February 28, 2017 Mr. Hugo Martinez-Cazon Vermont ...

160 East Main Street, Suite 2F, Westborough, MA 01581 – T 508.366.7442 – F 508.366.7445 – www.komangs.com

February 28, 2017 Mr. Hugo Martinez-Cazon Project Manager Vermont Department of Environmental Conservation 1 National Life Drive – Davis 1 Montpelier, Vermont 05620-3704 Re: Draft Remedial Action Work Plans

FUDS Property D01VT0363 01 Former Lyndonville Air Force Station East Haven, Vermont

Debris Area: VT SMS #91-1152 Cantonment Area: VT SMS #2009-3914

Dear Mr. Martinez-Cazon:

On behalf of the U.S. Army Corps of Engineers (USACE), KOMAN Government Solutions, LLC (KGS) and Stone Environmental, Inc. (Stone) are pleased to present one (1) copy of the enclosed Draft Remedial Action Work Plan (RAWP) including the Contractor Quality Control Plan (CQCP), Quality Assurance Project Plan (UFP-QAPP), and Field Sampling Plan (FSP) for the Former Lyndonville Air Force Station, located in East Haven, Vermont. An electronic copy of the document is included on an attached compact disk. We respectfully request your review by March 24th, 2017.

We look forward to working you with you on this project. Please feel free to contact us at 508-366-7442 or Marie Wojtas (USACE Project Manager) at 978-318-8788 with any questions or comments.

Sincerely yours,

Gregory Birch, PMP® Senior Project Manager Quality Control Manager

cc: Marie Wojtas (CENAE)

Enclosure

DRAFT REMEDIAL ACTION WORK PLAN

FOR REMEDIAL ACTION AND PROJECT CLOSEOUT ACTIVITIES

AT LYNDONVILLE FORMER AIR FORCE STATION

EAST HAVEN, VERMONT

CONTRACT NUMBER: W912WJ-16-C-0020

DELIVERY ORDER NUMBER: N/A

Prepared For:

DEPARTMENT OF THE ARMY CORPS OF ENGINEERS

NEW ENGLAND DISTRICT

696 Virginia Road Concord, MA 01742

Prepared By

160 East Main Street, Suite 2F Westborough, MA 01581

FEBRUARY 2017

Draft Remedial Action Work Plan Lyndonville Former Air Force Station

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By their signature, the following individuals certify their review and approval of this Remedial Action Work Plan for the Remedial Action and Project Closeout Activities at the Lyndonville Former Air Force Station, East Haven, Vermont.

Signature Date

27 FEB 2017

Mr. Edward M. King, PE Program Manager

27 FEB 2017

Gregory Birch, PMP® Project Manager Quality Control Manager


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TABLE OF CONTENTS

Section Page No.

1.0 INTRODUCTION......................................................................................................................... 1

1.1 Project Objectives ........................................................................................................................... 2 1.2 Site Information .............................................................................................................................. 3

2.0 PREVIOUS REPORTS / INVESTIGATIONS .......................................................................... 5

3.0 PRE-DESIGN AND CONFIRMATION SAMPLING AND ANALYSIS ............................... 7

4.0 PROPOSAL TO COMPLETE ALL REQUIREMENTS ......................................................... 8

5.0 APPLICABLE REMEDIATION STANDARDS ....................................................................... 9

6.0 REMEDIAL ACTIONS ............................................................................................................. 10

6.1 Organization and Responsibilities ................................................................................................ 10 Organizational Structure and Staffing ................................................................................... 10 6.1.1 Subcontractors and Suppliers ................................................................................................ 10 6.1.2

6.2 WORK AREA CONSTRAINTS .................................................................................................. 11 Underground Utilities ............................................................................................................ 11 6.2.1 Site Access .............................................................................................................................. 11 6.2.2

6.3 PROJECT EXECUTION .............................................................................................................. 12 Project Management and Administration .............................................................................. 12 6.3.1 Plans and Submittals .............................................................................................................. 12 6.3.2 Construction Tasks ................................................................................................................. 13 6.3.3

TABLE 2 ................................................................................................................................................ 18

7.0 REMEDIAL ACTION AREAS ................................................................................................. 20

8.0 QUALITY ASSURANCE PROGRAM .................................................................................... 21

8.1 Scope and Complexity .................................................................................................................. 21 8.2 Data Quality Objectives ................................................................................................................ 21 8.3 Laboratory Information ................................................................................................................. 21 8.4 Project Contact Information for Sampling and Analysis Activities ............................................. 21 8.5 Analytical Methods/Quality Assurance ........................................................................................ 22 8.6 Site Specific Sampling Methods ................................................................................................... 22 8.7 Chemistry Electronic Data Deliverables ....................................................................................... 22

9.0 REQUIRED PERMITS / ACTIONS ........................................................................................ 23

10.0 SOIL AND SEDIMENT EROSION CONTROL AND MONITORING .............................. 24

11.0 SITE SPECIFIC HEALTH AND SAFETY PLAN ................................................................. 25

12.0 SITE RESTORATION PLAN ................................................................................................... 26

13.0 PROPOSED COMPLETION DATE AND PROJECT SCHEDULE .................................... 27


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FIGURES

Figure 1 Site Location Figure 2 Debris Area Map Figure 3 Pre-Design Investigation Units Figure 4 Cantonment Area Map – Well Locations for Decommissioning ATTACHMENTS

Attachment A Organizational Structure Attachment B Contractor Quality Control Plan Attachment C Quality Assurance Project Plan Attachment D Field Sampling Plan Attachment E Project Schedule


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LIST OF ACRONYMS ADR Automated Data Review ANSI American National Standards Institute AOCs Areas of Concern APP Accident Prevention Plan bgs below ground surface CENAE US Army Corps of Engineers – New England District CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CIH Certified Industrial Hygienist COC Chain-of-Custody COR Contracting Officer Representative CR Closeout Report CQC Contractor Quality Control CQCP Contractor Quality Control Plan CQCSM Contractor Quality Control Systems Manager CQM Construction Quality Management CSHP Corporate Safety and Health Program DD Decision Document DERP Defense Environmental Restoration Program DFW Definable Features of Work DOD Department of Defense DU Decision Unit E&S Erosion and Sediment EM Engineer Manual EPA Environmental Protection Agency ER Engineer Regulation FS Feasibility Study FUDS Formerly Used Defense Site FUDSCHEM Formerly Used Defense Site Chemistry Database IDW Investigation-Derived Waste ISM Incremental Sampling Methodology ITRC Interstate Technology Regulatory Council JCO The Johnson Company KGS Koman Government Solutions LLC KO Contracting Officer LFAFS Lyndonville Former Air Force Station mg/kg milligram per kilogram MS matrix spike MSD matrix spike duplicate NCP National Contingency Plan No. number OSHA Occupational Safety and Health Administration PCB poly-chlorinated biphenyls P.E. Professional Engineer


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PM Project Manager PGM Program Manager PMP Project Management Professional POC Point of Contact PP Proposed Plan PPE personal protective equipment PWS Performance Work Statement QAPP Quality Assurance Project Plan QA/QC quality assurance/quality control QCM Quality Control Manager QCS Quality Control System QSM Quality System Manual RAO Remedial Action Objective RAWP Remedial Action Work Plan RCRA Resource Conservation and Recovery Act RG Remedial Goal RI Remedial Investigation RSL Regional Screening Level SAP Sampling and Analysis Plan SARA Superfund Amendments and Reauthorization Act SEDD Staged Electronic Data Deliverable SHM Safety and Health Manager SMAC Site Management Activity Completed SMS Sites Management Section (Vermont) SOW Statement of Work SS Site Superintendent SSHO Site Safety and Health Officer SSHP Site Safety and Health Plan TBD to be determined T&D Transportation and Disposal TP Test Pit USACE U.S. Army Corp of Engineers USEPA U.S. Environmental Protection Agency VTDEC Vermont Department of Environmental Conservation WP work plan


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1.0 INTRODUCTION

Koman Government Solutions LLC (KGS) has prepared this Remedial Action Work Plan (WP) for the U.S. Army Corps of Engineers, New England District (USACE) under Contract Number (No.) W912WJ-16-C-0020. The overall intent of this work is to complete remediation activities at the Lyndonville Former Air Force Station (LFAFS).

This WP describes the means, methods, and procedures required to complete remediation activities, including a pre-design investigation, site set-up, vegetation clearance, soil excavation, confirmation sampling, waste characterization / transportation & disposal and site restoration at Lyndonville Former Air Force Station (Figure 1).

This WP is based on the following documents/regulations:

The Performance Work Statement (PWS) prepared by USACE entitled Remedial Action and Project Closeout Activities at Lyndonville Former Air Force Station, East Haven, VT, dated 26 May 2016 (revised 11 August 2016).

Department of the Army, 2000. Field Manual No. 5-434, Earthmoving Operations. Headquarters, Washington, DC. June 2000.

DoD Environmental Data Quality Workshop, 2013. Department of Defense Quality Systems Manual For Environmental Laboratories version 5.0.

Vermont Standards & Specifications for Erosion Prevention and Sediment Control dated 2006.

The Johnson Company, Inc. (JCO), 2013. Final Remedial Investigation Report, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. January 2013.

Stone Environmental, Inc. (Stone), 2014. Feasibility Study, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. November 2014.

Stone, 2015. Proposed Plan, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. June 11.

Stone & Webster (1995, 1997, 2001), Clean Harbors (1991) and Coastal Environmental (2001).

Stone, 2016. Final Decision Document, Lyndonville Former Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. September.

Interstate Technology Regulatory Council’s (ITRC) ISM Technical and Regulatory Guidance Document, (ITRC, 2012),

USACE, 1997. Engineering Manual (EM) 200-1-6, Chemical Quality Assurance for HTRW Projects, October 10.

USACE 1998. USACE EM 1110-1-4000, Monitoring Well Design, Installation and Documentation at Hazardous, Toxic and Radioactive Waste Sites, November 1.

USACE, 1998. Engineer Regulation (ER) ER 1110-1-263, Chemical Data Quality Management for Hazardous, Toxic, Radioactive Waste Remedial Activities, dated 30 April 1998.


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USACE, 2001a. EM 200-1-3 Requirements for the Preparation of Sampling and Analysis Plans.

USACE, 2003a. Engineer Manual (EM) 1110-1-4007 Safety and Health Aspects of Hazardous, Toxic, and Radioactive Waste Remediation Technologies.

USACE, 2003b. EM 385-1-1 Safety and Health Requirements Manual.

USACE, 2004. ER 200-3-1, Formerly Used Defense Sites Program Policy.

This WP includes the tasks identified in the PWS as well as those required to remove the affected soil and to restore the site. KGS will maintain and update this WP as necessary during the course of work, based on the need to do so, or at the direction of the Contracting Officer (KO) or authorized representative. This document is applicable to services performed by KGS as the prime contractor as well as any subcontractors under KGS’ control.

1.1 Project Objectives

Based on the PWS, the intent is to successfully complete all performance objectives shown in Table 1. The Contractor will furnish all labor, materials and equipment necessary to successfully complete all performance objectives identified in this PWS and Table 1, Performance Requirements Summary. Achievement of the performance objectives is successfully attained upon the finalization of appropriate documentation certifying that the documents have been accepted by the CENAE and coordination with VT DEC. CENAE approval of the Performance Standards will be by the CENAE KO or Contracting Officer’s Representative (COR). In the event that there may be multiple milestones and/or deliverables for each of the performance objective tasks, partial payments will be based on the successful completion of milestones. Final decisions regarding the adequacy of milestone and deliverable completion, and acceptance and approval of necessary site (s) investigation and/or remediation documentation resides with the KO or COR. Interactions with non-federal regulators will be consistent with CERCLA, the NCP, DERP, and FUDS and the VT DEC regulations.

Table 1 – Performance Requirements SummaryPerformance Objective/Task Performance Standard

Task 1- Project Management/Status Reports Submittal of status reports.Task 2.1 – Preparation Project Work Plan USACE acceptance of Final Work Plan. Task 2.2 – Preparation of Accident Prevention Plan (APP) and Site Safety and Health Plan (SSHP)

USACE acceptance of APP/SSHP.

Task 2.3 – Preparation of Sampling and Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP)

USACE acceptance of SAP/QAPP.

Task 3 – Project Meetings Support to USACE for meetings with local stakeholders (VT DEC and public).


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Task 4 – Soil Remediation – Debris Area AOC 1 PCB-Impacted Soils

Pre-Design Investigation/Work Plans (RAWP)/Reporting

Site Set-Up Soil Excavation Confirmation Sampling Waste Characterization/T&D Site Restoration

USACE and VT DEC acceptance of soil remediation activities and documentation. Review of available sample data, including pre- design sampling to confirm horizontal and vertical extents of Debris Area AOC 1 soil excavation. USACE and VT DEC acceptance of limits of excavation. USACE and VT DEC acceptance of Final RAWP. Completion of soil excavation activities, backfill, and site restoration per PWS and RAWP in accordance with USACE and VT DEC regulations. Daily summaries provided to USACE.

Task 5 – Monitoring Well Decommissioning Completion of monitoring well decommissioning (LY-01 and LY-02) and documentation in accordance with USACE and VT DEC regulations.

Task 5A (Optional) – Water Supply Well Decommissioning

Completion of water supply well decommissioning (Water Supply Well-A, Water Supply Well-B, and Water Supply Well-C) and documentation in accordance with USACE and VT DEC regulations

Task 6 (Optional) – Additional Soil Excavation Completion of additional soil excavation activities, backfill, and site restoration in accordance with the PWS and RAWP in accordance with USACE and VT DEC regulations.

Task 7 – Project Closeout USACE and VT DEC acceptance of Final Project Closeout Report including a summary of all remedial soil excavation activities, site restoration, site survey, “as-built” drawings, and monitoring well decommissioning. USACE acceptance of project documentation and closeout files.

1.2 Site Information

The Site is comprised of 50.2 acres in a remote forested area that currently is only accessible to the public by walking or by recreational vehicles (i.e., all-terrain vehicles (ATVs) or snowmobiles). There are two locked gates on the sole, privately owned, 11-mile-long access road to the Project. There are no known residences within 1,000 feet of the Project and there are currently no industrial or residential activities occurring at or near the Site. The nearest water supply well is more than 2 miles from the Project based upon visual observations and the Vermont water supply well graphical information system web site. As of the date of this report, the Site is completely surrounded by lands owned by Weyerhaeuser Company (formerly Plum Creek Timber Company) which owns approximately 86,000 acres of land surrounding the Site. All of the Areas of Concern (AOCs) listed in this document are primarily located on land owned by Northeast Kingdom Wind Power, although portions of the Debris Area are located on property owned by Weyerhaeuser Company.


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The Project includes 5 surveyed land parcels: 1) Debris Area, located approximately 3,000 ft down the access road from the Cantonment Area; 2) Cantonment Area, located along the access road at an elevation of 2,400 ft; 3) Operations Area, located at the top of East Mountain at an elevation of 3,400 ft; 4) Receiver Building, also located at the top of East Mountain; and 5) Parcel Adjacent to Cantonment Area. The Vermont Sites Management Section (SMS) stated in their May 14, 2009 letter to USACE-NAE that the Receiver Building and the Parcel Adjacent to Cantonment Area were immediately eligible for Site Management Activity Completed (SMAC) status without any institutional controls. Work activities performed under this contract are focused on a 30 ft by 30 ft area around Test Pit TP6 in AOC 1 of the Debris Area where one sample collected during the RI exceeded the remediation goal (RG), and the decommissioning of 2 monitoring wells (LY-01 and LY-02) located in the Cantonment Area and the Parcel Adjacent to the Cantonment Area. The contract also includes an optional provision for decommissioning 3 water former supply wells located in the Cantonment Area, if authorized by the USACE.


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2.0 PREVIOUS REPORTS / INVESTIGATIONS

Beginning in 1991 through approximately 2001, investigations, petroleum tank closures, and contaminated soils excavation and removal activities have been performed at the Project by numerous contractors including Stone & Webster (1995, 1997, 2001), Clean Harbors (1991) and Coastal Environmental (2001). In 1995, two overburden groundwater monitoring wells (LY-01 and LY-02) were installed by Stone & Webster in the Cantonment Area parcel and the parcel adjacent to the Cantonment Area. There are three existing water supply wells in the Cantonment Area and the (Well-A and Well-B) and the Parcel Adjacent to the Cantonment Area (Well-C).

In 2008, The Johnson Company (JCO) performed remedial investigation activities in the Debris Area and the Cantonment Area in order to confirm the location and extent of the debris, to evaluate current groundwater quality, and to evaluate the Cantonment Area dry well. During the investigation, Debris Area soils, sediment and surface water were sampled and analyzed, as were groundwater in the Cantonment Area, and the Well-B dry well contents (Johnson Company, Inc. (JCO), 2013.

In 2009, JCO conducted additional remedial investigation activities to address data gaps in the Debris Area identified in their 2008 investigation. For the purposes of the report, the Debris Area was separated into two AOCs: Debris AOC 1 and Debris AOC 2. The primary objective of the 2009 investigation was to collect additional data in the Debris Area AOCs 1 and 2 on Parcel A100-1 to determine the extent of solid waste and if contamination present in this area poses a risk to human health or the environment. In addition to the work performed in the Debris Area, a secondary objective was to remediate the Well-B dry well located in the Cantonment Area (JCO, 2011). The RI report included a human health and ecological risk assessment.

In 2014, the Feasibility Study (FS) was completed by Stone Environmental (Stone, 2014). The FS concluded that the only actionable risk at the Site was in the Debris Area AOC 1. The human health risk assessment indicated that total PCBs in soil would need to be less than or equal to 1.7 milligrams per kilogram (mg/Kg) to meet a residential Hazard Index (HI) of 1. [Note that this result corrects an error in the 2013 risk assessment (JCO, 2013), which resulted in an incorrect RG of 28.3 mg/Kg]. The only area where concentrations of total PCBs are equal to or exceed the RG is Test Pit TP6 in the Debris Area.

In the Debris Area, the estimated total volume of soil with total PCB concentrations greater than the RG is 1,872 cubic feet or 69 cubic yards in situ. Assuming a 20 percent increase in volume for fluffing (assuming a combination of sand, gravel and loam) and an additional 30 increase for conversion to tons (Department of Army, 2000) the total mass of waste material to be excavated would be approximately 108 tons. There is uncertainty in the lateral and vertical extent of the total PCB concentrations greater than the RG which were proposed to be addressed through pre-design characterization which was included as part of the Debris Area Alternatives 3 and 4 in the FS.

In 2015, the Proposed Plan (PP) was prepared by Stone Environmental on behalf of the USACE (Stone, 2015). The Proposed Plan recommended Alternative 4 of the FS. Alternative 4 is “Removal, Offsite Disposal and Backfill”, which includes:

Removal of contaminated soil [A pre-design soil investigation in Area of Concern (AOC) 1 is recommended to determine the specific soil removal extent];


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Off-site disposal of contaminated soil at a licensed facility; Backfill of soil removal area.

In 2016, the Decision Document (DD) was prepared by Stone Environmental on behalf of the USACE (Stone, 2016). The Decision Document specifies Removal, Offsite Disposal, and Backfill as the Selected Remedy for the Site.


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3.0 PRE-DESIGN AND CONFIRMATION SAMPLING AND ANALYSIS

Pre-design investigations will be conducted in a 30 ft by 30 ft target area centered at Test Pit TP6 to delineate the volume of soil that exceeds the RG of 1.7 mg/kg. The methodology proposed for conducting the pre-design investigation will be a modified version of the methodology described in the FS. The FS assumptions involved dividing the target area into cells, each of which would be characterized by analysis of a composite sample representing multiple incremental samples. While this general approach will be performed, the current sampling plan incorporates more of the principles of incremental sampling methodology (ISM) as described in Interstate Technology Regulatory Council’s (ITRC) ISM Technical and Regulatory Guidance Document, (ITRC, 2012), but is not consistent with all aspects of this guidance due to the small size of the target area being sampled.

The 30 ft by 30 ft target area will be divided into a grid of nine (9) 10 ft by 10 ft cells, extending from ground surface to 3 ft below ground surface (bgs); these cells are referred to as decision units (DUs). A second layer of nine additional DUs will extend from 3 ft to 4 ft bgs. A direct push drill rig will be used to collect soil cores from ground surface to a depth of 4 ft bgs, from which the incremental samples will be collected. A total of nine (9) soil sample increments will be collected from each of the 18 DUs, generating 18 composite samples that will be submitted to Katahdin Laboratory of Scarborough, Maine for analysis of PCBs via EPA Method 8082. Once at the laboratory, three replicate samples will be collected from each composite sample for analysis. For a detailed description of the sampling and analysis methodologies, see the Field Sampling Plan (FSP) and the Quality Assurance Project Plan (QAPP) and provided as Attachments C and D.

Based on the results of the pre-design investigations, an excavation plan will be developed. The excavation plan will delineate the areas (based on the DUs) where analytical results indicate total PCB concentrations in soil exceed the RG of 1.7 mg/kg. Only DUs with PCB exceedances of the RG will be excavated. Following excavation, confirmation sampling will be performed. The confirmation sampling will follow a methodology similar to the pre-design sampling, with three main differences. The samples will be collected by hand from the top 3 inches of soil as opposed to being collected by coring. The area to be sampled will be divided into five (5) DUs, rather than 9. The four side walls and the floor of the excavation will each be a separate DU. A total of 30 incremental samples will be collected from each of the DUs, instead of 9 incremental samples, as proposed for the pre-design sampling. The confirmation sampling plan may be reevaluated depending on the results of the pre-design investigations and the actual configuration of the excavation. As with the pre-design investigation, analysis for PCBs via Method 8082 will be performed by Katahdin. More detail on the confirmation sampling and analysis procedures are provided in the FSP and QAPP.

If confirmation sampling indicates that soil with total PCB concentrations exceeding the RG remain on on-site, the USACE will authorize KGS to proceed with an option to perform additional excavation of contaminated soil, followed by a second round of confirmation sampling. This sequence will be repeated, as many times as necessary, until all confirmation samples indicate that the RG has been attained at the side walls and floor of the excavation.

All analytical data will be validated and uploaded to the FUDSCHEM database, along with the Vermont State Plane coordinates associated with each of the DUs.


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4.0 PROPOSAL TO COMPLETE ALL REQUIREMENTS

KGS hereby proposes to complete all of the requirements as outlined in the PWS, as contained within this WP, and as required under USACE contract W912WJ-16-C-0020.


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5.0 APPLICABLE REMEDIATION STANDARDS

Based on available site information, and current and anticipated future land use considerations, the following soil remediation standards were established for the project RG and to complete closure of the site under the DERP-FUDS Program:

Total PCBs 1.7 milligrams/kilogram (mg/kg)


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6.0 REMEDIAL ACTIONS

6.1 Organization and Responsibilities

Organizational Structure and Staffing 6.1.1

An organizational chart showing the reporting relationships of personnel included on this project is provided as Attachment A.

Mr. Edward King, P.E. is the Program Manager (PGM) for this task. Mr. King and/or his designee represent KGS in all matters related to the project.

Mr. Gregory Birch, PMP® is the Project Manager (PM), Quality Control Manager (QCM) and will be the Point of Contact (POC) for the USACE Contracting Officer Representative (COR) for this task. Mr. Birch is responsible for the execution of the project in accordance with the requirements contained in the PWS, this WP, and the Accident Prevention Plan (APP)/Site Safety and Health Plan (SSHP).

Mr. Edward Kearney, CIH is the Safety and Health Manager (SHM). Mr. Kearney is a Certified Industrial Hygienist (CIH) whose Safety and Health responsibilities include oversight of the development and approval of the APP/SSHP, performing Safety and Health inspections and audits as scheduled with the PM, and providing Safety and Health technical assistance to the PM and Site Safety and Health Officer (SSHO).

The Site Superintendent (SS) role will be performed by Mr. John Hudacek. The SS is responsible for ensuring that all field activities are conducted in conformance with the requirements contained in the WP. The SS is also responsible for ensuring that subcontractor submittals are prepared and submitted on time and will also coordinate all field activities to be performed by KGS and its subcontractors.

Mr. Eric Lynch will serve as the Contractor Quality Control System Manager (CQCSM) and SSHO for this project. Mr. Lynch will be responsible for overall management of Contractor Quality Control (CQC) and have the authority to act in all CQC matters for KGS as the CQCSM. Mr. Lynch is responsible for coordinating and ensuring consistent application of safety and health practices and procedures for all staff, regardless of organizational affiliation. As the SSHO, Mr. Lynch is responsible for the implementation of the APP/SSHP and for the coordination of safety activities with the SS and the COR to ensure that the planned work objectives reflect adequate safety and health considerations. Mr. John Hudacek will be the alternate CQCSM/SSHO for this project.

Ms. Bette Nowack (Stone Environmental) will serve as the Technical Manager and will be responsible for coordinating all sampling activities and ensuring the compliance with the QAPP / FSP. The Technical Manager will report directly to the PM and will coordinate field sampling personnel and interface with the analytical laboratory.

Subcontractors and Suppliers 6.1.2

KGS will procure a qualified subcontractor to perform onsite tasks including surveying, clearing and grubbing, transportation and disposal of impacted soil, and site restoration. The subcontractor will comply with all permits and the Erosion and Sediment (E&S) control requirements, and will be responsible for obtaining and complying with any required


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construction permits. KGS intends to utilize the following subcontractors and material suppliers for this project:

Analytical Laboratory: Katahdin Analytical Services

Transportation/Hauling Subcontractor: Capitol Environmental.

Disposal Facility: Waste USA Landfill, 21 Landfill Lane, Coventry VT 05825 (pending USACE approval after waste characterization)

Clearing and Grubbing Subcontractor: KGS.

Clean Fill Supplier: TBD.

Site Restoration (seeding/strawing): KGS.

Sanitary Facilities Supplier: TBD

Laboratory Subcontractor: Will be included with the QAPP.

Surveyor: American Consulting Engineers & Surveyors, Inc.

6.2 WORK AREA CONSTRAINTS

The soil remediation will be performed at inactive locations of the LFAFS.

No work constraints are anticipated; however, the following sections discuss potential constraints that may be encountered during the execution of this task.

Underground Utilities 6.2.1

Although no underground utilities have been identified at the work areas, the potential for previously unidentified utilities exists. To ensure all potential excavation conflicts are identified prior to the start of work, a One-Call notification will be made at least 72 hours in advance as required by law. Because of the proximity of the work areas within the LFAFS facility, it is unlikely the One-Call will provide utility markout inside the facility boundaries. Further, any LFAFS-required permits (i.e. dig permit, etc.) will be obtained prior to commencing work.

Site Access 6.2.2

The LFAFS a Formerly Used Defense Site, no longer owned by the Government, and currently is privately owned. The land surrounding the property is owned by a timber company. As such, site access will need to be granted by the property owner and coordinated with the active timber company. It is KGS’ understanding that a key to the existing lock will be provided and KGS will secure their lock to the existing lock for further access to the site. All on-site personnel must report to the SS/SSHO and sign the Site Control Log. Personnel will be allowed onsite only after completing the applicable project paperwork and receiving the applicable training (e.g. site specific safety and health training). Any rules and regulations that exist regarding security and access on the privately owned properties will be strictly adhered to by all personnel while on-site.


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6.3 PROJECT EXECUTION

This section describes the resources, means, and methods that KGS will apply to complete the work outlined in this WP.

Project Management and Administration 6.3.1

The PM, Mr. Gregory Birch, PMP®, will manage this project. He will draw upon project support for management, cost and schedule, accounting, procurement, contract administration, safety and quality control from KGS’ internal resources. Key members of the project staff for this task order are identified previously, including the CQCSM/SSHO, roles of which will be performed by a single individual. Field staffing during all onsite work activities will include the CQCSM/SSHO on a full-time basis.

The PM will distribute a contact list prior to mobilization for technical and administrative matters within the KGS organization as well as project-related contacts. This contact list will also be included in the APP/SSHP. KGS intends to delegate authority for all technical decisions in the field to the CQCSM/SSHO in consultation with the SS, with daily support from the PM. The KGS PM will maintain responsibility for overall task order performance, provide a POC for the client regarding project contractual and financial matters, and will share responsibility for safety and quality performance with the field team.

Plans and Submittals 6.3.2

KGS has developed this WP to encompass the various plans required for submittal under the PWS. These plans are identified as follows and further presented under their respective sections of this WP.

6.3.2.1 Accident Prevention Plan/Site Safety and Health Plan

KGS has prepared an APP/SSHP specific to the field work in this task order, in accordance with Occupational and Safety Health Administration (OSHA) Standards 29 Code of Federal Regulations (CFR) 1910.120 and 1926.65, and USACE Safety and Health Requirements Manual [Engineer Manual (EM) 385-1-1], 30 November 2014. The APP/SSHP is a separate submittal from this WP.

6.3.2.2 Contractor Quality Control Plan

KGS will implement a Contractor Quality Control Plan (CQCP) to address construction quality for this task order. The CQCP, presented as Attachment B of this WP, meets the requirements of the contract and PWS specifications, and complies with USACE Construction Quality Management (CQM) concepts and procedures. The Quality Control System (QCS) to be applied by KGS to ensure the quality of the work under this task order involves seven basic elements:

Definable Features of Work (DFW),

Submittals,

Project Quality Control Meetings,

Three Phase System of Quality Control,


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Tests and Inspections,

Completion Inspection, and

Documentation.

Construction Tasks 6.3.3

6.3.3.1 Mobilization

After all pre-mobilization activities and submittals have been approved by the COR, KGS will mobilize required equipment and personnel to the job site including the SS, CQCSM/SSHO, equipment operators, and laborers. Subcontractors will mobilize to the site, as necessary, only after their respective submittals are approved and their readiness is confirmed. Any required temporary facilities will be set-up in preparation for construction activities. Work areas will be delineated with construction fencing and signage to control access.

Prior to mobilization, KGS will notify One Call to identify underground utilities at the site. A licensed surveyor will be onsite to mark out the work areas (limits of excavation) prior to the start of any intrusive activities.

The proposed truck delivery and egress route will be identified to minimize congestion and facilitate loading and offloading operations. KGS will consult USACE to identify an acceptable route that will minimize impact to the timber company operations. Prior to finalizing the vehicle routes, pre-existing conditions will be reviewed and documented. The entire onsite route, including all deficiencies and surfaces in need of repair, will be digitally photographed and submitted to USACE for future reference. The proposed vehicle route will be driven by the site management staff as a final confirmation of potential weight limitations over any crossings or culverts. The final site haul route will not be designated until after approval from USACE and the property owners. Once approved, the route will be posted and clearly marked for hauling vehicles entering and exiting the site. This will include signage to direct traffic as necessary.

Soil waste characterization samples will be collected in situ prior to excavation. Five-point composite samples will be collected via hand auger and/or trowels from each grid. Each sample will be homogenized and shipped offsite for analysis of PCB.

6.3.3.2 Site Preparation

Once initial mobilization is completed, site preparation activities will be conducted. Site preparation will consist of work zone delineation, site clearing, pre-design investigation, temporary site benchmark installation (as required), E&S control installation, development of nuisance water management and spill management procedures, and establishment of staging areas (i.e., materials handling areas).

KGS will have completed the One Call utility notification, and will have performed any appropriate utility clearance and mark-out, and procure any specific permit. No utility connections (e.g., phone service and electricity) will be required for onsite resources during this removal action.


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Work Zone Delineation

The horizontal extent of each soil remediation area will be identified during preparation for the respective AOCs. Site clearing will be initiated followed by installation of E&S controls and stake-out (for spatial and depth measurement) of the excavation area.

Work zones will be established and clearly delineated using fencing and signage at the project site and vicinity. The work zones will be established based on general construction safety concerns and equipment decontamination. The zones will include the exclusion zone, equipment decontamination area, and support zone. Signs will be posted at the perimeter of the site to advise visitors and trespassers.

The exclusion zone is defined as the area of excavation where equipment is actively performing intrusive work. Only personnel and equipment essential to the operation are permitted within the exclusion zone. Personnel must be properly trained and adorned with appropriate personal protective equipment (PPE) in accordance with the APP/SSHP while working within the exclusion zone.

The equipment decontamination area (ie. the contaminant reduction zone) is defined as the area adjacent to the exclusion zone, and is the area in which decontamination activities will be conducted. The area will be marked by traffic cones to indicate specific entry points into the exclusion zone and to indicate that specific PPE and/or training may be required prior to entering this area.

The support zone is the area of the site that is outside of the work area and houses support activities. This area will be comprised of equipment, clean material staging areas, and parking areas.

Site Clearing

Site clearing operations will be necessary prior to performing excavation activities. The total area to be cleared is approximately 0.5 acres. Additional clearing of vegetation within the limit of disturbance may be performed as needed. Site clearing operations will involve tree felling, brush removal, and vegetation clearing operations with conventional equipment (both mechanized heavy equipment and ground personnel). When appropriate, trees will be felled by ground crews utilizing chain saws (or brush cutters for small diameter materials). The minimum PPE selection for site clearing operations will be as follows:

• Long trousers, chainsaw chaps, and appropriate footwear (ANSI [American National Standards Institute]-rated)

• ANSI Z87 approved eyewear with a face shield

• A hardhat with the visor facing forward

• Leather work gloves

• Long-sleeved shirt

• Hearing protection

For land clearing operations, substitution of high visibility clothing can be considered where reflective/high visibility vests are normally utilized.


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Trees and other removed vegetation will be placed outside of the work areas for wildlife habitat. Specific safety guidelines/practices for the clearing activities are provided in the APP/SSHP.

Pre-Design Investigation

The Pre-Design Investigation will be conducted prior to soil excavation to determine the extent of soil excavation required to meet the remedial action objectives (RAOs). A brief discussion of the sampling and analysis to be conducted for the pre-design investigation is provided in Section 3.0. More details can be found in the FSP and QAPP, provided as Attachments C and D.

Erosion and Sediment and Stormwater Management Controls

If required, temporary E&S controls will be utilized and installed in accordance with best management practices and industry standards. Silt fence will be installed along the excavation boundary and surrounding the entire work area. The silt fence will be industry-standard, 36-inch tall, woven fabric. E&S controls will be inspected throughout the duration of the field activities, will be repaired/replaced as necessary and will be removed after the final site inspection. All E&S controls will be established, inspected, and maintained in accordance with the Vermont Standards & Specifications for Erosion Prevention and Sediment Control dated 2006.

Because of the remoteness of the areas, no stormwater inlets are anticipated in the work areas. The drainage patterns in the working areas will not be impacted by construction except when excavations are temporarily open.

If found necessary, a rock-lined stabilized construction entrance will be constructed to prevent haul truck tires from carrying loose material (e.g. rocks, mud, dirt) onto public highways. This construction entrance would be excavated to approximately 10 feet wide by 50 feet long, lined with geotextile, and filled with aggregate approximately six inches deep. Installation of a stabilized entrance will be at the professional judgment of the PM, SS, and/or their designee. In all cases, no gross amounts of loose rocks, mud, or dirt will be permitted to accumulate on public roads.

Spill Prevention Measures

To minimize the potential for spills and or releases from stationary fuel tanks, heavy equipment, and trucks; visual inspections will be performed periodically through the work shift for signs of drips, leakage, or stains on ground surfaces on and below the equipment. A fueling area will be pre-designated in an area that will have the ground surface protected in the event of a leak or spill from overfilling. KGS will utilize a truck-mounted fuel tank for refueling equipment.

Spill prevention and containment for recovery activities will be provided for spills up to 35 gallons. A larger spill may require additional support; therefore, the closest offsite support subcontractor or facility response team available with spill response equipment and materials will be identified. Onsite spill response equipment will include absorbent materials, sand, and other spill-containment devices necessary to prevent migration including absorbent media. Other equipment will include construction equipment used in ongoing construction activities.

All equipment will be inspected and maintained as necessary to ensure its proper operation in time of emergency. After an emergency, all equipment will be cleaned and ready for its intended use before normal operations resume.


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6.3.3.3 Soil Excavation, Transportation, and Disposal

KGS will excavate the 30’ x 30’ grid, 0’ – 2’ bgs (100 tons), with an option of 2’ – 4” bgs depending on pre-investigation sampling results; per the Stone Environmental Feasibility Study 2014, Section 5.5. and the Project Work Statement. Excavated soil will be stockpiled temporarily for expedited load out. Once each truck is loaded, it will be inspected for loose debris and appropriately decontaminated. Each truckload will be quality control inspected for all necessary paper work including non-hazardous waste manifests; and will then proceed directly to the disposal facility.

The disposal facility will be Waste USA Landfill, 21 Landfill Lane, Coventry VT 05825, and will depend upon waste characterization sample results and daily capacity. The disposal facility/facilities will be selected and approved by the USACE prior to commencement of excavation activities.

6.3.3.4 Confirmation Sampling

Once the appropriate excavation depth has been reached for the extents required, all activities in the specific area will cease. Confirmation samples will be collected on the side walls and floor of the excavation. A modified version of ITRC’s ISM procedures (ITRC, 2012) will be used to conduct the confirmation sampling as described in Section 3.0. The floor and each side wall of the excavation will be designated as a DU and 30 incremental samples will be collected to generate one composite sample for each DU.

The confirmation samples will be submitted to Katahdin Laboratory for 24 to 48 hour turnaround time to either allow for additional excavation or backfilling, which will minimize the time the excavation is left open. The confirmation sampling approach is detailed in the FSP and QAPP, provided as Attachment C. The modified ISM approach for collecting confirmation samples will provide an estimate of the mean total PCB concentration with a 95% confidence level, which can be compared to the RG (1.7 mg/kg) to determine if RAOs have been achieved.

All analytical data from the confirmation sampling will be validated and uploaded to the FUDSCHEM database, along with the Vermont State Plane coordinates associated with each of the DUs.

If any sample results exceed the RG, the USACE will be notified that additional excavating may be required. Upon authorization by USACE, additional excavation will occur in six-inch intervals until the remediation goals are met.

If all confirmation sample results indicated total PCB concentrations are below the RG of 1.7 mg/kg, KGS will survey the excavation areas and all DU corners for documentation in the Remedial Action Completion Report.

6.3.3.5 Decontamination

At the conclusion of the removal activities, or before leaving the site, all equipment will be properly decontaminated following all applicable OSHA and USACE standards. Decontamination will occur at a central location within the boundaries of the project site in a decontamination area that is properly cordoned off and contains applicable signage. Dry decontamination methods will be utilized based on the extent of soil/debris on the equipment and


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include brooms or other hand tools to remove soil and any other residual materials from tires, undercarriages, etc.

6.3.3.6 Backfill

Backfill material will be similar in nature to the material removed from the site and KGS will provide certification that all new backfill material meets VTDEC clean fill criteria. The backfill material will be approved by USACE prior to use.

After confirming and documenting appropriate soil excavation, KGS will begin backfilling operations. Clean general fill, topsoil, and loamy fill will be delivered to the site from offsite commercially-available sources. Prior to delivery, the general and loamy fills will be analyzed for metals.

Certified clean soil fill will be obtained and used to replace the excavated soil to match the surrounding grade. Samples of the topsoil and fill will be analyzed at an off-site laboratory prior to placement to verify that the fill is suitable for use at the site. The fill soil will be compacted in 6-inch lifts to minimize the formation of depressions. Finally, 6 inches of topsoil will be placed over the backfill and the area will be re-vegetated in accordance with the restoration plan provided as part of the remedial action work plan. Erosion mats or temporary barriers will be used as necessary to prevent erosion.

KGS will completely backfill and restore each excavation area. The areas will be restored with a minimum of six inches of topsoil and hand seeded with regional grass mix. In steep areas, erosion control measures such as compost logs and silt fencing will be employed to prevent erosion until vegetation is sufficiently robust to control erosion.

6.3.3.7 Site Restoration

The site will be cleaned up and all disturbed areas will be restored. This may include covering disturbed areas with a layer of top soil and seeding each area. The PM and/or CQCSM will conduct a site inspection prior to scheduling the pre-final or final inspections by the USACE representative and regulatory agencies as appropriate. All punch list items will be addressed prior to demobilizing from the site.

6.3.3.8 Monitoring Well Decommissioning During the same mobilization as the Soil Remediation task (Task 4 of Table 1), the Contractor will decommission the two (2) overburden groundwater monitoring wells installed in 1995, in accordance with applicable Federal (USACE EM 1110-1-4000 Monitoring Well Design, Installation and Documentation at Hazardous, Toxic and Radioactive Waste Sites, dated 1 November 1998) and State regulations. Table 2 provides a summary of the monitoring well construction. The site monitoring wells are shallow and it is assumed the monitoring wells will be decommissioned by case pulling/grouting in place. The Contractor will restore the site and areas at each decommissioned monitoring well location to the pre-existing conditions and recycle and/or dispose of all decommissioned monitoring well materials per applicable regulations and guidance. The Contractor will photo document the site conditions and each monitoring well location prior to and after decommissioning.


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Table 2 Monitoring Wells To Be Decommissioned at

Lyndonville Former Air Force Station, East Haven, VT

No. Well ID

Northing (ft)

Easting (ft)

Total Depth (ft bgs)

Screen Interval (ft bgs)

Protective Casing

1 LY-01 785679.78 1825418.9 6 15.5 5.5 - 15.5 Steel stick-up (2 ft)

2 LY-02 785792.31 1825439.3 5 20 10 – 20 Steel stick-up (2 ft)

The Contractor is responsible for documenting the well decommissioning field activities were completed in accordance with USACE and VT DEC regulations. The well decommissioning documentation should be incorporated into the Final Project Close-out Documentation (see Table 1, Task 7; Section 6.3.3.10). The report will include a photo log of the site conditions at each monitoring well location representing pre- and post-decommissioning. 6.3.3.9 Demobilization

KGS will demobilize equipment and personnel from the site upon completion of site restoration and punchlist items. A final site cleanup will be conducted to remove all materials involved in the remediation. Photographs of final site conditions will be taken for the closeout documentation.

6.3.3.10 Work Completion Documentation

KGS will provide a Closeout Report (CR) summarizing all activities performed. The CR will include a summary of all excavation activities, a summary of final material characterization and disposal information, a summary of confirmatory sample collection and analytical results, and a summary of all final backfill and restoration activities. The CR will also include appendices with all sampling logs, validated analytical data, and any other pertinent project information. The CR will include figures depicting survey of sampling locations, final surveyed excavation locations and dimensions, and the final disposition of all backfill and site restoration activities. All figures will be provided in GIS compatible format.

Potential Construction Activity Task Options –

The PWS for this contract contains two (2) optional tasks (See Table 1 - Task 5A & 6):

Task 5A (Optional) – Water Supply Well Decommissioning During the same mobilization as Soil Remediation (Task 4 of Table 1), the Contractor will decommission the three (3) water supply wells installed during active Air Force ownership, in accordance with applicable Federal (USACE EM 1110-1-4000, dated 1 November 1998) and State regulations. Table 2A provides a summary of the water supply well construction. All well are located in well houses.


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The Contractor will restore the site and areas at each decommissioned monitoring well location to the pre-existing conditions and recycle and/or dispose of all decommissioned monitoring well materials per applicable regulations and guidance. The Contractor will photo document the site conditions and each monitoring well location prior to and after decommissioning.

Table 2A Water Supply Wells To Be Decommissioned at

Lyndonville Former Air Force Station, East Haven, VT

No.

Well ID Northing

(ft)

Easting (ft)

Total Depth (ft bgs)

Screen Interval (ft bgs)

Protective Casing

1 Well-A 785530.16 1825479.65 unknown 30 Steel stick-up2 Well-B 785626.78 1825284.12 44.7 42 Steel stick-up3 Well-C 785711.04 1824982.26 150 85 Steel stick-up

The Contractor is responsible for documenting the well decommissioning field activities were completed in accordance with USACE and VT DEC regulations. The well decommissioning documentation should be incorporated into the Final Project Close-out Documentation (see Task 7 of Table 1). The report will include a photo log of the site conditions at each monitoring well location representing pre- and post-decommissioning. Task 6 (Optional) – Additional Soil Excavation The Contractor will excavate additional soils if the results of the excavation floor and side walls confirmation sampling conducted under Task 4 are determined to not meet the remedial goal. The Contractor will assume an additional 100 tons soil will be excavated, characterized, and sent off for transportation and disposal as outlined in Task 4. This optional task is executable up to four (4) times (total of 400 additional tons) and the task will be executed within the RA mobilization.


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7.0 REMEDIAL ACTION AREAS

As previously discussed, based on the PWS, one (1) previously identified area (AOC 1 of the Debris Area) is included in the remedial action. This WP only addresses the area that is scheduled for remediation.

The remedial action consists of the previously identified area requiring the removal and disposal of soil to an estimated depth of two (2) feet below ground surface (and option for additional depths). A separate composite sample will likewise be collected from the 3 to 4 ft interval to confirm the absence of PCB contamination at depth. The remedial action area addressed in this WP is shown in Figure 2. The proposed sampling grid is presented in Figure 3. Monitoring Well Decommissioning is shown in Figure 4.


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8.0 QUALITY ASSURANCE PROGRAM

To ensure KGS delivers the highest quality product to USACE and Lyndonville Former Air Force Station and VTDEC, a Quality Assurance Program consisting of a Quality Assurance Project Plan (QAPP) and Field Sampling Plan (FSP) is being implemented. The QAPP and FSP are provided as Attachments C and D, respectively.

8.1 Scope and Complexity

The scope of the pre-design and confirmatory sampling and laboratory analysis consists of several tasks that will determine if contaminated soil has been adequately removed from the target area in AOC 1. Samples will be collected, along with the appropriate quality assurance/quality control (QA/QC) samples, and sent to a certified laboratory for analysis. The laboratory results will undergo data validation before results are presented. The results of this sampling, along with concurrence from USACE, will determine the full extent of the initial excavation, if the excavated area can either be backfilled and restored, or if additional soil excavation will be required.

8.2 Data Quality Objectives

The data quality objectives of the sampling is to provide results that confirm enough soil has been removed from areas previously determined to be contaminated. Samples will be collected as required and as described in the FSP. The samples will be sent to a certified laboratory where analysis will be performed. Once the data is received by KGS, the results will be compared to the RG presented in Section 5.0 for acceptance.

8.3 Laboratory Information

Katahdin Analytical Services

600 Technology Way Scarborough, Maine 04074 (207) 874-2400

Contact: Kristen Schultz (207) 874-2400

8.4 Project Contact Information for Sampling and Analysis Activities

Stone Environmental

Project Manager: Ms. Bette Nowack, P.E. (603) 273-9250 - Responsibilities include overall project coordination including oversight of sampling activities.

Contractor Quality Control Systems Manager: Ms. Kim Watson (802) 229-2196 - Responsibilities include providing project QA/QC throughout project. Alternate CQCSM is Mr. Eric Lynch (484) 467-7232.

Field Sampling Team: Mr. Brian Diezel (802) 778-3008 and Mr. Lee Rosberg (802) 229-5378 - Responsibilities include sampling excavation areas as outlined in this QAPP and FSP.


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Manager: Kristen Schultz - Responsibilities include ensuring the laboratory follows the procedures outlined in the QAPP and Quality Systems Manual (QSM) while the laboratory is analyzing excavation area samples.

8.5 Analytical Methods/Quality Assurance

All samples collected for pre-design and confirmation sampling will be analyzed for total PCBs via EPA Method SW846/8082. Details on quality assurance are provided in the QAPP, included as Attachment C.

8.6 Site Specific Sampling Methods

Pre-design investigation and post-excavation sampling will be conducted using a modified incremental sampling methodology. The target area in Debris Area AOC 1 will be divided into multiple decision units (DUs) and multiple incremental samples will be collected and composited from each DU. Details on the establishment of DUs, numbers of increments, sample collection and sample handling procedures are provided in the FSP, included as Attachment D.

8.7 Chemistry Electronic Data Deliverables

The laboratory will report data using in a level 4 with full QC and SEDD/ADR 5.0/5.1 Stage 2.A EDD and a .pdf document file of the laboratory’s final data report that includes supporting documentation such as chromatograms and instrument calibrations. A comprehensive ADR project eQAPP will be generated. The ADR reviewed SEDD file, along with the associated eQAPP file and field data, will be uploaded into the Formerly Used Defense Site Chemical Database (FUDSCHEM).


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9.0 REQUIRED PERMITS / ACTIONS

State and Local Requirements

KGS will comply with state and local requirements applicable to the work to be performed under the Contract. Components of the work related to these requirements include, but are not limited to, the following:

Erosion & Sediment Control – permit not required.

Utility Location - One Call will be notified prior to performing any excavation or other intrusive activity. KGS will maintain utility mark outs and any other conditions during construction activities.

Excavation Permit – If required, KGS will acquire any project-specific digging/excavation permits as necessary.


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10.0 SOIL AND SEDIMENT EROSION CONTROL AND MONITORING

It is not anticipated that KGS will be required to submit a formal soil and sediment erosion plan. Regardless, as previously discussed in Section 6.3.3.2, if required, erosion and sedimentation control measures will be installed during the course of construction following local, state, federal and USACE regulations. The follow is a list of planned activities, although this list may change as field conditions indicate:

Silt fencing will be installed at key locations to inhibit erosive flows and contain any soil/sediment.

Any adjacent inlets will be protected using any combination of silt fencing, inlet filters, or other barrier as deemed appropriate.

The remediation site will be inspected and monitored on a continual basis by the SS and CQCSM/SSHO. Any situation encountered that are found to be against better judgment of the onsite team will be corrected on the spot immediately, as deemed appropriate.

All slopes that may be conducive to erosion will be stabilized as needed.

Any excess soil stockpiles will be properly protected and secured until final disposition.

Permanent vegetation and seeding will be utilized at the conclusion of the remedial actions and during site restoration.


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11.0 SITE SPECIFIC HEALTH AND SAFETY PLAN

KGS recognizes a responsibility to provide employees with a safe and healthful workplace and to provide clients with safe and effective services. Through implementation of a project specific APP/SSHP, KGS seeks to take proactive measures to recognize, evaluate, and control workplace hazards and to implement preventive actions to minimize the potential for employee injuries and illnesses. The APP/SSHP has been developed by KGS and submitted to the USACE under separate cover.

The APP contains accident prevention provisions established by EM 385-1-1. The APP, along with the SSHP, establishes the written safety and health program for personnel involved in project fieldwork and applies and interfaces in conjunction with requirements of the KGS Corporate Safety and Health Program (CSHP). The APP has been prepared to meet the requirements of: U.S. Department of Labor, OSHA standards, Title 29 CFR Part 1910 and 29 CFR Part 1926; EM 385-1-1; and the USACE PWS as previously referenced.

The APP will be primarily implemented by the KGS PM and the SS/SSHO, and SHM in coordination with the USACE COR and the site POCs.

Compliance with the APP is required of all KGS personnel, subcontractors, and associated third parties on site. A minimum of a single copy of the APP will be maintained on site during work activities and will be available for inspection and review by site or agency personnel. Field personnel will review applicable aspects of the APP before site work and will sign an “APP Review” acknowledgment form indicating they have reviewed the pertinent aspects of the plan.

The content of the APP may be revised and/or amended should additional information become available regarding the hazards present at the site and/or should significant changes occur in the scope of work, operational procedures, site hazards, and/or hazard control measures. The APP may be modified by the SSHO upon review and approval of the COR, PM, and SHM. Field personnel are informed of changes to the APP and SSHP through safety meetings and written addendum or revision to the APP.

The APP/SSHP will be submitted under separate cover.


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12.0 SITE RESTORATION PLAN

As discussed in Section 6.3.3.6 and Section 6.3.3.7, excavated areas will be backfilled and seeded, and the site will be cleaned up and all disturbed areas will be returned to pre-existing conditions. The PM and/or CQCSM will conduct a site inspection prior to scheduling the pre-final or final inspections by the USACE representative and regulatory agencies as appropriate. All punch list items will be addressed prior to demobilizing from the site.


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13.0 PROPOSED COMPLETION DATE AND PROJECT SCHEDULE

The remedial actions are scheduled to commence in December 2016 and proceed for a duration of approximately four (4) weeks (1 week for pre-design investigation, 3 weeks for RA field effort). One week for each additional option, as necessary. A detailed Project Schedule is included in Attachment E.

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ATTACHMENT A Organizational Structure

US ARMY Corps of Engineers, New England District *Marie Wojtas – [email protected]

978-318-8788 Project Manager, USACE

Vermont Department of Environmental Protection *Hugo Martinez-Cazon – [email protected] 802-522-5564 Project Manager, VT DEC

Program Management *Ed King, P.E. – [email protected] 484-437-6644 Program Manager, KGS Mr. King will be the primary point of contact, and manage all project activities.

Stone Environmental, Inc. Technical Staff *Bette Nowack, PE - [email protected] 603-273-9250 *Kim Watson – [email protected] 802-229-2196 *Lee Rosberg – [email protected] 802-229-5378 *Brian Diezel – [email protected] 802-778-3008 Technical staff will prepare FSP.QAPP documents, carry out field analysis, develop a remedial action work plan, and prepare a remedial action report

Katahdin Analytical Services *Kristen Schultz 207-874-2400 Project Manager Katahdin will perform fixed laboratory services.

Project Management *Gregory Birch – [email protected] 302-373-5724 Project Manager/QC Manager, KGS

CQC System Manager Eric Lynch – [email protected] 484-467-7232 John Hudacek – [email protected] (alternate) 516-449-6578

Site Safety Officer Eric Lynch – [email protected] 484-467-7232 John Hudacek – [email protected] (alternate) 516-449-6578

Site Superintendent John Hudacek – [email protected] 516-449-6578 Mr. Hudacek will oversee and coordinate all field construction activities.

* Person to receive QAPP

ATTACHMENT B Contractor Quality Control Plan

DRAFT

CONTRACTOR QUALITY CONTROL PLANFOR

REMEDIAL ACTION AND PROJECT CLOSEOUT ACTIVITIESLYNDONVILLE FORMER AIR FORCE STATION

EAST HAVEN, VERMONT

CONTRACT NUMBER: W912WJ-16-C-0020

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DEPARTMENT OF THE ARMYCORPS OF ENGINEERS

NEW ENGLAND DISTRICT696 VIRGINIA ROADCONCORD, MA 01742

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TABLE OF CONTENTS

SECTION PAGE

Contractor Quality Control Plan i KGS Remedial Action and Project Closeout Activities – Lyndonville FAFS November 2016East Haven, VT

1.0 INTRODUCTION............................................................................................................... 1 2.0 REFERENCES.................................................................................................................... 3 3.0 CQCP PURPOSE................................................................................................................ 4

3.1 CQCP Content................................................................................................................ 4 4.0 NOTIFICATION OF CHANGES..................................................................................... 5 5.0 COORDINATION .............................................................................................................. 6

5.1 Coordination Meeting .................................................................................................... 6 5.2 Weekly Progress Meeting .............................................................................................. 6 5.3 Subcontractor Pre-Construction Meeting....................................................................... 6 5.4 Problem Resolution Meeting.......................................................................................... 7

6.0 QUALITY CONTROL ORGANIZATION ..................................................................... 8 6.1 Quality Control Structure ............................................................................................... 8 6.2 Responsibility and Authority ......................................................................................... 9 6.3 CQC Personnel Qualifications and Training................................................................ 12 6.4 Contractor Quality Control Personnel.......................................................................... 13 6.5 Organizational Changes ............................................................................................... 13

7.0 SUBMITTALS .................................................................................................................. 14 7.1 Submittal Procedure ..................................................................................................... 14 7.2 Re-submittal Procedure ................................................................................................ 14 7.3 Deviations..................................................................................................................... 14 7.4 Control of Submittals ................................................................................................... 14 7.5 Submittal Register ........................................................................................................ 15

8.0 QUALITY MANAGEMENT PROCEDURES .............................................................. 16 8.1 Procedure Selection...................................................................................................... 16 8.2 Approval....................................................................................................................... 18 8.3 Monitoring and Observations....................................................................................... 18 8.4 Change and Control Procedures................................................................................... 18

9.0 CONTROL ........................................................................................................................ 20 9.1 Preparatory Phase......................................................................................................... 20 9.2 Initial Phase .................................................................................................................. 21 9.3 Follow-up Phase........................................................................................................... 21 9.4 Additional Preparatory and Initial Phases.................................................................... 22

10.0 COMPLETION INSPECTION....................................................................................... 23 10.1 Punch List..................................................................................................................... 23 10.2 Pre-Final Inspection ..................................................................................................... 23 10.3 Final Acceptance Inspection ........................................................................................ 23

11.0 DOCUMENTATION........................................................................................................ 24 11.1 Responsibility............................................................................................................... 24 11.2 Requirements................................................................................................................ 24 11.3 CQC Reports and Records ........................................................................................... 24 11.4 Forms and Records....................................................................................................... 26

12.0 CONTROL OF DOCUMENTATION............................................................................ 27

TABLE OF CONTENTS

SECTION PAGE

Contractor Quality Control Plan ii KGS Remedial Action and Project Closeout Activities – Lyndonville FAFS November 2016East Haven, VT

13.0 NONCONFORMANCE AND CORRECTIVE ACTION ............................................ 28 14.0 DEFICIENCY TRACKING SYSTEM........................................................................... 29 15.0 APPROVALS .................................................................................................................... 30

Contractor Quality Control Plan i KGS Remedial Action and Project Closeout Activities – Lyndonville FAFS November 2016East Haven, VT

TABLES

Table 1 Schedule of QC Observations and Testing by Definable Feature of Work (DFW)

APPENDICES

Appendix A Contractor Quality Control Manager Appointment Letter and Resumes Of Project Staff

Appendix B Contractor Quality Control Site Forms

Appendix C Project Organization Chart

Appendix D Submittal Register

Contractor Quality Control Plan ii KGS Remedial Action and Project Closeout Activities – Lyndonville FAFS November 2016East Haven, VT

LIST OF ACRONYMS

AE Architects/EngineersAPP Accident Prevention PlanCHSM Corporate Safety and Health ManagerCIH Certified Industrial HygienistCQC Contractor Quality ControlCQCP Contractor Quality Control PlanCQCSM Contractor Quality Control Systems ManagerCQM Certified Quality ManagerCOR Contracting Officer’s RepresentativeDFW Definable Features of WorkDQCR Daily Quality Control ReportFCR Field Change ReportLFAFS Lyndonville Former Air Force StationNCR Nonconformance ReportPE Professional EngineerPJE Project EngineerPM Project ManagerPGM Program ManagerQA/QC Quality Assurance/Quality ControlQCM Quality Control ManagerQA Director Quality Assurance DirectorSOW Statement of WorkSS Site SuperintendentSSHO Site Safety and Health OfficerSSHP Site Safety and Health PlanTL Technical LeadTO Task Order

Contractor Quality Control Plan 1 KGS Remedial Action and Project Closeout Activities – Lyndonville FAFS November 2016East Haven, VT

1.0 INTRODUCTION

Koman Government Solutions, LLC (KGS) has prepared this Contractor Quality Control Plan (CQCP) for the U.S. Army Corps of Engineers, New England District (USACE) under ContractNumber (No.) W912WJ-16-C-0020. The overall intent of this work is to complete remediation activities at the Lyndonville Former Air Force Station to facilitate site closure.

This CQCP was prepared in accordance with Contract No. W912WJ-16-C-0020. This CQCP is based on the following documents/regulations:

� The Performance Work Statement (PWS) prepared by USACE entitled Remedial Action and Project Closeout Activities at Lyndonville Former Air Force Station, East Haven,VT, dated 26 May 2016 (revised 11 August 2016).

� Department of the Army, 2000. Field Manual No. 5-434, Earthmoving Operations.Headquarters, Washington, DC. June 2000.

� DoD Environmental Data Quality Workshop, 2013. Department of Defense Quality Systems Manual For Environmental Laboratories version 5.0.

� The Johnson Company, Inc. (JCO), 2013. Final Remedial Investigation Report, FormerLyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. January 2013.

� Stone Environmental, Inc. (Stone), 2014. Feasibility Study, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. November 2014.

� Stone, 2015. Proposed Plan, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. June 11.

� Stone, 2016. Final Decision Document, Lyndonville Former Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. September.

Each KGS staff member and KGS team member understands and believes that the quality of the decision-making, planning, work process, and actual project implementation that each of us accomplishes every day is the major factor in creating the success of our client relationships, the success of each staff member, and the long-term success of our firm.

KGS achieves this quality by focusing on three major elements:

� The client’s requirements and expectations

� The attitude, qualifications, experience, and training of our staff

� The process, procedures, and protocols used to accomplish the project work efficiently, effectively, and with the quality results we require.

For this project, KGS will demonstrate its commitment and focus on these elements by:


� Continuously assessing the changing needs of our client and proactively requesting feedback on our performance

� Assuring that all staff assigned to the project are qualified, experienced, trained, and have an attitude valuing high-quality and responsive service to our client

� Providing adequate equipment and resources that will always be available to meet the client’s needs

� Auditing and assessing the performance of KGS and our team to identify aspects of our work that we can improve and to continuously be in the process of creating the “next edition” of these improved services.

KGS’s commitment to strict adherence to this CQCP is affirmed throughout the company including executive officers, management, field staff, subcontractors, vendors, and offsite fabricators.

KGS will:

� Clearly define roles, responsibilities, and authorities of all project staff

� Compile accurate and complete CQCP documents and records

� Empower CQCP representatives to fully implement this Plan throughout the contract duration

� Proactively detect, document, and resolve quality discrepancies

� Establish and maintain continuous, professional, and effective communications with USACE.

KGS will provide and maintain a documented CQC system that will ensure that the end product (equipment, materials, and/or services) provided to the government conforms to contract requirements. The CQCP is a “living” document and will be modified, as necessary, with therequired approvals throughout the life of the project.


2.0 REFERENCES

The publications/documents listed below are incorporated by reference into this CQCP:

� USACE Guide Specifications, Section 01 45 00. Contractor Quality Control.

� The Johnson Company, Inc. (JCO), 2013. Final Remedial Investigation Report, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. January 2013.

� Stone Environmental, Inc. (Stone), 2014. Feasibility Study, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. November 2014.

� Stone, 2015. Proposed Plan, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. June 11.

� Stone, 2016. Final Decision Document, Lyndonville Former Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. September.

� Accident Prevention Plan/Site Safety and Health Plan (APP/SSHP) prepared by KGS and submitted under separate cover.


3.0 CQCP PURPOSE

The purpose of the CQCP is to establish an effective CQC system for all construction and engineering activities, both on- and off-site, to be performed during the project entitled “Remedial Action and Project Closeout Activities, Lyndonville Former Air Force Station, East Haven, Vermont”. The implementation of this system will ensure, with a reasonable degree of certainty, that completed construction and/or engineering activities meet and/or exceed all design criteria, plans, and specifications.

3.1 CQCP Content

The CQCP describes the procedures and organization required to ensure that project quality objectives are met. This plan addresses both on- and off-site construction operations including work by subcontractors, fabricators, suppliers, and purchasing agents. In summary, the CQCP includes the following components:

� A description of the CQC organization including: (1) a chart showing lines of authority for this project, (2) acknowledgement that the CQC staff will implement the three-phase control system, (3) duties of the Contractor Quality Control System Manager (CQCSM) assigned to monitor the CQCP implementation for the project, reporting KGS’ CQC Manager (QCM).

� A list of the names, qualifications, duties, responsibilities, and authorities of the personnel assigned CQC functions.

� Procedures for scheduling, reviewing, certifying, and managing submittals, including those of subcontractors, off-site fabricators, suppliers, purchasing agents, designers of records, consultants, and architect/engineers (AE).

� Control, verification, and acceptance of testing procedures for each specific test to include the test name, feature of work to be tested, test frequency, and person responsible for each test.

� Procedures for tracking preparatory, initial, and follow-up control phases and control, verification, and acceptance tests including documentation.

� Procedures for tracking construction design and construction deficiencies from identification through acceptable corrective action. These procedures will establish verification that identified deficiencies have been corrected.

� Reporting procedures including proposed reporting formats.

� A list of the definable features of work (DFW). Although each section of the specifications may generally be considered as a DFW, there is frequently more than one definable feature under a particular section. This list will be agreed upon during the coordination meeting.


4.0 NOTIFICATION OF CHANGES

Once the Client has approved the CQCP, KGS will notify the Contracting Officer Representative (COR) in writing of any proposed change. Proposed changes will be subject to acceptance of the COR.


5.0 COORDINATION

The Project Manager (PM) will effectively communicate the content and intentions of the contract documents to all members of the project team to ensure consistency of project understanding and planned implementation.

Coordination will be based upon the concept of the three-phased CQC process (preparatory,initial, and follow-up, as discussed in Section 8.0). Scheduled coordination activities will be detailed on the project’s field schedule to integrate the CQC process into all aspects of the project.

KGS will provide notification to USACE personnel in order to coordinate meetings, inspections, testing, and start-up activities at the job site. KGS will also provide accurate test results and field reports throughout the construction process.

5.1 Coordination Meeting

A mutual understanding of the quality control (QC) system will be established during the coordination meeting held prior to mobilization. The coordination meeting will cover all QC issues, including the forms for recording the CQC operations, control activities, testing, and administration of the system for both on-site and off-site work, and the interrelationship of Contractor’s Management and Control and the Government’s Quality Assurance.

Minutes of the meeting will be prepared by the Government and signed by both the contractor and the contracting officer. Minutes will be part of the of the contract file.

5.2 Weekly Progress Meeting

Brief weekly progress meetings will be held to review site activities, to detail accomplishments, and to address any questions that arise. The weekly progress meetings will be documented by the CQCSM; the meeting records will be available for review at the KGS site office.

5.3 Subcontractor Pre-Construction Meeting

Following the mobilization of a major subcontractor to the site and following the project's initial pre-construction meeting, the COR or his or her designated representative, the CQSCM, the Site Superintendent (SS), and all subcontractor supervisory personnel will attend a pre-construction meeting prior to the subcontractor's initiation of any on-site activities, unless the major subcontractor attended the initial coordination meeting. The purpose of the meeting is the same as the original pre-construction meeting with the following additions:

� Discuss the subcontractor's scope of work.

� Discuss the subcontractor's proposed schedule.


� Discuss the construction schedule and impacts to ongoing work.

� Discuss the on-site CQCP and inspection program.

� Review the subcontractors’ required submittals.

The minutes of this meeting will be prepared by KGS’ CQCSM and distributed to all parties involved.

5.4 Problem Resolution Meeting

Problem resolution meetings will be held when special conditions warrant additional discussion. These meetings will be attended by, at a minimum, the CQCSM, related subcontractor(s), and the COR or their designated representative. The meeting purpose will be to define and discuss a problem, review solutions, and select an appropriate solution. The problem resolution meetings will be documented by the CQCSM, and the meeting records will be transmitted to all parties involved.


6.0 QUALITY CONTROL ORGANIZATION

KGS, as the prime contractor, is responsible for the development, implementation, and management of this CQCP. All subcontractor personnel will adhere to the requirements of this plan through their respective quality organizations.

The following list includes personnel involved in QA/QC for this project:

� Ed King, P.E., Program Manager (PGM)

� Gregory Birch, PMP, Project Manager (PM)

� Gregory Birch, PMP, Quality Control Manager (QCM)

� Eric Lynch, Contractor Quality Control Systems Manager (CQCSM)

� Eric Lynch, Site Safety and Health Officer (SSHO)

� Kim Watson, Alternate CQCSM

� John Hudacek, Site Superintendent (SS) and Alternate SSHO

� Bette Nowack, P.E., Technical Manager (Stone Environmental)

6.1 Quality Control Structure

An organizational chart showing the reporting relationship of personnel involved in this contract is provided in Appendix C.

The PGM oversees the development of site-specific project plans and delegates implementationof the Project Plans to the PM, who coordinates with the SS. The PGM delegates the implementation of the CQCP to the QCM. The PGM will delegate implementation of the Accident Prevention Plan/Site Safety & Health Plan (APP/SSHP) to the SHM who coordinates with the SSHO. This structure ensures that quality and safety issues within the project are not compromised by project cost/schedule considerations, and are allowed to immediately rise to a higher program and corporate level of responsibility in the organization for resolution, as necessary.

KGS will assign one person to function as the PM and SHM. The selected person will haveserved in these roles in the past.

The CQCSM is the focal point of CQC efforts on this project. The CQCSM will communicate the project CQC System requirements to all KGS staff and to each subcontractor and vendor to ensure the CQCP is implemented properly and that consistent quality results are achieved.

The CQC Team includes the SHM and the SSHO. Their duties under the CQC organization are to document the implementation of all planned safety procedures and requirements stipulated in


the APP/SSHP. In addition, as part of the three-phase CQC process, safety procedures and adequacy of the current activity hazard analyses are continuously evaluated and revised, as necessary, at every phased inspection point of the project.

6.2 Responsibility and Authority

The KGS CQC organization clearly identifies authority and responsibility for all aspects of Quality Assurance/Quality Control (QA/ QC). Each project team member will receive a written description of his/her responsibility on the project along with the chain of command. This information will be collectively communicated to the team via project kickoff and preconstruction meetings so that each member understands the project CQC system.

Each project team member with CQC responsibilities has a written job description specific to this project that includes the CQC duties, responsibilities, authority, and lines of authority under this project. The following are the job descriptions for each CQC position.

Program Manager (PGM)

The PGM, Mr. Ed King, P.E. has the overall responsibility for all technical, contractual, safety, and administrative matters for KGS under this contract. He will ensure a high degree of client responsiveness is maintained. Additionally, he will be responsible for reviewing and approving project plans, overseeing staff selection, monitoring contract and task funds and schedules, and implementing CQC processes. The PGM will delegate day-to-day management to the PM, CQC management to the CQCSM, and safety management to the SSHO.

Project Manager (PM)

KGS places ultimate accountability for performance, including construction compliance, with the PM. The PM, Mr. Gregory Birch, PMP is ultimately responsible for ensuring compliance with contract requirements, project plans, and other project documents. The PM coordinates closely with the USACE representative, PGM, SS, and CQCSM, as appropriate, to ensure each party’s needs are being met and to identify possible problems early on. The PM’s specific QC and safety duties and responsibilities include:

� Coordinate development of the CQCP

� Coordinate development of the APP/SSHP

� Coordinate with CQCSM and QC Officer to communicate and implement the CQCP

� Coordinate with CHSM and SSHO to communicate and implement the APP/SSHP

� Review CQC and Safety documentation prepared by the CQCSM and SSHO.


Quality Control Manager (QCM)

The QCM, Mr. Gregory Birch, PMP is responsible for the development and interpretation of CQC policies and procedures and carries the requisite authority to oversee and have the CQC activities properly executed for the project. He has overall responsibility for the Corporate CQC Program. He provides overall direction to the CQC functions, surveillance, and document reviews; and executes other quality functions as required. Implementation of the CQC activities in the field, are delegated to the CQCSM. Duties of the QCM include, but are not limited, to the following:

� Interfacing with the PM and the CQCSM on quality functions

� Designating the CQCSM

� Reviewing and approving the project CQCP

� Implementing CQC project requirements

� Overseeing onsite CQC staff

� Performing quality audits

� Initiating or recommending corrective action(s) that cannot be initiated immediately in the field

� Verifying implementation of corrective actions

� Notifying the CQM regarding conditions adverse to quality that cannot be resolved at the project level.

Site Superintendent (SS)

The SS, Mr. John Hudacek, will deploy resources in the most effective way to accomplish the required scope of work (SOW) and will conduct daily management and administration of fieldwork in accordance with project requirements. The SS reports directly to the PM and will provide the PM with daily progress reports. The SS will be accessible at all times while the field activities are in progress. The Site superintendent’s specific CQC duties and responsibilities include:

� Overall responsibility for all field activities and implementing all KGS qualityand safety policies and procedures

� Supervising and monitoring work execution by all subcontractors and KGSpersonnel to ensure contract items and conditions are fulfilled in accordance with work plans, specifications, and standard operating practices, where pertinent

� Coordinating closely with the PM, CQCSM, and safety personnel to ensure project operations comply with CQCP and APP/SSHP provisions


� Exercising “stop work” authority when required to prevent performances inconsistent with planning documents and project requirements

� Completing a daily activity report covering project activities and personnel for that day. Daily activity reports are submitted the next day to the PM. All reports will be compiled and submitted with the final closeout report

� Documenting all abnormalities (e.g., unanticipated site conditions or obstructions) and reporting them to the USACE representative.

� Ensuring site personnel assigned to the project are aware of company and site policies and procedures and abide by them

� Providing a safe working environment through a concerted effort with the SHMand the SSHO.

Contractor Quality Control System Manager (CQCSM)

The CQCSM, Mr. Eric Lynch, will be responsible for the enforcement of the CQCP in the field. The CQCSM reports to the QCM. The CQCSM’s specific duties and responsibilities include:

� Providing for continuous surveillance of project activities to ensure workmanship, methods, materials, and equipment conform to submittals and contract requirements and that work conforms to safety requirements

� Participating in the definition, isolation, and resolution of problems causing work not in conformance with project requirements with KGS’s appropriate employees, subcontractors, vendors, and engineers, and with USACE and other government and facility representatives

� Conducting documented orientation sessions with project staff including subcontractors and vendors to ensure maximum integration into the project quality requirements

� Certifying tests and qualifications, and providing other certifications required by engineering, Facility representatives, or USACE’s representatives

� Documenting activities, incidents, accidents, inspections, testing, and pertinent discussions with project staff, subcontractors, suppliers, government representatives, and visitors

� Exercising “stop work” authority when required to prevent or stop performance inconsistent with the SOW and CQCP. Initiating appropriate action to prevent, stop, or correct the occurrence of quality deficiencies. Documenting the occurrence of deficiencies and corrective actions as they occur


� Coordinating with KGS personnel, the Site Superintendent, the SSHO, and the subcontractors to ensure approved methods and materials are being used, safety procedures are being followed and documented, and quality goals are being met.

The Alternate CQCSM will be Ms. Kim Watson.

Site Safety and Health Officer (SSHO)

The SSHO, Mr. Eric Lynch, will be responsible for ensuring all work is conducted in compliance with the APP/SSHP, including proper use of personal protective equipment (PPE). The SSHO reports directly to the CHSM. The CHSM will empower the SSHO to enforce all safety and health issues in the field, including the authority to stop work for safety violations.

The Alternate SSHO will be Mr. John Hudacek.

Technical Manager (Stone Environmental)

The Technical Manager, Ms. Bette Nowack, will be responsible for coordinating all sampling activities and ensuring the compliance with the QAPP / FSP. The Technical Manager will report directly to the PM and will coordinate field sampling personnel and interface with the analytical laboratory.

Site Personnel and Subcontractors

All site personnel and subcontractors will be required to adhere to the procedures set forth in this CQCP. The SS, Mr. John Hudacek, will be responsible for overall management and coordination of KGS’s site personnel and subcontractors, and ensuring they perform all aspects of the work in accordance with the Project Plans, the APP/SSHP, and this CQCP. The CQCSMwill be responsible for ensuring the site personnel and subcontractors perform all aspects of the work in accordance with this CQCP. The SSHO will be responsible for ensuring the site personnel and subcontractors perform all aspects of the work in compliance with the APP.

The Site Superintendent, through a concerted effort with the SSHO and CHSM, will ensure that site personnel assigned to the project are aware of company and site policies and procedures and abide by them to provide a safe working environment.

6.3 CQC Personnel Qualifications and Training

Only personnel with direct documented QC experience will be assigned to CQC positions. Experience, education, and reference verification have been performed for all staff. The CQCSM will personally control all CQCP activities for the project. When the SS and SSHO perform certain CQC-related functions, they will be specifically trained and closely monitored by the CQCSM as part of the three-phase CQC inspection process to assure that all procedures and documentation are properly completed. In addition all involved staff will be trained for each DFW, to understand the required work procedures, the desired level of performance and workmanship, and the timing and means of the inspection points. This task-specific training will


be accomplished within the preliminary and initial phases of the CQC inspection process for each DFW.

6.4 Contractor Quality Control Personnel

The CQCSM has primary responsibility for proper implementation and managing of this CQCP.The CQCSM is responsible for the overall management of the QC Program. The CQCSM must be a graduate engineer, architect, scientist, construction manager, or a construction person with a minimum of 10 years in related work and must have sufficient practical, technical, and managerial experience to successfully oversee and implement QC activities; and must have demonstrated oral and written communication skills. The CQCSM must be certified by the USACE in Construction Quality Management for Contractors.

KGS’s CQCSM has construction/engineering fieldwork experience, with significant experience managing quality and field operations in construction/engineering projects. KGS’s QCM is a certified quality manager with substantial environmental and civil construction work experience.KGS PGM has comprehensive design and construction experience in environmental and large civil construction works.

The CQCSM will be assisted during certain tasks by the CHSM, SSHO and other technical resources as needed as part of the CQC Team. These additional staff members as well as the KGS organization as a whole can demonstrate extensive depth of required qualified experience to support this specialized task.

6.5 Organizational Changes

When necessary, KGS will revise the CQCP to reflect changes and submit the changes to the COR for acceptance.


7.0 SUBMITTALS

Preparation of submittals is the responsibility of the KGS PM. Submittals from KGS’ssubcontractors and vendors will be reviewed for technical content and accepted as a part of this submittal preparation procedure.

The CQCSM is responsible for the review and certification of all submittals before transmittal to either USACE or other required approval authorities. The CQCSM will review submittals for conformance to specifications, completeness, and accuracy. Submittals requiring modifications or changes will be returned to the originator, subcontractor, or vendor for correction and resubmission to the CQCSM. The CQCSM will approve or reject the submittal, as appropriate, and will indicate his or her action by his or her review stamp with signature and date before sending back to originator for revision or forwarding to government for approval.

7.1 Submittal Procedure

All submittals will be submitted in hardcopy via mail or in electronic files via by electronic mail, unless otherwise directed. Manufacturers’ descriptive data that have more than one model, size, or type or that show optional equipment will be marked to show the model, size, or type, and all optional equipment proposed for approval. Submittals on component items forming a system or that are interrelated will be submitted at one time as a single submittal to demonstrate that the items have been properly coordinated and will function as a unit. All submittals will be accompanied by a completed USACE Engineering Form 4025, signed by the CQCSM.

Submittals requiring government approval will be identified as having been reviewed, stampedand dated by the government and returned to the CQCSM or PM. The CQCSM will indicate the action by the government on the Submittal Register. Submittals approved by the government will be forwarded to Procurement.

7.2 Re-submittal Procedure

The government may require KGS to resubmit an item found not to comply with the project requirements. A subsequent submittal (re-submittal) due to the rejection of a previous submittal will be processed in the same manner as the original submittal.

7.3 Deviations

For submittals that include proposed deviations to the CQCP requested by KGS, the variation will be noted on the transmittal form. KGS will set forth in writing the reason for any deviations and annotate such deviations on the submittal. The government reserves the right to rescind inadvertent approval of submittals containing unnoted deviations.

7.4 Control of Submittals

KGS will carefully control its procurement operations so that materials and equipment are not ordered until the CQCSM and, where required, the government has approved the submittal


covering the subject material or equipment. KGS will plan its submittals preparation to allow review and approval time so that materials and equipment are ordered in time not to affect the project schedule.

7.5 Submittal Register

The CQCSM will maintain a Submittal Register as part of the CQC process. The register will provide a listing of all required submittals, the current status of each submittal, and any pending or planned action required by KGS or USACE. The submittal register will be updated weekly once mobilization begins.


8.0 QUALITY MANAGEMENT PROCEDURES

The following section outlines the use of operational procedures to ensure CQC from the preparatory stages of vendor material inspections and drawing reviews to delivery of a final product. This section also covers actual procedure for selection, approval, monitoring, change control, and application of remedial measures to construction activities outlined in the project SOW.

The KGS standard CQC forms are presented in Appendix B. They include the Daily Quality Control Report (DQCR), the Field Change Report (FCR), and the Nonconformance Report (NCR). The CQCSM completes these forms, as appropriate, to document the performance of quality management procedures. Further information regarding these standard forms is provided in Section 13, Control of Documentation.

8.1 Procedure Selection

The selection of CQC procedures and level of coordination is in accordance with the project specification requirements for each DFW and is further detailed in Table 1.

A Technical Lead and a Project Engineer are on staff to ensure compliance with specifications and compliance with local permits and requirements that may be necessary. A list of DFWs for this project is provided below:

1. Pre-Mobilization Activities� Project Coordination� Plans and Submittals� Preconstruction Site Visit

2. Mobilization and Site Preparation� Mobilization� Site Control Activities� Surveying� Erosion Controls and Environmental Protection, if required

3. Pre-Design Investigation / Soil Sampling� Confirm utility clearances� Collect pre-investigation soil samples prior to excavation activities.� Submit to analyzing laboratory for PCBs.

4. Excavation of Contaminated Soil� Review and approve equipment & methods� Observe excavation process to clean soil� Ensure E&S protection is in effect, if required� Stockpile / load-out excavated soil for transportation & disposal


5. Post-Excavation Soil Sampling� Collect representative soil samples from excavated areas to ensure removal of all

contaminated soil� Examine work area for layout work and clearances� Discuss QC inspection points and required level or workmanship� Submit soil samples for laboratory analysis of PCBs� Excavate additional soil if necessary and resample and submit for analysis of PCBs.

6. Site Restoration/Demobilization� Regrade area per drawings� Install fill, topsoil, and seeding where necessary� Remove all trash and debris and dispose of properly� Decontaminate and demobilize equipment� Transfer all project files to KGS’ Westborough, MA office� Perform final walk through with USACE, and property owner if necessary

7. Monitoring Well Decommissioning� Pull well casing and grout in-place� Restore the site and dispose of all decommissioned monitoring well materials

8. Project Closeout� Closeout documentation� Project deliverables� Post-construction activities � Project closeout

9. Water Supply Well Decommissioning (option)� Pull well casing and grout in-place� Restore the site and dispose of all decommissioned monitoring well materials

10. Additional Soil Excavation (option)� Observe excavation process to clean soil� Ensure E&S protection is in effect, if required� Additional confirmation sampling� Stockpile / load-out excavated soil for transportation & disposal

A detailed list of DFW’s is included in Table 1. Table 1 is intended to be used in the field by KGS QC staff.


8.2 Approval

The USACE Representative, PM, SS, and CQCSM will approve all detailed CQC procedures incorporated into this CQCP. The same parties will approve subsequent changes following initiation of work.

8.3 Monitoring and Observations

The CQC monitoring, observation, and surveillance system will be coordinated with key construction steps under each DFW. This system will include observation along withdocumentation of all tests performed and documentation of all inspections under each of the three-phases of the CQC system. The CQCSM keeps a daily log to document observations of construction techniques and reports on status of ongoing testing and analytical results and any other data relevant to the CQC effort. The daily log is used to support the daily DQCR and will be archived as part of project records.

The CQCSM closely monitors the actual field testing, verifying proper procedure technique, sample handling, and chain of custody, if required. The CQCSM reports the results of testing, compares the results with the project requirements and, if acceptable, indicates the work is acceptable and provides a timely authorization to proceed with subsequent work. If the CQCSM determines the test results or work is otherwise not acceptable, he/she immediately stops the work and initiates a conformance action.

8.4 Change and Control Procedures

A formal process identifies, documents, and tracks the status of procedural and condition changes in project design and remedial work. Changes required to an “Approved for Construction” drawing or specification, or field conditions that differ from those presented in contract documents shall be documented by a Field Condition Report (FCR).

Proposed changes that have not physically occurred are also documented on an FCR. In instances where the physical work has been completed, the FCR is used to provide the as-built information and allow design engineering the opportunity to review the impact of those changes on other components of the work.

The FCR is prepared by the Site Superintendent and the CQCSM, as required, and routed to the PM for review. The PM will discuss potential changes with the appropriate USACE Representative and KGS’s technical staff. Before routing, the SS uses the document control system to assign an FCR number, retains a copy for the FCR log and contract files, and then forwards a copy of the FCR to the PM. The CQCSM monitors the documentation and provides support.

The FCR is reviewed by the Project Engineer (PJE), CQCSM, SS, and PM. Upon resolution, each signs the FCR and forwards the FCR to the USACE Representative for review and processing.


9.0 CONTROL

CQC is the means by which KGS ensures that construction, including that of subcontractors and suppliers, complies with the requirements of the contract. Three phases of control shall be conducted by the CQCSM for each DFW of the construction work. A DFW is a task that is separate and distinct from all other tasks and has a specific set of control requirements (e.g., sheet pile installation, removal of riprap, etc.). Each control phase provides an opportunity to prevent deficiencies that result in nonconformance. Implementation of the three-phased CQC process is the responsibility of the project team, as discussed in Section 6.0, Quality ControlOrganization. The three phases are as follows:

9.1 Preparatory Phase

The preparatory meeting will be performed prior to beginning work on each DFW, after all required plans/documents/materials are approved, and after copies are at the work site.

Specifically, this phase will include:

� Review of each paragraph of applicable specifications, reference codes and standards.

� Review of the project shop drawings.

� Review to ensure that all materials and/or equipment have been tested, submitted, and approved.

� Review of provisions that have been made to provide required control inspection and testing.

� Examine the work area to ensure that all required preliminary work has been completed in compliance with the contract.

� Physically examine all required materials, equipment and sample work to ensure that they are available, conform to approved shop drawings or submitted data, and are properly stored.

� Review of the appropriate activity hazard analysis to ensure safety requirements are met.

� Discuss procedures for controlling quality of the work including detection of repetitive deficiencies. Establish construction tolerances and workmanship standards for this DFW.

� Check to ensure the portion of the plan for the work to be performed has been accepted by the Contracting Officer or her/his designee.

� Discuss the initial control phase.


� Notify the COR 48 hours in advance of the beginning the preparatory control phase. This phase include a meeting conducted by the CQCSM and attended by the SS, other CQC personnel as required and the Foremen responsible of the DFW. The results of the preparatory phase actions will be documented by separate minutes prepared by the CQCSM and attached to the Daily CQC report and supporting forms presented in Appendix B.

9.2 Initial Phase

This phase will be accomplished at the start of a DFW. The following will be accomplished during this phase:

� Check the work to ensure it is in full compliance with the project requirements. Review minutes of the preparatory meeting

� Verify adequacy of controls to ensure full project compliance. Verify required control inspection and testing are being performed

� Establish level of workmanship and verify it meets the desired acceptable workmanship standards. Compare with required sample panels as appropriate

� Resolve all differences

� Check safety to include compliance with an upgrading (if necessary) of the APPand activity hazard analysis. Review the activity hazard analysis with each worker

� Notify the Contracting Officer Representative in advance of the beginning the initial control phase. The results of the initial phase actions will be documented by separate minutes prepared by the CQCSM and attached to the Daily CQC report and supporting forms presented in Appendix B.

� The initial phase will be repeated for each new crew to work onsite, or any time acceptable specified quality standards are not being met.

9.3 Follow-up Phase

Follow-up inspection and testing is geared toward a level of effort to verify the continuation of project compliance and standards of workmanship established during the previous two phases. If a thorough job has been done during the preparatory and initial phases, the follow-up phase can be efficient and productive. Daily checks will be made a matter of record in the CQC documentation for each DFW. Final follow-up checks will be conducted and all deficiencies will be corrected before the start of additional DFWs that may be affected by the deficient work. Documentation of the CQC process, including DQCR, a narrative description of detailed CQC inspection procedure, minutes


of meetings, inspection results, corrective measures, etc., is prepared using the supportingforms presented in Appendix B.

9.4 Additional Preparatory and Initial Phases

Additional preparatory and initial inspections will be conducted on the same DFW if the quality of ongoing work is unacceptable, if there are changes in the applicable CQC staff, onsite supervision or work crew, if work on a DFW is resumed after a substantial period of inactivity, or if other problems develop.


10.0 COMPLETION INSPECTION

10.1 Punch List

Near the completion of the work, or when indicated in the specifications, the CQCSM shall conduct an inspection of the work. A punch list of items that do not conform to the approved drawings and specifications shall be prepared and included in the CQC documentation, as required by section 12, Documentation. The list of deficiencies shall include the estimated date by which the deficiencies will be corrected. The CQCSM or staff will make a second inspection to ascertain that all deficiencies have been corrected. Once this is accomplished, the CQCSM will notify the Government that the facility is ready for the Government Pre-Final Inspection.

10.2 Pre-Final Inspection

The Government and CQCSM will perform the pre-final inspection to verify that work was in completed in accordance with Contract No. W912WJ-11-D-0010, Delivery Order No. 0003. Agovernment Pre-final punch list may be developed as a result of this inspection. The CQCSM will ensure that all items on this list have been corrected before notifying the Government so that a final inspection with the client can be scheduled. Any items on the Pre-Final inspections will be corrected in a timely manner. These inspections and any deficiency corrections required by this paragraph shall be accomplished within the time slated for completion of the entire work or any particular increment of the work if the project is divided into increments by separate completion dates.

10.3 Final Acceptance Inspection

The KGS PM will notify the USACE representative when all deficiencies of the punch list have been corrected. Based upon this notice, the USACE COR will formally schedule the final acceptance inspection. The COR will be notified of the scheduled date at least 14 days prior to the final acceptance inspection, and will include KGS’s assurance that all specific itemspreviously identified are acceptable, along with all remaining work under the contract. TheCQCSM, SS, and the COR will be in attendance at the final acceptance inspection. If necessary, the property owner will attend the final inspection. After acceptance, the work will be under warrant for one year.


11.0 DOCUMENTATION

CQC records are the primary means of documenting and reporting construction quality and conformance to contract documents. This section outlines the general procedures to be followed for the identification, use, handling, filing, storage, and disposition of CQC records.

11.1 Responsibility

The CQCSM will complete and maintain CQC records including maintaining a record of all tests and inspections performed to provide factual evidence of compliance with project requirements and to document all CQC activities. These records include all work performed by subcontractors and suppliers. The CQCSM will sign each report and provide copies to the QCM and the USACE COR.

Records will be consistent with applicable codes, specifications, and contracts, and will be adequate for use in management of the project. Inspection and test records will identify the inspector or data recorders, the type of observation, the results, and the acceptability or action taken in connection with any deficiency.

11.2 Requirements

Individual inspections, tests, and/or observations will be scheduled at pre-determined points in the project. The proper documentation to record these activities will be compiled by the CQCSM or another designated CQC team member and discussed with the testing personnel before execution. The CQCSM or another designated CQC Team member will monitor the testing process and document progress and observations in the CQC logbook. This information will be summarized in the DQCR provided to the USACE Representative, Site Superintendent,and CQCSM.

11.3 CQC Reports and Records

The CQCSM will complete and maintain CQC records to provide factual evidence of compliance with project requirements and to document all CQC activities including maintaining a record of all tests and inspections performed. These records include all work performed by subcontractors and suppliers. The CQCSM will sign each report and provide copies to the PJE, QCM, and the USACE representative. The primary CQC reports are listed below.

Daily Quality Control Report (DQCR)

A DQCR is completed for each day of activity and includes:

� Description and location of the work performed today

� Weather conditions

� Identification of each subcontractor performing work on the project that day, identification of the work performed, references to specific project requirements,


and identification of the inspections performed including the control phase (preparatory, initial, follow-up)

� Test and control activities performed, including results, references to specific project requirements, and identification of the control phase (preparatory, initial, follow-up)

� Field change requests

� Documentation of the monitoring of receipt, storage, and use of materials and equipment at the site (including quantities)

� Job safety evaluations stating what was checked, results, and instructions or corrective actions

� Remarks (e.g., instructions given or received, conflicts identified between plans, specifications, and instructions, conflict resolution, etc.)

� Submittals reviewed and actions taken

� Contractor’s statement verifying compliance with contract documents

� Attachments, including site meeting minutes, inspection checklists, testing procedures and results, etc.

Field Change Report (FCR)

An FCR is completed when changes in the project work or site conditions impacting previously approved plans or the SOW are identified. The proposed or actual changes documented in the FCR will be reviewed by the responsible technical staff, SS, and PM. Upon resolution, each signs the FCR and the PM forwards the FCR to the USACE representative for review, approval, and processing. Information provided on the FCR includes:

� A description of the needed change

� The reason the change is necessary, including consequences of failing to implement the change

� Cost of materials, labor, and equipment to implement the change, and the total cost with overhead, fee, etc.

� Identification of other work that will be affected by the change.


Nonconformance Report (NCR)

An NCR is completed when work failing to meet project requirements is identified. Information provided on the NCR includes areas for:

� Description of the nonconformance, including who identified it and the date it was identified

� Description of the proposed corrective action, including who will perform the corrective action and the date it will be completed

� Description of the completed corrective action, including who performed the corrective action, the date of completion, who verified correction of the noncompliance, and the date of the verification.

11.4 Forms and Records

In addition to the CQC reports described in the previous section, the CQCSM or another designated CQC Team member will witness all required field testing and sign the appropriate forms for the work to be accepted. All forms will be filled out completely and be signed and dated before submittal for review and approval. Subcontractors will fill out the appropriate forms and submit them upon completion of each task, rather than hold them until the end of the project.

Inspection and testing forms will identify the equipment, materials, or installations involved. Installation and maintenance checklists will be marked where applicable. Locations, orientations, elevations, test parameters, test results, and other comments will be included on the forms, as appropriate. Forms are to be dated and signed by the person performing the observation, inspection, or test and by the CQCSM. They will be submitted to the PM for approval. Critical items such as impacts to cost and schedule, in addition to deficiencies and corrective actions will be clearly and concisely stated.

The CQCSM will also maintain appropriate CQC records, including:

� Copies of approved submittals� Personnel training records, qualifications, and certifications� Design drawings with “as-built” changes marked on them� Engineering/Manufacturer specifications.


12.0 CONTROL OF DOCUMENTATION

A standard records management and document control system will be used. The PM is responsible for implementing the system for the entire project and the Site Superintendent is responsible for carrying these practices to the field. Elements of the records management and document control system include:

� Controlled access

� Master index system (Attachment D - Submittal Register)

� Logging and issuing of document numbers

� Method to determine status of documents in progress

� Standardized procedures/forms

� Proper storage of documents

� Retrieval

� Archiving

� Retirement.

Project records will be maintained in a safe and retrievable manner until project closeout. Documents, records and working files will be provided to the client in physical and electronic formats, in accordance with contract and task requirements. Following project closeout, all project documents and records will be archived. Archived records will be protected from loss or damage for 5 years or as specified by the government.


13.0 NONCONFORMANCE AND CORRECTIVE ACTION

It is important for every identified nonconforming material, assembly, or construction method to be corrected through systematic actions. Any time a condition exists not in compliance with drawings, specifications, codes, workmanship standards, or USACE requirements, the nonconformity must be eliminated. The CQCSM will take the following actions:

� Notify the KGS PM and subcontractor (if appropriate) to initiate prompt corrective action

� Document the discrepancies that cannot be corrected immediately by verbal instructions on an NCR form. A detailed description of the item or condition failing to meet drawing or specification requirements will be given with an explanation of conditions at the time of failure and its probable cause

� Coordinate with the QCM, PM, and subcontractor (if appropriate) to evaluate discrepancies, determine and implement the appropriate corrective action, and identify corrective measures to prevent recurrence of the problem

� Repeat the inspection after the corrective action is complete

� Note on the Final Acceptance Report any retesting required and performed, nondestructive examination required and performed, or changes in identification of any replacement part used in correcting the problem.

A distribution list for discrepancy reports will be determined at the initial project-planning meeting. At a minimum, distribution will include the USACE Representative, KGS PM, PJE, SS, and CQCSM.


14.0 DEFICIENCY TRACKING SYSTEM

The KGS CQC process will identify deficiencies throughout the project. These deficiencies willbe tracked using the Deficiency Tracking Log. A list of deficiencies will be numerically tracked using the QC punch list items. The punch list gives KGS a means to communicate to the USACE comments resulting from an inspection, site visit, or various other reviews. This communication is a record keeping system, also referred to as a Deficiency Tracking System.

The USACE will log the deficiencies it has identified using its QA punch list items. The QA Punch List items give the USACE a means to communicate any noted deficiencies to KGS.Using the Punch List, the Government can draw KGS’s attention to an overlooked item. As the comment is issued as an action item, the comment is placed on the QC list to be corrected by KGS, reported corrected by KGS, and then verified by the USACE. The USACE QA punch list items will be included in the KGS DQCR. KGS will acknowledge receipt of these QA punch list items by specific number reference on the DQCR. KGS will update the correction status of both QC and QA punch list items on a weekly basis.


15.0 APPROVALS

By their signature, the following individuals certify their review and approval of this Contractor Quality Control Plan for the Remedial Action and Project Closeout Activities at Lyndonville Former Air Force Station, East Haven, Vermont.

Signature Date

17 Oct 2016

Mr. Ed King, PEKGS Program Manager

17 Oct 2016Mr. Gregory BirchKGS Project Manager

17 Oct 2016

Mr. Eric LynchContractor Quality Control Systems Manager

TABLE 1SCHEDULE OF QC OBSERVATIONS

BY DEFINABLE FEATURE OF WORK (DFW)

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K: P

re–M

obili

zatio

nA

ctiv

ities

QC

TA

SKIN

SPE

CT

ION

AC

TIV

ITY

TE

ST F

RE

QU

EN

CY

or

OB

SER

VA

TIO

N

DE

SCR

IPT

ION

AC

CE

PTA

NC

E

CR

ITE

RIA

PRE

PAR

ATO

RY

PHA

SE

Not

ify U

SAC

E N

ew E

ngla

ndD

istri

ct o

f sch

edul

eSc

hedu

le o

n si

te a

ctiv

ities

.O

ne ti

me

per m

obili

zatio

n.

Obt

ain

site

ent

ry a

utho

rizat

ion

Subm

it re

quire

d in

form

atio

n to

pro

perty

ow

ners

.

One

tim

e.

USA

CE

CO

R

appr

oval

Prec

onst

ruct

ion

Mee

ting

Prep

are

agen

da a

nd

sche

dule

mee

ting(

s).

One

tim

e.

Iden

tify

area

of a

ctiv

ity, a

nd

utili

ty c

lear

ance

Obs

erva

tion:

Ens

ure

prop

er a

sses

smen

t of

utili

ties.

“One

Cal

l / D

ig

Safe

” be

fore

and

sche

dule

ut

ility

cle

aran

ce fo

r the

co

nstru

ctio

n ar

ea.

One

tim

e, a

nd a

s nee

ded.

INIT

IAL

PHA

SE

Prec

onst

ruct

ion

Mee

ting

Rev

iew

all

site

act

iviti

es to

be

per

form

ed in

clud

ing

QC

and

safe

ty is

sues

.

One

tim

e.

Iden

tify

area

of a

ctiv

ity a

nd

utili

ty lo

catio

nR

evie

w: m

arks

of u

tility

lo

catio

n, (u

nder

grou

nd a

nd

over

head

).

Ensu

re m

arks

are

in p

rope

r lo

catio

n.C

OR

, SS.

and

QC

O

ffic

er a

gree

qu

ality

stan

dard

s ar

e m

etF

OLL

OW

-UP

PHA

SEPr

econ

stru

ctio

n M

eetin

gD

istri

bute

mee

ting

min

utes

to

stak

ehol

ders

.O

ne ti

me.

Iden

tify

area

of a

ctiv

ity a

nd u

tility

lo

catio

nR

evie

w/O

bser

vatio

n.En

sure

util

ities

are

iden

tifie

d.

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K:

Mob

iliza

tion

and

Site

Pre

para

tion

QC

TA

SKIN

SPE

CT

ION

AC

TIV

ITY

TE

ST F

RE

QU

EN

CY

or

OB

SER

VA

TIO

N

DE

SCR

IPT

ION

AC

CE

PTA

NC

E

CR

ITE

RIA

PRE

PAR

ATO

RY

PHA

SER

evie

w d

raw

ings

and

app

rove

d pl

ans.

Rev

iew

and

dis

cuss

ion.

Rev

iew

all

test

ing

and

insp

ectio

n re

quire

men

ts.

Ensu

re a

ll su

bmitt

als h

ave

been

su

bmitt

ed a

nd a

ppro

ved

befo

re w

ork

is

allo

wed

to st

art.

Rev

iew

AH

As.

Che

ck

on p

revi

ous D

FW.

Mat

eria

ls a

nd e

quip

men

tPh

ysic

al e

xam

inat

ion

of a

ll de

liver

ed m

ater

ials

, eq

uipm

ent,

com

pute

rs, f

urni

ture

, tra

ilers

, etc

. to

ensu

re c

ompl

ianc

e w

ith sp

ecifi

catio

ns, g

ood

cond

ition

s and

pro

perly

stor

ed.

On

goin

g.Sp

ec S

ectio

n

Wor

k ar

ea

Exam

ine

wor

k ar

ea, a

nd e

nsur

e al

l req

uire

d sa

fety

item

s are

com

plet

e an

d in

com

plia

nce.

En

sure

all

requ

ired

prel

imin

ary

wor

k is

com

plet

e an

d in

com

plia

nce.

Ens

ure

all p

relim

inar

y la

yout

wor

k is

com

plet

e an

d in

com

plia

nce

One

tim

e.

Dis

cuss

ion

of sp

ecifi

c Q

C in

spec

tion

poin

ts, r

equi

red

leve

l or w

orkm

ansh

ip

and

initi

al c

ontro

l pha

se o

pera

tions

.

Rev

iew

and

dis

cuss

ion.

INIT

IAL

PHA

SEO

bser

ve in

stal

latio

n of

tem

pora

ry

utili

ties,

traile

rs, e

quip

men

t, et

c. fo

r co

nfor

man

ce to

con

tract

requ

irem

ents

.

Obs

erva

tion

Test

for p

rope

r ope

ratio

n of

all

tem

pora

ry u

tiliti

es a

nd o

f all

supp

lied

equi

pmen

t and

syst

ems

in a

ccor

danc

e w

ith c

ontra

ct

docu

men

ts a

nd a

ppro

ved

subm

ittal

s.

Inst

alla

tions

are

in a

ccor

danc

e w

ith a

ll ap

plic

able

cod

es,

man

ufac

ture

r’s

reco

mm

enda

tions

, app

rove

d su

bmitt

als a

nd u

tility

au

thor

ities

’ req

uire

men

ts.

Surv

eyin

gO

bser

vatio

n. E

nsur

e pr

oper

ben

chm

arks

id

entif

icat

ion

for e

ach

site

wor

k (e

ast &

wes

t si

des)

CO

R, S

S. a

nd Q

C O

ffic

er

agre

e qu

ality

stan

dard

s are

m

etV

erify

that

agr

eed-

upon

leve

l of

wor

kman

ship

is a

chie

ved.

Obs

erva

tion

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K:

Mob

iliza

tion

and

Site

Pre

para

tion

(Con

tinua

tion)

FO

LLO

W-U

P PH

ASE

Rev

iew

AH

As a

nd d

eter

min

e if

revi

sion

to sa

fety

pro

cedu

res i

s re

quire

d.

Rev

iew

and

dis

cuss

ion.

Obs

erve

ope

ratio

n of

all

equi

pmen

t, sy

stem

s and

serv

ice

utili

ties.

Obs

erva

tion

Obs

erve

that

all

syst

ems,

equi

pmen

t and

util

ities

co

ntin

ue to

func

tion

prop

erly

an

d as

requ

ired

by c

ontra

ct

docu

men

ts a

nd a

ppro

ved

subm

ittal

s.Su

rvey

ing.

O

bser

vatio

n. A

t the

end

of t

he su

rvey

:�

Ensu

re p

rope

r ben

chm

arks

wer

e lo

cate

d.�

Esta

blis

h co

ntro

l poi

nts f

or u

se d

urin

g th

e lif

e of

the

proj

ects

Ong

oing

.Q

ualit

y fr

om in

itial

pha

se is

m

aint

aine

d

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K:

Pre-

Des

ign

Inve

stig

atio

n / S

oil S

ampl

ing

QC

TA

SKIN

SPE

CT

ION

AC

TIV

ITY

TE

ST F

RE

QU

EN

CY

or

OB

SER

VA

TIO

N

DE

SCR

IPT

ION

AC

CE

PTA

NC

E

CR

ITE

RIA

PRE

PAR

ATO

RY

PHA

SER

evie

w a

ppro

ved

plan

s and

dr

awin

gs.

Rev

iew

and

dis

cuss

ion.

Rev

iew

AH

As

Ensu

re a

ll su

bmitt

als h

ave

been

su

bmitt

ed a

nd a

ppro

ved

befo

re

wor

k is

allo

wed

to st

art.

Rev

iew

as a

min

imum

th

e fo

llow

ing

sect

ions

of

the

Wor

k Pl

anan

d Er

osio

n an

d Se

dim

enta

tion

Con

trol

Plan

(if re

quire

d).

Rev

iew

mat

eria

ls a

nd e

quip

men

t Ph

ysic

al in

spec

tion

of m

ater

ials

. Ens

ure

they

m

eet p

lan

requ

irem

ents

,are

pro

perly

stor

edan

d al

l mat

eria

l are

on-

site

bef

ore

com

men

cing

w

ork.

Ong

oing

.

Che

ck w

ork

area

Ex

amin

e w

ork

area

, and

ens

ure

all r

equi

red

safe

ty it

ems a

nd p

relim

inar

y w

ork

are

com

plet

e an

d in

com

plia

nce.

Ens

ure

spill

re

spon

se e

quip

men

t is k

ept o

nsite

dur

ing

cons

truct

ion.

Ong

oing

.

INIT

IAL

PHA

SE

Eros

ion

and

Sedi

men

t Con

trols

(if

requ

ired)

Che

ck a

pplic

able

E&

SC a

relo

cate

d in

ac

cord

ance

with

the

limits

of d

istu

rban

ce.

Ensu

re te

mpo

rary

layd

own

area

islo

cate

d ac

cord

ing

to d

raw

ings

and

pla

ns.

Ong

oing

.U

SAC

E PO

C, S

S,

CQ

CSM

agr

ees o

n qu

ality

of w

orkm

ansh

ip

Soil

Sam

plin

gV

erify

soil

sam

plin

g (e

quip

men

t is

deco

ntam

inat

ed, s

ampl

es a

re c

olle

cted

, co

ntai

neriz

ed, p

acka

ged

and

ship

ped)

is

cond

ucte

d pe

r pla

ns a

nd re

quire

men

ts (Q

APP

/ SA

P).

Ong

oing

.U

SAC

E PO

C, S

S,

CQ

CSM

agr

ees o

n qu

ality

of w

orkm

ansh

ip

FO

LLO

W-U

P PH

ASE

Che

ck w

ork

area

En

sure

ero

sion

and

sedi

men

t con

trol r

emai

ns

curr

ent a

s sta

ted

in In

itial

Pha

se.

Ong

oing

in a

ccor

danc

e w

ith th

e W

P.

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K:

Exc

avat

ion

of C

onta

min

ated

Soi

l(an

d op

tion

for

addi

tiona

l soi

l exc

avat

ion)

QC

TA

SKIN

SPE

CT

ION

A

CT

IVIT

YT

EST

FR

EQ

UE

NC

Y o

rO

BSE

RV

AT

ION

DE

SCR

IPT

ION

AC

CE

PTA

NC

E

CR

ITE

RIA

PRE

PAR

ATO

RY

PHA

SER

evie

w a

ppro

ved

plan

s.O

ne ti

me.

Ensu

re a

ll eq

uipm

ent &

met

hods

ha

ve b

een

subm

itted

and

ap

prov

ed.

Rev

iew

.O

ne ti

me.

INIT

IAL

PHA

SEO

bser

ve a

ll ex

cava

tion

oper

atio

ns.

Obs

erve

.C

ontin

uous

Obs

erve

exc

avat

ion

limits

/ de

pths

to c

lean

soil.

Obs

erve

.C

ontin

uous

Obs

erve

stoc

kpili

ng /

load

ing

of so

il in

to

truck

s and

dec

onta

min

atio

n of

truc

ks (a

s ne

cess

ary)

prio

r to

depa

rting

site

.

Obs

erve

.C

ontin

uous

Vis

ual I

nspe

ctio

n in

ac

cord

ance

with

pla

ns

FO

LLO

W-U

P PH

ASE

Obs

erve

all

exca

vatio

n op

erat

ions

.O

bser

ve.

On

goin

g.O

bser

ve e

xcav

atio

n lim

its /

dept

hs to

cl

ean

soil.

Obs

erve

.O

n go

ing.

Obs

erve

stoc

kpili

ng /

load

ing

of so

il in

to

truck

s and

dec

onta

min

atio

n of

truc

ks (a

s ne

cess

ary)

prio

r to

depa

rting

site

.

Obs

erve

.O

n go

ing.

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K: P

ost-

Exc

avat

ion

(Con

firm

atio

n) S

oil S

ampl

ing

and

Ana

lysi

sQ

C T

ASK

INSP

EC

TIO

N A

CT

IVIT

YT

EST

FR

EQ

UE

NC

Y o

rO

BSE

RV

AT

ION

D

ESC

RIP

TIO

N

AC

CE

PTA

NC

E C

RIT

ER

IA

PRE

PAR

ATO

RY

PHA

SER

evie

w la

yout

dra

win

gs,

appl

icab

le sp

ecifi

catio

ns a

nd

appr

oved

pla

ns.

Rev

iew

and

dis

cuss

ion

of a

ll te

stin

g an

d in

spec

tion

requ

irem

ents

and

ens

ure

all s

ubm

ittal

s ha

ve b

een

subm

itted

and

app

rove

d by

the

requ

ired

appr

ovin

g au

thor

ity b

efor

e w

ork

is

allo

wed

to st

art.

Rev

iew

AH

As a

nd d

iscu

ssio

n.

One

tim

e.

Mat

eria

ls a

nd e

quip

men

t.R

evie

w a

nd e

nsur

e th

at m

ater

ials

and

equ

ipm

ent

have

bee

n su

bmitt

ed, a

ppro

ved,

in g

ood

wor

king

co

nditi

ons f

or th

e ta

sk a

t han

d.

Plan

s and

subm

ittal

s

Exam

ine

wor

k ar

ea.

Obs

erva

tion.

Ens

ure

all r

equi

red

prel

imin

ary

layo

ut w

ork

is c

ompl

ete

and

in c

ompl

ianc

e.O

ne ti

me.

Dis

cuss

ion

of sp

ecifi

c Q

C

insp

ectio

n po

ints

, req

uire

d le

vel

of w

orkm

ansh

ip a

nd in

itial

co

ntro

l pha

se o

pera

tions

.

Rev

iew

and

dis

cuss

ion.

One

tim

e.

Site

logi

stic

sR

evie

w, d

iscu

ss a

nd id

entif

y al

l exi

stin

g st

ruct

ures

, ter

rain

, enc

umbr

ance

s etc

.with

in th

e ar

ea o

f wor

k as

des

crib

ed w

ithin

the

plan

stha

t re

quire

may

requ

ire m

onito

ring

durin

g co

nstru

ctio

n ac

tiviti

es.

One

tim

e.Pl

ans a

nd su

bmitt

als

INIT

IAL

PHA

SEIn

spec

t equ

ipm

ent f

or o

pera

tion.

Obs

erva

tion.

Che

ck sa

fety

gui

des,

equi

pmen

t op

erat

ion.

Ong

oing

.

Site

logi

stic

sO

bser

vatio

n. C

ontin

ued

mon

itorin

g of

stru

ctur

es,

terr

ain,

enc

umbr

ance

s etc

. with

in th

e ar

ea o

f w

ork.

Ong

oing

.

Con

firm

atio

n Sa

mpl

ing

Obs

erva

tion.

Con

firm

com

plia

nce

with

QA

PP /

SAP.

Ong

oing

.Pl

ans a

nd su

bmitt

als

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K: P

ost-

Exc

avat

ion

Soil

Sam

plin

g an

d A

naly

sis(C

ontin

uatio

n)

FO

LLO

W-U

P PH

ASE

Insp

ect e

quip

men

t for

ope

ratio

nan

d de

cont

amin

atio

n.O

bser

vatio

n. C

heck

safe

ty g

uide

s, eq

uipm

ent

oper

atio

n.O

ngoi

ng.

Plan

s.

Site

logi

stic

sO

bser

vatio

n. C

ontin

ued

mon

itorin

g of

stru

ctur

es,

terr

ain,

enc

umbr

ance

s etc

. with

in th

e ar

ea o

f w

ork.

Ong

oing

.

Con

firm

atio

n Sa

mpl

ing

Obs

erva

tion.

Con

firm

com

plia

nce

with

QA

PP /

SAP.

Ong

oing

.

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K:

Mon

itori

ng W

ell D

ecom

mis

sion

ing

(& o

ptio

n -W

ater

Sup

ply

Wel

l Dec

omm

issi

onin

g)

QC

TA

SKIN

SPE

CT

ION

AC

TIV

ITY

TE

ST F

RE

QU

EN

CY

or

OB

SER

VA

TIO

N D

ESC

RIP

TIO

NA

CC

EPT

AN

CE

CR

ITE

RIA

PRE

PAR

ATO

RY

PHA

SER

evie

w a

ppro

ved

plan

s.R

evie

w a

nd d

iscu

ssio

n of

de

com

mis

sion

ing

para

met

ers a

nd p

erm

it re

quire

men

ts

One

tim

e.

Plan

s

Mat

eria

ls a

nd e

quip

men

tPh

ysic

al e

xam

inat

ion

of a

ll de

liver

ed

mat

eria

ls a

nd e

quip

men

t to

ensu

re

com

plia

nce

with

requ

irem

ents

, goo

d co

nditi

on a

nd p

rope

rly st

ored

.

One

tim

e.Su

bmitt

als

Wor

k ar

eaO

bser

vatio

n, e

nsur

e al

l req

uire

d pr

elim

inar

y la

yout

wor

k is

com

plet

e an

d in

com

plia

nce.

One

tim

e.

Dis

cuss

ion

of sp

ecifi

c Q

C in

spec

tion

poin

ts, r

equi

red

leve

l of w

orkm

ansh

ip

and

initi

al c

ontro

l pha

se o

pera

tions

.

Rev

iew

and

dis

cuss

ion.

INIT

IAL

PHA

SEO

bser

ve w

ell d

ecom

mis

sion

ing

activ

ities

.O

bser

vatio

nO

ngoi

ng.

In a

ccor

danc

e w

ith

plan

s.F

OLL

OW

-UP

PHA

SEO

bser

ve w

ell d

ecom

mis

sion

ing

activ

ities

(incl

udin

g do

cum

enta

tion)

.O

bser

vatio

nO

ngoi

ng.

In a

ccor

danc

e w

ith

plan

s.A

s-bu

ilt d

raw

ings

Ver

ifica

tion

Ong

oing

.In

acc

orda

nce

with

pl

ans.

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

G B

Y D

EFI

NA

BL

E F

EA

TU

RE

OF

WO

RK

DE

FIN

AB

LE

FE

AT

UR

E O

F W

OR

K:

Site

Res

tora

tion

QC

TA

SKIN

SPE

CT

ION

AC

TIV

ITY

TE

ST F

RE

QU

EN

CY

or

OB

SER

VA

TIO

N D

ESC

RIP

TIO

NA

CC

EPT

AN

CE

C

RIT

ER

IAPR

EPA

RA

TOR

Y PH

ASE

Rev

iew

app

rove

d pl

ans.

Rev

iew

and

dis

cuss

ion

to id

entif

y al

l ar

eas t

hat m

ust b

e re

stor

ed to

pre

-co

nstru

ctio

n co

nditi

ons

One

tim

e.

Spec

Sec

tion

Mat

eria

ls a

nd e

quip

men

tPh

ysic

al e

xam

inat

ion

of a

ll de

liver

ed

mat

eria

ls a

nd e

quip

men

t to

ensu

re

com

plia

nce

with

requ

irem

ents

, goo

d co

nditi

on a

nd p

rope

rly st

ored

.

One

tim

e.Su

bmitt

als

Wor

k ar

eaO

bser

vatio

n, e

nsur

e al

l req

uire

d pr

elim

inar

y la

yout

wor

k is

com

plet

e an

d in

com

plia

nce.

One

tim

e.

Dis

cuss

ion

of sp

ecifi

c Q

C in

spec

tion

poin

ts, r

equi

red

leve

l of w

orkm

ansh

ip

and

initi

al c

ontro

l pha

se o

pera

tions

.

Rev

iew

and

dis

cuss

ion.

INIT

IAL

PHA

SEO

bser

ve p

repa

ratio

n, b

ackf

illin

g,

grad

ing

exca

vatio

n ar

easa

nd

plac

emen

t of v

eget

ativ

e co

ver.

Obs

erva

tion

Ong

oing

.In

acc

orda

nce

with

pl

ans.

FO

LLO

W-U

P PH

ASE

Obs

erve

cle

an-u

p an

d re

stor

atio

n of

di

stur

bed

grou

nd b

y m

aint

enan

ce a

nd

rem

oval

of t

empo

rary

ero

sion

con

trol

(if re

quire

d) w

hen

surf

aces

are

re

stor

ed.

Obs

erva

tion

Ong

oing

.A

s req

uire

d by

pla

ns.

Tab

le 1

-Sc

hedu

le o

f QC

Obs

erva

tions

and

Tes

ting

by D

efin

able

Fea

ture

of W

ork

(DFW

)

Dra

ft Co

ntra

ctor

Qua

lity

Con

trol

Pla

nK

GS

Lynd

onvi

lle F

AFS

Rem

edia

l Act

ion

and

Proj

ect C

lose

out A

ctiv

ities

Oct

ober

2016

East

Hav

en,V

T

SCH

ED

UL

E O

F Q

C O

BSE

RV

AT

ION

S A

ND

TE

STIN

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APPENDIX ACONTRACTOR QUALITY CONTROL MANAGER

APPOINTMENT LETTERAND

RESUMES OF PROJECT STAFF

160 East Main Street, Suite 2F, Westborough, MA 01581 – T 508.366.7442 – F 508.366.7445 – www.komangs.com

October 17, 2016

Eric Lynch / Kim Watson160 East Main Street, Suite 2FWestborough, MA 01581

Subject: Appointment Letter – CQCSM/SSHO AuthorityRemedial Action and Project Closeout Activities at the Lyndonville Former Air Force Station,East Haven, VermontContract Number W912WJ-16-C-0020, Delivery Order 0000

Dear Mr. Lynch and Ms. Watson:

This letter is to authorize Mr. Lynch to act for KGS Environmental, Inc. (H&S) as the primary Contractor Quality Control Systems Manager (CQCSM) and Site Safety and Health Officer (SSHO) for the above referenced project. Mr. Lynch will have no other duties other than those specified for the CQCSM/SSHO. He is authorized to act on KGS’ behalf to manage and implement the QC Program as described in the referenced contract in the following manner:

� Perform all QCM/SSHO duties on the project.� Direct work to ensure compliance with the approved statement of work, work plan, drawings,

specifications, and applicable regulations.� Stop work which is not in compliance with the contract.� Direct the removal and replacement of non-conforming work.� Designate and supervise QC task managers, as necessary.� Prepare and submit project submittals.� Coordinate and supervise QC tests.� Prepare daily activity reports.

Ms. Watson will serve as the alternate CQCSM/SSHO, and will have all duties assigned above when performing the role of CQCSM/SSHO.

If you have any questions, please feel free to contact me at (484) 437-6644 or Greg Birch (KGS Project Manager) at (302) 373-5724.

Sincerely,H&S Environmental, Inc.

Edward M. King, P.E.Vice President, Operations

Cc: D. Heims – KGSG. Birch – KGS

Eric R. Lynch – QC Manager / Site Safety and Health Officer

KGS Environmental

Education: University of Maryland, B.S. -

Industrial Technology, 1988

License(s)/Certification(s): � OSHA 40-HR HAZWOPER Supervisor � OSHA 10-HR Construction Safety Training � OSHA-30 HR Construction Safety Training � OSHA Permit Required Confined Space � American Red Cross First Aid and CPR Certified � USACE- Construction Quality Management for

Contractors

Work History: Years with Current Firm: 1 Total Years Experience: 25 Qualifications Highlights: � 25+ years of experience

implementing safety, occupational health and quality control for Construction Sites

� Contractor Quality Control Systems Manager (CQCSM) for over $75M of remediation/ construction projects, since 2001; completing all projects in compliance with quality control standards and contract specifications

� Inspected work site and activities to identify safety and health deficiencies, developed correction action plan and completed specified action;

� Conducted site-specific safety training, safety stand-down meetings, daily tailgate safety briefings, project specific safety and quality training, such as confined space entry training, lock-out / tag-out, equipment & material inspections

� Developed detailed safety and quality control daily reports documenting field activities including compliance issues, waste management, material tracking

� Performed personal and area monitoring/air sampling to insure potential contaminant isolation and proper PPE utilization

Experience: Site Safety & Health Manager/Contractor Quality Control Systems Manager (CQCSM), USACE Louisville District, Remediation Action at the Former Lockbourne AFB Landfill, Columbus, OH, $14.5M FFP, 2013 – 2015. Responsible for Safety & Quality Control on a $14.5M contract. Duties included implementation and execution of the corporate health and safety program, project specific safety plans, site security, daily tailgate safety meetings, monthly supervisors safety meetings, safety stand-down meetings to discuss unsafe acts/ conditions and develop & complete corrective actions for a former 72-acre AFB landfill with activities including excavation of military waste from trenches and consolidation of waste (landfill footprint reduction to 23.6 acres), backfill and grading of waste excavated areas with select fill, capping of waste consolidation area with cover soil clay, installation of a seep prevention trench collection system, groundwater monitoring well abandonment and installation, installation of drainage outflows and site restoration, and 5-year maintenance program. Additionally, duties included management of the QC system for all definable features of work including three-phase control inspections, material submittal development, progress and field inspections /verifications and testing, daily reporting, and as-built records development. USACE Kansas City District, Fried Industries Superfund Site, East Brunswick, NJ, $5.2M FFP, 2011 – 2012. Responsible for Safety & Quality Control for $5.4M cost fixed price contract for the erection of a groundwater treatment building including piling and concrete foundation, installation of groundwater extraction wells, trenching for supply piping, interior process piping, electric installation, automated controls, control room construction for PCE / TCE contaminated groundwater. USACE Kansas City District, Remedial Action, Rockaway Borough Well Field Superfund Site, East Main/Wall Street (OU-2), Morris County, NJ, $7.9M FFP, 2011 - 2012. Site Safety & Health Manager and Quality Control System Manager for building construction, process equipment and piping installation, SCADA control installation and startup. Responsibilities included daily safety training, safety inspections for all field activities, three phase QC inspections, submittal review, testing, and oversight of onsite quality control personnel. Insured compliance with the requirements identified in the PWS, Corporate Health & Safety Program, Site Safety & Health Plan and the Contractor QC Plan, work plans, drawings, specifications, and applicable regulations. Project involved design and construction of a GWTP to remove and treat groundwater contaminated with chlorinated solvents. This EPA Region 2 Fund-lead Superfund Site project involved installing groundwater extraction wells, piping, and a treatment system in residential, industrial, and commercial neighborhoods to treat the contamination.

AFCEE, Repair / Renovate Hangar 10. Joint Base Andrews Air Force Base, MD, $2.1M, 2010 - 2011. Site Safety & Health Officer & Quality Control System Manager for $2.1M cost fixed price contract for the repair & renovation of Hangar 10 (housing C-5 planes). Construction activities included interior demolition, demising wall relocation,

construction of new office space, locker rooms, maintenance shop, upgrade of the existing HVAC and ADAL fire suppression system.

U.S. Air Force Reserve Command (AFRC), Fire Suppression and Ceiling Repair, Alert Hangar, Homestead Air Reserve Base (ARB), FL, $1.7M FFP, 2009 – 2011. Safety Manager, Superintendent & CQCSM for DB project converting the existing non-functional aqueous film forming foam (AFFF) fire suppression system in the four hangar bays of Building 877 into a turnkey high-expansion foam fire suppression system. The work also included installing a fire alarm system and mass notification system for the entire building, as well as refurbishments and repairs ceilings and replacement of a personnel door.

USACE Louisville District, Construction of Special Operations Forces (SOF) Indoor Range, Fort Campbell, KY. Fort Campbell, KY, $5.4M FFP, 2008 – 2010. Safety Manager, Contractor Quality Control System Manager (CQCSM) and Assistant Superintendent for design/build (DB) project for removing and disposing of existing site structures and infrastructure and constructing a new single-story indoor range. Activities included demolition, site preparation, subgrade preparation, concrete foundation / slab / tilt-wall construction, split-face block exterior, erection of a standing seam metal roof, dust collection system, baffle / bullet trap / target system, electrical & fire suppression system, elevated control room construction.

Naval Facilities Engineering Command (NAVFAC) Southeast, Repairs to Building 596, Station Training Facility, Marine Corps Air Station (MCAS) Beaufort, SC, $2.2M, 2009– 2010. Site Safety Manager, QC Manager and Assistant Superintendent for renovation and repairs to a multi-story building that included providing temporary facilities for building occupants while repairs are being accomplished. Activities included Interior demolition & renovation of office spaces (wall construction, electric upgrades, flooring, HVAC with controls, restroom relocation, EFIS exterior and standing seam metal roof installation (SSMR).

AFCEC, Aero Club, Dover AFB, DE, $4.3M FFP, 2008 – 2009. CQCSM/SSHO/Assistant PM for DB of an aero club hangar and support spaces (approximately 5,825 square feet [sf]). Provided onsite oversight of S&H and QC while coordinating the efforts of our subcontractors. AFCEC, Repair Firing Range, Dover AFB, DE, $4.6M FFP (Adapt/Build), 2005 – 2007. SHSO/CQCSM. Demolished an existing 28-point firing range and constructed a new, fully enclosed, outdoor 21-point, 20,000 sf firing range. Oversaw safety and construction quality control of all project functions to ensure compliance with drawings and specifications for activities including demolition, site prep, concrete foundation / wall / slab construction, exterior split-face, HVAC, bullet trap & baffle construction, dust collection system, electric control system. Provided site specific safety training, daily tailgate safety meetings and implementation of the corporate safety program. Managed the submittal process to ensure compliance with the contract documents and conducted compliance inspections for quality (three-phase QC process) and safety. Developed and conducted bimonthly progress meetings and provided input to the PM on compliance issues. USACE Baltimore District, Source Area Remediation, Fort Drum, NY, $7.5M CPFF & FFP, 2002– 2007. Site Safety & Health Manager and Quality Control Supervisor. Responsible for project safety and quality including the design-build of three treatment systems addressing a free product plume extending from three former underground storage tank (UST) areas. The vadose zone in the area of the former USTs was impacted with petroleum hydrocarbons and LNAPL/petroleum hydrocarbons were present at the water table interface. Contaminated groundwater was discharging to a drainage channel onsite and had impacted both surface water and sediment. The project required trenchless excavation using micro-tunneling under State Highway 26 and

significant coordination with the New York State Department of Transportation (NYSDOT) to complete the work with no interruptions to traffic. Project completed on schedule with no deficiencies. This EPA Region 2 project was performed in accordance with USACE specifications and NYSDEC guidance and regulations. USACE Kansas City District, Rocky Hill Municipal Well/Montgomery Township Housing Development Superfund Sites, NJ, $3.7M FFP, 2003 – 2006. Site Safety & Health Officer and Quality Control Supervisor for the construction of a groundwater treatment facility including residential well abandonment and tie-in to city water. Responsible for project safety including overall site management of activities including clearing & grubbing, groundwater well installation, concrete foundation and slab construction, pre-engineered building erection, trenching and process piping installation, SCADA control system & electric and quality of design review, construction, system startup, and O&M of GWTF #1 and GWTF #2 to treat VOC contamination. System used contaminated groundwater extraction followed by onsite treatment and surface water discharge. Project completed on schedule with no deficiencies. This is an EPA Region 2 Fund-lead Superfund site project. USACE Philadelphia District, Rabbit Run Channel Reconstruction, Lipari Landfill, Pitman, NJ, $1.4M FFP, 2002 – 2003. Site Safety & Health Officer and Quality Control Supervisor. EPA Region 2 project to provide soil remediation/drainage channel reconstruction. Responsibilities included onsite safety and QC of project processes including site preparation, excavation, liner installation, and site restoration. CAPE developed Remedial Action Work Plan, Erosion and Sedimentation Control Plan, Waste Management Plan, SSHP, project specs, and design drawings. Implemented and executed the QC system, performed construction inspections, submittal review and processing, O&M Manual development for drainage channel excavation, liner installation, concrete weir construction, and channel restoration including Soil Conservation District permitting and completed on schedule with no deficiencies. USACE Kansas City District, Pre-Placed Remedial Action Contract (PRAC), Federal Creosote Site, Manville, NJ, 2000 – 2002). Site Safety and Health Officer for two abatement/demolition projects. Responsible for implementation of Site Safety and Health Plan (SSHP). Responsibilities included on site supervision of asbestos abatement before the demolition of buildings, capping utilities, and removal of landscaping. CAPE was responsible for the removal and disposal of all asbestos-containing materials (ACM). Conducted all S&H training including fit testing on site. Conducted daily “tailgate” safety meetings before starting work to identify specific hazards that might be encountered each day. Work was done in a densely populated residential area. CAPE had up to 25 employees and subcontractors on site at a time and with no S&H incidents at either task order (TO).

KKim Watson, RQAP-GLP / QA Manager / Health & Safety Officer

[email protected] / 802.229.2196 / www.stone-env.com 1

Ms. Watson has over 34 years of experience in all phases of production and laboratory procedures, quality control and quality assurance, QA management and project management in an environmental analytical laboratory in the context of EPA regulated environments (GLP, RCRA and CERCLA). She has over 24 years of experience in private quality assessment consulting, data and method validation, environmental project planning and coordination, field and laboratory audits, third party review, and single and double blind performance testing programs.

Employment History

Stone Environmental Inc., Montpelier, Vermont Quality Assurance Manager, 10/2001 – Present Health and Safety Officer, 2004-Present

Manages compliance with Good Laboratory Practices (GLP) and other Quality Assurance (QA) programs such as OECD GLPs. Manages and tracks regulatory requirements associated with The National Environmental Accreditation Program (NELAP), National Environmental Field Activities Program (NEFAP) under TNI (The NELAC Institute), and ISO 17025 Quality Standards. Supervises Stone’s QA/QC internal procedures, and performs both internal and external field and GLP audits. 2013-2015 Chair, NEFAP Executive Committee.

Acts as the Quality Assurance Unit (QAU) for EPA related environmental and agrochemical studies. Responsible for reviewing outgoing protocols/reports for GLP compliance. Assesses field activities assessors for compliance to NEFAP standards and ISO 17025 standards. Responsible for reviewing for compliance Environmental Impact Assessments (EIA) for veterinary medicines under the FDA.

Responsible for providing assistance in writing and reviewing Standard Operating Procedures (SOPs). Manages corporate quality practices and developed the Quality Management Plan (QMP), Quality Systems Manual (QSM) for Field Sampling and Analysis.

Responsible for developing and implementing quality systems for company processes both project and non-project related. Approves Site Specific and Generic Quality Assurance Project Plans (QAPPs).

Administers the Corporate Health and Safety Management Program; acts as a resource for employees of the company and manage the Safety Committee. Reviews all accident and injury reports and report to Safety Committee. Reviews and approves project-specific site Health and Safety Plans for field investigations. Trainer of staff (internal and external) on 29 CFR 1910.120 standards (8 Hr. OSHA refresher) and QA/GLP Standards.

Assists in conducting all aspects of pesticide fate and transport studies under FIFRA groundwater monitoring studies including database management and report writing. Has performed modeling scenarios in CXTFIT2, SETBACK, PRZM3, PE5, APEX and EXPRESS.

Project Management in QA Services with master service agreements with Phoenix Chemistry Services and other consultants which includes all Tiers of data validation, data assessment, data production and auditing (laboratory

Years of Experience / 35

Years of Experience at Stone / 15

Education B.S., Environmental Engineering Technology, cum laude, 1981, Norwich University, Vermont

Environmental Applications of Gas Chromatographic Mass Spectrometry, 1995, Indiana University

Professional Certifications Registered Quality Assurance Professional in Good Laboratory Practices, RQAP-GLP, April 2004 - 2017

Skills Current Trainer of 8-Hr Refresher of the 40-Hour (29 CFR 1910.120) OSHA health and safety training for hazardous waste operations and emergency response, November, 1995-present.

Trained auditor in laboratory and field sampling and measurement activities.

Trained in environmental and agrochemical sample collection and analysis; soil water and air.

Department of Justice, expert witness in environmental chemistry principals.

Honors and Awards Engineering Technology Award, Norwich University, 1981

Employee of the Month – April 19, 2006, September 2012 and December 2014

Professional and Community Activities See last page



audits, facility audits). Responsible for the marketing and sales of Stone’s QA services such as data validation and outside auditing and field inspections.

Severn Trent Laboratories (TestAmerica Burlington), Colchester, Vermont Quality Assurance Manager, 1997-2001

Responsible for the overall laboratory quality assurance. Responsible for the continuous development, documentation of QA procedures dealing with the day to day operation of the laboratory, and the implementation of the QA Program for inorganic and organic analyses of environmental samples.

Inchcape Testing Services, Aquatec Laboratory, South Burlington, Vermont GC/MS Data Review Group Leader, Chemistry Project Director, QA/QC Data Review Specialist, Extraction Lab Technician, 1983-1995

Responsible for a group of seven people working on the review of data, publication, and mass spectral interpretation. Analytical experience in the VOA HP5971A MSD GC/MS Systems.

Project Director for USEPA Special Analytical Service Solicitations Contracts, CLP government contracts, and other private client contracts.

LCIC (Love Canal) Habitability Study; reviewed final data deliverables and responsible for daily electronic upload of GC/MS analytical data to project bulletin board.

PCB Study, New Bedford, MA: Performed review and quality control of GC/MS analysis for the development of analytical procedures published in “Application of a Mixed-Method Analytical Scheme for Analysis of PCB in Water and Sediment Samples from a Polluted Estuary,” Richard A. McGrath, William Steinhauer and Siegfried Stockinger (1987)

Trillium, Inc. Home Office, Montpelier, Vermont Quality Assessment Manager, 4/1995-6/1997

Reviewed and validated CLP-type data packages generated in support of sampling analysis program at clients’ industrial/commercial plant sites. Validation was conducted in accordance with EPA’s National Functional Guidelines, regional guidelines, other agency procedures, method specific standard operating procedures, and professional judgment as appropriate.

Responsibilities included compilation and evaluation of site data from various on-site analytical programs. Gained experience in design and development of an on-site analytical laboratory.

Upon request from USEPA Region I, provided extensive review and comments on Parts I and II of the Region I, EPA-New England Data Validation Functional Guidelines for Evaluation Environmental Analyses.

Facilitated education seminars on environmental chemistry for Engineers and Lawyers.

Vermont Agency of Environmental Conservation Solid Waste Program, Montpelier, Vermont Air and Solid Waste Technician, 1981-1982

Responsible for the environmental engineering design of solid waste and waste disposal facilities and water quality monitoring at the solid waste facilities throughout the State of Vermont.

Publications and Presentat ions

Watson, Kim. 2016, NAICC, “Things I wish I knew when I started in QA”—Lab/Field Perspective, Panel Discussion.

Watson, Kim. 2014, Presented – NEMC Trials and Tribulations of Being a Mobile Laboratory – Methodologies and Accreditations.

Watson, Kim. Gaynor, Ph.D., Deborah, 2013, Presented – NEMC, Legal Defensibility of Data. How to Choose a Laboratory that Will Meet Your Data Assessment and Testing Needs?

Watson, Kim. 2013. TNI/NELAP – Presented / Article TNI-Newsletter, Organizations: What Are the Benefits of Accreditation?

Watson, Kim. May 2013. OELA – Presented TNI NEFAP- Field Sampling & Measurement Organization Accreditation Program



Watson, Kim & SQA EPA GLP Specialty Group. February 2005. GLP Inspection Experiences from the Regulated Communities Perspective. 2005 SQA World Conference.

Watson, Kim. April, 2004. The New NELAC and ELAB Update. Presented to SQA Annual Meeting.

Watson, Kim, 2004. Quality Assurance Training. Data Integrity Procedures and Ethics and Laboratory Quality Assurance. Full Day Workshop for ITLA (Independent Testing Laboratory Association), New England.

Watson, Kim. 2003. Manual Integration Basics, Techniques in Manual Integration. Presented to NY&PA AAEL August 2003

Watson, Kim. 2002. GOT ETHICS, Ethics Training, Fraud Prevention and Detection. Presented to NERCSQA November 2002.

Addit ional Education

Leadership Development and Communication Training, Co-Chair Market Segmentation Team, @1, November 2014-June 2015

Scientific Integrity in Federal Agencies Lessons from the Environmental Protection Agency, August 8, 2014

DOD Quality Systems Manual Training, January 30, 2014

GLP Training, Quality System Consultants, Inc. Patricia Royal, M.S.;D.A.B.T., QAP/GLP Registered, January 2002

Gearing Up for NELAP, National Laboratory Training Network, November 1998

Management Problems of the Technical Person in a Leadership Role, Fred Pryor Seminar, September 1997.

Supervisory Skills in Positive Discipline, October, 1997

Water Environment Federation, "Environmental Labs: Testing the Waters", Cincinnati, Ohio, August 13-16, 1995.

PACS Training Course in Mass Spectral Interpretation, May 4-6, 1994

Inchcape Managerial Skills Training Workshop I: April 12-13, 1993, Training Workshop II: July 7-8, 1994

Professional and Community Activit ies

TNI, The NELAC Institute, member 2001-present

NEFAP, National Environmental Field Activities Program Executive Committee, Chair, 2009-present

NEMC, National Environmental Monitoring Conference Succession Chair, 2013-2016

TNI NGAB, Non-Governmental Accreditation Body Committee Member, 2014-present

FSMO, Field Sampling Measurement Organization Standard Training (AB Evaluator Training), February 14, 2011; Member, 2007-present

NEMC/TNI, Session Chair, 2013, 2014, 2015.

NAICC, National Alliance of Independent Crop Consultants – Ethics Committee; GLP QA Committee; Member, 2013-present

ACS, American Chemical Society , member 1995-present

ASQ, American Society for Quality, member 1995-present

SQA, Society of Quality Assurance, member 2001-present

Uniform Federal Policy for Quality Assurance Project Plans Course #06042, 2006

TNI FSMO Standard Training (AB Evaluator Training): February 14, 2011

East Montpelier Planning Commission: Member (Elected), 2010-Present; Secretary, 2006-present

East Montpelier Development Review Board: Member (Appointed), 2010-present

Norwich University Engineering Society: President and Co-Founder of Chi Beta Chapter of Tau Alpha Phi

APPENDIX BCONTRACTOR QUALITY CONTROL SITE FORMS

__________________________________________________________________________________________________________________October 2016 KGS

320-1 SITE CONTROL LOG (SCL)Contract Number:Project Number DateContract Title

TIMENAME ORGANIZATION

In Out

October 2016 KGS

320-2 DAILY CONSTRUCTION QUALITY CONTROL REPORT(DCQCR)

Contract Number: DCQCR #Project Number DateContract/Task Order Title

Weather(www.accuweather.com)

Clear Partly cloudy CloudyTemp

Max Min Precipitation (Inches)/Type

1. CONTRACTOR /SUBCONTRACTOR AND AREA OF RESPONSIBILITY

EMPLOYERFIRMCODE

# EMPLOYEES HOURS AREA OF RESPONSIBILITY

12345

2. OPERATING PLANT OR EQUIPMENTPLANT OR

EQUIPMENTDATES HOURS

ARRIVAL DEPARTURE SAFETY CHECK USED IDLE REPAIR

3. WORK PERFORMED TODAY Job

Task #FIRM CODE

DFW (From CQC Plan Table 1) LOCATION DESCRIPTION

4. MONITORING OF MATERIALS RECEIVEDItem

Covered by submittal #

Quantity DESCRIPTION

Adequate Storage

Provided

Material Quality Inspection ResultsComply

Reject(3)

Buy American Act CommentsComply Reject

Yes NoYes NoYes NoYes NoYes No

(3) Complete Nonconformance report, Form 320-4

October 2016 KGS

(1) Complete Preparatory Phase Inspection checklist / Meeting Minutes, and attach it to the DCQCR.

(2) Complete Initial Phase Inspection checklist / Meeting Minutes, and attach it to the DCQCR.6. SUBMITTALS AND DELIVERABLES REVIEWED BY QC OFFICER

CDRL/ DID

Submittal Item # Spec paragraph #

ClassificationAction Taken

GA IOReview, approve and forward to PJM Approved by ClientReview, disapprove and return to supplierReview, approve and forward to PJM Approved by ClientReview, disapprove and return to supplier

7. OFFSITE SURVEILLANCE ACTIVITIESDescription Action Taken

8. JOB SAFETY EVALUATION (Daily comment required on safety activities)

9. REMARKS : (Cover any conflicts in plans, specifications, or instructions; action taken in review of submittal; verbal instructions received. Any delays encounter)

VERIFICATION: The above report is complete and correct and all material and equipment used and work performed during this reporting period is in compliance with the contract plans and specifications except as noted above.

QC Officer:

5. RESULT OF CONTROL ANALYSIS (Check all that apply)

DFW Phase Testing Control DFW Description / CommentsTesting Results Control Results

P(1)

I(2)

F

Checked testing procedure Checked Instrument calibration

Checked recording Forms & tracking ID#

None

Does testing result comply with plans and specs?

YesNo, comment

QC Officer observation

Qualified Inspector 3rd party Insp&testingOther, ____________

Does work comply with plans and specs?

YesNo, comment

P(1)

I(2)

F



None

Checked recording Forms & tracking ID #

None




YesNo, comment

P(1)

I(2)

F



None


None




YesNo, comment

P(1)

I(2)

F



None


None




YesNo, comment

P(1)

I(2)

F



None


None




YesNo, comment

October 2016 KGS

320-3 FIELD CHANGE REPORT (FCR)Contract Number: FCR #Project Number DateContract Title

CHANGE IN IMPACT ACTION REQUIRED(Check one) (Check all that apply).

A Field Condition SOW. Schedule Approved Budget Approved Plans and Documents.Other explain:______________

__________________________________________________________

Cost Review to Increase. Cost Review to Reduce. Schedule update PJM approval Client approval Mod request. Other explain:

_________________________

B Project Construction / Production Work

C Other, explain_______________________

1. CHANGE REQUEST INFORMATION1. Description of needed change:

2. Why is it required:

3. Consequences of failing to implement change

4. Other work that will be affected by the change

2. FINANCIAL IMPACT2.1 Labor Direct (hours____x rates_____) 2.8 From MS-ETC2.2 Material � Direct� Indirect:

2.8.1 JTD cost

2.3 Equipment 2.8.2 EAC2.4 Other direct costs associated with possible delays 2.9 % Impact2.5 Total Directs 2.10 Comments:2.6 Indirects (Overhead, indirects, fee, etc)2.7 Total3. SIGNATURES AND DATE

QC OFFICER PROJECT ENGINEER

SITE SUPERINTENDENT

PROJECT MANAGER

CLIENT REPRESENTATIVE

October 2016 KGS

320-4 NONCONFORMANCE REPORT (NCR)Contract Number: NCR #Project Number DateContract Title

Subcontractor Subcontract #Location Specification/Drawing DFW1. NONCONFORMANCEDESCRIPTION:

Identified by: Date:2. CORRECTIVE ACTION REQUIRED TO RECTIFY AND TO PREVENT RECURRENCEDESCRIPTION:

Prepared by: Date:To be performed by: DateTo be verified by Date3. CORRECTIVE ACTION TAKEN

Performed by Date:Verified by: DateREMARKS:

October 2016 KGS

320-5 PREPARATORY PHASE INSPECTIONCHECKLIST MEETING MINUTES

Contract Number KGS Project #Project LocationDFW Spec section Date

1. Personnel Present# Name Position Company/Client

1234

2. Inspection Checklist and Minutes of MeetingDone N/A Description

Review each paragraph of applicable specifications and drawingsReview of the Project Shop drawingsReview submittals. Ensure that materials and/or equipment have been tested, submitted and approved.Are all materials submitted, tested and approved? Yes, No. If no what item is missing? __________________________________________Is equipment submitted, tested and approved? Yes, No. If no, What item is missing: ______________________________________________Examine the work area to ensure that all required preliminary work and permits has been completed and are in compliance with the contract. Are permits on file? Yes, No, action taken: ______________________________________________________________Physically examine all required materials, equipment and sample work.Are all materials at hand? Yes, No. If no, What item is missing: _________________ _________________________________Properly stored Yes, No. If no, action taken: _________________________________Are all pieces of equipment present Yes, No. If no, What is missing __________________________________Properly stored? Yes,

No. If no, Action taken: _________________________________________Review of the appropriate activity hazard analysis to ensure safety requirements are metDiscuss procedures to accomplish the work, including points of control. ________________________________________________________________________________________

Establish construction tolerances and workmanship standards for this DFWReview of provisions that have been made to provide required control (check one): Sub/Consultant QC Officer or another member of the CQC Team. 3rd party InspectionTesting: Test to be performed?________________ Frequency______________ By whom? ______________. When:________________ Where? ______________ Has testing facilities been approved? Yes, No. If no, action taken:_________________________Check to ensure the portion of the plan for the work to be performed has been accepted by the governmentDiscuss the initial control phase: ________________________________________________________________________________________________________________________

I hereby declare that: -The above required materials delivered to the job site and methods and procedures are certified to fully comply with the project requirements.

Quality Control Representative: _____________________________________

October 2016 KGS

320-6 INITIAL/FOLLOW-UP PHASE INSPECTIONCHECKLIST / MEETING MINUTES

Contract Number KGS Project #Project LocationDFW Spec section Date

1. Personnel Present# Name Position Company/Client12345Was client representative notified? Yes No

2. Inspection Checklist and Minutes of MeetingDone N/A Description

Check preliminary work and review minutes of the preparatory meetingCheck materials and equipment being used comply with project requirements.Check the work to ensure it is in full compliance with the project requirements

Controls to ensure full complianceControls Testing

QC Officer observationQualified Inspector 3rd party Inspection & testingOther, ___________________________

Checked testing procedureChecked Instrument calibrationChecked recording Forms & tracking ID #None

Establish level of workmanshipWork locationIs a sample panel required? No, Yes.Is initial work considered as a sample? No, Yes.Check for omissions and resolve any differences of interpretation with the government representativeCheck safety to include compliance with safety plan and activity hazard analysis. Review the activity hazard analysis.Were procedures and work methodswitnessed in strict compliance with project requirements?

No, Yes., If not, explain: _______________________________________________

Is a re-inspection required? No, Yes. If yes explain: ________________________________________________

Brief summary of initial inspection procedure and result, points of concern etc.


October 2016 KGS

320-7 PREFINAL INSPECTION – “PUNCHLIST”Contract Number: Site location:ClientProject Number DateContract/Task Order Title

1. Assistants

Client POC, CAPE Representative

2. Description of work performed. (Brief description of work performed by the SOW.)

3. Type of inspectionVisual NDE Dimensional Other

4. Reference, (check all that apply)Drawing Specification numbers ___________ _______________ ______________ _______________Plans. Other, explain:

________________________________________________________________________________________________________________________________________________________________________________________5. Findings: (List all items not conforming to the approved drawings and specifications. Continue on the back page if necessary)Item Description of Outstanding Deficiencies Estimated date of

completion123456789

101112

6. REMARKS

October 2016 KGS

320-8 FINAL ACCEPTANCE INSPECTION

Contract Number: Site location:ClientProject Number DateContract/Task Order Title

Assistants:

Client POC, Sub Representative 1 Sub Representative 2

Sub Representative 3 Sub Representative 4 CAPE Representative

Description of work performed. (Brief description of work performed by each sub.)Sub 1

Sub 2

Sub 3

Sub 4

Type of inspectionVisual NDE Dimensional Other

Reference: Drawing Specification numbers ___________ _______________ ______________ _______________Plans. Other, explain: ________________________________________________________________________________

________________________________________________________________________________________________________Findings:

________________________________________________________________________

3. REMARKS

October 2016 KGS

320-9 SITE CLOSEOUT CHECKLISTContract Number: Site Location:Project Number DateContract/Task Order Title

1. PROJECT RECORD DOCUMENTSAS BUILT DRAWINGS PRODUCT DATA

CADD drawings. NA Record listing as-built materials and equipment incorporated into the construction of the project

Approved marked working as-built drawings, including but not limited to:

Location, kinds and sizes of all subsurface utility linesLocation and dimensions of any changes within the

building structureCorrect grade elevations, cross section alignment of roads, earthwork, and structures.

Change in details of design or additional information

Warranty of materials and equipment incorporated into the construction project. (providing name, address and phone number of each of the guarantor’s representative nearest to the project location.

Copy of warranty tags.Final walkthrough and as built drawing and product data

verification with client representative.

Other as built drawings requirement: Explain:________________________________________________________.

Other product data requirement: Explain:________________________________________________________.

2. QC/ QACopy of testing of space temperature control. NACopy of HVAC testing/adjusting/balancing. NACopy of 320-8. Final Acceptance Inspection.

Cleanup completed, “broom clean”. NA.Interior and exterior glass surfaces, remove temporary labels,

stains and foreign substances. NA.Vacuum carpeted and soft surfaces. NARemove waste and surplus materials, rubbish and construction

material from the site. NA.Extraordinary cleanup (Check for unusual cleanup

requirements); explain: _______________________________________________________________________________. NA.

3. REMARKS

QC Officer:

Site Superintendent: Date:

Project Manager: Date

October 2016 KGS

320-10 FIELD INSPECTION REPORT

Contract Number KGS Project #Project Location Report #DFW Spec section DatePrepared by

Description: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Visual �� NDE � In Progress �

Dimensional � Other � Final �

Reference Drawing/Standard________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Findings____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________Sketch

________________________________ __________________________________Inspector Date


October 2016 KGS

320-11 TEST REPORT LIST

Contract Number KGS Project #Project Location Report #DFW Spec section DatePrepared by

Description: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Visual �� NDE � In Progress �

Dimensional � Other � Final �

Reference Drawing/Standard________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Findings____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________Sketch

________________________________ __________________________________Inspector Date


APPENDIX CORGANIZATIONAL CHART

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APPENDIX DSUBMITTAL REGISTER

(TO BE UPDATED WEEKLY)

ATTACHMENT C Quality Assurance Project Plan

DRAFT QUALITY ASSURANCE

PROJECT PLAN

FORMER LYNDONVILLE AIR FORCE STATION EAST HAVEN, VERMONT REMEDIAL DESIGN

FUDS Project Number: D01VT0363-01

Contract Number: W912WJ-16-R-0027

Stone Project ID: 16-101

February 2017

Prepared for: Prepared by:

US Army Corps of Engineers, New England District Stone Environmental, Inc.

696 Virginia Road 535 Stone Cutters Way

Concord, MA 01742-2751 Montpelier, VT 05602

Tel. / 802.229.4541

E-Mail / [email protected]

Former Lyndonville Air Force Station Remedial Action Draft QAPP / February 2017 i

Table of Contents

QAPP WORKSHEET #1 & 2: TITLE AND APPROVAL PAGE ............................................................. 3

QAPP WORKSHEET #3 & 5: PROJECT ORGANIZATION AND QAPP DISTRIBUTION ................... 4

QAPP WORKSHEET #3 & 5 (CONT): PROJECT ORGANIZATION AND QAPP DISTRIBUTION ..... 5

QAPP WORKSHEET #4, 7, & 8: PERSONNEL QUALIFICATIONS AND SIGN-OFF SHEET ............ 6

QAPP WORKSHEET #6: COMMUNICATION PATHWAYS ................................................................. 7

QAPP WORKSHEET #9: PROJECT PLANNING DOCUMENTATION ................................................ 8

QAPP WORKSHEET #10: PROBLEM DEFINITION ............................................................................ 9

QAPP WORKSHEET #11: PROJECT QUALITY OBJECTIVES/SYSTEMATIC PLANNING PROCESS STATEMENTS .................................................................................................................. 10

QAPP WORKSHEET #12: MEASUREMENT PERFORMANCE CRITERIA ...................................... 12

QAPP WORKSHEET #13: SECONDARY DATA CRITERIA AND LIMITATIONS TABLE ................. 13

QAPP WORKSHEET #14: SUMMARY OF PROJECT TASKS .......................................................... 14

QAPP WORKSHEET #15: REFERENCE LIMITS AND EVALUATION TABLE ................................. 16

QAPP WORKSHEET #16: PROJECT SCHEDULE ............................................................................ 17

QAPP WORKSHEET #17: SAMPLING DESIGN AND RATIONALE.................................................. 18

QAPP WORKSHEET #18: SAMPLING LOCATIONS AND METHODS/SOP REQUIREMENTS TABLE .................................................................................................................................................. 19

QAPP WORKSHEET #19 & 30: ANALYTICAL SOP REQUIREMENTS TABLE ............................... 20

QAPP WORKSHEET #20: FIELD QUALITY CONTROL SAMPLE SUMMARY TABLE .................... 21

QAPP WORKSHEET #21: PROJECT SAMPLING SOP REFERENCES TABLE .............................. 22

QAPP WORKSHEET #22: FIELD EQUIPMENT CALIBRATION, MAINTENANCE, TESTING AND INSPECTION TABLE ........................................................................................................................... 23

QAPP WORKSHEET #23: ANALYTICAL SOP REFERENCES TABLE ............................................ 24

QAPP WORKSHEET #24: ANALYTICAL INSTRUMENT CALIBRATION TABLE ............................. 25

QAPP WORKSHEET #25: ANALYTICAL INSTRUMENT AND EQUIPMENT MAINTENANCE, TESTING AND INSPECTION TABLE ................................................................................................. 26

Former Lyndonville Air Force Station Remedial Action Draft QAPP / February 2017 ii

QAPP WORKSHEET #26: SAMPLE HANDLING SYSTEM ............................................................... 27

QAPP WORKSHEET #27: SAMPLE CUSTODY REQUIREMENTS .................................................. 28

QAPP WORKSHEET #28: QC SAMPLES TABLE ............................................................................. 29

QAPP WORKSHEET #29: PROJECT DOCUMENTS AND RECORDS TABLE ................................ 30

QAPP WORKSHEET #31, 32, & 33: ASSESSMENT AND CORRECTIVE ACTION TABLES .......... 31

QAPP WORKSHEET #34: DATA VERIFICATION AND VALIDATION INPUTS ................................ 32

QAPP WORKSHEET #35: DATA VERIFICATION PROCEDURES ................................................... 33

QAPP WORKSHEET #36: DATA VALIDATION PROCEDURES ....................................................... 34

QAPP WORKSHEET #37: USABILITY ASSESSMENT ..................................................................... 35

Former Lyndonville Air Force Station Remedial Action Draft QAPP / February 2017 3

QAPP WORKSHEET #1 & 2: TITLE AND APPROVAL PAGE

Site Name/Project Name: Former Lyndonville Air Force Station Remedial Action

Site Location: East Haven, Vermont


Document Title: QAPP-Former Lyndonville Air Force Station

Lead Organization: U.S. Army Corps of Engineers, New England District (NAE)

Preparer’s Name and Organizational Affiliation: Bette Nowack and Brian Diezel, Stone Environmental, Inc.

Preparer’s Address, Telephone Number, and E-mail Address: 535 Stone Cutters Way, Montpelier, VT 05602

Preparation Date (Month/Day/Year): 2/15/2017

Koman Government Solutions, LLC Project Manager: Gregory T. Birch, PMP

Signature Date

Stone Environmental, Inc. Project Manager: Bette L. Nowack, PE

Signature Date

Stone Environmental, Inc. Project QA Officer: Kim Watson

Signature Date

USACE, New England District Project Manager: Marie Wojtas

Signature Date

Vermont Department of Environmental Conservation Project Manager: Hugo Martinez-Cazon, PE


QAPP WORKSHEET #3 & 5: PROJECT ORGANIZATION AND QAPP DISTRIBUTION

QAPP Recipients Title Organization Telephone Number

E-mail AddressDocument

Control Number

*Marie Wojtas Project Manager USACE 978-318-8788 [email protected] v0.0

*Hugo Martinez-Cazon Project Manager VT DEC 802-522-5564 [email protected] v0.0

*Ed King Program Manager KGS 484-437-6644 [email protected] v0.0

*Gregory Birch Project Manager KGS 302-373-5724 [email protected] v0.0

John Hudacek Site Manager, Site Safety Officer/CQC System Manager (Alternate)

KGS 516-449-6578 [email protected] v0.0

Eric Lynch Site Safety Officer/CQC System Manager

KGS 484-467-7232 [email protected] v0.0

*Bette Nowack, P.E Project Manager Stone Environmental, Inc. 603-273-9250 [email protected] v0.0

*Lee Rosberg Field Operations Leader Stone Environmental, Inc. 802-229-6434 [email protected] v0.0

*Brian Diezel Field Sampler Stone Environmental, Inc. 802-229-5378 [email protected] v0.0

*Kim WatsonQA Officer/Health & Safety Officer

Stone Environmental, Inc. 802-229-2196 [email protected] v0.0

*Kristen SchultzProject Manager/Food & Microbiology Laboratory Supervisor

Katahdin Analytical Services 207-874-2400 [email protected] v0.0

* Person to receive QAPP

mailto:[email protected]












QAPP WORKSHEET #3 & 5 (CONT): PROJECT ORGANIZATION AND QAPP DISTRIBUTION


QAPP WORKSHEET #4, 7, & 8: PERSONNEL QUALIFICATIONS AND SIGN-OFF SHEET

Organization: U.S. Army Corps of Engineers New England District (NAE)

Project Personnel Title Education/Experience Specialized

Training/Certifications Signature/Date

Marie Wojtas Project Manager

Organization: KOMAN Government Services



Ed King Program Manager Gregory Birch Project Manager John Hudacek Site Superintendent

Eric Lynch Site Safety Officer/CQC

Manager

Organization: Vermont Department of Environmental Conservation



Hugo Martinez-Cazon Project Manager

Organization: Stone Environmental, Inc.



Bette Nowack, PE Project Manager M.S. Civil/Environmental Engineering,

34 yrs. experience Licensed PE in VT, 40 Hr.

OSHA

Kim Watson QA Officer B.S., Environmental EngineeringTechnology, 35 yrs. experience

RQAP-GLP, 40 Hr. OSHA

Lee Rosberg Project Geologist B.S. Geology, over 8 yrs. experience 40 Hr. OSHA

Brian Diezel Project Engineer B.S. Civil Engineering, over 2 yrs.

experience 40 Hr. OSHA

Notes: N/A – not applicable *Signatures indicate personnel have read and agree to implement this QAPP as written.


QAPP WORKSHEET #6: COMMUNICATION PATHWAYS

Communication Drivers Responsible Entity Name Phone Number Procedure (Timing, Pathways, Etc.)

Point of Contact with NAE Contractor Program/Project

Managers Ed King,

Gregory Birch

302-373-5724 All materials and information about the project will be forwarded to Marie Wojtas

Manage all Project Phases Contractor Program/Project

Managers Ed King,

Gregory Birch

302-373-5724 Notify Marie Wojtas of field-related problems by COB the next business day

Pre-Design and Confirmation Sampling

Project Manager Bette Nowack 603-273-9250 Will notify Gregory Birch and Marie Wojtas of any deviations from the QAPP and Field Sampling Plan (FSP).

QAPP changes QAPP Preparer Kim Watson and

Brian Diezel 802-229-2196

Will notify about minor changes to the QAPP; prepare QAPP amendments for major changes.

QAPP Amendments Contractor Project Manager Gregory Birch 978-318-8021 Any major changes to the QAPP must be approved by Laurie Ekes before the changes can be implemented.

Weekly Field Progress Reports Site Superintendent John Hudacek 516-467-6578 Will provide written reports of weekly field progress to Marie Wojtas.

Recommendations to stop work and initiate corrective action

Site Superintendent John Hudacek 516-467-6578 Will notify Marie Wojtas where unforeseen circumstances require the stoppage of work and/or immediate remedial actions.

Reporting Lab Data Quality Issues

Laboratory Quality Assurance Officer

Kristen Schultz 207-874-2400 All QA/QC issues with project field samples will be reported to the Filed Team Leader by the laboratory QAOs.

Field and Analytical Corrective Actions

Contractor Quality Assurance Officer

Kim Watson 802-229-2196 The need for corrective action for field and analytical issues will be determined.

Release of Analytical Data Contractor Quality Assurance

Officer Kim Watson 802-229-2196

No analytical data can be released until validation is completed and has approved the release.


QAPP WORKSHEET #9: PROJECT PLANNING DOCUMENTATION

Project Scoping Session Participants Sheet

Project Name: Former Lyndonville Air Force Station Projected Date(s) of Sampling: November 2016 Project Manager: Bette Nowack

Site Name: Former Lyndonville Air Force Station Site Location: East Haven, Vermont

Date of Session: September 26, 2016 Scoping Session Purpose: Project Kick-Off Meeting

Name Affiliation & Project Role

Marie Wojtas USACE, Project Manager

Cynthia Colquitt USACE, Risk Assessor Paul Young USACE, Geologist Dion Lewis USACE, Project Chemist Greg Birch KGS, Project Manager John Hudacek KGS, Site Superintendent Edward King KGS, Program Manager Laurie Ekes KGS, Project Chemist Bette Nowack Stone Environmental, Project Manager Kim Watson Stone Environmental, Chemistry QA/QC Brian Diezel Stone Environmental, Staff Engineer Lee Rosberg Stone Environmental, Staff Geologist

Meeting Summary: Team roles and responsibilities were discussed. KGS is the Prime contractor overseeing all contract work and project management. Stone will prepare the QAPP/FSP, perform pre-design investigation and confirmation sampling, and prepare a remedial action report. Capitol Environment will perform Transportation and Disposal work. Greg Birch discussed project schedule and deliverables. The possibility of expediting site mobilization by simplifying the SSHP was discussed. Bette Nowack spoke about recommended modifications to the pre-design investigation sampling plan as described in the Final Feasibility Study Report (FS, Stone, 2014). Everyone was in agreement that modifications to the approach discussed in the FS would be considered. In follow up emails, USACE personnel agreed to using 10 ft by 10 ft decision units instead of 5.5 ft by 5.5 ft decision units.

Action Items: Marie to speak with the USACE safety team to determine what type of health and safety plans would be needed. KGS to begin preparation of the remedial action work plan. Stone to prepare the QAPP/FSP.


QAPP WORKSHEET #10: PROBLEM DEFINITION

Environmental Questions: What are the extents of Poly Chlorinated Biphenyl (PCB) contamination around TP6? Following excavation, is the concentration of PCBs below the RG within the excavation? Secondary Data: The Final Remedial Investigation Report (RI, JCO, 2013) detected PCBs from Test Pit 6 (TP6) above the Remedial Goal (RG) of 1.7 milligrams per kilogram (mg/kg) which was established in the FS. The FS identified soil excavations as a remedy to the contamination but indicated that further pre-design investigation should be conducted. Contaminants of Concern: The RI investigation identified PCBs in soil as the only contaminate of concern (COC). Contamination was caused by the disposal of PCB containing materials in an onsite landfill known as the Debris Area. Data Use: Data will be used by Stone, KGS, and USACE. Pre-design Investigation data will be used to identify the extents of PCB contamination with the area of concern (AOC 1) around TP6. A remedial design will be conducted to create a soil excavation that will remove PCB contamination above the RG. Post excavation data will be used to confirm PCB concentrations above the RG have been removed from AOC 1. Additional Site information is provided in Section 1 of the FSP.


QAPP WORKSHEET #11: PROJECT QUALITY OBJECTIVES/SYSTEMATIC PLANNING PROCESS STATEMENTS

Problem Statement: There is inadequate data defining the extents of PCB impacts within AOC 1. TP6 which is located within AOC 1 is the only sampling location where PCBs where detected. PCBs were detected at a concentration of 48 mg/kg from TP6. Additional sampling is needed to delineate the extents of PCB impacts in order to prepare a remedial design excavation. Following soil excavation to remove PCB impacts, confirmation sampling will need to be conducted to confirm that soil with PCB concentrations above the RG has been removed. Project Goals: Pre-Design Investigation: Historic investigation and reporting identified a layer of grey material approximately 2-2.5 ft bgs in AOC 1. The grey material was sampled and analytical results detected PCB concentrations of approximately 48 mg/kg. It is anticipated that the grey material is the source of the PCB impacts, however the extents of the grey material is unknown. Pre-design investigation will use modified Incremental Sampling Methodology (ISM) to delineate the vertical and horizontal extents of PCB impacts around TP6. Results will aid in the design of remedial excavations. Post Excavation Confirmation: Following excavation to remove PCB impacted soil, confirmation sampling will be performed using modified ISM to confirm PCB concentrations greater the RG were removed. Information Inputs:

• Visual data defining the extents of the grey layer • Laboratory analysis of soil samples using USEPA SW-846 Method 8082

Data Collection Boundaries: A 30 ft by 30 ft area centered at TP6 is the target area for pre-design investigation. Modified ISM will be conducted to delineate the extents of PCB impacts. 18 Decision Units (DUs) will be sampled within the 30 ft by 30 ft target area. DUs 1-9 will characterize soil from 0-3 ft bgs and DUs 10-18 will characterize soil from 3-4 ft bgs. Three replicate samples will collected from each DU to estimate the contaminant concentration. Each replicate sample will be a composite of three incremental samples from within a DU. Sampling extents during confirmation sampling will be defined by excavation extents. Excavation extents will be designed following receipt of investigation sampling data, however both the FSP and QAPP assume that a 30 ft by 30 ft by 4 ft deep area centered at TP6 will be excavated. Data will be used to ensure excavation extents remove impacted soil that is above the RG. The floor and sidewalls of excavations will be sampled using modified ISM to determine PCBs above the RG have been removed. Sidewalls will each serve as a DU and the floor of the excavation will be another DU. Three replicate samples, which will each be a composite of 10 incremental samples, will be collected within a DU to estimate contaminant concentration. Data collection boundaries for confirmation sampling are subject to change based on pre-design investigation and volumes excavated. Data collection boundaries are further described and discussed in Section 2 of the FSP.


Analytical Approach: Samples collected from each DU during pre-design investigation and post excavation confirmation sampling will be sent to a fixed laboratory for analysis. Once received by the laboratory, each replicate will be thoroughly homogenized and 30 grams of soil will be collected from each homogenized replicate sample for extraction and analysis. Samples will be extracted using soxhlett (method SW3540) which utilizes drying with sodium sulfate. The samples will also be analyzed for total solids and the results will be adjusted for this. The replicates from each DU will produce an estimate of the mean contaminate concentration. One Matrix Spike and Matrix Spike Duplicate (MS/MSD) soil sample will be analyzed during investigation and confirmation sampling. If the contaminant concentration is above the RG then the soil associated with that DU will require removal. Performance and Acceptance Criteria: The following performance and acceptance criteria will be established for samples collected in support of Remedial Action:

• Field and Analytical performance/acceptance criteria per method as detailed in the DoD Quality Systems Manual (QSM) V5.0 and defined on Worksheet # 12;

• USEPA Method 8082 will provide an acceptable detection limit and accuracy for use in decisions related to attaining screening criterion; • The laboratory will review and apply usability qualifiers to the analytical data; and • Data validation and review will be performed in conformance with Stage 2BEM (Tier III) guidelines as defined by the USEPA (EPA 540-08-005,

January, 2009), and to the extent possible. USEPA guidelines as defined by the USEPA National Functional Guidelines for Superfund Organic Methods Data Review (EPA 540-R-08-01, June, 2008) and the New York Department of Environmental Conservation Technical Guidance for Site Investigation and Remediation (Division of Environmental Remediation-10, May, 2010) Appendix 2B Guidance for Data Deliverables and Development of Data Usability Summary Reports will also be considered during the evaluation, and professional judgment will applied as necessary and appropriate.

Plan for Obtaining Data: The plan for data collection is provided in Section 2 of the FSP.


QAPP WORKSHEET #12: MEASUREMENT PERFORMANCE CRITERIA

Matrix Soil Samples

Analytical Group PCBs Concentration

Level Low to High

Sampling Procedure1

Analytical Method/SOP2

Data Indicators (DQIs)

Measurement Performance Criteria

QC Sample and/or Activity Used to Assess

Measurement Performance

QC Sample Assesses Error for Sampling (S),

Analytical (A) or Both (S&A)

9a EPA Method

8082/EXT3540/1b, 2b

Precision Relative standard deviation

(RSD) ≤ 30% Laboratory Replicates A

Precision RSD ≤ 30% Matrix Spike/Matrix

Spike Duplicate (MS/MSD)

A

Accuracy/Bias Laboratory Control Limits3 Lab Control Sample

(LCS) A

Accuracy/Bias No reported concentrations above ½ quantitation limits

Method blank A

Accuracy/Bias Laboratory control limits 3 MS/MSD A

Accuracy Laboratory control limits 3 Surrogate:

Tetrachloro-m-xylene Decachlorobiphenyl

A

Note 1: See Worksheet #21 for cross-reference to sampling procedure. Note 2: See Worksheet #23 for cross-reference to analytical method SOP. Note 3: LCS and MS/MSD control limits may be compound-specific; individual control limits are provided in laboratory SOPs and for this project are the DOD limits.


QAPP WORKSHEET #13: SECONDARY DATA CRITERIA AND LIMITATIONS TABLE

Secondary Data

Data Source

(Originating Organization, Report Title, and Date)

Data Generator(s) (Originating Org., Data Types, Data Generation/

Collection Dates)

How Data Will Be Used

Limitations on Data Use

Remedial Investigation (RI) sample results

Johnson Company, RI Report, 2008

Johnson Company, July 2008

Provides a starting point to build DUs to determine the extents of PCB contamination.

Quantitative: Limited data detailing the extents of PCB concentrations.


QAPP WORKSHEET #14: SUMMARY OF PROJECT TASKS

Sampling Tasks: Pre-Design Investigation Samples: Eighteen DUs will be sampled from within the target area around TP6. DUs 1-9 will characterize soil from 0-3 ft bgs and DUs 10-18 will characterize soil from 3-4 ft bgs. Nine sample locations will be marked within each DU using pin flags, three replicates (each a composite of 3 increments) will be collected from each DU, and sent under COC to the laboratory for analysis by EPA Method 8082. Section 2.1 of the FSP provides further discussion of pre-design investigation sampling. Post-Excavation Confirmation Sampling: 5 DUs will be sampled from the excavation around TP6. The floor of the excavation will serve as a single DU, DU 19. The northern, southern, eastern, and western sidewalls will each be designated as separate DUs, DUs 20-23. Thirty sample locations will be marked within each DU using pin flags, three replicates (each a composite of 10 increments) will be collected from each DU, and sent to the laboratory for analysis by EPA Method 8082. Section 2.2 of the FSP provides further discussion of post-excavation confirmation sampling. Analysis Tasks: Katahdin Analytical Services, will perform fixed site lab analysis of all samples for PCBs. Pre-Design Investigation Samples: Katahdin will receive 54 samples consisting of approximately 1 gallon in volume. Once received by the laboratory, the samples will be thoroughly homogenized and 30 grams of soil will be collected from the homogenized sample for extraction and analysis. Samples will be extracted using soxhlett (method SW3540) which utilizes drying with sodium sulfate. The samples will also be analyzed for total solids and the results will be adjusted for this. The laboratory will report each replicate analyses, 3, for a given DU. In total 54 analyses will be run for the pre-design investigation, 3 for each of the 18 DUs. Post-Excavation Confirmation Samples: Katahdin will receive 15 samples (3 replicates for each of 5 DUs), each with an approximate volume of .25 gallon. Once received by the laboratory, each replicate will be thoroughly homogenized and 30 grams of soil will be collected from the homogenized sample for extraction and analysis. Samples will be extracted using soxhlett (method SW3540) which utilizes drying with sodium sulfate. The samples will also be analyzed for total solids and the results will be adjusted for this. The laboratory will report each replicate analyses, 3, for a given DU. In total 15 analyses will be run for the pre-design investigation, 3 for each of the 5 DUs. Quality Control Tasks: Three replicate samples will be collected from each DU in the field to evaluate field sampling variability. Analysis of equipment blanks and matrix spike/matrix spike duplicate analysis will be performed at laboratory. An ISM-processing laboratory duplicate (set of three replicates from a single location) will be selected for PCBs to allow independent evaluation of field and laboratory precision for ISM samples. Secondary Data: Visual evidence of the grey material originally found in TP6 will be used in combination with pre-design investigation results to design the remedial excavations.


Data Management Tasks: Analytical data will be received from the laboratory using SEDD Stage 2a format and spreadsheets entered into the USACE ADR software for data review. Data will be uploaded to the FUDSCHEM database in a format approved by USACE. All data must contain a table that links the Sample ID to the Location ID. In addition to the ADR spreadsheets and SEDD, the laboratory and contractor error reports, eQAPP file, field QC associations, and data validation report will also be uploaded to the FUDSCHEM database. Documentation and Records: All new sampling locations will be marked for survey. Field forms will be used to record field sampling data, screening data and conditions at each sampling location. All chains of custody and shipping documents will be retained for the samples. Laboratory data packages will include a level 4 reporting package (results with full QC/Calibrations) and SEDD/ARD 5.0/5.1, Stage 2A EDD. All documents will be filed in electronic format on Stone Environmental’s secure local area network, which is backed up daily. Final documents will be stored at a Site specific repository. GPS coordinates (VT State Plane) for the center points of pre-design investigation DUs and post-excavation confirmation sampling DUs will be surveyed and uploaded to the FUDSCHEM database. Assessment/Audit Tasks: Fielding sampling audit tasks are detailed in Worksheet #31. Data Review Tasks: Data and all related field logs/notes/records will be reviewed to assess total measurement error and determine overall usability of the data for project purposes. Data limitations will be determined and data will be compared to Project Quality Objectives and required method detection limits. Corrective action is initiated by the laboratory, as necessary. Final data are placed in database, with any necessary qualifiers, and tables, charts, and graphs are generated.


QAPP WORKSHEET #15: REFERENCE LIMITS AND EVALUATION TABLE

Matrix Soil Analytical Group PCBs/8082 Concentration Level Low to High

Analyte CAS Number Remedial Goal (RG)1 (mg/kg)

Achievable Laboratory Detection Limits (mg/kg)

MDL/LOD RL/LOQ

Aroclor 1016 12674-11-2 - 0.0060 0.017 Aroclor 1221 11104-28-2 - 0.0079 0.017 Aroclor 1232 11141-16-5 - 0.0093 0.017 Aroclor 1242 53469-21-9 - 0.0058 0.017 Aroclor 1248 12672-29-6 - 0.0061 0.017 Aroclor 1254 11097-69-1 - 0.0047 0.017 Aroclor 1260 11096-82-5 - 0.0060 0.017 Total PCBs2 1336-36-3 1.7 - - Note 1: RG is a human health risk based concentrations identified in the FS (Stone, 2014). Note 2: Total PCBs will be calculated as the summation of all detectable aroclors during laboratory analysis.


QAPP WORKSHEET #16: PROJECT SCHEDULE

Dates (MM/DD/YY) Activities Organization Anticipated Date(s) of

Initiation Anticipated Date(s) of Completion

Deliverable Deliverable Due Date

Work Plan (FSP/QAPP) KGS & Stone October 2016 November 2016 Work Plan December 2016 Pre-Design Sampling Stone December 2016 December 2016 Remedial Design Plan April 2017 Remedial Construction KGS & Stone May 2017 May 2017 Remedial Action Report September 2017 Confirmation Sampling Stone May 2017 May 2017 Remedial Action Report September 2017


QAPP WORKSHEET #17: SAMPLING DESIGN AND RATIONALE

Refer to the Section 2 of the Field Sampling Plan, for details. Sampling design and rationale is provided in Section 2 of the FSP.


QAPP WORKSHEET #18: SAMPLING LOCATIONS AND METHODS/SOP REQUIREMENTS TABLE

Sampling Location/ID Number

Matrix Depth (ft) Analytical Group

Concentration Level

Number of Samples (Identify Field Duplicates)

Sampling SOP Reference

Rationale for Sampling Location

Debris Area Pre- Design Sampling: AOC 1

Soil

0-3 ft (DU 1-9) 3-4 ft (DU 10-18)

PCBs

Low-High 54 Total Samples (18 DUs with 3 replicates per DU)

SSP SEI 16-101 1 0 Composite Soil Sampling

Delineate horizontal and vertical extents of PCB contamination from the previous Remedial Investigation (RI).

Debris Area Post-Excavation Confirmation Sampling: AOC 1

2 inches below top of ground surface

Low 15 Total Samples (5 DUs with 3 replicates per DU)

Confirm PCB removal excavations meet the RG of 1.7mg/kg.


QAPP WORKSHEET #19 & 30: ANALYTICAL SOP REQUIREMENTS TABLE

Laboratory (Name, sample receipt address, POC, e-mail, and phone numbers): Katahdin Analytical Services Kristen Schultz 600 Technology Way, Scarborough, ME 04074 207-874-2400

Matrix Analytical Group

Concentration Level

Analytical and Preparation Method/SOP Reference

Sample Volume

Containers (number, size and type)

Preservation Requirements (chemical, temperature, light protected)

Maximum Holding Time (preparation/ analysis)

Soil PCBs Low to High 8082 0.25-1 gallons

1 gallon Ziploc bags

<6 degrees Celsius

30 days


QAPP WORKSHEET #20: FIELD QUALITY CONTROL SAMPLE SUMMARY TABLE

Matrix

Analytical Group

Concentration Level

Analytical and Preparation SOP Reference

No. of Decision Units1

No. of Field Replicates Per DU

No. of MS2

No. of MSD3

No. of Trip Blanks

No. of Equip. Blanks/Field Blank4

Total No. of Samples to Lab

Total No. of Samples

Soil PCBs Low-High 8082/1 23 3 2 2 n/a 2 69 75

Note 1: DUs listed are a combination of pre-design sampling and confirmation sampling. Note 2: One MS sample will be collected per sampling event (pre-design and confirmation sampling). Note 3: One MSD sample will be collected per sampling event (pre-design and confirmation sampling). Note 4: One equipment blank will be collected per sampling event (pre-design and confirmation sampling).


QAPP WORKSHEET #21: PROJECT SAMPLING SOP REFERENCES TABLE

Reference Number

Title, Revision Date and/or Number Originating Organization

Equipment Type Modified for Project Work?

Comments

1a SOP SEI-4.2.7 Chain of Custody Procedures, 05/10/12, revision number: 7

Stone Environmental, Inc.

N/A No

2a SOP SEI-4.5.11 Data Handling, Storage, Retrieval and Error Coding, 05/10/12, revision number: 11


N/A No

3a SOP SEI-5.1.5 Maintenance and Decontamination of Field Equipment, 02/20/04, revision number: 5


N/A No

4a SOP SEI-6.1.6 Collection of Soil Samples for Preliminary Site Characterization, 11/18/05, revision number:6


Geoprobe No

5a SOP SEI-6.16.4 Handling, Collection and Transportation of Samples, 04/16/04, revision number: 4

Stone Environmental, Inc. N/A No

6a Hager-Richter Geoscience, Inc. Standard Operating Procedures Utility Clearance for Boring Installations.

Hager-Richter Geoscience, Inc.

Geonics EM-61-MK2, Sensors and Software Noggin Plus digital GPR system

No

7a SOP SEI-6.24.1 Locating Soil Sampling Points in a Sampling Area, 11/18/05, Revision:1


N/A No

8a

SOP SEI-6.46.0 Geologic Description of Unconsolidated Deposits Using the Unified Soil Classification System, 10/15/12, revision: NA


N/A No

9a

SSP SEI 16-101.1.0 Procedure for collection of Composite Samples Using Incremental Sampling Methodology, 10/12/16, revision:NA


N/A Yes


QAPP WORKSHEET #22: FIELD EQUIPMENT CALIBRATION, MAINTENANCE, TESTING AND INSPECTION TABLE

Field equipment will not generate data and will not require calibration or maintenance. Field equipment will consist of but is not limited to, hand augers, soil pans, trowels, and shovels. All samples collected will be shipped to Katahdin Analytical Services for fixed lab analysis.


QAPP WORKSHEET #23: ANALYTICAL SOP REFERENCES TABLE

Reference Number

Title, Revision Date, and/or Number Definitive or Screening Data

Analytical Group

Instrument Organization Performing Analysis

Modified for Project Work?

1b

CA-329 Analysis Of PCBs As Total Aroclors By Gas Chromatography/Electron Capture Detector (GC/ECD): SW-846 Method 8082, 03/16, Revision 15.

Definitive Soil/PCBs

NA Gas Chromatography (GC)/ Electron Capture Detector (ECD)


No

2b

Preparation Of Sediment/Soil Samples By Soxhlet Extraction Using Method 3540 For Pesticide/PCB Analysis, 12/14 Revision 9.

Definitive Soil/PCBs Not applicable (extraction)


No

3b CA-331 Sulfur Cleanup of Pesticide/PCB Extracts Using SW846 Method 3660

Definitive Soil/ PCBs Not applicable Katahdin Analytical Services

No


QAPP WORKSHEET #24: ANALYTICAL INSTRUMENT CALIBRATION TABLE

Instrument Calibration Procedure

Frequency of Calibration

Acceptance Criteria Corrective Action (CA)

Person Responsible for CA

SOP Reference

GC/ECD-PCBs

ICAL - A minimum 5-point calibration is run except for mid-point calibration of Aroclors 1221, 1232 and 1248; if targets are detected, then 6-point calibration is performed.

Instrument receipt, major instrument change, when CCV does not meet criteria.

Six point calibration of Aroclors 1016/1260, 1242, and 1254 – One of the options below: Option 1: %RSD for each analyte must be ≤ 20%; Option 2: linear least squares regression: r must be ≥ 0.995; Option 3: non-linear regression: r2 must be ≥ 0.99 (6 points shall be used for second order)

Repeat ICAL and/or perform necessary equipment maintenance. Check calibration standards. Reanalyze affected data. Analyst,

Department Manager

1a

Continuing Calibration Verification (CCV)

Prior to sample analysis, after every 10 field samples, and at the end of the analysis sequence.

%D must be ≤ 15% for all project compounds.

Correct problem, then rerun calibration verification. If that fails, then repeat ICAL. Reanalyze all samples since the last successful calibration verification.


QAPP WORKSHEET #25: ANALYTICAL INSTRUMENT AND EQUIPMENT MAINTENANCE, TESTING AND INSPECTION TABLE

Instrument/ Equipment

Maintenance Activity Testing Activity

Inspection Activity

Frequency Acceptance Criteria

Corrective Action

Responsible Person

SOP Reference1

GC/ECD

Check pressure and gas supply daily. Change septa and/or liner as needed, replace or cut column as needed. Other maintenance specified in lab Equipment Maintenance SOP.

Pesticides, PCBs, and Herbicides.

Injector liner, septa, column, column flow.

Prior to ICAL and/or as necessary.

Acceptable calibration or CCV

Correct the problem and repeat calibration or CCV.

Analyst, Department Manager.

1a

1 From the Analytical SOP References table (Worksheet #23)

Former Lyndonville Air Force Station Remedial Action Draft QAPP / November 2016 27

QAPP WORKSHEET #26: SAMPLE HANDLING SYSTEM

Task

SAMPLE COLLECTION, PACKAGING, AND SHIPMENT

Sample Collection: Stone field staff Sample Packaging: Stone field staff Coordination of Shipment: Stone field staff Type of Shipment/Carrier: Coolers, UPS or FedEx overnight Sample Receipt, Custody and Storage, Preparation, Determinative Analysis

Stone, Katahdin Analytical Services

SAMPLE ARCHIVING

Field Sample Storage N/A Sample Extract/Digestate storage See Worksheet #19 for holding times Biological Sample Storage N/A Personnel/Organization Fixed Facilities Responsibility SAMPLE DISPOSAL Personnel/Organization Stone, Katahdin Analytical Services

Former Lyndonville Air Force Station Remedial Action Draft QAPP / November 2016 28

QAPP WORKSHEET #27: SAMPLE CUSTODY REQUIREMENTS

Field Sample Custody Procedures (sample collection, packaging, shipment and delivery): All samples will

be placed in appropriate containers according to Worksheet #19. Sample labels will include: site name, date,

time, preservative, and analytical method. Preprinted labels provided by Stone Environmental, Inc. will be used

as much as possible. All samples will be documented on a Chain of Custody, which will accompany the samples

to the laboratory. All samples will be placed in coolers with wet ice and maintained at 4°C ± 2°C during storage

and shipping. Coolers will be packed with sufficient packing material (not Styrofoam) to minimize movement

during transit. The coolers will be sealed with tape and shipped via UPS or FEDEX (overnight) to the appropriate

laboratory. The laboratory will be responsible for notifying Stone Environmental, Inc. as soon as possible of any

inconsistencies or breakage upon receipt. FUDSCHEM will be used to generate sample container labels and

chains of custody.

Laboratory Sample Custody Procedures (receipt of samples, archiving, and disposal): The laboratory will

check all samples against the Chain of Custody upon receipt, and will electronically archive all samples before

analysis. Samples will be disposed of by the laboratory in accordance with applicable RCRA Hazardous Waste

regulations.

Sample Identification Procedures: The protocol for determining sample IDs for the composite samples is

described below. Sample IDs will consist of 18 digits which indicate the DU number, as well as type of sample

(pre-design or confirmation), depth for pre-design samples or surface location for confirmation samples, and a

replicate code identification number.

Pre-Design Investigation Example: DUxx-PD03-110616-2, where xx is the DU number (1 through 18), PD

indicates pre-design sample, 03 indicates depth interval 0-3 ft bgs, 110616 indicates the date the sample was

taken, and 2 indicate the sample is the second replicate.

Post-Excavation Confirmation Example: DUxx-CSFL-110616-2, where xx is the DU number (19), CS

indicates confirmation sample, FL indicates it was collected from the floor of the excavation, 110616 indicates

the date the sample was taken, and 2 indicates the sample is the second replicate.

DUxx-PDSW-110616-1, where xx is the DU number (20 through 23), CS indicates confirmation sample, SW

indicates it was collected from the southern sidewall of the excavation, 110616 indicates the date the sample was

taken, and 1 indicates the sample is the first replicate.


QAPP WORKSHEET #28: QC SAMPLES TABLE

Matrix Soil Sampler’s Name Field Staff

Analytical Group VOCs Field Sampling Organization Stone Sampling SOP 9a Analytical Organization Katahdin

Analytical Method/ SOP Reference EPA Method 8260C/ASTMD6520/27b No. of Sample Locations 23

QC Sample Frequency/Number Method/SOP QC

Acceptance Limits

Corrective Action Person(s)

Responsible for Corrective Action

Data Quality Indicator (DQI)

Measurement Performance

Criteria

Replicate samples (triplicates)

3 per DU RSD 30%

Reanalyze samples or review similarity of samples.

Brian Diezel Precision/Bias- contamination

RPD ≤ 50%

Method Blank 1 per event No reported concentrations ≥ ½ quantitation limits

Redigest samples with new method blank and reanalyze for analyte.

Katahdin Analytical

Contamination No reported concentrations ≥ quantitation limits

Lab Control Sample

1 per event DOD limits

Analyte may not be reported without a narrative; rerun batch.

Katahdin Analytical

Accuracy DOD limits – see attached tables

Equipment Blank 1 per sampling event DOD limits

Analyte may not be reported without a narrative.

Stone Environmental

Accuracy No reported concentrations ≥ quantitation limits

MS/MSD 1 per sampling event DOD limits

Determine root cause, flag MS/MSD data; discuss in narrative.

Katahdin Analytical

Accuracy/Bias/Precision DOD limits


QAPP WORKSHEET #29: PROJECT DOCUMENTS AND RECORDS TABLE

Sample Collection and Field Records

Record Generation Verification Storage location/archival

Field logbook or data collection sheets Environmental Field Team Lead Environmental Lead Project File

Chain-of-Custody Forms Environmental Field Team Lead Environmental Lead Project File

Laboratory Records Record Generation Verification Storage location/archival

Chain-of Custody Forms Field Technician Katahdin Katahdin

Data packages (Case Narratives, Sample Results, QC Summaries, Raw Data)

Katahdin analysts, PM, QA Katahdin, analyst,

peer review, QA review Katahdin

Custody Seals Field Technician Katahdin upon arrival Katahdin

Laboratory Data Deliverables

Record PCBs

Narrative X

COC X

Summary Results X

QC Results X

Chromatograms X


QAPP WORKSHEET #31, 32, & 33: ASSESSMENT AND CORRECTIVE ACTION TABLES

Assessments:

Assessment Type Frequency Responsible Party & Organization

Estimated Dates

Assessment Deliverable

Deliverable Due Date

Data Usability After all data is generated and checked

Kim Watson, Stone Environmental Inc.

Unknown Data validation report and EDDs with qualifiers

30 days after receipt of laboratory final data package

Laboratory Technical Systems/Performance Audits

1/At receipt of sampling results


Unknown Laboratory quality assurance report

30 days from receipt of samples

Field Audit Following each sampling event


Unknown Field audit will be discussed during data validation.

30 days after receipt of laboratory final data package

Assessment Response and Corrective Action:

Assessment Type Responsible Party & Organization

Assessment Response Documentation

Time Frame for Response

Responsibility for Implementing CA

Responsible for Monitoring CA Implementation

Data Usability Kim Watson, Stone Environmental Inc.

Data Usability Summary Report (DUSR)

30 days Katahdin Analytical Services

Laboratory Technical Systems/Performance Audits


Laboratory Quality Assurance Report

30 days Katahdin Analytical Services

Laboratory Quality Assurance Manager


QAPP WORKSHEET #34: DATA VERIFICATION AND VALIDATION INPUTS

Item Description Verification

(completeness)

Validation (conformance to specifications)

Planning Documents/Records

1 Approved QAPP X X 2 Contract X 4 Field SOPs X 5 Laboratory SOPs X

Field Records

6 Field logbooks X X 7 Chain-of-Custody Forms X X 8 Sampling diagrams/surveys X X 9 Drilling logs X X 10 Relevant Correspondence X X 11 Change orders/deviations X X 12 Field audit reports X X 13 Field corrective action reports X X

Analytical Data Package

14 Cover sheet (laboratory identifying information) X X 15 Case narrative X X 16 Internal laboratory chain-of-custody X X 17 Sample receipt records X X

18 Sample chronology (i.e., dates and times of receipt, preparation, & analysis)

X X

19 Communication records X X 20 Project-specific PT sample results X X 21 LOD/LOQ establishment and verification X X 22 Standards Traceability X X 23 Instrument calibration records X X 24 Definition of laboratory qualifiers X X 25 Results reporting forms X X 26 QC sample results X X 27 Corrective action reports X X 28 Raw data X X 29 Electronic data deliverable in accordance with

specifications associated with Environmental Restoration Information System (ERIS)

X X


QAPP WORKSHEET #35: DATA VERIFICATION PROCEDURES

Records Reviewed Process Description Responsible Person,

Organization

Field logbooks Field notes will be reviewed periodically to determine completeness, appropriateness, ease of understanding, etc., of information recorded. Upon completion of field work, logbooks will be placed in the project files.


Chain-of-custody forms

Chain-of-custody forms will be reviewed against the samples packed in the specific cooler prior to shipment. Original chain-of-custody forms will be sent with the samples to the laboratory, while a copy is retained for the project files.

Brian Diezel, Stone Environmental Inc.

Sample receipt and log-ins

Sample receipt and log-in summaries will be reviewed to determine potential receipt issues that may impact data quality and for consistency with the chain-of-custody forms.

Kristen Schultz, Katahdin Analytical Services

Laboratory analytical data package prior to release

Data packages will be reviewed/verified internally by the laboratory performing the work for completeness and technical accuracy prior to submittal.

Kristen Schultz, Katahdin Analytical Services

Laboratory analytical data package

Data packages will be reviewed by Kim Watson. The data will undergo a Level III, Stage 2BEM validation protocol.


Electronic data Electronic laboratory data and field data will be reviewed for consistency with the hardcopy information.


Data validation report The validated analytical results will be compiled in a tabulated summary. Entries will be reviewed/verified against hardcopy information.



QAPP WORKSHEET #36: DATA VALIDATION PROCEDURES

Analytical Group/Method: PCBs by 8082 Data Validator (Title and Org.)

Data deliverable requirements: Level 4 data package Kim Watson, QAO, Stone Environmental, Inc.

Analytical specifications: See Worksheet 12

Measurement performance criteria: See Worksheet 12

Percent of data packages to be validated: 100%

Percent of raw data reviewed: 100%

Validation procedure: SEDD/ADR, NFG for Superfund Organic Methods Data Review

Validation code: S2BVEM (100%),

Electronic validation program/version: NA


QAPP WORKSHEET #37: USABILITY ASSESSMENT

The Data Usability Assessment will be headed by Kim Watson, QAO, of Stone Environmental, Inc. The

Project Manager will be responsible for assigning task work to the individual task members who will be

supporting the Data Usability Assessment. After the Data Usability Assessment has been performed, data

deemed appropriate for use will then be used to support the FS. The results of the Data Usability Assessment

will be presented in the Final Remedial Action Report. The accuracy, precision and completeness of data will

be assessed and conclusions drawn based on their results. Accuracy and precision of analytical results will be

evaluated based on criteria specified in the analytical methods used. Such criteria will include, but not be

limited to, blank results, surrogate percent recovery values, correlation coefficients, and detection limits.

Accuracy: The amount of agreement between the true value of a parameter and the measured value. Accuracy

is a statistical measurement of correctness and includes components of random error (variability due to

imprecision) and systemic error. It therefore reflects the total error associated with a measurement. A

measurement is accurate when the value reported does not differ from the true value or known concentration of

the spike or standard. Analytical accuracy is measured by comparing the percent recovery of analytes spiked

into an LCS to a control limit. The percent recovery will be calculated. The control limits for percent recovery

of spike compounds and surrogates are listed in the laboratory SOP corresponding to the specific analytical

method used for analysis.

Precision: The measurement of the agreement between samples from the same population. It is strictly defined

as the degree of mutual agreement among independent measurements as the result of repeated application of the

same process under similar conditions. Precision can be expressed as the standard deviation between

independent samples or as the relative percent difference between duplicate samples.

Completeness: The measure of the amount of validated data obtained compared to that which was expected to

be obtained. The number of valid results divided by the number of possible individual analyte results, expressed

as a percentage, determines the completeness of a data set. For completeness requirements, valid results are all

results not qualified with an “R” flag. An “R” flag is place on the data by the data validator and means that the

data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria.

Representativeness: Expresses the degree to which data accurately and precisely represent characteristics of a

population, parameter, and variation at a sample point, process condition, or environmental condition. More

specifically, it is the degree to which the data gathered by the project accurately and precisely represent the

actual field conditions. To evaluate representation of the sample result, field duplicate (FD) samples will be

collected on a regular basis for all analysis parameters. Representativeness will be evaluated using the RPD

criterion for field and/or laboratory duplicate analyses for this project. According to the Region I guidelines for

data validation, field duplicate acceptance criteria s is 30% RPD for aqueous samples and 50% RPD for non-

aqueous samples. Acceptance specifications for laboratory duplicates are outlined in the laboratory quality

systems manuals. Data representativeness for primary source data for this project will be accomplished through

implementing standard sampling procedures and analytical methods which are appropriate for the intended data

uses.

Sensitivity: The measure of the analytical system to differentiate a target analyte from method or instrument

noise or background. Several measures of sensitivity will be used for this project. The quantitation limit (QL,

also known as reporting limit [RL] or minimum quantitation limit [MQL]) is the sample concentration

equivalent to the lowest calibration standard. It is the lowest level at which the target analyte can be measured

at a known level of precision and accuracy. Other sensitivity values include method detection limits (MDL, also


known as detection limit [DL]). The MDL is a statistical estimate of the minimum concentration of a target

analyte that can be measured in an interference-free matrix. It is recommended that the laboratory MDL be 2 to

5 times less than the QL. A laboratory's estimate of the minimum amount of an analyte in a given matrix that an

analytical process can reliably detect in their facility is defined as the limit of detection (LOD). Deviations from

protocols described in this QAPP or the site-specific QAPP will be documented and approved by the project

manager and discussed in the data summary reports. Data that do not meet the listed QC acceptance criteria will

be reviewed by the project manager or designee and an assessment of the potential effect of the results will be

made. Affected samples may be rejected or reanalyzed at the discretion of the project manager. Data that are

accepted outside these criteria will be flagged with an appropriate data qualifier, and the rationale for accepting

the analysis and associated limitations will be documented.

Standard Operating

Procedures

(Files provided on attached compact disk)

Standard Operating Procedures

KATAHDIN ANALYTICAL SERVICES SOP Number: CA-329-15 STANDARD OPERATING PROCEDURE Date Issued: 03/16

Page 4 of 34

TITLE: ANALYSIS OF PCBs AS TOTAL AROCLORS BY GAS CHROMATOGRAPHY/

ELECTRON CAPTURE DETECTOR (GC/ECD): SW-846 METHOD 8082

Please acknowledge receipt of this standard operating procedure by signing and dating both of the spaces provided. Return the bottom half of this sheet to the QA Department.

I acknowledge receipt of copy of document SOP CA-329-15 titled ANALYSIS OF AS TOTAL

AROCLORS BY GAS CHROMATOGRAPHY/ELECTRON CAPTURE DETECTOR (GC/ECD): SW-

846 METHOD 8082.

Recipient: Date:

KATAHDIN ANALYTICAL SERVICES STANDARD OPERATING PROCEDURE

I acknowledge receipt of copy of document SOP CA-329-15 titled ANALYSIS OF PCBs AS

TOTAL AROCLORS BY GAS CHROMATOGRAPHY/ELECTRON CAPTURE DETECTOR

(GC/ECD): SW-846 METHOD 8082.

Recipient: Date:

KATAHDIN ANALYTICAL SERVICES SOP Number: CA-329-15 STANDARD OPERATING PROCEDURE Date Issued: 03/16 Page 5 of 34 TITLE: ANALYSIS OF PCBs AS TOTAL AROCLORS BY GAS CHROMATOGRAPHY/

ELECTRON CAPTURE DETECTOR (GC/ECD): SW-846 METHOD 8082 1.0 SCOPE AND APPLICATION

This SOP describes all aspects of the analysis of extracts of aqueous, solid, tissue, wipe and oil samples for PCBs by EPA Method 8082A as performed by Katahdin Analytical Service. including sample analysis, data review, standard preparation and instrument calibration. It is applicable to the following compounds: Aroclor-1016 (AR1016), Aroclor-1221 (AR1221), Aroclor-1232 (AR1232), Aroclor-1242 (AR1242), Aroclor-1248 (AR1248), Aroclor-1254 (AR1254), Aroclor-1260 (1260), Aroclor-1262 (AR1262) and Aroclor-1268 (AR1268). Extracts are analyzed by Gas Chromatography-Electron Capture Detector (GC-ECD).

1.1 Definitions

ANALYTICAL BATCH: 20 or fewer samples which are analyzed together with the same method sequence and the same lots of reagents and with the manipulations common to each sample within the same time period or in continuous sequential time periods. METHOD BLANK (laboratory reagent blank): An artificial sample designed to determine if method analytes or other interferences are present in the laboratory environment, the reagents, or the apparatus. For aqueous samples, laboratory reagent grade water is used as a blank matrix; for soil samples, muffled sand is used as a blank matrix. The blank is taken through the appropriate steps of the process. CALIBRATION CHECK: Verification of the ratio of instrument response to analyte amount, a calibration check is done by analyzing for analyte standards in an appropriate solvent. Calibration check solutions are made from a stock solution that is different from the stock used to prepare standards. CALIBRATION STANDARD (WORKING STANDARD): A solution prepared from the stock standard solution that is used to calibrate the instrument response with respect to analyte concentration. INDEPENDENT CALIBRATION VERIFICATION STANDARD (ICV): A solution prepared from a stock standard solution independent of the calibration mix that is used to verify the calibration. LABORATORY CONTROL SAMPLE (LCS): A blank that has been spiked with the analyte(s) from an independent source and is analyzed exactly like a sample. Its purpose is to determine whether the methodology is in control, and whether the laboratory is capable of making accurate and precise measurements. The matrix used should be phase matched with the samples and well characterized.


Page 6 of 34



MATRIX SPIKE/MATRIX SPIKE DUPLICATE (MS/MSD): Predetermined quantities of stock solutions of certain analytes are added to a sample matrix prior to sample extraction and analysis. Samples are split into duplicates, spiked and analyzed. Percent recoveries are calculated for each of the analytes detected. The relative percent difference between the samples is calculated and used to assess analytical precision.

STANDARD CURVE (CALIBRATION CURVE): A curve that plots concentration of known analyte standard versus the instrument response to the analyte.

STOCK STANDARD SOLUTION: A concentrated solution containing a single certified standard that is a method analyte, or a concentrated solution of a single analyte prepared in the laboratory with an assay reference compound. Stock standard solutions are used to prepare calibration standards.

SURROGATES: Organic compounds which are similar to analytes of interest in chemical composition, extraction and chromatography, but which are not normally found in environmental samples. These compounds are spiked into all blanks, Aroclor 1660 standard, samples and spiked samples prior to analysis. Percent recoveries are calculated for each surrogate.

KATAHDIN INFORMATION MANAGEMENT SYSTEM (KIMS): A complete multi-user system with the capabilities of integrating laboratory instrumentation, generating laboratory worksheets, providing complete Lab Order status and generating reports. KIMS utilizes these features through a database.

PE NELSON TURBOCHROM OR HP CHEMSTATION: data acquisition systems that are used to collect chromatographic data. The systems can also be used to archive raw data files.

TARGET: A software system that combines full processing, reporting and comprehensive review capabilities, regardless of chromatographic vendor and data type.

TARGET DB: An oracle database used to store and organize all Target data files.

1.2 Responsibilities

1.2.1 This method is restricted to use by, or under the supervision of analysts experienced in the analysis of PCBs by method 8082. Each analyst must demonstrate and document their ability to generate acceptable results with this method. Refer to Katahdin SOP QA-805, “Personnel Training & Documentation of Capability,” current revision.


Page 7 of 34



1.2.2 It is the responsibility of all Katahdin technical personnel involved in analysis by method 8082 to read and understand this SOP, adhere to the procedures outlined, and to properly document their data in the appropriate lab notebook. Any deviations from the test or irregularities with the samples should also be recorded in the lab notebook and reported to the Department Manager or designated qualified data reviewer responsible for this data.

1.2.3 It is the responsibility of the Department Manager to oversee that members of their group follow this SOP, to ensure that their work is properly documented and to initiate periodic review of the associated logbooks.

1.3 Health and Safety

1.3.1 Users of this procedure must be cognizant of inherent laboratory hazards, proper disposal procedures for contaminated materials and appropriate segregation of hazardous wastes. The toxicity or carcinogenicity of each reagent used in this method has not been precisely defined; however, each chemical should be treated as a potential health hazard. A reference file of material safety data sheets is available to all personnel involved in the chemical analysis. Everyone involved with the procedure must be familiar with the MSDSs (material safety data sheets) for all the materials used in this procedure.

1.3.2 Each qualified analyst or technician must be familiar with Katahdin Analytical Environmental Health and Safety Manual including the Katahdin Hazardous Waste Plan and must follow appropriate procedures. These include the use of appropriate personal protective equipment (PPE) such as safety glasses, gloves and lab coats when working with chemicals or near an instrument and not taking food or drink into the laboratory. Each analyst should know the location of all safety equipment. Each analyst shall receive a safety orientation from their Department Manager, or designee, appropriate for the job functions they will perform.

1.4 Pollution Prevention/Waste Disposal

1.4.1 Whenever possible, laboratory personnel should use pollution prevention techniques to address their waste generation. Refer to the current revision of the Katahdin Hazardous Management Program for further details on pollution prevention techniques.

1.4.2 Wastes generated during the preparation of samples must be disposed of in accordance with the Katahdin Analytical Environmental Health and Safety Manual and SOP SD-903, “Sample Disposal,” current revision. Expired


Page 8 of 34



standards are lab packed, placed in the Katahdin hazardous waste storage area, and disposed of in accordance with this SOP.

1.4.3 Wastes generated during standards preparation are disposed of in the Mixed Flammable Waste (O). After the extracts have been analyzed, the autosampler vials and any expired standard vials or ampules are disposed of in the PCB Vial Waste (H).

2.0 SUMMARY OF METHOD

2.1 Method 8082 provides gas chromatographic conditions for the detection of PPB concentrations of certain PCBs. Prior to the use of this method, appropriate sample extraction techniques must be used. Both neat and diluted organic liquids (Method 3580, waste dilution) may be analyzed by direct injection. A 2 to 5 ul aliquot of sample is injected into a gas chromatograph (GC) using the direct injection technique, and compounds in the GC effluent are detected by an electron capture detector (ECD).

2.2 The sensitivity of Method 8082 usually depends on the concentration of interferences rather than on instrumental limitations. If interferences prevent detection of the analytes, Method 8082 may also be performed on samples that have undergone the following cleanups: Method 3660 - Sulfur Cleanup and Method 3665 - Sulfuric Acid Cleanup.

3.0 INTERFERENCES

Interferences by phthalate esters can pose a problem in PCB determinations when using the electron capture detector. Common flexible plastics contain various amounts of phthalates. Care has to be taken to avoid using any plastic materials during the extraction process. Exhaustive cleanup of reagents and glassware may be required to eliminate background phthalate contamination.

Compounds from the sample matrix to which the detector will respond, such as single-component chlorinated pesticides including the DDT series.

4.0 APPARATUS AND MATERIALS

4.1 Gas chromatograph

4.1.1 GC Hewlett Packard 5890 series I or II connected to the Turbochrom or HP Chemstation data system, or equivalent.


Page 9 of 34



4.1.2 Columns - Instruments are configured with a pre-column originating from the injection port, which is connected to a deactivated glass Y splitter that connects two different columns to two detectors. The most commonly used columns are: RTX-35 30M x 0.53 mm ID, RTX-5 30M x 0.53 MM ID, or RTX-1701 30M x 0.53 mm ID. Equivalent columns can be used.

4.1.3 Detectors: Electron capture detectors (ECD). Note: Two detectors must be employed when using dual columns.

4.2 Volumetric flasks, class A: sizes as appropriate with the ground-glass stoppers.

4.3 Syringes: various sizes for preparing standards and injecting samples on the instrument.

4.4 Vials: various sizes and types including crimp tops.

4.5 Refrigerator for storage of extracts and standards.

5.0 REAGENTS AND STANDARDS

5.1 Solvents

5.1.1 Hexane: pesticide quality or equivalent for diluting samples and standards.

5.2 Standards

5.2.1 Stock standard solutions: Solutions purchased from suppliers like Restek or other acceptable retailers. Expiration dates are one year from date of opening vial or sooner if manufacturers date is less. Upon receipt, all standards are logged into the appropriate logbook with the date of receipt, expiration date, source, lot number, solvent and concentration of compounds. Standard solutions are stored at 4C in polytetrafluoroethylene (PTFE)-sealed containers in the dark.

5.2.2 Calibration standards: Prepared through the dilution of the stock standards with hexane. Expiration date is 6 months or sooner. Information is documented in standards prep logbook. The concentrations of the working PCB calibration standards are 0.05 ug/ml, 0.10 ug/ml, 0.25 ug/ml, 1.0 ug/ml, 2.5 ug/ml, and 10.0 ug/ml. The Aroclor 1660 standard also contain the surrogates Tetrachloro-m-xylene (TCX) and Decachlorobiphenyl (DCB) at the respective concentrations: 0.001 ug/ml, 0.002 ug/ml, 0.005 ug/ml, 0.020 ug/ml, 0.050 ug/ml, and 0.20 ug/ml.



5.2.3 Independent Calibration Verification standard (ICV): Prepared through the dilution of the stock standards with hexane. Expiration date is 6 months or sooner. Information is documented in standards prep logbook. The concentration of the ICV PCB standard is 1.0 ug/ml.

6.0 SAMPLE COLLECTION, PRESERVATION AND HANDLING Extracts must be stored under refrigeration and analyzed within 40 days of extraction.

Note: The holding time above is a recommendation. PCBs are very stable in a variety of matrices, and holding times under the conditions listed above may be as long as a year.

7.0 PROCEDURES

7.1 Extraction

Refer to the appropriate SOPs for the correct extraction procedure. In general, water samples are extracted using methods 3510, 3520 or 3535 while solid samples use methods 3540, 3545, 3546 or 3550. Tissue samples are extracted using method 3545 or 3540. Wipes and oils are generally extracted using method 3580.

7.2 Instrument conditions

Refer to the instrument logbook for the current column and conditions.

Typical conditions are:

Makeup flow: 60 ml/min Helium, Ar/Methane or Nitrogen Column flow: 6 ml/min Injector Temp: 200 Detector Temp: 300 Oven Ramp: 160(0) - 5/min - 260(10) Run time: 30 min Injection size: 2 ul

7.3 Calibration

7.3.1 The GC system is calibrated using the external standard calibration procedure.

Six-point calibration standards of AR1660 (AR1016 and AR1260), AR1242, and AR1254 are prepared. Six-point calibration standards of AR1221, AR1232, AR1248, AR1262 and AR1268 are also prepared. If AR1221, AR1232,



AR1248, ARR1262 and AR1268 are suspected, then a six-point curve of the respective Aroclor will be analyzed prior to the analysis of samples. At a minimum, a single point calibration standard is analyzed for these Aroclors. If using a single point and the Aroclor is required for a project and is detected in a sample, then the GC would be calibrated for the Aroclor and the samples would be reanalyzed.

Each calibration standard is injected using the technique that is used to

introduce the actual samples into the GC. Three to five characteristic peaks from each Aroclor are used to calibrate a curve. The Target system will calculate a peak height for all three to five peaks in each Aroclor. A separate calibration curve for each of the three to five peaks can be prepared in Target using the peak height against the concentration of the standard. A non-linear calibration applying a second order polynomial (quadratic fit) equation is used to prepare the curve. In order to be used for quantitative purposes, the Coefficient of Determination (r2) must be greater than or equal to 0.990. The quadratic equation is:

y = ax2 + bx + c

where: y = Instrument response b = Slope of the line x = Concentration of the calibration standard c = the intercept

7.3.2 A non-linear calibration model may not be allowable for certain states, federal

programs, or clients. South Carolina does not allow non-linear calibration work originating in their state. In these cases, a linear calibration model must be used. Each calibration standard is injected using the technique that is used to introduce the actual samples into the GC. Three to five characteristic peaks from each Aroclor are used to calibrate a curve. The Target system will calculate a peak height for all three to five peaks in each Aroclor. A separate calibration curve for each of the three to five peaks can be prepared in Target using the peak height against the concentration of the standard.

7.3.2.1 Linear calibration using the average calibration factor

The calibration factor (CF) is calculated using the following formula: CF= As / Cs Where: As = Peak area (or height) of the analyte or surrogate. Cs = Concentration of the analyte or surrogate, in μg/L.



To evaluate the linearity of the initial calibration, calculate the mean CF, the standard deviation (SD), and the RSD. If the RSD of the calibration factor is less than or equal to 20% over the calibration range, then linearity through the origin may be assumed, and the average calibration or response factor may be used to determine sample concentrations.

7.3.2.2 Linear calibration using a least squares regression

y = bx + c where: y = Instrument response b = Slope of the line x = Concentration of the calibration standard

c = the intercept

The analyst should not force the line through the origin, but have the intercept calculated from the five data points. In addition, do not include the origin (0,0) as a sixth calibration point. The regression calculation will generate a correlation coefficient (r) that is a measure of the "goodness of fit" of the regression line to the data. A value of 1.00 indicates a perfect fit. In order to be used for quantitative purposes, r must be greater than or equal to 0.995. The ICAL must be successful before any samples or other QC check samples can be analyzed.

7.3.3 All six point calibration curves (AR1660, AR1242 AR1454 and if any other

Aroclor is required) must be checked initially by analyzing a standard containing the same analytes as the curve but prepared from another source. If the response of the analytes from the independent source varies by more than 20%, a new independent source standard must be analyzed or a new calibration curve must be prepared and/or analyzed.

7.3.4 The working calibration curve must be verified prior to sample analysis and

every 10 samples thereafter by injecting the mid-point calibration standard. If the response for any analyte varies from the expected response by more than 15%, a new calibration curve must be prepared for that analyte. The average result for 5 peak heights of the Aroclors is used for quantitation. For clients or projects requiring DoD QSM, current version, compliance, the response for any analyte must not vary from the expected response by more than + 20%, or a new calibration curve must be prepared for that analyte. If the



CCV fails the above criteria, reanalyze all samples since the last successful calibration verification. If reanalysis cannot be performed, data must be qualified and explained in the narrative. Additionally, apply a Q-flag to all results for the specific analyte(s) in all samples since the last acceptable calibration verification.

7.4 Retention time windows

7.4.1 Three injections are made of all the PCBs throughout the course of a 72 hour period.

7.4.2 A major peak from the envelope is chosen and a standard deviation is

calculated using the three retention times for that peak. 7.4.3 Plus or minus three times the standard deviation of the retention times for each

standard is used to define the retention time window; however, the experience of the analyst should weight heavily in the interpretation of chromatograms. The analyst should use the retention time window, but should primarily rely on pattern recognition.

7.4.4 Retention time windows are calculated for each standard on each GC column at

method setup and after major maintenance, including whenever a new GC column is installed. The data is kept on file in the laboratory.

7.4.5 If the calculated retention time window results in a value of 0.03 minutes or less,

the laboratory will apply nominal windows. This is done in order to avoid any false negative hits because of the window being to narrow. The windows are: 0.07 for all target analytes. By utilizing these windows, a false positive hit may be initially indicated, but an experienced analyst could determine a false positive from scrutinizing the chromatograms. Please note that the use of nominal retention time windows may not be allowable for certain states, federal programs, or clients. South Carolina does not allow the use of nominal limits for compliance work originating in their state. In these cases, a window of 0.03 minutes must be used if the established retention time window is less than 0.03 minutes.

7.5 Gas chromatographic analysis

7.5.1 Shake samples and let them sit for one minute before vialing for analysis. 7.5.2 All instrument injections are performed using the direct injection technique with

an autosampler set for 2-5 ul injection volumes.



7.5.3 Samples are analyzed in a set referred to as an analysis sequence. The sequence begins with instrument calibration as listed in section 7.3 followed by sample extracts interspersed with mid-concentration calibration standards. Before any samples are analyzed the instrument must be calibrated by analyzing a six-point calibration or a 1.0ppm calibration verification standard (CV) for AR1660, AR1242 and AR1254. If a CV is run, the calculated concentration must not exceed a difference of 15%. For clients or projects requiring DoD QSM (current version), the response for any analyte must not vary from the expected response by more than + 20%.

Each sample analysis must be bracketed with an acceptable initial calibration or an opening CV and an ending CV for each 12-hour shift. The closing CV for all Aroclors is a 0.25ppm concentration standard. If a second window of samples is run immediately after the closing CVs, the concentration of all aloclors at the completion of this window would be 1.0ppm. The calibration standard must also be injected at intervals of not less than once every ten samples and at the end of the analysis sequence. If the CV fails, the instrument is checked for any obvious problems and maintenance is performed if deemed necessary. Another CV is analyzed or the instrument is recalibrated and then samples are injected. All samples that were injected after the standard exceeding the criterion must be reinjected. If reanalysis cannot be performed, data must be qualified and explained in a narrative. Additionally, apply a Q-flag to all results for the specific analyte(s) in all samples since the last acceptable calibration verification.

7.5.3.1 However, if the CV analyzed after a group of samples exhibits a

response is more than 15% (or 20%) above the initial calibration response and the analyte was not detected in the samples analyzed during the analytical shift, then the extracts for those samples may not need to be reanalyzed, as the CV standard has indicates a high bias and the analyte would have been detected if it were present. For clients or projects requiring DoD QSM, current version, compliance, a Non-conformance report should be filled out and the client needs to be contacted before reporting the sample results.

7.5.3.2 In contrast, if the CV analyzed after a group of samples exhibits a

response is more than 15% (or 20%) above the initial calibration response and the analyte was detected in the samples analyzed during the analytical shift then re-injection is necessary to ensure accurate quantitation. If the CV analyzed after a group of samples exhibits a response is more than 15% (or 20%) below the initial



calibration response and the analyte was not detected in the samples analyzed during the analytical shift, reanlaysis is necessary to ensure that the detector response had not deteriorated to the point that the analyte would not have been detected even though it was present.

7.5.4 The center of the retention time window for each analyte and surrogate is

established by using the absolute retention time for each analyte and surrogate from the daily opening calibration verification or initial calibration.

7.5.5 The identification of PCBs is based on agreement between the retention times

of peaks in the sample chromatogram with the retention time windows established through the analysis of standards of the target analytes. An analyte is tentatively identified when a peak from a sample falls within the daily retention time window. Each tentative identification must be confirmed using a second GC column of dissimilar stationary phase or using another technique such as GC/MS. If the retention times of the peaks on both columns fall within the retention time windows on the respective columns, then the target analyte identification has been confirmed.

7.5.5.1 An additional criterion is applied for the identification and quantitation

of PCBs. Identification is based on the characteristic fingerprint retention time and shape of the major peaks. Major peaks are defined as those peaks in the Aroclor standard that are at least 25% of the height of the largest Aroclor peak. The sample chromatogram is compared to the individual Aroclor standard chromatograms. Once the Aroclor pattern has been identified, a concentration is then calculated in Target.

7.5.5.2 Three to five Aroclor concentrations are calculated using the peak

heights of the three to five characteristic peaks of the Aroclor. These three to five concentrations are then averaged to determine the concentration of that Aroclor.

7.5.6 When samples are analyzed from a source known to contain specific Aroclors,

the results from a single-column analysis may be confirmed on the basis of a clearly recognizable Aroclor pattern.

7.5.7 If the response for an analyte exceeds the calibration range of the system, the

sample must be diluted and reanalyzed. 7.5.8 If peak detection and identification are prevented due to interferences, the

hexane extract may need to undergo a cleanup. The extract may be subjected to a sulfur cleanup (method 3660) and/or a sulfuric acid cleanup (method 3665).



Note: Samples routinely receive a sulfuric acid clean up. However, for samples from a known site with a clean matrix, a sulfuric acid clean up may not be performed. Whenever a sample receives a cleanup, the associated QC must also be subjected to the same cleanup(s) and reanalyzed.

7.5.9 When a GC system is determined to be out of control because either a CV cannot pass or a six point calibration does not meet the correlation coefficient criteria, instrument maintenance is likely necessary. Routine instrument maintenance may involve changing the septum, replacing the liner, clipping the pre-column, or replacing the column. This information is recorded in the instrument run log (Figure 1). When an instrument requires more severe maintenance like replacing the ECD or an electronic board, this information is written in the instrument maintenance logbook.

7.6 Calculations

7.6.1 The concentration of an analyte is calculated by using the calibrated curve that

is prepared in Target. When an analyte is identified, Target displays a concentration after the file is processed through the appropriate calibration method. Aroclor quantitation is accomplished by the method described in section 7.5.4.1.1. However, if a sample contains more than one Aroclor, a peak common to both analytes must not be used to quantitate either compound.

7.6.2 The concentrations from the reports are then incorporated with the extraction

data to arrive at a final concentration. Water: Concentration (ug/L) = (C) (Vt)/ (Vs) Soil/Sediment: Concentration (mg/kg) = (C) (Vt)/ (Ws) (D) where, C = concentration calculated by Target in ug/ml

Vt = Volume of total extract including any instrument dilutions Vs = Volume of sample extracted Ws = Weight of sample extracted D = Decimal total solids

7.7 Data Review

7.7.1 Initial Data Review

The initial data review is accomplished by the analyst who ran the samples. This review is of sufficient quality and detail to provide a list of samples that need to be reanalyzed or diluted and reanalyzed. The initial data review is



performed on the detailed quantitation reports of the analyzed samples. This data review examines criteria that directly impact whether or not the sample needs to be reanalyzed and/or extracted. These criteria include:

QC criteria for method blank, LCS, MS/MSD, and calibration – refer to

section 8.0. Surrogate recovery Chromatography: cleanups, manual integration. Target compound detection: quantitation, confirmation, false positives. The requirement of the GC laboratory is that this initial data review be completed no later than the end of the next workday. After the analyst has completed his or her initial data review, the information is then ready to be processed for reporting. Refer to section 7.8.

7.7.2 Surrogate recovery

All recoveries must meet the most recent laboratory established acceptance

limits, which are listed on the GC Laboratory Surrogate Acceptance Limit sheet.

The sample is evaluated for recoveries of the two surrogates. If the recovery of one surrogate is within the acceptance limit, and the second is out, the data is narrated. If the surrogate recoveries are high for both and the sample contains less than the PQL for all target analytes, the data is narrated. If the surrogate recoveries are low and may be attributable to matrix interference or a matrix effect, the data is narrated. If the surrogate recoveries are low and the sample concentration is less than the PQL for all target analytes and there is no apparent matrix effect, reextract the sample. For method blanks, if the recoveries of both surrogates are low or high, and the blank does not contain any target analytes above the PQL, and the recoveries of both surrogates in the sample(s) are acceptable, the data is narrated. If the recoveries in the blank are low and it does not contain any target analytes above the PQL, and the recoveries in the samples are acceptable but the sample contains one or more target analytes above the PQL, the sample may be reextracted.

For laboratory control samples (LCS), if the only discrepancy in the extraction batch is with the LCS, and the analyte spike recoveries are acceptable, the data is narrated. If the recoveries of both the surrogates and the analyte spikes are low, the samples may need to be reextracted.



For DoD QSM (current version) use QC acceptance criteria specified by DoD, if available. Otherwise, use in-house control limits. When the surrogate recoveries fall outside of the acceptance criteria, apply Q-flag to all associated analytes.

7.7.3 Chromatography

The chromatography should be examined for the presence of any non-target peaks, which can be used as an indication of whether or not matrix interference might be influencing surrogate recoveries. If the chromatogram indicates interferences, then a cleanup may be needed. See section 7.5.7. Manual integrations are to be performed when chromatographic conditions preclude the computer algorithm from correctly integrating the peak of concern. In no instance shall a manual integration be performed solely to bring a peak within criteria. Each peak of concern is examined by the primary analyst to ensure that the peak was integrated properly by the computer algorithm. Should a manual integration be necessary (for instance, due to a split peak, peak tailing, or incomplete resolution of isomeric pairs), an “m” qualifier will automatically be printed on the quantitation report summary. The analyst will date and initial the “m” on the quanitation report summary and assign a code that indicates the reason for the manual integration. Refer to Katahdin SOP QA-812 “Manual Integration on GC/MS, GC, HPLC and IC Datasystems” for more information.

7.7.4 Target Compound Detection

GC analysis relies heavily on the experience of the analyst. Sample chromatograms must be evaluated focusing on scientific judgment, knowledge of the column behavior and matrix effects. The chromatogram from channel A is evaluated with that from channel B. If a target analyte is present on both channels and the concentration is within the calibration range, and the quantitation from both chromatograms agrees within 40%, the analyte is considered present in the sample. In cases where the RPD is greater than 40% and the analyte is reported, the analyte must be J-flagged and narrated. The higher of the two concentrations is reported unless matrix interference is causing erroneously high results. In this case report the lower result and narrate. In some cases a non-confirming analyte may be reported. In these cases the analyte must be Q-flagged and narrated...



In order to avoid reporting false positives, identified peaks on a chromatogram may need to be undetected electronically in Target. The possible scenarios are: If an analyte is present on one column but its concentration is below the PQL, if an analyte is present on one column but does not confirm on the other channel, if an analyte is present on both columns but the concentrations differ by more than 40%, or if an analyte is present but its retention time is 0.04 minutes or more than the retention time of the analyte in the preceding CV. The GC Analyst must rely on technical experience in reviewing chromatograms in determining if a hit is an actual analyte or a false positive. If reporting data that has an RPD that is >40%, the data must be flagged with a “J” indicating that the result is an estimated value. Sometimes interference on one column (i.e. sulfur) will prevent a target analyte from detection and it is present on the conformational column. In this scenario, the result would be reported from one column and need to be “Q” flagged to indicate that it was not confirmed on a second column.

7.7.5 Reporting

After the chromatograms have been reviewed and any target analytes have been quantitated using Target, the necessary files are brought into KIMS. Depending on the QC level requested by the client, a Report of Analysis (ROA) and additional reports, such as LCS forms and chronology forms, are generated. The package is assembled to include the necessary forms and raw data. The data package is reviewed by the primary analyst and then forwarded to the secondary reviewer. The secondary reviewer validates the data and checks the package for any errors. When completed, the package is sent to the Department Manager for final review. A completed review checklist is provided with each package. The final data package from the Organics department is then processed by the Data Management department.

8.0 QUALITY CONTROL AND ACCEPTANCE CRITERIA

Refer to Table 1 and to details in this section for a summary of QC requirements, acceptance criteria, and corrective actions. These criteria are intended to be guidelines for analysts. The criteria does not cover all possible situations. If any of the QC requirements are outside the recovery ranges listed in this section or in Table 1, all associated samples must be evaluated against all the QC. In some cases data may be reported, but may be reanalyzed in other cases. Making new reagents and standards may be necessary if the standardization is suspect. The corrective actions listed in this section and in Table 1 may rely on analyst experience to make sound scientific judgments. These decisions are based on holding time considerations, client and project specific Data Quality Objectives and on review of



chromatograms. The supervisor, Operations Manager, and/or Quality Assurance Officer may be consulted to evaluate data. Some samples may not be able to be reanalyzed within hold time. In these cases “qualified” data with narration may be advisable after consultation with the client. In some cases the standard QC requirements listed in this section and in Table 1 may not be sufficient to meet the Data Quality Objectives of the specific project. Much of the work performed at the lab is analyzed in accordance with specific QC requirements spelled out in a project specific Quality Assurance Project Plan (QAPP) or in a program specific Quality Systems Manual (QSM). The reporting limits, acceptance criteria and/or corrective actions may be different than those specified in this SOP. In these cases the appropriate information will be communicated to the Department Manager and/or senior chemists before initiation of the analyses so that specific product codes can be produced for the project. In addition, the work order notes for each project will describe the specific QAPP or QSM to be followed.

8.1 For each analytical batch (up to 20 samples), a method blank, laboratory control

sample (LCS), matrix spike and matrix spike duplicate are analyzed. They are carried through all stages of the sample preparation and analysis steps.

8.2 Spike concentrations: The LCS and the MS/MSD are spiked at the same concentration with AR1660. The spike concentrations are:

Compound WATER ug/L SOILS mg/kg AR1660 5.0 0.17

The surrogate spike concentrations in the final extract are:

Compound WATER ug/ml SOILS ug/ml Tetrachloro-m-xylene(TCX) 0.10 0.10 DCB 0.10 0.10

8.3 LCS and MS/MSD acceptance criteria and Corrective Action: All QC samples are calculated for percent recovery of the spiked analyte. The recoveries are compared to laboratory established acceptance limits. The LCS acceptance limits for PCBs are established for both water and soil matrices. The MS/MSD acceptance limits for PCBs use the respective matrix LCS acceptance limits. Separate limits for MS/MSD pairs are not calculated because of the varying matrices involved. In addition many of the MS/MSD data points cannot be used (i.e. recoveries not calculable due to a matrix effect). If any spike compound in the laboratory control sample falls outside of the established recovery acceptance limit window, the QC sample is considered to be out of control and any sample that is associated should be evaluated with other QC elements to determine the corrective action. If the recovery is high and the associated samples do



not contain the specific compound(s), the data can possibly be accepted with narration. In other cases, the associated samples must be extracted. If a spike compound is outside of the acceptance limits in the matrix spike sample but is acceptable in the LCS, the data is considered acceptable. The cause of the failure is possibly attributable to matrix interference. However, if the compound fails in both the LCS and the MS/MSD, the result for that analyte is suspect and may not be reported for regulatory compliance purposes. For DoD QSM (current version), use QC acceptance criteria specified by DoD, if available. Otherwise use in-house control limits. In-house control limits must not be greater than + 3 times the standard deviation of the mean LCS recovery. If the LCS fails the acceptance criteria, correct problem, then reprep and reanalyze the LCS and all samples in the associated preparatory batch for failed analytes, if sufficient sample material is available. If reanalysis cannot be performed, data must be qualified and explained in the narrative. Apply Q-flag to specific analyte(s) in all samples in the associated preparatory batch. For MS, when applying DoD QSM (current version), apply J-flag to specific analyte(s) also in parent sample, if acceptance criteria not met. RPD must be </= 30% between MS and MSD.

8.4 Surrogate acceptance criteria and Corrective Action: Surrogate recoveries are

calculated on all samples, blanks and spikes. The recoveries are compared to laboratory established acceptance limits.

When a sample has a surrogate that falls outside of the laboratory established acceptance limit window, the problem should be investigated. If the recovery looks like it is affected by the sample matrix, the sample may be reinjected to confirm matrix interference. When a sample has no detectable surrogate recovery, the sample should be reextracted. For DoD QSM, use QC acceptance criteria specified by DoD, if available. Otherwise, use in-house control limits. When the surrogate recoveries fall outside of the acceptance criteria, apply Q-flag to all associated analytes.

8.5 Non-conformance Report: Whenever data is not acceptable because of a failing LCS or

surrogate recovery, a non-conformance report (NCR) must be initiated as soon as possible to document resolution.


ELECTRON CAPTURE DETECTOR (GC/ECD): SW-846 METHOD 8082 9.0 METHOD PERFORMANCE

The method detection limit (MDL) is defined as the minimum concentration of a substance that can be measured and reported with 99% confidence that the value is above zero. The MDLs shall be determined and verified one time per type of instrument unless otherwise required by the method. A Limit of Detection (LOD) is an estimate of the minimum amount of a substance that an analytical process can reliably detect. An LOD is analyte and matrix specific and may be laboratory-dependent. LODs must be determined for all parameters for which the laboratory is accredited under the DoD Environmental Laboratory Accreditation Program. LOD’s must be verified for every preparation and analytical method combination and on every applicable instrument on a quarterly basis. The Limit of Quantitation (LOQ) is the minimum levels, concentrations, or quantities of a target variable (e.g., target analyte) that can be reported with a specified degree of confidence. The LOQ shall be set at the lowest point in the calibration curve for all analyses utilizing an initial calibration. LOQ’s must be verified quarterly for every preparation and analytical method combination and on every applicable instrument on a quarterly basis for all parameters included in the DoD Scope of Accreditation. The LOQ must be verified at least once annually if the analysis is not included in the DoD Scope of Accreditation. MDLs are filed with the Organic Department Manager and then with the QAO. LOD and LOQ verifications are filed with the QAO Refer to the current revision of Katahdin SOP QA-806, Method Detection Limit, Instrument Detection Limit and Reporting Limit Studies and Verifications, for procedures on determining the MDL.

Refer to the current revision of Method 8082 for other method performance parameters and requirements.

10.0 APPLICABLE DOCUMENTS/REFERENCES

Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, 3rd Edition. Final Update IV, dated February, 2007, Method 8082A. The National Environmental Laboratory Accreditation Conference (NELAC) Standards, June 2003. The NELAC Institute, Laboratory Accreditation Standards, Volume 1, Management and Technical Requirements for Laboratories Performing Environmental Analysis, 10/06/2010.



Department of Defense Quality Systems Manual for Environmental Laboratories (DOD QSM), Version 4.2, 10/25/2010.

Department of Defense (DoD) and Department of Energy (DOE) Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, DoD QSM Version 5.0, March, 2013 Katahdin Analytical Services, SOP CA-101, Equipment Maintenance and Troubleshooting, current revision.

Katahdin Analytical Services, SOP QA-806, Method Detection Limit, Instrument Detection Limit and Reporting Limit Studies and Verifications, current revision.

LIST OF FIGURES

Table 1 QC Requirements Table 2 DoD QSM Version 4.2 QC Requirements Table 3 DoD QSM Version 5.0 QC Requirements Table 4 Summary of Method Modifications Figure 1 Instrument Run Log Figure 2 Review Checklist Figure 3 PQLs



TABLE 1

QC REQUIREMENTS

QC Check Minimum

Frequency

Acceptance Criteria Corrective Action

6pt calibration of Aroclor 1660, 1242, 1254 and mid-point cal of other Aroclors

Initial cal prior to sample analysis

Average Model – at least 5 points, % RSD </= 20% Linear Model – at least 5 points, correlation coefficient (r) 0.995 Quadratic Model – at least 6 pt calibration, coefficient of determination (r2) 0.990

(1) Repeat Initial calibration (2) If single pt cal Aroclor is identified in analysis of sample,5 or 6-pt calibration (depending on calibration model) of identified compound with reanalysis of sample.

Independent Calibration Verification

Immediately following calibration

± 20 % D (1) Reanalyze standard (2) Reprep standard (3) Reprep standard from fresh stock.

CCV After every 10 samples; If calibration curve previously analyzed, analyze daily before samples.

± 15 % D (1) Evaluate the samples: If the %D >+15% and sample results are <PQL, narrate.

(2) If %D >15% only on one channel, narrate. If %D >15% for closing CV, and is likely a result of matrix interference, narrate.

(3) Otherwise, reanalyze all samples back to last acceptable CV.

Method blank One per prep batch

No analyte detected >PQL

(1) Investigate source of contamination (2) Evaluate the samples and associated QC: i.e. If the

blank results are above the PQL, report sample results which are <PQL or > 10X the blank concentration.

(3) Otherwise, reprep a blank and the remaining samples.

LCS One per prep batch of twenty or fewer samples

Laboratory statistically derived limits.

(1) Evaluate the samples and associated QC: i.e. If an MS/MSD was performed and acceptable, narrate.

(2) If an LCS/LCSD was performed and only one of the set was unacceptable, narrate.

(3) If the surrogate recoveries in the LCS are also low but are acceptable in the blank and samples, narrate.

(4) If the LCS recovery is high but the sample results are <PQL, narrate.

(5) Otherwise, reprep a blank, QC and the remaining samples.

Matrix Spike\ Matrix Spike Duplicate

One for every set of 20 samples

Same as for LCS (1) Evaluate the samples and associated QC: i.e. If the LCS results are acceptable, narrate.

(2) If both the LCS and MS/MSD are unacceptable reprep samples and QC.

Sample Duplicate

One sample duplicate per ten samples if requested

RPD <20 (1) If lab QC in criteria and matrix interference suspected, flag data or narrate

(2) Otherwise, reanalyze

Demonstration of analyst proficiency – 4 replicates

Once per analyst initially and annually thereafter

P&A meet method criteria (1) Repeat P&A study

MDL study Refer to KAS SOP QA-806, “Method Detection Limit, Instrument Detection Limit and Reporting Limit Studies and Verifications”, current revision.



TABLE 2

DOD QSM 4.2 QC REQUIREMENTS

QC Check Minimum

Frequency

Acceptance Criteria Corrective Action Flagging Criteria Comments

Demonstrate acceptable analytical capability

Prior to using any test method and at any time there is a significant change in instrument type, personnel, test method, or sample matrix.

QC acceptance criteria published by DoD, if available; otherwise, method-specified criteria.

Recalculate results; locate and fix problem, then rerun demonstration for those analytes that did not meet criteria.

Not Applicable (NA). This is a demonstration of analytical ability to generate acceptable precision and bias per the procedure in Appendix C. No analysis shall be allowed by analyst until successful demonstration of capability is complete.

LOD determination and verification

Refer to current revision of SOP QA-806

LOQ establishment and verification

Refer to current revision of SOP QA-806

Retention time (RT) window width calculated for each analyte and surrogate

At method set-up and after major maintenance (e.g., column change).

RT width is ± 3 times standard deviation for each analyte RT from a 72-hour study.

NA. NA.

Minimum five-point initial calibration (ICAL) for all analytes

ICAL prior to sample analysis.

6 point calibration of Aroclors 1016, 1242,1254 and 1260 - One of the options below: Option 1: RSD for each analyte ≤ 20%; Option 2: linear least squares regression: r ≥ 0.995; Option 3: non-linear regression: coefficient of determination (COD) r2 ≥ 0.99 (6 points shall be used for second order). Mid point calibration of Aroclors 1221, 1232 and 1248; if targets are detected, 6-point calibration is performed.

Correct problem then repeat ICAL.

Flagging criteria are not appropriate.

Problem must be corrected. No samples may be run until ICAL has passed. Calibration may not be forced through the origin. Quantitation for multicomponent analytes such as chlordane, toxaphene, and Aroclors must be performed using a 5-point calibration. Results may not be quantitated using a single point.

Retention time window position establishment for each analyte and surrogate

Once per ICAL and at the beginning of the analytical shift.

Position shall be set using the midpoint standard of the ICAL curve when ICAL is performed. On days when ICAL is not performed, the initial CCV is used.

NA. NA.



TABLE 2


QC Check Minimum

Frequency


Second source calibration verification (ICV)

Immediately following ICAL.

All project analytes within established retention time windows. All project analytes within ± 20% of expected value from the ICAL.

Correct problem, rerun ICV. If that fails, repeat ICAL.

Flagging criteria are not appropriate.

Problem must be corrected. No samples may be run until calibration has been verified.

calibration verification (CCV)

Prior to sample analysis, after every 10 field samples, and at the end of the analysis sequence.

All project analytes within established retention time windows. All project analytes within ± 20% of expected value from the ICAL.

Correct problem, then rerun calibration verification. If that fails, then repeat ICAL. Reanalyze all samples since the last successful calibration verification.

If reanalysis cannot be performed, data must be qualified and explained in the case narrative. Apply Q-flag to all results for the specific analyte(s) in all samples since the last acceptable calibration verification.

Problem must be corrected. Results may not be reported without a valid CCV. Flagging is only appropriate in cases where the samples cannot be reanalyzed. Retention time windows are updated per the method.

Method blank One per preparatory batch.

No analytes detected > ½ RL (> RL for common lab contaminants) and > 1/10 the amount measured in any sample or 1/10 the regulatory limit (whichever is greater). Blank result must not otherwise affect sample results.

Correct the problem. Report sample results that are <LOD or >10x the blank concentration. Reprepare and reanalyze the method blank and all associated samples with results > LOD and < 10x the contaminated blank result. Contact Client if samples cannot be reprepped within hold time.

If reanalysis cannot be performed, data must be qualified and explained in the case narrative. Apply B-flag to all results for the specific analyte(s) in all samples in the associated preparatory batch.

Problem must be corrected. Results may not be reported without a valid method blank. Flagging is only appropriate in cases where the samples cannot be reanalyzed.

Laboratory control sample (LCS) containing all analytes to be reported, including surrogates

One per preparatory batch.

The laboratory shall use laboratory control limits (CLs) or use DoD-generated LCS-CLs, if available depending on project requirements. In-house CLs may not be greater than ± 3 times the standard deviation of the mean LCS recovery. A number of analytes may fall outside the CL but within marginal exceedance limit depending on the total number of analytes in the LCS.

Correct problem, then reprep and reanalyze the LCS and all samples in the associated preparatory batch for failed analytes, if sufficient sample material is available. Refer to Table G-1 for number of marginal exceedences allowed. Contact Client if samples cannot be reprepped within hold time.

If reanalysis cannot be performed, data must be qualified and explained in the case narrative. Apply Q-flag to specific analyte(s) in all samples in the associated preparatory batch.

Problem must be corrected. Results may not be reported without a valid LCS. Flagging is only appropriate in cases where the samples cannot be reanalyzed.



TABLE 2


QC Check Minimum

Frequency


Matrix spike (MS)

One per preparatory batch per matrix if sufficient sample is available.

For matrix evaluation, use laboratory control limits (CLs) or use DoD-generated LCS-CLs, if available depending on project requirements.

Examine the project-specific DQOs. Contact the client as to additional measures to be taken.

For the specific analyte(s) in the parent sample, apply J-flag if acceptance criteria are not met.

For matrix evaluation only. If MS results are outside the LCS limits, the data shall be evaluated to determine the source of difference and to determine if there is a matrix effect or analytical error.

Matrix Spike duplicate (MSD)

One per preparatory batch per matrix if sufficient sample is available.

MSD: For matrix evaluation, use laboratory LCS CLs or use DoD-generated LCS CLs, if available depending on project requirements. MS/MSD: RPD ≤ 30%.

Examine the project-specific DQOs. Contact the client as to additional measures to be taken.

For the specific analyte(s) in the parent sample, apply J-flag if acceptance criteria are not met.

The data shall be evaluated to determine the source of difference.

Surrogate spike

All field and QC samples.

The laboratory shall use laboratory CLs or use DoD-generated Surrogate CLs, if available depending on project requirements.

For QC and field samples, correct problem then reprep and reanalyze all failed samples for failed surrogates in the associated preparatory batch, if sufficient sample material is available. If obvious chromatographic interference with surrogate is present, reanalysis may not be necessary. Contact Client if samples cannot be reprepped within hold time.

Apply Q-flag to all associated analytes if acceptance criteria are not met.

Alternative surrogates are recommended when there is obvious chromatographic interference.

Confirmation of positive results (second column or second detector)

All positive results must be confirmed (with the exception of Method 8015).

Calibration and QC criteria same as for initial or primary column analysis. Results between primary and second column RPD ≤ 40%.

NA. Apply J-flag if RPD > 40%. Discuss in the case narrative.

Use project-specific reporting requirements if available; otherwise, use method reporting requirements; otherwise, report the result from the primary column.

Results reported between DL and LOQ

NA. NA. NA. Apply J-flag to all results between DL and LOQ.



TABLE 3

DOD QSM 5.0 REQUIREMENTS

QC Check Minimum Frequency Acceptance Criteria Corrective Action Flagging Criteria Comments

Initial Calibration (ICAL) for all analytes (including surrogates)

At instrument set-up and after ICV or CCV failure, prior to sample analysis.

ICAL must meet one of the three options below: Option 1: RSD for each analyte</= 20%; Option 2: linear least squares regression for each analyte: r >/= 0.995; Option 3: non-linear least squares regression (quadratic) for each (quadratic) for each analyte: r2 >/= 0.99.

Correct problem then repeat ICAL.

Flagging is not appropriate.

Minimum 5 levels for linear and 6 levels for quadratic. Quantitation for multicomponent analytes such as chlordane, toxaphene, and Aroclors must be performed using a 5-point calibration. Results may not be quantitated using a single point. No samples shall be analyzed until ICAL has passed.

Retention Time window position establishment

Once per ICAL and at the beginning of the analytical sequence.

Position shall be set using the midpoint standard of the ICAL curve when ICAL is performed. On days when ICAL is not performed, the initial CCV is used.

NA. NA. Calculated for each analyte and surrogate.

Retention Time (RT) window width

At method set-up and after major maintenance (e.g., column change).

RT width is ± 3 times standard deviation for each analyte RT from the 72-hour study.

NA. NA. Calculated for each analyte and surrogate.

Initial Calibration Verification (ICV)

Once after each ICAL, analysis of a second source standard prior to sample analysis.

All reported analytes within established RT windows. All reported analytes within ± 20% of true value.

Correct problem, rerun ICV. If that fails, repeat ICAL.

Flagging is not appropriate.

No samples shall be analyzed until calibration has been verified with a second source.

Continuing Calibration Verification (CCV)

Before sample analysis, after every 10 field samples, and at the end of the analysis sequence with the exception of CCVs for Pesticides multi-component analytes (i.e. Toxaphene, Chlordane), which are only required before sample analysis.

All reported analytes and surrogates within established RT windows. All reported analytes and surrogates within ± 20% of true value.

Recalibrate, and reanalyze all affected samples since the last acceptable CCV; or Immediately analyze two additional consecutive CCVs. If both pass, samples may be reported without reanalysis. If either fails, take corrective action(s) and re-calibrate; then reanalyze all affected samples since the last acceptable CCV.

If reanalysis cannot be performed, data must be qualified and explained in the case narrative. Apply Q-flag to all results for the specific analyte(s) in all samples since the last acceptable calibration verification.

Results may not be reported without a valid CCV. Flagging is only appropriate in cases where the samples cannot be reanalyzed.



TABLE 3



Method Blank (MB) One per preparatory batch.

No analytes detected > 1/2 LOQ or > 1/10 the amount measured in any sample or 1/10 the regulatory limit, whichever is greater.

Correct problem. If required, reprep and reanalyze MB and all samples processed with the contaminated blank.

If reanalysis cannot be performed, data must be qualified and explained in the case narrative. Apply B-flag to all results for the specific analyte(s) in all samples in the associated preparatory batch.

Results may not be reported without a valid method blank. Flagging is only appropriate in cases where the samples cannot be reanalyzed.

Laboratory Control Sample (LCS)


A laboratory must use the QSM Appendix C Limits for batch control if project limits are not specified. If the analyte(s) are not listed, use in-house LCS limits if project limits are not specified.

Correct problem, then reprep and reanalyze the LCS and all samples in the associated preparatory batch for failed analytes, if sufficient sample material is available.

If reanalysis cannot be performed, data must be qualified and explained in the case narrative. Apply Q-flag to specific Apply Q-flag to specific analyte(s) in all samples in the associated preparatory batch.

Results may not be reported without a valid LCS. Flagging is only appropriate in cases where the samples cannot be reanalyzed.

Matrix Spike (MS) One per preparatory batch.

A laboratory must use the QSM Appendix C Limits for batch control if project limits are not specified. If the analyte(s) are not listed, use in-house LCS limits if project limits are not specified.

Examine the project- specific requirements. Contact the client as to additional measures to be taken.

For the specific analyte(s) in the parent sample, apply J-flag if acceptance criteria are not met and explain in the case narrative.

If MS results are outside the limits, the data shall be evaluated to determine the source(s) of difference, i.e., matrix effect or analytical error.

Matrix Spike Duplicate (MSD) or Matrix Duplicate (MD)


A laboratory must use the QSM Appendix C Limits for batch control if project limits are not specified.If the analyte(s) are not listed, use in-house LCS limits if project limits are not specified. RPD = 30% (between MS and MSD or sample and MD).

Examine the project- specific requirements. Contact the client as to additional measures to be taken.

For the specific analyte(s) in the parent sample, apply J-flag if acceptance criteria are not met and explain in the case narrative.

The data shall be evaluated to determine the source of difference.

Surrogate Spike All field and QC samples.

QC acceptance criteria specified by the project, if available; otherwise use QSM Appendix C limits or in-house LCS limits if analyte(s) are not listed.

Correct problem, then reprep and reanalyze all failed samples for all surrogates in the associated preparatory batch, if sufficient sample material is available. If obvious chromatographic interference with surrogate is present, reanalysis may not be necessary.

Apply Q-flag to all associated analytes if acceptance criteria are not met and explain in the case narrative.

Alternative surrogates are recommended when there is obvious chromatographic interference.



TABLE 3



Confirmation of positive results (second column)

All positive results must be confirmed (except for single column methods such as TPH by Method 8015 where confirmation is not an option or requirement).

Calibration and QC criteria for second column are the same as for initial or primary column analysis. Results between primary and secondary column RPD </= 40%.

NA. Apply J-flag if RPD > 40%. Discuss in the case narrative.

Use project-specific reporting requirements if available; otherwise, use method requirements if available; otherwise report the result from the primary column.



TABLE 4

SUMMARY OF METHOD MODIFICATIONS

TOPIC KATAHDIN SOP CA-329-15 METHOD 8082, current revision Procedures

7.4.5 If the calculated retention time window results in a value of 0.03 minutes or less, the laboratory will apply nominal windows. This is done in order to avoid any false negative hits because of the window being to narrow. The windows are: 0.07 for all target analytes. By utilizing these windows, a false positive hit may be initially indicated, but an experienced analyst could determine a false positive from scrutinizing the chromatograms. Please note that the use of nominal retention time windows may not be allowable for certain states, federal programs, or clients. South Carolina does not allow the use of nominal limits for compliance work originating in their state. In these cases, a window of 0.03 minutes must be used if the established retention time window is less than 0.03 minutes.

9.3 refers to method 8000B section 7.6.3: If the standard deviation of the retention times for a target compound is 0.000 (i.e., no difference between the absolute retention times), then the laboratory may either collect data from additional injections of standards or use a default standard deviation of 0.01 minutes. (Recording retention times to three decimal places rather than only two should minimize the instances in which the standard deviation is calculated as 0.000).

Apparatus/Materials

Reagents

Sample Preservation and handling

QC – Spikes

QC – LCS

QC – Accuracy/ Precision

QC - MDL

PQL Practical Quantitation Level – three to ten times the MDL.

EQL Estimated Quantitation Level – five to ten times the MDL



FIGURE 1

EXAMPLE OF INSTRUMENT RUN LOG



FIGURE 2

DATA REVIEW CHECKLIST



FIGURE 3

PQLs FOR METHOD 8082

ANALYTE

Practical Quantitation Level (PQL)

(ug/L)

Practical Quantitation Level (PQL)

(ug/kg) PCB-1016 0.50 17 PCB-1221 0.50 17 PCB-1232 0.50 17 PCB-1242 0.50 17 PCB-1248 0.50 17 PCB-1254 0.50 17 PCB-1260 0.50 17 PCB-1262 0.50 17 PCB-1268 0.50 17

KATAHDIN ANALYTICAL SERVICES, LLC SOP Number: CA-524-09 STANDARD OPERATING PROCEDURE Date Issued: 12/14 Page 3 of 19 TITLE: PREPARATION OF SEDIMENT/SOIL SAMPLES BY SOXHLET EXTRACTION USING

METHOD 3540 FOR PESTICIDE/PCB ANALYSIS

Please acknowledge receipt of this standard operating procedure by signing and dating both of the spaces provided. Return the bottom half of this sheet to the QA Department. I acknowledge receipt of copy of document SOP CA-524-09, titled PREPARATION OF SEDIMENT/SOIL SAMPLES BY SOXHLET EXTRACTION USING METHOD 3540 FOR PESTICIDE/PCB ANALYSIS. Recipient: Date: KATAHDIN ANALYTICAL SERVICES, LLC SOP Number: CA-524-09 STANDARD OPERATING PROCEDURE Date Issued: 12/14 I acknowledge receipt of copy of document SOP CA-524-09, titled PREPARATION OF SEDIMENT/SOIL SAMPLES BY SOXHLET EXTRACTION USING METHOD 3540 FOR PESTICIDE/PCB ANALYSIS. Recipient: Date:



1.0 SCOPE AND APPLICATION

The purpose of this SOP is to describe the procedure for extracting pesticides/PCBs from solids such as soils, sludges, and wastes using Method 3540. The Soxhlet extraction process ensures intimate contact of the sample matrix with the extraction solvent.

This method is applicable to the isolation and concentration of water-insoluble and slightly water-soluble organics in preparation for a variety of chromatographic procedures including methods 8081 for pesticides and 8082 for PCB’s.

1.1 Definitions

METHOD BLANK (laboratory reagent blank): An artificial sample designed to determine if method analytes or other interferences are present in the laboratory environment, the reagents, or the apparatus. For aqueous samples, reagent water is used as a blank matrix; for soil samples, baked organic-free sand is used as a blank matrix. The blank is taken through the appropriate steps of the process. LABORATORY CONTROL SAMPLE (LCS): A blank that has been spiked with the analyte(s) from an independent source, and is analyzed exactly like a sample. Its purpose is to determine whether the methodology is in control, and whether the laboratory is capable of making accurate and precise measurements. The matrix used should be phase matched with the samples and well characterized. MATRIX SPIKE/MATRIX SPIKE DUPLICATE (MS/MSD): Predetermined quantities of stock solutions of certain analytes are added to a sample matrix prior to sample extraction and analysis. Samples are split into duplicates, spiked and analyzed. Percent recoveries are calculated for each of the analytes detected. The relative percent difference between the samples is calculated and used to assess analytical precision. SURROGATES: Organic compounds which are similar to analytes of interest in chemical composition, extraction and chromatography, but which are not normally found in environmental samples. These compounds are spiked into all blanks, standards, samples and spiked samples prior to analysis. Percent recoveries are calculated for each surrogate.

1.2 Responsibilities

This method is restricted to use by, or under the supervision of analysts experienced in the extraction of samples for pesticide/PCB analysis. Each analyst must demonstrate and document their ability to generate acceptable results with this method. Refer to Katahdin SOP QA-805, current revision, “Personnel Training and Documentation of Capability”.



It is the responsibility of all Katahdin technical personnel involved in the extraction of samples for pesticide/PCB analysis to read and understand this SOP, adhere to the procedures outlined, and to properly document their data in the appropriate lab notebook. Any deviations from the test or irregularities with the samples should also be recorded in the lab notebook and reported to the Department Manager or designated qualified data reviewer responsible for this data. It is the responsibility of the Department Manager to oversee that members of their group follow this SOP, to ensure that their work is properly documented and to indicate periodic review of the associated logbooks.

1.3 Safety

Users of this procedure must be cognizant of inherent laboratory hazards, proper disposal procedures for contaminated materials and appropriate segregation of hazardous wastes. The toxicity or carcinogenicity of each reagent used in this method has not been precisely defined; however, each chemical should be treated as a potential health hazard. A reference file of material safety data sheets is available to all personnel involved in the chemical analysis. Everyone involved with the procedure must be familiar with the MSDSs for all the materials used in this procedure. Each qualified analyst or technician must be familiar with Katahdin Analytical Environmental Health and Safety Manual including the Katahdin Hazardous Waste Plan and must follow appropriate procedures. These include the use of appropriate personal protective equipment (PPE) such as safety glasses, gloves and lab coats when working with chemicals or near an instrument and not taking food or drink into the laboratory. Each analyst should know the location of all safety equipment. Each analyst shall receive a safety orientation from their Department Manager, or designee, appropriate for the job functions they will perform.

1.4 Waste Disposal

Wastes generated during the preparation of samples must be disposed of in accordance with the procedures described in the current revision of the Katahdin Hazardous Waste Plan and Safety Manual and SOP SD-903, “Sample Disposal,” current revision. Expired standards are lab packed, placed in the Katahdin hazardous waste storage area, and disposed of in accordance with this SOP. Any methylene chloride solvent waste generated during the rinsing of glassware etc. should be disposed of in the “D” waste stream satellite accumulation area nearest the point of generation. Acetone and hexane are considered flammable waste, and should be disposed of in the “O” waste stream satellite accumulation area nearest the point of generation. Post-extraction soil samples, used glass wool, and sodium sulfate waste should be disposed of in the soil with organics “I” waste stream



satellite accumulation area nearest the point of generation. Acid waste generated during the cleanup of PCB samples should be disposed of in the “K” satellite accumulation area nearest the point of generation. Please refer to the current revision of SOP CA-107 for the location of satellite waste accumulation areas.


2.1 The solid sample is mixed with anhydrous sodium sulfate, placed in a Soxhlet

extractor and extracted with methylene chloride.

2.2 The extract is then dried, concentrated, and exchanged into hexane for GC analysis. Sulfuric acid cleanup is performed on extracts for 8082 PCB analysis.

3.0 INTERFERENCES

Solvents, reagents, glassware, and other sample preparation apparatus may yield interferences to GC analysis due to the presence of contaminants. These contaminants can lead to discrete artifacts or elevated baselines in chromatograms. Routinely, all of these materials must be demonstrated to be free from interferences under the conditions of the analysis by running reagent blanks. Interferences caused by phthalate esters can pose a major problem in pesticide analysis. Common flexible plastics contain varying amounts of phthalates that are easily extracted during laboratory operations, so cross-contamination of glassware frequently occurs when plastics are handled. Interferences from phthalates can best be minimized by avoiding the use of such plastics in the laboratory. At no time may gloves that have not been tested for phthalates or gloves known to contain phthalates be used or stored in the organic extraction lab. Additionally, whenever possible plastic items in this lab must be replaced with metal or teflon or other non-phthalate plastic substitute.

Special care should be taken to ensure clean glassware and apparatus are used, pre-

rinsed with the appropriate solvent prior to use. Solvents should be analyzed prior to use to demonstrate that each lot is free of contaminants that may interfere with the analysis.

Interferences coextracted from the samples will vary considerably from source to source. If analysis of an extracted sample is prevented due to inteferences, further cleanup of the sample extract may be needed to minimize interferences.


4.1 Soxhlet extractor – 45/50 top joint and 24/40 lower joint.

4.1.1 500 mL flat-bottom boiling flask



4.1.2 Allihn cooling water condenser

4.2 Powder Funnels – 100 mm top diameter, 35 mm stem

4.3 Kuderna-Danish (K-D) apparatus 4.3.1 Concentrator tube - 10-mL 4.3.2 Evaporation flask - 500-mL 4.3.3 Snyder column - Three-ball macro 4.4 Nitrogen evaporation (N-EVAP) apparatus.

4.5 Boiling stones, 12 mesh silicon carbide (carborundum) – pre-purified by Soxhlet extraction in methylene chloride

4.6 Water bath - Heated, with concentric ring cover, capable of temperature control (±

5°C). The bath should be used in a hood. 4.7 Vials - Glass, 4, 12, or 16 mL with Teflon-lined screw caps 4.8 Glass wool (fiberglass) - baked at 400°C for a minimum of 4 hours or overnight. 4.9 Heating mantles - Rheostat controlled. 4.10 Disposable glass Pasteur pipets, 5 ¾”, and bulbs.

4.11 Drying oven - capable of maintaining 105°C for glassware drying. 4.12 Muffle oven – capable of maintaining 400 °C for baking glass wool and organic-free

sand. 4.13 Beakers, 250 or 400 mL

4.14 Top-loading balance - capable of weighing to 0.01 g.

4.15 Spatulas, stainless-steel 4.16 Long forceps, stainless-steel

4.17 Metal clips – for securing Soxhlets to boiling flasks

4.18 Filter paper, 18.5 cm, Fisherbrand or Whatman 114V (or equivalent)



4.19 Gel Permeation Chromatograph (GPC) - J2 Scientific AccuPrep MPSTM with internal UV detection

5.0 REAGENTS

5.1 Sodium sulfate (granular, anhydrous and powdered, anhydrous) (ACS reagent grade), Na2SO4. Certified by the manufacturer/vendor as purified by heating at 400°C for 4 hours prior to receipt by the laboratory.

5.2 Sulfuric acid solution (1:1 H2SO4 : H2O) – Prepared in an icebath by slowly adding a volume of concentrated H2SO4 to an equivalent volume of reagent water and swirl gently to mix. Caution should be taken when adding the acid to the water as the reaction is highly exothermic.

5.3 Methylene chloride - (pesticide grade or equivalent) purchased by lot, evaluated

prior to use by concentration of 300 mL to 1 mL followed by GC/MS analysis.

5.4 Acetone and hexane – (pesticide grade or equivalent) purchased by lot, evaluated prior to use by concentration of 300 mL to 1 mL followed by GC/MS and GC analysis.

5.5 Organic-free sand, purified by baking at 400 °C at a minimum of 4 hours or

overnight. Method blanks serve as checks on the baked sand.

5.6 Surrogate spiking solution - Prepare a solution of decachlorobiphenyl (DCB) and tetrachloro-meta-xylene (TCMX) at a concentration of 1 ug/mL in acetone.

5.7 Matrix Spike/Lab Control Sample spiking solution

5.7.1 Pesticide spike solution – prepare in pesticide grade methanol containing the analytes listed below at concentrations of 0.5 ug/mL.

4,4’-DDD Endrin 4,4’-DDE Endrin Aldehyde 4,4’-DDT Endrin Ketone

Aldrin gamma-BHC (Lindane) alpha-BHC Heptachlor beta-BHC Heptachlor Epoxide delta-BHC Methoxychlor

Dieldrin alpha-Chlordane Endosulfan I gamma-chlordane Endosulfan II Endrin

Endosulfan Sulfate Endrin Aldehyde



5.7.2 PCB spike solution – prepare Aroclor 1660 (Aroclor 1016 and 1260) in pesticide grade acetone at a concentration of 5.0 ug/mL each.

5.8 Store the solutions mentioned in sections 5.5 and 5.6 at -10 to -20 °C (±2 °C) in a

Teflon sealed container. Solution must be verified by GC/ECD prior to use and must be replaced every 6 months or sooner if degradation is evident.

6.0 SAMPLE COLLECTION, PRESERVATION AND HANDLING Sediment/soil samples must be collected in a soil jar and must be maintained at 4°C (±2°C). Holding time for extraction of sediment/soil samples for Method 3540 is 14 days from date

of sample collection, although the analyst should be aware that actual holding times employed may be project/program specific. Store all extracts at 4°C (±2°C) in the dark in labeled Teflon-sealed containers. See SOP SD-902, "Sample Receipt and Internal Control," current revision, for storage areas and temperature maintenance procedures.

7.0 PROCEDURES

The following information must be recorded in the extraction logbook. • Extraction method • Surrogate and spike IDs • Lot numbers of all solvents, acids and bases, sodium sulfate, filter paper • Nitrogen evaporation water bath temperature • pH if applicable • Extraction and Concentration dates • Extraction and Concentration analyst • Soxhlett extraction start and end times, also the prep start and end times • Sample ID or QC sample ID • Initial and final volumes or weight • Surrogate and spike amounts • Final extract tray location • Any comments regarding the sample extraction (ie. Emulsion)

Samples need to be “swiped” out when removing and “swiped” in when replacing samples in storage locations to maintain the internal chain of custody. Refer to Katahdin SOP, Sample Receipt and Internal Control, current revision, for the proper procedure for removal and return samples.



7.1 Preparing the Soxhlet Extraction Apparatus

7.1.1 Rinse the Soxhlet extractors and 500 mL flat-bottom boiling flasks three times with methylene chloride. Be sure that the solvent rinses through the large vapor tube and smaller siphon tubes of the Soxhlet. Inspect these for tiny cracks. Also rinse the 24/40 lower joint.

7.1.2 Add ~ 250 mLs of methylene chloride to the 500 mL boiling flask. Add

several boiling stones. Rinse the stainless steel forceps with Methylene chloride. Working in a hood, place a plug of the glass wool at the bottom of the Soxhlet so that the siphon tube hole is covered. Insert the 24/40 joint of the Soxhlet extractor into the 500 mL boiling flask and secure with a metal clip. Cover the top of the Soxhlet extractor with a piece of aluminum foil until ready to begin loading the sample.

7.2 Sample Handling

7.2.1 Do not decant any water on the sediment sample

Note: Some workorders may have to decant samples in the work notes. This is always done during login and never at the time of extraction. Samples decanted during login will be marked accordingly. 7.2.2 Mix the sample thoroughly with the stainless steel spatula. If the sample

container is full to the extent that stirring the sample is impractical, try to remove the “best representative” aliquot from the jar based on color, particle size, moisture, etc. Discard any foreign objects such as sticks, leaves, and rocks.

7.2.3 Gummy, fibrous, or oily materials not amenable to mixing should be cut,

shredded, or otherwise reduced in size to allow for maximum exposure of the sample surfaces to the extraction solvent. Materials such as glass, rubber, metal, etc. may not require mixing with powdered sodium sulfate to disperse the sample. Plastic materials must be tested for degradation (melting) in methylene chloride prior to Soxhlet extraction.

7.2.4 Please refer to Katahdin Analytical Services SOP CA-108, current revision,

“Basic Laboratory Techniques” for more information of subsampling.

7.3 Weigh out an approximate, greater than 30 g portion of sample into a labeled 400 mL beaker. Record sample weight to nearest 0.01 g in appropriate extraction logbook. Add between 30 to 60 g of powdered sodium sulfate, as required, to produce a “free-flowing” mixture. The amount of sodium sulfate added will depend upon the moisture content of the sample (e.g., low moisture content will require less



sodium sulfate). Mix well with a spatula. Keep the spatula in the sample beaker and cover the beaker with aluminum foil. Record sodium sulfate lot in logbook.

7.4 A method blank must be prepared with each extraction batch, not to exceed 20 client

samples. To prepare method blank, weigh out one greater than 30 g portion of purified sand in a labeled 400 mL beaker. Record sample weights to nearest 0.01 g in appropriate extraction logbook. Add 60 g sodium sulfate and mix well. (Although a “free-flowing” mixture can be achieved with less than 60 g sodium sulfate, the method blank must contain 60 g in order to evaluate the sodium sulfate as a potential source of contamination.)

7.5 A laboratory control sample (LCS) must be prepared with each extraction batch, not

to exceed 20 client samples. To prepare LCS, weigh out one greater than 30 g portion of purified sand in a labeled 400 mL beaker. Record sample weights to nearest 0.01 g in appropriate extraction logbook. Add 30 g sodium sulfate and mix well. With extraction batches prepared for combined 8081/8082 Pesticide and PCB analysis, separate Pesticide and PCB LCS’s must be prepared (refer to section 5.6). If an MS/MSD pair is not extracted on a particular day, an LCS/LCSD pair may be required in order to meet client-specific or program-specific requirements. This information will be disseminated from the project manager or Department Manager.

7.6 A matrix spike/matrix spike duplicate (MS/MSD) set should be prepared for every 20

samples. An MS/MSD will be analyzed only if enough sample has been provided by the client. Additionally, in the event that the batch MS/MSD requirement cannot be fulfilled, a laboratory control spike duplicate must be analyzed. To prepare MS/MSD, weigh out two approximate, greater than 30g portions of the sample designated for MS/MSD into each of two labeled 400 mL beakers. Record sample weights to nearest 0.01g in appropriate extraction logbook. Add 30 g sodium sulfate to each to produce a free-flowing mixture, and mix well. With extraction batches prepared for combined 8081/8082 Pesticide and PCB analysis, separate Pesticide and PCB MS/MSD pairs must be prepared (refer to section 5.6).

7.7 Once all of the QC and field samples have been weighed and mixed with sodium

sulfate, begin adding each to the assembled and appropriately labeled Soxhlet extractors using the stainless steel spatulas. Carefully scrape all of the mixtures from the beaker walls so that no more than 1% remains behind in the beaker. Be careful that none of solid material falls into the extract flask through the large vapor tube.

7.8 To all samples, method blank, LCS/LCSD, and MS/MSD add 1.0 mL (if FV=10mL,

adjust amount for different final volumes) of the pesticide/PCBs surrogate spiking solution using a 1.0 mL gas tight syringe. Record surrogate spike volume and identification code in the extraction logbook. Thoroughly rinse syringe with solvent between each use.



7.9 To LCS/LCSD and MS/MSD add 1.0 mL (if FV=10mL, adjust amount for different final volumes) of either the pesticide or PCBs matrix spike/LCS spiking solutions using a 1.0 mL gas tight syringe. Record matrix spike/LCS spiking solution volume and identification codes in the extraction logbook. Thoroughly rinse syringe with solvent between each use.

7.10 Rinse the joints of the Allihn cooling condensers with Methylene Chloride, collecting

the waste in a methylene chloride solvent waste container. Place each of the Soxhlet extractors in a heating mantle and lower the Allihn cooling water condensers into the 45/50 joints of the extractors. The condensers should be set to a temperature of 15ºC. Save the pieces of aluminum foil for covering the Soxhlets when the extraction is complete. Switch on the individual heating mantles and be sure that the Rheostat of the variable transformer is set to 55% of the output voltage. Once the methylene chloride begins to boil and the Soxhlet begins to cycle (solvent will immerse the sample and collect in the Soxhlet until the level reaches that of the small siphon tube and then begin to spill over into the extract flask), re-check the apparatus’ for leaks. Allow the samples to extract for 18-24 hours. Be sure the chiller/recirculator temperature is set low enough to provide enough cooling capacity for the number of extractions in the batch.

7.11 When the extraction is complete, allow the extracts to cool before dismantling.

Remove the Allihn condenser and replace the aluminum foil on top of the extractor. Move the extractors to a hood and detach the extractor from the extract flask. Tilt each extractor slightly to cause any remaining solvent in the sample chamber to drain through the siphon tube into the extract flask. This will help to cool the extract flask and make the apparatus easier to dismantle. Try to drain as much solvent as possible from the extractor into the flask. This is done by rinsing a glass tube in methylene chloride and pressing on the sample slightly so that as much solvent as possible is drained into the extract flask. Cover the flask with aluminum foil and store in the interim extract storage refrigerator unless the extracts are to be concentrated the same day.

7.12 Immediately remove the extracted soil/sodium sulfate mixtures from the extractors

using a square edge spatula, and dispose of in an appropriate solid waste container. It is important to do this soon after the extractors are dismantled, as the sample mixture will tend to “freeze” into a solid mass in the Soxhlet as the solvent dries.

CONCENTRATION OF THE EXTRACTS

7.13 Rinse the K-D glassware (flask, concentration tube, and Snyder column, including the ground glass joints on the flask and columns) three times with methylene chloride before assembling. Add a few boiling chips to the K-D. Insert 18.5 cm filter papers into short stem powder funnels and add ~ 2 inches of sodium sulfate



crystals. Place the assembled K-D’s under the funnels. Record the lot numbers of the solvent, sodium sulfate and filter papers in the extraction logbook.

7.14 If samples are to be GPC’d, refer to the current revision of Katahdin SOP CA-513,

Extract Cleanup Using Gel Permeation Chromatography, for appropriate concentrating procedures. Samples that undergo GPC are not solvent exchanged into hexane. All pesticide soil samples should be cleaned up to reduce matrix interferences.

7.15 If samples are not to be GPC’d follow Steps 7.16 through 7.23 to concentrate

extracts to final volume of 10 mLs (or a client specified final volume) 7.16 For a solvent exchange, (for samples not being GPC’d), add approximately 50 mL

hexane to funnel and let drain through. Since methylene chloride has a lower boiling point than Hexane, this will result in a final extract in hexane only. Record the lot number of the solvent in the extraction logbook.

7.17 Transfer the extracts to the K-D concentrator setups through the sodium sulfate in

the funnels. This is the drying step, which is required to remove residual water from the extracts. Any large water layers must be removed by other means, prior to pouring through the sodium sulfate. After pouring all of the extract volume through the sodium sulfate, rinse the extract flask three times with ~ 2 – 3 mLs of methylene chloride. Add the rinsings through the sodium sulfate to complete a quantitative transfer. Rinse the sodium sulfate with ~ 15 mLs of methylene chloride and allow to drain.

7.18 Transfer the labels from the extract flasks to the K-Ds. Remove the funnel and

attach a 3-ball macro Snyder column. Pre-wet the Snyder column with 1 mL of methylene chloride.

7.19 Place the K-D in a hot water bath set at 80°C. Gently swirl K-D in the water until

boiling begins. At the proper distillation rate, the Snyder balls should chatter but the chambers should not flood with condensed solvent. The K-D should be kept in a vertical orientation while on the bath. When the apparent volume in the concentrator tube reaches ≈ 6 mL, remove the K-D from the water bath. Allow the K-D to cool for 10 minutes. Rinse the Snyder column lower joint with ≈ 1 mL of methylene chloride, hexane, if exchange is taking place. Remove the Snyder column. Wipe off any water from the neck above the lower joint of the flask. Separate the K-D flask from the concentrator tube, rinsing the ground glass joint with ≈ 1 mL methylene chloride, hexane, if exchange is taking place.

7.20 Reduce the extract in the concentrator tube to approximately 1-2 mL using the

nitrogen blow-down apparatus to ensure all methylene chloride has been evaporated. The bath temperature must be no higher than the boiling point of the



solvent (39°C for methylene chloride). Turn the gas to 3 psi. Be careful not to splash the extract out of the tube. During concentration on the N-evap, the internal wall of the concentrator tube and the N-evap sparging pipet must be rinsed down at least once or twice with ≈1 mL of hexane. The solvent level in the concentrator tube must be positioned below the level of the water bath as much as possible to prevent water from condensing into the sample extract. As the extract volume is reduced, lower the N2 sparging pipet closer to the surface of the extract to expedite the concentration. Record the temperature of the water in the nitrogen evaporation water bath in the extraction logbook, also note any problems or extract losses, if they occur.

7.21 Complete quantitative transfer of the extract to a vial by using hexane. Adjust the

volume of the hexane extract to 10 mL (or a client specified final volume) in either a 12 or 16 mL vial using the appropriate “reference vial” for volume comparison.

7.22 Label the vial with lab sample number, extraction date, matrix and analysis. Store

extract vials at a temperature of 4 ± 2 °C until ready for analysis. Indicate in the extractions logbook the box number and “tray location” of the individual extract vials.

7.23 All sample extracts for 8082 PCB analysis must undergo a sulfuric acid wash

(cleanup) prior to analysis, unless it has been GPC’d. All sample extracts for 8081 pesticide analysis should undergo further cleanup using the GPC unless time is a factor. All sample extracts for combined 8081/8082 analyses must be split unless GPC’d. One portion must be acid cleaned for 8082 analysis. The associated method blank must be split and acid-cleaned in the same fashion. PCB LCSs and matrix spikes are acid cleaned also. Pesticide LCSs and matrix spikes are not subjected to further cleanup. Record the lot number of the acid in the extraction logbook. Please refer to Katahdin SOP CA-525 (current revision), Extract Cleanup Using Sulfuric Acid, for further instructions.


A method blank must be extracted for each and every item listed below: - Each sample matrix (soil, water) - Each day of extraction (24 hours midnight - midnight) - Each extraction method or level - Every 20 samples extracted in a 24-hour period A laboratory control sample (LCS) is required for each and every item listed below: - Each sample matrix - Each extraction method or level



- Every extraction batch of twenty or fewer samples - Each analysis (pesticide and/or PCB) to be performed Refer to the current revision of the applicable Katahdin SOP for analysis of Pesticides and PCBs for quality control acceptance criteria. Each extractions analyst must demonstrate proficiency in performing the extractions that prepare samples for analysis. Demonstration consists of preparation (extraction), by the analyst, of at least four aliquots which are then analyzed according to the analytical method in question. These QC samples must meet all quality control acceptance limits. Demonstration must be documented by use of a form which summarizes the results of the analysis of these aliquots, calculated percent recoveries, and standard deviation. Demonstration of proficiency must be done one time per analyst initially and then annually thereafter. Refer to SOPs QA-805 and QA-807, current revision.

If, upon analysis of the extracted samples, it is discovered that quality control acceptance criteria have not been met, all associated samples must be evaluated against all the QC. In some cases data may be reported, perhaps with narration, while in other cases, other corrective action may be taken. The corrective actions may include re-extraction of the samples associated with the quality control sample that did not meet acceptance criteria, or may include making new reagents and standards if the standardization is suspect. These decisions are based on holding time considerations, client and project specific Data Quality Objectives and on review of chromatograms. The supervisor, Operations Manager, and/or Quality Assurance Officer may be consulted to evaluate data. Some samples may not be able to be reanalyzed within hold time. In these cases “qualified” data with narration may be advisable after consultation with the client.

Much of the work performed at the lab is analyzed in accordance with specific QC requirements spelled out in a project specific Quality Assurance Project Plan (QAPP) or in a program specific Quality Systems Manual (QSM). The reporting limits, acceptance criteria and/or corrective actions may be different than those specified in this SOP. In these cases the appropriate information will be communicated to the Department Manager and/or senior chemists before initiation of the analyses so that specific product codes can be produced for the project. In addition, the work order notes for each project will describe the specific QAPP or QSM to be followed.

9.0 METHOD PERFORMANCE

The method detection limit (MDL) is defined as the minimum concentration of a substance that can be measured and reported with 99% confidence that the value is above zero. The MDLs shall be determined and verified one time per type of instrument unless otherwise required by the method.



A Limit of Detection (LOD) is an estimate of the minimum amount of a substance that an analytical process can reliably detect. An LOD is analyte and matrix specific and may be laboratory-dependent. LODs must be determined for all parameters for which the laboratory is accredited under the DoD Environmental Laboratory Accreditation Program. LOD’s must be verified for every preparation and analytical method combination and on every applicable instrument on a quarterly basis.

The Limit of Quantitation (LOQ) is the minimum levels, concentrations, or quantities of a target variable (e.g., target analyte) that can be reported with a specified degree of confidence. The LOQ shall be set at the lowest point in the calibration curve for all analyses utilizing an initial calibration. LOQ’s must be verified quarterly for every preparation and analytical method combination and on every applicable instrument on a quarterly basis for all parameters included in the DoD Scope of Accreditation. The LOQ must be verified at least once annually if the analysis is not included in the DoD Scope of Accreditation.

MDLs are filed with the Organic Department Manager and then with the QAO. LOD and LOQ verifications are filed with the QAO

Refer to the current revision of Katahdin SOP QA-806, Method Detection Limit, Instrument Detection Limit and Reporting Limit Studies and Verifications, for procedures on determining the MDL.

Refer to the applicable analytical SOP for other method performance parameters and requirements.

10.0 APPLICABLE DOCUMENTS/REFERENCES Test Methods for Evaluating Solid Waste-Physical/Chemical Methods, Method 3540C, SW-846, Third Edition, Updates I, II, IIA, IIB, and III Revised December 1996, US EPA. Department of Defense Quality Systems Manual for Environmental Laboratories (DOD QSM), Version 4.2, 10/25/2010.

Department of Defense (DoD) and Department of Energy (DOE) Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, DoD QSM Version 5.0, March, 2013 The NELAC Institute, Laboratory Accreditation Standards, Volume 1, Management and Technical Requirements for Laboratories Performing Environmental Analysis, 10/06/2010..



LIST OF TABLES AND FIGURES Table 1 Summary of Method Modifications Figure 1 Example of Logbook Page



TABLE 1


TOPIC KATAHDIN SOP CA-524-09 METHOD 3540, current revision Apparatus/Materials

1. short stem funnels

1. drying columns

Reagents

Sample preservation/ handling

Procedures

1. Use 30 grams of sample and 30 grams of sodium sulfate.

2. Use 250 mL of methylene chloride 3. no apparatus height specification for

concentration on water bath 4. water bath at 75-85 deg C 5. sample removed from water bath

when volume reaches ~6 mL 6. Solvent exchange to hexane is

performed using K-D apparatus with addition of approximately 50 mL hexane at the start of concentration process

1. Use 10 grams of sample and 10 grams of sodium sulfate.

2. Use 300 mL of methylene chloride 3. partially immerse concentrator tube in

water and lower apparatus to complete concentration in 10-15min

4. water bath at 80-90 deg C 5. sample removed from water bath when

volume reaches 1-2 mL 6. Solvent exchange to hexane is

performed using K-D apparatus with addition of approximately 50 mL hexane after concentrating methylene chloride extract to 1 mL

QC - Spikes

QC - LCS

QC - Accuracy/Precision

QC - MDL



FIGURE 1

EXAMPLE OF LOGBOOK PAGE

ADDENDUM

SOP NO CHANGE FORM

KATAHDIN ANALYTICAL SERVICES, INC. SOP Number: CA-331-08 STANDARD OPERATING PROCEDURE Date Issued: 06/14 Page 3 of 8 TITLE: SULFUR CLEAN-UP OF PESTICIDE/PCB EXTRACTS USING SW846 METHOD 3660 Please acknowledge receipt of this standard operating procedure by signing and dating both of the spaces provided. Return the bottom half of this sheet to the QA Department. I acknowledge receipt of copy of document SOP CA-331-08, titled “Sulfur Clean-Up of Pesticide/PCB Extracts Using SW846 Method 3660”. Recipient: Date: KATAHDIN ANALYTICAL SERVICES, INC. STANDARD OPERATING PROCEDURE I acknowledge receipt of copy of document SOP CA-331-08, titled “Sulfur Clean-Up of Pesticide/PCB Extracts Using SW846 Method 3660”. Recipient: Date:

KATAHDIN ANALYTICAL SERVICES, INC. SOP Number: CA-331-08 STANDARD OPERATING PROCEDURE Date Issued: 06/14 Page 4 of 8 TITLE: SULFUR CLEAN-UP OF PESTICIDE/PCB EXTRACTS USING SW846 METHOD 3660 1.0 SCOPE AND APPLICATION

The purpose of this SOP is to describe the procedures and requirements used by Katahdin Analytical technical personnel for the sulfur cleanup of aqueous and soil samples by SW846 Method 3660 using copper powder for the subsequent analysis of pesticides and PCBs.

1.1 Definitions 1.2 Responsibilities

This method is restricted to use by, or under the supervision of, analysts experienced in the extraction and cleanup of aqueous and soil samples for Pesticide/PCB analysis using method 3660. Each analyst must demonstrate and document their ability to generate acceptable results with this method. Refer to Katahdin SOP QA-805, current revision, Personnel Training and Demonstration of Capability.

It is the responsibility of all Katahdin personnel involved in the preparation of aqueous and soil samples for Pesticide/PCB analysis to read and understand this SOP, to adhere to the procedures outlined, and to properly document their data in the appropriate lab notebook. Any deviations from the test or irregularities with the samples should also be recorded in the lab notebook and reported to the Department Manager or designated qualified data reviewer responsible for the data. It is the responsibility of the Department Manager to oversee that the members of his/her group follow this SOP, to assure that their work is properly documented, and to initiate periodic review of the pertinent logbooks.

1.3 Safety

Users of this procedure must be cognizant of inherent laboratory hazards, proper disposal procedures for contaminated materials and appropriate segregation of hazardous wastes. The toxicity or carcinogenicity of each reagent used in this method has not been precisely defined; however, each chemical should be treated as a potential health hazard. A reference file of material safety data sheets is available to all personnel involved in the chemical analysis. Everyone involved with the procedure must be familiar with the MSDSs (material safety data sheets) for all the materials used in this procedure. Each qualified analyst or technician must be familiar with the Katahdin Analytical Health and Safety Manual including the Katahdin Hazardous Waste Management Plan and must follow appropriate procedures. These include the use of appropriate personal protective equipment (PPE) such as safety glasses, gloves and lab coats when working with chemicals or near an instrument and not taking food or drink into the laboratory. Each analyst should know the location of a respirator and all safety equipment. Each

KATAHDIN ANALYTICAL SERVICES, INC. SOP Number: CA-331-08 STANDARD OPERATING PROCEDURE Date Issued: 06/14 Page 5 of 8 TITLE: SULFUR CLEAN-UP OF PESTICIDE/PCB EXTRACTS USING SW846 METHOD 3660

analyst shall receive a safety orientation from their Department Manager, or designee, appropriate for the job functions they will perform.

1.4 Pollution Prevention/Waste Disposal

Whenever possible, laboratory personnel should use pollution prevention techniques to address their waste generation. Refer to the current revision of the Katahdin Hazardous Waste Management Program for further details on pollution prevention techniques. Wastes generated during the preparation of samples must be disposed of in accordance with the Katahdin Hazardous Waste Management Plan and Safety Manual and SOP SD-903, “Sample Disposal,” current revision. Expired standards are lab packed, placed in the Katahdin hazardous waste storage area, and disposed of in accordance with this SOP.


After Pesticide/PCB extraction using Method 3510, 3520, 3540, 3545 or 3550 (current revisions), a portion or all of the 10 mL final volume is removed and mixed with copper. The mixture is then shaken. The extract is then analyzed via GC/ECD for Pesticides/PCBs.

3.0 INTERFERENCES

The copper technique requires that the copper powder be very reactive, as evidenced by a bright shiny appearance (see Sec. 5.6 for the preparation of this reagent). However, care must be taken to remove all traces of the acid used to prepare the copper, in order to avoid degradation of some analytes.


4.1 Pipets, disposable - Pasteur type. 4.2 Glass bottles or vials - 10 mL and 2 mL, with polytetrafluoroethylene (PTFE)-lined

screw caps or crimp tops. ______________________________________________________________________________ 5.0 REAGENTS

5.1 Organic-free reagent water 5.2 Hydrochloric, HCl, dilute (ACS reagent grade). 5.3 Acetone, (CH3)2CO - Pesticide quality or equivalent.


5.4 Copper, granular - Remove oxides by rinsing well with dilute 1:1 hydrochloric acid, rinse two times with organic-free reagent water to remove all traces of acid, rinse three times with acetone. Then quickly transfer to an aluminum foil tray and dry in oven at 150 ºC for 30 minutes. Transfer to a VOA vial. (Copper, Granular (20-30 Mesh) from J.T. Baker or equivalent).

6.0 SAMPLE COLLECTION, PRESERVATION AND HANDLING

Prior to using this sulfur cleanup procedure, it should be determined whether samples were preserved properly. Refer to the current revision of the applicable preparatory or analytical SOP for analysis of Pesticides/PCBs for sample collection, preservation and handling.

7.0 PROCEDURES

7.1 Removal of sulfur using copper.

7.1.1 Concentrate the sample to exactly 1.0 mL or other known volume. Perform concentration using the techniques described in the appropriate preparatory method.

7.1.2 Add enough cleaned granular copper to cover the bottom of an autosampler

vial (approximately 1g). Using a disposable pipet, transfer approximately 0.5mL of the sample extract to the vial. Cap the vial and shake vigorously for at least 1 minute.

7.1.3 The associated QC samples must be treated identically as the samples. 7.1.4 Separate the extract from the copper by drawing off the extract with a

disposable pipet and transfer to a clean vial.

Note: This separation is necessary to prevent degradation of the pesticides.


Refer to the current revision of the applicable analytical SOP for analysis of Pesticides/PCBs for quality control acceptance criteria. Note sulfur cleanup in logbook.

9.0 METHOD PERFORMANCE N/A

KATAHDIN ANALYTICAL SERVICES, INC. SOP Number: CA-331-08 STANDARD OPERATING PROCEDURE Date Issued: 06/14 Page 7 of 8 TITLE: SULFUR CLEAN-UP OF PESTICIDE/PCB EXTRACTS USING SW846 METHOD 3660 10.0 APPLICABLE DOCUMENTS/REFERENCES Test Methods for Evaluating Solid Waste - Physical/Chemical Methods, Method 3660B, US

EPA SW-846, Third Edition, Final Update III, December, 1996. LIST OF TABLES AND FIGURES Table 1 Summary of Method Modifications


TABLE 1


Topic Katahdin SOP CA-331-08 Method 3660, current revision Apparatus/Materials

None

Reagents None

Sample preservation/ handling

None

Procedures 7.1.2 Add enough cleaned granular copper to cover the bottom of an autosampler vial (approximately 1g). Using a disposable pipet, transfer approximately 0.5mL of the sample extract to the vial. Cap the vial and shake vigorously for at least 1 minute.

7.1.3 Add approximately 2 g of cleaned copper powder to the centrifuge tube. (The copper will fill the tube to approximately the 0.5 mL mark). Vigorously mix the extract and the copper powder for at least 1 min on the mechanical shaker. Allow the phases to separate.

ADDENDUM

SOP NO CHANGE FORM

ATTACHMENT D Field Sampling Plan

Koman Government Solutions Draft Field Sampling Plan / February 2017 ©2017 Stone Environmental. All rights reserved

2

DRAFT FIELD SAMPLING PLAN

FORMER LYNDONVILLE AIR FORCE STATION EAST HAVEN, VERMONT REMEDIAL DESIGN

FUDS Project Number: D01VT0363-01


Stone Project ID: 16-101

February 2017

Prepared for: Prepared by:

US Army Corps of Engineers, New England District Stone Environmental, Inc.

696 Virginia Road 535 Stone Cutters Way

Concord, MA 01742-2751 Montpelier, VT 05602

Tel. / 802.229.4541

E-Mail / [email protected]


3

Acknowledgements

This project was undertaken by Stone Environmental, Inc. for KOMAN Government Solutions, LLC with funding provided by the U.S. Army Corps of Engineers.


4

Table of Contents

Contents

Acknowledgements ....................................................................................................................3 1. Introduction..........................................................................................................................5

1.1. Project Organization ....................................................................................................... 5 1.2. Site Background .............................................................................................................. 5 1.3. Project Overview ............................................................................................................. 6 1.4. Sampling Area ................................................................................................................. 6 1.5. Health and Safety ............................................................................................................ 6

2. Field Sampling Plan ..............................................................................................................7 2.1. Pre-Design Investigation Sampling .................................................................................. 7

2.1.1. Sampling Objectives.......................................................................................... 7 2.1.2. Sampling Locations, Frequency, and Rationale ................................................. 8 2.1.3. Sampling Equipment ........................................................................................ 9 2.1.4. Sampling Procedure .......................................................................................... 9

2.2. Post Excavation Confirmation Sampling ....................................................................... 10 2.2.1. Sampling Objectives........................................................................................ 10 2.2.2. Sampling Locations, Frequency, and Rationale ............................................... 10 2.2.3. Sampling Equipment ...................................................................................... 11 2.2.4. Sampling Procedure ........................................................................................ 12

2.3. Sample Identification (ID) Nomenclature ...................................................................... 12 2.3.1. Pre-design samples: ........................................................................................ 12 2.3.2. Confirmation samples: .................................................................................... 13

2.4. Chemistry Electronic Data Deliverables ......................................................................... 13 2.5. Quality Assurance Project Plan ...................................................................................... 13 2.6. Decontamination and Investigation Derived Waste ...................................................... 13

2.6.1. Decontamination Procedures .......................................................................... 13 2.6.2. Investigation Derived Waste (IDW) ................................................................. 13

3. References .......................................................................................................................... 15 Figures ...................................................................................................................................... 16


5

1. Introduction

On behalf of KOMAN Government Solutions, LLC. (KGS), Stone Environmental, Inc. (Stone) has prepared this Sampling and Analysis Plan (SAP) for the Former Lyndonville Air Force Station (Site) located on Radar Road in East Haven, Vermont (Figure 1). This SAP is a component of the Remedial Action Work Plan prepared by KGS for the United States Army Corps of Engineers (USACE) to remediate Polychlorinated Biphenyl (PCB) impacted soil and meet Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requirements to achieve “No Further Department of Defense Action Indicated” for the Site.

This SAP provides proposed project sampling strategies using site-specific information. Sampling strategies include pre-design investigation and post excavation rationale and methods, and field, laboratory analytical, and Quality Assurance/Quality Control (QA/QC) methods.

1.1. Project Organization KGS is performing project work for USACE, New England District under contract number W912WJ-16-R-0027. USACE will provide technical oversight and administrative support and review. The lead regulatory agency for the Site is the USACE with regulatory oversight by the Vermont Department of Environmental Conservation (VTDEC), Waste Management and Prevention Division, Sites Management Section (SMS). Additional stakeholders in the project include Northeast Kingdom Wind Power, and Weyerhaeuser Company (formerly Plume Creek Timber Company). Stone will perform pre-design investigation and post excavation sampling to be submitted to Katahdin Analytical Services, Inc. for fixed laboratory analysis.

1.2. Site Background The Lyndonville Air Force Station is located on Radar Road in East Haven, Vermont. The Site is situated on East Mountain and is a Formerly Used Defense Site (FUDS) that the United States Air Force operated between 1956 and 1963 as an aircraft control and warning radar station. The Air Force Station was closed in 1963 and later sold to East Mountain Development Corporation. The Site, currently owned by Northeast Kingdom Wind Power, is approximately 50.2 acres and surrounded by heavily wooded forest owned by the Weyerhaeuser Company (formerly Plum Creek Timber Company).

The Site was broken up into 5 parcels; the Debris Area, Cantonment Area, Operations Area, Receiver Building, and Parcel Adjacent to Cantonment Area. The Final Remedial Investigation Report (RI, JCO, 2013) and the Final Feasibility Study Report (FS, Stone, 2014) concluded that the only actionable risk based on the human health risk assessment was at the Debris Area in Area of Concern 1 (AOC 1) (Figure 2). The Debris Area was created by disposal of solid waste generated at the Air Force Station. Further investigation indicated that PCBs were the only contaminant of concern (COC) in AOC 1, and contaminated media was limited to soil.

The FS (Stone 2014) established a Remedial Goal (RG) for PCBs of 1.7 milligrams per kilogram (mg/Kg). The only detection of PCBs above the RG during site investigation was in a sample collected from Test Pit 6


6

(TP6), (Figure 2) at a concentration of 48.23 mg/Kg and a depth of 2 feet below ground surface (ft bgs). The RI identified a layer of gray material, distinct from soil, in TP6 from 2 to 2.5 ft bgs, from which the sample was collected. Since only one sample was collected from TP6, it is unclear whether the sample results are representative of PCB concentrations in the gray material, or of a larger volume of PCB contaminated soil in the vicinity of TP6. The PCB concentration in the sample collected from the gray material was two orders of magnitude higher than PCB concentrations detected in samples collected from Test Pits TP9 and TPN and TP7 to the east, west, and north of TP6, respectively. Due to the limited number of samples collected in the Debris Area, the FS specified that additional sampling and analysis should be conducted in the vicinity of TP6 to delineate the extent of the RG exceedances.

1.3. Project Overview The remedial action objective was stated in the Final Decision Document (Stone, 2016) as the following:

Prevent or reduce potential future residential human exposure to soil with total PCB concentrations that result in risks in excess of USEPA’s target ELCR level (1x10-4) and/or which exceed a target non-cancer HI greater than 1.0.

The FS assumed an approximate 30 by 30 foot remedial target area around TP6 for soil excavation to remove PCB contamination above the RG. Pre-design investigation sampling will be conducted for vertical and horizontal delineation of PCB impacts above the RG within the target area. Data generated during the investigative sampling will aid in the design of soil excavations within the target area. Confirmation sampling will be conducted following excavation of the target area to ensure RGs are met. Investigation and confirmation sampling methodology is discussed in Section 2.

1.4. Sampling Area Sampling will be conducted in two phases, pre-design investigation and confirmation sampling. The pre-design investigation sampling area includes soil from ground surface to 4 ft bgs within the 30 ft by 30 ft remedial target area centered around TP6 (Figure 2). The target area will be divided into a 10 ft by 10 ft grid with 2 depth intervals for sampling: 0 to 3 ft bgs (expected to include the layer of gray material) and 3 to 4 ft bgs (soil underlying the gray material). (Figure 3). Confirmation sampling will be conduct on the sidewalls and floor of the proposed excavation. Incremental Sampling Methodology (ISM) will be used for investigation and confirmation sampling. Sampling rationale and methodology are discussed in Section 2.

1.5. Health and Safety The work described in this SAP will be performed under the Accident Prevention Plan (APP), Site Safety and Health Plan (SSHP), and Activity and Hazard Analyses (AHA) prepared by KGS. The SSHP contains the following elements: project description and contaminant characterization, safety and health hazard(s) assessment and risk analysis, organization and responsibilities of safety and health staff, site-specific training and medical surveillance parameters, personal protective equipment (PPE) and decontamination facilities with documented procedures to be used for same, monitoring and sampling requirements, safety and health work precautions and procedures, site control measures, onsite first aid and emergency equipment, emergency response plans and contingency procedures (onsite and offsite), logs, reports, and record keeping.


7

2. Field Sampling Plan

Investigation and confirmation sampling will be conducted by Stone following the general approach described in Interstate Technology Regulatory Council’s (ITRC) ISM Technical and Regulatory Guidance Document, (ITRC, 2012), with modifications to better accommodate the small sampling area targeted by this investigation.

2.1. Pre-Design Investigation Sampling The RI and FS identified TP6 as the only location on the Site and within the Debris Area AOC 1 with PCB concentrations greater than the RG of 1.7 mg/Kg. During the RI TP6 was excavated to a width of 2 ft (North-South), length of 6 feet (East-West) and depth of 7 ft bgs. A layer of gray material was found in the eastern end of the trench between 2 and 2.5 ft bgs. A sample was collected and analyzed from the gray material, PCBs were reported at 48 mg/kg. The gray material is thought to be a source of PCB contamination, but insufficient sampling was conducted during the RI to delineate the extent of this material, or to confirm that the PCB RG exceedances were limited to the gray material. The RI estimated the gray material to be ½ ft thick and less than 10 ft long in the East-West direction, however the extent of the gray material in the North-South was not well delineated.

Further investigation will be conducted to identify the extent of the layer of gray material and subsequent PCB contamination around TP6. A 30 by 30 ft area centered at TP6 will be the subject of further investigation. RI test pit data indicated the soil within AOC 1 was non-homogenous. The solid waste used as fill material within AOC 1 can also provide a non-homogenous distribution of contamination. ISM will be used to eliminate possible bias from discrete sampling. Rather than characterize soil using discrete samples, multiple samples will be composited within a defined volume of soil known as a Decision Unit (DU). Results from each DU using ISM will provide an estimate of the mean contaminant concentration of soil.

2.1.1. Sampling Objectives The objective of pre-design investigative sampling is to delineate the volume of soil that presents a risk to human health. Because the soils and materials in the vicinity of TP6 are not homogeneous, a large number of discrete samples would need to be collected to estimate the mean concentration of PCBs to which a Site occupant would be exposed. By dividing the target area into DUs and collecting composite samples within each DU, a more accurate estimate of the mean can be obtained for each DU at a lower analytical cost. The size of the DU has been selected based on the size of the target area, the depth of the suspected source material, and practical limitations regarding standard excavation equipment. Data generated from sampling will be compared to the RG and used to aid in the design of PCB soil excavations. Should full delineation not be completed during pre-design investigation, excavations will be designed with the available data and further decision making will be made during the confirmation sampling described in Section 2.2.

Data obtained will be of sufficient quality and quantity to allow the project team to make decisions regarding the mean PCB concentration for soils in each DU relative to the RG, and design an excavation plan to achieve the projects remedial action objectives. Samples will be taken from a 0-3 ft interval where the gray material was observed, as well as a 3-4 ft layer below the gray material. The RG, 1.7 mg/Kg, used for decision making is


8

Site-specific and based on the human health risk assessment included in the RI (JCO, 2013) and FS (Stone Environmental, 2014). The pre-design sampling plan has been designed to provide data of sufficient quantity and quality to determine if the mean concentration in soils is below the RG within the 95% upper confidence level (UCL), in accordance with the ISM Guidance (ITRC, 2012). A DU with a mean concentration above the RG will be removed for off-Site disposal.

A summary report will be submitted to USACE following pre-design investigation sampling. The report will discuss sampling activities that occurred during the investigation, including sample locations, soil descriptions, and any deviations from the proposed plan. Deviations will be discussed with USACE real-time so an agreement can be made and make the best use of the mobilization. Laboratory analytical results will be summarized and full analytical reports will be provided as an attachment to the report. The report will also serve as the final design document for remedial excavations. Decision making for the excavation design will be presented alongside analytical results and 95% UCL calculations. UCL calculations will be calculated using the ITRC spreadsheet (www.itrcweb.org/ISM-1/documents/Calculate_95UCL_for_ISM.xls). Expected deviations from the confirmation sampling plan discussed in section 2.2.2 will be addressed in the summary report.

Data Quality Objectives, analytical methods, and Quality Assurance/ Quality Control (QA/QC) for laboratory analysis is provided in the Quality Assurance Project Plan.

2.1.2. Sampling Locations, Frequency, and Rationale Eighteen 10 by 10 ft DUs will be divided into 2 layers centered on TP6 (Figure 3). DUs 1-9 will characterize soil from 0-3 ft bgs and DUs 10-18 will characterize soil from 3-4 ft bgs. The gray material mentioned in the RI (JCO 2013), which is the likely source of PCB contamination exceeding the RG, is estimated to be between 2 and 2.5 ft bgs. DU’s 1-9 extend an extra ½ ft below the observed depth of the gray material to account for variations in depth throughout the target area and potential leaching of PCBs from the gray material. DU 5 is centered on TP6 where previous investigation detected PCB concentrations at 48 mg/Kg. Surrounding DUs, DU 1-4 and 6-9, will serve to delineate the horizontal extents of RG exceedances and estimate the contaminant concentration within the top 3 ft of soil. The bottom layer of DUs, DU 10-19, are intended to characterize the soil below the gray material. If the analytical results of the composite samples from this lower layer of DUs have contaminant concentrations below the RG, the excavation plan will not include removal of soil greater than 3 ft bgs during the initial excavation effort. However, if the analytical results in the lower 3-4 ft interval indicate PCB concentrations above the RG, soils will be removed to a minimum depth of 4 ft bgs.

Per the guidance, the number of increments needed for each DU depends on a number of factors, including size of, and heterogeneity within, the DU, the difference between the mean concentration and the level of interest (e.g., action level), and project data quality objectives. The ISM guidance document generally recommends 30 increments as the minimum number of increments to be collected when no prior data are available to estimate the homogeneity. Because the target area being investigated is relatively small (30 ft by 30 ft), the DUs for the pre-design investigation will be 10 ft by 10 ft, which is the smallest practical size for excavation using standard equipment. Collection of 30 core samples within a 100 square feet (sq ft) DU would be impractical, therefore, deviations from the ISM guidance document were made accordingly.

Design of the ISM for the pre-design investigations involves collection of 3 replicate samples from each DU. Each replicate will be comprised of 3 incremental samples (soil cores). A direct push drill rig with 2.25-inch diameter dual tube sampling tool will be used to collect 1.5-inch diameter soil cores in acetate liners. The incremental sampling locations will be spaced evenly across the horizontal extent of each DU as shown in Figure 3. Incremental samples will be collected as continuous cores extending across the entire vertical depth of the DUs. Sampling procedures are further discussed in Section 2.1.4. All samples will be submitted for

http://www.itrcweb.org/ISM-1/documents/Calculate_95UCL_for_ISM.xls


9

fixed laboratory analysis for PCBs by US EPA Method 8082. Once received by the laboratory, each replicate will be thoroughly homogenized and 30 grams of soil will be collected from each homogenized replicate sample for extraction and analysis. Samples will be extracted using soxhlett (method SW3540) which utilizes drying with sodium sulfate. The samples will also be analyzed for total solids and the results will be adjusted for this. Information regarding laboratory requirements for detection limits, precision, and accuracy of soil samples is discussed in Section 3.0.

2.1.3. Sampling Equipment Geoprobe® direct-push rig, or equivalent; DT22 dual-tube sampling tool (2.25-inch diameter) or MC5 system used in Piston mode; Acetate liners for dual-tube sampling tool; Decontamination supplies, including Alconox, buckets, brush, and clean water; Soil sample containers (see QAPP Worksheet #19 for sample container requirements); Stainless steel scoops and spatulas; Gallon-sized zip lock plastic bags; Field notebook, sample collection form, or other acceptable medium for recording field notes.

Ballpoint, indelible pens; Camera for photo documentation; Shipping materials (coolers, ice, ziplock bags, etc.); Sample Labels generated from FUDSCHEM; Chain of Custody forms generated from FUDSCHEM; Measuring tape; Trimble Geo 7X GPS; Appropriate personal protection equipment, as described in the APP/SSHP/AHA (PPE); Plastic sheeting for laying out soil samples for characterization; Pin flags in 2 different colors, one to mark corners of DUs, another to mark increment sampling

locations within the DUs.

2.1.4. Sampling Procedure 1. Pre-clear all drilling locations by calling DigSafe (888-DIG-SAFE) for subsurface utility clearance at

least 72 hours prior to drilling activities. 2. The corners of the 30 ft by 30 ft target area will be surveyed. The 10 ft by 10 ft grid defining the DUs

will be marked in the field using a GPS and tape measure. Nine sampling locations within each DU will be measured and marked with a pin flag. Each replicate will comprise of three of the nine sampling locations within each DU. The three locations for each replicate will be chosen at random prior to sampling.

3. Soil cores will be collected utilizing direct-push technology (DPT) per Stone SOP SEI-6.1.6. 4. The DT22 dual-tube sampling tool and/or MC5 tool will be advanced to a depth of 4 ft bgs and

retrieved. 5. Nine cores will be collected from each DU. For DUs 1-9, the ISM increments will consist of one-

third of the top 3 ft from each of the 9 cores in the DU. Diligence must be taken to when splitting the core into 3 lengthwise sections to ensure that each vertical section from each core is approximately the same volume and includes soil representative of the full 0-3 ft depth interval. For DUs 10-18, the ISM increments will consist of the 3-4 ft depth interval from each of the 9 cores in the DU. Three field replicates, each consisting of 3 increments will be generated for each DU. Each of the 3 replicates will consist of 3 increments and will be placed in a gallon-sized zip lock plastic bag. Each replicate will consist of approximately one gallon volume of soil.


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6. An experienced geologist or other qualified geoscience professional will log the soils as per Stone SOP SEI-6.46.0, using the Unified Soil Classification System (USCS), noting the following characteristics: i. Particle size distribution; ii. Gradation; iii. Color; and iv. Odor.

7. Once the 3 increments for each replicate have been composited into a bag, the sample will be sealed, labelled, and prepared for shipment under COC to a fixed laboratory for analysis. The composite sample collected from each DU will consist of approximately one gallon volume of soil.

2.2. Post Excavation Confirmation Sampling Results from pre-design investigation sampling will be used to develop the plan for soil excavations around TP6. It shall be noted that the volumes and areas discussed for soil excavation and confirmation sampling hereafter are subject to change based on the pre-design investigation. For the purpose of this FSP, a 30 ft by 30 ft by 4 ft deep area centered at TP6 will be the assumed for the PCB soil excavation. Following soil excavation, confirmation sampling along the floor and sidewalls of the excavation will be conducted to determine if RGs were met.

2.2.1. Sampling Objectives The objective of post excavation confirmation sampling is to determine if the remaining soil following excavation contains PCBs at concentrations exceeding the RG. ISM will be conducted on the floor and each sidewall of the excavation to estimate the mean concentration of PCBs. Each sidewall of the excavation and the floor of the excavation will be designated as separate DUs, however this is subject to change based on the results of pre-design investigations and the actual areas and volumes excavated. Data generated from sampling will be compared to the RG and used to determine if additional excavation is needed. Should the initial excavation not meet RGs and additional excavation is needed, a second round of confirmation sampling will be completed using ISM from the floor and sidewalls of the step-out excavation. Results from the step-out excavation will be compared to the RG. Excavation and sampling will continue until analytical results indicate that the concentration of PCBs in floor and side walls of the excavation do not exceed the RG.

Data obtained will be of sufficient quality and quantity to allow the project team to make decisions regarding the mean PCB concentration for soils in each DU relative to the RG in order to determine if additional excavation is need. Samples will be collected 2-inches below surficial soil to ensure native material is being sampled from the excavation floor and sidewalls. The RG, 1.7 mg/Kg, used for decision making is Site-specific and based on the human health risk assessment included in the RI (JCO, 2013) and FS (Stone Environmental, 2014). The confirmation sampling plan has been designed to provide data of sufficient quantity and quality to confirm that the mean concentration in the remaining soils is below the RG within the 95% upper confidence level (UCL), in accordance with the ISM Guidance (ITRC, 2012). A DU with a mean concentration above the RG will require further excavation.

Data Quality Objectives, analytical methods, and Quality Assurance/ Quality Control (QA/QC) for laboratory analysis is provided in the Quality Assurance Project Plan.

2.2.2. Sampling Locations, Frequency, and Rationale The confirmation sampling procedures will differ from the pre-design sampling procedures in that the confirmation sampling will focus on collecting samples from the surface of the excavation floor and sidewalls. Samples will be collected by hand from the top 2 inches of soil, rather than coring soils at depth with a direct push drill rig.


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The following procedures for the confirmation sampling are based on excavation of all 18 DUs, creating an excavation of 30 ft by 30 ft by 4 ft deep; however, this is subject to change based on the results of the pre-design sampling and the actual excavation plan. The floor of the excavation will be designated as one DU to confirm that the excavation proceeded to the depth necessary to remove soil with PCBs exceeding the RG. The northern, southern, eastern, and western sidewalls will each serve as separate DUs to determine if the horizontal extents of PCB impacts have been removed. Three replicate samples will be collected from each of the 5 DUs, resulting in a total of 15 samples to be submitted to the Laboratory. Each replicate sample will be a composite of 10 increments within the designated DU. It should be noted that other factors including excavation shape and visual evidence of unexcavated gray material will factor into establishing DUs for confirmation sampling. Once received by the laboratory, each replicate will be thoroughly homogenized and 30 grams of soil will be collected from the homogenized sample for extraction and analysis. Samples will be extracted using soxhlett (method SW3540) which utilizes drying with sodium sulfate. The samples will also be analyzed for total solids and the results will be adjusted for this. Information regarding laboratory requirements for detection limits, precision, and accuracy of soil samples is discussed in Section 3.0.

Any deviations to the confirmation sampling plan discussed above will be communicated to USACE through the pre-design investigation sampling summary report. The summary report will discuss the reason for deviation from the proposed confirmation sampling plan and excavation dimensions. Deviations could be the result of pre-design investigation data that indicates a particular DU has a mean concentration below the RG and does not need to be removed for disposal. In the event of a difference from original excavation dimensions, all efforts will be made to avoid deviations to the verification sampling plan. The floor of the excavation will be designated as one DU, and the sidewalls will be divided into a minimum of 4 DUs. In general, the corners of sidewalls will be used to separate sidewall DUs, therefore side wall DUs may vary in size and number depending on the configuration of the excavation. However, the area of each of the sidewall DUs will not exceed the maximum area proposed in this plan. The USACE will have an opportunity to comment on any significant deviations to the confirmation sampling plan before it is implemented.

Prior to conducting surface soil sampling in each DU, pin flags will be used to mark the locations for 30 surface sample location, approximately evenly spaced across the DU surface. To create each of 3 replicate samples in each DU, 10 increments will be randomly chosen from the marked sample locations and will be composited. Approximately 3 ounces of soil will be collected with a stainless steel spoon or scoop from the top 2 inches of each incremental sampling location. The soil will be placed in a gallon-sized zip lock plastic bag and combined with the other 9 increments for that replicate sample. Care will be taken to ensure that all incremental samples are similarly sized to avoid sampling bias. Zip lock bags containing the sample will be labeled with the prepared FUDSCHEM generated labels, placed in an ice filled cooler, and shipped to the laboratory under standard chain of custody procedures. All samples will be submitted for fixed laboratory analysis for PCBs by US EPA Method 8082. Information regarding laboratory requirements for detection limits, precision, and accuracy of soil samples is discussed in Section 3.0.

Sampling procedures are further discussed in Section 2.2.4. All samples will be submitted for fixed laboratory analysis for PCBs by US EPA Method 8082. Information regarding laboratory requirements for detection limits, precision, and accuracy of soil samples is discussed in Section 3.0.

2.2.3. Sampling Equipment Soil sample containers (see QAPP Worksheet #19 for sample container requirements); Stainless steel scoops and spatulas; Gallon-sized zip lock plastic bags;


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Field notebook, sample collection form, or other acceptable medium for recording field notes. Ballpoint, indelible pens;

Camera for photo documentation; Shipping materials (coolers, ice, zip lock bags, etc.); Sample Labels generated from FUDSCHEM; Chain of Custody forms generated from FUDSCHEM; Measuring tape; Trimble Geo 7X GPS; Decontamination supplies, including Alconox, buckets, brush, and clean water; Appropriate personal protection equipment, as described in the APP/SSHP/AHA (PPE); Pin flags in 2 different colors, one to mark corners of DUs, another to mark increment sampling

locations within the DUs.

2.2.4. Sampling Procedure 1. DUs will be established on the excavation floor and each sidewall. Thirty evenly distributed sampling

locations will be marked with a pin flag in each DU. Ten increments will be randomly chosen from the marked sample locations and will be composited to create each of the 3 replicate samples within a DU.

2. Approximately 3-oz of soil will be collected from the top 2-inches of each incremental sampling location and composited into a plastic zip lock bag. Three ounce of soil from each increment will provide the laboratory with enough soil (approximately 0.25 gallon) to analyze 3 replicate samples.

3. An experienced geologist or other qualified geoscience professional will log the soils as per Stone SOP SEI-6.46.0, using the Unified Soil Classification System (USCS), noting the following characteristics: i. Particle size distribution; ii. Gradation; iii. Color; and iv. Odor.

4. Once all 10 increments for each replicate have been composited into a bag, the samples will be sealed, labelled, and prepared for shipment under COC to a fixed laboratory for analysis. The composite sample collected from each DU will consist of approximately 0.25 gallons of soil. Once received by the laboratory, each replicate will be thoroughly homogenized and 30 grams of soil will be collected from the homogenized sample for extraction and analysis. Samples will be extracted using soxhlett (method SW3540) which utilizes drying with sodium sulfate. The samples will also be analyzed for total solids and the results will be adjusted for this.Information regarding laboratory requirements for detection limits, precision, and accuracy of soil samples is discussed in Section 3.0

2.3. Sample Identification (ID) Nomenclature The protocol for determining sample IDs for the composite samples is described below. Sample IDs will consist of 18 digits which indicate the DU number, as well as type of sample (pre-design or confirmation), depth for pre-design samples or surface location for confirmation samples, and a replicate code identification number.

2.3.1. Pre-design samples: The following are examples of the sample ID protocol for pre-design samples:


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DUxx-PD03-110616-2, where xx is the DU number (1 through 18), PD indicates pre-design sample, 03 indicates depth interval 0-3 ft bgs, 110616 indicates the date the sample was taken, and 2 indicate the sample is the second replicate.

DUxx-PD34-110616-1, where xx is the DU number (1 through 18), PD indicates pre-design sample, 34 indicates depth interval 3-4 ft bgs, 110616 indicates the date the sample was taken, and 1 indicate the sample is the first replicate.

2.3.2. Confirmation samples: The following are examples of the sample ID protocol for confirmation samples:

DUxx-CSFL-110616-2, where xx is the DU number (19), CS indicates confirmation sample, FL indicates it was collected from the floor of the excavation, 110616 indicates the date the sample was taken, and 2 indicates the sample is the second replicate.

DUxx-CSSW-110616-1, where xx is the DU number (20 through 23), CS indicates confirmation sample, SW indicates it was collected from the southern sidewall of the excavation, 110616 indicates the date the sample was taken, and 1 indicates the sample is the first replicate.

2.4. Chemistry Electronic Data Deliverables The laboratory will report data using the Staged Electronic Data Deliverables (SEDD)/Automated Data Review (ADR) format version 5.0/5.1 Stage 2.A EDD. The laboratory will provide a level 4 data package with full QC and a .pdf document file of the laboratory’s final data report that includes supporting documentation such as chromatograms and instrument calibrations. A comprehensive ADR project eQAPP will be generated. The analytical data (SEDD File) will be reviewed using ADR and the associated eQAPP file and field data, will be uploaded into the Formerly Used Defense Site Chemical Database (FUDSCHEM) with the assistance of Synectics and KGS.

2.5. Quality Assurance Project Plan A Quality Assurance Project Plan (QAPP) has been prepared in accordance with Uniform Federal Policy for Quality Assurance Project Plans: Optimized UFP-QAPP Worksheets, dated March 2012. The QAPP is a standalone document prepared as an accompaniment to this FSP. Please refer to the QAPP for details regarding analytical procedures and QA/QC.

2.6. Decontamination and Investigation Derived Waste

2.6.1. Decontamination Procedures Collection of incremental samples for compositing will occur in one DU at a time. Decontamination of equipment used for sampling will not be required between collection of incremental samples within a single DU, since the increments will be composited into a single sample. However, when moving from one DU to the next, all sampling equipment will be decontaminated. Stainless steel drill pipe used for collection of the soil cores, as well as all spoons, scoops, bowls, or measuring devices will be washed with a solution of Alconox and water and rinsed with clean municipal water before proceeding from one DU to the next.

2.6.2. Investigation Derived Waste (IDW) During the pre-design investigations, excess soil from soil coring, that was not used to generate the composite samples, will be placed on the ground surface in the DU where it was obtained. Decontamination fluids from each DU will also be discharged to the ground surface in the DU from which they were generated.


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During the confirmation sampling, no IDW will be generated from soil sampling because increments will be collected by hand using scoops or spoons. As described for the pre-design investigation decontamination fluids, the small volume of decontamination fluids that will be generated from the confirmation sampling effort will be discharged in the area where the sampling was performed. Decontamination fluids generated from sampling the excavation floor DU will be discharged onto the excavation floor. Decontamination fluids generated from the side wall DU sampling will be discharged along the outside perimeter of the excavation within approximately 1 foot of the edge of the excavation. Therefore, if there are exceedances of the RGs in any DUs during confirmation sampling, the soils where the decontamination fluids were discharged for that DU will be designated for removal based on confirmation sampling results.


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3. References

1. Intergovernmental Data Quality Task Force, 2012. Uniform Federal Policy for Quality Assurance Project Plans: Optimized UFP-QAPP Worksheets. March.

2. The Interstate Technology & Regulatory Council Incremental Sampling Methodology Team, 2012. Technical & Regulatory Guidance Incremental Sampling Methodology. February.

3. The Johnson Company, Inc. (JCO), 2013. Final Remedial Investigation Report, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. January.

4. Stone Environmental, Inc. (Stone), 2014. Final Feasibility Study, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for: U.S. Army Corps of Engineers, New England District. November.

5. Stone, 2016. Final Decision Document, Former Lyndonville Air Force Station, East Haven, Vermont. Prepared for U.S. Army Corps of Engineers, New England District. September.


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Figures

Figure 1: Site Location Map

Figure 2: Debris Area

Figure 3: Pre-Design Investigation Decision Units

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ATTACHMENT E Project Schedule

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1000 CONTRACT AWARD 0 0 06SEP16 0 0

1010 KICK-OFF MEETING 1d 1d 26SEP16 * 26SEP16 0 0

1015 USACE RIGHT OF ENTRY FOR FAFS 155d 155d 27SEP16 01MAY17 10d 0

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1280 OPTION 1-ADDT'L 100 TN SOIL EXCAV (IF 5d 5d 07SEP17 13SEP17 0 0



1310 OPTION 4-ADDT'L 100 TN SOIL EXCAV (IF 5d 5d 28SEP17 04OCT17 0 0

CONTRACT AWARD

KICK-OFF MEETING

USACE RIGHT OF ENTRY FOR FAFS LYNDONVILLE

PREPARE DRAFT WORK PLANS (APP/QAPP/SAP)

USACE NED REVIEW DRAFT WORK PLANS

DEVELOP RTCS / DRAFT FINAL WORK PLANS

VT DEC REVIEW DRAFT FINAL WORK PLANS

DEVELOP RTCS / FINAL WORK PLANS

USACE NED/VT DEC REVIEW FINAL WORK PLANS

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PROCUREMENT SUBS / SUPPLIES

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MOBILIZATION (PRE-DESIGN INVESTIGATION)

COMPLETE PRE-DESIGN INVESTIGATION

SAMPLE ANALYSIS / LAB RESULTS

PREPARE DRAFT RAWP ADDENDUM (IF NECESSARY)

USACE NED REVIEW DRAFT RAWP ADDENDUM

DEVELOP RTCS / DRAFT FINAL RAWP ADDENDUM

VT DEC REVIEW DRAFT FINAL RAWP ADDENDUM

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USACE NED / VT DEC REVIEW FINAL RAWP ADDENDUM

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PERMITS (DIG/WELL)

MOBILIZATION (REMEDIAL ACTION)

SITE PREPARATION (CLEAR/GRUB/E&SC)

EXCAVATION (BASE 108 TONS) AOC-1 DEBRIS AREA

WASTE TRANS & DISPOSAL (BASE 108 TONS)

CONFIRMATORY SAMPLING (BASE AOC-1)

LAB ANALYSIS / SAMPLE RESULTS FOR ISM CONFIRM

OPTION 1-ADDT'L 100 TN SOIL EXCAV (IF NECESSARY)




Start date 06SEP16Finish date 16JAN18Data date 06SEP16Run date 01MAR17Page number 1A

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1320 SITE RESTORATION 5d 5d 05OCT17 11OCT17 0 0

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1410 VT DEC REVIEW DRAFT FINAL RACR 15d 15d 11DEC17 02JAN18 0 0

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1440 FINAL RACR APPROVED 0 0 16JAN18 0 0

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1460 PROJECT COMPLETION 0 0 09JAN18 5d 0

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USACE NED / VT DEC FINAL INSPECTION

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DEVELOP DRAFT REMEDIAL ACTION COMP REPORT (RACR)

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VT DEC REVIEW DRAFT FINAL RACR

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USACE NED / VT DEC REVIEW FINAL RACR

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PROJECT CLOSEOUT

PROJECT COMPLETION

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Remedial Action and Project Closeout ActivitiesLyndonville Former Air Force Station, VT

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February 28, 2017 Mr. Hugo Martinez-Cazon Vermont ...

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