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                     ** DRAFT COPY **                 
              
              Mini Quality Assurance Project Plan 
                    for Field Oversight of 
     Site Investigation and Remedy Development Activities 
        at the Lemon Lane Landfill Bloomington, Indiana


Prepared for:

     U.S. Environmental Protection Agency
     Region 5
     77 West Jackson Boulevard
     Chicago, IL 60604

Prepared by:

     EARTH TECH
     5555 Glenwood Hills Parkway SE
     Grand Rapids, Michigan 49588-0874

March 1995

U.S. EPA Contract No. 68-W8-0079
WA No. 23-SBZ
EARTH TECH Project No. 04023

U.S. EPA Region S Work Assignment Manager

U.S. EPA Region 5 QA Manager

EARTH TECH Project Manager
               TABLE OF CONTENTS

(Note: scanning this document for the BBS changed the pagination,
and the page numbers listed here may no longer be accurate)

1.0  PROJECT DESCRIPTION                     1-1
     1.1  Site Background and History        1-1
          1.1.1 Site Background              1-2
          1.1.2 Waste Disposal               1-2
          1.1.3 Site Topography              1-2
          1.1.4 Site Geology                 1-2
          1.1.5 Hydrogeology                 1-3
          1.1.6 Groundwater Use              1-4
          1.1.7 Surface Water Hydrology      1-4
          1.1.8 Site Land Use                1-4
          1.1.9 Past Data Collection 
               Activities                    1-4
     1.2  Summary of Oversight Activities         1-5
     1.3  Project Schedule                   1-7

2.0  PROJECT ORGANIZATION AND 
     RESPONSIBILITIES                        2-1

3.0  QUALITY ASSURANCE OBJECTIVES FOR 
     ANALYTICAL DATA                         3-1
4.0  FIELD SAMPLING PROCEDURES                    4-1
     4.1 Sampling Site Selection             4-1
     4.2 Sampling Procedures                 4-1
     4.3 Sampling Custody Concerns           4-2
     5.0  SAMPLE CUSTODY                     5-1
     5.1  Introduction                       5-1
     5.2  Field Specific Custody Procedures       5-1
          5.2.1 Field Procedures             5-1
          5.2.2 Field Logbooks/Documentation      5-2
          5.2.3 Transfer of Custody and 
               Shipment Procedures           5-3
          5.3  Laboratory Custody Procedures      5-4
          5.4  Final Evidence Files Custody 
               Procedures                    5-4

6.0  CALIBRATION PROCEDURES                  6-1

7.0  ANALYTICAL PROCEDURES                   7-1
8.0  DATA REDUCTION, VALIDATION, AND 
          REPORTING                          8-1

9.0  INTERNAL QUALITY CONTROL CHECK          9-1
10.0 PERFORMANCE AND SYSTEM AUDITS           10-1

11.0 PREVENTIVE MAINTENANCE                  11-1

12.0 DATA ASSESSMENT PROCEDURES              12-1

13.0 CORRECTIVE ACTIONS                      13-1

14.0 QUALITY ASSURANCE REPORTS               14-1

               TABLES (NOT SCANNED FOR BBS)

Table 1-1      Contract Lab Program Organic Parameters      Target Compound List
Table 1-2      Contract Lab Program Inorganic Parameters    Target Analyte List
Table 1-3      Target Compound List and Quantitation Limits      for
               Dioxins and Furans
Table 1-4      MQAB Target Compound List and Quantitation Limits
               for Residential Well Water Samples
Table 1-5      MQAB Target Analyte List and Quantitation Limits
               for Residential Well Water Samples
Table 4-1      Sample Containers, Preservation, Shipping, and
               Packaging Requirements

          FIGURES (NOT SCANNED FOR BBS)

Figure 1-1     Regional Site Location Map
Figure 1-2     Spring Sampling Locations
Figure 1-3     Monitoring Well Sample Locations
Figure 1-4     Residential Well Sample Locations
Figure 2-1     Project Organization

          APPENDICES (NOT SCANNED FOR BBS)

Appendix A     Summary of Historical Data
Appendix B     Summary Tables of Sampling and Analysis Program
Appendix C     Special Analytical Services (SAS)
Request Forms
 
1.0 PROJECT DESCRIPTION

The purpose of this project is to conduct oversight of Site
Investigation and Remedy Development activities conducted by the
potentially responsible parties (PRPs) and their contractors at
the Lemon Lane Landfill site. Westinghouse Remediation Services
will conduct the Site Investigation. EARTH TECH (formerly WW
Engineering & Science) will monitor and observe field activities
conducted by the PRP's remediation service and determine whether
these activities are being performed in accordance with the PRP's
Work Plan, Quality Assurance Project Plan, Field Sampling Plan,
and Health and Safety Plan (collectively referred to as Project
Plans), prepared by the contractor. Site Investigation and Remedy
Development oversight field activities include collecting and
splitting sediment, surface water, and groundwater samples on the
majority of the samples collected by the PRPs. While Westinghouse
is restricting their analysis to only PCBs, EARTH TECH will
collect and submit sediment, surface water, and ground water
samples according to routine analytical services (RAS) protocol
for organics and inorganics as well as dioxins and furans by
special analytical services (SAS). The groundwater from the
residential wells will be analyzed using low concentration SASs
for organics, inorganics, and for dioxins and furans.

The purpose of conducting oversight of sampling is to evaluate
the sampling, shipping, and analytical procedures of the PRP's
contractor and laboratory, as well as to analyze samples for a
more complete list of possible contaminants.

An overview of the site location is described in the QAPP for the
Bloomington Sites Vol. I, March 1995. A more detailed description
of site conditions is presented in QAPP-Volume II, Field Sampling
Plan for the Lemon Lane Groundwater Monitoring investigation,
March 1995. The Lemon Lane Landfill site covers approximately 10
acres and is located on the northwest side of Bloomington,
Indiana in Monroe County (Figure 1-1).

1.1 SITE BACKGROUND AND HISTORY

The following site history and background information is taken
directly from the QAPP for the Bloomington Sites, Westinghouse
Bloomington Project, March 1995.

(EDITORIAL NOTE TO BBS USERS: IN THE EPA/EARTH TECH DOCUMENT,
SECTIONS 1.1.1 THROUGH 1.1.9 WERE WRITTEN IN ITALICS)
 
1.1.1 SITE BACKGROUND

The Lemon Lane Landfill is on the northwest side of Bloomington
in Monroe County, Indiana. The 10-acre landfill is bounded on the
east by Lemon Lane, on the south by the L&N Railroad, on the
north by residential property, and on the west by undeveloped
land. The Indiana State Route 37 Bypass is about 900 feet
northwest of the landfill entrance.

1.1.2 WASTE DISPOSAL

The Lemon Lane Landfill opened as a refuse dump in 1933. The City
of Bloomington operated the landfill from 1950 to 1964 as a
municipal waste landfill. It was also used as a repository for
industrial debris and waste. Electrical capacitors from
Westinghouse's Bloomington Plant were deposited in Lemon Lane
Landfill between 1958 and 1964 by contracted local haulers.
Landfill operations were typical of the period, without the
controls and design features common to modern facilities. No
liner or cover was used, dumping was not controlled with regard
to waste content, site security, or records, and scavenging and
burning were common daily practices. In cases where the disposed
items, such as capacitors, were popular in salvage activities,
such items would be placed at the edge of the landfill to prevent
salvagers from interfering with dump operations.

1.1.3 SITE TOPOGRAPHY

The Lemon Lane Landfill is situated in a surface depression
interpreted to be associated with a compound sinkhole. The
compound sinkhole runs northeast to southwest and extends
southwest of the Lemon Lane Site beyond the L&N Railroad. The
site is near topographic divides between the headwaters of Clear
Creek to the southeast, Stout's Creek to the northwest, and Griff
Creek to the northeast. The topography across most of the site
moderately slopes to the west. The surface elevation of the
landfill ranges from 850 to 890 feet above mean sea level.

1.1.4 SITE GEOLOGY

The earthen cover at the site consists of fill material and
native soils ranging from about 10.5 to 43 feet thick. The fill
material is described as clayey, silty, sandy, and gravelly soils
mixed with varying amounts of ash, cinders, glass, plastic, wood,
wire, metal, asphalt, cement, paper, and brick. The soil beneath
the fill consists of indigenous red clay.
 
The earthen cover is underlain by Mississippian age bedrock
units. The St. Louis Limestone of the Blue River Group underlies
the overburden layer and is in turn underlain by the Salem
Limestone of the Sanders Group. The St. Louis Limestone consists
of layers of gray to yellow brown limestone, dolostone, and
shale, with many water-bearing and dry solution features. The
Salem Limestone is described as a light grayish and yellow to
gray, thick, cross-bedded calcarenite, which is famous as a
building stone known as the "Indiana Limestone." Bedrock at Lemon
Lane is similar to that of southern Indiana and the Bloomington
area and generally dips west to southwest at about 30 feet per
mile.

1.1.5 HYDROGEOLOGY

The groundwater flow system associated with the site consists of
recharge areas, flow areas, and discharge areas. Recharge to the
groundwater flow system is believed to occur primarily through
sinkholes and swallow holes in the region surrounding the
landfill, and to a lesser extent by seepage through the earthen
cover adjacent to the landfill. On the basis of existing data for
the site, the groundwater system beneath Lemon Lane Landfill
appears to occur within two intervals separated by a shale unit
occurring at 782 feet above mean sea level to the east and 778
feet to the west. The shallow groundwater zone occurs within
bedrock between 798 and 820 feet, and the deeper zone occurs
within bedrock between 760 and 770 feet.

Basin studies have indicated a maximum flow depth in the Illinois
Central basin between 150 and 185 feet. This is supported by
monitoring well data at Lemon Lane. Packer and slug testing of
the wells demonstrated that they yield very little water.
Continuous water level monitoring indicated no response to storm
events in the deep wells. Low sulfate concentrations also
indicated that there is not a deep paretic component of flow.

Groundwater within the shallow zone is believed to flow primarily
through conduits. Groundwater within the deeper zone is believed
to flow primarily through fractures relatively unmodified by
dissolution. In 19&7, a low-flow dye tracer test was conducted,
and in 1989 and 1990, high-flow dye tracer tests were conducted
to determine the groundwater flow from Lemon Lane Landfill. From
data gathered during low-flow conditions, groundwater flows to
the southeast and eventually drains at Illinois Central Spring
and then at Quarry Spring. During high-flow conditions, the
primary flow network from the landfill is still Illinois Central
and Quarry springs. There are indications that a minor amount of
groundwater from the perimeter of the landfill flows to the
northwest and discharges at the Slaughterhouse Spring,
Packinghouse (PH Road Spring, and PH Culvert Spring.


1.1.6 GROUNDWATER USE

Residences and businesses near and downgradient of the landfill
are served by the municipal water supply. A private well user
survey published in 1986 by Indiana University School of Public
and Environmental Affairs provided names and addresses of private
wells used for commercial or residential purposes within 5,000
feet of the landfill. The survey concluded that there were 1,050
properties and 20 private wells in use within this radius. Since
1990, all residents served by private wells near the Lemon Lane
Landfill have been connected to the city water source. This was
confirmed by a Westinghouse survey.

 
1.1.7 SURFACE WATER HYDROLOGY

The site lies along the eastern margin of the Mitchell Plain
region, a low plateau developed on limestones of the
Mississippian Blue River and Sanders Group. The Mitchell Plain
surface is characterized by relatively flat topography with
moderate slopes and by karst topography. Topographic features
near the landfill include sinkholes, caves, three surface streams
(Clear Creek, Stout's Creek, and Griff Creek) and associated
tributaries, perennial and intermittent springs, and at least one
sinking stream. A sinkhole pond (Sargent's Pond) is located
northwest of the site. Springs in the area include the Illinois
Central, Quarry, ICG-1, ICG-2, ICG-3, PH Road, PH Culvert, and
Slaughterhouse springs.

1.1.8 SITE LAND USE

Within several hundred feet to the west of the Lemon Lane site is
undeveloped land owned by Westinghouse. The north and east sides
of the site are bordered by residential areas (about 22 houses
and 6 mobile homes). A commercial area (2 or 3 businesses) lies
northeast of the site along Vernal Pike, and a cemetery lies
south of the site.

1.1.9 PAST DATA COLLECTION ACTIVITIES

Various investigations have been undertaken to characterize Lemon
Lane Landfill since the early 1980s. Investigative activities
included geophysical surveys, aerial photograph analyses,
monitoring well installations, groundwater elevation monitoring,
groundwater sampling and
 
analyses (including springs), surface water sampling and
analyses, stream sediment sampling and analyses, air sampling,
soil boring installations, hydraulic conductivity testing, and
high and low flow dye tracer tests.

Numerous sampling activities have characterized PCB
concentrations in environmental media at the Lemon Lane Landfill.
Sampling has been performed to characterize PCDDs and PCDFs in
soils and to characterize volatile organic compounds (VOCs),
semivolatile organic compounds (SVOCs), metals, and pesticides in
surface waters. Because surface capacitors were removed, hot
spots remediated, and a synthetic membrane installed, the pre-Interim Remedial Measures (IRM) surface soil, groundwater,
surface water, sediment, and air monitoring data are not
representative of existing site conditions.

Historical data collected at the site is contained in Appendix A.

1.2 SUMMARY OF OVERSIGHT ACTIVITIES

As part of remedial oversight, EARTH TECH, the U.S. EPA Oversight
Contractor, will provide field oversight of "key" activities as
requested by the WAM (Work Assignment Manager). EARTH TECH will
monitor and observe field activities conducted by the PRP's and
determine whether these activities are being performed in
accordance with the Project Plans prepared by Westinghouse
Remediation. EARTH TECH oversight personnel will document field
activities in a daily log. EARTH TECH will prepare and submit
letter reports to the WAM summarizing field activities within 30
calendar days of completion of the activity. The EARTH TECH site
project manager or his designated representative will contact the
WAM in the event that there are any onsite emergencies,
significant delays or problems that arise during the course of
the investigation, and any significant field modifications that
differ from those specified in the PRP's Project Plans.

Site Investigation oversight activities include collecting and
splitting sediment, surface water, and groundwater samples
collected by the PRPs. EARTH TECH will collect and split surface
water and sediment samples from surrounding natural springs,
existing monitoring wells, and residential wells. Appendix B
contains summary tables which detail sample matrices, analytical
parameters, Data Quality Objectives (DQOs) and frequencies of
sample collection.

Because of the hydrology in the area, six springs shown to be
directly hydrologically connected with Lemon Lane Landfill
(Figure 1-2) will be sampled by Westinghouse Remediation for PCB
contamination as described in their Field Sampling Plan. EARTH
TECH will collect and split samples from these six springs in the
following manner. Surface water from Illinois Central and
Slaughterhouse Springs will be collected and analyzed quarterly
for one year for RAS Target Compound List (TCL) organics and
Target Analyte List (TAL) inorganics listed on Tables 1-1 and 1-2. Dioxins and furans listed on Table 1-3 will be analyzed using
a SAS on the first and third quarters only. Sediment samples will
be collected from the two springs on the first and third quarter
for one year and analyzed for RAS TCL organics and TAL inorganics
plus dioxins and furans. Surface water and sediment will be
analyzed from the remaining four springs, Quarry, ICG- 1, PH
Culvert, and PH Road springs, during two sampling events for RAS
TCL organics and TAL inorganics.

Nine other springs (Figure 1-2) that were shown to be
hydrologically connected to the Lemon Lane Landfill will be
sampled by Westinghouse Remediation for PCB contamination as
described in their Field Sampling Plan. These springs include:
ICG-6, Bypass 37, Urban, Crestmont, Snoddy, Stony West, Stony
East, WN-1, and WS-2. EARTH TECH will collect and split samples
from these nine springs in the following manner. One round of
surface water and sediment samples will be split and collected
from each of the nine springs for RAS TCL organics and TAL
inorganics.

Monitoring wells to be sampled are shown on Figure 1-3. Five
monitoring wells (MW-4I, MW4D, MW-6, MW-7, and MW-8D) will be
sampled quarterly for one year and the groundwater will be
analyzed for RAS TCL organics and TAL inorganics. Dioxins and
furans will be analyzed using a SAS on the first and third
quarters only.

Residential wells to be sampled are shown on Figure 1-4. The
specific wells have not been selected to date and will depend on
site access issues. Up to twenty residential wells will be
sampled quarterly for one year using a residential well SAS for
the low concentration organics and inorganics listed on Tables 1-4 and 1-5. Dioxins and furans will be analyzed using a SAS on the
first and third quarters only.

The majority of the oversight field samples will be submitted to
the Contract Laboratory program (CLP) Laboratory. The CLP
supports the U.S. EPA's Superfund effort by providing a range of
state of the art chemical analysis services of known quality on a
high volume cost effective basis. It provides the basic
requirement to provide legally defensible analytical results for
use in supporting the U.S. EPA's enforcement actions. Accuracy
and precision requirements for CLP protocol analyses are
described in the most recent CLP Statements of Work (SOWs). A
 
compliance quality assurance program has been incorporated into
all aspects of CLP operation. The specific laboratory or
laboratories which will provide the chemical analyses of the
oversight samples will be assigned by the Contract Laboratory
Analytical Services Support (CLASS) on a weekly basis.

Groundwater samples from residential wells will either be
submitted to the Region S Monitoring Quality Assurance Branch
(MQAB) or be subcontracted by EARTH TECH as a SAS. Dioxins and
furans will be subcontracted by EARTH TECH as a SAS.

1.3 PROJECT SCHEDULE

The sampling will occur in conjunction with the PRP's sampling
schedule. Although the PRP QAPP indicates that "the project
schedules are described in detail in the site-specific FSP's,"
EARTH TECH could not locate a succinct project schedule in the
Field Sampling Plan, March, 1995. EARTH TECH personnel will
provide field oversight of activities detailed in this MiniQAPP.
Any field oversight deviations from the Work Plan will be with
the expressed and written consent of the U.S. EPA WAM.
 
     
2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES

The oversight sampling program for the Site Investigation and
Remedy Development Activities at the Lemon Lane Landfill site
will be performed by the U.S. EPA ARCS oversight contractor,
EARTH TECH. The U.S. EPA WAM, Dan Hopkins, serves as the primary
contact and liaison for this site. EARTH TECH will be present on-site as specified in this document.

Analyses of the majority of oversight samples will be performed
by a CLP laboratory. EARTH TECH will properly schedule any
analytical needs with Brian Freeman of the U.S. EPA Region 5.
Arrangements for these analyses are the responsibility of the
Monitoring and Quality Assurance Branch (MQAB) of U.S. EPA,
Region 5. MQAB will also be responsible for final data validation
of CLP data including review of tentatively identified compounds
(TICs). Responsibility for external performance and systems
audits of the CLP laboratory rests with the quality assurance
division of U.S. EPA's Environmental Monitoring and Support
Laboratory (EMSL) in Las Vegas, NV. Figure 2-1 shows the
essential project organization.

The Region 5 MQAB will analyze the groundwater samples from the
residential wells for low concentration organics and inorganics,
if their capacity allows. The Region 5 MQAB Contract Analytical
Support Section (CASS) will be responsible for final data
validation if the MQAB is used. If the Region 5 MQAB is unable to
analyze the samples, EARTH TECH will subcontract these analyses
to another laboratory as a SAS. EARTH TECH will also subcontract
the data validation.

Samples collected for dioxins and furans will be subcontracted as
a SAS by EARTH TECH. Independent data validation will also be
subcontracted.
 
3.0 QUALITY ASSURANCE OBJECTIVES FOR ANALYTICAL DATA

The overall quality assurance objective is to ensure that the
oversight data are of known and acceptable quality. They must be
sufficiently precise and accurate to be used in a comparison with
the data generated by the PRPs. This oversight sampling program
will serve as an external quality assurance measure to check the
sampling and analytical procedures of the PRPs and their
laboratory. In addition, EARTH TECH will be collecting samples
for separate analyses that will be used to support a Risk
Assessment.

To achieve the overall data quality objectives, proper sample
handling and analyses and data handling procedures will be
followed. These procedures are described in the following
sections of this Mini-QAPP.

To assess whether the overall quality assurance objectives have
been met, analyses of specific field quality control samples will
be required. These quality control samples include field
duplicates, field equipment blanks, trip blanks and matrix spike,
matrix spike duplicates (MS/MSD). The preparation of each of
these types of samples is described in Section 4.0. The frequency
with which they will be collected are included on the tables
contained in Appendix B.

Field duplicate sample results will be used to assess the
precision of the field sampling procedure and laboratory results.
They will be used to monitor overall precision, including the
reproducibility of field sampling and laboratory analytical
procedures, as distinct from the precision of analyses of
laboratory replicates. Field duplicate samples are collected at a
frequency of one per group of 10 or fewer investigative samples
per sample matrix.

Field equipment blanks will monitor contamination during all
phases of sample collection, handling, storage, and analysis.
They are distinct from method or laboratory blanks that do not
monitor contamination introduced in the field during sample
collection and handling. held equipment blank samples are
collected at a frequency of one per group of ten or fewer
investigative samples per sample matrix. Field equipment blanks
will not be collected for monitoring well samples as the wells
have dedicated sampling equipment nor for residential wells and
surface water samples as no field equipment will be used to
collect these samples.

Trip blanks will be analyzed for volatile organic compounds only.
They will monitor volatile organic compound migration during
container shipment and sample storage. The trip blank 
sample is collected at a frequency of one per shipping cooler of
volatile organic analysis (VOA) samples.

Matrix Spike/Matrix Spike Duplicate (MS/MSD) samples will be
collected at a frequency of one per 20 or fewer investigative
samples per sample matrix. For water samples, extra sample volume
shall be collected for sample designated for MS/MSD analysis.
Triple the normal sample volumes will be collected for VOAs,
semi-VOAs, pesticide/PCBs, and dioxins and furans. Double the
normal volume is needed for metals and cyanide. For sediment
samples, no extra volume is required.

All sediment, surface water, and groundwater samples will be sent
to the MQAB, CLP, and/or SAS laboratory for analyses. RAS TCL and
TAL analyses will be performed using a current statement of work
(SOW) for organic and inorganic analyses. Tables 1-1 and 1-2
contain the quantitation levels for the TCL and TAL,
respectively.

Either the Region S MQAB or a subcontracted laboratory will
analyze the samples collected from residential wells under the
provisions of a SAS contained in Appendix C. Tables 1-4 and 1-5
contain the quantitation levels for low concentration organics
and inorganics for residential wells, respectively.

A subcontracted laboratory will provide dioxins and furans
analysis using the methods specified in the SOW DFLMO1.0. The
dioxins and furans SAS is included in Appendix C. The
quantitation levels for dioxins and furans are listed on Table 1-3.
 
4.1 SAMPLING SITE SELECTION

With the exception of finalizing the selection of residential
well sample locations, the remainder of the co-located sample
locations have been selected and approved by the WAM.

4.2 SAMPLING PROCEDURES

Sampling procedures to be used by the PRP contractor are
described in the Field Sampling Plan for the Lemon Lane
Groundwater Monitoring Investigation, Westinghouse, March 1995.
EARTH TECH, the U.S. EPA oversight contractor, will be on-site
overseeing the PRP's sampling activities. At the sampling
location where an oversight sample is required, EARTH TECH will
hand the PRP contractor the necessary sample containers for the
oversight sample. The PRP contractor will fill their sample
containers and the oversight containers at the same time. If at
anytime, the volume of sample is not sufficient to fill all the
required sample containers, the priority of analysis is as
follows:

>    VOAs; 
>    PCBs;
>    dioxins and furans; 
>    inorganics;
>    SVOCs; and
>    pesticides

EARTH TECH will retrieve the filled oversight sample containers.
Any field measurements required will be taken by the PRP
contractor and recorded by EARTH TECH in a field notebook for the
oversight program at the time of sampling.

The bottles used for this sampling effort will be prepared using
procedures specified in "Specifications and Guidance for
Obtaining Contaminant-Free Sampling Containers, December 1992."

Tables contained in Appendix B outline the parameters to be
analyzed and the number of quality control samples to be
submitted for analysis for each media Figures 1-2, 1-3 and 1-4
present the PRP's investigation sample locations. EARTH TECH's
proposed co-located sample locations are also noted on the
figures.

Field quality control samples will consist of field duplicates,
field equipment blanks, and trip blanks. One field duplicate per
every ten or fewer sample matrices will be collected
simultaneously with the collection of the investigative sample.
The field duplicate will be analyzed for the same parameters as
the investigative sample.

A field equipment blank will be collected off of the sampling
device used to sample the sediment sample. After decontaminating
the sampling device and prior to collecting the sediment sample,
deionized water will be poured over the sampling device. The
water in the sampling device will then be allowed to drain into
the specified containers. The field equipment blank sample will
be analyzed for the same parameters as the investigative sample.

Each oversight sample cooler shipped to the CLP laboratory will
contain a trip blank to be analyzed for VOAs. Each trip blank
will consist of two 40 ml glass vials with Teflon lined septa
caps filled with organic-free deionized water. The trip blank
vials should travel to and from the field without being opened.

For one investigative oversight sample, three times the normal
sample volume will be collected for VOAs, extractables,
pesticides/ PCBs, and dioxins and furans. For aqueous samples,
double the normal sample volume will be collected for inorganics.
The extra volumes will be used by the laboratory for matrix
spike/matrix spike duplicate analyses. The additional sample
containers will be labeled with the sample number followed by MS
or MSD to identify to the laboratory which sample containers
should be used for the matrix spike and matrix spike duplicate
analyses.

Table 4-1 contains directions on the types and quantities of
sample containers required for each analysis, the proper sample
preservation techniques, and holding times.

4.3 SAMPLING CUSTODY CONCERNS

Sample documentation, custody procedures, sample packaging, and
shipment will be performed according to the U.S. EPA requirements
as described in the U.S. EPA "Sampler's Guide to the Contract
Laboratory Program (December 1990)" and the "User's Guide to the
Contract Laboratory Program (January 1991). Each sample container
will be enclosed in a clear plastic bag and placed in a cooler
packed with non-combustible, absorbent packing material. Coolers
must contain enough ice to maintain sample temperatures at < 4¿C.
Each cooler must be sealed with custody tape in such a manner
that the tape would be broken if the cooler were opened.
Waterproof tape must cover the custody tape. Coolers will be
shipped by overnight carrier.
 
5.0 SAMPLE CUSTODY

5.1 INTRODUCTION

It is EARTH TECH's policy to follow the U.S. EPA Region 5 sample
custody, or chain of custody protocols as described in "NEIC
Policies and Procedures", EPA-330/9-78DDI-R. Revised June 1985.
This custody is in three parts: Sample collection, Laboratory
analysis, and Final evidence files. Final evidence files,
including all originals of laboratory reports and purge files,
are maintained under document controls in a secure area.

A sample and/or evidence file is under your custody if they:

>    are in your possession;

>    are in your view, after being in your possession;

>    are in your possession and you place them in a secured
     location; or

>    are in a designated secure area.

5.2 FIELD SPECIFIC CUSTODY PROCEDURES

The sample packaging and shipment procedures summarized below
will ensure that the samples will arrive at the laboratory with
the chain-of-custody intact.

5.2.1 FIELD PROCEDURES

A.   The field sampler is personally responsible for the care and
     custody of the samples until they are transferred or
     properly dispatched. As FEW people as possible should handle
     the samples.

B.   All bottles will be tagged with sample numbers and
     locations. The Sample Management Office (SMO) number and
     stickers will be affixed.

C.   Sample tags are to be completed for each sample using
     waterproof ink unless prohibited by weather conditions. For
     example, a logbook notation would explain that a pencil was
     used to fill out the sample tag because the ball-point pen
     would not function in freezing weather.
 
D.   EARTH TECH will review all field activities to determine
     whether proper custody procedures were followed during the
     field work and decide if additional samples are required.

5.2.2 FIELD LOGBOOKS/DOCUMENTATION

Field logbooks will provide the means of recording data
collecting activities performed. As such, entries will be
described in as much detail as possible so that persons going to
the site could reconstruct a particular situation without
reliance on memory.

Field logbooks will be bound, field survey books. Logbooks will
be assigned to field personnel, but will be stored in the
document control center when not in use. Each logbook will be
identified by the project-specific document number.

The title page of each logbook will contain the following:

> Person to whom the logbook is assigned;

> Logbook number;

> Project name;

> Project start date, and

> End date.

Entries into the logbook will contain a variety of information.
At the beginning of each entry, the date, start time, weather
conditions, names of all sampling team members present, level of
personal protection being used, and the signature of the person
making the entry will be entered. The names of visitors to the
site, field sampling or investigation team personnel and the
purpose of their visit will also be recorded in the field
logbook.

Measurements made and samples collected will be recorded. All
entries will be made in ink and no erasures will be made. If an
incorrect entry is made, the information will be crossed out with
a single strike mark. Whenever a sample is collected, or a
measurement is taken, a detailed description of the location of
the station, which includes compass and distance measurements,
shall be recorded. The number of the photographs taken of the
station, if any, will also be noted. All equipment used to make
measurements will be identified, along with the date of
calibration.

Samples will be collected following the sampling procedures
documented in the Mini-QAPP. The equipment used to collect
samples will be noted, along with the time of sampling, sample
description, depth at which the sample was collected, volume
collected and number of containers. Sample identification number
will be assigned prior to sample collection. Field duplicate
samples, which will receive an entirely separate sample
identification number, will be noted under sample description.

5.2.3 TRANSFER OF CUSTODY AND SHIPMENT PROCEDURES

(a)  Samples are accompanied by a properly completed chain-of-custody form. The sample numbers and locations will be
     listed on the chain-of-custody form. When transferring the
     possession of samples, the individuals relinquishing and
     receiving will sign, date, and note the time on the record.
     This record documents transfer of custody of samples from
     the sampler to another person, to a mobile laboratory, to
     the permanent laboratory, or to/from a secure storage area.

(b)  Samples will be properly packaged for shipment and
     dispatched to the appropriate laboratory for analysis, with
     a separate signed custody record enclosed in each sample box
     or cooler. Shipping containers will be locked and secured
     with strapping tape and EPA
     custody seals for shipment to the laboratory. The preferred
     procedure includes use of a custody seal attached to the
     front right and back left of the cooler. The custody seals
     are covered with clear plastic tape. The cooler is strapped
     shut with strapping tape in at least two locations.

(C ) Whenever samples are co-located with a source or government
     agency, a separate Sample Receipt is prepared for those
     samples and marked to indicate with whom the samples are
     being co-located. The person relinquishing the samples to
     the facility or agency should request the representative's
     signature acknowledging sample receipt. If the
     representative is unavailable or refuses to sign, this is
     noted in the "Received By" space. 

(d)  All shipments will be accompanied by the Chain-of-Custody
     Record identifying the contents. The original record will
     accompany the shipment, and the pink and yellow copies will
     be retained by the sampler for retuming to the sampling of
     fice.
 
(e)  If the samples are sent by common carrier, a bill-of-lading
     should be used. Receipts of bills of lading will be retained
     as part of the permanent documentation. If sent by mail, the
     package will be registered with return receipt requested.
     Commercial carriers are not required to sign off on the
     custody form as long as the custody fonn is sealed inside
     the sample cooler and the custody seals remain intact.

5.3 LABORATORY CUSTODY PROCEDURES

The chain-of-custody procedures for the Contract Laboratory
Program (CLP) are described in the Statements of Works (SOWs) for
TCL Organics and TAL Inorganics referenced in Section 3.0. These
custody procedures along with the holding time requirements for
CLP samples are described in the appropriate SOW documents. The
same custody procedures applies to SASs.

5.4 FINAL EVIDENCE FILES CUSTODY PROCEDURES

The final evidence files from the MQAB and Contract Laboratory
Program (CLP) are maintained by Region 5 MQAB Laboratory Support
Team, Data Coordinator.

EARTH TECH will maintain the field oversight of the Site
Investigation and Remedy Development files along with all
relevant records, reports, logs, field notebooks, pictures,
subcontractor reports and the Contract Analytical Services
Section (CASS) of MQAB's data reviews in a secured, limited
access area and under custody of EARTH TECH's Site Project
Manager (SPM).
 6.0  CALIBRATION PROCEDURES

The CLP calibration of laboratory instruments will be consistent
with the CLP Statement of Works referenced in Section 3.0.

The SAS calibration of laboratory instruments will be consistent
with the SAS contained in Appendix C for low concentration
organics and i: lorganics and for dioxins and furans.

The PRPs contractor's field personnel will perform all required
field measurements on the water samples including pH,
conductivity, temperature and turbidity in accordance with the
Quality Assurance Project Plan for the Bloomington Sites,
Westinghouse, March 1995. EARTH TECH will document the field
calibration and record measurements in the field notebook.
 
7.0 ANALYTICAL PROCEDURES

All media sampled will be submitted for CLP RAS TCL organics and
TAL inorganics and as a SAS for low concentration organics and
inorganics and for dioxins and furans using the SOWs specified in
Section 3.0. All analytical and quality control requirements
specified in the SOWs will be adhered to by either the CLP, MQAB,
or subcontracted SAS laboratory.

EARTH TECH is not performing any analytical procedures in the
field.
 
     
8.O DATA REDUCTION, VALIDATION, AND REPORTING

Data reduction will be performed by the CLP, MQAB, or SAS
laboratory in accordance with the requirements of the CLP and SAS
SOWs referenced in Section 3.0.

Data validation will be perforrned by U.S. EPA Region 5 Central
Regional Laboratory (CRL) using the Functional Guidelines for the
Validation of Organic and Inorganic Data for CLP data.

An independent subcontractor will validate any SAS data in
accordance with the following guidelines:

>    data package completeness 
>    holding times 
>    instrument tuning 
>    calibration
>    blanks 
>    surrogate recoveries 
>    matrix spike/ matrix spike duplicate 
>    field duplicates 
>    internal standard performance 
>    compound identification
>    compound quantitation

Analytical results will be reported in accordance with the CLP
and SAS SOWs referenced in Section 3.0.
 
9.0 INTERNAL OUALITY CONTROL CHECK

The internal quality control check of the laboratory analysis
will be in accordance with the CLP and SAS SOWs referenced in
Section 3.0.

No field measurements will be collected by EARTH TECH personnel.
All field measurements will be taken by the PRP contractor's
personnel.
 
     
10.0 PERFORMANCE AND SYSTEM AUDITS

Project audits can determine adherence to established and
documented sample collecting, handling and documentation
procedures. Audits will be performed at the discretion of the WAM
and the Quality Assurance Officer (QAO). Results of the audits
will be reported to the QAO and the WAM who will identify any
areas in which corrective action is needed.

Performance audits of the CLP laboratory are conducted as part
of, and according to, the requirements of the Contract Laboratory
Program. Responsibility for such audits rests with EMSL-Las
Vegas.

Performance audits of the SAS laboratory may be conducted at the
discretion of the U.S. EPA Region MQAB and/or Central District
Office (CDO).
 
11.0 PREVENTTVE MAINTENANCE

Laboratory equipment will be maintained according to
manufacturer's specificaions and in such a way that the quality
control requirements of the CLP and SAS laboratories will be met
for all analyses performed

No field measurements will be collected by EARTH TECH personnel,
hence no preventive maintenance for field instruments is
required.
 
     
12.0 DATA ASSESSMENT PROCEDURES

All analytical data will be evaluated for precision, accuracy,
and completeness. The acceptability of the analytical precision
and accuracy will be determined by comparing them to the control
limits recommended in the CLP and SAS SOWs referenced in Section
3.0. data detemmined to be insufficiently precise or accurate
will be subject to the corrective action prescribed by the
appropriate CLP or SAS analytical method. The quality control
samples used in the determination of precision and accuracy have
been described in Section 9.0. Specific equations used to
calculate precision, accuracy, and completeness are presented
below:

Precision will be expressed in terms of relative percent
difference (RPD).

RPD = (Concentration 1 - Concentration 2 x 100)/((Concentration 1
     + Concentration 2) /2(

Accuracy as determined from the analysis of an extemal reference
standard will be expressed as percent recovery (%R).

% R = (Measured Concentration x 100)/Actual Concentration

Accuracy as determined from the analysis of a spiked sample will
also be expressed as percent recovery (%R).

% R = (Spiked Sample Concentration - Sample Concentration x 100)/
     (Concentration of Spike Added)

Completeness will describe the number of usable analytical
results as a percentage of the total number of samples submitted
for analysis.

% Complete = (Number of usable results x 100)/ (Number of samples
     submitted)
  
13.0 CORRECTIVE ACTIONS

Corrective action must be taken any time a situation develops
that threatens data quality. Corrective action may be required if
field or laboratory audits reveal unacceptable deviations from
approved procedures. It may be required any tirne duplicate or
spiked sample analyses exceed the quality control limits or when
blank analyses indicate unacceptable levels of contamination.
Corrective action may include resar,npling and reanalysis of a
few samples or the cessation of all analyses with subsequent
reanalysis of all samples upon resolution of the problem.
Specific analytical corrective actions are described in the CLP
and SAS SOWs referenced in Section 3.0 and will be adhered to by
the laboratory. A quality control problem that cannot be solved
by immediate corrective action must be thoroughly investigated to
determine the extent of the problem and to ensure that all
samples affected by the problem are identified and reanalyzed.
14.0 OUALITY ASSURANCE REPORTS

Analytical data will be validated in accordance with the
following U.S. EPA guidance documents:

1.   Region 5 Standard Operating Procedure for Validation of CLP
     Organic Data, U.S. EPA Region 5, Central Regional Laboratory
     (now MQAB) August 1993.

2.   Region 5 Standard Operating Procedure for Validation of CLP
     Inorganic Data, U.S. EPA Region 5, Central Regional
     Laboratory (now MQAB), September 1993.

A summary quality assurance statement will accompany the
analytical results. This quality assurance report will include an
assessment of data quality based on the quality control data as
well as an account of any significant quality assurance problems
encountered and corrective actions taken. Because data validation
of the CLP analyses is the responsibility of U.S. EPA Region 5
MQAB, they will issue the quality assurance assessment of the CLP
analytical results to the U.S. EPA WAM and EARTH TECH. Data
validation of SAS analyses will be the ultimate responsibility of
EARTH TECH. A quality assessment of any SAS analytical results
will be issued to the U.S. EPA WAM via a monthly report.

SOURCE: Scanned by COPA for the COPA BBS
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