Operable Unit 3 Field Sampling PlanThe SAP, along with the Remedial Investigation and Feasibility...

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Operable Unit 3Field Sampling Plan

Anniston PCB Site,Anniston Alabama

February 2005Revision 2.0

Report on

OPERABLE UNIT 3FIELD SAMPLING PLAN

FOR THE

ANNISTON PCB SITE(Docket No. CV-02-PT-0749-E)

Prepared for:

United States Environmental Protection AgencyWaste Management Division

Atlanta Federal Center61 Forsyth Street, S.W.

Atlanta, GA 30303

Prepared by:

Solutia Inc. and Pharmacia Corporation702 Clydesdale Avenue

Anniston, Alabama 36201

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TABLE OF CONTENTS

Table of Contents i

SECTION "' PAGE

1 INTRODUCTION : 1

2 PROJECT MANAGEMENT 32.1 Project Organization 3

2.1.1 Solutia Project Manager 32.1.2 CERCLA Manager 32.1.3 OU-3 RJ/FS Manager 42.1.4 RI/FS Quality Assurance Manager 42.1.5 Site Sampling Manager 42.1.6 Sampling Health and Safety Officer 42.1.7 Contractors 42.1.8 Contract Laboratories 4

2.2 Project Description 52.3 Quality Assurance Objectives for Measurement 6

2.3.1 State the Problem 72.3.2 Identify the Decision 72.3.3 Identify the Inputs to the Decision 72.3.4 Define the Boundaries of the Study 72.3.5 Develop Decision Rules 72.3.6 Specify Tolerable Limits on Decision Errors and Optimize the Design for

Obtaining Data 82.4 Special Training Requirements/Certifications 102.5 Documentation and Records 10

2.5.1 Document Control 102.5.2 Field Operation Records 11

2.5.2.1 Field Logbook 112.5.2.2 Field Sampling Log 122.5.2.3 Chain-of-Custody 122.5.2.4 Changes in Procedures 13

2.5.3 Laboratory Records 132.5.4 Laboratory Data Reporting Packages 14

3 MEASUREMENT/DATA ACQUISITION 163.1" Identified Data Gaps 16

3.1.1 Soil 173.1.2 Groundwater 17

3.1.2.1 OLBSI 203.1.2.2 Interior Facility and Northeast Perimeter 213.1.2.3 West End Landfill 223.1.2.4 South Landfill 223.1.2.5 Expanded Parameter List Sampling 233.1.2.6 Well Survey 23

3.1.3 Biological Surveys 23

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TABLE OF CONTENTS(continued)

3.2 Sampling Location and Frequency 243.2.1 Soil Sampling 243.2.2 Groundwater Sampling 26

3.2.2.1 OLBSI 273.2.2.2 Interior of Facility and Northeast Perimeter 283.2.2.3 West End Landfill Sampling 283.2.2.4 Expanded Parameter List Sampling 283.2.2.5 Well Survey 29

3.2.3 Biological Surveys 293.2.3.1 Investigation 1: Soil/Grass Invertebrate Surveys 303.2.3.2 Investigation 2: Wildlife Surveys 303.2.4 Habitat Surveys 31

4 SAMPLE IDENTIFICATION 324.1 Sample Identification Code ' 32

5 SAMPLFNG EQUIPMENT AND PROCEDURES. 335.1 General 335.2 General Drilling Procedures 335.3 Monitoring Well Construction 34

5.3.1 Site Preparation 345.3.2 Monitoring Well Installation 345.3.3 Casing Requirements 355.3.4 Well Screen Requirements 355.3.5 Annular Space Requirements 365.3.6 Filter Pack Requirements 365.3.7 Bentonite Seal Requirements 365.3.8 Casing Grout Requirements 365.3.9 Surface Completion Requirements 37

5.4 Monitoring Well Completion Diagrams 375.5 Monitoring Well Development 375.6 Borehole/Monitoring Well Abandonment 385.7 Groundwater Sampling '. 39

5.7.1 Monitoring Well.Sampling 395.7.2 Water Level Measurement 395.7.3 Purging Prior to Sampling 405.7.4 Sample Collection 40

5.7.4.1 Equipment 415.7.4.2 Sample Containers and Storage 425.7.4.3 Sample Acquisition 425.7.4.4 Sample Preservation 43

5.8 Soil Sampling 435.8.1 Surface Soil Sampling 445.8.2 Depth Soil Sampling 445.5.3 Equipment 455.8.4 Sample Containers and Storage 46

5.9 Field Measurements :.46

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TABLE OF CONTENTS(continued)

5.9.15.9.25.9.35.9.45.9.55.9.6

5.10

5.1

Temperature 47pH 47Specific Conductance 47Dissolved Oxygen : 47Turbidity 48Oxidation/Reduction Potential 48

Decontamination 485.10.1 Drilling Equipment 495.10.2 Sampling Equipment '....: 49Surveying 50

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SAMPLE ANALYTICAL METHODS AND SHIPPING 516.1 Analytical Methods 516.2 Sample Shipping 51

QUALITY ASSURANCE/QUALITY CONTROL SAMPLES 52

WASTE HANDLING AND DISPOSITION 54

REFERENCES 55

In OrderFollowing

6LIST OF TABLES

Table 1 Key Project Personnel and Contact InformationTable 2 Proposed Remedial Investigation and Data Quality ObjectivesTable 3 PARCC Data for Aqueous SamplesTable 4 Laboratory Precision and Accuracy Criteria for Aqueous TCL/TAL SamplesTable 5 PARCC Data for Soil SamplesTable 6 Laboratory Precision and Accuracy Criteria for Soil TCL/TAL SamplesTable 7 . Target Compounds/Analytes of InterestTable 8 PCB Congener and Homologue Group Reporting LimitsTable 9 Soil Sampling Statistical AnalysisTable 10 Analytical Methods, Sample Containers, Preservation and Analytical Hold Times

for Aqueous SamplesTable 1 1 .Analytical Methods, Sample Containers, Preservation and Analytical Hold Times

for Soil Samples

LIST OF FIGURES

Figure 1 Facility Areas (OU-3)Figure 2 Proposed Temporary Well and Groundwater Sampling LocationsFigure 3 Potable Well Survey Response LocationsFigure 4 Proposed Soil Sample LocationsFigure 5 Shallow Potentiometric Surface for Facility Area

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I TABLE OF CONTENTS(continued)

APPENDICESIAppendix A OU-3 Health and Safety Procedures

• Appendix B Field Forms

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1 INTRODUCTION

On behalf of Solutia Inc. and Pharmacia Corporation (the Parties), Colder Associates Inc. (Colder)

has prepared this Field Sampling Plan (FSP) for Operable Unit 3 (OU-3) of the Anniston PCB Site

(Site). This FSP, together with a Site-wide Quality Assurance Project Plan (QAPP), which has been

submitted under separate cover, form the Sampling and Analysis Plan (SAP) for OU-3. OU-3

consists of the plant site, the South Landfill , and the West End Landfill (collectively, the Facility).

The SAP, along with the Remedial Investigation and Feasibility Study (Rl/FS) Work Plan and the

Health and Safety Plan (HSP), are deliverables required of the Partial Consent Decree (CD), Docket

No. CV-02-PT-0749-E, filed by the U.S. Environmental Protection Agency (EPA) on October 23,

2002. The CD was entered by the United States District Court of the Northern District of Alabama

on August 4, 2003.

The Parties had elected, and the EPA had agreed, to subdivide the Anniston PCB Site into four

OUs. The description of and rationale for defining the OUs were provided in the Phase I

Conceptual Site Model (CSM) Report (BBL, 2003). After consultation with the EPA it was

determined that OU-1 and OU-2 could be combined into a single OU. The OUs are now defined as:

OU-l/OU-2 - Anniston Residential/Non-Residential;

OU-3-Facility; and

OU-4 - Choccolocco Creek.

The Parties have submitted and the EPA has approved a single "global" RJ/FS Work Plan that is

applicable to all OUs. The.RJ/FS Work Plan provides a framework for completing the

investigations and feasibility studies for the entire Site. During the course of the RI/FS, a monthly

progress report w i l l be prepared that describes activities that have been conducted for the entire Site,

encompassing activities that have been carried out for all OUs. In addition, a single HSP and a

single QAPP have been submitted for the entire Site. Details that pertain to individual OUs, such as

data collection activities, are being provided in OU-specific FSPs, such as this one for OU-3. As

documented in the Rl/FS Work Plan, due to the different schedules for each of the OUs, project

deliverables, except the monthly progress report, w i l l be prepared as OU-specific documents.

This OU-3 FSP has been prepared for remedial investigation field activities and is supported by the

Site-wide RI/FS Work Plan, QAPP and HSP. This FSP provides specific information regarding

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• field sampling and analytical and quality assurance/quality control (QA/QC) procedures for OU-3.

In addition, health and safety procedures that are specific to the field activities for this OU, such as

• the job hazard analysis, are included in Appendix A of this FSP.

• This OU-3 FSP was prepared in accordance with the CD for the Site and the EPA guidance

documents specified below, and which are referenced herein as appropriate:

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. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA

(EPA/540/G-89/004), dated October, 1988;

2. EPA NEIC Policies and Procedures Manual (EPA 330/9-78-001-R) dated May 1978,

revised May 1986;

3. A Compendium of Superfund Field Operations Methods (OSWER Directive 9355-0-14),

December 1987;

4. EPA Requirements for Quality Assurance Plans. EPA OA/R-5 (EPA 240 B-01/003),

I March 2001;

• 5. Guidance for the Data Quality Objective Process. EPA OA/G-4. (EPA 600 R-96/055),August 2000; and

| 6. A Guideline for Dynamic Workplans and Field Analytics: The Keys to Cost- Effective Site

Characterization and Cleanup (Albert Robbats, Jr. Tufts University and EPA Region I).

This document is the FSP section of the SAP and it incorporates specific OU-3 QA/QC

• information, which together with the Site-wide QAPP forms the OU-3 QAPP. A summary of the

elements of the DQO process for OU-3 is included in Section 2.3 of this report.

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2 PROJECT MANAGEMENT

2.1 Project Organization

The lead regulator)' agency for the Site is EPA Region IV. Management and implementation of

this FSP wi l l be performed by a team of contractors hired by the Parties. The Parties wi l l provide

the project coordination, and Golder along with Genesis Project, Inc. w i l l perform the sampling

activities. Key personnel thus far identified for the project team are listed in Table 1. These

individuals wil l have primary responsibility for the project although other individuals may be

involved.

The project management personnel have been selected to ensure that the organization, objectives,

functional activities, and specific QA/QC activities are supervised and implemented in a manner

to obtain.data of sufficient quali ty and quant i ty to meet project requirements. The key personnel

listed below will be responsible for the supervision and implementation of the requirements

outlined in the SAP:

• Project Manager: Craig Branchfield (Solutia Inc.)

• CERCLA Manager: John Loper (The Loper Group, Inc.)

• OU-3 RI/FS Manager: Gayle Macolly (Golder Associates Inc.)

• RI/FS Quality Assurance Manager: Lori Anne Hendel (Golder Associates Inc.)

• Site Sampling Manager: Kevin Haborak (Golder Associates Inc.)

• Sampling Health and Safety Officer: Charles Haury, CIH (Golder Associates Inc.)

2.1.1 Solutia Project Manager

The Project Manager for the Parties has overall responsibility for projects associated with the

Site. The Project Manager has final authority for decisions made by the project team associated

with the Site.

2.1.2 CERCLA Manager

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

Manager has overall responsibility for management and technical oversight of the Anniston PCB

Site CERCLA project. The CERCLA Manager offers technical and management support to the

Project Manager.

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2.1.3 OU-3 RI/FS Manager

The OU-3 RI/FS Manager has overall responsibility for management and technical oversight of

the OU-3 portion of the RI/FS project. The OU-3 RI/FS Manager is a liaison between ihe Project

Manager anoVor CERCLA Manager and the Site Sampling Manager. The OU-3 RI/FS Manager

assesses final data and reports findings to the CERCLA Manager and the Project Manager.

2.1.4 RI/FS Quality Assurance Manager

The RI/FS Quality Assurance Manager is responsible for implementing the SAP. The Quality

Assurance Manager will work closely with the Site Sampling Manager to ensure usable quality

data are produced. The Quality Assurance Manager reports directly to the OU-3 RI/FS Manager

and can require corrective action by the Site Sampling Manager and field team for work not

performed in accordance with the QAPP and this FSP.

2.1.5 Site Sampling Manager

The Site Sampling Manager is responsible for implementation of the SAP. The Site Sampling

Manager is the communications liaison between the sampling team and: the RI/FS Manager or

their designee.

2.1.6 Sampling Health and Safety Officer

The Health and Safety Officer (I-ISO) is the primary reviewer of the Sampling HSP and is

responsible for health and safety technical support.

2.1.7 Contractors

Golder and Genesis Project, Inc., the sampling contractors, are responsible for compliance with

the provisions set forth in the SAP. These contractors wil l report to and lake direction from the

Site Sampling Manager or their designee.

2.1.8 Contract Laboratories

STL-Savannah Laboratories, a division of Severn Trent Laboratories, Inc. (STL), and Alta

Analytical Prospective (Alta) have been selected as the RI/FS analytical contract laboratories.

The contract laboratories are responsible for compliance with the provisions set forth in the

QAPP. The laboratory QAP for STL and Alta has been presented under separate cover as part of

the Site-wide QAPP.

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2.2 Project Description

The Facility is located in the north-central part of Alabama and has been evaluated extensively

for over 20 years. Work at the Facility has included a combination of investigative and remedial

efforts conducted under Solutia (and formerly Monsanto Company) corporate ini t iat ives,

operation and closure permits under State of Alabama and Federal programs, along with

Corrective Actions under the Resource Conservation and Recovery Act (RCRA). Investigative

and remedial efforts at the Facility have included surface and subsurface soils, groundwater, air,

and stormwater media. Major remedial efforts have been undertaken to control stormwater flow

around the Facil i ty and to contain Facility source areas. Additional details regarding investigative

and remedial efforts at the Facili ty area are included in Sections 2 and 3 of the Phase I CSM

Report.

The work addressed in this FSP pertains to OU-3; the Facility area. The Facility area is depicted on

Figure 1 and is bordered to the north by the railway, by Coldwater Mountain to the south, by

Clydesdale Avenue to the east, and by First Avenue to the west.

The primary focus of the OU-3 remedial investigation is to address gaps in the data that have been

gathered from the extensive investigations and interim corrective measures that have been

performed in OU-3 to date. As further described in Section 3.0 of this FSP, the data gaps identified

pertain to the soil and groundwater media and ecological receptors. Soil samples wil l be collected

to better define the distribution of PCBs in surface and subsurface soils. In addition, three soil

samples wil l be collected for analysis of a broader suite of parameters (including polychlorinated

biphenyl [PCB] congeners). Groundwater samples will be collected to investigate the nature and

extent of PCBs and other constituents of potential concern (COPCs) in the vicinity of well OW-

21 A. Groundwater samples will also be collected in the northeast area of the Facility to confirm

perimeter containment of impacted groundwater at the Facility. Similar to the soil sampling

program, certain groundwater samples will also be collected for a broad suite of analyses (including

PCB congeners). Sampling and investigation programs to be performed under this FSP are

summarized in Table 2.

A qualitative evaluation of ecological receptors inhabiting OU-3 is required for the Ecological Risk

Assessment. Habitat in OU-3 is entirely terrestrial and limited to select locations. To document the


use of habitats, biological surveys will be used that identify organism type, and when possible,

relative abundance.

2.3 Quality Assurance Objectives for Measurement

This FSP describes the measures that will be taken to produce data of known and sufficient

qua l i ty and to characterize the impacts to environmental media at the Facil i ty. These data wil l be

used by the Parties and EPA to assess potential environmental risks and determine appropriate

remedial actions for this OU. As part of the evaluation component of the qual i ty control program,

results w i l l be compared to data qual i ty indicators that are part of the overall Data Quality

Objectives (DQOs) for the project. DQOs are qual i ta t ive and/or quantitative statements that:

• define the degree and extent of releases to the environment; and

• support the development and evaluation of any necessary response actions.

The DQO Guidance document specified in Section 1.0 uses a seven step planning approach to

develop the sampling design for data collection activities that support decision making. The seven

steps are as follows:

• State the Problem - Define the problem, identify the planning team, and examine budgetand schedule;

• Identify the Decision - State the decision; identify the study questions, and definealternative actions;

• Identify the Inputs to the Decision - identify the information needed for the decision(information sources, basis for Action Level, and sampling and analysis methods);

• Define the Boundaries of the Study - Specify sample characteristics, define spatial andtemporal limits, and define units of decision making;

• Develop a Decision Rule - Define statistical parameters, specify Action Levels, anddevelop the logic for action;

• Specify Tolerable Limits on Decision Errors - Set acceptable limits for decision errorrelative to consequences (health effects, and cost); and

• Optimize the Design for Obtaining Data - Select a resource-effective sampling and analysisplan that meets the performance criteria.

The following sections present details on the seven step planning approach.

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2.3.1 State the Problem

Section 2.1 identifies the project team for the investigation. The purpose of the investigation, as

defined in Section 2.2, is to supplement the existing data by.collecting data at portions of the

Facility where data are limited. These data will allow further understanding of the nature and extent

of COPCs in soils and groundwater at the Facility. Further delineating the nature and extent, both

horizontally and vertically, w i l l provide a platform to perform a Human Health Baseline Risk

Assessment and conduct a FS.

2.3.2 Identify the Decision

The principal study questions addressed in this FSP are:

• What is the nature and extent of the COPCs in groundwaler within OU-3?

• What is the nature and extent of PCBs in soil within OU-3?

• Are there risks to human health associated with the distribution of these compounds?

2.3.3 Identify the Inputs to the Decision

The data gaps are discussed in Section 3.1. The data collected to address these data gaps, along

with data already collected, will be used to evaluate characteristic OU-3 risks and potential remedial

alternatives. The sampling and analysis methods that will be used while addressing these data gaps

are discussed in detail in Sections 4 through 7.

2.3.4 Define the Boundaries of the Study

The spatial boundaries for the program as described in the Phase I CSM Report and the RJ/FS Work

Plan are the plant site including the South Landfill and the West End Landfill , and in the case of

groundwaler any contamination that has migrated off the Facility to another OU. The locations for

the groundwater and soil investigations are discussed specifically in Section 3.2.

2.3.5 Develop Decision Rules

As part of developing a decision rule, the DQO process recommends that an action level be selected

to dictate a course of action. However, one of the primary purposes of the investigation is to derive

the data necessary to perform a Human Health Baseline Risk Assessment that will establish the

action levels.

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Also critical to the Decision Rule is collecting data that would allow the determination of the

appropriate "population parameter." For risk assessment purposes, the recent guidance on

calculating the 95% upper confidence l imit (UCL) of the mean (USEPA, 2002c) wi l l be used to

ensure the proposed sampling program provides data useful for deriving an exposure point

concentration.

2.3.6 Specify Tolerable Limits on Decision Errors and Optimize the Design for Obtaining

Data

The sample collection program (sample location and frequency) is described in Section 3.2. The

sampling program was developed based upon the following steps:

1. Identify the issue(s) to be addressed;

2. Identify data and information needed to evaluate the issue(s);

3. Identify additional data needs;

4. Develop a data collection program to address those needs:

5. Collect data;

6. Identify/develop related data which wil l be useful in addressing the issue(s); and

7. Define quantitative data acceptance criteria (data quality indicators).

The data quality indicators include precision, accuracy, representativeness, completeness, and

comparability (PARCC). These indicators are used to evaluate data with respect to DQOs. Each

indicator is defined as follows:

1. Precision is the agreement or reproducibility among individual measurements of thesame sample point, usually made under the same conditions;

2. Accuracy is the degree of agreement of a measurement with the true or accepted value;

3. Representativeness is the degree to which a measurement accurately and preciselyrepresents a characteristic of a population, parameter, or variations at a sampling point,a process condition, or an environmental condition;

4. Completeness is a measure of the amount of valid data obtained from a measurementsystem compared with the amount that was expected to be obtained under correctnormal conditions; and

5. Comparability is an expression of the confidence with which one data set can becompared with another data set in regard.to the same sample point.

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The precision, accuracy, and representativeness of data wi l l be functions of the sample origin,

analytical procedures, and the specific sample matrices. QC practices used to evaluate these data

qual i ty indicators include use of accepted analytical procedures, adherence to holding times, and

analysis of QC samples such as blanks, replicates, spikes, calibration standards and reference

standards. Tables 3 through 6 summarize the PARCC criteria for groundvvater and soil samples that

wi l l be collected for laboratory measurements. Tables 7 and 8 provide reporting limits for the

analytical constituents. Establishing appropriate reporting limits is important in the overall DQO

process as the reporting limits are used in evaluating compliance with action levels and in the risk

assessment process.

Precision and Accuracy are quantitative characteristics that will be established inaccordance with the specific analytical method employed, published historical data,laboratory method validation studies and laboratory experience with similar samples.

Representativeness is a non-quantitative (qualitative) characteristic, which primarilyaddresses proper design of a sampling program in terms of number and location of samplesand sample collection techniques. The rationale for the number and location of samples forthis project is discussed in Sections 3.1 and 3.2 of this FSP and the sampling procedures aredescribed in Section 5.0. The representativeness of the analytical data is also a function ofthe procedures used to process the samples. Wherever possible, standard EPA or EPA-accepted analytical procedures wil l be followed.

Completeness is a quanti tat ive characteristic that is defined as the fraction of valid dataobtained from a measurement system (sampling and analysis) compared to that which wasplanned. Completeness can be less than 100 percent due to poor sample recovery, sampledamage, or disqualification of results that are outside of control l imits due to laboratoryerror or matrix-specific interference. Completeness is documented by including sufficientinformation in the laboratory reports to allow the data user to assess the quality of theresults. For this project, every attempt will be made to attain 85 percent or bettercompleteness (field and laboratory).

Comparability is a qualitative characteristic, which allows for comparison of analyticalresults with those obtained by other laboratories. This may be accomplished through theuse of standard accepted methodologies; traceability of standards to National Bureau ofStandards (NBS) or EPA sources; use of appropriate levels of quality control; reportingresults in consistent, standard units of measure; and participation in inter-laboratory studiesdesigned to evaluate laboratory performance.

Tables 3 through S provide details regarding the planned chemical analyses and the quality criteria

used to assess the data. The DQOs, as summarized by the PARCC criteria in these tables, may not

always be achievable. The laboratory will be instructed to minimize dilutions to report the lowest

levels possible, but dilutions might be necessary' due to matrix interferences. The EPA Region IV

data validation guidelines provide direction for the determination of data usability. Qualified data

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can often provide useful information; although, the degree of certainty associated with the results

may not be as planned. Professional judgment wil l , therefore, be used to determine data usability

with respect to project goals.

2.4 Special Training Requirements/Certifications

Personnel trained in the use of sampling equipment wi l l collect samples. Consistent with 29 CFR

1910.120, OSHA Hazardous Waste Operations, personnel performing fieldwork associated with

the data collection activities wi l l have received formal off-Site hazardous waste t raining (with

three days on-the-jdb training) prior to performing on-Site work. This consists of 40 hours of

i n i t i a l training and 8 hours of annual refresher training for field staff. Managers and supervisors

wil l also have received an additional 8 hours of specialized off-Site training oriented toward their

supervisory responsibilities. Excluded from this responsibility are workers who wi l l not be

directly involved with on-Site activities, such as truck drivers or delivery personnel. Laboratory

personnel wi l l have been trained in the analysis of samples and the review of analytical data.

2.5 Documentation and Records

2.5.1 Document Control

The term document control refers to the maintenance of project files. The following documents

wi l l be kept in project files:

• Original Chain-of-Custody (COC) Records, bound field logbooks, and all recordsobtained during the investigation;

• A complete copy of the analytical data and memoranda transmitting analytical data;

• Official correspondence received relating to the investigation including records oftelephone calls;

• One copy of any draft report (to be discarded on completion of final reports);

• One copy of the final report and transmit tal memoranda; and

• Other final material documents pertaining to the original investigation or follow-upactivities related to the investigation.

Under no circumstances wil l personal observations or irrelevant information be placed in the

official project files. The Project Manager, or designee, wi l l review the file at the conclusion of

the project to ensure completeness.

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2.5.2 Field Operation Records

Field personnel will use bound field logbooks; sampling, boring, and well installation log forms;

and COC forms for the maintenance of all sampling field records.

2.5.2.1 Field Logbook

Information pertinent to the field investigation will be recorded in bound and numbered field

notebooks. Logbooks will be dedicated to the project. The investigator's name, project name,

and project number wi l l be entered on the inside of the front cover of the logbook. The field team

members' initials, , project name, date, and weather wi l l be recorded in the logbook at the

beginning of each workday. The time that entries were made wi l l also be recorded. The names

of visitors to the Site during investigations, their affiliation, and the time each person arrived/left

wi l l be documented in the logbooks, as appropriate. Alteration or violation of general field

procedures or other standard procedures wi l l be documented in the field logbook.

Sample collection and handling information, including but not limited to, field analytical

equipment, equipment utilized to make physical measurements, time of sampling, location of

sampling, method of sampling, and method of sample storage will be recorded in the field

logbooks. If detailed information is recorded on log forms, the field logbook wi l l reference the

log forms. Calculations, results, and calibration data for field sampling, field analytical

measurement, and field physical measurement equipment wil l also be recorded in the field

logbooks. Field analyses and measurements are to be traceable to the specific piece of field

equipment utilized and to the field investigator collecting the sample, making the measurement,

and/or performing the analyses.

Entries in the field logbooks will be dated, will be legible, and will contain accurate and inclusive

documentation of an individual 's project activities. Copies of the field logbooks wi l l be made on

a weekly basis and included in the project files. Field logbook records wi l l be recorded in

waterproof, non-erasable ink. If errors are made, corrections wil l be made by crossing a single

line through the error and entering the correct information. Corrections will be initialed and dated

by the investigator. When practicable, corrections wi l l be made by the individual making the

error.

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2.5.2.2 Field Sampling Log

When collecting groundwater and soil samples, detailed sample collection information will be

documented on field sampling log forms. Examples of field-sampling log forms for groundwater

and soil samples are presented in Appendix B. The detailed sample collection information that

w i l l be recorded for each sample is included on these forms.

The field sampling logs wil l be numbered to ensure that each log form has a unique identification

number. These field sampling logs will be utilized to input additional data into a database. Once

completed, these field-sampling logs will be maintained as part of the project files. Field

sampling log records will be recorded in waterproof, indelible ink. If errors are made, corrections

wil l be made by crossing a single line through the error and entering the correct information.

Corrections wil l be initiated and dated by the investigator. When practicable, corrections wil l be

made by the individual making the error.

2.5.2.3 Chain-of-Custody

The COC documentation is an essential part of maintaining the integrity of a successful sampling

and analysis program. When properly completed, the COC form wil l contain project information,

sample collection information, analyses requested, and transfer information to document the

progression of the samples from collection to final destination. The project information recorded

wi l l be client information, project number and project name. The sample collection information

recorded will be sample number, date, time of collection, grab or composite sample designation,

total number of sample containers for each sample, sample matrix, and preservative. The analysis

requested wi l l indicate the analytical test parameters that are required for each sample. The

transfer information wi l l document each person involved in handling the sample from the

sampling personnel to the laboratory representative. The samplers' and or sampling team leader's

signature(s) wil l be included in the designated signature block. The field investigator and

subsequent transferee(s) must document the transfer of the samples listed on the COC form. Both

the person relinquishing the samples and the person receiving them wi l l sign the form, and the

date and time that this occurred wil l be documented on the COC form. Examples of the STL

COC form and the Alia COC form are presented in Appendix B.

COC records will be recorded in waterproof, indelible ink. If errors are made, corrections wil l be

made by crossing a single line through the error and entering the correct information. All

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February 2005 . Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation Page 13 of 56

corrections wi l l be ini t ialed and dated by the investigator.' When practicable, the individual

making the error will make the corrections. Copies of completed COC records wil l be maintained

in the project files.

2.5.2.4 Changes in Procedures

Approval from the EPA Remedial Project Manager wi l l be obtained as needed prior to

implementation for major changes in sampling procedures as outlined in this SAP. Minor

procedural changes will be made by the Site Sampling Manager, and if present, with the

concurrence of the on-site EPA representative. Changes wil l be documented in the field notebooks.

2.5.3 Laboratory Records

Laboratory compiled records are to contain sample data, sample management records, test

methods, and QA/QC reports. The sample data records are to include, but not be limited to the

following:

• Overall number of samples;

• Sample location information;

• Sample collection date and time;

• Sample analysis date and time;

• Deviations from the Standard Operating Procedures (SOPs); and

• Corrective action procedures taken.

The sample management records should include, but not be l imited to the following:

• Laboratory receipt of the sample;

• Sample handling and storage;

• Analysis schedule;

• COC maintenance;

• Sample preservation;

• Sample condition upon receipt; and

• Log-in of samples.

The analytical testing methods information should include, but not be limited to the following:

• Sample preparation;

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• Sample analysis;

• Instrument standardization;

• Detection limits;

• Reporting limits; and

• Test-specific QC criteria.

The QA/QC information should include, but not be limited to the following:

• Init ial calibration;

• Continuing calibration;

• Analytical performance monitoring;

• Calibration verification;

• Blank sample information;

• Matrix spike and matrix spike duplicate information;

• Surrogate spike information;

• Calibration check information; and

• Duplicate sample information.

Laboratory data files wi l l be stored at the individual laboratories for a minimum of ten years.

Laboratory data will be entered into a single Laboratory Information Management System

(LIMS) that provides a database for storing information, tracking samples, tracking holding

times, scheduling preparations, scheduling analyses; storing results, storing QC data, reviewing

data in reference to the correlating QC data; and printing analytical reports.

2.5.4 Laboratory Data Reporting Packages

Level II data packages wi l l be provided by the laboratory for all of the samples collected. The

laboratory will also provide validatable Level IV data packages for approximately 5 percent of

these samples. Laboratory log records wil l be recorded in waterproof, non-erasable indelible ink.

If errors are made, corrections will be made by crossing a single l ine through the error and

entering the correct information. Corrections wil l be initialed and dated by the responsible

person. When practicable, the individual making the error will make corrections. The laboratory

data packages and documentation information are described below and detailed further in the

laboratory QAP.

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• Level II laboratory' data packages will include sample results, quantitation limits,laboratory blank results, QC batch ID, laboratory control standard (percent recovery),laboratory duplicate (as appropriate), batch specific matrix spike and matrix spikeduplicate percent recovery (organics), matrix spike percent recovery (inorganic),surrogate recovery (organics only), date extracted (organics only), and date analyzed.

• Level IV laboratory data packages (organic analyses) wil l include sample results,quantitation limits, laboratory blank results, QC batch ID, in i t i a l calibrationverification, continuing calibration verification, laboratory control standard (percentrecovery), laboratory duplicate, matrix spike and matrix spike duplicate percentrecovery, surrogate recovery, date extracted, date analyzed, sample raw data,standard raw data, and case narrative.

• Level IV laboratory data packages (inorganic analyses) wi l l include, as appropriate,sample results, quanti tat ion limits, laboratory blank results, QC batch ID, i n i t i a lcalibration verification, continuing calibration verification, standard solution, initialcalibration blanks, continuing calibration blanks, preparation blanks, ICP interferencecheck samples, matrix spike and matrix spike duplicate, duplicate results, laboratorycontrol standard, graphite furnace atomic absorption QC, ICP serial dilution,preparation logs, run logs, ICP linear information, sample raw data, standard rawdata, and case narrative.

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3 MEASUREMENT/DATA ACQUISITION

3.1 Identified Data Gaps

The primary objectives for the data collection in this OU are: 1) to confirm nature and extent of

releases; 2) to ensure sufficient data for conducting the Human Health and Ecological Risk

Assessments; and 3) to have sufficient information to complete the FS. With only a few exceptions,

the nature and extent of releases has generally been determined, or is in the process of being

determined for the four Facility-specific media of concern (stormwater, air, soil, and groundwater).

With the augmentation of the existing data set, sufficient information wi l l be available to conduct

the Human Health Risk Assessment and complete the FS. As discussed in the Rl/FS Work Plan, a

qualitative evaluation of ecological receptors inhabiting OU-3 is required for the Ecological Risk

Assessment.

As stated above, the nature and extent has generally been determined for each of the four media of

concern. For stormwater, sufficient data exist for completion of the Rl/FS. Consequently, other

than continuing with the stormwater monitoring program consistent with the Facility's National

Pollutant Discharge Elimination System (NPDES) program, no other stormwater data are required.

The detailed air monitoring program for the Facility has been completed and recently submitted to

the USEPA (ENSR, 2004). The findings of the recent air study indicate that average PCB

concentrations are several orders of magnitude lower than published standards, that the Facility,

including the landfills, is not a discrete PCB source, and that no additional air monitoring data are

needed to conduct the Rl/FS for OU-3. The recently collected data are also consistent with ambient

conditions in other areas of the United States and confirm earlier data collected by the USEPA

(ASTDR, 2003).

In order to complete the Human Health Risk Assessment for the Facility, additional soils and

groundwater data are required. Additional habitat survey data are needed to complete the Ecological

Risk Assessment. Given the data needs for soil, groundwater, and habitat evaluation, the sections

below have been prepared to document the rationale for collection of these data. Specific details

concerning the number and location of samples to be collected, sample collection procedures,

analytical methods, survey methods, etc. are presented in subsequent sections of this FSP.

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February 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation • Page 17 of 56

3.1.1 Soil

During the RFI/CS investigations conducted for the Facil i ty area, seventeen surface (or near

surface) samples and five subsurface soil samples were collected from various locations. Based

on the results, the primary COPCs delected in surface soils at the Facil i ty were PCBs. During the

Supplemental RFI, one additional soil sample was collected from each of SWMU-17, AOC-A,

SWMU-25, and SWMU-31, and analyzed for PCBs. Nine samples were also collected from

SWMU-12 and analyzed for PCBs with two samples also analyzed for mercury.

Soil sample results from the RFI and Supplemental RFI provide good coverage of suspected

contaminant sources (AOCs, SWMUs, and WMAs) on the Facility. However, due to the nature of

the investigative programs for which the data were collected, the samples from these programs are

biased since the samples were collected only at areas of suspected contamination. In addition, a

preponderance of the data collected was from surface soil with only limited analysis of subsurface

soil. Consequently, additional surface and subsurface soil data are needed to characterize areas of

the Facility.

Samples from selected locations wil l be analyzed for a broad suite of analytical parameters. After

collection of the samples discussed above, the PCB results wil l be reviewed and three sample

locations will be selected to represent areas of high, medium, and low PCB concentrations. These

samples will be analyzed for: PCB congeners (Method 1668A); 2,3,7,8-tetrachJorodibenzo-p-dioxin

(TCDD), 2,3,7,8-susbstituted chlorinated dibenzofurans (DFs), and for total polychlorinated

dibenzofuran (PCDF) homologue groups (SW-864 Method 8290); Target Compound List (TCL)

volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and chlorinated

pesticides; Target Analyte List (TAL) metals and cyanide; and organophosphorous pesticides.

3.1.2 Groundwatcr

Groundwater data have been collected at the Facility since the early 1980s. These data were

collected under a number of investigation and remediation programs. During the RFI, an

extensive evaluation of groundwater chemistry data was conducted by sampling multiple wells

for the COPC list included in Table 1 of the RI/FS Agreement (Appendix F to the CD).

During the RFI, specific investigations addressed the issue of whether groundwater impacts

would be expected, or whether such impacts might be present in deeper zones (generally deeper

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February 2005 Armiston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation Page 18 of 56

than 45 feet) of the residuum at the Facility. As discussed in the Rl/FS Work Plan, vertical

hydraulic gradients are downward at the Facility indicating a potential for downward movement

from the shallow residuum to the deeper residuum. However, field testing revealed very low

hydraulic conductivities at the Facili ty. In fact, boring OWR-3D encountered dense clay that

would not yield water in the deep residuum. Consequently, from a hydraulic standpoint, the data

indicate that horizontal gradients control and that groundwater predominantly flows along a

horizontal path in the shallow zone, and not along a vertically downward path.

Seven deep residuum wells (wells OWR-1D through OWR-7D) were installed as part of the RFI to

investigate the potential presence of contaminants in the deep residuum. The results from the

analyses of samples from these seven wells are as follows:

OWR-1D - no parameters reported above permit concentration limits or Maximum

Contaminant Levels (MCLs);

OWR-2D - no parameters reported above permit concentration limits or MCLs;

OWR-3D - dry well (no sample collected);

OWR-4D - no parameters reported above permit concentration limits or MCLs;

OWR-5D - chlorobenzene (46 ug/1) above permit concentration l imit (1 ug/1) but below

. MCL( 100 ug/1),

- pentachlorophenol (1.2 ug/1) above permit concentration l imit (1 ug/1),

- 4-nitrophenol (2,300 ug/1) above permit concentration l imit (1,000 ug/1),

- PCBs (210 ug/1) above permit concentration l imit (0.5 ug/1) (filtered BDL),

- cobalt (81 ug/1) above permit concentration limit (10 ug/1),

- lead (21 ug/1) above permit concentration limit (15 ug/1);

OWR-6D - mercury (1.3 ug/1) (filtered 0.27 ug/1) above permit concentration l imit (0.2

ug/1), but below the MCL (2.0 ug/1); and

OWR-7D - PCBs (2.2 ug/1) above permit concentration limit (0.5 ug/1) (filtered BDL).

These results generally confirm that the deeper zone within the residuum is not impacted with

contaminants. However, there are two areas where impacts have been noted: well OWR-5D and

well OWR-7D. Well OWR-5D is located within the line of interceptor wells at the South Landfill .

The interceptor wells are nominally 24 inches in diameter and completed to depths of 68 feet below

ground surface (bgs), and are essentially screened through their entire depth. Well OWR-5D is a

IIIIIIIIIIIIIIIIIII


nominal two-inch diameter monitoring well that is screened from a depth of 58 to 68 feet bgs. It is

suspected that the single, full-depth screens in the interceptor wells has caused contamination in the

shallow groundwater to be pulled downward and to have impacted the deeper zone between the

interceptor wells, which is where the screen in OWR-5D is located. Therefore, the detections in

well OWR-5D are ascribed to the installation and operation of the interceptor well system and not

to vertical migration under natural conditions.

Well OWR-7D is located in the vicinity of the West End Landfill and has been part of a West End

Landfill monitoring program. The West End Landfill monitoring program consists, of four

successive semi-annual sampling events prior to recommending a final monitoring program for this

area of the Facility. This monitoring program has recently been completed. The concentration of

PCBs in Well OWR-7D consistently decreased from a high of 2.2 ug/1 in 1998 (RFI sampling) to

1.81 ug/I, to 1.5 (J) ug/1, to 0.61 ug/1, to non-detect in the sampling events for the West End landfill

sampling program. Based on the trend of decreasing to non-detect data, drag down of

contamination during well installation was considered the likely cause of the detections in the deep

residuum zone.

It is significant that the results from the other deep wells have indicated the absence of

contamination since these wells were placed in areas where deeper contamination might be

expected. Well OWR-4D was placed down gradient of the OLBSI recover,' system in the vicinity

of well OW-21 and well OW-22. Impacts were reported in these two shallow monitoring wells but

not in well OWR-4D. Well OWR-2D was placed in the deep residuum zone in the vicinity of a

bedrock trough, a potential area of preferential flow. Again, no contaminants were detected in the

results from this well. Wells OWR-1D and OWR-6D were installed in the northeast area of the

Facility and both were free of contamination above the MCL. Well CAVR-3D was placed in an area

in the interior of the Facility and was found to be dry.

The deep residuum zone wi l l be investigated in two additional areas. One area wi l l be in the

vicinity of OW-16A. The deep residuum well at this location wi l l address whether impacts detected

at OWR-5D have migrated laterally. The location will also be useful to evaluate whether impacts

from the shallow residuum are migrating to the deeper zones. The second area of investigation wi l l

be in the vicinity of OWR-13 (the old PCB manufacturing area). Along with OW-16A, this well

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February' 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation Page 20 of 56

wil l be used to address the potential for vertical migration of contaminants into the deeper zone.

These two wells wi l l be sampled for the parameters listed as COPCs.

Since 1998, groundwater data have been collected from twenty-six (26) shallow residuum wells

on a semi-annual or annual basis as required by Solutia's RCRA Part B Post Closure Permit.

These data wi l l be used during the RI/FS process to determine the nature and extent of

groundwater impacts, to perform the risk assessment, and to complete the FS for the Facility.

Additional groundwater investigations wi l l be conducted to f i l l in the few data gaps in this

extensive data set.

For the purpose of reviewing historical groundwater data to determine data gaps, the Facility has

been divided into four areas: 1) the Old Limestone Bed Surface Impoundment (OLBSI); 2)

interior Facility and northeast perimeter; 3) the West End Landfill; and 4) the South Landfill . A

review of the data gaps in the shallow residuum groundwater monitoring program is presented

below.

3.1.2.1 OLBSI

OW-21A

Observation well OW-21A was installed on the Northside property in February 2003 during the

Supplemental RJFI to replace well OW-21. At this location, groundwater impacts have been

detected with increasing concentrations in the most recent sampling events. Groundwater results

from this well have reported PCB concentrations from 64 to 7,400 ug/L, which are above the permit

concentration limits. The following constituents have also been reported above the permit

concentration limits at well OW-21 A with the following maximum concentrations: parathion (4,500

ug/L), paranitrophenol (PNP) (30,000 ug/L), sulfotepp (150 ug/L) and cobalt (61 ug/L). One of the

objectives for the RI/FS is to determine if PCBs, as well as other constituents detected above the

permit concentration limits in well OW-21 A, are restricted to a local area, or if the constituents are

part of a plume that has migrated from the Facility. The objective will be met by install ing and

sampling a series of temporary wells, as discussed in Section 3.2.

MW-15. 16 and 20.4

During semi-annual sampling of monitoring wells MW-16, MW-15, and MW-20A, various

constituents have been reported at concentrations above the permit limits, including mercury (MW-

IIIIIIIIIIIIIIIIIII


15 and MW-16), chlorobenzene, dichloromelhane, 1,2-dichlorobenzene, pentachlorophenol, cobalt

and other constituents in MW-20A. As shown on Figure 2, these monitoring wells are located up

gradient of or within the capture zone of the OLBSI recovery system. Consequently, the

groundwater impacts at these wells are controlled and are not migrating off the Facility.

Furthermore, these constituents have not been detected in wells down gradient of the OLBSI.

Therefore, no further investigations are planned for these exceedances.

MW-9andMW-14

Historically, detections of parameters above permit concentration limits were not reported in

samples from monitoring well MW-9, which is located down gradient of the OLBSI. Well MW-

14 is also located down gradient of the OLBSI. In February 2003, well MW-9 was abandoned

and replaced with monitoring well MW-9A as part of the Supplemental RFI investigation. Well

MW-9 was abandoned because the integrity of the well was compromised by a pump getting

lodged in the upper section of the casing. During the First 2003 Semi-Annual Sampling event in

April 2003, PCBs were reported in the analysis results from a groundwater sample from well

MW-9A. The detection was flagged as tentatively identified due to possible column overload

from analysis of an undiluted sample from well OW-21A. The well was sampled again during

the April 2004 semi-annual sampling event. The results from this re-sampling event were non-

detect for all the parameters analyzed including PCBs. Because of its recent sampling, this well

w i l l not be sampled as part of the RI/FS program. However, MW-14 wil l be sampled for the

expanded parameter list to evaluate the nature and extent of groundwater impacts (if present) in

this area.

3.1.2.2 Interior Facility and Northeast Perimeter

As discussed in the RJ/FS Work Plan, PCBs have been detected above the permit concentration

limit in groundwater samples from observation wells OW-8/8A, OW-15, and OW-16/16A. In

February 2003, observation well OWR-11 was installed north of OW-8A as part of the

Supplemental RFI investigation. PCBs were reported in groundwater samples from OWR-11 at

170 ug/L (unfiltered) and 20 ug/L (filtered). PCBs have not been detected in wells OW-9 and

OW-10, which are located down-gradient from wells OW-8, OW-11, OW-15 and OW-16, thus

indicating that PCBs are riot migrating to off-Facility areas. However, OW-9 and OW-10 have

not been sampled since 1998.

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February 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolatia Inc. and Pharmacia Corporation . Page 22 of 56

Groundwater migration pathways from these and other interior areas are to the northeast portion of

the Facility. During the RFI, the northeast area wells OW-9, OW-10, and OWR-1S were sampled

and PCBs were not detected. These wells will be sampled again as part of this FSP. In addition,

three new temporary monitoring wells will be added to provide more robust well coverage in this

area of the Facility.

3.1.2.3 West End Landfill

Monitoring around the West End Landfil l was not a requirement of the RCRA Post-Closure

Permit. However, as part of the RFI process, a groundwater monitoring program for this area of

the Facil i ty was instituted. The program involved collecting four semi-annual samples over a

two-year period, followed by an evaluation of the data to evaluate potential future monitoring

needs.

The Parties have recently completed collection of the fourth set of samples as part of this program.

Well WEL-01 had an initial detection for PCBs but had no detections in the final three events. Well

WEL-02 had no detections during the sampling program. The results for well WEL-03 from the

four events included init ial low-level detections of PCBs above the permit concentration limit that

have decreased to non-detect in the most recent event. Monitoring'well OWR-10, which was

installed down gradient of these wells, has not had detections of PCBs in the most recent sampling

event. The most recent results for OWR-7D (a deep residuum well in the vicinity of the West End

Landfill) indicate a decreasing trend in PCB concentrations to below the detection l imit in the most

recent event. One additional round of groundwater samples wi l l be collected in this area for the

parameters listed as COPCs. Once collected, these new data, along with the existing data, will be

assessed further in the Preliminary Site Characterization Summary.

3.1.2.4 South Landfill

Various constituents have been reported above the permit concentration limits in observation wells

located around the South Landfill . During the RFI, well OWR-5D was sampled and exceedances

were reported for PNP, PCBs, cobalt, chlorobenzene, and methyl parathion. During semi-annual

sampling events, PCBs have been reported in samples from OW-2 and OW-4 at concentrations less

than 1 ug/L, and parathion, sulfotepp, and cobalt have been reported above the permit concentration

limit in OW-4. These wells are located up-gradient of the recovery system on the South Landfill.

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Consequently, the groundwater impacts indicated by the results from these wells are controlled and

are not migrating off the Facility. Therefore, no further groundwater data, beyond that required by

the RCRA Permit, wil l be collected for the South Landfill during the RJ/FS process.

3.1.2.5 Expanded Parameter List Sampling

As part of the RI/FS, the Parties agreed to collect samples for a broad suite of analytical parameters

at ten percent of the sample locations (with a minimum of three sample locations). The intention is

to select sample locations that represent high, medium, and low PCB concentrations. For

groundwater, an additional criterion of selecting the three sample locations along a flow line was

included. These samples wil l be collected from OVV-16A, OW-8A, and OW-9.. In addition, select

perimeter wells wi l l be sampled for the expanded parameters list. The perimeter wells to be

sampled for the expanded list include MW-14, OVVR-1S, OW-10 and up to five temporary wells to

be installed as discussed in Sections 3.1.2.1 and 3.1.2.2. Samples collected from these wells will be

analyzed for: PCB congeners (Method 1668A); 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD),

2,3,7,8-susbstituted chlorinated dibenzofurans (DFs), and total polychlorinated dibenzofuran

(PCDF) homologue groups (SW-864 Method 8290); Target Compound List (TCL) volatile organic

compounds (VOCs), semi-volatile organic compounds (SVOCs), and chlorinated pesticides; Target

Analyte List (TAL) metals and cyanide; and organophosphorous pesticides.

3.1.2.6 Well Survey

As required by the CD, a survey of private wells within a one-mile radius around the Facility wil l be

conducted (Figure 3). The survey wi l l be undertaken to document the presence or absence of water

wells on each property and if wells are located to determine the type of water usage, the well

construction method, the number and age of users, and the volume and rate of water usage.

3.1.3 Biological Surveys

A Screening Level Ecological Risk Assessment (SLERA) consistent with USEPA guidance was

conducted for OU-3 as part of the RI/FS Work Plan. The development of the SLERA provided a

survey and assessment of the habitat existing on the Facility grounds; however, the activity also

identified a data gap that relates to a qualitative evaluation of ecological receptors inhabiting OU-3.

Given the data needs for identifying species present-on or util izing the Facility in order to complete

the SLERA, a biological survey as discussed in Section 3.2.3 has been prepared to outline the

methods for obtaining this information.

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3.2 Sampling Location and Frequency

3.2.1 Soil Sampling

As reported in Section 3.1.1, soil samples have been collected during the RFI/CS investigations

and again during the Supplemental RFI. For this RI investigation, additional soil samples are

needed to augment the RFI data by providing a broader geographic coverage as well as providing

more subsurface samples to allow for the calculation of a 95% UCL for risk assessment purposes.

The following statistical analysis was performed to determine the number of additional samples

to be collected as part of this investigation.

The procedure for using classical statistical methods to define the number of soil sample locations

required for the characterization of OU-3 and to satisfy DQOs is outlined in USEPA Data Quality

Objective guidance (USEPA, 2000). This procedure specifies that for a known mean, variance and

comparison criterion, a sample number can be calculated such that future statistics can be calculated

with a known confidence and power. The following equation used to calculate the number of

samples required is identified in the USEPA DQO guidance in Appendix A:

Where:

00= Confidence Interval

P= Power

a2 = Variance (standard deviation)

n = sample size

Z = Z-statistic (area under normal curve)

A= difference between the mean of the extant samples and the PRO

To apply this equation to OU-3, the PCB concentrations from existing soil samples collected as part

of the RFI/CS and Supplemental RFI investigations were tabulated. Five of the 42 data points were

excluded from the analysis because these data points were located outside of the plant site

boundaries. The arithmetic mean and variance (standard deviation) of the PCB concentrations were

calculated. A comparison value of 0.74 mg/kg was selected, which represents the industrial action

level for PCBs in soil (Region 9 PRO table).

11•

111̂

M

1

1

1

1


The above equation assumes a normal population distribution. However, the PCB concentration vs.

Z-score graph was evaluated and it did not represent a normal population distribution.

1S.000.000 - -

16.000.000 •

M .000.000

"ar^ 12.000.000 •

1 10.000.000 •R

S E.000.0000

3 6.000.000 •

J.000.000 -

2.000.000 -

Sululia Soil Sampling Analysis

I'CB vi /.-score

i

» j

. .. /.

/-

/ . .

; . / . . . .' •. . . . //. . - -.- /

-2.000 -1.500 -1.000 -0.500 0000 0.500 1.000 1.500 2.000

/^score

Therefore, the log of the PCB concentrations was used which resulted in

1

1

a more accurate

representation of a normal distribution graph.

Solutia Soil Simplinp Ana lys i sFCUOug) vsX-scorc

Q nn . .. . „

1

1

1

1

1

700

_ 600

~St~ 5.00C

h.

1 4.00cc(JIf 3.00

5~ 2.00

.00

n nn

.̂ ^

. . . . . . *^f* * ~ " ^ . . .^f*

1 ^ * ^ ^. . . . ^ -̂-̂ . _

^^^i

.xj"*1^

J* ' ̂ ~

^"^

\-2.000 -1.500 -1.000 -0.500 0.000 0.500 1.000 1500 2000

1

1

X-scorc

IIIIIIIIIIIIIIIIIII


The mean and standard deviation of the log values were then calculated and used in the above

equation to determine the proposed sample size for OU-3. The data and the results of the

calculation are presented in Table 9.

When using the log values for the mean and standard deviation, the calculated sample size is 12.6.

However, the log graph still did not represent a true normal population distribution, consequently

the sample size was increased by 15% as described by Pitman's Asymptotic Relative Efficiency

Equation (Pitman, 2004) resulting in a calculated sample size of 14.

Consequently, 14 surface and 14 subsurface samples wil l be collected. The additional samples will

be located based upon providing more complete sampling coverage across the plant site and wil l

include placement of sample(s) near the former chemistry laboratory. Although geostatistical

methods are often used to determine sampling locations at contaminated waste sites, the

heterogeneous nature of the plant site due to production areas (that include SWMUs, AOCs,

WlvlAs, etc.) and non-production areas (where contaminant releases are less likely) makes it more

appropriate to select locations based on area types and locations of previous samples. The proposed

locations for additional samples are presented on Figure 4.

In addition to the above samples, two surface samples will be collected at the West End Landfill to

determine the PCB concentrations in the cover soils. The proposed locations for the samples are

presented on Figure 4.

3.2.2 Groundwater Sampling

A minimum of 19 groundwater samples wil l be collected as part of the RJ/FS for OU-3. Five of

these samples will be collected from temporary shallow wells installed as part of the RI/FS (these

temporary wells may later be converted to permanent wells), two from deep residuum wells

installed as part of the RI/FS, and 12 from existing wells. The locations of the wells to be sampled

are shown on Figure 2. The rationale for well installation and sample collection is described in the

following sections.

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3.2.2.1 OLBSI

OW-21 Area

To provide an understanding of the source of the impacted groundwater reported in well OW-21 A,

two temporary' wells wi l l be installed south (up gradient) of well OW-21 A. The monitoring wells

will be installed within the first water bearing zone to a depth of no greater than 45 feet below

ground surface (bgs). The screening interval will be based on the lithology encountered during

drilling, and the determination of the water bearing unit will be the responsibility of the field

geologist overseeing the installation. Both wells wil l be installed near the 1101 Street Ditch. One

temporary well will be installed on the south side of the ditch and one well will be installed on the

north side of the ditch. Groundwater from these wells wi l l be sampled and analyzed for cobalt,

PCBs, parathion, and PNP. The results of these analyses will be used to determine if the source of

impacted groundwater is located on the Facility (there is a possibility that some parameters may be

from the Facility while other parameters may be from off-Facility sources).

To determine the nature and down gradient extent of PCBs and other constituents reported at well

OW-21 A, a groundwater sample wi l l be collected from monitoring well MW-07. This well is

located approximately 100 feet directly down-gradient of well OW-21A, as shown on Figure 5.

Prior to sampling, this well wi l l be redeveloped. The sample from MW-07 will be analyzed for

cobalt, PCBs, parathion, and PNP. If the concentrations of these parameters are below the permit

concentration limit (and/or MCL), then the nature and extent of the down-gradient portion of the

groundwater impacts at OW-21 A wi l l be considered as having been determined.

If the analytical results from the groundwater sample collected from MW-07 indicate that these

parameters are above the permit concentration l imi t (and/or MCL), then a temporary monitoring

well wi l l be installed approximately 100 feet further down-gradient to determine the extent of the

plume. Groundwater samples will be collected from this temporary monitoring well. If the

constituent concentrations are above applicable limits at that location, then the temporary well will

be abandoned and another temporary well wi l l be installed down gradient from the previous

temporary well's location. The actual distance down gradient from the previous well will be

determined based upon a review of the analytical data collected in this program. This procedure

will continue until constituent concentrations are at or below the applicable limits or unti l

constituent concentrations have decreased such that the extent of the impacted groundwater may be

approximated without having concentrations below the applicable limits. Once the down gradient

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boundary is established, the final temporary monitoring well wil l be converted into a permanent

monitoring well.

MW-9A and AW-14 Area

MW-14 wi l l be sampled for the constituents included in the expanded parameter list to evaluate the

nature and extent of groundwater impacts (if present) in this area.

3.2.2.2 Interior of Facility and Northeast Perimeter

To confirm that off-Facility migration of COPCs is not occurring in the northeastern portion of the

Facility, monitoring wells OWR-1S, OW-10, and OW-9 wil l be sampled for the constituents

included in the expanded parameter list. In addition, three new temporary monitoring wells will be

added to provide more robust well coverage in this area of the Facility. The monitoring wells will

be installed within the first water bearing zone to a depth of no greater than 45 feet bgs. The

screening interval will be based on the lilhology encountered during drilling, and the determination

of the water bearing unit will be the responsibility of the field geologist overseeing the installation.

In the same manner as described for the OW-21A investigation, if any parameters are detected

above the applicable concentration limits in the perimeter wells, the investigation will broaden.

Down-gradient temporary wells wil l be installed and sampled for the parameters of interest unt i l a

down-gradient boundary is established. Once the down gradient boundary is established, the

final temporary monitoring well wi l l be converted into a permanent monitoring well.

3.2.2.3 West End Landfill Sampling

One additional round of groundwater samples will be collected in the area of the West End

Landfill for the parameters listed as COPCs. The samples wil l be collected from OVVR-07D,

OWR-10, WEL-01, WEL-02, and WEL-03 and analyzed for the parameters listed as COPCs.

3.2.2.4 Expanded Parameter List Sampling

Samples will be collected from wells OW-16A, OW-SA, and OW-9. In addition, select perimeter

wells will be sampled for the expanded parameters list. The perimeter wells to be sampled for the

expanded list include MW-14, OWR-1S, OW-IO and up to five temporary wells to be installed as

discussed in Sections 3.1.2.1 and 3.1.2.2. Samples collected from these wells wil l be analyzed for:

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PCB congeners (Method 1668A); 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-susbsiituted

chlorinated dibenzofurans (DFs), and total polychlorinated dibenzofiiran (PCDF) homologue

groups (SW-864 Method 8290); Target Compound List (TCL) volatile organic compounds (VOCs),

semi-volatile organic compounds (SVOCs), and chlorinated pesticides; Target Analyte List (TAL)

metals and cyanide; and organophosphorous pesticides.

3.2.2.5 Well Survey

A private well survey wil l be conducted for wells within a one-mile radius around the Facility

(Figure 3). The Parties wi l l request private well information from the City of Anniston to determine

if the City has any records of private well users in the area under investigation. The Parties wi l l

conduct a door-to-door survey of private homes and businesses in the area indicated on Figure 3.

Occupants of the properties will be questioned to determine the presence or absence of water wells

and if wells are located on the property to determine the type of water usage, well construction

methods, the number and age of users, and the volume and rate of water usage.

Well surveys have already been performed at a limited number of residential properties as part of

the residential property sampling program. Information obtained from these well surveys wi l l be

used in the evaluation, and the occupants of these properties wil l not be included in the survey.

3.2.3 Biological Surveys

The preliminary findings of the SLERA indicate that there are elevated levels of a number of

contaminants in soil. A habitat survey to determine if habitat capable of supporting populations of

ecological receptors within OU-3 wi l l be conducted. The quality of the habitat will be determined

on a population basis. In order to determine the impact on wildlife populations, qualitative surveys

of terrestrial biota residing in or uti l izing the environs of OU-3 will be conducted.

Habitat in OU-3 is entirely terrestrial and limited to only several locations. To document the use of

habitats for purposes of the SLERA, biological surveys can be used that identify organism type, and

when possible, relative abundance. Survey information wil l be used to augment observations on

habitat quality in the environmental setting of the SLERA, and wi l l provide additional evidence on

the potential exposure of organisms to site constituents.

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Two site-specific biological surveys are proposed for documenting species habitat use in OU-3.

These include field surveys of the subsurface and surface ecology in OU-3 terrestrial habitats. The

locations where these surveys would be conducted are:

1) Maintained Facility Grounds;

2) Employee Park;

3) West End Landfil l ; and,

4). South Landfill .

Soil/grass invertebrate and wi ld l i fe surveys wi l l be conducted in these areas. The methods used to

conduct these surveys are provided in the following sections.

3.2.3.1 Investigation 1: Soil/Grass Invertebrate Surveys

Core sampling (! foot PVC or Lexan tubing) of the biological active layer will be used to sample

soil invertebrates. Where grass is at sufficient height (greater than 6 inches) sweep nets wi l l be used

to sample phytophilous invertebrates. Samples wi l l be sieved, place in pans, and invertebrates will

be identified and enumerated in the field. In samples where invertebrates are numerous, only the

first 100 individuals wi l l be counted (similar to rapid bioassessment protocols for aquatic systems).

The data wil l be reported as raw counts and relative abundance (as percent) and recorded in field

log books. Locations where sampling is conducted wi l l be recorded using a global positioning

system (GPS). The total number of sample points for each of the OU-3 areas wi l l be: Maintained

Facility Grounds (5 samples); Employee Park (1 sample); West End Landfill (4 samples); and

South Landfill (9 samples) for a minimum of 19 core samples with any additional samples resulting

from sweep netting (if feasible).

3.2.3.2 Investigation 2: Wildlife Surveys\.

The focus of the wildl i fe survey wi l l be to document the use of OU-3 habitats by birds and

mammals either directly or by signs. The survey will include a reconnaissance of each of the OU-3

locations listed above and wi l l be conducted simultaneously with Investigation 1 described in

Section 3.2.3.1. In addition to direct observations the survey wil l document (using the field form

included in Appendix B), wi ldl i fe tracks, scat, burrows, daybeds, nests, browse, and any other signs

observed by ecologists.

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| 3.2.4 Habitat Surveys

Additional data that wil l be collected at each of the four survey locations includes:

I• Description of primary' habitat type (e.g., early/late successional field; scrub/shrub; new/old

I forest; etc.);

• Approximate percent cover of habitat types;

• • Dominant vegetation, vegetation density (e.g., dense, patchy, sparse), and vegetation.

height;

• • Bordering habitat types or land use;

• Evidence of natural or anthropogenic disturbance; and

• • Miscellaneous observations.

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4 SAMPLE IDENTIFICATION

4.1 Sample Identification Code

The samples will be adequately marked for identification from the time of collection and packaging

through shipping and storage. Marking wi l l be on a sample label attached to the sample container.

Sample identification wil l include, as a minimum:

• Project name and/or code;

•. Sample identification number;

• Analysis requested;

• Chemical preservatives added to the sample container;

• Sample date and time; and,

• In i t ia l s of the individual performing the sampling (samples for chemical analysis).

Each sample wil l be assigned a unique sample identification number to be recorded on the sample

label. Each sample identification number wil l be recorded in the field notebook and, as applicable,

on chain-of-custody documentation. Designations for sample identification numbers for this project

are described below.

Subsurface and surface soil samples will be identified by the sample station from which they are

taken followed by the maximum depth of the sample in inches. The sample station labeling wi l l

be adapted from the RFI such that samples will be called SSR. Numerical designations will

continue from the RFI sampling (i.e. begin at SSR23). An example sample identification for a

soil sample might be SSR27-48, and would represent an aliquot from sample location SSR27

with a maximum depth of 48 inches.

Groundwater samples wi l l be identified by the monitoring well / temporary well ID from which

they are taken (e.g. OWR-1S). Field Duplicate samples taken from the same monitoring well

samples will be identified with an alphanumeric designation (e.g. OWR-1S-X). Samples collected

from the same well but at different times wil l be identified by a date and time label also included

with the sample collection form. Additional sample volume collected from a sample location for

use as a matrix spike/matrix spike duplicate (MS/MSD) wil l not be given a separate ID number

from that of the primary sample.

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5 SAMPLING EQUIPMENT AND PROCEDURES

5.1 General

The ultimate quality of any data generation begins with sampling and measurement procedures

which are well conceived and carefully implemented. This section presents the procedures with

which samples will be acquired.or measurements made during the Rl/FS OU-3 investigation.

The number and location of samples for this project are summarized in Table 2.

5.2 General Drilling Procedures

The drilling and well installation procedures will conform to state and local regulations. The drill

rig will be cleaned and decontaminated according to the guidelines described in Section 5.10. Drill

rigs that are leaking iluids that may enter the borehole or contaminate equipment that is placed in

the hole wil l not be used. The use of rags or absorbent materials to absorb leaking fluids is

unacceptable. Drilling lubricants will not introduce or mask contaminants at the Site; vegetable oil

is an acceptable drilling lubricant.

The boreholes will be advanced using a hollow stem auger (HSA). Continuous two-foot split-

spoon soil samples or five-foot CME samples wi l l be collected throughout the length of the

borehole for lithologic description.

All samples will be inspected and logged by a geo-professional. The soil description wil l follow

the Universal Soil Classification System general format:

• consistency or density;

• color;

• structural characteristics;

• composition with major components in capital letters;

• minor characteristics; and

• geologic description in capital letters.

For environmental soil samples, additional descriptions such as odor, staining, oily sheen, etc.

wil l be noted in field notebooks. ' •

A log of drilling activities will be kept in a bound field notebook. Information in the log book wil l

include location, time on Site, personnel and equipment present, down time, materials used, samples

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collected, blow count measurements (if performed), and any other observations or information that

would be necessary' to reconstruct field activities at a later date.

5.3 Monitoring Well Construction

5.3.1 Site Preparation

Prior to drilling, surface soils wil l be sampled for PCBs at each monitoring well location. Soil wi l l

be collected at approximately one-foot intervals and field-screened for PCBs using immunoassay

techniques (EPA Method No. 4020). Soil wil l be tested until field results indicated that PCBs are

no longer detected. To prevent the potential drag-down of constituents in the surface soil during

well installation, soil wil l be excavated from a five-foot square area to the depth determined from

the soil screening. The excavation wil l be backfilled with clean soil to create a clean drilling pad.

The excavated soil wil l be characterized and disposed of in accordance with standard procedures

(see Section 8.0).

5.3.2 Monitoring Well Installation

Typically, both permanent and temporary monitoring wells will be drilled and installed using

double well casings to further prevent cross-contamination of the borehole from the shallow soils

during drilling. Init ial ly, a large diameter borehole (nominally 12 inches) will be advanced to a

depth of approximately ten feet. An eight-inch diameter casing wi l l be cemented in place and

allowed to cure for at least 24 hours prior to continuing drilling. An eight-inch nominal diameter

borehole will be advanced through the surface casing to the completion depth of the well. This

surface casing may be eliminated for wells installed in areas with measured low concentrations of

PCBs in the soil.

Monitoring wells will be constructed using a two-inch diameter, flush-threaded, Schedule 40

polyvinyl chloride (PVC) casing and a ten-foot section of slotted, Schedule 40 PVC screen. An

appropriately-sized quartz filter pack wi l l be used to fill the annular space between the borehole

and the well and will act as a filter to keep fine-grained materials from clogging the well screen.

The filter pack and screen slot size wi l l be based on the formation material and the procedures

outlined in the Environmental Investigations Standard Operating Procedures and Quality

Assurance Manual (EISOPQAM), (USEPA, 200Ib). The filter pack will be placed by pouring

the sand through the hollow stem augers as the augers are withdrawn. A three to five-foot thick

bentonite seal will be installed on top of the filter pack. The bentonite wil l be allowed to hydrate

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for 8 hours or the manufacturer's recommended time, whichever is greater. If the water table is

below the pellet seal, potable or higher quali ty water wi l l be added repeatedly to hydrate the

pellets prior to grouting. The total volume of water added wi l l be recorded on the monitoring

well installation log. The remainder of the annulus wi l l be filled with a bentonite/cement grout.

Permanent monitoring wells wi l l be completed at the surface with a three by three foot concrete

pad with locking anodized aluminum protective cover.

Procedures for completing the monitoring well wi l l include the following:

• . Only the well screen and filter pack portion of the completed monitoring well should beadjacent to the particular single water-bearing zone to be monitored.

• The l iquid slurry grouts wi l l be placed by pumping the grout through a tremie pipe to theappropriate locations, or, if bentonite pellets are used, the pellets wi l l be properlyhydrated and compacted in place using the following steps:

1. the bentonite pellets wi l l be poured slowly down the well annulus or tremied intoplace to mitigate bridging of the pellets within the borehole above the desireddepth;

2. the pellets will be compacted in place using a PVC tremie pipe with a cap; and

3. the pellets wi l l either be allowed to hydrate for 8 hours or the manufacturer'srecommended time (whichever is longer) prior to continuing with well constructionactivities either by existing groundwater in the borehole (if present) or by addingpotable or high quality water as they are placed into the borehole.

• The protective surface casing w i l l be set in both the cement grout and the concrete pad.

5.3.3 Casing Requirements

The well casing requirements that w i l l be followed are: (1) all casing wi l l be new, unused, and

decontaminated according to the specifications of Section 5.10; (2) glue or solvent wil l not be used

to join casing, and casings wil l be joined only with water-tight flush-joint threads; (3) all PVC wil l

conform to the ASTM Standard F-480-88A or the National Sanitation Foundation Standard. 14

(Plastic Pipe System); and (4) the casing will be straight and plumb within the tolerance stated for

the borehole. The casing wil l be notched at the top to provide a point of reference for measuring

groundwater elevations.

5.3.4 Well Screen Requirements

Well screen requirements are: (1) all requirements that apply to casing wil l also apply to well

screen, except for strength requirements; (2) monitoring wells wi l l not be screened across more than

one water-bearing unit; (3) screens wi l l be factory slotted; (4) screen slots wi l l be sized to prevent

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February 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation . Page 36 of 56

90 percent of the filter pack from entering the well; and (5) the bottom of the screen is to be capped,

and the cap will be joined to the screen by threads.

5.3.5 Annular Space Requirements

The annular space requirements are the following: (1) the annular space wil l be filled with a filter

pack, a bentonite seal, and casing grout between the well string and the borehole wall; and (2) as the

annular space is being filled, the well string wi l l be centered and suspended such that it does not rest

on the bottom of the hole.

5.3.6 Filter Pack Requirements

The filter pack will consist of silica sand and will extend from the bottom of the hole to at least two

feet above the top of the well screen. The filter pack material will be clean, inert, and well-rounded

and wil l contain less than two percent flat particles. The sand wi l l be certified free of contaminants

by vendor or contractor.

The filter pack will have a uniform, well-sorted grain size and uniformity coefficient compatible

with the formation materials and the screen, as described in Section 6.6.4 of the EISOPQAM,

November 2001. The filter pack wil l not extend across more than one water-bearing unit. The

filter pack wi l l be placed by pouring the sand through the hollow stem augers as the augers are

withdrawn.

5.3.7 Bentonite Seal Requirements

The bentonite seal requirements are the following: (1) the bentonile seal wil l consist of at least three

feet of bentonite between the filter pack and the casing grout; (2) the bentonite wil l be hydrated

before placement of casing grout; and (3) only 100 percent sodium bentonite will be used.

5.3.8 Casing Grout Requirements

The casing grout requirements are the following: (1) the casing grout wil l extend from the top of the

bentonite seal to two feet below ground surface, (2) the grout wi l l be mixed in the following

proportions: 5 percent bentonite powder and 95 percent Portland® cement grout slurry, (3) all grout

will be pump tremied using either a side-discharge or a bottom-discharge tremie pipe.

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5.3.9 Surface Completion Requirements

The aboveground surface completion of the permanent monitoring wells will be completed by

extending the well casing two or three feet above the land surface. A casing cap will be provided

for each well, and the extended casing wi l l be shielded with a locking anodized aluminum

protective cover, seated in a 3-foot by 3-foot by 6-inch concrete surface pad. To allow for escape of

gas, a small diameter (e.g., 1/4-inch) vent hole will be placed in the well casing, or a ventilated well

cap wi l l be used. A weep hole will be installed in the protective cover to prevent the casing f i l l ing

with water. The diameter of the sleeve wi l l be at least two inches greater than the diameter of the

casing. The concrete pad wil l be sloped away from the well. A lockable cap or lid wi l l be installed

on the protective cover. The identity of the well will be permanently marked on the casing cap and

the protective cover.

5.4 Monitoring Well Completion Diagrams

A completion diagram wil l be submitted for each monitoring well installed. It will include the

following information: (1) well identification (this will be identical to the boring identification

described); (2) drilling method; (3) installation date(s); (4) elevations of ground surface and the top

of casing; (5) total boring depth; (6) lengths and descriptions of the screen and casing; (7) lengths

and descriptions of the filter pack, bentonite seal, casing grout, and any back-filled material; (8)

elevation of water surface before and immediately after development; and (9) summary of the

material penetrated by the boring.

5.5 Monitoring Well Development

Monitoring wells wil l not be developed un t i l at least 24 hours after the instal la t ion of the surface

pads or unt i l at least 24 hours after grouting the annular space, if a surface pad is not installed.

The monitoring wells wil l be developed using a combination of bailing and/or pumping to

produce representative formation water. Development wi l l be accomplished using a standard size

pump wi th a surge block and/or a stainless steel or Teflon® bailer with nylon rope. Development

wi l l be continued unt i l representative water that is free of cuttings or other materials introduced

during well construction is obtained. Representative water is assumed to have been obtained

when the water is free of visible sediment and the pH, temperature, and specific conductivity

have stabilized to within + 0.1 standard units, + 0.5°C, and + 10 percent, respectively. Also, the

measured turbidity readings should be less than 10 Nephelometric Turbidity Units (NTUs) or

should have stabilized to within + 10 percent for values greater than 10 NTUs in accordance with

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EPA's Standard Operating Procedures for Low-Stress (Low Flow) / Minimal Drawdown Ground-

Water Sample Collection.

The minimum duration of well development will vary in accordance with the method used to

develop the well. For example, surging and pumping the well may provide a stable, sediment

free sample within minutes; whereas, bailing the well may require several hours of continuous

effort to obtain a clear sample. Field personnel w i l l determine appropriate development methods

based on site-specific conditions observed during well construction. The methods of well

development, duration, pH, temperature, turbidity, and specific conductivity readings wil l be

recorded on the well development log by the field personnel.

.All of the development water will be containerized in 55-gallon drums and wi l l be discharged to

the on-Facility groundwater recovery system in accordance with State and Federal regulations.

5.6 Borehole/Monitoring Well Abandonment

Temporary' monitoring wells and boreholes that are not converted to permanent monitoring wells

will be abandoned in accordance with applicable federal, state and local requirements. Boreholes

will be pressure (tremie) grouted with a 5 percent bentonite powder and 95 percent Portland®

cement grout slurry to the surface to prevent the potential for migration from the ground surface to

the water table.

Prior to abandonment of temporary monitoring wells, a water level measurement and total depth

measurement will be recorded. The well casing wi l l be over-drilled using a HSA and a lead bit,

which guides the HSA down the borehole inside the PVC casing. The bit ensures that the entire

casing is ground into small cuttings and returned to the surface on the rotating flights. After the

casing materials are removed from the borehole, the borehole will be pressure (tremie) grouted with

a 5 percent bentonite powder and 95 percent Portland® cement grout slurry to the surface to prevent

the potential for migration of contaminants from the ground surface to the water table.

All abandoned boreholes wi l l be checked 24 to 48 hours after grout/bentonite emplacement to

determine whether curing is occurring properly. More specific curing specifications may be

recommended by the manufacturer and wi l l be followed. If settling has occurred, a sufficient

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amount of mud/solid bentonite will be added to fill the hole to (he ground surface. These curing

checks and any addition of mud/solid bentoniie wil l be recorded in the field log.

5.7 Groundwater Sampling

5.7.1 Monitoring Well Sampling

All sampling activities wi l l be recorded in the field logbook. Additionally, all sampling data will be

recorded on a groundwater sampling log form (Appendix B). Before groundwater sampling begins,

wells wil l be inspected for signs of tampering or other damage. If tampering is suspected, (i.e.,

casing is damaged, lock or cap is missing) this wi l l be recorded in the field logbook and on the well

sampling form.

Before the start of sampling activities, plastic sheeting will be placed on the ground surrounding the

well. The plastic sheeting wi l l be used to provide a clean working area around the wellhead, and

prevent any soil contaminants from contacting sampling equipment. Water wil l be removed from

the protective casing or the vaults around the well casing prior to venting and purging. Purging and

sampling wil l be performed in a manner that minimizes aeration in the well bore and the agitation of

sediments in the well and formation. Equipment wil l not be allowed to free-fall into a well.

The following information will be recorded each time a well is purged and sampled: (1) depth to

water before and after purging; (2) sounded total depth of the monitoring well; and (3) the condition '

of each well.

5.7.2 Water Level Measurement

Water-level measurements wil l be taken after all wells have been installed and developed and their

water levels have recovered completely. Any conditions (e.g., barometric pressure) that may affect

water levels will be recorded in the field log. Static'water levels will also be measured each time a

well is sampled, and before any equipment enters the well. If the casing cap is not vented, allow

time prior to measurement for equilibration of pressures after the cap is removed. Measurements

will be repeated until water level is stabilized.

The groundwater level will be measured to the nearest 0.01 foot using an electric water-level

indicator or weighted tape coated with chalk. Water levels wi l l be measured from the notch located


at the lop of the well casing and recorded on the Groundwater Sampling Form. If well casings are

not notched, measurements will be taken from the north edge of the top of the well casing.

Following water level measurement, the total depth of the well from the top of the casing will be

determined using a weighted tape, electric sounder, or installation log and recorded on the

Groundwater Sampling Form. The water level depth wil l then be subtracted from the total depth of

the well to determine the height of the water column present in the well casing.

IIIIII• 5.7.3 Purging Prior to Sampling

Purging of the monitoring well is performed to evacuate water that has been stagnant in the well and

• may not be representative of the aquifer. Purging wil l be accomplished using a either a disposable

• pump system or dedicated bladder pump for some previously installed wells at a rate of between 65

• to 100 milliliters per minute (ml/min) to ensure minimal drawdown within the well.

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Purging will continue until water-quality parameters (i.e., temperature, pH, conductivity, turbidity

and dissolved oxygen) have stabilized in accordance with the USEPA's Standard Operating

Procedures for Low-Stress (Low Flow) / Minimal Drawdown Ground- Water Sample Collection.

Water removed from the well during purging wil l be containerized in 55-gallon drums and will be

discharged to the on-Facility groundwater recovery system in accordance with State and Federal

regulations. Detailed information concerning handling of investigative derived wastes is presented

in Section 8.

5.7.4 Sample Collection

Sampling of the new groundwater observation wells wi l l be performed no sooner than 24 hours

after development of the new wells, in order to allow the aquifer to recover.

Groundwater sampling data wil l be maintained in a hard copy format, and wil l include:

• Specific field sampling data;

• Inspection results; and

• Well maintenance information.

The list of proposed analytes and analytical methods for groundwater samples is presented in

Tables 3, 7, and 10. A summary of groundwater sampling procedures are given below.

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5.7.4.1 Equipment

At the Facili ty, dedicated positive-pressure (bladder) pumps are generally used to evacuate wells

and collect samples. Equipment to operate these dedicated pump systems (i.e., air compressor,

compressed air or nitrogen cylinders, electric generator, etc.) may be necessary. In addition, non-

dedicated sampling apparatus such as surface discharge tubing and valving may also be required.

If wells do not have dedicated pump systems a disposable pump system wi th accessories small

enough to enter the wells w i l l be necessary. All equipment that could contact the sample wil l be

made of acceptable materials. Acceptable materials that may contact any groundvvater sample are

stainless steel, fluorocarbon resin (Teflon®), polytetrafluoroethylene (PTFE), fluorinated

ethylene propylene (FEP), or perfluoro alkoxy (PFA), and glass.

Sample bottles and preservatives appropriate-for the parameters to be sampled wi l l be necessary,

as well as organic-free deionized water, coolers, and ice. Table 10 summarizes sample bottle

type, preparation, and preservation requirements.

Field equipment includes the following;

• Thermometer;

• pH meter with oxidation/reduction probe and standards;

• Conductivity meter and standards;

• Dissolved oxygen meter;

• Turbidity meter and standards;

• Filtration apparatus (0.45 micron and .1 micron), if necessary;

• Groundwater measurement probe:

• Indelible ink pens and felt-tip markers;

• Decontamination equipment and solutions;

• Container(s) for capturing, containing, treating and measuring waste decontaminationsolutions, if necessary; and

• As required, 55-gallon steel drums fitted with bung holes, or suitable tank(s) forcontaining purged groundwater.

Documentation forms and notebooks to have on hand include: Groundwater Sample Collection

Forms (Appendix B), COC, sample labels and seals, and field logs.

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February' 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation . Page 42 of 56

5.7.4.2 Sample Containers and Storage

Table 10 provides a summary of the type and minimum size of the sample bottles (which also

represents minimum sample size), preservation, storage/handling requirements and maximum

holding times for the parameters to be analyzed. All groundwater samples wi l l be labeled with a

water-proof marker, sealed, and immediately stored in coolers with securely closed lids for

storage and transport. The samples wi l l be packed with ice and maintained at a temperature

below 4 degrees Celsius. Samples must be received by the analytical laboratory in sufficient time

to conduct the requested analyses within the specified holding time.

5.7.4.3 Sample Acquisition

5.7.4.3.1 Volatile Organic Compounds

Samples for VOCs wi l l be obtained from the well using a dedicated positive-pressure .(bladder)

pump or disposable pump system and wi l l be collected directly from the pump discharge tube

into several properly cleaned and prepared 40 mL glass vials to overflowing. Contact with air

and sample agitation should be minimized. If necessary, pumping rates may be significantly

reduced during sampling for VOCs. These samples w i l l not be filtered. Samples for EPA

SW846 Method 8260 wil l be preserved with hydrochloric acid (HC1) to a pH less than two.

Immediately after collection, a Teflon® lined silicon septum cap wi l l be tightened onto the vial .

There should be no air bubbles remaining wi th in the vial once the cap. has been fastened.

5.7.4.3.2 Semi-volatile Organic Compounds, PCBs, and Pesticides

Samples for extractable SVOCs, PCBs, or pesticide analyses wi l l be collected directly from a

dedicated positive-pressure (bladder) pump discharge port or disposable pump system into

appropriate sample bottles with Teflon®-lined lids. Samples should not be allowed to overflow

the sample bottle. No preservatives wil l be added to the samples. The same procedures wil l be

used to collect samples for PCB congeners and for dioxin/furans.

Filtered and unfiltered samples for PCB analysis wi l l be collected. Fi l t ra t ion is best accomplished

with the use of an in-line filter system in which the sample is directly fed from the discharge port

of the pump through the filter and into the appropriate sample bottle. A less preferred but

acceptable method is the collection of an adequate amount of sample from a pump into a properly

cleaned and prepared high-density linear polyethylene or glass bottle, then immediately filtered

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with the use of a peristaltic pump .and collected directly into the appropriate sample bottle. The

filter pore sizes should be a 0.45 micron followed by a 0.1 micron. (Note: New filters wi l l be

used for each sample and the filter system must be decontaminated before and after each sample.)

In addition, aliquots of unfiltered samples wi l l be collected directly from a pump discharge port

into the appropriate sample bottle.

5.7.4.3.3 Metals

Unfiltered and filtered samples for metals analysis wi l l be collected using the sampling method as

described above. Samples for metals wi l l be immediately filtered after acquisition, as above.

Additionally, these groundwater samples (filtered and unfiltered) wil l be preserved wi th nitric

acid (HNOi) to a pH less than two.

5.7.4.4 Sample Preservation

When possible, sample containers wi l l be provided by the laboratories with premeasured

preservatives. Additional preservatives w i l l also be provided by the laboratory. All samples

requiring preservation should be preserved immediately upon collection in the field or after

filtration. Sample containers for metal analyses should be checked to ensure that the proper pH

level has been obtained, and additional preservative should be added, if necessary.

Table 10 lists the preservatives required for the parameters to be analyzed. Teflon® or glass rods

and disposable, glass Pasteur pipettes are the only addit ional equipment which may be used

during sample preservation. Equipment wi l l be decontaminated as discussed in Section 5.10.

5.8 Soil Sampling

Surface soil sampling will be performed from the ground surface to a depth of six inches using

hand tools. Depth sampling wil l be performed from a depth of 36 to a maximum of 48 inches

using hand tools and/or direct push technology (DPT) dr i l l ing method. The sampling procedures

are described in Sections 5.8.1 and 5.8.2 for surface soil and depth soil sampling, respectively.

Sampling equipment, sample acquisition, and sample preservation are discussed in Sections 5.8.3

and 5.8.4. '

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February 2005 Anniston PCB SiteRevision 2.0 . OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation Page 44 of 56

5.8.1 Surface Soil Sampling

Surface soil samples will be collected from the ground surface to a depth of six inches. Sample

locations wi l l be identified using stakes, flagging, or other appropriate means, and wi l l be noted

in field logbooks and/or soil sampling logs (Appendix B). Sample points wi l l be located using a

GPS, or alternatively using measurements from structures and/or permanent property.

Soil samples collected for analytical testing wil l be obtained using equipment that has been

thoroughly decontaminated by the procedures presented in Section 5.10. Soil not used for

analysis wi l l be containerized in labeled drums for characterization and disposal in accordance

with federal and state regulations. Sample boreholes wil l be backfilled with bentonite to the

ground surface.

Prior to collecting a surface soil sample, the ground surface will be prepared by clearing away

brush, root mat, grass, leaves, gravel, or other debris from the sampling location. Surface soil

samples wi l l be collected with a stainless steel spade, spoon and/or hand auger that wi l l be

advanced to a depth of six inches, and the soil will be deposited into a stainless steel bowl.

Samples to be submitted for VOC analyses will be taken immediately and placed in the

appropriate pre-preserved containers. For the remainder of the samples, the soil wi l l be divided

into quarters and each quarter will be mixed individual ly using a stainless steel spoon in a

stainless steel bowl. Then two quarters will be mixed thoroughly to form halves. The two halves

will then be mixed thoroughly to form a homogenous sample.

When the sample has been homogenized, the soil wil l be placed into new, clean, laboratory-

provided containers appropriate for the anticipated analysis. The amount of sample retained will be

dependent on the analytical requirements. The top of each container will be immediately closed

tightly to seal it. The samples wil l be identified as described in Section 4.

5.8.2 Depth Soil Sampling

The depth soil samples will be collected at approximately the same locations as the surface

samples. Depth soil samples are those samples collected from 36 to a maximum of 48 inches bgs.

Sample locations will be noted on a diagram of the property in field logbooks .and/or soil

sampling logs (Appendix B) using GPS coordinates or measurements from structures and/or

permanent property fixtures.

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February 2005 Annislon PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolatia Inc. and Pharmacia Corporation , Page 45 oF56

Soil samples collected for analytical testing wi l l be obtained using samplers that have been

thoroughly decontaminated by the procedures presented in Section 5.10. Soil not used for

analysis wi l l be containerized in labeled, 55-gallon drums for characterization and disposal in

accordance with federal and state regulations. Sampling boreholes wi l l be backfilled wi th

bentonite clay to the ground surface.

Prior to 'collecting a soil sample, the ground surface wi l l be prepared by clearing away brush,

grass, leaves, gravel, or other debris from the sampling location. Depth soil samples w i l l be

collected using a hand auger, spade or shovel, or a DPT drill rig with a tube sampler equipped

with a dedicated Teflon® liner. The sample wi l l be homogenized in the same manner as

described for surface soil samples in Section 5.8.1 and containerized and stored as described in

Section 5.8.4.

5.8.3 Equipment

Sample bottles and preservatives appropriate for the parameters to be sampled wil l be necessary,

as well as organic-free distilled/deionized water, coolers, and ice. Table 11 summarizes sample

bottle type, preparation, and preservation requirements.

Field equipment wil l include the following:

• Stainless steel bowls;

• Stainless steel spoons;

• Stainless steel spades;

• Stainless steel hand augers;

• Field logbooks;

• DPT dri l l rig and associated equipment;

• Indelible ink pens and felt-tip markers;

• Decontamination equipment and solutions;

• Scalable plastic bags (e.g., Ziploc ®);

• Coolers; and

• Container(s) for capturing, containing, treating and measuring waste decontaminationsolutions, if necessary.

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Documentation forms and notebooks to have on hand include: Soil Sample Log Forms (Appendix

B), Chain-of-Cuslody Forms (Appendix B), sample labels and seals, and field logbooks.

5.8.4 Sample Containers and Storage

Table 11 provides a summary of the type and minimum size of the sample bottles (which also

represents minimum sample size), preservation, storage/handling requirements and maximum

holding times for the parameters to be analyzed. The laboratory wi l l supply prepared sample

containers. Certified clean containers from the manufacturers, such as I-Chem® 200-series, wil l

also be acceptable.

Sample containers will be kept closed unt i l the time each container is to be filled. After filling,

the container wi l l be securely closed, residue wi l l be rinsed from the exterior sides of the

containers, and the containers wil l be immediately placed in coolers wi th securely closed lids for

storage and transport. Samples wi l l be kept chilled at four degrees Celsius (4° C), using ice or

blue ice packs, and shipped to the laboratory' in sufficient time to conduct the requested analyses

within specified holding times.

Samples wi l l be marked for tracking from the time of collection and packaging through shipment

and storage. Marking wil l be on a sample label attached to the sample container using an

indelible ink pen. The information on the sample label wi l l include, at a minimum, the project

name/number, sample ID number, requested analysis, sample date, sample time, and in i t ia ls of

the individual performing the sample collection.

5.9 Field Measurements

Field groundwater parameters, measured during groundwater well purging and sampling, wil l

include pH, specific conductance, turbidity, dissolved oxygen, oxidation/reduction potential, and

temperature. These parameters wi l l be measured and recorded as indicators of groundwater

conditions and for potential correlation to other data. Because these parameters can change

significantly shortly following sample acquisition, these parameters must be measured in the field

unfiltered and unpreserved in a clean glass container separate from those intended for laboratory

analysis. Each instrument used to measure these parameters wil l be operated in accordance wi th

the manufacturer's instruction manual. Each instrument/probe must be thoroughly rinsed with

distilled/deionized water before and after each use.

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5.9.1 Temperature

A calibrated thermometer w i l l be used to measure the temperature during well development,

purging and immediately before sample acquisition. The thermometer reading wi l l ' be allowed to

stabilize and will 'be recorded to the nearest 0.5° C. Care wi l l be exercised to measure the

temperature as soon as possible in an area shaded from direct sunlight.

5.9.2 pH

A pH meter will be used to measure the pH during well development, purging and immediately

before sample acquisition. Measurements will be made immediately on the obtained aliquot.

(Note: If possible, measure pH continuously on the purged water in a closed flow-through

system.) Calibration wi l l be performed at least once daily with standardized buffered pH

solutions, and in accordance with the manufacturer's procedures (provided with the instrument).

The pH will be recorded to one-tenth (or one-hundredth if meter is stable enough) of a standard

uni t .

5.9.3 Specific Conductance

A conductivity probe wi l l be used for conductivity measurement during well development,

purging and immediately before sample acquisition. Measurements will be made as soon as

possible on the obtained aliquot. The meter will be calibrated in accordance with manufacturer's

procedures (provided with the instrument) with standardized potassium chloride (KC1) solutions.

At a minimum calibration will be performed at the beginning of each day's use. The conductivity

w i l l ' b e recorded to two significant figures. The temperature of the sample at the time of

conductivity measurement will also be recorded.

5.9.4 Dissolved Oxygen

A dissolved oxygen meter wi l l be used to measure dissolved oxygen (DO) in water samples

during well development, purging and immediately before sample acquisition. The meter will be

calibrated in accordance with the manufacturer's procedures (provided with the instrument) daily.

The temperature and salinity compensators will be adjusted (if equipped). Measurements will be

recorded to the nearest 0.1 ppm concentration.

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5.9.5 Turbidity

A turbidi ty meter wil l be used to make tu rb id i ty measurements during well development, purging

and immediately before sample acquisition. Measurements wi l l be made as soon as possible on

the obtained al iquot . Operation and calibration wi l l be in accordance with the manufacturer 's

procedures (provided wi th the instrument). Standardized solutions w i l l be used for calibration at

least once daily. The outside of the glass vials used for containing the aliquot for measurement

must be wiped thoroughly dry before and after each use. Measurements wi l l be recorded to the

nearest 0.1 NTU when less than one NTU; the nearest one NTU when between one and ten NTU;

and the nearest ten NTU when greater than ten NTU.

5.9.6 Oxidation/Reduction Potential

Oxidation/Reduction (ORP) should be taken during well development, purging and immediately

before sample acquisition. It is important to minimize aeration during purging which can affect

oxidation/reduction potential measurements. Calibration wil l be in accordance with the

manufacturer's procedures (provided with the instrument). Calibration wil l be performed with

standardized solutions and conducted at least once daily. The oxidation/reduction measurements

will be recorded to the nearest 0.1 millivolt (mV) when less than one mV; the nearest one mV

when between one and ten mV; and the nearest ten mV when greater than ten mV.

5.10 Decontamination

Decontamination procedures in this section are intended for use by field personnel for cleaning

sampling, dri l l ing and other equipment in the field. Deviations from these procedures should be

documented in the field records and investigative reports. Specifications for standard

decontamination materials follow. These materials wil l be used, as appropriate, for non-dedicated

equipment used during sample collection (e.g., stainJess steel bailers, bowls, spoons, and knifes).

• Soap wi l l be a phosphate-free laboratory detergent such as Liquinox® or Alconox®. Useof other detergent must be documented in the field logbooks and investigative reports.

• Solvent wil l be pesticide-grade isopropanol. Use of a solvent other than pesticide-gradeisopropanol for equipment cleaning purposes must be justified and documented in fieldlogbooks and investigation reports.

• Nitric Acid - A ten percent solution of trace-grade nitric acid wi l l be used fordecontamination of equipment used in the collection of samples for metals analysis.

• Tap water may be used from any municipal water treatment system. Use of an untreatedpotable water supply is not an acceptable substitute for tap water.

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February 2005 Annislon PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation Page 49 of 56

• Deionized water is tap water that has been run through a standard deionizing resin column.It is commercially available.

• Distilled water is tap water that has been distilled. It is commercially available.

• Analyte free water is tap water that has been treated with activated carbon and a standarddeionizing resin column. At a minimum, the finished water should contain no constituentsabove the laboratory reporting limits that are being analyzed for as part of the remedialinvestigation.

• Other solvents may be substituted for a particular purpose if required. For example,removal of concentrated waste materials may require the use of either pesticide-gradehexane or petroleum ether. After the waste material is removed, the equipment must be

. subjected to the standard cleaning procedure. Because these solvents are not miscible withwater, the equipment must be completely dry prior to use.

Solvents, laboratory detergent, and rinse waters used to clean equipment wi l l not be reused during

field decontamination and will be stored in DOT-approved 55-gallon drums. These materials will

be treated as investigation derived waste (IDW). See Section S.O for proper handling and disposal

of these materials.

5.10.1 Drilling Equipment

The procedures in this section are to be used for all non-dedicated drilling equipment. All

decontamination procedures in this section will be performed on a decontamination pad.

1. Clean with tap water and soap using a brush to remove obvious paniculate matter andsurface films;

2. Rinse thoroughly and power wash with potable water; and,

3. Rinse non-dedicated equipment that might contact samples with distilled water. If distilledwater is not available, equipment should be allowed to completely dry.

5.10.2 Sampling Equipment

The procedures in this section are to be used for all non-dedicated sampling equipment used to

collect and/or homogenize samples.

1. Clean with tap water and soap using a brush to remove obvious paniculate matter andsurface films;

2. Rinse thoroughly with tap water;

3. Rinse thoroughly with deionized or distilled water;

IIIIIIIIIIIIIIIiiii


4. Rinse thoroughly with solvent (pesticide-grade isopropanol) unless made of PVC or plastic,these items are not to be solvent rinsed;

5. Rinse thoroughly with analyte free water. If analyte free water is not available, equipmentshould be allowed to completely dry; and

6. Equipment should be wrapped in aluminum foil unt i l needed for sampling.

5.11 Surveying

All surveyed locations will be measured by a certified land surveyor as the distance in feet from a

reference location that is tied to the state plane system. All.surveyed locations wi l l be reported

using the State Plane North American Datum of 1983 in United States Survey Feet. Surveyed

elevations wi l l be referenced to the National Geodetic Vertical Datum of 1988. The survey control

information for all data collection points will be recorded and displayed in a table. The table will

give the X and Y coordinates in state plane coordinate values, the ground-surface elevation, and the

measuring point elevation if the location is a groundwater monitor well. The elevation of all newly

installed wells, including temporary wells, wi l l be surveyed at the water level measuring point

(notch) on the riser pipe. Horizontal locations (x,y coordinates) should be reported to a tenth of a

foot. Elevations (z coordinates) should be reported to .a hundredth of a foot. GPS wil l be used to

locate soil sampling points.

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6 SAMPLE ANALYTICAL METHODS AND SHIPPHS'G

6.1 Analytical Methods

Most samples collected during this project will be analyzed by analytical methods from the

following documents:

1. Test Methods for Evaluating Solid Waste - Physical/Chemical Methods. SW-846. ThirdEdition, November 1986; Update I I I , Revision 5, April 1998;

2. Method 1668. Revision A: Chlorinated Biphenyl Congeners in Water. Soil. Sediment, andTissue by HRGC/HR.MS. (EPA-821-R-00-002), December 1999.

Method references for the analyses to be performed for this project are summarized in Tables 3

through 6. These chosen methods are deemed suitable for achieving the project DQOs discussed in

the QAPP. Information regarding the laboratory's equipment and capability in performing the

analytical methodologies will be provided in the laboratory QAP.

6.2 Sample Shipping

Custody of the samples is transferred to the laboratory through a courier or commercial transporter.

The samples collected during this investigation wi l l be transported to STL-Savannah and Alia using

a commercial courier such as Federal Express. The sample custody included in each cooler should

indicate the Federal Express air bil l number if at all possible. The coolers should be sealed using

tape and custody seals. The laboratory Project Managers should be notified that samples are being

shipped so that they can anticipate the arrival of samples. This is especially important if samples

are being shipped on a Friday for delivery on Saturday or if samples are being shipped over a

holiday weekend. If it is not possible to record the air bill numbers on the COCs, then the air bil l

numbers wi l l be recorded in the field notebooks. The records concerning the custody transfer are

maintained in field and laboratory records.

I


7 QUALITY ASSURANCE/QUALITY CONTROL SAMPLES

Five types of field quality assurance/quality control (QA/QC) samples, defined below, will be

utilized to meet the project data qual i ty objectives (DQOs) described in this FSP. QA/QC

samples will be collected only for samples undergoing chemical analysis.

• Trip Blanks

For each shipment of sample containers sent from the analytical laboratory', one container wi l l befilled with analyte-free water at the laboratory, sealed, and included in the shipment. The blanksare transported to the site with the balance of the sample containers and remain unopened.Otherwise, they are handled in the same manner as the other samples. The trip blanks are returnedto the laboratory' with the samples and are analyzed for the volatile constituents. The resultsprovide an indication of cross-contamination during transit of volatile constituents.

• Field Blanks

Field blanks are prepared by transferring deionized water to the sample containers at the samplingsite. The blank water will be analyzed by the laboratory for the constituents defined by theprogram, as appropriate. Field banks test for contamination introduced during the samplingprocess.

• Equipment Rinsate Blanks

A blank that is prepared in the field using organic-free water which is poured over/throughsampling equipment which has been decontaminated. The blank water will be collected insample bottles and analyzed by the laboratory for the constituent defined by the program, asappropriate. The results wil l provide indication of contamination being introduced by contact ofsample medium with sample equipment after the decontamination process is completed.

• Field Duplicates

Duplicate samples taken in the field at the same location of a primary sample will be analyzedby the laboratory. The results wi l l provide an indication of the homogeneity of the samplemedium and the precision of the field sampling and laboratory sample analysis. Accurate fieldnotes will ensure that each duplicate can be matched to its corresponding primary sample.

• Matrix Spike/Matrix Spike Duplicates (MS/MSDs)

A "MS" is a subsample of a primary sample to which the laboratory adds a spike containinganalytes at known concentrations prior to extraction/analysis of the sample to assess the effect ofsample matrix on the extraction and analysis methodology. The MSD is another subsamplefrom the primary sample (subsampling performed at the laboratory), which is similarly spiked.The sample selected for MS/MSD analysis will not be from the location from which the fieldduplicate is obtained and wil l be indicated on the chain-of-custody. Additional sample volumeswi l l be collected to perform these analyses.

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ii

February 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation Page 53 oF56

Field duplicates w i l l be identified through the use of an "X" at the end of the sample ID number

(e.g., 1234-3A-X). Equipment rinsate blanks wil l be identified through the use of a "Y" at the

end of the sample ID number (e.g., 1234-3A-Y).

Trip blanks wil l be provided with each shipment of containers sent from the Site to the analytical

laboratory that include containers for volatile constituents. Field blanks and equipment rinsate

blanks wi l l be collected at a frequency of one for every 20 primary samples, with at least one

field blank and rinsate blank collected each week field sampling is performed. Field

duplicates/splits will be collected at a frequency of one for every ten primary samples. MS/MSDs

wi l l be collected at a frequency of one for every 20 primary samples. To ensure the proper

amount collected, QA/QC samples wi l l be collected at the beginning of every set o f t e n or 20 of

primary samples, whichever is appropriate. The laboratory wi l l conduct internal QC testing in

accordance with the requirements of the analytical methods and their own QA Plans.

i

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8 WASTE HANDLING AND DISPOSITION

Waste handling wil l be dealt with on an area-by-area basis. Waste may be classified as non-

investigative waste or investigative waste.

Non-investigative waste, such as li t ter and household garbage, wil l be collected on an as-needed

basis to maintain each area in a clean and orderly manner. This waste wi l l be containerized and

transported to the designated collection bin. Acceptable containers wil l be sealed boxes or plastic

garbage bags.

Investigation derived waste wi l l be properly containerized and temporarily stored at the Facility,

prior to transportation. Depending on the constituents of concern, fencing or other special marking

may be required. The number of containers will be estimated on an as-needed basis. Acceptable

containers will be sealed, U.S. Department of Transportation (DOT)-approved steel 55-gallon

drums or small dumping bins with lids. The containers wil l be transported in such a manner to

prevent spillage or paniculate loss to the atmosphere.

The investigative derived waste will be segregated at the Facility according to matrix (solid or

liquid) and as to how it was derived (drill cuttings, drilling fluid, decontamination fluids, and purged

grbundwater). Each container will be properly labeled with Site identification, sampling point,

depth, matrix, constituents of concern, and other pertinent information for handling. Soil cuttings

will be staged at the Site for characterization and disposal. Decontamination waste solutions and

purged groundwater may be disposed of in the on-Facilily groundwater recovery system.

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9 REFERENCES

Alabama Department of Environmental Protection (ADEM). 2001. Hazardous Waste FacilityPermit. RCRA Post-Closure Permit for WMA I (Closed Hazardous Waste Landfi l lCells), WMA1I (Closed Surface Impoundment). Solutia Inc. ALD 004 019 048. IssuedJanuary?, 1997. Modified November 13, 1997 and May 3, 2001.

Agency for Toxic Substances and Disease Registry (ATSDR). 2003. Health Consultation:Anniston PCB Air Sampling. January 2003.

Blasland, Bouck & Lee, Inc. 2003. Phase I Conceptual Site Model Report for the Anniston PCBSite, May 2003.

Blasland, Bouck & Lee, Inc. 2004. Remedial Investigation/Feasibility Study Work Plan for theAnniston PCB Site, Revision 2.0, December 2004.

Blasland, Bouck & Lee, Inc. 2004. Quality Assurance Project Plan for the Anniston PCB Site,Revision 2.0, February 2005.

Blasland, Bouck & Lee, Inc. 2004. Health and Safety Plan for the Anniston PCB Site, June2004.

ENSR International (ENSR). 2004. RFI/CS Air Monitoring Report. July 2004.

Colder Associates. 2002. RFI/CS Report for the Anniston, Alabama Facility, October 2002.

Colder Associates. 2003. Supplemental RFI/CS Report for Solutia Inc., Anniston Facility, May2003.

United States Environmental Protection Agency, 1983. "Methods for Chemical Analysis of Waterand Wastes." EPA 600/4-79-020, July 1979 (revised March 1983).

United States Environmental Protection Agency, 1986. "EPA NE1C Policies and ProceduresManual", EPA 330/9-78-001 -R, May 1978, revised May 1986.

United States Environmental Protection Agency, 1987. "A Compendium of Superfund FieldOperations Methods", OSWER Directive 9355-0-14, December 1987.

United States Environmental Protection Agency, 1988. "Guidance for Conducting RemedialInvestigations and Feasibility Studies, under CERCLA", EPA 540 G-89/004, OSWERDirective 9355.3-01, dated October 1988.

United States Environmental Protection Agency, 1990. "Quality Assurance/Quality ControlGuidance for Removal Activities, Sampling QA/QC Plan and Data Validation Procedures,Interim Final", EPA 540 G-90/004, April 1990.

United States Environmental Protection Agency, 1991. "A Compendium of ERT Soil Samplingand Surface Geophysics Procedures", OSWER Directive 9360.4-02, January 1991.

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United States Environmental Protection Agency, 1998.'Office of Solid Waste, SW-846 3rd

Edition; Revision 5; "Test Methods for Evaluating Solid Waste - Physical/ChemicalMethods", April 1998.

United States Environmental Protection Agency Region IV, 1999. "Dala Validation StandardOperating Procedures for Contract Laboratory Program Routine Analytical Services",'Revision 2.1, July 1999.

United States Environmental Protection Agency. 2000a. "Guidance for the Data Quality ObjectiveProcess", EPA QA/G-4, EPA 600 R-96/055, August 2000.

United States Environmental Protection Agency, 200la. "EPA Requirements for Quality AssuranceProject Plans", EPA QA/R-5, EPA 240 B-01/003, March 2001.

United States Environmental Protection Agency Region IV, 2001 b. "EnvironmentalInvestigations Standard Operating Procedures and Quality Assurance Manual,"November 2001.

United States Environmental Protection Agency Region IV, 2002a. Partial Consent Decree, UnitedStales of America vs. Pharmacia Corporation (p/k/a Monsanto Company) and Solutia. Inc.Civil Action No. CV-02-PT-0749-E. October 2002. Effective Date August 4, 2003.

United States Environmental Protection Agency, 2002b. "Guidance on Environmental DataVerification and Validation", EPA QA/G-8, EPA 240 R-02/004, November 2002.

United States Environmental Protection Agency, 2002c. "Guidance for Quality Assurance ProjectPlans", EPA QA/G-5, EPA 600 R-02/009, December 2002.

TABLES

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Page 1 of 2

TABLE 1KEY PROJECT PERSONNEL AND CONTACT INFORMATION

EPA Remedial Project Manager:

Project Manager:

CERCLA Project Manager:

RI/FS Manager:

RI/FS Quality Assurance Manager/Data Management:

Site Sampling Manager:

Laboratory Quality Assurance Officer:

Pam ScullyUSEPA Region IVWaste Management DivisionAtlanta Federal Center61 Forsyth Street. S.W.Atlanta, GA 30303Telephone: 404-562-4300Fax: 404-562-8896Email: [email protected]

Craig BranchfieldSolutia, Inc.702 Clydesdale AvenueAnniston, Alabama 36201Telephone: 256-231-8404Fax: 256-231-8451Email: crbranl Osolutia.com

John LoperThe Loper Group, Inc.702 Clydesdale AvenueAnniston, Alabama 36201Telephone: 256-231-8420Fax:256-231-8451Email: [email protected]

Gayle MacollyGolder Associates Inc.702 Clydesdale AvenueAnniston, Alabama 36201Telephone: 256-231-8412Fax: 256-231-8451Email: [email protected]

Lori Anne Hendel, CHMMGolder Associates Inc.8933 Western Way, Suite 12Jacksonville, FL 32256Telephone (904) 363-3430Fax: (904) 363-3445Email: [email protected]

Kevin HaborakGolder Associates Inc.3730 Chamblee Tucker RoadAtlanta, GA 30341Telephone (770) 496-1893Fax: (770) 934-9476Email: [email protected]

Andrea TealSTL-Savannah5102 LaRoche AvenueSavannah, GA 31404Telephone (912) 354-7858Fax:(912)351-3673Email: [email protected]

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Page 2 of 2

TABLE 1KEY PROJECT PERSONNEL AND CONTACT INFORMATION

Laboratory Project Manager:Alternate Laboratory Project Manager:

Laboratory Quality Assurance Officer:

Laboratory Project Manager:

Lidya GuliziaBetsy BeauchampSTL-Savannah5102 LaRoche AvenueSavannah, GA31404Telephone (912) 354-7858Fax:(912)351-3673Email: [email protected] / [email protected]

Yves TondeurAlta Analytical Perspectives2714 Exchange DriveWilmington, NC 28405Telephone (910)794-1613Fax:(910)794-3919Email: [email protected]

Amy BohemAlta Analytical Perspectives2714 Exchange DriveWilmington, NC 28405Telephone (910)794-1613Fax: (910) 794-3919Email: [email protected]


Anniston PCB SiteOU-3 Reid Sampling Plan

Page 1 of 1

TABLE 2PROPOSED REMEDIAL INVESTIGATION AND DATA QUALITY OBJECTIVES

Remedial. nvestlgatlon Ma<r|x Number of samp.es AreaActivity

Northeast Perimeter, OW-Reid Screening Soil 7 minimum 21A area, and Interior

Facility

30 Facility-wide

Contamination Delineation Soil

3 TBD

3 minimum OW-21 Area

1 MW-9 Area

Contamination Delineation Groundwater 8 Interior Facility andNortheast Perimeter

2 Deep Residuum

5 West End Landfill

Surveying -GPS and surveyor NA " S°" l£££and "" Faci.rty.wide

Biological Survey NA NA Facility-wide

Locations

at temporary well / deepwell locations

see Figure 4

TBD

temporary wells, MW-7

MW-14

OW-16A, OW-8A, OW-9.OWR-1S, OW-10, three

temporary wells

new wells

WEL-01.WEL-02.WEL-03, OWR-7D, and OWR-

10

see Rgures 2 and 4

TBD

Parameters ol Interest

PCBs

PCBs

OrganophosphorousPesticides, TCUTAL, PCB

congeners, dioxin, andfurans

Parathton, PNP, PCBs,Cobalt

OrganophosphorousPesticides, TCL/TAL, PCB


OrganophosphorousPesticides, TCl/TAL, PCB


COPC list

COPC list

Northings and eastings andwell elevations

Soil/Grass InvertebrateSurvey, Wildlife Surveys

Frequency ofMonitoring

Once

Once

Once

Once

Once

Once

Once

Once

Once

Once

Purpose/Objective of Activity

Immunoassay screening to provide information for properconstruction of wells.

Collect definitive data to define nature and extent ofcontamination and for use in preparing the Human Health

and Ecological Risk Assessments.



Collect definitive data to define nature and extent ofcontamination in OW21 A area.



Collect definitive data to define nature and extent ofcontamination and for use in preparing me Human Hearth






Provide accurate location and elevation data for soilsample locations and wells.

Qualitative survey to confirm lack of impact on wildlifepopulations.

Notes:1. The Target Compound List (TCL) VOC, SVOC, and Pesticide lists are defined in CLP Statement of Work OLM04.3.

The Target Analyte List (TAL) parameters are listed in CLP Statement of Work ILM05.2.The COPC list consists of the Organophosphorus Pesticides, SVOCs, VOCs, and metals from Table 1, Appendix F of the Consent Decree.The Aroclors to be analyzed are Aroclor 1016, Aroclor 1221, Aroclor 1232, Aroclor 1242, Aroclor 1248. Aroclor 1254, Aroclor 1260, and Aroctor 1268

2. The methodologies that will be used for analysis are listed in Tables 3 and 5.3. Quality control samples will be collected per matrix at the following frequency: 1 field duplicate per ten primary samples; 1 MS/MSD pair per twenty primary + field duplicate samples;

1 equipment rinsate blank per twenty samples where non-dedicated equipment is used. 1 trip blank per day when aqueous VOC samples are collected.4. Field Parameters for groundwater monitoring include: pH, Temperature, Specific Conductivity, Turbidity, Dissolved Oxygen, and Oxidation-Reduction Potential.5. Detection limits for each analyte which may be tested have been determined by the end use of the data, the analytical methodology employed and the analytical laboratory retained to perform the work.

February 2005Revision 2.0Solatia Inc. and Pharmacia Corporation

Anniston PCS SiteOU-3 Field Sampling Plan

Page 1 of 1

TABLE 3PRECISION, ACCURACY, REPRESENTATIVENESS, COMPARABILITY AND COMPLETENES DATA FOR AQUEOUS SAMPLES

MEASUREMENTPARAMETER

METHODREFERENCE

LABORATORYPRECISION

FIELD & LABORATORYPRECISION

ACCURACY COMPLETENESS (

TCL Volatile OrganicsTCL Semi-Volatile Organics

Pentachlorophenol

TCL Pesticides

PCBs

Organophosphorous Pesticides

TAL Metals

TAL CyanidePCB Congeners and totalhomologue groups

2,3.7,8-TCDD

2,3,7,8-substituted PCDFs

PCDF homologue groups

Turbidity

Oxidation-Reduction Potential

Dissolved Oxygen

Specific Conductance

pHTemperature

SW846 8260B

SW846 8270C

SW846 8270C (SIM)

SW8468081A

SW846 8082SW8468141A

SW846 601 OB/7470

SW8469012

EPA1668A

SW846 8290

SW846 8290

SW846 8290Electrode °

Electrodec

Electrodec

Electrodec

Electrodec

Electrode °

see Table 4 ±20% laboratory, ± 35% field

see Table 4 +20% laboratory, ± 35% field



see Table 4 ±20% laboratory, ±, 35% field








NA ±20%NA ±20%NA ±20%NA ±20%NA ±0.5 std pH units

NA ±0.5 deg C

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4

see Table 4NA(a)

NA(a)

NA(a)

NA(a)

NA(a)

NA(a)

Notes:(a) Accuracy goals that can not be defined as matrix spikes will not be performed.(b) While the goal for completeness of laboratory measurements is 90%, the goal for total completeness (sampling and analytical) is 85%.(c) Field meters will be standardized/calibrated daily and checked every four hours at a minimum.

1. NA = Not applicable2. TCL = CLP Target Compound List, see CLP Statement of Work OLM04.3; TAL = CLP Target Analyte List, see CLP Statement of Work ILM05.2. See Table 7.3. Precision expressed as either percent relative standard deviation (%RSD) or relative percent difference (%RPD).4. Accuracy expressed as percent recovery of matrix spike or laboratory control sample.5. Precision and accuracy for TCL/TAL parameters provided in Table 4.6. Representativeness and Comparability are non-quantitative parameters.

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

IIIIIIIiiiiiiiiiiii



Page 1 of 2

TABLE 4LABORATORY PRECISION AND ACCURACY CRITERIA FOR AQUEOUS TCL/TAL SAMPLES

VOLATILE ORGANICS:Target Spike Compound1,1-DichloroetheneTrichloroetheneBenzeneTolueneChlorobenzene

Surrogate CompoundToluene-d8BromofluorobenzeneDibromofluoromethane

SEMI-VOLATILE ORGANICS:Target Spike CompoundPhenol2-ChlorophenolN-Nitroso-di-n-propylamine4-Chloro-3-methylphenolAcenaphthene4-Nitrophenol2,4-DinitrotoluenePentachlorophenolPyrene

Surrogate CompoundNitrobenzene-d52-FluorobiphenylTerphenyl-d14Phenol-d52-Fluorophenol2,4,6-Tribromophenol

CHLORINATED PESTICIDES:Target Spike Compoundgamma-BHCHeptachlorAldrinDieldrinEndrin4,4'-DDT

Surrogate CompoundTetrachloro-m-xyleneDecachlorobiphenyl

% Recovery53%- 144%70%- 123%69%-128%71%-129%72%-126%

74%-122%70%-119%68%-129%

% Recovery40%-109%43%-110%42%-117%53%-117%53%-116%38%-131%44%-129%49%-126%52%-141%

51%-115%55%- 11 6%11%-120%46%-112%43%-114%47%-133%

% Recovery26%-119%21%-114%20%-99%

46%-124%37%-128%41%-145%

30%-150%30%- 150%

QC LIMITS% RPD0%-30%0%-30%0%-30%0%-30%0%-30%

Not ApplicableNot ApplicableNot Applicable

QC LIMITS% RPD0%-40%

• 0%-40%0%-40%0%-40%0%-40%0%-40%0%-40%0%-40%0%-40%

Not Applicable«. Not Applicable

Not ApplicableNot ApplicableNot ApplicableNot Applicable

QC LIMITS% RPD

0%-40%0%-40%0%-40%0%-40%0%-40%0%-40%

Not ApplicableNot Applicable

IIIIIIIIIIIIIIIIIII



Page 2 of 2

TABLE 4LABORATORY PRECISION AND ACCURACY CRITERIA FOR AQUEOUS TCL/TAL SAMPLES

POLYCHLORINATED BIPHENYLS:Target Spike CompoundAroclor 1016Aroclor 1260


ORGANOPHOSPHOROUS PESTICIDES:Target Spike Compound

Ethyl Parathion

Surrogate CompoundTriphenylphosphate

TARGET ANALYTE LIST:Target Spike CompoundMetalsMercuryCyanide

PCB CONGENERS:Target Spike Compound

12 WHO Congeners & First/Last Elutersfor each congener group (i.e., 27 congeners)

Surrogate Compound12 WHO Congeners & First/Last Eluters foreach congener group (i.e., 27 congeners; 13C12-labeled)

% Recovery32%-109%39%-132%

30%-150%30%-150%

% Recovery30%-150%

29%-152%

% Recovery75%-125%80%-120%75%-125%

50% -150%

25% -150%

QC LIMITS% RPD0%-40%0%-40%


QC LIMITS% RPD

0%-40%

Not Applicable

QC LIMITS% RPD0%-20%0%-20%0%-20%

0%-50%

Not Applicable

2,3,7,8-TCDD/PCDFsTarget Spike Compound

Eleven 2,3,7,8-Substituted PCDD/F Congeners

Surrogate Compound

Eleven 13C12-2,3,7,8-Substituted PCDD/F

70%-130%

40%-130%

0%-25%

Not Applicable

Notes:1. TCL accuracy and precision criteria based upon STL established limits.2. PCB congeners and dioxin accuracy and precision criteria based upon Alta established limits. Although QC will

collected for PCDFs as well as PCDDs, the Site target compounds do not include 2,3,7,8-PCDDs.3. TAL accuracy and precison criteria based upon CLP SOW ILM05.2.4. Precision criteria for metals is +CRDL (reporting limit) for results less than SxCRDL.



Page 1 of 1

TABLE 5PRECISION, ACCURACY, REPRESENTATIVENESS, COMPARABILITY AND COMPLETENESS DATA FOR SOIL SAMPLES

MEASUREMENT

PARAMETER

METHOD

REFERENCE

LABORATORY

PRECISION

FIELD & LABORATORY

PRECISION

ACCURACY COMPLETENESS (a)

TCL Volatile Organics

TCL Semi-Volatile Organics

TCL Pesticides

PCBs


TAL Metals

TAL CyanidePCB Congeners and total homologuegroups2,3,7,8-TCDD2,3,7,8-substituted PCDFsPCDF homologue groups

SW846 8260B

SW846 8270C

SW8468081A

SW846 8082

SW8468141A

SW846 601 OB/7470

SW8469012

EPA1668A

SW846 8290SW846 8290SW846 8290

see Table 6 ±35% laboratory, + 50% field see Table 6

see Table 6 ±35% laboratory, ± 50% field see Table 6






see Table 6 ±35% laboratory, ± 50% field see Table 6see Table 6 ±35% laboratory, ± 50% field see Table 6see Table 6 ±35% laboratory, ± 50% field see Table 6see Table 6 ±35% laboratory, ± 50% field see Table 6

Notes:(a) While the goal for completeness of laboratory measurements is 90%, the goal for total completeness (sampling and analytical) is 85%.

1. TCL = CLP Target Compound List, see CLP Statement of Work OLM04.3; TAL = CLP Target Analyte List, see CLP Statement of Work ILM05.2. See Table 72. Precision expressed as either percent relative standard deviation (%RSD) or relative percent difference (%RPD).3. Accuracy expressed as percent recovery of matrix spike or laboratory control sample.4. Precision and accuracy for TCL/TAL parameters provided in Table 4.5. Representativeness and Comparability are non-quantitative parameters.

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

85%

IIIIIIIIIIIIIIIIIII



Page 1 of 2

TABLE 6LABORATORY PRECISION AND ACCURACY CRITERIA FOR SOIL TCUTAL SAMPLES

VOLATILE ORGANICS:Target Spike Compound1,1-DichloroetheneTrichloroetheneBenzeneTolueneChlorobenzene

Surrogate CompoundToluene-d8BromofluorobenzeneDibromofluoromethane

SEMI-VOLATILE ORGANICS:Target Spike CompoundPhenol2-ChlorophenolN-Nitroso-di-n-propylamine4-Chloro-3-methylphenolAcenaphthene4-Nitrophenol2,4-DinitrotoluenePentachlorophenol .Pyrene

Surrogate CompoundNitrobenzene-d52-FluorobiphenylTerphenyl-d14Phenol-d52-Fluorophenol2,4,6-Tribromophenol

CHLORINATED PESTICIDES:Target Spike Compoundgamma-BHCHeptachlorAldrinDieldrinEndrin4,4'-DDT


% Recovery46%-142%64%-126%65%- 130%63%-133%69%-128%

65%-128%68%-121%66%-127%

% Recovery20%- 108%22%- 109%17%-110%22%-124%39%-104%13%- 133%18%- 125%17%-140%36%-132%

31%-99%37%-106%38%-120%31%-105%31%- 105%26%- 127%

% Recovery35%-132%31%-142%34%- 124%40%-133%42%-137%46%-156%

30%-150%30%-150%

QC LIMITS% RPD0%-50%0%-50%0%-50%0%-50%0%-50%

Not ApplicableNot ApplicableNot Applicable

QC LIMITS% RPD0%-50%0%-50%0%-50%0%-50%0%-50%0%-50%0%-50%0%-50%0%-50%

Not ApplicableNot ApplicableNot ApplicableNot ApplicableNot ApplicableNot Applicable

QC LIMITS% RPD0%-50%0%-50%0%-50%0%-50%0%-50%0%-50%


IIIIIIIIIIIIIIIIIII



Page 2 of 2

TABLE 6LABORATORY PRECISION AND ACCURACY CRITERIA FOR SOIL TCL/TAL SAMPLES

POLYCHLORINATED BIPHENYLS:Target Spike CompoundAroclor 1016Aroclor 1260


QC LIMITS% Recovery % RPD24%-132% 0%-50%28%-153% 0%-50%

30%-150%30%-150%


TARGET ANALYTE LIST:Target Spike CompoundMetalsCyanide

QC LIMITS% Recovery % RPD75%-125% 0%-20%75%-125% 0%-20%

PCB CONGENERS:Target Spike Compound

12 WHO Congeners & First/Last Eluters 50% -150%for each congener group (i.e., 27 congeners)

Surrogate Compound12 WHO Congeners & First/Last Eluters for 25% -150%each congener group (i.e., 27 congeners; 13C12-labeled)

0%-50%

Not Applicable

2,3,7,8-TCDD/PCDFsTarget Spike Compound

Eleven 2,3,7,8-Substituted PCDD/F Congeners

Surrogate Compound

Eleven 13C12-2,3,7,8-Substituted PCDD/F

70%-130%

40%-130%

0%-25%

Not Applicable

Notes:1. TCL accuracy and precision criteria based upon STL established limits.2. PCB congeners and dioxin accuracy and precision criteria based upon Alta established limits. Although QC will

collected for PCDFs as well as PCDDs, the Site target compounds do not include 2,3,7,8-PCDDs.3. TAL accuracy and precison criteria based upon CLP SOW ILM05.2.4. Precision criteria for metals is +CRDL (reporting limit) for results less than SxCRDL.

IIIIIIIIIIIIIIIIIII



Page 1 of 5

TABLE 7TARGET COMPOUNDS/ANALYTES OF INTEREST

TARGET PARAMETERSFORRI

Volatile Organic CompoundsDichlorodifluoromethaneChloromethaneBromomethaneVinyl chlorideChloroethaneTrichlorofluoromethane1 ,1 ,2-Trichloro-1 ,2,2-trifluoroethaneMethyl acetateMethylene chloride *AcetoneCarbon disulfidefert-Butyl methyl ether1,1-Dichloroethene1,1-Dichloroethanec/s-1 ,2-Dichloroethenefrans -1 ,2-DichloroetheneChloroform1 ,2-Dichloroethane2-ButanoneBromochloromethane1,1,1-TrichloroethaneCyclohexaneCarbon TetrachlorideBromodichloromethane1 ,2-Dichloropropanec/s-1 ,3-DichloropropeneTrichloroetheneMethylcyclohexaneDibromochloromethane1 ,1 ,2-TrichloroethaneBenzenetrans -1 ,3-DichloropropeneBromoform4-Methyl-2-pentanone2-HexanoneTetrachloroetheneIsopropylbenzene *1 ,1 ,2,2-Tetrachloroethane *1-2-DibromoethaneTolueneChlorobenzene *EthylbenzeneStyreneXylenes (total)1 ,3-Dichlorobenzene1 ,4-Dichlorobenzene *1 ,2-Dichlorobenzene *1 ,2-Dibromo-3-chloropropane1 ,2,4-Trichlorobenzene

AQUEOUS REPORTINGLIMITS [ug/L]

1.01.0.0.0.0

.0

.010

5.0251.0 '101.01.01.01.01.01.0101.0

1.0101.01.01.01.01.0101.01.01.01.01.010101.0

1.01.0

1.01.0

1.01.01.02.01.01.01.0

1.01.0

SOLIDS REPORTINGLIMITS [ug/kg]

5.05.05.05.05.0

5.05.010

5.0505.0505.05.05.05.05.05.0255.05.0105.05.05.05.05.010

5.05.05.05.05.0

2525

5.05.05.05.0

5.05.05.05.0

105.05.05.0

5.0

5.0

IIIIIIIIIIIIIIIIIII

February 2005 Anniston PCB SiteRevision 2.0 • OU-3 Field Sampling PlanSolatia Inc. and Pharmacia Corporation Page 2 of 5



Semi-Volatile Oraanlc CompoundsBenzaldehydePhenol *bis -(2-Chloroethyl)ether2-Chlorophenol2-Methylphenol2,2'-oxybis(1 -Chloropropane)Acetophenone4-MethylphenolN-Nitroso-di-n-propylamineHexachloroethaneNitrobenzeneIsophorone2-Nitrophenol2,4-Dimethylphenolbis-(2-Chloroethoxy) methane2,4-Dichlorophenol *Naphthalene4-ChloroanilineHexachlorobutadieneCaprolactam4-Chloro-3-methylphenol2-MethylnaphthaleneHexachlorocyclopentadiene2,4,6-Trichlorophenol *2,4,5-Trichlorophenol *1,1'-Biphenyl2-Chloronaphthalene2-NitroanilineDimethylphthalate2,6-DinitrotolueneAcenaphthylene3-NitroanilineAcenaphthene2,4-Dinitrophenol4-Nitrophenol (PNP) *Dibenzofuran2,4-DinitrotolueneDiethylphthalateFluorene4-Chlorophenyl-phenyl ether4-Nitroaniline4,6-Dinitro-2-methylphenolN-Nitroso-diphenylamine4-Bromophenyl-phenyl etherHexachlorobenzeneAtrazinePentachlbrophenol (SIM) *PhenanthreneAnthraceneCarbazoleDi-n-butyl phthalateFluoranthenePyreneButylbenzyl phthalate3,3'-Dichlorobenzidine


1010101010

1010101010101010101010105010101010

1010101010501010105010502510101010

105050

1010

10

101

10

10

101010

101020


330330330330330330330330330330330330330330330330330660330

330330330330330330330

3301700330

3303301700330170083033033033033033017001700330330

330330

1700330

330330330330330330660

IIIIIIIIIIIIIIIIIII

February 2005 Anniston PCB SiteRevision 2.0 OU-3 Field Sampling PlanSolutia Inc. and Pharmacia Corporation - Page 3 of 5



Benzo(a)anthraceneChryseneWs-(2-Ethylhexyl) phthalateDi-n-octylphthalateBenzo(b)fluorantheneBenzo(k)fluorantheneBenzo(a)pyrenelndeno(1 ,2,3-cd)pyreneDibenzo(a,h)anthraceneBenzo(g,h,l)peryleneO,O,O-Triethyl phosphorothioate *

Pesticides/PCBsalpha-BHCbeta-BHCdelta-BHCgamma-BHCHeptachlorAldrinHeptachlor epoxideEndosulfan IDieldrin4,4'-DDEEndrinEndosulfan II4,4'-DDDEndosulfan sulfate4,4'-DDTMethoxychlorEndrin ketoneEndrin aldehydealpha-Chlordanegamma-ChlordaneToxapheneAroclor-1016 *Aroclor-1221 *Aroclor-1232 *Aroclor-1242 *Aroclor-1248*Aroclor-1254 *Aroclor-1260 *Aroclor-1268*


1010

10

1010 v

101010101010

0.050.050.050.050.050.050.050.050.10.10.10.10.10.1

0.1

0.50.10.1

0.050.055.0

0.50.50.50.5

0.50.5

0.50.5


330330

330330330

330

330330330

330330

1.71.71.7

1.71.71.71.71.7

3.33.33.3

3.33.33.33.3173.33.3

1.71.7170

336733

33333333

33

IIIIIIIIIIIiIIIIIII



Page 4 of 5



Orqanophosphorous PesticidesEthyl Parathion *Methyl Parathion *Sulfotepp *

Target Analvte ListAluminumAntimonyArsenic *Barium *Beryllium *Cadmium *CalciumChromium *Cobalt *CopperIronLead *MagnesiumManganese *Mercury *Nickel*PotassiumSeleniumSilverSodiumThalliumVanadium *ZincCyanide

PCB Congeners (see Table 8)Each congenerTotal homologue groups

Dioxin/Furans2,3,7,8-TCDD2,3,7,8-TCDF1,2,3,7,8-PeCDF2,3,4,7,8-PeCDF1,2,3,4,7,8-HxCDF1,2,3,6,7,8-HxCDF2,3,4,6,7,8-HxCDF1,2,3,7,8,9-HxCDF1,2.3,4,6,7,8-HpCDF1,2,3,4,7,8,9-HpCDFOCDF

PCDF Homologue Groupstetra-CDFpenta-CDFhexa-CDFhepta-CDF


1

0.50.5

Fug/Li20020

101045

500101020505

500100.2

4010001010

5001010205

units (pg/L)4040

units (pg/L)10105050505050505050

100

10

50

5050


NANANA

fmq/kql2021

10.4

0.55011

25

0.5501

0.024

10011

501

1

20.5

units (pg/g)44

units (pg/g)11555

5

5555

10

1

555

IIIIIIIIIIIIIIIIIII



TARGET PARAMETERS AQUEOUS REPORTING SOLIDS REPORTING

FORRI LIMITS [ug/L] LIMITS [ug/kg]

Notes:1. VOC, SVOC, and Pesticide Lists from CLP SOW OLM04.32. TAL Metals List from CLP SOW ILM05.23. The Reporting Limits shown for the Target Analyte List are the maximum reporting limits that may be used for an

undiluted sample. The laboratory will report results to the Instrument Detection Limit (IDL) which are generatedevery quarter.

4. Reporting Limits will be modified on an individual sample basis depending upon dilution, percent solids, andsample matrix considerations.

5. Constituents denoted with an asterisk (*) are listed in the Consent Decree as a Potential Constituent of Concern.6. The laboratory reporting limits and MDLs are reassessed on an annual basis and may change slightly over the

course of the project.



Page 1 of 5

TABLE 8PCB CONGENER AND MONOLOGUE GROUP REPORTING LIMITS

IUPAC No. BZ#Chlorination

LevelStructure Ring Chlorine

PositionAqueous Reporting

Limit [pg/L]Solids Reporting

Limit [pg/gm]

PCB Conqenersr2

3 '4 '567891011121314

15 1

161718

19 '2021222324252627282930313233343536

37 1

383940414243444546

MonoMono ,.MonoDiDiDiDiDiDiDiDiDiDiDiDiTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTriTetraTetraTetraTelraTetraTetraTetra

2342-2232-3242-425263-3343-4354-423-224-225-226-223-323423-423523624-325-326-324-424524625-426-434-235-234-335-334-434535-423-23234-223-24235-223-25236-223-26

4040

40

40

40

40

40

44

4

4

4

4

4



Page 2 of 5

TABLE 8PCB CONGENER AND HOMOLOGUE GROUP REPORTING LIMITS

IUPAC No.

47484950515253

54 '5556575859606162636465666768697071727374757677"787980

81 z

828384858687888990919293

BZ#Chlorination

Level

TetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraTetraPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPenta

Structure Ring ChlorinePosition

24-24245-224-25246-224-2625-2525-2626-26234-323-34235-323-35236-3234-423452346235-4236-4235624-34245-324-35246-325-3426-3425-3526-35245-4246-4345-234-34345-334-3535-35345-4234-23235-23236-23234-242345-2234-252346-2234-26235-24236-24235-252356-2

Aqueous ReportingLimit [pg/L]

40

40

40

Solids ReportingLimit [pg/gm]

4

4

4



Page 3 of 5


IUPAC No.

949596979899100101102103

104 1

105 z

106107 3

108 3

109 J

110111112113

1141

115116117

1181

119120121122

123 1

124125

126 1

127128129130131132133134135136137138139140

BZ#

108

109

107

ChlorinationLevel

PentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaPentaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexa


235-26236-25236-26245-23246-23245-24246-24245-25245-26246-25246-26234-342345-3234-352346-3235-34236-34235-352356-3236-352345-42346-4234562356-4245-34246-34245-35246-35345-23345-24345-25345-26345-34345-35234-2342345-23234-2352346-23234-236235-2352356-23235-236236-2362345-24234-2452346-24234-246


40

40

40

40

40

40


4

4

4

4

4

4



Page 4 of 5

TABLE 8PCB CONGENER AND MONOLOGUE GROUP REPORTING LIMITS

IUPAC No.

141142143144145146147148149150151152153154

155 1

156 2

157 z

158159160161162163164165166

167 2

168

1692

170171172173174175176177178179180181182183184185186187

BZ#Chlorination

Level

HexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHexaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHeptaHepta


2345-2523456-22345-262346-252346-26235-2452356-24235-246236-245236-2462356-252356-26245-245245-246246-2462345-34234-3452346-342345-3523456-32346-35235-3452356-34236-3452356-3523456-4245-345246-345345-3452345-2342346-2342345-23523456-232345-2362346-2352346-2362356-2342356-2352356-2362345-24523456-242345-2462346-2452346-24623456-2523456-262356-245


40

8

8

40

40


4

8

8

4

4

IIIIIIIIIIIIIIiiiii



Page 5 of 5


IUPAC No.

188 '189 z

190191192193194.195196197198

199 4

200"201 "202 '203204

205 1

206 ]

207

208 '209 '

BZ#

201

199

200

ChlorinationLevel

HeptaHeptaHeptaHeptaHeptaHeptaOctaOctaOctaOctaOctaOctaOctaOctaOctaOctaOctaOctaNonaNonaNonaDeca


2356-2462345-34523456-342346-34523456-352356-3452345-234523456-2342345-23462346-234623456-2352345-235623456-2362346-23562356-235623456-24523456-24623456-34523456-234523456-234623456-235623456-23456


40

40

40

40

40

40

40


4

4

4

4

4

4

4

PCB Homoloque Groups 5

mono-CIdi-CItri-CItetra-CIpenta-CIhexa-CIhepta-CIocta-CInona-CIdeca-CI

40404040404040404040

4444444444

1. First and last eluting congeners for each retention time window. Reporting limits reflect the equivalent of thelowest standard for the WHO congeners and first and last eluters. Actual reporting limits will be based onthe instrument signal to noise ratios and will be less than the low standard.

2. World Health Organization (WHO) congeners3. IUPAC#s 107,108, & 109 correspond to BZ #s 108, 109 & 107.4. IUPAC#s 199, 200, & 201 correspond to BZ #s 201, 199 & 200.5. Values for each homologue group will be calculated using the sum of those peaks that meet the mass ratio

criteria within the established retention time window. Total PCBs will be calculated as the sum of thedetected homologue groups. If PCBs are not detected, the total PCBs will be reported as the loweststandard for a single congener or homologue group.

IIIIIIIIiiiiiiiiiii



Page 1 of 1

TABLE 9

SOIL SAMPLING STATISTICAL ANALYSIS

# of Samples =AL(ug/kg) =

37

740

ZVoo = -1 .645

Zi-p = -0.842

MeanMean tog

Std Dev

Std Dev log

772,5253.900

3,123,054

1.473

A2 = 5.96E+1 1A2

tog = 1 .06

n =nlog =

10112.6

Sample Location

SSR-18

SSR-18SSR-15SSR-09SSR-07

SWMU-12-24ESSR-05SSR-04

SWMU-12-24CSSR-15

SWMU-12-24GSWMU-25

SWMU-12-24FSWMU-12-24ASWMU-12-24ASWMU-12-241

SSR-13SWMU-31

SSR-02SSR-06

SWMU-12-24DSSR-14AOC-A

SWMU-12-24HSWMU-17

SSR-03SSR-12SSR-21

SWMU-12-24B

SSR-19SSR-17

SSR-11SSR-10SSR-10SSR-08SSR-01SSR-16

lotaiKUU(Mg/kg)

16,620,000

9,800,000861 ,000282,000229,000169,000106,000104,00084,00065,00041 ,20038,60028,10026,30026,20018,00016,00013,6701 1 ,2009,3009.1106,4005,7204,4404,120

2,170670559

540507

205204

87

6534

237

Log(TotPCB)

7.22

6.995.945.455.365.235.035.024.924.814.614.594.454.424.424.264.204.144.053.973.963.813.763.653.613.342.832.752.732.712.312.311.941.811.531.360.83

Rank37

363534333231302928272625242322212019181716151413121110987654321

Probability0.974

0.9470.9210.8950.8680.8420.8160.7890.7630.7370.7110.6840.6580.6320.6050.5790.5530.5260.5000.4740.4470.4210.3950.3680.3420.3160.2890.2630.2370.2110.1840.1580.1320.1050.0790.0530.026

Z-score1.938

1.6201.4121.2521.1191.0030.8990.8050.7160.6340.5550.4800.4070.3360.2670.1990.1320.0660.000-0.066-0.132-0.199-0.267-0.336-0.407-0.480-0.555-0.634-0.716-0.805-0.899-1.003-1.119-1.252-1.412-1 .620-1 .938



Page 1 of 1

TABLE 10ANALYTICAL METHODS, SAMPLE CONTAINERS, PRESERVATION AND ANALYTICAL HOLD TIMES FOR AQUEOUS SAMPLES

PARAMETER



Pentachlorophenol

TCL Pesticides

PCBs


TAL Metals

TAL CyanidePCB Congeners and total homologuegroups

2,3,7,8-TCDD

2,3,7,8-substituted PCDFs

PCDF homologue groups

Turbidity

Oxidation-Reduction Potential

Dissolved Oxygen

Specific ConductancePHTemperature

METHODOLOGY

SW846 8260B

SW846 8270C

SW846 8270C (SIM)

SW846 8081

SW846 8082SW -846 81 41

SW846 601 OB/7470

SW8469012

EPA1668A

SW846 8290

SW846 8290

SW846 8290

Electrode

Electrode

Electrode

ElectrodeElectrodeElectrode

CONTAINER

3-40 mL Glass

2-1 000 mL Glass

2-1 000 mL Glass

2-1 000 mL Glass

2-1 000 mL Glass

2-1 000 mL Glass

1 -500 mL Plastic

1-1 000 mL Plastic

2-1 250 mL Glass

2-1 250 mL Glass

2-1 250 mL Glass

2-1 250 mL Glass

NANA

NANANA

NA

MINIMUMSAMPLE

3-40 mL1000mL

1000mL

1000mL

1000mL

1000mL

250 mL500 mL

2000 mL

2000 mL

2000 mL

2000 mL

NANANANANANA

PRESERVATION (1)

Cool 4 °C;HCI,pH<2

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 CC

Cool 4 °C

Cool 4 °C; HNO3, pH<2

Cool 4 °C; NaOH, pH>12

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

None

None

None

NoneNoneNone

HOLD TIME (2>

14 days (3)

7 days (5)

7 days (5)

7 days (5)

7 days (5)

7 days (5)

180 days (6)

14 days

365 days (7)

30 days

30 days

30 days

Field Measurement (4)



Field Measurement (4)Field Measurement (4)Field Measurement (4)

Notes:1. Sample preservation is performed by sampler immediately upon sample collection.2. Hold time based upon day of sample collection not Verified Time of Sample Receipt.3. If sample cannot be preserved due to foaming, unpreserved sample will be analyzed within 7 days.4. Field measurements will be collected using a flow-through cell equipped with a field meter and parameter specific electrodes.5. Hold time is 7 days until start of sample extraction, 40 days following extraction for analysis.6. Hold Time for metals is 180 days, except for Mercury which is 28 days.7. Aqueous at 0-4°C and soil samples at -10°C can be stored for up to one year.



Page 1 of 1

TABLE 11ANALYTICAL METHODS, SAMPLE CONTAINERS, PRESERVATION AND ANALYTICAL HOLD TIMES FOR SOIL SAMPLES

PARAMETER



TCL Pesticides

PCBs

TAL MetalsTAL CyanidePCB Congeners and totalhomologue groups

2,3,7,8-TCDD2,3,7,8-substituted PCDFsPCDF homologue groups

METHODOLOGY

SW-846 5030/8260

SW846 3550B/8270C

SW846 3550B/8081SW846 3550B/8082

SW846 3050B/601 OB/7471

SW8469012

EPA1668A

SW846 8290SW846 8290SW846 8290

CONTAINER

3-40 mL Glass

4 oz Glass

4 oz Glass

4 oz Glass

4 oz Glass

4 oz Glass

4 oz Glass

4 oz Glass4 oz Glass4 oz Glass

MINIMUMSAMPLE

5gm

30 gm30 gm30 gm30 gm30 gm

30 gm

30 gm30 gm30 gm

PRESERVATION (1)

Cool 4 °C; NaHSC-4 (pH<2), Methanol

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

Cool 4 °C

HOLD TIME w

14 days (3)

7 days (4)

7 days (4)

7 days (4)

180 days (5)

1 4 days

365 days (6)

30 days

30 days

30 days

Notes:

1. Sample Preservation is performed by sampler immediately upon sample collection except for VOCs which is performed

by laboratory upon receipt (see Note 3).

2. Hold time based upon day of sample collection not Verified Time of Sample Receipt.

3. Hold time is 48 hours for preservation using methanol and/or sodium bisulfate and 14 days to analysis.

4. Hold Time for SVOCs, Pesticides/PCBs is 7 days for extraction and 40 days for analysis.

5. Hold Time for metals is 180 days, except for Mercury which is 28 days.6. Aqueous at 0-4°C and soil samples at -10°C can be stored for up to one year.

FIGURES

I SCALE ....... . . ... . . . . ....... ..:: ..:. .:::a 0 . . . . .........I g::,, ........ . . . : . . . . . . . . ....................

0::::::: Q--' .a :.::.:.: -I.:: ;. ....... ... coldwater dlountain 200 0 200 400 600 Feet : : ...... .......

.... n n '0 -

Facility Areas (OU -3)

OU-3 Field Sampling Plan

Anniston PCB Site, Anniston, Alabama

LEGEND

,.".,/ On-Site Boundary /V Major Roads ...':..... " Minor Roads

5Y Drainage Basin Railroads 0 Buildings f Paved Surface

( On-Site Area Landfill Areas

NOTES

Alabama East 101

lllAP PROJECTION

Golder Associates (on-site base map) USGS 1:2400 Quad Mans

US State Plane NAD83

-0CATION MAP

Anniston PCB Site

)ATE: PRODUCED BY FILE No: FIGURE NO.

February 2005 wigis^- is^-mf.av 1

Proposed Monitoring Well and Groundwater Sampling Locations



LEGEND

On-Site Boundary /V Major Roads a Recovery Well . . .. . . . . . . ' .. ... Minor Roads 0 Shallow Residuum Monitoring1

/V Drainage Basin Observation Well

Railroads Exiding Wells to be Sampled Buildings During the RllFS

2 Iabama power * Temporary Wells to be Sampled

a =-'.~tia Inc. During the RllFS

ed Surface Deep Wells to be Installed During the RllFS

NOTES

Golder Associates (on-site base map) Alabama East 101 USGS 1:2400 Quad Maps

rllAP PROJECTION 1 DATUM

US State Plane NAD83

LOCATION MAP

Anniston PCB Site

1 )ATE: PRODUCED BY: PROJECTlFlLE No: FIGURE NO.

February 2005 JES Q\gis\ ... sup-rfi.apr


One Mile Perimeter Parcels with Potable Wells Sampled Parcels Litigants

US State Plane

LOCATION MAP

niston

Anniston PCB Site

Proposed Soil Sample Locations



LEGEND

)V Railroads /V Major Roads ...'.. ... Minor Roads ; ..: 'N Drainage Basin

& Property Line

Paved Buildings

Landfill Area

@ RFIICS Subsurface soil sample RFIICS Surface (or near surface) soil sample Supplemental RFIICS Soil Sample

Proposed Soil Sample Location

NOTES

ZONE SOURCE Golder Associates (on-site base map)

Alabama East 101 USGS 1 :2400 Quad Maps

MAP PROJECTION DATUM

US State Plane I NAD83

LOCATION MAP

Anniston PCB Site

]ATE: PRODUCED BY: PROJECTlFllE No: FIGURE No:

February 2005 1 K G ~ . . ~ i \ p r o p \ p r o p s a m . a 983-3m 1 4



LEGEND

A Recovery Well O Shallow Residuum Monitoring

Observation Well @ Deep Residuum Monitoring

Observation Well

/\I Equipotential Contour (feet above mean sea level)

Anniston PCB Site

X" niston

I

)ATE: Pf?ObUCED BY: PROJECTIFILE No: FIGURE NO.

February 2005 JES Q\gis\ ... sup-rfmpr 5

IIII• APPENDIX A

I• OU-3 Health and Safety

Procedures

IIIIIIIIIIIB

IIIIIIIIIIIIIIIIIII

February 2005 Anniston PCB SiteRevision 2.0 OU-3 Health And Safety Procedures

page i of I

TABLE OF CONTENTS

SECTION ' PAGE

Al. INTRODUCTION . 1

A2. FACILITY DESCRIPTION....... 2

A2.1 General Information '. 2

A2.2 Facility/Work Site Description 2

A3. HEALTH AND SAFETY ORGANIZATION 3

A4. HAZARD EVALUATION 4

A4.1 General 4

A4.2 Field Activities 4A4.3 Activity-Specific Hazards 4

A4.4 Physical Hazards 5

A4.5 Chemical Hazards 6

A4.6 Biological Hazard 6

AS. WORK TASKS AND PERSONAL PROTECTIVE EQUIPMENTREQUIREMENTS ..7

In OrderFollowing

Page 7

TABLES

Al. OU-3 Field Activities PPE Requirements

IIIIIIIIIIIIIIIIIII


Page 1 of 7

Al. INTRODUCTION

These health and safety procedures have been developed to provide safety procedures that are

specific to the field activities for Operable Unit 3 (OU-3), including a specific job hazard analysis

for this OU. OU-3 consists of the plant site, the South Landfill, and the West End Landfill

(collectively, the Facility). These procedures, together with the Site-wide Health and Safety Plan

(HSP), which is to be submitted under separate cover, form the OU-3 HSP. The OU-3 HSP has

been developed for the protection of the Remedial Investigation and Feasibility Study (RI/FS)

project team and other persons that may be exposed to hazards associated with RI/FS field

activities performed at the Facility. The purpose of the OU-3 HSP is to assign responsibilities,

establish personal protection standards, specify and establish safe operating procedures and

practices, and provide for contingencies that may arise while conducting field activities at the

Facility.

The OU-3 HSP is based on the information available concerning the possible chemical and

physical hazards found on the Facility.

IIIIIIIIIIIIIIIIIII


Page 2 of 7

A2. FACILITY DESCRIPTION

A2.1 General Information

The field activities will be conducted in accordance with the RI/FS Work Plan and the OU-3

Field Sampling Plan. Solutia Inc./Pharmacia Corporation has designated Mr. Craig Branchfield

as its Project Manager. Mr. Branchfield is located at Solutia's Anniston facility at:

Solutia Inc.

702 Clydesdale Ave

Anniston, Alabama 36201

(256)231 -8404

A2.2 Facility/Work Site Description

The Facility is located approximately one mile west of downtown Anniston, Alabama along

Highway 202, in Calhoun County. Work tasks will include the following:

• surveying;

• sampling surface and subsurface soils;

• installing monitoring wells;

• sampling monitoring wells; and

• performing ecological habitat survey.

II February 2005 Anniston PCB Site

Revision 2.0 OU-3 Health And Safety Procedures• Page 3 of 7

A3. HEALTH AND SAFETY ORGANIZATION

I The key personnel listed below will be responsible for the supervision and implementation of the

requirements outlined in the OU-3 HSP for the Facility.

• Project Manager: Craig Branchfield (Solutia Inc.)

• 011-3 RI/FS Manager: Gayle Macolly (Colder Associates Inc.)

• Sampling Health and Safety Officer: Charles Haury (Colder Associates Inc.)

• OU-3 Sampling Health and Safety Coordinator: Kevin Haborak (Colder Associates Inc.)

• OU-3 Site Safety Officer: Katie Ross (Colder Associates Inc.)

• OU-3 Ecological Survey Leader: Dave Ludwig (BBL, Inc.)

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

The responsibilities for each of these personnel are described in the Site-wide HSP.

IIIIIIIIIIIIIIIIIII


Page 4 of 7

A4. HAZARD EVALUATION

A4.1 General

This section presents chemical and physical hazard information to be used for the development of

health and safety protocols for Facility activities. The goals of the hazard evaluation are twofold:

1) to summarize available chemical information and the corresponding impacts on worker health

and safety; and 2) to adequately describe the physical hazards associated with the Facility. This

information is important in the development of action levels to be used for the determination of

levels of respiratory and dermal protection. The judgment of the Sampling Health and Safety

. Officer will provide the basis for upgrading or downgrading levels of protection. The main

constituents of concern at the Facility are listed in the Site-wide HSP.

A4.2 Field Activities

Field activities that will be performed during the OU-3 investigation include the following:

• surveying;

• surface and subsurface soil sampling;

• monitoring well installation and groundwater sampling; and

• ecological habitat survey.

Each of these activities involves different potential hazards and requires different levels of

protection.

A4.3 Activity-Specific Hazards

The health and safety hazards associated with the types of activities to be performed at the

Facility are described below:

• Surveying

This is a non-intrusive task and will typically be performed after all intrusive activitiesare complete. Therefore, the potential hazards to personnel performing these tasks areanticipated to be low.

• Surface and Subsurface Soil Sampling

The potential hazards associated with this activity include inhalation or dermal contactwith potentially contaminated soils and physical hazards, such as slips, falls, or sprains.

IIIIIIIIIIIIIIIIIII


Page 5 of 7

• Monitoring Well Installation and Groundwater Sampling

The installation of monitoring wells requires several steps. The initial steps involvepositioning the rig over the borehole, boring for the well, sampling solids and liquids, andthe placement of well casing and likely slotted screens in the borehole. These steps aretypically followed by the packing of the well placement materials (cement grout,bentonite, sand, cement) around the screen and casing, and well development. Theprocedure is completed by the purging and actual sampling, testing, or both of themonitoring well. Two types of potential chemical hazards are associated with these steps.The main hazard at the Facility is dermal contact with potentially-impacted materials,water, and apparatus. The less likely type at this site is potential exposure to vaporsduring well installation, well development, and sampling activities. There are physicalhazards also associated with these steps including slips, falls, or sprains; and workingaround a drill rig.

• Ecological Habitat Survey

This is generally a non-intrusive task. However, limited soil sampling will be conductedas part of the survey activities. The potential hazards associated with the samplingactivity include inhalation or dermal contact with potentially contaminated soils.

A4.4 Physical Hazards

Physical safety hazards are inherent at an operating facility. It is the responsibility of the project

personnel to follow all applicable regulations as well as those requirements outlined in the OU-3

HSP and all requirements from the Facility in order to reduce avoidable accidents and injuries.

The following is a list of potential hazards:

• utilities (above and below ground);

• machinery (e.g., drilling rigs, etc.);

• vehicular traffic;

• weather;

• heat or cold stress;

• holes and ditches;

• uneven terrain;

• slippery, irregular surfaces; and

• operations (e.g., chemical manufacturing, offices and laboratory).

IIIIIIIIIIIIIIIIIII


Page 6 of 7

A4.5 Chemical Hazards .

Because the Facility has been shown to contain a variety of chemicals (such as polychlorinated

biphenyls (PCBs), organophosphorous pesticides, phenols, and potentially some volatiles), there

is a potential for the RI/FS workers to be exposed to chemical hazards. The likely pathway for

exposure to occur is dermal contact with materials, via inhalation of vapors or particulate

materials, or both. Ingestion could also occur if personal hygiene is inadequate. The Site-wide

HSP lists known exposure limits and action levels for constituents of potential concern at the

Facility. The Site-wide HSP also includes lexicological data for these anticipated constituents.

A4.6 Other Hazards

Other safety hazards present at the Facility are likely to be encountered in the portions of the

Facility that do not contain significant improvements (i.e. West End and South Landfills). The

following is a list of potential hazards:

• tick bites and other insects;

• poisonous snakes; and

• poisonous plants.

IIIIIIIIIIIIIIIIIII


Page 7 of 7

AS. WORK TASKS AND PERSONAL PROTECTIVE EQUIPMENTREQUIREMENTS

The level of protection required for each area of the Facility involving field activities will be

based on the recognized hazards of the chemical constituents expected onsite, most likely routes

of exposure (e.g., dermal, ingestion and 'possibly inhalation) and on air monitoring and action

levels determined from a hazard evaluation of the chemicals known or suspected to be present in

these areas. The purpose of PPE is to ensure that the individual is protected from the hazards

encountered in the course of the project. The elements involved in PPE include protective

clothing, eye and face protection, and respiratory protection that should be utilized by individuals

involved in RI/FS field activities.

A description of minimum requirements for Level C and Level D protection is summarized in the

Site-wide HSP. When using Level C criteria, the buddy system must be used; at least two

persons must conduct the work. Planned field activities will be initiated at Level D protection.

The Health and Safety Coordinator will decide if an upgrade to Level C is necessary due to

airborne dust. If PPE above Level C is deemed necessary, then field activities will cease pending

assessment.

A summary of PPE requirements for the OU-3 specific tasks is provided in Table 1.

Modifications in the personal protective equipment requirements outlined in this document may

be necessary as new conditions and/or tasks warrant. Addenda and revisions to the OU-3 HSP

will be made in accordance with the Site-wide HSP.

IIIIIIIIIIIIIIIIIII

February 2005Revision 2.0

Anniston PCB SiteOU-3 Health And Safety Procedures

Page 1 of 1

TABLE 1

OU-3 FIELD ACTIVITIES PPE REQUIREMENTS

Task

Surveying

Soil Sampling

Monitoring WellInstallation

GroundwaterSamplingEcologicalHabitat SurveyDecontamination

Respiratory

NA

NA

NA

NA

NA

NA

Clothing

Level D

Level D

Level D

Level D

Level D

Level D

Gloves

NA

L,N(optional)

L,N(optional)

L,N(optional)

L,N(optional)

L,N(optional)

Boots

.B

B

B

B

B

B

Other *

SG and HH

SG and HH

SG and HH(HP withdrill rig)

SG and HH

SG and HH

SG

NOTES:BHH =HP =LNNA =SG =TW =* =

Steel-toe work bootsHard hatHearing ProtectionLatexNitrileNot AnticipatedSafety glassesTyvekWork GlovesDepending on Area

APPENDIX B

Field Forms

GROUNDWATER SAMPUNG FORM

Project Number

Project Name/Site Name

Well ID

Event

Subevent •

Date

Begin Time _____

End Time '

Sampler(s) _______

Weather

Page of

COCID#1_

COC ID #2_

COCID#3_

COCID#4_

COC ID #5_

COCID#8_

COCID#7_

COC ID #8

= Original Sample

_= Duplicate

_= Field Blank

_= MS/MSD

= Original Sample - Filtered

= Duplicate - Filtered

_= Field Blank - Filtered

= MS/MSD • Filtered

Temperature (°C I °F)

pH (Standard Unit)

Turbidity (NTU)

Conductivity (pmhos/cm)

Sampling Method/Material

SAMPLING DATA / FIELD PARAMETERS

Color

Appearance _

DO (mg/L) _

ORP (mV)

CONTAINER AND ANALYSES DESCRIPTION

COLLECTED CONTAINER AND ANALYSES40 ml glass vial with HCI for VOA analysis (82608)1 L glass vial with no preservative for SVOA (8270C)1 L glass vial with no preservative for Pentachlorophenol (8270C SIM)1 L glass vial with no preservative for TCL Pesticide (6081)1 L glass vial with no preservative for PCB (8082)1 L glass vial with no preservative for Organophosphorous Pesticide (8081)1 L plastic with NaOH for TAL Cyanide (9012)1250 ml glass vial with no preservative for PCB congeners (EPA 1668A)1250 ml glass vial with no preservative for 2.3.7.8TCDD/PCDFS (EPA 1668A)500 ml plastic with HNO3 for TAL metals 601 OB/7470

NOTES

REMARKS

PARAMETER LISTTCL Volatile OrganicsTCL Semi-Volatile OrganicsPentachlorophenolTCL PesticidesPCBs

Organophosphorous PesticidesTAL MetalsTAL CyanidePCB congeners2.3.7.8 TCDD/PCDFs

Associates Atlanta, Georgia

GROUNDWATER SAMPLING LOG

CLIENT/PROJECTJES

OU-3 FIELD SAMPLING PLANANNISTON PCB SITE

CHECKEDKH

SM

APRIL 2004

N/AFILE NO.

Appendix B l.cdr

943-3680

B-1

SOIL (SOLID) SAMPLING LOG

Project Number

Event

Subevent _

Weather _

Sampler(s)

Page of

Date

Begin Time

End Time

Location

CoCID/M _

CoCID*2_

CoCID#3_

CoCID#4_

CoCID#5_

CoCID#6

as DO as aws/MSDOS DD DB OMS/MSD

as DD DB OMS/MSD

OS DD DB DMS/MSO

as DD OB DMS/MSO

as DD DB OMS/MSD

Min Depth (in.)

Max Depth (In.)

Sample Composite Includes Soil From SampleLocations (indicated on the diagram sheet):

GPS Coordinates: Point*

Point #

Point»

Point #

Point #

SAMPLING DATA / FIELD PARAMETERS

Description (vrf cofor & Irthofogy):

Check if applicable: a Fill D Natve a Other

Sampling Method/Material

CONTAINER AND ANALYSES DESCRIPTION

Quantity Container and Analysis

40 ml Glass w methanol/sodium bisulfate preservative - TCL Volatile Organics

4 oz Glass - TCL Semi-Volatile Organics

4 oz Glass - TCL Pesticides

4 oz Glass • PCBs

4 oz Glass - TAL Metals

4 oz Glass - TAL Cyanide

4 oz Glass • PCB congeners

4 oz Glass - 2.3.7,8-TCDD/PCDF's

REMARKS

S - Original Sample B = Equipment BlankABBREVIATIONS

D - Duptcale Sample MS/MSD = Matrti SplkeAtatrlx Spike Duplicate

r GolderAssociates Atlanta, Georgia

SOIL SAMPLING LOG

CLIENT/PROJECT JESOU-3 FIELD SAMPLING PLAN

ANNISTON PCB SITEKH

SM

APRIL 2004

N/A

Appendix B l.cdr

943-3680

FIGURE NO.'B-2

'

.Serial Number '025025

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PECEIVEO BY; iigCH*TL«t) 0*TE

RECCJVEO FOH wBCffy.iOFrv BY: DATE

-

1U.IE

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nwE

CLIENT/PROJECT

OU-3 FIELD SAMPLING PLAN

ANNISTON PCS SITE

DRAWN

JESCHECKED REVIEWED

KH SM

d

T™

1£

U5

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i:oi.o

nil ft.v

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CUSTODY SU'-SL tCXT. NO. LAOOflATCBY. HCMAnKS;

. . . - . . . - - -

IIpGolder"Associates Atlanta, Georgia

April 2004 N/A Append ix_B_2

ORIG

INAL

TITLE

STL CHAIN OF CUSTODY

943-3680 B-3

ALTA ANALYTICAL PERSPECTIVES' • - • • ' • -

KO.'Noi: SAMPLER:(PRINTED NAME) (SIGNATURE

REVJMQUISHCDOYlCSIONATUnEarRlKTEDHAME) DATE:: TIME: RECEIVED BY: (8IONATURE ft PRINTED NAME) DATE: TIME:

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REUNQUISHED BY: <6ioNATUREi9i PRINTED NAME) DATE:. TIME: RECEIVED BY-. (SIGNATURE a PRINTED NAME) 'DATE: TIME:

SHIP TO:;

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AUTA-ANALYTICAL PERSPECTIVES2714 EXCHANGE DRIVEWlLMINaTON, NC 38405•PH.:'9i'di794-jf(5l3'.

METHOD OF SHIPMENT:

SHIPMENT ID:

SAMPLE ID DATE: TIME SAMPLE DESCRIPTION

SPECIAL INSTRUCTIONS/COMMENTO:

CONTAINER TYPES: A:•= I L AMBER; G» GLASS JAR; P » PUF;f .= MMS TRAIN;:p-OTHER _______

BPT=-BOTmjE:PRESERVATiVETYPE:T = THIpBUl.FATE;O= OTHER

Please specify- . - ,.. ~ . .. . . — »S«nd Documentation 4 Reiulls to: -ctTEFs"

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Name:Company:Address:City;: . '

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Fax:

Zip:

CLIENT/PROJECT


AssOOales Atlanta, Georgia

TITLE

ALTA CHAIN OF CUSTODY

JES KH SM April 2004 N/A Appendix_B_2 943-3680

DWG NO/REV NO.

B-4

Table E-1Fish and Wildlife Survey Form

Data (mmAid/vwvV • /

Time:

Page ol

. ' ;Species". :Nanie ..

:..'

. . •

.

Number'.Obs.;

•

SightCode'

Sign'Code

ObserversInitials

Habitat Type / Location'(approximate) . ',

•

.: ;

.

. - '• " .

'

Instructions:• Enter tpaciu common name In column 1 and number obwrwd in column 2• S«lac1 appropriate "tighr or7«ion" codn from txkwand «m«r Into an>gnal«o boio»-Enl«fJnlUiliolObwrrtr ' ". . '• Enlw hobftat'wnere ipocioi yia> ctmervta tria «pprbiimal» kxjtton In riw

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nwtir>fl. parchingcalling•Kght 'oilier: _

Skin Codo«;SC teatSL i«d>

OHB oan. hut burrowTR tracAaDB oay bad

CA callWE nailTR IrackiFO browse_ othor. _

BIASLAMD. BOUCK & L£E. INC.A s E-1-

BLASLAND, BOUCK & LEE, INC. ENVIRONMENTAL SURVEY LOG

I

CLIENT/PROJECTJES


KH

SM

APRIL 2004JOB NO.

SCALEN/A

DWG NO.

Appendix B l.cdr

943-3680

B-5

MONITORING WELL PURGING/DEVELOPMENT LOG

Project Number

ProjectName - Location

Page .of

Well ID: 'Date/ ...

Water Level: Time (Water;Leyel):__

Description of Measuring'PoInt

Purging Time:"-

,Oft,@: _

Evacuation Method:

Well Depth; .

Watertevei:

Water Column:"

paljons per'Foot:

Purging Personnel:

; Well Vyizard'Unit:

'Volume in-Well (gal);

; Well Diameter,

Eva.cuatioh":Rate'(g"al/min):

'DEVEUpPMENf/PURGIN<5

Date/ilme:

Color:

Odor

App»aranco:

Tempera! ur»(C/F): "

PH:

Turbidity(NTU):Spec. Cond.(unihos/c'm):DO(mfl/L):ORP(mV):Remoysd(gallons):

j

;

CALCULATIONS/NOTES:

. Gold^rAssociates Atlanta, Georgia

TITLE

WELL DEVELOPMENT LOG

CLIENT/PROJECTJES


KHSM

APRIL 2004

N/A

Appendix B l.cdr

943-3680

FIGURE NO.B-6

Operable Unit 3 Field Sampling PlanThe SAP, along with the Remedial Investigation and Feasibility...

Documents

Transcript of Operable Unit 3 Field Sampling PlanThe SAP, along with the Remedial Investigation and Feasibility...