ATTACHMENT_2_Master_QAPP_2018_Final.pdf

MASTER QUALITY ASSURANCE PROJECT PLAN

FOR

DON EDWARDS SAN FRANCISCO BAY NATIONAL

WILDLIFE REFUGE

Prepared for:

Regional Water Quality Control Board

Prepared by:

USFWS &

H. T. Harvey & Associates i

Table of Contents

Section 1.0 Introduction

1.1 Problem Definition

1.2 Purpose of QAPP

1.3 Basis for QAPP Criteria and Procedures

1.4 Permits Guiding Use of Terrestrial Fill at the Refuge

Section 2.0 Project Team Organization and Responsibilities

Section 3.0 Fill Analysis Procedures and Contaminant Screening Criteria

3.1 Initial Screening

3.2 Phase 1 Borrow Site Analysis

3.3 Phase 2 Borrow Site Analysis

3.3.1 Site Sampling Plan

3.3.2 Acceptance or Rejection of Fill

3.4 Contaminant Screening Criteria

3.4.1 Wetland Surface Material

3.4.2 Wetland Foundation Material

3.5 Laboratory Analysis Methods

3.5.1 Chemical Constituents

3.5.2 Method Detection Limits and Reporting Limits

3.5.3 Accuracy

3.5.4 Precision

3.6 Quality Assurance during Fill Transport and Placement

3.6.1 Agency Approval of Proposed Work

3.6.2 From Borrow Site to Truck

3.6.3 From Truck to Project Site

3.6.4 Fill Placement at Project Site

3.7 Reporting Requirements

Section 4.0 References

Tables

Table 1. Minimum Sampling Requirements Table 2. Contaminant Screening Criteria for Wetland Surface Material Table 3. Contaminant Screening Criteria for Wetland Foundation Material

Figures

Figure 1. Refuge Managed Lands Figure 2. Screening Guideline Decision Tree for Approving Borrow Sites

Appendix

Appendix A. USFWS Master QAPP Project Addendum.....................................................................................A-1

Section 1.0 Introduction

1.1 Problem Definition

The Don Edwards National Wildlife Refuge (Refuge) is located in South San Francisco Bay, California, largely in areas formerly owned by Cargill (Figure 1). The former salt ponds contain more than 70 miles of levees that require ongoing operations and maintenance (O&M) to maintain the level of flood protection formerly provided under Cargill’s management. In addition, the Refuge is part of the South Bay Salt Pond Restoration

Project (SBSPRP), the largest tidal wetland restoration project on the West Coast, which is being implemented over several phases (Phase 1, Phase 2, etc.), and is a partner with other federal, state and local agencies in the construction of flood protection levees on the Refuge.

The Refuge seeks fill from upland projects to use for a variety of purposes, ranging from habitat enhancement features, pond restoration, levee maintenance, levee construction, and other O&M activities on the Refuge. The

San Francisco Bay Regional Water Quality Control Board (RWQCB) requires an RWQCB-approved quality assurance project plan (QAPP) before terrestrial fill can be imported and used on the Refuge (RWQCB 2008).

1.2 Purpose of QAPP

The purpose of this Master QAPP is to set forth the process for evaluating the sources of fill, so that the fill imported to the Refuge meets RWQCB contaminant screening guidelines for the protection of aquatic life

(RWQCB 2000). This Master QAPP establishes the process and details for QAPP implementation, describes fill material screening procedures, provides screening levels for contaminants in imported fill soil, and specifies the laboratory testing methods that, when properly implemented, provide a high level of confidence that material placed in the complexes will meet RWQCB contaminant screening guidelines for the protection of aquatic species. It also describes the quality assurance measures that will be implemented during the transport and placement of fill.

For each project to be implemented within the Refuge, a project-specific Addendum to the Master QAPP shall be developed by the Refuge and submitted to the RWQCB for review and approval. Each project-specific

Addendum to the Master QAPP shall include the identities and qualifications of the project’s team members, the project purpose, project-specific permits (including the agency-specific identification numbers for those permits), and project-specific material handling protocols. An example of a project-specific Addendum to the

Master QAPP is included in this document as a guide.

Figure 1. Refuge Managed Lands

1.3 Basis for QAPP Criteria and Procedures

For terrestrial fill to be approved, the borrow site proponent must demonstrate that the fill has contaminant levels below screening limits established in this Master QAPP. The contaminant screening limits in this Master

QAPP are based on those in the San Francisco Bay RWQCB’s Beneficial Reuse of Dredged Materials: Sediment

Screening and Testing Guidelines (RWQCB 2000) for use of fill in wetland environments, the RWQCB-approved QAPP for Inner Bair Island Fill Import and Placement (USFWS 2008b), and the RWQCB’s

Environmental Screening Levels (RWQCB 2013). The requirement that fill intended for use in wetland environments meet contaminant screening limits is appropriate because levee material could become part of the wetland environment in the future (e.g., through reworking of levees during future restoration actions).

Many of the screening levels in the San Francisco Bay RWQCB’s Beneficial Reuse of Dredged Materials:

Sediment Screening and Testing Guidelines (RWQCB 2000) are based on ambient levels of constituents in San

Francisco Bay sediments. As data are collected from San Francisco Bay sediments during on-going monitoring programs, ambient constituent levels will be adjusted to reflect the most recent data sets. In addition, the

RWQCB’s Environmental Screening Levels are periodically revised to reflect the most recent science on exposure routes and toxicity of constituents. As these screening levels are updated, this Master QAPP should be updated to incorporate the most recent screening levels.

Screening procedures in this QAPP were developed using the QAPP for Inner Bair Island Fill Import and

Placement (USFWS 2008b), the California Department of Toxic Substance Control’s (DTSC’s) Information

Advisory: Clean Imported Fill Material (DTSC 2001), and the U.S. Environmental Protection Agency’s (EPA’s)

Guidance for Quality Assurance Project Plans (EPA 2002).

The following key structural elements were critical to the successful implementation of the Bair Island

QAPP. Therefore, these elements are also incorporated in this Master QAPP.

Clearly defined project roles to provide robust oversight of soil screening methods, analysis of soil screening results, and soil import

Use of a qualified, detail-oriented soil import contractor with a track record of successfully implementing QAPP procedures

Use of a full-time gate keeper to screen all trucks entering the project site

Oversight of the contractor and gatekeeper by an independent quality assurance officer

Oversight of soil screening results by a peer reviewer prior to soil acceptance by the quality assurance officer, combined with regular coordination and consultation with the RWQCB

Consultation with the RWQCB by the quality assurance officer prior to acceptance of soil when laboratory results have a method detection limit for one or more chemical constituents that exceeds the screening criterion.

1.4 Permits Guiding Use of Terrestrial Fill at the Refuge

Each project-specific addendum shall include a list of all permits that guide the use and placement of imported terrestrial fill necessary to implement the project purpose.

Section 2.0 Project Team Organization and Responsibilities

This section identifies the parties involved with implementing this QAPP and their respective roles. Sites that will serve as potential sources for fill for levee O&M are referred to as borrow sites.

Quality Assurance Officer. The quality assurance officer is responsible for leading in verifying that all QAPP procedures and contaminant screening criteria are met and has the following key responsibilities:

o The quality assurance officer will verify that the borrow site sampling procedures identified in this QAPP are followed. The quality assurance officer will: (1) review the Phase 1 Borrow Site

Analysis (Phase 1 Analysis), the Borrow Site Sampling Plan (Site Sampling Plan), and the Phase

2 Borrow Site Analysis (Phase 2 Analysis); (2) make a minimum of one visit to each borrow site; and (3) review borrow site sampling results.

o After the quality assurance officer is satisfied that the proposed borrow site meets the contaminant screening criteria outlined in this QAPP, the quality assurance officer will prepare a borrow site characterization memorandum for submission to the Project Management Team.

The borrow site characterization memorandum will document that the fill meets the contaminant screening levels.

o The quality assurance officer will maintain a spreadsheet cataloging the names, addresses, and fill depths and volumes of acceptable borrow sites.

o The quality assurance officer will monitor construction to verify that QAPP procedures are followed during borrow site excavation and fill placement. Monitoring includes making random, unannounced visits to the borrow sites during excavation and random, unannounced visits during fill placement to monitor compliance with this QAPP. The quality assurance officer also will verify that the gate keeper is accepting and tracking trucks in accordance with this QAPP.

o The quality assurance officer will prepare and submit quarterly reports described in Section

3.7.

o The quality assurance officer will consult with the RWQCB when a sample procedure or result does not strictly meet QAPP requirements, but there is reason to believe that the soil could be acceptable for use.

Project Management Team—The Project Management Team is composed of personnel from the

USFWS and may include other partners for specific projects (e.g., Coastal Conservancy for the

SBSPRP). This team will manage the roles and responsibilities of all parties involved throughout the life of this QAPP. The Project Management Team also will review quarterly reports provided by the quality assurance officer(s).

Borrow Site Proponent—The borrow site proponent will carry out the Phase 1 Analysis to screen potential fill sources, develop the Site Sampling Plan, sample the borrow site in accordance with the

Site Sampling Plan, and send fill sample data to a laboratory approved by the quality assurance officer for contaminant screening.

Contractor—The contractor will identify and review potential borrow sites, orient and guide the borrow site proponent through QAPP procedures, and submit the Phase 1 and Phase 2 Analyses to the quality assurance officer. If fill is approved by the quality assurance officer, the contractor will transport and place the fill on site. The contractor will issue a daily dispatch log, documenting the approved number of trucks and the trucking company transporting fill from each borrow site.

Peer Reviewer—The peer reviewer will review laboratory analysis methods for suitability based on the QAPP goals and will provide a second level of review of the Site Sampling Plan and borrow site sampling results. The peer reviewer will be contracted to the quality assurance officer and will therefore be contractually independent of the borrow site proponent.

Gate Keeper—The gate keeper is an employee of the contractor. The gate keeper will ensure that only trucks carrying fill from approved borrow sites are allowed onto the project site. The gate keeper will monitor the entrance to the project site full time during fill transport. The gate keeper will keep a log to document the number of trucks entering the project site, the borrow source location of each truck, the trucking company, the volume of fill delivered for comparison with the dispatch log issued by the contractor, and whether the fill is acceptable as cover or foundation material. Upon approval by the peer reviewer, a soil acceptance form will be generated listing the name and location of the project, approved volume, and the date of approval. Copies of these forms will be delivered to the borrow site to be handed to each truck. These forms will be collected upon entry and logged by the gate keeper.

Each truck shall also be given a unique tag prior to leaving the borrow site. Trucks without a soil acceptance form from an approved source and without the unique tag issued at the borrow site shall be rejected from entry to the fill site.

Persons Responsible for QAPP Update and Maintenance—Changes and updates to this QAPP will be made after a review of the rationale for change by the quality assurance officer and with the concurrence of RWQCB and the Project Management Team. The Project Management Team will identify an agent (e.g., the quality assurance officer) to make changes to this QAPP, submit drafts for review, prepare a final copy, and submit the final version for review and approval by RWQCB.

Section 3.0 Fill Analysis Procedures and Contaminant

Screening Criteria

This QAPP will be implemented in accordance with the procedures and fill screening criteria described below.

Figure 2 summarizes the screening decision tree process for approving borrow sites.

3.1 Initial Screening

The contractor will work with the borrow site proponent to determine whether a borrow site is potentially suitable for use as a source for fill based on the borrow site location, land use history, economics, timing, and the quantity of material available. Sites that have any history of industrial or commercial activities likely to lead to contamination (e.g., gas stations and dry cleaners) will not be considered as a source. At sites with a history of agricultural use, the upper 3 feet of the site may be discarded from consideration if they are contaminated by agricultural pesticides. If a borrow site is potentially suitable, then the contractor will request a Phase 1

Analysis from the borrow site proponent. The borrow site proponent will make appropriate due diligence inquiries into the previous ownership and uses of the site including, but not limited to, review of previous environmental site assessments (if available), review of city and historical records, interviews with the current property owner and other persons associated with the subject and adjoining properties, and searches of environmental databases, such as the California State Water Resources Control Board’s GeoTracker. Borrow sites are likely to be located in the San Francisco Bay Area. The contractor will review the initial borrow site characteristics, including review of GeoTracker, EnviroStor, prior Phase 1 or Phase 2 environmental site assessments, and any other available site history documents including available environmental and geotechnical reports.

3.2 Phase 1 Borrow Site Analysis

Phase 1 Analysis is a qualitative analysis carried out by the borrow site proponent to help the contractor and quality assurance officer identify potential environmental hazards present in the borrow site fill. Either party may reject part or all of a borrow site that has a high likelihood of contamination based on the results of the

Phase 1 Analysis (Figure 2). The borrow site proponent is responsible for carrying out the Phase 1 Analysis and providing a Phase 1 Analysis report to the contractor and quality assurance officer for review.

A complete Phase 1 Analysis report will include the following information:

Name of borrow site proponent

A map showing the location and extent of the potential borrow site

Current and previous landowners’ names and dates of ownership

A description of current and past site use(s) and any possible environmental conditions that could lead to fill contamination, including the likelihood that volatile organic compounds (VOCs) may be present in fill material

Photos of the borrow site with descriptions that can inform the type of analysis to perform

Any previously collected contaminant data for the site

The approximate volume of anticipated fill acceptable for use in the Refuge.

The following steps are involved with carrying out Phase 1 Analysis:

The borrow site proponent writes the Phase 1 Analysis report and provides it to the contractor.

The contractor prescreens the Phase 1 Analysis report for accuracy and completeness and then provides the Phase 1 Analysis report to the quality assurance officer for review.

If requested by the quality assurance officer, the contractor and quality assurance officer will perform a site visit to confirm site conditions and identify potential sources of contamination.

3.3 Phase 2 Borrow Site Analysis

Phase 2 Analysis consists of conducting the quantitative assessment of contaminant concentrations in the potential borrow material. Following completion of the Phase 2 Analysis, the contractor will review the sampling plan to confirm alignment with QAPP procedures and screen laboratory data results against the contaminant screening criteria. If contamination levels in the potential fill are below the threshold levels identified in this QAPP (Section 3.4), the contractor will prepare a Phase 2 Analysis report for review by the quality assurance officer.

A complete Phase 2 Analysis report will include the following information:

A borrow site sampling plan (described below)

A description of the sampling methods used and summary of whether the methods deviated from those described in the borrow site sampling plan (and if so, why)

A description of laboratory contaminant analysis methods

Laboratory contaminant results and identification of any contaminants exceeding the screening criteria presented in Section 3.4

Conclusions with an accurate map of the areas and depths that the contractor recommends be accepted or rejected for use as either wetland surface material or wetland foundation material.

The following steps are involved with carrying out the Phase 2 Analysis:

The borrow site proponent develops a Site Sampling Plan (Section 3.3.1).

The contractor provides the Site Sampling Plan to the quality assurance officer.

The Site Sampling Plan is reviewed by the quality assurance officer and peer reviewer. If needed, the borrow site proponent will revise the Site Sampling Plan to address concerns.

The Site Sampling Plan is approved by the quality assurance officer.

The borrow site proponent carries out the Site Sampling Plan.

The quality assurance officer may make site visits during fill sampling to verify that methods are being followed.

The borrow site proponent sends samples for analysis to an approved laboratory.

Laboratory results are sent to the borrow site proponent, contractor, and quality assurance officer.

If some or all portions of the borrow site meet the contaminant screening criteria for either wetland surface material or wetland foundation material, the contractor will prepare a Phase 2 Analysis report and provide it to the quality assurance officer.

The quality assurance officer and peer reviewer will review the Phase 2 Analysis report and then determine whether the fill meets the screening requirements in this QAPP for either wetland surface material or wetland foundation material. The quality assurance officer may either approve the borrow site, reject the borrow site, or request that the contractor and borrow site proponent conduct further sampling and testing and resubmit the results for review.

3.3.1 Site Sampling Plan

The Site Sampling Plan will be developed by the borrow site proponent before samples are collected. The Site

Sampling Plan will be submitted to the quality assurance officer by the contractor and will:

Include accurate maps showing the proposed borrow site, any areas of environmental concern identified in the Phase 1 Analysis report, and sample locations and depths;

Identify the expected volume and acreage of the borrow site;

Describe the rationale for the sampling design (the number of samples should, at a minimum, meet

DTSC recommendations (Table 1) (DTSC 2001);

Describe the methods for sample collection, including:

o Global Positioning System or other navigation method to proposed sample locations;

o sampling equipment (e.g., coring device; type of buckets, glass jars, coolers);

o sampling procedures to prevent contamination of samples (e.g., decontamination of equipment and sample containers, and clean handling techniques to prevent contaminating the samples) o depth of samples;

o sample compositing plan, if any; and o sample handling (i.e., identification, labeling, transport, storage, holding time, and disposal);

Provide contact information for the selected laboratory where samples will be analyzed;

Specify the chain-of-custody form and procedure that will be followed from sample collection through laboratory analysis so that the physical possession of samples is known at all points in the project;

Identify the analytical parameters to be tested (Section 3.5); and

Identify the laboratory’s reporting limit for each constituent being sampled compared to the contaminant screening criteria below. If the reporting limit is greater than the contaminant screening criteria for a constituent(s), the method detection limit (MDL) for the constituent(s) also will be provided (see section 3.5.2).

Table 1. Minimum Sampling Requirements

Area or Volume Minimum Number of Samples Required

Area of individual borrow area

2 acres or less Four samples

2–4 acres One sample every 0.5 acre

4–10 acres Eight samples

Volume of borrow area stockpile

Up to 1,000 cubic yards One sample per 250 cubic yards

1,000–5,000 cubic yards Four samples for first 1,000 cubic yards and one sample for each additional 500 cubic yards

Greater than 5,000 cubic yards 12 samples for first 5,000 cubic yards and one sample for each additional 1,000 cubic yards

Source: DTSC 2001

3.3.2 Acceptance or Rejection of Fill

All fill samples must meet the contaminant criteria for wetland surface material (Section 3.4.1) for an entire borrow site to be approved for unrestricted use as wetland surface fill (Figure 2). If only a portion of the samples collected at a potential borrow site meet the contaminant criteria for wetland surface material, the quality assurance officer will specify on a map the volume and extent of the portion of the site that is approved for use as wetland surface fill, based on sample locations and depths along with the associated analytical results. At the discretion of the quality assurance officer, additional sampling may be required to delineate the extent of the suitable wetland surface fill material. If a high potential for pesticide residue exists at a site, such as from previous agricultural use, the upper 3 feet of material may be rejected at the discretion of the borrow site proponent or contractor, or tested to confirm the presence of contamination.1

If contaminant levels exceed the screening criteria for use as wetland surface material, the data may be compared to the wetland foundation screening criteria in Section 3.4.2. If only a portion of the samples collected at a potential borrow site meet the contaminant criteria for wetland foundation material, the quality assurance officer will specify on a map the volume and extent of the portion of the site that is approved for use as wetland foundation fill, based on sample locations and depths along with the associated analytical results. At the discretion of the quality assurance officer, additional sampling may be required to delineate the extent of the suitable wetland foundation fill material.

If the results of the Phase 2 Analysis indicate that the borrow site contains fill that is suitable as wetland surface material and/or wetland foundation material, the quality assurance officer will summarize the conclusions in a borrow site characterization memorandum submitted to the contractor, the Project Management Team, and the RWQCB. The memorandum will serve as a partial soil acceptance form and will document the name and address of the acceptable borrow site, the volume of material at the site, the volume of fill approved for surface

1 Because the Southern Bay Area was historically used for agriculture, pesticides are ubiquitous in Southern Bay Area surface soils. It is rare for the upper three feet of soils in this area to have pesticide levels that are low enough for use as wetland surface soils. At most sites in the Southern Bay Area, it is prudent to discard the upper three feet of soils, rather than testing them for potential use in wetlands.

material, the volume of fill approved for foundation material, and their location(s) and depths in the borrow area. The Phase 1 and 2 Analysis reports will be included as attachments. In addition, each load of soil will be assigned a unique tag. Trucks will not be admitted to a project site without the unique tag issued at the borrow site.

3.4 Contaminant Screening Criteria

Fill used at the Refuge as wetland surface material must meet the contaminant screening criteria identified in

Table 2 and fill used at the Refuge as wetland foundation material must meet the contaminant screening criteria identified in Table 3. If the reporting limit is greater than the contaminant screening criteria for a constituent, the MDL and the associated test result will be used for comparison to the contaminant screening criteria (see section 3.5.2).

The contaminant limits identified in this QAPP are based on those in the San Francisco Bay RWQCB’s

Beneficial Reuse of Dredged Materials: Sediment Screening and Testing Guidelines (RWQCB 2000). RWQCB 2000 provides contaminant screening levels based on the RWQCB’s current understanding of the appropriate physical, chemical and biological quality requirements of re-use of dredge materials for various beneficial reuse placement options (RWQCB 2000). The RWQCB 2000 screening levels were used as the basis to accept or reject terrestrial soil for use in tidal wetland and upland habitats in the Quality Assurance Project Plan for Inner Bair

Island Fill Import and Placement (USFWS 2008b). The RWQCB 2000 contaminant screening criteria were adopted in this QAPP with the following two exceptions:

Screening criteria for total hydrocarbon components were not covered in RWQCB 2000.Therefore, screening criteria for total hydrocarbon components are based on the limits approved by the RWQCB in the QAPP for Inner Bair Island Fill Import and Placement (USFWS 2008b).

Screening criteria for VOCs are not covered in RWQCB 2000 or the QAPP for Inner Bair Island Fill

Import and Placement (USFWS 2008b). Therefore, screening criteria for VOC’s are based on RWQCB

2013 Environmental Screening Levels (RWQCB 2013). These screening levels were developed by the

RWQCB to help expedite the identification and evaluation of potential environmental concerns in soils

(and other media).

As was noted in Section 1.3, screening levels are modified periodically in response to ongoing data collection for ambient constituent levels in Bay Area sediments and updated guidance on toxicity and exposure routes for contaminants. As screening levels are modified, the screening levels in Sections 3.4.1 and 3.4.2 in this Master

QAPP are to be revised.

3.4.1 Wetland Surface Material

Wetland surface material is fill material chemically suitable to come in contact with wetland flora and fauna.

RWQCB has set limits to identify what level of contamination is permissible for wetland surface material

(RWQCB 2000) (Table 2). Because levee material may be reworked during future levee maintenance or wetland restoration, new imported fill placed on levees must be suitable for placement in wetlands. Wetland surface material will be placed on levees according to the conditions of the permits.

Table 2. Contaminant Screening Criteria for Wetland Surface Material

Constituent Screening Criterion

Metals (mg/kg, dry weight)

Arsenic 15.3a

Cadmium 0.33a

Chromium 112a

Copper 68.1a

Lead 43.2a

Mercury 0.43a

Nickel 112a

Selenium 0.64a

Silver 0.58a

Zinc 158a

Constituent Screening Criterion

Organochlorine pesticides/polychlorinated biphenyls

(µg/kg, dry weight)

DDTs, sum 7.0a

Chlordanes, sum 2.3a

Dieldrin 0.72a

Hexachlorocyclohexane, sum 0.78a

Hexachlorobenzene 0.485a

Polyclorinated biphenyls, sum 22.7a

Polycyclic Aromatic Hydrocarbons (µg/kg, dry weight)

Polycyclic Aromatic Hydrocarbons, total 3,390a

Total Hydrocarbon Components (mg/kg, dry weight)

Total Petroleum Hydrocarbons from Gasoline 100b

Total Petroleum Hydrocarbons from Jet Fuel, Kerosene, Diesel Fuel, or Motor Oil

200b

Volatile organic compounds (µg/kg, dry weight)

Acetone 8.6c

Benzene 27c

Bromodichloromethane 605c

Bromoform (Tribromomethane) 1,210c

Bromomethane 14c

Carbon tetrachloride 17c

Chlorobenzene 55c

Chloroethane 2.4c

Chloroform 247c

Chloromethane 385c

Dibromochloromethane 5,148c

1,2-dibromo-3-chloropropane 0.26c

1,2-Dibromoethane 393c

1,2-Dichlorobenzene 86c

1,3-Dichlorobenzene 398c

1,4-Dichlorobenzene 93c

1,1-Dichloroethane 15c

1,2-Dichloroethane 348c

1,1-Dichloroethene 15c cis-1,2-Dichloroethene 209c trans-1,2-Dichloroethene 310c

1,2-Dichloropropane 664c

1,3-Dichloropropene 11c

Constituent Screening Criterion

1,4-Dioxane 11,725c

Ethylbenzene 156c

Hexachlorobutadiene 270c

Hexachloroethane 2,400c

Methylene chloride 244c

Methyl ethyl ketone 630c

Methyl isobutyl ketone 228c tert-Butyl methyl ether 480c

Naphthalene 286c tert-Butyl alcohol 6,660c

1,1,1,2-Tetrachloroethane 873c

1,1,2,2-Tetrachloroethane 225c

Tetrachloroethene 186c

Toluene 237c

1,2,4-Trichlorobenzene 445c

1,1,1-Trichloroethane 68c

1,1,2-Trichloroethane 471c

Trichloroethene 598c

Vinyl chloride 145c

Xylenes 407c

Notes: mg/kg = milligrams per kilogram; RWQCB = Regional Water Quality Control Board; THC = Total Hydrocarbon

Components; µg/kg = micrograms per kilogram.

a Source for contaminant screening criteria is RWQCB’s Beneficial Reuse of Dredged Materials: Sediment Screening and

Testing Guidelines (RWQCB 2000) unless otherwise noted.

b THC levels in accordance with the Quality Assurance Project Plan for Inner Bair Island Fill Import and Placement (USFWS

2008b).

c Values from RWQCB December 2013 Estuary Aquatic Habitat Environmental Screening Levels (RWQCB 2013). The values were converted using the following equation:

Soil value = Surface water value x organic carbon coefficient x fraction of organic carbon (assumed 1%).

3.4.2 Wetland Foundation Material

Wetland foundation material is fill material that has a potential for biological effects if directly exposed to organisms, so it must be placed in a manner that will isolate it from biological receptors. The maximum depth of biological activity in wetlands is conservatively estimated at three feet, and thus surface material must be at least three feet thick when overlaying foundation material. Project proponents are encouraged to maximize surface material thickness. RWQCB has set limits to identify what level of contamination is permissible for wetland foundation material (RWQCB 2000) (Table 3). Due to a lack of biologically significant exposure routes for VOCs in foundation layer soils, this QAPP does not include screening levels for VOCs in wetland foundation material.

Table 3. Contaminant Screening Criteria for Wetland Foundation Material

Constituent Screening Criterion

Metals (mg/kg, dry weight)

Arsenic 70a

Cadmium 9.6a

Chromium 370a

Copper 270a

Lead 218a

Mercury 0.7a

Nickel 120a

Selenium 1.4b

Silver 3.7a

Zinc 410a

Constituent Screening Criterion

Organochlorine pesticides/polychlorinated biphenyls

(µg/kg, dry weight)

DDTs, sum 46.1a

Chlordanes, sum 4.8a

Dieldrin 4.3a

Hexachlorocyclohexane, sum 0.99a

Hexachlorobenzene 6c

Polyclorinated biphenyls, sum 180a

Polycyclic Aromatic Hydrocarbons (µg/kg, dry weight)

Polycyclic Aromatic Hydrocarbons, total 44,792a

Total Hydrocarbon Components (mg/kg, dry weight)

Total Petroleum Hydrocarbons from Gasoline 400d

Total Petroleum Hydrocarbons from Jet Fuel, Kerosene, Diesel Fuel, or Motor Oil

500d

Notes: mg/kg = milligrams per kilogram; RWQCB = Regional Water Quality Control Board; THC = Total Hydrocarbon

Components; µg/kg = micrograms per kilogram.

a Source for contaminant screening criteria is RWQCB’s Beneficial Reuse of Dredged Materials: Sediment Screening and Testing Guidelines (RWQCB 2000) unless otherwise noted.

bFoundation criteria for selenium taken from 2000 Order, based on Regional Water Board Sediment Screening Criteria and

Testing Requirements for Wetland Creation and Upland Beneficial Reuse, Interim Final, December 1992.

cApparent Effect Threshold(AET), Marine Sediment SquiRTs, Buchman MF (2008) NOAA Screening Quick Reference

Tables, NOAA OR&R Report 08-1. Office of Response and Restoration Division, National Oceanic and Atmospheric

Administration, Seattle, 34 pp d TPH Screening levels for soil. Values based on leaching Non-Drinking Water. from TPH Risk Evaluation at Petroleum Contaminated

Sites (2017), Hawai´i Department of Health Hazard Evaluation and Emergency Response Office Honolulu, Hawai´i 129 pp

3.5 Laboratory Analysis Methods

The following laboratory methods will be used during the Phase 2 Analysis. With approval from the quality assurance officer and the RWQCB, laboratories may use professional judgment to modify the protocols described below.

3.5.1 Chemical Constituents

Fill samples will be collected and analyzed for specific chemical compounds using the methodologies set forth in EPA’s Test Methods for Evaluating Solid Waste, Physical and Chemical Methods (EPA 1986). Analyses for metals will follow the EPA Methods 6000/7000 series, analyses for organochlorine pesticides will follow EPA Method

8081B, analyses for polychlorinated biphenyls will follow EPA Method 8082A, and analyses for polycyclic aromatic hydrocarbons will follow EPA Method 8270. If the Phase 1 Analysis determines there is potential

VOC contamination in the proposed import soils, laboratory analysis for VOCs will follow EPA Method

8260B. If the Phase 1 Analysis indicates there is no potential for VOC contamination, there will be no test for

VOCs. Analytical results for compounds will be reported in dry weight.

3.5.2 Method Detection Limits and Reporting Limits

MDL is the lowest concentration at which a particular compound can be measured and reported with a 99% confidence that the concentration is greater than zero. MDLs for each analyte will be determined by the analytical laboratory using the applicable Solid Waste (SW)-846 protocol (EPA 1986) or the method specified in Title 40 Code of Federal Regulations Part 136, Appendix B (GPO 2015). The laboratory will then develop reporting limits that represent concentration levels that can be consistently obtained by the specified method.

The reporting limits for data submitted by analytical laboratories will, to the extent feasible, be below the contaminant screening criteria identified in Table 2. In cases when it is not feasible to obtain a reporting limit for a constituent that is less than the screening criterion, the Water Board shall be contacted for approval to report down to the MDL. In these instances, the MDL should be below the screening criterion. The laboratory results based upon the MDL will then be compared to the screening criterion to determine the likelihood that a specific contaminant is present at a concentration greater than the screening criterion. Constituents expected to regularly require comparison to the MDL include: cadmium, mercury, selenium, silver, chlordane, dieldrin, hexachlorocyclohexane (sum), polychlorinated biphenyls (sum), and 1,2-dibromo-3-chloropropane (Appendix

A). The Water Board shall be provided with data for constituents that are reported at levels above the MDL, but below the reporting limit. Based on these data, the Water Board may either 1) reject the use of the proposed source of fill, based on data above the MDL; approve the use of the proposed source of fill; or request that the analysis be repeated using a different testing method and/or laboratory.

For example, the chlordane contaminant screening criterion at a potential wetland site located in the San

Francisco Bay Area is 0.009 mg/kg. The laboratory reporting limit for chlordane was 0.042 mg/kg. Since the reporting limit was greater than the screening criterion, the laboratory was requested to provide the MDL, which was 0.0031 mg/kg. The MDL was lower than the contaminant screening criterion for chlordane at the site.

Finding laboratories with the required MDLs is not anticipated to be an issue. However, if meeting the MDL is an issue for a particular contaminant at a particular site, the quality assurance officer will work with the laboratory to determine a course of action to attempt to reduce the MDL below the screening criterion (e.g., selecting an alternative analytical method that may achieve the screening levels, or collecting additional soil to be re-analyzed). In the case where the MDL remains above the screening criterion for a particular analyte after the additional laboratory analysis, and soil otherwise appears suitable for import, the quality assurance officer will defer to the RWQCB to determine whether the sample/soil source is approvable prior to fill import and placement.

3.5.3 Accuracy

Accuracy is the degree of closeness between laboratory contaminant concentration results and the actual contaminant concentrations in the samples. Accuracy will be assessed through the evaluation of the percent recoveries associated with laboratory control samples and matrix spikes and matrix spike duplicates

(MS/MSDs). Accuracy is generally expressed as percent recovery (%R), which is defined as:

where:

%𝑅 = 100% × s = measured spike sample concentration, C = sample concentration, and

T = true or actual concentration of the spike.

𝑠 − 𝐶

𝑇

Accuracy will be controlled by comparing percent recoveries to the acceptable control limits in the SW-846 tables (EPA 1986).

3.5.4 Precision

Precision is a measurement of the reproducibility of data under a specific set of conditions (e.g., variation in contaminant concentrations among laboratory replicates of a given sample). It is a quantitative measure used to assess the variability of a data set in reference to the calculated average value. Precision will be assessed by the evaluation of the day-to-day variances in the laboratory control samples. Precision will be evaluated for matrix effects using the MS/MSDs. Results of the duplicate analysis are used to calculate the relative percent difference (RPD) or relative standard deviation (RSD).

3.6 Quality Assurance during Fill Transport and Placement

The following measures will be implemented to ensure that only fill from approved borrow sites is used for

O&M, levee repair, levee construction, or permitted restoration actions, and to ensure that the fill is placed in conformance with permit requirements.

3.6.1 Agency Approval of Proposed Work

Project permits typically require that USFWS and Partners provide advanced notification before fill work is conducted. The advanced notification will identify the purpose of the fill, the fill volumes, whether or not the fill will be used for wetland surface or wetland foundation layers, and placement locations and depths.

3.6.2 From Borrow Site to Truck

The quality assurance officer will make unannounced visits to borrow sites to verify that approved material is being loaded. The quality assurance officer will visually spot-check the suitability of material loaded in trucks for the project using indicators, such as color, texture, and odor. If questionable or anomalous material is encountered, the quality assurance officer will halt transport of fill until suitability is confirmed. If a borrow site has segregated fill into material acceptable and unacceptable for project use, the quality assurance officer will conduct periodic site visits to the borrow site to confirm that acceptable material is loaded for transport to the project site. If a borrow site has segregated fill into material acceptable for use as wetland surface layer fill and material acceptable for wetland foundation layer fill, the quality assurance officer will conduct periodic site visits to the borrow site to confirm that wetland surface and wetland foundation material are loaded into separate trucks for transport to the project site. The quality assurance officer also will confirm that proper best management practices are being implemented at the site. For example, incoming trucks must be clean of soils and debris

(including seed from invasive plant species) from other sites, and loading equipment must be clean and in good working order.

Prior to leaving the borrow site, a soil acceptance form and a tag that is unique to that truckload of soil will provided to each truck. The soil acceptance form and tag must clearly identify if the fill placed in the truck is acceptable for use as wetland surface material or wetland foundation material.

3.6.3 From Truck to Project Site

The contractor will dispatch trucks carrying approved borrow fill to a designated project site. A truck dispatch log will be maintained by the contractor to keep track of which trucks left which approved borrow sites, whether the fill in each truck was approved for use as wetland surface or wetland foundation material, and each truck’s approved delivery destination within the Refuge. The truck dispatch log will be communicated in a timely way to the gate keeper daily so that only approved trucks are allowed into the site. The truck dispatch log will include the following information:

Name and contact information of trucking company and truck boss

Number of trucks and volume of fill approved for transport as wetland surface material

Number of trucks and volume of fill approved for transport as wetland foundation material

Borrow site origination name and address

Unique tag per load

Location in the Refuge where the imported fill will be used, including whether the fill will be used as wetland surface or wetland foundation material.

The entrance to the fill site will be monitored by the gate keeper on a full-time basis. When trucks arrive, the gate keeper will fill out a truck log with the identification tag number, the license plate number, and trucking company. It is the gate keeper’s responsibility to confirm that the truck and dispatch log data match before the truck is admitted. If any data from the dispatch log and the truck log do not match, then the truck will not be allowed to enter the site.

Soil acceptance forms and the unique identifier tag will be collected upon entry and logged by the gate keeper.

Trucks without a soil acceptance form and a unique identifier tag from an approved source will be rejected from entry to the fill site.

The gate keeper will keep a running total of the volume of fill for use in wetlands surface layers and the volume of fill for use in wetland foundation layers brought on site by borrow site. The gate keeper will ensure that the volume of fill allowed on site will not exceed the estimated quantity approved in the borrow site characterization memorandum. For the duration of fill import, the quality assurance officer will make random, unannounced visits to review the gate keeper’s work.

3.6.4 Fill Placement at Project Site

The quality assurance officer will monitor placement of fill material at the start of new work and then make random, unannounced visits throughout the duration of fill placement to determine whether the intent of this

QAPP is being met. If questionable or anomalous material is encountered, the quality assurance officer will halt placement of fill until suitability in accordance with this QAPP is confirmed.

Operational Roles and Responsibilities

The Contractor is responsible for ensuring that fill placement at the project site is in compliance with the project’s permits and specifications, including review and approval of testing data, agency reporting, required notifications, oversight of on-site stockpiling of fill material, and fill material placement during project construction.

The Contractor is responsible for:

Tracking the delivery of appropriately screened wetland surface and/or wetland foundation material to the project site

Storing surface and foundation material in separate and clearly identified stockpile locations

Ensuring that fill material is placed in approved locations at the project site

Ensuring that foundation material is placed below at least three feet of surface material

Ensuring that no mixing of foundation and surface soils occurs during the placement of fill material

Transmitting documentation of these activities to the Quality Assurance Officer and the Project

Management Team.

Fill Tracking Procedures

The Contractor shall prepare and maintain a sequencing and placement plan for each project site. The sequencing plan shall include the following information:

Borrow site project name

Volume of fill to be imported for wetland surface layer

Volume of fill to be imported for wetland foundation layer

Estimated schedule for start and end of fill delivery to the project site.

Stockpile locations at the project site for surface fill and stockpile locations for foundation fill

Procedures to prevent mingling of surface and foundation fill

Procedures to prevent fill in foundation layer stockpiles from being discharged to waters of the State during storage or placement of foundation layers

Destination within the project site for foundation fill from each borrow site

Destination within the project site for surface layer fill from each borrow site.

The Contractor shall maintain a written copy of the sequencing and placement plan for fill at the project site. A revised plan shall be posted at the project site whenever the sequencing plan is revised.

During periods of active fill transport and placement, the Contractor shall provide weekly notifications to the Project Management Team of any changes to the amount, type, and timing of incoming material at the project site

The Contractor shall submit daily logs of incoming material to Project Management Team staff. Logs must be submitted by email to USFWS staff (a cell phone photograph of the logs is acceptable) by 9:30 AM each morning, detailing the activity for the previous day. Daily logs shall include the following information:

Borrow site project name

Type of fill material (cover, foundation or both)

Truck type, number of trucks, and total loads

Destination for material within the project site for wetland surface fill and wetland foundation fill

Arrival time of first load of the day

Arrival time of final load of the day

Contact name and cell phone number for Contractor’s on-site representative

Any other observations related to ensuring appropriate fill stockpiling and placement.

Verification of Fill Tracking Procedures Whenever a project accepts both wetland surface layer and wetland foundation layer fill, the Gate Keeper shall verify that incoming soil has been placed in appropriate stockpiles and that any soil moved from stockpiles to final placement at the project site has been managed to maintain the segregation of wetland surface and wetland foundation soils. Each day that the Gate Keeper is on site, the Gate Keeper shall:

Verify that surface layer and foundation layer material are stored in separate and clearly identified stockpile locations;

Confirm that fill material is placed in approved stockpiles at the project site;

Confirm that foundation material is placed below at least three feet of surface material

Confirm that no mixing of foundation and surface soils occurred during the placement; of fill material;

and

Immediately contact the Quality Assurance Officer, the Project Management Team, and RWQCB staff overseeing the project if any failure to maintain the separation of wetland surface layer and wetland foundation layer fill is observed.

3.7 Reporting Requirements

The Refuge shall provide quarterly progress reports to the RWQCB during projects that require fill import and placement. Reports shall identify the location of the borrow site(s), the quantity of wetland surface fill material moved and placed during the prior quarter by borrow site, the quantity of wetland foundation fill material moved and placed during the prior quarter by borrow site, the balance of approved fill volume remaining by borrow site, and the approximate location of fill placed by borrow site. Borrow site characterization memoranda

(including sample plans, sample maps, Phase 1 reports, test data, and other associated reports related to fill acceptance) approving sources during the preceding quarter will be attached as appendices to quarterly reports.

Field notes, dispatch/truck logs, and reports form the Gate Keepers shall also be included as appendices. Copies of the reports and memoranda shall be provided to the RWQCB.

Section 4.0 References

[DTSC] California Department of Toxic Substance Control. 2001. Information Advisory: Clean Imported Fill

Material. October. Sacramento, California.

[EPA] U.S. Environmental Protection Agency. 1986. Test Methods for Evaluating Solid Waste, Physical and

Chemical Methods (SW-846). Third edition of SW-846 with Update I (pages dated September 1992), Update II (pages dated August 1993), Update IIA (pages dated September 1994), Update IIB (pages dated January 1995), Update III (pages dated December 1996), Update IIIa (pages dated April 1998), and Update IIIb (pages dated November 2004)

[EPA] U.S. Environmental Protection Agency. 2002. Guidance for Quality Assurance Project Plans. ESP

QA/G-5. Office of Environmental Information, Washington, D.C.

[GPO] U.S. Government Publishing Office. Code of Federal Regulations. Title 40: Protection of the

Environment, Part 136 – Guidelines Establishing Test Procedures for the Analysis of Pollutants.

Authority: Secs. 301, 304(h), 307 and 501(a), Pub. L. 95-217, 91 Stat. 1566, et seq. (33 U.S.C. 1251, et seq.) (Federal Water Pollution Control Act Amendments of 1972 as amended by the Clean Water Act of 1977). <http://www.gpo.gov/>. Accessed 9 June 2015.

[RWQCB] Regional Water Quality Control Board. 2000. Beneficial Reuse of Dredged Materials: Sediment

Screening and Testing Guidelines. Draft staff report. May.

[RWQCB] Regional Water Quality Control Board. 2013. Environmental Screening Levels. San Francisco Bay

Region. <http://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/esl.shtml>.

Accessed September 4, 2015.

[USFWS] U.S. Fish and Wildlife Service. 2008b. Quality Assurance Project Plan for Inner Bair Island Fill Import and Placement. Revised January 10, 2008.

http://www.gpo.gov/ http://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/esl.shtml

A-1

Appendix A.