ARFQ DEP2500000018-Attachment 6 Vienna PCE Superfund_SAP_ R1 (2).pdf

SAMPLING AND ANALYSIS PLAN

OPERATIONS AND MAINTENANCE

LONG TERM REMEDIAL ACTION MONITORING

WVDEP VIENNA PCE SITE

405 29TH STREET

VIENNA, WEST VIRGINIA

Prepared for:

West Virginia Department of Environmental Protection

Mr. William F. Huggins, Jr.

Project Manager

WVDEP-Division of Land Restoration

Office of Environmental Remediation

131A Peninsula Street

Wheeling, WV 26003

Prepared by:

ATC Group Services LLC

June 25, 2021 ii

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 SITE DESCRIPTION & BACKGROUND

2.1 Site Location & Source History

2.2 Site History & Previous Assessment Activities

2.3 Conceptual Site Model and Remedial Design

2.3.1 Treatment Units

3.0 PROJECT ORGANIZATION

3.1 Project Organization and Distribution List

3.2 Project Tasks and Schedule

4.0 PROJECT IMPLEMENTATION: MONITORING AND SAMPLING

4.1 Groundwater Sampling

4.1.1 Groundwater Sampling Schedule

4.1.2 Groundwater Sample Collection Protocols

4.1.3 Groundwater Analytical Schedule

4.1.4 Groundwater Quality Assurance/Quality Control Protocols

4.2 Vapor Sampling

4.2.1 Vapor Sampling Schedule

4.2.2 Vapor Sample Collection Protocols

4.2.3 Vapor Analytical Schedule

4.2.4 Vapor Quality Assurance/Quality Control

4.3 Discharge Water Sampling

4.3.1 Discharge Water Sampling Schedule

4.3.2 Discharge Water Sample Collection Protocols

4.3.3 Discharge Water Analytical Schedule

5.0 DECONTAMINATION PROCEDURES

5.1 Personnel Decontamination

5.2 Equipment Decontamination

6.0 INVESTIGATION-DERIVED WASTE MANAGEMENT

6.1 Purge Water

6.2 Decontamination Water

7.0 SAMPLE HANDLING, STORAGE AND SHIPMENT

7.1 Sample Numbering System

7.1.1 Scope and Application

7.1.2 Summary of Method

7.1.3 Procedure

7.1.4 Precautions

7.2 Storage and Handling

iii

7.3 Shipping

8.0 QUALITY ASSURANCE/QUALITY CONTROL

8.1 Quality Assurance Objectives

8.2 Sampling Procedures

8.3 Sample Custody

8.4 Calibration Procedures and Frequency

8.5 Data Reporting, Validation and Reduction

8.6 Internal Quality Control Checks

8.7 Private Field Maintenance

8.8 Quality Assessment and Data Validation

8.9 Data Management Plan

9.0 REPORTING

LIST OF TABLES

Table 1 Groundwater Sampling Schedule – June 2021

LIST OF FIGURES

Figure 1 Site Location Map

Figure 2 Site Monitoring Location Map

LIST OF APPENDICES

Appendix A Personnel Qualifications

Appendix B Standard Operating Procedures

Appendix C Field Forms iv

LIST OF ACRONYMS

°C Degrees Celcius µg/L Micrograms per Liter

AST Aboveground Storage Tank

AS Air Sparge

ATC ATC Group Services LLC bgs below ground surface

KEMRON KEMRON Environmental Services, Inc.

kg Kilogram

LPGAC Liquid Phase Granular Activated Carbon

LTRA Long Term Remedial Action

MCL Maximum Contaminant Level

MS/MSD Matrix Spike/Matrix Spike Duplicate

MW Monitoring Well

O&M Operations and Maintenance

Pace Pace Analytical Laboratories

PCE Tetrachloroethene

QA/QC Quality Assurance/Quality Control

RAO Remedial Action Objectives

RCRA Resource Conservation and Recovery Act

RI Remedial Investigation

SAP Sampling and Analysis Plan

SVE Soil Vapor Extraction

SVOC Semivolatile Organic Compound

TCL Target Compound List

TU Treatment Units

UST Underground Storage Tank

USEPA United States Environmental Protection Agency

VMP Vapor Monitoring Points

VOC Volatile Organic Compound

VPGAC Vapor Phase Granular Activated Carbon

WVDEP West Virginia Department of Environmental Protection

Sampling and Analysis Plan

WVDEP Vienna PCE Site

Vienna, West Virginia

1.0 INTRODUCTION

ATC Group Services LLC (ATC) has been retained by West Virginia Department of Environmental

Protection (WVDEP) via contract 0313-DEP2100000020-2 to operate and maintain the existing remediation system at the Vienna Superfund Site (United State Environmental Protection Agency

[USEPA] ID# WVD988798401), located at 405 29th Street in Vienna, Wood County, West Virginia

(Site). The location of the Site property is depicted in Figure 1.

In addition to operations and maintenance (O&M) activities, ATC will also be responsible for environmental monitoring at the Site. This Sampling and Analysis Plan (SAP) has been prepared to summarize the procedures for collection and analysis of groundwater and vapor samples collected as part of the environmental monitoring activities at the Vienna Superfund Site. This

SAP has prepared to incorporate the requirements specified in the draft Quality Assurance

Program Plan (QAPP) for the WVDEP Division of Land Restoration, Office of Environmental

Remediation dated September 2020. This SAP will be revised as necessary to reflect any future modifications made to the draft QAPP. Additionally, this SAP will outline ATC’s approach to data collection necessary to evaluate overall remediation system performance in conjunction with the ongoing long-term remedial action (LTRA) being conducted at the Site. A Site Monitoring Location

Map is provided as Figure 2.

2.0 SITE DESCRIPTION & BACKGROUND

2.1 Site Location & Source History

The Vienna Superfund Site consists of areas impacted by two separate and distinct sources of contamination that have been confirmed (identified as Vienna Cleaners and Busy Bee Cleaners), as well as a suspected third source that has not yet been confirmed. The Site is located in the

City of Vienna, West Virginia, which is a residential, commercial, and industrial community situated along the eastern (left-descending) bank of the Ohio River, as shown on Figure 1. A mountain ridge is located north and east of the City of Vienna; the city of Parkersburg, West

Virginia is located to the south of Vienna.

Vienna Cleaners operated from the late 1940s through the mid-1990s and was located at the intersection of 30th Street and 5th Avenue. In 1992, during a WVDEP inspection, the Vienna

Cleaners property owner stated that past practices included pouring tetrachloroethylene (PCE), a drycleaning solvent, directly onto the ground behind the facility. Spillage of PCE while filling outdoor, aboveground storage tanks (ASTs) had also been reported. The quantity of PCE released at Vienna Cleaners is unknown. A 1992 WVDEP Compliance Evaluation Inspection

Report classified Vienna Cleaners as a small quantity generator under the Resource

Conservation and Recovery Act (RCRA), producing 121 kilograms (kg) of PCE waste each month.

Busy Bee Cleaners operated from the 1960s to the early 2000s and was located at the intersection of 27th Street and Grand Central Avenue. The circumstances resulting in the release of PCE from the Busy Bee Cleaners facility (including quantity, pathways, and time frame of release) are unknown.

The third suspected source (a former drycleaning facility) was reportedly located along 29th

Street, between Grand Central Avenue and 3rd Avenue; the presence of this drycleaning facility was not able to be confirmed using county records. It may have operated during the 1930's and ceased operations by 1940. The quantities of PCE released, if any, from this possible third source area are unknown.

Residents and most businesses in Vienna currently receive their water from the Vienna municipal water supply, which consists of eight production wells located in clusters distributed throughout the City. The municipal water supply originally consisted of 12 wells, but four wells were abandoned in 1992 due to PCE contamination. The Vienna Cleaners and Busy Bee Cleaners were identified as the probable sources of the groundwater contamination. PCE has been detected at elevated levels in surface and subsurface soils at the Vienna Cleaners facility, in groundwater beneath the vicinity of the facility, and in City sewers in the immediate vicinity of the former Vienna Cleaners facility. Lower concentrations of PCE were detected in the groundwater near the Busy Bee Cleaners facility.

2.2 Site History & Previous Assessment Activities

City of Vienna municipal production wells PW-V1 through PW-V4 were shut down in June 1992 due to the identified PCE contamination. This shutdown followed the 1991 closure of PW-V5 and

PW-V6, which occurred because of gasoline-related contamination from an underground storage tank (UST). Municipal wells PW-V7 and PW-V8 (screened between 60 and 75 feet below ground surface [bgs]) are located downgradient of the dissolved-phase PCE plume, north of the City, adjacent to the Ohio River.

Before 1995, the water supply for Vienna’s residents was drawn from 12 municipal wells located in five clusters throughout the City, with no treatment facility for water from other sources (i.e.

surface water from Ohio River) available. In 1992, with production discontinued at six municipal wells due to contamination, the City faced a potential water supply shortage. As a result, two additional municipal wells (PW-V13 and PW-V14) were installed in 1995 using USEPA emergency funds to serve as a backup water supply. To meet water supply demands, the two wells were activated for full-time service on March 10, 1997.

On April 22, 1999, the Site was proposed to be added to the National Priorities List, and the listing was finalized on October 22, 1999.

In 2000, the USEPA Removal Program designed a pilot Unterdruck Verdampfer Brunnen system to remove subsurface contamination in the area of the Vienna Cleaners facility using a single air sparge/ soil vapor extraction (AS/SVE) well. The system was located in a small building adjacent to Vienna Cleaners and began removing contamination from an approximately 1,500-square foot area of soil in March 2001.

USEPA contracted CDM Smith to perform a Remedial Investigation (RI) that included the installation of 37 monitoring wells. In 2002, CDM Smith submitted three documents for the Site:

Final RI Report documenting the nature and extent of groundwater contamination (CDM

Smith 2002a);

Final Feasibility Study Report, which provided a detailed evaluation of remedial alternatives to address the PCE contamination (CDM Smith 2002b); and CDM Smith

A groundwater model to predict advective transport and travel times of contaminants

(CDM Smith 2002c).

USEPA’s Record of Decision, dated September 27, 2002, selected AS/SVE as the groundwater remedy. The remedial action objectives (RAOs) were developed to mitigate, restore, and/or prevent existing and future potential threats to human health and the environment. The RAOs for the selected remedy included reducing the PCE concentrations in groundwater to or below the drinking water standard (maximum contaminant level [MCL]) of 5 micrograms per liter (μg/L);

prevent/minimize human exposure to contaminated groundwater; and minimize the migration of contaminated groundwater into the Ohio River.

USEPA contracted CDM Smith to prepare the remedial design, which was finalized in April 2004

(CDM Smith 2004). CDM Smith completed construction of the treatment system for USEPA in

July 2005. A baseline sampling event including groundwater and vapor sampling was conducted in June 2005 prior to treatment system startup.

CDM Smith operated and maintained the Vienna treatment system for USEPA from system start up in July 2005 until turnover of O&M to WVDEP in May 2017; WVDEP subsequently retained

KEMRON Environmental Services, Inc. (KEMRON) to continue O&M activities, including biannual groundwater sampling and overall system performance monitoring. In May 2021, ATC was retained by WVDEP to continue with groundwater monitoring and system O&M activities. Periodic groundwater and vapor samples have been collected on-Site beginning in 2001 through the present to evaluate groundwater quality and assess whether vapor intrusion poses a threat to human health.

2.3 Conceptual Site Model and Remedial Design

The remediation approach for the Vienna PCE Site uses AS/SVE to remove volatile organics from the groundwater and vadose zone. These systems are combined with a hydraulic control system that is designed to maintain the historic gradient of the Vienna Cleaners groundwater plume while the plume is undergoing remediation.

Air sparging (AS) is a groundwater remediation technology that involves the injection of air under pressure into wells screened in the groundwater plume. Generally, air sparging is more effective for contaminants with greater volatility and lower solubility and for soils with higher permeability.

Air sparging is well suited for the Site given PCE’s low vapor pressure and the highly permeable, relatively homogeneous sandy subsurface conditions found at the Site.

At the Site, air is injected (sparged) below the water table, and the injected air volatilizes dissolved-phase PCE in groundwater. The volatilized PCE migrates upward into the vadose zone and is removed from the subsurface by the SVE system, which is comprised of blowers, air/water separators, pressure/vacuum gauges, bleeder valves, and sample ports for collecting vapor samples for analysis. The rate at which the contaminant mass is removed decreases as air sparging operations proceed and concentrations of dissolved contaminants are reduced.

The air sparging systems at the Site have been designed with air flow rates and pressures to treat the extent of the contaminant plume, while minimizing the potential for uncontrolled releases of contaminated vapors to the atmosphere, houses, or industrial buildings. In addition, portions of the air sparging systems were designed to act as barriers to prevent contamination from further migration. These barriers, referred to as sparge curtains in this report, consist of multiple air sparge wells located in series perpendicular to groundwater flow direction. Two sparge curtains were installed at the Site.

SVE is a remediation technology where a vacuum is applied to vapor extraction wells installed in the vadose zone. This vacuum creates a negative pressure gradient in the unsaturated zone causing the movement of vapors toward these SVE wells. The extracted vapors are then treated by vapor phase granular activated carbon (VPGAC) units and discharged to the atmosphere.

Until 2002, two production wells at a former manufacturing facility, located downgradient and west of the Vienna Cleaners source area, exerted a controlling influence on the hydraulic gradient of the Vienna Cleaners PCE plume. These two production wells, which produced approximately

30,000 gallons of water per day, were taken out of service in October 2002 when the manufacturing facility closed. The groundwater flow model developed by CDM Smith indicated that shutting off the manufacturing facility’s production wells would likely cause the hydraulic gradient to shift northwest toward the City’s municipal production wells. The Site hydraulic control system was designed to offset the effects of the manufacturing facility well shutdown and to minimize groundwater plume migration toward the City’s municipal wells by restoring the historic gradient at the Site. The hydraulic control system consists of a single groundwater extraction well removing groundwater at a rate of approximately 20 gallons per minute (gpm) over a 40-foot screened interval. Bag filters and liquid phase granular activated carbon (LPGAC) units are used to treat the extracted groundwater prior to discharge to the City storm sewer, which then flows into the Ohio River.

The simple Conceptual Site Model (CSM) of groundwater contamination presented in the 2017

Vienna PCE Site Remediation System O&M and Groundwater Report prepared by KEMRON shows the center of the PCE plume concentrated south of 29th Street. The highest PCE concentrations have been observed in MW-27S, which is located within the vicinity of the suspected third source. The PCE plume extends west onto the former production plant property, and east towards Vienna Cleaners.

The remediation system for the Site originally consisted of four discrete Treatment Units (TUs), with three of the TUs still present. Figure 2 identifies the overall layout of the TUs and their relationship to the Site.

2.3.1 Treatment Units

2.3.1.1 Vienna Cleaners Source Area – TU1

This area is located east of Grand Central Avenue and the objective of the unit is to remove the highest percentage of the contaminant mass located under and near the former Vienna Cleaners building (now razed) and to minimize further migration away from this source area. TU1 consists of air sparging and SVE systems, with 23 air sparge wells and nine SVE wells, including the two existing SVE wells previously installed by the USEPA Removal Program. The AS/SVE process equipment includes two air compressors, an air sparge well manifold header to distribute the pressurized air to the sparge wells, an SVE well manifold header to collect the vapors, an air/water separator to remove water from vapor extraction, an SVE blower, and two VPGAC units operating in series to remove contaminants from the extracted vapor prior to discharge to the atmosphere through an exhaust stack. The equipment is housed in a metal building on the Vienna Cleaners property.

2.3.1.2 Vienna Well Protection Area – TU2 – Provisionally Offline

This area is located directly southeast of City of Vienna production wells, PW-V7 and PW-V8. The objective of TU2 was to provide a sparge curtain on the downgradient edge of the Vienna

Cleaners plume to protect the City of Vienna production wells. TU2 consists of an AS system, with 15 air sparge wells located perpendicular to the plume gradient along River Road and 32nd

Street. Given the low concentration of contaminants expected to migrate into this area, no SVE is required, as there would be very little contaminant mass present to be captured in the vapor phase. The air compressor and AS well manifold headers are located in a metal treatment building on the west side of River Road near PW-V7 and PW-V8. TU2 is currently not operational and remains on standby until needed. The standby status of TU2 includes periodic startup and run testing to ensure viability should system operation be deemed necessary in the future.

2.3.1.3 Vienna Cleaners Central Plume Area – TU3

This area is located west of Grand Central Avenue, downgradient of the Vienna Cleaners source area. The objective of TU3 is to address the high levels of contaminant mass in the central portion of the Vienna Cleaners plume. TU3 consists of AS, SVE, and hydraulic control systems, with 37

AS wells, 17 SVE wells, and one groundwater extraction well (EW-1) for hydraulic control. A sparge curtain was installed on 3rd Avenue to intercept the groundwater plume before it migrates under the former manufacturing facility. The TU3 AS/SVE process equipment includes two air compressors, an AS well manifold header, an SVE well manifold header, an air/water separator, an SVE blower, two VPGAC units operating in parallel, and an exhaust stack. TU3 also contains the treatment system to treat groundwater extracted from EW-1. Groundwater pumped from the hydraulic control well (EW-1) passes through a treatment train consisting of bag filters and two

LPGAC units in series. Treated groundwater is discharged to the City storm drain system adjacent to the treatment building that drains to the west and empties into the Ohio River. The metal treatment building is located on the north side of 29th Street, west of and adjacent to a church parking lot.

2.3.1.4 Busy Bee Cleaners Source Area – TU4 – Decommissioned in 2009

This area is located adjacent to the Busy Bee Cleaners building and along 27th Street. The objective of TU4 was to address the Busy Bee Cleaners plume, which is separate from the Vienna

Cleaners plume. Because the plume had largely decreased, TU4 was decommissioned and relocated in 2009. TU4 previously consisted of AS and SVE systems, with six AS wells and three

SVE wells. The process equipment included an air compressor, an AS well manifold header, an

SVE well manifold header, an air/water separator, an SVE blower, two VPGAC units operating in series, and an exhaust stack.

3.0 PROJECT ORGANIZATION

As discussed in the Section 1.0, the objectives of this plan are to outline the protocols to monitor groundwater, vapor, and overall system performance in conjunction with the ongoing LTRA conducted at the Site. The following project organization and structure has been prepared to ensure project objectives are achieved and reporting on activities is completed in a timely fashion.

3.1 Project Organization and Distribution List

As WVDEP’s contractor, ATC will manage and perform both O&M and sampling. Deliverables will be submitted to WVDEP and USEPA according to the project’s distribution list. The ATC project team is presented below, and a copies of resumes showing personnel qualifications is included in Appendix A.

Project Manager

A supervisory position directing the overall operation, maintenance, monitoring and management of the project milestones, including O&M of the TUs, groundwater sampling events, client/agency communications and financial review/invoicing. Primary responsibilities are the following:

Ensure competency and safety of operations

Ensure compliance with all permit requirements

In charge of development and execution of plans

In charge of approving all changes in treatment system operation

Perform other related administrative and management work

Project Engineer

This position is responsible for providing technical assistance to the System Operator and Project

Manager in daily operations, maintenance, and monitoring of treatment system, monitoring site data to ensure the systems are operating at specified performance levels and providing changed in operation schedules and control functions, as needed.

Environmental Scientist

This position is responsible capable of completing highly technical work, such as but not limited to: field investigation management, borehole logging (soil sample description, organic vapor monitoring, and data interpretation), soil vapor sample collection, low-flow groundwater sampling, health and safety monitoring, and sample documentation/management.

System Operator

This individual is in charge of daily operation, maintenance, monitoring, and management of the treatment systems, extraction well system, and associated facilities, attainment of effluent and air discharge requirements, record maintenance, reporting, waste disposal, and other associated on-site operations. Responsibilities include the maintenance of accurate and orderly O&M records, the performance of other related work including administrative and routine office duties, as required.

3.2 Project Tasks and Schedule

ATC will complete a comprehensive groundwater sampling event in June/July 2021, which will include all monitoring wells associated with the Site. The sampling schedule for June 2021 is presented in Table 1. All groundwater samples will be collected and analyzed according to procedure detailed in Section 4.0. Results of this sampling event will be reviewed with WVDEP;

changes to the existing sampling schedule may be implemented based on the review of the June

2021 groundwater sampling event. Currently the project maintains a semi-annual reporting frequency (January through June and July through December).

ATC will perform weekly O&M visits and submit reports detailing the completed activities.

Treatment system performance will be evaluated and presented to WVDEP on a quarterly basis.

When feasible, this report will be incorporated into the semi-annual report.

4.0 PROJECT IMPLEMENTATION: MONITORING AND SAMPLING

All sampling will be completed utilizing the WVDEP Field Activities Standard Operating

Procedures (March 2021) for the Comprehensive Environmental Response, Compensation, and

Liabilities Act (Superfund) and Federal Facilities Program. Copies of applicable standard operating procedures are included in Appendix B.

4.1 Groundwater Sampling

4.1.1 Groundwater Sampling Schedule

As mentioned in Section 3.2, ATC will complete a comprehensive groundwater sampling event in June/July 2021, which will include all monitoring wells associated with the Site. Samples are scheduled to be collected from all the wells listed in Table 1.

All collected groundwater samples will be analyzed for target compound list (TCL) VOCs (PCE, TCE, 1,2-Dichloroethane, Methylene Chloride and Vinyl Chloride) using USEPA Method 8260.

As part of this event, the condition of the wells will be evaluated; repairs will be implemented after the completion of the sampling event. ATC will review and assess the data obtained during this sampling event with WVDEP. Sampling locations and frequency were selected based on prior dissolved-phase sampling results, prioritizing areas affected by plume migration, and to monitor system effectiveness. A modified sampling schedule will be developed based on this data and submitted to WVDEP for approval in an amended SAP or SAP Addendum.

The monitoring well network has been installed at three different depth intervals to measure the dissolved phase impacts to the three different aquifers beneath the Site and monitor the plume migration. Shallow wells (S notation) are generally screened at 40-60 ft. bgs, intermediate wells

(I notation) are generally screened at 70-85 ft. bgs, and deep wells (D notation) are generally screened 80-90 ft. bgs.

4.1.2 Groundwater Sample Collection Protocols

Groundwater gauging and sampling will be accomplished using low-flow sampling techniques in a manner that is consistent with the USEPA publication Low-Flow (Minimal Drawdown) Ground-

Water Sampling Procedures and with WVDEP approved Standard Operating Procedures

(WVDEP SOP OER-0110, dated March 4, 2021). Field equipment will be calibrated daily per factory specifications and calibration logs will be maintained. Copies of the calibration logs are included in Appendix C.

For each sampling event, the depth to water in all site monitoring wells (Table 1) will be gauged using an electronic water level indicator. The low-flow pump (either bladder or submersible pump) will be connected to flow-through cell in which a multi-parameter probe can monitor parameters as water is purged from the well. A water level indicator probe will be set at the desired drawdown limit within the screened interval of the well. All equipment will be set up within each well slowly and securely to ensure minimal disturbance of the water column. Placement of water intake will be at the middle of the screened interval or between the depth to water and the bottom of the screened interval if the water column is observed below the top of the screen. Pumping rates will be kept a minimal flow, between 200 and 300 mL/min (0.05 and 0.08 gallons per minute), to ensure minimal drawdown to the monitoring well throughout the purging and sampling activities.

Each monitoring well will then be purged of groundwater until drawdown on the water table and field parameters (temperature, pH, dissolved oxygen, oxidation reduction potential, and conductivity) have stabilized. The water quality parameters must be stabilized over three consecutive readings, per the stabilization criteria presented in the table below:

Parameter Stabilization Criteria pH ± 0.1 standard units

Conductivity ± 3% of readings

Temperature ± 1.0º C

Dissolved Oxygen ± 10% of readings

Turbidity ± 10% of readings [less than 10 nephelometric turbidity units (NTU), if possible]

Eh ± 10 millivolts

All depths to water, flow rates, water quality parameters, sample ID, location, color, odor, etc. will be recorded in a field logbook or groundwater sampling field sheet throughout the purging process. A copy of the groundwater sampling field data sheet is included in Appendix C.

Following purging, groundwater samples will be collected from each well. To keep agitation of the sample to a minimum, groundwater samples will be transferred directly from the low-flow pump to the appropriate laboratory-supplied sample containers. Per WVDEP groundwater sampling protocols, samples will be collected in the following order: volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), nitroaromatics, herbicides/pesticides, and metals. If future water samples are to be collected for analysis of dissolved metals, they will be field filtered prior to containerization using a 0.45 µm filter, and following 500 mL of filtered water to ensure representative sampling. Current groundwater sampling requirements are limited to TCL VOC analysis. Groundwater samples will be placed in an ice-filled cooler (maintained at 4ºC) with the appropriate chain-of custody documentation and submitted to WVDEP representative, or, if arranged through WVDEP, a courier for an analytical laboratory under contract to WVDEP. All low-flow sampling equipment that comes into contact with groundwater will be thoroughly decontaminated prior to reuse. New polyethylene tubing will be used for each groundwater monitoring well sampled.

In the event that low-conductivity formations render this drawdown limit infeasible, a modified purging method will be employed. If the well screen is entirely below the water table, the pump intake shall be placed just above the screen top, and purging shall be performed as gradually as possible. This configuration will ensure that the formation will not be exposed to air. However, if the well screen straddles the water table, purging the well dry may be unavoidable. In such a case, the well will be allowed to recharge for at least two hours, after which the sample will be collected when sufficient water is available. This low-conductivity protocol is intended to be consistent with the corresponding protocol in the USEPA Groundwater Sampling Guidelines (May

2002), page 9. As before, purging shall be conducted in a manner that will ensure completion in no more than two hours. Field readings taken in the process of sampling shall be recorded as the conditions of record for the sample.

4.1.3 Groundwater Analytical Schedule

The groundwater samples will be analyzed for specific VOC analytes by USEPA Method 8260 on a standard turnaround basis. During the June 2021 sampling event, ATC will collect groundwater samples from all monitoring wells associated with the Site as listed in Table 1.

The following analytes will be sampled for the corresponding groundwater monitoring wells:

Analyte Method CAS RN

MCL

(µg/L)

Tetrachloroethene 8260 127-18-4 5

Trichloroethene 8260 79-01-6 5

1,2-Dichloroethane 8260 107-06-2 5

Methylene Chloride 8260 75-09-2 5

Vinyl Chloride 8260 75-01-4 2

The samples will be collected in certified clean bottleware supplied by Pace Analytical

Laboratory (Pace), in Greensburg, Pennsylvania (WVDEP Certification #143 and West Virginia

Department of Health and Human Resources Certification #9964C). Copies of the certifications are included in Appendix D. The bottleware will contain preservative and be handled as indicated in the table below:

Analyte Method Sample

Container Volume

Holding

Time Preservative

1,2-Dichloroethane 8260 Glass, Teflon septum 3 - 40 mL 14 Days Cool ≤ 6°C; HCl to pH < 2

Methylene Chloride 8260 Glass, Teflon septum 3 - 40 mL 14 Days Cool ≤ 6°C; HCl to pH < 2

Trichloroethene 8260 Glass, Teflon septum 3 - 40 mL 14 Days Cool ≤ 6°C; HCl to pH < 2

Vinyl Chloride 8260 Glass, Teflon septum 3 - 40 mL 14 Days Cool ≤ 6°C; HCl to pH < 2

Tetrachloroethene 8260 Glass, Teflon septum 3 - 40 mL 14 Days Cool ≤ 6°C; HCl to pH < 2

4.1.4 Groundwater Quality Assurance/Quality Control Protocols

In accordance with Quality Assurance/Quality Control (QA/QC) protocols, the following samples will be collected and analyzed for the above-referenced VOC list by USEPA Method 8260.

Samples will be collected at the intervals indicated below or at a minimum of one QA/QC set per day.

QA/QC Sample Method Matrix

Estimated

Quantitation

Limit

Total Samples

Duplicate 8260 Groundwater 5 µg/L One per 10 Samples

Equipment Rinsate

Blank 8260 Groundwater 5 µg/L One per 20 Samples

Field Blank 8260 Groundwater 5 µg/L One per 20 Samples

MS/MSD 8260 Groundwater 5 µg/L One per 20 Samples

Trip Blank 8260 Groundwater 5 µg/L One per cooler

4.2 Vapor Sampling

4.2.1 Vapor Sampling Schedule

In an effort to assess the effectiveness of TU1 and TU3, 26 vapor samples for VOC analysis will be collected at sample ports or vapor monitoring points (VMPs) on the SVE treatment systems.

ATC will collect a full round of vapor samples during 2021 once the treatment systems are fully operational. The results of this sampling will be evaluated with WVDEP and the required sampling frequency will be determined.

4.2.2 Vapor Sample Collection Protocols

There are nine SVE wells associated with TU1 and 17 SVE wells associated with TU3. Ports are installed on each line for the individual wells immediately before the connection to the influent manifold. Ports are also located at influent, intermediate and effluent points of the GAC vapor treatment vessels. Each individual SVE well head is fitted with a pressure gauge, a vacuum line valve and a sample port with a quick release fitting to accommodate sample collection. Air tight connections to the sample ports will be achieved through the use of ¼ x ¼ inch quick-connect fittings and flexible tubing. Each individual SVE well head is fitted with a pressure gauge, a vacuum line valve and a sample port with a quick release fitting to accommodate sample collection. In an effort to ensure consistent sampling conditions, the treatment units will be manipulated to operate all sparge points and VMPs simultaneously during sampling. Measures will be taken to ensure that the VMPs are properly purged by applying vacuum for a minimum of two minutes prior to sample collection. Vapor samples will then be collected from individual VMPs by closing the valve from the well to the VMP manifold. For field measurements, a photoionization detector or minirae will be utilized at each sample collection point and results will be recorded.

Vapor samples will be collected from the VMPs using either certified pre-cleaned, one liter Summa canisters using five minute regulators or one-liter Tedlar® bags provided by Pace Analytical

Laboratory, for analytical services to be provided at their facility in Minneapolis, Minnesota.

Tedlar® is a trade name for a polyvinyl fluoride film developed by DuPont Corporation in the

1960’s. Using a bag to collect an air sample normally involves “active” sampling, unlike an evacuated canister that can be filled “passively” by simply opening the valve. Each Tedlar® bag expands as the vapor sample is pulled into it. When the target volume, 2/3 capacity of a one liter

Tedlar® bag, of the sample is collected, the valve is closed and the bag is returned to the laboratory. Tedlar® film is tough yet flexible and retains its impressive mechanical properties over a wide range of temperatures (from well below freezing to over 200°F). Tedlar® exhibits low permeability to gases, good chemical inertness, good weathering resistance and low off- gassing.

For sampling with the Tedlar® bags, first the sample port and affiliated tubing must be purged.

Next, the tubing from outlet/sample port is attached to the bag valve. For sampling collection on the vacuum side of the system, a small portable pump will be required to collect samples. The bag valve is then opened. While collecting the sample, the bag will be filled to 2/3 capacity (do not exceed 2/3 capacity). After it has been filled to at least 2/3 capacity, the valve on the Tedlar® bag can be closed by hand tightening the valve clockwise. The bags do not need to be chilled for shipping, but will be packaged in a rigid shipping container to maintain the integrity of the bags.

If using the one-liter Summa canisters for sample collection, once the tubing connection between the canister and the sampling port is accomplished, an integrated sample will be collected by opening the valve on the evacuated canister until reaching a vacuum of -3” to -1” Hg. In the case of a leak during sampling, all fittings will be tightened, or the VMP will be resealed or replaced as needed to obtain a sample with the appropriate integrity.

4.2.3 Vapor Analytical Schedule

The vapor samples will be analyzed for specific VOC analytes by USEPA Method TO-15 on a standard turnaround basis. The sampling frequency will be evaluated pending a review of the initial sampling event data. The following analytes will be sampled for the corresponding groundwater monitoring wells:

Reporting

Limit

(µg/m3)

VMPs to be Sampled

Tetrachloroethene TO-15 127-18-4 0.3 TU1 – 9 SVE Wells/VMP

TU3 – 17 SVE Wells/VMP

The samples will be collected in laboratory supplied certified clean containers. The containers will be handled as indicated in the table below:

Analyte Method Sample

Container Volume

Holding

Time Preservative

Tetrachloroethene TO-15 Summa Canister 1-L 14 Days Ambient Temperature; Keep out of light

Tetrachloroethene TO-15 Tedlar® 1-L 48 Hours Ambient Temperature; Keep out of light

4.2.4 Vapor Quality Assurance/Quality Control

In accordance with QA/QC protocols, the following samples will be collected and analyzed for the above-referenced VOC list by USEPA Method 8260.

QA/QC Sample Method Matrix

Estimated

Quantitation

Limit

Total Samples

Duplicate TO-15 Groundwater 0.3 µg/m3 One per 10 Samples

Following completion of soil vapor sampling, soil vapor samples will be logged on an appropriate chain-of-custody form and submitted via to Pace, for analytical services at their NELAC certified facility in Minneapolis, Minnesota for analysis. Soil vapor samples will be analyzed for PCE by

USEPA Method TO-15. One duplicate sample per TU will be collected and analyzed for PCE by

USEPA Method TO-15 as per QA/QC protocols.

4.3 Discharge Water Sampling

4.3.1 Discharge Water Sampling Schedule

At TU3, groundwater extracted from EW-1 is treated before being discharged into the City of

Vienna storm drain system. In an effort to monitor the effectiveness of the treatment units, discharge water samples will be collected from three points (influent, mid-carbon, and effluent) in the treatment system on a monthly basis.

4.3.2 Discharge Water Sample Collection Protocols

An influent sample is taken prior to the two LPGAC treatment vessels, an intermediate sample is taken between the two vessels, and a final sample taken at an effluent port.

4.3.3 Discharge Water Analytical Schedule

The groundwater samples will be analyzed for specific VOC analytes by USEPA Method TO-15 on a standard turnaround basis. The following analytes will be sampled for the corresponding groundwater monitoring wells:

MCL

(µg/L)

Discharge Water Sampling

Locations

Tetrachloroethene 8260 127-18-4 5 Influent, Mid-Carbon, Effluent

These three sampling locations are to be collected monthly and to be analyzed for PCE via

USEPA Method 8260 on a standard turn around basis, will be placed in an ice-filled cooler with the appropriate chain-of custody documentation, and submitted to Pace, in Greensburg, Pennsylvania for laboratory analysis.

5.0 DECONTAMINATION PROCEDURES

Decontamination procedures to be employed for personnel and equipment during O&M activities at the Site are summarized below. The decontamination process is designed to remove any contamination acquired during sampling and to keep the spread of contaminated materials from migrating off-site. Care must be exercised to ensure that contaminants are removed from personnel and equipment before the personnel or equipment leaves the Site. Decontamination of equipment will be accomplished in a manner that is consistent with the USEPA publication Field

Equipment Cleaning and Decontamination and with WVDEP approved Standard Operating

Procedures (WVDEP SOP OER-0110, dated March 4, 2021).

5.1 Personnel Decontamination

Dry decontamination is the preferred method utilized by ATC. This method of decontamination involves the removal and containment of contaminated layers of personal protective clothing.

Personal protective equipment, such as nitrile gloves, will be removed and properly disposed of after sampling at each groundwater monitoring well.

All Site employees will wash hands and face before leaving the site for the day to reduce transferring potential contamination from groundwater sampling activities. In the event of an emergency, site personnel may assist with the emergency decontamination only if they are protected from exposure. An emergency eyewash and first aid kit will be located within each ATC vehicle in the event that emergency decontamination is needed.

5.2 Equipment Decontamination

This procedure is applicable for any equipment that will be used to collect a sample for chemical analysis. Whenever feasible, field equipment will be pre-cleaned (using this procedure) at the equipment maintenance area, wrapped in aluminum foil, and dedicated to a particular sampling point. In instances where this is not feasible, field decontamination will be performed as follows:

1. Non-phosphate detergent wash;

2. Distilled water rinse, and

3. Air dry.

Note: All wastewater generated will be collected, placed in a properly labeled 55-gallon drum, and temporarily staged on-Site pending being processed through the TU3 treatment system.

6.0 INVESTIGATION-DERIVED WASTE MANAGEMENT

Investigation-derived wastes generated during O&M activities at the Site will be containerized and managed in accordance with the procedures specified below.

6.1 Purge Water

Purge water generated during O&M activities at the Site will be temporarily containerized in 5-gallon buckets or 55-gallon drums during generation, where applicable. The containerized purge water will be treated in the existing groundwater treatment system in TU3. In the event the purge water needs temporarily staging on-site, contained material will be properly labeled until treatment is complete.

6.2 Decontamination Water

Decontamination water generated during O&M activities at the Site will be temporarily containerized in 5-gallon buckets or 55-gallon drums following completion of daily decontamination activities. The containerized decontamination water will be properly labeled and temporarily staged on-site pending treatment in existing groundwater treatment system in TU3.

7.0 SAMPLE HANDLING, STORAGE AND SHIPMENT

7.1 Sample Numbering System

7.1.1 Scope and Application

This procedure is applicable to samples collected during the field work at the Site by ATC. The sample numbering system used by the WVDEP or their contractor may not comply with those stated herein. An accurate sample numbering system is important for sample tracking and matching of results with sample locations.

7.1.2 Summary of Method

A unique number is assigned to each sample collected according to a predetermined set of criteria.

7.1.3 Procedure

The sample numbering system will be used to identify each sample taken and to provide a tracking procedure for retrieval of information.

The sample ID code will consist of three parts:

• Site identifier (VPCE, for Vienna PCE Site);

• Sample Location ID (MW-02 S, VMP-01, etc.); and

• Sampling Date (210628) (YYMMDD - Year, Month, Day).

QA/QC samples would be identified as follows:

Duplicate: VPCE-MW-DUP_A-210628 or VPCE-VMP-DUP_A-210628

MS/MSD: VPCE-MW-16S-210628MS and VPCE-MW-16S-210628MSD

Equipment Blank: VPCE-MW-EB-1-210628

Field Blank: VPCE-MW-FB-1-210628

7.1.4 Precautions

It is critical that the sample numbers be recorded correctly on the sample label, the field logbook, and the chain-of-custody record.

7.2 Storage and Handling

The sample holding time begins to elapse immediately following sample collection.

Once a sample has been collected, the sample will be secured in a locked vehicle, locked trailer, custody-sealed cooler or in a visual sight of the person(s) assuming the chain-of-custody until shipment to the laboratory or transfer to the laboratory courier.

Groundwater samples will be placed on ice and stored at 4ºC prior to analysis. Following analyses, the laboratory will store the samples at room temperature in a secure area for 45 days months.

7.3 Shipping

This procedure is applicable to packing and shipping the environmental samples that will be collected during the field activities at the Site. Proper packing/shipping is critical to the sample chain-of-custody, as well as protection of the shipper and carrier. The following applies to samples not suspected to contain potentially hazardous constituents. For all other shipping, consult applicable guidance documents. If samples are discolored, odorous, or contain non- aqueous phase materials, applicable shipping guidance should be considered.

1. Prepare containers for shipment.

Affix “This Side Up” and appropriate shipping labels on each of the containers.

Place mailing label with laboratory address on top of containers.

Assign chain-of-custody records and corresponding custody seals to respective shipping containers.

2. Prepare sample bottles.

Check to see that lids are on tight and that bottle labels are firmly affixed and labeled.

Spray the bottles with tap water and wipe with a paper towel.

3. Arrange the sample containers in front of their assigned shipping containers.

4. Seal each sample container in a separate sealable zipper storage plastic bag and place the sample containers in their designated shipping containers. Appropriately sized commercially available plastic bags may be used in the event that the sample bottle will not fit in a sealable zipper storage bag.

5. Place bags of ice directly on and around the sample containers. Ice should be double- bagged in a sealable zipper storage bag. Alternatively, blue ice blocks may be used.

6. A temperature blank shall be added in each cooler.

7. Fill the remaining space with vermiculite absorbent packing material.

8. Sign the chain-of-custody form (or obtain the signature) and indicate the time and date the samples are relinquished to the overnight carrier or laboratory courier.

9. Seal the proper chain-of-custody copy in a sealable zipper storage bag and tape it to the inside lid of the container.

10. Close the lid and latch the container.

11. Carefully peel the custody seals from their backings and place them intact over the front and back edges of the shipping container. Cover the seals with clear protection tape.

12. Tape the container shut on both ends, making several complete revolutions with strapping tape (do not cover the custody seals).

13. Address the shipment and relinquish the shipping container(s) to the overnight carrier or laboratory courier.

14. Telephone the laboratory on the day of shipment. Provide the following information:

Sampler name;

Number of samples sent to the laboratory for analysis; and

Airbill numbers (if applicable).

8.0 QUALITY ASSURANCE/QUALITY CONTROL

8.1 Quality Assurance Objectives

Data Quality Objectives define the total uncertainty in the data that is acceptable for each specific activity during the investigation. This uncertainty includes both sampling error and analytical error.

The data collected during the investigation will be used to monitor and evaluate the efficacy of the ongoing O&M of the LTRA. The parameters that will be used to specify data quality requirements and to evaluate the analytical system performance are precision, accuracy, representativeness, completeness, and comparability.

The objective with respect to the field investigation is to maximize the confidence in the data in terms of precision and accuracy. Section 4.0 presents the frequency with which trip blanks, field duplicates, field blanks, and matrix spike/matrix spike duplicate (MS/MSD) will be collected. The data quality objective for field duplicates is to achieve precision equal to or greater than that specified in the analytical methods and the laboratory quality assurance plan.

Precision will be calculated as the relative percent difference if there are only two analytical points and as relative standard deviation if there are more than two analytical points. The submission of blanks will monitor potential contaminants introduced during the sampling, preservation, handling, shipping, and the analytical processes. Through the submission of field QC samples and review of resultant analytical data, the distinction can be made between laboratory problems, sampling technique, and sample matrix variability.

Every effort will be made to obtain complete and valid data for all sampling points. To establish a degree of comparability, ATC will use standardized methods of field analysis, sample collection, and preservation, as well as adhering to established holding time requirements.

Groundwater samples will be submitted to Pace Analytical Laboratory, for analytical services to be provided at their facility in Greensburg, Pennsylvania. Air/Vapor samples will be submitted to

Pace Analytical Laboratory, for analytical services to be provided at their facility in Minneapolis, Minnesota. The laboratories will be expected to document all analytical problems encountered during the course of the investigation and communicate any problems as soon as they become apparent. Communication will be maintained with the laboratory so that, should analytical problems be encountered, ample opportunity will be available to recollect these samples, if necessary. In the event QC problems are detected by the lab (e.g., calibration standardization, machine failure, or detections in method blanks); we will be notified prior to analysis of the samples. No samples that have exceeded method holding times are to be analyzed without prior authorization. If spike recoveries are found to be outside the method specified range, then a QC check sample containing the spiked analyte that failed must be prepared and analyzed to determine matrix interferences.

The overall data management objective is to provide a complete database with a high degree of confidence using a phased approach of sampling, analysis, data assessment (data review), data qualification and feedback.

8.2 Sampling Procedures

Sampling will be performed in accordance with the procedures outlined in Section 4.

8.3 Sample Custody

The primary objective of these sample custody procedures is to create an accurate written record that can be used to trace the possession and handling of all samples from the moment of their collection, through analysis, until their final disposition. Chain-of-Custody documentation for samples collected during this investigation will be maintained by the Project Manager or field team collecting the sample. The field team will be responsible for documenting each sample transfer and maintaining custody of all samples until they are shipped to the laboratory.

A WVDEP contracted laboratory will supply all necessary sample containers…