Supplemental Attach 2-2008-Eldred Rock Tech Memo.pdf

4300 B Street, Suite 600 Anchorage, AK 99503-5922 USA 9.907.563-3322 Fax 9.907.563-3320

Jacobs Engineering Group Inc.

Memorandum

Date 2 April 2008

To Mark Ridgway, USCG Bob Brock, USAED Bob Glascott, USAED

From Jon McVay

Subject Eldred Rock; Project 17-J4199; Draft October 2007 Eldred Rock Sample Results

Introduction

The Eldred Rock Lighthouse is located in southeast Alaska, on Eldred Rock Island in the Lynn Canal, 25 miles south of Haines and 50 miles northwest of Juneau, at 58° 58� 03� N and 135° 12� 02� W (Figure 1, Attachment 1). The Eldred Rock Lighthouse, Alaska�s oldest lighthouse, was constructed as part of a congressional program passed in 1900 to build light stations in Alaska. Construction of the lighthouse began in 1905, and the station was first lit on 1 June 1906. The Eldred Rock Lighthouse was decommissioned in 1973 and is now operated remotely as a minor aid to navigation. The site was converted to solar power in the 1980s.

The U.S. Coast Guard (USCG) defines Eldred Rock as an excess property and is in the process of turning the 2.4-acre parcel over to the Bureau of Land Management under the National Historic Lighthouse Preservation Act of 2000. The USCG is in the process of conveying Eldred Rock to the Eldred Rock Lighthouse Committee under the sponsorship of the Sheldon Museum and Cultural Center. As part of the divesture process, USCG agreed to remove waste posing a potential threat to human health or the environment at the Eldred Rock site. In accordance with the agreement between the USCG and the Alaska Department of Environmental Conservation (ADEC), Jacobs personnel conducted a Modified Phase II/III Environmental Due Diligence Audit (EDDA) Site Investigation at the USCG Eldred Rock Light Station. The objectives of the investigation were to determine an average site-wide lead concentration, to delineate residual-range organics (RRO) contamination near the paint shed, and to evaluate the potential hazards posed to human and environmental health resulting from these contaminants. Photographs collected during the investigation are presented in the Photo Log (Attachment 2). The following sections summarize the work completed during the 2007 investigation.

Work Plan Deviations

The Final 2007 Modified Phase II/III EDDA Eldred Rock Work Plan (U.S. Army Engineer District, Alaska) identified a defined lead exposure area covering the entire island. Upon completion of reconnaissance activities, the field team determined that samples could not be obtained from the coastal areas, which consisted of large boulders and lava formations. The exposure area was adjusted to include the elevated vegetative areas and a small section of the beach that exhibited signs of recreational use. In addition, soil samples were not collected at the depth interval of 6 to 12 inches below ground surface (bgs) based on consistent refusal less than 1 foot bgs.

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Lead Field Screening Results

A total of 45 field screening samples were collected throughout the adjusted exposure area and analyzed using a Niton X-Ray Fluorescence lead screening device. All field screening samples were collected from the ground surface to 6 inches bgs. Sample locations are depicted in Figure 2 (Attachment 1). The average lead screening concentration was 434 parts per million (ppm). Sample locations were submitted for both toxicity characteristic leaching procedure (TCLP) and total lead analyses as discussed in the following sections. Table 1 presents the field screening results.

Table 1 Eldred Rock Lead Field Screening Results

Sample Location NITON Results (ppm) Field Notes

1 <54 Vegetative mat/roots

2 384 High organics with few small cobbles

3 358 High organics and roots on top bedrock

4 77.7 Mostly organics with some sand

5 147 Mostly organics

6* 2,040 Visible paint chips

7 172 High organics with some large gravels and small cobbles

8 60.6 High organics with some large gravels and small cobbles

9 174 Very organic material

10 486 High organics

11 <81 High organics with many large gravels and small cobbles

12 272 Vegetative mat and roots

13* 1,180 Many paint chips

14 <26 Rocky with vegetative mat, no paint chips

15 <30 Organic on top of bedrock

16 <41 High organics

17 <72 Met refusal

18 67.6 Organics overlying beach material

19 <59 Vegetation on top of cobbles

20 <39 Vegetation overlying beach material

21 169 Organic soil with gravel and paint chips

22* 1,690 Gravel soil with paint chips

23 69.8 Visible paint chips

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Sample Location NITON Results (ppm) Field Notes

24 188 Organic soil; no paint chips

25 283 No paint chips present

26 <69 High organics

27 46.5 Soil with organics, no visible paint chips

28 248 Visible paint chips

29 514 Paint chips present

30 <100 No paint chips present

31 184 Organic matter

32* 808 Vegetative mat

33* 1,080 Visible paint chips

34 74 Mostly bedrock, no visible paint chips

35* 4,890 Many paint chips

36* 594 Organic with visible paint chips

37* 1,620 Mostly organic with visible paint chips

38 <170 Vegetative mat

39 <76 Mostly organic

40 444 Paint chips present

41 <80 High organics

42 <140 Beach material (small rocks and shells)

43 <110 Beach material (small rocks and shells)

44 <150 Beach material (small rocks and shells)

45 <130 Beach material (small rocks and shells)

Notes: *Sample locations submitted for TCLP and lead analysis.

All field screening samples were collected from surface to 6 inches bgs.

Lead Analytical Sampling Results

A total of 45 analytical samples were collected from the same locations as the field screening samples. Subsurface samples were not obtained based on consistent refusal at less than 1 foot bgs. All soil samples were collected from depths ranging between 0 and 6 inches bgs. Eight of these samples were submitted for TCLP analyses based on the highest field screening results.

Total lead analytical results were compared to the alternate cleanup level (ACL) of 1,064 milligrams per kilogram (mg/kg) and TCLP analytical results were compared to the cleanup level of 5 milligrams per liter (mg/L) as defined in 40 CFR 261.24 for TCLP lead. Analytical results were used to calculate a site-wide average lead concentration of 1,492 mg/kg.

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Table 2 Eldred Rock Lead Analytical Results

Sample Number Sample Delivery Group

(SDG) Lead (mg/kg) TCLP Lead (mg/L)

07ER-SW-001SO K0709524 90.3 �

07ER-SW-101SO

Dup of 07ER-SW-001SO K0709524 345 �

07ER-SW-002SO K0709524 745 �

07ER-SW-003SO K0709524 450 �

07ER-SW-004SO K0709524 3,640 �

07ER-SW-005SO K0709524 1,300 �

07ER-SW-006SO K0709524 7,010 1.03

07ER-SW-106SO

Dup of 07ER-SW-006SO K0709524 8,290 �

07ER-SW-007SO K0709524 1,160 �

07ER-SW-008SO K0709524 201 �

07ER-SW-009SO K0709524 541 �

07ER-SW-010SO K0709524 159 �

07ER-SW-011SO K0709524 40.3 �

07ER-SW-012SO K0709524 1,150 �

07ER-SW-013SO K0709524 4,550 2.47

07ER-SW-014SO K0709524 325 �

07ER-SW-015SO K0709524 47.8 J �

07ER-SW-016SO K0709524 197 �

07ER-SW-017SO K0709524 814 �

07ER-SW-018SO K0709524 353 �

07ER-SW-019SO K0709524 31.3 J �

07ER-SW-020SO K0709524 621 �

07ER-SW-021SO K0709524 56.1 �

07ER-SW-022SO K0709524 5,210 7.39

07ER-SW-023SO K0709524 2,180 �

07ER-SW-024SO K0709528 385 �

07ER-SW-025SO K0709528 427 �

07ER-SW-026SO K0709528 703 �

07ER-SW-027SO K0709528 302 �

07ER-SW-127SO

Dup of 07ER-SW-027SO K0709528 288 �

07ER-SW-028SO K0709528 1,300 �

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Sample Number Sample Delivery Group

(SDG) Lead (mg/kg) TCLP Lead (mg/L)

07ER-SW-029SO K0709528 2,750 �

07ER-SW-030SO K0709528 577 �

07ER-SW-031SO K0709528 1,030 �

07ER-SW-032SO K0709528 31,200 0.76

07ER-SW-032SO1 K0711789 7,990 �

07ER-SW-032SO-DUP1 K0711789 5,510 �

07ER-SW-033SO K0709528 2,260 2.47

07ER-SW-034SO K0709528 1,880 �

07ER-SW-035SO K0709528 2,610 9.52

07ER-SW-036SO K0709528 6,680 0.57

07ER-SW-037SO K0709528 5,950 0.82

07ER-SW-137SO

Dup of 07ER-SW-037SO

K0709528 6,720 �

07ER-SW-038SO K0709528 545 �

07ER-SW-039SO K0709528 369 �

07ER-SW-040SO K0709528 321 �

07ER-SW-041SO K0709528 207 �

07ER-SW-042SO K0709528 9.26 J �

07ER-SW-043SO K0709528 ND [19.5] �

07ER-SW-044SO K0709528 ND [19.8] �

07ER-SW-144SO

Dup 07ER-SW-044SO K0709528 23.7 �

07ER-SW-045SO K0709524 8.68 J �

Notes:

1These results are the re-analysis of sample 07ER-SW-032SO. The sample was spilt, homogenized, and re-analyzed.

Bold = Exceeds cleanup criteria J = The analyte was positively identified but the associated result was less than the practical quantitation limit (PQL) but greater than the method detection limit (MDL).

� = not analyzed [ ] = Value in brackets presents the PQL ND = Nondetect All samples were collected from 0 to 6� bgs

RRO Field Screening Results

Previous investigations at the Eldred Rock Light Station indicated elevated concentrations of RRO near the Paint Shop. Field screening samples were collected in 2007 to guide the locations of analytical soil samples to delineate RRO contamination. RRO field screening activities began at the source location as depicted in Figure 3 (Attachment 1). A total of 17 heated head space field screening samples were collected in the Paint Shop area and analyzed with a photoionization detector (PID). The average concentration was 6.3 ppm. Table 3 presents the PID field screening results from the Paint Shed area.

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Table 3 Eldred Rock RRO Field Screening Results

Sample Location PID Results (ppm)

RRO 1* 9.9

RRO 2 3.1

RRO 3* 4.3

RRO 4* 7.9

RRO 5 1.5

RRO 6* 7.8

RRO 7* 12.1

RRO 8* 18.6

RRO 9* 4.6

RRO 10* 15

RRO 11 2.8

RRO 12* 7.7

RRO 13* 4.6

RRO 14 1.4

RRO 15 1.9

RRO 16 0.9

RRO 17 3.7

Note: * Analytical sample location.

RRO Analytical Results

A total of 10 analytical samples were collected from locations of the highest PID field screening results for RRO analysis by AK103 and by silica gel cleanup process to remove naturally occurring organic material from the sample results. In general, no staining of soil was observed and no petroleum odors were detected during sampling activities. The area was heavily vegetated, with water entering the borings immediately after hand-augering activities. Analytical soil sample results were compared to ADEC Method Two Ingestion Cleanup levels (8,300 mg/kg). No sample results exceeded the screening criteria and the average RRO concentration was 187 mg/kg. Table 4 presents the analytical results.

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Table 4 Eldred Rock RRO Analytical Results

Analyte SDG SDG RRO (mg/kg) RRO - Silica Gel Treated (mg/kg)

07ER-PS-RRO001SO K0709522 990 JH,JL+ 240

07ER-PS-RRO002SO K0709522 470 JH,JL+ 230

07ER-PS-RRO003SO K0709522 440 JH,JL+ 220

07ER-PS-RRO004SO K0709522 560 JH,JL+ 110 J

07ER-PS-RRO005SO K0709522 530 JH,JL+ 140 J

07ER-PS-RRO006SO K0709522 890 JH,JL+ 190 J

07ER-PS-RRO007SO K0709522 640 JH,JL+ 110 J

07ER-PS-RRO008SO K0709522 1,200 JH,JL+ 300

07ER-PS-RRO108SO

Dup of 07ER-PS-

RRO008SO

K0709522 1,300 JH,JL+ 250

07ER-PS-RRO009SO K0709522 780 JH,JL+ 140 J

07ER-PS-RRO010SO K0709522 510 JH,JL+ 130 J

Notes:

JH = The numerical result is considered an estimate because the analysis was performed at greater than the method holding time and less than twice the method holding time.

JL+ = The result is an estimated value because the analyte failed recovery criteria in the laboratory control sample (LCS) and/or laboratory control sample duplicate (LCSD) samples.

J = The analyte was positively identified but the associated result was less than the PQL but greater than the MDL.

Data Evaluation and Quality Assessment

An evaluation of the data using Rosner�s outlier test from PRO UCL software determined that sample 07ER-SW-032SO (analyzed for lead) was a statistical outlier (31,200 mg/kg) compared to the results of the overall data for lead. The sample was homogenized, split, and each split sample was re-analyzed. The results were 7,990 mg/kg and 5,510 mg/kg, respectively. The 7,990 mg/kg result was used to calculate the site-wide average lead concentration.

A data quality review and ADEC laboratory data review checklists (Attachment 3) were completed by Jacobs, using the Quality Assurance Project Plan from the 2007 Eldred Rock Work Plan for compliance to quality control criteria for holding times, LCS control limits, surrogate spike control limits, matrix spike sample control limits, and laboratory method blanks.

The overall quality of the data was acceptable as qualified. Flagged data are considered usable but estimated. The following data qualifiers were applicable to the 2007 Eldred Rock analytical data.

J � The analyte was positively identified, but the associated result was less than the PQL but greater than or equal to the MDL.

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JH � The numerical result was considered an estimate because the analysis was performed at greater than the method holding time and less than twice the method holding time. The result may be biased low.

JL+ � The result was an estimated value because the analyte failed recovery criteria in the LCS and/or LCSD. The result was biased high because the LCS and/or LCSD recovery exceeded the upper control limit.

All AK103 non-silica gel extracts were analyzed outside the 40 day extract hold time and are qualified �JH�. Samples 07ER-PS-RRO001SO through 07ER-PS-RRO010SO and 07ER-PS- RRO108SO may be biased low.

The LCS for AK103 batch KWG0713642 (SDG K0709522) had a recovery of 123 percent; the upper control limit is 120 percent. The following samples are qualified �JL+�. Samples 07ER- PS-RRO001SO through 07ER-PS-RRO010SOand 07ER-PS-RRO108SO may be potentially biased high. No other anomalies associated with the analysis of these samples affect data usability. The supporting laboratory documentation is located in Attachment 3.

Conclusions

The following sections present the conclusions for the lead and RRO-contaminated soil at Eldred Rock Light Station.

Lead

A total of 45 field screening and analytical soil samples were collected for lead analysis. The site-wide lead average exceeded the ACL of 1,064 mg/kg with a concentration of 1,492 mg/kg.

Table 5 presents the options available for Eldred Rock.

Table 5 Eldred Rock Lead Remediation Options

Option Description Advantages Disadvantages

Eliminates potentially harmful exposure scenarios.

No elimination of exposure pathway.

Access Restriction

Restrict access to Eldred Rock except for

USCG, NOAA, and FAA personnel

Reduces risk to site workers performing the work based on the terrain and logistics issues.

Conflicts with National Lighthouse

Preservation Act.

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Option Description Advantages Disadvantages

Requires annual monitoring of the cap.

Cap Cap the lead-impacted soil surrounding the buildings.

Reduces exposure to lead-impacted soil.

Requires precarious logistics: Transport of heavy equipment, cap material, sling-loading of all equipment and materials.

Risky precarious logistics: Transport of heavy equipment, backfill material, sling-loading of all equipment and materials.

Soil Removal

Excavate and remove all lead-impacted soil from around the buildings. Conduct confirmation sampling.

Removes lead source.

Extensive site restoration after removal activities.

Reevaluation of Exposure Scenarios

Recalculate the original risk screening performed by CH2M Hill.

Technical approach may be used at all Light Stations in Southeast

Alaska.

Does not mitigate the source.

Ease of application.

In Situ Treatment

Chemical treatment (i.e., EcoBond) can reduce TCLP concentrations and bioavailability.

Sufficiently reduces the risk to receptors.

TCLP concentration reduction may vary from site to site.

RRO

The results of the Paint Shop samples analyzed for RRO contamination indicate that RRO is not a contaminant of concern. RRO was detected in all samples below applicable cleanup criteria.

Silica gel cleanup was also run on each sample to remove biogenic organics. RRO concentrations were significantly lower after being run through the process. No further action is required.

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ATTACHMENT 1

Figures

FAIRBANKS

ANCHORAGE

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PROJECT LOCATION AND VICINITY MAP

ELDRED ROCK, ALASKA

Fig 1 Project Location.dwg

Fig 1 Project Location

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ABBREVIATIONS / ACRONYMS

J THE RESULT IS AN ESTIMATED VALUE; THE ANALYTE

WAS POSITIVELY IDENTIFIED BUT THE RESULT WAS

LESS THAN THE PQL BUT GREATER THAN THE MDL

MDL METHOD DETECTION LIMIT

mg/kg MILLIGRAMS PER KILOGRAM mg/L MILLIGRAMS PER LITER

NA NOT ANALYZED

ND NOT DETECTED; PQL SHOWN IN BRACKETS

PQL PRACTICAL QUANTITATION LIMITS

TCLP TOXICITY CHARACTERISTIC LEACHING PROCEDURE

NOTES

1. RESULTS IN BOLD TEXT EXCEEDED CLEANUP CRITERIA.

2. LEAD SAMPLE UNITS ARE mg/kg; TCLP LEAD SAMPLE

UNITS ARE mg/L.

3. THESE RESULTS ARE THE RE-ANALYSIS OF SAMPLE

07ER-SW-032SO. THE SAMPLE WAS SPLIT,

HOMOGENIZED, AND RE-ANALYZED.

07ER-SW-001SO

Lead 90.3

07ER-SW-101SO DUP

Lead 345

07ER-SW-002SO

Lead 745

07ER-SW-003SO

Lead 450

07ER-SW-030SO

Lead 577

07ER-SW-035SO

Lead 2,610 TCLP Lead 9.52

07ER-SW-031SO

Lead 1,030

07ER-SW-029SO

Lead 2,750

07ER-SW-004SO

Lead 3,640

07ER-SW-005SO

Lead 1,300

07ER-SW-028SO

Lead 1,300

07ER-SW-032SO ³

Lead 7,990

07ER-SW-032SO ³ DUP

Lead 5,510

07ER-SW-033SO

Lead 2,260 TCLP Lead 2.47

07ER-SW-006SO

Lead 7,010 TCLP Lead 1.03

07ER-SW-106SO DUP

Lead 8,290

07ER-SW-027SO

Lead 302

07ER-SW-127SO DUP

Lead 288

07ER-SW-034SO

Lead 1,880

07ER-SW-007SO

Lead 1,160

07ER-SW-036SO

Lead 6,680 TCLP Lead 0.57

07ER-SW-043SO

Lead ND [19.5]

07ER-SW-044SO

Lead ND [19.8]

07ER-SW-144SO DUP

Lead 23.7

07ER-SW-042SO

Lead 9.26

07ER-SW-045SO

Lead 8.68 J07ER-SW-039SO

Lead 369

07ER-SW-040SO

Lead 321

07ER-SW-026SO

Lead 703

07ER-SW-009SO

Lead 541

07ER-SW-008SO

Lead 201

07ER-SW-010SO

Lead 159

07ER-SW-037SO

Lead 5,950 TCLP Lead 0.82

07ER-SW-137SO DUP

Lead 6,720

07ER-SW-038SO

Lead 545

07ER-SW-025SO

Lead 427

07ER-SW-041SO

Lead 207

07ER-SW-024SO

Lead 385

07ER-SW-023SO

Lead 2,180

07ER-SW-022SO

Lead 5,210 TCLP Lead 7.39

07ER-SW-021SO

Lead 56.1

07ER-SW-014SO

Lead 325

07ER-SW-017SO

Lead 814

07ER-SW-018SO

Lead 353

07ER-SW-019SO

Lead 31.3 J

07ER-SW-020SO

Lead 621

07ER-SW-011SO

Lead 40.3

07ER-SW-012SO

Lead 1,150

07ER-SW-013SO

Lead 4,550

07ER-SW-015SO

Lead 47.8 J

07ER-SW-016SO

Lead 197

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LEAD EXPOSURE AREA

POTENTIAL SAMPLE GRID

ELDRED ROCK LIGHT STATION, ALASKA

Fig 2 Sample Locations.dwg

Fig 2 Sample Locations

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FIELD SCREENING SAMPLE WITH ANALYTICAL

RESULTS

FIELD SCREENING SAMPLE ONLY

1997 CH2M HILL SAMPLE

FUEL OIL LINE

LIGHT

RRO RESIDUAL-RANGE ORGANICS

NOTE

1. ALL RRO SAMPLE UNITS ARE mg/kg (MILLIGRAMS

PER KILOGRAM).

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RRO 470

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RRO 440

07ER-RRO004-SO

RRO 560

07ER-RRO005-SO

RRO 530

07ER-RRO006-SO

RRO 890

07ER-RRO007-SO

RRO 640

07ER-RRO008-SO

RRO 1,200

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RRO 780

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RRO 510

07ER-RRO001-SO

RRO 990

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PAINT SHED 2007 SAMPLE LOCATIONS

AND ANALYTICAL RESULTS

ELDRED ROCK LIGHT STATION, ALASKA

Fig 3 Paint Shed.dwg

Fig 3 Paint Shed

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ATTACHMENT 2

Photo Log

Aerial photograph of the Eldred Rock Light Station taken from heilcopter on the northwest side of the island. Photo taken by SH on 10/10/07.

Eldred Rock hillside sampling location (lead sample #11) looking south from the Boathouse. Photo taken by JA on 10/10/07.

Eldred Rock beach displaying signs of recreational activity sampled for lead (samples #42 through #45). Photo looking northwest at location of sample #45 from location of sample #43. Photo taken by DA on 10/10/07.

Eldred Rock beach displaying signs of recreational activity sampled for lead (samples #42 through #45). Photo looking west towards sample #42 from location of sample #45. Photo taken by DA on 10/10/07.

Collecting soil sample for lead analysis at location #3 southwest of the light station building. Photo taken by JA on 10/10/07.

Photo of RRO field screening samples (pink flags) on the north side of the Paint Shop taken from the Carpenter Shop. Photo taken by CS on 10/11/07.

ATTACHMENT 3

ADEC Laboratory Data Review Checklists

Version 2.4 Page 1 of 8 08/07

Laboratory Data Review Checklist

Completed by:

Title:

Date:

CS Report Name:

Report Date:

Consultant Firm:

Laboratory Name:

Laboratory Report Number:

ADEC File Number:

ADEC RecKey Number:

1. Laboratory

a. Did an ADEC CS approved laboratory receive and perform all of the submitted sample analyses?

Yes

No

Comments:

b. If the samples were transferred to another �network� laboratory or sub-contracted to an alternate laboratory, was the laboratory performing the analyses ADEC CS approved?

2. Chain of Custody (COC)

a. COC information completed, signed, and dated (including released/received by)?

Angela Elmore - Jacobs Engineering

Project Chemist

February 26, 2008

Eldred Rock Technical Memorandum

February 29, 2008

Jacobs Engineering

Columbia Analytical Services

K0709522

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Version 2.4 Page 2 of 8 08/07

b. Correct analyses requested?

3. Laboratory Sample Receipt Documentation

a. Sample/cooler temperature documented and within range at receipt (4° ± 2° C)?

b. Sample preservation acceptable � acidified waters, Methanol preserved VOC soil (GRO, BTEX, Volatile Chlorinated Solvents, etc.)?

c. Sample condition documented � broken, leaking (Methanol), zero headspace (VOC vials)?

d. If there were any discrepancies, were they documented? For example, incorrect sample containers/preservation, sample temperature outside of acceptable range, insufficient or missing samples, etc.?

e. Data quality or usability affected? Explain.

4. Case Narrative

a. Present and understandable?

The temperature blank was documented at 1.6°C and the cooler temperature at 0.8°C.

According to the case narrative and cooler receipt there were no anomalies associated with the sample condition.

The temperatures were noted in the cooler receipt form.

Although the temperature blank was below the acceptable range, the samples were not frozen and data quality and usability are not affected.

Version 2.4 Page 3 of 8 08/07

b. Discrepancies, errors or QC failures identified by the lab?

c. Were all corrective actions documented?

d. What is the effect on data quality/usability according to the case narrative?

5. Samples Results

a. Correct analyses performed/reported as requested on COC?

b. All applicable holding times met?

c. All soils reported on a dry weight basis?

d. Are the reported PQLs less than the Cleanup Level or the minimum required detection level for the project?

Discrepancies are discussed in the respective sections of this checklist.

Corrective actions were not required.

According to the case narrative there is no affect on the data usability.

AK103 silica gel treated was performed, the non silica gel treated analysis was not performed within the holding time.

Method AK103 non-silica gel treated extracts were analyzed outside the 40 day hold time.

Non silica gel treated samples are qualified "JH" and results may be biased low.

Version 2.4 Page 4 of 8 08/07

6. QC Samples

a. Method Blank

i. One method blank reported per matrix, analysis and 20 samples?

ii. All method blank results less than PQL?

iii. If above PQL, what samples are affected?

iv. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

v. Data quality or usability affected? Explain.

b. Laboratory Control Sample/Duplicate (LCS/LCSD)

i. Organics � One LCS/LCSD reported per matrix, analysis and 20 samples?

ii. Metals/Inorganics � one LCS and one sample duplicate reported per matrix, analysis and

20 samples?

According to the project QAPP all samples associated with method blanks with detections above the MDL and within a factor of five would be qualified "B" and considered potentially biased high. AK103 method blank associated with lab lot KWG0713642 had a detection above the MDL but below the PQL at 14 mg/kg.

All sample results were greater than a factor of five of the method blank contamination. No samples were affected.

Data quality and usability has not been affected.

Version 2.4 Page 5 of 8 08/07

iii. Accuracy � All percent recoveries (%R) reported and within method or laboratory limits?

And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, AK102 75%-125%, AK103 60%-120%; all other analyses see the laboratory QC pages)

iv. Precision � All relative percent differences (RPD) reported and less than method or laboratory limits? And project specified DQOs, if applicable. (AK Petroleum methods 20%; all other analyses see the laboratory QC pages)

v. If %R or RPD is outside of acceptable limits, what samples are affected?

vi. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

vii. Data quality or usability affected? Explain.

c. Surrogates � Organics Only

i. Are surrogate recoveries reported for organic analyses � field, QC and laboratory samples?

The AK103 non-silica gel treated LCS associated with lab lot KWG0713642 had a percent recovery of 123%.

All samples associated with lot KWG0713642 were affected. Samples 07ER-PS-RRO001SO, 07ER-PS-RRO002SO, 07ER-PS-RRO003SO, 07ER-PS-RRO004SO, 07ER-PS-RRO005SO, 07ER-PS-RRO006SO, 07ER-PS-RRO007SO, 07ER-PS-RRO008SO, 07ER-PS-RRO009SO, 07ER-PS-RRO010SO, and 07ER-PS-RRO108SO.

Samples are qualifed "JL+", the result is an estimated value because the analyte failed recovery criteria in the LCS and/or LCSD samples. The result is biased high because the LCS recovery exceeded the upper control limit.

Results qualified "JL+" are considered potentially biased high.

Version 2.4 Page 6 of 8 08/07

ii. Accuracy � All percent recoveries (%R) reported and within method or laboratory limits?

And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other analyses see the laboratory report pages)

iii. Do the sample results with failed surrogate recoveries have data flags? If so, are the data flags clearly defined?

iv. Data quality or usability affected? Explain.

d. Trip blank � Volatile analyses only (GRO, BTEX, Volatile Chlorinated Solvents, etc.): Water and

Soil

i. One trip blank reported per matrix, analysis and cooler?

ii. All results less than PQL?

e. Field Duplicate

i. One field duplicate submitted per matrix, analysis and 10 project samples?

Not Applicable

Not Applicable

Version 2.4 Page 7 of 8 08/07

ii. Submitted blind to lab?

iii. Precision � All relative percent differences (RPD) less than specified DQOs?

(Recommended: 30% water, 50% soil)

RPD (%) = Absolute value of: (R1-R2) x 100

((R1+R2)/2)

Where R1 = Sample Concentration R2 = Field Duplicate Concentration

f. Decontamination or Equipment Blank (if applicable)

i. All results less than PQL?

ii. If above PQL, what samples are affected?

iii. Data quality or usability affected? Explain.

Samples 07ER-PS-RRO008SO and 07ER-PS-RRO108SO are duplicates.

Version 2.4 Page 8 of 8 08/07

7. Other Data Flags/Qualifiers (ACOE, AFCEE, Lab Specific, etc.)

a. Defined and appropriate?

Version 2.4 Page 1 of 8 08/07

Date:

CS Report Name:

Report Date:

Consultant Firm:

Laboratory Name:

Laboratory Report Number:

February 27, 2008

Eldred Rock Technical Memorandum

February 29, 2008

Jacobs Engineering

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Version 2.4 Page 2 of 8 08/07

The temperatures were not within the 4° ± 2°C. The temperature is not applicable because the cooler contained lead analysis only. Method SW6020 does not require temperature preservation.

There were no discrepancies associated with this delivery group.

Version 2.4 Page 3 of 8 08/07

According to the case narrative there is no affect on the data usability.

Version 2.4 Page 4 of 8 08/07 high. SW6010B method blank associated with lab lot 56779 had a detection above the MDL but below the PQL at 0.03 mg/L. SW6020 method blank associated with lab lot 56828 had a detection above the MDL but below the PQL at 0.06 mg/kg. SW6020 method blank associated with lab lot 56829 had a detection above the MDL but below the PQL at 0.05 mg/kg.

All sample results were greater than a factor of five of the method blank contamination. No samples were affected.

Not Applicable

Data quality and usability has not been affected.

Not applicable

One LCS and a MS/MSD were reported per batch.

Version 2.4 Page 5 of 8 08/07

And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, All LCS recoveries were within 80-120%. MS and MSD recoveries associated with lab lots 56828 and 56829 are not applicable because the spike concentrations were less than 1/2 of the parent sample.

The RPD associated with MS/MSD lab lot 56828 was greater than 20% at 82%. This may be due to sample heterogeneity and/or the high concentrations of the sample compared to the spike amounts.

The MS/MSD parent sample associated with lab lot 56828 was 07ER-SW-006SO.

The MS/MSD parent sample associated with lab lot 56829 was 07ER-SW-013SO

Samples were not flagged because the spike concentrations were less than 1/2 of the parent sample.

Data quality and usability is not affected.

Version 2.4 Page 6 of 8 08/07

And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other

Not Applicable

Not Applicable

Not Applicable

Version 2.4 Page 7 of 8 08/07

Samples 07ER-SW-001SO and 07ER-SW-101SO are duplicates.

Samples 07ER-SW-006SO and 07ER-SW-106SO are duplicates.

Duplicate pair 07ER-SW-001SO/07ER-SW-101SO had concentrations of 90.3 mg/kg and 345 mg/kg respectively (RPD 117%). This is possibly due to sample heterogeneity of the site.

Duplicate pair 07ER-SW-006SO/07ER-SW-106SO was within criteria with a RPD of 17%.

Data quality and usability has not been affected.

Not Applicable

Version 2.4 Page 8 of 8 08/07

Version 2.4 Page 1 of 8 08/07

Date:

CS Report Name:

Report Date:

Consultant Firm:

Laboratory Name:

Laboratory Report Number:

February 27, 2008

Eldred Rock Technical Memorandum

February 29, 2008

Jacobs Engineering

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Version 2.4 Page 2 of 8 08/07 cooler contained lead analysis only. Method SW6020 does not require temperature preservation.

Version 2.4 Page 3 of 8 08/07

Version 2.4 Page 4 of 8 08/07 high. SW6020 method blank associated with lab lot 56828 had a detection above the MDL but below the PQL at 0.06 mg/kg. SW6020 method blank associated with lab lot 56830 had a detection above the MDL but below the PQL at 0.03 mg/kg.

All sample results were greater than a factor of five of the method blank contamination. No samples are affected.

Not Applicable

Data quality and usability has not been affected.

Version 2.4 Page 5 of 8 08/07

And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, All LCS recoveries were within 80-120%. MS and MSD recoveries associated with lab lots 56828 and 56830 are not applicable because the spike concentrations were less than one-half of the parent sample.

The RPD associated with MS/MSD lab lot 56830 was greater than 20% at 120%. This may be due to sample heterogeneity and/or the high concentrations of the sample compared to the spike amounts.

The MS/MSD parent sample associated with lab lot 56828 was 07ER-SW-006SO (SDG K0709524). The MS/MSD parent sample associated with lab lot 56830 was 07ER-SW-040SO.

Samples were not flagged because the spike concentrations were less than 1/2 of the parent sample.

Data quality and usability is not affected.

Version 2.4 Page 6 of 8 08/07

And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other

Not Applicable

Not Applicable

Not Applicable

Version 2.4 Page 7 of 8 08/07

Samples 07ER-SW-027SO and 07ER-SW-127SO are duplicates.

Samples 07ER-SW-037SO and 07ER-SW-137SO are duplicates.

Samples 07ER-SW-044SO and 07ER-SW-144SO are duplicates.

Duplicate pair 07ER-SW-044SO/07ER-SW-144SO had concentrations of ND and 23.7% respectively. The RPD is 99.8% if the MDL is used for sample 07ER-SW-044SO. This is possibly due to sample heterogeneity of the site and of the sample. Duplicate pair 07ER-SW-027SO/07ER- SW-127SO was within criteria with a RPD of 4.7%. Duplicate pair 07ER-SW-037SO/07ER-SW- 137SO was within criteria with a RPD of 12%.

Data quality and usability has not been affected.

Version 2.4 Page 8 of 8 08/07

Version 2.4 Page 1 of 7 08/07

Date:

CS Report Name:

Report Date:

Consultant Firm:

Laboratory Name:

Laboratory Report Number:

February 27, 2008

Eldred Rock Technical Memorandum

February 29, 2008

Jacobs Engineering

K0711789

The samples were received and original logged in as SDG K0709528. We requested the lab to re-analyze sample 07ER-SW-032SO due to the high lead concentration. The lab split the sample and homogenized each split according to our instruction.

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Version 2.4 Page 2 of 7 08/07 cooler contained lead analysis only. Method SW6020 does not require temperature preservative.

Version 2.4 Page 3 of 7 08/07

Version 2.4 Page 4 of 7 08/07 high. SW6020 method blank associated with lab lot 60095 had a detection above the MDL but below the PQL at 0.02 mg/kg.

All sample results are greater than a factor of five of the method blank contamination. No samples are affected.

Not Applicable

Data quality and usability has not been affected.

Version 2.4 Page 5 of 7 08/07

And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other

All LCS recoveries were within 80-120%. MS and MSD recoveries associated with lab lots 60095 are not applicable because the spike concentrations were less than one-half of the parent sample.

The RPD associated with MS/MSD lab lot 60095 was greater than 20% at 170%. This may be due to sample heterogeneity and/or the high concentrations of the sample compared to the spike amounts.

The MS/MSD parent sample associated with lab lot 60095 was 07ER-SW-032SO.

Sample not flagged because the spike concentrations were less than 1/2 of the parent sample

Data quality and usability is not affected.

Version 2.4 Page 6 of 7 08/07

Not Applicable

Not Applicable

See SDG checklist K0709528.

Version 2.4 Page 7 of 7 08/07

See SDG checklist K0709528

Not Applicable