Attachment 2 WVDEP CERCLA QAPrP Final October 2022-signed_09072022_BM.pdf

CONTROLLED DOCUMENT

WVDEP-OER-CERCLA--001

Revision Number: 1 Effective Date: October 11, 2022

Quality Assurance Program Plan for the

West Virginia Department of Environmental Protection

Division of Land Restoration

Office of Environmental Remediation

CERCLA (Superfund) Program

Prepared by:

601 57th Street SE

Charleston, WV 25304

October 2022

Revision Number: 1

This document has been designated a “CONTROLLED

DOCUMENT” by Ross Brittain, Quality Assurance Manager, WV

DEP OER. To ensure the current version, contact Ross via email at

Ross.A.Brittain@wv.gov . If an updated revision has been issued, instructions for obtaining the updated document will be provided.

Notification will be sent if the revision cited is not current. When printed, this documented becomes “UNCONTROLLED”.

Revision Number: 1

Quality Assurance Program Plan for the

West Virginia Department of Environmental Protection

Division of Land Restoration

CERCLA (Superfund) Program

Signature/Approval Page

Casey Korbini, Deputy Director

WVDEP DLR/OER

Date

Jason McDougal, Superfund Program Manager

8/19/2022

Ross Brittain, Quality Assurance Manager

USEPA Region 3 Project Officer Date

USEPA Region 3 Applied Science and Quality

Assurance Branch (ASQAB) Delegated

Approving Official (DAO)

Date

Digitally signed by: Ross Brittain, PhD DN: CN = Ross Brittain, PhD email = ross.a.brittain@wv.gov C = US O = WVDEP Office of Environmental Remediation OU = WVDEP-

DLR-OER

Date: 2022.08.19 08:51:15 -05'00'

Ross Brittain, PhD

Digitally signed by: Jason McDougal DN: CN = Jason McDougal email = jason.s.

mcdougal@wv.gov C = US O = DEP OU = OER Date: 2022.08.23 11:14:53 -04'00'

Jason McDougal

Casey E. Korbini Digitally signed by Casey E. Korbini DN: cn=Casey E. Korbini, o, ou, email=Casey.E.Korbini@wv.gov, c=US Date: 2022.08.24 08:39:33 -04'00'

BRANDON MILLER

Digitally signed by BRANDON

MILLER

Date: 2022.09.07 14:15:10 -04'00'

ANGEL ADAMES-CORRALIZA Digitally signed by ANGEL ADAMES-CORRALIZA Date: 2022.09.08 10:51:26 -04'00'

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Table of Contents

1.0 Introduction 12

1.1 Purpose of the QAPrP 12

1.2 The EPA Quality System, and ANSI/ASQC E4-2004 14

1.3 The Graded Approach and the EPA Quality System 14

1.4 Intended Audience 14

1.5 Period of Applicability 15

1.6 Points of Contact 15

1.6.1 Program Managers 15

1.6.2 Contract Manager 16

1.6.3 Quality Assurance Manager 16

1.6.4 Data Users 16

1.6.5 Contractors 16

1.6.6 Sub-Contractors 16

1.6.7 Data Analysis 17

1.6.8 Data Validation 17

1.6.9 Organizational Chart 18

1.7 Disclaimer 18

2.0 QAPrP Requirements 19

3.0 QAPrP Elements 19

3.1 Content Requirements 19

3.2 Program Management 21

3.2.1 Title and Approval Sheet 21

3.2.2 Table of Contents 21

3.2.3 Site Background 21

3.2.4 Problem Definition 21

3.2.4.1 Decisions 22

3.2.4.2 Actions 22

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3.2.4.3 Information 22

3.2.4.4 Action Levels 22

3.2.4.5 Decision Rule 24

3.2.5 Project Description and Schedule 25

3.2.6 Training 25

3.2.7 Quality Objectives and Criteria 26

3.2.7.1 Measurement Methods 26

3.2.7.2 PARCCS 28

3.2.8 Special Training Certification 34

3.2.8.1 OER Personnel and Contractors 34

3.2.8.2 Analytical Laboratory Personnel 34

3.2.9 Documentation and Records 35

3.2.9.1 Field Documentation 35

3.2.9.2 Chain-of-Custody 35

3.2.9.3 Laboratory Records 35

3.2.9.4 Project Records 35

3.2.9.5 QAPrP 35

3.3 Data Generation and Acquisition 36

3.3.1 Sample Design 36

3.3.2 Sampling Methods Requirements 38

3.3.2.1 Standard Operating Procedures (SOPs) 38

3.3.2.2 Sample Handling, Tracking, and Custody Requirements 41

3.3.2.3 Analytical Methods Requirements 43

3.3.3 Program-Defined Field Quality Control Requirements 43

3.3.3.1 Blanks 44

3.3.3.2 Duplicate Samples 45

3.3.4 Program-Defined Laboratory Quality Control Requirements 46

3.3.4.1 Detection Limits (DL) 46

3.3.4.2 Instrument Calibrations 47

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3.3.4.3 Laboratory Control Samples 48

3.3.4.4 Method Blank 48

3.3.4.5 Internal Standard 49

3.3.4.6 Surrogate Standard 49

3.3.4.7 Matrix Quality Control Samples 49

3.3.4.8 Technical Holding Times 49

3.3.4.9 Sample Preservation 50

3.3.5 Instrument/Equipment Testing, Inspection, and Maintenance Requirements 50

3.3.5.1 Field Equipment 50

3.3.5.2 Laboratory Equipment 50

3.3.6 Instrument Calibration and Frequency 50

3.3.7 Inspection/Acceptance Requirements for Supplies and Consumables 51

3.3.8 Data Acquisition Requirements for Non-Direct Measurements 51

3.3.9 Data Management 51

3.3.9.1 Paperwork Requirements 52

3.3.9.2 Analytical Requests 52

3.3.9.3 Sample Numbering 52

3.3.9.4 Sample Labeling and Tags 52

3.3.9.5 Sample Packaging and Shipping 53

3.3.9.6 Custody Seals 53

3.3.9.7 Chain-of-Custody 54

3.3.9.8 Field Logbook 54

3.3.10 Corrective Action 55

3.3.10.1 Paperwork Corrections 55

3.3.10.2 Memo-to-File (Letter to File) 55

3.3.10.3 Data Reduction 56

3.3.10.4 Analytical Data Deliverable Requirements 57

3.3.10.5 Data Validation Process 58

3.3.10.6 Data Management Procedures 59

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3.4 Assessment and Oversight 60

3.4.1 Assessment and Response Actions 60

3.4.1.1 WVDEP Technical Systems Audits 61

3.4.1.2 WVDEP Management System Reviews 61

3.4.1.3 Field Performance Audits 61

3.4.1.4 Laboratory Performance Audits 62

3.4.1.5 Field Corrective Action 62

3.4.1.6 Laboratory Corrective Action 62

3.4.2 Reports to Management 62

3.4.2.1 Reports to USEPA 63

3.4.2.2 Field Audit Reports 63

3.4.2.3 Laboratory Audit Reports 63

3.5 Data Review 64

3.5.1 Data Review 64

3.5.2 Data Verification and Validation Methods 64

3.5.3 Data Quality Assessment 65

3.5.4 Reconciliation with Data Quality Objectives 66

4.0 References 66

Figure 1. Department Organization Chart 69

Figure 2. Laboratory Chain of Custody Form 70

Table 1. Sample Containers, Preservation, Volumes, and Holding Times 71

Table 2. Container Types 74

Table 3. Preventative Maintenance – Field Equipment 75

Table 4. Calibration and Corrective Action for Field Equipment 76

Table 5. Field Quality Control Requirements 77

Table 6. Data Evaluation 78

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Distribution List

Secretary – WVDEP

Director – WVDEP/DLR

Deputy Director for Remediation Programs – WVDEP/DLR/OER

Superfund Program Manager – WVDEP/DLR/OER

Superfund Project Manager(s) – USEPA, Region 3

Quality Assurance Manager – WVDEP/DLR/OER

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Acronym List

ATSDR Agency for Toxic Substances and Disease Registry

BTAG Biological Technical Assistance Group

CCV Continuing Calibration Verification

CEL Certified Environmental Laboratory

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CLP Contract Laboratory Program

COC Chain of Custody

COC Contaminant of Concern

COPC Contaminant of Potential Concern

CSM Conceptual Site Model

DAS USEPA Delivery of Analytical Services

DL Detection Limit

DLR Division of Land Restoration, WVDEP

DOT Department of Transportation

DQI Data Quality Indicator

DQO Data Quality Objective

EPCRA Emergency Planning and Community Right-to-Know Act

ERT Emergency Response Team

ESAT Environmental Services Assistance Team

FASTAC Field and Analytical Services Teaming and Advisory Committee

FID Flame Ionization Detector

FOIA Freedom of Information Act

FOM Field Operations Manager

GIS Geographic Information System

GPS Global Positioning System

HASP Health and Safety Plan

HAZWOPER Hazardous Waste Operations and Emergency Response

HRS Hazard Ranking Score

IATA International Air Transport Association

ICP Inductively Coupled Plasma (spectroscopy)

ICV Initial Calibration Verification

IDL Instrument Detection Limit

IS Internal Standard

ITRC Interstate Technology and Regulatory Council

LTSB Laboratory and Technical Services Branch

LCS Laboratory Control Sample

LOQ Limit of Quantitation

LUST Leaking Underground Storage Tank

MB Method Blank

MCL Maximum Contaminant Level

MD Matrix Duplicate

MDL Method Detection Limit

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MS Matrix Spike

MSD Matrix Spike Duplicate

NPL National Priorities List

OER Office of Environmental Remediation, WVDEP

OSHA Occupational Safety and Health Administration

PA Preliminary Assessment

PARCCS Precisions, Accuracy, Representativeness, Completeness, Comparability, and

Sensitivity

PCB Polychlorinated Biphenyl

PID Photoionization Detector

PPE Personal Protective Equipment

PQL Practical Quantitation Limit

QAPrP Quality Assurance Program Plan

QA Quality Assurance

QAM Quality Assurance Manager

QAO Quality Assurance Officer

QAP Quality Assurance Plan

QC Quality Control

QMP Quality Management Plan

PFAS Per- and Polyfluoroalkyl Substances

PID Photoionization Detector

RAS Routine Analytical Services

RBC USEPA Region 3 Risk-based Concentration

RL Reporting Limit

RPD Relative Percent Difference

RSCC Regional Sample Coordination Center

RSD Relative Standard Deviation

RSL USEPA Regional Screening Level

SAP Sampling and Analysis Plan (aka SAWP)

SAR Site Assessment Report

SAWP Site Assessment Work Plan (aka SAP)

SEMS Superfund Enterprise Management System

SI Site Inspection (aka Site Investigation)

SMO Sample Management Office

SOP Standard Operating Procedure

SOW Statement of Work

SPLP Synthetic Precipitation Leaching Procedure

SQL Sample Quantitation Limit

SW846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, 3rd Edition

SVOC Semi-Volatile Organic Compound

TCLP Toxicity Characteristic Leaching Procedure

TR Traffic Report

TSA Technical Systems Audit

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UECA Uniform Environmental Covenants Act

USEPA United State Environmental Protection Agency

VISL Vapor Intrusion Screening Level

VOC Volatile Organic Compound

VRP Voluntary Remediation Program

WVDEP West Virginia Department of Environmental Protection

XRF X-Ray Fluorescence

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1.0 Introduction

1.1 Purpose of the QAPrP

United States Environmental Protection Agency (USEPA) CIO 2105.0 (formerly Order 5360.1

A2) and the applicable Federal regulations establish a mandatory Quality System that applies to all USEPA organizations and organizations funded by USEPA. Organizations, such as the West

Virginia Department of Environmental Protection (WVDEP), must ensure that data collected for the characterization of environmental processes and conditions are of the appropriate type and quality for the intended use and that environmental technologies are designed, constructed, and operated according to defined expectations.

This Quality Assurance Program Plan (QAPrP) is intended for use by the WVDEP Division of

Land Restoration (DLR), Office of Environmental Remediation (OER), Superfund Program.

One of the key responsibilities of the WVDEP Superfund Program is to perform various investigatory tasks at sites relative to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The sites include those working under a Pre-

Remedial Cooperative Agreement with USEPA Region 3. This QAPrP applies to the Pre-

Remedial Program [Preliminary Assessments (PAs) and Site Inspections (SIs), or other pre-remedial investigations], Removal Program, and other CERCLA site work and assessment investigations conducted in the State of West Virginia.

The QAPrP integrates all technical and quality aspects of a project, including planning, implementation, and assessment. The ultimate success of an environmental program or project depends on the quality of the environmental data collected and used in decision-making. This

QAPrP is intended as a generic description of procedures and practices that will be followed by

WVDEP personnel, contractors, and sub-contractors in conducting typical Pre-Remedial

CERCLA investigations.

Quality Assurance (QA) is a system of management activities that involves planning, implementation, assessment, reporting, and quality improvement. WVDEP-OER strives to ensure that the information collected for environmental projects (whether collected by our office or by contractors) will allow us to make informed, legally defensible decisions.

The purpose of the QAPrP is to serve as a guidance document describing how WVDEP-OER will identify the type and quality of the environmental data needed for site assessment.

WVDEP-OER will utilize the Data Quality Objectives (DQOs) Process to identify the type and quality of environmental data needed for sites requiring investigation. DQOs are qualitative and quantitative statements that allow the user to:

● Clarify the intended use of the data to be collected.

● Define the type of data needed to support the decision.

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● Identify the conditions under which the required data should be collected.

● Specify the acceptable limits on the probability of making a decision error based on uncertainty in the data.

The seven steps of the DQO process provide guidance on developing data quality criteria and performance specifications for decision making. They are used during the planning of projects to ensure that field activities, data collection operations, and the resulting data meet the project objectives. A summary of the DQO Process is provided below:

Step 1 – State the Problem –The project will be concisely summarized, with prior studies and existing information reviewed. Answer the question; What is the purpose of the project?

Step 2 – Identify the Decision – Determine the available options under consideration and identify the decision(s) that need to be made based on the environmental data collected.

Step 3 – Identify Inputs to the Decision – Identify the information that is needed to make informed, defensible decision(s).

Step 4 – Define the Boundaries of the Study – The time periods and geographical area of study will be identified, including when and where data will be collected. Also, budgetary constraints of the project will be identified.

Step 5 – Develop a Decision Rule – The specific screening levels and parameters of interest will be defined and integrated with the previous DQO outputs to describe a logical basis for choosing an appropriate action based on the results. Formulate “if...then” statements that relate the data to the decision to be supported.

Step 6 – Specify Limits on Decision Errors – An estimate of how much uncertainty in the data that is acceptable will be determined. The acceptable decision error rate will be based on the possible consequences of making an incorrect decision.

Step 7 – Optimize the Design for Obtaining Data – The information from the previous steps will be evaluated to generate alternative data collection designs to meet and satisfy the

DQOs in the most efficient and cost-effective manner while ensuring that the resulting data meets the project objectives.

Application of the seven step DQO process is a common-sense approach that translates broad consensus-based goals into specific tasks. In this way, the DQO process is used to prepare a road map, which can then guide the project, inform the public and other interested parties, and bring newcomers to the project up to speed quickly.

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1.2 The USEPA Quality System and ASQ/ANSI E4-2014

The USEPA Quality System, based on the American National Standard ASQ/ANSI E4-2014, Quality Management Systems for Environmental Information and Technology Programs—

Requirements with Guidance for Use, provides the framework for planning, implementing, assessing, and improving work performed and for quality assurance (QA) and quality control

(QC) activities. The USEPA Quality System includes Policy, Organization/Program, and Project components. This generic QAPrP is part of the Organization/Program component to inform the development of Project components that involve the generation, acquisition, and use of environmental data. The Project Life Cycle includes the three Project components of planning, implementation, and assessment, which lead to a specific product or decision.

In the case of pre-remedial CERCLA activities, once the USEPA has placed a site on the

Superfund Enterprise Management System (SEMS), a Preliminary Assessment (PA) of the site is conducted by WVDEP or USEPA in order to ascertain the potential impact that the site may have on the environment and the public's health. If this investigation determines that contaminants of concern (COCs) are either suspected or known to be present, a Site Investigation

(SI) with the appropriate sampling and monitoring will be initiated. The results of the SI will provide the analytical data necessary to properly assess the site. Sites which meet the criteria needed for ranking using the USEPA Hazard Ranking System (HRS) may be placed on the

National Priorities List (NPL) for further investigation and possible Federal Superfund remediation. Those sites which do not rank on the NPL or do not warrant USEPA Emergency

Assessment, but which the State feels warrant further assessment and possible cleanup, will be addressed under a State-led program such as the Brownfields Assistance Program, Voluntary

Remediation Program, or Leaking Underground Storage Tank (LUST) Program.

In accordance with this generic QAPrP, the State of West Virginia proposes sites for investigation. Once approval for the investigation is given by USEPA Region 3, the QAPrP is implemented, and a site-specific Sampling and Analysis Plan (SAP) is prepared. The SAP will include a site-specific quality assurance project plan (QAPP), site-specific field sampling plan

(FSP), and a site-specific health and safety plan (HASP).

1.3 The Graded Approach and the USEPA Quality System

This QAPrP contains general procedures and protocols which will be used to assure that suitable analytical results will be obtained during pre-remedial CERCLA activities in WV that will allow valid conclusions to be drawn from the results. WVDEP-OER is the organization responsible for this QAPrP, with USEPA oversight and approval. The QAPrP covers all areas of field sampling that are subject to review and interpretation as well as laboratory QA objectives and requirements.

1.4 Intended Audience

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The following list identifies the intended audience of the quality of the data generated under this program; it includes but is not limited to:

● WVDEP’s Superfund Program

● WVDEP’s Voluntary Remediation Program

● WVDEP’s Brownfields Assistance Program

● WVDEP’s Division of Water and Waste Management

● Environmental Consulting Industry

● United States Environmental Protection Agency

● Environmental Remediation Contractors

● Department of Defense

● State Legislature

● County Governments

● Municipal Governments

● Property Owners

● Potential Purchasers

● Potential Future Residents

● Potential Future Workers

● Lending Institutions

● Developers

● Surrounding Property Owners

● Surrounding Residents

1.5 Period of Applicability

This QAPrP is applicable for a period of five years from the effective date.

1.6 Points of Contact

1.6.1 Program Managers

The key decision makers of the WVDEP Superfund Program are the WVDEP Superfund

Program Manager and assigned USEPA Region 3 Project Manager. Their responsibilities include overall project coordination, selection and prioritization of sites, selection of laboratories, implementation of the QAPrP (whether program or site-specific), and final review/approval of all data and documents generated.

The WVDEP Superfund Program Manager’s responsibilities also include selection and management of contractors to perform tasks as assigned. The WVDEP Superfund

Program Manager is managed by the WVDEP-OER Deputy Director. The WVDEP-

OER Deputy Director is managed by the WVDEP-DLR Director.

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1.6.2 Procurement Section Manager

The WVDEP-DLR Procurement Section Manager has overall fiscal responsibility, including selection and payment of contractors, for the WVDEP Superfund Program. In the event WVDEP contract laboratories are utilized, the contract manager is responsible for their payment.

1.6.3 Quality Assurance Manager

The WVDEP-OER Quality Assurance Manager (QAM) has overall quality assurance and quality control (QA/QC) responsibility, including systems and performance auditing, for the WVDEP Superfund Program. This individual is independent of the data generators

(i.e., laboratories and contractors). All decisions regarding this QAPrP and related issues should be made by the WVDEP-OER QAM in consultation with the WVDEP Superfund

Program Manager and USEPA Region 3 Project Manager.

1.6.4 Data Users

The users of the data generated under this QAPrP are generally the contractors, the

WVDEP Superfund Program Manager, and the USEPA Region 3 Superfund Project

Manager (this is meant to represent any project manager within the CERCLA federal programs, including On-Scene Coordinators, Site Assessment Managers, and Remedial

Project Managers). For a listing of stakeholders that may also be interested in the data, please refer to Section 1.4 of this QAPrP. It should be noted that the different stakeholders may use the data for different purposes and some of the data may not be publicly available.

1.6.5 Contractors

The contractors (vendors registered with the State of West Virginia OASIS system) are selected by the WVDEP Superfund Program Manager, the WVDEP-DLR Procurement

Section Manager, and a representative of the WVDEP Purchasing Department. The contractors are selected based upon evaluation criteria that include their qualifications.

After the selection of a contractor, costs are negotiated. The contractors are responsible for the generation of a site-specific SAP for each site. The contractors are also responsible for the selection and assignment of a Field Operations Manager (FOM), performance and quality control of sampling operations, sampling quality control, data processing, documentation, and report generation as it applies to the specific tasks assigned.

1.6.6 Subcontractors

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The contractors are responsible for the selection of subcontractors. However, a subcontractor cannot be used without the approval of the WVDEP Superfund Program

Manager. Subcontractors are required to follow the guidelines of the QAPrP. It is the responsibility of the primary contractor to ensure that potential subcontractors are familiar with the QAPrP and provide oversight of the subcontractor.

1.6.7 Data Analysis

The WVDEP Superfund Program uses USEPA’s Contract Laboratory Program (CLP) services or WVDEP Certified Environmental Laboratories (CEL), through WVDEP’s

Laboratory Quality Assurance Program and Quality Management Plan (QMP). For pre-remedial projects, USEPA and WVDEP officials determine the laboratories utilized for their respective projects. The selection of laboratories will be determined by the site-specific SAP based on factors such as location of site, scope of analytical request, laboratory certification, laboratory capacity, turn-around time requirements, analytical costs, etc. Utilization of the assigned analytical services will conform with directions published in Sample Submission Procedures for the Laboratory and Technical Services

Branch (LTSB) Laboratory Section, Revision 15, August 22, 2019. This process allows the USEPA Region 3 laboratory and analytical services coordinators to assign laboratories into the appropriate Field and Analytical Services Technical Advisory

Committee (FASTAC) Strategy by establishing a centralized analytical services brokerage team. There are four tiers considered when assigning analytical services using this brokerage. The four tiers are as follows:

Tier 1: USEPA Regional Laboratory

Tier 2: Contract Laboratory Program

Tier 3: Delivery of Analytical Service through Commercial Laboratories

Tier 4: Field Contractor Subcontracting for Analytical Services

Note that personnel of the USEPA Region 3 Regional Sample Coordination Center

(RSCC) and Sample Management Office (SMO) perform Quality Assurance Officer

(QAO) functions for CLP services.

When USEPA CLP laboratories are utilized, the laboratory selection and analysis will be managed by the USEPA Region 3 client services team. The environmental samples will be analyzed and reported via the USEPA Routine Analytical Services (RAS) CLP or the

USEPA Delivery of Analytical Services (DAS) commercial lab procurement program as applicable. When WVDEP CELs are utilized, the laboratory selection, analysis, and data processing will be managed by the WVDEP-OER Project Manager and contractor.

1.6.8 Data Validation

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Data validation under the WVDEP Superfund Program will be performed by either an

Environmental Services Assistance Team (ESAT) contractor to the USEPA Region 3

(FASTAC Tiers 1, 2, and 3) or contractors to the WVDEP (Tier 4). The contractor performing the data validation will be responsible for the data quality review. The selection of the organization to perform the data validation will be determined by the site-specific SAP and/or QAPrP based on factors such as scope of validation request, turn-around time requirements, validation costs, etc. The organization performing the data validation will be independent of the analytical laboratory(ies) that generated the data.

If CLP services are utilized, they will include external party data validation and QA/QC procedures that will be adhered to throughout the project. Once all analyses of samples have been completed, the data validator (an individual independent of the data generation group) will initiate a quality assurance review of the results. The QAO will perform data review, assign codes to the data, and determine its usability as per the USEPA Guidance for Labeling Externally Validated Laboratory Analytical Data for Superfund Use, January 2009; USEPA Contract Laboratory Program Statement of Work for Superfund

Analytical Methods (Multi-Media, Multi-Concentration) (SFAM01.1), November 2020 and USEPA Contract Laboratory Program Statement of Work for High Resolution

Superfund Methods (Multi-Media, Multi-Concentration) (HRSM02.1), November 2020, or most current procedures.

The data validator will submit the results and a Quality Assurance Report to the USEPA

Region 3 Project Manager as well as the WVDEP Superfund Program Manager. The report will include data review and data processing quality control. The QAO will perform an in-house audit. In addition, the laboratory will participate in the quarterly

Performance Evaluations (blind samples) conducted by the USEPA.

1.6.9 Organizational Chart

The organizational chart provided in Figure 1, WVDEP Superfund Program

Organizational Chart, depicts lines of authority and reporting responsibilities, including the USEPA and contractors.

Certain individuals may be responsible for more than one of the aforementioned project functions. The organizational chart provides sufficient evidence that the lines of authority for all referenced organizations (including contractors and subcontractors) are appropriate to accomplish the quality assurance objectives of the WVDEP Superfund

Program.

1.7 Disclaimer

Mention of trade names or commercial products in this document does not constitute endorsement or recommendation for use.

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2.0 QAPrP Requirements

It is the policy of WVDEP to collect the minimum number of samples necessary to adequately assess any potential pathways of exposure to any site-related receptors. At a minimum, the

Impacted Media (i.e., surface and/or subsurface soils) need to be thoroughly assessed and then any potential Exposure Media (e.g., groundwater, surface water, sediment, vapor intrusion, fish consumption) will also need to be characterized as needed. The purpose of these samples is to ensure that the risks for all receptors can be assessed for every potentially complete pathway of exposure, as applicable to sites within the Federal Programs of WVDEP-OER. The SAPs, Site

Assessment Work Plans (SAWP), or functionally equivalent plans required by specific federal programs (hereafter, all are referred to as SAP) for any Superfund Program site within WVDEP-

OER will need to comply with this QAPrP.

At the program level, this policy will be fulfilled by having the WVDEP-OER QAM oversee updating the QAPrP every five years. No later than 48 months after the effective date, the

WVDEP-OER QAM will begin a review of the QAPrP to ensure that all policies, content, and

Standard Operating Procedures (SOPs) of the QAPrP are updated to comply with the latest information from the USEPA and relevant organizations, such as the Interstate Technology and

Regulatory Council (ITRC). A draft of any updates to the QAPrP should be presented by the

WVDEP-OER QAM to the WVDEP Superfund Program Manager for WVDEP internal review.

A WVDEP internally approved draft should be prepared and submitted to the USEPA for review. The final version of an updated QAPrP should be approved by both WVDEP and

USEPA no later than 60 months after the current effective date. The updated and approved

QAPrP will replace the old QAPrP upon its effective date.

3.0 QAPrP Elements

3.1 Content Requirements

The primary documents expected to be produced during any Superfund project as part of this

QAPrP are the SAP and SAR.

The SAP will include the following sections (as applicable to federal programs):

● Introduction

● Site Description and Background

● Problem Definition

● Project Organization and Distribution List

● Personnel Qualifications

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● Conceptual Site Model

● Project/Data Quality Objectives

● Measurement Performance Criteria

● Project Tasks and Schedule

● Project Action Limits and Laboratory-Specific Detection/Quantitation Limits

● Sampling Design and Rationale

● Sampling Location and Methods

● Sample Containers, Preservation, and Hold Times

● Field QC Sample Summary

● Field SOPs

● Field Equipment Calibration, Maintenance, Testing, and Inspection

● Analytical SOP References

● Analytical Instrument Calibration

● Analytical Instrument Equipment Maintenance, Testing, and Inspection

● Sample Handling, Custody, and Disposal

● Analytical Quality Control and Corrective Action

● Data Validation Procedures

● Figure showing Project Location Map

● Figures showing proposed sample locations for Soil, Groundwater, Surface Water, Vapor, and Sediment as needed

The SAR will include the following sections:

● Introduction

● Site Description and History

● Current Site Investigation Description

● Field Descriptions

● Deviations from the Approved SAP

● Field Data

● Bore/Well Logs

● Certifications of Subcontractors

● Shipping Documentation

● Photo Documentation

● Analytical Summary Tables of sample results compared to appropriate action levels

● Laboratory Analytical Reports and Validation Reports

● Copies of Right of Entry Forms

● Copies of Field Notes

● Environmental Setting

● Conceptual Site Model

● Figures showing sampling locations of Soil, Groundwater, Surface Water, Sediment, and

Vapor

● Figures showing samples locations results

● Tables showing results of sample analyses

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● Tables showing results of screening analyses to determine the Contaminants of Concern

● Groundwater, Surface Water, Soil Exposure, and Air Pathways Discussions

● Summary and Recommendations

3.2 Program Management

3.2.1 Title and Approval Sheet

Each document submitted under the QAPrP (i.e., SAP and SAR) must have a Title Page that should at least include a title, site name, site location, contract number (as applicable), project number (as applicable), and date. After the Title Page should be an

Approval Page signed and dated by the principal authors and responsible personnel.

3.2.2 Table of Contents

The Table of Contents should include a list of all sections and subsections of the document, followed by a list of figures, tables, and appendices. Preferably, the Table of

Contents sections would be linked directly to the relevant section to improve the reader’s ability to find the information they require.

3.2.3 Site Background

Site background information will be provided in the site-specific SAP to be reviewed and approved by the WVDEP-OER Project Manager and the USEPA Region 3 Project

Manager. Site background information should include as applicable:

● A list of the known and suspected contaminants in each medium and estimates of their concentration, variability, distribution, and location.

● The site’s physical and chemical characteristics that influence migration and associated human, environmental, and physical targets.

● A conceptual site model and exposure pathways.

● A summary of the outcome and status of any previous response(s) at the site, such as early actions or previous data collection activities.

● Site maps (historical and present).

3.2.4 Problem Definition

USEPA Region 3, in coordination with and supported by WVDEP-OER, will determine whether site investigation activities are warranted to assess potential risk associated with a site and whether the site should undergo further investigation or action under CERCLA.

These site investigation activities can include removal site evaluations, pre-remedial site investigations, or other CERCLA program investigations. Other state level investigations or emergency actions/investigations will be at the discretion of WVDEP.

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3.2.4.1 Decisions

Decisions that will be made based upon the outcome of the investigations may be:

● No further action

● Emergency action

● Referral to another federal or state agency

● Referral to consider a voluntary cleanup program (i.e., Brownfields Assistance

Program or Voluntary Remediation Program)

● Recommendation for listing on the NPL

3.2.4.2 Actions

If a recommendation is made that remediation or removal of contamination is warranted at the site, the following actions will be taken:

Non-Emergency Action

● The WVDEP Superfund Program Manager will notify the WVDEP-OER Deputy

Director of the site conditions and recommendations. It will be the responsibility of the WVDEP-OER Deputy Director to ensure appropriate action is taken.

● It will be the responsibility of the USEPA Region 3 Project Manager to ensure appropriate action is taken within the USEPA.

Emergency Action

● The WVDEP Superfund Program Manager will notify the WVDEP-OER Deputy

Director of the site conditions and recommendation for emergency action. It will be the responsibility of the WVDEP-OER Deputy Director to notify the USEPA

Office of Land and Emergency Management (OLEM) for emergency action.

● Once notified, it will be the responsibility of the USEPA OLEM to take the appropriate emergency action.

3.2.4.3 Information

The types of informational inputs needed for decision making, if applicable, are field data, laboratory analytical results, field screening results, natural background concentrations (site-specific or published), data validation results, database searches identifying exposure pathways and targets, risk-based action limits, and HRS scoring.

3.2.4.4 Action Levels

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In order to determine if there is potential risk to human health and/or the environment at the site, contaminants known to be present or contaminants potentially present based upon the historical use of the property will be assessed. A listing of contaminants that could potentially be investigated in the Superfund Program is provided in USEPA’s List of Lists: Consolidated List of Chemicals Subject to the

Emergency Planning and Community Right to Know Act (EPCRA), Comprehensive

Environmental Response, Compensation and Liability Act (CERCLA), and Section

112(r) of the Clean Air Act (2019). Contaminant concentrations will be compared to the Regional Screening Levels (RSL). The RSL tables provide comparison values for residential and commercial/industrial exposures to soil, air, and tap water (drinking water). The unified use of the RSLs to screen chemicals at Superfund sites promotes national consistency and is now the source of screening levels for all the USEPA regions.

Current RSLs can be found at https://www.epa.gov/risk/regional-screening-levels-rsls. Here you will find tables of risk-based screening levels, calculated using the latest toxicity values, default exposure assumptions, and physical and chemical properties, and a calculator where default parameters can be changed to reflect site-specific risks.

Additionally, ecological exposures should be screened using the USEPA Region 3

Biological Technical Advisory Group (BTAG) screening values found at https://www.epa.gov/risk/biological-technical-assistance-group-btag-screening-values. If a chemical of concern at a site is not listed in the BTAG list of screening values, or a potential receptor/pathway is not listed in BTAG, then the USEPA

Region 4 Ecological Risk Assessment Supplemental Guidance screening values should be used (https://www.epa.gov/risk/regional-ecological-risk-assessment-era-supplemental-guidance). The potential for vapor intrusion can also be screened using the benchmarks available in the USEPA Vapor Intrusion Screening Levels (VISLs) website at (https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator).

In the absence of a federal standard, the following state action levels will be used:

● Soil – Current WV De Minimis Standards for residential soil and industrial soil are located in the Voluntary Remediation and Redevelopment De Minimis

Standards Rule (W. Va. Interpretive Rule 60CSR9). The WV De Minimis

Standards can be found at https://dep.wv.gov/dlr/oer/technicalguidanceandtemplates/Pages/default.aspx.

● Potable Water - Current USEPA safe drinking water standards, or maximum contaminant levels (MCLs), can be found at https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations.

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● Groundwater - Current WV De Minimis Standards for groundwater are located in the Voluntary Remediation and Redevelopment De Minimis Standards Rule

(W. Va. Interpretive Rule 60CSR9) or in the Requirements Governing

Groundwater Standards Rule (W. Va. Legislative Rule 47CSR12), whichever is more stringent. The WV De Minimis Standards for groundwater can be found at https://casetext.com/regulation/west-virginia-administrative-code/agency-60-environmental-protection-secretarys-office/title-60-interpretive-rule-department-of-environmental-protection-secretarys-office/series-60-09-voluntary-remediation-and-redevelopment-de-minimis-standards. Requirements Governing

Groundwater Standards (W. Va. Legislative Rule 47CSR12) can be found at http://apps.sos.wv.gov/adlaw/csr/ruleview.aspx?document=8233.

● Surface Water – Current surface water standards are located in Requirements

Governing Water Quality Standards (W. Va. Legislative Rule 47CSR2), category

A (public water supply), category B (aquatic life), or category C (water contact recreation) criteria, whichever is most stringent. Requirements Governing

Ground Water Quality Standards (W. Va. Legislative Rule 47CSR2) can be found at http://apps.sos.wv.gov/adlaw/csr/readfile.aspx?DocId=27572&Format=PDF.

● Sediment – Human health sediment exposures are screened using the WV De

Minimis Standards for residential soil and industrial soil in the Voluntary

Remediation and Redevelopment De Minimis Standards Rule (W. Va.

Interpretive Rule 60CSR9) located at https://casetext.com/regulation/west-virginia-administrative-code/agency-60-environmental-protection-secretarys-office/title-60-interpretive-rule-department-of-environmental-protection-secretarys-office/series-60-09-voluntary-remediation-and-redevelopment-de-minimis-standards. Ecological sediment exposures are screened using the

USEPA Region 3 Biological Technical Advisory Group (BTAG) screening values or the USEPA Region 4 Ecological Risk Assessment Supplemental Guidance screening values when BTAG values are not available.

All of the relevant benchmark screening levels, including RSL, VISL, BTAG, USEPA Region 4 Ecological Risk Assessment Supplemental Guidance, WV

Water Quality Standards, and WV De Minimis Standards, are available on the

WVDEP-OER Technical Guidance and Templates webpage.

(https://dep.wv.gov/dlr/oer/technicalguidanceandtemplates/Pages/default.aspx) in an Excel spreadsheet labeled, “De Minimis and Relevant Benchmarks.”

3.2.4.5 Decision Rule

If any contaminant is greater than its applicable action level, it is to be considered a contaminant of concern (COC). All COCs require some type of action. The type of action will be determined by the concentration of the contaminant, the source of the contamination, the media impacted, the exposure pathway, and the receptors to the

Revision Number: 1 contaminants. The decision as to what course of action should be taken is the responsibility of the WVDEP Superfund Program Manager and the USEPA Region 3

Project Manager.

For pre-remedial projects, contaminants that meet observed release and/or observed contamination criteria will be included in a site evaluation using the HRS scoring system. If the site HRS score is 28.50 or greater, then USEPA, with the concurrence of the WVDEP Superfund Program Manager and WVDEP-OER Deputy Director, will complete an HRS scoring package with the goal of listing the site on the NPL.

Note that site-specific circumstances may warrant a qualification of the scoring, and therefore the impact recommended course of action. Regardless, the decision as to what course of action should be taken is ultimately the responsibility of USEPA

Region 3 Project Manager, as supported by WVDEP-OER.

3.2.5 Project Description and Schedule

Project description and schedule information will be provided in the site-specific SAP to be reviewed and approved by the WVDEP Superfund Project Manager, the USEPA

Region 3 Superfund Project Manager, and a USEPA Region 3 Applied Science & Quality

Assurance Branch Delegated Approving Official. Project description and schedule information should include as applicable:

● A description of the work to be performed; providing sufficient information as to the project’s goals and types of activities to be conducted.

● Special personnel and equipment requirements that may indicate the complexity of the project (particularly for any new or innovative sampling or analytical technique being employed).

● Project schedule timeline (graphical or tabular format), including start and completion dates for all project activities (including quality assurance assessments).

● A procedure for notification of project participants concerning schedule delays

(identify job function, organization name, personnel responsible for providing and receiving such notification, and personnel responsible for approving schedule changes).

● Discussion of resource and time constraints, such as seasonal sampling restrictions and considerations (if applicable).

3.2.6 Training

The WVDEP-OER Deputy Director is responsible for ensuring that each WVDEP-OER staff member has received the necessary training and certifications required for site assessment. Program managers and/or project managers should have a working knowledge of the DQO process and the USEPA QAPrP requirements. Training will be coordinated by the WVDEP Superfund Program Manager. WVDEP-OER staff are

Revision Number: 1 required to complete 40-hour Hazardous Waste Operations and Emergency Response

(HAZWOPER) training from OSHA and be up to date on subsequent annual 8-hour refresher courses. WVDEP-OER staff members are also encouraged to take advantage of relevant CERCLA training courses available at the CERCLA Education Center

(www.trainex.org) and numerous training opportunities from ITRC, USEPA, and the

Agency for Toxic Substances and Disease Registry (ATSDR). Similarly, the data validators should have completed at least one USEPA-approved training course on data validation, in addition to the required degrees in higher education. Laboratory personnel shall complete all training required by their respective employers to comply with the

USEPA Contract Laboratory Program.

3.2.7 Quality Objectives and Criteria for Measurement Data

When conducting a CERCLA site assessment, all measurements will be made so that results are reflective of the medium and conditions being measured. Data collected will be used to:

● Ascertain if there is a threat to public health or the environment;

● Locate and identify potential sources of contamination;

● For pre-remedial sites, determine if contamination establishes observed release and/or observed contamination criteria, and/or the potential to release hazardous substances into the environment; and

● Ascertain if contamination present equals or exceeds USEPA Region 3 SLs, Safe

Drinking Water Act MCLs, or other applicable or relevant and appropriate standards

(e.g., WV De Minimis Standards).

Prior to all environmental measurement activities, site-specific DQOs and measurement performance criteria will be determined. DQOs are qualitative and quantitative statements that specify the quality of the environmental monitoring data required in order to support decisions. DQOs are established in accordance with the anticipated end uses of the data that are to be collected. DQOs are applicable to phases and aspects of the data collection process including site investigation, design, construction, and remedy operations.

3.2.7.1 Measurement Methods

The purpose of performing a CERCLA assessment is to determine the presence and identity of contaminants along with the extent to which they have become integrated into the surrounding environment. The objective of this effort is to collect and analyze a sample that is representative of the media under investigation. The measurement methods used for analyzing the media vary with the associated physical properties and contaminants for which the media is to be analyzed. Due to the nature

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Project specific action limits, project required quantitation limits, and laboratory detection limits will be outlined in a site-specific SAP.

To ensure that uniform and acceptable measurement methods are being used, the following measurement methods will be required based upon the type of laboratory used:

USEPA Contract Laboratory Program (CLP)

If USEPA contract laboratories are to be utilized, the laboratory selection and analysis will be managed by the USEPA Region 3 client services team. The environmental samples will be analyzed and reported via RAS under FASTAC Tier 2 or DAS commercial lab procurement program under FASTAC Tier 3 as applicable.

If USEPA RAS CLP is to be utilized, measurement methods will follow the guidelines found in the USEPA Superfund Analytical Methods (Multi-Media, Multi-

Concentration) Statement of Work (SFAM01.1) and the USEPA High Resolution

Superfund Methods Statement of Work (HRSM02.1), as applicable. Note: Matrix

Spike (MS) and Matrix Spike Duplicates (MSD) are no longer applicable to Volatile

Organic Compounds (VOCs) and Semi-Volatile Organic Compounds (SVOCs) analyses if SFAM01.1 SOW is used.

If non-routine, DAS is needed, commercial lab procurement will be managed by the

USEPA Region 3 client services team. DAS measurement methods will follow the guidelines found in the Test Methods for Evaluating Solid Waste, Physical/Chemical

Methods, SW-846, 3rd Edition (SW-846) as applicable. Selection of the SW-846 method to be used will be provided in the site-specific SAP. Assistance with analytical method selection can be provided by contacting the USEPA Region 3

Quality Assurance Team at https://www.epa.gov/hw-sw846. Note: MS/MSDs remain applicable to VOC and SVOC analyses if SW-846 is used.

If the analysis method measurement is not provided in SW-846, the selected laboratory QAPrP and SOPs will be utilized.

West Virginia State Contract Laboratory

If a CEL under contract to the WVDEP is to be utilized, measurement methods will follow the guidelines found in the Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, 3rd Edition (SW-846) as applicable. Selection of the SW-846 method to be used will be provided in the site-specific SAP.

If the analysis method measurement is not provided in SW-846, the selected laboratory QAPrP and SOPs will be utilized.

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Field Screening

If the measurements are to be obtained in the field utilizing field screening technologies such as X-Ray Fluorescence (XRF), immunoassay test kits, photoionization detector (PID), flame ionization detector (FID), etc., a minimum of

10 % of the media must be submitted to an analytical laboratory for confirmation.

The criteria for selecting which field results are confirmed are (1) select samples whose results are closest to the action level and (2) select at least one non detect sample result per day.

3.2.7.2 PARCCS

It is important to note that the level of detail and data quality needed will vary with the intended use of the data. DQOs are typically assessed by evaluating precision, accuracy, representativeness, completeness, and comparability (PARCCS) of all aspects of the data collection process. The PARCCS parameters are Data Quality

Indicators (DQI) or Data Quality Measures. PARCCS is defined as:

Precision

Precision is a measure of the reproducibility of analyses under a given set of conditions. Precision examines the spread of data about their mean. The spread presents how different the individual reported values are from the average reported values. Precision is thus a measure of the magnitude of errors and will be expressed as the relative percent difference (RPD) or the relative standard deviation (RSD). The lower these values are, the more precise that data. Field measures of precision are typically field duplicates, matrix spike/matrix spike duplicates, matrix duplicates, and using the appropriate sampling procedure. Conversely, laboratory measure of precision includes laboratory control sample/laboratory control sample duplicate, matrix spike duplicate, and historical data trends. The applicable RPD and RSD quantities are defined as follows:

RPD (%) = 100 x (S - D)

(S + D)/2

OR

RPD (%) = 100 x 2 (S – D)

(S + D) where S = Analyte or compound concentration in a sample

D = Analyte or compound concentration in a duplicate sample

Or when there are more than two measurements:

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RSD (%) = 100 (s)

X

Where s = Standard deviation of replicate measurements x = Mean of replicate measurements

The duplicate samples utilized to evaluate precision include laboratory matrix duplicate (MD), matrix spike (MS), matrix spike duplicate (MSD), and field duplicates samples. The goal is to maintain a level of analytical and sampling precision consistent with the objectives of the sampling event. To maximize precision, consistent sampling and analytical procedures are to be followed as presented in the QAPrP. Unless provided in a site-specific SAP, the control limit for field duplicate sample analyses depends on the media being sampled.