99006-k slridt rd appendix b 092905 - barr engineering rap 092905/slridt rd... · i 99006-k slridt...

99006-K SLRIDT RD Appendix B 092905.doc i

TABLE OF CONTENTS 1.0 INTRODUCTION .............................................................................................................. 1

1.1 Distribution List ......................................................................................................... 2 1.2 Project Organization .................................................................................................. 3 1.3 Problem Definition/Background Information............................................................ 5 1.4 Project/Task Description and Schedule ................................................................... 10 1.5 Quality Objectives and Criteria for Measurement Data .......................................... 11

1.5.1 Specifying Quality Objectives ..................................................................... 11 1.5.1.1 State the Problem .......................................................................... 11 1.5.1.2 Identify the Decision..................................................................... 12 1.5.1.3 Identify Inputs to the Decision...................................................... 13 1.5.1.4 Define the Study Boundaries ........................................................ 18 1.5.1.5 Develop a Decision Rule .............................................................. 18 1.5.1.6 Specify Limits on Decision Errors................................................ 19 1.5.1.7 Optimize the Design for Obtaining Data. ..................................... 19

1.6 Special Training Requirements/Certification .......................................................... 19 1.7 Documentation and Records .................................................................................... 20

2.0 MONITORING/SAMPLING PROGRAM SPECIFICS .................................................. 21 2.1 Sampling Process Design......................................................................................... 21

2.1.1 Existing Data Used in the Remedial Design................................................ 21 2.2 Sampling Method Requirements ............................................................................. 21 2.3 Sample Handling and Custody Requirements ......................................................... 22 2.4 Analytical Method Requirements ............................................................................ 24 2.5 Analytical Quality Control Requirements ............................................................... 24

2.5.1 Precision....................................................................................................... 24 2.5.2 Bias .............................................................................................................. 25 2.5.3 Accuracy ...................................................................................................... 25 2.5.4 Sensitivity .................................................................................................... 27 2.5.5 Completeness ............................................................................................... 27 2.5.6 Representativeness....................................................................................... 27 2.5.7 Comparability .............................................................................................. 28 2.5.8 Blank, Standard & Check Sample Procedure .............................................. 29

2.6 Instrument/Equipment Testing, Inspection, and Maintenance Requirements ......... 30 2.7 Instrument Calibration and Frequency .................................................................... 30 2.8 Inspection Acceptance Requirements for Supplies and Consumables .................... 31 2.9 Data Acquisition Requirements for Non-Direct Measurements.............................. 32 2.10 Data Management .................................................................................................... 32

2.10.1 Electronic Data Deliverable Requirements.................................................. 34 3.0 ASSESSMENT AND REPORTING................................................................................ 35

3.1 Assessment and Response Actions .......................................................................... 35 3.2 Reports to Management ........................................................................................... 36

4.0 REVIEW, VALIDATION AND VERIFICATION ......................................................... 38 4.1 Data Review Methods.............................................................................................. 38 4.2 Validation and Verification Methods ...................................................................... 38

4.2.1 Procedures Used to Verify Field Instrument Data....................................... 39 4.2.2 Procedures Used to Verify Laboratory Data................................................ 40

4.3 Reconciliation with User Requirements .................................................................. 40 5.0 REFERENCES ................................................................................................................. 42

99006-K SLRIDT RD Appendix B 092905.doc ii

LIST OF TABLES

Table B-1 Deleted

Table B-2 Laboratory Detection Limits

Table B-3 Field Measurement Quality Objectives

Table B-4 Materials Testing Laboratory Methods

Table B-5 Borrow Material Monitoring Summary Table

Table B-6 Deleted

Table B-7 MPCA Cleanup Levels

Table B-8 QC Parameters

Table B-9 Laboratory Audit Checklist

Table B-10 Maintenance and Corrective Actions for Field Equipment

LIST OF ATTACHMENTS

Attachment B-1 Pre-Response Action Monitoring Plan (Completed, Statement Only)

Attachment B-2 Response Action Monitoring Plan

Attachment B-3 Post-Response Action Monitoring Plan (To Be Completed)

Attachment B-4 Field Forms

Attachment B-5 Braun Intertec Quality Assurance Manual and Laboratory SOPs

Attachment B-6 Pace Analytical Services Quality Assurance Manual and Laboratory SOPs

Attachment B-7 Lab Electronic Data Deliverable SOP

Attachment B-8 MPCA Noise Control Manual

Attachment B-9 Invasive and Exotic Species Monitoring SOP

Attachment B-10 Calibration Procedure for ArSLID

Attachment B-11 Deleted

Attachment B-12 Chronic Air Monitoring Operating and Calibration Procedures

Attachment B-13 LIF to PAH Calibration Procedures by Dakota Technologies, Inc.

Attachment B-14 Collection and Logging SOP for Vibrocore and Drop Core

Attachment B-15 ASTM Guidelines

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TECHNICAL TERMS AND ACRONYMS

Agreement Contract between the MPCA and the Companies reopening the RI/FS and establishing a PRT

ARARs Applicable or Relevant and Appropriate Requirements under CERCLA

ArSLID Aromatic Specific Laser Ionization Detector

BAZ Bioactive Zone

BETX Benzene, Ethyl Benzene, Toluene, Xylenes

Braun Braun Intertec Corp. – laboratory used for environmental sample analysis (all media except air monitoring samples)

BAT Best Available Technology

BT/PT The Best Technology in Process and Treatment

CAD Contained Aquatic Disposal – An engineered disposal facility used to confine dredged material in a laterally and vertically contained system with a cap that is below water

Cap Fill placed on contaminated material to isolate contaminants from, and to contain, the Bioactive Zone

CERCLA Comprehensive Environmental Responsibility, Compensation and Liability Act (also known as Superfund)

CFR Code of Federal Regulations

City City of Duluth

COC Contaminants of Concern

COE United States Army Corps of Engineers

Companies XIK Corp. (formerly The Interlake Corporation), Honeywell International, Inc., and Domtar Inc. These are the three responding Responsible Parties (of the four named Responsible Parties)

Cover Material placed over recently dredged or excavated surface to dilute or enhance the natural recovery of contaminated residue

DGR Data Gap Report

Dike Earthen berm used to laterally contain contaminated dredged material disposed within a CAD

DNR Minnesota Department of Natural Resources

DOT Department of Transportation

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TECHNICAL TERMS AND ACRONYMS (CONT’D)

DQA Data Quality Assessment

DQI Data Quality Indicators

DQO Data Quality Objectives

Dredge Prism The three-dimensional dredge volume defined by neat-line dredge surfaces

DTI Dakota Technologies, Inc.

EDD Electronic Data Deliverable

Engineer SERVICE Engineering Group

Environmental Medium

Hydric soil consisting mainly of silt and clay with lesser amounts of sand and organics

EPA United States Environmental Protection Agency

FAV Final Acute Values

FS Feasibility Study

GC Gas Chromatograph

GIS Geographic Information System

Hallett Hallett Dock Company

HBV Health Based Value for ambient air quality

HRL Health Risk Limits (State)

in situ Undisturbed, In Place

IZ Isolation Zone

LCS/LCSD Laboratory Control Sample/Laboratory Control Sample Duplicate

LIF Laser-Induced Fluorescence

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MDL Method Detection Limit

MERLA Minnesota Environmental Response and Liability Act

mg/Kg Milligram per Kilogram (parts per million)

mg/L Milligram per Liter (parts per million)

Minnesota Channel

The Federally authorized navigation channel on the south end of the Site, currently maintained to 23 feet

MPCA Minnesota Pollution Control Agency

msl Mean Sea Level referenced to North American Vertical Datum 88 (96)

MS/MSD Matrix Spike/Matrix Spike Duplicate

NAPL Non-Aqueous Phase Liquid

NCP National Contingency Plan

NPDES National Pollution Discharge Elimination System

NPL National Priority List

NRT Natural Resource Trustees—a group of State, Federal and Tribal entities authorized to seek damages for injuries to natural resources at the Site

OSHA Occupational Safety and Health Administration

Overdredge Non-contaminated sediment, below the neat-line, that is removed to ensure removal of all contaminated sediment above the neat-line

Owner See Companies

Pace Pace Analytical Services – laboratory used for air monitoring sample analysis

PAHs Polycyclic Aromatic Hydrocarbons

Parties The MPCA and the Companies

PEC Probable Effects Concentration

PEC-Q Probable Effects Concentration Quotient

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PPE Personal Protection Equipment

PQL Practical Quantitation Limit

PRT Peer Review Team

PUF/XAD Polyurethane Foam with XAD Resin

QAPP Quality Assurance Project Plan

QA/QC Quality Assurance/Quality Control

RA Response Action

RAC Response Action Contractors – One or more contracting firms to be selected by the Companies to implement the RD/RA Plan

RAO Response Action Objective

RD Remedial Design

REMPI Resonance Enhanced Multi-Photon Ionization

RFRA Request for Response Action

RI/FS Remedial Investigation/Feasibility Study

RL Reporting Limit

RLS Registered Land Surveyor

ROD Record of Decision

RPD Relative Percent Difference

RSD Relative Standard Deviation

SedOU Sediment Operable Unit

SERVICE Service Engineering Group

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SHASP Site Health and Safety Plan

SIM Selected Ion Monitoring

Site The St. Louis River/Interlake/Duluth Tar Site

SLRIDT St. Louis River/Interlake/Duluth Tar Superfund Site

SOP Standard Operating Procedure

SOU Soil Operable Unit

SQT Sediment Quality Targets

Surcharge A temporary extra thickness of capping sand whose weight is used to compress the cap into the sediment, after which the surcharge is removed

SWQS/C Surface Water Quality Standards and Criteria

TPAHs The sum of the individual PAH compounds measured

TSOU Tar Seep Operable Unit

ug/Kg Microgram per Kilogram (parts per billion)

ug/L Microgram per Liter (parts per billion)

ug/m3 Microgram per Cubic Meter

WCA Wetland Conservation Act

WDNR Wisconsin Department of Natural Resources

WLSSD Western Lake Superior Sanitary District

99006-K SLRIDT RD Appendix B 092905.doc 1

1.0 INTRODUCTION

This Quality Assurance Project Plan (QAPP) and Response Action Monitoring Plan are part of

the Remedial Design/Response Action (RD/RA) Plan being submitted in conformance with the

requirements of the Minnesota Pollution Control Agency (MPCA) Requests for Response Action

(RFRA) issued to the Responsible Parties (Companies), and in fulfillment of the Companies

commitment, in the Agreement between the MPCA and Companies (Agreement), to implement a

properly selected remedy at the St. Louis River/Interlake/Duluth Tar (SLRIDT) Site for the

Sediment Operable Unit (SedOU). The RD/RA Plan also serves to describe the project for the

various permit applications that must be approved for remediation, and to provide additional

detail about the Response Action (RA) for consideration by the Natural Resource Trustees in

their assessment of the restorative value of the remedy.

This QAPP and Monitoring Plan is an integral part of the RD/RA Plan. As such, some

components of the QAPP will be found elsewhere in the RD/RA Plan. Where that is the case,

this QAPP cites to the location where the information is presented so as to avoid potential errors

of duplication.

The SLRIDT Site is a State-lead National Priority List (NPL) site, and is one of the sites

identified in the Pilot Enforcement Deferral Project agreement between the MPCA and the U.S.

Environmental Protection Agency (EPA) dated June 20, 1995. RAs at the SedOU will be taken

pursuant to the Minnesota Environmental Response and Liability Act (MERLA) as per the Pilot

Enforcement Deferral Project agreement. The RA will be subject to applicable Federal, State

and local permit requirements.

This QAPP and Monitoring Plan identifies the remediation monitoring and sampling required by

the RFRA, and the Record of Decision (ROD). The main body of the text is the QAPP, with a

Pre-Response Action Monitoring Plan completion statement included as Attachment B-1, a

Response Action Monitoring Plan included as Attachment B-2, and a statement that the Post-

Response Action Monitoring and Maintenance Plan will be submitted for approval at a later date

as stated in Attachment B-3.


1.1 Distribution List

The following individuals will be provided a copy of the final, approved version of this

document. Any future additions or changes will also be sent to them.

Dr. Daniel Talsma Ms. Jane Mosel GKN - North America Minnesota Pollution Control Agency 550 Warrenville Road 525 Lake Avenue, Suite 400 Lisle, IL 60532-4387 Duluth, MN 55802 630-719-7237 218-529-6250 Mr. Michael Costello Mr. Michael Bares SERVICE Engineering Group Minnesota Pollution Control Agency 675 Vandalia Street 520 Lafayette Road St. Paul, MN 55114 St. Paul, MN 55155-4194 651-644-6680 651-297-8599 Mr. Marcel Sylvestre Mr. Chuck Geadelmann Domtar Inc. Honeywell 395 Boulevard de Maisonneuve Ouest 7171 Ohms Lane Montreal, Quebec H3A 1L6 Edina, MN 55439 514-848-5324 952-830-3685 Mr. Steve Albrecht Mr. Jim Japps Braun Intertec Corp. Minnesota Department of Natural Resources 11001 Hampshire Avenue South 500 Lafayette Road Bloomington, MN 55438 St. Paul, MN 55155-4040 651-995-2622 651-297-4600 Mr. William Gregg Mr. Duane Lahti ENSR International Wisconsin DNR 4500 Park Glen Road, Suite 210 1401 Tower Avenue St. Louis Park, MN 55416 Superior, WI 54880 952-924-0117 715-395-6911 Mr. Craig Foxhoven Mr. James Mohn Braun Intertec Corp. City of Duluth 11001 Hampshire Avenue South 411 West First Avenue, City Hall Room 402 Bloomington, MN 55438 Duluth, MN 55802 651-995-2600 218-730-5580 Mr. Paul Voge Mr. Daryl Peterson LHB Engineers and Architects Pace Analytical Services Lake Superior Place 1700 Elm Street, 21 West Superior Street, Suite 500 Suite 200 Duluth, MN 55802 Minneapolis, MN 55414 218-727-8446 612-607-6386


Ms. Patty Fowler Mr. Timothy Peterson DNR, Division of Waters USACE - St. Paul District 1568 Highway Two 1554 Highway 2, Suite 2 Two Harbors, MN 55616 Two Harbors, MN 55616 218-834-6621 218-834-6630 1.2 Project Organization

SERVICE will implement the remediation monitoring and sampling in cooperation with the

MPCA, the Companies and RA Contractors (RAC), as shown on the SedOU QAPP Organization

Chart, below. The SERVICE project manager and field team leader will be responsible for

oversight and implementation of all remediation monitoring and sampling performed in

accordance with this QAPP.


Management Responsibilities

Mike Costello is the site engineer and project manager for the project and is responsible for

ensuring the completion of the project stated in this QAPP. Mike Costello, the project manager

is also in charge of overall quality assurance (QA) and reporting, has final signature authority for

corrective actions and work performed on Site, and oversees contracted laboratory and field

services. All project-related activities will be coordinated through Mr. Costello, or his delegate.

Mr. Costello will be responsible for project oversight and will be the focal points for all Site

communication with regulatory agencies, the Companies, and other interested parties.

Quality Assurance Responsibilities

Jane Mosel and Luke Charpentier are responsible for the review and approval of this QAPP. Bill

Flynn, QA manager, is responsible for data verification and data assessment. Craig Foxhoven is

responsible for chemistry laboratory analysis quality assurance at Braun Intertec Corp. (Braun).

Gary Newton is responsible for chemistry laboratory analysis quality assurance at Pace

Analytical Services (Pace).

Field Responsibilities

Guy Partch is the field team leader and is responsible for ensuring that all field activities are

performed in accordance with this QAPP. All monitoring and sampling activities will be

coordinated through the field team leader, who will have overall responsibility for all field

sampling activities, including:

• Identification of all field monitoring and sampling activities;

• Identification and ordering of any required equipment and containers;

• Instruction of field personnel on use of appropriate monitoring forms (Attachment B-4);

• Coordination of sample collection and analysis requests in accordance with QAPP and

Monitoring Plan protocols;

• Instruction of field personnel on use and calibration of monitoring equipment;

• Field measurement Quality Assurance/Quality Control (QA/QC);

• Field location of sample collection and monitoring points using global positioning system

(GPS) and/or other surveying conducted under the supervision of Paul Voge of LHB, a

Registered Land Surveyor (RLS); and

• Field audits.


Laboratory Responsibilities

Steve Albrecht is the laboratory project manager for Braun and is responsible for chemistry

analysis and reporting. Chemistry laboratory responsibilities are further described in the Braun

QA Manual shown in Attachment B-5. Daryl Peterson is the air services program director for

Pace and is responsible for air chemistry analysis and reporting. Air analysis laboratory

responsibilities are further described in the Pace QA Manual shown in Attachment B-6. A

materials testing laboratory is yet to be determined and will be responsible for materials testing

analysis and reporting in accordance with methods and procedures presented in Table B-4 and

Attachment B-15.

1.3 Problem Definition/Background Information

The purpose of this QAPP is to define the protocol for monitoring, sampling, and analysis of

various media, including sediment, water and air, to evaluate whether remediation activities

performed at the SLRIDT Site are in compliance with regulatory requirements. The data

generated under this QAPP and Monitoring Plan will be important for determining the

effectiveness of the remediation and the overall protection of human health and the environment.

Site Description

The SLRIDT Site is located on the St. Louis River in Duluth, Minnesota, approximately 4 miles

upriver from its confluence with Lake Superior as shown on the Site Location Map below. The

Site includes approximately 255 acres of land, river bays, wetlands, and shipping slips currently

operated by Hallett Dock Company (Hallett). The land includes the 59th Avenue Peninsula and

the 54th Avenue Peninsula. The aquatic portion of the Site includes Stryker Bay (approximately

40 acres that defines the western boundary), Slip 6 (approximately 23 acres), Slip 7

(approximately 27 acres that defines the eastern boundary), and the St. Louis River to the south.

Residences are located west of the Site on the 63rd

Avenue Peninsula, and to the north of the

railroad tracks defining the northern boundary of the Site. Approximately 960 people live within

one half mile of the Site. A small portion (approximately 1.5 acres) of the SedOU at the mouth

of Slip 6 is within the waters of the State of Wisconsin.

The SedOU to be remediated consists of three water bodies (Stryker Bay, Slip 6, and Slip 7), as

well as portions of the Federal navigation channel (Minnesota Channel) of the St. Louis River

adjacent to the site.


Site Location Map

Problem Definition and Background Information

The Site has been used for industrial purposes since at least the 1890s as described in the SedOU

Feasibility Study (SERVICE 2003).

In 1979, polycyclic aromatic hydrocarbons (PAHs) were detected in Stryker Bay sediments by

the MPCA. An oil slick was noted on the surface of the bay in 1981. The site was nominated to,

and listed on, the NPL in combination with the United States Steel Site, located about four miles

upriver. In 1991 and 1993, RFRAs were issued to the Companies for the Tar Seep Operable

Unit (TSOU) and Soil Operable Unit (SOU). Remediation of the TSOU by excavation and off-

site thermal treatment was completed in 1993. In most of the areas of the SOU, soil was

excavated and either thermally treated or transported off-site. These activities were completed in

1996 and 1997, with bioventing of a portion of the SOU completed in 2003.

The SedOU has been the subject of several investigations during the past nine years, including a

remedial investigation (RI) and risk assessment completed in 1997 (IT 1997a). Four additional

studies have been submitted since the RI. A Draft Alternatives Screening Report (IT 1997b),


which screened 44 technologies and developed and compared nine alternatives, carried forward

six alternatives to a Draft Feasibility Study (IT 1998). One of the alternatives carried forward

included a thin cap, which the MPCA found not to be protective. A Focused Feasibility Study

Update (SERVICE 1999a) and a Supplemental Detailed Analysis Report (SERVICE 1999b)

were submitted that examined an alternative consisting of a thicker cap (2-3 feet thick).

In 2000, the Companies and MPCA entered an agreement to reopen the RI/FS, to gather

information to fill 14 data gaps, and to evaluate four alternatives. The Agreement also provided

for the creation of a Peer Review Team (PRT) of national experts to review the results collected

and render opinions on the 14 issues and on the strengths and weaknesses of the alternatives.

The data collected to fill the data gaps was submitted to the MPCA in 2002 in the Data Gap

Report (SERVICE 2002). Meetings were held during the data gathering period in 2001 and 2002

to discuss the data and associated issues with the PRT. The MPCA facilitated a two-day meeting

in February 2003, following completion of the DGR, with the Companies, MPCA staff, the PRT,

staff of the DNR and other natural resource managers, a Site property owner, the City of Duluth

and other stakeholders. The February 2003 meeting produced a number of new hybrid

dredge/cap alternatives and identified unresolved key regulatory issues affecting remedy

selection and implementation. Using the information developed at the February 2003 meeting

the Companies, the MPCA, and the DNR identified a hybrid alternative to be evaluated in

another FS (SERVICE 2003). The Parties then reconvened the stakeholders and sought their

reaction to the new hybrid option. As a result, the Companies and the MPCA amended the 2000

Agreement to add the Dredge/Cap Hybrid Alternative in place of the Dredging & On-Site

Disposal Alternative option.

The primary chemicals of concern at the Site are polycyclic aromatic hydrocarbons (PAHs) in

sediment located in Stryker Bay, Slip 6, Slip 7 and the St. Louis River. Contaminated sediment

underlies most of Stryker Bay in a relatively discreet one- to two-foot thick layer with PAH

concentrations as high as 35,000 mg/Kg. In the northeastern portion of the bay only, PAH-

bearing material has migrated down to the underlying native peat or clayey silt sediment. The

uppermost sediment layer is a nearly uniform layer averaging six inches thick throughout the

bay, except in shallow wave-washed areas with an average PAH concentration of 34 mg/Kg.


Shipping activities in the Slips have resulted in the sediments containing greater than 13.7

mg/Kg PAHs mixing with native sediment and other industrial sediment (coal, coke, and slag) in

the top few feet of sediment throughout the majority of the Slips. Mercury levels in slip

sediments do not exceed ambient harbor background (SERVICE 2002).

Naphthalene is the most concentrated PAH compound on-Site. The following figure details

naphthalene concentrations in sediment.

Naphthalene Concentrations (shown in mg/Kg)

Mercury is elevated above ambient levels in portions of Stryker Bay, but is not elevated in the

Slips. Due to the high sulfide levels found throughout the sediments of the Site (SERVICE 2002

and IT 1997), almost all mercury in Stryker Bay sediment is expected to be in an insoluble

sulfide form, causing the concentration in the leachate to approximate the ambient river water

quality (SERVICE 2002). Leachate from the sediment to be remediated meets chronic surface

water quality standards/criteria (SWQS/C) for all other heavy metals (SERVICE 2002).

In Stryker Bay, contaminated sediment exists in areas up to eight- to ten-feet-thick along the

eastern shore. Throughout most of Slips 6 and 7, PAH-contaminated sediment is located near

the surface. The extent of PAH contamination is detailed on the following figure.


Extent of PAH Contamination Using Threshold Concentration of 13.7 ppm

South of Slip 6, some PAH-contaminated sediment is located across the state line in Wisconsin

and south of Slip 7, some PAH-contaminated sediment is located within the Minnesota Channel,

a 23-feet-deep Federal navigation channel. Because the channel was dredged, the adjacent

waters are much shallower. Slopes as steep as five to one connect the shallows to the deep

channel. An area south of the former industrial discharge point between the slips is known as the

48-inch outfall area because an industrial wastewater discharge occurred here in the late 50’s

until 1961. As in the shallows of Slip 7, a bed of hard slag caps the shallows between the slips

and creates a sandy shallow wave-washed surface. PAH-contaminated sediment is draped down

the slopes, with the most contaminated area to the southeast. Mercury does not exceed harbor

background in the sediments of the main channel or adjacent shallows.

The sources of PAH releases at the Site were primarily wastewater discharges from facilities

formerly located on the Site and possibly from other former sources in the contributing

watersheds. The last industrial discharges from facilities at the Site were terminated no later than

1961 when Interlake Iron shut down the last operating facility. Other off-site potential sources

cited above have also terminated operations. Urban runoff and atmospheric fallout and the

river’s wash load continue, but are not likely sources for recontaminating the site.


The RD/RA Plan details the proposed response actions to be performed to remediate the SedOU

portion of the Site. The response actions are summarized in Section 1.5.1.2.

1.4 Project/Task Description and Schedule

The objective of the RA is to remediate the SedOU portion of the SLRIDT Site as presented on

the figure below and is being performed pursuant to MERLA as stated in Section 1.0. The

RD/RA Plan details the specific tasks that will be performed to complete the SedOU remediation

and the anticipated schedule for completion of the work. The quality objectives of the RA are

detailed in Section 1.5.1.

Response Action Plan Overview

This QAPP and Monitoring Plan details the monitoring, sampling and analysis which will be

performed during (Attachment B-2) the response action activities in order to evaluate whether

the activities comply with regulatory agency requirements and to document completion of the

response actions. Specific monitoring tasks will be tied to the associated remediation tasks and

will therefore be subject to the remediation schedules presented in Figure 16-1 of the RD/RA

Plan.


1.5 Quality Objectives and Criteria for Measurement Data

The purpose of this section is to document the Data Quality Objectives (DQOs) of the project. It

was prepared in accordance with EPA’s Data Quality Objectives Process for Hazardous Waste

Site Investigations (EPA 2000).

1.5.1 Specifying Quality Objectives

The DQO process is a series of planning steps based on the Scientific Method that is designed to

ensure that the type, quality, and quantity of environmental data used in decision-making are

appropriate for the intended application. DQOs are qualitative and quantitative statements

derived from outputs of each step of the DQO process that:

• Clarify the intended use of the data;

• Define the type of data needed to support the decision;

• Identify the conditions under which the data should be collected; and

• Specify tolerable limits on the probability of making a decision error due to uncertainty in the

data.

The DQO process consists of the following seven steps:

1. State the problem;

2. Identify the decision;

3. Identify inputs to the decision;

4. Define the study boundaries;

5. Develop a decision rule;

6. Specify limits on decision errors; and

7. Optimize the design for obtaining data.

Data Quality Indicators (DQIs) can be evolved from DQOs for a sampling activity through the

use of the DQO process (EPA 2000). For this project, the individual steps of the DQO process

are listed below.

1.5.1.1 State the Problem

Contaminated sediments are present at the SLRIDT site at levels that require response action.

Response actions will be taken in accordance with the MPCA ROD to ensure protection of


human health and the environment from the chemicals of concern at the Site, primarily PAHs

(Section 1.3). This QAPP and Monitoring Plan presents the monitoring requirements to be taken

during response actions to ensure protection of human health and the environment and document

attainment of the remedial goals presented in Table B-7.

A SedOU conceptual response action plan was agreed upon by the MPCA and the Companies,

which includes in situ capping on portions of the Site and dredging of some contaminated

sediments, which will be placed in an on-Site Contained Aquatic Disposal (CAD) facility.

Design details are presented in the accompanying RD/RA Plan.

The DQO planning team involved in development of the RD/RA Plan and this QAPP and

Monitoring Plan includes the key personnel shown in the Organization Chart presented on page 3

of this QAPP as well as the Quality Assurance/Quality Control (QA/QC) staff for each of the

represented organizations. The primary resources in use at the Site include the staff at

SERVICE, the MPCA project staff, Braun laboratory analytical staff, and Pace air analytical

staff. In addition, additional resources are available, as needed, from Dakota Technologies,

Anchor Environmental, W/L Delft, and members of the PRT.

1.5.1.2 Identify the Decision

The MPCA, through its ROD, has determined that the SedOU portion of the SLRIDT Site should

be remediated. The objective of this RA is to remediate the SedOU portion of the SLRIDT.

This QAPP and Monitoring Plan is designed to obtain data during implementation of the RA to

ensure compliance with Response Action Objectives (RAOs) and cleanup levels, presented in

Section 3 of the ROD and also detailed in Section 1.5.1.3 and in Table B-7. The applicable

response actions to achieve RAOs and cleanup levels for the SLRIDT Site are:

1. Removal of PAH-contaminated sediments from:

• Stryker Bay,

• On-shore wetlands of Slip 7,

• Wisconsin waters, south of Slip 6, and

• Portions of the Minnesota Channel in the St. Louis River between Slips 6 and 7.


2. Isolation and containment of the dredged sediment in a CAD facility to be constructed in

Slip 6.

3. In situ subaqueous capping/covering of PAH-contaminated sediment in:

• Stryker Bay,

• Slip 6,

• On-shore wetlands of Slip 7, and

• Slip 7 (including a portion of the Minnesota Channel in Minnesota)

4. Establishment of riparian buffers along the eastern portion of Stryker Bay, if agreement

between the MPCA and current landowners is reached.

1.5.1.3 Identify Inputs to the Decision

Data obtained under this QAPP and Monitoring Plan must have sufficiently low detection limits

for comparison to RAOs and cleanup levels (Section 3 of the ROD and summarized in

Table B-7), or must otherwise be useful for ongoing RA decisions.

Response Action Objectives and Cleanup Goals

The chemistry data must have sufficiently low detection limits to compare to the RAOs and

cleanup levels outlined in Section 3 of the ROD and Table B-7.

The cleanup level for bulk sediment is 13.7 mg/Kg PAH. The PAH concentration is comprised

of the additive total of the detected concentration, or ½ of the reporting limit (RL) for

compounds not detected at the RL, for 17 PAH compounds historically analyzed at the Site

(acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(b)fluoranthene,

benzo(k)fluoranthene, benzo(g,h,i)perylene, benzo(a)pyrene, chrysene, dibenz(a,h)anthracene,

fluoranthene, florene, indeno(1,2,3-cd)pyrene, 2-methylnaphthalene, naphthalene, phenanthrene,

and pyrene). The RL, or practical quantitation limit (PQL), for solids will be low enough to

distinguish if PAHs by dry weight exceed 13.7 mg/Kg in sediment with water contents like those

found at the Site. At Braun, the Standard Method SW-846-8270 produces quantitation limits of

0.067 mg/Kg for each compound when measured as wet weight. It is anticipated that

subaqueous samples of the sand cap will contain approximately 30 percent moisture by weight.

Therefore, dry weight quantitation limits could be as high as 0.1 mg/Kg (0.067/(1-0.3)). If all


compounds were present at the quantitation limit, the PAH value would be 1.6 mg/Kg, which is

approximately 12 percent of the 13.7 mg/Kg cleanup level. Therefore, Standard Method SW-

846-8270 was selected as the analytical method for PAHs in solids. Extraction will be by

method SW-846-3545, which is Braun’s standard extraction method for semi-volatiles and is

described in Braun SOP GCMS6258270C2 located in Attachment B-5.

Braun will use method SW-846-7471 to analyze bulk sediment for the presence of mercury.

Braun’s PQL for mercury is 0.02 mg/Kg, which is more than an order of magnitude less than the

cleanup level of 0.26 mg/Kg. Braun will use method SW-846-6020 to analyze bulk sediment for

the presence of the other metals listed in Table B-7. The cleanup levels established by the

MPCA for the other metals is the mean probable effects concentration quotient (PEC-Q) = 0.6,

using the Level II Sediment Quality Targets (Crane et. al. 2000). The Mean PEC-Q is the

arithmetic mean of the quotient of the detected concentration (or ½ the RL for non-detected

compounds) divided by the Level II SQT for each of the identified metals in Table B-7, except

mercury, which has a separate cleanup level. The Mean PEC-Q would be 0.01 if all compounds

were detected at the PQL [Mean (PQL/Level II SQT) = 0.01], which is more than an order of

magnitude less than the cleanup level of mean PEC-Q = 0.6.

The cleanup levels for PAH compounds in surface water are presented in Table B-7. Final acute

values (FAV) serve as cleanup values for surface water samples collected outside the work zone.

BT/PT and BAT, which has been defined as microfiltration followed by activated carbon

filtration, will apply to treated CAD water as presented in Table B-7. The FAV values for

acenaphthene, acenaphthylene, fluoranthene, naphthalene and phenanthrene range in

concentration of 0.625 to 818 ug/l. Braun will use method SW-846-8270 SIM to analyze the

surface water samples collected to evaluate water quality from the remedial treatment zone.

Using method 8270 SIM the PQL for naphthalene is 0.05 ug/l, and is 0.01ug/l for acenaphthene,

acenaphthylene, fluoranthene, and phenanthrene, which are sufficiently below the cleanup values

for identification of exceedances. Analytical methods will be established for treated CAD water

when the design parameters for the wastewater treatment plant (carbon bed depth, carbon

efficiency, linear flow rate, etc.) have been determined.

The cleanup levels for BETX compounds in surface water are presented in Table B-7. FAV

values serve as cleanup values for surface water samples collected outside of the work zone and


treated CAD water. The cleanup values for the BETX compounds range from 2,703 to 8,974

ug/l. Braun will use method SW-846-8260 to analyze the surface water treatment samples

collected to evaluate water quality from the remedial treatment zone and CAD. Using method

8260 the PQL for BETX is 1.0 ug/l, which is sufficiently below the cleanup values for

identification of exceedances.

The cleanup levels for inorganic metals other than mercury and major ion compounds in surface

water are presented in Table B-7. FAV values serve as cleanup values for surface water samples

collected outside of the work zone. BT/PT will apply to treated CAD water. The FAV values

for the inorganic compounds and major ions range from 6.04 to 2,693 ug/l analytical method

EPA 200.8 will be used to analyze arsenic, cadmium, copper, iron, lead, manganese, nickel, and

zinc. The PQLs for these compounds are sufficiently below the cleanup values for identification

of exceedances. Braun will use analytical method SW-846-7196 for hexavalent chromium and

use a calculation subtracting hexavalent chromium from total chromium (method 200.8) to

document chromium+3. Braun will use method SW-846- 9012A for the analysis of free cyanide,

which has a PQL of 10 ug/l, with a cleanup level of 44 ug/l.

The cleanup level for mercury in river water outside the remedial treatment zone is 0.26 µg/L,

which is greater than Braun’s PQL of 0.10 µg/L (0.009 µg/L MDL) for mercury using method

EPA 245.1. The pervasive nature of mercury in the atmosphere, water vapor from human

breathing and other environmental factors is the reason for the large difference between the MDL

and PQL. In order to lower the effective PQL as much as possible, all water samples collected

for mercury analysis will be handled by all field and lab personnel wearing particulate masks to

avoid mercury vapor from dental fillings from contaminating the samples. In addition, a field

blank will be collected for each set of mercury samples submitted for analysis. If initial

monitoring indicates that the effective PQL is too high for comparison to the cleanup level, ultra-

low-level mercury sampling and analysis (EPA method 1631) will be instituted. If the ultra-low-

level mercury methodology is required, SERVICE will issue a QAPP addendum detailing the

sampling and analysis method and including a QA manual for the selected laboratory. Other

metals monitored outside the treatment/work zone (Table B-7) will be analyzed by Braun using

method EPA 200.8, which attains a PQL at least 25 times lower than the FAV for each

compound.


Prior to discharge to the St. Louis River, CAD water and compost and decontamination water

will be treated using Best Available Technology (BAT) and Best Technology in Process

Treatment (BT/PT) for those compounds as shown on Table B-7. It has been determined that

CAD water and compost and decontamination water will be treated using microfiltration

followed by activated carbon filtration.

To measure air concentrations for comparison to the acute hourly average requirements in

Section 3.2.4 of the ROD, a real-time monitoring mobile analyzer will be used that was

developed by Dakota Technologies, Inc. (DTI). The Aromatic Specific Laser Ionization

Detector (ArSLID) is designed to measure aromatic compounds at very low concentrations.

ArSLID is based on the spectroscopic technique referred to as resonance enhanced multi photon

ionization (REMPI). In the REMPI process, molecules with one or more aromatic rings become

electronically excited when they absorb ultraviolet photons.

The ArSLID’s intrinsic selectivity, sensitivity, and speed yield a simple yet efficient instrument

for the quantification of aromatic species at the µg/m3 level. Therefore, DTI has designed a

custom ArSLID system that will meet or exceed all of the needs for this application.

The ArSLID system is capable of averaging naphthalene measurements at hourly intervals.

These measurements will be transmitted to the data logger, which will record the hourly

averages. The acute standard threshold is 38 parts per billion by volume (ppbv)

(200 µg/m3) on an average hourly basis. The ArSLID instrument is capable of measuring

naphthalene below this acute standard and, therefore, is viable for use as a measure of acute

naphthalene concentrations. Additional details are presented in Attachment B-2, Section 1.2.

Chronic monitoring for naphthalene will be conducted using EPA Method TO-13A. At the

request of the MPCA, the standard list of TO13 PAHs will be reported for each analyses.

However, naphthalene is the only compound for which there is a Response Action Goal. This

method will use high volume polyurethane foam (PUF) samplers that have sandwiched XAD

resin (SKC part no. 226-129). The sampling equipment will be hardwired to existing utilities

and capable of sampling in the range of 200 – 280 L/minute. The sampling will be conducted

every 6 days over 48 hours to collect 600 cubic meters of air. The PUF/XAD samples will be


removed after 48 hours and shipped to the laboratory for analysis. Additional details are

presented in Attachment B-2, Section 1.3.

Laboratory analysts will utilize a GC/MS SIM (selected ion monitoring) as described in the

PACE analytical MN-O-534-B SOP (Attachment B-6). The laboratory reporting limit for

naphthalene is 0.1 µg per sample. Based on a 600 cubic meter air sample over 48 hours, this

method will have a reporting limit of 0.0002 µg/m3 (6.27 x 10-5 ppbv) which is lower than the

chronic Health Based Value (HBV) of 9 µg/m3 (1.7 ppbv).

Laboratory MDL and PQL, as well as the corresponding cleanup levels for each of the

compounds and media monitored are listed in Table B-2.

Field measurement quality objectives are detailed in Table B-3. The accuracy of field

measurements is controlled through calibration of field instruments in accordance with

manufacturer’s specifications. The manufacturer or instrument provider will calibrate

instruments that cannot be field calibrated. Instrument calibration is discussed in Section 2.7.

Dredge residual will be produced as a result of:

• Suspension and resettlement of fine-grained sediment from the dredging activity;

• Material falling off the cutterhead or bucket;

• Nearby sediments shearing and sloughing into the dredge cut;

• Propwash from support vessels inducing shear forces on soft sediment; and

• Currents and bed shear from waves redistributing sediments.

Normal dredge residue will be defined during pilot dredging in Stryker Bay and the Minnesota

Channel area using real-time laser induced fluorescence (LIF) as a screening tool. The LIF will

then be used during the remaining dredging to determine if the dredging activity adequately

removed the contaminated sediment.

The general operation method, detection, and calibration procedures for the LIF equipment are

presented in Attachment B-13.


1.5.1.4 Define the Study Boundaries

The Site boundaries for the SedOU remediation, presented on the figure shown in Section 1.4,

include the three water bodies of the Site: Stryker Bay, Slip 6 and Slip 7; as well as portions of

the St. Louis River adjacent to the south side of the Site.

Sediments will be dredged in Stryker Bay to depths ranging from 0 to approximately 5 feet

below the existing sediment surface. Sediments will be dredged in the Minnesota Channel area

at depths ranging from 0 to approximately 8 feet below the existing sediment surface. Capping

of some contaminated sediments at locations not identified for dredging will be performed in

Slip 7, along the eastern shore of Stryker Bay and on top of the CAD.

Pre-RA monitoring has been conducted and is summarized in Section 3.0 of the RD/RA Plan. A

separate report to the MPCA will detail the results. The remedial activity is expected to take

approximately four years. Post-RA monitoring is not anticipated until at least 2009. A Post-RA

monitoring plan will be developed and submitted to the MPCA for approval prior to

implementation.

1.5.1.5 Develop a Decision Rule

Monitoring, sampling and analysis detailed in the Monitoring Plan (Attachment B-2) determine

if activities undertaken to remediate the SedOU of the SLRIDT Site are performed in compliance

with regulatory standards and criteria set by the MPCA in its ROD. The PAH cleanup of 13.7

mg/Kg was used to determine the limits of the sediment to be capped or dredged. Monitoring

during RA will evaluate whether the dredge prism has successfully remediated the sediments

with PAH concentrations greater than 13.7 mg/Kg, and determine normal dredge residue.

Monitoring will also be performed to evaluate whether response actions are adversely affecting

surface water quality outside the outermost engineering control. The cleanup goals summarized

in Table B-7 will be used for comparison to values obtained during RA monitoring. In addition

monitoring will be performed to evaluate air quality and noise associated with response action

activities. Details regarding thresholds and requirements for air and noise monitoring are

included in Attachment B-2, Sections 2.0 and 3.0, respectively.

Monitoring that indicates a ROD requirement exceedance will be reported to the SERVICE

engineer and project manager, then to the MPCA project team. The MPCA project team and

SERVICE project manager, will evaluate the need for additional, or more frequent, monitoring


and/or engineering controls as described in Section 19.0 of the RD/RA Plan. The decision rules

will be determined on a case-by-case basis in conjunction with MPCA project staff to ensure

protection of human health and the environment.

1.5.1.6 Specify Limits on Decision Errors

The monitoring will be performed based on the RAOs and Cleanup Levels outlined in

Appendix A and summarized in Table B-7. Monitoring locations and frequencies were

established to allow effective identification of exceedances, based on Site studies designed to

determine sediment, water and air characteristics and interaction. The following quality control

guidelines will ensure that decisions are based on reliable, accurate data.

Laboratory precision and accuracy will be assured by strict attention to quality control protocols

as detailed in Attachment B-5, Section 2.8 for Braun and Attachment B-6, MN-O-534-B SOP

for Pace and by analysis of appropriate replicates, matrix spike/matrix spike duplicate

(MS/MSD) samples, standards, reagent blanks, method blanks, tissue blanks, and daily

calibration of instruments according to manufacturer guidelines. One MS/MSD pair will be

analyzed for every 20 samples submitted for laboratory analysis. One duplication sample will be

analyzed for every 10 samples submitted for laboratory analysis.

Field precision and accuracy will be assured by strict attention to monitoring and sampling

protocols, including training on field equipment use, training on identification of erroneous

readings, and calibration of instruments in accordance with manufacturer guidelines.

1.5.1.7 Optimize the Design for Obtaining Data.

The design of the monitoring, sampling and analysis program has been optimized by consensus

of the MPCA, SERVICE and the Companies, and by incorporation of input from experts at

WL/Delft, Anchor Environmental LLC, and the Peer Review Team (PRT) enlisted to evaluate

remedial options.

1.6 Special Training Requirements/Certification

All staff performing monitoring tasks during remedial activities, regardless of affiliation, will

have successfully completed the Occupational Safety and Health Administration (OSHA) 40-

hour training and up-to-date annual 8-hour refresher training. Certificates verifying this training


will be filed on-Site in the SERVICE field office. OSHA safety requirements are detailed in the

Site Security and Safety Plan, in Appendix E.

All field personnel will be qualified and trained to perform the monitoring and sampling tasks

assigned to them. Field staff training will be performed by the SERVICE field team leader, or

his delegate, and documented in the project file.

All laboratory personnel will be qualified and trained to perform the analysis on the equipment

assigned to them. The laboratory will maintain all applicable certifications (Attachment B-5,

Section 2.6 and Appendix D-1 and Attachment B-6, Certifications), and will notify the

SERVICE QA officer within 24 hours of any loss of certification. The SERVICE QA officer, or

his delegate, and the MPCA project team will approve in advance any laboratory samples

submitted by Braun or Pace for analysis at another laboratory.

1.7 Documentation and Records

All records generated before or during the remediation activities, as well as the post-remediation

monitoring and maintenance will be retained by SERVICE in a secure location at its office, or

other secured and approved location, until such time as the MPCA Commissioner approves of

their disposal in writing. Hard copy data will be stored in SERVICE offices in St. Paul or

Duluth, Minnesota, or a subcontracted file storage facility such as Iron Mountain. Electronic

data will be stored on the SERVICE computer server, which is backed up regularly. The backup

server tapes are stored in a fireproof safe at the SERVICE office in St. Paul.

See Section 17.0 of the RD/RA Plan for more detailed a discussion of record retention.


2.0 MONITORING/SAMPLING PROGRAM SPECIFICS

2.1 Sampling Process Design

The specific monitoring, sampling and analysis plan for Response Action Monitoring is included

in Attachment B-2. The attachment details the monitoring, sampling and analysis to be

performed for each of the tasks described in the RD/RA Plan. Following is a summary of the

existing data.

2.1.1 Existing Data Used in the Remedial Design

The accompanying RD/RA Plan details specific remediation designs, which were based on data

previously collected at the SLRIDT Site from 1996 to the present.

Historical Database

Sample analysis results for all samples collected in the SedOU since 1996 are located in a

Microsoft Access database on the SERVICE computer server. Sample analysis results contained

in the SERVICE database have been reviewed for QA/QC compliance. Analytical results for

samples collected in accordance with this QAPP and Monitoring Plan will be added to the

SERVICE database. Attachment B-7 contains a description of the Electronic Data Deliverable

(EDD) specifications for reporting of all sample analysis data.

2.2 Sampling Method Requirements

Sampling methods detailed in Attachment B-2 vary depending on the media, required detection

limit and decision rules for each sample type. Field logs will be prepared during sampling,

which will include, at a minimum:

• Date and time of collection;

• Type of sample (media, grab or composite, aliquots, etc.);

• Sample ID (in accordance with SLRIDT sample naming protocols);

• Collector’s name;

• Analysis type;

• Sample purpose;

• Sample location.

Unless specifically exempted, samples will be placed on ice in a cooler, and transported to the

SERVICE field office for final preparation and submittal to the laboratory.


2.3 Sample Handling and Custody Requirements

All samples will be assigned a unique sample ID that identifies the project sample site and

sample location. Sample collection information will be included on the sample collection log

identified in Attachment B-4. Labels supplied by the laboratory with the sample containers will

also report the sample time and the person collecting the sample. Sample labels are to be

completed for each sample using permanent ink.

“Undisturbed” sediment core tubes (including vibracores, Shelby tubes, etc.) will be prepared for

transportation by securely fitting a watertight seal to the top and bottom of the tube and clearly

identifying the top of the core. The watertight seal may be made of plastic, rubber or wax, and

must be fastened securely. The core tubes will then be placed upright in the shipping container.

Undisturbed sediment core tubes will be shipped in appropriately sized, watertight containers.

The container will be obviously marked as “FRAGILE,” with a minimum of four arrows clearly

marked with “THIS SIDE UP.” Marking will be completed using a thick-tipped permanent

marker.

Composite sediment samples will be collected in stainless steel bowls or a clean five-gallon

plastic bucket, and homogenized using stainless steel utensils. Laboratory-supplied containers

appropriate to the analysis and containing the proper preservative, will be filled with

homogenized sediment, capped, labeled, and kept cool on ice pending shipment to the

laboratory.

Grab sediment samples will be collected directly into laboratory-supplied containers appropriate

to the analysis and containing the proper preservative, taking care to minimize handling of the

sediment. A gloved hand or stainless steel utensil may be used, but either must be dedicated or

cleaned using soap and water wash, with a hexane or cyclohexane rinse, and a deionized water

final rinse. The sample container will be capped, labeled, and kept cool on ice pending shipment

to the laboratory.

Composite water samples will be homogenized in a container large enough to contain all sample

aliquots and made of an inert material. The homogenized sample will be collected into

laboratory-supplied containers appropriate to the analysis and containing the proper preservative.


The sample container will be capped, labeled, and kept cool on ice pending shipment to the

laboratory.

Grab water samples will be collected directly into laboratory-supplied containers appropriate to

the analysis. If the container contains a preservative, the sample must be transferred from a

sampling vessel made of an inert material. The sample container will be capped, labeled, and

kept cool on ice pending shipment to the laboratory.

Air monitoring will be conducted as detailed in Attachment B-2, Section 1.0.

The field team leader, or his designee, will be responsible for the care and custody of the samples

until they are transferred. Under normal circumstances, samples will be shipped within 48 hours

of their collection. Hexavalent chromium samples will be delivered to the laboratory within 20

hours of sampling. The laboratory will be notified in advance of any hexavalent chromium

samples so they can extract the sample within 24 hours of collection, in accordance with the

holding time limit for this test.

Samples are considered collected when the sample container is filled. Samples will be in view of

the sampling crew at all times or locked in a secure area. Samples will be shipped via overnight

or local courier. The sample will be marked on the appropriate chain of custody form

(Attachment B-4) as relinquished to the shipping company tracking number. The shipping bill

or a copy of the shipping bill will be kept as proof of transfer of custody during sample shipment.

The laboratories will provide sample kits, including sample bottles, coolers, packaging material,

and chain of custody forms. The field team leader, or his designee, will ensure the samples are

packaged properly by keeping them cold, on ice in a cooler, and immobilized with packing

material to reduce the risk of breakage. Dry ice will not be used to cool samples. A temperature

blank will be included in each cooler sent to the laboratory. A copy of the chain of custody form

will be placed in a resealable bag and taped to the inside lid of the shipping container or cooler.

Coolers will be taped shut prior to shipment to ensure security of the samples. The laboratory

name and address, as well as the return name and address, will be clearly labeled on the outside

of the container or on the shipping billet. The samples are not classified as hazardous waste;


therefore, Department of Transportation regulations for hazardous waste will not apply for

laboratory analytical shipments.

Laboratory custody procedures for sample receiving and log-in, sample storage and numbering,

tracking during sample preparation and analysis, and storage of data will follow each

laboratory’s internal procedures. The procedures for Braun are given in Attachment B-5,

Sections 7.3 and 7.4. Pace’s internal procedures are shown in Attachment B-6, Section 2.0.

The SERVICE field team leader, or QA officer, will be notified immediately of any difficulties

including identification, sample integrity or uncertainty regarding requested testing. The

samples will be stored in darkness at 4oC until they are prepared for testing.

The chain-of-custody will constitute the analytical request from SERVICE and the sample

tracking record for the project files, with the original copy delivered to SERVICE with the hard

copy of the analytical results.

When the laboratory is done using the sample, it will retain the sample until authorized to

dispose by SERVICE. The laboratory will notify SERVICE at least 48 hours prior to disposing

of samples per its in-house requirements.

2.4 Analytical Method Requirements

Laboratory analytical methods have been selected to ensure that MDL and PQL (Table B-2) for

each compound are sufficiently low to allow comparison with Cleanup Levels (Table B-7).

Corresponding lab SOPs are listed on Table B-2 with the respective analytical method.

Laboratory standard operating procedures are detailed in the Braun QA Manual and Laboratory

SOPs (Attachment B-5) and Pace QA Manual and Laboratory SOPs (Attachment B-6).

2.5 Analytical Quality Control Requirements

The analytical QC parameters are described in detail in the following sections. Table B-8 lists

the QC parameters that will be reviewed when performing data verification.

2.5.1 Precision

Precision is a measure of agreement among replicate measurements of the same property, under

similar prescribed conditions. This agreement is calculated as a percentage of the mean of the


measurements, such as relative percent difference (RPD) or relative standard deviation (RSD)

(for three or more replicates).

Field precision is assessed through the collection and measurement of field replicates at a rate of

one duplicate per ten analytical samples. This allows precision information to be obtained on

sample acquisition, handling, shipping, storage, preparation, and analysis. Both samples can be

carried through the steps in the measurement process together to provide an estimate of

precision. Precision control limits are presented in Attachment B-5, Appendix E-2 for Braun

and Attachment B-6, MN-O-534-B SOP for Pace.

For duplicate measurements, relative percent difference (RPD) is calculated as follows:

RPD (%) = ((D1 - D2) x 100)/((D1 + D2)/2)

where:

RPD = relative percent difference

D1 = sample value

D2 = duplicate sample value

2.5.2 Bias

Bias is the systematic or persistent distortion of a measurement process that causes errors in one

direction. Bias assessments for environmental measurements are made using personnel,

equipment, and spiking materials or reference materials as independent as possible from those

used in the calibration of the measurement system. When possible, bias assessments should be

based on analysis of spiked samples rather than reference materials so that the effect of the

matrix on recovery is incorporated into the assessment. A documented spiking protocol and

consistency in following that protocol are important to obtaining meaningful data quality

estimates. See additional discussion of spikes below.

2.5.3 Accuracy

Accuracy is defined as the difference between a measured value and the true value of a

parameter being measured. Accuracy is assessed through the analysis of reagent blanks,

laboratory control samples (LCSs), and matrix spike samples. Primary measures of accuracy in

this study are laboratory control spikes and matrix spikes. In order to assure the accuracy of the


analytical procedures, an environmental sample will be collected in triplicate (Sample/Matrix

Spike/Matrix Spike Duplicate) and spiked with a known amount of the analytes to be evaluated.

In general, a sample spike and duplicate spike will be included as per the approved method or

one set in every 20 samples tested on each instrument. The spike samples will then be analyzed.

The increase in concentration of the analyte observed in the spiked sample, due to the addition of

a known quantity of the analyte, compared to the reported value of the same analyte in the

unspiked sample determines the percent recovery. The percent recovery for a spiked sample is

calculated according to the following formula:

%R = 100 x (S-U)/Csa

where:

%R = percent recovery

S = measured concentration in spiked sample

U = measured concentration in unspiked sample

Csa = actual concentration of spike added

For situations where a standard reference material is used in addition to a matrix spike:

%R = 100 x Cm/Csrm

where:

%R = percent recovery

Cm = measured concentration of SRM

Csrm = actual concentration of SRM

The analytical DQIs for accuracy and spike recovering limits are given in Attachment B-5,

Appendix E-2 for Braun and Attachment B-6, MN-O-534-B SOP, Section XIII for Pace.

In recognition of the documented matrix interferences found in sediments at the SLRIDT Site,

failure of a MS or MSD to meet the limits specified in Attachment B-5, Appendix E-2 for Braun

when the LCS and LCSD are within limits can be attributed to matrix interference. For Pace

Method TO-13, insufficient sample volume is typically provided for an MS/MSD, if a set were

extracted, it would be evaluated against the LCS/LCSD criteria until sufficient data points were

collected to create internally generated QC limits (Attachment B-6, MN-O-534-B SOP). Also,


if the spike concentration is less than the measured concentration from the environmental

sample, or if there is a 10 to one or greater dilution after addition of the spike, the sample may

still be accepted if the LCS and LCSD and surrogates are within limits. The sample must still be

appropriately flagged. Samples that fail these criteria shall be appropriately flagged in the

laboratory report narratives and in the laboratory data review summary.

2.5.4 Sensitivity

The sensitivity of a measurement is expressed as the method detection limit. The reporting limits

(RL) shown in Table B-2 are low enough to meet the project objectives.

2.5.5 Completeness

Completeness is a measure of the amount of valid data obtained from a measurement system

compared to the amount that was expected under normal conditions. Field completeness is a

measure of the amount of valid measurements obtained from all the measurements taken in the

project. Field completeness for this project will be greater than 90%. Laboratory completeness

is a measure of the amount of valid measurements obtained from all the measurements taken in

the project. Laboratory completeness for this project will be greater than 95% of the total

number of samples submitted to the analytical laboratories. The calculation for percent

completeness is as follows:

%C = 100% x (V/n)

where;

%C = percent completeness

V = number of valid measurements

n = number of measurements planned

Where found valid, using CLP guidelines, flagged data may be counted as part of V. Rejected

data is not valid.

2.5.6 Representativeness

Representativeness expresses the degree to which data accurately and precisely represent a

characteristic of a population, parameter variations at a sampling point, a process condition, or an

environmental condition. Representativeness is a qualitative term that should be evaluated to


determine whether in situ and other measurements are made and physical samples collected in

such a manner that the resulting data appropriately reflect the media and phenomenon measured

or studied.

For field data, representativeness is dependent upon the proper design of the sampling program

and will be satisfied by ensuring that protocols identified in this QAPP and Monitoring Plan are

followed and that proper sampling techniques are consistently used.

Representativeness in the laboratory is ensured by using the proper analytical procedures;

meeting sample holding times; and analyzing and assessing laboratory duplicates for the

chemistry samples.

2.5.7 Comparability

Comparability is the qualitative term that expresses the confidence that two data sets can

contribute to a common analysis and interpolation. Comparability must be carefully evaluated to

establish whether two data sets can be considered equivalent in regard to the measurement of a

specific variable or groups of variables. In a laboratory analysis, the term comparability focuses

on method type comparison, holding times, stability issues, and aspects of overall analytical

quantitation.

There are a number of controls that can make two data sets comparable, and the presence of each

of the following items enhances their comparability:

• Two data sets should contain the same set of variables of interest;

• Units in which these variables were measured should be convertible to a common metric;

• Similar analytical procedures and quality assurance should be used to collect data for

both data sets;

• Time measurements of certain characteristics (variables) should be similar for both data

sets;

• Measuring devices used for both data sets should have approximately similar detection

levels;

• Rules for excluding certain types of observations from both samples should be similar;

• Samples within data sets should be selected in a similar manner;

• Sampling frames from which the samples were selected should be similar; and


• Number of observations in both data sets should be of the same order or magnitude.

These characteristics vary in importance depending on the final use of the data. The closer two

data sets are with regard to these characteristics, the more appropriate it will be to compare them.

For this investigation, comparability will be satisfied by ensuring that the field sampling plan is

followed and that proper sampling techniques are used. Field data will be comparable with data

sets that use these same methods and equipment.

To assure the accuracy of the measurements, the laboratories will follow general quality control

protocol (i.e. analysis of replicates, analysis of standards and method blanks, and daily

calibration of instruments according to manufacturer guidelines).

All equipment used in the labs is inspected daily and maintained per manufacturer

recommendations for each specific instrument. Blank and check samples are run daily and

results are recorded and compared with previous results to verify and document that the

instruments are operating properly.

2.5.8 Blank, Standard & Check Sample Procedure

The following QC samples will be collected and analyzed in the laboratory. One MS/MSD set

will be analyzed per 20 samples collected, to determine matrix interference with a minimum of

one set per analyte. One duplicate sample will be analyzed per 10 samples collected, with a

minimum of one sample per analyte. One trip blank will be analyzed for volatile organic

compounds per sample cooler. One field blank will be collected per sample crew per piece of

sampling equipment, except for equipment that is dedicated or does not interface with the

sample. A temperature blank will be included in each cooler sent to the laboratory. All

laboratory QC data will be reported to SERVICE via the EDD SOP detailed in Attachment B-7.

In addition, Braun and PACE will provide a narrative summary of QC issues, the corrective

actions taken with regard to the QC data, and whether in the opinion of Braun and PACE, the

data QC is acceptable. SERVICE will review the data to verify the laboratory QC and field data

logs and will make an independent determination as to the quality of the data. The laboratory-

specific QC procedures, certifications, and internal and external laboratory audits are presented

throughout Attachment B-5 and Attachment B-6. Internal and external laboratory audits are

discussed in Attachment B-5, Section 2.4 and 2.5 for Braun and Attachment B-6, Section 8.1


and 8.2 for Pace. Certifications for Braun and Pace are included in Attachment B-5, Section 2.6

and Appendix D-1 and Attachment B-6, Certifications, respectively. The QC parameters for

each analyte will be based on the most updated MDLs. QC data limits established in this QAPP

are summarized in Attachment B-5, Appendix E-2 for Braun and Attachment B-6, SOP MN-

O-534-B, Section XI for Pace. The laboratories will be responsible for submitting any updates to

QC data limits to the SERVICE QA officer, who will then provide these changes to the

individuals identified in Section 1.1.

2.6 Instrument/Equipment Testing, Inspection, and Maintenance Requirements

A list of Braun’s lab equipment and maintenance procedures is included in Appendix N-1 in the

attached Braun Intertec QA Manual located in Attachment B-5. Corrective actions for

identified equipment problems are detailed in Appendix N-1of Attachment B-5. The equipment

used by Pace is identified on page 6 of the MN-O-534-B SOP located in Attachment B-6. Pace

preventative maintenance and corrective actions are described in Pace’s SOP for Maintenance

and Maintenance Procedures as well as on the Equipment List and Preventative

Maintenance Schedule: TO-13, which can be found at the end of the Pace QA Manual in

Attachment B-6. Field equipment will be maintained and corrective action taken in accordance

with manufacturers recommendations. A preventative maintenance and corrective actions

schedule for field instruments is detailed on Table B-10.

2.7 Instrument Calibration and Frequency

Numerous field instruments will be used to monitor air, water, sediment, noise and other media

during completion of RA activities. Each of these instruments will be maintained and calibrated

in accordance with its maintenance and operating manuals. Standards supplied by the

manufacturer or other approved supplier will be used for calibration. The field team leader is

responsible for assuring inspection, maintenance, and calibration of the field equipment. If

testing or sampling was conducted while using faulty equipment, re-sampling will be the typical

corrective action.

Laboratory equipment will be inspected, maintained and calibrated in accordance with each

laboratory’s QA/QC program and the requirements of the methods used for the specified testing.

Braun’s protocol for the maintenance and calibration of equipment is given in Attachment B-5,

Sections 8.0 and 9.3. Attachment B-5, Appendix F-1 provides a QC summary including


calibration requirements, frequency, acceptance criteria, and corrective action for each analysis

method. Specific calibration information is addressed in the SOP of the applicable method.

Calibration records are stored in the appropriate data packet, which is traceable through the

Laboratory Information Management System to individual sample numbers and are retained

according to Braun’s record keeping procedures as detailed in Attachment B-5, Sections 6.0. At

a minimum Braun uses a linear calibration curve. Organic chemistry utilizes a minimum of 5

points and inorganic chemistry utilizes a minimum of 4 points. The protocol for Pace’s

maintenance and calibration of equipment is shown in Attachment B-6, Section 6.0 and MN-O-

534-B SOP, Section XI. Specific calibration information including calibration requirements,

frequency, acceptance criteria, and corrective action, for Pace is addressed in Attachment B-6,

Pace MN-O-534-B SOP, Section XII, Subsections C and D and Table 6.1 in Attachment B-6,

Pace Quality Manual, Midwest Regional Addendum. Calibration records are stored and retained

according to Pace's record keeping procedures as detailed in Attachment B-6, Pace Quality

Manual, Section 7.4. Information regarding calibration standards purity, testing, and traceability

is maintained in accordance with the procedures given in Attachment B-6, Pace Quality

Manual, Section 6.1, page 35. At a minimum Pace uses a linear calibration curve. Organic

chemistry utilizes a minimum of 5 points and inorganic chemistry utilizes a minimum of 3

points.

2.8 Inspection Acceptance Requirements for Supplies and Consumables

The main supplies that will come in contact with the samples are disposable samplers, which will

be used once and discarded and inert bowls and spoons which will be cleaned between uses with

a soap and water wash, hexane or cyclohexane, and final deionized water rinse. All

preservatives, sample jars and containers will be supplied by the laboratory and certified new and

clean.

Braun and Pace use only off-site support services that are of adequate quality to sustain

confidence in the laboratory tests. Records of suppliers for services or supplies required for tests

are maintained. Braun’s procedure for the use of suppliers is given in Attachment B-5, Sections

7.2, 7.8, and 10.3.4. The protocol for Pace’s use of suppliers is shown in Attachment B-6,

Section 6.1 and MN-O-534-B SOP, Section X. Pace will supply the cartridges used for TO-13

analysis sampling. Pace’s procedure for cartridge preparation is given in Attachment B-6, MN-


O-534-B SOP, Section VIII. Labels including the following information on receipt and testing

shall be used for critical supplies:

• Unique identification number;

• Date received;

• Date opened;

• Expiration date.

Method blanks are prepared and analyzed with each sample batch in order to validate the purity

of all the reagents and solvents used in the analytical procedure.

2.9 Data Acquisition Requirements for Non-Direct Measurements

Previously collected data gathered by the Companies consultants, MPCA, and EPA on the Site

will be used in conjunction with the newly gathered data for analyses and evaluation. Existing

site data has been collected using methods and procedures detailed in several previous MPCA-

approved Work Plans. Data collected during the initial RI/FS by IT (1996 to 1998) was

collected and analyzed in accordance with an MPCA-approved Work Plan dated November

1995. Data collected by SERVICE during the Data Gap investigation was collected and

analyzed in accordance with four MPCA-approved Work Plans, prepared in July 26, 2000,

August 31, 2000, March 7, 2001, and April 2, 2001. Data collected by SERVICE prior to the

Data Gap investigation was not collected and analyzed in accordance with an MPCA-approved

Work Plan, but was collected using similar methods and procedures to those detailed in the IT

and SERVICE Work Plans. The sampling and analysis methods and procedures detailed in this

QAPP is consistent with the previously completed Work Plans, so the RA monitoring data will

be comparable to the historical data at the Site.

2.10 Data Management

Data generated during all response actions will be managed by the SERVICE database manager,

under the direction of the SERVICE QA officer. Electronic data will be stored in the Access

database maintained on the SERVICE computer server, under the direction of the SERVICE

database manager. Hard copy paper data, including field logs and notebooks, will be submitted

on a daily basis to the SERVICE field team leader, or his designee. Hard copy paper data will

then be maintained at the SERVICE St. Paul or Duluth offices by SERVICE database manager,

or her designee.


Data generated during all response actions will flow according to the following chart:

All data recorded on log forms or in notebooks will provide as much detail as possible, to avoid

the reliance on memory. Entries will be written in ink, with errors crossed out with a single

strike. Erasures are not permitted.

Electronic data will be stored on the SERVICE computer server, which is backed up regularly.

The backup server tapes are stored in a fireproof safe at the SERVICE office in St. Paul.

See Section 17.0 of the RD/RA Plan for more detailed a discussion of record retention.

Braun internal data management, including document control, data handling and reporting, and

record keeping will be as described in Sections 4, 5, and 6, respectively, of Attachment B-5.


Pace internal data management, including document control and change, and control of data will

be as described in Section 5 and 7, respectively, of Attachment B-6.

2.10.1 Electronic Data Deliverable Requirements

All subcontracted laboratories will report analytical results to SERVICE in accordance with the

EDD SOP included in Attachment B-7. It will be the responsibility of the laboratory to ensure

that all data entry, transposition and/or manipulation are completed prior to submitting the data

electronically to SERVICE. If SERVICE identifies code or data entry errors in an EDD, it will

be the responsibility of the subcontract laboratory to remedy the error(s) in a timely manner, as

directed by SERVICE. The standard turnaround time is eight to ten working days for Braun and

fourteen days for Pace.

In addition to the EDD submitted by Braun and Pace, the laboratory reports will include a

QA/QC narrative summary detailing any problems or inconsistencies.


3.0 ASSESSMENT AND REPORTING

Quality assurance will be assessed throughout the project, during audits and reviews. Errors and

omissions will be identified, documented, and remedied throughout the monitoring, sampling

and analysis of the remediation activities. Each chemistry laboratory report will include a case

narrative describing the QA/QC performed for that batch of samples. Similarly, each materials

testing laboratory report will include a discussion of any QA/QC issues encountered during

testing. (Please see Attachment B-5, Section 5.2 for Braun and Attachment B-6, Section 7.3

for Pace for an outline of the minimum requirements of a laboratory report.) The custom EDD

format for this project is outlined in Attachment B-7.

Annual QA/QC reports will be submitted to the MPCA. The Completion Report will include a

discussion of the QA/QC monitoring and any problems identified and solutions implemented.

3.1 Assessment and Response Actions

Quality control checks for laboratory equipment will be performed per manufacturers

instructions, or per laboratory procedures. (Please see Attachment B-5, Section 8, Appendix F-

1, and Appendix N-1 for Braun and Attachment B-6, MN-O-534-B SOP, Section XIII.A for

Pace)

If during laboratory or field work it is discovered that any equipment that obtains direct reading

measurements is not operating properly, the equipment will be repaired. A record of the

problems encountered, how they were resolved, and how previous data was evaluated for

accuracy will be documented in the logbooks and included in a report to SERVICE.

Audits may be conducted in the lab as described in Attachment B-5, Section 2.4 and 2.5 for

Braun and Attachment B-6, Section 8 for Pace. The SERVICE QA officer will conduct, at a

minimum, annual laboratory audits of Braun and Pace. A laboratory audit checklist is given in

Table B-9.

The frequency of Braun’s internal audits is dependent on the type of information being audited.

Documents are audited annually. Facilities are audited at a minimum of twice annually. Data is

audited at a minimal rate of one data item per month. Regulatory agencies, accrediting

authorities, and clients perform external audits. Regulatory agencies include the Minnesota


Department of Health, the Wisconsin Department of Natural Resources, the National Voluntary

Laboratory Accreditation Program (NVLAP), and the American Industrial Hygiene Association

(AIHA). Results, documentation and corrective action for internal and external audits are

discussed in Attachment B-5, Section 2.4.8 and Section 2.5.2, respectively.

Pace’s internal audits are conducted yearly at a minimum and include the following: quality

system documents, personnel and training files, safety protocols, equipment and instrumentation

documents, calibration/maintenance records, operating manuals, sample receipts and

management practices, analytical documentation, and general procedure of data security, review,

documentation, reporting, and archiving. Regulatory agencies and clients perform external

audits. Regulatory agencies include the Minnesota Department of Health, the Wisconsin

Department of Natural Resources, and the National Environmental Laboratory Accreditation

Program. Results, documentation and corrective action for internal and external audits are

discussed in Attachment B-6, Section 8.1.3, Section 8.2 and Section 9.2.7.

Field audits will be performed monthly during times when work is occurring at the Site. Field

audits will be performed by the field team leader or their designee. Field audits will include a

site visit by the auditor to observe a particular field monitoring and/or sampling task, a review of

all task-generated paperwork and a debriefing session with individuals involved in performing

the task.

3.2 Reports to Management

A QA/QC report will be prepared by SERVICE and submitted to the MPCA with the

Completion Report. Interim QA/QC reports will be submitted twice during the year, one QA/QC

report will be prepared two months after construction begins and the other upon completion of

construction activities for the year, to ensure that problems arising during the project are

investigated and corrected. The QA reports will contain:

• Data validation and assessment results;

• Field audit results;

• Significant QA/QC problems, recommended solutions, and results of corrective actions

undertaken;

• Status of report on data quality assessment (DQA), e.g., stating the extent to which the

project DQO was satisfied;


• Minor changes in the QAPP;

• Summary of QA/QC programs, training and other miscellaneous accomplishments;

• Results of technical systems and performance evaluation audits;

• Data quality assessment in terms of precision, accuracy, representativeness,

completeness, comparability, and detection limits;

• Indication of whether the QA objectives were met; and

• Limitation on use of the measurement data.


4.0 REVIEW, VALIDATION AND VERIFICATION

The primary objective of the QA/QC procedures outlined in this section is to ensure that the data

generated in this project is accurate.

4.1 Data Review Methods

Data generated in the field will be reviewed by the SERVICE field team leader, or his designee,

as soon as is practicable following collection to ensure that all DQOs are met. The SERVICE

QA officer will audit the field-generated data on a regular basis, to verify the SERVICE field

team leader’s review.

Materials testing laboratory data will be reviewed, validated and verified by the SERVICE QA

officer, or his designee, to ensure that all DQOs are met.

Data generated by Braun will be reviewed, validated and verified as Attachment B-5, Section

5.1. Data generated by Pace will be reviewed, validated, and verified as described in

Attachment B-6, Sections 7.2.

4.2 Validation and Verification Methods

Data reduction addresses data transformation operations such as converting raw data into

reportable quantities and units, use of significant figures, recording of extreme values, blank

corrections, et cetera. Data verification ensures the accuracy of data transcription and

calculations, if necessary, by checking a set of computer calculations manually. Data validation

ensures that QC criteria have been met.

Utilizing laboratory EDD will minimize data reduction. Electronic data will be provided in the

form specified in the SOP presented in Attachment B-7 for direct insertion into the site database

and GIS system. For data received in other tabular forms such as spreadsheets or word

processing tables, the data will be converted into a form importable to Access. Any required

reduction of data such as: conversion of sample names, addition of data on sample depth,

conversion of formulas to values, conversion to dry weight, adjusting non-detects to half the

detection limit, deletion of extraneous fields or records, and transposing rows and columns will

be documented in accordance with SERVICE procedures on database input (previously provided

to the MPCA). This is the same procedure applied to historical data when entering it into the


Site database. Reentry of data will be avoided wherever possible. All data reduction and all

reentered data will be 100% check printed by a peer reviewer. The data will be managed and

reported from the Site database by the SERVICE database manager. QC reports will be

presented annually. The goal is to have 100 percent accurate data reduction.

The laboratory verifies and validates its information in the first instance and indicates in its cover

letter or narrative which data exceeded QC criteria defined in the methods, the laboratory’s

QA/QC program or this plan. The laboratory is responsible for investigating these variances and

recommending if the data should be qualified. Qualified SERVICE staff, assigned by the project

manager, will conduct a second data review. Upon receipt of the data, the SERVICE QA

manager, or his designee will evaluate the duplicate precision, accuracy (spike and surrogate

recoveries), holding times, representativeness, blanks and the narratives by the laboratories.

Table B-8 includes all QC parameters to be reviewed by the SERVICE QA manager. The

review will be summarized in annual QC reports. Upon its review, the MPCA may accept, reject

or modify these conclusions in its comments on the draft report. All data qualifiers will be noted

in the analytical data summary tables and on the laboratory reports.

4.2.1 Procedures Used to Verify Field Instrument Data

Procedures to evaluate field data for this project primarily include checking for transcription

errors and reviewing field forms, notebooks, and calibration logs. This task will be the

responsibility of SERVICE field team leader.

Completed field monitoring forms (Attachment B-4) will be reviewed by the field team leader

(environmental), site engineer (geotechnical), Paul Voge (surveying), or their designees, for

completeness as soon as possible after field activities are completed. Any identified errors or

omissions will be corrected or flagged immediately. The sampling personnel and reviewer will

initial all edits or additions. A single strike-through will constitute a deletion. If in the field

form reviewer’s opinion, the monitoring must be completed a second time to obtain the proper

data, the additional monitoring event will be performed as soon as possible, a new, clean

monitoring form will be used and the reason for the additional monitoring will be clearly stated

on the new form.


4.2.2 Procedures Used to Verify Laboratory Data

The QA officer will conduct a systematic review of the analytical data for compliance with the

established QC criteria (Table B-8) based on the spike, duplicate, and blank results provided by

the laboratory. All technical holding times will be reviewed, the instrument performance check

sample results will be evaluated, and results of initial and continuing calibration will be reviewed

and evaluated. One hundred percent of the analytical data will be evaluated.

The data review will identify any out-of-control data points and data omissions, and the QA

Officer, will interact with the laboratory to correct data deficiencies. Decisions to repeat sample

collection and analysis may be made by SERVICE based on the extent of the deficiencies and

their importance in the overall context of the project.

If during laboratory work it is discovered that any laboratory equipment which obtains direct

reading measurements is not operating properly, laboratory work shall cease until new

equipment can be obtained to complete work or until the equipment can be repaired. If previous

readings appear to be inaccurate, all measurements shall be redone. Record of the problems

encountered, how they were resolved, and how previous data was evaluated for accuracy will be

documented in the logbooks.

All QA/QC concerns will be reported to the SERVICE QA officer. Significant problems and/or

changes related to the QAPP will be reconciled with Jane Mosel, MPCA Project Manager, Mike

Bares, MPCA hydrogeologist, and/or Luke Charpentier, MPCA QA Coordinator.

4.3 Reconciliation with User Requirements

If project results are inconsistent with the DQO outlined in this document, a resolution will be

formulated between applicable project personnel, including, at a minimum, the SERVICE QA

officer, SERVICE field team leader, SERVICE site engineer, SERVICE project manager and

MPCA project team. The response action goals and measures of success are determined by

meeting the response action objectives (RAOs), cleanup levels, and other requirements of the

MPCA ROD, detailed in Section 3.2, 3.3 and 3.4 of the ROD.

Based on the acceptability of the data via the verification and validation procedures detailed

above, RA data will be evaluated for completeness, as described in Section 2.5.5. Field


completeness for this project will be greater than 90%. Laboratory completeness for this project

will be greater than 95% of the total number of samples submitted to the analytical laboratories.

Flagged data will be evaluated for inclusion in the RA data set. If it is determined that flagged

data may be used for comparison to the RAOs and Cleanup Levels, a discussion of the reasons

for accepting this data will be provided with the data.


5.0 REFERENCES

Crane J.L., D.D. MacDonald, C.G. Ingersoll, D.E. Smorong, R.A. Lindskoog, C.G. Severn, T.A.

Berger, and L.J. Field. 2000. Development of a framework for evaluating numerical sediment

quality targets and sediment contamination in the St. Louis River Area of Concern. EPA-905-R-

00-008. Great Lakes National Program Office, United States Environmental Protection Agency,

Chicago, Illinois.

EPA/USACE 1998. Evaluation of Dredged Material Proposed for Discharge in Waters of the

U.S. – Testing Manual. EPA-823-B-98-001. Washington, D.C.

EPA 2000. Data Quality Objectives Process for Hazardous Waste Site Investigations. EPA

Office of Environmental Information, EPA/600/R-00/007, January, 2000.

IT 1997a. Remedial Investigation Data Report, Sediment Operable Unit, St. Louis

River/Interlake/Duluth Tar Site: Duluth, Minnesota, IT Corporation, May 1997.

IT 1997b. Draft Alternatives Screening Report, Sediment Operable Unit, St. Louis

River/Interlake/Duluth Tar Site, Duluth Minnesota, IT Corporation, December 1997.

IT 1998. Draft Feasibility Study Report, Sediment Operable Unit, St. Louis

River/Interlake/Duluth Tar Site, Duluth Minnesota, IT Corporation, June 1998.

MDH 2003. Air Health-based Value for Naphthalene, Memorandum by Hillary Carpenter,

Minnesota Department of Health, February 19, 2003.

SERVICE 1999a. Focused Feasibility Study Update, Thick Cap Alternative, SLRIDT Site,

Duluth, Minnesota, SERVICE Environmental and Engineering, June 25, 1999

SERVICE 1999b. Supplemental Detailed Analysis Report, Wetland Cap Alternative, SLRIDT

Site, Duluth, Minnesota, SERVICE Environmental and Engineering, September 16, 1999

SERVICE 2002. Data Gap Report, St. Louis River/Interlake/Duluth Tar Site, Duluth,

Minnesota, SERVICE Engineering Group, November 27, 2002.


SERVICE 2003. Revised Draft Feasibility Study, St. Louis River/Interlake/Duluth Tar Site,

Duluth, Minnesota, SERVICE Engineering Group, December 30, 2003.

SERVICE 2004. Feasibility Study Revised Addendum No. 1, St. Louis River/Interlake/Duluth

Tar Site, Duluth, Minnesota, SERVICE Engineering Group, March 29, 2004.

APPENDIX B TABLES

(NOT INCLUDED)

ATTACHMENT B-1

PRE-RESPONSE ACTION MONITORING PLAN

(NOT INCLUDED)

ATTACHMENT B-2

RESPONSE ACTION MONITORING PLAN

99006-K SLRIDT RD Attachment B-2 092305.doc 1

Attachment B-2

Quality Assurance Project Plan and Monitoring Plan:

Response Action Monitoring and Sampling Plan

TABLE OF CONTENTS

1.0 AIR MONITORING........................................................................................................... 2 1.1 Air Emission Thresholds and Requirements........................................................... 2 1.2 Acute Monitoring Procedures ................................................................................. 3

1.2.1 ArSLID System........................................................................................... 3 1.3 Chronic Monitoring Procedures.............................................................................. 4 1.4 Reporting................................................................................................................. 5

2.0 NOISE MONITORING...................................................................................................... 7 3.0 SURFACE WATER ........................................................................................................... 9

3.1 Surface Water Outside the Treatment/Work Zone ................................................. 9 3.2 Reintegration of Treatment/Work Zone with River.............................................. 10 3.3 Treated Water....................................................................................................... 10

4.0 SURVEYING ................................................................................................................... 12 5.0 COMPOST MATERIAL.................................................................................................. 13 6.0 DREDGE RESIDUAL AND POST DREDGE VERIFICATION SAMPLING ............. 14 7.0 CAP THICKNESS AND SETTLEMENT MONITORING............................................. 16

7.1 Settlement plates ................................................................................................... 16 7.2 Settlement Cells and Profilers............................................................................... 16 7.3 Vibrating Wire Piezometers.................................................................................. 17 7.4 Coring ................................................................................................................... 17

8.0 BORROW MATERIAL TESTING.................................................................................. 18


1.0 AIR MONITORING

The Air Monitoring plan will include the following components based on site activities,

proposed monitoring methods, and requirements of the ROD:

1) Monitor acute exposure levels during response action operations with real-time

analysis using Aromatic Specific Laser Ionization Detector (ArSLID).

2) Monitor chronic exposure levels during response action operations using High

Volume Polyurethane Foam (PUF) samplers with XAD Resin.

3) Fugitive Dust Management by Visual Observation

The criteria for each and the sampling details are presented below.

1.1 Air Emission Thresholds and Requirements

Perimeter air monitoring will be performed to compare the hourly naphthalene concentrations to

actions thresholds presented in Table 3.2.4-1 of the ROD and reproduced below.

200-400 µg/m3 Increased monitoring: In the event air concentrations of naphthalene

reach 200-400 µg/m3, monitoring frequency will be increased and steps

will be taken to reduce emissions.

2,000 µg/m3 Discontinuation of dredging or other water activities.

20,000 µg/m3 Consideration of relocation of residents.

Perimeter air monitoring will also be performed using 48-hour samples to compare the

construction season’s average naphthalene concentration to the Minnesota Department of Health

(MDH) site-specific Chronic Health-Based Value (HBV) of 9 µg/m3 or 1.7 parts per billion by

volume (ppbv). The MDH has established a site-specific one-hour acute HBV of 38 ppbv (200

µg/m3).

Since most of the material during capping and dredging operations will be handled in a wet

condition, the MPCA has indicated particulate sampling will not be required. During trucking

and material handling of dry sand, observations will be made for visible dust emissions. Road

watering or water spraying will be implemented if visible dust is observed from response actions.


1.2 Acute Monitoring Procedures

1.2.1 ArSLID System

To measure concentrations for the acute average hourly thresholds, a real-time monitoring

analyzer will be used that was developed by Dakota Technologies, Inc (DTI). The ArSLID is

designed to measure aromatic compounds at very low concentrations in air. The ArSLID is

based on the spectroscopic technique referred to as resonance enhanced multi photon ionization

(REMPI). In the REMPI process, molecules with one or more aromatic rings can absorb

ultraviolet photons to become electronically excited. The threshold concentration of interest is

38 ppbv (200µg/m3) on an average hourly basis. This instrument is capable of measuring below

this value and, therefore, is viable for use, but may not be able to measure low enough to meet

the chronic standard of 1.7 ppbv (9 µg/m3). The procedures and methods for operation and

calibration are given in the ArSLID information in Attachment B-10.

The ArSLID system is capable of averaging naphthalene measurements at the required hourly

intervals. These measurements will be transmitted to the data logger, which will record the

hourly averages.

The acute monitoring instrumentation is capable of generating a 0 to 5 volt output signal that will

be transmitted using radio frequencies (RF) to a receiver attached to the on-Site weather station

data-logger manufactured by NovaLynx. The data-logger is programmed to record data at five-

minute intervals for wind speed and direction, temperature, precipitation and humidity. The

weather station data logger is equipped with an RF receiver to receive this data and then transmit

to an on-Site laboratory office computer receiver to download at five-minute intervals. The

weather and naphthalene data will be displayed using NovaLynx Graphical Display Software. A

screen example is shown.

The screen will be tailored to show wind speed and direction, temperature from the weather

station and average hourly naphthalene concentrations from the analyzer locations. Air

monitoring will be performed 24 hours per day, seven days per week during activity on the water

at the Site. If emissions at any of the four monitoring locations approach or exceed 76 ppbv (400

ug/m3) on the ArSLID monitor, efforts will be made to reduce emissions. If naphthalene

concentrations exceed 190 ppbv (1,000 ug/m3) on any of the ArSLID monitors, Jane Mosel of


the MPCA will immediately be notified on her cell phone. If naphthalene concentrations exceed

380 ppbv (2,000 ug/m3) on any of the ArSLID monitors , operations creating the emissions will

immediately be discontinued until emissions improve.

Four fixed stations will utilize an ArSLID detector for continuous monitoring near the site

receptors. The four fixed locations are shown in Figure 13-1.

Separate channels will show naphthalene equivalent results on a real-time basis for each station.

The data display will be logged onto the Internet from the laboratory computer to allow viewing

remotely by SERVICE personnel. Data will be posted on the project website so that hourly

trends, including the most recent hourly average concentration can be viewed. The laboratory

software/computer system will include alarms to notify SERVICE personnel pagers or cell

phones of conditions requiring repair or if potential exceedances of the MPCA acute threshold

level has occurred.

1.3 Chronic Monitoring Procedures

Chronic monitoring of naphthalene will be conducted in accordance with EPA Method TO-13A.

This method will use a high volume Polyurethane Foam (PUF) air sampler that have sandwiched

XAD resin. The sampling will be conducted over 48 hours to collect 600 cubic meters of air at a

flow rate of approximately 0.225 cubic meters per minute (m3/min). Samples will be collected at

each of the two chronic monitoring stations (shown in Figure 13-1) once every six days. The


PUF/XAD samples will be removed after 48 hours, iced and shipped to the laboratory for

analysis within the recommended 1-week holding time.

The chronic air monitoring will be conducted using a Tisch Environmental, Inc. Poly-Urethane

Foam High Volume Air Sampler, Model Number TE-1000PUF. This unit is capable of a flow

rate of 200 – 280 Lpm (7 – 10 cfm). The unit will also use a microquartz filter to remove

particulates prior to the sandwiched PUF/XAD sampling media. The equipment will be hard

wired into existing utilities and will be collocated with two of the four acute monitoring stations.

The calibration and operating procedures for the chronic naphthalene monitoring are shown in

Attachment B-12.

Laboratory analysts will utilize GC/mass spectrometer (MS) selective ion monitoring (SIM) as

described in the PACE analytical SOP MN-O-534-B included in Attachment B-6. The

laboratory reporting limit for naphthalene is 0.1 µg per sample. Based on a 600 cubic meter air

sample over 48 hours, this method will have a reporting limit of 0.0002 µg/m3 (6.27 x 10-5

ppbv), which is lower than the chronic HBV standard of 9 µg/m3 (1.7ppbv). A log will be kept

for recording date, time, flow rate, sample number, and calibration data.

1.4 Reporting

A report will be prepared summarizing the hourly data from acute monitoring and 48-hour

average chronic monitoring results on a monthly basis. The reports will summarize the data and

make recommendations for adjustments of future monitoring of ambient air during response

action operations. If results show that emissions are not a concern during response actions, a

reduced or discontinued monitoring recommendation will be submitted to the MPCA. If the

MPCA approves the modifications, they will be implemented in subsequent sampling.

During the course of air monitoring, SERVICE and DTI may attempt to use the results from the

ArSLID and PUF/XAD tubes to establish a correlation between the ArSLID readings of all

aromatics and the naphthalene concentration. This correlation may be proposed to calculate a

correction factor to account for other PAHs that may be measured with naphthalene. All data

and calculations will be submitted to the MPCA for approval. Until such approval is given, it

will be assumed that the entire ArSLID reading is naphthalene concentration.


Detailed data from all the data loggers, ArSLID computer files and sampler histories will be

downloaded and stored in the SERVICE Duluth office files. All field data sheets and calibration

data will be stored in the SERVICE Duluth office files.


2.0 NOISE MONITORING

Noise associated with response action activities will be monitored in accordance with Minnesota

Rules Chapter 7030.0030 as presented in the MPCA Guide to Noise Control in Minnesota

(Attachment B-8). Noise area classifications will be identified at all monitoring locations.

Noise Area Classification 1 is assigned to monitoring areas near residential neighborhoods.

Monitoring locations near on-Site industrial leasees will be assigned Noise Area Classification

3. Assignment of noise area classifications will be consistent with Attachment B-8.

Noise monitoring will be conducted at two locations adjacent to residential neighborhoods and

one location near on-Site leasees (Figure 13-1). Noise will be measured and evaluated using a

portable sound level meter that conforms to Type 1 specifications under ANSI S1.4-1983 and

IEC 651 (BS5969). Noise monitoring equipment will be operated and calibrated in accordance

with manufacturer recommendations and will follow the procedures outlined in MPCA NTP-2

test procedures summarized in the MPCA Noise Control Manual included in Attachment B-8.

Daytime and nighttime noise control standards will be consistent with the standards outlined in

Table 3.1.3.3-1 of the ROD and repeated below.

Daytime Units Nighttime Units Noise Area Classification L50 L10 L50 L10

1 60 65 50 55

2 65 70 65 70

3 75 80 75 80

1. Residential.

2. Includes most businesses.

3. Manufacturing and Industrial (would includes railroad tracks and maritime shipping).

4. For details on Noise Area Classification, see Minn. Rule ch. 7030.0050

“L10” means the sound level, expressed in dB(A), which is, exceeded 10 percent of the time for a one hour survey,

as measured by test procedures approved by the commissioner.

“L50” means the sound level, expressed in dB(A), which is, exceeded 50 percent of the time for a one hour survey,

as measured by test procedures approved by the commissioner.

“Daytime” means those hours from 7:00 a.m. to 10:00 p.m.

“Nighttime” means those hours from 10:00 p.m. to 7:00 a.m.

dB(A) means a unit of sound pressure level expressed in decibels (dB) and A-weighted. Decibel means a unit of

sound pressure level, abbreviated as dB.


Noise will be monitored during response action monitoring operations at the location identified

in Figure 13-1 on a weekly basis. Whenever feasible, sample collection will be scheduled when

the wind direction is to the west, north or northwest and when the local manufacturing operations

are not sandblasting or otherwise producing significant local noise. Noise levels will also be

measured, when the MPCA, neighboring businesses, or homeowners request.

Worker noise exposure will be monitored as detailed in Appendix E.


3.0 SURFACE WATER

3.1 Surface Water Outside the Treatment/Work Zone

Surface water outside the Work Zone will be monitored weekly during response action activities

at locations identified in Figure 13-1, for parameters identified in Table B-7. Turbidity and pH

will be monitored using field meters.

A background surface water monitoring location has been selected to document surface water

quality upstream of the Site during the response action monitoring. It is located west of the Site

in the St. Louis River. This background location, in addition to a sample location downriver of

the Site, has been sampled as part of the pre-response action monitoring and the results will be

summarized in a separate report.

Surface water quality grab samples will be collected weekly during aquatic response actions

within 10 feet riverside of the water quality control structures. Where silt curtains are used, the

water quality grab samples will be collected from either the upper two feet of the water column

or the bottom two feet of the water column every 400 linear feet of silt curtain depending on the

silt curtain configuration. If the silt curtain is open at the bottom, the grab sample will be

collected from the lower two feet of the water column. Similarly, if the silt curtain is open at the

top, the grab water sample will be collected from the upper two feet of the water column. Where

a water-filled dam or the end dike constitutes the outermost engineering control structure, one

water quality grab sample will be collected from the mid-point in the water column within 10

feet of the outside of the structure.

Water quality at each sampling point will be compared to the background river concentration and

water quality requirements defined in Table B-7. A turbidity value will be set at 25 NTU above

background river levels, collected upstream from the Site during the same sampling event.

Exceedances, of water quality requirements will be reported to the MPCA within 24 hours of

receiving the quantitative results. Because turbidity is not toxicity-based, greater than 25 NTU

exceedance of the background value would trigger inspection of the silt curtains, and discussion

with the MPCA. Exceedance of the turbidity value would not trigger a shut down of operations.

Additional sampling or increased sampling frequency may be required by the MPCA to

document the nature of the exceedance. After repeated exceedances of the turbidity value the


MPCA could require modifications to the approved water control structures as necessary to

protect water quality in the river. Silt curtains, whether anchored to the bed or not, often move in

the current, suspending nearby sediment. This local suspension may not be distinguishable for

some chemical parameters (e.g., metals and TSS) from suspension caused by dredging or

capping in the work area. In order to estimate the contribution from the silt curtain itself, if silt

curtains are configured to allow passage of water near the bed, water quality testing will be

conducted after the silt curtain is installed and prior to dredging or capping activity in the work

area. Contingency actions are outlined in Section 19.0 of the RD/RA Plan. If sample results

document favorable water quality control performance, a reduced parameter list may be

developed and submitted to the MPCA for approval.

3.2 Reintegration of Treatment/Work Zone with River

When individual response action activities are complete, or at the end of each construction

season, treatment/work zones will be reintegrated with the river when the water quality within

the work zone meets the cleanup levels outlined in Table B-7. Water quality will be measured

by monitoring inside the treatment/work zone, near the water quality control structure.

Reintegration monitoring will be conducted for the same parameters and regulatory standards

described for surface water sampling outside the treatment/work zone described above, or as may

be reduced by MPCA.

3.3 Treated Water

Prior to discharge to the St. Louis River, CAD water and compost and decontamination water

will be treated using Best Available Technology (BAT) and Best Technology in Process

Treatment (BT/PT) for those compounds as shown on Table B-7. It has been determined that

CAD water and compost and decontamination water will be treated using microfiltration

followed by activated carbon filtration.

Untreated water is passed through primary filtration consisting of a slant plate clarifier. This

water is then fed through a microfiltration system, followed by a series of activated carbon

columns. The microfiltration system will be operated and backwashed according to the selected

manufacturer’s specifications to avoid fouling. When the design parameters (carbon bed depth,

carbon efficiency, linear flow rate, etc.) have been determined, a frequency schedule for the


monitoring of the treated water between the two carbon columns will be submitted. The treated

water monitoring is used to determine when breakthrough of PAHs is imminent. The treated

water will be monitored for the presence of the PAH compounds listed in Table B-7.


4.0 SURVEYING

Bathymetric surveys will be performed prior to dredging and immediately after dredging is

completed.

Ninety percent of the bathymetric survey data will be within ½ contour interval (CI) of actual

elevations, in accordance with industry standards.

For survey areas with greater than two feet of water depth, hydrographic survey data will be

collected and one-foot contours will be created. For all survey areas with less than two feet of

water depth, one-foot contours will be created using conventional survey methods and will be

merged with the bathymetric surveys by the licensed surveyor.

Documentation will include a field notebook noting location, survey crewmembers, dates, times,

weather, field sketches, photographs and other pertinent data (e.g. computer calculations or

coordinates used to verify survey accuracy, closure notes, etc). Data recorded electronically will

be preserved on a compact disk (CD). A hard copy of all electronically obtained data will be

maintained. Record drawings will conform to the practice within the industry. All survey data

will be collected and analyzed under the supervision of the Registered Land Surveyor.


5.0 COMPOST MATERIAL

Aquatic plants harvested from Stryker Bay prior to dredging will be stockpiled on-Site and

allowed to decompose (Section 5.0). The harvested and composted material may be placed on

top of the dredged material and below the CAD cap. If the PAH content of the composted

material is low enough, it may be offered for approval by the MPCA to use as high carbon

Environmental Medium. If the compost pile causes exceedances of the MPCA’s RAO for air

quality during remedity construction (Section 3.2.4 of the ROD), then the compost pile will be

covered to reduce emissions. Water collected in the compost material containment area will be

discharged to the wastewater treatment plant from which the effluent will be treated using Best

Available Technology (BAT) and Best Technology in Process Treatment (BT/PT)as described in

Section 3.3.


6.0 DREDGE RESIDUAL AND POST DREDGE VERIFICATION SAMPLING

Environmental dredging is expected to leave residual contaminated sediment. The amount of

normal dredge residue is difficult to predict, but can be affected by water depth, the complexity

of the dredge prism, and the amount of overdredging allowed.

Because of these variables, two dredge pilot tests will be conducted to determine the normal

dredge residue in the dredging environments as described in Section 3.2.6 of the ROD.

Dredging of the Stryker Bay transition zone between the cap and dredge areas of Stryker Bay

and a dredge area in the Minnesota Channel, the location of which is yet to be determined, will

be used as pilot test areas. Measurement of dredge residue will be made using the Rapid Optical

Screening Tool (ROST) using laser-induced fluorescence (LIF) system. The real-time logging

tool will be used to define normal dredge residue in terms of thickness and PAH concentrations.

Operation and calibration procedures for the ROST/LIF equipment are included in

Attachment B-13. If the dredge residual pilot tests are successful, the ROST/LIF method will

be used for future dredge monitoring.

An initial ROST survey will be conducted prior to dredging activity. A bathymetric survey will

be conducted in each pilot test area after dredging activity occurs to determine if the dredge

prism was removed. Twenty sample locations will be used for the Stryker Bay transition zone

pilot test area and 10 samples locations will be used for the Minnesota Channel pilot test area.

Sample grids will be established by dividing the pilot test areas into similar-sized sample areas

based on the number of samples to be collected. Date, time, water depth and GPS coordinates

will be collected at each sample point to document horizontal and vertical location of the

samples. A second ROST survey will be conducted at the same locations after the pilot test areas

have been dredged to define normal dredge residue.

A report will be prepared summarizing those results and recommending a procedure for

measuring normal residue for all remaining dredging in the Minnesota portion of the project.


Dredge residual monitoring in areas subject to regulations under Wisconsin statutes and

administrative rules will be covered in the Wisconsin permit application and approved by the

Wisconsin Department of Natural Resources.


7.0 CAP THICKNESS AND SETTLEMENT MONITORING

Geotechnical instrumentation will be used to measure cap thicknesses and to monitor settlement

in the surcharged area of Stryker Bay, in the CAD dike, and at the top of the slope in Slip 7.

Settlement measurements will be used to monitor sediment strength increase and pore pressure

dissipation. The data will inform decisions about when to add more surcharge weight or dike

fill, and when to remove the surcharge. It can also be used to update post-remediation

bathymetry estimates, allowing for better habitat planning.

The geotechnical instrumentation will consist of settlement plates, settlement cells, settlement

profilers and vibrating wire piezometers. The location of each monitored area is presented on

Figure 13-1. The geotechnical instruments will be used in conjunction with bathymetric

surveying and coring to measure cap thickness and settlement as detailed below.

7.1 Settlement plates

Settlement plates, with graduated rods, will be driven into the sediment prior to cap placement in

Stryker Bay. A plate with a vertical pipe welded to it will be placed at the top of the mudline,

with the pipe placed over the rod. Both the pipe and the graduated rod will be a minimum two

feet above the final estimated water elevation at each location for surveying. The tops of the

collar of the settlement plate pipe and graduated rod will be surveyed periodically using a log

time scale to measure vertical change over time. The amount of shallow sediment consolidation

will be measured by the elevation change of the collar. Deeper settlement, measured by the

change in elevation of the rod would be added to that measured at the pipe collar to determine

the total settlement at the time of measurement.

7.2 Settlement Cells and Profilers

Settlement cells and sediment profile systems will be placed on the Stryker Bay sediment prior to

cap and surcharge material placement. A settlement cell will also be placed on the foundation of

the end dike prior to end dike construction. The geotechnical equipment, tubes and cables will

be anchored on the sediment to minimize risk of cable and tube damage. Monitoring access

tubes and cables will be located on shore. The geotechnical equipment will be surveyed for

horizontal and vertical control before placement of cap material. Geotechnical readings will be

obtained as cap and surcharge lifts are being placed and as the end dike is constructed. Each


geotechnical instrument location will provide a horizontal and vertical measurement of the cap

base over time.

Settlement cells and settlement profile tubes will be placed in the sediment at locations presented

in Figure 13-1 of the RD/RA Plan. The geophysical probes will be monitored between cap lift

intervals. The elevation of the cap bottom is expected to settle as additional lifts of cap material

are placed. The settlement probes and profiler tubes will measure the elevation of the bottom of

the cap at specific locations and will be used in combination with the settlement plates. The

information obtained from bathymetric and survey measurements and geotechnical

instrumentation will be used to calculate cap thickness while tracking settlement over time.

7.3 Vibrating Wire Piezometers

Vibrating wire piezometers will be placed in the top few feet of soft sediment prior to cap

placement in each of the shallow areas to be surcharged. They will also be installed beneath the

capped at the crest of the slope in Slip 7 to monitor slope stability, and in the peat deposits

located on the flanks of the CAD dike to monitor pore pressure dissipation. The vibrating wire

piezometers will be used to determine when the pore pressure of the soft sediment is sufficiently

dissipated to allow placement of additional above-water lifts and dike material.

7.4 Coring

In the areas receiving a cap without surcharge, the cap thickness will be confirmed by collecting

drop tube samples or vibrocore samples. A core log of core measurements will be prepared for

each core and samples will be visually classified by a field geologist, making note of the nature

of the sediment cap interface and any mixing observed. Drop tube and Vibrocore sampling and

classification procedures are outlined in the standard operating procedures included in

Attachment B-14.


8.0 BORROW MATERIAL TESTING

Borrow material for use in dike construction, armoring, capping, covering dredged areas, or

habitat enhancement (Environmental Medium) will be tested prior to acceptance using a tiered

approach, based on the Inland Testing Manual (EPA/USACE 1998). The tiered approach is

summarized in Table B-5. Material which is not accepted after assessment of Tier II-A will not

likely be further evaluated for use on-Site. The number of samples collected from each borrow

source will be determined in Tier I, based on the anticipated consistency of the source.

Sampling will consist of chemical testing for potential contaminants and physical testing. Any

material with detected contaminants will be assessed relative to Level 1 Sediment Quality

Targets (SQTs) for individual metals, and total PAHs for upland sources. For sediment sources,

total PCBs and pesticides will be added. The Level 1 SQTs are described in Table 14 of

Development of a Framework for Evaluating Numerical Sediment Quality Targets and Sediment

Contamination in the St. Louis River Area of Concern Final Report by J.L. Crane et. al., 2000.

Physical testing results will be compared to the specification prepared for each particular use

(specifications are presented in Table 13-1 of the RD/RA Plan).

Material considered for potential use as Environmental Medium will be tested for nutrient

properties prior to approving the material for placement. The nutrients (nitrogen, phosphorous,

potassium, percent organic matter, pH and caption exchange capacity) will be evaluated prior to

using any material as Environmental Medium to ensure the material is acceptable as a wetland

plant substrate. Characterization of the exotic seed content of sediment sources will be

addressed in the DNR permit.

The MPCA must approve or accept each source of borrow material prior to use at the Site.

ATTACHMENT B-3

POST-RESPONSE ACTION MONITORING PLAN

(NOT INCLUDED)

ATTACHMENT B-4

FIELD FORMS

(NOT INCLUDED)

ATTACHMENT B-5

BRAUN INTERTEC QA MANUAL AND LABORATORY SOPS

(NOT INCLUDED)

ATTACHMENT B-6

PACE ANALYTICAL SERVICES QA MANUAL AND

LABORATORY SOPS

(NOT INCLUDED)

ATTACHMENT B-7

LAB ELECTRONIC DATA DELIVERABLE SOP

(NOT INCLUDED)

ATTACHMENT B-8

MPCA NOISE CONTROL MANUAL

(NOT INCLUDED)

ATTACHMENT B-9

INVASIVE AND EXOTIC SPECIES MONITORING SOP

(NOT INCLUDED)

ATTACHMENT B-10

CALIBRATION PROCEDURE FOR ARSLID

(NOT INCLUDED)

ATTACHMENT B-11

(DELETED)

ATTACHMENT B-12

CHRONIC AIR MONITORING OPERATING AND CALIBRATION

PROCEDURE

(NOT INCLUDED)

ATTACHMENT B-13

LIF TO PAH CALIBRATION PROCEDURES

BY DAKOTA TECHNOLOGIES, INC.

(NOT INCLUDED)

ATTACHMENT B-14

COLLECTION AND LOGGING SOP FOR

VIBROCORE AND DROP CORE

(NOT INCLUDED)

ATTACHMENT B-15

ASTM GUIDELINES

(NOT INCLUDED)