Appendix E-1 OBOD Sampling Plan.pdf
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This document is an Environmental Sampling Plan for Open Burning/Open Detonation (OB/OD) Areas at Letterkenny Army Depot in Chambersburg, Pennsylvania, revised in January 2018. The plan outlines comprehensive environmental monitoring requirements mandated by the RCRA Part B Permit conditions issued by the Pennsylvania Department of Environmental Protection (PADEP). The sampling program covers three operational areas: Open Burning Unit No. 1 (OB1, approximately 3 acres), Open Burning Unit No. 2 (OB2, approximately 3.3 acres), and the Open Detonation Area (approximately 25.7 acres total, including Short Field and Long Field). The facility handles thermal treatment of propellants, explosives, and pyrotechnics.
The sampling plan specifies annual environmental monitoring across six primary media types: sediment traps (one sample each from OB1 and OB2), sedimentation basin dredgings (one sample annually from the OD Area), soil samples (three samples annually from the OD Area following detonation operations), surface water (five samples annually from Back Creek and Rocky Spring Branch sub-basins and reference locations), groundwater (nine monitoring wells sampled annually, with quarterly sampling in the first year including analysis for perfluorinated alkyl acids), and benthic macroinvertebrate sampling (six samples each from two compliance locations plus a reference location in Muddy Run). All samples undergo analysis for metals, organic compounds, explosives parameters, inorganic constituents, and field parameters, with results compared to human health and ecological screening levels. Data evaluation and reporting are conducted by a Pennsylvania-licensed professional geologist, with resampling triggered within 10 days if analytical results indicate degradation from OB/OD activities above background concentrations.
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APPENDIX E-1
ENVIRONMENTAL SAMPLING PLAN FOR
OPEN BURNING/OPEN DETONATION (OB/OD) AREAS
January 2018 Revised Draft
ENVIRONMENTAL SAMPLING PLAN
FOR OPEN BURNING/OPEN DETONATION (OB/OD) AREAS AT
LETTERKENNY ARMY DEPOT
CHAMBERSBURG, PENNSYLVANIA
Prepared for
LETTERKENNY ARMY DEPOT
1 Overcash Avenue
Chambersburg, PA 17201
August 2007 Revised March 2016, December 2016, and January 2018
Prepared by
WESTON SOLUTIONS, INC.
1400 Weston Way
West Chester, Pennsylvania 19380-1499
W.O. # 14697.002.001.0035
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TABLE OF CONTENTS
Section Page INTRODUCTION AND SITE BACKGROUND ....................................................... 1-1
1.1 INTRODUCTION ............................................................................................... 1-1
1.2 SITE BACKGROUND ........................................................................................ 1-3
1.2.1 Open Burning Unit No. 1 ...................................................................... 1-3
1.2.2 Open Burning Unit No. 2 ...................................................................... 1-3
1.2.3 Open Detonation Area .......................................................................... 1-3
ENVIRONMENTAL SAMPLING OBJECTIVES .................................................... 2-1
SEDIMENT SAMPLING .............................................................................................. 3-1
3.1 SEDIMENT TRAP .............................................................................................. 3-1
3.2 SEDIMENTATION BASIN ................................................................................ 3-1
SOIL SAMPLING ......................................................................................................... 4-1
SURFACE WATER MONITORING .......................................................................... 5-1
GROUNDWATER MONITORING ............................................................................ 6-1
MACROINVERTEBRATE SAMPLING ................................................................... 7-1
DATA EVALUATION AND REPORTING ............................................................... 8-1
REFERENCES ............................................................................................................... 9-1
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LIST OF TABLES
Table
Table 1 Matrix of Sampling Media and Analyses
Table 2 Sediment Human Health and Ecological Screening Levels
Table 3 Soil Human Health and Ecological Screening Levels
LIST OF FIGURES
Figure
Figure 1 Property Location
Figure 2 Open Burning and Open Detonation OB/OD Areas
Figure 3 Proposed Sediment Basin/Trap Sample in OB1 Area
Figure 4 Proposed Sediment Basin/Trap Sample in OB2 Area
Figure 5 Proposed Sediment Basin Sample in OD Area
Figure 6 Proposed Stream Surface Water Sampling Locations
Figure 7 Groundwater Monitoring Well Locations
Figure 8 Benthic Macroinvertebrate Compliance Sampling Locations
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LIST OF ATTACHMENTS
ATTACHMENT A—RCRA PART B PERMIT – PART IV: PERMIT CONDITIONS
ATTACHMENT B—QUALITY ASSURANCE PROJECT PLAN ADDENDUM
ATTACHMENT C—FIELD FORMS
ATTACHMENT D—WELL CONSTRUCTION LOGS
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LIST OF ACRONYMS
AA Ammunition Area bgs below ground surface CFR Code of Federal Regulations DO dissolved oxygen
EPT Ephemeroptera, Plecoptera and Trichoptera HBI Hilsenhoff Biotic Index HMX cyclotetramethylenetetranitramine IBI Index of Biotic Integrity LEAD Letterkenny Army Depot MSC medium-specific concentration OB/OD Open Burning/Open Detonation OB1 Open Burning Unit No. 1 OB2 Open Burning Unit No. 2 OD Open Detonation ORP oxidation/reduction potential PADEP Pennsylvania Department of Environmental Protection PEP propellants, explosives, and pyrotechnics PFAA perfluorinated alkyl acid PFAS Per- and Polyfluoroalkyl Substance PFBS Perfluorobutanesulfonic acid PFC perfluorochemical PFDA Perfluorodecanoic acid PFDoA Perfluorododecanoic acid PFHpA Perfluoroheptanoic acid PFHxA Perfluorohexanoic acid PFHxS Perfluorohexanesulfonic acid PFNA Perfluorononanoic acid PFOA Perfluorooctanoic acid PFOS Perfluorooctane sulfonate PFTA Perfluorotetradecanoic acid
LIST OF ACRONYMS (CONTINUED)
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PFTrDA Perfluorotridecanoic acid PFUnA Perfluoroundecanoic acid QAPP Quality Assurance Project Plan RBP Rapid Bioassessment Protocol RCRA Resource Conservation and Recovery Act RDX cyclotrimethylenetrinitramine SVOC semivolatile organic compound TCL Target Compound List TDS total dissolved solids TSS total suspended solids UFP-QAPP Uniform Federal Policy Quality Assurance Project Plan VOC volatile organic compound
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1-1
INTRODUCTION AND SITE BACKGROUND
1.1 INTRODUCTION
Letterkenny Army Depot (LEAD) is located in Franklin County, 5 miles north of the Borough of
Chambersburg, PA (see Figure 1). LEAD was established in 1942 as Letterkenny Ordnance Depot, an ammunition storage facility. In subsequent years, various other operations were added to the facility. Most of LEAD is still an ammunition storage facility (16,614 acres), which is referred to as the Ammunition Area (AA). The industrial, maintenance, and recreational areas, which are primarily located in the southeast corner of LEAD, cover approximately 2,500 acres. LEAD is under the command structure of the United States Army Aviation and Missile Life Cycle
Management Command.
LEAD overhauls, rebuilds, modifies, tests, and repairs a wide variety of missile systems ranging from air-launched missiles to large ground-based air defense missile systems. LEAD also overhauls, modifies, and converts various ground support vehicles. In addition to equipment maintenance, LEAD also receives, stores, issues, renovates, and demilitarizes conventional ammunition.
Munitions that are designated for disassembly and subsequent treatment, including munitions and components that do not meet appropriate military standards or have been declared unsafe, are taken to the open burning/open detonation (OB/OD) areas located within AA at LEAD. The OB/OD units are employed to thermally treat various propellants, explosives, and pyrotechnics (PEP) and
PEP-related materials.
At the request of the Pennsylvania Department of Environmental Protection (PADEP), in
December 2001, the Army submitted a Draft Resource Conservation and Recovery Act (RCRA)
Part B Permit Application for the OB/OD areas located within the AA at LEAD. This request was made in accordance with 40 Code of Federal Regulations (CFR) Chapter 270.10, as incorporated by reference under 25 PA Code Section 270a.10. The draft permit application was reviewed by
PADEP, and technical comments were provided to the Army on 24 January 2006. The Army submitted the Final RCRA Part B Permit Application to PADEP on 7 November 2006, which incorporated all revisions/amendments associated with PADEP review comments. PADEP approved the permit application in February 2007LEAD received a permit for the OB/OD
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1-2 operation in August 2008. A new permit application is being submitted in February 2018 in order to renew the permit. The OB/OD areas at LEAD covered by the permit are as follows:
Open Burning Unit No. 1 (OB1) Open Burning Unit No. 2 (OB2) Open Detonation (OD) Area
As part of the RCRA Part B Permit, LEAD was authorized to treat energetic wastes in accordance with Parts I, II, and III of the permit, which are subject to the following permit conditions (as contained in Part IV of the final permit, issued by PADEP 5 August, 2008 [see Attachment A]):
A. Construction Activities
1. Installation of diversion dikes and a sedimentation trap downgradient of OB1. The diversion dikes shall divert runoff to the sediment trap.
2. Installation of diversion dikes and a sedimentation trap downgradient of OB2. The diversion dikes shall divert runoff to the sediment trap.
B. Environmental Sampling Activities
1. Sediment Trap Sampling: Annual sediment sampling in the sediment traps of OB1 and
OB2.
2. Sedimentation Basin Sampling: Annual sampling of the sedimentation basin dredgings.
3. Soil Sampling: Annual soil sampling in the OD Area.
4. Surface Water Sampling: Annual surface water sampling in the Back Creek Sub-Basin (reference location) and Rocky Spring Branch Sub-Basin downgradient from the OB/OD areas.
5. Groundwater Sampling: Annual groundwater sampling of nine monitoring wells in the OB/OD areas.
6. Macroinvertebrate Sampling: Annual macroinvertebrate sampling in the Back Creek Sub-Basin (reference location) and Rocky Spring Branch Sub-Basin downgradient from the OB/OD areas.
As requested by PADEP in comments dated 7 December 2017 regarding the revised Sampling
Plan, the following sampling had been added to the January 2018 plan: Groundwater Sampling:
Quarterly sampling of nine monitoring wells in the OB/OD areas for the first year of the annual
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1-3 sampling, including sampling for perfluorinated alkyl acids (PFAAs) in the initial quarterly sampling round.
This Environmental Sampling Plan incorporates the sampling conditions specified in Part IV of the RCRA Part B Permit, which is provided in Attachment A. All analyses will be conducted in accordance with the amendment to the Depot-Wide Quality Assurance Plan for Environmental
Analytical Services to Support Investigation, Removal, and Disposal Activities Performed by
Contractors at the Letterkenny Army Depot, Chambersburg, Pennsylvania (WESTON, 2003), which is provided in Attachment B. The Quality Assurance Project Plan (QAPP) amendment in
Attachment B contains the Site Specific QAPP Checklist that describes the analytical protocols for constituents not previously addressed in the QAPP. PFAA sampling and analysis will be performed in accordance with the Uniform Federal Policy Quality Assurance Project Plan, Per-and Polyfluoroalkyl Substance (PFAS) Investigation, Property Disposal Office (PDO) Operable
Unit (OU) 4 Letterkenny Army Depot, Chambersburg, Pennsylvania (WESTON, 2017).
1.2 SITE BACKGROUND
1.2.1 Open Burning Unit No. 1
OB1 is located in an approximately 3-acre, sparsely vegetated, slightly raised land that slopes downward in the southwest and northeast directions. Currently, OB1 contains two burning cages and two burn pans. Thermal battery activation is also conducted at the OB1 Area. The OB1 area boundary is shown in Figure 2.
1.2.2 Open Burning Unit No. 2
OB2 is approximately 3.3 acres and consists of mostly graveled land that slopes gently to the northwest. At present, there are 24 burn pans and 28 rocket motor static firing tubes in OB2.
Thermal battery activation is also conducted at the OB2 Area. The OB2 area boundary is shown in Figure 2.
1.2.3 Open Detonation Area
The OD Area encompasses two distinct detonation areas, the Short Field and the Long Field, with surface areas of 9.8 acres and 15.9 acres, respectively. The boundaries of the Short Field and Long
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1-4 pyrotechnics, bombs, grenades, fuses, conventional warheads, mines, rocket motors, rockets, and demolition material by detonation. Open detonation is performed in excavated pits covered with earth. A maximum of 500 pounds of material is placed in one pit, filled with explosives, backfilled, and detonated on the same day. The total combined number of detonations per day in both the
Short Field and Long Field is limited to 28. In rare occasions, aboveground detonation is required for munitions that contain sub-munitions to ensure proper detonation. Army regulations limit aboveground detonations to 50 pounds of munitions per shot.
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2-1
ENVIRONMENTAL SAMPLING OBJECTIVES
As part of the RCRA Part B Permit conditions, PADEP has requested that LEAD perform chemical characterization and benthic macroinvertebrate sampling at selected locations within the AA. The areas to be sampled include locations within and downgradient of OB1, OB2, and the OD Area, as well as in a background reference location in the nearby Back Creek Sub-Basin. The purpose of this environmental sampling program is to document that activities conducted within the
OB/OD areas are not adversely impacting the surrounding environment. The following sections describe the environmental sampling procedures and analyses that will be performed for the
OB/OD area. A matrix of sampling media and their respective analyses is provided in Table 1.
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SEDIMENT SAMPLING
3.1 SEDIMENT TRAP
As part of the RCRA Part B Permit, LEAD installed diversion dikes and sediment traps downgradient of both OB1 and OB2. These diversion dikes are intended to divert runoff from OB1 and OB2 to the sediment traps in each area. Figures 3 and 4 show the location of the diversion dikes and sediment traps at OB1 and OB2, respectively.
One sample will be collected from each sediment trap (OB1 and OB2) per year, provided there is sufficient volume of sediment available. The proposed sediment sampling locations for OB1 and
OB2 are shown on Figures 3 and 4, respectively. Samples will be collected from the sediment traps as grab samples using decontaminated stainless steel scoops, homogenized in decontaminated stainless steel bowls, and placed into clean, laboratory-prepared containers for analysis of the parameters listed in Table 1.
Sediment samples will be collected by coring using polycarbonate tubes. Retrieved sediment cores will be extruded and carefully examined to identify the transition from the underlying native soil from the base of the sediment trap to the overlying unconsolidated sediment resulting from surface water transport from the OD OB areas. Any native soil from the base will be removed from the core sample and only the remaining clearly distinguishable accumulated sediment from the core sample will be homogenized and placed in the sample container for analysis.
Sediment samples will be analyzed on a dry-weight basis and all metals analyses will be for total metals, except for hexavalent and trivalent chromium analyses, which will be performed individually. Analytical data will be compared to the human health and ecological screening levels for sediment, which are listed on Table 2.
3.2 SEDIMENTATION BASIN
In 2003, aA new sedimentation basin was constructed directly downslope of the Long Field for the OD Area to allow for collection of sediment that could ultimately flow to the impoundment pond further downstreamin 2002. The basin, shown in Figure 5, traps sediment runoff from botht ehboth the Long Field and Short Field at the OD Area. The sedimentation basin requires dredging at least once per year, but occasionally more often depending upon precipitation/runoff rates
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3-2 throughout the year. A sediment sample will be collected at least once per year, immediately following dredging activities, or collected directly from the sedimentation basin. Sediment samples will be collected as grab samples with stainless steel scoops, homogenized into decontaminated stainless steel bowls, and placed in clean, laboratory-prepared containers for analysis parameters listed on Table 1.
Sediment samples will be analyzed on a dry-weight basis and all metals analyses will be for total metals, except for hexavalent and trivalent chromium analyses, which will be performed individually. Analytical data will be compared to the human health and ecological screening levels for sediment, which are listed on Table 2.
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SOIL SAMPLING
Soil sampling will be conducted in the OD Area immediately following detonation operations.
One sample will be collected from the base of a freshly fired detonation crater (approximately
10 feet below ground surface [bgs]), and at least one sample will be collected at ground surface in the footprint of the detonation crater following regrading of the area. These samples will be collected from the Long Field. A single surface soil sample will be collected at the Short Field, which is not used as often, on the same day that samples are collected at the Long Field. The proposed sampling locations will be determined by the location of detonation at the OD Area
(Figure 5). The soil sample to be taken at ground surface will be collected within 50 feet of the detonation, per Permit Condition IV.B.3.
Soil samples will be collected from the first 6 inches of soil (at the base of the detonation crater and at the surface following regrading) with stainless steel scoops, homogenized into decontaminated stainless steel bowls, and placed in clean, laboratory-prepared containers for analysis parameters listed on Table 1. Soil samples will be analyzed on a dry-weight basis and all metals analyses will be for total metals, except for hexavalent and trivalent chromium analyses, which will be performed individually. Analytical data will be compared to the human health and ecological screening levels for soil, which are listed on Table 3.
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SURFACE WATER MONITORING
A total of five surface water samples will be collected from the AA as follows:
One surface water sample will be collected from the Back Creek Sub-Basin in the unnamed tributary downstream from OB1 and OB2, on the downstream side of Georgia Avenue.
One surface water sample will be collected from the Rocky Spring Branch Sub-Basin in the effluent stream of the sediment pond.
One surface water sample will be collected from the old impoundment pond, downstream of Barricade Road.
One surface water sample will be collected in the Back Creek sub-basin not affected by OB/OD activities, on the branch of the stream paralleling Georgia Avenue, upstream of the confluence of Back Creek and the tributary that flows form OB2 and unaffected by OB1 drainage.
One surface water sample will be collected in the Rocky Spring Branch sub-basin not affected by OB/OD activities. A suitable surface water sampling location exists on the eastern limb of the headwaters of the unnamed tributary to Rocky Spring Branch upgradient of the old impoundment pond, west of Barricade Road and south of Kentucky Avenue extension, and unaffected by drainage from OD 2.
Figure 6 shows the approximate locations of the surface water samples.
Surface water sampling will be within 24 hours of a high rainfall event. A high rainfall event shall be defined as no less than 2 inches of rain per 12-hour period. Daily rainfall measurements are currently tracked and recorded by personnel at the LEAD industrial Industrial Wwastewater treatment Treatment plantPlant. On-site LEAD environmental personnel will monitor the forecast to ensure the sampling is performed when an appropriate storm event occurs. There is a rain gauge at the Industrial Wastewater Treatment Plant that can be utilized and LEAD’s sampling personnel/contractor will be able to mobilize and access sampling points during a high rainfall time of elevated flow after the rain event.
Prior to collecting surface water samples, field measurements of pH, specific conductance, dissolved oxygen (DO), temperature, and turbidity will be collected using a calibrated YSI water quality meter or equivalent and will be recorded on the field sampling sheets. An example surface water sampling log is provided in Attachment C. Surface water samples will be collected in clean, laboratory-prepared containers with appropriate preservative and shipped under full chain-of-
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5-2 custody to a certified laboratory for analysis of the parameters listed on Table 1. Note: all samples collected for dissolved metals analysis will be filtered in the field at the time of sample collection.
In addition, streamflow measurements will be collected at each specific sampling location during each sampling event. Stream velocities will be measured at a series of nodes along a transect and combined with stream channel cross-sectional areas associated with each node to obtain estimates of instantaneous flow at the time of sampling.
Water samples were not analyzed for dissolved explosives in the initial rounds because: 1) explosive compounds are either insoluble or have low solubility in water; and 2) explosive compounds were either detected in low concentrations or not detected in surface water and groundwater. However, after re-evaluation, total and dissolved analyses for explosives were added to the sampling plan and are also included as a condition of the RCRA Part B permit, Part IV, Sections IV.B.5 and IV.B.7 (see Attachment A).
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6-1
GROUNDWATER MONITORING
The locations of the groundwater monitoring wells in the OB/OD area are shown on Figure 7.
Sampling will be conducted from the following nine wells:
OB1: 90-14, 90-16, and 90-17 OB2: 90-3 and 90-5 OD Area: 01-OD2-1, 01-OD2-2, and 01-OD2-3.
Background: 90-18
The OD Area monitoring wells were installed as part of the field activities performed for the 2006
RCRA Part B Permit Application. Well construction logs for the OB/OD areas are provided in
Attachment D.
Groundwater sampling efforts will commence with the collection of depth-to-water measurements from the top of the well casings at all wells prior to beginning purging activities. Groundwater will be purged from the wells using decontaminated, 2-inch, stainless steel submersible pumps and dedicated polyethylene discharge lines. The pump will be lowered to within 5 feet of the bottom of each well, and the static water level will be allowed to re-stabilize. Pumping will be conducted at a rate that minimizes the drawdown of the water level in each well to minimize volatilization of the samples.
Throughout the purging, water level measurements will be recorded and the field parameters of pH, specific conductance, DO, temperature, oxidation/reduction potential (ORP), and turbidity will be collected using a YSI flow-through cell instrument or equivalent. An example groundwater sampling log is provided in Attachment C. Groundwater will be purged until three consecutive
YSI readings of the following field parameters have stabilized as noted below:
pH: ±0.1 unit Specific conductance: ±3% ORP: ±10 millivolt
DO: ±10%
Temperature: ±0.1 degree Celsius
Purging of the wells will continue until stabilization is achieved. At that time, the purge rate will be reduced to the lowest practical rate (e.g., approximately 100 to 500 milliliters per minute) to
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6-2 minimize aeration, and samples will be collected from the end of the discharge tubing in the following order of parameters:
Target Compound List (TCL) volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs).
Total and dissolved metals. Note: all samples collected for dissolved metals analysis will be filtered in the field at the time of sample collection.
General chemistry parameters (i.e., ammonia, chloride, total dissolved solids [TDS], fluoride, free cyanide, hardness [as calcium carbonate (CaCO3)], nitrate, nitrite, total suspended solids [TSS], sulfate).
Perchlorate, ammonia nitrogen, alkalinity (as CaCO3), and chloride.
Total and dissolved explosives parameters. Note: Water samples were not analyzed for dissolved explosives in the 2001 initial rounds because: 1) explosive compounds are either insoluble or have low solubility in water; and 2) explosive compounds were either detected in low concentrations or not detected in surface water and groundwater.
However, after re-evaluation, total and dissolved analyses for explosives were added to the sampling plan and are also included as a condition of the RCRA Part B permit, Part IV, Sections IV.B.5 and IV.B.7 (see Attachment A).
At the request of PADEP, the first quarter of groundwater sampling of the first year will include analysis for PFAAs. Additional terms used to describe these PFAAs and related fluorinated organic compounds include perfluorochemicals (PFCs) and Per- and Polyfluoroalkyl Substances
(PFASs). Hereinafter the term “PFAAs” will be used throughout this Sampling Plan. PFAAs analysis will include the following compounds (using EPA SW-846 Method 537):
Perfluorobutanesulfonic acid (PFBS) Perfluorodecanoic acid (PFDA) Perfluorododecanoic acid (PFDoA) Perfluoroheptanoic acid (PFHpA) Perfluorohexanesulfonic acid (PFHxS) Perfluorohexanoic acid (PFHxA) Perfluorononanoic acid (PFNA) Perfluorooctanesulfonic acid (PFOS) Perfluorooctanoic acid (PFOA) Perfluorotetradecanoic acid (PFTA) Perfluorotridecanoic acid (PFTrDA) Perfluoroundecanoic acid (PFUnA)
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6-3
Groundwater samples will be collected in clean, laboratory-prepared containers with appropriate preservative and shipped under full chain-of-custody to a certified laboratory for analysis of the parameters listed on Table 1. Groundwater samples for PFAA will be collected using precautions listed in the 2017 UFP-QAPP to avoid cross-contamination of samples.
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MACROINVERTEBRATE SAMPLING
Macroinvertebrate sampling will be performed at two compliance locations as follows:
Five Six samples (ODB01 through ODB05ODB06) will be collected in the unnamed tributary (referred to herein as the OD stream) between the OD Area impoundment pond and Louisiana Run (a tributary to Rocky Spring Branch).
Five Six samples (OBB01 through OBB056, formerly referred to as MRB01 through MRB05) at an unnamed tributary to Back Creek, west of OB1 and near Georgia Avenue, to assess the stream for impacts from OB1 and OB2. The previous five samples collected from this stream reach were designated as MRB01 through MRB05.
Figure 8 shows the macrobenthic invertebrate sampling locations. Rocky Spring Branch flows into
Back Creek downstream of the LEAD boundary and is located within the Potomac River drainage basin. Samples OBB01 to OBB056 are located to the west of the OB 1 Area and the sampling location was selected with PADEP concurrence on 4 April 2001 as part of the sampling that was conducted for the permit application. Further reconnaissance of both the reference stream and OD stream reaches was performed with PADEP biologist, Mark Embeck, in 23 July 2001 to select sampling locations that maximize habitat similarity. Although a different sampling methodology will be utilized (as required by PADEP), sampling will occur within the same stream reaches that were established in 2001 and initially sampled in January 2002 in order Toto allow comparisons with prior macrobenthic invertebrate monitoring data, annual sampling will occur at the same locations that were established in 2001 and initially sampled in January 2002.
At PADEP’s request, a new reference stream location was selected for developing data on the benthic macroinvertebrate community for comparison with benthic macroinvertebrate data to be obtained from the previously sampled locations on Back Creek and the unnamed tributary to
Rocky Spring Branch. Because headwater stream flow in both the Back Creek and unnamed tributary to Rocky Spring Branch drainages above confluence with drainages from the OB/OD operations are appreciably lower than the established monitoring points, other areas within the
Ammunition Area were evaluated as candidate reference stream locations. Dennis Creek was excluded from consideration because of shallow gradient, dominant agricultural land use in the riparian zone, and differences in substrate characteristics (silt vs. cobble). The headwaters of
Muddy Run were selected on the basis of comparable geology, stream channel morphology and habitat similarity, and stream size. The candidate sample reach is shown on Figure 9. The benthic
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7-2 macroinvertebrate sampling locations in the Muddy Run reference stream will be selected in the field on the basis of more detailed, current information on substrate characteristics and stream flow obtained during sampling of the compliance monitoring locations in Back Creek and in the unnamed tributary to Rocky Spring Branch. Because benthic macroinvertebrate community composition is strongly influenced by habitat conditions, the surber sampling reache locations within Muddy Run will be selected to correspond as closely as possible with the characteristics of the compliance monitoring points to minimize the effect of habitat as a confounding variable in community comparisons.
Sampling methods will previously followed those presented in the EPA Rapid Bioassessment
Protocol (RBP) guidance (EPA 841-B-99-002; EPA, 1999) and the methods contained in
“Macroinvertebrate Field and Laboratory Methods for Evaluating the Biological Integrity of
Surface Waters” (EPA 600/4-90/030; EPA, 1990). Quantitative sampling will bewas performed in
2002 by using a 1-square foot Surber sampler to collect the five replicate samples from riffle areas in each of the streams. Five replicate samples shall be collected from each of the two study areas.
Based on comments received from PADEP, the sampling methodology will be revised to follow the procedures described in the guidance document: A Benthic Macroinvertebrate Index of Biotic
Integrity for Wadeable Freestone Riffle-Run Streams in Pennsylvania (PADEP, 2012).
Data collection methods used in the development of the wadeable riffle-run Index of Biotic
Integrity (IBI) consisted of the collection of six kick samples from each collection site using a 500-micron mesh D-frame net (PADEP, 2012). The procedure described in the Field Sampling and
Lab Methods (Appendix A of the 2012 IBI development document) as a semi-quantitative method is appropriate for anti-degradation surveys and will be used over 100-meter reaches at each of the three streams to be sampled. Both slower flowing shallow riffles and faster flowing deeper riffles, where present, will be sampled by individual kick samples from approximately 1-square-meter areas of substrate disturbed to a depth of approximately 10 centimeters for 1 minute. Composited samples from the six kicks will be preserved in the field with 95% ethanol and transferred to the laboratory for enumeration and identification following the same sample processing and taxonomic identification procedures used in the IBI development document (PADEP, 2012).
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Field measurements of pH, specific conductance, dissolved oxygen (DO), temperature, and turbidity will be made at the sampling locations. Additional information on 12 parameters covering stream substrate, instream cover, channel morphology, and riparian area characteristics will be recorded at differing scales (see field forms in Attachment C) as described in the following sentences. Instream fish cover, epifaunal substrate, embeddedness, and velocity/depth regime will be evaluated in the immediate vicinity of the sampling reaches. Channel alteration, sediment deposition, riffle frequency, and channel flow status will be evaluated in the larger area surrounding the sampling reaches. At the largest scale, the condition of banks, bank vegetative protection, grazing or other disruptive pressures, and riparian vegetative zone width will be evaluated. These 12 parameters will be scored using the DEP-RBP habitat assessment methodology (Appendix A; PADEP, 2012). Benthic macroinvertebrates will be preserved and shipped to a laboratory for identification to the lowest practicable taxon and enumeration. A variety of statistical and index methods will be reported in the benthic macroinvertebrate community analysis including diversity, similarity, and community indices.
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DATA EVALUATION AND REPORTING
Following receipt, review and validation of analytical data, a summary report of the OB/OD area sampling will be prepared and submitted to PADEP. The report will include a summary of sampling activities, summary of results, and a narrative data evaluation, including sample location figures, a groundwater contour map and data tables. The data submitted will be prepared by a PA-licensed professional geologist.
LEAD will make arrangements to resample within 10 days after receipt of surface water or groundwater analytical data that indicates degradation from OB/OD activities. PADEP considers degradation to be a measureable increase in the concentration of one or more contaminants above background in groundwater or surface water. Resampling will be triggered by detections of those parameters listed for surface water and groundwater in Table 1, with the exception of iron, manganese, sodium, potassium, zinc, total dissolved solids, hardness, total suspended solids, sulfate, and alkalinity.
Analytical data for soil sample results will be compared to the human health and ecological screening levels for soil, which are listed on Table 3. Analytical data for sediment sample results will be compared to the human health and ecological screening levels for sediment, which are listed on Table 2. Data from the LEAD background shale soil and sediment sampling report
(WESTON, 2002) (sediment data from Keasey Run in northernmost area of the Ammo Area) will also be used in the OB/OD data evaluation process.
Downstream surface water analytical data will be compared to data from the relative upstream background locations; groundwater analytical data will be compared to data from the background well, 90-1 818, provided it does not show any effects from OB/OD activities.
Benthic macroinvertebrate and habitat assessment data from each of the stream reaches will be tabulated in a benthic macroinvertebrate community analysis. A variety of statistical and index methods will be reported including taxa richness, diversity, similarity, and other community indices. These will include the six core metrics of total taxa richness, Ephemeroptera, Plecoptera and Trichoptera (EPT) richness, Beck’s Index, Hilsenhoff Biotic Index (HBI), Shannon diversity, and Percent Sensitive Individuals used in the PADEP wadeable freestone riffle-run stream IBI
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8-2 scoring (PADEP, 2012). Comparisons of habitat conditions and community metrics will be performed between the Rocky Spring Branch and Back Creek streams located downstream of the
OB/OD areas and the Muddy CreekRun reference stream to identify potential impacts to the benthic macroinvertebrate community(ies).
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9-1
REFERENCES
EPA (U.S. Environmental Protection Agency). 1999. Rapid Bioassessment Protocols For Use in Streams and Wadeable Rivers: Periphyton, Benthic Macroinvertebrates, and Fish, Second Edition. EPA 841-B-99-002. U.S. Environmental Protection Agency; Office of Water;
Washington, D.C. 1999.
EPA (U.S. Environmental Protection Agency). 1990. Macroinvertebrate Field and Laboratory Methods for Evaluating the Biological Integrity of Surface Waters. EPA/600/4-90/30. U.S.
Environmental Protection Agency; Office of Research and Development; Washington, D.C.
November 1990.
PADEP. 2012. A Benthic Macroinvertebrate Index of Biotic Integrity for Wadeable Freestone Riffle-Run Streams in Pennsylvania. Pennsylvania Department of Environmental Protection.
Division of Water Quality Standards.
http://files.dep.state.pa.us/Water/Drinking%20Water%20and%20Facility%20Regulation/WaterQ ualityPortalFiles/Technical%20Documentation/freestoneIBImarch2012.pdf
WESTON (Weston Solutions, Inc.). 2017. Uniform Federal Policy Quality Assurance Project Plan, Per- and Polyfluoroalkyl Substance (PFAS) Investigation, Property Disposal Office (PDO) Operable Unit (OU) 4 Letterkenny Army Depot, Chambersburg, Pennsylvania. Final. April 2017.
WESTON (Weston Solutions, Inc.). 2003. Depot-Wide Quality Assurance Plan for Environmental Analytical Services to Support Investigation, Removal, and Disposal Activities Performed by Contractors at the Letterkenny Army Depot, Chambersburg, Pennsylvania. October, 2003.
WESTON (Roy F. Weston, Inc.). 2002. Background Soil and Sediment Sampling Results, Letterkenny Army Depot. Final. January 2002.
http://files.dep.state.pa.us/Water/Drinking%20Water%20and%20Facility%20Regulation/WaterQualityPortalFiles/Technical%20Documentation/freestoneIBImarch2012.pdf http://files.dep.state.pa.us/Water/Drinking%20Water%20and%20Facility%20Regulation/WaterQualityPortalFiles/Technical%20Documentation/freestoneIBImarch2012.pdf
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TABLES
Table 1 Matrix of Sampling Media and Analyses
Sample Medium Location Number of Samples Analyses Notes
Sediment Trap OB1 1
Sediment Trap OB2 1
Sedimentation Basin 1
Soil OD Area 3
1) All Parameters listed in Table 4 of Appendix A of 25 Pa Code § 250.1 et seq.; 2) the inorganic parameters of sulfate, chloride, fluoride, nitrate, and nitrite; 3) the explosives parameters of nitrocellulose, nitroguanidine, nitroglycerine, perchlorate, 2,4-dinitrotoluene, 2-amino-4,6-dinitrotoluene, 4-amino-2,6-dinitrotoluene, tetryl, 1,3,5-trinitrobenzene, 2,4,6-trinitrotoluene, HMX and RDX; and 4) TOC and pH
Long Field - subsequent to detonation operations, 1 sample from a freshly fired detonation crater at least 10 ft bgs, and 1 sample taken at grade surface within 50 feet of detonation operations after regrading is completed. Short Field - single surface sample collected on the same day as the Long Field sample collection.
Back Creek Sub-Basin, unnamed tributary downstream of OB1 and OB2
Rocky Spring Branch Sub-Basin, effluent of the sedimentation pond.
Rocky Spring Branch Sub-Basin, effluent of the old impoundment pond.
Rocky Spring Branch Sub-Basin, upstream of impoundment pond, not influenced by drainage from OB/OD areas.
Back Creek Sub-Basin, upstream of OB1 and OB2, not influenced by drainage from
OB/OD areas.
1) TCL VOCs and SVOCs; 2) total and dissolved phase metals parameters listed in Table 4 of Appendix A of 25 Pa Code § 250.1 et seq.; 3) total and dissolved phase of the inorganic parameters of sulfate, chloride, fluoride, nitrate, and nitrite; 4) TOC, TDS, TSS, ammonia nitrogen, alkalinity (as CaCO3), and hardness (as CaCO3); 5) the total and dissolved phase explosives parameters of nitrocellulose, nitroguanidine, nitroglycerine, perchlorate, 2,4-dinitrotoluene, 2-amino-4,6-dinitrotoluene, 4-amino-2,6-dinitrotoluene, tetryl, 1,3,5-trinitrobenzene, 2,4,6-trinitrotoluene, HMX and RDX; and 6) field parameters of dissolved oxygen (DO), pH, turbidity, specific conductivity, and temperature.
1) All Parameters listed in Table 4 of Appendix A of 25 Pa Code § 250.1 et seq.; 2) the inorganic parameters of sulfate, chloride, fluoride, nitrate, and nitrite; 3) the explosives parameters of nitrocellulose, nitroguanidine, nitroglycerine, perchlorate, 2,4-dinitrotoluene, 2-amino-4,6-dinitrotoluene, 4-amino-2,6-dinitrotoluene, tetryl, 1,3,5-trinitrobenzene, 2,4,6-trinitrotoluene, HMX and RDX; and 4) TOC and pH
Sediment
Surface Water
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Sample Medium Location Number of Samples Analyses Notes
OB1 Area - 3 Wells (90-14, 90-16, and 90-17)
OB2 Area - 2 Wells (90-3 and 90-5)
OD Area - 1 well just outside OD area, and 2 wells downstream
(01-OD2-1, 01-OD2-2, and 01-OD2-3)
Background Well (90-18) 1
Unnamed Tributary between the OD Area Impoundment Pond and Louisiana Run
Unnamed tributary to Back Creek, west of OB2 and near Georgia Ave.
Reference location in Muddy Run 5
Notes:
CaCO3 - Calcium Carbonate TCL - Target Compound List ft bgs - foot below ground surface TDS - total dissolved solids HMX - cyclotetramethylenetetranitramine TOC - total organic carbon PFAA - perfluorinated alkyl acids TSS - total suspended solids RDX - cyclotrimethylenetrinitramine VOC - volatile organic compound SVOC - semivolatile organic compound
Benthic macroinvertebrate identification, stream temperature, pH, dissolved oxygen, specific conductance, and turbidity.
1) TCL VOCs and SVOCs; 2) all the total and dissolved phase metals parameters listed in Table 4 of Appendix A of 25 PA Code § 250.1 et seq. (See Table 2); 3) general chemistry parameters (i.e., TOC, ammonia, chloride, TDS, fluoride, free cyanide, hardness (as CaCO3), nitrate, nitrite, TSS, sulfate; 4) perchlorate, ammonia nitrogen, alkalinity (as CaCO3), and chloride; 5) the total and dissolved phase explosives parameters of nitrocellulose, nitroguanidine, nitroglycerine, perchlorate, 2,4-dinitrotoluene, 2-amino-4,6-dinitrotoluene, 4-amino- 2,6-dinitrotoluene, tetryl, 1,3,5-trinitrobenzene, 2,4,6-trinitrotoluene, HMX and RDX; and 6) field parameters pH, DO, turbidity, specific conductivity, and temperature.
PFAA analyses (12 compounds from EPA Method 537 list) for one baseline round.
Collection should be done using a 1-square foot Surber sampler to collect the samples from riffle areas
Groundwater
Macroinvertebrates
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Table 4 of Appendix A of 25 Pa Code § 250.1 et seq.
Sediment Soil Surface Water Groundwater
Aluminum Aluminum total/dissolved Aluminum total/dissolved Aluminum Antimony Antimony total/dissolved Antimony total/dissolved Antimony Arsenic Arsenic total/dissolved Arsenic total/dissolved Arsenic Barium and compounds Barium and compounds total/dissolved Barium and compounds total/dissolved Barium and compounds Beryllium Beryllium total/dissolved Beryllium total/dissolved Beryllium Boron and Compounds Boron and Compounds total/dissolved Boron and Compounds total/dissolved Boron and Compounds Cadmium Cadmium total/dissolved Cadmium total/dissolved Cadmium Chromium III Chromium III total/dissolved Chromium III total/dissolved Chromium III Chromium VI Chromium VI total/dissolved Chromium VI total/dissolved Chromium VI Cobalt Cobalt total/dissolved Cobalt total/dissolved Cobalt Free Cyanide Free Cyanide total/dissolved Free Cyanide total/dissolved Free Cyanide Fluoride Fluoride total/dissolved Fluoride total/dissolved Fluoride Iron Iron total/dissolved Iron total/dissolved Iron Lead Lead total/dissolved Lead total/dissolved Lead Lithium Lithium total/dissolved Lithium total/dissolved Lithium Manganese Manganese total/dissolved Manganese total/dissolved Manganese Mercury Mercury total/dissolved Mercury total/dissolved Mercury Molybdenum Molybdenum total/dissolved Molybdenum total/dissolved Molybdenum Nickel Nickel total/dissolved Nickel total/dissolved Nickel Perchlorate Perchlorate total/dissolved Perchlorate total/dissolved Perchlorate Selenium Selenium total/dissolved Selenium total/dissolved Selenium Silver Silver total/dissolved Silver total/dissolved Silver Thallium Thallium total/dissolved Thallium total/dissolved Thallium Tin Tin total/dissolved Tin total/dissolved Tin Vanadium Vanadium total/dissolved Vanadium total/dissolved Vanadium Zinc Zinc total/dissolved Zinc total/dissolved Zinc sulfate sulfate TCL VOCs TCL VOCs chloride chloride TCL SVOCs TCL SVOCs fluoride*** fluoride*** total/dissolved sulfate total/dissolved sulfate nitrate nitrate total/dissolved chloride total/dissolved chloride nitrite nitrite total/dissolved fluoride*** total/dissolved fluoride*** nitrocellulose nitrocellulose total/dissolved nitrate total/dissolved nitrate nitroguanidine nitroguanidine total/dissolved nitrite total/dissolved nitrite nitroglycerine nitroglycerine TDS TDS
Appendix A, Table 4 - MSCs for Inorganic
Regulated Substances in Soil
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Table 4 of Appendix A of 25 Pa Code § 250.1 et seq. (continued) Sediment Soil Surface Water Groundwater perchlorate*** perchlorate*** TSS TSS 2,4-dinitrotoluene 2,4-dinitrotoluene ammonia nitrogen ammonia nitrogen 2-amino-4,6-dinitrotoluene 2-amino-4,6-dinitrotoluene alkalinity (as CaCO3) alkalinity (as CaCO3) 4-amino-2,6-dinitrotoluene 4-amino-2,6-dinitrotoluene hardness (as CaCO3) hardness (as CaCO3) tetryl tetryl total/dissolved nitrocellulose total/dissolved nitrocellulose 1,3,5-trinitrobenzene 1,3,5-trinitrobenzene total/dissolved nitroguanidine total/dissolved nitroguanidine 2,4,6-trinitrotoluene 2,4,6-trinitrotoluene total/dissolved nitroglycerine total/dissolved nitroglycerine HMX HMX total/dissolved perchlorate*** total/dissolved perchlorate*** RDX RDX total/dissolved 2,4-dinitrotoluene total/dissolved 2,4-dinitrotoluene total/dissolved 2-amino-4,6-dinitrotoluene total/dissolved 2-amino-4,6-dinitrotoluene total/dissolved 4-amino-2,6-dinitrotoluene total/dissolved 4-amino-2,6-dinitrotoluene total/dissolved tetryl total/dissolved tetryl total/dissolved 1,3,5-trinitrobenzene total/dissolved 1,3,5-trinitrobenzene total/dissolved 2,4,6-trinitrotoluene total/dissolved 2,4,6-trinitrotoluene total/dissolved HMX total/dissolved HMX total/dissolved RDX total/dissolved RDX ammonia* ammonia ammonium perchlorate* ammonium perchlorate free cyanide*,*** free cyanide*** specific conductivity** specific conductivity pH** pH temperature** temperature turbidity** turbidity
**Included per PADEP request ***Included in Table 4 of Appendix A of 25 PA Code 250.1
Appendix A, Table 4 - MSCs for Inorganic
Regulated Substances in Soil
*ammonia, ammonium perchlorate, and free cyanide included in groundwater analysis. Include in surface water too?
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Table 2 Sediment Human Health and Ecological Screening Levels
Letterkenny Army Depot, Chambersburg, PA
Consensus LANL EcoRisk 3.2 EPA Region 3
Chemical (0-2 ft) Based TEC Sediment BTAG
Semivolatile Organic Compounds 2-Amino-4,6-Dinitrotoluene 230 n NA NA NA 34 NA 34 N/A
4-Amino-2,6-Dinitrotoluene 230 n NA NA NA 10 NA 10 N/A
2,4-Dinitrotoluene 7.4 c 0.21 E 260 G NA 0.29 0.0416 0.042 0.66
2,6-Dinitrotoluene 1.5 c 3.70 E 2,800 G NA 9.7 NA 1.50 3.3 Tetryl 230 n NA NA NA 100.0 NA 100 N/A 1,3,5-Trinitrobenzene 3,200 n NA NA NA 1,300 NA 1,300 N/A HMX 5,700 n 40 E 140,000 G NA 27,000 NA 5,700 N/A
RDX 28.0 c 0.20 E 720 G NA 45.0 0.013 0.013 N/A
2,4,6-Trinitrotoluene 51.0 n 0.20 E 1,400 G NA 420.0 0.092 0.092 N/A Inorganics
Aluminum 110,000 n NA 190,000 C NA NA NA 110,000 N/A Antimony 47.0 n 27 1,100 C NA 0.36 2.0 0.36 N/A Arsenic 3.0 c 29 53 G 10 9.7 9.8 3.00 N/A Barium 22,000 n 8,200 190,000 C NA 150 NA 150 N/A Beryllium 230.0 n 320 5,600 G NA 73.0 NA 73.0 N/A Boron and Compounds 23,000 n 1,900 190,000 C NA 10.0 NA 10.0 N/A Cadmium 98.0 n 38 1,400 G 0.99 0.33 0.99 0.33 N/A Chromium Total NA NA NA 43 43 43 43.0 N/A Chromium III 180,000 n 190,000 190,000 C NA NA NA 180,000 N/A Chromium VI 6.3 c 190 8,400 G NA 680.00 NA 6.3 N/A Cobalt 35.0 n 50 840 G NA 230 50 35.0 N/A Iron 82,000 n NA 190,000 C NA 20,000 20,000 20,000 N/A Lead 800 450 1,000 S 36 27 36 27.0 N/A Lithium 230 n 2,200 5,600 G NA 150 NA 150 N/A Manganese 2,600 n 2,000 130,000 G NA 460 460 460 N/A Mercury 4.6 n 10 450 G 0.18 0.018 0.180 0.018 0.2 Methyl mercury 12.0 n NA NA NA 0.00046 NA 0.00046 N/A Molybdenum 580.0 n 650 14,000 G NA 27 NA 27.0 N/A Nickel 2,200 n 650 56,000 G 22.7 13.0 22.7 13.0 N/A Selenium 580 n 26.0 14,000 G NA 0.72 2.00 0.72 N/A Silver 580 n 84.0 14,000 G NA 0.50 1.0 0.50 N/A Thallium 1.2 n 14.0 200 G NA 0.044 NA 0.044 N/A Tin 70,000 n 190,000 190,000 C NA NA NA 70,000 N/A Vanadium 580 n 26,000 20,000 G NA 30.0 NA 30.0 N/A Zinc 35,000 n 12,000 190,000 C 121 65 121 65.0 N/A
Soil RSL Non-Residential Soil
Ecological Sediment (mg/kg) b
Minimum Sediment PAL
Human Health Soil/Sediment (mg/kg) a
ORNL Industrial PADEP
PQL
Act 2 PADEP Soil to Groundwater
Used Aquifers TDS < = 2500, Residential
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