-
APPENDICESWORK AND QUALITY ASSURANCE PLAN
FOR THEHOSIER ROAD REMEDIAL INVESTIGATION
AND FEASIBILITY STUDY
Prepared for:
The City of Suffolk441 Market Street
Suffolk, Virginia 23434
Prepared by:
SCS Engineers11260 Roger Bacon DriveReston, Virginia 22090
(703) 471-6150
January 3, 1991File No. 289099-04
AR3Q0222
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CONTENTS
Appendix Title
A Physical/Chemical Properties and Degradation of
PesticidesDisposed at the Hosier Road Landfill
B 1. Summary of the Scoping Session2. VDWM's October 24, 1990
Letter and The City of Suffolk's
Response of January 11, 1991
C SCS Engineers Resumes
D General Physics Organization Chart and Resumes
E Field Instrument Operation Manuals for Calibration
F GP Environmental Services, Inc. (formerly JTC
EnvironmentalConsultants, Inc.) Laboratory Quality
Assurance/QualityControl Manual
SR300223
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APPENDIX A
PHYSICAL/CHEMICAL PROPERTIES ANDDEGRADATION OF PESTICIDES
DISPOSED AT THE
HOSIER ROAD LANDFILL
t
SR30Q22U
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PHYSICAL/CHEMICAL PROPERTIES AND DEGRADATION OF
PESTICIDESDISPOSED AT THE HOSIER ROAD LANDFILL
Pesticides reportedly disposed at the site include Dlsyston
(Disulfoton), Cu7'Sulfur (Copper + Sevin + Sulfur), 7 Sulfur (Sevin
+ Sulfur), Thimet, andCyanox. Reportedly, Disulfoton made .up the
bulk of the material disposed. Abrief discussion of the chemical
properties of these pesticides follows.
DISULFOTON
Svnonvms and Trade Names
Synonyms and trade names include Disyston, ethylthiodemeton,
thiodemeton, M-74,Frumin AL [FCH, 1989], dithiodemeton, Bay 19639,
ENT 23347, Dithiosystox,Frumin G, Solvirex [Windholz, 1983],
Solvigran [USDA, 1990].
Chemical Composition . . . . . . _ , .,.., .... .
Disulfoton is a member of the organophosphorus family, with a
chemical formulaof CH 0 PS,. The molecule
3 19 2 3
The chemical structure is:
of C8H1902PS3. The molecular weight is 274.38, and the CAS
number is 298-04-4.
P-S-CHj-CH,-S-C3HsC3H50X
Physical State
The technical grade is a colorless liquid at room temperature.
Commercialformulations include a dry seed dressing (Frumin AL),
emulslfiable concentrate,granules (15% and 1.5%) [FCH, 1989],
pelleted and tableted formulations, andready to use liquids [USEPA,
1984a]. The Merck Index reports Disulfoton as acolorless oil
[Windholz, 1983], It is also reported as a pale yellow
liquid[Verschueren, 1983 and USEPA, 1984a].
Chemical Properties
The following chemical properties apply to technical grade
Disulfoton:Property _ Value Reference
Density: 1.144 FCH, 1989Water Solubility: 25 mg/1 Verschueren,
1983
1
fiR300225
-
Insoluble Windholz, 198325 mg/1 @ 20°C WERL, 199012 mg/1 @ 20°C
" - USDA, 199060 mg/1 - USEPA, 19845
Melting Point: Below -25°C RSC, 1989Boiling Point: 62°C (? 0.01
mm Hg FCH, 1989Vapor Pressure: -7.2x10"* mm Hg @ 20°C FCH, 1989
1.8x10"* mm Hg @ 20°C Windholz, 19831.8x10 mm Hg (? 20°C
Verschueren, 19833.00x10"* mm Hg0 20 - 25°C USEPA, 1984b
7.2 mPa 0 20°C USDA, 1990Vapor Density: ——— ———Flash Point: >
200°F FCH, 1989
> 180°F " USEPA, 1984bLog Octanol/Water Partition
Coefficient 3.94 WERL, 19903.95 @ 20°C USDA, 19904.02 @ 0GC
USDA, 1990
-Log Soil/Water PartitionCoefficient 3.25 (sandy loam) Sims et
al., 1988
Soil/Water PartitionCoefficient 770 (sandy loam) USDA, 1990
578 (loam) USDA, 1990664 (sand) USDA, 1990
Henry's Law Constant 0.22 Pa nr/mol USDA, 19900.16 Pa nr/mol
USDA, 1990
Field dissipation half-life -40 days USDA, 199028 days USDA,
199090 days USDA, 199060 days USDA, 1990
Half-life (biodegradation) 19 days (sandy loam) Sims et al.,
1988Soil half-life (aerobic) 2.4 days (sandy loam) USDA,
1990Half-life (hydrolysis @ 70°C) 7.2 hours SRC, 1978Hydrolysis
rate constant 0.0021/day @ 20°C
and pH 7 USDA, 1990Photolysis rate constant 0.063/day (soil)
USDA, 1990
0.693/day (water) USDA, 1990
Figure 1 presents a graph of the first-order degradation of
disulfoton byphotolysis.
Disulfoton is a systemic insecticide-acaricide. Uses include
side dressing,broadcast, and foliar spray in the seed furrow to
control many species ofinsects and mites. It is also used as a seed
treatment for sucking insects.Disulfoton is currently marketed in
the United States [FCH, 1989].
SR300226
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o4->O_cQ.
co
Crt•îO
cro
s-O)C1Q
flR300227
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Specific applications include grain crops, nut crops, cole
crops, root crops,pome, strawberry and pineapple fruits, forage,
field and vegetable crops,sugarcane, seed crops, forest plantings,
ornamentals, and potted plants(including houseplants) . Both ground
and aerial application are performed[USEPA, 1984a].
Disulfoton was originally registered in 1958. The EPA document
Suspended,Cancelled, and Restricted Pesticides lists approximately
80 suspended,cancelled, or restricted pesticides. Oisulfoton is not
on the list.
Persistence and .Degradation ._, .. .. . . . . . . . .
Disulfoton (Disyston) biodegrades under aerobic conditions
[Verschueren, 1983]When used as an insecticide, control may persist
for 6 to 8 weeks [FCH, 1989].It is stable under normal storage
conditions, but it subject to hydrolysisunder alkaline conditions
[FCH, 1989].
Disulfoton is absorbed by plants. The major plant metabolite
appears to bedisulfoton sulfone [USEPA, 1984a]. Other metabolites
include disulfoton,sulfoxide, disulfoton 0-analog, disulfoton
0-analog sulfoxide, disulfoton0-analog sulfone, diethyl phosphate,
diethyl phosphorothioate, and phosphoricacid [USEPA, 1984c].
Alkaline hydrolysis of disulfoton proceeds by the following
reaction:
s CB" s 'i or I_0 *Cc2i5o)2?sc2a4sc235 —— * — cc2BjO)2Po«
The products formed are diethylphosphorothioic acid and ethyl
thioethylmercaptan. Diethyl phsophorothioic acid is relatively
non-toxic. Sinceethanedlthiol , the parent compound of ethyl
thioethyl mercaptan, is much lesstoxic than disulfoton, it is
assumed that ethyl thioethyl mercaptan also is lesstoxic (SRC,
1978).
Complete hydrolysis of disulfoton requires an equimolar ratio of
the pesticideand hydroxide. Since thiols are weak acids, it is
recommended that excess basebe added to insure completion of the
hydrolysis reaction. Since disulfoton isrelatively insoluble in
water, the best decontamination solution would be a1 N sodium
hydroxide, 50% ethanol solution (SRC, 1978).
Hydrolysis of disulfoton is pH and temperature dependent. Table
1 belowprovides kinetic data on the hydrolysis reaction in water.
The data indicatethat the hydrolysis reaction proceeds more quickly
as the pH and temperature ofthe water increase.
flR300228
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Table 1 .Kinetic Data for Hydrolysis" of Disulfoton
(SRC,1978)
T«p«r*tur«. *C j)gjr k(10 hour" ) _H«lf -llf •
70 oHCl 2. SB 24 hour*
1 1.11 62 hours
2 1.11 ' 62 houri
3 1.10 62 houri
4 1.11 62 heuri
5 1.16 60 hours
6 1.56 44, hour*
7 2. SO 27.6 hours
8 3.22 21.5 hours
9 9.61 7.2 hours
0 1-5 1.2xlO~* 232000
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THIMET
Synonyms and Trade Names ._. . . . , , .
Synonyms and trade names include Phorate, Timet AAstar, AC 8911,
Rampart, andThimenox [FCH, 1989], American Cyanimid 3911, El 39"11,
ENTT24042 [Windholz,1983]. •
Chemical Composition _.,
Thimet is a member of the organophosphate family, with a
chemical formula ofC,H 0 PS . The molecular v7 17 2 3
The chemical structure is:C?Hi7°2PS3* The molecular weight is
260.40, and the CAS number is 298-02-2.
C2H5OS
Physical StateThe technical grade is a clear liquid at room
temperature [FCH, 1989 andWindholz, 1983], with a skunk-like odor
[USEPA, 1985b], Commercialformulations include an emulsifiable
concentrate and granules (10%, 15% and20%) [FCH, 1989].
Chemical Properties
The following chemical properties apply to technical grade
Thimet:
Property Value Reference
Density: 1.156 Windholz, 1983Water Solubility: 0.5 ppm 0 21°C
FCH, 1989
17.9 ppm 0 20°C USDA, 199022 ppm 0 25°C USDA, 199050 ppm 0 25°C
FCH, 198950 ppm @ 25°C Windholz, 198385 mg/1 0 20°C Nye, 1985
Melting Point: Below -15°C(technical >90%) RSC, 1989
-42.9oC USDA, 1990Boiling Point: 118-120°C @ 0.8 mm Hg USEPA,
1985bVapor Pressure: 8.4x10 mm Hg 0 20°C Windholz, 1983
84.7 mPa 0 25T USDA, 1990158 mPa 0 35°C USDA, 1990270 mPa 0 45°C
USDA,1990
Flash Point: 160°C' USEPA, 1985b
flR300230
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Vapor Density: ——— ———Henry's Law Constant 1,8 Pa m3/mol p°C
USDA, 1990Soil/Water Partition Coeff: ".3,200 . . FCH, 1989Log
Octaoo.l/Water Partition _ . . . . . .
Coefficient " ". """ 2.92 WERL, 19903.92 0 25°C USDA, 19904.26 0
0°C USDA, 1990
. 3.33 0' 0°C USDA, 1990Log Soil/Water Partition
Coefficient ""* 2.54 (sandy loam) Sims et al., 1988
Soil/Water PartitionCoefficient 310 (sand 0 25°C) USDA, 1990
627(sandy loam 25°C) USDA, 1990322(silt loam @ 25°C) USDA,
1990545 (loam 0 25°C) USDA, 1990
Field dissipation half-life 2 days (Georgia soil) USDA, 19905
days (Nebr. soil) USDA, 199012 days (Iowa soil) USDA, 1990
Half-life (bibdegradation) 32 days (sandy loam) Sims et al.,
1988Soil half-life (aerobic) 3 days (sandy loam) USDA,
1990Half-life (hydrolysis 0 70°C) 2 hours SRC, 1978Hydrolysis rate
constant 0.2170/day 25°C pH 5 USDA, 1990Photolysis rate constant
0.3758/day(soil 25°C) USDA, 1990
0.229/day(water 25°C) USDA, 1990
Figure 2 presents a graph of the first-order degradation of
phorate byphotolysis.
Use . . . . . . .......,.._ - --•
Thimet is the sixth most commonly used 'insecticide in American
agriculture[Kearney, et.al, 1985]. It is a soil and systemic
insecticide-nematicide.Applications include non-domestic
terrestrial and aquatic food/feed crops andgreenhouse commercial
nursery stock (both indoor and greenhouse). It is ,usedfor a wide
range of insects on a variety of crops, including alfalfa,
barley,rice (in India), beans, bermudagrass, corn, cotton, lettuce,
peanuts, potatoes,rice, sorghum, sugar beets, soybeans, sugarcane,
tomatoes, and wheat. It isalso used in combination with fertilizers
and fungicides [FCH, 1989 and USEPA,1985b].. Thimet is currently
marketed in the United States [FCH, 1989].
Phorate was originally registered in 1959 [USEPA, 19855], The
EPA documentSuspended, Cancelled, and Restricted Pesticides lists
80 pesticides that havebeen either suspended, cancelled, or
restricted because of their toxicity.Phorate is not on the
list.-
AR30023I
-
pJZa.
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Persistence and Degradation
Thimet is-considered stable under neutral and acidic conditions,
and is subjectto hydrolysis, under alkal in.e..conditions, /It is
considered non-persistent(half-life of 30 days or less). The
shelf-life of Vegru Foratox, a thimetproduct of M/S Pesticides
India^, is 2 years; for technical grade Thimet, it isat least 2
years at room temperature [FCH, 1989].
Thimet is stable.at room temperature, but is hydrolyzed in the
presence ofwater and alkali [Windholz, 1983].
The soil/water partition coefficient of 3,200 indicates that it
has a highpreference for soil adsorption over water solubility.
Phorate is metabolized in plants by rapid oxidation to the
sulfoxide (someoxidation to the 0-analog may also occur), followed
more slowly by oxidation tothe s.ulfone and/or the 0-analog
sulfoxide; phorate sulfone and phorate 0-analogsulfoxide are'then
further oxidized to the 0-analog sulfone. 'Available
studiesindicate that hydrolysis of the oxidized metabolites
eventually occurs to yieldnon-toxic water-soluble products. A field
study of corn treated at 1 Ib.active ingredient/acre with 10%
granular formulation indicate that phorateresidues were
non-detectable (
-
The half-life of hydrolysis is pH- and temperature-dependent.
Table 2 belowshows the temperature dependence of hydrolysis at pH
1-5. The data indicatethat the reaction proceeds more quickly as
the temperature increases.
Table 2.Kinetic Data on Hydrolysis of Phoratea(SRC, 1978).
. 'C k fhouf'xIO Balf-llf«
0 0.014 200
10 0,08 36
20 0.4 72
30 1.83 1-6
40 7.14 0.4
* pi 1-3 in wiccr.
Most organophosphorus pesticides used currently are
biodegradable and disappearrapidly from the soil[Kearney, et.al.,
1985].
CYANOX
Svnonvms and Trade Names __.
Synonyms and trade names include Cyanophos, CYAP [FCH, 1989],
Ciafos, Bay34727, S 4084, Sumitomo S 4084 [Windholz, 1983].
Chemical Composition _ ' - - —
Cyanox is an organophosphorus compound, with a chemical formula
of C H NO PS.The molecular weight is 243.21, and the CAS number is
263-62-62.
The chemical structure is:
Physical State
The technical grade is a clear, amber liquid at room
temperature. Commercialformulations include 3% dust, 50%
emulsifiable concentrate, and 1% oil-basedliquid spray [FCH, 1989].
The Merck Index [Windholz, 1983] reports a it as ayellow to
reddish-yellow transparent liquid.
10
flR30023t*
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Chemical Properties ._._. . ......-„-,...... ,-- -.. - .
The following chemical properties apply to technical grade
Cyanox:
Property _ „._ ,___^..._. ._ ...... . Value Reference
Density: • _! 1.255 - 1.265 RSC, 1989Water Solubility: • slight
Windholz, 1983
46 mg/1 RSC, 1989Melting Point: 14 - 15°C FCH, 1989Boiling
Point: decomposes f?
119 - 120°C RSC, 1989Vapor Pressure: 105 mPa 0 20°C RSC,
1989
Use . . .: ,.,._..__.....,. ...-....,--^ - —- —— - - - - - -
--.-. - • -
Cyanox is used as^an insecticide for fruits and vegetables. When
used on aregular schedule, it controls lepidopterous larvae on
apples. It is also usedas a grain protectent [FCH, 1989]. The EPA
document Suspended, Cancelled, andRestricted Pesticides lists 80
pesticides that have been suspended, cancelled,or restricted in
their use because of their toxicity. Cyanophos is not on
thelist.
Persistence and Degradation . . . _ . . , .,
Cyanox is rapidly decomposed under alkaline conditions or upon
exposure tolight. It decomposes above 120°C. [Windholz, 1983].
Hydrolysis of cyanox proceeds through the following
reaction:Crt,C\ 4$ +
The products of the reaction are dimethyl phosphorothioic acid
andp-cyanophenol . Since diethyl phosphorothioic acid is relatively
non-toxic, itis assumed that dimethyl phosphorothioic acid also is
non-toxic. Data on thetoxicity of p-cyanophenol could not be
located.
As with disulfoton and phorate, hydrolysis will proceed most
rapidly underalkaline conditions. Most likely, the reaction needs
to be carried out in anaqueous solution containing ethanol since
cyanox is only slightly soluble inwater. An excess of hydroxide
should be present to insure completion of thehydrolysis.
Hydrolysis of cyanox should be pH- and temperature-dependent,
although datacould not be found to verify this assertion. Cyanox is
a member of the same
11
flR300235
-
category of pesticides as disulfoton and phorate—the
phosphorodithioates.Since the rate of hydolysis increases with pH
and temperature for disulfotonand phorate, it probably will do the
same for cyanox.
Most organophosphorus pesticides used.currently are
biodegradable and disappearrapidly from the soil [Kearney, et al.,
1985].
SEVIN
Svnonvms and Trade Names ' _; ._ . .. -
Synonyms and trade names include Carbaryl, Bug Master,
Cekubaryl, Crunch,Denapon, Devicarb, Dicarbam, Hexavin, Karbaspray,
Septene, Tercyl, Tricarnam[FCH, 1989], Carbatox-60, Crag Sevin, ENT
23969, Karbaryl (Polish),experimental insecticide 7744 [Sax, 1984],
OMS-29, Ravyon, Seffein [Windholz,1983], Arylam, Patrin, Murvin,
and Carylderm [USDA, 1990].
Chemical Composition
Sevin belongs to the carbamate family. The chemical formula is C
H NO ,resulting in a molecular weight of 201.24. The CAS number is
63-25-7. Thechemical structure is:
Physical State
The natural physical state of technical grade (99%) Sevin is
solid whitecrystals. It is essentially odorless. Commercial
formulations include aqueousdispersions, dusts and powders, baits,
emulsifiable concentrations, granules,and suspensions in oil [FCH,
1989 and'USEPA, 1985a]. Both ground and aerialmethods of
application are practiced [USEPA, 198Sa].
Chemical Properties - - - - - - -The following chemical
properties apply to technical grade Sevin:
Property Value Reference
Density: 1.232 FCH, 1989Water Solubility: 40 ppm @ 30°C FCH,
1989
120 ppm 0 30°C • Windholz, 198399 mg/1 @ 20°C Nye, 1985100 ppm @
20°C USDA, 199083 ppm @ 25°C USDA, 1990590 ppm @ 25°C USDA,
1990
Melting Point: 142°C FCH, 1989
12
flR300236
-
Boiling Point: —-—. ———Vapor Pressure:
-
C/Jff—t/)
'oo0.
(OCJ
•*-*fO•o03s-o>4)
LUa:cfl
(sAop) 3[AH NOIlVQVd03a
" flR300238
-
The EPA document Suspended, Cancelled, and Restricted Pesticides
lists 80pesticides that have been suspended, cancelled, or
restricted in their usebecause of the.ir toxicity. Sevin is not on
the list.
Persistence .a'nd.J]£jjrada..tion , ; . „_,.". ..,-, ̂ , .....
.
Carbaryl is considered moderately persistent, with a half life
in the range of30 to 99 days. It hydrolyzes rapidly under alkaline
conditions [FCH, 1989].It is stable to heat, light, and acids, but
is hydrolyzed in alkalis [Windholz,1983]. _ . - - - - - -
Carbaryl is slowly taken up into plants, after which it is
metabolized. Thedisappearance of carbaryl residue from plant
surfaces is attributed tomechanical attribution, volatilization and
uptake into the plant.Photochemical degradation does not appear to
be a factor. 1-Naphthol is themajor metabolite [USEPA, 19.85a].
Carbaryl is degraded by fungi. The soil fungi attack carbaryl by
hydroxylationof the side chain and ring structure. Carbaryl is
metabolized by pure andmixed cultures of bacteria; fungi, and to
some extent by other soil and waterorganisms. The half-life appears
to range from 7 to 28 days in aerobic andanaerobic soils,
respectively [USEPA, 1985a].
Animals also degrade carbaryl. The chemica.1 is metabolized by
hydrolysis andhydroxylation. The most prevalent products are
1-naphthyl glucuronide,1-naphthyl sulfate, and 4-hydroxycarbaryl
glucuronide (USEPA, 1980).
Alkaline hydrolysis of carbaryl proceeds through the following
reaction (TRWSystems, 1975):
The products of the hydrolysis reaction are 1-naphthol,'methyl
amine,. andsodium carbonate. 1-Naphthol is unstable and degrades
further to carbondioxide and other .products. The main product is a
precipitate that is toxic tocertain estuarine species (TRW Systems,
1975).
15
AR300239
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Hydrolysis of carbaryl is pH- and temperature-dependent. Table 3
belowillustrates this dependence. As with the other organophosphate
pesticides, threaction proceeds more rapidly as the temperature and
pH of the solutionincrease.
Table 3.Kinetic Data on Hydrolysis of Carbaryl (TRW Systems,
1975).
Ŵ ^̂ MĤ MM
PH
8.08.03.0
10.55410.95410.95410.954
1010109.89.59.29.0
• ' —
Temperaturefc)
^̂ ^̂ ^̂••••̂••fcMÎM
172028
3132333
12253525252525
»«^^BB^___M__
Ha If- 11 Co
115.2 hr84 hr24 hr
32 min11 min3.8 mfn1.4 min
99 min20 min8 mfn
27 rain58 min1)6 nin173 tain
Btmolecular Activationrate constant energyl/fmole.-uln)
(caynote) Reference
100U° 2̂ .090 Karinen et al48460
24.269.1204 16,900 Aly and El-0(b49537
70340900430 19.390 Wauchope and Hague50300380400
The following hydrolysis and direct photolyis half-lives are
reported [Ver-schueren, 1983]:
Hydrolysis Direct Photolysishalf-life half-life
SM — --- fdavs) _ fdavs)_____5 1,500 ' 6.67 15 6.69 0.15 — -,
-
The half-life by bacterial biolysis is reported as greater than
30,000 days,assuming a bacterial population of 0.1 mg/1
[Verschueren, 1983].
Field studies determined that approximately 90% of the applied
Sevin disappears(by a variety of mechanisms) from surface soils
within a period ofapproximately 10 to 15 days [Kearney, et al.,
1985].
16
AR3002W
-
Persistence in river water in a sealed glass jar, under sunlight
and artificialflourescent light is reported as follows
[Verschueren, 1983], for an initialconcentration of 10 ug/1:
Percent of Initial Compound Detected
after: I hour . . ...Lw.eek .,... t weeks 4 weeks 8 weeks
90 5. 0 0 0
Sevin does not bioaccumulate in mammalian tissue [Sax,
1984].
17
flR3002m
-
REFERENCES FOR PESTICIDE INFORMATION
ACGIH, 1989: American Conference of Governmental
IndustrialHygienists, Threshold Limit Values and BiologicalExposure
Indices for 1989-90, ACGIH, Cincinnati, 1989.
Dlllon, 1981: Dillon, A.P., Editor, Pesticide Disposal
andDetoxification Processes and Techniques, Noyes DataCorporation,
Park Ridge, NO, 1981.
FCH, 1989: Farm Chemicals Handbook, 75th Edition,
MeisterPublishing Company, Willoughby, Ohio, 1989
Kearney, et al., 1985 Kearney, Philip C., Ralph G. Nash, and
Charles S.Helling, Pesticide Degradation Properties, presented
atthe National Workshop on Pesticide Waste Disposal,Denver,
Colorado, January, 1985.
NFPA, 1978: 'National Fire Protection Association, Fire
ProtectionGuide on Hazardous Materials, Seventh Edition,
NFPA,Boston, 1978.
NIOSH, 1985: U.S. Department of Health and Human Services,
NIOSHPocket Guide to Chemical Hazards, U.S. GovernmentPrinting
Office, 1985.
Nye, 1985: Nye, John C.., Physical Treatment Options: Removal
ofChemical from Wastewater by Adsorption, Filtrationand/or
Coagulation, presented at the National Workshopon Pesticide Waste
Disposal, Denver, Colorado, January,1985
RSC, 1989: _.__. Royal Society of Chemistry, The Agrochemicals
Handbook,Second Edition, Cambridge, England, 1989.
Sax, 1984: Sax, N. Irving, Dangerous Properties of
IndustrialMaterials, Sixth Edition, Van Nostrand Reinhold
Company,New York, 1984.
Sims et al., 1988: Sims, R.C., W.J. Doucette, J.E. McLean, W.J.
Grenney,and R.R. Dupont, Treatment Potential for 56 EPA
ListedHazardous Chemicals, for the Robert S. KerrEnvironmental
Research Laboratory, Ada, Oklahoma, 1988.
18
AR3002«f2
-
SRC, 1978: Syracuse Research Corporation, Center for
ChemicalHazard Assessment, Identification and Description
ofChemical Deactivation/Detoxification Methods for theSafe Disposal
of Selected Pesticides, for the U.S.Environmental Protection
Agency, Office of Solid Waste,Syracuse, NY, 1978. •
TRW Systems, 1975: TRW Systems, Inc., Handbook of Pesticide
Disposal byCommon Chemical Methods, For the U.S.
EnvironmentalProtection Agency, Office of Solid Waste
ManagementPrograms, Washington, D.C., 1975.
USDA, 1990: U.S. Department of Agriculture, Agricultural
ResearchInstitute, Pesticide Properties Database, Beltsville,MD,
1990.
USEPA, 1980: U.S. Environmental Protection Agency, Carbaryl:
DecisionDocument, Office of Pesticide Programs, Washington,D.C.,
1980.;
USEPA, 1984a: U,.S... Environmental Protection Agency, Fact
Sheet Number43: Disulfoton, issued December 31, 1984. in
PesticideFact Handbook (a compendium of U.S EPA issued
pesticide
:._. fact sheets), Noyes Data Corporation, Park Ridge,
NewJersey, 1988.
USEPA, 1984b: U.S. Environmental Protection Agency, Review of
In-placeTreatment Techniques for Surface Soils, Cincinnati,
OH,1984.
USEPA, 1984c: U.S. Environmental Protection Agency, Guidance
forReregistration of Pesticide Products ContainingDisulfoton as the
Active Ingredient, Office ofPesticides and Toxic Substances,
Washington, D.C., 1984.
USEPA, 1984d: U.S. Environmental Protection Agency, Guidance
forReregistration of Pesticide Products Containing Carbarylas the
Active Ingredient, Office of Pesticides and ToxicSubstances,
Washington, D.C., 1984.
USEPA, 1985a: U.S. Environmental Protection Agency, Fact Sheet
Number21: Carbaryl, revised September 5, 1985. in PesticideFact
Handbook (a compendium of U.S EPA issued pesticidefact sheets),
Noyes Data Corporation, Park Ridge, NewJersey, 1988
19
-
USEPA, 1985b: U.S. Environmental Protection Agency, Fact
"Sheet34.1: Phorate (Thimet), issued February 1, 1985. inPesticide
Fact Handbook (a compendium of U.S EPA issuedpesticide fact
sheets), Noyes Data Corporation, ParkRidge, New Jersey, 1988
USEPA, 1986: U.S. Environmental Protection Agency, Superfund
PublicHealth Evaluation Manual, Office of Emergency andRemedial
Response, Washington, D.C., 1986.
USEPA, 1988: U.S. Environmental Protection Agency, Guidance
forReregistration of Pesticide Products Containing Phorateas the
Active Ingredient, Office of Pesticides and ToxicSubstances,
Washington, D.C., 1988.
USEPA, 1990: U.S. Environmental Protection Agency,
Suspended,Cancelled, and Restricted Pesticides, Office ofPesticides
and Toxic Substances, Washington, D.C., 1990.
Verschueren, 1983: , Verschueren, Karel, Handbook of
Environmental Data onOrganic Chemicals, Second Edition, Van
Nostrand ReinholdCompany, New York, 1983.
WERL, 1990: Water Engineering Research Laboratory
(WERL),Treatability Database, Revision 2, USEPA, Cincinnati,Ohio,
11/6/90
Windholz, 1983: Windholz, Martha, Editor, The Merck Index,
TenthEdition, Merck & Co., Inc., Rahway, NJ, 1983.
20
AR3Q02UI*
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APPENDIX B
1. SUMMARY OF THE SCOPING SESSION
2. VDWH'S OCTOBER 24, 1990 LETTER AND THE CITY OF SUFFOLK'S
RESPONSE OFJANUARY 11, 1991
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COMMONWEALTH of VIRQINIADEPARTMENT OF WASTE MANAGEMENT
11th Floor, Monroe Building101 N. 14th Street
Richmond, VA 23219(804) 225-2667
November 22, 19S9
Mr. John L. Rows, Jr.City ManagerCity of SuffolkP.O. BOX
1S5SSuffolk, VA 23434
Re: Suffolk City Landfill-SiteSummary of Discussions
DuringScoping Session
Dear Mr. Rowe:
Attached, please find a summary of the discussions during
theScoping Session held on November 20, 1989, at our office
inRichmond, VA. This summary of discussions should
provideadditional guidance in the development of the RI/FS Work
Plan. Ifyou have any questions or comments, please call me at (304)
225-3263.
Sincerely,
A.M. TopiProject Coordinator
cc: K.C DasAndrew Palestini, EPAPhillip Koren, Esq.Jonathan
Horli
Anaderson, Esq.
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Summary of Discussions During the RI/FS Scoping Session
Suffolk City Landfill
November 20, 1939
Introduction
The project coordinator for the Department of Waste
Management(DWM) gave a brief introduction and stated the ' purpose
of themeeting. , - .. ..
There was an overview of site area by John Rowe (City of
Suffolk)and a statement of their committment to ensuring the
protection ofhuman health and the environment.
In response to a question by SCS (contractor for the City
ofSuffolk) A.M... Tope, the DWM project coordinator, stated that
-hemajor issue at the site is the organophosphate pesticides.
There was discussion of flaws in earlier studies by the-City
ofSuffolk, .and their attorney - those mentioned were
demographicinformation and chemical analyses.
Several points were made by K.C. Das, Director of the
SuperfundProgram, DWM: 1) the initial study results are not
intended toanswer all questions - that is the purpose of the RI/FS,
2) costeffectiveness is only one consideration in remediation, and
3) anyremedial action should be geared towards permanence.
Details of. the RI/FS(Presented by Mike McLaughlin of .SCS, on
beh'alf of the City of•Suffolk) . - - - -
It was pointed out that background considerations will be
importantbecause of the major agricultural usage in the area and
theoresence of several other potential sources of contamination
nearthe landfill.
Geology of the area was briefly discussed. There is a
clayconfining layer beneath the site but it will be necessary
todetermine the exact depth and thickness of this layer at the
site.SCS proposes to do this with a boring in a background location
justto the west of the site. They expressed concern about
boring•through the clay layer in the landfill area itself.
Groundwater is to be investigated by installing 5 wells on-site
inaddition to the background. These wells will be located for
themost part on the periphery of the site and not within the
fillareas. At a later point in the presentation there was
somediscussion of the proposed plan to locate a well near the
allegeddisposal site of the pesticides. . Several people mentioned
that it
flR3002l{7
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would be very difficult to bore in this area and there may be
apotential to penetrate any liner present, therefore
potentiallyfacilitating migration.
Surface water will be tested by taking two rounds (wet .and
dryseasons) of S samples. Sediments will only be sampled in
oneround. Two samples are to be taken upgradient of the site and
therest in downgradient locations or on-site. Alyce Fritz of
NOAAexpressed concern that depositional areas may not be sampled
withthe suggested plan.
Other possible sources on-site are to be investigated by
soilsampling. These will be determined by interviews,
temporalconsiderations, and other information that comes to light
in thestudy.
Groundwater levels in monitoring wells will be measured monthly
todetermine groundwater flow direction. Stream flows will
beestimated to aid in determining a hydrologic budget for the
site.
A question was raised about why there were no deep wells
plannedin the study. SCS argued that it was unnecessary because
they feltthey could get some information from previous studies, and
in anycase the lower aquifers are artesian, therefore they are
unlikelyto be contaminated by the site.
Response to .RI/TS Plan bv DWM and Further Discussion
DWM felt that more soil sampling was needed to fully
characterizethe problem and strongly suggested that this be
incorporated intothe work plan. DWM suggested the use of test pits
or borings asmeans to do this. SCS responded that they believe this
would onlyresult in digging up garbage. It was agreed that some
focused soilsampling could be considered such -as the alleged
pesticide disposalarea and any cells at the landfill that were open
during the timewhen the dumping may have occured, or where there is
some suspicionthat pesticides may be buried.
EPA and DWM expressed concerns about proposed locations
ofmonitoring wells. EPA also suggested additional wells to
definesite-specific hydrogeologic conditions in the area.
DWM suggested additional on-site and off-site surface
watersampling including leachate, retention basin, retention pond,
andstreams.
SCS proposed a modification of full CLP protocol. They do not
wantto obtain printouts of all QA/QC data from the
contractedlaboratory due to the cost (although it would still be
availableupon request) , DWM and/or EPA would recieve the QA/QC
data for apercentage of samples for review, to be chosen in any
manner wewish. All sample results will still undergo validation by
thecontracted laboratory. DWM agreed to consider this request.
I
SR3Q02U8
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SCS stated that the analytical parameters to be tested include
allTarget Compound List/Target Analyte List parameters except
acidextractable organics. It also includes organophosphate
pesticidesby the appropriate SW-846 method. Cyanox will not be
measured bythis method, however it will be estimed by cyanide
measunnents.
SCS requested that they only take filtered samples for metals
'ingroundwater. DWM agreed to consider.
SCS did not propose to take any homewell samples, based on
recentconfirmatory sampling_ which showed no contamination. DWM
expressedsome reservations about this.
Miscellaneous Topics
DWM discussed specific activities to be conducted at the
SuffolkCity Landfill site during the RI/FS (Appendix C,. Guidance
forConducting RI/FS •under CERCLA, EPA/540/G-89/Q04, October
1988).They include project plans, community relations,
fieldinvestigations, sample analysis/validation, data evaluation,
riskassessment, treatability studies (if any), RI reporting,
remedialalternatives development and screening, detailed analysis
ofalternatives, and FS reporting.
DWM discussed the deliverables that will be a part of this
project.
In accordance with the AOC, the work plan is due by December
20,1989. SCS, on behalf of the City, requested extension of the
duedate of the work plan to January 10, 1990. DWM requested.a
writtenrequest from the City seeking such extension.
The time needed for the project was estimated to be 18 months
bySCS and the city of Suffolk.
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RECEIVED OCT 2 9 1930
COMMONWEALTH of VIRGINIADEPARTMENT OF WASTE MANAGEMENT
11th Floor, Monroe Building101 N. 14th Street
Richmond, VA23219(804)725-2667
October 24, 1990
Mr. John L. Rowe, Jr.City ManagerCity of SuffolkP. O. Box
1853Suffolk, Virginia 23434
Re: RI/FS Work PlanSuffolk City LandfillHosier Road Landfill NPL
Site . ,
Dear Mr. Rowe:
The Virginia Department of Waste Management (VDWM) hascompleted
its review of the following documents prepared for theCity of
Suffolk by SCS Engineering (SCS) and received by theDepartment May
4, 1990:
1. Work and Quality Assurance Plan for the RemedialInvestigation
and Feasibility Study at the Hosier RoadLandfill
2. Memorandum of Preliminary Remedial Action Objectives
andAlternatives
3. Quality Assurance Supplement for the Hosier Road
RemedialInvestigation and Feasibility Study
4. Health and Safety Plan for Field Activities,
RemedialInvestigation/Feasibility Study, Hosier Road
Landfill-,Suffolk, Virginia.
They will hereinafter be -referred to as the Work Plan.
As discussed at the September 25, 1990, meeting, many of
thecomments to follow stem from a mis-communication which resulted
inchanges being agreed to by letter without having the actual
wordingof the work plan changed to reflect the changes or to
clarify theissues.
Since this is the second review of the documents, and as it
flR300250
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John L. Rowe, Jr.Page 2
is in our mutual best interests to approve the work pi an
andinitiate implementation of the remedial investigation, it
isrequested that all responses (changes to the work plan)
bereferenced by page number and.be italicized or otherwise marked
toassist in the review of the document. If there are items in
ourcomments to which you have an objection, please telephone me
at(804) 225-3263 to discuss the matter prior to submitting
yourwritten response.
The Department's comments are listed below in the order
aspresented in the May 2, 1990, memorandum to Mark H. Woodward
fromMichael Me Laughlin of SCS:
WORK AND QUALITY -ASSURANCE PLAN:
GENERAL:
1. The" reorganization of the Work Plan/Quality Assurance
Planmakes it easier to locate the data quality objectives
andcriteria.
SITE DESCRIPTION AND BACKGROUND;
LOCATION, OWNERSHIP, HISTORY (pages 2-1 through 2-8)
2. -Removal of the reference to "normal conditions" issatis
factory.
3. Deletion of the paragraph comparing the land application
rateof the material if it were to be used as a pesticide versusthe
quantities disposed in the landfill is satisfactory.Since the
hazards associated with the use of a commercialchemical product
depend upon the use of proper managementprocedures, the associated
hazards vary by application andcannot be adequately compared to the
hazard potential ofexposure resulting from mismanagement of the
waste material.
4. Please include a statement (s) in the Work Plan that
statesthat the areas of the landfill where municipal waste
wasplaced using the trench and fill method will be
clearlydelineated on a map 6~f the site* Also, include
similarstatements for areas where filling and compaction occurred
inlifts above grade, being certain to include references
tosupplemental diagrams of the cross sections of both thetrenches
and the lifts.
5. Please "include specific wording in the Work Plan
describingthe efforts which have taken place to solicit
information
AR30025
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John L. Rowe, Jr.Page 3
regarding additional chemicals and/or pesticides which mayhave
been disposed in the landfill. Such statements shouldinclude the
contacts made to date, the information obtainedfrom each contact
even if it did not prove fruitful, and anyother sources of
information which can be identified at thistime as being a source
worthy of further pursuit.
6. Inclusion of a reference to Appendix D of the Health
andSafety Plan for technical data on the pesticides issatisfactory.
It is commendable to eliminate redundancywherever possible.
GEOLOGY AND HYRDOGEOLOGY: (pages 2-8 through 2-15)
7. The modification of Figure 2-3 to show the
approximatelocation of the Hosier Road Landfill is satisfactory.
Pleaseinclude a statement in the Work Plan stating that the
Sitehydrogeology will be shown in a cross sectional plan once
thedata has been collected during the -RI sampling phase.
8. Please include a statement in the Work Plan stating that
thelithologic and hydraulic properties of all sediments aboveth©
Yorktown confining unit will be characterized at the siteand that
diagrams will be developed to show the locations ofthese formations
with respect to the Landfill.
PREVIOUS INVESTIGATIONS: (pages 2-15 through 2-17)
9. Enclosed, please find a copy of the NUS*January 9, 1987,
fieldtrip report. This report states that the site was sampled
fordisulfoton,, cyanophos, phorotoxon, and phorate sulfoxide.Both
disulfoton and cyanophos were detected. Please refer tothis report
and revise this section accordingly.
10. See 9 above.
11. Wording as provided is acceptable.
12. Please include the analytical results from the split
samplesobtained by the City including any qualifying factors such
asexceeds holding times or insufficient recovery of the spikeetc.
Describe these results in the text of the Work Plan andcompare them
to their "splits" in a table.
13. Please include statements in the Work Plan that figures
willbe developed which show:
a. the topography of the Site (existing),
b. locations of all seeps,
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John L. Rowe, Jr.Page 4
c. surface hydrology showing both natural and constructed. =
drainage corridors,
d. a legend showing which streams are perennial and whichare
intermittent,
e. the location of the confluence of all streams and ditchesin
relation to the Pocosin Swamp,
f. the location of the perforated pipe which runs beneaththe
fill and collects/carries leachate from the westernportion of the
landfill to the retention basin,
g. the location and name of the stream positioned'approximately
3/4 of a mile south of the Site,
h. the locations of all drainage diversion ditches andsimilar
structures,
i. 'the locations of the to-be-installed leachate
collectionpiping, and
j. the location of the landfill cells including thepesticide
disposal area. These cells/trenches/liftsshould be distinguished by
type using different crosshatch or shading techniques.
14. Please include tables of all available data including the
NUSreports, and the two TAT team reports. Include the samplingdate
on each table. Where split samples were analyzed, pleaseindicate
the pairs.
15. The rainfall data as presented is acceptable,
PROJECT. DESCRIPTION;
OBJECTIVES: (pages 3-1 through 3-3)
16. The wording as provided is acceptable in reference to theU.
S. Fish and Wildlife Service participation in thedevelopment of the
Work Plan.
17. We were unable to locate the attachment containing the
summaryof the RI/FS scoping session discussion held 11/20/89.
Pleaseprovide a copy and a reference as to its location in the
nextrevision of the Work Plan.
SCOPE OF WORK: (pages 3-3 through 3-17)
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John L. Rowe, Jr.Page 5
18. The wording change from "feasibility" to
"implementability11is satisfactory.
Task 3:
19. Addition of the appropriate objectives to this section
issatis factory.
20. The Department is allowing slug tests to be performed on
themonitoring wells in lieu of pump tests as a concession to
thebudget constraints of Suffolk City. Please be advised thatit may
be found necessary to perform pump tests at a laterdate in order to
evaluate the feasibility of variousgroundwater remediation
techniques.
21. The wording describing the acquisition of
additionalgroundwater data is acceptable.
22. Please state in the Work Plan the sources to be searched
tolocate previous groundwater monitoring data in the area.Please
state that this data will be included in the RI andthat if the data
is deemed not to be valid or reliable it willstill be included via
appendix with the reasoning forinvalidating the data clearly
presented.
23. Adding a statement that home wells down gradient of the
sitewill be sampled immediately upon detecting pesticides
inmonitoring wells is satisfactory.
24. The Work Plan must identify the sources to be searched
toidentify the exact locations of the pesticide disposaltrenches
and the area(s) in the landfill where pesticides weredisposed. It
must also identify any other potential sourcesof hazardous
constituents. Such information could be obtainedby researching the
files and contacting entities which mayhave disposed of potentially
hazardous materials at the Site.
24a. In addition the Work Plan must state that six continuous
splitspoon soil boring samples will be obtained in the vicinity
ofthe pesticide disposal trenches. Two of these samples willbe
obtained within the central area of the trenches, and theother four
will be obtained from locations 5 to 15 feet fromeach side of the
assumed disposal site. Each soil boring willgo to a depth of 10
feet or until subsurface waters arecontacted, whichever is less.
The borings will be visuallyinspected and a sample will be obtained
from the area wherevisual contamination can be determined and at
three to fivefeet below this level. If visible contamination is
not
AR30025U
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John L. Rowe, Jr.Page 6 • . -
observed and another indication such as changes from disturbedto
undisturbed soils can be detected, samples shall ' beobtained just
above the interface and three to five feet belowthe interface. If
no interface is observed, samples shall beobtained at depths of six
and ten feet. The sampling shallbegin in the area of most likely
contamination and proceeduntil a sample showing visible signs of
contamination isobtained or until .all six soil borings have been
completed.If "trash" is encountered in the boring process, that
samplinglocation will be omitted.
All of these samples will be analyzed for
organophosphoruspesticides and for Cyanox as per methods already
discussed inthis letter.
The exact sampling locations and samples to be obtained willbe
determined at the site by the VDWM project coordinatorafter
consultation with the City's contractor. This changefrom the
tentative agreement made at the September 25thmeeting has been made
based upon information obtained from theTAT team officer(s) that
sampling in the area of the assumedpesticide disposal trenches did
not go below 3 feet in depth.This information was confirmed by
telephone discussion withMr. Jim Wilcox of Weston. The power auger
had a maximum depthcapacity of three feet at the time the sampling
took place.He did not know any thing about an extension being used
to
- sample to depths of five feet. A copy of the two TAT
teamreports are included for your reference.
Please revise the Work Plan to include all of the
activitiesaddressed in this item.
Task 5:
25. The wording as provided is acceptable.
26. The wording as provided is acceptable.
27. It is unclear as to why discussion of the water budget
wasdeleted from this section of the Work Plan rather thanmodified
to incorporate the comments of the April 4, 1990,notice of
deficiency. Please address this in your responsecover letter.
28. Updating the Work Plan to include references to the
mostcurrent revision of the appropriate guidance documents
issatisfactory.
29. Please add statements to the Work Plan indicating what
fieldoperations are to take place to identify receptors (such
field
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John L. Rowe, Jr.Page 7
operations might identify the locations where the benthicsurveys
are to take place, etc.) and what documents are to besearched and
contacts investigated to assist in identifyingall potential
receptors.
29a. Please add statements to the Work Plan requiring
physicalproperties of the habitats such as the depth and width of
allstreams/channels, the substrates, and the volume of flow.
30. Please identify the literature and other sources which
hasand/or will be searched to assist in identifying allpesticides
and other hazardous contaminants, organophosphateand otherwise, and
their physical properties, hazardpotential, treatability,
persistence and biodegradationproducts which may be present at the
site.
Task 6:
31. The update of the Work Plan to reflect the current NCP
issatisfactory.
32. Please change the last sentence on page 3-17 to eliminate
anyreference' to a recommendation of a remedial actionalternative.
This recommendation will come only after VDWMand EPA have reviewed
the data provided in the RI/FS andevaluated it using the criteria
in the NCP. In order toprevent bias in the decision making process
it is imperative.that a recommendation not be made during the RI/FS
process.
33. Inclusion of the no action alternative in the Work Plan
hasbeen satisfactorily done.
3 4, Please include a statement in the Work Plan that
noalternative treatment technologies or resource
recoverytechnologies appear germane to the Site at this time
andprovide a basis for this statement. Also state if
suchtechnologies later appear potentially applicable at the
Site,they will be addressed in the FS.
PROJECT SCHEDULE: (pages 3-18 through 3-21)
35. Please state in the Work Plan that all sampling data will
beprovided to the VDWM immediately following laboratory and SCSdata
validation or earlier upon request by the VDWM. Pleasealso specify
at what period of time relative to approval ofthe work plan that
this data will be provided to VDWM for eachround of sampling.
36. Please ravise the wording on page 3-19, Task 3 to reflect
thatthe months of May, June and September are also acceptable
• flR300256
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John L. Rowe, Jr.Page 8
• sampling months. Also note that the year must be changed
to1991. - - -
37. The summary of the project schedule is acceptable in the
formof a Gant Chart. Please be certain to make the
appropriatemodifications to this chart as indicated elsewhere in
thisletter.
38. Please change the first sentence of page 3-20 to state
thatthe final Remedial Investigation and Baseline Risk
AssessmentReports will be submitted to "VDWM within 30 days of
receiptof the latter of: 1) the written comments from VDWM on
thePreliminary Report, or 2) the written comments from
VDWMfollowing a meeting requested by the City of Suffolk todiscuss
the initial set of VDWM comments.
39. Two copies of each deliverable must be sent both to EPAto
VDWM when the submittal is made. Please state this in theWork
Plan.
40. The PRAOA has been received.
PROJECT ORGANIZATION AND RESPONSIBILITIES (pages 4-1 through
4-4_
41. The reference to the appropriate companies on Table 4-1
isacceptable.
42. The name of the person representing EEI on Figure 4-1
isacceptable as presented.
43. Inclusion of the areas of responsibilities for your
juniorstaff in this section is acceptable.
FIELD OPERATIONS (pages 6-1 through 6-12)
44. Please include statements in the Work Plan indicating that
allmonitoring wells shall be placed so as to avoid boring
throughtrash, and that the exact locations of the wells are
subjectto the on-site approval of the VDWM project coordinator.
44a, Please revise Figure 6-1 to reflect the modified
monitoringwell locations agreed to during the September 25,
1990,meeting.
44b. After discussion with the VDWM staff it has been decided
thatthe approximate locations of the surface water/sedimentsampling
sites shall be in the approximate locations of
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John L. Rowe, Jr.Page 9
(1 through 5) the current HRS-1, HRS-2, HRS-3, HRS-4, HRS-6
(6) and include a sampling point on unnamed stream S justprior
to the confluence with unnamed stream N,
(7) at the bottom of the drainage diversion ditch near
HRS-2at'the Retention Pond (the current figure 6-1 does not showthe
drainage diversion d^tch around the retention pond),
(8) after the filter at the discharge of the retention
Basin,
(9) from the drainage ditch south of the pesticide
disposaltrench,
(10) near the entrance to the Retention Basin,
(11 through 13) and at three leachate seeps whose locationsare
to be identified by the VDWM project coordinator on-site.
This results in a total of 13 surface water/sediment
samplingsites". The exact locations of all sampling sites shall
beapproved by the VDWM project coordinator at the time ofsampling.
Due to unforseen conditions the locations of thesampling sites may
change but the number of 'samples to beobtained will not change for
the Phase I sampling.
45. The Work Plan must state that all samples from the
monitoringwells will be tested both filtered and unfiltered
forinorganics. This data will be used in the risk assessment.
46. Please state the sampling and analytical methods to be
usedin determining if the drummed wastes generated during
wel1cutting and purging activities are hazardous wastes. Alsoplease
identify the alternate management and disposal methodswhich will be
used to comply with either the VirginiaHazardous Waste Management
Regulations (VHWMR) or the VirginiaSolid Waste Management
Regulations (VSWMR) as appropriate.
47. Please include a statement in the Work Plan that
asappropriate materials are encountered during the RI, sampleswill
be collected for Total Organic Carbon (TOC) analysis.
48. Please include statements in the Work Plan to the effect
thatall sediment samples will be obtained in calm areas where
themajority of the sediments would be expected to collect andthat
surface water samples will be taken so as to reflect thehighest
concentrations of contaminants.
49. The wording as provided in the last sentence of page 6-4
is
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John L. Rowe, Jr.Page 10
acceptable.'
50. Please include a statement in the Work Plan that
allmonitoring wells will be installed in accordance with
TEGD,Chapter 3. Where this is not to be done, please provide
adetailed explanation as to the reasoning behind and need foran
alternate design and installation.
51. Please see the Department's comments in items 24, 24a,
44,44a, and 44b above. We have noted your reluctance to
performadditional sampling in the vicinity of the assumed
pesticidedisposal area since the TAT team has already sampled
thislocation. However, the Department does not find that
theproposed sampling locations and number of sampling
locationsproposed will provide sufficient data to adequately
identifythe presence or -absence and likely source of
hazardousmaterials at the Site. Please be advised that based upon
theinformation currently available with respect to the site,
alesser number of samples would not be acceptable to
theDepartment.
52. Please modify the second paragraph of page 6-11 to
indicatethat sediment samples shall be taken to a depth of six
inchesunless otherwise approved by the VDWM project coordinator
on-site.
53. Please state in the Work Plan that all non-detects will
bereported as per Risk Assessment Guidance for Superfund and theEPA
Region III guidance. Where "other rules" are to be used,state the
values as per the guidance as well as the rationalebehind the use
of the "other rule". A statement to the effectof the preceding
sentence must be included in the Work Planor all reference to
"other rules" must be eliminated.
54. Please modify the Work Plan to include analyses for
hardnessand pH. The hardness value directly affects the impact
ofvarious inorganic constituents on aquatic life. TheDepartment has
agreed to waive the requirement for .totalsuspended solids testing
since the City chooses not to performthis test which could indicate
that the presence of heavymetals in the surface water samples are
associated withparticles, not solubilized and are less likely to
adverselyimpact aquatic life.
55. See item 24a of this letter. The pesticide disposal area
hasnot been adequately investigated. The information which
wasprovided by SCS that the soil samples in the vicinity of
theassumed pesticide disposal area were obtained at depths offive
to six feet is incorrect. The deepest samples wereobtained at three
feet below grade.
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John L. Rowe, Jr.Page 11
56. The pesticide Sevin (Carbaryl) has reportedly been
disposedat the Site. This is a carbamate pesticide and will
requirean additional analytical method (it is not measured
withMethod 8140).
56a. The. detection limits in Table 8-1 are not low enough
todetermine whether there are any adverse impacts to aquaticlife.
Please modify the Work Plan to use SW-846 Method # 8141as it has
lower Practical Quantitation Limits (PQL's) thanMethod £ 8140 for
the compounds in question.
56b. Also, as of this point in time, we have been unable
todetermine if either of these methods detect the
disulfotondegradation products, disulfoton sulfoxide and
disulfotonsulfone, as disulfoton. Please be certain that the
analyticalmethods used either include the degradation products with
thedisulfoton or detect and report them separately.
56c. Please modify the Work Plan to reference the analytical
methodnumber to be used and the EPA publication in which it
iscontained. Each constituent should be identified as well asthe
method number and PQL.
56d. Cyanox is not included in either Method # 8140 or # 8141.
Canits environmental concentrations be estimated by cyanidelevels?
If so, please provide documentation of the technicalbasis for such
a decision and a full discussion of theassociated uncertainties and
assumptions in the Work Plan.If not, please provide an analytical
method for detectingcyanox in the environment and its associated
PQL in the WorkPlan and include a copy of the method for
reference.
57. Please modify the Work Plan to identify seep locations.
Then,identify those seep locations which should be sampled
andprovide the rationale behind their selection. Please includea
table of the locations and a brief description of the sourcearea
for each seep in the Work Plan, state in the Work Planthat all seep
sampling will take place in the spring.
58. See item f 4 above.
59. Please state the diameter of the concrete apron to
beinstalled around each monitoring well in the Work Plan. Notethat
a minimum of three feet is acceptable.
60. Figure 6-1 is satisfactory.
61. Please include a statement in the Work Plan that bailer
cordswill not be allowed to contact the ground prior to
sampling
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O
John L. Rowe, Jr.Page 12 _..-
and that clean cords be used for each set of samples at
eachwell.
MEMORANDUM OF PRELIMINARY REMEDIAL ACTIONOBJECTIVES AND
ALTERNATIVES fPRAOAi
PRELIMINARY OBJECTIVES: (pages 2-1 through 2-2)
62. The requested change has been adequately addressed.
63. This section has been adequately relabeled.
64. Please cite all references used in identifying and
complyingwith ARARs and also identify which were used in
developingthis section.
65. Please include a statement that Federal and state
criteria,advisories, guidances, and local ordinances will be
consideredin developing the remedial action alternatives.
66. Page 2-2 is missing from the copy of the PRAOA submitted
tothe Department. Please be certain that item # 66 of the April4,
1990 letter is adequately addressed in the revised copy tobe
submitted. Based upon what is currently in this section,it does not
appear that the contaminants of concern or the.receptors have been
clearly identified, nor have theacceptable contaminant levels for
each exposure route beenaddressed.
POTENTIAL REMEDIAL ALTERNATIVES:
67. Reorganization of the PRAOA has been completed as
instructed.
68. Tables 3-1, 3-2 and 3-3 are referenced in your letter but
aremissing from the PRAOA. Please submit a complete revisedcopy. If
Tables 4-1 through 4-3 are the tables in question,then no column
indicating environmental media is present asrequested in the April
4, 1990 letter.
69. See item #68 above. Please include a statement in the
PRAOAindicating that the data requirements necessary to evaluatethe
various remedial action options will be obtained once theextent of
contamination becomes more apparent.
.70. No further comment.
71. Ingestion of surface soils has been included among
thepathways for exposure.
flR30026l
-
*̂wfcnis '' ". 11260 Roger Bacon Or --^-^- ^C3 J"--4'50Seston.VA
2209Q ._ =..".- 5M "Cj'̂ '-
SCS ENGINEERS
January 11, 1991File No. 289099-04
Mr. Khoa NguyenVirginia Department of Waste ManagementMonroe
Building, llth Floor101 North 14th StreetRichmond, VA 23219
Mr. Andrew PalestiniU.S. Environmental Protection AgencyRegion
III841 Chestnut BuildingPhiladelphia, PA 19107
Subject: Submission of the RI/FS Work Plan/Quality Assurance
Plan and RelatedDocuments, Hosier Road Landfill RI/FS
Gentlemen:
On behalf of the City of Suffolk, we are pleased to submit two
copies each ofthe Work and Quality Assurance Plan (with Appendices)
and the Memorandum ofPreliminary Remedial Action Objectives and
Alternatives (PRAOA). Theinformation in the Quality Assurance
Supplement (previously submitted) hasbeen incorporated in the Work
and Quality Assurance Plan, eliminating theSupplement document. All
comments on the Health and Safety Plan have beenpreviously
resolved, so that document is not enclosed.
The enclosed documents are the result of extensive discussions
between theCity, its advisors, the Department, and the Agency. The
approach described inthe Work and Quality Assurance Plan represents
a consensus between allinterested parties. Formal comments on the
earlier draft were provided byletter dated October 24, 1990 from
Ms. Wilcox of the Virginia Department ofWaste Management; other
comments were provided by a VDWM memorandum of June 1,1990 by Glenn
Metzler and a U.S. EPA memorandum of July 31 by AndrewPalestine
We understand that the October 24 letter by Ms. Wilcox
summarizes all thesignificant outstanding concerns at that time. To
assist you in your reviewof the changes made in the enclosed
documents, we provide below a response toeach of the 85 comments in
Ms. Wilcox's letter. Many of the 85 comments wereto the effect that
the Department agreed with previous changes made to theWork Plan,
thus indicating that the issue was resolved in the previous
draft.
The responses to the October 24 letter are:
1. Issue resolved in draft; document reflects this comment.
2. Issue resolved in draft; document reflects this comment.
-
Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991Page 2.
3. Concur. A comparison of the amount of pesticides disposed
comparedto that which would be applied in normal agricultural
practice isInstructive but more appropriate in an RI Report than in
a Work Plan.The discussion about the associated hazards thus
becomes moot.
4. Concur. Page 2-2, line 11.
5. Concur. Page 3-10, line 1.
6. Issue resolved in draft; document reflects this comment.
7. Concur. Page 2-22, line 11.
8. Concur. Page 2-25,. line 2.
9. Concur. Page 2-29, paragraph 3.
10. See 9 above.
11. Issue resolved in draft; document reflects this comment.
12. Concur. Page 2-36, line 1 and table 2-8.
13. Concur. Page 2-6, line 1.
14. Concur. Tables 2-3 through 2-7.
15. Issue resolved in draft; document reflects this comment.
16. Issue resolved 1n draft; document reflects this comment.
17. Concur. Appendix B.
18. Issue resolved in draft; document reflects this comment.
19. Issue resolved in draft; document reflects this comment.
20. Issue resolved in draft; document reflects this comment.
21. Issue resolved in draft; document reflects this comment.
22. Concur with modifications. The sources to be searched are
given onpage 3-10, last paragraph. As agreed in a telephone
conversationwith Ms. Wilcox on November 5, 1990, all data will be
summarized butonly the valid, reliable data will be given in
detail; criteria forvalidity and reliability will be given. Thus,
possibly large amountsof useless information need not be
copied.
23. Issue resolved in draft; document reflects this comment.
24. Concur. Page 2-10, line 1 and page 2-3, bullet 7.
flR300265
-
Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991Page 3.
24a The sampling plan proposed by VDWM on December 17 and
incorporated inthis Work Plan obviates the need for soil sampling
in the pesticidedisposal area.
25. Issue resolved in draft; document reflects this comment.
26. Issue resolved in draft; document reflects this comment.
27. Concur. We prefer to remain silent on the matter of a water
budgetin the Work Plan rather than to promise to perform an
activity whichmay be unnecessary or require a drastic increase in
effort to attaindata for a defensible budget. If the results of the
fieldinvestigation would be better interpreted by means of a water
budgetand if the necessary data (e.g., streamflow
values,evapotranspiration and infiltration rates) can be collected
to thedegree .required, a water budget may be calculated.
28. Issue resolved in draft; document reflects this comment.
29. Concur. Page 3-15, line 13 to page 3-17, paragraph 4.
29a Concur. Page 3-17, line 3.
30. Concur. Appendix A summarizes the physical/chemical
properties anddegradation of pesticides reportedly disposed at the
site.
31. Issue resolved in draft; document reflects this comment.
32. Concur with reservations. A recommendation of a remedial
actionalternative will not be submitted as part of the Feasibility
StudyReport. However, the City reserves its right to request a
separatereport from its contractor which will recommend a remedial
actionalternative based on the RI/FS investigation.
33. Issue resolved in draft; document reflects this comment.
34. Concur. Page 3-22, paragraph 2.
35. Concur with modifications. Page 3-27 and Project Schedule,
page3-23. The analytical data will not be submitted to VDWM until
it hasbeen validated. The validation will be done expeditiously as
shownby the schedule. Data will not be submitted before validation
inorder to prevent needless concern by the public.
36. This comment has been obviated by finding detailed
groundwater levelrecords for a monitoring well near the site (see
page 2-23 and Figure2-4). The project schedule reflects this direct
information ratherthan the indirect information from precipitation
alone.
37. Concur. Figures 3-2 and 3-3.
flR300266
-
Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991 • •Page 4. ,
-
38. The project schedule reflects a 45 day period for submission
of Rland FS Reports after receipt of VDWM's comments or a meeting
con-cerning those comments. This time period has been agreed upon
by allbecause of the need for the City Council to meet and approve
thefinal reports.
39. Concur. Page 3-27, paragraph 2 and page 3-30, last line.40.
The revised PRAOA also is included in this submission.
41. Issue resolved in draft; document reflects this comment.
42. Issue resolved in draft; document reflects this comment.
43. Issue resolved in draft; document reflects this comment.
44. Concur. Page 6-3, line 16.
44a. Concur with updating to reflect the latest monitoring
welllocations proposed by VDWM on December 17, 1990.
b.. Table 6-3 and Figure 6-1 show the surface water/sediment
samplingsites proposed by VDWM on December 17,1990.
45. Concur. Page 6-17, paragraph 2.46. Concur. Page 6-13,
paragraph 4,
47. Concur. Page 6-22, last paragraph and Table 6-5.48. Concur.
Page 6-22, paragraphs 3 and 4.
50. Concur. Page 6-5, last paragraph.51. Noted^ This comment_no
longer pertains because the sampling
locations agreed upon are those proposed by VDWM.
52. Concur. Page 6-22, last paragraph.
53. Concur. Page 3-14, first bullet.
54. Concur. Tables 6-2, 6-4, and 6-5.
55. See 24a above.56. Concur. The High Performance Liquid
Chromatography methods listed in
Tables 6-2 and 6-4 are more sensitive than the colorimetric
methodproposed earlier and thus are the ones selected.
56a Concur. Tables 6-2, 6-4, and 8-1.
AR3Q0267
-
Mr. Knot NguyenMr. Andrew Palestinl . .._ . .January 11,
1991Page 5.
56b Concur. A note in Table 8-1 indicates that the breakdown
products-will be detected and quantified separately. Standards for
thebreakdown products have been located.
c Concur. Tables 6-2, 6-4, and 8-1.
d Concur with modification. Cyanox can be analyzed by either
EPAmethod 8140 or 8141 if a standard 1s available. The General
PhysicsLaboratory has made arrangements to obtain such a standard
from USEPA Chemical Standards Repository in Research Triangle Park,
NorthCarolina. Method 8141 will be employed. This method is
described inTest Methods for Evaluating Solid Waste, Physical/
Chemical Methods -Third Edition Proposed Update Package, U.S. EPA
PB89-148076. 1989.The PQL's are currently not documented in the
record but will bedetermined by method detection limit studies as
part of the analysesand reported with them.
57. Concur with modifications because of the new sampling plan.'
Allseeps will be located (Page 2-6, bullet 2); source areas will
beidentified at that time. We intend to do this in the spring
byupdating the map of seep locations that is part of the
TemporaryLeachate Collection Plan. A copy of that Plan was
previously sent toVDWM. One seep is to be sampled (sample HRS-10E
in Table 6-5) andthis will be done in the spring.
58. See 4 above.
59. Concur. Page 6-10, line 8.
60. Issue resolved in draft; document reflects this comment.
61. Concur. Page 6-14, line 18.
62. Issue resolved in draft; document reflects this comment.63.
Issue resolved in draft; document reflects this comment.
64. Concur. Page 3-1 of the PRAOA, paragraph 2.
65. Concur. Page 4-1 of the PRAOA, line 4.66. Concur with
exception to the last sentence. Page 2-2 (Figure 2-1) Is
Included. A major purpose of the RI is to actually identify
thecontaminants of concern, the receptors, and the
acceptablecontaminant levels (by risk assessment where no standards
currentlyexist). This is stated on page 2-4 Of the PRAOA.
67. Issue resolved in draft; document reflects this comment.68.
Concur. Tables 4-1 through 4-3 are the tables in question.
Environmental media are now explicit in column 1 of Table 4-1;
theyare Implicit in the titles of Tables 4-2 and 4-3.
SR300268
-
Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991Page 6.
69. Concur. .Page 4-7, line 16.
70. Issue resolved in draft; document reflects this comment.'
•
71. Issue resolved in draft; document reflects this comment.
72. Issue resolved in draft; document reflects this comment.
73. Issue resolved in draft; document reflects this comment.
74. Issue resolved in draft; document reflects this comment.
75. Issue resolved in draft; document reflects this comment.
76. Concur. Page 3-13, paragraph 2 ff.
77. Issue resolved in draft; document reflects this comment.
78. Issue resolved in draft; document reflects this comment.
79. Issue resolved in draft; document reflects this comment.
80. Issue resolved In draft; document reflects this comment.81.
Noted.
82. Concur. Table 6-5 on pages 6-26 and 6-27.
83. Concur. Page 3-12, last paragraph.
84. Concur., Project Schedule subsection,, page 3-23 ff.
Validation oflaboratory data will be the responsibility of SCS
Engineers. Thecomplete laboratory deliverable documents which will
be used tovalidate the data will be submitted upon request only
(page 3-30,line 5).
85. Issue resolved in draft; document reflects this comment.
Section 3 of the Work and Quality Assurance Plan provides
alternate schedulesfor completion of the RI/FS. The Department
previously has indicated that itplans to promptly approve the Work
and Quality Assurance Plan; if formalapproval is provided by
January 28, then field work can begin in February.
flR300269
-
Mr. Khoa NguyenMr. Andrew PalestiniJanuary 11, 1991Page 7.
If you have any questions of a minor or technical nature, please
telephoneus. Any other questions or comments should be addressed to
Mr. ThomasUnderwood, the new Project Coordinator for the City of
Suffolk.
Very truly yours,
RoWrt W. Luce, PhD, CPG Michael W. McLaughlin, PEProject Manager
Project DirectorSCS ENGINEERS SCS ENGINEERS
RWL/jwg
Enclosures
cc: T.G. UnderwoodM.H. WoodwardW.A. Anderson, II, Esq.A.T.
Ellis
SR300270
-
Company "resume'S~cron"taihed ."on pages 300271-300355have been
removed,, - '
-
APPENDIX E
FIELD INSTRUMENT OPERATIONMANUALS FOR CALIBRATION
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APPENDIX F
GP ENVIRONMENTAL SERVICES, INC.(FORMERLY JTC ENVIRONMENTAL
CONSULTANTS, INC.)
LABORATORY QUALITY ASSURANCE/QUALITY CONTROL MANUAL
RR3QQ369
-
copy v * w of 75
JTC ENVIRONMENTAL CONSULTANTS, INC.
LABORATORY QUALITY ASSURANCE/
QUALITY CONTROL MANUAL
REVISED AND APPROVED BY
QUALITY CONTROL OFFICER
JOHN T. COOKSON,
AR300370
-
JTC QA/QC MANUAL
Table of Contents
EAOEI. INTRODUCTION 1
A. QA/QC Objectives 1
B. Policy Statement 1
C. Scope and Approach 1
II. LABORATORY ORGANIZATION AND PERSONNEL 2
A. Overview 2
B. Roles and Responsibilities 2
C. Assignment of Responsibilities 3
D* Personnel Qualifications 6
III. GENERAL QA/QC PROGRAM 8
A. Program Requirements 8
B. Data Requirements . 8
C. ""Program Goal 9
IV. GUIDELINES FOR QA/QC PROCEDURES 10
A. . Baseline Laboratory Assurance 10
B. Sample Handling Assurance 13
C. Analytical Methods Assurance 17
D. Data Handling Assurance 22
9R30037
-
JTC QA/QC MANUAL
Table of Contents (cont'd.)
V. QUALITY CONTROL DOCUMENTATIONAND CONTROL CHARTS 24
VI. MANAGEMENT OF OUT-OF-CONTROL EVENTS 25
A. Definition of Out-of-Control Events . 25
B. Responsibilities and Procedures forResponding to an
Out-of-Control Event 27
C. Documentation of Out-of-Control Events 31
D* Corrective Action 34
E. Examples of an Out-of-Control-Event ' 35
VII. SAMPLE COLLECTION ' 37
VIII. FACILITIES, EQUIPMENT, AND SUPPLIES 38
A. Facilities 38
B. Equipment _ 39
C. Supplies 39
IX. DATA GENERATION 40
A* Quality Assurance Modification 40
5. Standard Operating Procedures 40
C. QA/QC Plan Review and Approval 42
X. DATA PROCESSING 43
A. Collection . . ... . ._ 43
-ill- flR'300372
-
--— JTC QA/QC MANUAL
Table of Contents (cont'd.)
PAGE
X. B. Validation " 43
C. Storage 44
D. Transfer , 44
E. - Reduction 44
XI. REFERENCES 46
APPENDIX A
Tables 1 through 5
APPENDIX B
Quality Control,Forms used for Inorganic and OrganicAnalyses
APPENDIX C
Generation and Use of Control Charts
APPENDIX D
Tables of Content for Individual SOP's
flR300373-iv-
-
JTC QA/QC MANUAL
List of Figures
FIGURE ' PAGE
1 JTC Organization Structure 4
2 Chain-of-Custody Record 14
3 Sample Receipt Form . 15
4 Sample Checkout Log 16
5 Sample Disposal Log 17a
6 Management of Out-of-Control Events 28
7 Quality Control **S~ituation Alert** 32
BR30037U-V-
-
JTC ENVIRONMENTAL CONSULTANTS, INC.
LABORATORY QUALITY ASSURANCE/QUALITY CONTROL MANUAL
I. INTRODUCTION
This document describes the Quality Assurance/QualityControl
(QA/QC) Plan for analytical services performed by JTCEnvironmental
Consultants, Inc. (JTC). This plan is designed toensure that
quality data are generated for all JTC clients.Items addressed by
the plan include personnel responsibilities,sampling,
chain-of-custody, laboratory operations, analyticalmethods, data
handling, quality control charts, management ofout-of-control
situations, and standard operating procedures.
A. QA/QC Objectives
The objective of the QA/QC program is to assess,ensure, and
document that all data generated, stored, andreported by JTC are
scientifically valid, defensible, and ofknown precision and
accuracy.
B. Policy Statement
It is the policy of JTC to establish and maintain aprogram of
quality assurance and quality Control to assure thatall data
collected are of known and documented quality. TheQA/QC program^
requirements cover all activities which generatemeasurement
data.
C. scope and Approach
. . The scope of the QA/QC program is over alllaboratory
operations, from sample receipt, through analysis, todata
reporting. The approach is to ensure that a uniform basisis used
for sample handling, methods control, instrumentconditions,
performance evaluation, and data generation andreporting for all
samples received for analysis.
AR300375
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II. LABORATORY ORGANIZATION AND PERSONNEL
A. 'Overview
JTC Environmental Consultants, Inc., provides avariety of
professional services that address environmental andhealth-related
problems. Founded and managed by experiencedprofessionals, JTC
provides innovative and high quality servicesin the analytical,
research and development, and engineeringconsulting fields. The
staff at JTC consists of individualsskilled in the physical,
chemical, biological, engineering, andsocial sciences, backed up by
exceptional laboratory and supportcapability. This provides the JTC
client with problem-solvingflexibility which is strengthened by
rigorous quality control andproject management.
JTC has developed extensive analytical laboratorycapabilities to
support our scientific and technical services.The JTC laboratory
was one of the first qualified by the U.S.Environmental Protection
Agency for priority pollutant analyses.It has extensive
capabilities in the area of environmentalanalysis. We are staffed
and equipped to provide a completeinvestigation of waste
discharges, from sampling programdevelopment through trace chemical
analysis, includinginterpretation of results in accordance with the
latestregulations. The JTC laboratory is divided into four
sections:Wet Chemistry, Metals, Organic Chemistry, and Biology.
Eachlaboratory section is managed by an experienced
LaboratoryDirector.
B. Roles and Responsibilities
The authority and responsibility for directingQA/QC activities
within JTC are delegated to the QualityAssurance Officer (QAO) and
include all areas covered by thequality assurance program. Each JTC
Project Manager (PM) setsthe level of quality assurance required
for the individualproject and has the responsibility for
implementing the qualityassurance program outside of the
laboratory, such as fieldactivities which include sample collection
and fieldmeasurements. Each Laboratory Director (LD) has the
overallresponsibility for implementing the quality assurance
programwithin each laboratory. The following persons are designated
forthese positions at JTC:
Quality Assurance Officer John T. Cookson, Ph.D.
Project Managers As designated by theExecutive Committee
Metals and wet ChemistryLaboratory Director Mr. Edward
Dantsker
-2- HR300376
-
Organic Laboratory Director Alien Brause, Ph.D.
Biology Laboratory Director Mr. Paul Haynos (Acting)
Director of Analytical Services Ms. Ann E. Rosecrance
In addition to the above, the Quality AssuranceCommittee will be
called upon when an out-of-control situationcannot be adequately
resolved by the LDs. A chart depictingJTC's organizational
structure is provided in Figure l.
C. Assignment of Responsibilities
Each person involved in the generation of data isimplicitly a
part.of the QA/QC program. The follow ingindividuals have
specifically delegated QA/QC responsibilities.
o Quality Assurance Officer
All QA/QC management responsibilities for JTCshall be directed
by the Quality Assurance Officer (QAO). Theindependence and
objectivity of the QA/QC program depends on theQAO's being
independent of the data generation process.
The QAO has primary responsibility for alllaboratory QA/QC
activities. The QAO reports directly to the JTCPresident. His/her
responsibilities include the development,evaluation, and
documentation of QA/QC policy and proceduresappropriate to the JTC
mission.
The QAO performs the day-to-day auditing oflaboratory activities
to ensure that the QA/QC plan is beingimplemented. The QAO has the
authority to perform laboratoryaudits without notice, submit
control samples, and request accessto data files and' other
information to satisfy the goals of anindependent audit.
The QAO periodically reports on the progressand - deficiencies
of the laboratory QA/QC program, identifiesspecific needs (e.g.,
methods development and problem areas), andrecommends specific
courses of action for strengthening theprogram.
Motivation of personnel is a critical factorin the success of
the laboratory QA/QC program. A majorresponsibility of the QAO is
to ensure that all personnel have agood understanding of the
laboratory QA/QC plan, an understandingof their respective roles to
__one another, and an appreciation ofthe importance of their roles
to the overall success of.theprogram. - * -
HR300377
-
UJO
UJ0£Q.
\— UJz c:UJ
-
o project Manager
The JTC Project Manager (PM) is responsiblefor managing and
implementing the technical and administrativerequirements of
the.project. He/she must ensure and document thequality of each
task output'. The PM collaborates with the JTCQA/QC organization to
formulate and fulfill a suitable QA/QCproject plan for each task
under his/her purview, in conformitywith the quality assurance
.requirements of the client.
The PM has overall responsibility fordesignating the level of
quality control necessary for theintended use of the data, and for
formulating the QA/QC projectplans and activities. He/she will also
enlist and encourage thecooperation of all JTC personnel in the
QA/QC project plan andprogram.
o Laboratory Directors
The JTC Laboratory Directors (LD) haveoverall responsibility for
all laboratory activities, includingQA/QC. The success of the QA/QC
program ultimately depends onthe LD's full support of QA/QC
management. The LD will enlistand encourage the cooperation of all
JTC personnel in theprogram. . ._.,_._ :_.. .._.
Each LD is responsible for seeing that thequality assurance
requirements are implemented for each analysisperformed in his/her
laboratory. The quality assurancerequirements shall encompass those
established by the PM and QAO,in addition to further QA/QC
requirements of the specificanalytical methods. The laboratory
staff will be directed by theLD in the performance of QA/QC
protocol for all analyses.
o Quality Assurance CommitteeThe Quality Assurance Committee
(QA
Committee) is designated by JTC's Board of Directors. It
iscomposed of technical personnel with extensive experience inareas
such as chemistry, microbiology, and engineering. Themembers are
responsible for providing the necessary technicalexpertise to
ensure adequate implementation and review of thelaboratory QA/QC
programs. In particular, they are available forconsultation on the
technical aspects of specific task activitiesthat affect overall
data quality, and aid to the QAO in thedevelopment, implementation,
and evaluation of audit programs.
The QA Committee reviews proposals,recommends improvements in
QA/QC policies and procedures, andreports and evaluates potential
data quality problem areas. It
-5- flR300379
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also acts as a QA coordinator, consulting on matters of
QA/QC,serving as a source of information on QA/QC matters, and
helpingto implement the laboratory QA/QC program.
The QA Committee serves as an advisorycommittee to promote the
continuity and application of the QA/QCprogram. The Committee's
functions include assisting in theevaluation and refinement of the
data quality objectives of theQA/QC program, so that they meet
laboratory needs with a minimumdisruption of existing work loads
and procedures, reviewingrecommendations presented to the QAO and
the Committee, andassessing the effectiveness of the QA/QC
program.
D. Personnel Qualifications
All personnel within JTC must have adequateeducation, training,
and experience in the area of theirtechnical expertise and in
quality assurance to meet theirdesignated responsibilities. To
ensure that their knowledge isboth sufficient and applicable to the
tasks at hand, and thatthey continue to keep abreast of new
developments in the field,the QAO shall periodically recommend
training to all personnelengaged in QA activities within JTC. Where
appropriate,participation in relevant seminars, short courses,
andprofessional meetings is recommended and supported.
1. Quality Assurance Officer
The Quality Assurance Officer for JTC willhave at least the
following qualifications:
o Sufficient professional and adminis-trative stature and
experience to dealeffectively with project officers,program
managers, and organizationaldirectors, and administrators
o Demonstrated QA/QC experience
o Knowledge and experience in a scientificdiscipline; a
knowledge of statistics ishighly desirable
o Knowledge of appropriate Federal laws,Agency regulations, and
guidelines formethod-related QA/QC requirements
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o Effectiveness in meeting and dealingwith the general public,
privateindustry, and officials of Federal,State, and local
agencies
2. Project Managers and Laboratory Directors
In order to provide the necessary technicalexpertise to the JTC
QA/QC organization and to ensure adequateimplementation and review
of the laboratory QA/QC program, the PMand LD shall have
demonstrated technical competence in areas suchas chemistry,
microbiology, and engineering. They shall havesufficient knowledge
of the principles and practice of QA/QC toconsult with
investigators in developing and implementingappropriate QA/QC
project plans.
3. Laboratory Personnel
All personnel participating in datacollection-related activities
under the auspices, of JTC shallpossess adequate experience and
training to satisfactorilyperform all technical tasks assigned. The
LD will review theanalyses and QA/QC related activities performed
by the laboratorystaff. At the project level, personnel
qualifications shall bereviewed and evaluated by the PM. In
addition, the QAO may, atany time, review and evaluate task
personnel qualifications.
Where appropriate, personnel will be expectedto participate
regularly in certification programs, includingexternal audit
program for performance evaluation and/oraccredited training
courses in their areas of specialization.
4. Sample Custodian
The sample custodian will have sufficientexperience in clerical
and data handling procedures to log andmaintain tracking records on
sample receipt in a responsiblemanner. Professional experience with
computerized data entry,chart and form preparation, and knowledge
of sample sizerequirements for various analyses is required.
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III. GENERAL.QA/QC PROGRAM
All laboratory activities within JTC shall be performed
inconformity with the approved QA/QC project plan. Approval of
aQA