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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY. -—. » REGION IIIi SK * 841 CHESTNUT BUILDINGo*s< " PHILADELPHIA, PENNSYLVANIA 19107

July 16, 1992

CERTIFIED MAIL: RETURN RECEIPT REQUESTED

Mr. Michael J O'Brien, ManagerEnvironmental AffairsCooper IndustriesFirst City Tower, Suite 4000, P.O. Box 44461001 Fannin Street, 40th FloorHouston, Texas 77210

Re: Osborne Landfill - Operable Unit 4 ., .Pine Township, Mercer County, PA

Dear Mr. O'Brien:

EPA has reviewed the revised draft Work Plan for the Remedi-al Design of OU4, dated August 22, 1992. Below are the commentsreceived from various reviewers. When necessary, I have added astatement in brackets to clarify the comment, to explain what EPAis requesting, or to note that EPA disagrees with the comment andexplain the rationale for the disagreement.

RCRA

.Figures that show the Site should have a scale bar to avoidconfusion in reduced copies.

The boundary conditions, impermeable boundaries, constant-headboundaries and water table boundaries, are used as the boundariesof the flow net in figure 4. Therefore, the flow net construc-tion used mostly applies to porous granular media. If thefracture density is high, or turbulent flow exists, the flow netswill not be valid. [RPM comment: Although this is true, EPArequested this analysis to give a rough estimate of the problemposed by pumping and treating this aquifer.]

Bedrock cores should be logged and photographed with elevationmarks for comparison with other logging methods employed.

Page 4-14 The Field Sampling /Ground Water Monitoring Planshould also contain plans for air monitoring. [ RPM comment:Emission controls are required for VOCs and the design mustcontain the details of monitoring the emissions.]

The pre-final/final design should include cost estimates, com-plete lists of material and equipment, services procurement andbids.

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Wherever a reference is made to a sampling plan for water, airsampling should also be discussed.

COMMENTS BY GARY POLING

1. Workplan, pg 4-3, para 4.1.2: Figure 7 is referenced, but isapparently missing from the workplan documents. Please providethis figure in your next submittal. [ RPM comment: The figurewas sent to EPA, but EPA cannot copy blueprints. If it is notpossible to limit drawings to 11" x 17" sheets, please supply atleast five extra sets of blueprints to EPA].

2. Workplan, pg 4-7, Figure 8: This figure should be transposedonto the site map to show the relationship with the site and the"plume". [RPM comment: This was done on Figure 7, but thereviewer did not have a copy.] *'

3. Workplan, pg 4-9, para 4.1.5.d:a. The pump rate during the pump test should simulate theanticipated pump rate during the proposed remedy as closelyas possible (in addition to being a "sustainable pumpingrate"). [RPM comment: The primary purpose of the pump testis to determine the aquifer characteristics so that modelingcan be performed and design pump rates determined. The EPAhydrogeologist will work with the Cooper's contractor tomake sure that pump rates are appropriate.]

b. As previously indicated (See Roy Leach QU4 comment #1,dated November 22, 1991), discharging pump test water intothe on-site pond could spread or worsen the contamination.However, it is indicated in your response to previous com-ments that this issue has been resolved. Please confirmthat there has been an agreement, and identify the partiesinvolved. [RPM comment: Only VOC contaminants are presentat low levels and the water will drain back into the forma-tion that it was taken from. Additionally, a spray nozzlewill be used and most of the very low levels of VOCs willstrip into the air. EPA and the state have given the re-sponsible party permission to discharge the pumped waterinto the pond.]

c. Clarify the "modified" CLP method to be used. Is itacceptable to EPA? [RPM comment: The modified method hasbeen discussed with EPA's CRL and is acceptable to EPA, butI would like additional information about the method to beincluded.]

4. Workplan, pg 4-10, para 4.2, item 3 Complete the sentence inthis item.

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5. Workplan, pg 4-14, para 4.6: Ensure that a Health and SafetyPlan is included in the Final Design documents.

6. Workplan, pg 5-2, Figure 9 (project schedule): Portions ofthe Data Evaluation activity can begin before AlternativesAnalysis is complete. This could shorten the overall schedule byseveral weeks.

*

Note: BPA does not approve health and safety plans for responsi-ble party leads. It is the responsible party's responsibility toassure that all health and safety regulations are complied with.The following comments are advisory in nature only and theultimate liability rests with the responsible party.

7. Health and Safety Plan, pg 15, para 4.2.1: All personnelentering the exclusion zone must be on a medical monitoringprogram in accordance with OSHA, in addition to "passing aphysical examination".

3. Health and Safety Plan, pg 15, para 4.2.1: All personnelentering the exclusion zone must read and sign off that theyunderstand the Health and Safety Plan, not just "receive abriefing" on it.

9. Health and Safety Plan, pg 17, Section 5.0: There are noindications of taking precautions against the site hazards. Thisplan starts with no respiratory protection (Level D), and up-grades if a hazard is detected. It is likely that the workers{and certainly the person manning the monitoring equipment) willhave been exposed to the chemical hazard before you decide toupgrade the protection using this method. Proper procedure is tostart in an appropriate level of protection against the potentialhazards (vinyl chloride, etc, as described in para 3.3 of thisplan) and then downgrade based on air monitoring.

10. Health and Safety Plan, pg 19, para 6.2: Since vinylchloride has an IP of 9.99eV, it will not have a "high response"to a Hnu with a 10.2eV lamp. A higher lamp should be used, orthe OVA.

11. Health and Safety Plan, pg 22, Section 7.0: disposal ofpersonnel decon fluids in the onsite ponds defeats the purpose oftrying to minimize the spread of contamination, as discussed incomment 3b above, these fluids should be collected, tested andproperly disposed of. [RPM comment: See response to 3a above]

12. Health and Safety Plan, pg 26, Section 9.0: Medical moni-toring and physicals must also be in accordance with OSHA regula-tions (29 CFR 1910.120.

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SUBJECT: comments to DRAFT Quality Assurance Project Plan,Remedial Design Operable Unit 4, Osborne Landfill site, GroveCity, PA, CEC Project 91187, Hay 14, 1992.1. The following comments are provided to the above subjectQAPP:

a. Section 4.3, page 21, paragraph'no. 2.Comment: If this is a USAGE project, is the Savannah Labo-

ratories and Environmental Services, Inc. a USACE validated lab?ER 1110-1-263 requires that any laboratory used on an USACE HTRWproject be validated by the USAGE for the parameters and matriceswhich will be tested for that project. [Not a USACE project]

b. Page 26, 3rd line from the bottom.Comment: The Table listed is incorrect. Change to Table 5-3.

c. Page 28, 4th line from the bottom.Comment: same as item Ib.

d. Section 5.4, page 31.Comment: The paragraph states one round of QA samples will also

be obtained during sampling at the beginning and completion of thepump test. However in the subparagraphs which follow, QA samples arenot stated for pre and post pump test sampling events. QA samples forthe pump test) should be mentioned in the subparagraphs describingTrip Blanks, Duplicates, and Field Blanks.

The last line states that no blanks or duplicates will be includ-ed with the samples collected during the pump test. However in Table5-2 on page 25, Volatile Organics is listed as one of the analyses forthe groundwater (Pump Test). If a sample will be collected forvolatile organics on the groundwater pump test, then a Trip Blank willbe required to be taken and shipped with the samples taken that dayfor that parameter.

e. Section 5.7, page 32, 1st paragraph, 2nd line.Comment: after the word recorded add "using indelible ink"

f. Section 7.1, page 36, paragraph 7.1.2Comment: Add a statement that the sample tags will be filled out

including the project name, date sampled, preservative added (if any),the parameters to be analyzed, and the name or initials of the persontaking the sample.

g. Section 9.0, page 40, 2nd line.Comment: same as item Ib.

h. Section 90, page 40.Comment: In this paragraph nor in the referenced laboratory QA

manual included in Appendix C, there is no mention of the useand completion of a Cooler Receipt Form upon receiving environmental

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samples at the laboratory. The information gathered on the coolerreceipt form will verify the condition of the samples upon receipt atthe laboratory. This information is used to assess the quality of thefield sampling, sample handling, labeling and chain of custody formaccuracy/completion, and shipping procedures.

i. Section 10.0, page 41, paragraph 10.1, 3rd line.Comment: same as item Ib.

j. Section 10.0, page 41, paragraph 10.3Comment: A listing of "Data Deliverables" is not included.

Give a detailed listing of all sample and QA/QC analytical data andresults to be included in the Report.

k. Section 11.0, page 42, paragraph 11.1, 3rd line.Comment: same as item Ib. „. -

1. Section 11.0, page 42, paragraph 11.2.Comment: Include a statement that all field analyses and mea-

surements will be recorded in permanently bound field logbooks, datedand signed by the field sampling technician.

m. Subsection 13.1, page 44, 1st bullet under the 2nd para.Comment: Include a statement that all calibrations will be

documented in the field logbook.

n. Page 45, top line.Comment: Replace the word "going" with "doing".

o. Subsection 13.2, page 45.Comment: Include a statement that all field instruments or

equipment repairs done in the field will be documented in the fieldlogbook, listing the instrument type, model, serial number, and theinitials of the person performing the repair.

p. Appendix A, Section 3.2, page 40, paragraph III.Comment: Include a.statement requiring a trip blank (40ml VOA

vial filled with high-purity distilled water) to be included in anycoolers containing samples collected for TCL volatile organic Com-pounds (VOC) analysis.

q. Appendix A, Section 3.3, page 45, paragraph II F.Comment: If a sample is to be collected for volatile organics

during the groundwater pump test (as stated in Table 5-2 of the QAPP),then a trip blank should be included with these samples. This wouldapply to samples taken for VOCs at well PW-l "before test initiation"and at "test completion" as listed in table format for sampling to beconducted at the time of the pump test (see Appendix A, section 3.3,page 44, paragraph IIA, 3rd subparagraph).

r. Appendix A, Section 3.3, page 47, paragraph V A.2.Comment: The "Sampling Data Sheet" which will have all of the

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field measurements and observations noted, should be part of (orinside) a permanently bound field logbook. All entries should berecorded in indelible ink. Ensure this is made clear to the fieldsampling technicians and in the procedures.

s. Appendix A, Section 3.3, page 47, paragraph VII.Comment: The bailer or any other equipment coming in contact

with the sample should be made of stainless steel, teflon, or someother non-reactive type of material.

t. Appendix A, Section 3.3, page 47, paragraph VII.Comment: Include as part of the supplies list: sampling bot-

tles, sample tags/labels, zip-lock plastic bags, acid and/or basepreservatives.

u. Appendix A, Section 3.4, page 51, paragraph III., No 10.Comment: Add the word "barrel" before the word filter and add

the words "and components" after the word filter.

PAPER

1. Paces 3-5. 3-6. and 3-7; Figures 4, 5 and 6: When constructingflow nets, the equipotential lines and flow lines should form an areaof nearly equal length and width (see attachment). This constructionprincipal was not strictly adhered to for the construction of the flownets in these figures. These flow nets form the basis for CEC'sconclusions concerning the hydrogeologic relationship between theClarion Sandstone and the mine void.

2. Page 3-8; Equation for shallow cone of depression in Figure 6;This equation is apparently incorrect. This flow net has two (2)complete flow tubes drawing from the mine void. The first number inthe numerator should be 2, not 1. The radius of influence at the minevoid is larger than the radius of influence at the water table.

3. Page 4-3; Figure 7; Figure 7 is missing from the document.

4. Page 4-10; Item 3y Incomplete sentence.

Hydrogeologist's Comments on Work Plan4.1.5 Aquifer Testing

1. The suggested use of slug tests and analytical models is not appro-priate for designing the pump test. Step drawdown tests are moreappropriate for determination of the parameters for the long-term pumptest.

EPA discussed this comment with CEC and Cooper Industries and thesuggestion was made by CEC that they could obtain the needed datafor the pump test during well development. EPA's hydrogeologist

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has considered this proposal, but does not believe that this willbe adequate and EPA must insist on a step drawdown test toproperly determine the correct rate.

2. Information from the long term pump test, as well as sampling data,should be input into some tupe of capture zone analysis or particletracking model for design of the extraction system. A flow andtransport model will not aid in system design; a capture zone analysiswill. Specific models that will be used'should be discussed.3. For treatment purposes, it may be a good idea to take severalsamples during the course of the pump test. [RPM comment: EPA dis-cussed this with Cooper Industries in the recent conference call. Theinformation would help confirm whether infiltration is occuring andEPA strongly recommends that a sample be taken near the middle of thepump test and analyzed for VOCs.]

4. Borehole Dilution Test and Pump Test - The hydrogeologist isconcerned that 12 hour sampling intervals may not be adequate for thetracer test, especially since the borehole dilution test initiallyrequires 10-min sampling intervals. The hydrogeologist is alsoconfused about the procedures to be used and has noted that there issome inconsistency between the QAPP and the Work Plan, (one reportstates 2 hour intervals)

5. Observation wells should be placed along dip and strike at logritW'hmic distances from the pumping well. Please explain whether thewells will be placed at logrithmic intervals and explain the rationalefor the well locations.CRL Comments on QAPPI have attached the all of the comments from EPA's CRL to this docu-ment.

I will not be available between July 17 through July 31. Ifthere are any questions regarding the comments, I encourage you todiscuss them with the following individuals. If the problem cannot besolved or if it involves RCRA comments, I will resolve the issue aftermy return.

Army Corps of Engineers: Gary Poling 301-962-4500

Hydrogeologist: Mindy Snoparsky 215-597-0676

CRL: Hike Ellickson 301-573-2703

PADER: John O'Hara 814-332-6070

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8

Sincerely,

, f —• *r —— <M w — f

Fp&.nk Vavra, Remedial Project ManagerWestern PA Section

Attachment

cc. Jeff PikeKindy Snoparsky (3HW15)C.K. Lee (3HW51)Gary Poling (ACE)John O'Hara (PADER)

4K306306

U>OTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION m

CENTRAL REGIONAL LABORATORY839BESTGATE ROAD

ANNAPOLIS, MARYLAND 21401- 3013(410)573-2799

DATE : June 19, 1992

SUBJECT : Draft QAPjP for Osborne LF Site (FY92170)

FROM : Hike Ellickson, Env. SettProgram Support Section^ (3ES32)

TO : Frank Vavra, RPMWestern PA Section (3HW23)

THRU : Cynthia Metzger. ChiefProgram Support Section (3ES32)

The Draft Quality Assurance Project Plan (QAPjP) for the Osborne Landfill,dated Hay 14, 1992 vas reviewed for compliance with QAMS 005/80 andtechnical adequacy. In general it vas veil vritten and most of the requiredelements vere present. Conditional approval is therefore given. However,before sampling begins the following items should be addressed.

1. The Flan states that the CLP 2/88 Statement of Vork (SOU) for volatilesvill be modified vith a five-fold increase in sample volume to lower thedetection limits for Target Compound List (TCL) volatiles. As explainedon page 4 of the attached checklist, OLC02.0 is the current SOW for CLPvolatiles and should be used as the reference rather than the 2/88 SOW.Also, Table 5-4 does not include all of the volatile analytes in the currentTCL.

2. Procedures for approved changes in the QAPjP should be included. Afterthe Plan is approved and sampling starts, it is very probable that thetimetable and other parts of the Project Plan vill need revisions becauseof weather-delayed sampling, etc. Refer to page 16 of the attachedchecklist.

To gain full approval, all of the other discrepancies in the attachedchecklist must also be addressed.

If you have any questions, please call me at FTS (410) S73-2707.

Attachment

Excellence and Purpose in Action --- Environmental Services DivisionAR306307

Environmental Protection Agency Revision No.: 4Region III Date: 1/3/91

Page: 1 of 16

Quality Assurance Project Plan Review

Site Name: Osbome Landfill Account No.: TGB03N638Document Trtlefs): Draft Remedial Design Document Number: FY92170Requester Name: Frank Varva Mail Code: 3HW23Title: RPM Phone No.: J21.5) 597-0676

Plan Prepared by: Civil and Evnironmental Consultants, Inc.

Date Received: June 5,1992 Date Review Requested By:

Program: ,,X..CERCLA .....REMOVAL .....Fund-Lead.....Other (Specify) ..X.REMediaf .JC..ENF-Lead

.....SI .....State-LeadSummary y N

Does Plan provide sufficient documentation -enough information so reviewer (and others)

- knows what will be done, by whom, etc.? ..... Almost .....Has document been correctly applied (comply withapplicable regulation or guidance)? ..... Almost .....

Does document accomplish what ft is supposed to? ..... Almost .....Major Deficiencies were found in the following elements:

...Title page JCQA Objectives ...Analytical Proc. ...Prev. Main.

...Table of Contents .XSampfing Proc. .XData Reduction ...Data SOPs

...Project Descrip. ...Sample Custody ...Internal QC Ck. ...Corr. Action

.X.Org. and Resp. ...Cafib. Proced. ...Audits .X.QA Reporting

See the attached for discussion of comments relative to all elements.

Conclusion/Recommendation: QA Reviewer: Mike EllicksonApproval .......Resubmissfon .......Conditional ...X... Date Review Complete: June 19,1992

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Section: I & IIRevision No.: 4Date: 1/3/91Page: 2 of 16

Identification

I) Title page • IA IU Nl NADoes page include:1 - Title of project? ...X.. ...... ...... ......2 - Name(s) of principal investigators

and affiliates shown? ...X.. ...... ...... ......3 - Appropn'ate approval lines at bottom? ...X.. ...... ...... ......4 • Plan prepared in document control format? ...X.. ...... ...... ......

II) Table of Contents •• ~Does Table include:1 - List of all Plan required elements and

appropriate page numbers? ...X.. ...... ...... ......2 - Include distribution list? ...X. ...... ...... ......3 - Include list of Appendices? ...X. ...... ...... ......

Not*: IA »Included ft Acceptable -*IU • Included I UnacceptableNl • Not IncludedNA • No« Applicable

Comments:

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Section: IIIRevision No.: 4Date: 1/3/91Page: 3 of 16

III) Project DescriptionIA IU Nl NA

Are the following addressed (or referenced),consistently presented, technically correct?

1 - Statement of general objectives (purpose)? ..X, ...... ......2 - Dates for start and completion of project and

sampling activities (schedule)? ...... ...... ..(1).3 - Overview of project's scope (activities)? ...X.. ...... ......4 • Specific objectives for this phase of work? ...X..5 - Background information? ...X..

5a - Description of site? ...X..5b - Site History (operational, legal, remedial efforts)? ...X..

6 - Brief statement of intended data uses? ...X.. ...... ......*7 - Description of sampling network design

and rationale? ...X........ ......7a • Design of overall monitoring systems? ...X.. ...... ......7b • Specific location of sampling sites? ...X.. ...... ......7c - Justification of overall design? ...X.. ...... ......

*8 • Sample matrices? ...X.. ...... ......*9 - Sample locations? ...X.. ...... ......MO - Parameters to be measured? ...X........ ......*11 - Frequency of collection? . ...... ..*... ..(2).*12 • Reld and lab measurements? ...X..13 - Procedures for groundwater sample

preparation, or other similarfractions/sub-groups specified andincluded in parameter definition? ...X..

14 - Type of sample(s) (grab, composite, etc.)? ..JC..15 - Are data needs relative to data uses addressed?

(Will the data answer specific objectives?) ...X.. ...... ...... ......

'Depending on the Program and/or project, information related to samplingmay be discussed under Project Description (Section 111) or Sampling Procedures(Section VI) in the QAPjP or in a separate Field Sampling Plan -the questions-apply regardlessof format.Comments: .(1) Dates for start and completion should be Included before sampling begins.(2) It is assumed this is a one-time sampling event? •

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Section: IVRevision No.: 4Date: 1/3/91Page: 4 of 16

IV) Project OrganizationIA IU Nl NA

1 - Does the Plan identify key peopleresponsible for

1a - Overall QA/QC? ...X..1b-Sampling operations and sampling QC? ...X..1c - Laboratory analyses and laboratory QC? ...... ..(1)....... ......1d - Data processing and data processing QC? ...X. ...... ...... ......1e • Data review oversight? ...... ..(2)....... ......1f - Performance and System Audits? ...X.. ...... ...... ......

(Lab and Field)2 - Does the QAPjP define who performs:2a - Data review? ...X.. ...... ...... ......2b • Review and confirmation of any tentatively

identified organic compounds? ...... ...... ..(3). ......2c - if CLP, preparation and final review of SAS

requests? ...... ...... ...... ...X.3 - Are phone numbers and addresses included? ...... ...... ...X. ......4 - Is line authority for all referenced

organizations explained or demonstratedby including an organizational chart(s)? ...X. ...... ...... ......

4a • Are contractors and subcontractors includedin organizational chart? ...X. ...... ...... ......

5 - Are personnel qualifications included?Training? Experience? Resumes? ...X. ......

6 - Is the organizational structure appropriateto accomplish the QA objectives of the project? ...X. ......

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Comments:(1) Ran ttatMVOCtnalymwilb* "modified 2/83 CtPprocwtaw* and n Refer to.OLC 02.0 » correct the

list of volatile* In Table 5-4. Some of the detection Itmttsgfven are tower than the proposed standards that are to be used. Please explainthis. The OA/OCfbr the non-CLP analyses should be In accordance with Region IB SAS procedures.

§0ata oversight (final approval) should be addressed.Are DCs going to be reviewed and confirmed?

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Section: Vv j Revision No.: 4

Date: 1/3/91Page: 5 of 16

V) QA Objectives (DQOs)IA IU Nl MA

1 - Is there a statement of intended data usage?. ...X..2 - Are the terms and definitions for precision,

accuracy, representativeness, comparability,and completeness property used andexpressed (i.e., QA/QC concepts and theoriesare understood and properly implemented andfollowed throughout the plan)? ...X..

3 • Are Data Quality Objectives (DQOs)quantitatively stated for precision andaccuracy (bias)? ...X..3a • Have the following been defined for

each matrix and parameter?1)Level of QA effort (frequency of QC, etc.)? -..X..2)Accuracy (matrix spikes, surrogate spikes,reference samples, etc.)? ..X.3)Precision (replicate samples)? ..X.

t 4)Sensitivity or MDL? ...... ..(1). ......SJStatistical reporting units? ...X.

3b - Are quantitative limits established for each? ...... ..(1).......3c - Are field and lab both covered? ...... ...... ......3d - Are QA objectives presented in a table format? ..X.3e - Is it clear that a distinction has been

defined for total" system variability andbias and not just looking at the laboratory? ...X..

3f - Are objectives/requirements property expressed(e.g., not confused with capabilities)? ...X,.

4 - If appropriate, are completeness objectivesquantitatively stated? ...X..

5 - Are representativeness and comparabilityappropriately addressed? ..X.

6 - Are the interrelationships (and differences)between study design (number of samples needed),analyticaf procedures, internal QC, and dataassessment reflected in the DQOs? ..X.

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Comments: .(1) See Comment # 1 on page 4 of this checklist

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Section: VI -Revision No.: 4Data: 1/3/91Page: 6 of 16

VI) Sampling Procedures(See also Section III)

IA IU Nl NA*

1 - Does the Plan:1a - Provide specific guidance for all field work? ...X. ...... ...... ......1b - Provide a mechanism for planning and

approving site activities? ...X.. ...... ...... ......1c - Ensure that sampling activities are limited to

those that are necessary and sufficient? ...X. ...... ...... ......1d • Provide a common point of reference for all

parties to ensure comparability andcompatibility between all activities performed

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2 - Are the following elements included?2a • Investigation objectives? ...X. ......2b • Site background? ...X. ......2c - Analysis of existing data? ...X.. ......2e - AnaJytes of Interest? ...X. ......2f - Sample types? ...X. ......2g - Map of locations to be sampled? ...X. ......2h - Sample locations and frequency? ...X. ......2i - Technique or guideline used to select sites? ...X. ...... ......2j - Specific sample collection methods? ...X.. ...... ......2k - Description of sampling devices? ...X. ......21 - Containers (type and source)? ...X. ......2m -Preservatives (type and source)? ...X.......2n • Procedures for preservation? ...X.. ......2o - Holding times? ...X. ......2p - Reagents (type and source)? ...X. ......2q • Transport and storage? .. JC. ......2r - Preparation of sampling equipment (before

and during sampling) and containers? ...X. ......2s - Blanks? ...X. ......2t - Filtering procedures, if applicable? ...... ..(1). ...... ......2u • Record-keeping requirements? ...X. ...... .'..... ......2v • Coordination with laboratory? ...... ...... .. .X. ......

Comments:(1) Filtering procedures are included and the Plan states all metal samples win be filtered. Reasons should be given for not taking unflltered

(total metal) samples along with filtered samples. Refer to Region III GAD 009. , i

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Section: VIIRevision No.: 4Date: 1/3/91Page: 7 of 16

VII) Sample CustodyIA IU Nl NA

1 - Sample Collection: Does the plan address:1a • Reld custody procedures? • ...X..

1)Transfer of custody and shipment? ...X..2)Receipt of samples? ...... ...... ..(1). ......3)Lab custody procedures? ...... ...... ..(1).......

1b - Does Plan include examples of forms, tags,labels, records, etc.? ...X..

1c - Does Plan address evidentiaryconsiderations? ..JC.

2 - Do field documentation procedures:2a - Document source of reagents or supplies? ...... ...... ...X.. ......2b - Include procedures/forms for recording the

exact location and specific considerationsassociated with sample acquisition? ...X..

2c - Document specific preservation method? ...X..2d - Include labels containing all necessary

information? ...X.. ...... ...... ......2e - Include form to track custody? ...X........ ...... ......

3 - Do lab custody procedures:3a • Identify Sample custodian? ...... ...... ..(1).......3b • Provide for custody record within the lab? ...... ...... ..(1).......

. 3c - Specify procedures for sample handling,storage, dispersement for analysis, anddisposal? ...... ...... ..(1).......

4-'Does the Plan address final evidence files? ...... ...... ..(2).......

Comments:(1) Laboratory custody prootdurn an not addrtwd.(2) Explain wt»r» final •vfdtnc* fife* wfll bt tocattd.

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Section: VIIIRevision No.: 4Date: 1/3/91Page: 8 of 18

VIII) Calibration Procedures and FrequencyIA IU Nf NA

1 - For the Fieldla • Does Plan include methods/procedures to

assure field equipment are functioningoptimally? ...X....... ...... ......

1 b • Is schedule/frequency of above included? .. JC.1c - Are equipment logbooks required to record

usage, maintenance, calibration, and repair? ...X......1d • Does Plan include calibration standards

or reagents to be used, their source andtraceability procedures? ..JC. .....'.

1a - ooes Plan include documentationrequirements for calibration:1)Date(s) of calibration? ..JC.......2)ldentification of standards used? ...X.......3)Personnel performing calibration? ...X. ......4)Results of calibration (raw data andsummary statistics)? ...X.......

5)Corrective actions taken? ...X. _.2 - Laboratory2a - Does Plan include methods/procedures

to assure lab equipment are functioningoptimally? ..JC.......

2b • Is schedule/frequency of above Included? .. JC. ......2c - Are equipment logbooks required to record

usage, maintenance, calibration, and repair? ...X. ......2d • Does Plan include calibration standards

to.be used, their source and traceabilityprocedures? ...X. ......

2e - Does Plan include calibrationdocumentation requirements:1)Date(s) of calibration? ...X.......2)Identiffcation of standards used? ...X. ......3)Personnel performing calibration? ...X. ......4)Results of calibration (raw data andsummary statistics)? ...X.. ...... ...... ......

SJCorrective actions taken? ...... ...... ...... ......2f.- Are calibration procedures applicable to analytical

methods chosen? -JL ...... ...... ......2g • Are ail analytes included in calibration

oicUiQcuQ3r •••*\*» **•••• *«••** •••••* —*sComments:

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•••••• •••*••

•'£'•'$• Section: IX. Revision No.: 4

Date: 1/3/91Page: 9 of 16

IX) Analytical ProceduresIA IU Nl NA

1 - Are all analytical procedures documentedor written as SOPs and included in full *or by reference for all parameters? ...X.. ...... ...... ......

1a • Are all procedural steps and optionsdescribed? ...... ...... ...X.. ......

2 - Are the criteria of method selectionincluded (e.g., in order to obtaina particular DQO)? ...X. ......

3 -.If method choice is governed byregulatory requirement (e.g., NPDES,SDWA, RCRA), have the appropriatemethods been chosen? ...X.. ......

4 - Are the following included?4a • Designated laboratory name? ...X.. ......4b - Description of laboratory facilities? ...X.. ......4c - Description of laboratory equipment and

supplies? ...X.. ......4d • Laboratory credentials? ...X.. ......

5 • Do the methods include specificQC requirements (type, frequency,acceptance, etc.)? ...X.. ...... ...... ......

6 - Are the analytical procedures approved,or equivalent to EPA procedures? ,.X. ...... ...... ......

7 - Are analytical costs included? ...... ...... ...... ...X..7a - Are costs reasonable to meet objectives? ...... ...... ...... ...X..

Comments:

••* *•••

AR30631-6

Section: XRevision No.: 4Date: 1/3/91Page: 10 of 16

X) Data Reduction, Validation, and ReportingIA IU Nl NA

Reduction1 - Are units specified for all determinations? ...X.. ...... ...... ......2 - Are equations/procedures used to calculate

concentrations included or referenced? ...X.. ...... ...... ......3 - Are the types of records to be maintained

described, including how and where stored? ...... ...... ..(1). ......4 - Are procedures included for transfer of data

to forms, reports, etc.? ...X.. ...... ...... ......5 - Are procedures for proofing (transcription -• -

errors) and cross-calculation checks included? ...... ...... ...X. ......6 - Are procedures for handling blank results

described? ...... ...... ...X.. ......

Validation1 - Are functions and scope specifically defined? ...X.. ...... ...... ...... ,2 • Are techniques presented and summarized? ...X. ...... ...... ......3 - Are criteria used to accept or reject data

described in a uniform and consistent manner? ..(2)....... ...... ......(See also Section XI)

4 - If CLP, does the Plan include provision for datareview using the functional guidelines andqualified review personnel, etc.? ...... ...... ...... ...X.

Reporting1 - Is the flow or reporting scheme from

collection of raw data through documentstorage included? ...X. ...... ...... ......

2 - Are requirements for recordkeeping infield and lab notebooks described? ...X. ...... ......

3 - Are the key individuals who willhandle or report data identified? ...X.. ...... ......

4 - Are examples of forms and reports included? ...X. ...... ......5 - Does the Plan describe exactly

what will be reported (e.g., QCresults, etc.)? ...X. ...... ......

Comments:(1) See Comment @2onpage T of the checklist,(2) Tabti 5-3 for precision, accuracy and completeness has analytical QA objectives that may be hard to achieve. (TDS, TSS, TOO, etc.).

Refer to Region IK SAS requirements for QA/QC that Is currently being used for the above analyses.

AR3063I7

-TCrjV Section: XIIRevision No.: 4Date: 1/3/91Page: 12 of 16

XII) Performance and System AuditsIA IU Ml NA

1 - Are audits addressed: .1a - For field activities (sample collection,

Cul3iy56Sj Giw*y* ««»/\«* *••••• •*•••• •••••1b - For lab activities? ...X........ ...... .....

2 - Does the Plan identify who willconduct the audits(s)

2a - for field activities? ...X.. ............ .....2b - for lab activities? ...X........ ...... .....

3 - Does the Plan describe whatprotocol will be used for -. -audits?

3a • for field activities? ...X.. ...... ...... .....3b - for lab activities? ...X.. ...... ...... .....

4 - Are acceptance criteria defined?4a - for field activities? ...X........ ...... .....4b - for lab activities? ...X.. ...... ...... .....

5 - Does the Plan describe distributionof audit reports? ...... ...... ...X.. .....

6 - Is a schedule of audits included? ...... ...... ...X.. .....7 - Are quality control samples scheduled? ...... ...... ...... .....

Comments:

AR3063I8

Section: XIRevision No.: 4Date: 1/3/91Page: 11 of 16

XI) Internal QC ChecksIA IU Nl NA

1 - Does Plan describe procedures for both fieldand lab? - ...X.. ...... ...... ......

2 - Are the protocols used (spikes, surrogates,blanks, etc.) described for each parameter andmatrix? ...X.. ...... ...... ......

3 - Are field and lab acceptance or control limitsspecified for each? ...X.. ...... ...... ......

4 • Is the frequency of the checks described? ...... ...... ...X.. ......5 - Is the system measuring total error/variability

and not just sampling/lab error/variability? ...X.. ...:::'...... ......6 - Are the procedures described for internal QC

checks consistent with the procedures usedto assess precision and accuracy (SectionXIV)? ...X.. ...... ...... ......

Comments:

HR3063I9

Section: XIIIRevision No.: 4Date: 1/3/91Page: 13 of 16

XIII) Preventive MaintenanceIA IU Nl NA

1 - Does the Plan include a maintenanceschedule to minimize downtime?1a-For the Reld activities? ...X........ ...... ......1b-For the Lab activities? ...X........ ...... ......

Comments:

2 - Is a spare parts list available? ...X.. ...... ......3 - Is a source of spare parts identified? ...X.. ...... ......4 - Is the source of repair described? - ...... ...-.-.. • ...X..

AR30632CL

Section: XIVRevision No.: 4Date: 1/3/91Page: 14 of 16

XIV) Specific SOPs Used to Assess DataPrecision, Accuracy, Representativenessand Completeness

IA IU Nl NA

1 - Relative to the objectives in Section V,does the Plan include protocols formonitoring whether requirements were met? ...X.. ...... ...... ......

2 - Does the Plan include the equations usedto calculate precision, accuracy (bias),and completeness? ...X.. ....•«.

3 - Does the Plan describe the methods usedto gather information for precisionand accuracy (bias) calculations? ...X.. ......

4 - Are statistical procedures useddocumented?

Comments:

AR30632I

Section: XVRevision No.: 4Date: 1/3/91Page: 15 of 16

XV) Corrective Action for Out-of-ControlSituations

IA IU Nl NA

1 • Does the Plan include a scheme to:1a-Identifydefects? ...X........ ...... ......1b - Trace defects to source? ...X.. ...... ...... ......1c-Plan and implement correction? ............ ...X. ......1d-Document results of process? ...X........ ...... ......1e • Document where documents are kept? ...... ...... ...X.. ......

2 - Does the Plan include predeterminedlimits for data acceptability beyondwhich corrective action is required? ...X........ ...... ......

Comments:

3 - Are procedures for corrective action(who initiates, who approves) included? ...... ...... ...X.. ......

4 - Is feedback from performance audits (laband field) addressed? ...... ...... ...X.........

RR306322

Section: XVIRevision No.: 4Date: 1/3/91Page: 18 of 18

XVI) QA Reporting Procedures to Management(A IU Nl NA

1 - Does the Plan specify the type andfrequency of reporting? ...X....... ...... ......

2- Do the reports address:2a • Status of project (time table)? ...... ...... ..(1).......2b - Results of performance and system audits? ...X....... ...... ......2c - Data quality assessment? ...X. ...... ...... ..\...2d - Significant QA problems and proposed

corrective action? ...... .....-.--.2).......2e • Changes in the QAPjP? ...... ...... ..(2). /.....

3 - Final Summary Report and distribution? ...... ...... ..(3).......3a - Final storage and security of data files? ...... ...... ..(3).......

Comments:(1) SMCommtnt 01 on pag* 3 of ftis checklist(2) Provision* for approved changn in this Ban should b» txplalntd along with corrections for tlgnfflcantQA prebtena.(3) Se« Comment #2 on pagt 7 of tn« checklist

AR306323