BROSSMAN SHORT FORM FOR THE TUTU WELL FIELD SITE ST. THOMAS, U.S. VIRGIN ISLANDS Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Waste Programs Enforcement Washington, D.C. 20460 EPA Work Assignment No. EPA Region Site No. Contract No. COM FEDERAL PROGRAMS CORPORATION Document No. Prepared By Work Assignment Project Manager Telephone Number EPA Work Assignment Manager Telephone Number Date Prepared C02048 II 2P1D 68-W9-0002 TESV-C02048-QA-CLFV COM FPC Sally Odland (212) 393-9634 Caroline Kwan (212) 264-0151 April 22, 1992 TUT OO6 O358 *64581* 64581 SOU, OVERSIGHT AND SAMPLING SOIL AND GROUNDWATER INVESTIGATION U.S. EPA CONTRACT NO. 68-W9-0002 BROSSMAN SHORT FORM FOR THE TUTU VELLFIELD SITE ST. THOMAS, U.S. VIRGIN ISLANDS WORK ASSIGNMENT NO: C02048 DOCUMENT NO: TESV-C02048-QA-CLFV Work Assig(fynent Manager Sally Odland TES V Regional 1 lanager Scott, draber Date/ Date TES V QA Director Date EPA Remedial Project Manager Caroline Kwan Date QA Officer EPA Region I Date TUT O06 O359 1. PROJECT: Remedial Investigation of Groundwater and Soil Tutu Uellfield Site U.S. Virgin Islands 2. PROJECT REQUESTED BY: USEPA Region II USEPA Contract No.: 68-W9-0002 Site Number: 2P1D Work Assignment No.: C02048 3. DATE OF REQUEST: April 1992 4. DATE OF PROJECT INITIATION: May 1992 5. EPA WORK ASSIGNMENT MANAGER: Caroline Kwan 6. EPA QUALITY ASSURANCE OFFICER: Laura Scalise 7. PROJECT DESCRIPTION Volatile organic contamination of the drinking water aquifer by petroleum hydrocarbons and chlorinated compounds has been documented at the Tutu Wellfield Site on St. Thomas, U.S. Virgin Islands. Several facilities in the area use and/or store some form of the contaminants of concern. To date, three potentially responsible parties have been identified: Esso Standard Oil SA., Texaco Caribbean, Inc., and L'Henry, Inc., which operates the O'Henry dry cleaning facility. Esso and Texaco have joined together to form the Tutu Environmental Investigation Committee (TEIC). Pursuant to an Administrative Order on Consent issued by EPA, TEIC and L'Henry are initiating a remedial investigation to determine the extent of contamination in groundwater and subsurface soil. COM FEDERAL PROGRAMS CORPORATION (COM FPC) TES V personnel will provide enforcement support for EPA through document evaluation and review, oversight of field activities, and confirmatory sampling and analysis at the Tutu Wellfield site. A. Objective and Scope: COM FPC will provide field investigation oversight and split sample analyses in accordance with established EPA procedures and the Scope of Work incorporated in the Administrative Order. The oversight team will observe and document all procedures to ensure that the TEIC contractor, Geraghty and Miller (G&M), adheres to established Region II protocol and the EPA approved G&M March 1992 Work Plan and site Field Operations Plan. TES V personnel will accept split-samples from the PRP of approximately 202 of their soil and groundwater samples. All split samples will be analyzed through EPA's Contract Laboratory Program (CLP) for the same constituents as the PRP samples. These are: EPA's Target Compound List (TCL) volatile organics plus 1,2-Dibromoethane, n-Propylbenzene, and methyl-tertiary- butyl-ether (MTBE); TCL base neutral acid extractables (BNAs); inorganic target analyte list (TAL) metals and cyanide; and total petroleum -1- TUT 006 0360 hydrocarbons (TPH). CDM FPC will prnviHp .sample containers for split samples and coordinate the packaging and shipping of all samples to the CLP laboratories. B. Data Usage: The CLP split-sample data will be used to confirm the accuracy of the PRP's analytical data. C. Sampling Locations: Based on Geraghty and Miller's March 1992 Work Plan, they will collect a minimum of one subsurface soil sample from each of 30 soil borings, at the site. Seventeen of the borings will be converted to monitoring wells. A map of Geraghty and Miller's proposed boring and well locations is shown in Figure 1. Two rounds of groundwater samples will be collected from the 17 wells. COM FPC will accept splits of six subsurface soil samples, two surface soil samples, two sludge samples and eight groundwater samples. D. Analytical Parameters and Their Rationale: The principal contaminants of concern in site groundwater are petroleum hydrocarbons, including benzene, toluene, ethylbenzene and xylenes (BTEX), and chlorinated volatile organic compounds. Geraghty and Miller will field screen all subsurface soil samples for BTEX, dichloroethylene (DCE), trichloroethylene (TCE) and tetrachloroethylene (PCE) gas using a portable gas chromatograph. Subsurface soil samples selected by Geraghty and Miller for laboratory analysis will be analyzed for TCL volatile organic compounds (VOCs) plus 1,2-Dibromoethane, n-Propylbenzene, and methyl-tertiary-butyl- ether (MBTE) TCL; BNAs; total petroleum hydrocarbons (TPH); and TAL metals and cyanide cyanide. Groundwater samples will be analyzed for the same list of constituents. Per EPA direction, split samples of all matrices accepted by COM FPC will be analyzed for TCL VOCs plus 1,2-Dibromoethane, n-Propylbenzene, and MTBE; TCL BNAs; TAL metals and cyanide; and TPH. Analysis for the TCL compounds will be in accordance with the EPA CLP Statement of Work (SOW) for oranics, document number OLM01.8 (or current revision). TAL analytes will be analyzed in accordance with the EPA CLP SOW for inorganics, document number ILM01.0 (or current revision). E. Analytes: See Table 1. F. QC Sample Analysis: See Table 2. Duplicates Environmental duplicates will not be collected because the samples accepted per this Brossman Short Form are split samples of the PRP samples. -2- TUT OO6 O361 Trip Blanks A. A Trip blank will be prepared by the FPC TES V team at the start of each day on which aqueous samples will be collected for the analysis of TCL volatiles. Trip blanks are used to determine whether on site atmospheric contaminants are seeping into the sample vials, or if any cross-contamination of samples is occurring during shipment or storage of samples containers. A trip blank consists of demonstrated analyte-free water (based on TCL analysis results below Contract Required Detection Limits) sealed in 40 ml septum vials with no headspace (including bubbles) in the vials. Trip blanks will be kept in close proximity to the samples being collected and maintained at a temperature of 4 degrees celcius. One trip blank will be included with each daily shipment to CLP laboratories that contains aqueous samples collected for TCL volatile organic analysis. Trip blanks will be analyzed for volatile organic compounds only. Control of all trip blanks related to split samples will be the responsibility of the FPC TES V field personnel. Certification of blank water quality received in the field will be kept on site and/or will be requested from the supplier and will be filed in the FPC TES V project files once field work is completed. Further definition of what constitutes "demonstrated analyte-free water" may be found in the EPA Region II CERCLA Quality Assurance Manual, Revision 1 (October 1989), Section 10-A.2 (pages 59-60). Field Blanks COM FPC will accept splits of Geraghty and Miller's field blank samples. One field blank will be accepted for each equipment type and will be analyzed for the same constituents as the environmental sample splits. Field blanks, also known as "rinsate blanks" or "equipment blanks" are used to assess the effectiveness of equipment decontamination. Field blanks will be collected prior to use of the decontaminated equipment for sampling. The frequency for field blanks is one per "decon" event, not to exceed one per day, for each equipment type and for each sample matrix. Field blanks are generated by pouring demonstrated analyte-free water over the decontaminated sampling piece of equipment. Field blanks will be collected in a manner that will minimize potential contamination from the ambient air. It is permissible to use the same aliquot of water on all equipment associated with a particular sample matrix for analysis of semi-volatile organics, and inorganic analytes. However, a separate field rinse blank must be collected for each piece of equipment associated with a particular sample media that will be analyzed for volatile organic compounds. Matrix Spike/Matrix Spike Duplicates Matrix spike samples are collected to demonstrate the precision of laboratory analysis. It should be noted that ground water and surface water constitute two distinct matrices. An aqueous matrix spike sample requires the collection of a triple volume in order to perform matrix spike and matrix spike duplicate (MS/MSD) analysis for organics. -3- TUT OO6 O362 According to EPA's Region II CERCLA QA Manual, a minimum of one matrix spike sample per matrix must be submitted to the laboratory for every sample delivery group (SDG). An SDG is defined as one of the following: 1. All samples of a RAS or SAS case if the sample number is less than 20 (including environmental duplicates, but excluding QC blanks) and if sampling is completed in less than 14 calendar days. 2. Each group of 20 samples within a RAS or SAS case (including environmental duplicates, but excluding QC blank) if the number is greater than 20. 3. Each 14 calendar day period within a RAS case if the number of samples collected is less than 20. Each 7 calendar day period within a SAS case if the number of samples collected is less than 20. 8. SCHEDULE OF TASKS AND PRODUCTS: The field work associated with the sampling activities is tentatively projected to begin the week of May 26, 1992 and is estimated to take approximately 18 weeks. 9. PROJECT ORGANIZATION: The following is a list of key project personnel and their corresponding responsibili ties: Sampling Operations Sampling QC Laboratory Analysis Laboratory QC Data Processing Activities Data Processing QC Data Quality Review Internal Systems Audit Technical Systems Audit Overall QA Health & Safety Coordinator Overall Project Coordination Andrew Scano Pam Phillip Contract Laboratory Program Contract Laboratory Program Andrew Scano Jeniffer Oxford TES V data validation staff Susan Flakus Susan Flakus Rosemary Ellersick Jeanne Li twin Sally Odland 10. DATA QUALITY REQUIREMENTS AND ASSESSMENTS: Data quality will be assessed in terms of accuracy, precision, sensitivity, representativeness, comparability and completeness within each data set and comparison of the split sample data with the PRP's data. The accuracy and precision requirements for the Target Compound List (TCL) to be performed through Routine Analytical Services (RAS) and Special Analytical Services (SAS) and Target Analyte List analyses to be performed through RAS are specified in the EPA CLP Statement of Work for Organics (SOW OLM01.8, or current version) and the EPA CLP Statement of Work for -4- TUT O06 0363 Inorganics (SOU OT.M01.0, or rnrrent version). In aHHiHnn to the for volatile organic parameters on the TCL list, analysis will be performed for n-Propylbenzene, 1,2-Dichloroethane, and HTBE. The method will be SOW OLM01.8, or current version. Historical precision and accuracy requirements will be observed for TPH analyses, to be performed through Special Analytical Services (SAS) by the CLP as specified in method 418.1 for TPH. Sensitivities required for the CLP analysis of QA samples will be method detection limits from the same cited Statements of Work and the SAS request for TPH. A. Data Representativeness: Representativeness expresses the degree to which the sample portrays the population characteristics of process/environmental conditions at a given location and point in time. Samples from the six soil borings and four monitoring wells (two rounds of sampling yeilding 8 groundwater samples) shown in Figure 1 will be split between Geraghty and Miller and the TES V sampling team, or will be collected by G&M and accepted by the TES V sampling team. The samples will be split by equally dividing the contents into two sets of sample containers. Samples will then be sent to different laboratories for analysis. B. Data Comparability: All data will be presented in the units specified in the Contract Laboratory Program's Information For Bidders (IFBs). Split sample data will be compared to the results reported by Geraghty and Miller. 11. SAMPLING PROCEDURES: Prior to sampling, and between sampling points, all field equipment will be decontaminated by the PRP using the following EPA approved method: o Wash and scrub with low phosphate detergent o Potable water rinse^ o Rinse with 10% HN03 (1% for carbon steel implements) o Potable water rinse* o Methanol rinse* o Hexane rinse* o Thorough Deionized demonstrated analyte free water rinse (at least five times the volume of solvent used) o Air dry o Wrap in aluminum foil * Acid will be Ultrapure grade; solvent will be pesticide grade or better. + Tap water from any municipal water treatment system may be used. The use of untreatedpotable water supply is not acceptable. During the sampling activity, the TES V team will note the following in the -5- TUT OO6 0364 field logbook: o Date, time and weather o Field personnel/affiliations o Level of personal protective clothing/gear o Schedule for the day o Sample container and demonstrated analyte-free water shipment lot numbers (as received in the field) o Sample description, depth and location (from two reference points) o Any unusual discoloration or evidence of contamination o Field parameter measurements (such as temp. pH, and specific cond.) o Calculations o Sample identification number used by the contractor for their sample and by the TES team for the split sample. o CLP RAS or SAS sample number o Overnight courier airbill number o Decontamination procedures for the equipment o Equipment used (record ID numbers) and calibration information o Any preservation requirements o Deviations from the PRP's approved field operations plan, this Brossman or other problems o Descriptions of any photographs taken o Notes of conversations with project coordinators A. Subsurface Soil Sampling 1. Geraghty and Miller will collect subsurface soil samples during soil boring installation in accordance with their March 1992 Work Plan and Field Operations Plan. 2. Split samples for VGA, and TPH soil aliquots will consist of co-located grab samples. 3. Soil samples for all remaining analyses will be homogenized in a stainless steel bowl before filling the containers. 4. All soil samples and splits samples will be carefully logged, packed in coolers, and sealed for shipment according to the procedures described in section 12. B. Groundwater Sampling 1. After well development, Geraghty and Miller will collect groundwater samples from newly installed monitoring wells in accordance with their approved March 1992 Work Plan and Field Operations Plan. 2. Split samples for VOAs plus 1,2-Dibromoethane, n-Propylbenzene, and MTBE; BNAs; metals plus cyanide; and TPH will be provided by the alternate filling of Geraghty and Miller and COM FPC sample bottles such that representative samples are collected. VOA bottles will be filled first, followed, BNAs, TPH and metals plus cyanide. 3. The pH of the VOA sample aliquots will be adjusted to <2 by the dropwise addition of 1:1 HC1 to the VOA vials prior to sample -6- TUT O06 O3S5 collection. The amount of preservative required at ea^h well w i l l he determined by adding HC1 to a separate aliquot of equal volume and testing with pH paper. All vials will be checked to ensure zero headspace. 4. The pH of the TPH samples will be adjusted to <2 by adding 1:1 HC1. The HCl will be added a small amount at a time, mixed into the sample by tipping, and tested with pH paper. 5. The pH of the metals sample aliquot will be adjusted to <2 by adding HNO^. The HNO., will be added a small amount at a time, mixed into t sample by tipping the bottle, and tested with pH paper. 6. The pH of the cyanide sample aliquot will be adjusted to >12 by adding NAOH. The NAOH will be added a small amount at a time, mixed into the sample by tipping the bottle, and tested with pH paper. 7. All samples and split samples will be carefully logged, packed in coolers and sealed for shipment according to the procedures described in Section 12. 12. SAMPLE CUSTODY PROCEDURES: A. Traffic Reports: A CLP Sample Traffic Report is a four page carbonless form. A preprinted identification number will be assigned in the field by the TES V team for each sample collected. The preprinted identification number will be affixed by the TES V team to each container of the sample. An organic traffic report (Figure 2) will be completed for samples receiving organic analyses (VGA and BNA analysis). An inorganic traffic report (Figure 3) will be completed for samples receiving inorganic analyses (metals). A SAS Packing List (Figure A) will be completed for all SAS samples (TPH and MTBE analysis). The information that must be completed on the traffic reports is detailed in the User's Guide to the Contract Laboratory Program, January, 1991. B. Chain of Custody Record: To maintain a record of sample collection and transfer for every sample processed, a "Chain-of-Custody" will be completed for each cooler shipment. In Region II, the EPA Environmental Services Division form should be used. Figure 5 is an example of this chain-of-custody record which must be secured to the inside of the shipping cooler along with the CLP traffic reports (for samples submitted for RAS analyses). A copy of the custody record is retained for the FPC TES V files. Shipping coolers will be secured with nylon fiber strapping tape or its equivalent and custody seals (see Figure 6) will be placed across cooler openings so that the cooler may not be opened without breaking either seal. A mailing label addressed to the laboratory will also be attached to the cooler and protected by clear tape as back-up to the courier airbill so that coolers may not need to be opened by courier staff in the event that the airbill is separated from the cooler. -7- TLJT O06 0366 The PRP contractor will be required to sign COM FPC's custody form as the sample collector. Each time the samples are transferred to another person, signatures of the persons relinquishing and receiving them, as well as the time and date of transfer will be completed in the appropriate spaces on the chain-of-custody record. The PRP contractor will relinquish the sample to the TES V sampler (FPC) who will be the second sampler. Samples will be shipped from the field directly to the laboratories designated to perform the analyses via Federal Express or an equivalent overnight courier. Samples will be sent to the laboratory from the field within 24 hours of sample collection. All courier receipts and/or paperwork associated with shipment of the samples will serve as a custody record for the samples while they are in transit from the field to the laboratory. Custody seals should remain intact during this transfer. When the samples are delivered to the laboratory, signatures of the labortory personnel receiving them and courier personnel relinquishing them will be completed in the appropriate spaces on the chain-of-custody record. This will complete sample transfer. It will be the CLP laboratory's responsibility to maintain internal log books and records that provide a custody record throughout sample preparation and analysis. To track field samples through data handling, FPC will maintain photocopies of all traffic reports, SAS packing lists and chain-of-custody records. When responsible for sample custody, field personnel should keep in mind the definition of sample custody according to the EPA Office of Enforcement and Compliance Monitoring National Enforcement Investigations Center (NEIC) Policies and Procedures (May 1986) that states that a sample is under custody if: 1. it is in one's possession, or 2. it is in one's view, after being in one's possession, or 3. it is locked up after being in one's possession, or 4. it is in a designated secure area. C. Sample Labels and Tags: One numbered adhesive RAS label from the strip (Figure 4) or a hand written label for SAS samples (and the additional MS/MSD bottles filled for aqueous RAS organic extractables) is affixed to each container making up the sample. To protect the label from water and solvent damage, each label is covered with clear waterproof tape. For samples requiring decontamination, the self-adhesive sample labels must be completely covered with clear mylar tape prior to sampling. The sample labels permanently identify each sample collected and link each sample component throughout the analytical process. In addition to the preprinted sample identification number, each split sample container for CLP analysis will be identified with a sample tag -8- TUT OO6 O367 (Figure 6). These sample taps are retained by the CI.P laboratories as physical evidence of sample receipt and must therefore be signed by the sampler, which in the case of split samples is the TES V oversight contractor (FPC) sampler accepting the split sample. The sample tag will contain an abbreviated summary of the field logbook entry for the sample. The information that must be entered on the sample tag is detailed in the CLP User's Guide and listed below. o Site spill number (do not provide the site name or address) o CLP case number or SAS number o RAS of SAS sample number o Date and time of collection o Station number/location o Sampler signature o Sample type (composite or grab) o Sample matrix o Preservative added and type o Type of analysis required. D. Field Notebooks: A final element in the documentation process will be the completion of a formal field notebook by TES V personnel. The field notebooks will be maintained by the TES V team and will be stored in the TES V document control systems. All entries will be made in accordance with the TES V requirements for maintaining field notebooks as detailed in the Camp Dresser and McKee Inc. Site Investigation Procedures Manual, SOP #5621004. A copy of this SOP will be available on-site. The information that will be recorded in the field notebooks for each sample collected by the Contractor is described in Section 12, Sampling Procedures. E. Sample Bottles: COM FPC will purchase pre-cleaned sample containers which meet EPA specifications. These bottles are pre-cleaned in accordance with OSWER Directive number 9240.0-05 and QC tested according to prescribed procedures to ensure that no contamination exists that might affect sample data. QC screening procedures include container cleaning by lot group; each lot group is assigned a unique identifying number, which is permanently affixed to each container. Prior to shipment, one percent of the containers per lot are QC checked, by performing analyses specific for the container type. In addition to the QC analysis check, an additional bottle is removed from each lot and stored for QC purposes. Clean, empty bottles are shipped to users in protective cardboard cartons. F. Sample Handling, Packaging, and Shipping: When sent by common carrier, the packaging, labeling and shipping of hazardous wastes and substances is regulated by the U.S. Department of Transportation (DOT) under CFR 49. Samples obtained at uncontrolled hazardous waste sites are classified according to pollutant concentration. "Low Level" samples are generally dilute and are usually collected from areas surrounding a spill or dump site (i.e., offsite samples from soils, -9- TUT OO6 0368 rivers, lakes, etc.)- "Medium I.PVP!" ^amplps are ppnprallv on-site, in areas of moderate dilution by normal environmental processes. It is anticipated that contaminant concentrations in all samples collected from the Tutu site will range between low level and medium level. All samples will be packaged and shipped according to the following procedures detailed in the User's Guide to the Contract Laboratory Program, January, 1991. Samples will be kept on ice to maintain a temperature of 4 degrees C. The samples will be shipped within 24 hours of collection via an overnight carrier. Each sample label will be covered with clear waterproof tape to protect it from water and solvent attack. A custody seal (Figure 6) is to be placed over the lid of all sample bottles and also the shipping cooler, before shipping it to the laboratory. This will ensure that the samples are not opened prior to their arrival at the laboratory. G. Sample Shipment Coordination: To enable the Sample Management Office (SMO) to track the shipment of samples from the field to the laboratory and ensure timely laboratory receipt of samples, the TES V team will notify the SMO (phone number: (703) 684-5678) immediately following all sample shipments, and provide the following information: o Sampler name and phone number o Case number and RAS or SAS number o Site name/code o Exact number(s) and matrix(ces) and concentrations of samples shipped o batch numbers (dioxin only) o Laboratory(ies) samples were shipped to o Carrier and airbill number(s) for the shipment o Method (e.g., overnight, two-day) o Date of shipment o Any irregularities or anticipated problems with the samples, including special handling instructions, or deviations from established sampling procedures. o Suspected hazards associated with the samples or site, o Status of the sampling project (e.g., final shipment, update of future shipping schedule.) H. Sample Trip Reports: A sample trip report is required to be completed for each case number and must contain all the information as shown below. All blanks and duplicates must be clearly indicated. o Site number o Sampling date o EPA case number and RAS or SAS number o Site location/name o Sample description -10- TUT OO6 O369 o Names, addresses of lalioratories receiving samples and sample types going to those laboratories. o Sample dispatch data (e.g., Federal Express airbill number(s)) o Names, organization, affiliation and duties of onsite sampling personnel o Additional comments (samples types, totals, blanks, etc.; o Name of preparer and date of eport o Approval signature and date This trip report will be sent directly to the Regional Sample Control Center (RSCC) with a copy to the TES V CLP coordinator. 13. CALIBRATION PROCEDURES AND PREVENTATIVE MAINTENANCE: A. Field Equipment: Each piece of TES V equipment used for measuring, monitoring, analytical purposes is calibrated and maintained periodically to ensure accuracy within specified limits. Calibration and maintenance procedures and the frequency at which these procedures should be applied are detailed in the COM FPC Field Equipment Operation, Maintenance, and Calibration Manual(FEOMC Manual). A copy of this SOP will be onsite. TES V field equipment undergoes calibration and maintenance by qualified personnel before and after every field activity. If an instrument is to be in the field for longer than four weeks, it is returned to the Region II equipment room to undergo full calibration and maintenance. Where applicable, instrument calibration is field checked. The following equipment will be used by the TES V team at the Tutu site: Instrument SOP Reference HNu Photoionization Detector (PID) FEOMC Manual, Section 1.0 A field equipment status report is kept for each piece of field equipment and kept in a Region II Log Book. The Log Book is stored at the COM FPC Regional office. These reports contain the following information: o Date of calibration and date of last maintenance o Initials of person performing the calibration and/or maintenance o Accuracy prior to and following calibration and/or maintenance o Notations on equipment failures B. Laboratory Equipment: Calibration procedures and preventative maintenance for laboratory equipment is the responsibility of the Contract Laboratory Program (CLP) lab selected to analyze the samples. 14. DOCUMENTATION, DATA REDUCTION, AND REPORTING: A. Documentation: -11- TUT OO6 O370 Each sample submitted for analysis will be properly documented to ensure timely, correct, and complete analysis for all parameters requested and to support the use of analytical data in potential enforcement actions. The following documentation will be submitted: o Organic and inorganic sample traffic reports o Chain of Custody Records o Field notebooks o Sampling labels o SAS packing list (where appropriate) B. Data Reduction and Reporting The CLP will be responsible for preparing the analytical data packages for organic analysis and providing this information to the SMO. SMO will then send the package to the RSCC for data validation. Data reduction will consist of summarizing the data collected during the field work. The data will be used to prepare a report summarizing the analytical results and notes taken during the field work. 15. DATA VALIDATION: Analytical data will be validated by the TES V team by the following EPA Region II standard operating procedures: 1. SOP Number HW-2: Inorganic Data Validation, Revision 11, January 1992. 2. SOP Number HW-6: Organic Data Validation, Revision 8, January 1992. 16. SYSTEM AUDIT: A technical system audit may be conducted by the COM FPC QA staff. If so, it will be documented in a report discussing any observed deficiencies for each phase of work. If needed, a Corrective Action Request will be completed and sent with the audit report. Upon receipt of a satisfactory response, an Audit Completion Notice will be issued. If no deficiencies are noted, the Audit Completion Notice will be sent with the original audit report. Reports are sent to the audit file with copies to the audited entity, COM FPC management and EPA. Laboratory performance audits are the responsibility of the contract laboratory program and EPA. Internal system audits may be conducted by COM FPC QA staff during the course of the work assignment. They will be scheduled and reported as described under performance audits. System audits may also be performed by EPA. 17. CORRECTIVE ACTION: -12- TUT OO6 O371 If a nnnrnnf ormance or rirfi ri pnry is iHontifi^d Hnrinp a syst-pms a u d i t , corrective action will be initiated by the TES V team and its subcontractors. The TES V Quality Assurance Director will be responsible for filing a report of the audit along with a Corrective Action Request Form if any nonconformances were noted during the audit. The TES V Quality Assurance Director will also be responsible for ensuring that corrective action is taken and will forward the report to the TES V Regional Manager and the Site Manager. All Corrective Action Request Forms will be maintained by the TES V team for all non-laboratory related deficiencies. The TES V team will be responsible for reporting all suspected technical nonconformances by initiating a Corrective Action Request Form. Any staff member who discovers or suspects a nonconformance in an approved document shall inform the Site Manager, who is responsible for determining if a corrective action is required. The Site Manager shall ensure that no additional work, which is dependent on the nonconforming activity, is performed until the nonconformance report is corrected. 18. REPORTS: The EPA will be provided with all the data gathered during this field activity. During field activities, COM FPC will provide weekly written or verbal reports to EPA detailing PRP activities and any observed discrepancies from the approved sampling plans. An overall field summary report will be provided to EPA at the end of each period of field work. Laboratory results from split samples will be evaluated and presented to EPA in the form of a Letter Report, detailing QA/QC measures taken during sampling/field activities. Any report containing measurements will contain a AQ section which includes data quality objectives and parameters, the results of any audits peformed by the FPC TES V QA staff and/or EPA, and any deviations from the EPA approved guidance documents (such as this Brossman Short Form). -13- TUT O06 O37\ TATU.F. 1 Page 1 of 2 PARAMETER TABLE FOR TES V SPLIT SAMPLES SUBSURFACE SOIL INVESTIGATION TUTU WELLFIELD SITE ST. THOMAS, U.S. VIRGIN ISLANDS ANALYSIS EST'D MATRIX ANALYTICAL NO OF METHOD SAMPLES* VOCs*** 6 soil Ref. 1 BNAs 6 soil Ref. 1 Metals 6 soil Ref. 2 TPH 6 soil 418.1(3) HOLDING TIME PRESERVATIVE VTSR ** Cool to 4°C 10 days Cool to 4oC 10 days to extraction 40 days to analysis Cool to 4oC 6 months Hg-26 days Cool to 4oC **** 26-days SAMPLE CONTAINER 2X40-ml wide-mouth glass vials IxSoz wide-mouth glass jars IXSoz glass jars IxSoz wide-mouth glass jar * - Based on splitting 20% of the PRP samples ** - From verified time of sample receipt *** - TCL plus MTBE, n-Propylbenzene, and 1,2-Dichloroethane **** _ The extraction of soil for TPH analysis is to be performed according to EPA/Army Corps of Engineers approved Oil and Grease Procedure for Sediment Samples given in Attachment I. After extraction proceed to Step 7.6 in Method 418.1 for TPH analysis -14- TIJT 006 0373 TAm.F. 1 Page 2 of 2 PARAMETER TABLE FOR TES V SPLIT SAMPLES GROUNDWATER INVESTIGATION TUTU UELLFIELD SITE ST. THOMAS, U.S. VIRGIN ISLANDS ANALYSIS ESTIMATED MATRIX NO. OF SAMPLES* VOCs *** 8 aqueous BNAs 8 aqueous ANALYTICAL PRESERVATION METHOD HOLDING TIMES VTSR ** Ref. 1 Cool to 4oC 1:1 HCL to pH<2 (a) 10 days Ref. 1 Cool to 4oC 5 days to extraction 40 days to analysis SAMPLE CONTAINERS 2x40ml glass vials 4Xl-liter amber jars Metals aqueous Ref. 2 Cyanide TPH aqueous aqueous Ref. 2 418.1(3) Cool to 4oC HN03 to pH<2 6 months Hg - 26 days NaOH to pH>12 12 days Cool to 4oC 1:1 H2S04 to pH<2 26 days IXl-liter poly bottle 1X1 -liter poly bottle Ixl-liter amber jars * - Based on splitting 20% of the PRP samples ** - From verified time of sample receipt ***- TCL plus MTBE, n-Propylhenzene, and 1,2-Dichloroethane (a) If sample acidification causes effervescence, the sample will not be acidified but will be cooled to approximately 4 C. In this event, the holding time is 7 days from the time of sampling. -15- TUT 006 0374 Table 1, rnnt. References 1. "Statement of Work for Organic Analysis, Multi-Concentration." USEPA Contract Laboratory Program, OLM01.8 (or current revision). 2. "Statement of Work for Inorganic Analysis, Multi-Concentration." USEPA Contract Laboratory Program, ILM01.0 (or current revision). 3. Methods for Chemical Analysis of Water and Wastes: EPA-600/4-79-020, revised March, 1983. -16- TUT 006 TARJ.F 7 QA/QC SAMPLE SUMMARY TABLE SOIL AND GROUNDWATER INVESTIGATIONS TUTU WELLFIELD, ST. THOMAS, U.S. VIRGIN ISLANDS Sample Type Matrix Parameter Invest!- Matrix Field Trip Total gative spike blank blank Aqueous VOAs *** 8 2** 4 4 18 Aqueous Extractables 8 2 * * 4 - 1 4 (BNAs) Aqueous Inorganics 8 2 4 - 1 4 (Metals + Cyanide) Aqueous TPH 8 2+ 4 14 Soil VOAs * * * 6 * 6 - 1 2 Soil Extractables 6 * 6 1 2 Soil Inorganics 6 * 6 - 1 2 (Metals and Cyanide) Soil T P H 6 * 6 1 2 1) Based on accepting splits of 20% of the PRP's samples. 2) Assumes two groundwater sampling events with split samples accepted on 2 days for each event. For soils, assumes a field blank will be accepted each day a soil split sample is accepted, with one subsurface boring split samples accepted on 6 separate days. * The lab will analyze a matrix spike and matrix spike duplicate from existing soil or sediment sample volume. ** Triple volume must be collected (volume includes investigative sample). *** TCL VOCs plus MTBE, n-Propylbenzene, and 1,2-Dibromoethane. Because the entire sample is consumed in analysis, a laboratory duplicate will be collected for every sample delivery group for aqueous TPH analyses and labeled as a lab duplicate. -17- TUT 006 O376 D« riATt 06AP092 I MX* NO. PHOI30' ] 1l£ NO - APOROVCO OANAH* \ SON. •OHNC SNAU.OW UOMTOKMC WCU. KtPEK i*>n tan w Cooeerv IreMon t«to» M-med SMeSpNlO 05 Scmplw (N*m«| SvmpkngCo Joan Sampler 1 Slvp to /Ano///ica/ Lab 100 tenter Avc Anyfottfn, CA W548 AHn A.Mcfol RASAneryrii Cyvnkto (0) Special K~ MS/dup 4 DM* Shipped //-v-ea AJrWi Number 09076S&2J Ceiilec Fed Ex Oouble volume lequlred tor melrhi •prke'dupkcMe equeou* umple Ship medium end high concentration umplef In ptlnt can*. See reverie tor addHlonal tnetrudlon* SlMlon LocMton LOG-/ LOC-2 LOC-3 M?C-V IOC-5 LOC-& IOC-9 LOC-IO LOC-IL LOL-12 Detemmeof Sempto CoCectfon //-V/QftOO /A?7 yjoafi oo JM& JA332. tMOC.vr CeeeMomU 1010 1 IA9Mo(ll«ppHc.bi») & Sample Deacrlpflon (Enter In Column A} 1. Surtec* Wrier 2. Ground Water 3. Loachale) 5. So«/S«rJm*n» 6. OM(SAS) 7. Waata(SAS) 8. Olhef (SAS) (Specify) Organic Sampta Number J/L521 JA325 JA329 OM33I WM*-U*<>w»vMMvni.i . L* Copy FIGURE ;- ««.S. ENVIRONMENTAL PROTECTION AGENCY f'.LP Sample Management Office P.O. Boi»IS - Alexandria, Virginia 22313 703/557-2490 - FTS/«7-2«»0 SAS Number tOOp- A 13. 16. 17. IX. 19. 20. SPECIAL ANALYTICAL SERVICE PACKING LIST Sampling Office: 'plfChp/l T. J Sampling Contact: JjpL Sn/*0itV (name) lJ5^-l*i4 (phone) 1. 2. 3. *. 5. 6. 7. I. 9. 10. 11. 12. 13. Sampling C il)>\- «» DateShipf tlU — unt - —— )ateed: tf Site Name/Code: •*OI Sample Samp Numbers Le, Analysis, I COO A - o l LDvV fDrV. . WdA IOOOA • 05\ looc A • oi IDCCA -ovt- 100O4 - o«C IOOOA • OL. Ship To: For Lab Use Only SAS LA6 100 Moi * Skta Dmte ^P'*1 Rec • M H •* For Lab Use Only White • SMO Copy, Yellow - Region Copy, Pink - Lab Copy (or return to SMO, Cold - Lab Copy TUT OO6 O38O CHAIN OF CUMOUT INVItOMMIMTAl MOTtCTOM AOIMCY - UOION • Environmental Services Division iOltON. NIW JIUIT 0«*17 •*•»• *i U«it • *« A44'«IK \ **•••' *•••'• .1 M.Bk.r |e. «..», FIGURE TUT QO6 O3S1 U-JMI i-aoti ucn io£ Preservative: Yes D No C Type———————— ANALYSIS voutii* Orotnict Orgintct-BNAt PesticiMs/PCBs c ci o "a E w a. 0 ** «.. • s Ui« 1 M | a 8^ Mttait i Cyamat 2.3.7.&-TCDD Rtmarns: : O IZI UI ,» TUT O06 O382 COM FEDERAL PROGRAMS CORPORATION Figure 6 Sample Tag/Custody Seal Attachment I EPA/Army Corps of Engineers Oil and Grease Procedure for Sediment Samples TUT 006 O383 Procedure for Sediment Samples (Sir) The procedure for determination of oil and grease in sedi- ment samples is similar to that used to quantify oil and grease in •water sar.tles. The sa.~ple is extracted vith Freer, and the extractacle- material is quantified. As indicated in Figure 3-39. a moist sedimer.t sample must be used as a dried sample vill yield lov results. Because of the operational definition of the oil and grease procedure and the lack of precision associated with the test, it is recommended that con- ditions of sampling, sample pretreatment , and analysis be standardized tc ensure co-par ability of the final data.3 Method 1: Freon Extraction1 pparatus Extraction apparatus, Soxhlet Vacuum pump or other source of vacuum Extraction thimble, paper Ir.frarei spectrcphctorr.eter or balance Peager.ts Either cor.c. hydrochloric acii, KC1, or cone, sulfuric acid, H:5 Magnesium sulfate monohydrate: prepare MgSOu • KaO by drying a thin • 7H20 overnieht in an oven at 10?°C. Freer. ( 1,1 , 2-trichloro- 1,2,2-trifiuoroethar.e) , boiling point 17°C. The solvent should leave no measurable residue on evaporation. Eedi-- still if necessary. Grease-free cotton: extract nonabsorbent cotton vith Freon. :Ir.:vr oil reference standard: accurately veigh about 0.05 g of known oil directly into a 100-ml volumetric flask. Add 80 ml Freon and dissolve the oil. If, as in the case of a heavy fuel oil, all the oil does not go into solution, let stand overnight. Filter through a Whatman No. *>0 filter paper into a second 100-ml volu- metric "flask and dilute to volume vith Freon. UrJrnowr. oil reference standard (10 ul = 7.-? ^£ oil): pipet 15 mi n-hexadecane, 15 ml isooctane, and 10 ml benzene into a 50-ml glass-stoppered bottle. Assume the specific gravity of this mixture to be 0.769 and maintain the integrity of the mixture by keeping the bottle stoppered except vhen withdrawing aliquots. Veigh a 20.0-r sar.ple of ncist sediment (SID) in a 15C-ml 3-231 TUT OO6 0384 beaker. (The solids content of the sample should be known in advance cr" determined on a separate sample aliquot.) Acidify the sample with ccr.r. sulfuric cr cone, hydrochloric acid to pK 2. Add 25 g MgSOu ' H2C to the acidified sediment sample. Stir tc make a uniformly smooth paste that is spread on the beaker vail. Allcv tc stand 15 to 3C min until solidified. Remove the solids and grind in a porcelain mortar. The use of a desiccated, uniformly ground sar.ple improves the efficiency of the extraction process. Add the ground sample to a paper extraction thimble. The beaker and mortar should be wiped with a small piece of filter paper that has been soaked in Freon. Add the filter paper to the paper thimble, "ill '.':.•= thi:.'."-le vith glass vool or small glass beads. Extract the pre- pared sample vith Freon in a Soxhlet apparatus at a rate of 20 cycles/hr for - hr. If the final extract is turbid, filter the sample through grease-free cotton into a clean flask. Rinse the initial sample con- tainer and the cotton vith Freon and add the washing tc the filtered sar.ple. Determine the oil and grease concentration of the extract by either infrared spectrophotometry (a_) or gravimetry (b_). The infrared method would be preferred because it is generally more precise; partir- ularl" at low oil and grease concentrations. _a. Infrared spectrophotometry. ' Quantitatively transfer the sediment extract tc a convenient size volumetric flask and dilute to volume vith Freon. Prepare calibration standards using either the known oil reference standard or the unknown oil reference standard. (A knovn oil is defined as the only grease and/or oil component in the samples being analyzed. An unknown oil is defined as the grease and/or oil component1'sN in the sample being analyzed for which standard prepara- tions are not available.) Transfer required amount? of the appropriate reference material into 100-r.l volu- metric flasks using microliter pipettes. Dilute to volume with Freon. The most appropriate pathlength for the quartz cells tc be used in the spectrophotcmetric determination is determined by the expected sample concentration. The following information is presented as a guide for selecting cell length: 3-285 TUT OO6 0385 Pathlength, en Expected Range, mg 1 u - kO 5 0 . 5 - 8 10 0.1 - 1* Based on observed ranges of oil and grease in seii-er.ts , it nay be necessary to dilute the sample extracts to the working ranges indicated above. Scan the standards and samples from 3200 to 2700 cm"1 using a recording infrared spectrophotometer. Freon should be used in the reference beam of a dual beam instrument or to zero a single beam instrument. The absorbance of the 2930-cm"1 peak should be used to con- struct a standard curve. Gravimetry.* The gravimetric determination of oil and grease does not require dilution of the samples. However, the procedure is considered less precise than the infra- red determination because the method is subject to posi- tive sulfur interference and greater uncertainty at lew oil and grease concentrations. To implement the method, quantitatively transfer the sediment extract to a tared distilling flask. Rinse the extract container with Freon and add to the distilling flask. Distill the Freon from the extraction flasks using a water bath at 70°C. After the solvent has beer, evaporated, place the flask on a warm stear. bath for 15 min and draw air through the flask by means of an applied vacuum for the final 1 min. Cool in a desiccator for 30 min and weigh. The gain in weight is due to cil and grease if the solvent is free of residue. ~2._cu_ations Select the appropriate method ar.d calculate the oil and grease concentration based on the method of quantification that was used. a_. Infrared spectrophotometry. When colorimetry is used, prepare a standard curve by plotting measured absorbance vs. oil and grease concentration of the standards. Compare the absorbance of the Frecn extract to the standard curve to determine the oil and grease concen- tration. Calculate the oil and grease concentration 0 + G of the original water sample as follows: « /, t * • v*\ (xHvHiooo) 0 + G mg/kg (wet weight) = ————jt———— sensitive paper 10 the cap to insure that the pH is 2 or lower. Add more acid if necessary. 7.2 Pour the sample into a sepantory funnel . . . 7J Add 30 ml fluorocarbon-l 13 (6.2) to the sample bottle and rotate the bottle to rinse the sides. Transfer the solvent into the separatory funnel Extract by shaking vigorously for 2 minutes. Allow the layers to separate. 7.4 Filter the solvent layer through a funnel containing soIvenMnoistened filter paper into a 100 ml volumetric flask. NOTE I: An emulsion that fails to dissipate can be broken by pouring about 1 g sodium sulfate (6 J) into the filter paper cone and slowly draining the cmuisioa through the sab. Additional I g portions can be added to the cone as required. 7.5 Repeat (7 J and 7.4) twice more with 30 ml portions of fresh solvent, combining all solvent into the volumetric flasav 7.6 Rinse the tip of the separatory funnel, filter paper, and the funad with • total of 5-10 ml sohrearaadcotleerthe rinisagi in thrihafcPuutethe extractio 100 mt Iftheeatncrst- *iin trttttrthin H*? mjjf mm hjfitr appiopiiauponka of the sampk ton 100 ml volunMUic and dfluieio volume. 7.7 Discartaboat 5-10 ml sotatk» front tkevotenxtrk flasavAdd3gsificagct(M)afMis»r stirring bar; stopper the volumetric flask, and stir the solution for aaatnaoumofSminoer TUT OO6 039O 7.1 Select appropriate working standards and cell pathlenfth according to the following table of approximate working ranges: fUayt Calibrate the instrument for the appropriate ceUs osing a aerie* of working standards. (6JJ). It is not necessary to add silica gel to the standards. Determine abaorbance directly for each solution at the absorbance maximum at about 29)0 cm*'. Prepare a calibration plot of absorbance vs. mg petroleum hydrocarbon* per 100 ml solution. 7.9 AAer the silica gel has settled in the sample extract, fill a clean cell with solution and determine the absorbance of the extract. If the absorbance exceeds 0.1 prepare an appropriate dilution. NOTE 2: The possibility that the absorptive capacity of the silica gel has been exceeded can be tested at this point by adding another 3.0 g silica gel to the extract and repeating the treatment and determination. 7.10 Determine the concentration of petroleum hydrocarbons in the extract by comparing the response against the calibration plot. Calculations 1.1 Calculate the petroleum hydrocarbons in the sample using the formula: rag/1 Petroleum Hydrocarbons • u .10V D-< " V • irtunwrfsaiBpk, fitter*. f.l Prertdonartdaccaracydataareneiavanabkatthisi TUT OO6 O391