on the worksheets as estimated values. The low flow worksheet for GZ-123 should include a note such as, “The mid-day calibration check for ORP was not within the acceptable range; therefore, these ORP values can only be used for determining stabilization and not as representative of actual ORP values of the water being sampled.”

6. Finding – Calibration Data

Not all of the calibration data was entered onto the calibration log at the time of calibration, including the barometric pressure, instrument serial numbers etc. When the sampler performed the calibration check after sampling the two wells, at least some of the missing information from the morning had been filled in, apparently from memory sometime during sampling of the wells.

Corrective Actions –

a. All calibration data must be recorded on the calibration logs at the time of calibration and calibration checks, including date and times.

b. Provan & Lorber should provide clarification on how and when the calibration was competed along with an explanation as to the delay of recording the information.

Discrete Interval Sampling at GZ-125

1. Finding – It appears that the modifications to the Discrete Interval Sampler SOP have been implemented.

2. Finding: Depth Measurement

a. The sampler took a depth of well measurement using the water level without adjusting for the end of the water level probe. The tape is measured from the zero measurement

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point, as in the picture below, not from the end of the probe itself.

Corrective Action - When using the water level to measure the depth of the well you must add the distance between the end of the probe and the zero measurement point to the total depth measurement, which is typically between 2-3 inches.

b. The depth of the well was not recorded on the sampling worksheet. This issue was also previously brought to the attention of Provan & Lorber in the attached EPA quality assurance review of the 2011 Annual Report by Charles Porfert, dated April 24, 2012. His review noted that total depths, and other pertinent information, was missing from some of the worksheets.

Corrective Action – A more thorough review of the worksheets is needed before leaving each sampling location to make sure the worksheets are filled out completely and correctly.

3. Finding – Sample Handling

The sampler collected the samples for VOCs and metals and then left them on the ground while he finished writing out the labels for all the samples and repeated the sampling process once more to collect readings from the multiparameter meter (for temperature, DO, pH, ORP, specific conductivity and turbidity). The samples, including the VOCs, were left on the ground for approximately 10 minutes before they put in a cooler. The integrity of the VOC samples may be questionable.

In addition, the VOC samples were placed on top of a plastic re-sealable bag containing ice, not in ice. There did not appear to be a thermometer in the cooler to ensure the samples were being cooled to the proper temperature preservation required.

Corrective Actions –

a. Sample labels should be completely filled out just prior to sample collection.

b. VOC samples must be put in a cooler of ice immediately after sample collection, not left exposed to the elements for any length of time.

c. VOC samples should be placed within loose ice to ensure proper temperature preservation.

Low Flow Sampling at GZ-123

1. Finding - 5 gallon Bucket

The LF SOP requires a graduated bucket to measure the total volume purged. The bucket used during the low flow sampling was not graduated so the total volume could not be accurately measured.

Corrective Action – Replace the bucket with one that is graduated.

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2. Finding – Purge Rate

a. According to the LF SOP, the purge (flow) rate should be recorded in ml/min. The worksheet Purge Rate column does not contain units and the sampler did not write in any units. It is unclear what the numbers in that column represent (e.g. “252”, is that 252 ml, and is it per minute, or per every 5 minutes, etc.).

Corrective Action – Revise the worksheet to show units as ml/min.

b. The worksheet showed that the purge rate varied. There is nothing under the comment section to indicate if the pump settings were adjusted or not.

Corrective Action – Record any changes in pump settings.

c. A measuring cup was used to measure purge rate. The measuring cup held a total of 500 ml and measured in 50 ml increments. Yet some of the purge rates were recorded as 272, 258, and 252. These appear to be more accurate readings than possible with a container graduated in 50 ml increments.

Corrective Action – Use a standard graduated cylinder that is graduated down to 2 ml increments.

3. Finding - Flow Through Cell

a. A significant amount of gas or air was entrapped and clearly visible at the top of the flow through cell throughout the sampling of the well, which may cause the probes to act erratically and would affect the dissolved oxygen readings.

Corrective Actions –

1) Follow the LF SOP and refer to the attached low flow setup diagram. Tilt the flow cell at a 45 degree angle with the port facing upward. The LF SOP states, “The flow-through-cell must be designed in a way that prevents gas bubble entrapment in the cell. Placing the flow-through-cell at a 45 degree angle with the port facing upward can help remove bubbles from the flow-through-cell (see Appendix B Low-Flow Setup Diagram). All during the measurement process, the flow-through-cell must remain free of any gas bubbles. Otherwise, the monitoring probes may act erratically.”

2) Clean the flow through cell.

b. While not mandatory, the LF SOP “prefers” the use of a transparent low through cell. The flow through cell was not transparent enough to see whether or not individual bubbles were collecting around the probes or not.

Corrective Action – Use a transparent flow through cell so you can see whether or not individual bubbles were collecting around the probes and possible sediment buildup in the flow cell which could affect the readings.

c. While not mandatory, the LF SOP “prefers” the use of a small (250 ml or less) transparent low through cell. The flow through cell used was not 250 ml or less, it held approximately 500 ml.

While the flow rate seemed adequate for this particular well, the FL SOP states, “The pump=s flow rate must be able to “turn over” at least one flow-through-cell volume between measurements (for a 250 mL flow-through-cell with a flow rate of 50 ml/min., the monitoring frequency would be every five minutes; for a 500 mL flow-through-cell it

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would be every ten minutes). If the cell volume cannot be replaced in the five minute interval, then the time between measurements must be increased accordingly.”

Accordingly, with a 500 ml volume flow through cell, the time between readings would have to be more than 5 minutes apart for any flow rates below 100 ml/minute. A review of previous sampling worksheets indicates that other site wells would be affected. For example in August 2011, monitoring well MW-10 had a flow rate of 80 and 90 (assuming those values meant 80 or 90 ml/minute). The flow rate was lower at other locations such as FPC-2a and GZ-105 (flow rate of 84), yet the readings were still collected every five minutes. It appears that a 500 ml flow through cell may not be adequate for all site locations.

Corrective action - Use a flow cell that is 250 ml or less, which is available on request from vendors.

4. Finding – Tubing

a. There was an excessive amount of tubing coming out of the well and exposed to the elements.

Corrective action - Utilizing shorter tubing is more appropriate. There should be just enough tubing above the top of the casing to connect easily to the peristaltic pump. The LF SOP states, “Pump tubing lengths, above the top of well casing should be kept as short as possible to minimize heating the groundwater in the tubing by exposure to sun light and ambient air temperatures. Heating may cause the ground water to degas, which is unacceptable for the collection of samples for VOC and dissolved gases analyses.”

b. There was a kink in the rigid tubing coming from the well before the tubing connected to the peristaltic pump during the entire low flow sampling of that well. The kink caused the tubing to angle down at nearly 90 degrees so that the water in the tubing was cascading down the tubing for approximately 18 inches or so before the tubing leveled out. This can cause erratic dissolved oxygen readings and the groundwater to degas resulting in the loss of VOCs.

Corrective Actions –

1) The sampler must check the condition and placement of the tubing before and during sampling.

2) The tubing in well GZ-123 must be replaced.

5. Finding – Sample Collection

a. The sampler did not slow the pump down from a purge rate of approximately 250 ml/minute (assuming those are the correct units) when collecting VOCs, which may have caused aeration and loss of VOCs.

Corrective Action – The FL SOP states “Fill all sample containers by allowing the pump discharge to flow gently down the inside of the container with minimal turbulence….. If the pump rate is too high to collect the VOC/dissolved gases samples, collect the other samples first. Lower the pump’s flow rate to a reasonable rate and collect the VOC/dissolved gases samples and record the new flow rate.”

b. The sampler also did not slow or stop the pump while putting the filter on the end of the

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tubing to collect dissolved metal samples, thereby spraying contaminated water over the equipment and surrounding area.

Corrective Action – Shut the peristaltic pump off momentarily (with no loss of pressure) while the filter is placed on the end of the tubing to avoid contaminating the surrounding area.

V. CONCLUSIONS

While Provan & Lorber generally followed the sampling protocols in the January 2011 revised Discrete Interval Sampler SOP, it appears that they were not completely familiar with or correctly following the EPA’s Calibration and Low Flow SOPs as many details were overlooked. Corrective action is required.

Calibration issues include: Not calibrating the turbidity meter prior to use; not using the correct standards and/or not using them appropriately; not recalibrating the ORP when the mid-day calibration check did not meet the calibration criteria, and not recording the calibration data on the Calibration Log at the time of calibration. A thorough review of the Calibration SOP and the POP and a revision of the Calibration Log is required.

Sampling issues include: Not recording all pertinent data on the sampling worksheets; sample collection and handling (high flow rate during sample collection and not putting VOCs in the cooler immediately after sample collection); significant amount of air in the flow through cell and tubing causing erratic probe readings and loss of VOCs. A thorough review of the Low Flow Sampling SOPs and the POP is required.

The following two findings were previous brought to the attention of Provan & Lorber and had to be readdressed here: the turbidity meter not being calibrated prior to use and the missing information on the sampling worksheets.

__________________________________________________________________________

-----Original Message-----From: Gerardo Millan-Ramos [mailto:Millan-Ramos.Gerardo@epamail.epa.gov] Sent: Friday, April 27, 2012 3:18 PM To: Donovan, Joe Cc: Mike Jasinski Subject: Fw: Coakley Landfill

Joe, I hereby request that a state field auditor be assigned for the Coakley Landfill next sampling round (August 2012). I strongly suggest that it be Sharon Perkins as she is experienced, has personally observed the discrete interval sampler on-site, and is highly regarded by our expert, Charlie Porfert. Attached you will see my request for a field auditor to our Lab at EPA, and a copy of Charlie's comments. You will see Charlie's comments included in my set of comments soon.

Please call with any questions.

Gerardo Millán-Ramos Remedial Project Manager Office of Site Remediation and Restoration U.S. EPA - New England, Region 1 5 Post Office Sq. Suite 100 Mail Code OSRR07-1 Boston, MA 02109-3912 tel. (617) 918-1377 fax (617) 918-0377 ----- Forwarded by Gerardo Millan-Ramos/R1/USEPA/US on 04/27/2012 03:12 PM ----­

From: Gerardo Millan-Ramos/R1/USEPA/US To: Gerry Sotolongo/R1/USEPA/US@EPA Cc: Charlie Porfert/R1/USEPA/US@EPA, Mike Jasinski/R1/USEPA/US@EPA Date: 04/25/2012 09:47 AM Subject: Coakley Landfill

Gerry,

Attached you will find a copy of a memo I recently received from Charlie Porfert providing his comments after reviewing the latest Annual Report. Charlie did, as always, a great job in detecting flaws that pertain to the QA/QC of the data. As you will see in the memo, some information is missing from the field forms which question the data's reliability. In fact, depending on the response I receive from the PRP, the entire data set may need to be rejected.

I am hereby requesting that a field auditor be assigned to my site for the next sampling event (August, 2012). The purpose of the field audit is two-fold:

1) Verify the implementation of the field work against the approved Project Operation Plan and Environmental Monitoring Plan, paying particular attention to the deficiencies pointed out by Charlie on the attached memo.

2) Verify the correct use and performance of a Solinst TM Discrete Interval Sampler. Modifications to its

use were required by NHDES and EPA after observing its use for the very first time. According to the PRP those modifications have been implemented, yet we have not had an opportunity to confirm it and to verify that it is working properly.

(See attached file: CoakleyLandfill-2011Report.doc) Thanks in advance, and please call with any questions you may have.

Gerardo Millán-Ramos Remedial Project Manager Office of Site Remediation and Restoration U.S. EPA - New England, Region 1 5 Post Office Sq. Suite 100 Mail Code OSRR07-1 Boston, MA 02109-3912 tel. (617) 918-1377 fax (617) 918-0377

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND

OFFICE OF ENVIRONMENTAL MEASUREMENT & EVALUATION 11 TECHNOLOGY DRIVE

NORTH CHELMSFORD, MA 01863-2431

MEMORANDUM

DATE: April 24, 2012

SUBJ: Coakley Landfill Site North Hampton, NH

2011 Annual Report March 28, 2012 Prepared by Provan & Lorber, Inc.

QA RFA # 10084

FROM: Charles Porfert Quality Assurance Unit

TO: Gerardo Millan-Ramos OSRR07-2

The above document was submitted to the Quality Assurance Unit for review. Below are my comments on the above document.

1. Page 4, 2.3 Quality Control Samples

The first sentences says duplicate samples were collected from MW-5S and AE-3B and analyzed for VOCs, 1,4-dioxane, total TAL metals and dissolved iron and manganese. Identify where this data is located. This also, applies to the leachate data.

2. Page 9, Recommendations

Add to Section 3.4 Data Validation or create a new section which describes the review the field information (e.g., field sheets, instrument calibration logs, etc.).

3. Section 2 Field Data Sheets – Observations

The sheet describes the sampler’s observations of the wells. The observations show that some of the wells are missing the well locks. Part of the Chain-of-Custody for the site is to have the wells locked between sampling events. The wells need to be locked to ensure the integrity of the wells.

4. Section 2 Field Data Sheets – Well Purging Information

On some of the Sheets, the Depth to Water, Total Depth, and Pump Intake Depth information are missing. These Sheets need to be completed so there is a record of how the wells were sampled.

5. Section 2 Calibration Sheets (Table 1 Instrument Calibration Log)

All the Sheets are missing the Turbidity calibration data. Was the Turbidity meter calibrated before it was used? If the meter was not calibrated before use then the data from the meter needs to be rejected. Please explain.

The YSI meter (serial number 01D1093AB) which appears in all the Sheets, does not meet the dissolved oxygen (DO) criterion (<0.5 mg/L) when the DO probe is placed in a zero DO solution. The meter did not meet the criterion in the morning and at the end of the day according to the Sheets. Explain why the meter was not replaced or fixed on-site. If the meter was used to perform environmental measurements then that DO data needs to be rejected.

The end of day calibration check was not performed for the YSI meter (serial number 00D1093AB) on 8/18/2011. It was performed on the other days the meter was used. Please explain.

The barometric pressure which is needed for the dissolved oxygen calibration is missing from all the Sheets. Was the 100% dissolved oxygen water saturated air calibration for the dissolved oxygen meter corrected for barometric pressure? Please explain.

If you have any questions on my review, please contact me at (617) 918-8313 or email me at porfert.charlie@epa.gov.