File 3 2022 SAP GM38 DEC2022.pdf

N90845_003843

NWIRP BETHPAGE, NY

SSIC 5000-33b

FINAL SAMPLING AND ANALYSIS PLAN, OPERATIONS, MAINTENANCE AND

MONITORING OF THE GROUNDWATER TREATMENT PLANT GM 38 AREA

NWIRP BETHPAGE NY

12/01/2022

KOMAN GOVERNMENT SOLUTIONS LLC

Approved for public release: distribution unlimited.

NIRIS Cover sheet rev. 5, Aug 2020

SAMPLING AND ANALYSIS PLAN

Operations, Maintenance, and Monitoring of the Groundwater Treatment Plant

GM-38 Area, Naval Weapons Industrial Reserve Plant Bethpage, NY

Contract No. N40085-16-D-2288 Contract Task Order No. 0005

December 2022

Prepared for

Naval Facilities Engineering Systems Command Mid Atlantic

9324 Virginia Avenue Norfolk, VA 23511-3095

Prepared by

KOMAN Government Solutions, LLC 180 Gordon Drive, Suite 110

Exton, PA 19341

Tier II Sampling and Analysis Plan Site Name/Project Name: NWIRP Bethpage GM-38 GWTP Site Location: Bethpage, NY

Contract No N40085-16-D-2288 – 1 –

Contract Task Order No. 0005

27 Dec 2022

Review Signatures: Patrick Schauble KGS Program Manager/QAM

Date

Robert Gregory KGS Project Manager

Laurie Ekes KGS Project Chemist

KOMAN Government Solutions, LLC

January 2023

Title and Approval Page (UFP-QAPP Manual Section 2.1 – Worksheet #1)

TIER II SAMPLING AND ANALYSIS PLAN

Operations, Maintenance, and Monitoring of the Groundwater Treatment Plant

GM-28 Area, Naval Weapons Industrial Reserve Pla Bethpage, New York

December 2022

Prepared for:

Department of the Navy

Naval Facilities Engineering Systems Command Mid-Atlantic 9324 Virginia Ave Norfolk, VA 23511-3095

Prepared by:

KOMAN Government Solutions, LLC

180 Gordon Drive Suite 110 Exton, PA 19341 610-363-0601

Prepared under:

Contract Number N40085-16-D-2288

Task Order 0005

Title: Operation, Maintenance, and Monitoring Plan SAP Revision Number: 1

Revision Date: December 2022

Tier�II�Sampling�and�Analysis�Plan� Title:�Operation,�Maintenance,�and�Monitoring�Plan�SAP� Site�Name/Project�Name:�NWIRP�Bethpage�GM-38�GWTP�� Revision�Number:�1� Site�Location:�Bethpage,�NY� Revision�Date:�DecemberOctober�2022�

Contract�No�N40085-16-D-2288� –�1�–� KOMAN�Government�Solutions,�LLC�

Contract�Task�Order�No.�0005� � October�December�2022�

Title�and�Approval�Page� � (UFP-QAPP�Manual�Section�2.1�–�Worksheet�#1)�

TIER�II�SAMPLING�AND�ANALYSIS�PLAN��

Operations,�Maintenance,�and�Monitoring�of�the��

Groundwater�Treatment�Plant� GM-28�Area,�Naval�Weapons�Industrial�Reserve�Plant�

Bethpage,�New�York�

October�December�2022�

Prepared�for:� Department�of�the�Navy��

Naval�Facilities�Engineering�Systems�Command� Mid-Atlantic�

9324�Virginia�Ave� Norfolk,�VA�23511-3095�

Prepared� by:�

KOMAN�Government�Solutions,�LLC� 180�Gordon�Drive�Suite�110�

Exton,�PA�19341� 610-363-0601�

Prepared�under:�

Contract�Number�N40085-16-D-2288� Task�Order�0005�

Review�Signatures:� Patrick�Schauble� KGS�Program�Manager/QAM�

Date�

Robert�Gregory� KGS�Project�Manager�

Date�

Laurie�Ekes� KGS�Project�Chemist��

���Date�

Approval�Signatures:� Kenneth�Bowers� NAVFAC�QAO/Chemist� NAVFAC�Mid-Atlantic�

Date�

SOLOMON.JUDITH.A.146188

Digitally signed by

SOLOMON.JUDITH.A.1461885000

Date: 2023.01.04 08:50:44 -05'00'

Tier II Sampling and Analysis Plan Title: Operation, Maintenance, and Monitoring Plan SAP Site Name/Project Name: NWIRP Bethpage GM-38 GWTP Revision Number: 1 Site Location: Bethpage, NY Revision Date: December 2022

Contract No N40085-16-D-2288 – 2 – KOMAN Government Solutions, LLC

Contract Task Order No. 0005 December 2022

EXECUTIVE SUMMARY

This Tier II Uniform Federal Policy (UFP) Sampling and Analysis Plan (SAP) describes sampling and monitoring activities which are performed as part of the Operation, Maintenance, and Monitoring (OM&M) activities associated with the Groundwater Treatment Plant (GWTP) at the Naval Weapons Industrial Reserve Plant (NWIRP), GM-38 Area, in Bethpage, New York. Revision Number 1 of this SAP was prepared by KOMAN Government Solutions, LLC (KGS) on behalf of Naval Facilities Engineering Systems Command (NAVFAC) Mid-Atlantic under Contract Number N40085-16-D-2288, Task Order Number 0005. This SAP revision is required to update the NAVFAC and prime contractor personnel information, update the analytical support laboratories, update the required analytical methods, include the addition of a new recovery well location, and to include the analysis of 1,4-dioxane in the list of monitoring requirements.

The GM-38 Area refers to a cluster of monitoring wells that were installed in the 1990s by the Northrup Grumman Corporation (NGC) and that first identified an isolated groundwater contaminant plume in this area. The GM-38 Area is approximately 8,500 feet south-southeast and hydraulically downgradient of NWIRP Bethpage. The GWTP is owned by the United States Department of the Navy (Navy) and is located within a utility easement that is located east of Broadway Avenue, west of the Seaford Oyster Bay Expressway (Route 135), and between the north and south dead ends of Windhorst and Herman Avenues.

As stated in the March 2001 Record of Decision (ROD), the purpose of the GWTP is to “Eliminate, to the extent practical, site-related contaminants from the affected public water supplies and to prevent, to the extent practical, the future contamination of public water supplies through the implementation of the offsite groundwater remediation.” The treatment system was designed for a 5-10 year operational life. It is not intended to remediate groundwater contamination in the local aquifer to non-detectable levels.

Rather, the intent of the system is to remove mass, reduce elevated volatile organic compound (VOC) levels to levels similar to those in the surrounding aquifer, and minimize the impacts on water supply wells and currently unaffected portions of the aquifer.

Various sampling and monitoring scenarios have been conducted as part of the GWTP operations. These include:

Sampling and monitoring of the GWTP aqueous and air process streams (influent, intermediate, and effluent/emissions) during the start-up period;

Sampling and monitoring of the GWTP aqueous and air process streams (influent, intermediate, and effluent/emissions) during the prove-out period;

Sampling and monitoring of the GWTP aqueous and air process streams (influent, intermediate, and effluent/emissions) during routine operations; and

Sampling and monitoring of groundwater from surrounding monitoring wells.

During the start-up period, various process streams were sampled and/or monitored. The purpose of this sampling and monitoring was for tracking and documenting GWTP operation performance as well as for regulatory compliance. The start-up period was defined as the first 30 days of operations. During the system start-up period, aqueous and air samples were collected on a frequent (weekly) basis.

Following the start-up period, a prove-out period was initiated and extended until the GWTP was functional for an additional five months. Sampling of both aqueous and air process streams continued to be collected on a weekly basis.

During routine operations, the same aqueous and air process streams as those sampled during the start-up and prove-out periods are sampled and/or monitored but at a reduced frequency. The majority of this sampling and monitoring is for the purpose of tracking and documenting the performance of GWTP operations and not for regulatory compliance reporting purposes. Only the GWTP process effluent

Contract No N40085-16-D-2288 – 3 – KOMAN Government Solutions, LLC streams are required to be sampled for regulatory compliance purposes for the parameters identified by New York State Department of Environmental Conservation (NYSDEC). Based on experience gained in operating the GWTP, the frequency of sampling and analyses for the influent process water the intermediate process streams for plant operations was optimized. All analytical parameters for regulatory compliance are collected monthly (samples for pH will continue to be collected weekly). Samples are analyzed at a laboratory certified by NYSDEC and accredited by the Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) for the specified analytical parameters. In addition to the GWTP process samples, aqueous samples from operational recovery wells RW-1, RW-4, and/or RW-3 (currently not operating) are also collected monthly.

Sampling and monitoring of the groundwater from the 12 existing and additional proposed monitoring wells, as required, will be performed throughout the period of operation of the GWTP and for two years beyond the shut-down of GWTP operations to determine the effectiveness of the remediation activities and monitor the hydraulic containment and capture of the groundwater “hot spot” by the recovery wells.

Water level measurements will be performed in all 12 monitoring wells on a quarterly basis. In addition, samples for water quality monitoring were collected from 8 of the 12 wells on a quarterly basis for the first two years from the start of GWTP operations. The frequency of groundwater sampling at these eight locations has since been reduced to semi-annual basis. It was deemed unnecessary to collect samples from all 12 wells because some of them are in close proximity and are therefore expected to have the same water quality.

The final determination to take the GWTP off-line will be made by NAVFAC in consultation with NYSDEC. When concentrations of chlorinated VOCs in the GM-38 Area groundwater “hot spot” are equal to those concentrations in the surrounding aquifer, the operating contractor will confer with the Navy to confirm that GWTP operations can be terminated. With consent from the Navy and NYSDEC, sampling and monitoring of the groundwater quality will continue for two years (on a semi-annual basis) beyond the shut-down of the GWTP operations.

Contract No N40085-16-D-2288 – 4 – KOMAN Government Solutions, LLC

TABLE OF CONTENTS

Section Page No.

TITLE AND APPROVAL PAGE

LIST OF FIGURES

LIST OF APPENDICES

ACRONYMS AND ABBREVIATIONS

1.0 – PROJECT ORGANIZATIONAL CHART

2.0 – COMMUNICATION PATHWAYS

3.0 – PROJECT PLANNING SESSION PARTICIPANTS SHEET

4.0 – CONCEPTUAL SITE MODEL

5.0 – PROJECT QUALITY OBJECTIVES/SYSTEMATIC PLANNING PROCESS STATEMENTS ... 14

5.1 Overall Project Quality objectives

5.2 Data Users

5.3 Data Uses

5.4 Data Required

5.5 Project Action Limits

6.0 – SAMPLING AND ANALYTICAL STRATEGY

6.1 Field Quality Control Samples

7.0 – SAMPLING DESIGN AND RATIONALE

7.1 Sampling and Monitoring for Routine Operations

7.2 Sampling and Monitoring of Groundwater in GM-38-Area

8.0 – FIELD PROJECT IMPLEMENTATION (FIELD PROJECT INSTRUCTIONS)

8.1 FIELD PROJECT TASKS

Mobilization/Demobilization Site-Specific Health and Safety Training Field Decontamination Procedures Field Documentation Procedures

8.2 Reference Limits and Evaluation Tables

8.3 Sample Details Table

8.4 Analytical SOP Requirements Table

8.5 Field Quality Control Sample Summary Table

9.0 – FIELD SOPS REFERENCE TABLE

10.0 – ANALYTICAL SOP REFERENCE TABLE

11.0 – LABORATORY QC SAMPLE TABLES

12.0 – DATA VERIFICATION AND VALIDATION (STEPS I AND IIA/IIB) PROCESS TABLE

13.0 – REFERENCES

Contract No N40085-16-D-2288 – 5 – KOMAN Government Solutions, LLC

TABLE OF CONTENTS (continued)

LIST OF FIGURES

1 Site Location Map

2 Area of Impacted Groundwater

3 GM-38 Recovery Well Locations

4 GM-38 Monitoring Well Locations

LIST OF APPENDICES

A Site-Specific Field Standard Operating Procedures

B Laboratory DoD ELAP Accreditation and NYSDOH/NELAC Certification

C Laboratory Analytical Standard Operating Procedures.

Contract No N40085-16-D-2288 – 6 – KOMAN Government Solutions, LLC

ACRONYMS AND ABBREVIATIONS

oC Degrees Celsius

% Percent

%R Percent Recovery

A Analysis

AA Atomic Absorption

APP Accident Prevention Plan bgs Below Ground Surface

BS Blank Spike

CA Corrective Action

CAS Chemical Abstract Service

CCV Continuing Calibration Value

COC Chain of Custody

CSM Conceptual Site Model

CWA Clean Water Act

DI Deionized Water

DL Detection Limit

DQI Data Quality Indicator

DoD Department of Defense

DQO Data Quality Objective

ELAP Environmental Laboratory Accreditation Program

EPA United States Environmental Protection Agency

FSP Field Sampling Plan

FTMR Field Task Modification Request

GAC Granular Activated Carbon

GC Gas Chromatograph

GC/MS Gas Chromatograph/Mass Spectrometer

GW Groundwater

GWTP Groundwater Treatment Plant

HCl Hydrochloric Acid

HDPE High Density Polypropylene

HNO3 Nitric Acid lb/hr Pounds per Hour

ICAL Internal Calibration

Contract No N40085-16-D-2288 – 7 – KOMAN Government Solutions, LLC

ID Isotope Dilution

IDW Investigation Derived Waste

IS Internal Standard

KGS KOMAN Government Solutions LLC

LCS Laboratory Control Sample

LCSD Laboratory Control Sample Duplicate

LIMS Laboratory Information Management System

LOD Limit of Detection

LOQ Limit of Quantification

MCL Maximum Contaminant Level

MDL Method Detection Limit µg /L Microgram per Liter mg/L Milligram per Liter ml Milligram

MPC Measurement Performance Criteria

MS/MSD Matrix Spike/Matrix Spike Duplicate

NAVFAC Naval Facilities Engineering Systems Command

Navy United States Department of the Navy

NELAC National Environmental Laboratory Accreditation Conference

NCDH Nassau County Department of Health

NGC Northrup Grumman Corporation

NWIRP Naval Weapons Industrial Reserve Plant

NYSDEC New York State Department of Environmental Conservation

OM&M Operation, Maintenance & Monitoring

OSHA Occupational Safety and Health Administration

PAL Project Action Limit

PARCC Precision, Accuracy, Representativeness, Completeness, and Comparability

PCB Polychlorinated biphenyl

PCE Tetrachloroethene

PDF Portable Document Format

PE Performance Evaluation

PG Professional Geologist

PgM Program Manager

PM Project Manager ppbv Parts per Billion-Volume

Contract No N40085-16-D-2288 – 8 – KOMAN Government Solutions, LLC

PPE Personal Protection Equipment

PQOs Project Quality Objectives

PQL Practical Quantitation Limit

QA Quality Assurance

QAM Quality Assurance Manager

QAPP Quality Assurance Project Plan

QC Quality Control

QL Quantitation Limit

OSHA Occupational Safety and Health Administration

QSM Quality Systems Manual

RL Reporting Limit

ROD Record of Decision

RPD Relative Percent Difference

RPM Remedial Project Manager

RSD Relative Standard Deviation

RT Retention Time

S Sampling

SAP Sampling and Analysis Plan

SDG Sample Delivery Group

SHM Safety and Health Manager

SIM Selective Ion Monitoring

SOP Standard Operating Procedure

SPDES State Pollutant Discharge Elimination System

SVOC Semivolatile Organic Compounds

TBD To Be Determined

TCE Trichloroethene

TCL Target Compound List

TCLP Toxicity Characteristic Leaching Procedure

TSS Total Suspended Solids

TtEC Tetra Tech EC

UFP Uniform Federal Policy

VOA Volatile Organic Analysis

VOC Volatile Organic Compounds

Contract No N40085-16-D-2288 – 9 – KOMAN Government Solutions, LLC

1.0 – Project Organizational Chart (UFP-QAPP Manual Section 2.4.1 – Worksheet #5)

Lines of Authority Lines of Communication

SHM - Safety and Health Manager PgM – Program Manager

KGS - KOMAN Government Solutions, LLC PM - Project Manager NAVFAC – Naval Facilities Engineering QAM - Quality Assurance Manager Systems Command QA – Quality Assurance NYSDEC – NY State Department of Environmental Conservation RPM - Remedial Project Manager

Contract No N40085-16-D-2288 – 10 – KOMAN Government Solutions, LLC

2.0 – Communication Pathways

(UFP-QAPP Manual Section 2.4.2 – Worksheet #6) The communication pathways for the Sampling and Analysis Plan (SAP) are shown below.

Communication Drivers

Responsible Entity Name Phone Number Procedure

(Timing, Pathway To/From, etc.)

SAP Amendments Navy Remedial Project Manager (RPM)

Scott Sokolowski 760-672-3814 Immediately informs KGS Project Manager (PM).

Document via Field Task Modification Request (FTMR) form; complete within 1 week or less.

Changes in Schedule

KGS PM Robert Gregory 610-400-0636 Informs Navy RPM via schedule impact letter as soon as impact is realized. Schedule revised within 1 week or less.

Unanticipated field conditions that would require a change in plan and result in FTMRs

KGS Plant Operator Randall Hoffmaster 513-413-5099 Plant Operator/FTL immediately informs PM; PM informs RPM; RPM issues scope change if warranted; scope change to be implemented before work is executed. Document via FTMR form (within 1 week or less). Navy Chemist review of the FTMR may be required if it pertains to changes to project DQOs, changes to target analyte lists or possible laboratory changes. FTMR to be completed within time frame as per agreement with Navy after authorization.

KGS PM Robert Gregory 610-400-0636

KGS Field Team Leader

(FTL)

Navy Chemist

Ericka Seiler

Kenneth Bowers

610-357-1346

757-322-8288

Conditions adverse to quality or health and safety

KGS Plant Operator Randall Hoffmaster 513-413-5099 Responsible party immediately informs site workers, Navy, and Project Team to stop work. Re-initiate work upon corrective action within 1 week or less (as possible). All project workers have the responsibility and authority to stop work if unsafe conditions exist.

KGS FTL Ericka Seiler 610-357-1346

KGS PM Robert Gregory 610-400-0636

KGS QAM Patrick Schauble 610-400-0619

KGS Safety and Health Manager (SHM)

John Rawlings 301-661-5629

Navy RPM Scott Sokolowski 760-672-3814

Analytical data quality issues

ALS Rochester PM Janice Jaeger 585-672-7472 Immediately notify KGS Project Chemist. Notify data review staff and KGS PM if necessary. Notify

Eurofins Air Toxics PM Brian Whitaker 916-605-3355

Contract No N40085-16-D-2288 – 11 – KOMAN Government Solutions, LLC

Communication Drivers

Responsible Entity Name Phone Number Procedure

(Timing, Pathway To/From, etc.)

KGS Project Chemist Laurie Ekes 508-367-7190 Navy RPM and Chemist, if necessary. Resolve within 1 week or less.

Navy Chemist Kenneth Bowers 757-322-8288

Contract No N40085-16-D-2288 – 12 – KOMAN Government Solutions, LLC

3.0 – Project Planning Session Participants Sheet

(UFP-QAPP Manual Section 2.5.1 – Worksheet #9)

Project Name: Operations, Maintenance, and Monitoring of the Groundwater Treatment Plant

Projected Date(s) of Sampling:

September 2021 – September 2023

Project Manager: Robert Gregory - KGS

Site Name: NWIRP Bethpage GM-38 Area

Site Location: Bethpage, NY

Dates of Sessions: Emails/Telephone Conversations, May 2009

Scoping Session Purpose: Identify OM&M Plan Elements and Information Required to Complete OM&M Plan.

Name Title Affiliation Phone # E-Mail Address Project Role

Stavros Patselas

Former Project Manager

Tetra Tech EC (TtEC)

215-702-4099 Stavros.Patselas@tetratech.com

Former Contractor Point of Contact

Maheyar Bilimoria

Former

OM&M

Engineer

TtEC 215-702-4049 Maheyar.Bilimoria@tetratech.co m

Former Project Engineer

Lora Fly Former

RPM

NAVFAC

Mid-Atlantic

757-444-0781 Lora.Fly@navy.mil Former Navy Point of Contact

Consensus Decisions:

Prepared suggested Table of Contents for OM&M Plan. Identified specific information/documents required to prepare and complete draft OM&M Plan.

Project Planning Summary:

The operational and monitoring requirements for the GM-38 Area GWTP were established by the Record of Decision, Operable Unit 2 Groundwater, Northrup Grumman and Naval Weapons Reserve Plant Sites, Nassau County, Site Numbers 1-30-003 A&B, March 2001, followed by construction and operation of the GWTP beginning in 2009.

The current revision of the SAP is required to update the NAVFAC and prime contractor personnel information, update the analytical support laboratories, update the required analytical methods, include the addition of a new recovery well location, and to include the analysis of 1,4-dioxane in the list of monitoring requirements.

Contract No N40085-16-D-2288 – 13 – KOMAN Government Solutions, LLC

4.0 – Conceptual Site Model

(UFP-QAPP Manual Section 2.5.2 – Worksheet #10)

NWIRP Bethpage, located in Nassau County, NY (Figure 1), was established in 1941. Since inception, the primary mission of the facility was the research, prototyping, testing, design engineering, fabrication, and primary assembly of military aircraft. The facilities at NWIRP Bethpage included four plants (Nos.

3, 5, and 20, used for assembly and prototype testing; and No. 10, which contained a group of quality control laboratories), two warehouse complexes, a salvage storage area, water recharge basins, an industrial wastewater treatment plant, and several smaller support buildings. Historical operations that resulted in hazardous material generation at the facility included metal finishing processes, maintenance operations, painting of aircraft and components, and other activities that involved aircraft manufacturing.

Wastes generated by plant operations were disposed directly into either drainage sumps, dry wells, and/or on the ground surface, resulting in the disposal of a number of hazardous wastes, including the VOCs tetrachloroethene (PCE) and trichloroethene (TCE), the semi-volatile organic compounds (SVOCs) polychlorinated biphenyls (PCBs), and the inorganic constituents chromium and cadmium at the site.

Some of these contaminants have migrated from the points of disposal to surrounding areas, including the soils of these sites and the groundwater beneath and downgradient of the NWIRP Bethpage property.

Chlorinated VOCs were identified in the GM-38 Area in moderately deep (220 to 470 feet below ground surface [bgs]) groundwater at concentrations greater than 500 micrograms per liter (µg/L). The contaminated groundwater in the area represents a relatively large mass of chlorinated VOCs that would remain for extended periods and could adversely affect public water supplies in the area, as well as other downgradient water supplies. Two public water supply systems are present in the general area and extract groundwater at depths ranging from 540 to 740 feet bgs. Navy and contractor funded groundwater treatment systems are in place at the public water supply wells to remove VOCs from the water prior to distribution.

The emerging contaminant 1,4-dioxane has more recently been detected in groundwater at GM-38. This SVOC has been added to the sampling protocol.

The GM-38 Area GWTP can receive and treat contaminated groundwater from a network of four recovery wells (Figure 2) to extract groundwater from the impacted aquifer zones. Currently the GWTP receives groundwater from two of the recovery wells, RW-1 and RW-4.

Contract No N40085-16-D-2288 – 14 – KOMAN Government Solutions, LLC

5.0 – PROJECT QUALITY OBJECTIVES/SYSTEMATIC PLANNING PROCESS

STATEMENTS

(UFP-QAPP Manual Section 2.6.1 – Worksheet #11)

5.1 OVERALL PROJECT QUALITY OBJECTIVES

Sample and monitor GWTP aqueous process streams (including influent, intermediate and effluent) during routine operations to ensure treatment components, including the air stripper and liquid phase granular activated carbon (LGAC) units (LGAC-1, LGAC-2, and LGAC-3) connected in parallel are functioning efficiently and that treated effluent meets the monitoring requirements and discharge limitations provided by NYSDEC in the State Pollutant Discharge Elimination System (SPDES) permit equivalent.

IF influent concentrations from the active recovery wells are below the groundwater cleanup levels designated by NYSDEC, THEN initiate assessment of the feasibility of GWTP shut down in response to attainment of cleanup levels. Consider if contaminant concentrations in currently inactive recovery wells may remain above cleanup levels, or if rebound of contaminant concentrations may occur following shut down.

IF intermediate process sample locations indicate that specific systems components are not meeting their performance requirements, THEN initiate engineering evaluation of the components to determine the need for repair, replacement, or upgrade.

IF the GWTP treatment train is not able to maintain effluent concentrations within the discharge limitations established by NYSDEC, THEN initiate engineering review of the existing system performance, evaluate potential system upgrades, and/or shut down the GWTP if performance cannot be immediately improved to meet the discharge limitations.

Sample and monitor GWTP air process streams (including influent, intermediate and emissions) during routine operations to ensure the three vapor phase granular activated carbon (VGAC) units (VGAC-1, VGAC-2, and VGAC-3) connected in series are functioning efficiently and that treated emissions meet the emission limitations provided by NYSDEC.

IF the air discharge limitations approved by NYSDEC are not being maintained, THEN initiate engineering review of the existing air stripper performance, evaluate the need for air stripper repairs or upgrades, or shut down the GWTP if performance cannot be immediately improved to meet the emission limitations.

Monitor the groundwater level in 12 monitoring wells and sample 8 of these 12 monitoring wells on a semi-annual basis, to facilitate the evaluation of contaminant capture and reduction of contaminant mass in the impacted groundwater.

IF contaminant concentrations in areawide groundwater monitoring wells decrease to levels less than cleanup levels, THEN consider, in conjunction with associated contaminant reduction in the recovery well network, shut down of the GWTP in response to attainment of cleanup levels.

5.2 DATA USERS

KGS - Prime Contractor

NAVFAC – GWTP Owner

Contract No N40085-16-D-2288 – 15 – KOMAN Government Solutions, LLC

NYSDEC - Regulatory Oversight

Nassau County Department of Health (NCDH) - Regulatory Oversight

City of Oyster Bay, NY – Local Government Oversight

5.3 DATA USES

Performance monitoring of the treatment components within the GWTP, Confirmation of the acceptability of the GWTP effluent for discharge per the SPDES permit equivalent, Confirmation of the acceptability of the GWTP vapor emissions for discharge per the NYSDEC, and

Monitoring of the hydraulic containment and capture of the groundwater GM-38 area “hot spot.”

5.4 DATA REQUIRED

GWTP Process Stream Sampling and Monitoring during Routine Operations – During routine operations, various process streams (either aqueous or vapor) will be sampled and/or monitored on a monthly basis (see Section 8.3 -Worksheet #18). The majority of this sampling and monitoring is for the purpose of tracking and documenting the performance of internal plant treatment components and not for regulatory compliance reporting purposes. Only the aqueous effluent and treated air emission streams will be sampled for regulatory compliance purposes for the parameters identified by NYSDEC. Based on experience gained in operating the GWTP, and after consultation with the Navy RPM, the frequency of sampling and analyses for the intermediate process streams may be adjusted. All analytical parameters for regulatory compliance will be collected monthly (samples for pH will be collected weekly) and analyzed at a laboratory certified by NYSDEC and accredited in accordance with the DoD ELAP for these parameters. In addition to the GWTP process samples, aqueous samples from operational recovery wells RW-1, RW-4, and/or RW-3 (currently not operating) will also be collected monthly.

Groundwater Sampling and Monitoring – Sampling and monitoring of the groundwater from the existing monitoring wells will be performed throughout the period of operation of the GWTP and for two years beyond the shut-down of GWTP operations to determine the effectiveness of the remediation activities and monitor the hydraulic containment and capture of the groundwater “hot spot” by the recovery wells.

Water level measurements will be performed in all 12 monitoring wells on a quarterly basis. In addition, samples for water quality monitoring will be collected from 8 of the 12 wells on a semi-annual basis. It was deemed unnecessary to collect samples from all 12 wells because some of them are in close proximity to each other and are therefore expected to have the same water quality.

The effectiveness of the treatment system will be determined by making a comparison between the concentrations of chlorinated VOCs within the “hot spot” with corresponding levels in the surrounding aquifer. When concentrations of chlorinated VOCs in the GM-38 Area groundwater “hot spot” are equal to those concentrations in the surrounding aquifer over a sustained period, the operating contractor will confer with the Navy to confirm that GWTP operations can be terminated.

The final determination to take the GWTP off-line will be made by NAVFAC in consultation with NYSDEC. With consent from NAVFAC and NYSDEC, sampling and monitoring of the groundwater quality for the same parameters will continue for two years (on a semi-annual basis) beyond the shut-down of the GWTP operations. If the concentrations of the chlorinated VOCs in the GM-38 Area groundwater “hot spot” increase after the operations at the GWTP are terminated, the operations may have to be resumed. This will be done, if necessary, after consultation with NAVFAC and NYSDEC.

Contract No N40085-16-D-2288 – 16 – KOMAN Government Solutions, LLC

Section 7.2 - Worksheet #17 presents the wells that will be sampled for water quality monitoring.

5.5 PROJECT ACTION LIMITS

The aqueous samples from the GWTP will be analyzed for the list of constituents associated effluent discharge limitations provided in the SPDES permit equivalent most recently updated on 8 August 2017, consisting of select VOCs (chloroform, 1,1-dichloroethane, 1,2-dichloroethane, 1,1-dichloroethene, cis- 1,2-dichloroethene, trans-1,2-dichloroethene, PCE, 1,1,1-trichloroethane, TCE, 1,1,2 -trichlorotrifluoroethane [CFC 113], and vinyl chloride); 1,4-dioxane, mercury, and total suspended solids (TSS) by the subcontracted laboratory, ALS Environmental, Rochester, NY. In addition, aqueous samples from the GWTP will be analyzed for pH with a hand-held pH meter. Groundwater samples collected from the monitoring well network will also be analyzed for these same constituents.

The Project Action Limits (PALs) for aqueous samples are shown below. Chloroform and 1,1,2-trichlorotrifluoroethane are also now monitored following the addition of these constituents during the 8 August 2017 update of the NPDES permit equivalent. 1,4-dioxane is now monitored following the establishment of a Drinking Water Standard by NYSDEC in August 2020.

Contract No N40085-16-D-2288 – 18 – KOMAN Government Solutions, LLC

(UFP-QAPP Manual Section 2.8.1 – Worksheet #15)

Matrix: Aqueous

Analytical Groups: VOCs, 1,4-dioxane, Mercury, TSS

Method Compound CAS No.

Project Action

Limit (µg/L)

Project Action Limit

Reference1

Achievable Laboratory Limits

LOQ

(µg/L)

LOD

(µg/L)

MDL

(µg/L)

EPA3 624.1 1,1,1-Trichloroethane 71-55-6 5 SPDES Effluent

Limitation 5.0 1.0 0.20

EPA 624.1

1,1,2-Trichlorotrifluoroethane

(CFC 113)

76-13-1 5 SPDES Effluent

Limitation 5.0 1.0 0.20

EPA 624.1 1,1-Dichloroethane 75-34-3 5 SPDES Effluent

Limitation 5.0 1.0 0.20

EPA 624.1 1,1-Dichloroethene 75-35-4 5 SPDES Effluent

Limitation

5.0 1.0 0.20

EPA 624.1 1,2-Dichloroethane 107-06-2 0.6 SPDES Effluent

Limitation 5.0 1.0 0.20

EPA 624.1 Chloroform 67-66-3 5 SPDES Effluent

Limitation

5.0 1.0 0.24

EPA 624.1 Tetrachloroethene 127-18-4 5 SPDES Effluent

Limitation 5.0 1.0 0.21

EPA 624.1 Trichloroethene 79-01-6 5 SPDES Effluent

Limitation 5.0 1.0 0.20

Contract No N40085-16-D-2288 – 19 – KOMAN Government Solutions, LLC

Method Compound CAS No.

Project Action

Limit (µg/L)

Project Action Limit

Reference1

Achievable Laboratory Limits

LOQ

(µg/L)

LOD

(µg/L)

MDL

(µg/L)

EPA 624.1 Vinyl Chloride 75-01-4 2 SPDES Effluent

Limitation

5.0 1.0 0.20

EPA 624.1 cis-1,2-Dichloroethene 156-59-2 5 SPDES Effluent

Limitation

5.0 1.0 0.23

EPA 624.1 trans-1,2-Dichloroethene 156-60-5 5 SPDES Effluent

Limitation

5.0 1.0 0.20

EPA 8270D

SIM

1,4-Dioxane 123-91-1 1

NYSDEC

Drinking Water Standard2

0.40 0.027 0.027

EPA 8270D

SIM (Isotope Dilution)

1,4-Dioxane 123-91-1 1

NYSDEC

Drinking Water Standard2

0.40 0.027 0.027

EPA 245.1 Mercury 7439-97-6 0.25 SPDES Effluent

Limitation

0.20 0.10 0.08

SM 2540D-11 Total Suspended Solids -- NA NA 1.0 -- --

1 Based on SPDES Permit Equivalent Discharge Limitations (August 2017).

2 NYSDEC Drinking Water Standard, adopted August 2020.

Contract No N40085-16-D-2288 – 20 – KOMAN Government Solutions, LLC

The Project Action Limits (PALs) for air samples are shown below. The constituents and associated action limits are based on the proposed revised air emissions discharge goals provided by the Navy’s consultant to NYSDEC on 21 November 2011, with concurrence subsequently received from NYSDEC on 31 October 2013.

(UFP-QAPP Manual Section 2.8.1 – Worksheet #15)

Matrix: Air Analytical Group: Select VOCs

Analyte

CAS

Number

Project Action Limit1 (µg/m3)

Project Action Limit Reference

Achievable Laboratory Limits2

RL

(µg/m3)

MDL

(µg/m3)

1,2-Dichloroethene (Total)

540-59-0 >100,000 NYSDEC Emission

Discharge Limit 4.0

0.40 (cis)

0.58 (trans)

Tetrachlorethene 127-18-4 5,100 NYSDEC Emission

Discharge Limit

3.4 0.70

Trichloroethene 79-01-6 2,600 NYSDEC Emission

Discharge Limit

2.7 0.69

Vinyl Chloride 75-01-4 560 NYSDEC Emission

Discharge Limit

1.3 0.34

1 The PAL is presented in µg/m3 and is based on the air emission discharge goals specified in the air emission documentation concurred by NYSDEC (31 October 2013).

2 Achievable Method Detection Limits (MDLs) and Reporting Limits (RLs) are limits that the laboratory can achieve when performing a specific analytical method. MDLs are instrument specific and will be determined during sample analysis.

Contract No N40085-16-D-2288 – 21 – KOMAN Government Solutions, LLC

6.0 – SAMPLING AND ANALYTICAL STRATEGY

In compliance with the SPDES permit equivalent an associated discharge limitations provided the NYSDEC, a specified list of aqueous target parameters for the plant process stream and effluent has been established as previously discussed with sampling to occur on a monthly basis. Groundwater sampling will continue to be performed semi-annually. Additional constituents, including 1,4-dioxane, were added to the target list during the most recent update of the SPDES permit equivalent. Initially, a VOC method was used to screen for 1,4 dioxane. However, SVOC Method 8270 Selective Ion Monitoring (SIM) was subsequently selected for use in place of VOC Method 8260 to achieve the required reporting limits.

Analytical evaluation indicates that measurable sample loss may occur during the sample preparation step within Method 8270 SIM. Method 8270 SIM Isotope Dilution (ID) has been developed and analytical evaluation indicates that this process can eliminate most of the sample loss experienced with Method 8270 SIM. To facilitate evaluation of the performance differences between the two 8270-based methods, two separate monthly sample fractions will initially be collected and analyzed by both 8270D SIM and 8270D SIM ID so that a comparison can be made. In addition, a Performance Evaluation (PE) sample obtained from a third partly will be introduced into the monthly sample sets for a period of two months.

The PE samples will be submitted to the laboratory as double-blind samples (identified as routine samples with unknown concentration). These data will be reviewed and assessed by the project team, with the objective to select a single analytical method that will be used following the evaluation period. The duration for which samples will be analyzed for 1,4-dioxane using both methods will be determined following discussion within the project team.

No changes to the analytical methods for the remaining aqueous parameters are currently proposed in this revision of the SAP. The analytical laboratory for aqueous samples has changed as indicated in this SAP.

Air sample parameters have also been established as previously discussed. Monthly air process and emission samples will continue to be collected. No changes to the sampling methods or analytical laboratory were required in this SAP.

Contract No N40085-16-D-2288 – 22 – KOMAN Government Solutions, LLC

6.1 FIELD QUALITY CONTROL SAMPLES

(UFP-QAPP Manual Section 2.6.2 – Worksheet #12)

QC Sample Analytical Group Frequency Data Quality

Indicators (DQIs) Measurement Performance Criteria

QC Sample Assesses Error for Sampling (S), Analytical (A), or both (S&A)

Measurement Performance Criteria Table – Field Quality Control (QC) Samples - Aqueous

Cooler Temperature Indicator

VOCs, Mercury, Total Suspended Solids (TSS), and 1,4-dioxane

One per cooler Accuracy / Representativeness

Between 2 and 6 degrees Celsius (oC).

S

Field Duplicate One per 20 samples Precision (field) 50 percent (%) Relative Percent Difference (RPD)

S&A

Field Blank One per 20 samples Representativeness No analyte > ½ LOQ. 1/10 the amount measured in any sample, or 1/10 the regulatory limit whichever is greater.

S&A

All samples All samples Sensitivity Method detection limits (MDLs) < project action limits listed on Worksheet #15

A

All samples All samples Data Completeness 95% overall S&A

Trip Blank VOCs One per cooler Bias No analyte > MDL S&A

Measurement Performance Criteria Table – Field QC Samples - Air

Field Duplicate VOCs 1 per 20 samples Precision (field) 50% RPD S&A

All samples All samples Sensitivity MDLs < project action limits listed on Worksheet #15

A

Contract No N40085-16-D-2288 – 23 – KOMAN Government Solutions, LLC

All samples All samples Data Completeness 95% overall S&A

All samples All Samples Cannister Cleanliness

Verify cannister vacuum prior to use. Delete if vacuum not maintained in field or upon receipt by laboratory.

S&A

Contract No N40085-16-D-2288 – 24 – KOMAN Government Solutions, LLC

7.0 – SAMPLING DESIGN AND RATIONALE

(UFP-QAPP Manual Section 3.1.1 – Worksheet #17)

Three sampling and monitoring programs will be conducted as part of the GWTP operations. These consist of:

1) Monthly sampling and monitoring of the GWTP aqueous process streams (including influent, intermediate, and effluent) for routine operations;

2) Monthly sampling and monitoring of the air process streams (including influent, intermediate, and discharge emissions) for routine operations; and

3) Quarterly monitoring and semi-annual sampling of groundwater.

7.1 SAMPLING AND MONITORING FOR ROUTINE OPERATIONS

During routine operations, the process streams as listed in Section 8.3 - Worksheet #18 will be sampled and/or monitored. It should be noted that most of this sampling and monitoring is for the purpose of tracking and documenting the performance of plant operations and not for regulatory compliance reporting purposes. Only the process effluent streams (aqueous and air) will be sampled for regulatory compliance purposes for the parameters identified by NYSDEC and for disposal purposes for parameters as required by the disposal facilities, at the designated frequency. Based on additional experience gained in operating the GWTP the frequency of sampling and analyses for some of the intermediate process streams may be reduced. All analytical parameters for regulatory compliance will be collected monthly (aqueous samples for pH will be collected weekly) and analyzed at a laboratory certified by the State of New York and accredited in accordance with the DoD ELAP for these parameters. Aqueous samples will be collected from recovery wells RW-1 and RW-4; RW-2 and RW-3 are currently offline, in standby status.

Aqueous and air process samples during routine GWTP operations will be analyzed for the parameters discussed previously in Section 5.

7.2 SAMPLING AND MONITORING OF GROUNDWATER IN GM-38-AREA

Sampling and monitoring of the groundwater from up to 12 monitoring wells will be performed throughout the period of operation of the GWTP and for two years beyond the shut-down of GWTP operations to determine the effectiveness of the remediation activities and monitor the hydraulic containment and capture of the groundwater “hot spot” by the recovery wells. The 12 wells are shown on Figure 3 and are located as follows:

There are three monitoring wells near recovery well RW-1 that are screened between 395 and 435 feet bgs. RW-1 MW-1 is located approximately 140 feet northwest of RW-1, and RW-1 MW-2 is located approximately 50 feet north of RW-1. RW-1 MW-3 is located approximately 400 feet northeast of RW-1, on the eastern side of Seaford Oyster Bay Expressway.

There are three monitoring wells near recovery well RW-2 that are screened between 470 and 510 feet bgs. RW-2 MW-1 is located approximately 60 feet northwest of RW-2, RW-2 MW-2 is located approximately 20 feet west of RW-2, and RW-2 MW-3 is located approximately 100 feet west of

RW-2.

There are four monitoring wells near recovery well RW-3. Two of these four wells (RW-3 MW-1 and RW-3 MW-3) are screened between 320 and 340 feet bgs. The other two wells (RW-3 MW-2 and RW-3 MW-4) are screened between 475 and 495 feet bgs. RW-3 MW-1 and RW-3 MW-2 are located approximately 500 feet west of cluster GM-38, at the intersection of Arthur Avenue and Leroy Avenue. RW-3 MW-3 and RW-3 MW-4 are located approximately 400 feet north of the

Contract No N40085-16-D-2288 – 25 – KOMAN Government Solutions, LLC intersection of Arthur Avenue and Broadway, on Broadway between Helena Avenue and Russell Avenue.

There is one monitoring well near injection well IW-1. IW-1 MW-1 is screened between 130 and 150 feet bgs and is located approximately 20 feet south of IW-1.

Monitoring well TP-1 is screened between 450 and 470 feet bgs and is located approximately 350 feet north of the GWTP building, alongside the GWTP access road.

Water level measurements will be performed in all 12 monitoring wells on a quarterly basis. In addition, samples for water quality monitoring will be collected from 8 of the 12 wells (RW-1 MW-1, RW-1 MW- 3, RW-2 MW-1, RW-3 MW-1, RW-3 MW-2, RW-3 MW-3, RW-3 MW-4, TP1) on semi-annual basis for calendar years 2021, 2022 and 2023. It was deemed unnecessary to collect samples from all 12 wells because some of them are in close proximity and are therefore expected to have the same water quality.

The final determination to take the GWTP off-line will be made by the Navy in consultation with NYSDEC. When concentrations of chlorinated VOCs in the GM-38 Area groundwater “hot spot” are equal to or less than those concentrations in the surrounding aquifer, the operating contractor will consult with the Navy to confirm that the GWTP operations can be shut-down. With consent from the Navy and NYSDEC, sampling and monitoring of the groundwater quality for the same parameters will continue for two years (on a semi-annual basis) beyond the shut-down of the GWTP operations.

Contract No N40085-16-D-2288 – 26 – KOMAN Government Solutions, LLC

8.0 – FIELD PROJECT IMPLEMENTATION (FIELD PROJECT INSTRUCTIONS)

Project implementation at the GM-38 GWTP is comprised of the following:

Sampling and monitoring of influent, effluent, and intermediate process streams within the GWTP for the purpose of evaluating the operation and performance of the process equipment used for air stripping, bag filtration, liquid-phase and vapor-phase granular activated carbon adsorption, and backwashing during routine operations.

Sampling and monitoring of the groundwater to determine the effectiveness of the remediation activities and monitor the hydraulic containment and capture of the groundwater “hot spot” by the recovery wells.

8.1 FIELD PROJECT TASKS

(UFP-QAPP Manual Section 2.8.1 – Worksheet #14)

The required field tasks and a brief description of these tasks are summarized below:

Mobilization/Demobilization

Site-Specific Health and Safety Training

GWTP Process Stream Sampling

Synoptic Water Levels and Groundwater Sampling

Investigation-Derived Waste (IDW) Management

Field Decontamination Procedures

Field Documentation Procedures

Sample Custody and Shipment Tasks

Mobilization/Demobilization

Mobilization will consist of the delivery of all equipment, materials, and supplies to the site, complete assembly in satisfactory working order of all such equipment at the site, and satisfactory storage at the site of all such materials and supplies. The KGS PM or designee will coordinate with the Navy PM to identify appropriate locations for the storage of equipment and supplies. Site-specific health and safety training for all field personnel and subcontractors will be provided as part of site mobilization.

Demobilization will consist of the prompt and timely removal of all equipment, materials, and supplies from the site following completion of the work. Demobilization includes the cleanup and removal of waste generated during the performance of the investigation.

Site-Specific Health and Safety Training

There are no specialized/non-routine project-specific training requirements or certifications needed by personnel to successfully complete the project or tasks. All field personnel will have appropriate training to conduct the field activities to which they are assigned. Each site worker will be required to have completed the Occupational Safety and Health Administration (OSHA) 40-hour course (and 8-hour refresher, if applicable) in health and safety training. Safety requirements are addressed in greater detail in the site-specific Accident Prevention Plan (APP).

Groundwater Treatment System Process Stream Sampling

The aqueous process samples from the GWTP will be analyzed for the list of constituents outlined in the SPDES permit consisting of select VOCs (chloroform, 1,1-dichloroethane, 1,2-dichloroethane, 1,1-dichloroethene, cis-1,2-dichloroethene, trans-1,2-dichloroethene, PCE, 1,1,1-trichloroethane, TCE, 1,1,2-

Contract No N40085-16-D-2288 – 27 – KOMAN Government Solutions, LLC trichlorotrifluoroethane [CFC 113], and vinyl chloride); mercury; and TSS by a subcontracted laboratory, ALS Environmental – Rochester, NY. In addition, aqueous samples from the GWTP will be analyzed for pH with a hand-held pH meter. Standard Operating Procedure (SOP)-001 (Appendix A) will be followed for the collection of these samples.

The air process and emission samples from the GWTP will be analyzed for select VOCs (1,2-dichloroethane, 1,2-dichloroethene, toluene, 1,1,2-trichloroethane, PCE, TCE, vinyl chloride, and xylenes) by a subcontracted laboratory, Eurofins Air Toxics – Folsom, California. SOP-002 (Appendix A) will be followed for the collection of these samples.

Synoptic Water Levels and Groundwater Sampling

On a quarterly basis, water level measurements will be collected during a one-day synoptic event. KGS will provide the personnel and equipment to gauge all of the monitoring wells included in the designated monitoring network. For the first and third quarters of each calendar year, the water level measurements will be collected prior to the semi-annual groundwater sampling event. SOP-003 (Appendix A) will be followed for the collection of these data.

The aqueous samples from the monitoring wells will be analyzed for select Target Compound List (TCL) VOCs, mercury, and TSS by the subcontracted laboratory, ALS Environmental - Rochester, NY. SOP- 004 and SOP-005 (Appendix A) will be followed for the collection of these samples.

The groundwater samples from the monitoring wells will be analyzed for pH just prior to sampling with a water quality meter. The select VOC list is used to compare the results with historical sampling data from the surrounding aquifer as part of the overall evaluation of remedial activities.

Investigation Derived Waste Sampling

IDW and other waste streams such as spent air stripper media, carbon, filters, etc. periodically require profile sampling prior to off-site disposal or regeneration. These materials will be sampled in accordance with SOP-008 and SOP-009 (Appendix A), respectively.

Profile samples of spent air stripper media, spent vapor phase GAC and spent aqueous phase GAC will be analyzed for Toxicity Characteristic Leaching Procedure (TCLP) VOCs and TCLP metals by a subcontracted laboratory, ALS Environmental - Rochester, NY, prior to regeneration and/or disposal.

Additional analyses may be required on a case-by-case basis at the discretion of the disposal facility and/or the Navy.

Aqueous IDW in the form of decontamination water will be generated during field activities. These waters will be returned to the GWTP for processing.

IDW consisting of spent personal protective equipment (PPE) will be bagged and disposed of as municipal waste in an appropriate facility waste container.

Field Decontamination Procedures

Decontamination of field equipment will be conducted in accordance with SOP-006 and SOP-007 (Appendix A). Sample containers will be provided certified-clean from the analytical laboratory.

Decontamination of sampling equipment (e.g., submersible pumps, etc.) will be conducted prior to and between sampling at each location. At each location, an abbreviated decontamination procedure consisting of a powdered Alconox® wash followed by a deionized water rinse will be performed.

Liquinox® will not be used for decontamination because it may contain trace amounts of 1,4-dioxane.

Rinsing of pumps includes pumping deionized water through all pump components, or complete disassembly of the pump to rinse individual components. The use of detergents will be minimized so as not to interfere with the treatment process.

Contract No N40085-16-D-2288 – 28 – KOMAN Government Solutions, LLC

Field Documentation Procedures

A summary of all field activities will be properly recorded in a bound logbook [with consecutively numbered pages that cannot be removed. Logbooks will be assigned to field personnel and will be stored in a secured area when not in use.

At a minimum, the following information will be recorded in the site logbook:

Name of the person to whom the logbook is assigned.

Project name.

Project start date.

Names and responsibilities of on-site project personnel including subcontractor personnel.

Arrival/departure of project personnel and any site visitors.

Arrival/departure of equipment.

Sampling activities and sample log sheet references.

Description of subcontractor activities.

Sample pick-up information, including chain-of-custody numbers, air bill numbers, carrier, time, and date.

Health and safety issues.

Description of photographs including date, time, photographer, roll and picture number, location, and compass direction of photograph.

All entries will be written in ink and no erasures will be made. If an incorrect entry is made, the person making the correction will strike a single line through the incorrect information, and initial and date the change. All documentation will be conducted in accordance with SOP-010 (Appendix A).

Sample Custody and Shipment Tasks

Sample Nomenclature

Sample locations and sampling…