Attachment 6 - SOW Attachment B_Draft SAP_2020.pdf

Naval Facilities Engineering Command Mid-Atlantic Norfolk, Virginia

Draft Tier II Sampling and Analysis Plan, (Field Sampling Plan and Quality Assurance Project Plan) Long-Term Groundwater Monitoring

Site 17 – Former Building 32, Gould Island

Naval Station Newport

Jamestown, Rhode Island

July 2020

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Sampling and Analysis Plan, Long-Term Groundwater Monitoring Site 17, Gould Island Revision No: 0 Jamestown, Rhode Island Revision Date: May 2020

S-112-20-145ID

Title and Approval Page

(UFP-QAPP Manual Section 2.1)

Document Title:

Tier I Sampling and Analysis Plan (SAP), (Field Sampling Plan and Quality Assurance Project Plan), Long-Term Groundwater Monitoring, Former Building 32, Gould Island (Site 17), Operable Unit 06, NAVSTA Newport, Jamestown, Rhode Island

Lead Organization: Naval Facilities Engineering Command (NAVFAC) Mid-Atlantic

Preparer’s Name and Organizational Affiliation: Helios/Tetra Tech Joint Venture (JV)

Preparer’s Address and Telephone Number: Twin Oaks I, Suite 102 5700 Lake Wright Drive Norfolk, Virginia 23502-1860

(757) 461-3768

Preparation Date (Day/Month/Year): 28/May/2020

Investigative Organization’s Project Manager: 5/28/2020

Signature/Date

Michael Horton, CEP, Tetra Tech

Investigative Organization’s Project QA Manager:

Tom Johnston, PhD, Tetra Tech

Lead Organization’s Project Manager:

Cecilia Landin, NAVFAC Mid-Atlantic

Lead Organization QA Officer:

NAVFAC Chemist, NAVFAC Atlantic

Approval Signatures:

Kymberlee Keckler, EPA

Shawn Lowry, RIDEM

***INTERNAL DELIBERATIVE - DO NOT RELEASE******

Site 17, Gould Island Revision No: 4 Jamestown, Rhode Island Revision Date: July 2020

S-112-20-152D Page 2 of 70

EXECUTIVE SUMMARY

This Sampling and Analysis Plan (SAP) was prepared to guide personnel in fulfilling the requirements of a

Long-term Monitoring/Management (LTM) Plan for groundwater set forth in the Record of Decision (ROD) for Site 17, Former Building 32, Gould Island, Operable Unit 06 at Naval Station (NAVSTA) Newport, in

Jamestown, Rhode Island. Included in this SAP are requirements for monitoring of groundwater.

This SAP describes long-term groundwater monitoring at 21 existing monitoring wells. As described in the

ROD, there are three purposes for performing groundwater monitoring at Site 17: (1) Monitoring natural attenuation (MNA) of pentachlorophenol (PCP), tetrachloroethene (PCE), and manganese concentrations in groundwater; (2) confirming that the source control measures for semi-volatile organic compounds

(SVOCs), polychlorinated biphenyls (PCBs), benzene, trichloroethylene (TCE), PCE, arsenic, and manganese were effective; and (3) confirming that contaminants present in soil at concentrations exceeding industrial and leachability criteria before source control measures (including SVOCs, PBCs, arsenic, manganese, cadmium, and, lead) are not impacting groundwater to the extent where groundwater remedial goals are being exceeded. Risk associated with subsurface soils at Site 17 has been mitigated by implementation of land use controls (LUCs).

The Site 17 ROD, which was signed on June 27, 2014, presents and describes the selected remedy for soil, sediment, and groundwater contamination at Operable Unit 06. The remedy includes soil and debris removal (completed in 2016), sediment removal, confirmation sampling of “shallow groundwater,” implementation of LUCs, MNA, long-term groundwater monitoring, limited sediment monitoring, annual inspections, and reporting. The scope of work described in this SAP describes activities associated with confirmation sampling of “shallow groundwater”, MNA, and long-term groundwater monitoring as described in the ROD.

This SAP is meant to be used as a long-term document, with modifications to be made on an annual basis as necessary when optimizations to sampling location, frequency, or parameters are deemed appropriate.

Modifications will be recommended and included as part of each Long-Term Monitoring Report.

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CONTENTS

Title and Approval Page

1.0 Project Organizational Chart

2.0 Communication Pathways

3.0 Project Planning Session Participants Sheet

4.0 Conceptual Site Model

5.0 Data Quality Objectives/Systematic Planning Process Statements

6.0 Field Quality Control Samples

7.0 Sampling Design and Rationale

8.0 Field Project Implementation (Field Project Instructions)

9.0 Reference Limits and Evaluation Tables

10.0 Analytical SOP References Table

11.0 Laboratory QC Samples Table

12.0 Data Verification and Validation (Steps I and IIa/IIb) Process Table

13.0 References

FIGURES

4-1 Site Location 4-2 Site Detail 7-1 LTM Plan

APPENDICES

A Tetra Tech SOPs B Laboratory Certifications

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ACRONYMS AND ABBREVIATIONS

AES Atomic Emission Spectroscopy

CAS Chemical Abstract Service COC Contaminant of concern CoC Chain of Custody CSM Conceptual site model

DCE Dichloroethene DI H2O Deionized water DL Detection limit DO Dissolved oxygen DoD Department of Defense DQO Data Quality Objective DV Data validation DVM Data Validation Manager

EB Equipment blank ECD Electron capture detector EE/CA Engineering Estimate/Cost Evaluation ELAP Environmental Laboratory Accreditation Program EPA United States Environmental Protection Agency ERA Ecological risk assessment ERP Environmental Restoration Program

FID Flame ionization detector FOL Field Operations Leader FS Feasibility Study FTMR Field Task Modification Request

GC Gas chromatography GW Groundwater

HCl Hydrochloric acid Helios/TT JV Helios, Tetra Tech Joint Venture HNO3 Nitric acid HSM Health and Safety Manager

ICAL Internal calibration ICP Inductively coupled plasma IDW Investigation derived waste IS Internal standard

LCS Laboratory control spike or Laboratory control sample LCSD Laboratory control spike duplicate LOD Limit of detection LOQ Limit of quantitation LTM Long-term monitoring LUC Land use control

MCL Maximum Contaminant Level mL Milliliter MNA Monitored natural attenuation MPI Measurement performance indicator MS Mass spectroscopy MS/MSD Matrix Spike/Matrix Spike Duplicate

NA Not applicable NAVFAC Naval Facilities Engineering Command

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NEDD Navy electronic data deliverable NELAP National Environmental Laboratory Accreditation Program NIRIS Naval Installation Restoration Information Solution NUWC Naval Undersea Warfare Center

ORP Oxidation reduction potential

PAH Polycyclic aromatic hydrocarbons PAL Project action limit PCB Polychlorinated biphenyls PCE Tetrachloroethene PCP Pentachlorophenol PDF Portable document format PM Project Manager POC Point of contact PQO Project quality objective

QA Quality assurance QAM Quality Assurance Manager QAO Quality Assurance Officer QC Quality Control QSM Quality Systems Manual

RG Remedial goal RI Remedial investigation RIDEM Rhode Island Department of Environmental Management ROD Record of Decision RPD Relative percent difference RPM Remedial Project Manager RSL EPA Regional Screening Value

SAP Sampling and Analysis Plan SDG Sample delivery group SIM Selected ion monitoring SOP Standard operating procedure SSHO Site Safety and Health Officer SVOC Semi-volatile organic compound

TBD To be determined TCE Trichloroethene

VC Vinyl chloride VOA Volatile Organic Analysis VOC Volatile organic compound

%R Percent recovery

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1.0 Project Organizational Chart

(UFP-QAPP Manual Section 2.4.1 – Worksheet #5)

Lines of Authority Lines of Communication

TBD – To be determined;

POC – Point of Contact;

RPM – Remedial Project Manager;

QA – Quality Assurance QAO – QA Officer QAM – QA; Manager PM – Project Manager;

SSHO – Site Safety and Health Officer;

HSM – Health and Safety Manager DVM – Data Validation Manager;

FOL – Field Operations Leader;

IDW – Investigation-Derived Waste

Note: All Helios/Tetra Tech Joint Venture

(Helios/TT JV) staff have communication access to the HSM and QAM at all times, especially if health and safety or quality incidents adverse to personnel safety or work performance are identified.

http://www.epa.gov/fedfac/pdf/ufp_qapp_v1_0305.pdf#page=47

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2.0 Communication Pathways

(UFP-QAPP Manual Section 2.4.2 – Worksheet #6)

Communication Drivers Responsible Entity Name Phone Number Procedure

(Timing, Pathway To/From, etc.)

Draft Sampling and Analysis Plan (SAP) Review/Revisions

Helios/TT JV PM

Naval Facilities Engineering Command

(NAVFAC) RPM

NAVFAC QAO/Chemist

Michael Horton

Cecilia Landin

TBD

603-328-1463

757-341-2014

TBD

Within 2 days of completing the draft SAP, the SAP will be submitted to NIRIS by the Helios/TT JV PM.

NAVFAC QAO/Chemist comments will be resolved to the satisfaction of the QAO/Chemist and the SAP will be uploaded to NIRIS for QAO/Chemist signature.

Regulatory Agency Interface NAVFAC RPM Cecilia Landin 757-341-2014

When due according to the project schedule the draft SAP will be submitted to the regulators by the NAVFAC RPM or designee. NAVFAC RPM will interface directly, via phone or via email with regulators as needed.

Request for Utility Clearance/Permit

Helios/TT JV FOL Dan Griben 603-328-1475

The FOL will submit a request for a utility clearance/permit with appropriate supporting documentation to Dig Safe and NAVSTA Newport a minimum of 14 days before intrusive activities are planned to be conducted.

Preparation for Sampling Helios/TT JV PM Laboratory PM

Michael Horton Heather Manz

603-328-1463 207-87-2400

At a time that ensures sample bottles will be available on site early enough to collect samples, the Helios/TT JV PM will contact the laboratory PM via email or teleconference to order bottles. The Helios/TT JV PM or project chemist will maintain weekly contact with the laboratory throughout the project to ensure project goals, including changes to laboratory-specific limits, are acceptable prior to and during the analyses.

Field Progress Reports Helios/TT JV FOL Helios/TT JV PM

Dan Griben Michael Horton

603-328-1475 603-328-1463

The Helios/TT JV FOL will provide email or verbal reports to the Helios/TT JV PM on a schedule arranged by the PM.

Stop Work Due to Safety Issues

Helios/TT JV FOL Helios/TT JV PM

NAVFAC RPM

Site POC Subcontractor PM

Dan Griben Michael Horton Cecilia Landin

Deb Moore Marine Transport (TBD)

603-328-1475 603-328-1463 757-341-2014 401-841-1790

TBD

If Helios/TT JV is the responsible party for a stop work command, the Helios/TT JV FOL will inform on-site personnel, subcontractor(s), the NAVFAC RPM and Site POC, and the identified Project Team members within 1 hour (verbally or by e-mail).

If a subcontractor is the responsible party, the subcontractor PM must inform the Helios/TT JV FOL within 15 minutes, and the Helios/TT JV FOL will then follow the procedure described above.

http://www.epa.gov/quality/qs-docs/g4-final.pdf#page=47

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Communication Drivers Responsible Entity Name Phone Number Procedure

(Timing, Pathway To/From, etc.)

SAP Changes Prior to Field/ Laboratory Work

Helios/TT JV FOL Helios/TT JV PM

NAVFAC RPM

Site POC

NAVFAC QAO

Dan Griben Michael Horton Cecilia Landin

Deb Moore

TBD

603-328-1475 603-328-1463 757-341-2014 401-841-1790

TBD

The Helios/TT JV PM will document the required change via a Field Task Modification Request (FTMR) form within 5 days and send it to the NAVFAC PRM and Site POC. If necessary, the PM will submit a concurrence letter on a schedule agreeable to the

NAVFAC RPM.

SAP amendments will be submitted by the Helios/TT JV PM to the NAVFAC RPM and Site POC for review and approval. At the RPM’s discretion, SAP changes will be submitted to the NAVFAC QAO for approval (e.g., when significant Data Quality Objective [DQO]-related changes occur, or the laboratory is changed).

The Helios/TT JV PM will communicate scope changes to the Project Team via e-mail within 1 business day.

SAP Changes in the Field

Helios/TT JV FOL Helios/TT JV PM

NAVFAC RPM

Site POC

Dan Griben Michael Horton Cecilia Landin

Deb Moore

603-328-1475 603-328-1463 757-341-2014 401-841-1790

The Helios/TT JV FOL will verbally inform the Helios/TT JV PM within 24 hours of realizing the need for a change.

The Helios/TT JV PM will document the change via a FTMR form within 5 days and send it to the NAVFAC RPM and Site POC. If necessary, a concurrence letter will be submitted within 7 days of identifying the need for change. The NAVFAC RPM will establish the required level of review. At the RPM’s discretion, SAP changes will be submitted to the NAVFAC QAO for approval (e.g., when significant changes are made to DQOs).

Field Corrective Actions in Response to Unusual Field Conditions or Conditions Otherwise Adverse to Quality (e.g., sample representativeness, comparability or other quality concerns)

Helios/TT JV FOL Helios/TT JV PM

NAVFAC RPM

Site POC NAVFAC QAO/Chemist

Dan Griben Michael Horton Cecilia Landin

Deb Moore

TBD

603-328-1475 603-328-1463 757-341-2014 401-841-1790

TBD

The FOL will alert the Helios/TT JV PM verbally of the condition adverse to quality as soon as it is safe to do so.

The Helios/TT JV PM and FOL will immediately develop appropriate corrective actions to preserve quality. This may require consult with other Helios/TT JV technical staff (such as the Project Chemist) or subcontractor PM.

If an appropriate action cannot be developed quickly or upon developing an appropriate action, the Helios/TT JV PM will notify the NAVFAC RPM verbally or via email and, at the RPM’s discretion, other NAVFAC personnel such as the Site POC or NAVFAC QAO/Chemist. Upon agreement between the Helios/TT JV PM and NAVFAC RPM regarding appropriate corrective actions, significant deviations from this SAP (if any) will be documented in the field logbook and on an FTMR form.

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Communication Drivers Responsible Entity Name Phone Number Procedure

(Timing, Pathway To/From, etc.)

Sample Receipt Variances

Laboratory Sample Custodian

Helios/TT JV FOL

Helios/TT JV Project Chemist

Helios/TT JV PM

NAVFAC RPM

Various

Dan Griben

Kelly Carper

Michael Horton Cecilia Landin

Various

603-328-1475

412-921-7273

603-328-1463

757-341-2014

The Laboratory Sample Custodian will report variances to the Helios/TT JV FOL, Helios/TT JV Project Chemist, or PM verbally or via email within 24 hours of identifying a variance and those individuals will attempt to resolve the variance with the laboratory. If the variance cannot be resolved, the Helios/TT JV PM will notify the NAVFAC RPM verbally or via email within 1 business day of the variances being brought to his attention. If necessary, the NAVFAC RPM will take corrective action commensurate with the deficiency.

Laboratory Quality Variances

Laboratory PM

Helios/TT JV Project Chemist

Helios/TT JV PM

Data Validators

NAVFAC RPM

NAVFAC QAO/Chemist

Heather Manz

Kelly Carper

Michael Horton

Various

Cecilia Landin

TBD

207-874-2400

412-921-7273

603-328-1463

Various

757-341-2014

TBD

The Laboratory PM will notify (verbally or via e-mail) the Helios/TT JV Project Chemist within 1 business day of when an issue related to laboratory data is discovered.

The Helios/TT JV Project Chemist will notify (verbally or via e-mail) the data validation (DV) staff and Helios/TT JV PM within 1 business day. The Laboratory PM will document all quality variances in the Case Narrative of the Analytical Laboratory Report. Corrective actions may include a consult with the RPM and, at the RPM’s discretion, with the NAVFAC QAO/Chemist.

Analytical Corrective Actions

Laboratory PM Helios/TT JV FOL Project Chemist Helios/TT JV PM

NAVFAC RPM

NAVFAC QAO/Chemist

Heather Manz Dan Griben Kelly Carper

Michael Horton Cecilia Landin

TBD

207-874-2400 603-328-1475 412-921-7273 603-328-1463 757-341-2014

TBD

If the impact of an identified deficiency is limited to this project, it will be resolved between the laboratory PM and Helios/TT JV PM and support staff and will be documented in the project report. If the deficiency is systemic and potentially affects other projects, the Helios/TT JV PM will verbally advise the NAVFAC RPM within 24 hours of notification from the Project Chemist or DVM. The NAVFAC RPM will take corrective action appropriate for the identified deficiency. Corrective actions may include a consult with the NAVFAC QAO/Chemist and coordination with the laboratory.

Reporting DV Issues

Helios/TT JV DV Chemist

Helios/TT JV Project Chemist

Helios/TT JV PM

NAVFAC RPM

Various

Kelly Carper

Michael Horton Cecilia Landin

Various

412-921-7273

603-328-1463 757-341-2014

Helios/TT JV DV Chemist will document data qualifications in the DV report and database. For serious deficiencies the DV Chemist will notify Helios/TT JV Project Chemist or PM verbally or via e-mail within 48 hours of recognizing that a significant laboratory quality deficiency has been detected that could affect this project and/or other projects. The Helios/TT JV PM will relay information regarding serious data concerns or laboratory concerns to the NAVFAC

RPM.

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Communication Drivers Responsible Entity Name Phone Number Procedure

(Timing, Pathway To/From, etc.)

DV Corrective Actions

Helios/TT JV DV Chemist

Helios/TT JV Project Chemist

Helios/TT JV PM

NAVFAC RPM

NAVFAC QAO/Chemist

Various

Kelly Carper

Michael Horton

Cecilia Landin

TBD

Various

412-921-7273

603-328-1463

757-341-2014

TBD

If a DV issue cannot be resolved between the Helios/TT JV DV Chemist and the laboratory or if the issue appears to be systemic, the Helios/TT JV validation chemist will alert, verbally or via email, the Helios/TT JV PM who will verbally advise the NAVFAC RPM within 24 hours of notification. The NAVFAC RPM will take corrective action that is appropriate for the identified deficiency. This may include a consultation with the NAVFAC QAO/Chemist.

Project Report Review

Helios/TT JV PM

Helios/TT JV support staff

NAVFAC RPM

Michael Horton

Various

Cecilia Landin

603-328-1463

Various

757-341-2014

Internal reviews will be conducted by the Helios/TT JV PM and support staff. Comments will be resolved internally to the satisfaction of the Helios/TT JV PM.

When satisfied with resolution of all comments, the report will be submitted by the Helios/TT JV PM or designee to the NAVFAC RPM in accordance with the project scope of work requirements. Upon resolution of NAVFAC comments, the report will be submitted to the NAVFAC RPM for transmittal to the regulators for review. Comments will be resolved to the satisfaction of the NAVFAC RPM, revisions will be made, and the report will be finalized for final distribution and submittal to NIRIS.

Identification of Systemic Quality Deficiencies on the Project

Helios/TT JV PM

Helios/TT JV support staff

Helios/TT JV QAM

Michael Horton

Various

Tom Johnston

603-328-1463

Various

412-921-8615

The person identifying the concern will communicate to the Helios/TT JV PM and QAM in a timeframe that supports correction of the concern as soon as practicable and sharing of "Lessons Learned" to prevent propagation of deficiencies.

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3.0 Project Planning Session Participants Sheet

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

Project Name: Groundwater LTM Site Name: Site 17, Former Building 32, Gould Island

Projected Date(s) of Sampling:

Bi-annually (March/April and September/October) Site Location: Jamestown, Rhode Island

Project Manager: Michael Horton

Date of Session: September/October 2019

Scoping Session Purpose:

Optimization of Long-Term Groundwater Monitoring at Site 17

Name Title Affiliation Phone # E-mail Address Project Role

Cecilia Landin RPM NAVFAC Mid-Lant 757-341-2014 cecilia.landin@navy.mil Navy

Manager

Kymberlee Keckler RPM Environmental

Protection Agency

(EPA)

617-918-1385 kymberlee.keckler@epa.gov

EPA

Manager

Greg Kemp EPA Consultant Mabbett 603-625-9116 kemp@mabbett.com

EPA

Consultant

Shawn Lowry RPM

Rhode Island Department of Environmental Management

(RIDEM)

401-222-2797 shawn.lowry@ri.dem.gov

RIDEM

Manager

Deborah Moore NAVSTA Newport POC NAVSTA Newport 401-841-1790 deborah.j.moore@navy.mil Facility POC

Michael Horton Project Manager Helios/TT JV 603-328-1467 mike.horton@tetratech.com Helios/TT JV

Manager

Stephen Parker Activity Coordinator Tetra Tech 603-328-1469 stephen.parker@tetratech.com Project Support

Laurel Boucher Facilitator The Management

Edge 703-407-1030 lboucher@up.net

Meeting Moderator

Comments/Decisions:

After completing the initial eight sampling events the project team agreed to meet for the purpose of discussing optimization of the Site 17 groundwater LTM. The Navy initially proposed the following optimizations:

• Reduce the frequency of monitoring to two times per year (March and September).

• Eliminate analysis of volatile organic compounds (VOCs).

• Eliminate analysis of pentachlorophenol (PCP).

http://www.epa.gov/fedfac/pdf/ufp_qapp_v1_0305.pdf#page=51

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• Eliminate analysis of polycyclic aromatic hydrocarbons (PAHs) from all wells where PAH exceedances of clean-up goals have not been reported during the first eight events and analyze samples at other wells only for the PAHs that have exceeded clean-up goals during the first eight monitoring events.

▪ Eliminate analysis of polychlorinated biphenyls (PCBs) from all wells where PCBs have not been detected during the first eight events.

• Continue analyzing samples collected from all wells included in the monitoring program for total and dissolved metals, anions, and alkalinity.

EPA formally responded to these proposals with the following:

• PAHs – EPA recommends that all PAHs that can reasonably contribute to drinking water risk be included in the optimization plan and analyzed in all wells. Based on EPA Regional Screening Level (RSL) values, these PAHs include benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenzo(a,h)anthracene, indeno(1,2,3-CD)pyrene, and naphthalene.

• PCP – Since PCP contributes to be a drinking water risk and the detections were an order of magnitude greater than the RSL (the 10-6 RSL is 0.041 ug/L), PCP should remain an analyte for all wells.

• Aroclor PCBs - EPA recommends that sampling for PCBs continue at wells where PCBs have been detected. This includes the seven wells that the Navy identified in Worksheet 18 plus MW303B where PCBs were also detected. Although PCBs were not detected at MW300B, EPA recommends that it be retained because it is proximate to the former transformer vault 53 where PCB releases occurred. (The greatest PCB detection to date, 1.5 µg/L, occurred at MW406, proximate to former transformer vault 54.)

• VOCs – EPA recommends continued sampling for trichloroethylene and vinyl chloride at wells MW304SR, 401, and 405 where TCE has consistently been detected at concentrations near the EPA Drinking Water Maximum Contaminant Level (MCL).

• Metals – EPA concurs with sampling all wells for arsenic, cadmium, lead, and manganese as well as anions and alkalinity.

• Semi-annual monitoring as proposed by the Navy is appropriate after the completion of the Year 2 monitoring event.

As of the date of this SAP RIDEM has not provided input regarding optimization of the Site 17 Groundwater LTM plan.

Consensus Decisions:

For the purpose of continuing to perform long-term monitoring (LTM) activities at Site 17, the Navy has prepared this SAP to implement bi-annual groundwater monitoring. The analytical requirements for groundwater samples have not been updated based on the optimization proposals presented here because project team consensus has not been reached; the Navy intends to continue monitoring for the full analytical suite at all monitoring locations until the project team agrees that adjustments are appropriate. When/if adjustments are made to the analytical suite, updates to this SAP will be made with FTMRs.

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4.0 Conceptual Site Model

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

Overview

The NAVSTA Newport facility encompasses approximately 1,400 acres on the west shore of Aquidneck

Island facing the East Passage of Narragansett Bay and is located primarily in the towns of Portsmouth, Middletown, Jamestown, and Newport, Rhode Island. Environmental Restoration Program (ERP) Site 17 is located on Gould Island, in Jamestown, Rhode Island. Gould Island is located in the East Passage of

Narragansett Bay, approximately 1.5 miles west of Newport, Rhode Island, between Aquidneck and

Conanicut (not shown on Figure 4-1) Islands. Former Building 32, located on the northeastern end of Gould

Island, occupied approximately 6 acres of land, not including the firing pier and former Building 35 to the north. Site 17 encompasses this 6-acre area around former Building 32, including the soil and groundwater and approximately 1 acre of marine sediment adjacent to the northern shoreline where contaminants from the former Building 32 and its operation have come to reside. The location of Gould Island within the

NAVSTA Newport facility is presented on Figure 4-1. The layout of Site 17 is included on Figure 4-2.

Gould Island is generally unoccupied, with the exception of Building 35. However, the surrounding waters are used for electronic equipment testing by Naval Undersea Warfare Center (NUWC), and the grounds of

Site 17 are intended for similar use. The Site is occasionally accessed by trespassers via recreational boating. At the northern end of Gould Island where Site 17 is located, the island consists of a constructed shoreline that is a combination of filled land, man-made structures, and natural island formations. These include the Firing Pier, a now demolished rigging platform (a timber dock), a piling field originally constructed to create a partial breakwater feature and support a pier platform, and constructed shoreline

(filled land behind bulkhead walls). The northeastern and northwestern intertidal shorelines of the Site are exposed and subject to wave action. The entire northeastern shoreline consists of a deteriorated sheet-piling bulkhead wall and a stony beach face. The entire northwestern shoreline is composed of riprap.

Two reference documents are available that best describe the operational history, physical characteristics, and other key elements of the conceptual site model (CSM): the Record of Decision (ROD) for Site 17 –

Former Building 32 Gould Island, Operable Unit 06, Jamestown, Rhode Island, Naval Station Newport, Rhode Island (NAVFAC, 2014); and the Feasibility Study for Site 17 – Former Building 32, Gould Island, Naval Station Newport, Newport, Rhode Island (Tetra Tech, 2014). These two reference documents provide most of the background information presented in this Section.

Operational History and Current Use

Building 32 was a Navy torpedo overhaul shop from the 1940s until it ceased major operations in the 1950s.

During that time, torpedoes were brought to the overhaul shop for dismantling, cleaning, and reassembly.

Operations within Building 32 included degreasing, parts washing, electroplating, sandblasting, mechanical and electrical testing, etc. Peripheral to Building 32, but featuring in the environmental investigations were

Building 33 (a steam plant); Building 34 (a small building for generating acetylene); Building 44 (a fuel pump house and associated underground fuel tanks); Building 41 (a storage shed); and a series of five small transformer buildings – Buildings 53, 54, 56, 58, and 60. All these former buildings are within the footprint of the Site 17 boundary. Minor structures that featured in the environmental releases were an acid storage shed and dust storage equipment associated with indoor sandblasting operations. Other storage sheds and http://www.epa.gov/fedfac/pdf/ufp_qapp_v1_0305.pdf#page=55

Jamestown, Rhode Island Revision Date: July 2020

S-112-20-152D Page 14 of 70 structures (administration building, guard shacks, etc.) were also present within the Site 17 boundary (all have been removed) and are not pertinent to the environmental conditions at the Site.

Groundwater at the Site is not currently being used for potable use, and there are no drinking water wells present at or within the immediate vicinity of the Site. Groundwater beneath Site 17 is classified as GA by the State of Rhode Island.

In 2016, the soil remedy (“source control measure”) as described in the ROD took place. The remedy consisted of removal and offsite disposal of sump debris from Former Building 32 foundation sumps, and excavation and offsite disposal of impacted vadose zone soils from identified impact areas. These actions not only mitigated risk from contact with contaminants of concern (COCs) in surface soils and sump debris, but also acted as a “source control measure” for shallow groundwater.

Summary of Topography, Geology, and Hydrogeology

During development of Gould Island in the 1940s, the Site was altered by cut-and-fill operations, cutting the natural soil from the hillside at the southern end of the Site and filling the sub-tidal waters to the north to create a level area large enough to construct Building 32 and its support systems. As a result, the northern portion of the Site contains fill comprised primarily of disturbed native soils from the area, consisting of a mix of silty sand and gravel. The thickness of the fill ranges from about 6 to 12 feet, with greater thicknesses at the northern end of the Site. Portions of the Site are underlain by glacial till consisting of silt, sand, and gravel. The till unit has not been encountered at the southern end of the Site but was encountered during drilling at thicknesses of up to 74 feet at the northern end of the Site beneath the fill. Bedrock underlying the Site is characterized as metamorphosed sedimentary rock, predominantly phyllite. This rock was found to be weathered in the upper 3 to 18 feet. As a result of the softness of the weathered zone, the transition from overburden to bedrock has not been clearly defined at the northwestern end of the Site where the depth to rock is greater than 30 feet. At the eastern shoreline of the island (and south of the Site), the overburden is very thin or nonexistent; the bedrock is exposed in places and is eroding due to wave action, forming a shingle-style beach face.

Although it has not been specifically assessed, local tidal cycles are expected to have an impact on local groundwater elevations and flows. In general, overburden groundwater flow at Site 17 radiates towards the north, east, and west, generally away from the island interior, following topography. Bedrock groundwater has been observed to flow towards the north and east, but a lack of bedrock wells along the western side of Site 17 likely skews the interpretation toward the north and east. Groundwater contours from the

September 2019 LTM event are depicted on Figure 4-2. Bedrock groundwater has not been adequately characterized with respect to flow pattern, although it is expected to behave in a similar manner as overburden groundwater.

Conceptual Site Model Summary

Historical investigations and long-term groundwater monitoring performed by, or on behalf of the Navy, at

Site 17 have indicated that presumed releases from various industrial processes related to the Site’s former torpedo overhaul operations have resulted in the presence of contaminants in soil and groundwater in specific areas of the Site and in nearby marine sediments, primarily in Stillwater Area sediments in the vicinity of the now demolished rigging platform. COCs were identified in the Remedial Investigation (RI) and

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S-112-20-152D Page 15 of 70 associated risk assessments. COCs for surface soil (0 to 2 feet below ground surface [bgs]) and subsurface soil (greater than 2 feet bgs or below a foundation) are: select semivolatile organic compounds (SVOCs), PCBs (total Aroclors), arsenic, cadmium, lead, and manganese. COCs for groundwater are: select PAHs, pentachlorophenol (PCP), benzene, trichloroethylene (TCE), tetrachloroethene (PCE), PCBs (total

Aroclors), arsenic, and manganese. COCs for sediment are: total PAHs, total PCBs, arsenic, cadmium, chromium, copper, lead, nickel, and zinc.

PCBs were released at previous transformer areas, and although the bulk of contaminated soil and sump debris has been removed, residual concentrations of PCBs appear to have intermingled with other contaminants in marine sediment. PAHs were found in sump debris and soil within and around the former

Building 32 footprint, where drains and/or overland runoff also carried them to nearby marine sediments.

Sediments in limited areas at the northeast shoreline, generally near some of the outfall pipes, have been found to contain PCBs, PAHs, and metals at lower concentrations than those detected in Stillwater Area sediments. These chemicals at the Northeast Shoreline are most likely a result of discharges from pipes that drained waste from specific building operations when the Site was active.

The SVOC PCP was found in building sump debris as well as groundwater. The MCL for PCP was exceeded during RI investigations at one groundwater sample location, only. During the RI, PCE was also detected in groundwater at a concentration exceeding the MCL at only one location, near a former parts shop in former Building 32, indicating possible use and release of cleaning solvents. PCP was not detected at concentrations exceeding the MCL in groundwater samples collected during the first two years of groundwater LTM.

Metals used and metal contaminants produced through electroplating and sandblasting operations in the southwestern corner of the former Building 32 appear to have been released to nearby sediments via building and roadway drainage systems. Manganese, a naturally occurring element in soil and rock, is present at elevated concentrations (above the EPA drinking water health advisory) in the groundwater across the Site.

Contaminants such as PCBs and PAHs are highly persistent and when released to the environment and are likely to remain adsorbed to the soil or sediment matrix, bound to particulate matter. As a result, these contaminants tend to migrate from source areas via bulk movement processes (e.g., transported as particles in surface water runoff or in wind erosion of soil). If leaching from soil to groundwater occurs, any migration that may take place is usually over relatively short distances. For these compounds, biodegradation is possible but is likely to be slow.

Metals are also persistent in the environment, and many metals such as cadmium and lead tend to adsorb strongly to soil particles or colloids, especially when the soil is of high organic content, and become more soluble under reducing conditions. Arsenic and manganese, however, are examples of metals that are generally more mobile. Soluble metals may be leached from native or contaminated soil to groundwater by infiltration of precipitation and through the seasonal rise and fall of the water table. Once dissolved in groundwater, metals will travel with groundwater flow. As groundwater migrates, some of the metals will undergo transformation processes that result in their return to an insoluble state. Oxidation-reduction reactions, precipitation, and adsorption reactions can cause the dissolved phase ions to leave the aqueous phase. The required timeframe for manganese to attenuate to concentrations in groundwater below cleanup goals is currently estimated at between 17 and 51 years for overburden, and between 23 and 69 years for

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S-112-20-152D Page 16 of 70 bedrock; this is based on a predicted rate for three volumes of groundwater to fully flow through the saturated zone at the Site. The predicted rate was calculated with groundwater flow data collected from select LTM program wells during the September 2018 LTM event; details are presented in the Draft Year

2, LTM Report (Tetra Tech, 2020).

During the RI, PCE and PCP were present in water-table overburden groundwater near the shoreline and were not found in deep overburden or bedrock groundwater at the Site. Given their location and concentration, it is likely that these COCs would flow with groundwater to discharge into the ocean to the east. Surface water samples were not collected from Narragansett Bay as part of the investigations because the tidal nature of the bay and the extremely large mixing zone associated with tidal waters limits confidence that data would have been representative of site related contamination. As a conservative measure, the groundwater data were evaluated in the Baseline Ecological Risk Assessment (ERA) to determine potential risks to marine organisms after groundwater discharges to surface water. Groundwater results from the first two years of groundwater LTM indicate that natural attenuation of PCE and PCP to concentrations less than clean-up levels has already occurred because there have been no exceedances of PALs during the first eight LTM events.

A ROD which presents and describes the remedy for soil, sediment, and groundwater at Site 17 was signed on June 27, 2014. The selected remedies were removal of sediment, removal of soil and debris (completed

2016), implementation of land use controls (LUCs), monitored natural attenuation (MNA), long-term groundwater monitoring, limited sediment monitoring, and annual inspections and reporting.

This SAP pertains only to the MNA and LTM of groundwater required by the ROD.

The following receptors and exposure pathways were identified in the ROD:

• Future construction workers by exposure from direct contact/incidental ingestion of shallow groundwater, and from inhalation of associated trench air, primarily due to concentrations of

SVOCs, including PAHs and pentachlorophenol, and PCBs.

• Adults and children consuming shellfish at a subsistence or recreational level, primarily due to concentrations of PCBs and PAHs in shellfish (mussels and clams).

• Exceedances of regulatory criteria in the screening assessment indicated a potential risk to hypothetical future residents from exposure to soil and groundwater.

• Ecological receptors from exposure to arsenic, chromium, copper, lead, nickel, zinc, PAHs, and

PCBs in sediment

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CSM Wire Diagram – Based on risk identified during the RI and described in the ROD. Although sediment and shellfish are presented here as potential exposure medium, this SAP is specific to the groundwater and soil remedies as presented in the ROD.

X – complete exposure pathway o – incomplete exposure pathway

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5.0 Data Quality Objectives/Systematic Planning Process Statements

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

5.1 Problem Statement

This monitoring effort is necessary to comply with the groundwater remedy described in the ROD. The remedy includes monitoring concentrations of PCP, PCE, manganese, and natural attenuation parameters in groundwater to support evaluation of MNA; and monitoring concentrations of both soil and groundwater

COCs in groundwater to document whether they are present at concentrations exceeding cleanup goals.

Based on the problem statement, the specific study goals of the planned monitoring are listed:

• Goal 1 – Evaluate concentrations of PCP, PCE, and manganese in groundwater and monitor natural attenuation parameters to monitor natural attenuation of these COCs and ensure that the

MNA remedy as stated in the ROD is appropriate.

• Goal 2 – Evaluate concentrations of soil and groundwater COCs in groundwater to identify potential data trends. Monitoring for both the soil and groundwater COCs in groundwater will allow for comparisons to be made regarding chemicals detected in groundwater and whether they are related to Site operations.

5.2 Information Inputs

Information inputs required to resolve the problem statement are:

• Groundwater sample analytical results for soil and groundwater COCs.

• Filtered and unfiltered metals analytical results.

• Analytical results for MNA parameters (anions, alkalinity, dissolved oxygen (DO), oxidation-reduction potential (ORP), conductivity, and pH) to evaluate conditions for natural attenuation.

• Field parameter measurements (pH, DO, ORP, temperature, turbidity, and conductivity) to evaluate well stabilization conditions prior to sampling and natural attenuation.

• Static groundwater gauging data to establish groundwater elevations at the time of the field events.

• Project Action Levels (PALs) that are based on federal and state promulgated risk-based criteria and are presented in Section 9, which will be used to evaluate data through comparison with measured analyte concentrations.

To conduct comparisons of Site data to PALs, the selected laboratory should have Limits of Quantitation

(LOQs) that are low enough to measure constituent concentrations that are less than the PALs. Analytical data reported by the laboratory must use the following reporting conventions: All results less than the

Detection Limit (DL) will be considered non-detects; positive results reported at concentrations between the

DL and LOQ will be reported with a “J” qualifier; and analytes not found (not detected) in a sample will be reported at the Limit of Detection (LOD) with a "U" qualifier. If the PAL is less than the DL or LOQ such results will be discussed in the uncertainty portion of the report. To remain consistent with previous LTM events EPA stage 2A data validation is needed on 100 percent of the data.

5.3 Boundaries of the Study

Site 17 encompasses the 6-acre area around former Building 32, including the soil and groundwater and approximately 1 acre of marine sediment adjacent to the northern shoreline where contaminants from the http://www.epa.gov/fedfac/pdf/ufp_qapp_v1_0305.pdf#page=56

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S-112-20-152D Page 19 of 70 former Building 32 and its operation have come to reside. The focus of this SAP is groundwater in bedrock and overburden. General spatial and temporal boundaries are described below.

Spatial Boundaries

The population of interest for this investigation is shallow groundwater potentially impacted by COCs within the 6-acre Site but also includes the groundwater upgradient of the Site where background monitoring wells are located.

Evaluation of LTM concentration trends to evaluate natural attenuation progress must be made for individual wells, but for estimating extent of contamination and other potential uses, the collection of data across a larger number of Site wells may be appropriate and will be dictated by context.

Temporal Boundaries

The LTM program is expected to extend for the foreseeable future; therefore this 2020 SAP is designed to support LTM for the foreseeable future with minor changes made with FTMRs. The types of modifications anticipated are adjustments to the sampling frequency, installation of new wells and COCs, or removal of existing wells and COCs from the program, etc. The modifications will be based on qualitative analysis of each year’s data.

Biannual sampling and groundwater COC analyses are required for the foreseeable future. Synoptic water level gauging events (described in Section 8) must be performed within one hour to limit influence from tides.

5.4 Analytic Approach

The analytic approach for the planned monitoring is comprised of a series of “if… then…else…” statements.

In each case, it is assumed that regulators will be involved in the decision making as part of the project team.

Goal 1 – Evaluate concentrations of PCP, PCE, and manganese in groundwater and monitor natural attenuation parameters to determine if natural attenuation of these COCs is an effective remedy as stated in the ROD and if natural attenuation conditions exist at the Site. Additionally, although daughter products of PCE (including vinyl chloride [VC] and 1,2-dichloroethene [1,2-DCE]) are not identified as COCs in the

ROD, as part of monitoring natural attenuation, their concentrations must be monitored as part of the MNA process.

Decision Rule Number 1 (applied to each well for the COCs PCE, PCP, and manganese annually):

If the measured groundwater concentrations of PCE, PCP, and manganese have all decreased to less than PALs in any well for two full years of monitoring, and if visual inspection of data trends indicate that such concentrations are not increasing, recommend cessation of monitoring for these parameters and MNA parameters in that well; otherwise, convene the project team to evaluate whether MNA parameters and COC concentration trends support natural attenuation of these

COCs and develop a path forward that is protective of human health and the environment.

Note: Indications of viable natural attenuation include decreasing COC concentration trends and

MNA parameter concentrations that support biodegradation of these three COCs as described in the Use of Monitored Natural Attenuation at Superfund, Resource Conservation and Recovery Act

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(RCRA) Corrective Action, and Underground Storage Tank Sites; US EPA Office of Solid Waste and Emergency Response Directive 9200.4-17P (EPA, 1999).

Goal 2 – Evaluate concentrations of soil and groundwater COCs (VOCs excluding PCE, SVOCs excluding

PCP, PCBs, and metals excluding manganese) in groundwater to identify potential data trends. Soil sampling is not required to support this goal.

Decision Rule Number 2 (applied to each well for VOCs excluding PCE; SVOCs excluding PCP;

PCBs; and metals excluding manganese after 8 rounds of sampling):

If the measured concentrations of any COC is less than its PAL in any well for two full years of monitoring, and visual inspection of the LTM data does not indicate that that COC concentration is increasing; or if any COC concentration exceeds its PAL but appears to be decreasing toward the

PAL in the selected well, then evaluate the option to cease monitoring for that parameter in accordance with Navy optimization guidance (DoN, 2010); otherwise review project objectives against the observed spatial and temporal concentration patterns to develop a strategy that continues to be protective of human health and the environment with regard to groundwater contamination.

5.5 Performance Criteria

Potential Sources of Error

Potential sources of error in the investigation may be divided into two main categories: sampling errors and measurement errors. A sampling error can occur when the sampling design, planning, and implementation do not provide for a representative range of heterogeneity at the Site. A measurement error can occur when performance variance from laboratory instrumentation, analytical methods, and/or operator error occurs.

EPA identifies the combination of these errors as a “total study error” (EPA, 2006). One objective of the planned investigation is to reduce the total study error so that decision-makers can be confident that the data collected accurately represent the chemical characteristics of the Site.

Managing Decision Error

The investigation will utilize decision-error minimization techniques in sampling design, sampling methodologies, and laboratory measurement of compounds of interest. Possible decision errors will be minimized during the field investigation by using the following methods:

• Use standard field sampling methodologies (as discussed in Sections 8.2 and 8.3). Perform sampling activities in accordance with the standard operating procedures (SOPs) referenced in this

SAP. Tetra Tech SOPs are included in Appendix A.

• Use applicable analytical methods (discussed in Section 10) for sample analysis by a competent analytical laboratory certified by the DoD Environmental Laboratory Accreditation Program (ELAP) to reduce measurement errors.

• Confirm analytical data to identify and control potential laboratory error and sampling error by using spikes, blanks, and replicated samples.

• For analytical results that do not achieve desired project action limits (PALs), include a discussion of alternate information inputs as part of the assessment conclusions and uncertainty analysis. The

PAL represents the limits of detection that analytical data must meet in order to be of sufficient

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Decision errors associated with judgmental sampling are based on sample design and measurement errors. Assuming that the best possible professional judgment was used to develop the sampling plan (e.g., position sampling locations), the most important decision errors will be associated with field and laboratory techniques involved in the collection and analysis of the data.

Sampling Methods and Procedures

Possible decision errors generated by sampling errors will be minimized during the field investigation by applying standardized field sampling and field measurement methodologies (to be discussed in Sections

6, 7, and 8).

Field Data Collection Methods and Procedures

Possible decision errors generated by data collection errors will be minimized during the field investigation by applying standardized field measurement methodologies (to be discussed in Sections 6, 7, and 8).

Laboratory Measurement of Compounds of Interest

Possible decision errors generated by laboratory measurement errors will be minimized by using applicable analytical methods (to be discussed Section 10) for sample analysis by a competent analytical laboratory evaluated and certified by the DoD ELAP.

Managing Laboratory Sampling Error

Control of potential laboratory error and sampling error will be minimized by using spikes, blanks, and duplicates. Sampling error may be introduced when the laboratory chemist selects a single portion of the field sample for laboratory analysis.

5.6 Plan for Obtaining Data

The selected sampling design is a biased design that make use…