I I

\ , FINAL PHASE I"̂̂ FIELD OPERATIONS PLAN

, CROYDON TCE SITE RI/FS! BUCKS COUNTY, PENNSYLVANIA

OCTOBER 1987

AR300137

EBASCO SERVICES INCORPORATED ________________________EEAECOj C-e Oxford 'Alley. Sune 414 Langnorne. PA 19CK7--829. (215) 752-02:2

I October 22, 1937RM/III/37-0303Response Required

Mr. Harry HarboldEnvironmental Protection AgencyRegion III341 Chestnut StreetPhiladelphia, Pennsylvania 19107

Subject: REM III PROGRAM - EPA CONTRACT NO. 63-01-7250WORK ASSIGNMENT NO. 124-3LM7CROYDON TCE SITE RI/FS, BUCKS COUNTY, PAFINAL PHASE I FIELD OPERATIONS PLAN_________

Dear Mr. Harbold:

Enclosed for your review are four (4) copies (3 bound and 1unbound) of the Final Phase I Field Operations Plan (FOP) for \the Croydon TCE Site RI/FS. The FOP consists of the Site . )Management Plan (SMP), the Field Sampling and Analysis Plan —̂'(FSAP), and the Health and Safety Plan (HASP). Commentssubmitted by the EPA Central Regional Laboratory (CRL) havebeen incorporated into this FOP. Additionally, modificationsto the sampling and analysis program are reflected in this .report.

If you have any questions or comments regarding thisdocument, please feel free to contact me or our Site Manager,Mr. Raymond P. Wattras at (412) 733-1030.

Very truly yours,

'Richard C. Evans, P.E.Regional Manager, Region III

RCE/DEM/slkEnclosures

I cc: 3. Del Re EPA, Region III ADOnnl^ft ^. 'P. Krantz EPA, Annapolis . AKOUUIdU ,1. I M. Yates ZPMOI M. Amdurer ZPMO1 A. Bomberger NUS

R. Wattras NUS "

OCTOBER 1987

IFINAL PHASE I FIELD OPERATIONS PLAN

I

• CROYDON TCE SITEBUCKS COUNTY, PENNSYLVANIA

I EFA WORK ASSIGNMENT NUMBER 124-3LM7UNDER

_ CONTRACT NUMBER 68-01-7250

i , PREPARED BY:^̂ NUS CORPORATION• PITTSBURGH, PENNSYLVANIA

• APPROVED BY:EBASCO SERVICES INCORPORATED

I LANGHORNE, PENNSYLVANIA

II

PREPARED BYs APPROVED BY:

RAYMOND P WATTRAS ' ^ V^RiCHARD C EVANS, P.$R3UUJ 39SITE MANAGER REGIONAL MANAGER, REGION IIINUS CORPORATION EBASCO SERVICES INCORPORATED

TABLE OF CONTENTS

I SECTION

1.0 SITE MANAGEMENT PLAN

I 2.0 FIELD SAMPLING AND ANALYSIS PLAN

3.0 HEALTH AND SAFETY PLANI

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FINAL SITE MANAGEMENT PLAN O*

I CROYDON TCE SITE RI/FSBUCKS COUNTY, PENNSYLVANIA

I OCTOBER 1937

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( . ' ' . BR300U2 )

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TABLE OF CONTENTSi

SECTION - . >AGE

1.0 SITE CONTROL 1

1.1 SITE ACCESS 1

1.2 SITE SECURITY/CONTROL . 6

I 1.3 FIELD OFFICE/COMMAND POST 6

2.0 SITE OPERATIONS 7

I 2.1 ORGANIZATION " 7

2.2 RESPONSIBILITIES OF KEY PERSONNEL . . 7

1 2.3 SCHEDULE 10

I FIGURES

NUMBER • PAGE

2-1, PROJECT ORGANIZATION 7

2-2 . FIELD OPERATIONS TEAM , 8

TABLES

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NUMBER PAGE

1-1 PROPERTY OWNERS - SITE ACCESS 2

AR300U3

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IL- 1.0 SITE CONTROL

1.1 SITE ACCESS

' The Croydon TCE Site covers a 4-square mile area (referred to asthe "study area") in Bristol Township, Bucks County,

> Pennsylvania. This study area is comprised of severalresidential communities and has an estimated population between2,000-3,000 residents. Several small-to-large scale industriesare also located within the study area. There are no physicalfeatures that would hamper site access; however, because thestudy area is mostly residential, property owners will have tobe contacted prior to entering various properties.Site access will be arranged prior to initiating the Phase I RIfield activities. These activities include drilling andmonitoring well installation, residential well sampling, surfacewater and sediment sampling, and soil sampling. Table 1-1identifies the various property owners that will be affectedduring the Phase I field activities.No REM III personnel shall enter the properties without firstmaking their presence known to the property owners. Propertieswhich are owned by various corporations (or businesses) will be

1 contacted by the REM III Site Manager or designee, through theEPA Region III Regional Project Manager (RPM), to. gain \

t permission for site access. Anticipated field dates will be \^JV given to the appropriate corporate contacts (i.e.; Works

Manager, security guards). Additionally, homeowners who willhave their residential wells sampled will be contacted by the SM

' or designee to obtain site access and arrange a suitable timefor collecting the well sample.In addition to notifying the property owners of the REM IIITeam's presence, no REM III Team member will enter the siteuntil: (1) written or verbal authorization is received from theSits Manager or designee, (2) at least 24-hour notice is givento the RPM before initiation of field activities, and (.3) eachfield team member possesses personal identification in the formof a driver's license, company identification card, or asuitable substitute approved by the Field Operations Leader(FOL). A list of persons authorized to enter the site will beprovided to the RPM by the Site Manager or the FOL. The list isintended to prevent unauthorized persons from gaining siteaccess. The list will be updated, as necessary, by the SiteManager or his designee. In gaining site access, no REM III

, Team member will sign or acknowledge any documents unlessapproved by the Site Manager. The Site Manager will contact the

1 RFM and EPA RPM prior to signing any document presented to aREM III Team member by a property owner.

1( RR300U1* J)

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TABLE 1-1PROPERTY OWNERS - SITE ACCESS

CROYDON TCE SITE

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Property Owners

Ovens-Illinois Corp.

Coyne Chemical

Rohm fi Baas Company

M,E. Tryon*

Bristol Cemetary Company

Robert J. Sabatini

Robert B. andDorothy Robinson**

Joseph Francis

Marie O'Brien

Barry and Nancy Updike

John Kotx .

Bosak Residence***

Location

State Road, Croydon(parcel No. 5-54-16) Contact: BillWaldron 788-7846State Road, Croydon(parcel No. 5-58-2-3) Contact: JohnWe i roan 785-3000CroydonContact: BobOlarnic 785-8219U.S. Route 13,(parcel No. 5-13-236)

U.S. Route 13,(parcel No. 5-58-1)Linton andMontgomery Avenue(parcel No. 5-12-77) Contact: RobertSabatini 786-5571

State Road andElm Street -(parcel No. 5-54-49)2056 Bigh Street788-4100

1905 Summit Avenue788-5726

2920 West Avenue788-8967

413 Linton Avenue .788-9647

2055 Bigh Street788-1225 ...

Remarks

Proposed monitoring veillocations Nos. 1, 5 and 6

Proposed monitoring veillocation No. 3

Proposed monitoring veillocation Nos. 4, 8, 9, 10,11, and 15Proposed monitoring veillocation Nos. 2 and 13

Proposed monitoring veil .location No. 14

Proposed monitoring veillocation No. 12

Proposed monitoring veillocation No. 7

Proposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsample

AR3UUI4b

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TABLE 1-1PROPERTY OWNERS - SITE ACCESS

I CROYDON TCE SITE1 PAGE TWO

Property Owners

John Boyd Jr.

James and Patricia Bein

George R. Hamilton

Conrad Raddi

Joyce Ritter

Joseph Cochran

Charles B. Rusk

Jean I. Lovden

Barry J. Gilbert

Christian S. Sautter, Jr.

Ralph 0. Hitman, Sr.

Edward Zeauskas

Arthur J. Dustman, Jr.

Barry I. Foster

Edward Conwell

Irene Grzecikowski

Pauline Gagne

Location

515 ExcelsiorAvenue 788-03251909 Summit Avenue788-3591401 Linton Avenue788-4914

2323 Maple Avenue785-6362

2319 Maple Avenue785-2339

211 Elm788-1019

1901 Summit Avenue788-1627

2311 Maple Avenue785-4334

1311 SycamoreAvenue 785-0867

1019 Emily788-6931

2314 BrightonAvenue 785-1361

2310 Maple Avenue785-4279

2030 Bigh Street785-3352

1601 River Road788-0341

3017 West Avenue788-1537

914 BelleviewAvenue 788-3425817 Girard Avenue788-5639

RemarksProposed residential wellsampleProposed residential yellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsample

Proposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential well .sampleProposed residential wellsampleProposed resident^ ft^QU 1sample

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TABLE 1-1PROPERTY OWNERS - SITE ACCESSCROYDON TCE SITEPAGE THREE

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Property OwnersRalph and DebbieVanderploegK -Metal Fabrication

Joe and CatherineAndrescavageFrancis and Elsie Clark

Alexander and JudithJohnsonH&H Foreign Car Service

Donald Patent

William G. Keller

Michael Postovski

William Surrick

Paul Kervick

John D'Amico

Lillian Bunter ' '

Walter Thomas

Raymond and Edith Dudek

Charles A. Lehr, Jr.

Barry C. Brown

Richard Coates

Location306 Franklin Avenue788-5651300 Linton Avenue788-55402916 LansdovneAvenue 788-14542401 Brighton •Avenue 788-1316922 Orchard Avenue785-6455Route 13 and PennStreet 781-0233400 Grant Avenue788-1658841 Keystone Street788-8271603 Grant Avenue788-78991028 Rosa Avenue761-0861209 Linton Avenue788-14302208 Garf ieldStreet 785-48851612 PennsylvaniaAvenue 788-8739400 Main Avenue788-35792925 West Avenue788-1463812 Keystone Street788-7569301 Elm Street788-5060401 Elm Street788-6675

RemarksProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsample 'Proposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residential veilsampleProposed residentialnVfHfi 1sample RKOUU 1

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TABLE 1-1PROPERTY OWNERS - SITE ACCESSCROYDON TCE SITEPAGE FOUR

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Property OwnersHugh Templeton

Pan Denner

Martin Mellor

Frank Bayden

Mr. and Mrs. Miller

Robert Ward

Barbara Bigginson

Marianne and Paul Ditzel

Christine Blade

J. R. Farrell, Jr.

David Grafenstein

Location204 Elm Avenue788-90371188 Bristol Pike781-9368700 Browns Lane788-11721933 Bristol Pike785-5386Cedar Avenue(Miller's TrailerPark) 337-8874700 Emily783-5602611 Sixth Avenue788-10093505 Rock view Drive788-2339619 Sixth Avenue785-06913004 West Avenue788-3356803 Girard Avenue788-0129

RemarksProposed residential wellsample .Proposed residential wellsampleProposed residential wellsample-Proposed residential wellsampleProposed residential wellsample

Proposed residential wellsampleProposed residential wellsample •Proposed residential wellsampleProposed residential wellsampleProposed residential wellsampleProposed residential wellsample

* M.E. Tryon resides at 619 Cedar Avenue, Croydon, Pennsylvania.-** Robert B. and Dorothy Robinson reside in South Hampton, Pennsylvania.*•* This property is owned by M. E. Tryon.

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RR300U8J

/ 1.2 SITE SECURITY/CONTROL\ t ,

i All removable equipment will be returned to the command post andI secured at the end of each work day. Any equipment (i.e.,1 drilling rig) left on site will be secured to the extent

possible to prevent unauthorized removal or vandalism. Any1 unfinished wells will be covered or capped in such a manner-as

to prevent tampering. Finished wells will be locked.

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1.3 FIELD OFFICE/COMMAND POST

A field-office trailer will be mobilized on site prior to theinitiation of any field activities. The office trailer willserve as a central command post through the duration of thefield investigation/ providing communications, shelter, officespace, sanitary facilities, and.space for equipment storage andsample handling. Permission has been granted by Rohm & HaasCompany to mobilize the field trailer onto their property. Thefield trailer will be stationed adjacent to the biologicaltreatment plant. A key to unlock the entrance gate will begiven to the FOL. Rohm £ Haas plant security will lock the gateafter normal working hours. It will not be necessary tocheck-in to the plant security every time you enter theirproperty; however, it is recommended that you call plantsecurity from the office trailer at the start and finish of eachworking day. The telephone number is 215-785-8000.

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\r 2.0 SITE OPERATIONS \V v J *

IThe following subsections outline the organization of the fieldteam for the Croydon TCE Site Phase I Remedial Investigation(RI) field activities, the responsibilities of key personnel,and the schedule for performance of the RI field work.2.1 ORGANIZATION

The overall project organization and responsibilities of keymanagement personnel are discussed in Section 6.0 of the RI/FSWork Plan. The organizational chart presented in Section 6.0 isreproduced as Figure 2-1 for easy reference.Field work will be performed by a single team under thedirection of'the FOL. As shown in Figure 2-1, the FOL reports

1 directly to the RI Task Manager. Figure 2-2 shows the fieldoperations organization in greater detail. The FOL will beresponsible for coordinating and overseeing all field activitiesand will interface with the Health and Safety Officer (HSO) in

i planning and performing the RI tasks. Each of the Field TeamLeaders (FTLs) designated for the site RI activities will reportto the FOL on a day-to-day basis. In accordance with the Health

. and Safety Plan (HASP), the HSO or his designee will interact> with the field team members during performance of their tasks.I, 2.2 RESPONSIBILITIES OF KEY PERSONNEL |)

Key personnel for field operations are identified in Figures 2-1and 2-2. Their specific responsibilities are discussed below.

• Field Operations Leader (FOL). The FOL or designee isresponsible for all day-to-day aspects of the CroydonTCE Site RI field work. The responsibilities of the FOLinclude:

Assuring that all field team members are familiarwith the Field Sampling and Analysis Plan (FSAP)and HASP.

Assuring that all field team members have completedhealth and safety training.

- Reporting to the RI Task Manager on a regular basisregarding the status of all field work and anyproblems encountered.Completing Field Change Requests, as necessary, forapproval by the Site Manager.

- Coordinating the activities of all field teams.' AR300I50 .1

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AR300151

FIGURE 2-2FIELD OPERATIONS TEAM

CROYDON TCE SITE

FIELD OPERATIONS LEADER

S BARXICE

BEALTH AMD SAFETY OFFICER

K BRADT

'( DRILLXKG MONITORINGHELL SAMPLINGAQUIFER TBST1VG

7XKLO TEAM LEADERS BARHICK

SOIL SAKPLZVGRESIDENTIAL HELL

SURFACE HATER AMD SEDIMENT SAKPLIM6

FIELD TEAM LEADERJ. BEHTLET

FIELD TEAK

GEOLOGISTS, EXGIKEERS, TECBHICIAHS

I AR300152 \( - ~̂/sI

j • Field Team Leader (FTP. The FTL reports directly tothe FOL and has the following responsibilities:

I - Providing team members with daily assignments.Assuring that team members comply with theprocedures outlined in the FSAF.

- Coordinating with the FOL to ensure sample shippingschedules are met.Reporting or. a daily basis to the FOL on theprogress of the team.

f v • '. " • •-.• • - . .'•• Health and Safety Officer (HSO). The HSO reports to the

Company Health and Safety Supervisor (CESS) and! indirectly to the FOL and Site Manager. Details of the! HSO's responsibilities are presented in the HASP and

include: .Controlling specific health and safety relatedfield operations such as personnel decontamination,monitoring of worker heat or cold stress,distribution of safety equipment, etc.

, - Assuring that field team personnel comply with all.f -,. procedures established by the HASP.^-^ - Identifying assistant HSOs or HSO designees.

Terminating work if an imminent safety hazard,emergency situation, or other potentially dangerous •situation is encountered.

• Regional Laboratory Sample Coordinator (RLSC1. The RLSCis responsible for the following:

; - Scheduling laboratory service through SMO and othervendors.Tracking camples and coordinating with EPA CRL.Scheduling data validation.

, - Identifying laboratory analytical methods andlaboratory QC.

• AR300153f " .- — —

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f 2.3 SCHEDULE \( • • . , y

The schedule for the Croydon TCE Site RI field activities isI presented rin Section 6.3 of the Phase I RI/FS Work Plan. Key' target dates are:

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Mobilization*Drilling and Monitoring HellConstruction (includes aquifertesting)Groundwater Sampling (residentialwells)Soil SamplingSurface Water and SedimentSamplingGroundwater Sampling (Rohm & HaasHells)Groundwater Sampling (REM IIImonitoring wells)SurveyDemobilization

Anticipated Dates

Start10/710/19

10/19

11/911/10

11/12

12/7

12/1412/18

End

10/1612/18

11/6

11/911/11

11/18

12/11

12/1812/23

•includes obtaining site access

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AR300I55

1i JIII

FINAL PHASE I FIELD SAMPLING AND ANALYSIS PLAN

CROYDON TCE SITE RI/FSBOCKS COUNTY, PENNSYLVANIA

OCTOBER 1987

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* TABLE OF CONTENTS

| SECTION ' ' PAGE

1.0 INTRODUCTION 1

I 1.1 SITE DESCRIPTION 1

i 1.2 PREVIOUS INVESTIGATIONS AND FINDINGS 4

1.3 OVERVIEW OF FIELD ACTIVITIES 4

I 2.0 GENERAL FIELD OPERATIONS 7

2.1 MOBILIZATION ACTIVITIES * 7

I 2.2 FIELD TEAM PERSONNEL AND RESPONSIBILITIES 7

• 2.3 PERSONNEL PROTECTION 7

" 2.4 FIELD TECHNICAL GUIDELINES 7

I 2.5 SAMPLE IDENTIFICATION AND CHAIN OF CUSTODY 82.6 SAMPLE CONTAINER REQUIREMENTS AND 10

HOLDING TIMES

2.7 SAMPLE PACKAGING AND SHIPPING 10

j 2.8 DOCUMENTATION . 14

2.9 FIELD AUDITS 14

I 2.10 PROCEDURES FOR FIELD CHANGE AND 14CORRECTIVE ACTION

I 2.11 FIELD INSTRUMENTATION 14

3.0 DATA QUALITY OBJECTIVES 16

I 4.0 DRILLING AND MONITORING WELL INSTALLATION 27

I 4.1 NUMBER OF WELLS AND LOCATIONS 27

4.2 DRILLING^OPERATIONS . 27

| 4.3 MONITORING WELL CONSTRUCTION/INSTALLATION 29

4.4 WELL DEVELOPMENT 32

4.5 DECONTAMINATION

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I TABLE OF CONTENTS (CONTINUED) ,,)

SECTION PAGE

4.6 AQUIFER TESTING 34

4.7 WATER LEVEL MONITORING 34

4.8 REPORTING - 34

5.0 PHASE I RI SAMPLING PROGRAM 36

5.1 GROUNDWATER 36

5.1.1 MONITORING WELLS ' 36

5.1.2 RESIDENTIAL WELLS 36

5.1.3 SAMPLING METHODS 37

5.2 SURFACE SOIL SAMPLING 40i . . . . . . . -4 5.2.1 NUMBER OF SAMPLES AND LOCATIONS 40

•( 5.2.2 SAMPLING METHODS 40 _̂y

5.3 SURFACE WATER AND SEDIMENT 40

i 5.3.1 NUMBER OF SAMPLES AND LOCATIONS 40

5.3.2 SAMPLING METHODS 40•

1 5.4 DECONTAMINATION 43

5.5 REPORTING 43

6.0 SURVEYING 44

APPENDICES

A REM III PROGRAM FORMSB METHOD PRECISION AND ACCURACY INFORMATION

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' TABLES

NUMBER • : . . . • PAGE

• 2-1 SUMMARY OF ANALYTICAL PARAMETERS, BOTTLE 11REQUIREMENTS, PRESERVATION REQUIREMENTS,

j AND HOLDING TIMES BY MEDIA

3-1 CRITERIA AND DATA COLLECTION ACTIVITIES 17I FOR MEETING THE PHASE I RI/FS OBJECTIVES

' 3-2 SUMMARY OF SAMPLING AND ANALYSIS PROGRAM 20

4-1 ESTIMATED MONITORING WELL CONSTRUCTION DETAILS 29

FIGURES

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• 1-1 LOCATION MAP - .' 2

j 1-2 GENERAL ARRANGEMENT 3

4-1 PROPOSED MONITORING WELL LOCATIONS 26

Ŝ y 4-2 PROPOSED WELL CONSTRUCTION DETAILS 28

4-3 FLUSH MOUNTED PROTECTIVE CASING INSTALLATION 31

1 4-4 PROPOSED RESIDENTIAL WELL SAMPLING LOCATIONS 36

f 4-5 PROPOSED SURFACE SOIL SAMPLING LOCATIONS 39* " ' • ' ' • ' . - .

4-6 PROPOSED SURFACE WATER AND SEDIMENT SAMPLING 404 LOCATIONS . . . . . . . .

flR300IS9

1.0 INTRODUCTION ,

This Field Sampling and Analysis Plan (FSAP) for the Croydon TCESite, Bucks County, Pennsylvania, is an integral part of thePhase I Remedial Investigation/ Feasibility Study (RI/FS) WorkPlan. Whereas the work plan develops the RI/FS objectives andscope, and defines what activities will occur, the FSAPconcentrates on how the various activities will be performed.Additionally, the FSAP identifies the sampling and analyticalobjectives, detailed sampling procedures, and Quality Assurance/Quality Control (QA/QC) requirements for sample collection,handling, and shipping. In the interest of continuity, some ofthe information from the work plan is repeated in this document.The emphasis, however, is to avoid repetition by the liberal useof references to the work plan.1.1 SITE DESCRIPTION

The Croydon TCE Site is located in Bristol Township, BucksCounty, Pennsylvania (Figure 1-1). Sampling of residentialwells and surface water in this area detected elevated levels oftrichloroethene (TCE), tetrachloroethene (PCE), and otherorganic and inorganic contaminants. The source of thiscontamination has not yet been defined and therefore a siteboundary has not been established. (A review of the HazardRanking System reference documents revealed no description of a >site boundary or a source of contamination.) However, a \^jboundary for this investigation has been established and will bereferred to as the "study area." This area encompassesapproximately 4 square miles and is depicted in Figure 1-2.As shown in Figure 1-2, the study area is bordered byInterstate 95 to the north, the Rohm & Haas Company property andthe Delaware River to the south, Neshaminy Creek to the west,and Route 413 to the east. The Rohm & Haas Company propertycontains a landfill which is under investigation by EPA forallegedly contaminating the groundwater beneath the landfillarea (i.e., south of River Road). The Croydon TCE Site RI/FSwill focus on the area north of the Rohm & Haas property sinceEPA is currently studying the landfill area and efforts would beduplicated. Additionally, there is evidence that thegroundwater contamination in the Croydon community is not theresult of the Rohm & Haas landfill.The geology of the Croydon TCE Site consists of unconsolidatedsand, gravel, silt, and clay deposits overlying raetamorphicbedrock. Unconsolidated deposits within the study area consistprimarily of glacial outwash which is overlain by a thin veneerof alluvium. The outwash deposits are generally erratic anddiscontinuous, and are made up primarily of sand and gravel withminor amounts of silt and clay. Cobble zones have been found inwell borings south of the study area. There is a gene5̂ o$4Aint n \upward trend to the outwash deposits. Alluvium fori

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veneer overlying the outwash deposits and consists of primarilyy fine-grained deposits.

j Several monitoring' wells have been drilled in the study areaduring investigations of the Rohm & Haas landfill, which islocated between River Road and the Delaware River. The boringlogs for the wells confirm the expected geologic conditions inthe unconsolidated deposits, as described in this section.Total thickness of the unconsolidated deposits in the wellborings ranged from 40 to over 65 feet. Depths to groundwaterwithin the alluvium are expected to range from 5 to 20 feet.I

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Bedrock underlying the unconsolidated deposits is described asthe Wissachickon Schist, a metamorphic rock unit described asbeing gneissic to schistose in character. The bedrock surfaceis irregular, and has an overall regional slope to thesoutheast. Local information suggests -that a low bedrock ridgeis present immediately south of the study area, resulting in alocal northeast slope of the bedrock surface in the southeasternpart of the study area, contrary to the regional trend.A more detailed description of the site can be found inSection 2.0 of the Croydon TCE Site Phase I RI/FS Work Plan.1.2 PREVIOUS INVESTIGATIONS AND FINDINGS

/ Please refer to Section 3.1 of the Croydon TCE Site Phase IV RI/FS Work Plan.

1.3 OVERVIEW OF FIELD ACTIVITIES

Various field investigations will be conducted to collect datato meet the Phase I RI/FS objectives (see Section 3.0 of theWork Plan). Provided below is a brief description of -theactivities that will be conducted during the Phase I RI at theCroydon TCE Site. A detailed description of these tasks isgiven in Sections 4.0 and 5.0 of this FSAP.Evdroqeoloqic Investigation - .

• Install 29 monitoring wells to delineate the knowngroundwater plume in the southeastern portion of thestudy area and to assess the effects _ of 10 potentialsource areas on the groundwater. .

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• Collect one round of samples from all newly installedI REM III monitoring wells (29) and 19 existing Rohm & HaasI wells. All samples will be analyzed for volatiles via .1 EPA Methods 601 and 602 (special analytical services)

through the Contract Laboratory Program (CLP).• Approximately 20 percent (10 samples) of the samples .will

be analyzed for base/neutral and acid extractable

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organics (B/N/A), pesticides, TCL inorganics and water \quality parameters. ^_j

• Perform in-situ hydrogeologic conductivity tests on thenewly-installed REM III wells and the 19 existing Rohm &Haas monitoring wells. At least two complete rounds ofwater level measurements will be taken on all newly-installed REM III monitoring wells and selected Rohm &Haas monitoring wells. Staff gauge measurements from HogRun Creek will also be taken. This data will be used tocharacterize the local hydrogeology of the site.

• Continuously record water level measurements at fiveREM III monitoring well locations in order to analyzetidal influence at the site. Water level recorders willbe positioned at well locations 1, 3, 9, 12, and 15.Water level measurements will be recorded for a 1-weekperiod.

Surface Water and Sediment Investigation •• Collect 22 surface water and sediment samples from

surface waters near the study area. These surface watersinclude: the Delaware River, Neshaminy Creek, Hog RunCreek, a pond which discharges into Hog Run Creek, andvarious intermittent streams within the study area. .

• Analyze the samples for volatile organics (EPA

• Submit approximately 20 percent (10 samples) of theresidential well samples to CLP for analysis ofsemi-volatile organics, pesticides, TCL inorganics (RAS),and water quality parameters (SAS).

The Data Quality Objectives (DQOs) for each sampling activityare discussed in Section 3.0.

AR300I65

2.0 GENERAL FIELD OPERATIONS

2.1 MOBILIZATION ACTIVITIES

Following the approval of this FSAP, arrangements will be madeto schedule and identify field sampling technicians, obtainsampling and health/safety equipment, review this FSAP andapplicable REM III Program Field Technical Guidelines (FTGs)with the candidate investigation team, and assist EPA withgaining site access. Mobilization activities will also includethe transport of the field office trailer to the site. Theoffice trailer will be located on the Rohm & Haas Companyproperty in order to avoid vandalism. Telephone and electricalhookups will be acquired through the proper authorities.2.2 FIELD TEAM PERSONNEL AND RESPONSIBILITIES

The overall project organization and responsibilities of keypersonnel are discussed in Section 6.0 of the Phase I RI/FS WorkPlan. The onsite direction of the Field Team will be theresponsibility of the Field Operations Leader (FOL) who willreport directly to the RI Task Manager. The Health and SafetyOfficer (HSO) will interact with Field Team members regardingonsite activities. Section 2.0 of the Site Management Plan(SMP) presents the names and responsibilities of key Field Teampersonnel and displays the Field Team organization (SMP,Figure 2-2).

2.3 PERSONNEL PROTECTION

A site-specific Health and Safety Plan (HASP) has been preparedas part of the Field Operations Plan (FOP). The HASP requires.personal protection Level D be utilized during field activities.Section 8.2 of the HASP, Personal Protection, providesadditional details. Section XI of the HASP details personaldecontamination procedures.2.4 FIELD TECHNICAL GUIDELINES

The following Field Technical Guidelines (FTGs), developed forthe REM III Program, will be referred to as guidance during thePhase I RI at the Croydon TCE Site.

FT-3.03 Sampling Station Location and Elevation SurveysFT-4.01 Geological CharacterizationFT-6.06 In Situ Hydraulic Conductivity Testing

Piezometric Head Measurement and GroundwatarContour Mapping

FT-7.02 Groundwater Sample AcquisitionFT-7.03 Soil and Rock Sample AcquisitionFT-7.04 Management of Sampling and Preparation of ^̂ uiJEsdi c.c

Forms A n o U U i o

I •7-

FT-7.05 Sample Identification and Chain of Custody_̂s' FT-7.06 Sample Preservation, FT-7.07 Sample Packaging and ShippingI FT-7.08 Surface Water and Sediment Sampling1 FT-7.10 Onsite Water Quality Testing

FT-12.01 Decontamination of Chemical Sampling and Field| Analytical Equipment' FT-13.01 Preparation, Approval, and Submittal of Periodic

Field Report (Section 5.3 only)i FT-13.02Forms Used in RI Activities (Section 5.1 only): FT-13.03Site Logbook

HS-1.02 DecontaminationHS-1.06 Control of Contaminated MaterialHS-1.12 Incident Investigation and Reporting

These guidelines are not meant to be taken verbatum since fieldconditions often necessitate modifications or deviations from aparticular procedure. For example: groundwater evacuation(purging) can be conducted in several ways, depending on thefield conditions. If the water level is high (i.e., less than15 feet from the top of casing), a suction pump would probablybe used. However, if water levels in the well are low (i.e.,50 feet below the top of the casing), then a bailer would haveto be used. The FTL or FOL should use his/her best judgement onhow a particular sample shall be taken, or how a certain pieceof equipment is decontaminated, using the FTG as areference/guidance. For instance: one would not expect toperform a 7 or 8-step decontamination procedure on an M-scopeduring well construction. A simple cleaning with deionizedwater would suffice under those conditions. The point is thatthe FTGs are to be used as a reference/guidance for undertakingthe RI field activities. The field notebooks (and associatedforms) shall document the actual procedure used in the field.A copy of the above FTGs will be made available and secured inthe field office trailer, along with a copy of the Final FOP. Ameeting will be held with the Field Sampling Team to review theabove FTGs as part of the mobilization activities.2.5 SAMPLE IDENTIFICATIONS AND CHAIN OF CUSTODY

II

II Sample identification and chain-of-custody procedures are

outlined in FT-7.05. Each sample will have its own number,( w h i c h will apply during the entire project. Each sample number

will consist of a four-faceted alpha-numeric code, which willidentify the site, the type of sample, the sample location, the

I number in the series at the location, and whether the sample is| a duplicate or a blank.

' RR300I67r ' . •• . ""•"..-'•i • •. "* • :

The site code for the Croydon TCE Site is CR. The sample typesare .

RW - Residential WellMW - Monitoring WellSO - Surface SoilSD - SedimentSW - Surface WaterFB - Field BlankTB - Trip BlankBB - Bottle Blank

Each location will have the sampling station number (i.e.,MW2(S), SW21, SOS, SD20, etc.) followed by the Series number(the series number would identify the number of samples obtainedfrom a particular sampling station). For example, the firsttime monitoring well Number MW-9(S) is. sampled, the number forthe sample shall be .

CR-MW9(S)-1

If it is sampled again at another period in time, the samplenumber would become

CR-MW9(S)-2

For duplicates, a letter designation will be . used for theduplicate sample. For example, the duplicate of CR-MW9(S)-1will be

CR-MW9(S)-1A

If a duplicate is taken at that point again, the number wouldbecome

CR-MW9(S)-2A

Field blanks will be designated by sample type followed by "FB.MFor example, the first field blank for each medium would be:

CR-MWFB-1

Bottle blanks will be designated by sample type followed by"BB.H For example, the first bottle blank for groundwater wouldbe:

CR-MWBB-1 .

! AR300168I - - - - -II . * ' ' ••

ITrip blanks shall be designated by sample type followed by "TB."

v_y For example, the first trip blank for each medium would be:| CR-MWTB-1

Monitoring wells that are owned by Rohm & Haas Company will alsobe sampled as part of this; Phase. I RI. Samples collected fromRohm & Haas wells shall be identified as follows:Example

LF-13-16: represents Rohm fi Haas monitoring well No. LF-13-18.CR-MW- ( LF-13-18 )-l: substitute "well location number" with Rohm

& Haas monitoring well number.2.6 SAMPLE CONTAINER REQUIREMENTS AND HOLDING TIMES

Sample container requirements and holding times are specified inTable 2-1.

2.7 SAMPLE PACKAGING AND SHIPPING

Samples will be packaged and shipped in accordance with FT-7.07.I The Field Operations Leader will be responsible for contacting

the EPA Sample Management Office (SMO) for each shipment of, samples and will report the following:

' • • . • : •• ' ! ' • .Dates the samples were shippedTypes of samples , •' • ,SMO Case NumberNumber of samplesAirbill numberLaboratory that the samples were shipped to

SMO and the Regional Laboratory Sample Coordinator (RLSC) shouldbe contacted either the day the samples are shipped, or thefollowing morning. The 'SMO telephone number is (703) 557-2940and the RLSC telephone number is (215) 752-0213.The RLSC will track sample shipment, receipt, analysis, and datavalidation and will be responsible for forwarding thisinformation to the EPA CRL. A weekly sampling summary sheet(Appendix A) shall be completed and forwarded to the RLSC at theend of the working week. • The , summary sheet will then beforwarded to the EPA CRL. :

I\

II

Note: This reporting procedure only applies to samples whichare being sent to a CLP laboratory. Samples being analyzed by aREM III Team laboratory should only be logged in the appropriatedocuments (i.e., site logbook, field notebook). • R̂ il̂ n i r ncommunication with the RLSC is required in order to plarA Baa Mill I b 3laboratory activities. REM III laboratories will only be "usedif CLP cannot accomodate the samples.

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J 2.8 DOCUMENTATIONJ

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A bound f weather proof field notebook shall be maintained by thefield team* The FOL, or designee, shall record all informationrelated to sampling or field activities. This information mayinclude sampling time, weather conditions, unusual events (welltampering), field measurements, etc.In addition to the field notebook, a site logbook shall bemaintained by the FOL. The requirements of the site logbook areoutlined in FT-13. 03. Essentially, this book will contain asummary of the day's activities and will reference the fieldnotebooks when applicable.2.9 FIELD AUDITS

A Quality Assurance (QA) performance audit will be performed bya designed QA Specialist during the remedial investigation. Theaudit will include checks on adherence to all samplingprotocols. Audit findings will be documented and distributed toproject team members. Pre-mobiliration meetings will beconducted to review applicable FTGs and familiarize the FieldSampling Team with the scope of work and quality of work that isexpected to be implemented in the field.2.10 PROCEDURES FOR FIELD CHANGE AND CORRECTIVE ACTION

Corrective action may be initiated as a result of audits, fieldobservations, or complaints. Under the REM III Program, allchanges or deviations from this FSAP must be documented in thefield notebook and a Field Change Request Form must beinitiated. (An example of this form can be found inAppendix A) . The Field Operations Leader shall contact the SiteManager, or designee, and explain the reason for the deviationor change. After discussing the situation with the SiteManager, corrective action will be determined and initiated.The Field Operations Leader is required to document all fieldchanges on the Field Change Request Form and return it to theSite Manager (at the most convenient time, i.e., end of workweek), who will sign it and distribute it to the RegionalManager, Quality Assurance Manager., Field Operations Leader, andproject file. A copy shall be kept in the onsite office trailerwith the FSAP.2.11 FIELD INSTRUMENTATION

Numerous monitoring instruments will be used during activitiesand may include the following s

• Temperature probe( • Specific conductance meter

• pH meter• Photoionization meter

• Organic vapor analyzer• Electronic water level meter

The temperature probe, conductivity meter, and pH meter will becalibrated according to the manufacturer's operating manualprior to each day's use. The other above-mentioned instrumentsshall be calibrated prior to mobilization and periodically atthe discretion of the FTL. Calibration will be documented on anequipment Calibration Log (FT 13.02). During calibration, anappropriate maintenance check will be performed on each piece ofequipment. If damaged or failed parts are identified during thedaily maintenance check and it is determined that the damagecould have an impact on the instrument's performance, theinstrument will be removed from service until the identifiedparts are repaired or replaced.

V AR300171*I

I-15-

3.0 DATA QUALITY OBJECTIVES

The RI/FS (fork Plan for the Croydon TCE Site reviewed availabledata, defined the RI/FS objectives, and identified the datarequired to meet the objectives. The RI/FS objectives are givenin Table 3-1, along with the criteria and data gatheringactivities needed to meet the objectives.This section of the FOP outlines the data quality factors neededto meet the objectives described in Table 3-1. DQOs areestablished to ensure that the data collected are sufficient andof adequate quantity and quality for their- intended uses(USEFA, 1987). Table 3-2 summarizes the sampling and analysisprogram for the Phase I field activities. Included in thistable are the objectives of each sample and the analyticalmethods which are needed to meet the objectives. •The analytical methods selected for risk characterization (seedata objectives column in Table 3-2) were based on the precisionand accuracy of the methods. Additionally, the detection limitsare consistent with risk assessment requirements and ARARs. Forthe engineering and site characterization needs, the precision,accuracy, and detection limits of the analytical method aresufficient. ;In general, a four-step methodology was used to developsite-specific DQOs, identify appropriate analytical protocols,and establish PARCC requirements for each data set. Thisfour-step approach included the following components!

• Comparison of ARARs, risk-based criteria, and data needs. to detection limits for available analytical methods;• Selection of appropriate methods to allow quantification

of parameters at levels sufficiently below ARARs, etc.,to minimize number of critical data points;

• Evaluation of maximum allowable variability (i.e.,maximum precision and accuracy range) based on comparisonof detection limit to ARARs, etc.;

• Development of a site-specific acceptable variability,based on proposed data uses and method-specific precisionand accuracy information.

This acceptable variability, or precision and accuracy "window"was compared to historical laboratory performance data on amethod-by-method basis (See Appendix B). 'This comparisonenabled a determination of site-specific goals attainable withinthe standard CLP or REM III framework, or whether more stringentprecision and accuracy requirements will be needed UK^Iadditional matrix spikes, etc.). ftRoOO I

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The objectives of the RI/FS find intended "end use" of the data._ define the FARCC parameters. The PARCC parameters for the

Phase I RI are described below.Precision and Accuracy - Precision is defined as a quantitativemeasure of the variability of a group of measurements comparedto their average value (OSEPA, March 1987). The overallprecision of measurement data is a combination of sampling andanalytical factors. In order to measure precision/ duplicatesamples will be collected from each medium. As shown onTable 2-1, one duplicate sample will be taken for every20 samples collected. When collecting duplicate samples, it isimportant to select a sampling location that may be critical tothe RI. This sampling location could be one that is needed todelineate a boundary of contamination,- such as the vertical orhorizontal boundary. Section 5.0 (Sampling Procedures)identifies the candidate locations where duplicate samples shallbe collected from.

Accuracy measures the bias in a measurement system. Sources oferror in the sampling process will have an effect on theaccuracy of the analytical method. To evaluate this, field and

( . trip blanks will be prepared and analyzed. Duplicate samplesj are also used to measure accuracy. Table 2-1 outlines the

number of field blanks, trip blanks, and duplicates for the• v Phase I RI sampling program.*--/ Field and laboratory precision and accuracy performance can

affect the attainment of project objectives. This isparticularly the case when decisions regarding compliance withestablished criteria will be made based upon laboratory analysis

1 of field samples. Such criteria comparisons are common to riskassessments and to screening remedial alternatives.The following precision and accuracy goals have been identifiedas necessary to meet the project objectives:

Precision ±50%Accuracy ±50% .

- Historical laboratory precision and accuracy data were reviewed• in order to select analytical methods suitable for'the intendeddata uses. The analytical methods presented in Appendix B wereselected because the precision and accuracy of these methods areare suitable for risk characterization, site characterization,and engineering evaluations. -Analytical precision and accuracy

I will be evaluated following receipt of the laboratory data.Analytical accuracy will be measured as percent recovery frommatrix and surrogate spike samples. Analytical precision willbe measured as the relative standard deviation from laboratory

P internal duplicates. Overall sampling and analyticaland accuracy will be determined using the same rati<

V_y blind field duplicates and laboratory internal QC data.'

I-24-I

I( Field sampling precision and accuracy is not readily amendable

to objective measurement. Some estimate can be inferred byI contrasting the overall precision and accuracy estimatesI obtained from field duplicates with internal laboratory

precision and accuracy estimates. To assure minimization ofprecision and accuracy errors associated with field activities,field sampling will be conducted in accordance with the FTGs orother EPA-approved procedures.It should be noted that no project resources will be expended todevelop precision and accuracy data for method validation,except/ those commonly applied in the CERCLA program forcollection of routine QA/QC data. Routine QA/QC data willinclude analyses from field duplicates, field blanks, equipmentrinsate blanks and trip blanks, based on the existing guidancewhich specifies the type,and proportion of samples submitted forQA/QC (DQO's for Remedial Response Activities, USEPAMarch, 1987).

An assessment of data validity with respect to the intended usewill be conducted based on laboratory supplied QA/QC data andprotocols routinely employed for validation of CLP-RAS/SAS

, analytical results. In general, results which are rejected byj ' the validation process will be disqualified for application to

the intended use. Qualified data, which are defensible, will beused to the most practical extent.

: Representativeness - Representativeness expresses the degree towhich sample data accurately and precisely represent anenvironmental condition (USEPA, March 1987). The

i representativeness criterion is met by making certain thatsampling locations are selected properly and a sufficient number.of samples collected. The rationale for the Phase I RI sampling

, locations are discussed in Section 4.3 (Field Investigations) ofthe Phase I RI/FS Work Plan. Because this RI/FS is beingconducted in two phases, only one round of samples will becollected during this Phase I RI.Completeness - Completeness is defined as the percentage ofmeasurements made which are judged to be valid measurements. Inorder to assure that the data are. valid measurements, .all dataresults will be validated by a qualified chemist experienced indata validation. This will be performed by the REM III Team,and reviewed and approved by EPA Central Regional .laboratory.Historically, all data for Level IV analytical techniques hasbeen found to be 80-85 percent complete (USEPA, March 1978)*

I Duplicate samples will be collected from critical locations tohelp assure the validity and completeness of the sample results.The sampling and analysis program is sufficiently broad in scope

I to prevent a single data point (or parameter) from sacrificing• attainment of the RI/FS objectives. AR3QOI81*

II

Comparability - Comparability is a qualitative parameterexpressing the confidence with which one set of data can becompared with another (USEPA, March 1987). This goal isachieved through using standard techniques to collect andanalyze representative samples and reporting analytical resultsin appropriate units. Established REM III Program FieldTechnical Guidelines (FTG) will be used to collect allgroundwater samples. This will ensure.that data can be comparedwith a high degree of confidence.

AR300I85

-26-

I

4.0 DRILLING AND MONITORING WELL INSTALLATION————————————————————————————————————4.1 NUMBER OF WELLS AND LOCATIONS

Fifteen well locations, consisting of 29 monitoring wells, willcomprise the Phase I drilling program. Fourteen well locationswill be two well cluster locations, with a water table well anda deep alluvial well in each cluster. One well location willhave a single well installed, as there is already one well there(BMC well No. LF-14-20) and only one more is needed to completethe cluster. The well clusters will provide data to determinelateral and vertical variations in contaminant concentrations,determine vertical flow components within the aquifer, andprovide data for determining groundwater flow patterns.The proposed monitoring wells and the location of theRohm & Haas wells are shown in Figure .4-1. The rationale foreach well location and the primary functions for each wellcluster are discussed in Section 4.3.2 of the Phase I RI/FS WorkPlan. The proposed well locations were selected by the REM IIITeam with input from EPA based on the locations of suspectedsource areas, the observed locations of TCE contaminated wells,the locations of existing groundwater monitoring pointspresently available for sampling, the overall expectedgroundwater flow pattern for the area, and the data requirementsof the Phase I RI/FS.4.2 DRILLING OPERATIONS

The preferred method for drilling monitoring well borings is thehollow stem auger method. Drillers will not be restricted tothe use of this method and should be capable of changingdrilling methods, should site conditions render auger drillingineffective. At a minimum, the driller shall be capable ofdrilling using mud rotary techniques, in addition to augerdrilling. The only drilling fluids approved for use if neededare potable water or a drilling mud mixed from potable water andpure bentonite. No organic based additive may be added todrilling fluids. Previous drilling activities in the site areautilized mostly hollow stem auger (throughout most of the studyarea) and occasionally mud rotary (along the southern edge ofthe study area) methods for wells. Monitoring well borings orauger casings must be of an adequate diameter (nominal 6 inchesor more) so that 2-inch diameter PVC wells can be properlyinstalled. The general Ebasco preference for drilling methodsat hazardous waste sites is hollow stem auger, air rotary, cabletool, mud rotary, and drive and wash/spinning casing, in thatorder of preference; however, drillers are not bound to selectthe most preferred option.

AR300I8&

I-27-

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5 '3

R300I87

During drilling operations of monitoring well borings, StandardPenetration Tests will be performed and split-barrel soilsamples taken at 5-foot intervals or as requested by the sitegeologist in the deepest well at each cluster location or ateach well at a single well location, in accordance withASTM D-1586-84, starting at 0.0 to 1.5 feet. Each soil samplewill be placed in a 8-ounce jar (to be provided by the driller),labeled, pertinent data recorded (project, boring, and samplenumbers, depth, blow counts, and date) and submitted to the SiteGeologist. The remaining boring at each cluster location neednot be sampled. The boring log for each boring will bemaintained by NUS. Lithologic samples will be. described usingthe Unified Soil Classification System (USCS). The followinginformation, when applicable, will be included in the boring logprepared for each boring that is sampled:

Sample numbers and typesSample depthsStandard Penetration Test dataSample recovery/sample intervalSoil density or cohesivenessSoil colorUSCS material description and symbol

I In addition, depths of changes in lithology, sample moistureobservations, depth to water, OVA/HNU readings (if taken),

.( drilling methods, and total depth of each borehole should be• included on each log, as well as any other pertinent

observations that may be made.

II

I

I

The driller shall prepare a separate written boring log for eachboring drilled, to be submitted to NUS at the conclusion of thefield activities. The boring log should describe lithologiesencountered, depths of various formations, sample locations,sample data (recovery, blow counts, etc), water levels, totaldepths, well construction summary, and any other pertinent data.

! 4.3 MONITORING WELL CONSTRUCTION/INSTALLATION

Monitoring wells shall be constructed of 2-inch diameter,1 nonglued-flush-joint, threaded, schedule 40 PVC casing and well* screens equipped with a PVC end plug and vented cap. Figure 4-2

illustrates typical well construction details for a monitoringI well. Table 4-1 provides a summary of monitoring well

construction details. Monitoring well construction andinstallation activities must be performed to the satisfaction ofthe Site Geologist and in accordance with the methodologydescribed in this section.Well screens will be 10 feet in length and slot size will be

1 0 . 0 2 inch. The PVC well installation procedure will consist ofplacing the PVC pipe and screen into the completed bor

( backfilling the annulus of the boring, around the welland approximately 2 feet above the well screen, with clean

-29-

ii MONITORING WELL

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NOTTO SCALE CXDRPORATON

-30-

TABLE 4-1 v—^

\II

ESTIMATED MONITORING WELL CONSTRUCTION DETAILSCROYDEN TCE SITE

BUCKS COUNTY, PENNSYLVANIA

WellNumber

HW1-SMW1-DMW2-SMW2-D

MW3-SMW3-DMW4-SMW4-DMW5-SMW5-DMW6-SMW6-D

MW7-SMW7-DMH8-SMW8-0

KW9-SKW9-DMW10-DMW11-SMW11-DMW12-SMW12-DMW13-SMW13-D

MW14-SMW14-D

MW13-DKW15-S

TOTALS

EstimatedDepth

30'65'so-so120'50'25'60*30'60'30'65*30'60'20'45'20'40'50'25'50'30'55'30'60'30'60'50'25'

1,205'

2" PVC

Casing22'57'22'52'12'42'17'52'22'52'22'57'22'52'12'37'12?32*42'17'42'22*47'22'52'22 1

52'42*17'

973'

Screen

10*10'10'10'10'10'10'10'10'10'10'10'10'10'10*10'10'10'10'10'10'10'10'10'10'10'10'10'10'

290'

Soil Sampling Required

Yes

z

X

X

X

X

X

X

• X

XX

X

X

X

XX

No

X

X

X

X

X

X

X

X

X

X

X

• x

X

j&sM 90

•31-

I

quartz sand U20-#30 U.S. Standard Sieve Size). A bentonitepellet seal (minimum 2-foot thickness) will then be installed;the remainder of the annulus of the boring will be backfilledwith a cement-bentonite grout to ground surface. The exactdepths of all backfill materials will be determined in the fieldby the NUS geologist, based on the observed subsurfaceconditions at each boring location. Backfill depths should beconstantly monitored by the driller during the well installationprocess by means of a weighted steel, plastic, or fiberglasstape to the satisfaction of the NUS geologist. Casingcentralizers will be used for wells greater than 35 feet, ifdeemed necessary by the Site Geologist.Protective steel casings (minimum 6 inch diameter, 5 feet inlength) equipped with locking caps shall be installed around allwells. Locks are to be supplied by the driller and must bekeyed alike. The locking caps must -be adequate to preventunauthorized access to the monitoring wells, and are subject toapproval by the NUS representative. Two small one quarter inchholes should be drilled at the base of the stickup of theprotective casing, to allow water drainage from inside theprotective casing. In some cases, flush mounted protectivecasings may be required at locations where a protruding casingwould be undesireable (near roadways). Typical design detailsfor these casings are shown in Figure 4-3.4.4 WELL DEVELOPMENT

. . , . • • • • : • • . • • ' . • • •Monitoring wells will be developed no 'sooner than the day .following installation. Wells may be developed by pumping,surging, and/or air lifting, to remove fines from formationmaterials and remove any residual drilling fluids from the area.around the well screen. Well development will be performed*until formation water is free of fines, or until approved by theSite Geologist. It is not anticipated that well developmentwater will need to be contained.

4.5 DECONTAMINATION .

All downhole drilling, sampling, and testing equipment and theback end of the drilling rig must be steam cleaned prior tobeginning monitoring well drilling/installation work, betweenboreholes, any time the drilling rig leaves the drill site priorto finishing a boring, and at the conclusion of the drillingprogram. Decontamination operations will consist of washingequipment using a high-pressure steam wash. All decontaminationequipment, including a steam cleaner and potable water, is to beprovided by the subcontractor* Monitoring well casing andscreens must also be decontaminated as described above, prior toinstallation. As an alternate, NSF approved PVC pipe andscreens may be used without steam cleaning. It isnCQtanticipated that decontamination water will needftR&QQbk.?contained, however, in the event that containment is- neededbased on organic vapor monitoring levels above 35 ppm, the

-32-

GROUND SURFACE.—j r-FORO METER BOX COVER OR EQUIVALENT (I2"0 OPENING)

CEMENT

PROTECTIVE CASINS W/LDCKINO CAP

MONITORING WELL ——— V i ' -K •• -*K- ————SAND PACK (FOR DRAINAGE)

CEMENT/BENTONITE GROUT

FLUSH MOUNTED • F'G"*E. frPROTECTIVE CASING INSTALLATION -« '

|( CROYDON TCE SITE. BUCKS COUNTY. PANOT TO SCALE I_LJ CXDRPORATTON

-33-

subcontractor should have 55-gallon (DOT Spec. 17) drums-̂S' available. NUS will provide a centralized location for

decontamination operations. This location will be determinedduring the mobilization activities.The driller shall have plastic sheeting available for setting upa temporary decontamination pad.4.6 AQUIFER TESTING

Monitoring wells will be used for aquifer testing to determinethe groundwater flow conditions in the alluvial aquiferinvestigated at the site. The data generated from these.testswill be used to define the water-yielding characteristics of theformation,' develop groundwater velocity values for the alluvialaquifer, and estimate the rate of groundwater movement acrossand away from the site. Slug tests or 'short-term pumping testswill be performed in the monitoring wells and evaluated usingthe most appropriate evaluation technique for each type of testand for each individual set of hydrogeologic conditions.Pressure transducers and data loggers will .be used for datacollection, where appropriate, to obtain the most accurate fielddata possible. M-scope or popper water level measuring devicesmay also be used where appropriate. It is anticipated that eachnew monitoring well and selected Rohm & Haas wells will be

f tested.4.7 WATER LEVEL MONITORING

At least two comprehensive rounds of water levels will be takenfrom the 29 REM III Team monitoring wells and the 19 Rohm t Haasmonitoring wells. Staff gauge readings along Hog Run Creek willbe recorded during each round of water level measurements. Allmeasurements for each collection round shall be collected withina 24-hour period of consistent weather conditions to minimizeatmospheric/preparation effects on groundwater conditions.Measurements will be taken with an M-scope (electrical water-level indicator) or popper, using the top of the well casing asthe reference point for determining depths of water. These

.. water levels will be used to determine groundwater flowdirections and to identify any variations which may occur inflow directions throughout the study area over time.4.8 REPORTING

The following reports and documentation will be theresponsibility of the Site Geologist during the drillingactivities. A copy of applicable forms that will be used by theSite Geologist are located in Appendix A.

| Site Logbook - See REM III Program Guidelines FT-13.03-~n- .Daily Record Surface Investigation Report - See Append be "A". •

II -34-

/ Boring Log - See Appendix A. .

Overburden Monitoring Well Sheet - See Appendix A;

' Data Sheet for Pumping Tests - See Appendix A.Groundwater Level Measurement Sheet - See Appendix A.

Weekly Field Summary Report - See REM III ProgramGuideline 13.01, Attachment C.The Site Geologist's logbook shall contain information about thedrilling activities such as start/finish times, standby timesand problems or changes encountered during drilling.Drilling/monitoring well construction information (i.e., footagedrilled, depth of casing, etc.) will be recorded daily on theboring log and the overburden monitoring well sheet. The boringlog, along with the geologist's logbook, will be used to preparethe Daily Record-Subsurface Investigation Report. This reportwill identify drilling activity and quantities of material usedon a daily basis, and shall be signed by the drill rig foreman(or equivalent) and the Site Geologist. The reports shall besubmitted to the Site Manager at the end of each week. Thesereports are also used to fill out the Daily Logbook.

I

V - AR300I9I* )V - .̂ -s

-35-

-- ' 5.0 PHASE I RI SAMPLING PROGRAM«-• a»B«.»M.»B»..»BB«.».»™«.».».».»««B«j.*.«..»«B-̂ B«B»*̂ B»B»B»B»M*».m*»B™.B*.«B.»««».-«B-»

j 5.1 GROUNDWATER

The groundwater sampling program will consist of sampling all29 newly-installed REM III Team monitoring wells, 19 existingRohm & Haas monitoring wells, and 51 residential wells.5.1.1 Monitoring WellsOne round of groundwater samples will be collected from thenewly-installed REM III monitoring wells and 19 Rohm and Haaswells. All of the samples will be analyzed for volatile organics(via EPA Methods 601/602). Approximately 20 percent of thesewells (6 REM III wells and 4 Rohm & Haas Wells) will be analyzedfor TCL semi-volatiles, pesticides, and -TCL inorganics through aContract Laboratory Program (CLP) laboratory using RoutineAnalytica Services (RAS). Additionally, these 10 samples willbe analyzed for selected water quality parameters including;

j total organic carbon (TOC), biological, oxygen demand (BOD),1 nitrates (N03), nitrites (N02), sulfates (SO4), total dissolved

solids (TDS), total suspended solids (TSS), chlorides (Cl),I carbonates (CO?), bicarbonates (HCO3), ammonia (NHj-H),

temperature, pH and specific conductance. Temperature, specific:' conductance, and pH will be analyzed in the field.i The ten samples (e.g., those samples that represent 20 percent

for full analysis) will be collected from the following well. locations:

I • REM III Well Cluster Nos. 13, 3, and 5 (6 samples)• Rohm & Haas Well Cluster Nos. LF-15 and CR-24

j (4 -samples)The sampling of the REM III Team monitoring wells will be

, initiated approximately 1 week after the conclusion of thedrilling/well construction/development activities. Figure 4-1depicts the proposed REM III monitoring well locations and the19 Rohm and Haas well locations. The Rohm & Haas wells will besampled during the drilling activities, following the conclusionof the residential well investigation (see Section 5.1.2).Sampling and analysis protocols and QA/QC sample requirementsare outlined in Table 2-1. Duplicate samples (a total of three)

: shall be taken from REM III well location number 5 (thislocation will consist of a shallow and deep well) and

i Rohm & Haas well number CR-24 -3 7.' 5.1.2 Residential Wells

I In order to assess the public health and environment

II

an e n v r m e n a . QC-posed by groundwater within the study area (i.e., OHjiodltfel " 0Number 2), one round of samples will be collected- from51 residential wells. All of the samples will be analyzed for

-36-

I1

volatile organics through the CLP via EPA Methods 601/602.Twenty percent (10 samples) of these samples will be analyzedfor TCL semi-volatiles, pesticides, TCL inorganics, and waterquality parameters. Temperature and specific conductance willbe analyzed for all samples in the field.The ten residential well samples (mentioned above) for "fullanalysis" shall be collected from the following locations:

2925 West Avenue2916 Lansdowne Avenue1028 Rosa Avenue1601 River Road914 Belleview Avenue922 Orchard Avenue400 Main Avenue1311 Sycamore Avenue2208 Garfield Street603 Grant Street

Figure 4-4 depicts the candidate residential well locations.The number of samples/analyses are summarized on Table 2-1.Duplicate samples shall be taken from the Postowski residence(603 Grant Street) and the Andrescavage residence(2916 Landsdowne Avenue).5.1.3 Sampling Methods

Groundwater samples will be collected in accordance withFT-7.02. Prior to obtaining the groundwater sample, the wellsshall be purged using dedicated stainless steel bailers or witha teal pump. Three to five well volumes will be purged. If thewells are purged dry with less than three well volumes removed,then the water level should be allowed to completely recoverprior to taking a sample. (Water level measurements shall betaken prior to purging.) Field measurements including pH,temperature, and specific conductance shall be taken at the endof purging.Residential well samples shall be collected using the followingprocedures:

1. Obtain the well depth, casing size/ and holding tankvolume. Calculate the volume of water in the system asfollows:Well volume (gallons) = TT (radius of well casing in ft)2(feet of water standing in the well) (7.48 gallons/ft?)Total water volume (gallons) * well volume * holding ...

' tank volume AR300196- -

-37-

i .

ui D

1

AR300I97

I I I " . I , I I I » I

/ Note: Well depth, casing size, and holding *»™fc volume \_>may be available from the Site Manager followingthe acquisition of questionnaires tftat were

i issued to the well owners.2. If a tap is available between the well head and the

| holding tank, purge three to five well volumes from theI system. If no tap is available, purge the total water

volume calculated above from the system plus two( a d d i t i o n a l well volumes. If information concerning well

depth or holding tank volume is not available, purge thewell for 15 minutes.

I Note: When purging from an outside tap, route the wateraway from the house or to a drain using a gardenhose.

I 3. Collect the sample from the tap closest to the wellhead, before the water is processed through any water-treatment devices. If it is not possible to sample

j before a treatment device, note this in the sample1 notebook. Do not take the sample from the garden hose

used to route the water away from the house.I Note: Some well owners may be reluctant to allow their

water to run for the period of time involved, in ,\, purging three well volumes. Community relations x—'/

considerations must be weighted against the needto obtain a representative sample, with thesampler having to make a judgement as to what

. actions should be taken. Exact times of purging' must be recorded.[ Field blanks (a.k.a. Equipment Rinsate Blank) will be obtainedI under representative field conditions by running analyte-free

deionized water through sample collection equipment (bailer)( a f t e r decontamination and placing it in the appropriate sample

containers for analysis. These samples are used to determine ifdecontamination procedures are sufficient.

I Bottle blanks are obtained by pouring analyte-free deionizedwater into a set of sample collection bottles. They serve as anoversight function in assessing the effect of residual

• contamination in the sample collection bottle.Trip blanks (volatiles only) will be prepared in the laboratory

i (or in the field, in an area outside of the zone ofI contamination) prior to the sampling event. Analyte-free• deionized water is poured directly into the sample jar and then

packaged for shipment with other samples. At no time afterI their preparation are trip blanks opened before/Jt$i§\QfiebQho the x

laboratory. . - - - - - .r ^)

-39-

IAII

Field duplicates and field blanks should be submitted at therate of one field duplicate or blank/matrix/day or one for every20 samples. Trip blanks should be submitted at the rate of oneper shipment.

5.2 SURFACE SOIL SAMPLING

5.2.1 Number of Samples and Locations

I It is anticipated that surface soil samples will be collected ateight locations as illustrated in Figure 4-5. In addition tothe appropriate QA/QC sample requirements (See Table 2-1), onesample will be obtained from each location and analyzed for TCL

I organics and inorganics via CLP-RAS. One duplicate sample shallI be obtained. The location for obtaining the duplicate sample

will be at the discretion of the FOL.5.2.2 Sampling Methods

. Surface soil samples will be collected in accordance withi REM III Guideline FT-7.03. A stainless steel trowel or a

stainless-steel hand auger will be used to collect the surfacesoil samples. The samples shall be collected from depths of

| approximately 0 to 3 inches, placed in appropriate samplecontainers and submitted for analysis as described in Table 2-1.Approximate sample locations shall be noted on a general

, arrangement map of the site for future reference (See—̂' Figure 1-2).

5.3 SURFACE WATER AND SEDIMENT

5.3.1- Number of Samples and Locationsj As shown in Figure 4-6, 22 surface water and sediment samplesI will be collected and analyzed for volatile organics (EPA

Methods 601/602), semi-volatiles (RAS), pesticides (RAS), andTCL inorganics. The samples will be collected from thefollowing surface waters:

Delaware River (four samples)Neshaminy Creek (five samples)Hog Run Creek (five samples)Pond (unnamed) (two samples)Four intermittent streams (five samples)Ponded area on the Coyne Chemical property

Table 2-1 outlines the sample analyses and QA/QC samplerequirements.5.3.2 Sampling Methods

Surface water and sediments samples will be collected R&QftJrft 9to REM III Guideline FT-7.08. The samples will be collectedfrom a relatively low-energy environment (quiet area of the

-40-

UJDC3Ou.

COoo

-«•<LU CO

ord.£

AR300200

-41-I

I

I

IIII\II

i stream) to provide a more representative sample. Samples will .be placed in appropriate sample containers and submitted to the ^^>CLP for analysis as described in Table 2-1. Sample locationswill be noted on the general arrangement map for futurereference.

5.4 DECONTAMINATION

All sampling equipment used for collecting samples shall bedecontaminated prior to sampling in the field, between eachsample,, and at the end of the sampling day. This equipment mayinclude bailers, split spoons, pumps, tubing, steel tapes,buckets and trowels. The following decontamination steps takenfrom REM III Guideline FT-12.01 should be taken.

Potable water rinseAlconox or liquinox detergent washPotable water rinseDistilled/deionized water rinseMethanol rinseDistilled/deionized water rinseAir dry

All personnel leaving the Exclusion Zone (area of potentialcontamination) shall exit through the Contamination ReductionZone (area of decontamination). This area of decontaminationshall include a system for washing and rinsing all of the .Aprotective clothing worn. The washing and rinsing will be ^^conducted in combination with a sequential removal of equipmentand clothing, starting at the first station with the mostheavily contaminated articles and progressing to the laststation with the least contaminated articles. HS-1.2 of theREM III Guidelines states the proper requirements for set up ofthe personnel decontamination area.

5.5 REPORTING

The following reports and documentation will be theresponsibility of the Field Team Leader (FTL) during thegroundwater, soil, and surface water/sediment samplingactivities:

Site logbook: See FT-13.03Weekly Field Summary Report: See FT-13.01, Attachment CWell Sampling Data Sheet: See FT-13.02, Section 5.1.9Sample Log Sheet: See FT-13.02, Section 5.1.10Sample Log Notebook: See FT-13.02, Section 5.1.11

AR300202

•43-

* ,6.0 SURVEYING

Surveying activities at the Croydon TCE Site will be performedas two separate elements. The first element will be performedby a subcontractor and will include the control survey andaerial photography necessary to produce a topographic map of thesite. The second element of the surveying work will beperformed by NUS personnel and will involve the location surveynecessary to establish the vertical and horizontal location ofthe newly-installed REM III monitoring wells and the 19 existingRohm & Haas monitoring wells. The surveying and mappingactivities will be performed in accordance with REM IIIGuideline FT-3.03.

AR300203

I •44-

3

AR3-0020I*

SECTION III

HEALTH AND SAFETY FLAN (HASP)

CROYDON TCE SITE RI/FS

This section contains the Health and Safety Plan (HASP) for theCroydon TCE Site. It is an integral part of the FOP; however,it is designed to function as a stand-alone document asreflected by its internal structure and organization. Mpqn'none

SITE-SPECIFIC HEALTH AND SAFETY PLAN FOR REM IIIHAZARDOUS WASTE SITE ACTIVITIES

SITE:___________Crovdon TCE Site

LOCATION: _______ Bucks County , Pennsylvania

DATE PREPARED: June 26, 1987'(\ PREPARED BY: _____ K. S. Bradv/NUS Corporation

(NAME/COMPANY)

' PLANNED SITE ACTIVITY DATES: September-November, 1987

REVISION: ______ Q _______

EBASCO SERVICES INCORPORATED, EBASCO SUBCONTRACTORS AND THEUNITED STATES ENVIRONMENTAL PROTECTION AGENCY DO NOT GUARANTEETHE HEALTH OR SAFETY OR ANY PERSON ENTERING THIS SITE. DU2 TOTHE HAZARDOUS NATURE OF THIS SITE AND THE ACTIVITY OCCURRINGTHEREON, IT IS NOT POSSIBLE TO DISCOVER, EVALUATE, AND PROVIDEPROTECTION FOR ALL POSSIBLE HAZARDS WHICH MAY BE ENCOUNTERED.STRICT ADHERENCE TO THE HEALTH AND SAFETY GUIDELINES SET FORTHHEREIN WILL REDUCE, BUT NOT ELIMINATE, THE POTENTIAL FOR INJURYAT THIS SITE. THE HEALTH AND SAFETY GUIDELINES IN THIS PLANWERE PREPARED SPECIFICALLY FOR THIS SITS AND SHOULD NOT BE USED.ON ANY OTHER SITE WITHOUT PRIOR RESEARCH AND EVA&lR&ftlf) ?$X6

, TRAINED HEALTH AND SAFETY SPECIALISTS* ? - - - - - - -

TABLE OF CONTENTS

SECTION PAGE

I GENERAL 1II HEALTH AND SAFETY PERSONNEL DESIGNATIONS 3III SITE HISTORY AND PHYSICAL DESCRIPTION 5IV SITE-RELATED INCIDENTS, COMPLAINTS, AND ACTIONS 11V WASTE DESCRIPTION/CHARACTERIZATION 12VI HAZARD ASSESSMENTS 14VII TRAINING REQUIREMENTS 19VIII ZONES, PERSONNEL PROTECTION AND COMMUNICATIONS 20IX MONITORING PROCEDURES FOR SITE OPERATIONS 27X SAFETY CONSIDERATIONS FOR SITE OPERATIONS 29

XI DECONTAMINATION PROCEDURES - 30XII ADDITIONAL SAFE WORK PRACTICES ' .' 31XIII DISPOSAL PROCEDURES 31XIV EMERGENCY PLAN 32XV AUTHORIZATIONS 38XVI MEDICAL DATA SHEET 39XVII FIELD TEAM REVIEW 40XVIII APPROVALS 41

AR300207

TABLES

NUMBER

1 COMPARISON OF EXISTING DATA WITH ARARsr

FIGURES

NUMBER PAGE

1 LOCATION MAP 62 STUDY AREA GENERAL ARRANGEMENT MAP . 73 POTENTIAL SOURCE AREAS 94 PROPOSED MONITORING WELL LOCATIONS 215 PROPOSED SURFACE WATER AND 22

SEDIMENT SAMPLING LOCATIONS

AR300208

iii

SECTION I: GENERAL

This plan has been prepared in conformance to REM III ProgramGuideline HS-1.01. It addresses all those activities associatedwith___ the Remedial Investigation/Feasibility Study _________f RI/FS)_____ at the Crovdon TCE Site ______

. ______ and will be implemented by the HSO duringsite work. Compliance with .this HASP is required of all personsand third parties who enter this site. Assistance inimplementing this Plan can be obtained from the REM ZXZ Healthand Safety Manager (HSM), and/or the NUS Corporation ________

'___________ Company Health and. Safety Supervisor(CESS). The content of this HASP may change or undergo revisionbased upon additional information made available to health andsafety (H&S) personnel, monitoring results or changes in thetechnical scope of work. .Any changes proposed must be reviewedby H&S staff and are subject to approval of the NUS________

Corporation CESS, and the HSM.

SITE______Crovdon TCE Site______SITE NO. 621Y________PLAN DATE June 26, 1987 ________SCOPE OF WORK Mobilization, monitoring well installation,geological investigation, (aquifer testing,' water levelmeasurements, et al.)/ surveying, groundwater, residential well,surface soil/ stream and sediment sampling, mobile laboratoryjfG.C.) operation. _____________;____________. • ' '• " '__________

SITE MANAGER HEALTH AND SAFETY OFFICERNAME Raymond P. Wattras Kathleen S. Bradv_______WORK PHONE 412-788-1080_____ 412-788-1080________

AR300209

-i-

EMERGENCY PHONE NUMBERS

Bristol_______ Police Dept. (215) 785-4040County Dispatch Fire Dept. (215) 547-5222County Dispatch Rescue Service (215) 547-5222Lower Bucks_____ Hospital (215)785-<Delaware Vallev Back-up Hospital (215)750-:

400 ER260 ER

National Response Center _(jPhiladelphia, PA Poison Control Center _Jj

001151

424-8802386-2100

Matthew H. SoltiS CHSS - (412) 788-1080REM III Regional Manager (215) 752-0212

TBA__________ Field Operations Leader (412) 788-1080REM III HSM (G. Smith orJ. Janous) (703) 558-7506

__________________ Community Relations,Coordinator ___________

County Dispatch Offsite Emergency Services (215) 547-5222Site Command Post TBA________

Note: 911 is not operational in this area of Pennsylvania.Emergency numbers were obtained by contacting Bristol Police andthe County Dispatch Fire/Rescue Service. In the event that firefighting or ambulance services become necessary, the dispatcherwill send the appropriate response unit upon receipt of the NUSwork location.

ER - Emergency Room

BR3002IO\ "

\-2-

. SECTION II: HEALTH AND SAFETY PERSONNEL

2.0 HEALTH AND SAFETY PERSONNEL DESIGNATIONS

The following briefly describes the health and safetydesignations and general responsibilities which may be employedfor the Crovdon TCE ______________ Site.(When preparing plan, delete all personnel not appropriate tothis site).2.1 COMPANY HEALTH AND SAFETY SUPERVISOR

The CHSS has overall responsibility for development andimplementation of this HASP. He also shall approve any changesto this plan due to modification of procedures or newly proposedsite activities. -The CHSS will be responsible for the development.of new companysafety protocols and procedures necessary for field operationsand will also be responsible for the resolution of anyoutstanding safety issues which arise during the conduct of sitework. Health and safety-related duties and responsibilitieswill be assigned only to qualified individuals by the •

, KUS Corporation ________.- _. • •••• - CHSS. Beforepersonnel may work on site, currentness of acceptable medicalexamination and acceptability of health and safety training must

V_> -*e approved by the CHSS.2.2 SITE HEALTH AND SAFETY OFFICER

j The HSO will be present on site during the conduct of allLevel A, or B, or high-hazard Level C field operations and willbe responsible for all health and safety activities and thedelegation of duties to the H&S staff in the field. Where thesite is identified as low-hazard Level C or Level D, the HSO maydirect the site health and safety efforts through an assistanthealth and safety officer approved by the CHSS. The assistant

I will be responsible for implementation of the HASP. He maydirect or participate in downrange activities as appropriatewhen this does not interfere with his primary HSOresponsibility. The HSO has stop-work authorization which hewill execute upon his determination of an imminent safetyhazard, emergency situation, or other potentially dangeroussituations, such as detrimental weather conditions.Authorization to proceed with work will be issued by the CHSSafter such action. The HSO will initiate and execute allcontact with support facilities and personnel when this action

i is appropriate.2.3 ASSISTANT HEALTH AKD SAFETY OFFICER

An Assistant HSO may be designated. On low-hazard ILevel D sites he may have collateral duties butqualified for the health and safety responsibility by the CHSS.

.-3-

( At Level A, B or high-hazard Level C sites, he will be thedownrange person who accompanies field sampling teams and willreport to the HSO. Additionally, he may be required to supportthe HSO when multiple operations are conducted that requiremonitoring and HSL surveillance. His primary responsibility isto provide the appropriate monitoring to ensure the safe conductof field operations. He will have access to continuouscommunications with the Command Post. The number of AssistantHSO' s will be dependent upon the number of downrange operationsoccurring simultaneously, site level of protection designation,and the individual assignments made by the HSO. The AssistantHSO will also share responsibility with the Field OperationsLead and the HSO for ensuring that all safety practices areutilized by downrange teams and that during emergency situationsappropriate procedures are immediately and effectivelyinitiated. He will also be responsible for the control ofspecific field operations and all related activities such aspersonnel decontamination, monitoring of worker heat or coldstress, distribution of safety equipment, and conformance withall other procedures established by the HASP.2.4 AIR MONITORING SPECIALIST

| The Air Monitoring Specialist, if needed, will perform allsupplemental air monitoring necessary to support specific

. , activities as required by the HASP. These activities will' include oper