wakefield lead in soil sampling plan report fd...the concentration of lead in two samples exceeded...

United States Coast GuardHousing Units in Wakefield, MassachusettsLead in Soil Sampling Plan

Project No.: 103G1058243.002October 2015DRAFT

DRAFT

Lead in Soil Sampling Plan

U.S. Coast Guard Wakefield, Massachusetts Housing Units

16 and 20 Tarrant Lane

Wakefield, Massachusetts, 01880

Prepared For:

United States General Services Administration

Office of Real Property Utilization and Disposal

1800 F Street, NW

Washington, DC 20405

Prepared By:

Tetra Tech, Inc.

45610 Woodland Road, Suite 400

Sterling, VA 20166

October 2015

Tetra Tech Project No: 103G1058243.002

Jimmy Kehs

Project Manager

Jeremy B. Travis

Program Manager


Project No.: 103G1058243.002October 2015DRAFT TOC i

TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................................................ 1

2.0 FIELD SAMPLING PLAN ................................................................................................................................. 3

2.1 Mobilization and Utility Mark Out ..................................................................................................................3

2.2 Soil Sample Locations......................................................................................................................................3

2.3 Soil Sampling and Analysis..............................................................................................................................3

2.4 Investigation-Derived Wastes.........................................................................................................................4

2.5 Decontamination Procedures .........................................................................................................................4

2.6 Site Health and Safety.....................................................................................................................................4

2.7 Quality Control................................................................................................................................................5

2.8 Laboratory Analysis ........................................................................................................................................6

3.0 FIELD REPORT ............................................................................................................................................... 7

4.0 REFERENCES ................................................................................................................................................. 8

FIGURES

Figure 1 Site Location Map

Figure 2 Proposed Sample Locations

TABLES

Table 1 Fixed Laboratory Sample Summary

Table 2 Analyses, Sample Container, Preservative, and Holding Time Requirements

Table 3 Fixed Laboratory Parameters and Benchmarks

ATTACHMENTS

Attachment A Standard Operating Procedures


Project No.: 103G1058243.002October 2015DRAFT Page 1

1.0 INTRODUCTION

In 2014, Tetra Tech, Inc. (Tetra Tech) was retained by the United States (U.S.) General Services

Administration (GSA) to perform Environmental Compliance Due Diligence Activities in support of the

U.S. Coast Guard (USCG) real estate transactions. The Environmental Compliance Due Diligence

Activities included a Phase I Environmental Due Diligence Audit (EDDA), Asbestos-Containing

Materials (ACM) survey and condition/risk assessment, Lead-Based Paint (LBP) Inspection and Risk

Assessment, Lead in Soil Sampling activities, and sensitive environmental area review including

National Environmental Policy Act (NEPA) data gathering. The Environmental Compliance Due

Diligence Activities were conducted for the twelve (12) single family USCG housing units located at 2,

6, 7, 10, 11, 12, 15, 16, and 20 Tarrant Lane and 91, 99, and 107 Hopkins Street in Wakefield,

Middlesex County, Massachusetts (Site) (Figure 1).

Prior to the late 1970s, many paints contained lead. When these paints become damaged, i.e., peeling

or flaking, or the painted surface is renovated or demolished, lead can be released into the

environment constituting an environmental and worker health hazard. Depending on the age of

structures, LBP may potentially exist, either exposed or covered over with other paints or materials

as a result of subsequent renovation. Flaking or peeling paint that could be lead-based should be

removed or encapsulated appropriately.

Tetra Tech conducted a lead in soil sampling effort on October 7 and 8, 2014 in accordance with

previously completed Environmental Compliance Due Diligence Activities for the USCG. Two soil

samples were collected per exterior structure wall at each of the Wakefield housing units. Soil sample

locations were within five feet (i.e., drip line) of each exterior wall. Two soil samples were collected

at each location, at the surface (0 to 3 inches below ground surface [bgs]) and from a depth of 6 to 9

inches bgs. A total of 96 soil samples were collected in association with the previous Environmental

Compliance Due Diligence Activities. All soil samples were submitted to Alpha Analytical Laboratories,

Inc. of Westborough, Massachusetts for total lead analysis by U.S. Environmental Protection Agency

(EPA) SW-846 Method 6010C. Samples were not analyzed for any other constituents.

Lead concentrations in soil at the Site ranged from 2.9 milligrams per kilogram (mg/kg) to 270 mg/kg.

The concentration of lead in two samples exceeded the Massachusetts Department of Environmental

Protection (MassDEP) RCS-1 reportable concentration of 200 mg/kg. Lead was detected in the soil

sample collected from the north side of 20 Tarrant Lane from a depth of 6-9” bgs at a concentration

of 270 mg/kg. Lead was detected in the soil sample collected from the north side of 16 Tarrant Lane

from a depth of 6-9” bgs at a concentration of 240 mg/kg.

The Massachusetts Contingency Plan (MCP) includes an exemption from reporting due to lead in soil

emanating from a point of original application of lead-based paint (310 Code of Massachusetts

Regulations [CMR] 40.317(8)(a)). If an exterior building component was painted with lead-based

paint, the lead in soil in the vicinity of the building might be present in soil as a result of deterioration



of paint over time. The buildings currently have vinyl siding and vinyl windows. However, the original

construction likely included painted wood windows and potentially painted siding. In order to

evaluate whether the exemption from reporting applies, Tetra Tech recommended collecting

additional soil samples at a greater distance from the building and at greater depths to ascertain the

horizontal and vertical distribution of elevated lead concentrations in soil at the Site. If it cannot be

determined that the lead in soil is likely the result of lead paint on the building’s exterior such as

elevated levels from further than the drip line, Tetra Tech recommends the condition be reported to

MassDEP in accordance with 310 CMR 40.0315 and evaluated by a Licensed Site Professional.

This Field Sampling Plan (FSP) has been prepared to outline procedures for soil sampling at the Site.

This work is to be completed by Tetra Tech on behalf of the GSA and the USCG. As requested by the

GSA, Tetra Tech is completing an additional lead in soil sampling assessment at this location. It is Tetra

Tech’s understanding that the USCG has requested these environmental activities in preparation for

divesture of the property. Tetra Tech is supporting GSA efforts to conduct necessary environmental

compliance due diligence on behalf of USCG for the planned sale of 12 housing units in Wakefield,

Massachusetts.



2.0 FIELD SAMPLING PLAN

Tetra Tech will collect soil samples to a) confirm if elevated lead concentrations in soil samples 16-

TARRANT-SS-N(6-9”) and 20-TARRANT-SS-N(6-9”) constitute a recognized environmental condition

(REC); b) evaluate the nature and extent of lead in soil north of the housing units at 16 Tarrant Lane

and 20 Tarrant Lane; c) evaluate the potential sources of lead in soil in excess of the MassDEP RCS-1;

and d) provide recommendations for necessary remedial action. Subtasks include soil sample

installation and logging, soil sampling, sample management and shipping, and laboratory analysis, as

described in the following sections.

2.1 MOBILIZATION AND UTILITY MARK OUT

Tetra Tech will coordinate field activities with GSA, USCG personnel, DigSafe (1-888-DIG-SAFE) and the

Town of Wakefield regarding utility clearance. Tetra Tech will verify the locations of underground

utilities in the field prior to beginning work based on the DigSafe utility markings. The use of

mechanized equipment for the advancement of soil samples is not required for this sampling effort.

Hand tools including a spade, shovel, post hole digger, or hand auger will be used to reach the depths

required for sampling.

2.2 SOIL SAMPLE LOCATIONS

Eight soil sample locations will be advanced by hand at the locations shown in Figure 2. The soil sample

locations will be located as follows:

One soil sample location immediately adjacent to each of the two existing soil sample locations

(i.e., 16-TARRANT-SS-N and 20-TARRANT-SS-N) – two soil sample locations total;

One soil sample location outside the drip zone, approximately 10 feet from each of the two

existing soil samples in a direction perpendicular to the buildings’ exterior walls – two soil sample

locations total; and

Two soil sample location within five feet of the buildings’ exterior walls, on both sides of, and

approximately 10 feet from, each of the two existing soil samples – four soil sample locations

total.

The soil sample locations will be advanced using hand tools (i.e., spade, shovel, post hole digger, or

hand auger) to an approximate depth of 18 inches bgs. Soil samples will be collected from three

depths from each location. The location of each soil sample will be surveyed using a global positioning

system (GPS) unit.

2.3 SOIL SAMPLING AND ANALYSIS

The sample summary including numbers of samples, analytical method container, preservative, and

holding time requirements is listed in Tables 1 and 2.



Tetra Tech will collect up to 24 soil samples (grab samples), two field duplicate samples, and two

matrix spike (MS) and matrix spike duplicate (MSD) pairs. Three soil samples will be collected from

each soil sample location: one from a depth of 0 to 3 inches bgs, one from a depth of 6 to 10 inches

bgs, and one from a depth of 14 to 18 inches bgs to determine if elevated levels of lead are present

in soil at or below the depth where elevated levels of lead were previously identified. Up to four

additional soil samples may be collected to characterize soil or materials at Tetra Tech’s discretion

based on field observations during soil sample installation.

Soil samples will be collected from the soil sample locations, in accordance with Tetra Tech’s Standard

Operating Protocol for Soil Sampling with a Spade and Scoop included in Attachment A. It is assumed

that potential lead-based paint impacts will decline with depth. Therefore, soil samples will not be

collected beneath 18 inches bgs.

Samples will be collected for total lead analysis by a fixed-base laboratory using EPA Method 6010C,

with a 5-day turnaround time for the results.

2.4 INVESTIGATION-DERIVED WASTES

Soil cuttings generated during soil sample activities will be returned to the soil sample location from

which they were removed. Soil sample equipment will be washed with Alconox (or other approved

detergent) and rinsed with deionized water.

Used personal protective equipment (PPE) (e.g., protective gloves) and disposable sampling

equipment (e.g., scoops/trowels and mixing bowls) will be rinsed with deionized water, placed in

doubly-lined polyethylene trash bags, and properly discarded as general refuse.

2.5 DECONTAMINATION PROCEDURES

Dedicated, disposable soil sampling equipment (e.g., scoops/trowels and mixing bowls) will be used

between sampling locations. The hand tools used to advance the soil sample locations will be

decontaminated prior to beginning work. The hand tools will be washed with Alconox (or other

approved detergent) and rinsed with deionized water to remove excess soil after completion of each

soil sample location, prior to moving to the next location. The hand tools will be rinsed over the test

pit location so rinsate will infiltrate site soils. As needed, any other non-dedicated field equipment

will be decontaminated in accordance with Tetra Tech’s Standard Operating Protocol for

Decontaminating Sampling Equipment, included in Attachment A.

2.6 SITE HEALTH AND SAFETY

Field activities will be performed in accordance with the site-specific Health and Safety Plan (HASP)

to be developed prior to mobilizing to the Site. Field personnel that will be performing work on Site

will review the pertinent sections of the HASP prior beginning work. The Site Safety Officer (SSO) will

review health and safety requirements at the start each task with the appropriate on-site personnel.



Dust control practices (e.g., water sprayer) will be implemented as necessary if there is visible dust

in the breathing zone during soil sampling activities.

2.7 QUALITY CONTROL

Two duplicate samples will be taken to evaluate field and laboratory precision. Two matrix spike

analyses will be conducted to evaluate laboratory accuracy in Site soil. Two matrix spike duplicate

analyses will be conducted to evaluate laboratory precision in Site soil.

The screening criteria and method detection limits for soil are listed in Table 3. The project action

limit for Site soil is based on the current MCP RCS-1 reportable concentration for lead in soil of 200

mg/kg. Soil with lead concentrations below this standard will be considered not reportable under the

MCP, not subject to MCP requirements, and not a REC. The project action limit is consistent with

commercially-available specified laboratory methods.

Each sample collected will be assigned a unique sample tracking number that will be used to catalog

the results. The sample tracking number will consist of alpha-numeric characters identifying the Site,

sample medium, the sample location, and the sample depth (if appropriate) or date. Any other

pertinent information regarding sample identification will be recorded on the sample log-sheets or

in the field logbooks.

The alpha-numeric (A-N) coding to be used in the sample system is detailed below and in the

subsequent definitions.

NN-AAAAAAA - AA - A-A - (NN-NN”)

(Site ID) - (Medium) - (Location) - (Sample Depth)

Site identifier: “16-TARRANT” for 16 Tarrant Lane

Medium identifier: “SS” for surface soil samples

Sample location identifier: Each sample location will be assigned a unique identifier that can be

composed of both alpha and numeric characters.

Depth: For soil sample locations, this portion of the tracking number will represent the depth in

inches bgs from which the sample was collected. The sample depth for soil samples collected from 0

to 3 inches bgs, will be recorded as (0-3”); and for sample collected from 14 to 18 inches bgs, the

sample depth will be (14-18”). For example, a soil sample collected near existing soil sample location

16-TARRANT-SS-N at a depth interval of 14 to 18 inches bgs would be labeled 16-TARRANT-SS-N-

A(14-18”).



Blind field duplicate samples will be designated such that the location designation will be replaced

with “DUP” followed by a sequential value (the nth duplicate sample collected during the overall

sampling event) and the date (MMDDYY). The sample log sheet will note which sample location the

duplicate was collected from. For example, the first field duplicate sample collected on October 21,

2015 would be labeled 16-TARRANT-SS-DUP01-102115 and the second field duplicate collected the

next day on October 22, 2015 would be 16-TARRANT-SS-DUP02-102215.

Samples will be delivered to the analytical laboratory using standard chain of custody procedures.

2.8 LABORATORY ANALYSIS

Chemical analysis will be performed by a subcontracted fixed-base laboratory, Alpha Analytical. The

samples for total lead will be analyzed with EPA Method 6010C with a 5-day turnaround time on the

results.

Following receipt of the analytical laboratory report, Tetra Tech will compare the soil analytical

results to the EPA Direct Contact Clean up Level Criterion of 400 mg/kg and the MCP RCS for Soil

(RCS-1) standard of 200 mg/kg. Per 310 CMR 40.0317(8)(a) release of hazardous materials indicated

by residues in the environment emanating from a point of original application of lead-based paint is

exempt from reporting.



3.0 FIELD REPORT

A verbal recommendation with respect to whether or not lead in soil constitutes a REC, and required

notification to MassDEP if necessary, will be provided to GSA within 10 business days of obtaining

the laboratory results. Information will be prepared summarizing the nature and extent of lead in soil

north of the housing units at 16 Tarrant Lane and 20 Tarrant Lane, evaluating whether or not lead in

soil surrounding soil samples 16-TARRANT-SS-N(6-9”) and 20-TARRANT-SS-N(6-9”) constitute a REC

and providing recommendations for necessary remedial action. Tetra Tech will incorporate the

information and findings associated with the second lead in soil sampling event including pit logs,

analytical results, and maps, as necessary to document the work completed in the proper sections of

the Environmental Compliance Due Diligence report for the Wakefield USGS housing properties.

The MCP includes an exemption from reporting due to lead in soil emanating from a point of original

application of lead-based paint. If lead concentrations in soil are found to be limited to the near

surface soil immediately adjacent to exterior walls, the source of lead in soil is likely attributable to

original application of lead-based paint, is therefore exempt from reporting under the MCP and does

not constitute a REC. However, if it cannot be determined that the lead in soil is likely the result of

lead paint on the building’s exterior such as of elevated levels beyond the drip lines of the housing

units, Tetra Tech recommends the condition be reported to MassDEP in accordance with 310 CMR

40.0315 and evaluated by a Licensed Site Professional.



4.0 REFERENCES

Massachusetts Department of Environmental Protection (MassDEP). 2014. Massachusetts

Contingency Plan (MCP). 310 CMR 40.0000. April.

Tetra Tech, Inc. 2015. Environmental Compliance Due Diligence Activities Report for U.S. Coast

Guard Wakefield, Massachusetts Housing Units, 2, 6, 7, 10, 11, 12, 15, 16 and 20 Tarrant Lane,

91, 99 and 107 Hopkins Street, Wakefield, Massachusetts, 01880. Prepared for United States

General Services Administration, Office of Real Property Utilization and Disposal, Washington,

DC. November.

U.S. General Services Administration, Office of Real Property Utilization and Disposal (GSA).

2015. Statement of Work, Environmental Compliance Due Diligence in Support of the U.S. Coast

Guard (USCG) Housing Sales: Six Housing Locations in Maine, Massachusetts, Rhode Island, and

New Jersey, PS01 Modification. July 29.



FIGURES

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FIGURE 1SITE LOCATION MAP

SITELOCATION

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and Hopkins StreetWakefield, Massachusetts 01880

LegendApproximate Property Boundary

Tarrant Ln

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FIGURE 2PROPOSED SAMPLE LOCATIONS

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US Coast Guard Housing Units2 Housing Units on Tarrant LaneWakefield, Massachusetts 01880

Legend

&( Proposed Sample Location

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16 Tarrant Ln

20 Tarrant Ln

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16TARRANTSS-N(69")

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TABLES

TABLE 1

FIXED LABORATORY SAMPLE SUMMARYFIELD SAMPLING PLAN, PHASE II SOIL SAMPLING AND ANALYSIS

U.S. COAST GUARD WAKEFIELD NIKE HOUSING UNITS, WAKEFIELD, MASSACHUSETTS

U.S. Coast Guard Wakefield Nike Housing Units

Sample Type Analysis/MethodField

Samples(max)

FieldDuplicates(1) Field Blanks Trip Blanks(2) Total

Lab QualityControl

Samples (3)

Surface SoilMetals (lead)U.S EPA SW-846Method 6010C

24 2 0 0 26 2

Notes:

(1) Collect 1 duplicate per 20 field samples per sample matrix.

(2) Collect 1 trip blank per VOC sample shipment.

(3) Collect 1 Lab QC per 20 samples - Inorganics - Matrix Spike and aDuplicate. The Lab QC volume is not included in the total sample count.

TABLE 2

ANALYSES, SAMPLE CONTAINER, PRESERVATIVE, AND HOLDING TIME REQUIREMENTSFIELD SAMPLING PLAN, PHASE II SOIL SAMPLING AND ANALYSIS



Sample Medium Analysis Sample Container(1) Preservative Holding Time

Soil Metals (total lead) 1-4 ounce wide mouth jar Cool to 4o Celsius 6 months to analysis

Notes:

(1) Double volume needed for metal laboratory QC, at a rate of one per 20 field samples. Also, actual volumes and bottle requirements needed for all analyses will beverified with the selected analytical laboratory prior to initiation of sampling event.

TABLE 3

FIXED LABORATORY PARAMETERS AND BENCHMARKS

FIELD SAMPLING PLAN, PHASE II SOIL SAMPLING AND ANALYSIS


Analyte Method PQLs (mg/kg)DQL1

(mg/kg)Basis

LeadU.S. EPA SW-846

Method 6010C0.1 200 MCP RCS-1

mg/kg - milligrams per kilogram

PQL - Practical Quantitation Limit

DQL - Data Quality Levels

MCP RCS-1 (see note 1)

Method References:

● SW846 - Test Methods for Evaluating Solid Wastes. EPA Office of Solid Waste. Third Edition.

1. MassDEP RCS-1 reportable concentration for soil. Massachusetts Contingency Plan April 25, 2014 (MassDEP,

2014).




ATTACHMENT A:STANDARD OPERATING PROCEDURES

Tetra Tech Rizzo 1

Standard Operating Protocol for Soil Sampling with a Spade and Scoop Discussion The simplest, most direct method of collecting soil samples is with a spade and scoop. Remove the top cover of soil to the required depth with a lawn or garden spade and then use a smaller stainless steel scoop to collect the sample. Uses This method can be used in most soil types but is limited to sampling near the surface. Samples from depths greater than 50 cm are extremely labor intensive in most soil types. Very accurate, representative samples can be collected with this procedure. Use a flat, pointed mason trowel to cut a block of the desired soil when undisturbed profiles are required. A stainless steel scoop or lab spoon can be used in most other applications. Avoid the use of devices plated with chrome or other materials that may contaminate samples for laboratory analysis. Procedures for Use 1. Prior to initiating any work, the Field Technician and the Project Manager will review the

Health and Safety Plan developed for the specific site activities. The indicated measures of the Plan should be enacted prior to initiation of the sampling activities. Concerns not addressed in the Health and Safety Plan document are to be brought immediately to the attention of the Health and Safety Officer.

2. Carefully remove the top layer of soil to the desired sample depth with a shovel or spade.

3. Use a stainless steel scoop or trowel to remove and discard the layer of soil that was in contact with the shovel.

4. Collect the sample and transfer it to an appropriate sample bottle with a stainless steel spoon or equivalent.

5. Check that a teflon liner is present in the cap, if required. Secure the cap tightly.

6. Label the sample jar and document the sample location, depth and field conditions in the field log. Complete the chain-of-custody. Store samples for laboratory analysis in a cooler.

7. Decontaminate equipment after use and between sample locations according to the Standard Operating Protocol for Decontaminating Sampling Equipment.

Adapted from

Characterization of Hazardous Waste Sites — A Methods Manual: Volume II Available Sampling Methods, Second Edition, EPA-600/14-84-076, December 1984.

Tetra Tech1

Standard Operating Protocol for Decontaminating SamplingEquipment

Whenever possible, sampling equipment will be dedicated to each sampling location ordisposable equipment will be used. When this is not possible, field decontamination of theequipment will occur prior to the collection of samples for chemical analysis. The method ofchoice for decontamination is that which most fully removes site contaminants from thesampling equipment with the least interference to the ultimate chemical analysis. Do not usefluids that have been stored in plastic bottles to decontaminate field equipment. Deionized waterand methanol used for decontamination should be stored in nalgene or teflon bottles.

Equipment used to collect samples for chemical analysis will be decontaminated as follows:

1. Wash equipment with a nonphosphate detergent solution (e.g., Alconox) and a brush.

2. Rinse thoroughly with tap water.

3. Rinse with reagent grade methanol.

4. Rinse the equipment thoroughly with deionized water.

5. Equipment that is stored or transported will be kept in a dedicated plastic bag or wrapped inaluminum foil to prevent contamination prior to use.

6. When collecting water samples, rinse the equipment three times with the media beingsampled before collecting the sample.

Steam cleaning is another acceptable technique for field decontamination.

Decontamination procedures will be recorded in the field book or on the field report form. Theseentries will include the date, time, location, personnel, equipment, and specific procedures usedfor the decontamination of field equipment and the source of all fluids, including water, used inthe procedure. Deviations from the standard protocols will also be noted in the field log.

Waste water and methanol solutions generated during decontamination procedures will bedischarged on-site, provided that the pH is between 2 and 12.

wakefield lead in soil sampling plan report fd...the concentration of lead in two samples exceeded...

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