dec 17 -990this work plan. 11. page 3-3, par. 3.3.2 - discuss the significance of the monitoring...

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 CHESTNUT BUILDINGPHILADELPHIA, PENNSYLVANIA 19107

DEC 17 -990Mr. Timothy TraversB&V Waste Science and Technology Corp.Public Ledger Building, Suite 272Independence SquarePhiladelphia, PA 19106

Re: Aladdin Plating Superfund SiteRI/FS Work Plan Comments

Dear Tim:

Please find enclosed comments that I have received from thevarious reviewers included in the EPA peer review process. Pleasenote that the DER comments have not yet been received, however,they are scheduled to be sent to me by December 21, 1990. I willforward a copy to you as soon as I receive them. Also listedbelow are my comments:

I. WORK PLAN -

1. -1, par. 2 - Drop the term "pickle liquor" from thediscussion. Electroplating wastes are generally not knownin the industry as "pickle liquor". Pickle liquor is a termused commonly in the steel industry and its used to removeoxide and other impurities from finished steel.

2. Page 1-1, par. 2 - Explain that the lagoons were back-filled in the mid-1970's and the disposal practice from thatpoint on included disposal of wastes directly onto theground.

3. Page 1-3, par. 4 - Explain what "substantially completed"means.

4. Page 1-5, par. 1 - An additional purpose of the RIFS isto evaluate the effectiveness of the ongoing soil remedia-tion project in abating further ground water contamination.

5. Page 2-1, par. 1 - Add to the last sentence that thelagoons were closed in the roid-1970's and waste was placedon the ground thereafter.

6. Pages 2-15 and 2-17 - A summary of the samplegenerated from B&V's own sampling discussed here ,,,. ,wv «.

included in the document as an attachment. To date/thisinformation has not been formally presented to EPA in anyformal report or summary form. It would be appropriate todo it here and now. In order for B&V to properly review thedata for consideration in the preparation of this work planthe data should have been summarized. Therefore, it shouldonly be a matter of attaching what should have already beendone to this document.

7. -19, par. 1 - Include a map to show the location ofthe creeks and reservoir.

8. Page 3-3., par. 5 - State that it is therefore believedthat, tlitt contaminated s ii as a primary source of contamina-tion to the ground water will have been removed and remed-iated by the end of January 1991.

9. Page 3-2, par. 3.3.2 - Specify the maximum concentrationsof the contaminants found (chromium, lead, cyanide, etc.) inthe soil at the site.

10. Page 3-3, par. 3.3.2 - Explain that there were somewells found to be contaminated with lead during the 1987sampling and also during the 1989 sampling. Explain thethat lead is a common contaminant found in residential waterdue to its presence in the distribution systems. Alsoexplain that the EPA Region III Office has established alevel of 15 ppb as an interim drinking water standard.Discuss that additional sampling of the wells in which leadwas found will be conducted during the implementation ofthis work plan.

11. Page 3-3, par. 3.3.2 - Discuss the significance of themonitoring well sample results in terms of the differentwell depths, filter vs. unfiltered samples, and in relation-ship to the nearby residential wells. There was cadmiumcontamination found in some of the monitoring wells.

12. Page 3-4 and 4-6 - These two pages are misplaced.

13. Page 3-4, Table 3-1 - Can't compare filtered to unfil-tered samples.14. Page 3-6, par. 3.3.4.2 - Explain that the risk from soilwill have been remediated as a result of the on going soilremediation activity.15. Page 3-8, par. 3.3.4.3 - Are we sure that Leggetts Creekwas not sampled in the past?16. Page 3-8, par. 3.3.4.4 - Mention the green perchfound on the site during Part 1 of the soil remediat

project. Discuss the possible affect and relationship to v Jwater quality in on-sita monitoring wells. ^^

17. -11, par. 3.3.6 - Why can't the additional dataneeds to assess potential risks to terrestrial and aquaticbiota be identified now and ba specified in the fieldsampling plan? How will this be budgeted for?

18. Table 3-6, Contaminant-Specific, Action-Specific, andLocation-Specific ARARs:

- Non zero MCLGs are considered ARARs by the NCP (page3343).

- Why is it stated that the AMQCs are "relevant andappropriate". Aren't they actually "applicable"?

- 40 C.F.R. Part 268 should be referenced here as anadditional RCRA ARAR. These are the land disposalrestriction regulations.

- The comment under the RCRA requirement is not clearand I don't believe it has any thing to do with RCRArequirements. -Past disposal practices have beendetermined by EPA not to be covered by RCRA and havealso been determined not to be relevant and ap-propriate, this was part of the ROD for the soilremedial action. Further there is no term defined byRCRA as "hazardous materials", this is strictly aCERCLA term.

- There are national ambient air standards for leadunder the Clean Air Act regulations at 40 CFR Section50.12, this could become applicable if there is aground water treatment system required for the removalof lead from the ground water.

-40 CFR Part 262 is applicable to persons who generatehazardous wastes whether they transport them off-siteor not. They would apply for any generation of hazar-dous waste and any subsequent on-sita storage of lessthan 90 days.

- The Clean Air Act citation is far too general. NewSource Performance Standards at 40 CFR Part 61 andNational Emission Standards for Hazardous Air Pol-lutants at 40 CFR Part 62 could be cited. All otherair pollution typa ARARs will be stata specific typeARARs since the Stata is delegated tha authority to.promulgate and enforce regulations on a pollutantspecific basis to achieve tha national ambientquality standards.

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19. -2, par. 4.2.3 - Why is sediment underlying theongoing excavation considered a source of contamination?The purpose of doing the excavation is to remove the con-taminated soil thus removing it as a source.

In the third sentence add "runoff" after the word "sur-face".

20.Page 4-2, par.4.2.4 - Discuss as an objective the evalua-tion of the soil remedial action in terms of accomplishingwhat it was design to do, that is, prevent any furthercontamination of ground water above the drinking waterstandard*. This is one of the purposes for running themodel.

21. Page 4-2, par. 4.2.4 - There is no evidence of and it isnot suspected that volatile organics have contaminated theground water. In fact on August 21, 1987, the on-sitemonitoring wells were sampled for VOCs .and no significantcontamination was found! Also, why are there terms like"other heavy metals... are suspected of contaminating groundwater" when we know that other heavy metals have con-taminated ground water because of the past -sampling results.

22. Page 4-3, par. 2 - The discussion on what backgroundliterature indicates should be deleted. We know that thereis chromium, lead, nickel, copper, and cyanide contaminationpresent because of past sample results. Further the use ofvolatile organics is merely conjecture and should be charac-terized as such. A statement that organics have beensampled for in the past and not been found should also bemade here.23. Page 4-4, par. 4.3.2.1 - What has changed that B&V nowthinks that hexavalent chromium can be successfully analyzedfor in the soil and sediment samples?

24. Page 4-4,par. 4.3.2.1 - A sample in the drainage ditchbetween•Scott Road and Leggetts Creek should also be con-sidered for sampling.Also, how were the percent of samples determined for thevarious analytical parameters? Shouldn't all samples beanalyzed for all appropriate parameters?

25. Page 4-16, Table 4-6 - An expanded list of residentialwells will be sampled during the RI. A list similar to theoriginal list sampled by the removal program in the earlystages of the site should be developed.

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26. Page 4-19, par. 4.3.2.3 - in listing the DQOs it shouldnot only explain what information will ba obtained'from eachparameter analyzed for but also how that information isplanning to ba used. For example is it going to ba used inrunning tha modal, for evaluating and designing a potentialtreatment system, ate.

27. Page 4-21, par. 4.3.2.4 - Why ara wa analyzing for VOAswhen in tha past no VOAs were found in tha monitoring wells?

23. -2, par. 5.1.4 - Add to this paragraph that B&Vwill identify to EPA from which entities access permissionis needed.

29. Page 5-6, par. 5.1.11 - When will the review for ex-pedited action ba completed, and conclusions and recommenda-tion mada to EPA? If its not going to dona eliminate itfrom the work plan discussion.

30. Page 5-6, par. 5.1.12 - There is a Part II CERCLACompliance with Other Laws Manual dated August 1939 thatalso should ba used to determine ARARs.

31. Paga 5-10, par. 5.1.16 - Tha administrative recordsupport needed includes tha compiling of documents that willba placed in tha administrative record aftar work plan ap-proval. EPA will then review tha compilation of documents \^sand then giva them to tha in-house contractor for placementinto tha record.

32. Paga 5-11, par. 5.3.2.1 - Absolutely NO soil investiga-tion is to ba conducted under this work plan. This is awork plan for the ground water and bioassessment operableunit ONLY! The only soil sampling to ba dona is tha streamsediments which should be specified and discuss only in thasurfaca water discussion and, tha drill borings during thawell installation which should be discussed in tha monitor-ing wall installation section.

Par. 5.3.2.3 - Thara is no air investigation necessary andit should ba stated hara with tha justification discussedbasetd in tha air sample results from tha on-going remedialaction. Thara will howaver be air monitoring conductedduring fiald work at tha sita.

Par. 5.3.3 - Tha paragraph on source tasting should bastricken from the work plan. The ongoing remedial action istha source control remedial action, no further sourcetasting is neededl33. 'Page 5-14, par. 3.6 - Isn't the extensive surveying doneby Dunda during the remedial action able to be used for this ,

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project also? If so, discuss it here. ,'

34. Page 5-16, par. 5.6.1 - The second paragraph in thissection is inaccurate. A number of contaminants in additionto chromium and cyanide have been found in the soils at thesite. These contaminants include arsenic, nickel, cadmium,copper, lead, and zinc. Further this discussion does notseem to take into account that the remedial action to removecontaminated soil from the site is ongoing.

35. Page 5-19, par. 5.6.5 - It should be stated that theprimary objective of the modeling is to evaluate the successof the remedial action in terms of protecting the groundwater as the clean up standard was design to do. Further itshould be made clear that the EPA Athens, GA Lab will runthe model and provide needed assistance in doing so.

Par. 7.7.1 - It should be state that the treatability studyif needed would be for evaluation of a treatment system forground water (not for soils).

II. QAPjP -

1. Section 2, page 2, par. 1 - Electroplating waste andpickle liquor are not the same thing. Delete the referenceto pickle liquor.

2. Section 2, page 10, par. 1 - Also discuss other metalsfound in the monitoring well water.

Par. 4 - Also discuss the other metals found in the soils,include in the discussion the concentrations found of eachmetal.

3. Section 2, pages 12 & 14 - Discussions about ground watercontamination found in the monitoring wells should indicatethat contamination of cadmium, lead, copper, nickel and zincwere also found in these wells. A summary table for theseresults.should be included.

4. Section 2, page 15 - The term "sampling soils" is some-what misleading, it should be replaced with the term "borehole samples".5. Section 3 - Hake all recommended changes in the sitedescription as was recommended in the work plan comments.A portion of Section 3.3 seems to be missing.

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III. HBALTH and SAFETY PLAN -

1. Page 2, para. II.C. - Delete references to "pickleliquor" and mention the practice of disposing wastes direct-ly on the ground.

2. Page 4, para. V.A. - The discussion here should mentionthe fact that a soil remedial program is near completion.Thus the soil concentrations of chromium and cyanide havelittle relevance in the discussion of potential hazardssince this contamination has been removed and clean backfillhas been placed on site.

3. Page 14, para.I - All waste generated will be disposedunder the terms of this work assignment. Since the remedialaction has already taken place, the RI generated waste willnot be left behind to be disposed of during remedial action.

4.Page 13 - The exclusion zone designated here will notexist during the majority of RI activity and should bediscussed as such in the HSP.

5. Page 24 - The list of contacts should be updated toreflect the new site* representative and my new phone number(597-1265). Also the notice at the end of the plan isUNACCEPTABLE. Language used in the remedial action HSP mustbe inserted.

IV. Field Sampling Plan -

1. All previous pertinent comments made in the precedingwork plan, QAPjP, and HSP shall also be incorporated in theFSP.

2. Section 2.0 - Change the name of this section to "BoreHole Sampling".3. Section 7.4.4 - Drum disposal will not be the respon-sibility of the RPM! All waste generated during the RIactivity will be disposed of under this work assignment.The arrangements will be made by 3&VWST.

V. COST ESTIMATE -

1. Are the usage numbers presented in the Activity Detailchart man-days? If they are the following usages seemexcessive:

- Project Planning - 1554 hours normally 800 - 1000hours.

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8 f-'-'r :- Remedial Investigation - 1988 hours normally 500 -600 hours.- Feasibility Study Report- 1038 hours normally 450 -525 hours.

2. The total cost for each subtask should also be listedhere.3. I would like to see subtotals for each subtask listed inthe activity detail sheet which is broke out by subtasks.Also it should be made clear whether TETC hours are alsoincluded in this break down.

Since the comments cover a large number of issues, I suggestthat we meet to discuss all the comments. If further clarifica-tion is needed from individual reviewers a follow-up meeting willbe arranged with the appropriate reviewer(s) . Please call me at597-1265 to schedule the meeting to discuss the comments.

Sincerely,

Patrick McManusRemedial Project ManagerEastern PA Remedial Section

Enclosures

cc: Dr. Richard Brunker, 3HW15Hindi Snoparsky, 3KW15Robert Davis, 3HW15Tom Ziemba, PA DER Wi Ikes -Bar reDebbie Eble, 3PM32Walt Graham, 2HW22Susan Janowiak, 3KW14

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dfec ? ift i*Jcri< ° i an tor Aladdin Piatir:^ RI/';-"S

•- r;.!in : Deer-Tie E b 1 e , Contract Specialist i 7-PM "2 )Suoerfund rinancial •'•lariagC'iiem: and Conrracts Section

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[ nave revie>,i?d rhe vocrk ciar- oroôsed 3/ Black 'f/ Vsatch forf~!f? Aladdin Pl^r^-q K [ '-5 ^c-1-. Jssigp-Tient in accordance with tnejasic con i- ' -set •- -i i a--'-..-TI t: t ions . "he overall costs procossd appearrsssonatle ^r)r r:ie -.C'lDinec Bv/E^C ...uE of 9Oi8 "curs, Deeding /ourtect~'r. ic a 1 review j*nd apDroval . However , a few elements of theT r o po s ed »Mc '• x p i. -i n •- «i-j -_i i -- => clarification:

' . Lacpr r?t2S- ""'">» labor rates outlined on the OP60 fc"~ bet"1filac^ *< Veatcb and its tea>T. subcontractor. Earth Technaloov,differ f-oTi t. ose agreed to during negotiation of the contractand <?sc3iated 4V. for year Z of tne contract:

Proposed Con tract

3V P3 *25.96 $24.O6P2 $17.37 $22.74PI $15.00 $19.6OT2 $13.50 $20.53Tl $ 9.OO $11.58

ETC P4 $32.00 $34.26P3 $24.00 $21.09P2 • $19.00 $16.04PI $14.00 $12.26T2 $14.00 $11.90 ^

Clerical $14.00 $11.96 ^CC2. Labor hour distribution- The proposed Bv/ETC labor hours ^

are weighted in the P2 labor category, 61V. versus 397. per thecontract. Is this primarily due to ETC s Dan Bostwic*designated as the site manager'7 David Wright is listed in tnework plan and has obviously performed work by signing thecover memo and the OF60, yet no associated P4 hours areprojected for this assignment. Additionally, no clericalhours are projected. Why not?

3. Earth Technology QF60- Our conversation last weekindicates the equipment costs listed in ETC's OF60 is for theseismic survey that was performed in the beginning of October.

E">~C Travel is a.:;---:; :.,?d-.~. - ."..•". •.<;••<••?'- ':. - -~ r.,ne 2asiccontract, $4,2GO .:> f .-..•!.. n .! ': -i i -.•.-•••.:.- l •• •• >-_-.-! • . -ior:n,;:'i tc: -- i v wr> ! f "'a :V: !_-•< t O f-— . f 1 r"' . " •: : /: .- •' " ' ' •'* '. •'' ' - .• f r'.r m _A '.' j .

'"-» . • :•, r ""••=• .: <%? r! i €j ii. '* - ~ -v- -. : , ..-i: r:if- :> ••" •". i ~ ~ * o" ~1 i a *• v~. ..i T'T L t , -A .

4 . "Our . •, r a t£? for •-•.:•.--..:..:••• " . • . - •: •••:;•- i ^ .-'."':• 3 c " ^ -5 it;ie- "'.our', not $7 -as nr-r_ •--.-••;.

I; /ou rt".v_. ire furtf'e-' ..~ *•".•- : , - . a' j. - i ,;^ >. i c" . I can ce

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 111

841 Chestnut BuikfingPhiladelphia, Pennsylvania 19107

SUBJECT: Aladdin Plating: Draft Workplan DATE: 12/7/90

FROM: Susan G. McDowell, 3ES43NEPA/309 Review Team

TO: Pat McManus, 3HW22Project Manager

I have reviewed the subject document for functionalequivalency with the National Environmental Policy Act (NEPA) .Although many of the areas of concern under NEPA have beenaddressed, the following comments should be addressed tocomplete the analysis:

Table 3-8 lists ARARs relevant to this site and provides abrief description of its applicability. It is unclear,however, how the determination was made for following areasof concern:

- Wetlands: the standard procedure for identifying wetlandsincludes the review of National Wetland Inventory maps inconjunction with soil maps and aerial photographs, if \^Javailable. Field visits are conducted to verify potentialwetland areas. Wetland delineations are performed inaccordance with the Federal Manual for Identifying andDelineating Jurisdictional Wetlands.

- Endangered or threatened species: Initially the resourceagencies are contacted, informally, requesting theinformation. The US Fish and Wildlife Service should becontacted as well as the Pa Natural Diversity InventoryProgram. Documentation of these inquiries should be includedin the RI report.

- Historic/archaelogical sites: a Stage 1A survey should beconducted, to determine whether the area is sensitive forhistoric or archaelogical sites. This information will beused to make the decision to conduct a field survey.

- Prime farmland: significant agricultural lands which may beimpacted by the site or its remediation should be identified.The state's Soil Conservation Soil Scientist should becontacted.

- The National Park Service should be contacted regarding wildand scenic rivers or rivers that are included on the NationalRivers List. , ,

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Thank you for the opportunity to review the subject document.Please contact me at 597-3634, if I can be of assistance.

cc: Diane Wehner

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841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Date: 12/10/90Subject: Soil Sample Collection: Aladdin Plating ,J

From: Rober/S? Davis (3HW15)Biologist

To: Patrick McManus (3HW22)Remedial Project Manager

As you will note from the STAG memo that is forthcoming, it issuggested that soils from the site be collected and tested for chronictoxicity using lettuce seed germination and earth worm studies.

In the Interest of moving this part of the effort along, you maywant to have your contractor contact Mr. Bob Donaghy of the WheelingField Office to discuss procedures. It would be best if the sampleswere to be collected by the contractor and shipped to the lab for thetests. Proper sampling methods and containers are important.

Bob Donaghy can be reached on 8/304/233-2315. If you have anyquestions, please feel free to call me on 6488.

cc R. Donaghy

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CENTRAL REGIONAL LABORATORY839 BESTGATE ROAD

ANNAPOLIS. MARYLAND 21401(301) 2664180

DATE : November 30, 1990

SUBJECT: QA Review: Aladdin Plating Site WP and SAP

Claudia P. Walters, ChemistFROM : Program support Section (3ES23)

Pat McManus (3HW22): Regional Project Manager

THRU: Cindy Metzger,Program Support Section (3ES23)

The Aladdin Plating Site WP and SAP (October 1990) has been

reviewed. Overall the Plan addresses most of the 16 elements.

However, some areas need to more details in the protocol and the

Plan needs to address the reasons for selecting methods. Since

most of the information is present, the recommendation is

conditional approval. Specific comments are described in the

attached checklist. If there are any questions, feel free to call.

Attachment

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Section:Revision No.: 3Date: 1/13/87Page: 1 of 16

QUALITY ASSURANCE PROJECT PLAN REVIEW

SITE NAME: Aladdin Plating Account No.: TFA03N9P7DOCUMENT NAME(S): Draft WP, QAPJP & FSP

Plan Submitted By: Pat McManus Mail Code: 3HW22Title: EPA REGIONAL PROJECT MANAGEROrganization: Phone No.: (215)597-3923Plan Prepared by: Black & Veatch

Date Received: Date Review Requested By:Date of Project Initiation:

Program: NPDES...... IF CERCLA: SI............. PRP.............SDWA....... REM.........X.. STATE SI........RCRA....... REMOVAL........ STATE RI/FS.....TSCA....... ENF REM........CERCLA...X. ENF REMOVAL....Other.... Specify

SUMMARY Y N

Does Plan provide sufficient documentation -enough information so reviewer (and others)knows what will be done, by whom, etc.? ....Some what....

Has document been correctly applied (comply withapplicable regulation or guidance)? ..X.. .....

Does document accomplish what it is supposed to? ....Some what.....

MAJOR DEFICIENCIES were found in the following elements:

...Title page .X.QA Objectives .X.Analytical Proc ...Prev. Main.

...Table of Contents .X.Sampling Proc. ...Data Reduction ...Data SOPs

...Project Descrip. ...Sample Custody ...Internal QC Ck. ...Corr. Action

...Org. and Resp. ...Calib. Proced. ...Audits ...QA Reporting

See the attached for* discussion of comments relative to all elements.

CONCLUSION: QA Reviewer: Claudia P. HaltersApproval Recommended .......Resubmission Recommended .......Conditional ApprovalRecommended ...X... Date Review Complete: 11/30/90

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Section:Revision No.: 1Date: 3/27/86Page 2 of 16

Identification

I) Title page Y N NA

1 - Does page include title of project? ..X..2 - Name(s) of principal investigators shown? ..X..3 - Appropriate approval lines at bottom? ..X..4 - Plan prepared in document control format? ..X..

II) Table of Contents

1 - Does T*Me include a list of all flanrequired elements and appropriate pg. no..? ..X..

2 - Include distribution list? ..X..3 - Include list of Appendices? ..X..

Comments

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Section:Revision No.: 3Date: 1/13/87Page 3 of 16

III) Project Description Y N NA

Are the following addressed, consistently presented,technically correct?

1 - Statement of objectives (purpose)? ..X.. ..... ....2 - Dates for start and completion of project and

sampling activities? ..X.. ..... ....3 - Overview of project's scope (activities)? ..X.. ..... ....4 - Background information? ..X.. ..... ....5 - Brief statement of intended data usage(s)? ..X.. ..... ....

*6 - Description of sampling network designand rationale? ..X.. ..... ....

6a - Design of overall monitoring systems? ..X.. ..... ....6b - Specific location of sampling sites? ..X.. ..... ....6c - Justification of overall design? ..X.. ..... ....

7 - Sample matrices? ..X.. ..... ....*8 - Parameters to be measured? ..... X ..... ....*9 - Frequency of collection? ..... X ..... ....*10 - Field and lab measurements? ..... X ..... ....*11 - Procedures for filtered/unfiltered groundwater,

or other similar fractions/sub-grcupsspecified and included in parameter definition? ..... X ..... ....

*12 - Type of sample(s) (grab, composite, etc.)? ..X.. ..... ....(Collection procedure in Sectj.cn vi)

^Depending on the Program and/or project, information related to sampling maybe discussed under Project Description (Section III), Sampling Procedures(Section VI) in the QAPjP or in a separate Sampling Plan (e.g., CERCLARemedial) - the questions apply regardless of format.

Comments

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IV. Project Organization Y N NA

1 - Does the Plan identify key peopleresponsible for:- Overall QA/QC? ..X.. .........- Sampling operations and sampling QC? ..X.. ..... ....- Laboratory analyses and laboratory QC? ..X.. ..... ....- Data processing and data processing QC? ..X.. ..... ....- Data review? ..X.. ..... ....- Performance and System audits?

(Lab and field) ..X.. ..... ....V,

2 - If CLP is to be used in State-lead remedial or SI,does QAPjP define responsible person(s) for:- Final data review of routine CLP services? ..X.. .....- Preparation and final review of SAS

requests? ..X.. ..... ....- Review and confirmation of any tenta-

tively identified organic compounds? ..X.. ..... ....

3 - Are phone numbers and addresses included? ..X..

4 - Is line authority for all referencedorganizations explained or demonstratedby including an organizational chart(s)? ..X..

5 - Are personnel qualifications included?Training? Experience? Resumes? ..X..

6 - is the organizational structure appropriate toaccomplish the QA objectives of the project? ..X..

• • *

Comments

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Section:Revision No. : 3Date: 1/13/87Page: 5 of 16

V) QA Objectives and Criteria Y N NA

1 - Is there a statement of intendeddata usage? . .X. . ..... .....

2 - Are the terms and definitions for precision,accuracy, representativeness,, comparability andcompleteness properly used and expressed(i.e., QA/QC concepts and theories areunderstood and properly implemented relativeto the Project)? ..... . .K. . .....

3 - Are Data Quality Objectives (DQOs) quantitativelystated for precision and accuracy (bias)? ..X.. ..... .....

3a - Have the following been defined for eachmatrix and parameter:

1) Level of QA effort (frequency of QC, etc)? ..... X ..... .....2) Accuracy (matrix spikes, surrogate spikes,

reference samples , etc .)? ..... X..... .....3) Precision (replicate samples)? ..... X ..... .....4) Sensitivity or MDL? ..... X ..... .....5) Statistical reporting units? ..X.. ..... .....

3b - Are quantitative limits established for each? ..X.. ..... .....3c - Are field and lab both covered? ..... ..X.. .....3d - Is it clear that a distinction has been defined

for "total" system variability and bias vsonly looking at the laboratory? ..... ..X.. .....

3e - Are objectives/requirements properly expressed(e.g., not confused w/capabilities)? ..... ..X.. .....

4 - If appropriate, are completeness objectivesquantitatively stated? ..X.. ..... .....

5 - Are representativeness and comparabilityappropriately addressed? ..... ..X.. .....

6 - Are the interrelationships (and differences)between study design (number of samplesneeded), analytical procedures, internalQC and data assessment reflected in the DQOs? ..... ..X.. .....

Comments

1. Comparability and representativeness have not been addressed.2. The entire discussion on Bioassessment (DQOs, sampling, and analytical) is vague.The bioassessment (flora and fauna) has not been described. What is the objective?How will it be measured? Who will perform the assessment? what is the criteria willbe used for the sediment and surface water results to determine if macro invertebratewill be sampled?3. why is Amorphous iron oxide being analyzed for?4. Table ll-l(SAP): Are the QC numbers listed per sampling event or the entire study?


VI) Sampling Procedures Y N NA(See also Section III)

1 - Are procedures documented and detailed forall parameters? ..... X..... .....

2 - Are the following elements included:- Investigation objectives? ..X.. ..... .....- Site background? ..X.. ..... .....- Analysis of existing data? ..X.. ..... .....- Analytes of Interest? ..X.. ...... .....- Sample types? ..X.. --..... .....- Map of locations to be sampled? ..X.. ..... . ...- Sample locations and frequency? ..... ..X.. .....- Technique or guideline used to select sites? ..... ..X.. .....- Specific sample collection methods? ..... X ..... .....- Description of sampling devices? ..... ..X.. .....- Containers (type and source)? ..X.. ..... .....- Preservatives (type and source)? ..... ..X.. .....- Holding times? ..X.. ..... .....- Reagents? ..X.. ..... .....- Transport and storage? ..X.. ..... .....- Preparation of sampling equipment (before and

during sampling) and containers? ..X.. ..... .....- Blanks? ..... ..X.. .....- Record-keeping requirements? ..X.. ..... .....- Coordination with laboratory? ..X.. ..... .....

3 - For RI/FS especially, does the (Sampling) Plan:- Provide specific guidance for all field work? ..... ..X.. .....- Provide a mechanism for planning and approving

site activities? ..X.. ..... .....- Ensure that sampling activities are limited to

those that are necessary and sufficient? ..X.. ..... .....- Provide a common point of reference for all

parties to ensure comparability andcompatibility between all activitiesperformed at the site? ..... X..... .....

Comments1. How many times at each location will the sediment and surface water be collected?2. Sampling Procedure 3.2.3:

o Surface water - need to check t!-.e pH (preservation). List preservative.o Surface water - Describe rinsate blanks.o Sediment - The sample can cot te stirred prior to removing sample forparameters which can be affected by oxidation (e.g. VOAs, amorphous Fe, etc.).Describe what about field measurements will be taken.o VOA samples must be collected in accordance to the QA Directive 7.

3. Sampling Procedure 4.4.2: Add the preservation step.4. Bioaseeesment (FSP CH 5): All the details for the sampling and environmental

v > assessment must be added - list the species, describe what samples, tot|~versus hexa-Cr, explain sample timing, and when will tree sampling occur and descrii

Section:Revision No. : 2Date: 1/13/87Page: 7 of 16

VII) Sample Custody Y N NA

1 - Does the plan address:- Field custody procedures? ..X.. ..... .....- Transfer of custody and shipment? ..X.. ..... .....- Receipt of samples? ..X.. ..... .....- Lab custody procedures? ..X.. ..... .....

2 - Does Plan include examples of forms, tags,labels, records, etc.? ..X.. ..... .....

3 - Does the Plan address evidentiaryconsiderations? ..X.. ..... .....

4 - Do field documentation procedures:- Document source of reagents or supplies? ..... ..X.. .....- Include procedures /forms for recording the

exact location and specific considerationsassociated with sample acquisition? ..X.. ..... .....

- Document specific preservative method? ..... ..X.. .....- Include labels containing all necessary

information? ..X.. ..... .....- Include form to track custody? ..X.. ..... ....

5 - Do lab custody procedures:- Identify Sample custodian? ..X.. ..... .....- Provide for custody record within the lab? ..X.. ..... .....- Specify procedures for sample handling,

storage, dispersement for analysis anddisposal? ..X.. ..... .....

Comments

SR30Q38Q

•f*


VIII) Calibration Procedures and Frequency Y N NA(Lab and Field)

1 - Does Plan include methods/proceduresto assure field and lab equipment arefunctioning optimally? ..X.. ..... .....

2 - Is frequency of above included? ..X.. ..... .....3 - Are equipment log books required to record

usage, maintenance, calibration and repair? ..X.. ..... .....4 - Does Plan include calibration standards to be

used, their source and traceabilityprocedures? ..... ..X.. .....

5 - Does Plan include calibration documentationrequirements: ..X.. ..... .....

- Date(s) of calibration? ..X.. ..... .....- Identification of standards used? ..X.. ..... .....- Personnel performing calibration? ..X.. ..... .....- Results of calibration (raw data and summary

statistics}? ..X.. ..... .....- Corrective actions taken? ..X.. ..... .....

Comments

AH30038I


IX) Analytical Procedures Y N NA

1 - Are analytical procedures written as SOPsand included in full or by reference? ..X.. ..... .....

la - Are all procedural steps and optionsdescribed? ..X.. ..... .....

2 - Are the criteria of method selection included(e.g., in order to obtain a particular DQO)? ..... ..X.. .....

3 - If method choice is governed by regulatoryrequirement (e.g., NPDES, SDWA, RCRA) havethe appropriate methods been chosen? ..... ..... ..X..

4 - For CERCLA can CLP equivalency be determined? ..X.. ..... .....5 - Is it evident from the Plan that the laboratory

has the appropriate facilities, services,equipment and supplies to perform the requiredanalysis(es)? ..... ..X.. .....

6 - Do the methods include specific QC requirements(type, frequency, acceptance, etc.)? ..X.. ..... .....

Comments

1. Table 4-6(WP) and the respective table in the SAP needs to be clarified. Why isthe sample code the same for both pages?

2. Explain Subtask 3.7, Field Screening/Analysis is? This has not been addressed inthe remaining text. What on-site laboratory?

3. What fixed lab will perform the analytical work? Is the CLP program going to beutilized? Be specific as to which parameters will be performed where. State whichparameters are RAS, which are SAS, which are non-CLP and what will be performed in thefield. All SAS requests are to be submitted in the SAP, per the QA Directive.

4. Any analytical work to be performed for the Bioassessment must be described.

5. Table 6-1 (QAPjP):o The matrices must be specific, e.g. surface water, ground water, etc. Theymay be grouped if they the same information.o There are two conflicting methods listed for Water, Organics.o Why are methods from Methods For Chemical analyses of Water and Wasteslisted rather than CLP, which was referenced in the text?o If field and un-filtered samples for TAL metals are to be collected, ther.both should be cleared listed in the table.o Soils, sediments and biota are listed together, but clearly some of theparameters are one matrix or the other.o The soils, sediments and biota section lists EPA 624 for volatiles but thetext states the 500 series.

6. Table 9-1 lists the DL for the TAL and TCL. List the DL for the other methods.

HR300382

;*•-•• •.';* Section:Revision No.: 2Date: 10/30/86Page: 10 of 16

X) Data Reduction, Validation and Reporting Y N NA

Reduction1 - Are units specified for all determinations? ..X.. ..... ....2 - Are equations/procedures used to calculate

concentrations included or referenced? ..X.. ..... ....3 - Are the types of records to be maintained

described, including how and where stored? ..X.. ..... ....4 - Are procedures included for transfer of data

to forms, reports, etc.? ..X.. ..... ....5 - Are procedures for proofing (transcription

errors) and cross-calculation checks included? ..X.. ..... ....6 - Are procedures foi handling blank results

described? ..X.. ..... ....

Validation1 - Are functions and scope specifically defined? ..X..2 - Are techniques presented and summarized? • ..X..3 - Are criteria used to accept or reject data

described in a uniform and consistent manner?(See also Section XI) ..X..

4 - If CLP, does the Plan include provision for datareview using the functional guidelines,qualified review personnel, etc.? ..X..

Reporting1 - Is the flow or reporting scheme from collection

of raw data through storage included? ..X..2 - Are requirements for recordkeeping in field and

lab notebooks described? ..X..3 - Are the key individuals who will handle or report

data identified? ..X..4 - Are examples of forms and reports included? ..X..5 - Does the Plan describe exactly what will be

reported (e.g., QC results, etc.)? ..X..

Comments

AH30G383


Internal QC Checks Y N NA

1 - Does Plan describe procedures for both fieldand lab? ..X.. ..... .....

2 - Are the protocols used (spikes, surrogates,blanks, etc.) described for each parameterand matrix? ..X.. ..... .....

3 - Are acceptance or control limits specifiedfor each? ..X.. ..... .....

4 - Is the frequency of the checks described? ..X.. ..... .....5 - Is it clear whether the intent is to measure

total error/variability or component(sampling/lab) error/variability? ..X.. ..... .....

6 - Are the procedures described for internal QCchecks consistent with the procedures usedto assess precision and accuracy (Section XIV)? ..X.. ..... .....

Comments


XII) Performance and System Audits Y N NA

1 - Are audits addressed for both field andlab activities? ..X.. .....

2 - Does the Plan identify who will conductthe audit(s)? ..X.. ..... .....

3 - Does the Plan describe what protocol willbe used for audits? ..X.. ..... .....

4 - Are acceptance criteria defined? ..X.. ..... .....5 - Doe? the Plan describe distribution of

audit reports? ..X.. ..... .....6 - Is a schedule of audits included? ..X.. ..... .....

Comments

AR300385


XIII) Preventive Maintenance Y N NA

1 - Does the Plan include a schedule ofimportant tasks that minimize downtime? ..X.. ..... .....

2 - Is a critical spare parts list available? ..X..

Comments

AR3Q0386


XIV) Specific SOPs Used to Assess Data Precision, Y N NAAccuracy, Representativeness and Completeness

1 - Relative to the objectives in Section V, doesthe Plan include protocols for monitoringwhether requirements were met? ..X.. ..... .....

2 - Does the Plan include the equations used tocalculate precision, accuracy (bias)and completeness? ..X.

3 - Does the Plan describe the methods used togather information for precision andaccuracy (bias) calculations? ..X.

Comments

AB300387


XV) Corrective Action for Out-of-control Situations Y N NA

1 - Does the Plan include a scheme to:- Identify defects? ..X.. ..... .....- Trace defects to source? ..X.. ..... .....- Plan and implement correction? ..X.. ..... .....- Document results of process? ..X.. ..... .....

2 - Does the Plan include predetermined limits fordata acceptability beyond which correctiveaction is required? ..X.

3 - Are procedures for corrective action (whoinitiates, who approves) included? ..X.

Comments

AR3Q0388


XVI) QA Reporting Procedures Y N NA

1 - Does the Plan specify the type andfrequency of reporting? ..X.. ..... .....

2 - Do the reports address:- Status of project (time table)? ..X..- Results of performance and system audits? ..X..- Data quality assessment? ..X..- Significant QA problem* arid proposed

corrective action? .*. ..X..- Changes in the QAPjP? ..X..

Comments

AR300389

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYRegion III

841 Chestnut BuildingPhiladelphia, PA 19107

SUBJECT: Review of Draft RI/FS Workplan Date: December 3, 1990and Field Sampling Plan for theAladdin Plating SF Site

From: Hindi Snoparsky, GeologistTechnical Support Section (3

To: Pat McManus, RPMEastern PA Section (3HW22)

Noted below are my comments and suggestions.

WORK PLAN

Monitor Well Groundwater p.2-81. It is not clear which phthalates are considered ubiquitous atthis site.2. It is not clear from either the narrative or Table 2-3 whetherthe monitor well samples were filtered for metals.

3.3.2 Preliminary chemicals of concernThe last paragraph on page 3-3 is confusing regarding the numberof on-site monitor wells. There are 16 wells, yet the hits forchromium are described as occurring in 10 out of 15 wells for1989, and 11 out of 13 wells for 1990.

Table 3-4This table would be more useful if it specified the locationswhere the contaminants were detected. It should be noted in thenarrative that contamination below MCL's in home wells may be dueto dilution.

3.3.5 Potential Receptors and Routes of ExposureIt should be noted that the bedrock aquifer is Class IIA.

3.5.1.1 Ground WaterThe primary objective of the investigation should be to quantifywhether the soil remedial action is protective of the aquifer.

AR3U0390

3.5.2.2. Ground Water Collection and TreatmentExtraction wells are not the only alternative for groundwatercollection. French drains are applicable in certain cases.

Soil Sampling p.5-11It is not clear in this discussion that the soil sampling will beconfined to the well borings. The Field Sampling Plan spellsthis out, but the Work Plan does not.

5.3.3 Source Testing p. 5-11 to 5-12The geophysical techniques noted are not appropriate for thedetermination of chemical source characterization. Dan Bostwickagrees with rae on this point and will investigate the intent ofthe narrative here.

5.3.4 Subtask 3.4 Geological/Hydrogeophysical Investigations1. Typo: Figure 4-3, not Figure 4-5, indicates proposed monitorwell locations.2. A diagram containg both proposed and existing monitor wellswould be easier to follow.

4.2.3 Conceptual Site HodelV.' It is not clear why sediment outside of the contaminated area is

a potential source. If the author is referring to potentiallycontaminated soils that were not excavated, this should be noted.Additionally, there seems to be some confusion regarding the useof the terms soil and sediment. The use of these terms should beconsistent with EPA's usage at the site from previous investiga-tions .

4.2.4. RI ObjectivesThere seems to be some confusion regarding the objectives of theRI. As indicated above, the objective should focus on quantify-ing whether the RA will assist in clean-up of the groundwater.The modeling and sampling could be considered to be phase IIIDQO's for this objective.

4.3.2.2 Soil SamplesThe discussion indicates confusion or possibly some unfamiliaritywith MINTEQ's appicability and data needs for the site.

Ground-water SamplingIt is not clear whether all of the analyses listed for ground-water are appropriate. Dan Bostwick is checking into this,especially regarding which specific analyses are important forrunning the groundwater models.

AR300391

Soil Engineering ParametersIt is not clear why soils won't be classified in 100% of thesamples. If the reason is, for example, that split spoons won'tbe taken in both wells of a cluster, this should be noted.

4.3.2.4 Monitor Well SamplingAlter discussion of objectives as noted above.

5.1.5.1 Geophysical ReconnaisanceThe main objective of the refraction survey was to aid develop-mentof the site conceptual model; this should be noted in thefirst sentence.

GROUND WATER SAMPLING PLAN

4.3.2 Purging WellsTurbidity should also be monitored during purging.

4.3.3 Sample CollectionPer our conversation with Dan Bostwick on 12/3/90, the notedchemical parameters will be checked as some of them seem unneces-sary. It seems that some of the parameters for surface water andsediment may have been included in the list by mistake.

4.6 Well Construction, Installation and Development1. Schedule 40 PVC is cheaper than Schedule 80 and may be used inthe bedrock up to 150 feet.

2. The bedrock wells should monitor discrete fractured intervalsthat yield approximately 3 to 5 gpm. As discussed with DanBostwick on 12/3/90, this should be noted in the narrative andclarified in Table 4-1.

3 . It is not clear what " . . . standard procedure for inserting...casings...11 means. The most appropriate guidance on thissubject is EPA's Handbook of Suggested Practices for the Designand Installation of Ground-Water Monitoring Wells by Aller, et alpublished by the NWWA. This guidance is appropriate for most ofthe hydrogeological techniques noted in this Field Sampling Plan.

4. There should be a 2" to 3" annular space between the outerdiameter of the screen and the inner diameter of the hollow stemto facilitate more effective filter pack placement. Tremieplacement is most appropriate, A tamping device should beutilized for both the filter pack and seal to pevent bridging.

5. The description on page 16 regarding emplacement of grout inthe bedrock wells is confusing. Pressure grouting the protectivecasing into the bedrock should be employed. The two methodspresently utilized for pressure grouting are: 1) Haliburton-grout is pumped down the well via rubber plug at bottom of well;grout is displaced into the annulus; the grout and rubber plugleft in the bottom of the hole are drilled after overnight set-up; and 2) A packer with attached tubing is placed near thebottom of the well through which grout is emplaced; after theannulus is sealed, the packer is released and pulled out of thehole. The remaining plug is drilled after overnight set-up.

6. It may be warranted to use formation water, if possible, forsurging in order to avoid alteration of ground-water chemistry.

4.7.2 Slug TestsIf the bedrock is confined in specific areas of the site (theauthor referred to the overburden as perched, which impliesconfinement of the bedrock), then Bouwer (1989), which is an"altered" version of for confined aquifers may be appropriate.The cite: Bouwer (1989) The Bouwer and Rice Slug Test - An UpdateGround Water:vol 27, no. 3, pp. 304 - 309.

4.9 Ground Water Modeling1. Better documentation regarding the use of HINTEQ and MULTIHEDis needed. This information will help determine which additionalfield measurements are necessary at the site.2. I am uncertain as to whether the KELP model is appropriate fordetermining infiltration rates at the site. -

4.7.3 Pump Test1. A step test should be performed as part of the pump test inorder to ascertain the proper pump rate for the test.2. The pump test should be run to equilibrium; this is moreimportant than.either the time period or the amount of water inthe well.

cc: Dick BrunkerBob Davis

AR300393

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYRegion III

841 Chestnut BuildingPhiladelphia, PA 19107

DATE: December 3, 1990

SUBJECT: A review of the toxicological aspects of the Work Planconcerning the Aladdin Plating Superfund faci]

FROM: Richard L. Brunker Ph.D. Senior ToxicologTechnical Support Section, (3HW15)

TO: Pat McManus, RPMEastern PA Section,(3HW15)

Attempts to review this document were hindered by a dearth ofreferences and a failure to demonstrate an awareness of theavailability of the latest guidance documents regarding theassessment of risk, exposure assumptions, and environmentalimpacts. It should not be necessary for the Agency to provide vastamounts of guidance to those who are presented as experts in thesefields.

This review of the proposed offering attempted to focus on mattersdirectly related to the execution of a baseline risk assessment.Little was offered concerning toxicology and environmental impactsand that which was offered was not from experts in these respectivefields. In support of the foregoing, the following is noted:

Page 5-15, last paragraph;The narrative indicates that the risk assessment results will bepresented separately for the "average plausible exposure case" andthe "maximum plausible exposure case" assumptions. This is not inconcord with the current guidance that has been in practice for thepast year and is delineated in the Risk Assessment Guidance forSuperfund, Volume 1, Human Health Evaluation Manual (Part A)December 1939 nor was this manual cited anywhere in this document.This guidance document clearly states that for Superfund exposureassessments intake variable values for a given pathway should beselected so that the combination of all intake variable results inan estimate of the reasonable maximum exposure for the pathway.The reasonable maximum exposure (RME) is the maximum exposure thatis reasonably expected to occur at a site. There is no provisionfor any other exposure scenario.

flR30039l*

There is ho indication concerning how any other contaminants ofconcern are to be identified as the remedial investigationprogresses. Again no references are provided in this regard. Theauthors appeared to be totally unaware of the need for guidancefrom the Superfund Exposure Assessment Manual (1988), the ExposureFactors Handbook (1989), the Exposure Assessment Methods Handbook(1989), the IRIS database, the Environmental Evaluation Manual(1989), or any of the other guidance documents available for thesetasks.There is no attempt to utilize any analytical methodology otherthan the CLP in this proposed investigation despite theavailability of the ARCS field vans in the near future. Theexclusive use of CLP analytical options is a very expensive andtime consuming default option and, considering recent revelationsregarding apparent illegal practices by some of these facilities,claims that they provide high quality data are not supported bythe facts concerning their performance.

On page 3-3, first paragraph, the narrative indicates that nosignificant contamination was found in the residential wells.However TABLE 2-1 reveals that eight homewells contain lead levelsthat exceed the current interim action level of 15 ppb (OSWERRecommendation dated Jun 21 1990). Despite claims to the contraryin the document, lead in the groundwater appears to be acontaminant of concern at this facility.

Table 3-1 provides data from both filtered and unfilteredmonitoring well samples, but no explanation is provided regardingprecautions that must be taken in their interpretation. This isan "apples versus oranges M situation.

We are provided with no insight as to just how the hazards fromlead. contamination is to be addressed. This is of significancesince there is currently no reference dose (RfD) or slope factorfor this element.

In section 4.3.2.1 SURFACE WATER AND SEDIMENT SAMPLES, an ambitiousanalytical scheme is proposed. TABLE 4-1 also lists the proposedanalyses to be carried out. There are numerous differences betweenthese two information sources concerning proposed analyticalprocedures. In any case, much of what is proposed are analysesthat are normally employed in order to determine -the effectivenessof a POTW in the removal of contaminants from domestic sewerage andserve no purpose in this study. While it is appreciated thatspecific instructions were provided for environmental-relatedanalytical work, analyses for ammonia, nitrogen, chloride,phosphate, sulfide, and sulfate in surface waters serve no usefulfunction in a remedial investigation for a hazardous waste facilityand would be a waste of time and money. The fact that theseinappropriate analyses were proposed is worrisome and indicatesthat those qualified primarily in sewage treatment technology are

attempting to use this inappropriate technology in the planning ofa remedial investigation of a hazardous waste facility. Theservices of a qualified Ph.D. toxicologist are necessary in thisregard. We should be assured that this will be done before thestructuring of the baseline risk assessment.

We are informed that groundwater samples will also be subjected toa sampling regimen including BOD, COD, TDS, TOG, TSS, and otherparameters that, without a doubt, would be a waste of time andmoney. Clearly, unqualified professionals are responsible for thiscontribution to this document. There is a critical need for aqualified toxicologist in the structuring of this work plan.

cc: Mindi SnoparskyBob Davis

dec 17 -990this work plan. 11. page 3-3, par. 3.3.2 - discuss the significance of the monitoring...

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