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December 17, 2008 ' !l *w > " ' ";

•JZ.C j. QMs. Diana EngemanRemedial Project ManagerSuperfund DivisionU.S. Environmental Protection Agency, Region VII901 North Fifth StreetKansas City, KS 66101 MWH #1914102.0102

RE: Focused Remedial Investigation Work Plan AddendumFormer Manufactured Gas Plant SiteClinton, IowaDocket No. CERCLA-07-2004-0307

Dear Ms. Engeman:

On behalf of Interstate Power and Light Company (IPL), MWH has prepared the enclosedrevised text and tables of the Focused Remedial Investigation (Rl) Work PlanAddendum (Focused Rl Work Plan Addendum) for the former manufactured gas plant site inClinton, Iowa (site).

The Focused Rl Work Plan Addendum was prepared to investigate potential vapor intrusion inthe site vicinity, in order to complete the Focused Rl objective of determining the associated riskto public health and the environment as discussed in the United States EnvironmentalProtection Agency (USEPA) June 19, 2007 letter to IPL. An addendum to the April 2005Focused RI/FS Sampling and Analysis Plan (SAP) and a revised site-specific Health and SafetyPlan Addendum were prepared to address vapor intrusion investigation activities and areincluded as Appendices A and B, respectively, of the Focused Rl Work Plan Addendum.

The Focused Rl Work Plan Addendum has been revised in response to USEPA commentsprovided in an October 28, 2008 letter to IPL. Instructions for updating the Focused Rl WorkPlan Addendum are provided with the enclosed revised text and tables.

Revisions in the December 2008 Focused Rl Work Plan Addendum include the following:

• Addition of references in Sections 4.1.1.3 and 4.1.1.4 to roles andresponsibilities of project personnel, including the Project Quality AssuranceOfficer, provided in the April 2005 Focused RI/FS Work Plan.

• Revision of total xylenes listed as site constituents of potential concern (COPCs)as identified in the August 2001 Engineering Evaluation/Cost Analysis Part II -Baseline Risk Assessment, instead of individual xylene isomers (i.e., m-xylene,o-xylene, and p-xylene). Sump water analytical results provide total xylene

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Superfund wwwmwhglobal com

Ms. Diana Engeman December 17, 2008

concentrations. Subslab soil gas, soil gas, indoor air, and outdoor air analyticalresults provide o-xylene and m,p-xylene concentrations, which will be summed tocalculate total xylene concentrations. Total xylene concentrations will becompared to total xylene action levels listed in updated Table 4-1.

• The reference in Section 5.3.4 was corrected from "Section 3.3.3" to"Section 5.3.4" of the April 2005 Focused RI/FS SAP.

• Target indoor air concentrations for ethylbenzene, toluene, and total xyleneswere updated to values provided in the September 12, 2008 Regional ScreeningLevels for Chemical Contaminants at Superfund Sites tables.

If you have any questions regarding the site, please contact Mr. Dean Hargens of I PL at319-789-4658 or me at 515-253-0830.

Sincerely,

Randy J. Kroneman, P.G.Project Manager

/khw:hlsEnclosurescc: Dean Hargens, IPL

Matt Gulp, Iowa Department of Natural Resources

PAWord Processing\ALLIANT-IPL\CLINTON-FMGP SiteNFOCUSED Rl WORK PLAN ADDENDA\2008 FOCUSED Rl WORK PLAN ADDENDUMM2-08-Focused Rl Work Plan Addendum\Ltr-12-08-Engeman-RI Work Plan Addendum Submittal doc

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Interstate Power and Light Company

Focused Remedial Investigation Work Plan Addendum

Clinton Manufactured Gas Plant SiteClinton, Iowa

September 2008

MWH

Interstate Power and Light Company

Focused Remedial Investigation Work Plan Addendum September 2008Clinton Manufactured Gas Plant Site

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FOCUSED REMEDIAL INVESTIGATION WORK PLAN ADDENDUM

FOR THE

FORMER MANUFACTURED GAS PLANT SITECLINTON, IOWA

Prepared for

INTERSTATE POWER AND LIGHT COMPANYCEDAR RAPIDS, IOWA

Project No. 1914102.0102

September 2008

Prepared by

MWH11153 Aurora Avenue

Des Moines, Iowa 50322515-253-0830

FOCUSED REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK PLAN

TABLE OF CONTENTS

PAGE

SECTION 1 INTRODUCTION 1-1

SECTION 2 RI WORK PLAN ADDENDUM RATIONALE 2-12.1 Guidance 2-12.2 Preliminary Screening 2-1

2.2.1 Step 1 - Is Acute Exposure Present? (No) 2-12.2.2 Step 2 - Is Site Characterization Sufficient? (Yes) 2-12.2.3 Step 3 - Are COPCs Sufficiently Volatile and Toxic? (Yes) 2-22.2.4 Step 4 - Are Buildings Located in Site Proximity Currently

or in Future Use? (Yes) 2-32.2.5 Step 5 - Identify Occupant Exposure Scenario and Screening Levels.... 2-32.2.6 Step 6 - Do Data Exceed Screening Levels? (Yes) 2-42.2.7 Step 7 - Do Exceedances Warrant Further Investigation? (Yes) 2-4

2.3 Identified Data Gaps 2-42.4 Investigative Strategy 2-42.5 Data Quality Objectives 2-5

SECTION 3 PREVIOUS INDOOR AIR RISK EVALUATION 3-1

SECTION 4 VAPOR INTRUSION INVESTIGATION TASKS 4-14.1 Project Planning 4-14.2 Community Relations 4-14.3 Field Investigation 4-24.4 Safety and Security 4-2

4.4.1 Health and Safety Plan 4-24.4.2 Equipment Storage 4-2

4.5 Data Evaluation 4-34.6 Risk Assessment 4-34.7 Focused RI Report Addendum 4-3

SECTION 5 PROJECT MANAGEMENT 5-15.1 Project Organization and Responsibilities 5-15.2 Quality Management 5-15.3 Subcontractor Management 5-15.4 Schedule 5-1

SECTION 6 REFERENCES 6-1

FOCUSED REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK PLAN

TABLE OF CONTENTS (CONTINUED)

LIST OF TABLES

TABLENO.

2-1 Comparison of COPC Groundwater Concentrations to Target GroundwaterConcentrations for Vapor Intrusion Screening

LIST OF FIGURES

FIGURENO.

1-1 Site Location Map

1-2 Site Layout

2-1 Potential Off-Site Sources of Contamination

2-2 Extent of Water Table Groundwater Plume - September 2006

2-3 Extent of Intermediate Depth Groundwater Plume - September 2006

2-4 Extent of Bedrock Surface Groundwater Plume - September 2006

2-5 Buildings Located within 100 Feet of the Site Groundwater Plume

LIST OF APPENDICES

APPENDIX A - SAMPLING AND ANALYSIS PLAN ADDENDUM

APPENDIX B - SITE-SPECIFIC HEALTH AND SAFETY PLAN ADDENDUM

GLOSSARY OF ABBREVIATIONS AND ACRONYMS

ARARsCERCLA

CFRCOPCConsent OrderDQOEE/CAEE/CA Baseline Risk

AssessmentEE/CA Site

CharacterizationEE/CA Remedial

Alternatives EvaluationEE/CA Work PlanEPAFMGPFSFSPHIHSPIPCIPLITRCNIOSHOSHAPAHPELPCPMPPEQAPPQA/QCRIRI/FSRI Work Plan AddendumRODSARASOWSVOCVOCWork Plan

applicable or relevant and appropriate requirementsComprehensive Environmental Response, Compensation and LiabilityActCode of Federal Regulationsconstituent of potential concernAdministrative Order on Consentdata quality objectiveEngineering Evaluation/Cost AnalysisEngineering Evaluation/Cost Analysis Part II - Baseline Risk

AssessmentEngineering Evaluation/Cost Analysis Part I - Site Characterization

Engineering Evaluation/Cost Analysis Part III - Remedial AlternativesEvaluation

Engineering Evaluation/Cost Analysis Work PlanUnited States Environmental Protection Agencyformer manufactured gas plantFeasibility StudyField Sampling PlanHazard IndexHealth and Safety PlanInterstate Power CompanyInterstate Power and Light CompanyInterstate Technology & Regulatory CouncilNational Institute of Occupational Health and SafetyOccupational Safety and Health Administrationpolynuclear aromatic hydrocarbonpermissible exposure limitProject CoordinatorProject Managerpersonal protective equipmentQuality Assurance Project PlanQuality Assurance/Quality ControlRemedial InvestigationRemedial Investigation/Feasibility StudyFocused Remedial Investigation Work Plan AddendumRecord of DecisionSuperfund Amendments and Reauthorization Act of 1986Statement of Worksemivolatile organic compoundvolatile organic compoundFocused Remedial Investigation/Feasibility Study Work Plan

SECTION 1

INTRODUCTION

Interstate Power and Light Company (IPL) and the United States Environmental ProtectionAgency (EPA), Region 7 entered into an Administrative Order on Consent (Consent Order),Docket No. CERCLA-07-2004-0307, dated September 24, 2004, for the former manufacturedgas plant (FMGP) site located in Clinton, Iowa (site), as shown in Figure 1-1. Pursuant to theConsent Order and attached Statement of Work (SOW), IPL is conducting a focused remedialinvestigation/feasibility study (RI/FS). The Consent Order and RI/FS are directed at impactsrelated to the FMGP operations. A focused RI/FS Work Plan (Work Plan) was prepared byMWH on behalf of IPL to complete the investigation of the nature and extent of FMGP impactsat the site and develop and evaluate potential remedial alternatives (MWH, 2005). The WorkPlan was approved by EPA on May 17, 2005. The site location, history, physical setting,previous investigations, nature and extent of impacts, conceptual model, RI/FS tasks, applicableor relevant and appropriate requirements (ARARs), and project management are described in theWork Plan (MWH, 2005).

On behalf of IPL, MWH has prepared this Focused Remedial Investigation (RI) Work PlanAddendum (RI Work Plan Addendum) to supplement the Work Plan to address potential vaporintaision in the site vicinity. The site layout is depicted in Figure 1-2. The proposed activitiesare intended to complete the RI objective to determine the associated risk to public health and theenvironment as discussed in the EPA June 19, 2007, letter to Dean Hargens of IPL. Anaddendum to the 2005 Sampling and Analysis Plan (SAP) and a revised site-specific Health andSafety Plan (HSP) addendum were prepared to include vapor intrusion investigation activitiesand are included as Appendices A and B, respectively.

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SECTION 2

RI WORK PLAN ADDENDUM RATIONALE

This section presents the rationale used to develop the detailed scope of work for the site vaporintrusion investigation. Vapor intrusion is the migration of volatile chemicals from thesubsurface into overlying buildings (EPA, 2002). The rationale is based on the existinginformation presented in the Work Plan (MWH, 2005), Focused RI Report (MWH, 2006),Focused RI Report Addendum (MWH, 2007), and additional site data collected in 2007.

2.1 GUIDANCE

As documented in the Consent Order, the focused RI is conducted under the oversight of EPA, asgranted by the Comprehensive Environmental Response, Compensation, and Liability Act of1980, as amended (CERCLA). Accordingly, the following documents were identified asapplicable guidance for the site vapor intrusion investigation:

• OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor AirPathway from Groundwater and Soils (Subsurface Vapor intrusion Guidance)(EPA, 2002).

• Vapor Intrusion Pathway: A Practical Guide (Interstate Technology &Regulatory Council [ITRCJ, 2007).

Applicable state-specific guidance was not identified for Iowa.

2.2 PRELIMINARY SCREENING

The EPA and ITRC guidance documents include a similar preliminary screening process toassess the potential for vapor intrusion at a site. A preliminary screening process based on theseguidance documents is outlined in subsections 2.2.1 through 2.2.7 and is used to assess thepotential for vapor intrusion and develop an investigative strategy for the site.

2.2.1 Step 1 - Is an Acute Exposure Present? (No)

An acute or emergency hazard resulting from vapor intrusion in the site vicinity is not suspected.Indicators of acute scenarios, such as physiological symptoms, wet basements, and/or measuredor likely explosive, acutely toxic, corrosive, or chemically reactive vapor concentrations, havenot been reported in buildings or connecting utility conduits in the site vicinity. Periodic odorsdescribed as "paint like" have been reported in a building located north of the site and adjacent toformer gasoline stations.

2.2.2 Step 2 - Is Site Characterization Sufficient? (Yes)

The site has documented soil and groundwater impacts resulting from FMGP operations andother historic land use. The site conceptual model and nature and extent of contamination aresummarized in the Work Plan (MWH, 2005). The nature and extent of off-site groundwaterimpacts are presented in the Focused RI Report (MWH, 2006) and Focused RI Report

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Addendum (MWH, 2007). Groundwater in the site vicinity is also likely impacted by potentialreleases from the former gasoline/automotive service stations identified in Figure 2-1 thatsurround the site. The extent of the water table, intermediate depth, and bedrock surfacegroundwater plumes are depicted in Figures 2-2, 2-3, and 2-4, respectively.

Based on the site conceptual model, impacted groundwater is a potential source of contaminationto indoor air in buildings in the site vicinity. The current monitoring network delineates thegroundwater plume to the north, west, south, and east, with the exception of limited areas in thevicinity of water table monitoring wells MW-49 and PZ-3 (Figure 2-2). The groundwater plumeis defined by locations where constituent of potential concern (COPC) concentrations are lessthan site delineation values, which are based on ARARs and risk-based concentrations identifiedin the Work Plan (MWH, 2005).

2.2.3 Step 3 - Are COPCs Sufficiently Volatile and Toxic? (Yes)

EPA considers a chemical to be sufficiently volatile if the Henry's Law Constant is equal to orgreater than IxlO"5 atmosphere-cubic meter per mole (EPA, 2002). EPA considers a chemical tobe sufficiently toxic if the vapor concentration of the pure component poses an incrementallifetime cancer risk greater than IxlO"6 or a noncancer hazard index (HI) greater than 1 (EPA,2002). Table 1 of the EPA guidance (2002) identifies common volatile organic compounds(VOCs) and semivolatile organic compounds (SVOCs) that are sufficiently toxic and volatile topose a concern through vapor intrusion.

Organic and inorganic analytes that have been detected in at least one site groundwater samplecollected to date are listed in Table 2-1 of this RI Work Plan Addendum. The following VOCsand SVOCs have been detected in at least one groundwater sample collected to date, and aresufficiently volatile and toxic to warrant further screening of the vapor intrusion pathway(Table 2-1):

• 1,1,1-Trichloroethane.• 1,2-Dichloroethane.• Acetone.• Benzene.• Bromomethane.• Carbon disulfide.• Chloromethane.• Ethylbenzene.• Methylene chloride.• Methyl-tert-butyl ether.• Naphthalene.• Toluene.• Xylenes, total.• Acenaphthene.« Benzo(b)fluoranthene.• Chrysene.• Fluorene.• Pyrene.

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2.2.4 Step 4 - Are Buildings Located in Site Proximity Currently or in Future Use? (Yes)

EPA guidance establishes an area within 100 feet vertically or laterally from a volatileconcentration of regulatory concern as a potential impact area for vapor intrusion (EPA, 2002).The area within 100 feet of the site groundwater plume is depicted in Figure 2-5. Currently, thefollowing buildings are partially or completely located within 100 feet of the groundwater plume,as indicated in Figure 2-5.

• 100 South 2nd Street (Benevolent Society office).• 101 South 2nd Street (Tegeler Music business).• 105 South 2nd Street (Tandem Car Care business).• 100-110 North 2nd Street (Eastman House Furniture business).• 101 North 2nd Street (IPL garage).• 112 North 2nd Street (Mediacom Communications Iowa LLC business).• 201 North 2nd Street (IPL district office, warehouse, and garage).• 200-206 North 2nd Street (Hartz Lock business).• 208 North 2nd Street (Barber Service business).• 216 North 2nd Street (Mike May Electric business).• 218 North 2nd Street (Gabel Chiropractic business).• 301 North 2nd Street (Ruhl & Ruhl Real Estate business).• 317 North 2nd Street (Turner Appliance business).• 401 North 2nd Street (Taco John's restaurant).• 407 North 2nd Street (Strand Wood Works business).• 409, 413, 417, and 429 North 2nd Street (Hagge Family Furniture business).• 501 North 2nd Street (Jacobs Engineering business)• 212 1st Avenue (residence).• 112 4lh Avenue North (residence).• 107 5lh Avenue North (Hagge Family Furniture business).• 500 Roosevelt Street (Hagge Family Furniture business).• 531 Ballpark Drive (Riverview Stadium maintenance garage and building).

2.2.5 Step 5 - Identify Occupant Exposure Scenarios and Screening Levels

Two residential buildings and 22 commercial buildings are located partially or completely within100 feet of the groundwater plume. The current residential and commercial land uses areexpected to continue in the future. However, future buildings are not expected to be built on theundeveloped properties located within 100 feet of the groundwater plume (i.e., Riverview Parkand the former Allied Steel property).

Target groundwater concentrations listed in Table 2c of the EPA guidance document (2002)were identified as applicable, conservative screening levels. The groundwater screening levelscorrespond to residential target indoor air concentrations where:

• Chemical partitioning from groundwater to soil gas obeys Henry's Law.• Soil gas to indoor air attenuation factor is 0.001.• Both target cancer risk of Ix 10"6 and noncancer HI of 1 are satisfied.

However, screening levels are only available for the 13 VOCs, including naphthalene, listed inSubsection 2.2.3. Based on the specified attenuation factor and risk levels, the vapor intrusionpathway for the 5 identified SVOCs is incomplete because the target soil gas concentrations

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required to produce the target indoor air concentrations exceed the maximum possible vaporconcentrations (EPA, 2002).

2.2.6 Step 6 - Do Data Exceed Screening Levels? (Yes)

The maximum detected groundwater concentrations of the sufficiently volatile and toxiccontaminants were compared to the identified screening levels. This comparison is summarizedin Table 2-1. The maximum detected groundwater concentrations of the following VOCsexceeded the specified screening levels:

• 1,2-Dichloroethane (exceeded only at MW-48).• Benzene.• Bromomethane (exceeded only at MW-19).• Chloromethane (exceeded only MW-7 and MW-29).• Ethylbenzene.« Methylene chloride (exceeded only at MW-10).• Naphthalene.• Toluene.

2.2.7 Step 7 - Do Exceedances Warrant Further Investigation? (Yes)

Because sufficiently volatile and toxic VOCs have been detected in site groundwater atconcentrations exceeding groundwater screening levels, additional site-specific investigation isrequired to evaluate the vapor intrusion pathway.

2.3 IDENTIFIED DATA GAPS

One or more of the following data types may be needed to further assess the potential for vaporintrusion in the site vicinity:

• Sump water concentrations.• Subslab soil gas concentrations.« Soil gas concentrations.• Indoor air concentrations.

2.4 INVESTIGATIVE STRATEGY

Subslab soil gas sampling in target locations was selected as the initial investigative strategy toevaluate the potential subsurface contributions to impact indoor air quality. Subslab soil gas dataprovide direct measurements of COPC concentrations present at a foundation with the potentialto enter a building through subsurface vapor intrusion. However, COPC concentrations inindoor air resulting from vapor intrusion are expected to be less than subslab soil gasconcentrations by one to several orders of magnitude due to lower permeability of the foundationmaterial and removal through natural and mechanical building ventilation. If subslab soil gasresults indicate site impacts will not result in unacceptable human health risk in indoor air, thevapor intrusion investigation will be concluded. This approach was chosen for initialinvestigation to avoid additional modeling required for and the conservative nature of using deepsoil gas data, and the contribution of indoor background sources that influence indoor air

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sampling. The following four target locations, as shown in Figure 2-5, were selected for subslabsoil gas sampling based on the occupant exposure scenario and proximity to the groundwaterplume:

• 401 North 2nd Street (Taco John's restaurant).• 112 4th Avenue North (residence).• 112 North 2nd Street (Mediacom Communications Iowa LLC business).• 100 South 2nd Street (Benevolent Society office).

Results of the subslab soil gas sampling will be used to evaluate the vapor intrusion pathway andthe need for additional data, such as data from other buildings and/or data from indoor airsampling. An indoor air evaluation for the IPL district office was previously completed in 2003and is summarized in Section 3 of this RI Work Plan Addendum. If target properties are foundto have sumps, water samples will be collected from the sump prior to subslab soil gas sampling.

2.5 DATA QUALITY OBJECTIVES

In order to address the identified data gaps and evaluate the vapor intrusion exposure pathway,the appropriate amount and type of data must be collected. Development of site-specific dataquality objectives (DQOs) helps determine what type and amount of data are needed. DQOs arequalitative and quantitative statements that specify the data quality necessary to support specificdecisions or regulatory actions. The DQOs describe which data are needed, why the data areneeded, and data end use. The DQOs also establish numeric limits for the data, to allow ihe datauser (or reviewers) to determine whether the data collected are of sufficient quality for theirintended use. The EPA seven-step DQO process (EPA, 2006) was used in preparation for thevapor intrusion investigation activities and is presented in Section 4.1 of the Focused RI/FS SAPAddendum included as Appendix A.

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SECTION 3

PREVIOUS INDOOR AIR RISK EVALUATION

In 2003, IPL completed an indoor air quality evaluation for the district office building to evaluatethe potential for vapor intrusion into IPL office space. The evaluation procedures and resultswere presented in a May 2003 EE/CA Indoor Air Risk Evaluation report (MWH, 2003)submitted to EPA and are summarized in this section.

The indoor air evaluation consisted of the following primary components:

1. Implementation of an air monitoring program to obtain actual indoor airconcentrations for the constituents of potential concern (COPCs) associated withvapor intrusion; and

2. A site-specific risk assessment to evaluate the potential risks associated with IPLworker exposure to COPCs in indoor air due to chemical vapor intrusion.

The sampling program was conducted by a certified industrial hygienist over a 30-day period inNovember and December 2002. Indoor air samples were collected at eight pre-selected locationsat the IPL district office building: one outdoor and seven indoor locations. These samplesprovided representation for each of the four heating/air conditioning zones in the IPL districtoffice building, and outdoor ambient conditions. Two of the seven indoor locations were alsoselected in close proximity to the location of a former gas holder.

Samples for VOC analyses were collected in 6-liter Summa® canisters that were fitted with anine-hour regulator to provide collection of integrated air samples. The samples were collectedand analyzed per EPA Method TO-ISA. Samples for polynuclear aromatic hydrocarbon (PAH)analysis were collected on polyurethane foam samplers and analyzed as described in EPAMethod TO-13A; however, the samplers were attached to personal air sampling pumps ratherthan high volume sampling pumps, as described by this method. Air samples for naphthaleneanalysis were also collected on SKC XAD-2 sorbent tubes attached to personal sampling pumpsand analyzed by National Institute of Occupational Safety and Health (NIOSH) Method 5506(modified).

EPA protocols were used to quantify risks from assumed exposures of on-site workers to VOCsand PAHs in indoor air. The quantitative exposure risks were evaluated against anoncarcinogenic HI of 1.0 and the EPA upper bound of its incremental carcinogenic risk range of1 in 10,000 (i.e., 10"4). Under current conditions for routine site activities, the results of thisevaluation indicate an HI of 0.6 and an excess lifetime cancer risk of 1.1 x 10"5. The HI is belowthe evaluation threshold for noncarcinogenic health concerns, and the estimated cancer risk fallsbelow the upper end of the EPA cancer risk range, (i.e., a cancer risk of 10"6 to 10"'').

The cancer and noncarcinogenic risks associated with indoor air were primarily associated withbenzene. The highest benzene concentrations were routinely detected in the garage portion ofthe district office building.

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It was also noted none of the observed indoor air concentrations exceeded Occupational Safetyand Health Administration (OSHA) Permissible Exposure Limits (PELs). Therefore, thedetected indoor air contaminants, even at maximum concentrations, do not present a chronicinhalation health situation for on-site workers under worker health and safety regulations.

The data was also reviewed in an attempt to identify trends or outlying data that may correspondto a sample location or event conducted during the sample collection. The review resulted in thefollowing observations:

• No carcinogenic PAHs were detected in any of the samples collected.

« Benzene concentrations for all monitoring events were highest in the garage.

• The locations of the greatest detections of toluene, ethylbenzene, and xylenesoccurred in the gas meter room during the November 27, 2002 sampling event.Note these detections were excluded from the data set used in the risk evaluation,because they were determined to be related to a one time spray painting eventwithin the gas meter room (not work related), rather than due to vapor intrusioninto the building. Excluding the November 27, 2002 sampling event, benzene,toluene, ethylbenzene, and xylenes concentrations for all other events werehighest in the garage.

• None of the highest VOC or PAH concentrations were detected in the samplinglocations near the former gas holder.

• Concentrations of VOCs in the outdoor sample were generally less than thosedetected in the indoor samples.

• Concentrations of PAHs in the outdoor samples were generally of the same orderof magnitude as the PAHs detected in the indoor samples.

It was concluded the measured concentrations of COPCs in indoor air at the IPL district officebuilding do not present a health threat to on-site workers. In addition, the observed indoor airconcentrations of benzene and naphthalene (the most volatile of the FMGP residual compounds)are similar to the outdoor concentrations measured at the site and to reported values in currentliterature for locations elsewhere in the United States. Therefore, it was also concluded theindoor air concentrations of benzene and naphthalene are not attributable to vapor intrusion fromon-site soil or groundwater sources.

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SECTION 4

VAPOR INTRUSION INVESTIGATION TASKS

The vapor intrusion investigation activities to be conducted to meet the defined RI/FS objectivesand DQOs are specified in this section in general accordance with the EPA standard RI/FS taskformat.

4.1 PROJECT PLANNING

Project planning for the vapor intrusion investigation has included review of the site setting,previous investigations, nature and extent of impacts, and conceptual model; review of theEngineering Evaluation/Cost Analysis (EE/CA) Site Characterization, EE/CA Baseline RiskAssessment, and EE/CA Removal Alternatives Evaluation results; evaluation of existing data;identification of ARARs, data gaps, and DQOs; and development of this Focused RI Work PlanAddendum.

4.2 COMMUNITY RELATIONS

As stated in the Consent Order SOW, the development and implementation of communityinvolvement activities are the responsibility of EPA. This responsibility includes thedevelopment of a community involvement plan. Copies of this Focused RI Work PlanAddendum and the final Focused RI Report Addendum report will be placed on file at theClinton Public Library and made available to the public by EPA. Additional copies of all majordeliverable documents and the Administrative Record are also on file at EPA. Inquiries andconcerns regarding the site should be directed to the principal contacts listed below as follows:

For IPL:Mr. Dean HargensSenior Environmental EngineerInterstate Power and Light CompanyP.O. Box 351Cedar Rapids, IA 52406-0351(319)786-4658

For EPA:Ms. Diana Engeman Ms. Beckie HimesRemedial Project Manager Community Involvement CoordinatorU.S. EPA Region 7 U.S. EPA Region 7Superfund Division Office of External Programs901 North 5lh Street 901 North 5th StreetKansas City, KS 66101 Kansas City, KS 66101(913)551-7746 (913)551-7253(800) 223-0425 (800) 223-0425

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4.3 FIELD INVESTIGATION

The field efforts that will be performed to achieve the stated DQOs and overall objectives of thevapor intrusion investigation include one or more of the following activities: sump water,subslab soil gas, soil gas, indoor air, and outdoor air sampling. These tasks are summarized inthe Field Sampling Plan (FSP) (Section 2 of the SAP) and discussed in greater detail in theQuality Assurance Project Plan (QAPP) (Section 5.2 of the SAP). EPA will be notified at leasttwo weeks in advance of the initiation of each stage of planned fieldwork.

4.4 SAFETY AND SECURITY

This section describes the measures that will be taken to ensure the safety of site workers andrestrict access to the site by unauthorized personnel.

4.4.1 Health and Safety Plan

A site HSP has been prepared for this site and the proposed activities, in compliance with29 Code of Federal Regulations (CFR) Part 1910.120. The HSP consists of the MWH StandardHSP and a site-specific HSP Addendum. The HSP Addendum, which is included as Appendix Bof this RI Work Plan Addendum, contains emergency procedures and contacts, activity hazardanalysis monitoring protocols for environmental and physical hazards, and personal protectiveequipment (PPE) requirements with upgrade criteria. The HSP Addendum will apply to allMWH personnel within any site exclusion zone requiring OSHA Level D PPE or moreprotective gear. Subcontractors are required to provide their own site-specific HSP. If theychoose, subcontractors can adopt applicable portions of the MWH HSP Addendum for thisproject. The adoption is an independent action on the part of the subcontractor. The StandardHSP is available upon request.

During field activities conducted by MWH, MWH personnel will be on site to act as the healthand safety officer(s) for the site work. Work will begin using OSHA Level D PPE. A detaileddiscussion of the Level D PPE to be used at the site is discussed in the HSP Addendum. Adecision to upgrade the level of protection will be based on on-site observations and fieldscreening.

A daily tailgate safety meeting will be conducted prior to the start of each day's activities.During the tailgate safety meeting, on-site workers will review the major components of the HSPAddendum as well as discuss the activities planned for that day. A copy of a blank tailgatesafety meeting form is contained in Attachment B of the HSP Addendum (Appendix B).

4.4.2 Equipment Storage

General equipment and supplies will be stored in secured field vehicles or within the fencedareas of the site. The storage area will be locked after normal business hours unless the site isattended by IPL or MWH personnel.

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4.5 DATA EVALUATION

Data collected during the vapor intrusion investigation will be analyzed to supplement the sitecharacterization, refine the conceptual site model, and determine if the vapor intrusioninvestigation objectives and DQOs have been met. Data to be evaluated include the following:

• Sump water, subslab soil gas, soil gas, indoor air, and outdoor air analytical results.• Indoor air field measurements.• Indoor/subslab pressure differential.• Soil and groundwater analytical results.• Groundwater elevations.• Field screening results.• Groundwater stabilization parameter measurements.• Field observations.• Environmental records.• Historical maps and photographs.

4.6 RISK ASSESSMENT

In August 2001, a Baseline Risk Assessment was completed to characterize potential risks tohuman health and the environment posed by the site and adjacent properties. Results of theBaseline Risk Assessment are presented in the EE/CA Baseline Risk Assessmentreport (Interstate Power Company flPCJ, 2001). Results of the vapor intrusion investigation maybe used to update the Baseline Risk Assessment.

4.7 FOCUSED RI REPORT ADDENDUM

The vapor intrusion investigation will be conducted to supplement findings of the Focused RIReport (MWH, 2006) and Focused RI Report Addendum (MWH, 2007). The activities andresults of the vapor intrusion investigation will be summarized in a focused RI report addendum.

A draft of the focused RI report addendum will be submitted to EPA for review and commentwithin 60 days of receipt of all analytical work required for the vapor intrusion investigation.The final focused RI report addendum will then be submitted to EPA within 60 days of receipt ofEPA comments on the focused RI report addendum.

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SECTION 5

PROJECT MANAGEMENT

This section describes the overall approach and management procedures that will be used duringthe vapor intrusion investigation activities. A description of the project organization,responsibilities, training, subcontractor management, procedures, and quality management ispresented in the following paragraphs.

5.1 PROJECT ORGANIZATION AND RESPONSIBILITIES

The project management team members for the focused RI/FS activities, including the vaporintrusion investigation, are identified in the Work Plan (MWH, 2005) along wnth theresponsibilities of key project personnel.

5.2 QUALITY MANAGEMENT

Quality management activities for this project are discussed in the QAPP, which is provided inAppendix A.

5.3 SUBCONTRACTOR MANAGEMENT

The MWH Project Manager (PM) and Environmental Scientist are responsible for all contactwith subcontractors, including scheduling field activities. MWH will coordinate all fieldactivities with the IPL Project Coordinator (PC) and the IPL Clinton district office manager inorder to minimize disruption to IPL activities.

5.4 SCHEDULE

Vapor intaision investigation activities are tentatively scheduled to commence during the thirdquarter of 2008, pending EPA acceptance of this RI Work Plan Addendum and obtaining accessagreements. Laboratory analysis will be completed within three weeks of sample collection. AFocused RI Report Addendum will be prepared and submitted to EPA within 60 clays of receiptof the analytical results from the final vapor intrusion investigation sampling event.

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SECTION 6

REFERENCES

CFR, 2003. Title 40, Chapter I, Part 300: National. Oil and Hazardous Substances PollutionContingency Plan. July 2003.

EPA. 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies UnderCERCLA. Interim'Final. EPA/540/G-89/004, October 1988.

EPA, 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathwayfrom Ground-water and Soils (Subsurface Vapor Intrusion Guidance). EPA/530/D-02/004.November 2002.

EPA, 2004. Administrative Order on Consent. Docket No CERCLA-07-2004-0307. Clinton,Iowa Coal Gas Superfund Site, September 24, 2004.

EPA, 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process -EPAQA/G-4. EPA/240/B-06/001. February 2006.

IPC, 1997. Engineering Evaluation/Cost Analysis Work Plan. Clinton, Iowa FormerManufactured Gas Plant Site, October 1997.

IPC, 2000. Engineering Evaluation/Cost Analysis Part I - Site Characterization. Clinton, IowaFormer Manufactured Gas Plant Site, June 2000.

IPC, 2001. Engineering Evaluation/Cost Analysis Part II - Baseline Risk Assessment. Clinton,Iowa Former Manufactured Gas Plant Site, August 2001.

IPL, 2002. Engineering Evaluation/Cost Analysis Part III - Removal Alternatives Evaluation.Clinton. Iowa Former Manufactured Gas Plant Site, July 2002.

ITRC, 2007. Vapor Intrusion Pathway: A Practical Guide. January 2007.

MWH, 2003. Engineering Evaluation/Cost Analysis Indoor Air Risk Evaluation. FormerManufactured Gas Plant Site, Clinton, Iowa. May, 2003.

MWH, 2005. Focused Remedial Investigation/Feasibility Study Work Plan. ClintonManufactured Gas Plant Site - Clinton, Iowa. April 2005.

MWH, 2006. Focused Remedial Investigation Report. Clinton Manufactured Gas Plant Site -Clinton, Iowa. February 2006.

MWH, 2007. Focused Remedial Investigation Report Addendum. Clinton Manufactured GasPlant Site - Clinton, Iowa. January 18, 2007.

United States Code, 2002. Title 42 Chapter 103: Comprehensive Environmental Response,Compensation, and Liability. January 2002.

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STUDY SAMPLING AND ANALYSIS PLANATTACHMENT D ADDENDUM FOR VAPOR INTRUSION INVESTIGATION

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DISTRIBUTION LIST D-l

SECTION 1 INTRODUCTION 1-1

PART I - FIELD SAMPLING PLAN

SECTION 2 FIELD INVESTIGATION 2-12.1 Sump Water Sampling 2-1

2.1.1 Sump Water Sampling Locations 2-12.1.2 Sump Water Sample Collection 2-12.1.3 Laboratory Analysis 2-1

2.2 Subslab Soil Gas Sampling 2-12.2.1 Subslab Soil Gas Sampling Locations 2-12.2.2 Subslab Soil Gas Sample System Construction 2-22.2.3 Subslab Soil Gas Sample System Purging 2-22.2.4 Subslab Soil Gas Sample Collection 2-22.2.5 Laboratory Analysis 2-2

2.3 Soil Gas Sampling 2-22.3.1 Soil Gas Sampling Locations 2--22.3.2 Soil Gas Sample Collection 2-22.3.3 Laboratory Analysis 2-3

2.4 Indoor Air Sampling 2-32.4.1 Indoor Air Sampling Locations 2-32.4.2 Indoor Air Sample Collection 2-32.4.3 Laboratory Analysis 2-3

2.5 Outdoor Air Sampling 2-32.5.1 Outdoor Air Sampling Locations 2-32.5.2 Outdoor Air Sample Collection 2-42.5.3 Laboratory Analysis 2-4

2.6 Sample Handling and Analysis 2-42.7 Equipment Decontamination 2-52.8 Investigation-Derived Waste 2-52.9 Equipment Storage 2-5

PART II - QUALITY ASSURANCE PROJECT PLAN

SECTION 3 PROBLEM DEFINITION/BACKGROUND 3-13.1 Purpose 3-13.2 Project/Task Description 3-1

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SECTION 4 QUALITY OBJECTIVES AND CRITERIA 4-14.1 Data Quality Objectives 4-1

4.1.1 Statement of the Problem 4-14.1.1.1 Problem Description 4-14.1.1.2 Conceptual Model 4-14.1.1.3 Decision Making 4-14.1.1.4 Resources 4-24.1.1.5 Schedule 4-2

4.1.2 Identified Decision 4-24.1.2.1 Alternate Actions 4-24.1.2.2 Decision Statement 4-3

4.1.3 Identified Inputs to the Decision 4-34.1.3.1 Information Required to Resolve the Decision Statement 4-44.1.3.2 Source of Information 4-44.1.3.3 Appropriate Sampling and Analysis Methods 4-44.1.3.4 Determination of Action Levels 4-44.1.3.5 Information to Establish an Action 4-4

4.1.4 Defined Boundaries 4-54.1.4.1 Population of Interest 4-54.1.4.2 Spatial Boundaries 4-54.1.4.3 Temporal Boundaries 4-54.1.4.4 Scale of Decisions 4-54.1.4.5 Practical Constraints for Data Collection 4-5

4.1.5 Analytic Approach 4-54.1.5.1 Population Parameter 4-54.1.5.2 Action Levels 4-54.1.5.3 Decision Rules 4-5

4.1.6 Decision Errors Limits 4-74.1.6.1 Range of Possible Values 4-74.1.6.2 Decision Errors 4-74.1.6.3 Consequence of Type I Error 4-74.1.6.4 Consequence of Type II Error 4-7

4.1.7 Optimal Design for Obtaining Data 4-74.1.7.1 Sump Water 4-74.1.7.2 Subslab Soil Gas 4-84.1.7.3 Soil Gas 4-94.1.7.4 Indoor Air 4-104.1.7.5 Outdoor Air 4-11

4.2 Measurement Performance Criteria 4-124.3 Special Training/Certification 4-124.4 Documentation and Records 4-12


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SECTION 5 DATA GENERATION, ACQUISITION, AND MANAGEMENT 5-15.1 Sampling Process Design 5-15.2 Sample Collection Procedures 5-1

5.2.1 Sump Water Sampling 5-15.2.1.1 Sump Water Collection 5-25.2.J.2 Equipment and Materials 5-25.2.1.3 Equipment Decontamination 5-3

5.2.2 Subslab Soil Gas Sampling 5-35.2.2.1 Subslab Soil Gas Probe Installation 5-35.2.2.2 Subslab Soil Gas Sampling Manifold Construction 5-45.2.2.3 Subslab Soil Gas Probe Purging 5-45.2.2.4 Subslab Soil Gas Sample Collection 5-45.2.2.5 Equipment and Materials 5-55.2.2.6 Equipment Decontamination 5-55.2.2.7 Corrective Action 5-6

5.2.3 Soil Gas Sampling 5-65.2.3.1 Soil Gas Sample Point Installation 5-65.2.3.2 Soil Gas Sampling Manifold Construction 5-65.2.3.3 Soil Gas Sample Point Purging 5-75.2.3.4 Soil Gas Sample Collection 5-75.2.3.5 Equipment and Materials 5-75.2.3.6 Equipment Decontamination 5-85.2.3.7 Corrective Action 5-8

5.2.4 Indoor Air Sampling 5-95.2.4.1 Indoor Air Sample Collection 5-95.2.4.2 Equipment and Materials 5-95.2.4.3 Equipment Decontamination 5-95.2.4.4 Corrective Action 5-9

5.2.5 Outdoor Air Sampling 5-105.2.5.1 Outdoor Air Sample Collection 5-105.2.5.2 Equipment and Materials 5-105.2.5.3 Equipment Decontamination 5-105.2.5.4 Corrective Action 5-11

5.3 Sample Handling and Custody 5-115.3.1 Sample Containers and Preservation 5-115.3.2 Sample Labels and Designation 5-125.3.3 Sample Packaging and Shipment 5-135.3.4 Sample Records and Custody 5-13

5.4 Analytical Methods 5-135.4.1 Field Screening 5-13

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5.4.1.1 Flammable Gas 5-135.4.1.2 Helium Tracer Gas 5-13

5.4.2 Laboratory Analytical Procedures 5-145.5 Quality Control 5-145.6 Equipment/Instrumentation Testing, Inspection, and Maintenance 5-155.7 Instrument/Equipment Calibration Procedures and Frequency 5-155.8 Inspection/Acceptance Requirements of Supplies and Consumables 5-155.9 Non-Direct Measurements 5-155.10 Data Management 5-15

SECTION 6 ASSESSMENT AND OVERSIGHT 6-1

SECTION 7 DATA VALIDATION AND USABILITY 7-1

SECTION 8 REFERENCES 8-1

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LIST OF TABLES

TABLENO.

2-1 Analytical Parameters

4-1 Vapor Intrusion Investigation Action Levels

4-2 Quality Control Sample Data Evaluation in Terms of Data Quality Indicators

4-3 Laboratory Quality Control Summary

4-4 Method Reporting Limits

4-5 Data Reporting Requirements

5-1 Sample Container and Analysis Summary

LIST OF FIGURES

FIGURENO.

2-1 Vapor Intrusion Investigation Target Sampling Locations

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LIST OF ACRONYMS AND ABBREVIATIONS

ASTMATLCOCCOPCDQOEPAFMGPGC/MSIDTDNRIPLLab PMLELMADEPMDLug/m3

NELAPNIOSHNPTODOSCPCPMPPEQAMQAPPQCRI/FSRIRLRPMSAPSAP AddendumSOPTACVOCWork PlanWork Plan Addendum

American Society for Testing and MaterialsAir Toxics LTDchain-of-custodyconstituent of potential concerndata qual i ty objectiveUnited States Environmental Protection Agencyformer manufactured gas plantGas Chromatography/Mass Spectroscopyinner diameterIowa Department of Natural ResourcesInterstate Power and Light Companylaboratory project managerlower explosive l imitMassachusetts Department of Environmental Protectionmethod detection l imitmicrogram(s) per cubic meterNational Environmental Laboratory Accreditation ProgramNational Institute for Occupational Safety and HealthNational Pipe Threadouter diameterOn-Scene CoordinatorProject CoordinatorProject Managerpersonal protective equipmentQuality Assurance ManualQuality Assurance Project Planquality controlRemedial Investigation/Feasibility StudyRemedial Investigationreporting limitRemedial Project ManagerSampling and Analysis PlanFocused RI/FS Sampling and Analysis Plan AddendumStandard Operating ProcedureTechnical Advisory Committeevolatile organic compoundFocused RI/FS Work PlanFocused RI/FS Work Plan Addendum

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DISTRIBUTION LIST

The following personnel wi l l receive or have ready access to copies of this Sampling andAnalysis Plan Addendum and are responsible for its implementation as it applies to their roles inthe project. Any needed clarifications of items presented in this plan should be directed to theMWH Project Manager.

Name

Diana En gem an

Kevin Larson

Matt Gulp

Randy Kroneman

Karin Wilhelm

Tim Wineland

Michael Kierski

Michael Geringer

Jeffrey Coon, P.E.

Dean Hargens

Brandon Dunmore

James Eggers

Company/Agency

EPA

EPA

IDNR

MWH

MWH

MWH

Exponent

MWH

MWH

Title

Remedial Project Manager

On-Scene Coordinator

Project Coordinator

Project Manager

Project Environmental Scientist/Field Supervisor

Project Quality Assurance Officer

Risk Assessment Manager

Project Health and Safety Coordinator/TAG Member

TAG Member

Interstate Power and Project Coordinator/TAC MemberLight Company

Air Toxics LTD. Laboratory Project Manager

Keystone Laboratories, Laboratory Quality Assurance ManagerInc.

Notes:EPAIDNRTAG

Environmental Protection AgencyIowa Department of Natural ResourcesTechnical Advisory Committee

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SECTION 1

INTRODUCTION

On behalf of Interstate Power and Light Company (IPL), MWH has prepared this Addendum tothe April 2005 Focused Remedial Investigation/Feasibility Study (RI/FS) Sampling and AnalysisPlan (SAP) (MWH, 2005a) to address a vapor intrusion investigation at the former manufacturedgas plant (FMGP) site in Clinton, Iowa (site). This Focused RI/FS SAP Addendum (SAPAddendum) follows the same format as the focused RI/FS SAP and references the focused RI/FSSAP, where appropriate, to reduce redundancy between the two documents.

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PART I - FIELD SAMPLING PLAN

SECTION 2

FIELD INVESTIGATION

One or more of the sampling activities discussed in this section wi l l be performed to achieve theoverall objectives of the vapor intrusion investigation. The United States EnvironmentalProtection Agency (EPA) will be notified at least two weeks in advance of the initiation of eachstage of planned fieldwork.

2.1 SUMP WATER SAMPLING

If a sump is present in a target building, water samples wil l be collected prior to other samplingactivities to evaluate the potential vapor intrusion exposure pathway for site impacts.

2.1.1 Sump Water Sampling Locations

Water samples wil l be collected from each sump located within each target building in the sitevicinity (Figure 2-1). Additional sump water sampling locations may be added to the monitoringnetwork, as needed.

2.1.2 Sump Water Sample Collection

Sump water grab samples wil l be collected from each location using the methods described inSection 5.2.1.1 of this SAP Addendum.

2.1.3 Laboratory Analysis

Collected sump water samples wi l l be submitted for laboratory analysis of the volatile organiccompound (VOC) constituents of potential concern (COPCs) listed in Table 2-1 of this SAPAddendum. Analytical methods, sample containers, holding times, and quality control (QC)requirements for each analysis are presented in Sections 5.3, 5.4, and 5.5 of this SAP Addendum.

2.2 SUBSLAB SOIL GAS SAMPLING

If a sump is not present in a target building, subslab soil gas sampling wi l l be conducted toevaluate the potential vapor intrusion exposure pathway for site impacts.

2.2.1 Subslab Soil Gas Sampling Locations

Subslab soil gas samples will be collected from a minimum of two locations within each selectedbuilding in the site vicini ty (Figure 2-1), pending the presence of a floor slab and dry subslab

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conditions. Additional subslab soil gas sampling locations may be added to the monitoringnetwork, as needed.

2.2.2 Subslab Soil Gas Sample System Construction

Subslab soil gas probes and sampling manifolds wi l l be constructed and installed, as described inSections 5.2.2.1 and 5.2.2.2 of this SAP Addendum, to conduct subslab soil gas sampling.

2.2.3 Subslab Soil Gas Sample System Purging

As described in Section 5.2.2.3 of this SAP Addendum, each installed subslab soil gas probe andconnected sampling manifold wil l be purged prior subslab soil gas collection to ensure collectionof a representative subslab soil gas sample.

2.2.4 Subslab Soil Gas Sample Collection

Subslab soil gas samples wi l l be collected from each location using the methods desciibed inSection 5.2.2.4 of this SAP Addendum.


Collected subslab soil gas samples will be submitted for laboratory analysis of the VOC COPCsand the leak test tracer compound listed in Table 2-1 of this SAP Addendum. Analyticalmethods, sample containers, holding times, and QC requirements for each analysis are presentedin Sections 5.3, 5.4, and 5.5 of this SAP Addendum.

2.3 SOIL GAS SAMPLING

Soil gas sampling may be conducted if building construction and/or subslab conditions precludethe use of subslab soil gas sampling to evaluate the potential vapor intrusion exposure pathwayfor site impacts.

2.3.1 Soil Gas Sampling Locations

Soil gas samples will be collected from a minimum of two locations near target buildings wheresubslab soil gas samples cannot be collected.

2.3.2 Soil Gas Sampling Collection

Soil gas samples wil l be collected from temporary soil gas points using the methods described inSection 5.2.3.1 of this SAP Addendum.

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Collected soil gas samples w i l l be submitted for laboratory analysis of the VOC COPCs and leaktest tracer compound listed in Table 2-1 of this SAP Addendum. Analytical methods, samplecontainers, holding times, and QC requirements for each analysis are presented in Sections 5.3,5.4, and 5.5 of this SAP Addendum.

2.4 INDOOR AIR SAMPLING

Indoor air sampling wi l l be conducted only in buildings where sump water and/or subslab soilgas results indicate indoor air data is required to further evaluate vapor intrusion of site impacts.Prior to sample collection, an indoor air quality building survey wi l l be conducted to identify,and potentially remove, potential indoor sources of air impacts.

2.4.1 Indoor Air Sampling Locations

In each selected building, indoor air samples wi l l be collected from a minimum of onedesignated location in the breathing zone of the lowest level of the building.

2.4.2 Indoor Air Sample Collection

Time-integrated indoor air samples wil l be collected in evacuated canisters from each locationusing the methods described in Section 5.2.4.1 of this SAP Addendum.


Collected indoor air samples will be submitted for laboratory analysis of the VOC COPCs listedin Table 2-1 of this SAP Addendum. Analytical methods, sample containers, holding times, andQC requirements for each analysis are presented in Sections 5.3, 5.4, and 5.5 of this SAPAddendum.

2.5 OUTDOOR AIR SAMPLING

Outdoor air sampling will be conducted concurrently with indoor air sampling in a buildingwhere sump water and/or subslab soil gas results indicate indoor air data is required to furtherevaluate vapor intrusion of site impacts.

2.5.1 Outdoor Air Sampling Locations

Outside of each selected building, outdoor air samples will be collected from a minimum of onedesignated location near the building ventilation system air intake or from the upwind directionof the building, as appropriate.

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2.5.2 Outdoor Air Sample Collection

Time-integrated outdoor air samples wi l l be collected in evacuated canisters from each locationusing the methods described in Section 5.2.5.1 of this SAP Addendum.


Collected outdoor air samples will be submitted for laboratory analysis of the VOC COPCs listedin Table 2-1 of this SAP Addendum. Analytical methods, sample containers, holding times, andQC requirements for each analysis are presented in Sections 5.3, 5.4, and 5.5 of this SAPAddendum.

2.6 SAMPLE HANDLING AND ANALYSIS

Once a desired sample is collected and logged by field personnel, the sample will be prepared fortransport to the laboratory. Sample handling procedures are presented in Section 5.3 of this SAPAddendum.

Air Toxics LTD of Folsom, California (ATL) wi l l serve as the analytical laboratory for subslabsoil gas, soil gas, indoor air, and outdoor air samples collected for this project. ATL is aNational Environmental Laboratory Accreditation Program (NELAP)-accredited laboratory; iscertified by 10 states, is validated by the United States Army Corps of Engineers and UnitedStates Navy Facilities Engineering Service Center, and was audited by MWH for Air ForceCenter for Engineering and the Environment project work in November 2006. KeystoneLaboratories, Inc. of Newton, Iowa (Keystone) wi l l serve as the analytical laboratory for sumpwater samples collected for this project. Keystone is a NELAP-certified and State of Iowa-certified analytical laboratory.

Each sample collected for laboratory analysis will be analyzed using the standard methodsdocumented in Table 2-1 of this SAP Addendum. ATL and Keystone wi l l conduct analyses inaccordance with the SAP Addendum to ensure accuracy and consistency of reported results.Modifications to the analytical methods, method detection limits (MDLs), preservatives, holdingtimes, etc., must be approved by EPA prior to implementation. Copies of the. ATL and KeystoneQuality Assurance Manual (QAM) are available upon request. Mr. Brandon Dunmore will serveas the ATL Laboratory Project Manager (PM) (Lab PM). Ms. Sue Thompson will serve as theKeystone Lab PM. The coordination of analytical services wil l be conducted between the LabPM and the MWH Environmental Scientist or MWH PM. Sample analyses for the vaporintrusion investigation are summarized in Table 2-1 of this SAP Addendum. The analyticalmethods, sample containers, preservatives, and holding times are discussed in Sections 5.3 and5.4 of this SAP Addendum. Data verification and validation responsibilities, which arereferenced in Section 7 of this SAP Addendum, wi l l be shared between ATL, Keystone, andMWH.

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2.1 EQUIPMENT DECONTAMINATION

Nondedicated sampling and measurement equipment wi l l be decontaminated prior to use orstorage to prevent possible cross-contamination of samples. Small equipment wi l l bedecontaminated by washing in a mixture of Alconox® detergent and distilled water and rinsingwith distilled water.

2.8 INVESTIGATION DERIVED WASTE

Disposable personal protective equipment (PPE) and other general solid wasle generated duringthe site field activities w i l l be containerized in garbage bags on site and protected from theelements before placed in a site dumpster for disposal with other general solid waste generatedby the IPL facility.

2.9 EQUIPMENT STORAGE

General equipment and supplies wi l l be stored within secured field vehicles or secured areas ofthe site.

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PART II - QUALITY ASSURANCE PROJECT PLAN

SECTION 3

PROBLEM DEFINITION/BACKGROUND

3.1 PURPOSE

The purposes of the Quality Assurance Project Plan (QAPP) and focused RI/FS are described inSection 3.1 of the focused RI/FS SAP (MWH, 2005a). The purpose of the vapor intrusioninvestigation is to evaluate potential vapor intrusion of site impacts in the site vicinity.

3.2 PROJECT/TASK DESCRIPTION

The vapor intrusion investigation wi l l include one or more of the following activities at targetlocations indicated in Figure 2-1 to achieve the data quality objectives (DQOs): sump water,subslab soil gas, soil gas, indoor air, and outdoor air sampling. The samples will be collectedaccording to methods described in Section 5.2 of this SAP Addendum. The proposed activitiesare intended to complete the RI objective to determine the associated risk to public health and theenvironment related to the nature and extent of off-site impacted groundwater as discussed in theEPA June 19, 2007, letter to Mr. Dean Hargens of IPL. The vapor intrusion field activities areanticipated to begin according to the schedule presented in Section 5.4 of the September 2008Focused Remedial Investigation (RI) Work Plan Addendum (Work Plan Addendum).

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SECTION 4

QUALITY OBJECTIVES AND CRITERIA

This section discusses the DQOs, measurement performance criteria, special training, anddocumentation established for the vapor intrusion investigation.

4.1 DATA QUALITY OBJECTIVES

In order to address the data gaps identified in Section 2.3 of the Work Plan Addendum andachieve the overall objectives of the focused RJ/FS, the appropriate amount and type of datamust be collected. The RI/FS process includes the development of site-specific DQOs to helpdetermine what types of data are needed. DQOs are qualitative and quantitative statements thatspecify the data qual i ty necessary to support specific decisions or regulatory actions. The DQOsdescribe which data are needed, why the data are needed, and data end use. The DQOs alsoestablish numeric limits for the data to allow the data user (or reviewers) to determine whetherthe data collected are of sufficient quality for their intended use. The EPA seven-step DQOprocess was used in preparation for the focused RI/FS activities designed to address theidentified data gaps (EPA, 2000).

4.1.1 Statement of the Problem

The nature of the vapor intrusion investigation and the associated planning team, resources, anddeadlines are summarized below.

4.1.1.1 Problem Description. The purpose of the vapor intrusion investigation is to determineif the nature and extent of site impacts result in unacceptable human health risk for indoor airthrough vapor intrusion.

4.1.1.2 Conceptual Model. The conceptual site model is summarized in Figure 3-5 of theFocused RI/FS Work Plan (MWH, 2005b). The conceptual site model components, includingsite geology and hydrogeology; nature and extent of contamination, and contaminant fate andtransport are described in Sections 3, 4, and 5, respectively, of the Focused RI Report(MWH, 2006).

4.1.1.3 Decision Making. The following individuals are involved in decision making for thesite vapor intrusion investigation activities:

• Ms. Diana Engeman - EPA Remedial Project Manager (RPM).• Mr. Kevin Larson - EPA On-Scene Coordinator (OSC).• Mr. Matt Gulp - Iowa Department of Natural Resources (IDNR) Project

Coordinator (PC).

• Mr. Dean Hargens - IPL PC.• Mr. Randy Kroneman - MWH PM.

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4.1.1.4 Resources. MWH personnel including geologists, engineers, environmental scientists,and chemists from corporate staff and qualified subcontractors wi l l be used to collect, analyze,and evaluate field data. MWH staff who wi l l be involved with the vapor intrusion investigationactivities include:

• Mr. Randy Kroneman - MWH PM.

• Ms. Karin Wilhelm - MWH Environmental Scientist.

• Other qualified MWH field personnel.

ATL, a NELAP-accredited laboratory, wil l perform subslab soil gas, soil gas, indoor air, andoutdoor air sample analyses. Keystone, a NELAP-accredited and State of Jowa-certifiedlaboratory, wi l l perform sump water sample analyses.

4.1.1.5 Schedule. Vapor intrusion investigation activities are tentatively scheduled tocommence during the third quarter of 2008, pending EPA acceptance of the Work PlanAddendum and obtaining access agreements. Laboratory analysis will be completed wi th in threeweeks of sample collection. A Focused RI Report Addendum wil l be prepared and submitted toEPA within 60 days of receipt of the analytical results from the final vapor intrusion monitoringevent.

4.1.2 Identified Decision

The vapor intrusion investigation activities wil l attempt to answer the following question:

1. Does vapor intrusion of site impacts result in unacceptable human health risk in indoorair in the site vicinity?

4.1.2.] Alternate Actions. Potential alternate actions to address the answers to the questionsstated above include:

• If the answer is "potentially,"

Verify data and conditions.

Collect additional data to further investigate potential pathway.

Evaluate impact of, and responses to, indoor air exceeding human healthrisk levels.

- Preemptively implement interim remedial measure.

Preemptively mitigate.

• If the answer is "yes,"

Verify data and conditions.

- Collect additional data to further investigate potential pathway.

Evaluate impact of, and responses to, indoor air exceeding human healthrisk levels.

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Implement interim remedial measure.

Mitigate.

• If the answer is "no,"

- Conclude vapor intrusion investigation.

4.1.2.2 Decision Statement. Determine whether the answers to the vapor intrusioninvestigation decision question stated above require any of the listed potential alternate actions.

4.1.3 Identified Inputs to the Decision

The following information may be required to resolve the decision statement:

• Sump water laboratory analytical results.

• Subslab soil gas laboratory analytical results.

• Soil gas laboratory analytical results.

• Modeled indoor air concentrations.

• Target indoor air concentrations to satisfy prescribed cancer and noncancer risklevels.

• Building construction details.

• Inventory of potential background sources of indoor air concentrations.

• Building use.

• Indoor air laboratory analytical results.

• Outdoor air laboratory analytical results.

• Groundwater laboratory analytical results.

• Groundwater elevations.

• Groundwater flow direction.

• Field measurements.

• Geologic conditions.

• Current and historic land use.

• Historical groundwater and soil analytical data and field measurements.

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4.1.3.1 Information Required to Resolve the Decision Statement. One or more of thefollowing types of samples wil l be collected and analyzed for VOC COPCs listed in Table 2-1:sump water, subslab soil gas, soil gas, indoor air, and outdoor air.

4.1.3.2 Source of Information. Historical groundwater and soil analytical data and fieldmeasurements previously collected at the site as well as additional subslab soil gas, indoor air,and/or outdoor data collected in the site vicini ty wi l l be used to resolve the decision.

4.1.3.3 Appropriate Sampling and Analysis Methods. Sample collection will be conductedaccording to the procedures specified in Section 5.2 of this SAP Addendum. Laboratory analysiswil l be conducted by ATL and Keystone in accordance with the procedures and methodsdescribed in sources listed in Table 2-J of this SAP Addendum with revisions, and/or inaccordance with other approved testing procedures. In addition, the laboratory analyses will beconducted according to the ATL and Keystone QAM and SOPs. Excerpts from the ATLMethods Manual are available upon request.

4.1.3.4 Determination of Action Levels. The vapor intrusion investigation action levels aretarget indoor air concentrations, ten percent of lower explosive l imit (LEL): and water methodreporting l imi t s (MRLs) listed in Table 4-1 of this SAP Addendum.

4.1.3.5 Information to Establish an Action. Vapor intrusion investigation alternate actionswill be determined by the:

• Comparison of sump water concentrations with MRLs, which are presented inTables 4-1 and 4-4 of this SAP Addendum.

• Comparison of subslab soil gas concentrations with target indoor airconcentrations, which are presented in Table 4-1 of this SAP Addendum.

• Comparison of soil gas concentrations with target indoor air concentrations,which are presented in Table 4-1 of this SAP Addendum.

• Estimated indoor air concentrations modeled from subslab soil gas and/or soil gasconcentrations.

• Comparison of estimated indoor air concentrations with target indoor airconcentrations, which are presented in Table 4-1 of this SAP Addendum.

• Comparison of measured indoor air concentrations with subslab soil gas and/oroutdoor air concentrations.

• Comparison of indoor air concentration with ten percent of LEL.

• Comparison of measured indoor air concentrations with inventory of potentialbackground sources of indoor air concentrations.

• Calculated attenuation factors.

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4.1.4 Defined Boundaries

The vapor intrusion investigation boundaries are defined in the following subsections.

4.1.4.1 Population of Interest. The population of interest includes indoor air concentrationsof site VOC COPCs, which are comprised of benzene, ethylbenzene, naphthalene, toluene,m-xylene, o-xylene, and p-xylene, resulting from vapor intrusion of site impacts. Thesecompounds are identified as site COPCs, have been detected in one or moie site groundwatersamples, and have been detected in groundwater at concentrations exceeding vapor intrusionscreening levels as discussed in Section 2.2.6 of the Work Plan Addendum. The population ofinterest may be determined through subslab soil gas or soil gas concentrations and/or by directindoor air measurements.

4.1.4.2 Spatial Boundaries. The area included in the vapor intrusion investigationencompasses buildings located within 100 feet (laterally and vertically) of the site groundwaterplume (Figure 2-1).

4.1.4.3 Temporal Boundaries. The temporal boundary for the population of interest includescurrent and future conditions. Current, historic, and future groundwater concentrations,elevations, and flow direction may be included in the vapor intrusion evaluation.

4.1.4.4 Scale of Decisions. The decision units for evaluating vapor intrusion of site impactsare individual buildings located within 100 feet of the site groundwater plume (Figure 2-1).

4.1.4.5 Practical Constraints for Data Collection. Inaccessibility of sample locations due topotential property access issues, structural obstacles, building construction, water table elevation,utilities, weather conditions, and indoor air background sources may l imit data collection.

4.1.5 Analytic Approach

A "decision problem" approach will be used to determine appropriate actions regarding vaporintrusion in the site vicinity.

4.1.5.1 Population Parameter. Individual VOC COPC (benzene, ethylbenzene, naphthalene,toluene, m-xylene, o-xylene, and p-xylene) concentrations wil l be used to evaluate vaporintrusion of site impacts in the site vicinity.

4.1.5.2 Action Levels. The action levels are target indoor concentrations to satisfy prescribedcancer and noncancer risk, ten percent of LEL, and water MRLs as listed in Table 4-1.

4.1.5.3 Decision Rules.

• If the concentration of each VOC COPC in each sump water sample collected fora building is below the respective MRL, the sump water wil l not be considered apredominant source of indoor air concentrations and the vapor intrusioninvestigation may proceed to subslab soil gas, soil gas, or concurrent indoor andoutdoor air sample collection.

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If the concentration of at least one VOC COPC in at least one sump water samplecollected for a building is equal to or above the respective MRL, the vaporintrusion investigation may proceed to concurrent indoor air, outdoor air, andsubslab soil gas or soil gas sample collection.

If the subslab soil gas concentration for each VOC COPC in each of the samplescollected for a building is equal to or below the corresponding target indoor airconcentration, the vapor intrusion pathway into that building is determined to be"not complete" and no further action is required for that building.

If subslab soil gas concentrations for each VOC COPC in each sample collectedfrom each target building are equal to or below the corresponding target indoor airconcentrations, the vapor intrusion pathway in the site vicini ty is determined to be"not complete."

If the subslab soil gas concentration for at least one VOC COPC in at least one ofthe samples collected for a building is above the corresponding target indoor airconcentration, the resulting indoor concentration wi l l be estimated throughmodeling and compared to the corresponding target indoor air concentration.

If the soil gas concentration for each VOC COPC in each of the samples collectedfor a building is equal to or below the corresponding target indoor airconcentration, the vapor intrusion pathway into that building is determined to be"not complete" and no further action is required for that building.

If the soil gas concentration for at least one VOC COPC in at least one of thesamples collected for a building is above the corresponding target indoor airconcentration, the resulting indoor concentration will be estimated throughmodeling and compared to the corresponding target indoor air concentration.

If the modeled indoor air concentration for at least one VOC COPC in at least oneof the samples collected for a building indicates indoor air concentrationsresulting from vapor intrusion exceed target indoor air concentrations, additionaldata wi l l be collected to verify indoor air concentrations.

If the indoor air concentration for at least one VOC COPC in at least one of thesamples collected for a building indicates indoor air concentrations resulting fromvapor intrusion exceed target indoor air concentrations, the impact of, andresponse to, the indoor air concentrations will be evaluated.

If ten percent of the LEL is detected in indoor air, an interim remedial action willbe implemented.

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4.1.6 Decision Error Limits

The possible range of values and the types and consequences of the decision errors are specifiedin the following subsections.

4.1.6.1 Range of Possible Values. Possible values for analytical results of VOC COPC indoorair concentrations range from the MDL to undetermined concentrations exceeding target indoorair concentrations and the LEL. The general nu l l hypothesis for each VOC COPC is: "theindoor air concentration resulting from vapor intrusion of site impacts is greater than therespective target indoor air concentration." The general alternative hypothesis for each VOCCOPC is: "The indoor air concentration resulting from vapor intrusion of site impacts is equal toor less than the respective target indoor air concentration."

4.1.6.2 Decision Errors. The two possible decision errors are:

• Type I (False Rejection) - reject the nul l hypothesis when it is true.

In this case, the measured VOC COPC indoor air concentration in a building isequal to or less than the respective target indoor air concentration when the trueVOC COPC indoor air concentration is greater than the target indoor airconcentration.

• Type II (False Acceptance) - accept the null hypothesis when it is false.

In this case, the measured VOC COPC indoor air concentration in a building isgreater than the respective target indoor air concentration when the true VOCCOPC indoor air concentration is equal to or less than the target indoor airconcentration.

4.1.6.3 Consequence of Type I Error. The true VOC COPC indoor air concentrationresulting from vapor intrusion of site impacts in a building exceeds acceptable human health riskfor residential use.

4.1.6.4 Consequence of Type II Error. Considerable resources may be expended, occupantsmay be displaced, and business may be disrupted through unnecessary interim remedial actionsand/or mitigation.

4.1.7 Optimal Design for Obtaining Data

Subslab soil gas sampling in target locations was selected as the initial investigative strategy toevaluate the potential subsurface contributions to impact indoor air quality. However, if a sumpis present in a building, sump water samples wil l be collected prior to other sampling activities.If sump water and subslab soil gas results indicate site impacts wil l not result in unacceptablehuman health risk in indoor air, the vapor intrusion investigation will be concluded.

4.1.7.1 Sump Water. Sump water data provide measurements of VOC COPC concentrationsavailable to directly volatilize from groundwater in a building sump into indoor air.

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4.7.1.1.1 Sample Design

Sump water data to evaluate the vapor intrusion pathway will be collected throughjudgmental sampling, where sample locations wi l l be based on professional judgmentwithout randomization.

4.1.7.1.2 Sample Locations

Water samples wi l l be collected from each sump, where present, in each target buildingidentified in Figure 2-1.

4.1.7.1.3 Sample Frequency

Sump water sample collection will be conducted during a minimum of one samplingevent prior to additional vapor intrusion sampling activities.

4.1.7.1.4 Sample Size

A minimum of one sump water sample wi l l be collected from each sump, where present,in each target building identified in Figure 2-1. After collection of a sample of the waterencountered in the sump, the sump will be evacuated by activating the sump pump. Ifgroundwater recharge into the sump is observed, a second sump water sample will becollected after a sufficient volume of water for sample collection has entered the sump

4.1.7.1.5 Sample Methodology

Water samples will be collected from each sump using dedicated bailers, or equivalentequipment; transferred into laboratory-supplied containers; and analyzed for benzene,ethylbenzene, naphthalene, toluene, m-xylene, o-xylene, and p-xylene, by methodSW-846 8260, as described in Section 5.2.1 of this SAP Addendum.

4.1.7.2 Subslab Soil Gas. Subslab soil gas data provide direct measurements of VOC COPCconcentrations present at a foundation with the potential to enter a building through subsurfacevapor intrusion.


Subslab soil gas data to evaluate the vapor intrusion pathway will be collected throughjudgmental sampling, where sample locations wi l l be based on professional judgmentwithout randomization.

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Subslab soil gas samples wi l l be collected from each target building identified inFigure 2-1. The exact sample locations in each building wi l l be determined on site basedon accessibility, utilities, and other building features. A minimum of two subslab soil gassampling points wi l l be installed in each target location during each sampling event toaddress spatial variability in subslab soil gas concentrations.


Subslab soil gas sample collection wi l l be conducted during a minimum of two samplingevents to address temporal variability in subslab soil gas concentrations. One of thesampling events wi l l be conducted in winter when closed buildings and stack effects cancreate worst case scenarios for vapor intrusion.


A minimum of four subslab soil gas samples wil l be collected from each buildingidentified in Figure 2-1 by collecting a minimum of two samples during each of amin imum of two sampling events.


Subslab soil gas sampling will be conducted in general accordance with procedures usedby Dominic DiGuilio of the EPA Office of Research and Development as documented inAssessment of Vapor Intrusion in Homes Near the Raynmrk Superfund Site UsingBasement and Sub-Slab Air Samples (EPA, 2006). Following subslab soil gas probeassembly, installation, and purging, time-integrated subslab soil gas samples wi l l becollected in evacuated Summa® canisters with flow controllers for analysis of benzene,ethylbenzene, naphthalene, toluene, m-xylene, o-xylene, and p-xylene, by EPA MethodTO-15, as described in Section 5.2.2 of this SAP Addendum.

4.1.7.3 Soil Gas. Soil gas data provide measurements of VOC COPC concentrations present inthe soil with the potential to migrate and enter a building through subsurface vapor intrusion.


Soil gas data to evaluate the vapor intrusion pathway wil l be collected throughjudgmental sampling, where sample locations wi l l be based on professional judgmentwithout randomization.


Soil gas samples will be collected near selected target buildings identified in Figure 2-1where building construction and/or subsurface conditions preclude collection of subslabsoil gas samples. The exact sample locations near each building wil l be determined onsite based on accessibility, utilities, water table elevation, and building features. A

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minimum of two soil gas sampling points wi l l be sampled near each target locationduring each sampling event to address spatial variability in soil gas concentrations.


Soil gas sample collection will be conducted during a minimum of one sampling event.


A minimum of two soil gas samples wi l l be collected from each selected target buildingidentified in Figure 2-1, where building construction and/or subsurface conditionspreclude collection of subslab soil gas samples, by collecting a minimum of one samplefrom a minimum of two soil gas points during a minimum of one sampling event.


Soil gas samples wi l l be collected from temporary monitoring points installed near atarget building. Following soil gas sample point assembly, installation, and purging,time-integrated soil gas samples wi l l be collected in evacuated Summa00 canisters withflow controllers for analysis of benzene, ethylbenzene, naphthalene, toluene,m-xylene, o-xylene, and p-xylene, by modified EPA Method TO-15, as described inSection 5.2.3 of this SAP Addendum.

4.1.7.4 Indoor Air. If sump water concentrations or modeled indoor air concentrationsindicate vapor intrusion of site impacts results in unacceptable human health risk for indoor air,indoor air sampling may be conducted to further evaluate the vapor intrusion pathway.


Indoor air data to evaluate the vapor intrusion pathway will be collected throughjudgmental sampling, where sample locations wi l l be based on professional judgmentwithout randomization.


Indoor air samples will be collected from each target building where subslab soil gas dataindicate indoor air VOC COPC concentrations potentially exceed target indoor airconcentrations due to vapor intrusion. Indoor air samples will be collected from thebreathing zone in the basement or the lowest level of the building. The enact locations ineach building will be determined on site based on accessibility, location of potentialbackground sources, and other building features. A minimum of one sample will becollected in each target location during each sampling event.


Indoor air sample collection wil l be conducted during a minimum of two sampling eventsto address temporal variability in indoor air concentrations. One of the sampling events

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wil l be conducted in winter when closed buildings and stack effects can create worst casescenarios for vapor intrusion.


A minimum of two indoor air samples wi l l be collected from each selected building bycollecting a minimum of one sample during each of a minimum of two sampling events.


Indoor air sampling wi l l be conducted in general accordance with procedures used byEPA (EPA, 2006) and Massachusetts Department of Environmental Protection (MADEP)(MADEP, 2002). Time-integrated samples will be collected in Summa® canisters withflow controllers for analysis of benzene, ethylbenzene, naphthalene, toluene, m-xylene,o-xylene, and p-xylene, by method TO-15, as described in Section 5.2.4 of this SAPAddendum.

4.1.7.5 Outdoor Air. If indoor air sampling is conducted to further evaluate the vaporintrusion pathway, outdoor air sampling will be conducted concurrently to evaluate backgroundVOC COPC contributions from outdoor air.


Outdoor air data to evaluate the vapor intrusion pathway will be collected concurrentlywith indoor air data through judgmental sampling, where sample locations will be basedon professional judgment without randomization.


Outdoor air samples will be collected outside of each building where subslab soil gas dataindicate indoor air VOC COPC concentrations potentially exceed target indoor airconcentrations due to vapor intrusion. Outdoor air samples will be collected from thebreathing zone upwind of the building or near the ventilation system air intake, if thesystem is operating. The exact location outside of each building will be determined onsite based on accessibility, location of potential background sources, and. other buildingfeatures. A minimum of one sample wi l l be collected outside of each target locationduring each sampling event.


Outdoor air sample collection will be conducted during a minimum of two samplingevents to address temporal variability in indoor air concentrations. One of the samplingevents wil l be conducted in winter when closed buildings and stack effects can createworst case scenarios for vapor intrusion.

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A minimum of two outdoor air samples wil l be collected from each selected building bycollecting a minimum of one sample during each of a minimum of two sampling events.


Outdoor air sampling wi l l be conducted in general accordance with procedures used byEPA (EPA, 2006) and MADEP (MADEP, 2002). Time-integrated (24-hour) samplesw i l l be collected in Summa canisters with flow controllers for analysis of benzene,ethylbenzene, naphthalene, toluene, m-xylene, o-xylene, and p-xylene, by method TO-15,as described in Section 5.2.5 of this SAP Addendum.

4.2 MEASUREMENT PERFORMANCE CRITERIA

Data quality for the vapor intrusion investigation will be evaluated with regard to measurementperformance criteria described in Table 4-2 of this SAP Addendum and Section 4.2 of thefocused RI/FS SAP (MWH, 200Sa), with the following additions:

• Results of tightness tests and tracer gas leak tests wi l l be used to evaluate fieldaccuracy and representativeness associated with subslab soil gas and soil gassampling.

• Summa canister certification will be used to evaluate laboratory datarepresentativeness.

• The Laboratory Quality Control Summary is provided in Table 4-3 of this SAPAddendum.

• MRLs are listed in Table 4-4 of this SAP Addendum.

4.3 SPECIAL TRAINING/CERTIFICATION

Personnel associated with the vapor intrusion investigation will have sufficient training to safely,effectively, and efficiently perform assigned tasks, as described in Section 4.3 of the focusedRI/FS SAP (MWH, 2005a).

4.4 DOCUMENTATION AND RECORDS

Appropriate records will be maintained to provide adequate documentation of the vapor intrusioninvestigation as described in Section 4.4 of the focused RI/FS SAP (MWH, 2005a), with thefollowing additions:

• Field data wil l be reported as described in Table 4-5 of this SAP Addendum.

• Results of soil gas and air samples will be reported in microgram(s) per cubicmeter (u.g/m3).

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SECTION 5

DATA GENERATION, ACQUISITION, AND MANAGEMENT

This section addresses the methods and materials required to collect, analyze, and manage thedata needed to satisfy the vapor intrusion investigation DQOs.

5.1 SAMPLING PROCESS DESIGN

Sample collection from target locations (Figure 2-1) based on exposure scenario and proximityto the groundwater plume wil l be conducted to evaluate the potential for vapor intrusion of siteimpacts, [f a sump is present in a target building, a water sample will be collected from eachsump. If sump water VOC COPC concentrations are below MRLs, the vapor intrusioninvestigation will proceed to subslab soil gas sampling, or soil gas sampling if buildingconstruction or subsurface conditions preclude subslab soil gas sampling. If sump water VOCCOPC concentrations are greater than MRLs, the vapor intrusion investigation may proceed toconcurrent subslab soil gas (or soil gas), indoor air, and outdoor air sample collection.

If a sump is not present in a target building, subslab soil gas (or soil gas) sampling wil l beconducted. The exact subslab soil gas sampling locations in each building wil l be determined onsite based on accessibility, utilities, and other building features. A minimum of two subslab soilgas sampling points wi l l be installed in each target location during each sampling event toaddress spatial variability in subslab soil gas concentrations. Results of the subslab soil gassampling will be used to evaluate the vapor intrusion pathway and the need for additional data,such as data from other buildings and/or data from indoor air sampling. If subslab soil gasresults indicate site impacts will not result in unacceptable human health risk in indoor air, thevapor intrusion investigation will be concluded.

When a target building is entered for sump water or subslab soil gas sample collection, theindoor air will be monitored with a portable multigas meter to ensure flammable gasconcentrations do not exceed ten percent of the LEL as described in Section 5.4.1.1 of this SAPAddendum.

5.2 SAMPLE COLLECTION PROCEDURES

Sample collection activities wil l follow the procedures summarized in Section 2 of this SAPAddendum and described in the following subsections.

5.2.1 Sump Water Sampling

Water samples will be collected from each sump, where present, in each target buildingidentified in Figure 2-1. Sump water sample collection will be conducted during a minimum ofone sampling event prior to commencing additional vapor intrusion sampling activities. Aftersample collection of water encountered in the sump, the sump will be evacualed by activating the

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sump pump. Jf groundwater recharge into the sump is observed, a second sump water samplewil l be collected after a sufficient volume of water for sample collection has entered the sump.

5.2.1.1 Sump Water Sample Collection. Prior to sample collection, the water level in eachsump wil l be measured to the nearest 0.01 foot from the top of the sump using a Solinst®Model 101, or equivalent, electronic water level indicator; the total depth of each sump wi l l bemeasured to the nearest 0.01 foot from the top of the sump using a graduated, weighted, stainlesssteel tape; and the diameter or length and width of the sump will be measured to the nearest0.1 foot with a measuring tape.

Vertically-integrated water samples wil l be collected from each sump using dedicated 0.75-inchouter-diameter (OD) high density polyethylene (HOPE) disposable bailers, or equivalentequipment. Water samples will be transferred from each bailer into laboratory-suppliedcontainers using dedicated disposable VOC sampling attachments. After collection of the init ialsample of water encountered in the sump, the sump pump will be activated to evacuate the sump.If groundwater recharge into the sump is observed, depth to water will be measured and a secondsump water sample wil l be collected after a sufficient volume of water for sample collection hasentered the sump. If a sample is collected after groundwater recharge into the sump, only thissample wi l l be submitted for laboratory analysis.

Sample collection information will be recorded in the field book or on individual samplecollection record forms. Each sample will be assigned a sample number, packaged, and shippedto the analytical laboratory as discussed in Section 5.3 of this SAP Addendum.

5.2.1.2 Equipment and Materials. Required sump water sampling equipment will include thefollowing:

• Electronic water level indicator.

• Graduated, weighted, stainless steel tape.

• Decontamination equipment.

• Distilled water.

• Measuring tape.

• 0.75-inch OD disposable HDPE bailers with VOC sampling attachments, orequivalent equipment.

• Sample containers, which are provided by laboratory (type and quantity areprovided in Table 5-1 of this SAP Addendum).

• Field logbook, well development forms, groundwater sample collection record:;,sample labels, chain-of-custody forms, custody seals, shipping forms, and pen ormarker with indelible ink.

• Coolers, ice, and freezer bags.

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5.2.1.3 Equipment Decontamination. Nondedicated equipment that conies into contact withsump water wil l be decontaminated prior to use and between sumps. The wetted portion of thewater level indicator and steel tape will be rinsed with distilled water prior to use in anothersump. Disposable bailers and VOC attachments wi l l be dedicated for each sump sample toprevent cross-contamination of samples and sumps. Disposable nitrile gloves wi l l be wornduring sampling activities and changed, at a minimum, between samples to preventcross-contamination. Disposable materials generated during sampling activities wi l l be collectedand contained for proper disposal as municipal waste.

5.2.2 Subslab Soil Gas Sampling

Subslab soil gas samples will be collected through probes installed in foundations of targetbuildings selected to evaluate the vapor intrusion pathway (Figure 2-1). In each selectedbuilding, subslab soil gas samples wi l l be collected concurrently from a minimum of twodesignated locations during a minimum of two sampling events. One of the sampling events wi l lbe conducted in winter when minimum air exchange rates and maximum stack effects areexpected.

5.2.2.1 Subslab Soil Gas Probe Installation. A ut i l i ty locate wil l be conducted to mark entrypoints of u t i l i ty lines outside of each building prior to probe installation. Subslab soil gas probeswil l be assembled prior to creation of holes in a building foundation to minimize exposure timeof subslab soil to ambient air.

Subslab soil gas probes wil l be constructed from gas chromatography-grade stainless steel tubingand fittings to minimize contamination from residual cutting oil. If the slab Ihickness is greaterthan 1 inch, probes will be constructed of the following or equivalent components:

• '/4-inch outer diameter (OD) gas chromatography grade 316 stainless steel tubing.

• '/4-inch OD Swagelok® stainless-steel compression fittings.

If the slab thickness is less than 1 inch, probes will be constructed of the following or equivalentcomponents:

• '/4-inch OD stainless-steel hex bushings.

A rotary hammer drill, or equivalent equipment, will be used to create inner and outer holes toset the probe in the foundation. The larger diameter (e.g., l-inch-OD) shallow outer hole wil l bedrilled first and cleaned with a towel damp with VOC-free water prior to drilling the deepersmaller diameter (e.g., D-inch-OD) inner hole. The inner hole wil l be advanced in the center ofthe outer hole to penetrate 2 inches into the subslab material to create an open cavity to preventpotential obstruction of probes during sampling. After drilling the inner hole, the outer hole wil lbe cleaned again with a damp towel to improve the surface seal. The probe tubing wi l l beinserted into the inner hole allowing the fittings to rest at the base of the outer diameter hole. Acap or plug will be placed on the top of the fittings to close the probe.

After placing the probe into the inner and outer holes, the annular space between the probe andthe outer hole wil l be sealed with a quick-drying, lime-based cement that expands upon drying or

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equivalent material. The sealing material and any water used should be VOC-free. The outsidediameter of tubing inserted into the inner hole wi l l closely approximate the diameter of the innerhole to restrict movement of sealant down the hole and into subslab material. Cement wil l beallowed to cure for a minimum of 24 hours prior to sampling. Before sampling, the pressuredifferential between the subslab and indoor air w i l l be measured with a digital pressure gauge.

5.2.2.2 Subslab Soil Gas Sampling Manifold Construction. A sampling manifold wil l beconstructed to facilitate apparatus tightness tests, leak tests, purging, and sampling. Thesampling manifold wi l l include a "T" fitting constructed to connect the subslab soil gas probe tothe sample canister for sampling and to a portable peristaltic pump, vacuum pump, or equivalentdevice, for purging the probe and sample lines and for tightness and leak tests. A particulatefilter, flow controller, vacuum gauge, and valve provided by the laboratory wil l be attachedinline with the sample canister. The initial vacuum of the sample canister wil l be verified with adigital pressure gauge and recorded. After the sampling manifold is connected to the closedsample canister and securely capped at the probe inlet end, an apparatus tightness test wi l l beperformed by drawing a vacuum across the sampling manifold with a pump device andmonitoring the sampling manifold vacuum gauge. If the vacuum gauge indicates the samplingmanifold is not airtight, the connections wil l be adjusted and the sampling manifold will beretested unt i l passing the apparatus tightness test.

5.2.2.3 Subslab Soil Gas Probe Purging. After the sampling manifold has passed a tightnesstest, the subslab soil gas probe and sampling manifold wil l be purged prior to sampling toremove indoor air introduced into the system during installation and connection to the samplingmanifold. Three system volumes wi l l be purged prior to sample collection. A system volumeincludes the total internal volume of sample tubing and associated fittings between the probe andsample container, tubing and fittings associated with subslab gas probes, the open inner hole inthe slab below the probe tubing, and the cavity created in the subslab material during drilling.The system will be purged with a portable peristaltic pump, vacuum pump, hand pump, syringe,or equivalent device at one end of the "T" fitting. The in-line valve at the pump end will beopened and the in-line valve at the sample canister wil l remain closed for the system purging.After purging, the in-line valve at the pump end of the "T" fitting will be closed.

During system purging, a probe seal leak test wil l be conducted with a tracer gas. A shroud willbe placed over the probe, sampling manifold, and sample canister. Helium, or an equivalenttracer gas will be introduced into the shroud. Air purged from the system wil l be monitored forthe tracer gas with a field instrument. If the tracer gas is detected in the purged air, the systemprobe seal and system fittings wi l l be inspected and adjusted, as necessary.

5.2.2.4 Subslab Soil Gas Sample Collection. Time-integrated subslab soil gas samples willbe collected at a flow rate equal to or less than 200 milliliters per minute by using a calibratedflow controller attached to an evacuated sample canister. Following system purging, the samplecanister valve wi l l be opened to initiate sample collection. If possible, the sampling progresswil l be monitored periodically. At the end of the sampling period, the sample canister valve willbe closed and the final vacuum of the canister wil l be recorded. Purging and sample collectioninformation wi l l be recorded in the field book or on individual sample collection record forms.

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Each sample will be assigned a sample number, packaged, and shipped to the analyticallaboratory as discussed in Section 5.3 of this SAP Addendum.

5.2.2.5 Equipment and Materials. Required subslab soil gas sampling equipment willinclude the following:

• Vi-inch-OD gas chromatography grade 3J6 stainless steel tubing and '/4-inch-ODSwagelok® stainless-steel compression fittings; '/4-inch OD long stainless-steelhex bushings; or equivalent materials.

• Rotary hammer drill and drill bits, or equivalent equipment.

• Quick-drying, lime-based cement (VOC-free) that expands upon drying, orequivalent material.

• Laboratory-supplied deionized water.

• Towel.

• Sample canisters, which are provided by laboratory (type and quantity areprovided in Table 5-1 of this SAP Addendum).

• Paniculate filters.

• Vacuum gauges.

• Flow controllers.

• In-line valves.

• Stainless steel, nylon, or Teflon® tubing.

• Compression fittings.

• Compression fitting caps.

• Digital pressure gauge.

• Teflon® tape.

• Hand wrenches.

• Plastic file box shroud, or equivalent

• Bottled helium tracer gas, or equivalent.

• Portable helium meter, or equivalent.

• Flexible tubing.

• Tedlar® bags, or equivalent.

• Portable vacuum pump, hand pump, syringe, or equivalent pump device.

5.2.2.6 Equipment Decontamination. Sample canisters will be certified via the ATL processcertification program, through which a subset (10 percent) of canisters cleaned are evaluated bygas chromatography/mass spectroscopy (GC/MS) analysis. Probe and sampling manifoldmaterials will be dedicated to each sampling point and any tubing used between the probe andsampling manifold wil l be discarded after each use to eliminate the need for equipment

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decontamination. Flow controllers and particulate filters w i l l be cleaned by the laboratory aftereach use. Sampling systems wil l be purged before sample collection.

Disposable nitrile gloves wi l l be worn during subslab soil gas sampling activities and changed, ata minimum, between sampling points to prevent cross-contamination. Disposable materialsgenerated during sampling activities wi l l be collected and contained for proper disposal asmunicipal waste.

5.2.2.7 Corrective Action. If a sample canister vacuum is less than 25 inches mercury, thesample canister wi l l not be used for sample collection and a replacement canister wil l be ordered.If a sample canister vacuum gauge is not functioning properly, the gauge wi l l not be used forsample collection and a replacement gauge wi l l be ordered. If the vacuum gauge indicates thesampling manifold is not airtight, the connections wil l be adjusted and the sampling manifoldwill be retested unt i l passing the apparatus leak test. If a tracer gas is detected in collected airduring system purging, the system probe seal and system fittings will be inspected and adjusted,as necessary.

5.2.3 Soil Gas Sampling

Soil gas samples will be collected near selected target buildings identified in Figure 2-1 wherebuilding construction and/or subsurface conditions preclude collection of subslab soil gassamples. The exact sample locations near each building will be determined on site based onaccessibility, utilities, water table elevation, and building features. A minimum of two soil gassampling points wil l be sampled near each target location during each sampling event to addressspatial variability in soil gas concentrations.

5.2.3.1 Soil Gas Sample Point Installation. Temporary soil gas sample points will beinstalled using direct-push technology. Direct-push probe rods wil l be advanced to the desiredsoil gas sampling depth approximately 1 foot above the water table and then retracted a fewinches to disengage an expendable drive point. This action wil l expose soil between theexpendable drive point left in place and the expendable point holder located at the bottom of theprobe rods. A stainless steel adapter will be connected to nylon sample tubing, inserted downthrough the probe rods, and connected with the expendable point holder to complete thediscreet-depth soil gas sample point.

5.2.3.2 Soil Gas Sampling Manifold Construction. A sampling manifold will be constructedto facilitate apparatus tightness tests, leak tests, purging, and sampling. The sampling manifoldwil l include a "T" fitting constructed to connect the subslab soil gas probe to the sample canisterfor sampling and to a portable peristaltic pump, vacuum pump, or equivalent device, for purgingthe probe and sample lines and for tightness and leak tests. A particulate filter, flow controller,vacuum gauge, and valve provided by the laboratory will be attached inline with the samplecanister. The initial vacuum of the sample canister will be verified with a digital pressure gaugeand recorded. After the sampling manifold is connected to the closed sample canister andsecurely capped at the soil gas sample point end, an apparatus tightness test will be performed bydrawing a vacuum across the sampling manifold with a pump device and monitoring the

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sampling manifold vacuum gauge. If the vacuum gauge indicates the sampling manifold is notairtight, the connections wi l l be adjusted and the sampling manifold wi l l be retested un t i l passingthe apparatus tightness test. After passing the tightness test, the sampling manifold will beconnected to the soil gas sample point nylon tubing with a stainless steel compression fitting.

5.2.3.3 Soil Gas Sample Point Purging. The soil gas sample point and sampling manifoldwill be purged prior to sample collection to remove outdoor air introduced into the system duringinstallation and connection to the sampling manifold. Three system volumes wil l be purgedprior to sample collection. A system volume includes the total internal volume of the samplingmanifold, sample point tubing and associated fittings, and the cavity created in the exposedcavity created in the soil. The system wi l l be purged with a portable peristaltic pump, vacuumpump, hand pump, syringe, or equivalent device at one end of the "T" fitting. The in-line valveat the pump end wi l l be opened and the in-line valve at the sample canister wi l l remain closed forthe system purging. After purging, the in-line valve at the pump end of the "T" fitting wi l l beclosed.

During system purging, a probe seal leak test wi l l be conducted with a tracer gas. A shroud willbe placed over the soil gas sampling point, sampling manifold, and sample canister. Helium, oran equivalent tracer gas, wil l be introduced into the shroud. Air purged from the system wil l bemonitored for the tracer gas with a field instrument. If the tracer gas is detected in the purgedair, the system probe seal and system fittings wi l l be inspected and adjusted, as necessary.

5.2.3.4 Soil Gas Sample Collection. Time-integrated soil gas samples wi l l be collected at aflow rale equal to or less than 200 mill i l i ters per minute by using a calibrated flow controllerattached to an evacuated sample canister. Following system purging, the sample canister valvewill be opened to initiate sample collection. If possible, the sampling progress will be monitoredperiodically. At the end of the sampling period, the sample canister valve will be closed and thefinal vacuum of the canister will be recorded. Purging and sample collection information will berecorded in the field book or on individual sample collection record forms. Each sample will beassigned a sample number, packaged, and shipped to the analytical laboratory as discussed inSection 5.3 of this SAP Addendum.

5.2.3.5 Equipment and Materials. Required subslab soil gas sampling equipment wi l linclude the following:

• Direct-push rig and tools.

• Direct-push probe rods, expendable drive points, expendable drive pointconnectors, and adapters.

• Nylon tubing.



• Vacuum gauges.

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• In-line valves.

• Stainless steel, nylon, or Teflon® tubing.

• Compression fittings.

• Compression fitting caps.

• Digital pressure gauge.

• Teflon® tape.

• Hand wrenches.

• Plastic file box shroud, or equivalent

• Bottled helium tracer gas, or equivalent.

• Portable helium meter, or equivalent.

• Flexible tubing.

• Tedlar® bags, or equivalent.

• Portable vacuum pump, hand pump, syringe, or equivalent pump device.

5.2.3.6 Equipment Decontamination. Sample canisters will be certified via the ATL processcertification program, through which a subset (10 percent) of canisters cleaned are evaluated byGC/MS analysis. Soil gas sample point and sampling manifold materials wi l l be dedicated toeach sampling point and any tubing used between the sample point and sampling manifold willbe discarded after each use to eliminate the need for equipment decontamination. Flowcontrollers and paiticulate filters will be cleaned by the laboratory after each use. Samplingsystems wil l be purged before sample collection.

Disposable nilrile gloves will be worn during soil gas sampling activities and changed, at aminimum, between sampling points to prevent cross-contamination. Disposable materialsgenerated during sampling activities wi l l be collected and contained for proper disposal asmunicipal waste.

5.2.3.7 Corrective Action. If a sample canister vacuum is less than 25 inches mercury, thesample canister will not be used for sample collection and a replacement canister wil l be ordered.If a sample canister vacuum gauge is not functioning properly, the gauge will not be used forsample collection and a replacement gauge will be ordered. If the vacuum gauge indicates thesampling manifold is not airtight, the connections will be adjusted and the sampling manifoldwill be retested until passing the apparatus leak test. If a tracer gas is detected in collected airduring system purging, the system probe seal and system fittings will be inspected and adjusted,as necessary.

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5.2.4 Indoor Air Sampling

Indoor air sampling w i l l be conducted in buildings where subslab soil gas results indicate indoorair data is required to further evaluate vapor intrusion of site impacts. In each selected building,indoor air samples wil l be collected from a minimum of one designated location during aminimum of two sampling events. One of the sampling events wil l be conducted in winter whenminimum air exchange rates and maximum stack effects are expected. Indoor air samples wi l lbe collected from the breathing zone of the lowest level of the building. Prior to samplecollection, an indoor air quality building survey wi l l be conducted to identify and potentiallyeliminate potential indoor sources that could affect indoor air quality.

5.2.4J Indoor Air Sample Collection. Time-integrated indoor air samples will be collectedover a 24-hour period by using a flow controller attached to an evacuated sample canister. Thein i t i a l vacuum of the sample canister wil l be verified and recorded. The sample canister will beelevated or suspended, as needed, to collect air samples from the breathing zone. The samplecanister valve will be opened to initiate sample collection. If possible, the sampling progresswill be monitored periodically. At the end of the sampling period, the sample canister valve willbe closed and the final vacuum of the canister wi l l be recorded. Sample collection informationwill be recorded in the field book or on individual sample collection record forms. Each samplewil l be assigned a sample number, packaged, and shipped to the analytical laboratory asdiscussed in Section 5.3 of this SAP Addendum.

5.2.4.2 Equipment and Materials. Required indoor air sampling equipment will include thefollowing:



• Vacuum gauges.


• In-line valves.

• Digital pressure gauges.

5.2.4.3 Equipment Decontamination. Sample canisters will be certified via ATL's processcertification program, through which a subset (10 percent) of canisters cleaned are evaluated byGC/MS analysis. Flow controllers and paniculate filters will be cleaned by the laboratory aftereach use.

Disposable nitrile gloves will be worn during indoor air sampling activities and changed, at aminimum, between sampling points to prevent cross-contamination. Disposable materialsgenerated during sampling activities will be collected and contained for proper disposal asmunicipal waste.

5.2.4.4 Corrective Action. If a sample canister vacuum is less than 25 inches mercury, thesample canister will not be used for sample collection and a replacement canister wil l be ordered.

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If the sample canister vacuum gauge is not functioning properly, the gauge w i l l not be used forsample collection and a replacement gauge w i l l be ordered.

5.2.5 Outdoor Air Sampling

Outdoor air sampling wi l l be conducted concurrently with indoor air sampling in buildingswhere subslab soil gas results indicate indoor air data is required to further evaluate vaporintrusion of site impacts. Outside of each selected building, outdoor air samples will be collectedfrom a minimum of one designated location during a minimum of two sampling events. One ofthe sampling events wil l be conducted in winter when minimum air exchange rates andmaximum stack effects are expected in the building. Outdoor air samples wil.1 be collected nearthe building ventilation system air intake or from the upwind direction of the building, asappropriate.

5.2.5.1 Outdoor Air Sample Collection. Time-integrated outdoor air samples will becollected over a 24-hour period by using a flow controller attached to an evacuated samplecanister. The ini t ia l vacuum of the sample canister wi l l be verified and recorded. The samplecanister wil l be elevated or suspended, as needed, to collect air samples from a representativelocation upwind or near the ventilation system air intake, if operating, of the building. Thesample intake wil l be located three to five feet off the ground (at the approximate midpoint of theground level) and about five to fifteen feet away from the building and wind obstructions. Thesample canister valve will be opened to initiate sample collection. If possible, the samplingprogress will be monitored periodically. At the end of the sampling period, the sample canistervalve will be closed and the final vacuum of the canister will be recorded. Sample collectioninformation wi l l be recorded in the field book or on individual sample collection record forms.Each sample wil l be assigned a sample number, packaged, and shipped to the analyticallaboratory as discussed in Section 5.3 of this SAP Addendum.

5.2.5.2 Equipment and Materials. Required indoor air sampling equipment wil l include thefollowing:

• Sample canisters, which are provided by laboratory (type and quantity aieprovided in Table 5-1 of this SAP Addendum).


• Vacuum gauges.


• In-line valves.

• Digital pressure gauges.

5.2.5.3 Equipment Decontamination. Sample canisters will be certified via ATL's processcertification program, through which a subset (10 percent) of canisters cleaned are evaluated byGC/MS analysis. Flow controllers and paniculate filters will be cleaned by the laboratory aftereach use.

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Disposable nitrile gloves will be worn during indoor air sampling activities and changed, at aminimum, between sampling points to prevent cross-contamination. Disposable materialsgenerated during sampling activities wil l be collected and contained for proper disposal asmunicipal waste.

5.2.5.4 Corrective Action. If a sample canister vacuum is less than 25 inches mercury, thesample canister wi l l not be used for sample collection and a replacement canister wil l be ordered.If the sample canister vacuum gauge is not functioning properly, the gauge will not be used forsample collection and a replacement gauge wi l l be ordered.

5.3 SAMPLE HANDLING AND CUSTODY

To ensure samples are identified correctly and remain representative of the environment, thesample documentation and custody procedures outlined in this section wi l l be adhered to duringthe sampling program to maintain and document sample integrity during collection,transportation, storage, and analysis. Field sampling personnel wi l l be responsible for ensuringproper documentation and custody procedures are initiated at the time of sample collection, andindividual samples can be tracked from the time of sample collection unt i l custody of thesamples is transferred to the laboratory. ATL and Keystone will be responsible for maintainingsample custody and documentation from the time the laboratory receives the samples until finalsample disposal.

5.3.1 Sample Containers and Preservation

Each water sample container wil l be obtained from Keystone specifically for this investigation.Keystone will be responsible for cleaning and preparing the containers as well as adding orproviding the appropriate preservatives. Methods of sample preservation are intended to:1) retard biological action, 2) retard hydrolysis, and 3) reduce sorption effects. The samplepreservatives are listed in Table 5-1 of this SAP Addendum. In addition, the collected sampleswi l l be thermally preserved by being kept in a refrigerator or iced cooler to cool the samples to atemperature of 4 ± 2 degrees Celsius (°C) until received by the laboratory. Care wi l l be takenduring sample collection to verify preservatives have been added to containers and theappropriate containers have been supplied. Samples collected during subfreezing temperatureswil l be protected from freezing.

Sample canisters, paniculate filters, and flow controllers wil l be obtained from ATL specificallyfor this investigation. ATL wil l be responsible for cleaning and preparing the canisters,paniculate filters, and flow controllers. The sample canister used for soil gas and air samplecollection and analysis do not require chemical or temperature preservation.

Any containers suspected of improper cleaning or preparation will not be used. Prior to use,containers will be stored in a clean, dry environment to prevent exposure to fuels, solvents, andother contaminants. Samples wi l l be collected in the containers and analyzed within the holdingtimes specified in Table 5-1 of this SAP Addendum.

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5.3.2 Sample Labels and Designation

Sample canisters for soil gas or air samples wil l be identified by sample tags. Sample containersfor water samples wil l be labeled immediately before sample collection using indelible ink. At aminimum, the tags and labels wi l l include the following information:

• Site Name.

« Sample Designation.

• Analysis Requested.

• Type of Preservative Added, if any.

• Date.

• Time.• Initials of Sampler.

Additional information, as applicable, will also be included on the label.

The sample designation scheme wi l l provide each sample with a unique number throughcollection, analysis, validation, and data reduction. Each sample number will consist of thefollowing components: sample location type, sample location, sample matrix, and monitoringevent. The specific samples are designated as follows:

KKnn - TT - i i i i

Where,

KK is the sample location type:• BL = Building.

nn designates the specific sample location:

for BL prefixes, nn is a number or letter designation for a specified building.

TT is the sample matrix or the matrix for which a field QC sample is analyzed:• IA = Indoor Air.• OA = Outdoor Air.• SG = Soil Gas.• SS = Subslab Soil Gas.• SW = Sump Water.

i i i i represents the number of the sample in a series of samples or sampling events:

For water, subslab soil gas, soil gas, indoor air, and outdoor air samples, i i i i , isthe one-digit number or letter designation of a specific sampling locationfollowed by the three-digit sequential sample collected associated with abuilding.

This designation will be placed on each sample container label or tag prior to sample collection.

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5.3.3 Sample Packaging and Shipment

Sample canisters wi l l be placed in boxes with packing material provided by the laboratory. Theoriginal completed chain-of-custody (COC) form wil l be placed in a waterproof plastic baginside one of the submitted boxes or relinquished directly to laboratory personnel. The boxeswill be secured with packaging tape. Each box wi l l be shipped by overnight earner 1:0 thelaboratory or transported to the laboratory by MWH or the laboratory courier.

Water samples w i l l be immediately placed in a hard plastic cooler. Samples w i l l be maintainedon sufficient wet ice to cool the samples to 4 ± 2 °C. Sufficient packing material wil l be placedin each cooler to minimize the potential for sample bottles to shift and become damaged orbroken. The original completed COC form wil l be placed in a waterproof plastic bag inside oneof the submitted coolers or relinquished directly to laboratory personnel. The lid will be securedby taping around the cooler. A custody seal wil l be placed between layers of tape securing mecooler. The cooler wi l l be shipped by overnight earner to the laboratory or transported to thelaboratory by MWH or the laboratory courier.

5.3.4 Sample Records and Custody

Sample records and custody will be maintained, as described in Section 3.3.3 of the focusedRI/FS SAP (MWH, 2005a).

5.4 ANALYTICAL METHODS

The vapor intrusion investigation activities will include both field screening and laboratoryanalytical procedures, which are described in this section.

5.4.1 Field Screening

MWH Field Staff will conduct field screening procedures for flammable gases and helium.

5.4.1.1 Flammable Gas. A portable multigas meter wi l l be used to monitor total flammablegas concentration in indoor air. The multigas meter wil l be operated and calibrated according tothe manufacturer operation manual. When entering a target building for sampling activities,MWH Field Staff wil l walk, at a minimum, the indoor perimeter of the bui lding level to besampled with a portable multigas instrument to ensure ten percent of the LEL is not exceeded inindoor air.

5.4.1.2 Helium Tracer Gas. Leak tests using helium as a tracer gas will be conducted to detectequipment leaks during subslab soil gas and soil gas purging and sample collection. A shroudfilled with helium wi l l be placed over the sample probe or point, sampling manifold, and samplecanister. Subslab soil gas or soil gas purged from the sampling system wil l be drawn intoTedlar® bags with a portable pump. A portable helium meter will be used by MWH Field Staff

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to monitor helium concentrations in the Tedlar bags and inside the helium shroud. The heliummeter wi l l be operated and calibrated according to the manufacturer operation manual.

5.4.2 Laboratory Analytical Procedures

ATL will conduct the subslab soil gas, soil gas, indoor air, and outdoor air analyses specified inTable 2-1 of this SAP Addendum. Keystone wi l l conduct the water analyses specified inTable 2-1 of this SAP Addendum. The analytical methods selected wi l l support the projectDQOs and data end use, and the associated MRLs or MLDLs will meet levels appropriate forhuman health risk assessments. The individual laboratory method SOPs are based upon methodsdocumented in Table 2-1 of this SAP Addendum, with revisions or in accordance with otherapproved testing procedures. These methods are from approved sources and have knownaccuracy and precision.

The following criteria for reporting laboratory analytical data wil l apply for all samples:

• Target analytes not detected above the MDL wil l be reported (at a minimum) asless than the RL.

• If the level of concern (e.g., target indoor air concentration) of a specificcompound is less than the MRL, the sample data wil l be reported to the MDL.

• If target analytes are detected between the MDL and MRL, they wi l l be reportedas quantified and qualified with a flag to indicate the data are estimated.

« If target analytes are detected at or above the MRL, they will be reported asquantified.

If analytical problems arise, ATL and Keystone wi l l follow method and internal laboratorycorrective action procedures.

5.5 QUALITY CONTROL

The QC parameters, samples, procedures, and criteria that wil l be used to evaluate analytical dataof the vapor intrusion investigation are described in applicable portions of Section 5.5 of thefocused RI/FS SAP (MWH, 2005a), with the following additions:

• The holding times for the vapor intrusion investigation analytical methods arelisted in Table 5-1 of this SAP Addendum.

• ATL and Keystone wil l be responsible for the proper calibration and maintenanceof laboratory analytical equipment.

• MRLs are listed in Table 4-4 of this SAP Addendum.

• QC sample data wil l be evaluated in terms of data quality indicators as shown inTable 4-2 of this SAP Addendum.

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5.6 EQUIPMENT/INSTRUMENT TESTING, INSPECTION, AND MAINTENANCE

A preventative maintenance program wi l l be in place to promote the timely and effectivecompletion of the vapor intrusion investigation measurement efforts, as described in applicableportions of Section 5.6 of the focused Rl/FS SAP (MWH, 2005a).

5.7 INSTRUMENT/EQUIPMENT CALIBRATION PROCEDURES ANDFREQUENCY

Instruments and equipment will be calibrated as described in applicable portions of Section 5.7of the focused Rl/FS SAP (MWH, 2005a).

5.8 INSPECTION/ACCEPTANCE REQUIREMENT OF SUPPLIES ANDCONSUMABLES

Supplies and consumables will be inspected and accepted according to Section 5.8 of the focusedRl/FS SAP (MWH, 2005a).

5.9 NON-DIRECT MEASUREMENTS•

Non-direct measurement data may be used as described in Section 5.9 of the focused Rl/FS SAP(MWH, 2005a).

5.10 DATA MANAGEMENT

Data wil l be managed as described in Section 5.10 of the focused Rl/FS SAP (MWH, 2005a),with the following addition:

• Water, subslab soil gas, soil gas, indoor air, and outdoor air sample collectioninformation wil l be recorded in the field book or on individual sample collectionrecord forms.

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SECTION 6

ASSESSMENT AND OVERSIGHT

QA assessment activities, corrective actions, and reports to management associated wkh thevapor intrusion investigation wil l be completed as described in Section 6 of the focused RT/FSSAP (MWH, 2005a).

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SECTION 7

DATA VALIDATION AND USABILITY

Data review, verification, validation, and reconciliation procedures wil l be conducted during thevapor intrusion investigation as described in Section 7 of the focused RI/FS SAP (MWH, 2005u).

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SECTION 8

REFERENCES

American Society for Testing and Materials (ASTM), 2007. Standard Test Method Analysis ofNatural Gas by Gas Chromatography. ASTM D-1945. Volume 05.06. September 2007.

EPA, 1999. Compendium of Methods for the Determination of Toxic Organic Compounds inAmbient Air. Second Edition. Compendium Method TO-15. Determination of VolatileOrganic Compounds (VOCs) in Air Collected In Specially-Prepared Canisters And Analyzedby Gas Chromatography/Mass Spectrometry (GC/MS). January 1999.

EPA, 2000. Guidance for Data Quality Objective Process (EPA QA/G-04). Office ofEnvironmental Information. EPA/600/R-96/055, August 2000.

EPA, 2001. Requirements for Quality Assurance Project Plans. EPA QA/G-5, March 2001.

EPA, 2002c. Guidance for Quality Assurance Project Plans. EPA/240/R-02/009, December 2002.

EPA, 2002d. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathwayfrom Groundwater and Soils (Subsurface Vapor Intrusion Guidance). EPA/530-D-02-004.November 2002.

EPA, 2006. Assessment of Vapor Intrusion in Homes Near the Raymark Superfund Site UsingBasement and Sub-Slab Air Samples. EPA/600/R-05/147. March 2006.

EPA, 2008. Regional Screening Levels for Chemical Contaminants at Superfund Sites. EPA,July 7, 2008.

Interstate Technology Regulatory Council (1TRC), 2007. Vapor Intrusion Pathway: A PracticalGuide. January 2007.

MADEP, 2002. Indoor Air Sampling and Evaluation Guide. WSC Policy #02-430. April 2002.

MWH, 2005a. Focused Remedial Investigation/Feasibility Study Sampling and Analysis Plan.Clinton Manufactured Gas Plant Site. April 2005.

MWH, 2005b. Focused Remedial Investigation/Feasibility Study Work Plan. ClintonManufactured Gas Plant Site. April 2005.

National Institute for Occupational Safety and Health (NIOSH), 2006. NIOSH Pocket Guide toChemical Hazards. August 2006.

New Jersey Department of Environmental Protection (NJDEP), 2005. Vapor IntrusionGuidance. October 2005.

P-\Word PrccessingWU-IANT-IPUClinlon-FMGP Sile\FOCUSED kl WORK PLAN ADDENDA\2008 FOCUSED Rl WORK I'LAN AI3IDENDUM\0<)-08-l:ocuscd Rl Work Pl.in Addi:ndumVW-08-APPI;NDIX A - Sampling and Analysis Finn Acldcndum\09-OS-R>cusetl RI-I:S SAP Atlachineiil.doc

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TABLES

WITH ATTACHED

DECEMBER 2008 FOCUSED REMEDIAL INVESTIGATION WORK PLANADDENDUM APPENDIX A - FOCUSED REMEDIAL INVESTIGATION/FEASIBILITY


TABLES

TABLE 2-1

ANALYTICAL PARAMETERS

AnalyteSump Water SampleAnalytical Method

Subslab Soil and Soil Gas SampleAnalytical Method

Indoor Air and Outdoor Air SampleAnalytical Method

VOC COPCs

Benzene

Ethylbenzene

Toluene

m,p-Xylene

o-Xylene

Naphthalene

Leak Test Tracer GasHelium

SW-846 8260 Modified TO-15 High/Low Level with SIM





SW-846 8260 Modified TO-15 Low Level

NA Modified ASTM D-1945

Modified TO-15 High/Low Level with SIM





Modified TO-15 Low Level

NA

Notes:ASTM D-1945 = Standard Test Method Analysis of Natural Gas by Gas Cliroinatogmphy, (American Society for Testing and Materials. 2007).NA = Not applicable.SIM = Selected ion monitoring.SW-846 = Test Methods for Evaluating Solid Wnste, SW-846, Physical/Chemical Methods, 3rd Edition, Washington. D.C., (United States

Environmental Protection Agency [EPA], 1986).TO-15 = Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air. Second Edition. Compendium Method

TO-15. Determination of Volatile Organic Compounds (VOCs) in Air Collected In Specially-Prepared Canisters and Analyzed bv GasCliroinaiography/Mass Spectroinetry (GC/MS) (EPA, 1999).

VOC COrC = Volatile organic compound constituent of potential concern.

Page 1 of 1

TABLE 4-1

VAPOR INTRUSION INVESTIGATION ACTION LEVELS

SumpWater

AnalytcMethod Reporting

Limit

Suhslab Soil Gas, Soil Gas, andIndoor Air

Target Indoor AirConcentration"

(ug/m') (ppbv)

IndoorAir

Lower ExplosiveLimit

Benzene

Ethylbenzene

Naphthalene

Toluene

Xylenes, Total

m-Xylene

o-Xylene

p-Xylene

1.0

1.0

1.0

1.0

2.0

NE

NE

NE

0.31

2.2

0.072 / 7.2 h

400

7,000

NE

NE

NE

0.098

0.51

0.0 1 37 /1. 37 b

110

1,600

NE

NE

NE

N-\

NA

NA

NA

NA

NA

NA

NA

Total Flammable Gas NA NA NA Ten Percent

Notes:" = To comply with prescribed cancer risk of 1E-06 and non-cancer target hazard index of 1 for residential

exposure scenario. The benzene, ethylbcnzene, toluene and xylenes target indoor air concentrations arepresented in Table 2C of OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathwayfrom Groiimlwater and Soils (Subsurface Vapor Intrusion Guidance) (EPA, 2002d). The naphthalene targetindoor air concentration is an updated number provided in the Residential Air Supporting Table in the July7, 2008 version of Regional Screening Levels for Chemical Contaminants at Superfiind Sites (EPA. 2.008).

h = The target indoor air concentration for naphthalene corresponding to 1E-06 cancer risk(0.072 ug/m3) is two orders of magnitude smaller than the laboratory method reporting l imit for naphthaleneby Modified TO-15 Low Level (2.62 ug/m3), as listed in Table 4-4 of this QAPP. Therefore, 7.2 ng/nr,which corresponds to a cancer risk of 1E-04, wil l be used as an action level for subslab soil gas, indoor air,and outdoor air naphthalene concentrations during this vapor intrusion investigation.

ug/L = Microgram(s) per liter.ug/m3 = Microgram(s) per cubic meter.NA = Not applicable.NE = Not established.ppbv = Part(s') per billion volume.

Page 1 of 1

TABLP5-2

QUALITY CONTROL SAMPLE DATA EVALUATION IN TERMS OF DATA QUALITY INDICATORS

Data QualityIndicator Quality Control Program Evaluation Criteria

Prec-ision

Accuracy

Representativeness

Comparability

Completeness

Sensitivity

Traceability

Field Duplicate Sample PairsLaboratory Control Standard/Laboratory Control Standard Duplicate PairsMatrix Spike/Matrix Spike Duplicate Sample Pairs

Initial CalibrationInitial and Continuing Calibration Verification StandardsInstrument Performance CheckInternal StandardsLaboratory Control StandardsLaboratory Control Standard DuplicatesMatrix Spike SamplesMatrix Spike Duplicate SamplesMethod BlanksSurrogate SpikesTrip Blanks

Field Duplicate Sample PairsQuality Assurance Project Plan ComplianceTightness TestLeak Test with Tracer GasHolding TimeReporting Limits

Standard Field ProceduresStandard Analytical MethodsStandard Units of Measure

Number of Samples CollectedValid Data (all data except "R" flagged data)

Reporting Limits

Field DocumentationChain.-of-Custody DocumentationAnalytical Reports

Relative Percent DifferenceRelative Percent DifferenceRelative Percent Difference

Relative Standard DeviationPercent Difference/Percent DriftQuantitative, Degree of ConfidenceQuantitative, Degree of ConfidencePercent RecoveryPercent RecoveryPercent RecoveryPercent RecoveryQuantitative, Degree of ConfidencePercent RecoveryQuantitative, Degree of Confidence

Quantitative/Qualitative, Degree of ConfidenceQualitative, Degree of ConfidenceQualitative, Degree of ConfidenceQuantitative/Qualitative, Degree of ConfidenceQualitative. Degree of ConfidenceQuantitative/Qualitative, Degree of Confidence

Qualitative, Degree of ConfidenceQualitative. Degree of ConfidenceQualitative, Degree of Confidence

Percent Samples CollectedPercent Acceptable Data

Quantitative/Qualitative, Degree of Confidence

Qualitative, Degree of ConfidenceQualitative., Degree of ConfidenceQualitative, Degree of Confidence

Paee 1 of 1

TABLE 4-3

LABORATORY QUALITY CONTROL SUMMARY

Analytical Method Parameter DQI QC Element Frequency Acceptance Criteria Corrective Action

SW-846 8260B BTEXNaphthalene

Accuracy

Accuracy

Accuracy

Accuracy

InstrumentPerformance Check

Initial Calibration

ICV(from second source)

CCV

Accuracy Method Blank

Accuracy Surrogate Spike

At beginning of eachanalytical batch.Every 12 hours ofanalysis.

Prior to analysis.As required.

Once, immediatelyfollowing the init ialcalibration.

Meet 4-hromofluorobenzene massintensity criteria listed in Table 4of the method.

Consists of minimum of 5 points.RSD< 15% or r> 0.990 fortarget analytes.

RF> 0.10 for chloromethane; 1,1-dichloromethane; and bromoform.RF > 0.30 for chlorobenzene and1.1,2,2-tetrachloroethane.RSD < 30% for CCCs.

At beginning of each • RF> 0.10 for chloromethane; 1,1-analytical batch.Every 12 hours ofanalysis.

1 per analytical batch<20 samples.Following each CCV.

Every sample,standard, methodblank, LCS, andMS/MSD

dichloromethane; and bromoform.RF > 0.30 for chlorobenzene and1,1,2,2-tetrachloroethane.%D < 20% for CCCs and targetanalytes.

<MRL.

%R within the laboratorygenerated control l imi ts(refer to l imits reported inlaboratory analytical report).

Retime instrumentRepeat standard analysis.

Evaluate system.Repeat calibration.


Evaluate system/standard.Reanalyze calibration checkstandard.Repeat i n i t i a l calibration.Repeat sample analysis tolast acceptable CCV.

Locate and eliminate sourceof contamination.Reanalyze method blank.Flag affected target analyteresults in affected samples.

Reanalyze sample.Flag affected analyte resultsin affected samples.

Pase 1 of 5

TABLE 4-3 (CONTINUED)


Analytical Method Parameter DQI

SW-S46 8260B BTEX Accuracy(continued) Naphthalene

(continued)

QC Element Frequency

MS • 1 per analytical batchof <20 samples.

Acceptance Criteria

• %R within the laboratorygenerated control l imits(refer to l imits reported inlaboratory analytical report).

Corrective Action

• Reanalyze sample.• Flag affected analyte results

in affected samples.

Accuracy andPrecision

Accuracy

Accuracy

MSD

LCS

IS

Representativeness Holding Time

1 per analytical batchof <20 samples.

1 per analytical batchof <20 samples.

Every sample,standard methodblank, LCS, andMS/MSD.

Every sample.

Representativeness Sample Preservation • Every sample.

ModifiedEPA TO-15

BTEXNaphthalene

Accuracy InstrumentPerformance Check

Prior to analysis.Every 24 hours ofanalysis.

%R and/or RPD within laboratorygenerated control l imits (refer tolimits reported in laboratoryanalytical report).

%R wi th in the laboratorygenerated control l imits(refer to limits reported inlaboratory analytical report).

RT ±30 seconds of RT of mostcurrent CCV IS RT.EICP area 50% to 200% of mostcurrent CCV IS EICP area.

Analysis within 14 days ofcollection.

2 to 6 degrees Celsius.For liquids: pH < 2.

Meet mass spectral ion abundancecriteria for bromofluorobenzenestandard, as specified in Table 3of method.



Dilute sample extract andreanalyze data.Flag affected data.Evaluate and correct system.Reanalyze sample.

Flag affected analyte resultsin affected samples.

Analyze within 7 days, ifpossible.Flag affected analyte resultsin affected samples.

Retune instrument.Repeat standard analysis.

Page 2 of 5




ModifiedEPA TO-15(continued)

BTEXNaphthalene(continued)

Accuracy Initial Calibration

Accuracy ICV

Accuracy CCV

Accuracy Method Blank

Prior to analysis.Following instrumentperformance check.Following sufficientcorrective action.

Once, immediatelyfollowing the ini t ia lcalibration.

Every 24 hours ofanalysis.

Minimum of 5 concentrationlevels, with 1 level near MRL.%RSD <30%.

%R + 30% for BTEX and %R +40% for naphthalene, between theaverage response of thecalibration standards and the ICV.Standard from second source.



%D <30% for each target analyte • Evaluate system/standard.between the CCV RF and theaverage RF of the in i t ia lcalibration curve.

1 per analytical batch. • <MRL.

Reanalyze calibration checkstandard.Repeat ini t ia l calibration.Repeat sample analysis tolast acceptable CCV.

Locate and eliminate sourceof contamination.Reanalyze method blank.Flag affected target analyteresults in affected samples.

Accuracy Surrogate Spike • Every sample,standard, methodblank, and LCS.

• %R70-130%. • Reanalyze sample.• Flag affected analyte results


Pa°e3o f5




ModifiedEPA TO- 15(continued)

BTEXNaphthalene(continued)

Accuracy LCS

Accuracy and LCSDPrecision

• 1 per analytical batch.

• 1 per analytical batch.

• %R 70-130% for BTEX and60-140% for naphthalene.

• %R 70-130% for BTEX and60-140% for naphthalene.

• %RPD ± 25%.

• Reanalyze sample.• Flag affected analyte results

in affected samples.• Reanalyze sample.• Flag affected analyte results


Accuracy IS


ModifiedASTMD-1945

Helium Accuracy Initial Calibration

Every sample,standard, methodblank, and LCS.

Every sample.

Prior to analysis.Following sufficientcorrective action.

Sample IS RT ±30 seconds of RTof most current CCV IS RT.Sample IS EICP area-50% to +200% of currentCCV IS EICP area.

Analysis within 30 days ofcollection.

Minimum of 3 concentrationlevels, with 1 level near MRL.%RSD<15%.

Dilute sample extract andreanalyze sample.Flag affected data.Evaluate and correct system.Reanalyze sample.



Accuracy

Accuracy

ICV

CCV

Once, immediatelyfollowing the initialcalibration.

Every 24 hours ofanalysis.

%R + 15%, between the averageresponse of the calibrationstandards and the ICV.Standard from second source.


%D <159o for each target anulyle • Evaluate system/standard.between the CCV RF and theaverage RF uf the in i t ia lcalibration curve.

Reanalyze calibration checkstandard.Repeat in i t i a l calibration.Repeat sample analysis tolast acceptable C'C'V.

Page 4 of 5



Analytical Method

ModifiedASTMD-1945(continued)

Parameter DQI

Helium Accuracy(Continued)

QC Element Frequency Acceptance Criteria

Method Blank • 1 per analytical batch. • < MRL.

Corrective Action

• Locate and eliminate sourceof contamination.

• Reanalyze method blank.• Flag affected target anulyte

results in affected samples.

Accuracy LCS

Accuracy and LCSDPrecision


1 per analytical batch. • %R 85-115%.

1 per analytical batch. • %R 85-115%.• %RPD ± 25%.

Every sample. Analysis within 30 days ofcollection.




Notes:% = Percent.%D = Percent difference.%R = Percent recovery.BTEX = Benzene, toluene, ethylbenzene, and xylenes.CCV = Continuing calibration verification standard.DQI = Data quality indicator.EICP = Extracted ion current profile.ICV = Initial calibration verification standard.

IS = Internal standard.LCS = Laboratory control standard.MDL - Method detection l imi t .MRL = Method reporting l imit .QC = Quality control.RF = Response factor.RPD = Relative percent difference.RT = Retention time.

Modified ASTM D-1945= Standard Test Method Analysis of Natural Gas by Gas Chromatography, American Society for Testing and Materials (ASTM), (ASTM, 2007) asmodified by ATL.

Modified TO-15 = Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air. Second Edition. Determination of Volatile OrganicCompounds (VOCs) in Air Collected In Specially -Prepared Canisters and Analzyed by Gas Chromarography/Mass Specrrometry (GC/MS), (United Stales EnvironmentalProtection Agency [EPA], 1999) as modified by ATL.

SW-846 = Test Methods for Evaluating Solid Waste. SW-846, Physical/Chemical Methods. 3'd Edition, Washington, D.C.. (EPA, 1986).

Page 5 of 5

TABLE 4-4

METHOD REPORTING LIMITS

Method Reporting Limit"

Analytical Method Analyte (ppbv) Percent

Modified TO-15 High/Low Level with SIMModified TO-15 High/Low Level with SIM

Modified TO-15 Low LevelModified TO-15 High/Low Level with SIMModified TO-15 High/Low Level with SIMModified TO-15 High/Low Level with SIM

BenzeneEthylbenzeneNaphthaleneToluenem,p-Xyleneo-Xylcne

NANANANANANA

0.160.0872.620.0750.170.087

0.0500.0200.500.0200.0400.020

NAMANAMANANA

Modified ASTMD-1945 Helium NA NA NA

Notes:

0.050

SW-846 8260BSW-846 8260BSW-846 8260BSW-846 8260BSW-846 8260B

BenzeneEthylbenzeneNaphthaleneTolueneXylenes, Total

1.01.01.01.02.0

NANANANANA

NANANANANA

MAMANAMANA

a = Reporting limits are instrument- and time-specific (based on laboratory standard operating procedureschedule for update). Laboratory will use most current reporting limits. The values listed in this table areadvisory only. Subslab soil gas, soil gas, indoor air, and outdoor air sample method reporting limitsassume a one-liter sample analysis volume from a six-liter canister; actual reporting limits wi l l be higherdepending on the canister dilution factor and/or sample matrix effects.

ug/L = Microgram(s) per liter.

ug/m3 = Microgram(s) per cubic meter,

ppbv = Part per billion volume.

Modified ASTM D-1945 = Standard Test Method Analysis of Natural Gas by Gas Cliromatography,American Society for Testing and Materials (ASTM, 2007) as modified by ATL.

Modified TO-15 = Compendium of Methods for the Determination of Toxic Organic Compounds in AmbientAir. Second Edition. Compendium Method TO-15. Determination of Volatile OrganicCompounds (VOCs) in Air Collected In Specially-Prepared Canisters And Analyzed by-Gas Chromatography/Mass Spectroinetry (GC/MS) (United Slated EnvironmentalProtection Agency [EPA], 1999) as modified by ATL.

SW-846 = Test Methods for Evaluating Solid Waste, SW-846, Physical/Chemical Mothods,3rd Edition, Washington, D.C., (EPA, 1986).

SIM = Selected ion monitoring.

NA = Not applicable.

Page 1 of 1

TABLE 4-5

DATA REPORTING REQUIREMENTS

Data Type Analysis Type Data Reporting Requirement Report Format

Building Survey Documentation

Subslab Soil Gas DocumentationProbe and Soil GasSample PointConstruction Details

Subslab Soil Gas and DocumentationSoil Gas SamplingManifoldConstruction Details

Screening Data: Pressure DifferentialSubslab Soil Gas andSoil Gas

Tightness Test

Leak Test

Screening Data: Flammable GasIiiuuui ail Coiiccniialioiii

Sample Collection Documentation

Location and type of potential sources of background air contamination.Building characteristics, occupancy, and factors that may influence indoor airquality.

Location, date, and time installed.Type and amount of tubing, fit t ing, and seal materials.

Location, date, and time installed.Type and amount of tubing, fitting, filter, flow controller, vacuum gauge, andvalve materials.

Location, date, and time measurement collected.Initial and continuing calibration data.Pressure data from subslab and indoor air.Pressure data from subsurface soil and outdoor air.

Location, date, and time measurement collected.Ini t ial and continuing calibration data.

Location, date, and time measurement collected.Init ial and continuing calibration data.Tracer gas data.

Location, date, and time measurement collected.Initial and continuing calibration data.Lower explosive l imit data.

Location, date, time interval, and time sample collected.Initial and final sample canister vacuum.

Project-specific field form orlogbook.






Project-specific field form oriogbouk.


Page 1 of 2

TABLE 4-5

DATA REPORTING REQUIREMENTS

Data Type Analysis Type Data Reporting Requirement Report Format

DefinitiveOrganic orInorganic Data

Specified LaboratoryMethods

Case narrative (including project name and number, condition of samplesreceived, date of issuance, analyses performed, any deviations fromrequested analytical methods, preparation and/or analytical batchnumbers, number of samples per matrix analyzed, dates of samplepreparation and analysis, holding time evaluation, samples not meetingQC criteria, out of control conditions, corrective actions, and matrixeffects with justification,).

Completed COC, sample receipt, and log-in forms.Cross reference of laboratory to project sample IDs.Sample preparation and analysis methods.Ini t ia l calibration summary.Instrument performance check resultsContinuing calibration summary.Internal standard area and retention time summary (if applicable).Target compound results for all samples, including field QC samples and

dilution factors, reporting limits, reanalysis, batching information, andbracketing information.

Method blank results.MS/MSD results (spike concentration, actual values, percent recovery, and

relative percent difference).LCS/LCSD results (spike concentration, actual values, percent recovery,

and relative percent difference).Surrogate results, organic analysis (spike concentration, actual values, and

percent recovery).Manually iriicgiaied data.

Signature of reviewer.

Electronic data deliverable andhard copy.

Notes:COCLCS/LCSD =MS/MSD =QC

Chain of custodyLaboratory control standard/laboratory control standard duplicate.Matrix spike/matrix spike duplicate.Quality control.

Page 2 of 2

TAI^EE 5-1

SAMPLE CONTAINER AND ANALYSIS SUMMARY

Parameter

Sump WaterBenzeneEthylbenzeneNaphthaleneTolueneXylenes, Total

Subslab Soil Gas and Soil GasBenzeneEthylbenzeneNaphthaleneToluenem,p-Xyleneo-XyleneHelium

Indoor and Outdoor AirBenzeneEthylbenzeneNaphthaleneToluenem,p-Xyleneo-Xylene

ContainerMethods Container Type Quantity/Size

SW-846 8260B Glass Purge Vial Three 40-mLSW-846 8260BSW-846 8260BSW-846 8260BSW-846 8260B

Modified TO- 15 High/Level with SIM Summa® Canister One 6-LModified TO- 15 High/Level with SIMModified TO- 15 Low LevelModified TO-15 High/Level with SIMModified TO-15 High/Level with SIMModified TO-15 High/Level with SIMModified ASTMD- 1945

Modified TO- 1 5 High/Level with SIM Summa® Canister One 6-LModified TO-15 High/Level with SIMModified TO-15 High/Level with SIMModified TO-15 High/Level with SIMModified TO-15 High/Level with SIMModified TO-15 High/Level with SIM

Preservative Holding Time

Cool,4±2°C 14 Daysl : l H C l t o p H < 2

None 30 Days

None 30 Days

Notes:

ASTMD-1945 Standard Test Method Analysis of Natural Gas by Gas Chromatograpliy. Annual Book of ASTM Standards. Volume 05.06(American Society for Testing and Materials [ASTMJ, 2007).

SW-846 Test Methods for Evaluating Solid Waste, SW-846, Physical/Chemical Methods, 3rd Edition, Washington, D.C.,(United States Environmental Protection Agency [EPA], 1986).

TO-15 Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air. Second Edition. CompendiumMethod TO-15. Determination of Volatile Organic Compounds (VOCs) in Air Collected In Specially-Prepared Canisters AndAnalyzed by Gas Clironmtograpliy/Mass Spectrometery (GC/MS) (EPA, 1999).

°C = Degree(s) Celsius. mL = Mil l i l i ter(s) .

HCI= Hydrochloric Acid. SIM = Selected ion monitoring.

L = Liter.

Page I of 1

•jz.c j. q · "section 5.3.4" of the april 2005 focused ri/fs sap. • target indoor...

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